Technical Monitoring Considerations for Advancing CCS Projects Under the California Low Carbon Fuel Standard in Relation to Other Global Regulatory Regimes

The California Air Resources Board Low Carbon Fuel Standard (LCFS) seeks to reduce GHG emissions associated with transport fuels used in California, including those produced outside the state and imported for use. The LCFS recognises emissions reductions through carbon capture, utilisation and geologic storage (CCUS) and enables these to generate LCFS credits provided that regulatory requirements and guidelines set forth within the LCFS CCS Protocol (CCSP) are met. These guidelines are focused on demonstration of “permanent storage” and environmental integrity which includes the entire storage complex but predominantly focuses in the near-surface and surface. Our analysis of the CCSP indicates several technical challenges with the regulation as written including 1) the requirement of prescriptive monitoring technologies, 2) a non-negotiable 100-year post injection site care period (PISC), 3) the need for meaningful data collection before a project can be certified, and 4) the expectation that environmental variations over the 100+ monitoring period can be predicted from a year of environmental baseline data. We discuss the technical ramifications of these requirements and discuss the ways in which common and low-cost near surface monitoring techniques can best be used to satisfy the requirements in light of new learning in environmental monitoring.