The Oil & Gas Industry’s Role in CCS and CDR: International Energy Agency Conclusions

Authored by Wil Burns, Co-Director, Institute for Carbon Removal Law & Policy, American University

As part of its World Energy Outlook Special Report Series, the International Energy Agency (IEA) last week released a report that focuses on what the Agency believes the fossil fuel industry should do “to align with the Paris Agreement and with the 1.5°C goal.” Pertinent to the Institute’s work, the report includes a section (2.3.1) discussing the potential role of carbon capture and storage (CCS) within the fossil fuel sector, as well as direct air capture (DAC). While CCS is not squarely in the purview of the Institute’s work, it plays an integral role in one carbon dioxide removal approach, bioenergy and carbon capture with storage (BECCS), and the technology’s deployment will contribute to the development of conveyance and storage infrastructure relevant to the development of the direct air capture (DAC) sector.

The report contends that neither CCS or DAC can be viewed by the industry as mechanisms to “retain the status quo.” Under a business-as-usual scenario, the study concludes that oil and natural gas consumption would require an “inconceivable” 32 billion tons of CCS/DAC, including 23 billion tons of DAC to be Paris-compliant. Moreover, the study projected that this would require 26,000 terawatts of electricity generation in 2050, which would be greater than electricity demand in 2022, and $3.5 trillion in annual investments through mid-century, commensurate with the fossil fuel industry’s annual average revenue in recent years.

However, the report also emphasizes the important role that the fossil fuel industry can play in achieving Paris Agreement objectives through responsible deployment and investment in these approaches. The IEA’s World Energy Outlook 2023 study outlines a number of scenarios that reflect future potential global conditions. These include the Stated Policies Scenario (STEPS), premised on current climate policy, and commitments, the Announced Pledges Scenarios (APS), premised on the assumption that governments meet all national energy and climate targets made to date, and the Net Zero Emissions by 2050 (NZE) Scenario, which limits warming to 1.5°C.

In the APS, carbon dioxide capture grows from 45 Mt CO2 in 2022 to 440 Mt CO2 in 2030, with early action through large-scale deployment of CCS in the fossil fuel sector providing the foundation for subsequent use in other sectors where abatement is critical after 2030. This is projected to result in the global capture of 3.5 GtCO2 by 2050.

The NZE scenario requires much more aggressive carbon capture to contribute to the goal of holding temperatures to 1.5°C: 1 GtCO2 by 2030, and 6 GtCO2 by 2050, half of which is from DAC and heavy industry. This requires a whopping $500 billion of investment just through 2030. The study concludes that this daunting task requires the fossil fuel industry to go beyond conceiving carbon capture as a “social license to operate,” focusing merely on reducing Scope 1 and Scope 2 emissions from the sector. Rather, the IEA argues that the fossil fuel sector could use its “sizeable balance sheets” to leverage a competitive advantage across the broader energy economy, helping further the industry’s diversification strategies while facilitating requisite levels of CCS and CDR.

Section 2.3.1 of the report also includes an extensive analysis of the specific role of, and limitations to, deployment of DAC. On the one hand, the IEA emphasizes that countries with low-cost energy resources and ample CO2 carbon capacity could reap $60-150 billion per year if certificates for DAC sequestration are traded between $100-250 per ton/CO2. However, the study concludes that the cost of deployment, energy constraints, competition for DAC CO2 from synthetic fuel production, and constraints on annual CO2 storage capacity will limit DAC deployment. It projects that under the NZE scenario, atmospheric removal of CO2 will reach 1.7 Gt/yr. by 2050, with one-third of this achieved by DAC. The study finds this will require about $70 billion in annual investment for DAC in 2050 and approximately 500 TWh of annual electricity generation in 2050.

As is often the case with IEA reports, this one is short on specific policy prescriptions to drive the kind of investment by the fossil fuel industry that is contemplated in the study. While the study discusses some specific roles that governments are, and can, play in incentivizing CCS/CDR, it is by no means clear these will be sufficient to substantially move the needle. The suboptimal levels of investment of the fossil fuel industry to date in these technologies, given the sector’s massive contribution to greenhouse gas emissions, suggests that it may not fulfill the role contemplated by the IEA without far most aggressive demand-pull mechanisms, such as a carbon take back obligation. Hopefully, the IEA’s future reports on this sector will consider a wider array of policy options to foster a more responsible role by the fossil fuel industry.

