The Center for Biological Diversity, Food and Water Watch, and the Center for International Environmental Law appreciate the opportunity to comment on CEQ's Carbon Capture, Utilization, and Sequestration Guidance. Unfortunately, the Proposed Guidance does little to actually guide better understanding of the public health, safety, and environmental risks and impacts of carbon capture, utilization, and storage ("CCUS") deployment, let alone ensure their prevention. Instead, CEQ offers—at best—only vague suggestions that agencies might want to consider these impacts when permitting CCUS projects, and—at worst—unquestioning cheerleading for the rapid adoption of carbon capture technologies that could prolong the use of fossil fuels, forestall adoption of proven and less harmful approaches, and put people's wellbeing and the environment at risk. Please see attached for our detailed comments that detail the Proposed Guidance's shortcomings and offer suggestions for CEQ to transform the Proposed Guidance into something more useful for decisionmakers and the public. After considering the enclosed comments and others—particularly from communities that stand to be most directly impacted by CCUS deployment—we ask that CEQ revise its Proposed Guidance and release another draft for public input, this time with at least 60 days built in for review and consideration by the public.
Carbon Capture, Utilization, and Sequestration Guidance
Activity
Center for Biological Diversity filed 2 comments on this docket between Mar 3, 2022 and Apr 19, 2022. 43 other organizations filed here. The comment window closed 1562d ago.
What Center for Biological Diversity filed (2)
The CEQ announced its goals to "incorporate the input of communities and reflect the best available science" by providing 30 days for public comment on its Carbon Capture, Utilization, and Sequestration Guidance, 87 Federal Register 8808 (February 16, 2022). Yet 30 days is simply not enough time to achieve these goals. On behalf of our collective millions of members and supporters nationwide, the over 100 organizations joining the attached letter request that you extend the period for public comment on the proposed CCUS Guidance to at least 60 days in order to allow for review of CEQ's complex proposal, particularly by communities that stand to be most directly impacted by CCUS projects. An extension of the comment period on the Proposed CCUS Guidance is warranted given (1) the novelty of CCUS at scale and broad scope of issues raised by the proposal; (2) the risks to public safety, health, and the environment posed by CCUS; and (3) the tremendous public interest in this topic. Please let us know of your decision promptly.
Abstract
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View on regulations.gov →Co-filers (43)
See everyone who commented →- Center for Biological DiversityTHIS ORG2 filings · confidence 97%
- Calpine Corporationunverified attribution2 filings · confidence 70%
- CARBON ASSET DEVELOPER ASSOCIATES LLCunverified attribution2 filings · confidence 70%
- AFL-CIO1 filing · confidence 97%
- Air Companyunverified attribution1 filing · confidence 70%
- ALPPA Trade Committeetrade assoc.1 filing · confidence 85%
- American Chemistry Counciltrade assoc.1 filing · confidence 97%
- American Iron and Steel Institutetrade assoc.1 filing · confidence 97%
- American Petroleum Institutetrade assoc.1 filing · confidence 97%
- American Water Works Associationtrade assoc.1 filing · confidence 97%
- BASF Corporationunverified attribution1 filing · confidence 70%
- Battelle Memorial Institutetrade assoc.1 filing · confidence 85%
- BP America Inc.unverified attribution1 filing · confidence 70%
- California Carbon Capture Coalitiontrade assoc.1 filing · confidence 85%
- Carbon Capture Coalitiontrade assoc.1 filing · confidence 85%
- Carbon GeoCapture Corpunverified attribution1 filing · confidence 70%
- Carbon Neutral Coalitiontrade assoc.1 filing · confidence 85%
- Carbon Sink LLCunverified attribution1 filing · confidence 70%
- Carbon Utilization Research Counciltrade assoc.1 filing · confidence 85%
- Center for Negative Carbon Emissions at Arizona State Universityunverified attribution1 filing · confidence 70%
- Climate Justice Alliancetrade assoc.1 filing · confidence 85%
- Edison Electric Institutetrade assoc.1 filing · confidence 97%
- Electrochaea Corporationunverified attribution1 filing · confidence 70%
- Environmental Defense Fundtrade assoc.1 filing · confidence 97%
- Exxon Mobil Corporationunverified attribution1 filing · confidence 70%
- Global Carbon Capture and Storage Institutetrade assoc.1 filing · confidence 85%
- HIF Global LLCunverified attribution1 filing · confidence 70%
- Institute for Policy Integrity at NYU School of Lawtrade assoc.1 filing · confidence 85%
- National Association of Manufacturers (NAM)trade assoc.1 filing · confidence 97%
- National Family Farm Coalitiontrade assoc.1 filing · confidence 85%
- National Ground Water Associationtrade assoc.1 filing · confidence 85%
- National Ocean Industries Associationtrade assoc.1 filing · confidence 85%
- Natural Gas Supply Associationtrade assoc.1 filing · confidence 85%
- Navigator CO2 Ventures LLCunverified attribution1 filing · confidence 70%
- Public Goods Institutetrade assoc.1 filing · confidence 85%
- Responsible Decarbonization Alliancetrade assoc.1 filing · confidence 85%
- San Juan Citizens Alliance and Diné C.A.R.E.trade assoc.1 filing · confidence 85%
- Schlumberger Technology Corporationunverified attribution1 filing · confidence 70%
- Southern Environmental Law Center (SELC)1 filing · confidence 97%
- Svante USA Incunverified attribution1 filing · confidence 70%
- Third Way and the National Wildlife Federationtrade assoc.1 filing · confidence 85%
- U.S. Chamber of Commerce1 filing · confidence 97%
- US Business Council for Sustainable Developmenttrade assoc.1 filing · confidence 85%
- World Resources Institutetrade assoc.1 filing · confidence 85%