Submission Number: 8655
Submission ID: 60611
Submission UUID: f713a6bb-df06-4071-88ff-e7e601b16de3

Created: Wed, 06/03/2026 - 14:42
Completed: Wed, 06/03/2026 - 14:48
Changed: Thu, 06/04/2026 - 14:04

Remote IP address: 198.99.76.2
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
Scott Rogers
Palmdale Water District
Alternative CCUS Technologies Inclusion in Concept of Potential Regulation

The specific requests are:
- Add definitions for "Non-CO₂ Carbon Storage" and broaden the definition of "Storage" to encompass carbon in non-CO₂ chemical forms;
- Add an explicit applicability category for DAC and point-source capture projects whose storage pathway involves chemical conversion of CO₂ into stable alkaline fluids or minerals;
- Develop a fit-for-purpose geologic storage monitoring and financial responsibility framework for non-CO₂ carbon storage projects that is calibrated to the actual risk profile of these technologies;
- Clarify that the Class II well prohibition in Section 95702(b) is limited to CO₂ injection for EOR and does not restrict the use of Class II wells for non-CO₂ carbon-containing fluid injection by CDR operators;
- Prioritize protocol development for subsurface alkaline fluid storage and ocean alkalinity enhancement;
- Include a provision for CARB review and approval of novel CDR storage pathways not enumerated in the current regulations, and
- Clearly define the co-benefits so there is no ambiguity in the regulations.

N/A