Reershemium, et al., Initial Validation of a Soil-Based Mass-Balance Approach for Empirical Monitoring of Enhanced Rock Weathering Rates, Environmental Science & Technology (2023)

Literature Review Series

Authored by Wil Burns, Co-Director, Institute for Carbon Removal Law & Policy, American University

There is growing interest in enhanced rock weathering (ERW) as a potentially important component of a carbon dioxide removal portfolio. Recent studies project that large-scale application of pulverized silicate rocks, such as olivine, basalt, or wollastonite, to croplands could effectuate atmospheric carbon dioxide removal of 0.5-4 gigatons annually by 2100. However, one of the most imposing barriers to scaling ERW as a climate response mechanism is the difficulty of monitoring and verifying carbon sequestration.

A new study in the journal Environmental Science & Technology tries to help address this issue. The study introduces a new tool to monitor and verify ERW sequestration. The approach seeks to measure differences in concentrations of ERW feedstock pre- and post-weathering by comparing concentrations of mineral-bound metal cations before and after feedstock deployment. More specifically, the approach, which is referred to as “TiCAT,” seeks to estimate the total loss of cations from the solid phase of soil samples vis-à-vis a titanium tracer. The researchers contend that this mass-balance approach can help us estimate the time-integrated amount of weathering of a silicate mineral, basalt in this study, within a given soil profile. The TiCAT approach was initially assessed through a laboratory mesocosm experiment that measured the concentration of reaction products in soils and leachate solution pools.

The researchers concluded that the TiCAT process accurately estimated initial CDR within the standard error or means of results from the more conventional method used to calculate weathering and initial CDR in mesocosm experiments. This suggests that “it can yield an accurate and robust estimate of initial CDR in enhanced weathering systems.” This could be a significant breakthrough, because prior methods of estimating ERW, especially those reliant on measuring quantities and transport of weathering reaction products, pose barriers to scaling given their time and labor intensiveness. Moreover, this approach could “directly integrate into existing agronomic practices,” as samples from the uppermost layer of soils are routinely taken for nutrient and soil pH analysis.

However, the authors of the study also proffer a number of caveats in terms of their findings, including the following:

    • The estimates from this approach are only an initial value, subject to potential leakage of initially captured carbon as it’s transported an alkalinity and dissolved inorganic carbon from soil to the oceans;
    • The variable lag time between feedstock dissolution and the capture of carbon dioxide needs to be taken into account in accurately assessing CDR;
    • As a next step, it needs to be established the approach can scale weathering rates from discrete sampling points to larger systems;
    • There may be site-specific conditions in some settings that would preclude accurate use of this approach, such as areas with high levels of physical erosion or where feedstocks with chemical conditions similar to those in the soils are applied.

As Mercer recently noted, robust monitoring, reporting and verification (MRV) of greenhouse gas removal approaches is a “market shaper” that can address a market failure that may preclude scaling of many options. Moreover, it’s critical to engender public acceptance and trust. While not as sexy as images of the construction of new CDR facilities, research of this nature needs to be front and center in our consideration.

DOE FECM should fund public and community organizations to lead on responsible carbon management

Authored by Dr. Sara Nawaz, Celina Scott-Buechler and Dr. Holly Caggiano

In August 2023, the Department of Energy’s Office of Fossil Energy and Carbon Management (DOE FECM) unveiled its Notice of Intent (NOI) and Request for Information (RFI) regarding the launch of a Responsible Carbon Management Initiative. The primary purpose of this announcement was to notify interested parties of the department’s intentions and to encourage project developers and industry stakeholders to prioritize safety, environmental stewardship, accountability, community engagement, and societal benefits in carbon management projects.

To engage stakeholders and gather input, DOE FECM sought responses to a set of questions, particularly focusing on the draft Principles for Responsible Carbon Management Projects and the broader initiative. Responding to this call for input, Dr. Sara Nawaz, the Institute’s Director of Research, collaborated with Dr. Holly Caggiano from the University of British Columbia and Celina Scott-Buechler from Stanford University to share feedback on the draft Principles.

