California Air Resources Board

Please see attached for a response to this solicitation prepared by environmental justice groups and allies.

• sb-905-ej-ccus-carb-letter.pdf

United Steelworkers response to California Air Resources Board Information Solicitation to Inform re: Implementation of the Carbon Capture, Removal, Utilization, and Storage Program: Senate Bill 905.

• 251006-usw-d12-rfi-comment-to-carb-on-ccus.pdf

Please find Environmental Defense Fund's responses to the SB 905 information solicitation attached.

Thank you.

• sb-905---edf-response,-information-solicitation-oct.-25-combined.pdf

IETA greatly appreciates this opportunity to provide feedback to CARB. Please find attached IETA’s full comments, along with IETA's recently published Geostorage and Carbon Crediting Handbook (Version 2.0).

• ieta-comments-carb-sb905-6oct2025_0.pdf
• ieta_gcs_handbook_2.0_0.pdf

The following response on the 'Information Solicitation to Advise Implementation of the Carbon Capture, Removal, Utilization, and Storage Program: Senate Bill 905' is submitted on behalf of the World Resources Institute (WRI), a global nonprofit research organization focused on global challenges at the intersection of climate change and sustainable development.

• wri---sb905-solicitation---oct-2025.pdf

Charles Davidson
Sunflower Alliance, Researcher

Subject: A Hybrid Renewable Energy Project using Solar PV + Ramping Natural Gas Combined Cycle (NGCC) Electrical Power Plant + Batteries.

Potential Alternative CEQA Project to Carbon Capture and Sequestration (CCS), requiring knowledge of grid modeling and renewable energy integration

The following is a grid-integrated low-carbon and cost-effective renewable energy alternative to the Montezuma Carbon Capture and Sequestration (CCS) Project and other CCS projects—one that would potentially deliver better climate benefits while avoiding serious risks to nearby communities. (1,2)

The Problem with Montezuma CCS
The concern about global warming centers about the methods and the motivation by which society has as its disposal to reduce global CO2 greenhouse gas emissions. There are multiple choices of methods for reducing GHG reductions. The following discussion is two alternative examples of the choices presented in the San Francisco Bay Area. and it includes rough cost-benefit analyses and risk reduction scenarios.

The difference between the two choices is clear:
• CCS utilizes the (maximum) daily full-capacity CO2 emissions produced by the natural gas power plant. And
• The hybrid renewable energy scenario uses local grid-integrated solar PV electricity and battery storage with partial down-ramped natural gas power plant usage during daytime peak solar. (3-6)

The Montezuma project plans to capture CO₂ from three natural gas power plants in Pittsburg and Antioch, then transport it by pipeline (and initially barge it) to Solano County for underground injection beneath the Montezuma injection site. The projects second phase would include capturing emissions from Bay Area refineries.

The CCS approach carries significant dangers:
• Pipeline safety risks: heavier-than-air, ground-hugging CO₂ leaks can cause asphyxiation to individuals in nearby communities and also environmental damage
• Seismic concerns: The injection site sits along the Pittsburg-Kirby Hills Fault that has had two >6.0 magnitude earthquakes in the 1890s.
• Corrosion problems: Impurities from refineries (like H₂S and N₂O) will accelerate pipeline deterioration, in and act synergistically with carbonic acid from H2O intrusion.
• Long-term liability: Taxpayers bear the cost of maintaining fossil fuel infrastructure disguised as climate action and high log-term sunk costs at end of powerplants’ lifetime.

The Superior Alternative: Solar + Flexible Gas Plants + Batteries
Instead of expensive, risky CCS technology, we can achieve deeper emissions cuts through a smarter cost-effective and reduced greenhouse gas production approach:

Deploy large-scale solar and wind power across the Bay Area on abundant brownfields (for example) and along regional power corridors, paired with battery storage where needed.

