SOCAN comments on USDA effort to adjust USFS rules allowing captured carbon to be stored beneath forests

To Whom It May Concern:

I write as cofacilitator of Southern Oregon Climate Action Now (SOCAN), an organization of over 2,000 rural Southern Oregonians who are concerned about the climate crisis and urge statewide action to address it. The mission of SOCAN is to promote awareness and understanding of the science of global warming and its climate chaos consequences and stimulate individual and collective action to address it. Since rural Oregonians occupy the frontlines in experiencing the impact of the drought, shrinking snowpack, wildfires and extreme weather that the climate crisis imposes, we are strongly committed to state and federal action that will address the climate crisis.

I also write as a retired Southeast Missouri State University biology professor, where I taught general ecology for many years. Many of us understand how global warming and its climate change consequences can cause increased hurricane intensity and, through adjusted precipitation patterns, increased drought and thus wildfire risk. However, few residents of the U.S. seem to understand that the projected changes will likely undermine our very life support system by the end of the century if the current trajectory is not averted. It was teaching a section of the ecology course on community ecology that alerted me to the dramatic effects that climate projections, as then proposed, would have on our natural ecosystems. Since then, the projections and the increased likelihood of their coming to pass have only increased. We have reached the point where being alarmed is the only rational response. This means that each and every one of us has to do what we can, both individually and collectively, to address the problem, both by promoting and undertaking adaptation to the climate consequences that are inevitable and mitigation to reduce the more serious outcomes that are avoidable with appropriate action.

General Background and Concerns

As Simon (2023) recently reported in an NPR story, “…lots of American companies have gotten behind a potential climate solution called carbon capture and storage, and the Biden administration has backed it with billions of dollars in tax incentives and direct investments. The idea is to trap planet-heating carbon dioxide from the smokestacks of factories and power plants and transport it to sites where it is injected underground and stored.” Simon explains how controversial the concept is due to the thousands of miles of pipelines necessary to transport the gas. The new proposal, Simon informs us, is that the US Forest Service seeks to change rules to allow an activity currently precluded, namely storing carbon dioxide under our national forests.

The plan, (Federal Register 2023) states that the USDA Forest Service “is proposing to amend its special use regulations, which prohibit authorizing exclusive and perpetual use and occupancy of National Forest System lands, to provide an exemption for carbon capture and storage. The Forest Service is also proposing to add a definition for Carbon capture and storage. This constitutes: “…the capture, transportation, injection, and storage of carbon dioxide in subsurface pore spaces…” While this statement seemingly precludes the use of carbon dioxide to promote fossil fuel extraction, the fact that Enhance Oil Recovery (EOR) was the genesis of CCS raises concerns about whether this would be precluded. If EOR were allowed, it would add to concerns that the effort comprises a fossil fuel corporation greenwashing effort to capture and store carbon while using it en route to extract further fossil fuel.

As defined, according to the proposal, carbon dioxide would be stored in the pore spaces in the soil below our forests where it may remain for 1,000 years.

This definition raises some serious questions about the impact of the process on the biological system that is the soil. As we know (e.g., EESI 2022), promoting the sequestration of carbon in natural ecosystems, especially forests, is critical to our ability to address the climate crisis. Among the natural ecosystems of the planet, as Figure 1 (EEA 2022) indicates among terrestrial ecosystems, forests are only exceeded by wetlands in their capacity to store carbon.

In addition, as Ontl and Schulte (2012) long ago pointed out: “…total C in terrestrial ecosystems is approximately 3170 gigatons (GT; 1 GT = 1 petagram = 1 billion metric tons). Of this amount, nearly 80% (2500 GT) is found in soil ….”Meanwhile, in a recent (as judged by the citations), though undated commentary, WRI (undated) report: “The world’s forests store approximately 861 gigatonnes of carbon, with 44 percent in soil (to one-meter depth), 42 percent in live biomass (above- and belowground), 8 percent in dead wood, and 5 percent in litter.” This source further notes: “Tropical forests store most of their carbon in vegetation (biomass), and boreal forests store vast amounts of carbon in soils.” Sindelar (2015) among many others, made the point that soils are alive. She also noted: “A single handful of soil contains millions of individual living organisms. Many of the ecosystem services provided by soil are actually performed by soil organisms.”

Among the many soil organisms, we find both aerobic and anaerobic organisms. The metabolic processes of the former depend on aerobic respiration which requires oxygen and produces carbon dioxide. The metabolic processes of the latter, however, involve methanogenesis. These organisms exhibit several pathways, but all produce methane, a potent greenhouse gas with a much greater warming effect on a 20-year basis than carbon dioxide. It seems likely that the process of carbon storage described will inevitably deplete the soil of oxygen, thus eliminating aerobic life forms, and creating conditions that are hospitable to anaerobic organisms. In my research regarding the costs and benefits of CCS, I have seen no discussion of the potential risk of promoting methanogenesis in our soils.

