California Air Resources Board

• nzc_stanford_princeton_comments-on-sb-905-solicitation.pdf

The California Air Resources Board (CARB) continues to lead in implementing policy frameworks that support California’s decarbonization goals. The SB 905 solicitation is a critical step toward integrating Carbon Capture, Utilization, and Storage (CCUS) technologies into the state’s climate strategy. cKinetics appreciates the opportunity to contribute insights based on our data-driven analysis of environmental markets and decarbonization mechanisms.

The cCarbon division at cKinetics specializes in business intelligence, analytics, and forecasting for global environmental markets. Since 2012, we have covered the Western Climate Initiative (WCI) and now provide insights on global compliance and voluntary carbon markets (including carbon dioxide removals), sustainable fuels, and other environmental commodities. Our clients rely on our data tools and analyst-driven insights for strategic decisions around compliance, investment, and forecasting.

Regarding SB905, we are tracking technological developments on four fronts:
A. Carbon Capture from point sources
B. Carbon Capture Utilization (CCU)
C. Carbon Dioxide Removal (CDR)
D. Carbon Transportation and Storage

Carbon capture from point sources
This segment is maturing rather quickly. As per cCarbon research, the cost of capture has dropped to values between $45 and $80 per ton of CO2 for point sources such as cement, ethanol production and natural gas power plants. Costs and logistics around carbon transportation and storage need to be addressed. The latter also tend to have a high compliance burden and lead times for implementation.

Coming reduction in the cost of carbon removal
In the last 5 years, over $9.8 billion has been committed to the carbon removal sector, encompassing both engineered and nature-based solutions. This capital is a mix of equity, government grants, and a smaller portion of debt, reflecting an industry in its early stages where risk tolerance is higher and government support is critical for de-risking new technologies

We estimate that against the above investment, approximately 12 million tCO2e of annual removal capacity has been created globally.

The attached note outlines some analysis and inputs related to SB 905

• carb-sb905-solicitation_ckinetics_ccarbon_comments.pdf

Please see attached pdf with comments in response to the Solicitation to Inform Implementation of Carbon Capture, Removal, Utilization, and Storage Program.

• ccusfinal_sb905_programinformation.pdf

Dear Air Resources Board:

Yosemite Clean Energy (YCE) appreciates the opportunity to comment on the implementation of SB 905. YCE is a bioenergy development company that specializes in transforming farm and forest wood waste into carbon-negative hydrogen, renewable natural gas, SAF and other e-fuels. Our process removes carbon from the natural carbon lifecycle by separating the hydrogen and carbon molecules present in wood waste, with the latter being sequestered. This prevents carbon and other dangerous short-lived climate pollutants from being released into the atmosphere when this waste otherwise inevitably decomposes or burns. As such, we submit the below recommendations:

• Include definitions of BECCS and BiCRS and adopt policies to advance these important CCSU pathways, ensuring modelling methodologies acknowledge forest and agricultural biomass pathways (CA-GREET vs H2-GREET)
• Include CCSU in the power sector as well as for other industrial sectors
• Avoid adopting environmental protections that duplicate or exceed existing protections for air or water quality – CCSU should not be held to higher standards than other types of projects
• Adopt permit consolidation requirements that require concurrent rather than consecutive permitting and include specific timelines

1. The Over-Arching Goal of SB 905 Regulations Should be to Accelerate, Not Constrain, CCSU.

Every recent report on how to achieve carbon neutrality has emphasized the need for CCSU to offset emissions that cannot be avoided. As Princeton University’s Net-Zero America report stated, “All pathways rely on large-scale CO2 capture and utilization or storage.” Stanford University, Lawrence Livermore National Lab and others agree with this assessment.

These studies also emphasize the need to ramp up CCSU and other climate solutions quickly. As The Net-Zero America report explains:

“Building a net-zero America will require immediate, large-scale mobilization of capital, policy and societal commitment, including at least $2.5 trillion in additional capital investment (relative to business as usual) into energy supply, industry, buildings, and vehicles over the next decade . . . . major investment decisions must start now, with levels of investment ramping up as the transition proceeds . . . Each transition pathway features historically unprecedented rates of deployment of multiple technologies.”