Their response highlighted the need for an important reconfiguration of DOE’s approach to responsible carbon management. Instead of treating ‘responsibility’ as something that individual developers should lead on and be supported in, the response argued for the need for DOE to support and fund democratic institutions and communities to better participate in decision-making about carbon removal.

Moreover, the response suggests the need for an autonomous, publicly funded entity to lead public engagement and participation processes. This entity would ensure that public and community views, concerns, and values are central to national, regional, and local planning for carbon management. These kind of independent public engagement processes have been demonstrated to improve public acceptance and social license, and to help in planning low-carbon transitions.

The response recommended a two-fold approach for DOE FECM:

    1. It suggests identifying and allocating funding to community organizations that are beginning to address issues of environmental justice, Tribal consultation, and more in carbon management. These funds would support community-led exploration of socially viable pathways for carbon management at the regional level.
    2. It proposes funding the scoping of an independent agency to lead governance and public co-creation of carbon management initiatives, with a focus on community participatory methods.

You can find a version of their full response below:

We commend the Department of Energy’s Office of Fossil Energy and Carbon Management (DOE FECM) for its commitment to exploring responsible carbon management. Approaching this topic via a set of Principles is a useful starting point, but as we will assert in this response, the current formulation of this RFI and these Principles offers only limited potential to meet the goal of responsible management. As we understand the RFI, it suggests that DOE FECM’s goal with a Responsible Carbon Management Initiative is to support [private] project developers in adequately meeting the Principles; it suggests that, in Phase 2, there will be a FOA that “would provide resources to support project developers seeking to meet the Principles or other aspects of this effort (including increasing transparency or third-party verification)”.

As written, the Principles appear to empower the private sector to lead emerging carbon management efforts. We urge that FECM reconsider this approach to carbon management. A socially and environmentally responsible carbon management regime is best led by our democratic institutions and the communities that have been, and will continue to be, most impacted by carbon-intensive industries.

Public and community leadership and ownership must be at the heart of DOE efforts on carbon management—and this initiative provides a unique opportunity to do so. If retooled to imagine carbon management as a public good, this flagship approach would empower government and community organizations to develop strategies tailored to local needs while developing ambitious long-term goals and the institutions necessary to meet them. A handful of local governments are already doing this through the 4 Corners Carbon Coalition. Another example of community-centered, and ultimately community-owned, carbon management project is the CALDAC DAC Hubs application. While we recognize the appeal of a private enterprise that can move faster and more nimbly than the government is sometimes able to do, we as social scientists must stress the importance of building social license and effective governance in any new industry. Given carbon management’s growing importance to meeting global climate goals—and the many examples of misuse of carbon management as a greenwashing tactic—the societal stakes of a successful industry are high. Like other forms of waste management in the U.S., carbon management should primarily be treated as a public project. This is further justified by the significant public funds that have been allocated to carbon management to date. Treating carbon removal as a public project

In addition to conceptualizing the carbon management industry as a public undertaking necessitating public control, we would further argue that a community-driven approach is needed over the proponent-led model implicit in this RFI. Developers of carbon management projects certainly need support in working towards more responsible deployment at the project level, but they are not the only group that do, nor are they the group with the greatest need for support. In fact, there are limits to what ‘developers’ alone can accomplish in working towards the goal of responsible deployment. To ensure adequate attention to the Principles (particularly on community engagement, environmental justice, Tribal consultation, workforce development and quality jobs, but also others), it will be crucial that community groups (e.g., Tribal, environmental justice, labor, and general public community groups) are supported in engaging with developers regarding potential projects and broader carbon management initiatives in their local areas.

