Adaptive management of CCS regulation

The problem:
The technology for carbon capture and deep geological sequestration holds great promise for reducing CO2 emissions. However, we currently lack understanding of a number of key issues including the risks of CO2 leakage and means of quantifying leakage , the availability and applicability of technologies to manage sequestration sites, and large-scale impacts to groundwater flow. Better understanding will require study of large-scale CO2-sequestration projects, presenting a “chicken and egg” problem. Even with extensive site characterization, using the best available tools, there is no way to know with certainty how CO2 will move in the deep subsurface prior to injecting CO2. This has led to calls to adopt an adaptive approach to regulating CCS. Such an approach would allow regulations to evolve over time as they incorporate new knowledge from projects.  It would not require that precise development plans be set in stone before injection begins for a decade long project injecting several million tons of CO2 per year.  Rather, within agreed performance and safety requirements, it would allow plans to evolve over time based on conditions being observed at the site.

The research:
Regulatory agencies have traditionally not been good at being adaptive.  In this research, Morgan, Michael Dworkin, and colleagues will build on the specifics of CCS technology and regulations, and their prior work in the CCSReg project (see CCSReg.org) in order to work on the design of performance-based technical, institutional and legal strategies that would make it possible for a state or federal regulatory agency to implement an approach that is adaptive while assuring that the regulatory framework is effective, and a project is run in a way that protects human health and the environment.  CDMC Advisory Board Member, Bob Fri, has argued that this problem is particularly important, and notes that if we are successful, it may be possible to extend some of the ideas developed to other complex regulatory contexts.

The decision makers:
AEP, EPRI, IRGC, NRDC, Peabody.