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Shearman’s Dajani moves to Baker Botts

Mona Dajani has moved to law firm Baker Botts after less than a year at Shearman & Sterling.

Baker Botts has brought on Mona Dajani as a partner in its New York office.

She will become global co-chair of energy infrastructure and hydrogen and co-chair of the firm’s energy sector, according to a news release.

Dajani joined Shearman & Sterling in February of this year, following four years at Pillsbury.

Her global practice has involved representation of some of the largest blue-chip clients worldwide, according to the release. In her over 20 years of practice, she has led numerous energy, sustainability, and infrastructure deals, including on complex mergers and acquisitions/dispositions, project development, financings, joint ventures, restructuring, tax equity and tax credit financings involving energy and related infrastructure facilities in the U.S. and around the world.

The transactions she has led involve solar, wind, hydrogen, hydroelectric and geothermal, as well as ammonia, mobility, various energy deals with data centers, electric vehicles, carbon capture and sequestration, renewable natural gas, biofuels, net-zero technology and other energy transition projects.

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Macquarie invests in Dutch SAF developer SkyNRG

By 2030 SkyNRG aims to build its dedicated SAF facilities in Europe and the US under offtake arrangements with strategic partners.

Macquarie Asset Management will support the growth of sustainable aviation fuels (SAF) with an initial investment of up to €175m in SkyNRG via the Macquarie GIG Energy Transition Solutions (MGETS) Fund.

The investment will support SkyNRG’s next phase of growth and help achieve its goal to become a major SAF producer.

BofA Securities Europe S.A. acted as sole private placement agent to SkyNRG. Clifford Chance LLP acted as legal advisor to SkyNRG. RBC Capital Markets acted as sole financial advisor and Freshfields Bruckhaus Deringer LLP as legal counsel to Macquarie Asset Management.

Additional terms of the investment were not disclosed.

By 2030 SkyNRG aims to build its dedicated SAF facilities in Europe and the US, in cooperation with strategic offtake partners. To date, SkyNRG has secured partnerships with, amongst others, KLM Royal Dutch Airlines and Boeing with envisaged long term commitments of up to €4bn in SAF purchases.

SkyNRG has been at the forefront of the development of SAF since it was founded over 14 years ago by, amongst others, Theye Veen and Maarten Van Dijk. They initially focused on creating a market for SAF and supplied the world’s first commercial flight using SAF in 2011. Since then, SkyNRG has expanded and is active in R&D, advisory services and in selling SAF. Today, the company provides SAF to airlines and corporates around the world and is still one of the leading and most active participants on the SAF market.

The SAF industry is benefitting from significant tailwinds, including voluntary corporate offtake commitments aligned to net-zero targets and growing political and regulatory support. This includes the European blending mandate (ReFuelEU) that requires the use of SAF, and the Biden Administration’s SAF Grand Challenge and the Inflation Reduction Act in the US, which is encouraging the use of SAF via strong tax incentives. By 2050, SkyNRG estimates that such incentives will create demand for up to €650bn of investment in the sector and accelerate the aviation industry’s transition away from fossil jet fuels.

Philippe Lacamp, CEO of SkyNRG, commented: “It is critical that SAF production capacity is developed now to enable the aviation industry to meet its net-zero goals. We are very proud that Macquarie has made this strategic investment in our business and are confident that they, with the ongoing support of our existing shareholders, will provide us with the resources and expertise we need to accelerate our growth journey towards becoming a major player in the SAF industry.”

Mark Dooley, Global Head of MAM Green Investments, said: “We have a track record for backing businesses working at the forefront of the energy transition. This is an exciting milestone for us, as our first SAF investment. SkyNRG has been a pioneer in SAF, with an entrepreneurial spirit and a strong commercial focus. We look forward to collaborating with the SkyNRG team as they grow their business and advance solutions to decarbonize the aviation industry.”

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8 Rivers appoints new CEO

8 Rivers Capital appoints Christopher Richardson to CEO position from law firm White & Case.

8 Rivers Capital, LLC, a decarbonization technology developer, has appointed Christopher F. Richardson as the firm’s new Chief Executive Officer, according to a news release.

He succeeds Dharmesh Patel, who has served for six months as interim CEO and previously served as Vice President and Financial Controller. Patel will ascend to the new position of Senior Vice President of Finance, effective immediately.

