Forest Service Proposed Rule on Carbon Capture and Storage

From Clearpath

This is where all this gets really interesting to me, as it is jostling between different environmental interests- climate vs. traditional preservation types.  So in what used to be our federal lands space, we will have environmental lawyers  and political operatives duking it out, with federal employees doing the NEPA work, the companies rolling the dice,  and the public likely relegated to the bleachers. And without all the partisan rancor featured in other discussions… at least so far.

The proposal published in the Federal Register would exempt carbon capture and storage (CCS) from an existing agency requirement prohibiting permanent or “perpetual” use of such lands.

Because CCS projects would store carbon dioxide in pore space underground for more than 1,000 years after the gas is injected, it would be tantamount to an “an exclusive and perpetual use and occupancy” not allowed under current rules, according to the Forest Service, which is part of the Department of Agriculture.

By exempting CCS from the prohibition on permanent projects, the Forest Service can review proposals and applications and “authorize proposed carbon capture and storage on NFS lands if, where, and as deemed appropriate,” the proposed rule said.

National forests and grasslands could support greater deployment of carbon capture projects, as they offer billions of tons of CO2 storage potential and blocks of land under government ownership, rather than involving multiple owners.

Some environmental and advocacy groups, however, rejected the prospect of allowing CCS projects on Forest Service lands, saying the plan would create pollution, prolong the fossil fuel industry and put delicate ecosystems at risk.

“This serious rule change invites polluters to apply for dangerous CO2-dumping permits in our national forests,” said Victoria Bogdan Tejeda, a staff attorney at the Center for Biological Diversity’s Climate Law program, in an email. “Our forests should be protected for people and wildlife, not handed over to companies for pollution-dumping pipelines that could asphyxiate and kill people if they rupture.”

In response, Scott Owen, a Forest Service spokesperson, said that at this time, the agency “does not have any carbon capture project proposals under consideration.”

Owen said the proposal only changes the initial screening criteria allowing the Forest Service to consider proposals for carbon capture and storage projects.

“All proposals must still pass secondary screening to be accepted as a formal application,” Owen said in a statement. “Carbon capture proposals are still subject to [National Environmental Policy Act] compliance and approval by the authorized officer on the Forest.”

Each forest has an authorized officer that would review individual carbon capture proposals for NEPA compliance prior to approval, Owen added.

The proposed rule also puts forward a definition for CCS where CO2 would not be classified as hazardous waste.

Tara Righetti, a law professor at the University of Wyoming, said in an email that CCS applications for review could be approved “if they met all other criteria required for special use authorizations, including environmental analysis and consistency with the land management plans.”

“When finalized, this rule will mark an important step towards utilization of forest system lands for CCS,” Righetti added.

Xan Fishman, director of energy policy and carbon management at the Bipartisan Policy Center, a think tank, called the rule a positive step forward.

“Fighting climate change is going to be a massive, massive endeavor and it’s going to require a bunch of solutions,” Fishman said in an interview.

Those solutions will involve point source capture, where CO2 emissions are trapped before they go into the atmosphere, and carbon removal, where legacy CO2 is pulled out of the air, he said.

“Opening up every reasonable avenue” to store CO2 is “smart,” Fishman said. “Here’s a way we can store it underground and it doesn’t mess with the rest of the forest for other uses.”

The comment period for the proposed rule ends Jan. 2.


Remember in our discussions of the Rock Springs RMP last week, the Wyofile story talked about how rights of way potentially needed for CCS might be blocked off by the conservation alternative.  Anyway, as the E&E story says:

Some environmental and advocacy groups, however, rejected the prospect of allowing CCS projects on Forest Service lands, saying the plan would create pollution, prolong the fossil fuel industry and put delicate ecosystems at risk.

It could be argued that current wind and solar projects prolong the fossil fuel industry, because they require natural gas backup at least until there are scalable batteries, with minerals and supply chain issues not yet worked out; certainly they create pollution and put delicate ecosystems at risk. To be fair, I think CBD is fairly consistent on not wanting wind and solar, transmission lines, nuclear,  nor mines for strategic minerals. If I’m not understanding their views I hope someone will correct me.

I get that certain ENGO’s (and CAP and some media) seem to hate the fossil fuel industry, but it’s hard to see that fossil fuels are going anywhere soon. Center for Western Priorities (run by D operatives) almost has a story about the oil and gas industry being bad in almost every newsletter.  Scratch the environmental veneer and there seems to be the waferboard of partisan self-interest.

