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INSIGHTi

Siting Challenges for Carbon Dioxide (CO2)
Pipelines
October 27, 2023
Carbon dioxide (CO2) pipelines are an essential part of carbon capture and storage (CCS) systems,
promoted by the Biden Administration and some in Congress to reduce emissions of CO2—a greenhouse
gas—from power plants and other industrial facilities. Approximately 5,000 miles of CO2 pipeline already
operate in the United States, primarily linking natural CO2 sources to oil fields for enhanced oil recovery.
However, a much larger pipeline network would be needed for CCS to meet national goals for greenhouse
gas reduction. Several large CO2 pipeline projects recently have been proposed in the Midwest, but these
projects have encountered public opposition and regulatory challenges, including denial of state siting
permits. One project has already been cancelled. These development challenges raise questions about the
future availability of CO2 pipelines for CCS and the federal role in CO2 pipeline expansion.
CO2 Pipelines in Development
Since 2021, four large CO2 pipeline projects have been proposed in the Midwest which, collectively,
would comprise over 4,000 miles of additional CO2 pipeline (Figure 1). Three projects involve building
new pipelines and one is a pipeline conversion. States have primary siting jurisdiction for new CO2
pipelines, although federal approvals may be required for specific segments (e.g., across waterways).
• Summit Carbon Solutions. Announced in February 2021, Summit’s project would build 2,000
miles of new CO2 pipeline across Iowa, Minnesota, Nebraska, North Dakota, and South Dakota to
support CCS from regional ethanol plants. On August 4, 2023, North Dakota regulators denied
Summit’s pipeline permit application, although on September 15, they granted the developer’s
petition to reconsider. On September 11, 2023, South Dakota denied siting approval to Summit’s
pipelines in that state, although the developer intends to refile its application and remains
committed to the project.
• Navigator CO2 Ventures. Announced in March 2021, Navigator’s Heartland Greenway project
planned to build 1,300 miles of new CO2 pipeline across Illinois, Iowa, Minnesota, Nebraska, and
South Dakota under a similar scheme to that of Summit. South Dakota denied pipeline siting
approval on September 6, 2023. Navigator subsequently asked regulators to suspend pipeline
permit proceedings in Iowa. On October 20, 2023, Navigator announced the cancellation of the
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entire project, citing “the unpredictable nature of the regulatory and government processes
involved.”
• Wolf Carbon Solutions. Announced in January 2022, Wolf Carbon Solutions proposes a new
280-mile CO2 pipeline from electric cogeneration and ethanol plants in Iowa to carbon
sequestration sites in Illinois. The developer filed pipeline permit applications with regulators in
both states in 2023. Both permit reviews are ongoing.
• Tallgrass Energy. Announced in May 2022, the Trailblazer Conversion Project would convert
392 miles of the existing Traiblazer natural gas pipeline to carry CO2 captured from ethanol
production facilities in Nebraska through Colorado to a sequestration site in Wyoming. Currently
an interstate natural gas pipeline, Trailblazer is under the jurisdiction of the Federal Energy
Regulatory Commission (FERC). On October 23, 2023, FERC issued an order approving the
“abandonment” of the Trailblazer mileage for the purposes of conversion to carry CO2. FERC
will no longer have regulatory authority over the pipeline after abandonment is completed.
Figure 1. Proposed CO2 Pipeline Projects in the Midwest

Source: Courtesy of Iowa Renewable Fuels Association, Comparative Economics of Carbon,
Sequestration for Iowa Ethanol Plants. Prepared by Decision Innovation Solutions, LLC, 2023.
Opposition to CO2 Pipelines
In states where CO2 pipeline projects are proposed, some local stakeholders favor their development,
citing job creation, support of ethanol producers, and other economic factors. However, other local groups
have opposed CO2 pipeline projects. The North Dakota Public Service Commission summarized several
reasons for opposition in its Summit permit denial.
The Commission received extensive public comment…. Those testifying expressed broad concerns
regarding eminent domain, safety, the policy of permanent CO2 sequestration and storage, setback
distances, irreparable harm to underground [drainage] systems, impacts on property values, and the
ability to obtain liability insurance.
Other groups object to CO2 pipelines because they believe CCS perpetuates the use of fossil fuels, which
they oppose, or because they believe federal funding for CCS would be better spent on other technologies,
such as renewable energy.

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CO2 pipeline safety is a particular concern. The Pipelines and Hazardous Materials Safety Administration
(PHMSA) has long regulated the safe construction, operation, and maintenance of CO2 pipelines (49
C.F.R. §§190, 195-199). However, a 2020 CO2 pipeline rupture near Satartia, MS, which required a local
evacuation and caused 45 people to be hospitalized, prompted criticism from pipeline safety advocates
about PHMSA’s existing regulations. In May 2022, PHMSA announced a rulemaking to update its CO2
pipeline safety standards. The agency plans to publish a Notice of Proposed Rulemaking in June 2024, but
has not set a date for a final rule. On October 3, 2023, 13 Members of Congress wrote to President Biden
asking for “a moratorium on any federal permitting of new carbon pipelines and related infrastructure
until PHMSA’s safety regulations are finalized.”
Issues for Congress
Cancellation of the Summit project has heightened concerns among some stakeholders about CO2
pipeline development, particularly considering the Biden Administration’s recent announcements of
financial support for regional hydrogen hubs and direct-air capture hubs, both of which may require CO2
pipelines. The Environmental Protection Agency’s proposed carbon pollution standards for fossil fuel-
fired power plants also include CCS as one compliance option. Some analysts assert that the current siting
regime for CO2 pipelines “will be a significant problem if more interstate CO2 pipelines are built.”
Given the siting challenges in the states, certain proposals would federalize interstate CO2 pipeline siting.
In May 2023, the Biden Administration urged Congress to “address the siting of ... carbon dioxide
pipelines and storage infrastructure and provide federal siting authority for such infrastructure.” Some
stakeholders may object to federalization of CO2 pipeline siting authority, however, contending that CO2
pipeline development for CCS is relatively new and that steps can be taken, such as finalizing new CO2
pipeline safety regulations, to facilitate pipeline development without federal preemption. Transporting
CO2 by other modes, such as tanker ship or rail, may also be an alternative.

Author Information

Paul W. Parfomak

Specialist in Energy Policy




Disclaimer
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