What DOE should consider as it makes decisions on Carbon Capture and Storage Demonstration Projects

By Jona Koka

Nearly $5 billion from the Department of Energy combined with the economic incentives in the Inflation Reduction Act represent the United States’ first major steps to building a domestic carbon management industry that supports our Paris commitments.

But funding is only one piece of the puzzle. For the government’s investment in carbon capture and storage, CCS, projects to produce advancements that are productive for the climate and communities, it should include key safeguards that protect both.

A Historic Investment in an Important Climate Change Tool

Secretary Granholm announced the Department of Energy’s $4.9 billion in funding for carbon capture and storage systems at the International Clean Energy and Mission Ministerial in September 2022. Part of the Bipartisan Infrastructure Law, the funding will support three programs focused on the demonstration and deployment of carbon dioxide capture systems, transport, and storage.

Currently, DOE is reviewing applications for these funding opportunities:

• Carbon Storage Validation and Testing will provide up to $2.25 billion for the development of large-scale commercial CO2 storage projects and associated infrastructure, with the capacity to store at least 50 million metric tons of CO2.
• The Carbon Capture Demonstration Projects Program will provide up to $2.54 billion to fund at least six commercial-scale carbon capture demonstration projects designed to further the development, deployment, and commercialization of technologies to capture and geologically store carbon emissions.
• Carbon Dioxide Transport, Engineering, and Design will provide up to $100 million to design regional CO2 pipeline networks to safely transport captured CO2 from key sources to centralized locations.

Carbon capture and storage, CCS, is not a substitute for aggressive efforts to reduce fossil fuel dependence and toxic industrial pollution. But experts like the International Panel on Climate Change and the International Energy Agency make clear there’s a critical role for these technologies in our global efforts to achieve the goals of the Paris Agreement. Secretary Granholm said that “nearly every climate model makes clear that we need to incorporate carbon management technology — especially in hard to decarbonize sectors and heavy industries such as steel and cement production — to tackle the climate crisis.”

Guidelines for CCS Projects.

CCS has the potential to be a valuable tool in our net-zero toolbox, but only if we handle its deployment correctly. This historic funding for carbon management gives DOE the opportunity to set the standard on what good CCS deployment looks like and help shape the future of this industry.

Because carbon capture, transport and storage projects are complex, projects should be assessed on a case-by-case basis to fully ensure just and responsible outcomes for both the environment and communities. That said, there are five key guidelines DOE should consider as it moves forward with the application process for these and future projects.

CCS Projects Should Demonstrate Safe and Secure Storage of Captured Carbon

A vital component of successful CCS implementation is the ability to demonstrate and verify that storage of captured carbon is secure and safe. This requires that project sites are shown to be selected, designed, operated, and monitored in a manner that creates confidence that leakage will be no more than 1% over 1,000 years, approximately 0.001% per year, a target the IPCC has concluded is achievable. Storage projects must also be designed and operated so that they do not cause water pollution or other ecological or local damage, such as through induced seismicity.  EDF has written more on safe and secure storage of carbon here and here.

Projects Should Be Transparent

Transparency is key to the success of CCS deployment. It is vital that all taxpayer funded CCS projects are properly permitted, including appropriate notice and comment periods, and are subject to publicly available reporting and verification processes for not only transparency, but also accuracy and accountability in carbon management accounting. Transparency will also foster improved public engagement and, potentially, trust in CCS technology and developers, allowing for more thorough and comprehensive dialogue and understanding between DOE, project operators, and potentially impacted communities and stakeholders.

Projects Should Include Genuine and Meaningful Public Engagement

Many communities have serious concerns and questions about CCS and DOE — as well as developers — should work to ensure that these projects meaningfully address these and other justice and equity considerations. Moving beyond “check-the-box” engagement to sincere, proactive work on the part of agencies and industries alike is long-overdue in terms of evolving from relying only on evaluation and consultation to pursuing results and actions that truly benefit communities burdened by industrial activities. New CCS projects should involve engagement and dialogue with communities, public health officials, and environmental justice leaders and should fully account for localized environmental impacts, equity concerns and safety risks. Project developers should also commit to real investments, actions, and project modifications designed to specifically address and proactively respond to voiced community concerns and collaborate with communities on making project improvements to address their needs.

DOE has made new progress on this front, as it will require applicants for these programs to implement a Community Benefits Plan that will detail their commitments to community and labor engagement, quality job creation, diversity and equity, and implementation of the Justice40 Initiative. It will be vital to ensure these plans are comprehensive, reviewed by impacted communities, and result in real impacts on the ground.

Operators Should Be Liable for their Mistakes 

Liability laws are designed to keep operators accountable when they or their subsidiaries fail to live up to their responsibilities. These rules not only encourage operators to do as good a job as technically feasible, but also provides assurance to communities that if something does go wrong the burden of liability does not fall on them.

However, some states have started to weaken their liability rules for operators of carbon sequestration and storage projects, often at the behest of large oil and gas companies. This trend is alarming, as it significantly threatens the integrity of these projects, their climate benefits, and their public acceptance. Thought leaders on this issue, such as DOE’s Brad Crabtree speaking at New York Climate Week in September of this year, have signaled that this type of liability exemption is generally unnecessary given that private insurance options are emerging, that knowledgeable developers are not worried about normal rules of liability given the safety record of the practice, and that pushing for exemptions sends a distracting and negative signal to the public.

With approximately $4.9 billion in upcoming funding, DOE should proceed very cautiously if at all when making funding available to projects in states that have weak liability laws for carbon sequestration and storage projects.

Projects Should Reduce Criteria Air and Other Pollutants where Feasible

In addition to reducing carbon dioxide pollution, CCS deployment could in many cases also reduce emissions of other kinds of pollution. Since major industrial carbon dioxide emitters are also usually major emitters of other criteria air pollutants, more should be done to understand how the technical processes for carbon capture could create co-benefits by also removing other air toxics, such as nitrogen oxides (NO_x) and sulfur dioxide (SO₂), protecting fenceline communities from increases in cumulative pollution and the negative health effects associated with them. Industrial facilities that utilize CCS technology also need to monitor emission of pollutants, as well partake in research to better understand what novel pollutants might be emitted from these facilities.