Regulatory Uncertainty and its Effects on Monitoring Activities of a Major Demonstration Project: The Illinois Basin - Decatur Project Case

Regulatory uncertainty is a component of carbon storage projects that can significantly affect project resources and timelines. The Illinois Basin - Decatur Project (IBDP) is a one-million tonne, deep-saline CO₂ storage project led by the Midwest Geologic Sequestration Consortium (MGSC) that was initiated before the United States carbon storage regulatory framework was fully developed. To address uncertainty in the evolving regulatory environment, a comprehensive, risk-based, monitoring strategy was used that was expected to be over and above the anticipated new regulatory requirements. Ten years after its initiation, the IBDP has successfully completed the pre-injection and injection phases and is currently in the post-injection site care and monitoring phase. The IBDP experienced two lengthy permitting processes that proved to be the rate-limiting factor for the project, increased the length of time before the project could begin injection, and required additional resources to conduct the project. Future projects are likely to continue to have significant amounts of regulatory uncertainty as their respective project designs and monitoring programs will need to be evaluated by regulators on a case-by-case basis. Operators and regulators alike can benefit from frequent proactive communications during the permitting process in order to significantly reduce the length of the permitting process, maintain the critical safeguards of the Class VI rules, and ultimately meet timely goals for reductions to atmospheric CO₂ emissions.