Deploying this scale of capital and this fast a build rate will require regulatory certainty and much faster timelines at every stage of the process, including the permitting phase. As Stanford said in its report on getting to carbon neutrality, “Time is of the essence . . . 2045 is closer than you think.” It is critical, therefore, that regulatory agencies do not unnecessarily constrain the development of CCSU by imposing stricter environmental standards than are applied to other sectors or frequently moving the goal posts.

YCE urges the Air Board to keep the focus of a CCSU program on policies and incentives to accelerate its deployment, which was the goal of SB 905.

2. A CCSU Program Should Prioritize BECCS and BiCRS.

Bioenergy or biomass with CCSU should be a central focus and priority of the SB 905 program for several reasons:

• BECCS or BiCRS can reduce Short-Lived Climate Pollutants, the most urgent climate solution, in addition to providing CCSU.
• BECCS offers the largest opportunity for carbon negative emissions in California.
• Increasing BECCS can also help to decarbonize the electricity, fuels, and hard to electrify sectors.
• BECCS and BiCRS provide numerous co-benefits, including wildfire mitigation, protection of air and water quality, reduction in landfill waste, and creating good, permanent jobs in a circular economy.

In the near-term, BECCS offers the single biggest opportunity for carbon negative emissions. All major reports that have considered how to achieve carbon neutrality assign a central role to BECCS, both to sequester carbon and to generate carbon negative emissions. As the Net-Zero America study concludes:

“Biomass plays an especially important role because i) it removes CO2 from the atmosphere as it grows and so combustion of hydrocarbon fuels made with sustainable-biomass carbon results in no net CO2 emissions to the atmosphere, ii) it can be converted into H2 while capturing and permanently sequestering its carbon, resulting in a net negative-emissions fuel, and iii) it can similarly be used to make negative emissions electricity and replacements for petrochemical feedstocks (via pyrolysis).”

It is hard to overestimate the significance of BECCS for addressing climate change. According to Lawrence Livermore National Lab, BECCS could generate two-thirds of all the carbon negative emissions needed for California to reach carbon neutrality. Stanford University also estimates that using California’s biogas potential for energy could cut the state’s total carbon emissions by eight percent and recommends coupling bioenergy with CCSU to maximize emissions reductions.

To achieve this, any regulations implemented must enable the use of all eligible waste, with an added emphasis and urgency regarding the highest emitting sectors. As such, we ask CARB to prioritize and expedite CCS pathways that utilize biomass from the highest polluting sectors, such as the forestry and agriculture industries. Multiple studies emphasize the urgent need to curb emissions from these sectors in particular, as major polluting events in these industries – like catastrophic wildfires and pile burning – often undo all other emission-reduction efforts .

YCE targets these waste streams in particular, but new regulatory hurdles at the federal level have slowed plant development. The Department of Energy’s (DOE) Greenhouse gases, Regulated Emissions, and Energy use in Technologies (GREET) model – 45VH2-GREET– established for the Section 45V tax credit, excluded all biomass waste streams apart from corn stover, meaning any bioenergy projects using other forms of biomass have to go through a lengthy administrative process to receive a provisional emissions rate (PER). To prevent worsening the extreme slowdown this arbitrary decision has caused, we urge CARB to use models and methodologies that have both forest and agricultural waste biomass built in.

Given the enormous and unique climate benefits of BECCS and BiCRS, YCE urges the Air Board to include specific CCSU pathways and incentives for bioenergy with CCSU.

3. A CCSU Program Should Include Its Use in the Power Sector.

A CCSU program should include its use in the electricity sector. Given the need for firm power and the many legacy power plants that rely on combustion, including CCSU in the power sector should be a priority of the SB 905 program.

