PAYNE INSTITUTE COMMENTARY SERIES: COMMENTARY

By Nicolas G. Perticari Pesci

July 15, 2024

CCS projects are slated to be multi-billion-dollar infrastructure projects comprised of carbon dioxide pipelines, capture sites, and injection wells for the sub-surface. While the technical feasibility of carbon capture projects is explained systematically, for example as part of the permitting application for Class VI wells for geological storage, the social implications of projects are equally important and must also be evaluated to better understand risks and holistic mitigation of liability for all involved parties.

Integrating the social implications of a project begins with a determination of what communities will be impacted. The potential benefits and burdens, both directly and indirectly stemming from the project, can then be assessed, which can feed into the development of a social risk calculus for each impacted community.

It is important for project developers to recognize that these assessments work both ways. On the positive side, there is consideration of how these projects can positively impact the communities in which they are located and as well as benefit from community stakeholders participating in the long-term stewardship of the project. The assessment is also not merely a “one-time” application. Rather it would serve as a baseline for upcoming projects.

On the risk side, a more thorough understanding of what is often limited infrastructure — in the forms of on-site power, information for monitoring and maintenance, and road access to a site — can materially impact the relative success of the project’s construction, long-term monitoring, and risk response over the project’s lifespan.

This paper provides an overview of research undertaken at the Colorado School of Mines in to this social risk associated with geological storage in CCS projects. Publication of a more thorough review of such research is pending as of the date of publication of this paper.

Communities in Play

As of December 2023, the Environmental Protection Agency had 61 Class VI Underground Injection Control permits under review, the current mechanism for projects to receive clearance for underground storage of captured carbon, excluding projects in Louisiana, North Dakota, and Wyoming, which have been granted primacy, or the right to authorize projects at the state level. Projects, especially those that require timetables of half a century or more of oversight, should have long-term considerations for the risks of the maintenance of a site’s infrastructure, especially in instances where sites are in remote areas that would solely be maintained by those liable for the site. Scenarios like these bring up contextual research questions:

1. How can communities be stewards of their lands and environment?
2. How are sites being evaluated for “ideal project characteristics”?
3. Are there limitations to isolated projects?
4. What community impacts are not being considered for these projects?

Additionally, considerations of the indirect impacts on communities by project development must be evaluated, and mitigation plans can be created with the communities to ensure that indirect burdens are not introduced to the communities, even before the construction of the well.

Methods

To determine the risk of long-term maintenance of injection sites and their respective infrastructure, an evaluation of the relative location of injection sites was compared against the infrastructure investments per county to understand what historic investment near sites has looked like. The Map of Progress from the White House was used as a publicly available dataset of private and public sector infrastructure investments based on regional data. The EPA has an active list of UIC Class VI Permits under review and the respective counties that the wells are in; however, the resolution of the data does not indicate exact locations, so evaluations such as the proximity of a site to a community are limited.

Findings

Figure 1: Map of the EPA Region Classifications.

Table 1. Breakdown of permit application counties without any reported infrastructure funding by EPA region

Discussion

A preliminary evaluation of injection site counties indicated that the current pools of projects on private and, at times, isolated lands are in counties with moderately low infrastructure funding, leaving the project owners responsible for road infrastructure. Without intentional oversight of the long-term management of the infrastructure associated with these projects, long-term access to the site may be compromised without consideration of the large timescales of over one hundred years of monitoring, the current time convention being used for evaluations of liability.

A clear example of pushback due to the limited consideration over community-based stewardship and collaborative evaluation of a project can be seen with the Navigator CO₂ pipeline in Illinois. On October 10^th, 2023, the 1300-mile Navigator pipeline project, which spanned over 30 ethanol plants based in Iowa, Minnesota, Nebraska, and South Dakota for sequestration in Illinois, withdrew its proposal to the state of Illinois, followed by the complete cancellation of the development ten days later after permit denial in South Dakota and a halting of the permit process in Iowa earlier that year. Navigator claimed in its press releases that the “unpredictable nature of the regulatory and government processes involved, particularly in South Dakota and Iowa.” ultimately led to the project’s cancelation.

Grassroots organizers argued that the systematic participation of communities in all five states led to the ultimate denial of the permitting for the pipeline. Publicized concerns around the project from these groups were centered on:

1. The use of eminent domain for carbon dioxide pipelines.
2. The limited liability of operators for damages caused by the pipelines and injection and long-term site stewardship.
3. A call to pause the project until the Pipeline and Hazardous Materials Administration released its revised safety standards for CO₂
4. Projects have limited benefits and extreme risks for the communities they pass through.

