Staff is planning to develop a Quantification Methodology (QM) that would properly account for the CO2 emissions sequestered by CCS, and a permanence protocol that would establish the requirements for permanence for CO2 sequestration. The QM and permanence protocol would be referenced by or incorporated into the LCFS and Cap-and-Trade regulations with any appropriate modifications and through the LCFS and Cap-and-Trade Program’s own and separate rulemaking processes. Although the LCFS and Cap-and-Trade Program have their own and separate rulemaking processes and require different accounting approaches (life cycle vs. facility-level accounting approaches), the requirements on sequestration permanence are the same for both programs. Staff plans to develop a single document that contains multiple parts including a permanence protocol along with two QMs for the LCFS and Cap-and-Trade Program respectively.
This concept paper lays out staff’s current vision for what the draft QMs and permanence protocol could contain and what some of the requirements might be. After the release of this concept paper, staff plans to hold a workshop and collect feedback to inform development of the draft QMs and permanence protocol. At the end of this concept paper is a potential outline for the document containing the QMs and permanence protocol parts.
