Regulatory Considerations for Carbon Capture Projects
Permitting a carbon capture project involves unique and challenging regulatory considerations which can take significant time and money to address. For example, assessing air permit applicability requires an understanding of changes in emissions due to the carbon capture project and whether the proposed project will be considered a modification to an existing source or a separate standalone facility. However, due to the novel nature of many carbon capture technologies, changes to air pollutant emissions can be difficult to quantify during early project planning. Additionally, carbon capture projects often trigger the requirements of the National Environmental Policy Act (NEPA), which can take years to complete. It is likewise important to be aware that various components of a project, including eventual carbon off-take, may be considered part of the action under NEPA. This presentation will discuss recent lessons learned from permitting a variety of carbon capture technologies, including important items take into account at the start of project planning.