Numerous studies have concluded that achieving 100 percent carbon free and reliable power will require enormous amounts of clean, firm power that is available whenever needed for as long as needed to fill in around solar and wind power. The California Energy Commission has estimated the California will need up to 15,000 megawatts of new, firm power to ensure reliability as the grid deploys more and more intermittent resources such as solar and wind. Other studies estimate that California will need closer to 30,000 megawatts of firm power for reliability and cost-containment. Nationwide, Princeton estimates that the United States will need almost 600 gigawatts of new, firm power to achieve carbon neutrality. Princeton also determined that bioenergy and decarbonized hydrogen could provide 100 percent of that clean firm power.
Environmental Defense Fund has explained why increasing clean, firm power is needed not just for reliability, but to keep electricity rates affordable:
“California needs a significant amount of clean firm power to meet its decarbonization targets while keeping rates affordable. Failing to procure clean firm power will require a massive overbuild of solar and wind that will increase rates by about 65 percent in 2045; by contrast, using clean firm power California could keep rates similar to those found today.”
The Net-Zero America study also found that BECCS was important to maintain electricity reliability while reducing emissions from the electricity sector. The study assumes a significant amount of power in 2050 will be generated from BECCS. And Lawrence Livermore National Lab, in Getting to Neutral, also found that BECCS to hydrogen and electricity are the most cost-effective and beneficial uses of BECCS.

Deploying CCSU in the electricity sector will be critical to maintain reliability, decarbonize firm power sources, and maintain costs while California electrifies more and more end uses.

4. Strategies to Protect Air and Water Quality Should Not Impose Higher Standards than Required for Other Sectors.

YCE supports regulations to protect air and water quality, but urges the Air Board not to impose stricter standards on CCSU than are required for other sectors and not to duplicate federal requirements. California already has the strictest air quality standards in the country and those should apply to CCSU as they do to other sectors. There is no reason to impose CCSU specific standards for criteria pollutants or toxic air contaminants that are already regulated under state and federal law.

On carbon dioxide emissions, YCE urges the Air Board to use the standards adopted by US EPA for Class VI injection wells. Class VI permits require:

• analysis of the CO₂ stream;
• continuous monitoring of injection pressure/rate/volume and annulus pressure/volume;
• quarterly corrosion monitoring;
• groundwater quality/geochemical monitoring above the confining zone;
• well testing; tracking of the CO₂ plume and pressure front;
• surface air and/or soil-gas monitoring;
• adoption of strategies to detect and quantify any surface leakage, and
• reporting of CO2 received, injected, produced, and emissions from equipment leaks and/or venting between the flow meter and wellhead.
YCE appreciates the need to protect public health and safety, but requiring CCSU to meet higher standards than other types of projects would only slow or stop its deployment in California, leading to the far worse outcome of failing to meet the state’s climate goals. Relying on existing state and federal standards strikes the right balance between the need to accelerate CCSU deployment and protecting public health and safety.

5. A Consolidated Permitting Process Should Also Require Concurrent Permitting to Reduce Delays and Conflicts.

YCE strongly supports the use of consolidated permitting, but the consolidated permit process should also require that permit review and development occur simultaneously rather than consecutively. In one recent waste to hydrogen project, the regional air district would not begin its permitting process until both the local Health Risk Assessment (HRA) and the CEQA permit were issued. The HRA and CEQA permits took about 1.5 years, after which the air permit took another 3.5 years, for a combined permitting process of more than 5 years. Had all three permits been reviewed concurrently – rather than consecutively – the project would have saved 1.5 years and millions of dollars in delays. Although this was not a CCSU project, it illustrates the need for concurrent, as well as consolidated, permitting.

As noted above and as every climate study underscores, the need for speed is paramount. Steps to consolidate permitting need to be coupled with steps to accelerate permitting, including concurrent permit review.

Thank you for your consideration of these comments. We look forward to the development of the SB 905 program and to rapid deployment of CCSU in California.

Sincerely,

Thomas Hobby - MBA, MA, MSc. P. Ag

Chief Executive Officer

• 20251006-sb905-implementation-comments-dm.v1.pdf

Please find our response attached.

• graphyte_carb_sb905_comment_letter_final_oct2025.pdf

Dear Ms. Sahota,

Bloom Energy appreciates the opportunity to submit feedback to the California Air Resources Board (“CARB”, or “Board”) as it works to implement Senate Bill (“SB”) 905 (Caballero, Statutes of 2022).