Use existing natural gas combined cycle (NGCC) plants as flexible "backup" power that partially ramps up and down to follow the sun—running at low capacity during sunny hours and ramping up for evening peak demand. (4-6)

This approach would:
• Cut emissions immediately (not after years of construction)
• Save over a billion dollars in natural gas costs over 20 years
• Avoid pipeline and sequestration risks entirely
• Accelerate renewable energy deployment
• Phase out gas plant dependence as renewable energy and storage capacity expand
• Solar panels have been found to maintain almost all original generation capacity after 30 years

Technical Implementation
The system would work through:
• Automated, weather-adaptive controls to optimize efficiency
• Utility-scale batteries to smooth power plant ramp-up during peak demand
• Protective measures to prevent thermal stress on gas plant equipment
• Strategic renewable siting to improve regional grid stability and resilience and cost

Why This Collaboration Matters
The most valuable deliverable would compare both approaches on cost per ton of CO₂ avoided, engineering viability and reliability, public health benefits, community risk, and deployment timeline.

Subject-matter expertise in gas-fired power plant operations, grid modeling and renewable energy integration could be pivotal in shifting the conversation away from risky CCS schemes toward truly sustainable solutions.

The Urgency
Given the rushed timeline for the Montezuma and numerous other subsidized CCS projects, we need to act quickly to ensure decision-makers have a comprehensive cost-benefit analysis and risk analysis and consider the grid-integrated hybrid renewable energy alternative.

This "solar + flexible gas + batteries" approach represents a potential pragmatic bridge to a much cleaner energy future—one that protects frontline communities, keeps the lights on, and accelerates the integration of renewable energy supplies without locking in decades of unnecessary fossil fuel dependence.

This discussion outlined a cost-effective proposal for hybrid renewable electrical power plant operations using viable and safe daily plant ramping to accommodate high solar PV grid input. These hybrid renewable projects are alternative projects for Carbon Capture and Sequestration.
REFERENCES:
1) SECTION A.I. SITE CHARACTERIZATION 40 CFR 146.82(a)(2), (3), (5), and (6) MONTEZUMA NORCAL CARBON SEQUESTRATION HUB Facility Information Facility name: Montezuma NorCal Carbon Sequestration Hub IW-A1 Facility contact: Jim Levine, Managing Partner 2000 Powell Street, Suite 920 Emeryville, CA 94608 Phone: (510) 409-1765 Email: jim.levine@upstream.us.com Well location: Collinsville, Solano County, California. Collinsville, Solano County, California Lat: 38o 5’ 7.334” N Long: -121o 51’ 30.914” W NAVD 88 Sec 28 T 3 N R 1 E. Application Materials: Montezuma NorCal Carbon Hub (zip). (Class VI Application Materials/Project Narrative.)
2) EPA Region 9. “The United States Environmental Protection Agency, Region 9 (EPA) has identified information or clarification needed for continued evaluation of the site characterization and area of review (AoR) delineation modeling for the Montezuma NorCal Carbon Sequestration Hub Project.” (Letter to Jim Levine. April 3, 2024). “EPA has determined that your response to the RAI does not contain sufficient information to move forward with our technical review of the application. As such, we are temporarily pausing our review, while Montezuma works on updating these portions of the application with essential technical information. (Letter to Jim Levine. August 14, 2024) Application Materials: Montezuma NorCal Carbon Hub (zip). Technical Materials.
3) Interactions between hybrid power plant development and local transmission in congested regions. Lawrence Berkeley National Laboratory. Kemp, Julie Mulvaney, Dev Millstein, James Hyungkwan Kim, Ryan H Wiser (06/2023)
4) Fast-Start HRSG Life-Cycle Optimization. POWER (June 1, 2013) https://www.powermag.com/fast-start-hrsg-life-cycle-optimization/
5) Power Plant Cycling Costs. N. Kumar et al. Intertek APTECH Sunnyvale, CA. NREL (April 2012) https://www.researchgate.net/publication/241910062_Power_Plant_Cycling_…
6) Combined cycle power plants. Siemens Energy. Global (Oct. 2025) https://www.siemens-energy.com/global/en/home/products-services/product…

• a-solar-pv-ramping-ngcc-electrical-power-plant-battery-project-renewable-energy-alternative-to-ccs.docx

Responses to questions in SB 905 information solicitation.