Key stakeholder groups in the area additionally stated:

“The cancellation of Navigator’s CO₂ pipeline project highlights Navigator’s failure to adequately address the widespread concerns from farmers, landowners, environmental advocates, and elected officials from both sides of the aisle regarding basic protections for communities, land, and water resources. Navigator’s inability to secure enough public support for the pipeline sends a clear message that stronger protections are needed at both the state and federal level.” -Pam Richart, co-founder of the Coalition to Stop CO₂ Pipelines

“Get some safeguards in place on this entire technology — not only pipelines but how these gasses are captured and ultimately stored. The wisest thing to do seems to be to take a minute to figure out the risks and implications at all stages of the process… [and] make sure we don’t make long-term mistakes that jeopardize people in this short-term rush to cash in on these tax subsidies.”-Jack Darin, Director of the Illinois Sierra Club

Conclusion

The periods associated with the geological sequestration of carbon dioxide must be re-evaluated to consider the interfaces between a project site and surrounding communities. At any rate, no matter how isolated a project is, at some point, communities will be involved. Infrastructure projects of a timescale like that of carbon sequestration are limited and require intergenerational planning considerations to mitigate a project’s risks and liabilities. Isolated sites may serve as a mitigation strategy to prevent harm to communities and direct impact on the transport and storage process. However, it begs the question of what is sacrificed in exchange for the ease of process. Isolated projects fundamentally encounter fewer obstacles of social hesitation; however, they can lose the opportunity to incorporate communities as collaborative stewards to ensure project benefits can continue to flow locally and globally.

While injection sites may be isolated from communities, access to sites and the eventual establishment of the infrastructure needed for projects can indirectly impact communities in their proximity. Limited roadway access for heavy machinery at high volumes would require considerations for traffic flows for nearby communities, road impacts of the transportation process to the site, and the consideration of impacts for roadway closures, which can exacerbate the impact for communities with already limited access to major thoroughfares. Hidden impacts like these can equally disrupt the progression of projects and require careful consideration and collaboration with local communities to collectively benefit from projects and offer reduced liabilities for projects through shared stewardship of sites. Increased resolution of specific sites for injection could also allow for a dimension of analysis that considers the relative proximity of sites to population centers and evaluate the level of emergency response planning that would be necessary relative to its distance.

While community engagement is often considered a threat to the success of conventional infrastructure projects, CCUS projects of all scales can arguably only benefit from direct community engagement to collectively determine the risks posed by any single project and work to mitigate adverse impacts to communities in a way the serves the project’s completion and support for communities to be involved in site-specific stewardship, minimizing collective social resistance.

An evaluation of only one form of infrastructure in the development of CCUS projects is a limited view of the true nature of these systems.  Rather a series of additional steps could be used to understand better the risks that could be associated with remote sites by investigating the following parameters:

1. An analysis of the transmission corridors and their proximity to a site must be considered for the resiliency of the local grid to support these projects, should they be grid-tied.
2. An evaluation of the Emergency Response Infrastructure that would need to be tailored to address a catastrophic failure of a site.
3. An exploratory study for road compositions that could facilitate the construction phase of a well and remain substantially undisturbed over time.
4. Conducting a risk analysis profile that varies the degree of community engagement and collaborative stewardship of a project to reduce risk and singular liability of a project site.
5. Determining if sites are being unequally overburdened by the demands of the energy transition in the form of land use for energy generation, piping carbon dioxide through less-populated lands, etc.

ABOUT THE AUTHORS

Nicolas G. Perticari Pesci
PhD Student, Civil and Environmental Engineering, Colorado School of Mines

Nicolas Pesci is a student in the Civil and Environmental Engineering Department. He is working on a PhD in Environmental Engineering and Science after completing an M.S. in Advanced Energy Systems and a graduate certificate in Humanitarian Engineering and Science from the Colorado School of Mines. His research is centered on the socio-technical implications of the energy transition, just outcomes, and community stakeholders’ involvement in the development process.

ABOUT THE PAYNE INSTITUTE

The mission of the Payne Institute at Colorado School of Mines is to provide world-class scientific insights, helping to inform and shape public policy on earth resources, energy, and environment. The Institute was established with an endowment from Jim and Arlene Payne, and seeks to link the strong scientific and engineering research and expertise at Mines with issues related to public policy and national security.

The Payne Institute Commentary Series offers independent insights and research on a wide range of topics related to energy, natural resources, and environmental policy. The series accommodates three categories namely: Viewpoints, Essays, and Working Papers.

For more information about the Payne Institute please visit:
https://payneinstitute.mines.edu/

or follow the Payne Institute on Twitter or LinkedIn:

DISCLAIMER: The opinions, beliefs, and viewpoints expressed in this article are solely those of the author and do not reflect the opinions, beliefs, viewpoints, or official policies of the Payne Institute or the Colorado School of Mines.