Carbon Capture Coalition Develops Guiding Principles to Improve the Permitting System for Carbon Management Infrastructure 

Unprecedented federal bipartisan investments in climate and energy policy under both the Bipartisan Infrastructure Law and the Inflation Reduction Act have catapulted carbon management technologies into the national spotlight. These significant investments in federal policy support for the full suite of carbon management technologies, including carbon capture, removal, reuse, transport, and storage, have set the stage to catalyze deployment of these climate-essential projects, but building out associated infrastructure will require efficient and effective permitting, grounded in robust environmental protections and community engagement. 

Reliable infrastructure to safely transport captured carbon dioxide (CO₂) to points of reuse or secure geologic storage is a fundamental component of any broader strategy to put America firmly on a path towards achieving net-zero emissions and enabling meeting midcentury climate goals. In fact, in its most recent Summary for Policymakers of the Sixth Assessment Synthesis Report, the Intergovernmental Panel on Climate Change (IPCC) reaffirms the central role that these technologies will play in capturing CO₂ from heavy industrial sectors, including cement, steel, refining, as well as directly removing excess carbon dioxide from the atmosphere.  

Carbon management projects are complex. Ensuring all pieces of a project come together – from capturing or removing CO₂ to eventual transport and storage or reuse – is necessary to scale deployment of these technologies across the economy. While the nation’s current permitting regime has been in place for decades, as this industry continues to expand in the near-term, gaps in policy for permitting these and other energy projects have created delays and bottlenecks at critical junctures of project deployment. Improvements to the current permitting system, along with targeted policy reforms, will be central to help facilitate the build-out of climate-essential projects and encourage private investment. 

The 117th Congress saw the most robust and holistic investments in climate and energy policy in the nation’s history, and the resulting increase in project announcements across the clean energy and industrial decarbonization spectrum underscores the fact that federal policy support will translate into tangible projects. However, many of the same lawmakers, project proponents, labor unions, and climate and energy policy organizations that supported these federal investments now recognize that the current pace of project permitting is insufficient to meet the urgency of this moment. This has prompted lawmakers at the federal level to discuss urgently needed improvements to the current project permitting system, in addition to targeted reforms.   

Subsequently, Members of Congress from both chambers and political parties, representing diverse regions of the nation, have been engaging in discussions to find a bipartisan path forward for ensuring energy projects can scale in this crucial deployment decade.  

With this in mind, a diverse cross-section of members of the Carbon Capture Coalition worked collaboratively over the course of 2023 to develop a set of six guiding principles for permitting focused on providing clarity, transparency and efficiency to catalyze the safe, effective and responsible deployment of carbon management projects. These principles are:   

• Ensure federal and state agencies have the resources, staffing, technology, and training to efficiently complete a growing number of reviews and community engagement processes as carbon management projects scale in deployment.   
• Ensure early, robust, meaningful, and timely public engagement and input from affected communities is reflected in decision making.   
• Ensure environmental standards and protections are maintained, and environmental outcomes are strengthened.   
• Direct agencies to appropriately use programmatic review and categorical exclusions for carbon management infrastructure.   
• Create a pathway for federal siting authority for interstate CO₂ pipelines, creating appropriate parity for all types of interstate linear infrastructure.    
• Ensure review of Class VI state primacy applications, as well as individual Class VI well applications, occur on a reasonable and predictable timeframe.   

These principles are meant to represent important considerations for responsible and successful project deployment and would further ensure the benefits associated with these projects flow to the communities that host these diverse projects and the workers that build them. These are not specific legislative proposals. And while these principles represent a consensus of the Coalition’s more than 100 members, which includes a unique cross-section of energy and industrial technology companies, labor unions, and environmental and conservation NGO’s, we recognize that both strengthening the current permitting system and providing targeted reforms to improve the system is complex and nuanced. Though the Coalition has not addressed the challenges of project permitting before explicitly, the themes and elements of the six guiding principles can be found throughout the Coalition’s foundational document, the 2023 Federal Policy Blueprint. 

With that context, it is essential that the supportive infrastructure, permitting and regulatory regime required to enable the growth of this industry are in place with the resources and staffing needed to execute these projects. Simply put, there is no time to waste in the responsible siting, permitting and operation of carbon management infrastructure nationwide. Significant deployment of carbon management technologies by 2030 is necessary, for meeting midcentury net zero emissions targets, as well as for expanding access to high-wage jobs, and supporting domestic manufacturing and energy production.   

As Congress weighs bipartisan targeted measures to address the challenges of permitting clean energy and industrial decarbonization projects, the Coalition urges Members of Congress to consider the key elements laid out in the Coalition’s guiding principles for permitting. Without meaningful improvements to the current system for permitting projects and targeted measures to address gaps in policy, the risk of projects in the development pipeline being cancelled grows. Project cancellations will imperil sustainable, high-wage jobs and economic development, American energy security, and the prospect of urgently needed – and achievable – greenhouse gas emissions reductions.