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IV. THE ROLE OF POLICY IN ACCELERATING CO2 UTILIZATION As described above, carbon utilization applications have enormous commercial and decarbonization potential. However, if carbon utilization is to approach the levels of market value and CO2 removal outlined by the 2016 Roadmap study, specific policies are needed to help overcome the challenges noted above. These policy options fall into four general categories: • Financial enablers include incentives like tax credits and subsidized project finance. • Research includes more and better coordinated federal spending on all phases of research, development, demonstration, and deployment (RDD&D). • Infrastructure includes development of CO2 transportation infrastructure. • Market enablers include industry standards, and procurement policies that provide preferential de- mand for products with recycled carbon. Congress provided an important financial enabler with the 2018 passage of the FUTURE Act, which improved and extended the federal “45Q” tax credit for carbon storage and utilization. This was a landmark for both carbon management and climate policy since it made the tax credit available for non-EOR utilization for the first time. When implemented, the tax credit has the potential to encourage all of the carbon uses identified above. But because individual CCU sectors are dissimilar both in terms of their levels of development and their future capacity, policymakers must also consider policies designed to overcome sector-specific challenges. In the pages that follow, a variety of policies and measures are outlined. The first section discusses cross- cutting mechanisms while the second focuses on specific sectoral challenges. Appendix A offers a summary comparison of specific policies along with an overview of the status, barriers and market potential of the individual carbon-use sectors. BROAD POLICY APPROACHES TO ACCELERATING CARBON UTILIZATION Financial Enablers The enactment of 45Q in 2018 was a significant achievement for all carbon uses, but two of its requirements may prevent non-EOR CCU from qualifying for the tax credit. First, because of the time involved in planning and developing a new project, developers may have difficulty reaching the law’s “begin construction” cutoff date of Dec. 31, 2023. Even then, they may not be able to ramp up to the 25,000-ton threshold level of CO2 usage necessary to qualify for the credit. If the tax credit is not claimed by a significant number of CCU developers, Congress should push back or eliminate the begin-construction deadline and lower the tax credit’s eligibility threshold to as little as 1,000 tons. In addition to the 45Q tax credit, making carbon capture projects (including CCU projects) eligible for existing forms of preferable treatment would improve their financial profile. For example, private activity bonds (PABs) are tax-exempt bonds that allow project developers to qualify for lower-cost financing for privately-run projects that provide a public benefit. Also, master limited partnerships (MLPs) allow entities organized as partnerships to be publicly traded (therefore combining the lower-tax treatment of a partnership with access to securities markets). Making carbon utilization projects eligible for these financing options like PABs and MLPs would make them more attractive to investors, with little direct cost to the U.S. Treasury. Finally, FEED (front end engineering design) studies represent a critical early step in project development, and one whose cost is not insubstantial for a startup. DOE presently has a selection process to fund FEED studies for capture projects; it could do the same for utilization projects. Meanwhile, incumbent industries such as oil CARBON UTILIZATION—A VITAL AND EFFECTIVE PATHWAY FOR DECARBONIZATION 17PDF Image | Carbon Utilization
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