There are a few reasons why these groups are well-positioned to support the implementation of responsible carbon management initiatives, and why DOE FECM should actively focus its attention and support on these important public and community groups. Despite holding crucial local knowledge, these groups often lack access to the conversations, options, and technical understandings of trade-offs that would help them make informed decisions about if, how, when, and where potential carbon management projects might benefit their communities. When developers lead the agenda on these topics, communities tend to enter the conversation later—yet, early participation is essential for effective community engagement and positive outcomes for environmental justice communities, workforces, and overall project acceptance and success. Beginning the conversation early means that communities can shape priorities from a project’s inception, rather than responsively negotiating at a table that has already been laid. When developers lead the conversation, communities are less likely to be offered the full range of possible options available to them, as developers tend to focus on options that they hope to implement, excluding other options (for decarbonization, community benefits, etc.) that might also exist.

As such, there is an urgent need for public engagement and participation processes that are shepherded and led by independent groups separate from developers—both to determine the scope and governance of carbon management nationally as well as to determine mechanisms for empowering communities to lead carbon management projects. DOE FECM should take steps towards establishing such an autonomous public entity that can ensure that public and community views, concerns and values are centered in national planning for carbon management and the production and ownership of individual projects.

 A key value of such a group would be the impartiality that such independent third-party actors bring. Precedents for such independent public participation bodies have been developed for environment and megaproject sectors in the Netherlands, Denmark, Canada, Italy, the UK, and France, with the most long-standing in Quebec and France. In France, a public entity that does public engagement (the National Commission for Public Debate, or Commission Nationale du Débat Public, CNDP) is designed to facilitate early public participation in potential environmental projects, so that participation occurs when it is still possible to substantially modify terms of projects. As such, the CNDP has the potential to meaningfully improve projects and generate social acceptance; of 101 public debates, 296 consultations, and 31 consultancy and expertise missions that the CNDP has facilitated in the last 25 years, only 3 projects were abandoned following public debate, 58% of projects saw design modifications, and all saw changes to their governance procedures.

Germany’s regional coal workforce transition also offers insights into how to ensure that carbon management is developed to facilitate a just transition. Beginning in the 1980s, Germany began a multi-decade community engagement process, acknowledging that a just transition away from coal must be a participatory process involving workers, industry and governments.” Since then, municipal governments have implemented a regional-level approach that relies heavily on participation—an approach that has been much more successful than its previous top-down approach with minimal public participation. Forms of engagement and participation used have included multi-stakeholder commissions (to advise on intervention design and oversee implementation), and multi-stakeholder conferences (to create local dialogues about regional needs and possibilities), and grant committees (to select projects for funding). Much of this has occurred at the local level, where the federal government transferred resources to local governments for them to oversee these participatory processes; such a transfer of resources to local governments was found to reduce coordination problems across policy levels, facilitating the efficacy of this transition away from coal.

From the German coal transition example, we see (1) the importance of conducting participation not just in relation to specific projects, but on broader sectoral transition and how it should unfold. We also see (2) that government-facilitated participation processes enable solutions that are targeted and adapted to local contexts and generate higher levels of acceptance. Both of these lessons will be relevant for carbon removal and carbon management, which needs to grow exponentially as a sector in the coming years and decades, and which will vary in form depending on the geographic regions in which they are conducted.

How can DOE FECM begin to incorporate these insights into its work? We propose that, instead of funneling its limited resources to developers, a better approach to responsible development by DOE FECM might involve the following:

    1. Identifying and allocating funding to a set of community organizations that are beginning to give attention to issues of environmental justice, Tribal consultation (and consent), etc. on carbon management. Funding would support these groups in leading initial exploration of socially viable pathways for carbon management at the regional level while considering the broader role and scope of carbon management in climate action. Redirecting resources directly to community organizations and facilitating these groups in leading on engagement activities would provide a strong pathway for DOE FECM to work towards its goals of “the highest levels of safety, environmental stewardship, accountability, community engagement, and societal benefits in carbon management projects”.
    2. Funding the scoping of an independent agency that might be chartered to lead governance of and public co-creation of carbon management (with attention to the many other issues covered in these Principles). Such a body might be deployed at regional levels to provide independent insights into community carbon management priorities through community participatory methods and inform the development of carbon management initiatives. Given the existing precedent for autonomous public entities to facilitate robust and sustained community engagement, we suggest that such an entity would be well-positioned to equitably and effectively facilitate the development of a Responsible Carbon Management Initiative.