Direct Air Capture: Assessing Impacts to Enable Responsible Scaling

Policy and Procedural Recommendations

Equitable DAC scale-up will require federal and subnational governments and project developers to enact and adhere to good practices. The following recommendations are based on our analysis and focus on environmental and social impacts of DAC, rather than DAC scale-up overall.

Procedural Recommendations

Early DAC projects will be critical for building understanding of and trust in the technology and laying the groundwork for equitable community participation. While public engagement may not ensure acceptance of DAC, local stakeholders need to be engaged in siting decisions and planning processes to increase likelihood of buy-in and to secure locally desirable outcomes (Moser and Pike 2015).

Engaging communities early in planning decisions related to DAC can improve information flow and integration of diverse perspectives and ensure that communities receive project benefits. Community engagement and effective communication can also prevent perception of opaque, bureaucratic, or unilateral decision-making (Katsonis 2019). Robust documentation of engagement processes and outcomes will also help to address the current lack of research on potential social impacts of DAC (Forbes et al. 2009; Groundwork USA 2021). Procedural steps and legal agreements that enshrine community benefits in project planning should become standard practice in DAC development, including the following:

  • Social Impact Assessment (SIA): SIA is a process that assesses the intended and unintended social impacts of development. Conducting SIAs alongside environmental impact assessment prior to energy or infrastructure development projects ensures that project developers are considering options to mitigate adverse social impact from a project’s outset.
  • Community Benefits Agreement (CBA): CBAs are negotiated legal agreements between coalitions of community groups and project developers that guarantee community benefits in exchange for a community’s agreement not to oppose the project. Benefits secured through CBAs can include local hiring and procurement agreements, reduction of environmental impacts during construction and operation, and other benefits tailored to unique community needs.
  • Project Labor Agreement (PLA) and Community Workforce Agreement (CWA): A PLA is a negotiated agreement between construction companies or contractors and unions, agreeing to terms for the project. Projects with PLAs require contractors to use union labor and include no-strike agreements in exchange for dispute resolution agreements. CWAs are provisions within PLAs that require the contractor to hire a negotiated percentage of local, low-income, or other marginalized workers, collaborate with local organizations to provide job training programs, and agree to job quality specifications.

Federal Policy Recommendations

Federal action can play an outsized role in accelerating responsible deployment of DAC, and federally mandated practices can set the standard for future DAC development. Congress has already recognized the importance of funding DAC: appropriations for DAC research development and demonstration (RD&D) are increasing year-on-year, and the Infrastructure Investment and Jobs Act (IIJA) includes $3.5 billion for four megaton-scale DAC hubs. The Department of Energy has also recently launched Carbon Negative Shot, to decrease the cost of all forms of carbon removal to below $100/tCO2. With these monumental investments in DAC, the federal government can ensure that public engagement, equity, and environmental justice are central to the development of all projects that receive federal funding. The Obama administration’s 2009 Executive Order 13502 set precedent for this by encouraging agencies to use project labor agreements for large construction projects (Carlock et al. 2021). More recently, the Biden administration’s 2021 Executive Order 14008 identified environmental justice and equity as key components of climate action across the federal government. The executive order directs agencies to create strategies for addressing environmental injustices, increase enforcement of environmental violations that disproportionately affect marginalized communities, and improve environmental monitoring and transparent reporting in frontline communities.

The following recommendations would build on existing federal momentum to enable responsible and equitable development and deployment of DAC. Other investments and initiatives will be needed to scale DAC, but these recommendations address federal action that could reduce the environmental impact of DAC and secure community benefits. The federal government could require that all DAC projects receiving federal funds do as follows:

  • Complete social and environmental assessments to identify siting locations that are socially and environmentally acceptable.
  • Engage in robust community engagement processes using skilled facilitators to ensure that all stakeholders, including marginalized community members, can choose to provide input on project development.
  • Encourage the use of legal agreements such as CBAs, PLAs, and CWAs, to ensure communities and workers can negotiate benefits they expect to receive.
  • Where possible, require that local labor and locally sourced, low-carbon material be used for construction and plant operation.
  • Where possible, require that DAC plants be powered by low- or zero-carbon energy sources and discourage the construction of new natural gas infrastructure.
  • Establish job training programs in communities adjacent to DAC plants and establish standards to ensure high-quality employment.