Richardson joins 8 Rivers with over 20 years of experience in energy and infrastructure transactions and projects and previously served as the head of the Americas energy and infrastructure projects section at the global law firm White & Case. He was based in the firm’s Houston office, which he established in 2018 as a founding partner.

In this role, Richardson led and managed a team of over 100 lawyers across eight offices in the Americas. Richardson’s expertise on developing, financing, and executing large-scale energy and infrastructure projects and related transactions spans the U.S. and more than 50 countries worldwide.

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Stonepeak acquires 50% stake in Virginia offshore wind farm

The infrastructure fund will acquire a 50% stake in Dominion’s Coastal Virginia Offshore Wind project for $3bn.

Stonepeak, a leading alternative investment firm specializing in infrastructure and real assets, today announced that it has reached an agreement with Dominion Energy to acquire a 50% interest in its Coastal Virginia Offshore Wind project through the formation of an offshore wind partnership.

The project is expected to be the largest offshore wind farm in the U.S. and one of the largest offshore wind farms globally upon completion.

CVOW is a 2.6 GW offshore wind project 27 miles off the coast of Virginia Beach, Virginia capable of serving the power needs of 660,000 homes.

Dominion Energy began developing CVOW in 2013 and is scheduled to begin offshore construction this spring. Construction is expected to be completed by year-end 2026. When fully constructed, each year CVOW will avoid carbon emissions equivalent to removing 1 million cars from the road, and will play an important role in supporting energy security and reliability, and lowering fuel costs by diversifying Dominion Energy customers’ energy supply.

Under the terms of the agreement, at closing Dominion Energy expects to receive proceeds of approximately $3bn, representing 50% of the CVOW construction costs incurred through closing less $145m (the initial withholding), Dominion said in a separate press release.

If the final construction costs of CVOW are $9.8bn or less, excluding financing costs, Dominion Energy will receive $100 million of the initial withholding. Such amount is subject to downward adjustment with Dominion Energy receiving no withheld amounts if the total costs, excluding financing costs, of CVOW exceed $11.3 billion. The transaction is expected to improve the company’s estimated 2024 consolidated FFO-to-debt by approximately 1.0% and reduce the company’s overall financing needs during construction.

Following closing, Dominion Energy and Stonepeak will each contribute 50% of the remaining capital necessary to fund construction of CVOW, provided the total project cost, excluding financing costs, is less than $11.3 billion (mandatory capital contributions). This represents 50/50 cost-sharing up to 15%, or nearly $1.5 billion, higher than the project’s current project budget ($9.8 billion) and up to 20%, or nearly $2.0 billion, higher than the project’s current pre-contingency budget ($9.45 billion).

“Having previously partnered with Dominion Energy, we look forward to extending our relationship through CVOW, which is a fitting addition to our global renewables strategy given its potential to provide meaningful renewable capacity to the U.S., advanced stage of development, and downside-protected fundamentals,” said Rob Kupchak, Senior Managing Director at Stonepeak. “Dominion Energy’s impressive track record building and operating large-scale infrastructure projects paired with Stonepeak’s experience successfully constructing offshore wind assets gives us confidence in CVOW’s path forward, and we are excited to partner with Dominion in delivering this critical renewable energy generation resource to its customers.”

Dominion Energy will continue to oversee CVOW’s day-to-day operations and construction at close, supported by Stonepeak’s expertise in investing in and delivering large and complex renewables and energy infrastructure projects including offshore wind. The transaction is subject to customary and regulatory approvals and is expected to be completed by the end of 2024.

Vinson & Elkins LLP served as legal advisor to Stonepeak. Mizuho Securities USA, through its affiliate Greenhill & Co., and Santander US Capital Markets LLC served as co-financial advisors.

McGuireWoods LLP and Morgan Lewis served as legal advisors to Dominion. Citi and Goldman Sachs & Co. LLC acted as sellside co-financial advisors for the transaction.

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Exclusive: Geologic hydrogen startup raising Series A

A US geologic hydrogen startup that employs electric fracking with a pilot presence on the Arabian Peninsula is raising a $40m Series A and has identified a region in the midwestern US for its first de-risked project.

Eden GeoPower, a Boston-based geologic hydrogen technology provider, is engaged in raising a Series A and has a timeline on developing a project in Minnesota, CEO and co-founder Paris Smalls told ReSource.