There’s the EIA report from last month:

Electricity generation from renewables and nuclear could provide as much as two-thirds of global electricity generation by 2050, according to the EIA.

Solar and wind show the highest levels of electricity generation growth. Meanwhile, coal and natural gas is expected to make up between 27% and 38% of power generation capacity by 2050, down from about half in 2022, EIA Administrator Joseph DeCarolis said on Wednesday during an event to present the outlook.

I found this from the Clean Air Task Force, but am trusting them on the details.  The basic point is that we need CCS to keep global warming to below 1.5 degrees C with no or limited overshoot, according to the IPCC.

Carbon capture and storage (including DACCS and BECCS) is central to IPCC mitigation pathways

WGIII made clear that carbon capture and storage is a critical decarbonization strategy in most mitigation pathways. Among the 97 assessed pathways that keep global warming to below 1.5ºC with ‘no or limited overshoot’ (meaning a reduced chance of exceeding 1.5ºC in the near term), there is a broad range of possible deployment levels for the technology, with a median average of 665 gigatonnes (Gt) of carbon dioxide cumulatively captured and stored between now and 2100.

WGIII also identifies seven specific pathways, termed ‘Illustrative Mitigation Pathways’ (IMPs) that best summarize and highlight different decarbonization strategies – four that achieve 1.5ºC and three that keep temperatures ‘likely below 2ºC. Only one of the seven IMPs includes no carbon capture. However, this scenario requires global energy demand to nearly halve in the next 30 years, which is socio-politically unrealistic given the existing energy poverty around the world and that energy demand must increase as much of the world industrializes and urbanizes. Even the IMP based on particularly high uptake of renewable energy still requires more than 3 Gt ofcarbon dioxide to be captured and stored annually by 2050 (Figure 3.15 in the full report).


DACCS is direct air capture and storage, and BECCS is bioenergy with carbon capture and storage.

So I guess we gotta do it, according to the IPCC. But not on federal land, says CBD.  And so it goes.. Next post: EIS for thee, but not for me.

2 thoughts on “Forest Service Proposed Rule on Carbon Capture and Storage”

  1. Yo, listen to my idea for the best carbon sequestration project ever. We’ve got a bunch of these things called “trees” that pull CO2 out of the air and lock it away in a substance called “wood”. Left on their own, those trees will eventually either burn up in forest fires or die and rot away, releasing that CO2 back into the environment. So I propose we allow people to go into the forests and cut down a bunch of those trees, and use them to build a bunch of buildings that (if properly maintained) will stick around for hundreds of years, way longer than trees by themselves would. Or if that’s not long enough, we could dig a giant pit encased in concrete and just bury all the trees in that, ensuring all that nasty carbon will never escape. Meanwhile once those trees are removed a bunch more could be planted to take their place and pull even more CO2 out of the atmosphere. How cool is that?

    • Hi Patrick: Way back in 1991 I joked in a paper to an international conference on climate change that we could best store carbon in trees by sinking in the ocean — as Japanese have been charged with doing — so they didn’t rot and could be mined for the benefit of future generations. Most reaction was negative, as if I’d recommended using nuclear energy to “decarbonize” the power grid.

      The problem is that the environmental industry uses taxpayer dollars to challenge almost all logging on federal lands — even after the trees are predictably killed in wildfires instead of being harvested for useful products. That has directly resulted in major damages to rural economic infrastructures, a generational loss of skilled workers, a gross reduction in road access, and legal delays in harvesting dead trees until they lose their commercial value.

      My friend Wayne Knauf, retired Berkeley-trained forester and businessman, suggests that the ruined rural manufacturing infrastructure could be replaced with electricity producing power plants that use wood waste and dead trees for fuel. That way, a goodly portion of the energy and pollution released by these ever-expanding wildfires could be converted to local jobs producing sustainable “green energy” instead. It doesn’t necessarily pencil out as a profitable approach to mitigating much loss due to wildfires, unless partly funded by the $900 billion we are currently losing to wildfires. Then it’s just a “cost of doing business” to the advantage of rural families and communities, American taxpayers, and electricity users.

      Managing a forest for carbon sequestration has always been a fool’s errand. All forests are carbon neutral over time ever since Nature invented wood-decaying fungi. Also, carbon isn’t a thermostat for climate, so there’s that, too.


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