We are involved in forming the Carbon Capture and Storage Coalition, a unique, non-profit coalition of industries involved in carbon capture and storage (CCS) that will analyze and develop key resources—model legislation and regulation, capacity-building programs, performance standards and commercial models—to accelerate CCS deployment. To develop these resources, the CCS Coalition will partner with academic institutions who are working at the forefront of CCS technology.
The CCS Coalition Is Unique
While there is a fair amount of CCS research and large-scale testing taking place, there is insufficient development of implementing legislation, regulations, capacity-building programs, standards, and commercial models. And while there are several CCS associations in the United States, all of them are relatively small and serve a traditional trade association role, i.e., support business interests, inform members about developments, and generally advocate for CCS. These groups are not developing detailed legal frameworks or capacity-building programs or performance standards.
The CCS Coalition will fill this space and, led by CCS experts in the engineering and legal fields, provide a unique and specialized approach to CCS development. Initially, the primary audience for the Coalition’s input will be U.S. federal and state lawmakers, policymakers, regulators, stakeholders, and business leaders, and its primary objective is to ensure that evolving greenhouse gas regulatory regimes incorporate CCS in a manner that is safe, environmentally sound, affordable, and compatible with emerging international regulations and standards.
Proposed Activities
In addition to issues identified by its industry members, the CCS Coalition will fill regulatory and programmatic gaps identified in August 2010 by the U.S. Federal Interagency Task Force on Carbon Capture and Storage and recently by the California Carbon Capture and Storage Review Panel. The CCS Coalition’s proposed activities include:
- Analyze and determine the most appropriate regulatory structures for addressing potential long-term liabilities.
- Develop regulatory frameworks for CCS for onshore and offshore federal lands.
- Develop capacity-building programs for underground injection control regulators.
- Analyze how the National Environmental and Policy Act would apply to CCS to help ensure timely completion of robust and comprehensive environmental reviews.
- Create performance standards consistent with the expectation of storage permanence and safety.
- Develop regulations in California under the California Global Warming Solutions Act (AB 32) regarding the treatment of CO2 emission reductions from CCS projects in capped and uncapped emission sources.
- Create a business model for commercial-scale CCS project that addresses and resolves key issues related to financial, insurance, liability and regulatory structures.
- Maintain a database on U.S. state CCS policies and legal developments.
- Seek to brief and educate U.S. Environmental Protection Agency’s (EPA) attorneys and other government officials on our relevant regulatory analysis and recommendations, especially given our extensive contacts at EPA’s Office of General Counsel.
Some Reasons to Participate
The CCS Coalition is seeking members from industries including oil and gas companies, power generators, pipeline companies, manufacturers, carbon storage servicers, banks, financial institutions, insurers, consultants, and other related industries. Some of the business reasons for participating in the CCS Coalition include the opportunity to:
- Identify and prioritize legislative, regulatory and commercial gaps related to CCS.
- Advance legislative, regulatory and programmatic models and support their implementation by working with lawmakers, policymakers, regulators, and business leaders.
- Improve knowledge and understanding of CCS legal developments.
- Network with other member companies.
For more information, please contact David Wagner.
