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Comments to CEQ on Carbon Capture, Utilization, and Sequestration Guidance

The White House Council on Environmental Quality (CEQ) recently released interim guidance on Carbon Capture, Utilization, and Sequestration (CCUS) to assist federal agencies with regulation, permitting, and associated activities. We filed comments urging CEQ to update the guidance document with additional targeted recommendations for agencies. Our comments offer the following suggestions:

  • CEQ should encourage agencies to develop more transparent monitoring, reporting and verification (MRV) programs. This will help build public confidence in the effectiveness and safety of CCUS, avoid possible fraud, and enable vast improvements in carbon offset and removal regimes that play crucial roles in some states’ net-zero-greenhouse gas laws and many companies’ climate strategies. MRV systems should be externally verifiable to the extent possible, and agencies should analyze MRV technology gaps and stimulate the development of useful technologies.
  • CEQ should advise agencies to focus their resources primarily on CCUS activities and projects with the greatest expected net benefits, such as prioritizing carbon dioxide removal over approaches that entail greater lifecycle emissions or local environmental impacts. CEQ’s guidance should encourage agencies to clearly differentiate between direct air capture (DAC), point-source capture, and other categories of CCUS in both their prioritization decisions and their public communications.
  • CEQ should encourage agencies to overtly prioritize community participation, environmental justice, and the generation of local net benefits in the creation of the four regional DAC hubs established by the Infrastructure Investment and Jobs Act.
  • CEQ should advise agencies to address discrepancies in lifecycle analysis burdens for CCUS tax credits offered under Section 45Q of the Internal Revenue Code. Currently, developers of carbon utilization projects face more burdensome requirements to receive 45Q tax credits than do developers of enhanced oil recovery projects. Agencies can provide resources to help remedy this discrepancy.