California Air Resources Board

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.