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Pioneering Change. From the Ground Up.
Public Engagement and the Regulatory Process:
Experiences from an Ac;ve CCS Project
Sallie E. Greenberg, Ph.D. Associate Director – Advanced Energy Technology Initiative
University of Illinois at Urbana-Champaign Junior Professional Legal/Regulatory Tutorial w GCCSIw 10 March 2014
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9 Partnership Geologic Province Target Injection
Big Sky Nugget Sandstone 1,000,000
MGSC Illinois Basin- Mt. Simon Sandstone 1,000,000
MRCSP Michigan Basin- Niagaran Reef 1,000,000
PCOR
Powder River Basin- Bell Creek Field 1,500,000
Horn River Basin- Carbonates 2,000,000
SECARB
Gulf Coast – Cranfield Field- Tuscaloosa
Formation 3,400,000
Gulf Coast – Paluxy Formation 250,000
SWP Regional CCUS Opportunity 1,000,000
WESTCARB Regional Characterization
Injec;on Ongoing
2013 Injec;on Scheduled
Injec;on Scheduled 2013-‐2015
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ü Four Partnerships currently injec3ng CO2 ü Remaining injec3ons scheduled 2013-‐2015
Injec;on began Nov 2011
Injec;on Started April 2009
Core Sampling Taken
Note: Some loca;ons presented on map may differ from final injec;on loca;on
Injec;on began August 2012
DOE Regional Carbon Sequestration Partnerships Phase III: Development Phase
Injec;on started in depleted reef February 2013
Injec;on Started May 2013
Seismic Survey
Completed
3 4
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Large-‐Scale Geologic Tests
Collaboration: • Midwest Geological Sequestration
Consortium, • Archer Daniels Midland Company
(ADM), • Schlumberger Carbon Services, • Additional subcontractors ���
Objective: • Inject 1 million metric tons ���
of anthropogenic carbon dioxide ���at a depth of ~2,130 m
• Demonstrate geological carbon sequestration in a saline reservoir at a site in Decatur, Illinois USA
Illinois Basin – Decatur Project
Cumulative Injection ���(26 February 2014):
750,000 tonnes
Operational Injection: ���17 November 2011
• IBDP fully operational 24/7
• IBDP is the first 1 million tonne carbon capture and storage project from a biofuel facility in the US
• Injection through fall 2014
• Intensive post-injection monitoring under MGSC through fall 2017
C!
800 m
A
B
D
E
1 km
photo by Illinois Dept. of Transportation, 8 November 2010
A. Dehydration/compression facility B. Pipeline (1.9 km) C. Injection well D. Verification/monitoring well E. Geophone well
US EPA Regions
www.epa.gov/superfund/community/tag/whereare.htm
Class III Wells
Class I Class II Class III Class IV Class VI
www.epa.gov
www.epa.gov
Class V
Covers all aspects of CO2 storage from re-‐injec;on to post-‐injec;on site care (PISC). § Geologic site characteriza;on § Dynamic Area of Review § Tes;ng and monitoring of:
§ Mechanical integrity of injec;on wells § Groundwater quality § Tracking plume and elevated pressure
§ Geomechanical and seismic data § Modeling § Injec;on well construc;on requirements § Financial responsibility § Extended post-‐injec;on monitoring and site care
Class VI
sequestration.org/step
Opera;ng in a Complex Regulatory Context
§ Permi_ng in an emerging regulatory framework § Illinois (USEPA Region V) has primacy: IEPA
§ UIC Class I, III, IV, V § UIC Class II through Illinois Department of Natural Resources – Mines and
Minerals Oil and Gas Division § Most recent new Illinois permit for a Class I Non-‐Hazardous well was issued in
1970s § Class V guidance for experimental wells issued § Class VI finalized December 2010, States apply for primacy by September 2011,
reapply for Class VI permits by December 2011 Illinois did not apply for primacy, permit reverts to US EPA Region V
§ Reapplied for Class VI permit in December 2011 § Class VI permit pending with US EPA Region V
IEA Carbon Capture and Storage Legal and Regulatory Review (3rd Edi;on)
Role of stakeholder engagement – Focus on project developer to-‐date – Shid to government and regula;ons
• Aspects more readily undertaken by government? • What is impact of regula;on on engagement and outreach?
• Are CCS laws best tool to determine engagement processes?
• How do stakeholder percep;ons of CCS impact framework?
Engagement Founda;ons
• Interna;onal Finance Corpora;on – World Bank Group
• IAP2 • World Resources Ins;tute Community Engagement Guidelines
• U.S. DOE Public Outreach and Educa;on for Carbon Storage Projects
Pioneering Change. From the Ground Up.
Investigate wAdapt w Engage
Regulators
Local Decision Makers
Project Developers
Successful outreach and engagement around a project does not always translate into successful deployment of CCS in that community.
