Coalition Submits Comments to EPA on Supplemental Proposed Rule to Ensure Transparency for Secure Geological Storage Operations Under the Greenhouse Gas Reporting Program 

July 28, 2023 | News

On July 21, 2023, the Carbon Capture Coalition submitted comments on the Environmental Protection Agency (EPA)’s re-proposed supplemental rule Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule. As part of updating the Greenhouse Gas Reporting Program (GHGRP), EPA proposed several important additions to the GHGRP. These proposed changes include additional measures to enhance transparency of the monitoring, reporting, and verification (MRV) protocols, as well as requesting additional information on the potential of adding carbon dioxide utilization, or reuse of CO2 or its precursor carbon monoxide (CO), as a separate source category to the GHGRP.  

The re-proposed rule included many of the Coalition’s recommendations made in initial comments, including suggestions related to harmonizing transparency and reporting mechanisms for those enhanced oil recovery (CO2-EOR) producers wishing to report under ISO 27916, to ensure robust MRV protocols for claiming the 45Q tax credit.   

Robust MRV protocols remain the foundational mechanism for ensuring public and policymaker confidence in the 45Q tax credit. Tax credit claimants must demonstrate secure geological storage of captured or utilized Carbon Dioxide (CO2) to EPA through robust MRV or lifecycle analysis (LCA) of the utilized CO2 or CO. The Coalition submitted three key general comments to EPA on the re-proposed rule: 

  • The Coalition reiterated its support for adding Direct Air Capture (DAC) to the “carbon dioxide stream” definition and as a CO2 supplier under subpart PP. Adding DAC under the CO2 supplier helps the DAC equipment owners to ensure that they can demonstrate secure geological storage to claim the tax credit. 
  • The Coalition strongly supports the creation of subpart VV under the GHGRP, geological storage of CO2 for enhanced oil recovery (EOR) using ISO 27916. The re-proposed supplement rule incorporates the Coalition’s recommendation to require the use of subpart VV for those CO2-EOR operators who opt-in to reporting through ISO 27916. It also makes clear that CO2-EOR operators electing to use ISO 27916 no longer have the option to report under subpart UU and instead would report under subpart VV. 
  • Previously, the Coalition had provided feedback on EPA’s earlier question on adding CO2 utilization as a separate source category. The Coalition commented that the EPA should review, synthesize and make public the initial comments received on the questions posed in the initial rule related to carbon reuse as they seek to better understand the greenhouse gas emissions and sinks related to carbon reuse.  

Additional Resources:  

  • View the re-proposed rule in the Federal Register (published May 22, 2023).  
  • Read the Coalition’s July 2023 comments on the re-proposed rule here.  
  • Read the Coalition’s October 2022 comments on the proposed rule here.  


Convened by the Great Plains Institute, the Carbon Capture Coalition is a nonpartisan collaboration of more than 100 companies, unions, conservation and environmental policy organizations, building federal policy support to enable economywide, commercial scale deployment of carbon management technologies. This includes carbon capture, removal, transport, utilization, and storage from industrial facilities, power plants, and ambient air.