Bloom Energy is a California-based manufacturer of solid oxide fuel cells and hydrogen electrolyzers. The company produces fuel cells for onsite power generation for commercial and industrial customers including hospitals, data centers, wholesalers, manufacturers, education, and research institutions. Bloom Energy’s fuel cells are distinct from other forms of firm generation because they use a non-combustion electrochemical process to convert hydrogen in methane molecules into electricity. Rather than using natural gas as a fuel for combustion, fuel cells use natural gas only as a carrier of hydrogen. This approach to power generation results in reduced carbon emissions, near-zero criteria pollutant emissions and minimal water use. In addition, Bloom’s solid oxide fuel cell systems are skid-mounted and can be deployed for relatively short project lives which, in combination with the inherent fuel flexibility, means fuel cells can be quickly deployed to meet onsite demand.

Critically for the issue at hand, fuel cells are ideally positioned for integration with carbon capture, utilization, and sequestration technologies (“CCUS”). Because they operate without combustion and its associated air emissions, fuel cells allow for carbon dioxide (“CO2”) to be separated from other exhaust constituents far more easily than is possible with combustion processes. When carbon capture technology is combined with Bloom’s generation technology, the result is a reliable, firm energy resource that minimizes air, water, noise, and climate impacts.

Bloom Energy strongly supports CARB’s work on the implementation of SB 905. We see enabling carbon capture, including projects paired with distributed, highly efficient, and modular energy generation systems, as a necessary component to addressing California’s energy supply and reliability challenges while reducing emissions. We support your efforts to quickly develop frameworks to support deployment of CCUS projects.

As part of CARB’s solicitation for feedback for implementation, staff provided a series of questions about program design and considerations for future rulemaking. Bloom Energy offers the following specific responses:

Question 10: What specific criteria pollutants or toxics emissions should be prioritized for monitoring and where along the CCUS/CDR project components (i.e. capture, transport, injection/utilization) should monitoring be prioritized?

The program should prioritize monitoring the main criteria pollutant emissions that are a result of combustion at the point of capture: particulate emissions (“PM”), nitrogen oxides (“NOx”), sulfur oxides (“SOx”), carbon monoxide (“CO”), and volatile organic compounds (“VOCs”). In doing so, different technologies’ impacts to local air quality can be best assessed, thus meeting statutory directives to minimize impacts to local air quality and health.

Question 15: What types of strategies are in use in other regulatory or voluntary programs that could be adapted to meet the statutory requirements?

Similar to our response to Question 10, SB 905 places emphasis on the requirement to minimize co-pollutant emissions and water quality impacts from carbon capture and storage (“CCS”) and CCUS projects enabled under the bill. Non-combustion technologies, such as fuel cells, are ideally suited for supporting SB 905’s air and water quality impact priorities, since they generate power through an electrochemical process that results in virtually zero criteria air pollutants and requires almost no water to run during normal operation. This results in the elimination of the emissions most harmful to air quality and public health. The reduction of co-pollutants also makes non-combustion technologies ideal candidates for carbon capture, since less energy and cost is required to separate CO2 from the emissions stream.

Question 22: What role could projects developed under SB 905 play in these programs and are there other programs or policies in which carbon capture removal, storage, and utilization could play a role for compliance?

Distributed energy projects developed under SB 905 could have the following effects:

• Cap-and-Trade and Low Carbon Fuel Standard (“LCFS”) Integration:
These projects should be eligible for credit under the Cap-and-Trade Program and LCFS, and emissions reductions via CCS and CCUS should be included in the Mandatory Reporting Regulation, corporate climate disclosure rules, and other relevant programs and regulations.

• Utility Procurement
CCUS projects could contribute to utility procurement goals. Ongoing discussions at the California Public Utilities Commission (“CPUC”) around Integrated Resource Planning (“IRP”) have identified CCS and CCUS as a potential tool for meeting reliability and emissions targets. SB 905 can help streamline development and enable utilities to procure CCS/CCUS resources through a unified framework.

• Grant Funding Opportunities
Distributed energy resources with CCS and CCUS may qualify for programs like the Distributed Energy Backup Assets (“DEBA”) initiative, which funds deployment of zero or low-emission technologies. A unified permitting process under SB 905 could enhance competitiveness and access to funding.

