Carbon Capture and Sequestration (CCS) is becoming an increasingly hot topic in the renewable fuels industry, especially as companies progress with construction of on-site carbon capture facilities. The energy industry is in the midst of a global decarbonization transformation as companies of all sizes pursue new opportunities such as CCS as a viable option to achieve their carbon reduction goals. With economic incentives like 45Q and the Intergovernmental Panel on Climate Change (IPCC) identifying CCS as key to mitigating the impacts of climate change, the soaring demand for CCS shows no signs of slowing down. North America is currently the global leader, accounting for 50% of all active CCS projects with 16 commercial facilities currently in operation, and more than 80 projects that are currently in development. Along with all these new projects, there are many questions that accompany this new frontier of Carbon Capture and Sequestration development.
Filling in the Gaps to Ensure Your Project’s Success
Recently, Christianson has answered many more questions from renewable fuel producer clients inquiring about what you need to know and how you can prepare to apply for CCS Pathways under the California Air Resources Board’s (CARB) Low-Carbon Fuel Standard (LCFS). Whether your CCS project is just starting construction or nearly up and running, we would love to share some insights with you on the current process for CCS and how to best equip yourselves for a successful journey.
This will be Part One of a two-part series where we investigate some of the most important components of the CCS Protocol and how to best prepare for your CCS pathway submission. In Part One, we will detail what to expect during the permanence certification application process and in part-two we will share more details on how this all ties together during your Pathway Validation.
The Carbon Capture and Sequestration Protocol is a document drafted by CARB that carries the weight of the LCFS regulation. The protocol applies to CCS projects that capture carbon dioxide and sequesters it onshore, in either saline or depleted oil and gas reservoirs, or oil and gas reservoirs used for CO2-enhanced oil recovery. The CCS protocol applies to any new CCS projects as well as any that are already existing, as long as the project meets the protocol’s permanence requirements. Now let’s dive into what you should know!
Approvals Necessary to Achieve Your Carbon Capture Goals
To generate CCS credits, you first must complete the work necessary to be issued a CCS Pathway, and at first glance the 139 pages of the CCS Protocol can be tough to understand. Christianson can help you navigate the protocol to ensure your company is ready to complete the necessary requirements, keep your timelines on track and have the proper experts at hand for the CARB approval process. There are two distinct approvals that your company will need in order to be issued a CCS pathway and generate carbon capture credits under the LCFS:
- Permanence Certification – Part 1 of this series
- Pathway/Project Validation – Part 2 of this series
Please note that both parts must be completed and approved by CARB in order to begin generating LCFS credits for carbon capture projects.
Permanence Certification Requirements
The Permanence Certification includes two distinct parts. In many ways each part has its own requirements and timelines and appear to be separate requirements, however the Permanence Certification encompasses and requires approval of both parts. To apply for your Permanence Certification your company will need to prepare all the necessary documentation materials for the Sequestration Site Certification and the CCS Project Certification.
What exactly is the difference?
Sequestration Site Certification- this section of the permanence certification is focused on the sequestration site itself and its geological characteristics. It includes Site Characterization, Risk Assessment, the Design, Monitoring, Operational & Closure Plans as well as the 3rd Party Professional Geologist Independent Review
CCS Project Certification – this section of the permanence certification is focused on the project well and includes detailed information on the Well Construction, Legacy Well Remediation, Updates to Previously Submitted Plans and the 3rd Party Petroleum Engineer Independent Review
When should these parts of the application be ready and submitted to CARB?
You can submit the certification in two parts – the Sequestration Site Certification and the CCS Project Certification, and CARB suggests submitting the site certification around the time that you start well drilling and submit the project certification close to the time that your CCS project is complete. You must ensure that each section is fully completed prior to your submission to CARB.
What if we have completed certain sections but are still working on other pieces? Can we submit the materials we have ready to begin the process while we complete the other work necessary for CARB?
You must ensure that each part of the application is completed in its entirety before your submission to CARB, however the sooner you start conversations with CARB about your facility’s specific circumstance the better. This also applies to any data that you can compile while planning your project, during construction, and at the time of commissioning; the sooner you start the better prepared you will be.
What happens once we submit all our materials to CARB?
Once you have everything ready for the permanence certification and you have submitted your materials to CARB, the CARB team will conduct a completeness review, followed by a detailed review of all your materials, then you will complete the independent review (see 3rd Party Independent Review), and lastly the final review and approval to issue the permanence certification.
3rd Party Independent Review
Prior to submittal of your CCS application to CARB for your Permanence Certification, the CCS Project Operator (the entity that is responsible for the CCS sequestration facility) must identify an accredited Professional Geologist as well as an accredited Professional Engineer to complete the 3rd Party Independent Review of the site certification and project certification, respectively. These 3rd parties that you identify to work on the Independent Review are subject to approval by CARB and must complete a Conflict-of-Interest evaluation. As you progress with the 3rd Party Review and the Permanence Certification, you can also move forward simultaneously with the pathway validation work. Look out for an in-depth look at the pathway validation process in Part 2 of this series in July 2022.
How long will it take to receive our Permanence Certification?
In total, from submission of your certification materials into CARB to the time of final review and approvals will take approximately 9 – 12 months to complete. Since it can take up to a year to achieve your permanence certification, it is critically important for the success of your CCS project to start as soon as possible.
At Christianson, we are thrilled to help support the trailblazers of the CCS industry as you progress with your Carbon Capture and Sequestration work and prepare your CCS pathway. If you’d like to learn more about CCS and how we can help be sure to catch us next month presenting at the Fuel Ethanol Workshop on Tuesday, June 14th, 2022. Need help sooner? Call us any time and one of our experts will be happy to help answer your questions!
