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:
- 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.
- 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:
- 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”.
- 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.