Question 23: Are there other things the state could be doing to scale up deployment of projects under SB 905?

In addition to its existing generation portfolio, California faces unprecedented load growth as a result of increased electrification and the expansion of digital infrastructure projects like data centers. In order to meet this load and maintain reliability amid extreme weather events, firm electricity resources with carbon capture must be a component of California’s energy mix. The SB 905 program is an important step for assessing and preparing for increased adoption of carbon capture technologies. In addition to “CCUS technologies” and related projects, which are defined within the statutory language, consideration should be given to those generation technologies that can be paired with CCS and CCUS technologies and result in cost-effective carbon capture at scale and most expeditiously.

Question 26: Should CARB consider adopting project type specific protocols or defining more widely applicable standards, or a combination of both? If CARB were to define key standards applicable to all methodologies as opposed to individual methodologies based on specific technology or storage, what could those look like (i.e. recommendations on existing standards), and would that approach help to scale and innovate in this space faster than development of individual protocols?

While there are many potential pathways CARB may consider creating protocols for, the board risks creating regulatory delays that will limit the amount and scale of carbon capture projects developed. One recommendation Bloom Energy would like to make would be the adoption of a single methodology for quantifying project emissions, sequestration, and providing for ongoing monitoring in sequestration ecosystems as a means of streamlining the Carbon Capture, Removal, Utilization, and Storage Program. CARB should also consider aligning its methodology with those already in common use or which are being developed. The American Carbon Registry, for example, has a draft of such methodologies that, as of submission of these comments, is nearing completion and which is likely to be considered an industry reference.

Bloom Energy appreciates the opportunity to respond to the Board’s solicitation for implementation of the SB 905 Carbon Capture, Removal, Utilization, and Storage Program and hopes CARB will consider the role of distributed generation in the design of the program.

Respectfully Submitted,

Dated: October 6, 2025

/s/ Sara O’Niell

Sara O'Neill
Vice President, Policy
Bloom Energy Corporation
4353 N First St.
San Jose, CA 95134
Tel: 916-802-7386
Email: sara.oneill@bloomenergy.com

• bloom-energy-sb-905-solicitation-response-10.6.25.pdf

Thank you for the opportunity to contribute.

• 2025kolodji-aiche-04102025final-rev-1.pdf
• letter-to-gov-newsom-8162025.docx
• kolodji-resume-42025.pdf
• 00kolodji-response-to-information-solicitation-to-inform-sb905-10062025.docx

Carbon Sequestration: Carbon Capture, Removal, Utilization, and Storage Programs
California Air Resources Board:
Please find the attached subject comments. WSPA appreciates the opportunity to provide these responses to the solicitation.
-Christine Luther Zimmerman

Christine Luther Zimmerman
Director, California Regulatory Affairs

• carb-sb-905-solicitation-document---final_20251006.pdf

Please find attached comments solicited by CARB.

• crc-sb905-pre-rulemaking-comments_final.pdf

We appreciate the opportunity to provide feedback regarding the implementation of SB 905 (Caballero, Statues of 2022). Ocean Visions is pleased to see the creation of the Carbon Capture, Removal, Utilization, and Storage Program for its purpose to evaluate, demonstrate, and regulate carbon dioxide removal (CDR) projects and technology, as well as carbon capture, utilization, and storage (CCUS) technologies.
Ocean Visions is a science-based ocean conservation organization focused on alleviating the unprecedented ocean warming and ocean acidification that are putting marine ecosystem health and reliant economic stability at risk. For the last five years, we have developed core programming to accelerate research and development of marine carbon dioxide removal (mCDR) pathways as necessary complements to the decarbonization required to address these ocean stressors and at scale. We develop open knowledge products and convene and facilitate progress among key actors to increase societal understanding and advance mCDR research, development, and demonstration (RD&D).
Below are responses to questions provided in the California Air Resources Board (CARB) solicitation to inform on the implementation of SB 905.

Definitions
• In addition to the terms defined in statute, are there other key terms that should be defined? Please provide any proposed definitions with applicable citations.
• Are there any definitions in the statute that may require further expansion or clarification?

