California Air Resources Board

California Air Resources Board:

We appreciate the opportunity to provide feedback regarding potential and partial regulation concepts to establish the Carbon Capture, Removals, Utilization, and Storage (CCUS) Program under Senate Bill 905 (SB 905) (Caballero, Chapter 359, Statutes of 2022).

Launched in 2019, Ocean Visions plays a distinct and critical role in the global response to climate change and ocean degradation. We are an ocean-focused organization working
exclusively on climate disruption as the primary driver of ocean harm, and we work on systemic challenges where solutions are least developed, most complex, or politically difficult—but potentially transformative. Gigaton-scale carbon dioxide removal will be necessary in any scenario that limits warming to 1.5°C or 2°C, making it an essential complement to decarbonization efforts, including in hard-to-abate sectors such as aviation and shipping. Through the Ocean Visions’ “Remove” program, we work to advance foundational knowledge of marine carbon dioxide removal (mCDR) technologies and help
create the enabling policy and governance conditions needed to accelerate responsible testing and development. We generate trusted evidence for informed decision-making on mCDR pathways and serve as a hub of data and knowledge; our programming includes open knowledge products and catalytic convenings with key actors to increase societal understanding and advance mCDR research development and demonstration (RD&D).
Our attachments contain our specific responses to the CCUS Program concepts document, organized by their associated section header. We have also reattached our response to the California Air Resources Board (CARB) RFI request for SB 905 implementation in October 2025, which includes examples and resources that may prove helpful for the agency’s request for
feedback on § 95706.