Coalition Supports Forest Service Proposed Rule to Facilitate CO2 Storage on National Forest Service Lands
January 5, 2024 | News
On January 2, the Carbon Capture Coalition submitted a comment to the US Forest Service (USFS) supporting the proposed rule “Land Uses; Special Uses; Carbon Capture and Storage Exemption.” This proposed rule would allow the agency to consider and review applications for the safe and permanent storage of captured carbon dioxide (CO2) in pore space overlayed by USFS-managed lands.
Federal lands are an important and valued national resource; if properly sited and implemented in a manner that protects public access and benefits and minimizes surface disturbance, the geologic storage of CO2 beneath federal lands offers a significant opportunity to catalyze a domestic carbon management industry consistent with reaching midcentury climate obligations. The USFS already oversees approximately 74,000 special use authorizations ranging from powerlines to telecommunications, campgrounds, and resorts. Additionally, while the geologic storage of captured CO2 is permanent, the proposed rule does not authorize perpetual use of the surface land that these projects would occupy for transport, injection, and storage.
Modeling from the International Energy Agency (IEA) and the Intergovernmental Panel on Climate Change (IPCC) emphasizes the critical role carbon management technologies must play, alongside a diverse set of decarbonization strategies, to achieve net zero emissions by 2050. To this point, an estimated 130 million acres of federal lands overlay suitable geology for the secure storage of captured CO2, and the USFS manages 21 percent of that land. However, federal regulatory authorities still need to develop the proper procedures to authorize and manage the storage of CO2 on federally managed lands. The USFS’ proposed rule is an essential step in unlocking the potential for CO2 storage on federal lands and harmonizing regulations across agencies.
Clarifying regulatory procedures is critical to providing developers access to domestic CO2 storage capacity that aligns with 2050 greenhouse gas emissions targets and anticipated demand for appropriate CO2 storage over the coming years.
Thanks to robust, bipartisan policy support provided by Congress, including the most recent enhancements to the 45Q tax credit, there have been over 190 publicly announced carbon management projects since 2018. These projects span both the carbon management value chain and stages of project development—from pilot scale and feasibility (front-end engineering and design studies) to commercial scale projects. Importantly, most of the 190+ announced projects intend to store captured CO2 deep underground safely and permanently in appropriate geologic formations.
Safe and permanent injection and storage of CO2 in deep geologic formations represents a well-understood commercial practice worldwide. CO2 storage risks are well understood, decrease over time, and can be mitigated with best practices and by adhering to established regulatory standards. The Environmental Protection Agency (EPA) regulates and permits geologic storage projects using the Underground Injection Control (UIC) Class VI Well Program. The UIC Class VI well requirements are designed to protect public health and underground sources of drinking water and ensure that geology in the project area can receive and permanently store injected CO2. Any storage project, if approved, would be subject to rigorous federal or state safety reviews at the design, planning, engineering, construction, operation, and closure phases.
The proposed language is narrow both in scope and function. Changing the definition of carbon capture and storage, as recommended in the proposed rule, allows for the USFS to consider each proposed project individually and ensure it is aligned with both USFS and EPA regulations. Notably, the proposed rule only approves or allows for the construction of any such project once developers demonstrate compliance with these regulations. As part of individual project review, agencies must determine if proposed CO2 storage projects do not present a significant health risk to nearby communities or the environment.
The Coalition supports the USFS’ proposal and looks forward to continuing to work with the administration in further aligning federal policies and procedures for allowing consideration of CO2 storage on federal lands.
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, reuse, and storage from industrial facilities, power plants, and ambient air. Members of the Coalition work together to advocate for the full portfolio of policies required to commercialize a domestic carbon management sector and inform policymakers as well as stakeholders on the essential role this suite of technologies must play in achieving these shared objectives.