The Series A target is $40m, with $10m being supplied by existing investors, Smalls said. This round, the company is looking for stronger financial investors to join its strategic backers.

The company has two subsidiaries wholly owned by the parent: one oil and gas-focused and one climate-focused. The Series A is topco equity at the parent level.

Eden was one of 16 US Department of Energy-selected projects to receive funding to explore geologic hydrogen; the majority of the others are academic lab projects. Eden has raised some $13m in equity and $12m in grant funding to date.

Beyond geothermal

Eden started as a geothermal resource developer, using abandoned oil and gas wells for production via electric fracking.

“We started seeing there were applications way beyond geothermal,” Smalls said. Early grant providers recommended using the electric fracking technology to go after geologic hydrogen reservoirs, replacing the less environmentally friendly hydraulic fracking process typically used.

A test site in Oman, where exposed iron-rich rock makes the country a potential future geologic hydrogen superpower, will de-risk Eden’s technology, Smalls said. Last year the US DOE convened the first Bilateral Engagement on Geologic Hydrogen in Oman.

Early developments are underway on a demonstration project in Tamarack, Minnesota, Smalls said. That location has the hollow-vein rocks that can produce geologic hydrogen.

“We likely won’t do anything there until after we have sufficiently de-risked the technology in Oman, and that should be happening in the next 8 months,” Smalls said. “There’s a good chance we’ll be the first people in the world to demonstrate this.”

Eden is not going after natural geologic hydrogen, but rather stimulating reactions to change the reservoir properties to make hydrogen underground, Small said.

The University of Minnesota is working with Eden on a carbon mineralization project, Smalls said. The company is also engaged with Minnesota-based mining company Talon Metals.

Revenue from mining, oil and gas

Eden has existing revenue streams from oil and gas customers in Texas and abroad, Smalls said, and has an office in Houston with an expanding team.

“People are paying us to go and stimulate a reservoir,” he said. “We’re using those opportunities to help us de-rick the technology.”

The technology has applications in geothermal development and mining, Smalls said. Those contracts have been paying for equipment.

Mining operations often include or are adjacent to rock that can be used to produce geologic hydrogen, thereby decarbonizing mining operations using both geothermal energy and geologic hydrogen, Smalls said.

“On our cap table right now we have one of the largest mining companies in the world, Anglo American,” Smalls said. “We do projects with BHP and other big mining companies as well; we see a lot of potential overlap with the mining industry because they are right on top of these rocks.

Anti-fracking

Eden is currently going through the process of permitting for a mining project in Idaho, in collaboration with Idaho National Labs, Smalls said.

In doing so the company had to submit a public letter explaining the project and addressing environmental concerns.

“We’re employing a new technology that can mitigate all the issues [typically associated with fracking],” Small said.

With electric fracturing of rocks, there is no groundwater contamination or high-pressure water injection that cause the kind of seismic and water quality issues that anger people.

“This isn’t fracking, this is anti-fracking,” Smalls said.
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exclusive

Pennsylvania blue hydrogen DevCo planning project equity raise

A natural gas company has tapped an advisor and is planning to launch a process to raise project equity in the fall for a blue hydrogen production facility with contracted offtake in Pennsylvania.

KeyState Energy, a Pennsylvania-based development company, has engaged a financial advisor to launch a $60m equity process in September, according to two sources familiar with the matter.

Young America Capital is advising on the forthcoming process, the sources said.

The capital raise is for the company’s marquee Natural Gas Synthesis blue hydrogen project in Clinton County, one of the sources said. CapEx for the project is estimated at $1.5bn. OCGI is a pre-FEED investor in the project and the coming equity raise is meant to attract a FEED investor.

The 200 mtpd project has contracted offtake with Nikola Corporation, one of the sources said. In October it was reported that Nikola and KeyState were working towards a definitive agreement to expand the hydrogen supply for Nikola’s zero-emissions heavy-duty fuel cell electric vehicles.

The 7,000-acre natural gas and geologic storage site was formerly known for coal, iron and rail, according to the company’s website.

KeyState Energy did not respond to a request for comment. YAC declined to comment.

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exclusive

Feature: Is the U.S. Midwest still navigable terrain for CO2 pipelines?

Strained efforts to build thousands of miles of carbon dioxide pipelines in the U.S. Midwest could carry major implications for future projects – and for the region’s nascent clean fuels industry. According to one industry CEO, “Ethanol plants are sitting on a gold mine.”

