Practice-based vs performance-based standards for carbon sequestration projects

Abstract Interest in deployment of carbon capture and sequestration (CCS) is at odds with the lack of regulations to guide deployment. This can be resolved by a practice-based regulatory framework focused on data collection, prediction, and iteration. Such a regulatory framework could require operators to undertake behaviors that would empower initial regulatory efforts and tell potential operators what to do and why, not how to do it or to what precision. The most important practices comprise prediction and validation. This approach would have several positive effects, including encouraging would-be operators to invest in site selection, planning, modeling and prediction, monitoring, and regular updating of geotechnical operation.