Given the nascent state of the mCDR field, this is the time to ensure projects are designed to include all crucial elements. To the extent possible, and where relevant in adopting new definitions for undefined terms related to SB 905, we encourage CARB to incorporate terminology inclusive of the environmental and social sciences. Where life and social sciences are not explicitly spelled out for project implementation, they may not readily be included or identified by how significant they can be to a successful operation.
Although SB 905 does not explicitly incorporate life and social sciences into the definition for CCUS and CDR projects, SB 905 indicates that it should be implemented to include evaluations of environmental health and safety and location-specific impacts (e.g., SB 905 ‘Legislative Counsel Digest’, Section 71461(a)(7); Section 71463, Section 71464(a) and (b); Section 71465(b)). Incorporating life and social sciences terminology into relevant new definitions will help to implement the intent of SB 905 and assist in the success of the Carbon Capture, Removal, Utilization, and Storage Program.

Applicability
• Are there suggestions for further description of these categories, or ways to group categories?

We encourage CARB to consider the most likely audience for the category descriptions. The general project categories given are not necessarily ones that are commonly used in communications tools for the public, which could create confusion. For example, it is currently unclear which CDR technologies are included in the category “passive air capture from ambient air.” This describes an action of CDR but does not specifically define the methods (e.g., direct-air carbon capture or DACC) in a way that reflects common understanding.
“Nature-based solutions” may also be too vague a category for CDR. Depending on the audience, certain types of CCUS or CDR projects could be identified as nature-based or be placed into a different category. We suggest adding more specificity for these categories, describing the process or outcome, and/or providing examples of projects as a way for different audiences to understand what is included in each category. Ocean Vision’s MCDR Field Trial Database may serve as a helpful resource for finding such examples and specificity on mCDR methodologies.
Financial Responsibility
• How should the requirements account for scenarios such as ownership transfer, bankruptcy, change of ownership structure, change in insurance carrier, etc.?
• Are there other ways to address investment uncertainty through insurance, or other mechanisms?

We recommend connecting with investigators who are de-risking nature-based solutions for climate change mitigation to gain additional insight. For example, the U.C. Santa Barbara’s Environmental Markets Lab (emLabs) project titled, “Coastal Wetland Restoration: A Nature Based Decarbonization Multi-Benefit Climate Mitigation Solution,” could present information that is helpful in shaping CARB’s needs and role in this context.

Criteria and Toxics Monitoring
• What project-specific air monitoring activities are CCUS/CDR developers currently conducting or intending to conduct, if any?
• What specific criteria for pollutants or toxics emissions should be prioritized for monitoring and where along the CCUS/CDR project components (i.e. capture, transport, injection/utilization) should monitoring be prioritized?

While the question asks about air monitoring, we’d like to offer insights that would ensure CARB has vital information to implement SB 905 for mCDR, as well as terrestrial CDR. Like open air, mCDR field trials will occur in open systems, coastal or open ocean. This means it is critical to ensure that monitoring, reporting, and verification (MRV) methods are at a mature-enough level to enable real-time monitoring at acute dosing events in parallel with modeling MRV. Modeling MRV in tandem with observed MRV from field trial data provides a “digital twin” of the system to provide a predictive model of the field project’s impact. Such modeling also ensures operators can continue to track field project impacts with relative accuracy over the limitations of observational methods. Digital twin activities can apply to any type of monitoring and are very important for tracking potential pollutants or toxics emissions.

• How long should criteria or toxics monitoring be conducted for?

For mCDR, each project’s timeline should be technology-specific to account for long-term impacts (within the 100-year cap) and catered to deployment/dosing periods (i.e., the ratio of observed versus modeled monitoring activities).

• What frequency of monitoring and reporting should CARB consider, and should this differ by project type? Do you have estimates on costs for monitoring and reporting?