“We’re just not interested.” 

That’s the sentiment that echoes through the testimonies of many landowners at an Iowa Utilities Board public hearing on November 7. The hearing is about Summit Carbon Solutions’ project to build a CO2 pipeline across five states, and the view is summarized in the words of Sue Carter, who owns a farm in the pipeline’s proposed path.

“We feel that it’s not a good idea to sequester the CO2, we feel that it would be detrimental to our farmland, to Iowa, and that we’re just not interested.” 

Summit Carbon Solutions, a private company backed by investors such as TPG Rise Climate, Tiger Infrastructure Partners, and John Deere, is planning to build around 2,000 miles of pipeline to transport CO2 captured at 34 ethanol and sustainable aviation fuel plants to geologic sequestration sites in North Dakota. The proposed network spans across Nebraska, North Dakota, South Dakota, Iowa, and Minnesota. 

The project, which would build one of the largest CO2 pipelines in the world, promises to capture and store up to 18 million tons of CO2 per year, offering the Midwest’s ethanol industry a path to net zero. 

But building is far from easy. 

In September, public service commissions in both North and South Dakota denied key permits to build the pipeline across those states. In Iowa, Summit is encountering staunch opposition from some landowners, who are worried about issues like safety and land preservation, and it is requesting the right of eminent domain over approximately 900 parcels of land. 

Commercial operations, which were initially expected for 2024, have been pushed back to 2026, and the project cost has risen from $4.5bn to around $5.5bn. 

In a country that, according to some estimates, needs to expand its carbon pipeline network more than ten times in 30 years to reach the ambitious goal of net zero emissions by 2050, Summit’s struggle to advance its Midwest project is emblematic of what might soon happen elsewhere. Navigator CO2 Ventures, for instance, has recently canceled a pipeline project in the area after encountering similar problems. 

And the uncertainty around pipeline development might hinder the region’s nascent clean fuels industry, which relies heavily on ethanol production and carbon capture technologies. 

*

Courtesy of Summit Carbon Solutions.

A potential cost increase was something that Summit took into consideration from the start, “whether that was because of factors related to inflation, supply chain shortages, or a longer-than-expected regulatory process,” according to Sabrina Ahmed Zenor, director of stakeholder engagement and corporate communications at Summit. He pointed out that Summit also increased the project’s expected capacity from 12 million to 18 million tons of CO2 since it was first announced. 

Regardless, the way Summit goes about securing success for its project and the extra costs and delays it faces are bound to set an example for developers across the country. 

“We need to see one or many of these projects be successful to develop a model as to how to deploy them,” said Matt Fry, senior policy manager at the Great Plains Institute, a non-profit organization dedicated to supporting carbon management technologies to achieve climate objectives. “We already have some infrastructure to transport CO2, but we just haven’t seen 1,000 to 2,000 miles transporting 10 plus million tons of CO2 a year yet.”

Already, Navigator has canceled its 1,300-mile Heartland Greenway pipeline, which was supposed to carry CO2 across Illinois, Iowa, Minnesota, Nebraska, and South Dakota. The company announced the decision on October 20, citing “the unpredictable nature of the regulatory and government processes involved, particularly in South Dakota and Iowa.”

Permitting regulations regarding carbon pipelines change from state to state. 

“Some states have deadlines or timelines associated with when an application is submitted to when a decision must be granted, which provides certainty. Some places not so much,” said Elizabeth Burns-Thompson, vice president of government and public affairs at Navigator. “Ultimately, the board did not see a pathway forward that was commercially viable.” 

According to Burns-Thompson, Summit’s challenges contributed to the decision as well. Navigator will now focus on a sequestration site in Illinois.  

Asked about Navigator’s cancellation, Summit said it “welcomes and is well positioned to add additional plants and communities to our project footprint.”

On a smaller scale, Wolf Carbon Solutions is also planning a 280-mile CO2 pipeline in Iowa and Illinois, where it filed permit applications in February and June respectively. And in May 2022 Tallgrass Energy announced its intention to convert 392 miles of natural gas pipeline into a CO2 pipeline connecting Nebraska, Colorado, and Wyoming.

