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Capturing and Utilizing CO2 from Ethanol: Adding Economic Value and Jobs to Rural Economies and Communities While Reducing Emissions Ethanol’s contribution to achieving LCFS goals is already large, and biofuels suppliers are uniquely positioned to help California achieve deeper carbon intensity reductions in pursuit of the proposed 2030 target. The carbon intensity score of ethanol in California’s program could be lowered substantially, if production facilities were equipped with carbon capture and accompanying geologic storage, thus further reducing net emissions on a lifecycle basis, whether the CO2 is stored in oilfields or saline formations. The ARB would help the state meet its proposed 2030 LCFS target cost-effectively by developing a quantification methodology (QM) that enables those ethanol producers selling into the California market to qualify additional reductions in carbon intensity. This is achieved by deploying carbon capture from ethanol fermentation and geologically storing the CO2 through EOR or in saline formations. However, capitalizing on this carbon management opportunity requires removing critical regulatory barriers in the proposed QM and the LCFS, which will discourage and potentially preclude commercial development of the best and safest projects to capture and store carbon emissions. The Work Group expressed this concern in formal comments to ARB in September 2017. Figure 11: Ethanol Plants with Approved ARB Pathways Source: CARB 2017. Figure authored by GPI, 2017 With the subsequent release of ARB’s draft QM, the Work Group continues to have concerns. In particular, the draft proposes to enforce site-selection and monitoring requirements on CO2 storage projects outside state boundaries. For instance, a Midwestern ethanol producer that captures biogenic CO2 could not claim lower carbon intensity for its fuel marketed in California, if it sells that CO2 to an oil company for storage through EOR, unless that company were to meet California’s additional requirements—even if its EOR operation complies with existing federal U.S. Environmental Protection Agency requirements to certify secure geologic storage for the purposes of claiming federal tax credits. The same would hold true for a Midwestern ethanol producer seeking to claim credits for capturing and storing CO2 in a saline formation outside of California. ARB has also proposed a requirement that geologic storage sites be monitored for 100 years after CO2 injection has ended, which would be unprecedented, if implemented. This would prevent private investment in carbon capture and storage projects aimed at participating in the California LCFS market, leave millions of tons of potential CO2 reductions on the table and making California’s achievement of its own policy goals more costly and uncertain. California state leaders are calling for continued progress in reducing our nation’s carbon emissions, and numerous ethanol producers have expressed interest in investing in carbon capture and storage with a view toward LCFS compliance, provided that regulatory requirements are commercially feasible. ARB has the strategic opportunity to design a regulatory system that drives industry investment in deployment of large-scale carbon capture and CO2 pipelines in states that may have different policy priorities from California, but which share a common interest in deploying technology and infrastructure that beneficially reduces emissions, while achieving other energy and economic objectives. Other State and International Low Carbon Fuels Policies Other states and international jurisdictions have LCFS policies and are looking to California to inform implementation of their own efforts. Oregon’s Clean Fuels Program and British Columbia’s Renewable and Low Carbon Fuel Requirement Page 26 Prepared by the State CO2-EOR Deployment Work GroupPDF Image | Capturing and Utilizing CO2 from Ethanol
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