California Air Resources Board

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.