Submitted Comment Name Andrew Jones Affiliation Carba Subject Comments on SB 905 Pre‑Rulemaking Concepts – Inclusion of Biochar Burial as Durable CDR Message Subject: Comments on SB 905 Pre‑Rulemaking Concepts – Inclusion of Biochar Burial as Durable CDR Dear CARB Staff, Thank you for the opportunity to comment on the Concepts for Potential Regulations for Establishing the Carbon Capture, Removals, Utilization, and Storage Program under SB 905. I am writing to recommend that CARB explicitly include biochar production and land burial as a high‑integrity, durable carbon dioxide removal (CDR) pathway and develop a fit‑for‑purpose MRV and stewardship framework for this pathway. § 95700 – Definitions CARB should explicitly list biochar burial as an eligible CDR pathway. Biochar produced from sustainable biogenic feedstocks and placed in appropriate burial or low-oxygen applications stores carbon for centuries to millennia, comparable to geologic storage on policy‑relevant timescales. Biochar is a hybrid technological–nature‑based solution aligned with California’s climate and land‑based strategies. § 95701 – Applicability SB 905 applies to removals as well as CCS. Biochar burial is a durable removal pathway that avoids the infrastructure and risk profile of geologic injection and should be clearly included. § 95702 – Reporting Requirements CARB should create a dedicated MRV track for biochar CDR, including feedstock chain‑of‑custody, reactor monitoring, biochar carbon characterization, mass/energy balance, burial documentation, and conservative uncertainty discounting. Engineered systems such as Carba’s demonstrate that high‑resolution, instrumented MRV is practical and scalable. § 95703 – Monitoring Requirements Monitoring should be risk‑proportionate. Biochar burial does not pose leakage risks analogous to CO₂ injection wells. Monitoring should focus on site integrity, recordkeeping, and land management, with reasonable monitoring periods supported by conservative upfront crediting. § 95704 – Financial Responsibility Financial responsibility requirements should reflect biochar’s low reversal risk. Stewardship plans and pooled insurance mechanisms are more appropriate than geologic‑style bonding. § 95705 – Protocol Development CARB should prioritize a biochar CDR protocol in early rulemaking. Biochar is commercially deployable today, leverages California’s abundant biomass waste, reduces methane and open burning, and supports wildfire resilience and forest health. § 95706 – Community & Environmental Safeguards CARB should adopt strong feedstock sustainability criteria, prioritizing waste and residue streams and prohibiting harvesting live trees solely for credit generation. Biochar projects can deliver air quality and economic benefits to disadvantaged communities. Additional Recommendations CARB should adopt performance‑based eligibility criteria, integrate SB 905 with AB 1757 nature‑based goals, and credit avoided methane where applicable. Thank you for your leadership in developing a high‑integrity CDR framework. I welcome further engagement as CARB develops pathway‑specific protocols for durable CDR, including biochar burial. Sincerely, Andrew Jones CEO, Carba andrew@carba.com File Upload (i.e., Attachments): N/A N/A
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