Joint Comments on ARB's CCS Protocol Concept Paper

The document outlines stakeholder feedback on the California Air Resources Board's (ARB) CCS Concept Paper, arguing that CCS is critical for California's GHG goals but requires flexible, risk-based regulatory frameworks to attract investment. The authors advocate for the integration of CCS into both the Low Carbon Fuel Standard and Cap & Trade programs, express skepticism toward a 'checkbox' approach for permanence protocols, and propose a tiered, performance-based system for post-injection monitoring instead of arbitrary 50- or 100-year default periods.

• The signatories argue that the deployment of CCS is essential for California to meet its greenhouse gas reduction targets, warning that if new projects are not operational by 2025, they are unlikely to contribute to the state's 2030 goals.
• The authors urge ARB to integrate the Quantification Methodology (QM) into both the Low Carbon Fuel Standard (LCFS) and the Cap & Trade (C&T) programs expeditiously, noting that a delay in the C&T framework would discourage investment in non-fuel related CCS projects.
• The coalition expresses caution regarding a 'checkbox' option for the permanence protocol, arguing that site-specific geological risks cannot be reduced to a checklist and that such an approach might be too restrictive or rely on incomplete public well records.
• The document recommends against a total prohibition on future activity in storage complexes after closure, suggesting instead that storage complexes be designated as covered entities so that any operator causing a release is held responsible.
• The authors identify the proposed 50- and 100-year default post-injection monitoring periods as the most significant barrier to project development, calling them arbitrary.
• To replace default monitoring periods, the authors propose a tiered structure based on site attributes, where shorter periods apply to low-risk sites (e.g., proven seals) and longer periods apply to high-risk sites (e.g., numerous old wells or known faults).

APA

Clean Air Task Force (2017). Joint Comments on ARB's CCS Protocol Concept Paper. https://cdn.catf.us/wp-content/uploads/2018/11/21093929/Joint_Comments_ARB_CCS_ConceptPaper.pdf

Chicago

Clean Air Task Force. Joint Comments on ARB's CCS Protocol Concept Paper. 2017. https://cdn.catf.us/wp-content/uploads/2018/11/21093929/Joint_Comments_ARB_CCS_ConceptPaper.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Joint Comments on ARB's CCS Protocol Concept Paper |date=30 May 2017 |url=https://cdn.catf.us/wp-content/uploads/2018/11/21093929/Joint_Comments_ARB_CCS_ConceptPaper.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2017joint, author = {{Clean Air Task Force}}, title = {{Joint Comments on ARB's CCS Protocol Concept Paper}}, publisher = {Clean Air Task Force}, year = {2017}, month = may, url = {https://cdn.catf.us/wp-content/uploads/2018/11/21093929/Joint_Comments_ARB_CCS_ConceptPaper.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }