CARBONCAPTUREANDSTORAGE-ClimateChangePortal.pdfVIP

California Carbon Capture and Storage Review Panel CARBON CAPTURE AND STORAGE CALIFORNIA PERMIT PROCESS IDENTIFICATION OF GAPS Jerry R. Fish Stoel Rives LLP June 2, 2010 1 Scoping the Permitting Process For CCS in California • This presentation looks at a high level at the permitting process for CCS projects in California. • The goal is to identify for discussion: – The diversity of permitting paths – Opportunities for cooperation among agencies – Opportunities to develop consistent CO2 standards – Gaps to be filled by new statutes or rules 2 Permit Process: First Impressions 3 Agencies with Potential Major CCS Role • California Air Resources Board/Air Districts • California Division of Oil, Gas Geothermal • California Energy Commission • California Public Utilities Commission • California State and Regional Water Boards • U.S. EPA Region 9 • See Elizabeth Burton’s 4/22/10 Presentation 4 Other Entities with Potential CCS Permitting Role • Counties • Water Districts • Air Quality Management Districts • Municipal Power Authorities • Federal Land Management Agencies • State Land Management Agencies 5 Where Are the Gaps? • CCS requires EPA Class VI injection well rules; will California seek primacy to administer these rules? • California can clarify ownership of and develop mechanism for acquiring pore space. • MOU’s are needed among federal, state, and local agencies to clarify their roles in permitting. • State agencies need to develop consistent protocols