• catf-responses_carb-sb-905-information-solicitation_100325.pdf

Dear Sir/Madam,

Please find attached the feedback. We would be very pleased to discuss further.

Lukas May OBE
Chief Commercial Officer
Isometric

• [2025-10]-feedback-on-sb-905.pdf

Dear Sir/Madam,

We are pleased to provide our feedback in the attached document. We would be happy to discuss this further - please do not hesitate to contact us at the details provided.

Kind regards,

Lukas May OBE
Chief Commercial Officer

• [2025-10]-feedback-on-sb-905.pdf

Hello,

Please find attached Actea's response to CARBS questions regarding implementation of SB905.

Thanks,
Jordan Miller

• actea_carb-response.pdf

We respectfully submit the attached letter in response to CARB's Information Solicitation to Advise Implementation of the Carbon Capture, Removal, Utilization, and Storage Program (SB 905).

• 20251003-cworthy-carb-sb905-comment-letter.pdf

Please see attachment

• npe-response-sb-905-implementation.pdf

Twelve Benefit Corporation (Twelve) is pleased to provide the following comments to the Implementation of the Carbon Capture, Removal, Utilization, and Storage Program: Senate Bill 905.

Question 3 of the solicitation asks "are there project categories missing from this list?" Twelve strongly encourages CARB to include as a project category the capture and utilization of carbon dioxide (CO2) to produce value-added products such as power-to-liquid (PtL) transportation fuels and consumer products. The general project category list included in the Information Solicitation is largely focused on sequestration and storage. In our view, the Program should also have a project category for carbon utilization that encompasses the use of captured CO2 to produce PtL fuels as well as PtL chemicals like naphtha that ultimately may be incorporated into a consumer product (e.g. plastics). This would be entirely consistent with section 39741.4, which authorizes CARB to “adopt protocols to support additional methods of utilization . . . of captured carbon dioxide, including carbon capture for use in products.” In this regard, we take this opportunity to remind CARB that earlier this year, as part of the Low Carbon Fuel Standard (LCFS) amendments, it added “captured CO2” to the LCFS definition of “alternative jet fuel.” See https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2024/lcfs2024/f….

Question 23 of the solicitation asks "are there other things the state could be doing to scale up deployment of projects under SB 905?" We encourage CARB in particular and the state more broadly to revisit CARB’s relatively recent decision as part of the LCFS amendments package to disallow indirect/book-and-claim accounting (i.e., the use of renewable energy certificates (RECs) under the LCFS for renewable or low-carbon intensity electricity that is used in the PtL fuel production process. Twelve’s August 27, 2024, comment letter articulates the shortcomings of this flawed CARB decision and why it hinders the scale-up of carbon utilization deployment projects in California; the comment letter, which includes links to our earlier comments on the indirect accounting issue, is posted in the LCFS public comments docket and is attached for convenience.

Question 25 of the solicitation asks "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?" As intimated in our response to question 3 above, the answer to this particular question is a resounding yes. We urge CARB to adopt a protocol(s) and to prioritize efforts for the utilization of captured CO2 in PtL fuels and PtL chemicals that ultimately get embedded in consumer products, all in support of hard-to-abate industrial sectors like aviation and chemicals production. Once again, we remind CARB that earlier this year, as part of the LCFS amendments, it added “captured CO2” to the LCFS definition of “alternative jet fuel.” In so doing, CARB appropriately acknowledged that “there is a growing interest in producing synthetic fuels by combining hydrogen with captured CO2.” See https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2024/lcfs2024/l…, at page 59.

