Siting Challenges for Carbon Dioxide (CO2) Pipelines
link to page 2 
INSIGHTi
Siting Challenges for Carbon Dioxide (CO2)
Pipelines
Updated November 30, 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 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 ethanol plants. On August 4, 2023, North Dakota regulators denied Summit’s
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.
• 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
entire project.
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• 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. On November 20, 2023, in response to a permit denial
recommendation from Illinois Commerce Commission staff, the developer announced the
voluntary withdrawal of its application in that state with plans to reapply in 2024. The Iowa
permit review is 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 approved 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. North Dakota regulators summarized several reasons for stakeholder
opposition in its Summit permit denial.
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.
CO2 pipeline safety is a particular concern. The Pipelines and Hazardous Materials Safety Administration
(PHMSA) has long regulated CO2 pipeline safety. However, a 2020 CO2 pipeline rupture near Satartia,
Congressional Research Service
3
MS, which required a local evacuation and caused 45 people to be hospitalized, prompted criticism from
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.” The proposed PIPES Act of 2023 (H.R.
6494) would require PHMSA to finalize its CO2 pipeline safety standards within a year of enactment.
Issues for Congress
Cancellation of the Navigator 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
Congressional Research Service
4
Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan shared staff
to congressional committees and Members of Congress. It operates solely at the behest of and under the direction of
Congress. Information in a CRS Report should not be relied upon for purposes other than public understanding of
information that has been provided by CRS to Members of Congress in connection with CRS’s institutional role.
CRS Reports, as a work of the United States Government, are not subject to copyright protection in the United
States. Any CRS Report may be reproduced and distributed in its entirety without permission from CRS. However,
as a CRS Report may include copyrighted images or material from a third party, you may need to obtain the
permission of the copyright holder if you wish to copy or otherwise use copyrighted material.
IN12269 · VERSION 8 · UPDATED
INSIGHTi
Siting Challenges for Carbon Dioxide (CO2)
Pipelines
Updated November 30, 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 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 ethanol plants. On August 4, 2023, North Dakota regulators denied Summit’s
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.
• 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
entire project.
Congressional Research Service
https://crsreports.congress.gov
IN12269
CRS INSIGHT
Prepared for Members and
Committees of Congress
Congressional Research Service
2
• 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. On November 20, 2023, in response to a permit denial
recommendation from Illinois Commerce Commission staff, the developer announced the
voluntary withdrawal of its application in that state with plans to reapply in 2024. The Iowa
permit review is 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 approved 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. North Dakota regulators summarized several reasons for stakeholder
opposition in its Summit permit denial.
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.
CO2 pipeline safety is a particular concern. The Pipelines and Hazardous Materials Safety Administration
(PHMSA) has long regulated CO2 pipeline safety. However, a 2020 CO2 pipeline rupture near Satartia,
Congressional Research Service
3
MS, which required a local evacuation and caused 45 people to be hospitalized, prompted criticism from
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.” The proposed PIPES Act of 2023 (H.R.
6494) would require PHMSA to finalize its CO2 pipeline safety standards within a year of enactment.
Issues for Congress
Cancellation of the Navigator 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
Congressional Research Service
4
Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan shared staff
to congressional committees and Members of Congress. It operates solely at the behest of and under the direction of
Congress. Information in a CRS Report should not be relied upon for purposes other than public understanding of
information that has been provided by CRS to Members of Congress in connection with CRS’s institutional role.
CRS Reports, as a work of the United States Government, are not subject to copyright protection in the United
States. Any CRS Report may be reproduced and distributed in its entirety without permission from CRS. However,
as a CRS Report may include copyrighted images or material from a third party, you may need to obtain the
permission of the copyright holder if you wish to copy or otherwise use copyrighted material.
IN12269 · VERSION 8 · UPDATED