*

Pipelines have been carrying CO2 in the U.S. for over 50 years, with the first large-scale carrier built in the 1970s. At the moment, there are around 5,000 miles of active CO2 pipelines in the U.S., mostly carrying the gas to oilfields, where it’s used for enhanced oil recovery. For comparison, the country has around two million miles of natural gas distribution mains and pipelines. 

“There’s a very high likelihood, almost a certainty, that if the US is to reach net zero by 2050, it’s going to need many hundreds of millions of tons of CCS, maybe a billion,” said Chris Greig a senior research scientist at Princeton University, and one of the lead authors of Net Zero America, a study that presents various pathways for the U.S. to achieve the net-zero emissions goal. 

If we capture carbon, we also need to transport it. According to the Net Zero America report, the U.S. would need to develop over 60,000 miles of new CO2 pipelines over the next 30 years, which would come at a capital cost ranging from $170 billion to $230 billion, depending on the overall reliance on carbon capture. 

*

The United States is the largest producer of ethanol in the world, and it mostly produces it in the Midwest, with Iowa leading the charge. 

Ethanol can be used to make sustainable aviation fuel, and its fermentation process emits a CO2 that is almost pure, making it a very good candidate for carbon capture. The CO2 captured at ethanol plants, in turn, can be used to produce clean fuels such as e-fuels, sustainable aviation fuel, or green methanol. 

That means the Midwest is well situated to become a major clean fuel hub, but some say that depends on the successful development of pipelines that can move CO2 at scale.  

Pipelines are not the only way to move CO2, which can be trucked or shipped. But Summit’s project is expected to transport around 18 million tons of carbon dioxide annually, and that would require an army of railcars and trucks, and cost much more. 

Navigator, whose canceled project was supposed to have the capacity to transport 10 million tonnes of CO2 per year, expandable to 15 million tonnes in the future, estimated that it would have had to employ nearly half a million trucks to move the same amount. 

Biofuel maker Gevo has recently vented the possibility of relocating its $1bn Lake Preston Net-Zero-1 sustainable aviation fuel plant if the Summit pipeline doesn’t go through. The Lake Preston project is anticipated to start operations in South Dakota in 2025 

“Failure for the Summit pipeline to be built in South Dakota puts our Lake Preston project at severe risk of being relocated to a more advantageous location that has the availability of CCS,” said Kent Hartwig, Gevo’s director of state and local affairs, at a Brown County, South Dakota, commission meeting on October 3. 

Because of the cancellation of Navigator’s pipeline, a memorandum of understanding between Infinium and Navigator to produce e-fuels was scrapped. Navigator was supposed to provide Infinium with 600,000 tons of CO2 per year for use as feedstock for e-fuels, an amount of CO2 that would require multiple ethanol emission sources tied together to be delivered. Infinium did not respond to a request for comment. 

An alternative could be to produce the fuels in the same place where the CO2 is captured. That’s the business model of CapCO2 Solutions, a company that develops green methanol-producing technology that fits in a shipping crate. 

“Ethanol plants are sitting on a gold mine,” said Jeffrey Bonar, CapCO2’s CEO. And that’s regardless of whether large CO2 pipelines get built. 

CapCO2 is currently raising money to place its first shipping crate at an ethanol plant in Illinois. Eight to ten shipping crates would be able to process all the carbon captured at an average ethanol plant, making green methanol as a result.

According to experts, though, the scale of carbon capture that pipelines can provide is still needed. 

“While it is possible to produce synthetic fuels with CO2, the current scale of these production activities and the markets are not yet able to utilize millions of tons of CO2 per year, so associated CO2 storage would be necessary,” said Fry at the Great Plains Institute. “If we are, as a nation, serious about meeting climate objectives, we’re going to have to figure out how to make this work.”

*

Summit says it has secured voluntary easements for 75%, or around 1,300 miles of the pipeline’s route, and it’s still working to secure rights over all the land it needs. More landowners “are signing every day,” according to Ahmed Zenor, of Summit.

In 2020, a pipeline carrying both CO2 and hydrogen sulfide ruptured in Satartia, Mississippi, sending 45 people to the hospital. The episode was the first major accident involving a CO2 pipeline in at least 20 years — according to the Pipeline and Hazardous Materials Safety Administration’s data, there have been 105 incidents since 2003, and no fatalities — and it spurred an ongoing update of PHMSA safety regulations. 

Among the landowners who don’t want to give Summit access to their land, the incident exemplifies their safety concerns. 