In addition to the potential problems delineated above regarding soil organisms, it is important to appreciate that soil is limited in depth. Indeed, the range in depth is from “very shallow (less than 25 cm), shallow (25 cm-50 cm), moderately deep (50 cm-90 cm), deep (90cm-150 cm) and very deep (more than 150 cm)” (Recare 2019). According to Boyle (2005), for example, soils of western forests are between 1 and 2.5 meters deep suggesting that it is unlikely that tree roots, in most forests, do not descend to the full depth of the soil. As noted in Portland (2021): “If the soil is dense and compacted (with no soil pores), there will not be enough oxygen available for respiration. Too much water in the soil will also limit the amount of oxygen the roots can take in.” Presumably, when carbon dioxide is injected into the soils to occupy the soil pores, it will displace the oxygen. This will undoubtedly compromise the ability of tree roots and aerobic microflora and microfauna to access the oxygen they require. The result will be asphyxiation and death of these organisms, destroying the forests and their soils.

In terms of direct health hazard risk Simon (2023) reports that: “If a pipeline breaks, CO2 can displace oxygen, and the plume can be hazardous to humans and anything else that breathes.” In addition, Simon (2023) reports that CO2 is a deadly asphyxiant whether it leaks near a town or elsewhere. Meanwhile, apparently denying the obvious risk from transporting the gas from its site of capture to its deposit site, the proposal itself (Federal Register 2023) reports: “The United States Environmental Protection Agency (EPA) has excluded carbon capture and storage from classification as a hazardous waste (40 CFR 261.4(h)) if carbon dioxide is captured, transported, and stored in compliance with the requirements for Class VI Underground Injection Control wells and the requirements in 40 CFR parts 144 and 146 of the Underground Injection Control Program of the Safe Drinking Water Act, including the requirements for EPA authorization by rule or by permit.” The assertion that the transportation of carbon dioxide constitutes no hazards seems prima facie irrational.

Meanwhile, the proposal (Federal Register 2023) also states: “The Forest Service’s preliminary assessment is that this proposed rule falls within this category of actions and that no extraordinary circumstances exist which would require preparation of an environmental assessment or environmental impact statement.” Given the extensive construction of infrastructure necessary to support this effort, and the potential threat to forest or grassland soils and hydrology from the insertion of carbon dioxide, this claim also seems unjustified.

Consideration of Terminology

Carbon Capture and Storage (CCS) is sometimes equated with Carbon Capture and Sequestration (CCS), though, since ‘sequester’ means ‘capture and store’ the latter phrase contains inherent redundancy. It might be better to distinguish between Carbon Capture and Storage (CCS) defined as the process designed to extract carbon from the atmosphere by technological means and then store it somewhere and retain the concept of Carbon Sequestration solely to refer to the natural biological process of photosynthesis where plants capture and store the carbon in biomass. Then, to confuse the issue further, we also have Carbon Capture and Utilization (CCU) or Carbon Capture, Utilization, and Storage (CCUS).  These last terms incorporate the concept that the captured carbon dioxide can be used in some way and then be stored underground. The most common use is in Enhanced Oil Recovery (EOR) where the gas is employed to extract further oil from depleted reserves. The genesis of the CCS technology was actually to promote this EOR, a gambit that, by extracting further fossil fuel for combustion, simply defeats the entire purpose and benefit of capturing the CO2 in the first place.

Forests as Carbon Sequestration Agents

There is no doubt that our national forests, like forests worldwide, can play a role in addressing the climate crisis.  This role, however, should be confined to promoting the capacity of trees and supporting soils, especially old-growth trees, to sequester carbon through photosynthesis.

Globally forests are estimated to store some 861 Gigatons of carbon in living and dead vegetation and the soil (Pan et al. 2012). Though this represents a very small fraction of the 1.85 billion tonnes of carbon on the planet, it compares more substantially to the 43,500 billion tonnes of carbon in the atmosphere (Envirotech 2019).  Since the carbon load in the atmosphere, largely in the form of carbon dioxide, is a major contributor to global warming and the climate crisis, this indicates the importance of retaining the carbon in our forests and their soils rather than allowing it to dissipate into the atmosphere and add to that load.

Meanwhile, within the mix of forests and forest trees, Senior conservation scientist of Natural United, Ronnie Drever, quoted by Weir (2022) stated: “Old forests are unrivaled in their ability to store carbon.” Indeed, Mildrexler et al. (2020) state: “Large-diameter trees store disproportionally massive amounts of carbon and are a major driver of carbon cycle dynamics in forests worldwide.”

Our forests are valuable agents for sequestering carbon and countering the climate crisis. They should be managed and protected for this capacity rather than compromised.

