Clean Air Task Force Initial Comments on Draft Accounting and Permanence Protocol for Carbon Capture and Geologic Sequestration under Low Carbon Fuel Standard

CATF argues that the California Air Resources Board's draft protocol for carbon capture and geologic sequestration relies on arbitrary timeframes, specifically a 100-year post-closure monitoring requirement, which may deter investment. CATF proposes a performance-based approach where site closure is determined by demonstrating CO2 plume stability and storage integrity rather than a fixed duration. The document highlights the different risk profiles of saline brine storage versus enhanced oil recovery (EOR) and cites the Mountaineer project in West Virginia as an example where stability was demonstrated in three years, allowing for early closure.

• CATF recommends that the California Air Resources Board (ARB) replace the proposed 100-year post-closure monitoring requirement with a performance-based approach to ensure the protocol is 'environmentally protective and economically workable'.
• The 100-year monitoring requirement is identified as a 'significant deterrent to investment in and deployment of CCS', and CATF requests that ARB provide the technical and empirical basis for this specific timeframe.
• CATF argues that the 100-year requirement, which ARB suggested was based on an urban forest offset protocol, is inapplicable because geologic sequestration differs fundamentally from forestry; for example, trees can die or be cut down, whereas geologic storage risks are related to subsurface stability.
• A performance-based approach should vary based on the storage type: saline storage has less subsurface knowledge and no pressure management, while enhanced oil recovery (EOR) projects have well-known geology but higher risks from 'unknown or poorly plugged wells'.
• The AES Mountaineer saline storage project in West Virginia serves as a practical example of a performance-based closure; it met its stability and safety criteria and closed after 3 years, despite an initial 20-year permit timeframe.

APA

Clean Air Task Force (2018). Clean Air Task Force Initial Comments on Draft Accounting and Permanence Protocol for Carbon Capture and Geologic Sequestration under Low Carbon Fuel Standard. https://cdn.catf.us/wp-content/uploads/2018/11/21093926/CATF_Comments_ARB_CCS_Protocol_Draft.pdf

Chicago

Clean Air Task Force. Clean Air Task Force Initial Comments on Draft Accounting and Permanence Protocol for Carbon Capture and Geologic Sequestration under Low Carbon Fuel Standard. 2018. https://cdn.catf.us/wp-content/uploads/2018/11/21093926/CATF_Comments_ARB_CCS_Protocol_Draft.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Clean Air Task Force Initial Comments on Draft Accounting and Permanence Protocol for Carbon Capture and Geologic Sequestration under Low Carbon Fuel Standard |date=1 February 2018 |url=https://cdn.catf.us/wp-content/uploads/2018/11/21093926/CATF_Comments_ARB_CCS_Protocol_Draft.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2018clean, author = {{Clean Air Task Force}}, title = {{Clean Air Task Force Initial Comments on Draft Accounting and Permanence Protocol for Carbon Capture and Geologic Sequestration under Low Carbon Fuel Standard}}, publisher = {Clean Air Task Force}, year = {2018}, month = feb, url = {https://cdn.catf.us/wp-content/uploads/2018/11/21093926/CATF_Comments_ARB_CCS_Protocol_Draft.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }