CO2 Pipelines Need Safeguards, Too
Any consideration of new CO2 pipelines must address the need for strong environmental, safety, and justice safeguards.
It’s well known that cutting carbon emissions is necessary to achieve a clean and safe future. That’s because carbon dioxide (CO2)—a potent greenhouse gas—makes up 75 percent of the human-caused emissions currently accelerating climate change. One proposal for reducing CO2 is “carbon capture and storage,” also known as “carbon capture and sequestration” or CCS. CCS is a technology that captures CO2 at the point of its release (the “smokestack”) and stores it securely underground in carefully selected geologic reservoirs where it will stay out of the atmosphere.
Some policymakers in DC are looking to expand federal support for research and development of CCS systems to capture CO2 generated by various industrial activities. Prime industrial targets include petrochemical plants, cement manufacturing, steel production, and others.
NRDC supports research and development of CCS in industrial applications that are critical to our economy, involve unavoidable processes that release large amounts of CO2, such as cement manufacturing, and lack a readily available cleaner alternative.
In these situations, CCS may prove essential to decarbonize the industry and meet climate goals. At the same time, we must pursue everything we can to accelerate renewable energy and energy efficiency to rapidly move our economy away from fossil fuels.
CO2 pipelines come with concerns
Captured CO2 can only be stored safely in sites with particular geologic characteristics that meet specific standards to protect groundwater and human health. Because these sites are not found everywhere in the country, captured CO2 would, in many cases, need to be transported from the point of capture to appropriate storage sites in order for CCS to make a meaningful contribution to decarbonization efforts. For this reason, some policymakers are supporting expanded government incentives to build a national network of pipelines to transport CO2 across the country.
In the recent Senate-passed Infrastructure Investment and Jobs Act, billions of dollars of incentives could support CCS. As part of these provisions, the bill provides $2.1 billion for financial loans and loan guarantees applicable to CO2 transport projects such as pipelines. Unfortunately, the bill language contains no protections to assure that pipeline construction projects are necessary for energy transition and regulated to prevent them from damaging clean water, wildlife habitat, and private property.
The evidence is clear and compelling: the way pipeline construction is currently permitted in the U.S. is inadequate to protect clean water and other natural resources, local communities, and environmental justice.
In addition, programs to build CO2 pipelines must be designed to avoid expanding oil and gas production. The science is clear that to protect the climate we must transition away from our dependence on fossil fuels. Pipeline networks that could encourage expanded oil or gas production via enhanced oil recovery (EOR) or enhanced gas recovery (EGR) would be inconsistent with our climate protection imperative. For this reason, and the other environmental impacts associated with oil or gas production, NRDC opposes policies that would expand EOR, EGR, or any other form of oil and gas production as a method of advancing CCS.
CO2 pipelines require critical safeguards
What’s missing from any current deliberation about new CCS pipelines? A recognition that, like oil and gas pipelines, CO2 pipeline projects require stronger safeguards. At a minimum:
- Review of any proposed CO2 pipeline should begin with a full assessment of the impact of the proposed pipeline, including on oil and gas production and use. Pipeline projects should be located, designed, and operated to avoid increases in oil or gas production or slowing the transition away from these fossil fuels. Carbon capture and CO2 pipelines are a supplementary means of climate protection and assessments should be structured to avoid any overbuilding of such networks.
- If a proposed pipeline is found to be compatible with energy transition needs, the pipeline approval process should fully consider alternatives that can reduce its impacts (for example, alternative routes, different approaches for stream crossings, and stronger inspection, maintenance and mitigation protocols). A systemic siting protocol should require planners to maximize use of already disturbed rights-of-way, minimize environmental impacts, and fully consider environmental justice impacts on vulnerable communities.
- To further environmental justice and public participation, there must be meaningful opportunities for the public to participate and to have their input incorporated into discussions about siting of pipelines and related facilities.
- There should be full recognition and respect for tribal rights and treaties, including requiring Free, Prior and Informed Consent from indigenous peoples where the people, their territories, resources, or rights could be impacted.
- To reduce abuse of eminent domain, affected landowners must be brought into the process early, be given a full opportunity to participate in the review of the pipeline proposal, and, if a taking becomes necessary, receive fair and timely compensation for their land.
- It is essential that federal agencies change their policies to ensure vigorous implementation of all federal regulations that apply to pipeline construction, including the Clean Water Act’s Section 404 provisions for discharges of dredged material or fill from pipeline construction where, to date, implementation has fallen short and allowed thousands of violations related to pipeline construction to continue.
- Finally, to ensure robust oversight and regulation, Congress must direct agencies with expertise in health, safety, and environmental protection to regulate CO2 pipelines and develop safety protocols that consider the hazards of CO2 transport, which may be different than oil or gas, and they must vigorously enforce those regulations.
Any consideration of new CO2 pipelines must address the need for these strong environmental, safety, and justice safeguards.