• twelve_comment_letter_on_carb_s_15-day_notice_final.pdf

The Western Wood Preservers Institute (WWPI), North American Wood Pole Council (NAWPC), Treated Wood Council (TWC), and Railway Tie Association (RTA) are pleased to provide the following comments to the Implementation of the Carbon Capture, Removal, Utilization, and Storage Program: Senate Bill 905. Attached you will find information about how wood products can be used to help California achieve its carbon neutrality goal.

Wood products play a vital role for achieving California’s carbon neutrality goal. The electricity we use is provided via overhead power lines supported by preserved wood utility poles. Vessels that transport cargo rely on preserved wood pilings for many dock and port functions. Commerce is transported by trains which ride on rails built on preserved wood railway ties that create the foundation of the railroad tracks. Vehicles are kept safely on roads with guardrails mounted on preserved wood posts. Farmers and ranchers utilize preserved posts and poles to construct fences for the livestock we consume and to support the agriculture we eat. While preserved wood products have been essential to our daily lives for centuries, the need for them will continue to increase as California works to reduce and store greenhouse gas emissions.

Using wood products (over CO2-polluting materials, like steel, concrete, or composites) increases proper forest management which compounds carbon sequestration and carbon storage. By harvesting and replanting, carbon is transferred from the air to the forests, and then into durable products like utility poles, crossarms, railway ties, foundational pilings, and many other building materials. Without an emphasis on wood products, we don’t believe California will be able to reach its carbon neutrality goal.

• final-carb-letter-on-sb-905-september.26.2025.pdf

List of low cost ways CARB can lower emissions and sequester carbon:
- Mandate all parking lots have trees that can tolerate drought
- Mandate that every household needs to plant and take care of at least one 1 tree in their front yard (lower emissions and cool sidewalks)
- Mandate that for every 1 tree that is cut down for logging operations, 2 trees of the same species are planted in its place (must be native trees suitable for the climate)
- Protect marshlands and wetlands from development in every county.
- Designate redevelopment sites for native tribes or non profits that they can use to redevelop in a sustainable way and if successful after redevelopment, can profit from the land without damaging it.
- plant deciduous, drought tolerant trees on the sides of highways to shade drivers and protect the ground from erosion.
- Cover canals with solar panels

Any program that is designed for carbon capture, removal, utilization and storage should include rigorous validation which is based on solid science including monitoring programs and data informed modeling. In addition it is paramount that nature based climate solutions be a center part of the states portfolio of these projects because of the "shovel ready" status and multiple benefits of these approaches.

CARB should create a structure to incentivize Carbon capture wherever possible. As carbon capture comes in many forms and can be done both through geological formations or through localized carbon capture via plant photosynthesis. CARB should incentivize carbon capture from the latter to promote greater biodiversity in our cities, improve our goals of cleaner air in California and reduce emissions from medium and Heavy-duty vehicles on the roads.

Recent science has shown that restored montane moist meadows capture carbon. Degrading meadows that are drying out release carbon into the atmosphere. Meadow restoration is part of the solution. Permitting reform to get the work completed faster would help increase the pace and scale.

The science behind climate change is irrefutable. With the increasing severity and frequency of drought, wildfire, extreme heat, and other impacts, Californians just have to look out their windows to know that climate change is real and rapidly getting worse. The impacts once thought decades away are happening now. Recent reports detail some of the impacts to the state: 

A 2024 national report ranked California the worst state for natural disasters fueled by a changing climate, with expected annual losses totaling more than $16 billion statewide. 
Home insurance is harder and more expensive to get. Seven of California’s largest property insurers, State Farm, Allstate, Farmers, USAA, Travelers, Nationwide and Chubb recently limited new homeowners policies in the Golden State — raising questions about the stability of the California home insurance market. 
During an 11-year period, exposure to wildfire smoke caused more than 50,000 deaths in California and more than $400 billion in economic impacts. 
During seven extreme heat events over the past decade, California experienced $7.7 billion in losses. 

The board needs to do more scientific research on the matter such as the way it will affect ground water, food, air quality. People live in areas that you want to do this they need professional scientists to assure them not a political agenda.