“Pipelines such as the one Summit Carbon Solutions has proposed are highly regulated to ensure public safety,” said Ahmed Zenor in an emailed statement. “In addition to being regulated by the PHMSA, the project is also subject to federal environmental regulations and state oversight.” 

Transporting materials via pipeline, she added, is safer than transporting them via truck or rail. 

The safety concerns mix with a list of worries, including construction spoiling the land, potential leaks contaminating water sources, misuse of public money, and what some landowners describe as generally aggressive behavior from Summit’s agents trying to convince them to sign voluntary easements.  

“They went to nursing homes with donuts to try to convince vulnerable senior landowners,” said Jess Mazour, program coordinator of the Iowa Chapter of the Sierra Club, an environmental organization that’s been active in fighting the pipeline.

Overall, Summit is facing the opposition any linear infrastructure always faces — a Maine transmission line linking hydroelectric dams in Canada to the Northeast, for example, has been slowed down by permitting delays — complicated by a lack of uniform regulations. 

“Siting and construction are dealt with on a state-by-state basis for CO2 pipelines,” said Danny Broberg, associate director for the Bipartisan Policy Center’s energy program. “This is not the case for gas pipelines, for which interstate siting and construction authorities exist through FERC, the Federal Energy Regulatory Commission. One challenge at play for CO2 pipelines is that there is no federal jurisdiction for interstate siting and construction.” 

Stakeholders and legislators have started discussing how to overcome the challenge — if, for example, siting and construction for CO2 pipelines should be through FERC or not — and in May, the Biden Administration urged Congress to consider providing federal siting authority for CO2 pipelines as a priority for facilitating clean energy development. No official proposal is on the table yet. 

Despite the permitting setbacks, Summit says it believes “the regulatory process around pipeline projects works well.” 

*

Eminent domain is, to use the Great Plains Institute’s Fry words, “one of the most contentious things on the planet,” and as activists and opposing landowners have pointed out during the Iowa Utilities Board public hearing, it’s not clear it would apply to CO2 pipelines, at least in Iowa. 

“In Iowa, you can only use eminent domain if it’s a public use and convenience,” said Mazour of the Sierra Club. “And that’s one of our biggest arguments. This is not a public benefit.”

Carbon capture, according to Mazour, is extending the life of a harmful industry. “We don’t believe that ethanol is the best solution to take care of our soils and our water and our rural communities and our farmers,” she said. “And then if we have healthy soils and if we treat the land differently and farm differently, we can actually sequester a lot of carbon in our ground.” 

A better solution, according to Mazour and the Sierra Club, would be to expand deployment of wind and solar. 

Whether Summit is entitled to use eminent domain in Iowa or not is something that will be settled once the Iowa Utilities Board issues its final decision — the public hearing wrapped up on November 8, and there is no deadline they have to meet. 

Additionally, Summit has to refile a permit application in South Dakota, and still gain all the necessary permits in North Dakota, Nebraska, and Minnesota. 

The debate over eminent domain ties to a more general discussion over the benefits and effectiveness of carbon capture technology. Recently, a Bloomberg investigation found that last year Occidental sold its Century carbon capture facility for way less than it spent building it, after the plant never reached its full capacity in over ten years. The Petra Nova carbon capture facility in Texas has also struggled to meet capacity and financial objectives, and it just recently came back online after suspending operations for over two years. 

“Innovation includes risks and some tolerance for failure,” said Broberg at the Bipartisan Policy Center. “It’s going to take the entire toolkit of resources to meet net zero, both from the government and the private sector.” 

*

As the Midwest becomes an incubator for plans and strategies to build CO2 pipelines, and conversations are starting over how to make regulations more uniform, developers are probably going to take a few lessons from Summit and Navigator. 

The most important of these, according to experts, is how to better engage with communities and spearhead education about carbon capture technologies. 

“Everyone’s in a rush to take advantage of subsidies through the IRA,” said  Greig at Princeton University. “But you can’t rush communities, right? I’m not convinced that all the developers have the level of sensitive, forward-looking stakeholder engagement and community engagement and discussion that is going to be necessary.” 

If government entities are serious about developing carbon capture technologies, however, it can’t just be private companies explaining why we need them, according to Navigator’s Burns-Thompson. “It needs to come from the trusted voice of the regulators themselves. And that’s not just state entities. That’s our federal entities as well.”

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