EffecAve community engagement cannot happen if the community perceives it does not have the ability to influence the decision-‐making process. When the project planning and management can adapt to meet the needs of the community, or engagement can be used to inform project design and operaAon, a mutually beneficial outcome can be reached.
Gaining the trust of the community is the key to successful engagement, and when that trust is broken it can be impossible to regain.
Public engagement will be affected by the local poliAcal and social dynamics, but the structure and design of the engagement process itself is also important.
Engagement and outreach cannot be added on to a project as an aJerthought, but must be integrated throughout the process.
§ no guarantee of public acceptance of CCS
§ helps identify main concerns
§ relationship between project developers, regulators, and communities is key
§ without engagement, public forms own opinions of CCS
§ public has perceived risks
§ no less "real" for implementing outreach
§ can rapidly expand transform into public opposition if ignored.
Starting Point for Stakeholder Engagement:
sequestration.org/step
Knowledgeable stakeholders
Public informed about potential project risks & benefits
Trusted project team
Scientific based information
Two-way communication
MGSC Public Engagement Objectives:
§ Part of portfolio to reduce GHG
§ Based on geologic knowledge of subsurface reservoirs
§ Based in long-standing industrial practices
§ Bridge technology
How we see CCS: Portrayed as Solution or Bridge
Source: IEA 2013 http://www.iea.org/publications
Formal Public Engagement
§ Public notice of permit application § Public comment period § Public can request public hearing § Public hearing § Public comment period § Response to comments § Public issuance of draft permit § Public comment period § Respond to comments § Public appeal period for final permit
Flexibility w Awareness w Respect w Intuition w Adaptation w Knowledge
Informal Engagement
• Began engagement early • Made engagement a priority • Integrated engagement into all
aspects of project management • Made sufficient investment in time
and resources • Sought to understand community • Consulted community • Created, evaluated, and refined
communications plan • Monitored and adapted as needed
Project Perspective: What Worked for MGSC and STEP?
§ How do you know the CO2 is staying where you put it? § What happens in the event of earthquakes?
§ Induced seismicity § Fracture and catastrophic release of stored CO2
§ Where does formation water go when CO2 is injected? § Increased pressure
§ Does CO2 injection fracture rocks during injection? § What are long-term implications of project? § Who is liable if something goes wrong with the project? § How do you know it is safe?
Outcome: Discovery of Common Ground Public Questions Reflect Research Objectives
One cup of ‘super cri;cal’ CO2 equals 277 cups of CO2 at the surface under atmospheric pressure
CO2 is highly compressible
Helping People See through Simple and Powerful Analogy Use: Visualizing volume and pressure implica;ons
One cup of CO2 stored in subsurface
277 cups of CO2 at the surface =
• Public engagement is critical • Projects provide successful
examples of engagement
• Do your homework
• Establish relationships • Talk a lot
– to as many different people as possible
– as often as possible
• Know your audience
• Know your topic
• Prepare • Listen, respond, respect
Take Home Points
sequestration.org/step
§ Regulations will drive monitoring activities § Ongoing and evolving § Research has not yet defined monitoring requirements § Researchers should consider obligation to evaluate commercial needs
§ Environmental baseline essential regardless of regulatory requirements § Risk mitigation § Support CCS primary deployment goals
§ Public engagement guidelines should be exceeded § Proactive approach increases transparency § Move beyond formal engagement requirements
§ Provide balance of information – detail important, but can distract
IBDP Regulatory Lessons
§ Modeling § Generation § Verification
§ Proactively educate regulators § Engage early § Familiarize yourself with regulatory time clock
§ Start early § Seek out examples (publicly available) § Remain flexible
IBDP Regulatory Lessons
Pioneering Change. From the Ground Up.
STEP is a program of the Advanced Energy Technology Initiative,
University of Illinois.
STEP is supported by the U.S. Department of Energy
under Award Number DE-FE0002462 and the Illinois Department
of Commerce and Economic Opportunity #09-484002.
• The Midwest Geological Sequestration Consortium is funded by the U.S. Department of Energy through the National Energy Technology Laboratory (NETL) via the Regional Carbon Sequestration Partnership Program (contract number DE-FC26-05NT42588) and by a cost share agreement with the Illinois Department of Commerce and Economic Opportunity, Office of Coal Development through the Illinois Clean Coal Institute.
• MGSC supports KIOST through the Development of Workflow for
Offshore Geologic Sequestration Storage Demonstration Project (Yr 2)
• The Midwest Geological Sequestration Consortium (MGSC) is a collaboration led by the geological surveys of Illinois, Indiana, and Kentucky.
• Landmark Graphics software via their University Donation Program and cost share plus Petrel software via Schlumberger Carbon Services.
Acknowledgements
“Public engagement around energy and environmental issues represents important opportunities to build greater understanding.” “Communication is never a barrier.”