Frequency of monitoring and reporting should differ by project type, as CDR technologies are variable and each project’s robust MRV needs will rarely be the same. The frequency should be informed by the current technological capacity feasible for MRV through both modeling and observational lens alongside the needs of the community where the project is sited (e.g., the LOC-NESS project used both observed and modeling monitoring).
• Should CARB consider different monitoring requirements at carbon capture sites versus carbon removals utilizing natural systems?
CARB should consider different monitoring requirements at CCUS sites versus CDR that utilize natural systems because the project and technology needs will differ. For example, the 2025 Carboniferous project proposal and permit request to perform research specifies MRV that is specific for placing sugarcane bagasse at the Orca Basin, a deep anoxic marine basin on the outer continental shelf south of Louisiana. The Carboniferous MRV includes, but is not limited to, monitoring carbon sequestration and storage of multiple tons of matter on the seafloor before, during, and after the biomass has been sunk, in addition to benthic seafloor biodiversity (e.g., microbes) impact assessments. Meanwhile, the 2024 Vesta field trial in Duck, North Carolina conducts coastal ocean alkalinity enhancement with olivine sand. Vesta’s project is using natural wave action to dissolve the olivine through a process known as mineral weathering and thereby remove atmospheric carbon dioxide. This Vesta project’s MRV includes, but is not limited to, sampling the quantity of olivine in the soil, soil transport modeling under normal and abnormal (e.g., hurricane) conditions, and it requires biodiversity monitoring to halt sand placement if species of concern (e.g., whales, sturgeon) are spotted in the project’s implementation zone.
Minimizing Local Water and Air Quality Impacts

• Are there other guardrails that should be considered beyond existing local, state, and federal regulations to minimize impacts? For example, many projects will have to meet the requirements of the California Environmental Quality Act (CEQA), what other requirements should be included and why? If proposing other requirements, please also provide any cost and time estimates for implementation.

We recommend reviewing and considering application of contents in the 2024 White House Environmental Justice Science, Data, and Research Plan.
• Is there any information from existing studies or projects to inform a CEQA analysis for the rulemaking?
We recommend exploring Ocean Visions’ MCDR Field Trial Database, which contains past and ongoing mCDR projects, to inform CARB’s guardrail analysis.
Because organizations like Ocean Visions, among others in the mCDR field, are crafting new resources to understand and reduce potential risks presented by mCDR projects, we encourage CARB to set a regular schedule to review and modify relevant rules for the implementation of SB 905. For example, Ocean Visions is currently driving development of the first comprehensive Environmental Impact Assessment Framework for mCDR to guide responsible development as a standardized resource for assessing risks and benefits of mCDR approaches (anticipated release: 2027).
Permit and Project Portal
• What key issues should CARB address when developing the unified permit application?

CARB could consider the value of using cost-cost or risk-risk analysis within the permit process. Such analysis considers the costs or risks of inaction versus the costs or risks of permitting the project.
• Considering the data and information portal will be voluntary to use, what features of the permit portal would increase the likelihood the portal is used by both project developers and permitting agencies?
Ocean Visions favors open access portals so that information is open and public.
• Are there examples of existing similar systems (e.g. CEQAnet) that CARB should look to when developing the permit portal?
• Are there examples of existing public CCUS project databases that we should look to and/or emulate for public reporting on project deployment?
For platforms to consider emulating, please see the Ocean Visions MCDR Field Trial Database. The database shows a list and map of past and ongoing mCDR projects. CARB may also find value in the mCDR Ecosystem Database which profiles different actors across multiple sectors in the mCDR field and how they are connected.
Integration with Existing State Programs and Potential New Policy Support
• What role could projects developed under SB 905 play in these programs and are there other programs or policies in which carbon capture removal, storage, and utilization could play a role for compliance?

We recommend viewing the U.S. National Marine Carbon Dioxide Removal Research Strategy as a reference in regard to policy and interagency coordination.

Similarly, the Ocean Visions Ocean-based Carbon Dioxide Removal Road Maps may be helpful for scoping critical research CDR gaps that still need to be filled. Such insights could help implement research and permitting, especially for analyzing the benefits of different project applications to California’s net-zero goals and knowledge-building activities.
• Are there other things the state could be doing to scale up deployment of projects under SB 905?
California could consider increasing capacity-building efforts or environmental and social impacts outside of the context of permitting and as standalone project categories due to the cross-cutting benefits such explorations would provide to CDR or CCUS knowledge and permitting. For example, Nawaz and Belotti (2025) and Nawaz et al. (2025) are examples of perspectives and real-time studies on community perspectives with regards to mCDR projects and their impacts, the latter of which was conducted in the same area as mCDR research currently conducted by the Pacific Northwest National Laboratory. This is an example of how social science research in tandem with life and/or physical science research can inform each other on the needs of the community and subsequent levels of feasibility for different mCDR technologies.
Protocols
• Are there certain carbon capture, removal, utilization, and storage project type methodologies that should be prioritized based on existing science, existing methodologies, or implementation experience?

