In order for the Section 45Q tax credit to achieve its potential, regulators must clarify the rules to access the credit so that project developers have the certainty they need to make investments in CCUS projects. Further, the requirements for accessing the credit through EOR must not place an unreasonable burden on operators and be consistent with state mineral property and natural resource conservation laws.
Robust and sustained funding for CCUS RD&D is essential in ensuring new technological innovation as well as in supporting the commercialization of maturing technology. The Energy Advance Center supports the continued strong funding of the Department of Energy’s applied research programs. We further support reforms that will allow the Department to be more effective at its mission of technology advancement.
How long-term liability is handled for CO2 storage projects is a critical issue that must be resolved for CCUS to advance. The Energy Advance Center supports a clear standard that can be applied across the states.
The outer continental shelf contains vast CO2 storage potential. Congress must correct barriers in both the Outer Continental Shelf Lands Act and Ocean Dumping Ban Act to allow for the development of CO2 storage sites on lands owned and controlled by the Federal Government. In addition, the Energy Advance Center urges to Congress to ratify the 1996 London Protocol on Maritime Pollution (as amended in 2007) as a means of further strengthening these statutory changes.
EPA should reform the Class VI UIC program to foster the build-out of underground CO2 storage projects, ensuring that the program is risk and performance based. Absent this necessary reform industry will not be able to take advantage of the vast storage potential for CO2 that exists in the US.
Permitting of large industrial projects today is a highly complex matter that poses many challenges for developers. The Energy Advance Center supports limited reforms which can expedite the time needed and reduce the cost of permitting CO2 mitigation projects while also protecting the environment and public health.