Federal agencies, including the Department of Energy, U.S. Geological Survey, and the Environmental Protection Agency can conduct RD&D to improve the technology and decrease the cost of DAC components as well as investigate methods to minimize and manage community and environmental impacts of DAC. Interagency research could prioritize the following:

  • Conduct thorough life-cycle assessments of DAC plants and supporting supply chain, transport, and storage infrastructure, to account for different geographies, energy sources, and DAC plant configurations. Research could also investigate potential impacts on human health and identify ways to decrease human and environmental impacts.
  • Evaluate existing regulatory frameworks to assess applicability to DAC plants and associated CO2 transportation and sequestration. Where necessary, clarify the regulatory frameworks that will apply to DAC development.
  • Improve techniques for manufacturing DAC components, including sorbents and solvents, in cost-effective and environmentally friendly ways.
  • Identify methods of powering DAC plants that maximize energy efficiency and minimize negative environmental, community, and climate impacts.
  • Identify factors that should be used to determine optimal siting for DAC plants, including practical constraints and local community considerations.
  • Conduct social science research and polling to assess public perceptions of DAC and to better tailor communication and outreach.
  • Establish a DAC demonstration grants program that requires DAC projects to conduct community education and outreach and encourages creation of CBAs with communities where appropriate (Kosar et al. 2021).

Subnational Recommendations

State and local land use policies are already changing to make planning and siting of industrial projects more equitable. Widespread use of these policies can help address historical patterns of inequitable land use and unequal distributions of impacts and benefits and help create conditions to enable an equitable DAC scale-up.

Zoning and Planning: Local planning and policies can help counteract historical patterns of land use that concentrate locally unwanted land uses near and in communities that are low-income, Indigenous, or composed predominantly of people of color (Baptista 2019). Planning can also help address zoning driven by “NIMBYism (not-in-my-backyard-ism)” or an acceptance of the need for infrastructure, but opposition to building the infrastructure near the opponent’s home or community. Zoning influenced by NIMBYism can concentrate industrially zoned land and the resulting facilities in communities that have less political power to inform siting decisions and negotiate benefits. State, county, or city environmental justice initiatives can assemble advisory panels that provide input on planning and zoning decisions to ensure that health and economic impacts on marginalized communities are considered in planning decisions, and infrastructure that serves a public good, such as DAC, is distributed equitably.

Construction Permitting Processes: Cities, states, and counties can develop ordinances requiring new DAC facilities, infrastructure, and CO2sequestration sites to complete environmental and environmental justice review processes to be eligible to receive building permits. Newark, New Jersey, set a precedent in passing an ordinance that requires developers seeking permits to disclose possible environmental impacts (Clean Water Action 2016). Related ordinances could similarly require community engagement and consultation prior to permits being granted.

Private Sector Recommendations: DAC project developers can prioritize procurement of lower-emission versions of materials like cement and steel, where possible, and can prioritize environmental impacts when selecting sorbents and solvents and their suppliers. DAC developers can also prioritize environmental impact, along with cost and efficiency, for in-house RD&D.

Because it has the potential to permanently remove carbon, DAC could provide verifiable carbon removals for emissions that are hard to abate in the near term (Joppa et al. 2021). If DAC projects provide carbon credits, credit certification programs could help to verify that DAC projects producing credits are developed in an environmentally and socially responsible way.

Leading voluntary carbon credit–verification programs already include thorough reviews of credit-producing projects to certify that credits are permanent and that projects do not harm communities or result in environmental degradation. While governmental oversight and regulation must be primarily responsible for enforcing the mitigation of environmental impact, verification programs may be able to help ensure that DAC projects follow good practices for community engagement and environmental impact mitigation beyond regulatory standards. DAC projects producing carbon credits should undergo review to verify that they have taken all possible actions to minimize negative environmental and community impact, and to ensure that benefits accrue to local communities. Project reviews conducted by carbon crediting programs could include the following criteria:

  • DAC developers should be required to provide transparent and regular reports on life-cycle environmental impacts of building and operating plants.
  • Developers should conduct community outreach and engagement processes consistent with the procedural recommendations above.
  • DAC plants should provide high-quality, long-term employment for their workers.
Start reading