Looking at the ocean space, abiotic mCDR methods are the most thoroughly researched pathway in regard to MRV and scaling for field trials in California. For example, the Port of Los Angeles hosts three mCDR projects (two by Captura and one by Equatic; see the Ocean Visions mCDR field trial database for more information). Specifically, the abiotic method of ocean alkalinity enhancement (OAE) is perceived as technologically feasible based on the state of knowledge into the physical and chemical processes by which it can occur, the robust MRV infrastructure already available and implemented, and OAE’s ability to deliver co-benefits to local ecosystems (e.g., ocean acidification remediation).
The state of the science for OAE should not discount the potential value for researching and developing other mCDR pathways however, as there are distinct advantages, costs, risks, and social acceptance levels associated with different pathways.
• Should CARB consider adopting project type specific protocols or defining more widely applicable standards, or a combination of both? If CARB were to define key standards applicable to all methodologies as opposed to individual methodologies based on specific technology or storage, what could those look like (i.e. recommendations on existing standards), and would that approach help to scale and innovate in this space faster than development of individual protocols?
Regarding CDR protocols, we recommend reaching out to Isometric as a potential thought partner.
Public Project Database
• Are there examples of existing public CCUS project databases that we should look to and/or emulate for public reporting on project deployment?

We recommend our resources, the MCDR field trial database and mCDR Ecosystem Database as examples of publicly available databases.

We look forward to following CARB in the implementation of SB 905 and are available should you have additional questions.

• ov_sb-905-implementation_comment-letter_6oct2025.pdf

Please attached 1PointFive's comments in regard to the SB 905 solicitation.

• sb-905-solicitation-_1pointfive-comments.pdf
• iogcc-model-statute-and-guidance-on-geological-sequestration-of-carbon-dioxide_2025.pdf

Please find Deloitte Consulting LLP's response to "Information Solicitation to Advise Implementation of the Carbon Capture, Removal, Utilization, and Storage Program: Senate Bill 905" attached. If you have any questions, please do not hesitate to contact me.

• deloitte-consulting-llp-response-to-carb-sb-905-information-solicitation.pdf

Find attached InventWood Comments on CARB SB 905 Information Solicitation

• iw_carb-905-comments_final_dhn_2025.10.06.pdf

Sacramento Municipal Utility District Comments on Solicitation to Inform Implementation of Carbon Capture, Removal, Utilization, and Storage Program

• 2025.10.06_smud-response-to-sb-905-information-solicitation.pdf

On behalf of the Coalition for Sustainable Cement Manufacturing & Environment (CSCME), please accept the California Cement Industry's Comments on California's Carbon Capture, Removal, Utilization, and Storage Program (SB 905).

• cscme.sb905.commentletter.vfinal.(10.06.25.pdf

Municipal Utility District Comments on Solicitation to Inform Implementation of Carbon Capture, Removal, Utilization, and Storage Program

• 2025.10.06_smud-response-to-sb-905-information-solicitation.pdf

Please see the attached comments and documents 1PointFive has submitted for the solicitation of SB905.

• sb-905-solicitation-_1pointfive-comments.pdf
• iogcc-model-statute-and-guidance-on-geological-sequestration-of-carbon-dioxide_2025.pdf

Please find our comments attached. Thank you.

• blue-planet_sb-905-solicitation-to-inform-implementation-comments.pdf

This attachment is submitted on behalf of Climate Action California, 350 Humboldt, and Santa Cruz Climate Action Network

• coalition-response-carb-solicitation-to-inform-implementation-of-sb905.pdf

Please see BAC's comments on SB 905 implementation, attached.

• bac-comments-on-carb-sb-905-solicitation.pdf