Submitted Comment Name Deepika Nagabhushan Affiliation Project 2030 Subject Broad CDR Applicability, BiCRS Framework, and Phase-Appropriate Financial Responsibility Message Dear Chair Sanchez, Board Members and Staff, Project 2030 is an independent environmental non-profit dedicated to helping California meet its net-zero climate goals equitably and effectively. In 2022, Project 2030 developed the foundational policy concepts that became SB 905, and we have a deep stake in seeing the program implemented well. We appreciate the opportunity to comment on CARB’s preliminary regulatory concepts for the SB 905 Carbon Capture, Removals, Utilization, and Storage Program, and we are grateful for the substantial work that CARB staff have invested in this pre-rulemaking effort. The current concepts are a strong foundation. Our recommendations focus on five areas: 1) Expanding program applicability to all durable CDR pathways; 2) Establishing a definitional framework for biomass-based removal; 3) Creating a quality-based expedited permitting pathway; 4) Leveraging and building upon the existing scientific work on measurement, reporting and verification (MRV) infrastructure currently being used in the VCM (voluntary carbon market); and 5) Ensuring financial responsibility instruments are genuinely accessible throughout the life of the project. Please find our detailed recommendations in the attached PDF. If the attachment did not come through, please refer to our email to the Clerk of the Board sent on June 5th at 12:15 PM, which included the full letter. Respectfully submitted, Project 2030’s CDR Team Bob Epstein, Co-Founder bobsepstein@gmail.com Diane Doucette, Co-Founder doucette.diane@gmail.com Deepika Nagabhushan, Senior Policy Researcher, Deepika.nagabhushan.work@gmail.com File Upload (i.e., Attachments): 32_nagabhushan_project2030.pdf N/A
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