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Copyright © 2018 Environmental Law Institute®, Washington, DC. Reprinted with permission from ELR®, http://www.eli.org, 1-800-433-5120. Farther in the future, EPA might also choose to encour- age the development of certain types of NETs—in particu- lar, olivine dispersal and direct mechanical removal of CO2 from coastal waters—by designating them as possible treat- ment technologies to address ocean acidification. Several water bodies in the United States have already become suf- ficiently acidic from air deposition that they do not meet the use designation or water quality standard set out for them, and as a result state environmental agencies (or EPA) will need to consider possible mitigation strategies to reduce their acidity.159 EPA has resisted citizen suit actions and administrative petitions to force it to update its ocean acid- ity water standards and to reject state water quality plans that did not directly mitigate ocean acidity.160 Its settlement of a citizen suit in 2010 led EPA to promulgate a guidance memorandum that will make any regulatory obligation to address ocean acidity unlikely for the near future.161 But if a NET project operator wished either to release CO2 entrained in ocean waters to increase the coastal or ocean water’s uptake capacity for additional CO2 absorp- tion, or to disperse finely ground olivine in coastal waters to accelerate enhanced weathering in a way that also reduced coastal or marine acidification, those technological options might constitute an acceptable control strategy for a state to propose to satisfy a wasteload allocation or total maximum daily load action plan. The environmental implications of directly manipulating ocean waters to reduce their CO2 uptake, however, will raise troubling issues about potential effects on marine ecosystems and protected marine organ- isms, and any regulatory consideration of these options will have to carefully address these possibly severe damages to ocean environments. All of these techniques are at such early stages of development that it is difficult to foresee their environmental impacts, and the regulatory tools that will be needed to deal with them. management, disposal, or release of wastes or pollutants from the facilities (aside from CO2). See discussion supra notes 13-16. 159.Memorandum From Denise Keehner, Director, Office of Wetlands, Oceans, and Watersheds, U.S. EPA, to Water Division Directors, Regions 1-10 (Nov. 15, 2010) (outlining EPA strategy for assessing total maximum daily loads for oceanic acidification), https://www.epa.gov/sites/production/ files/2016-01/documents/memo_integrated_reporting_and_listing_deci- sions_related_to_ocean_acidfication.pdf; Robin Kundis Craig, Dealing , 6 Wash. J. Envtl. L. & Pol’y 387, 426-28 (2016). 160. In particular, the Center for Biological Diversity has aggressively pursued EPA to require affirmative action to address listings of coastal and oceanic waters as impaired for failing water quality standards for acidity. Craig, supra note 159, at 421-28. 161. Id. at 425-28. See also Press Release, Center for Biological Diversity, Legal Settlement Will Require EPA to Evaluate How to Regulate Ocean Acidifica- tion Under Clean Water Act (Mar. 11, 2010), http://www.biologicaldiver- sity.org/news/press_releases/2010/ocean-acidification-03-11-2010.html. V. Conclusion Even if NETs meet the technical and logistical challenges to their adoption, they will still need to surmount legal uncertainties. Certain features of the technology will make it less controversial than other proposed techniques for climate engineering, but some types of NETs could still trigger burdensome obligations to obtain permits based on land use, emissions from associated equipment, and man- agement or disposal of captured GHGs. These technologies could also face unsettled risks from the difficulty of assess- ing their environmental impacts for NEPA. These legal impediments can be proactively addressed through the strategies discussed above. If so, legislators and regulators should provide adequate governance over- sight, ensure that all stakeholders receive opportunities to participate in decisions on risk and management, and help operators identify and manage unexpected or otherwise uninsurable risks. Finally, policymakers should remember that NETs, if they overcome legal impediments to their broad imple- mentation, will still pose important practical challenges. For example, while NETs could complement CCS and agricultural sequestration techniques, they may also com- pete with mitigation approaches. In addition, large-scale production of captured CO2 might cripple carbon credit markets with large volumes of CO2e removal credits for NETs. There is also the risk of moral hazard from wide- scale NETs because it might be politically and economi- cally less painful to withdraw CO2 from the ambient atmosphere than to restrict or minimize the emissions from industries or power generators.162 48 ELR 10432 ENVIRONMENTAL LAW REPORTER 5-2018 162. Faran & Olsson, supra note 134; Royal Society, supra note 28, at 37-39 (assessing moral hazard objections to wide-scale deployment of CO2 tech- nologies); Manya Ranjan & Howard J. Herzog, , 4 Energy Procedia 2869, 2875-77 (2011) (noting moral hazard issues raised by current framings of DAC options).PDF Image | NET Legal Pathways
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