Carbon Capture and Storage History and Consequences

In its commentary on the 2004 OPEC and the World Petroleum Congress, OPEC (2023) identified the primary purpose for this CCS technology in reporting: “Carbon dioxide emissions from power plants and stationary industrial sources account for more than 60 per cent of global greenhouse gas emissions. However, this CO2 can be captured and stored, and, if injected into depleting oil reservoirs, can increase recovery through an “enhanced oil recovery” (EOR) process. Thus, CO2 capture and storage and EOR present opportunities for the oil industry to participate in activities that will substantially reduce emissions, and, in the case of EOR, increase the recovery from oil fields.”  This illustrates that the process of CCS is lauded by the fossil fuel industry as a way to maintain its business model and profits. We should be very skeptical about a process lauded by the fossil fuel industry as a way to maintain this activity since this is the very business model that is causing the crisis we are seeking to address.

In assessing the climate value of the CCS technology, E3G (2023) report that CCS drives increased energy use, presumably because driving the carbon capture and storage process requires energy. CCS also risks locking in fossil fuel use rather than reducing it as we know is essential if we wish to avert the looming climate crisis. CCS further simultaneously continues the negative health effects consequent upon combustion of these fuels. This last point was echoed by CIEL (2022) where we learn that CCS may actually increase polluting emissions. That report also confirms that an energy penalty is associated with CCS because the process itself demands energy. They report that “the energy penalty increases the fuel requirement for electricity generation by 13–44%.” This analysis also questioned the value of CCS, reporting that the reduction in CO2 emissions in one Texas plant amounted to only 10.8% over twenty years.

Incorporating conclusions from NETL (undated) suggesting that of the 600 billion barrels of oil discovered in the U.S., 2/3 are unrecoverable conventionally, but half of that may be extracted via EOR, Buchsbaum and Donnelly (2023) reiterated the concern that CCS was developed for promoting and is used historically to promote extraction of oil and gas from depleted reserves.

EOR projects currently use about 73% of the carbon dioxide captured annually, while 80- 90% of the carbon captured from the gas industry is used for EOR (Buchsbaum 2023). Robertson and Mousavian (2022) similarly report: “[n]early 3/4ths of CO2 captured annually is reinjected into oil fields to push more oil and gas out of the ground.” These same authors also report that Scope 3 emissions are unaccounted for in claims of carbon capture benefits. As EPA (2023) defines Scope 3, this refers to emissions arising from “assets not owned or controlled by the reporting organization, but that the organization indirectly affects in its value chain.” Clearly, claims regarding the emissions reductions associated with CCS are incomplete and inaccurate. It is, therefore, appalling to see the USFS potentially opening our national forests to EOR under the guise of storing carbon and addressing the climate crisis.

Although E3G (2023) argues: “All other things being equal, capturing and permanently storing emissions is always better than simply continuing to emit…” they add “all unabated fossil fuels should ultimately be subject to a ban.” It might be argued that the CCS activity proposed in this rule adjustment simply removes the carbon from the atmosphere without using it to extract further fossil fuels, but it’s worth noting that fossil fuel corporations claim EOR is the outcome of their use of the carbon dioxide. Those of us exploring this issue remain skeptical that this rule change may actually turn into a means for promoting further fossil fuel extraction under the heading CCUS (Carbon Capture, Use and Storage).

It is worth noting that Joshi (2022) pointed out, referring to the IEEFA study (Roberston and Mousavian 2022): “[i}t found that the only times CCS does work, it’s part of the process of unlocking fossil gas from underground, worsening emissions.” Meanwhile Abdulla et al. (2020) based on analysis of 39 U.S. projects in which they sought an explanation of success versus failure by assessing 12 attributes of projects, reported “While many projects essential to commercializing the [CCS] technology have been proposed, most (> 80%) end in failure.”


In terms of the proposal to install infrastructure permitting the transport and insertion of carbon dioxide to and beneath our national forests, Environmental Impact Studies should be required to evaluate the environmental consequences of the installation of necessary infrastructure and the impact on hydrology and soil microflora and microfauna (including the potential enhanced emissions of methane).

The conclusion regarding CCS seems clear: it has not been demonstrated as a technology that contributes to reducing the threat of the climate crisis, especially when this involves Enhanced Oil Recovery. It is, therefore, inappropriate for the USFS to undertake rule changes that facilitate this activity.

In closing, the admonition of Harvey and Hiar (2023) is worth noting: that “…the technology could become a reason to keep burning fossil fuels is driving a growing division in the scientific community about how much attention and money the world should be devoting to CO2 removal.”

In short, Southern Oregon Climate Action Now) SOCAN strongly opposes this rule change arguing that potentially compromising our forests to promote a failing technology while simultaneously risking the promotion of EOR and the continuation of the very fossil fuel extraction and combustion behavior that is driving the climate crisis is not rational.

Respectfully Submitted



Alan R. P Journet Ph.D.
Cofacilitator,  Southern Oregon Climate Action Now
7113 Griffin Lane Jacksonville, Oregon 97530-9342

Literature Cited

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