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UPSTREAM EP ADVISORS
Where Technical Insight Meet Business Solutions
Policy & Regulations - We Can Help You
Do you find regulatory and permitting issues for CCUS confusing??
Don't worry, we can help you with Policy & Regulation as you start your CCS project in USA. We can guide you early on how it can impact your permitting process and profitability profile by answering questions like:
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What are the Federal 45Q credits? How they impact CO2-EOR & Aquifer storage projects?
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What are Cap & Trade Credits? How does it improve value of my project?
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What are Low Carbon Fuel Standards (LCFS)? How do they make my project profitable?
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How do I qualify to get California LCFS credits for my CCS project?
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What are EPA Subpart RR or UU of GHG Reporting Program
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What is Underground Injection Control ("UIC") Program & permit requirement
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What are Class-II & Class-VI injection wells? What are the permitting requirement?
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Does Class-VI well permit automatically qualifies my project for LCFS credits (No)??
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What are the differences between EPA CCS requirements & GHG Protocol requirement?
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And many other questions that help you start the project quickly.
Following observations are relevant in operational or under construction CCS projects
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Historically, US CCS projects are dominated by CO2-EOR due to; either low cost of CO2 capture from Natural Gas Processing plants or CO2 from underground reservoirs.
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The CO2-EOR (utilization) projects are Class-II injection Well with fewer EPA regulations
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The dedicated CO2 projects (Storage) in saline aquifer or depleted fields require Class-VI injection wells with stringent regulations for permitting and post site-closure site care.
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The revenue from enhanced CO2-EOR recovery (utilization), eliminates the need of grants.
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The storage projects in saline aquifer with no revenue models require grants/incentives
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In 2018 Federal 45Q credit ($50 for CO2-storage; $35 for CO2-EOR) were approved.
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Cap & Trade credits and Low Carbon Fuel Standards (LCFS) are administered by states (example California), they provide additional revenue.
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Carbon tax is not a popular way of carbon pricing
![C&T Credits.jpg](https://static.wixstatic.com/media/b6d3c7_250f8e89e6dc4244834bfbf9fe38e81b~mv2.jpg/v1/fill/w_108,h_80,al_c,q_80,usm_0.66_1.00_0.01,blur_2,enc_auto/C%26T%20Credits.jpg)
![CCS Policy & Regulations.jpg](https://static.wixstatic.com/media/b6d3c7_293b7c98356e42ed97d398d7906984c9~mv2.jpg/v1/fill/w_130,h_172,al_c,q_80,usm_0.66_1.00_0.01,blur_2,enc_auto/CCS%20Policy%20%26%20Regulations.jpg)
2- Overview of Policy & regulations in planned projects
![Screen Shot 2021-08-10 at 3.12.41 PM.png](https://static.wixstatic.com/media/b6d3c7_7f92d0f2027c42f8a2188cd290b97c62~mv2.png/v1/fill/w_88,h_40,al_c,q_85,usm_0.66_1.00_0.01,blur_2,enc_auto/Screen%20Shot%202021-08-10%20at%203_12_41%20PM.png)