Submitted Comment Name Mark Jacobson Affiliation Stanford University Subject All synthetic carbon capture and direct air capture increase CO2, air pollution, fossil mining, and pipelines. Message Dear CARB, I am writing this to alert you that the only published papers worldwide that have examined synthetic (as opposed to natural) carbon capture use and storage (CCU/S) and direct air carbon capture (DACCU/S) as a full system (rather than just what happens at the equipment) have found that both only increase CO2, air pollution, fossil mining, pipelines, other fossil infrastructure, energy costs, and total social costs, even in the best case of using renewable energy to power the equipment and pipeline transport. For example, if renewables power CCU/S or DACCU/S, the renewables can no longer be used to replace a fossil source that emits more CO2 as well as air pollution. As such, the CCU/S, DACCU/S increase CO2 and pollution. This is quantified for 149 countries, including the U.S., in this paper (also attached). https://web.stanford.edu/group/efmh/jacobson/Articles/I/149Country/149-… Even when CCU/S is added to ethanol refineries, CO2 and air pollution go up because the same money could have been used to replace flex-fuel vehicles powered by ethanol with battery-electric vehicles powered by wind/solar, reducing CO2 and air pollution a lot more, as shown in this paper. https://web.stanford.edu/group/efmh/jacobson/Articles/Others/23-E85vBEV… There are several other papers similarly finding that CCU/S, DACCU/S are opportunity costs that increases CO2, air pollution, and unnecessary infrastructure. Here are two more, for example: https://www.nature.com/articles/s44458-026-00068-0 https://web.stanford.edu/group/efmh/jacobson/Articles/Others/19-CCS-DAC… There are zero papers ever showing the CCU/S, DACCU/S decrease CO2 or air pollution or costs when the whole system and the opportunity cost is considered. I am asking you to modify your concept statement to clearly state up front that synthetic CCU/S and DACCU/S increase CO2, air pollution, fossil mining, pipelines, other fossil infrastructure, energy costs, and total social costs. Thank you. Sincerely, Mark Jacobson Professor of Civil and Environmental Engineering Stanford University File Upload (i.e., Attachments): 149-countries.pdf N/A
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