1. 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

2. 8
7
1
2
6
5
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
9
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
1
2
7
8
6
5
3
4
Large-­‐Scale
Geologic
Tests

3. 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

4. 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

5. 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

6. US
EPA
Regions
www.epa.gov/superfund/community/tag/whereare.htm

7. Class
III
Wells
Class
I
Class
II
Class
III
Class
IV
Class
VI
www.epa.gov

8. www.epa.gov
Class
V

9. 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

10. 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

11. 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?

12. 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

13. Pioneering Change. From the Ground Up.
Investigate wAdapt w Engage

14.
Regulators
Local
Decision
Makers
Project
Developers

15. Successful
outreach
and
engagement
around
a
project
does
not
always
translate
into
successful
deployment
of
CCS
in
that
community.

16. 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.

17. Gaining
the
trust
of
the
community
is
the
key
to
successful
engagement,
and
when
that
trust
is
broken
it
can
be
impossible
to
regain.

18. 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.

19. Engagement
and
outreach
cannot
be
added
on
to
a
project
as
an
aJerthought,
but
must
be
integrated
throughout
the
process.

20. § 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:

21. 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:

22. § 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

25. 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

26. Flexibility w Awareness w Respect w
Intuition w Adaptation w
Knowledge
Informal Engagement

27. • 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?

28. § 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

29. One
cup
of
‘super
cri;cal’
CO2
equals
277
cups
of
CO2
at
the
surface
under
atmospheric
pressure
CO2
is
highly
compressible

30. 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
=

31. • 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

32. 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

33. § 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

34. 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.

35. • 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

36. “Public engagement around energy and
environmental issues represents important
opportunities to build greater
understanding.”
“Communication is never a barrier.”