This week is the official last week of the summer internship cohort at Carbon180 ☹ Fortunately, I am still working for another two weeks! These past eight weeks were mainly leading up to my final presentation I presented this past Friday. During my final presentation, I presented on everything I researched and analyzed this summer from what is carbon capture and storage (CCS), to the current state of CCS, to CCS related legislation and programs. The majority of the presentation included my two policy recommendations I had regarding both CCS and environmental justice. My two policy recommendations are as follows:
2) Federally funded CCS research, development, and deployment (RD&D) should be restricted to the industrial sector thus excluding power plants.
Even with CCS, fossil fuel power plants are extremely harmful to the environment and surrounding communities. It is important to ensure that CCS is not used as a tool by fossil fuel companies to perpetuate society’s reliance on fossil fuels. To produce certain industrial materials, it is necessary to emit some amount of carbon dioxide such as cement and steel. It is important to focus CCS efforts on these situations since society is dependent on many of these materials. RD&D efforts for CCS should specifically support CCS deployment in the industrial sector. Federally funded RD&D efforts can power innovation but should only be available for CCS projects with industrial production to avoid the expansion of coal and fossil fuel plants. The $131 million recently allocated to CCS RD&D efforts from the DOE should exclusively fund the category regarding industrial production. Policymakers should contact the DOE contracting officer to amend the rules of this program to exclusively support industrial processes. Additionally, the Carbon Capture Improvement Act of 2019 would issue tax-exempt private activity bonds to finance carbon capture projects; this act should be amended to disqualify coal and fossil fuel power plants used to limit the exempt facility bonds for CCS deployment in the industrial sector.
2) Remove the categorical exclusion for small scale CCS projects.
The National Environmental Protection Act requires all federally funded projects that may have a significant impact on the environment to conduct an Environmental Analysis (EA) and possibly an Environmental Impact Statement (EIS) is necessary. EISs include significant public engagement such as extensive public comment and required feedback. A categorical exclusion is a category of actions that does not require either an EA or an EIS. Therefore, categorical exclusions allow projects to bypass public comment and community engagement. There is a categorical exclusion for small scale CCS projects, which allows projects to avoid conducting a comprehensive risk analysis report and consultation with stakeholders. Although there are almost a dozen large scale CCS projects in operation in the US, there has not been enough time and projects to adequately conclude that small scale CCS projects do not have significant environmental impacts, especially long-term impacts. Projects should only be deployed with sufficient engagement from key stakeholders, such as local community members, indigenous community members, landowners, community-based organizations, public health organizations, and environmental non-governmental organizations. EISs hold developers responsible for informing, listening, and engaging to key stakeholders and community members to ensure that they are included in the development discussion. It is imperative that all CCS projects conduct an EA and/or EIS; removing the categorical exclusion will guarantee a comprehensive risk assessment of each CCS plan that effectively engages with the public. This action will also close the gap in the EPA’s Underground Injection Control Program that does not require project developers to assess and evaluate environmental justice concerns.
As for the next two weeks, I will be working on writing a blog post related to all the research I have done this summer and my experience working on the environmental justice project. The blog post is going to detail whether or not CCS can be done in a way that upholds environmental justice, and if so, then how?