The Department of Environmental Protection (Department) issues this Request for Information (RFI) to assist in the development of a grant solicitation entitled Reducing Industrial Sector Emissions in Pennsylvania (RISE PA). The availability of funding for RISE PA will be contingent upon the Department's receipt of an award under the United States Environmental Protection Agency's (EPA) Climate Pollution Reduction Grants Program (CPRG): Implementation Grants General Competition (CPRG Competition).
This RFI is intended for respondents to provide comment on the information specified in this notice. This RFI is also intended to communicate the Department's general goals and objectives for RISE PA program development. This RFI does not constitute a grant solicitation, nor does it represent a commitment to issue a grant solicitation in the future. This RFI does not commit the Department to any specific form of grant solicitation. Responding to this RFI is not a pre-requisite for participation in a future grant solicitation process. Persons and organizations who choose to not respond to this RFI may still participate in any subsequent grant solicitation process for RISE PA. Respondents choosing to respond to this RFI will not, merely by submitting such a response, be deemed to be applicants to RISE PA and no respondent will have any preference, special designation, advantage or disadvantage whatsoever in any subsequent grantmaking process for RISE PA. Respondents should not anticipate a response from the Department regarding submitted materials.
The purpose of this RFI is to solicit feedback from industry, academia, community-based organizations and other interested stakeholders on issues related to the design and implementation of RISE PA as they relate to the criteria of the CPRG Competition. The Department is specifically interested in receiving input on program design, size, scope, scale and award sizes as well as the potential outputs and metrics, including emissions reductions and community benefits.
The 2022 Inflation Reduction Act (IRA) (Pub.L. No. 117-169) established the CPRG, which provides funds in two distinct but related phases:
The EPA issued a notice of funding opportunity on September 20, 2023, announcing the availability of up to $4.3 billion1
for the CPRG Competition. Lead organizations for CPRG planning grants must submit their PCAPs to the EPA by the deadline of March 1, 2024, for lead organizations and other eligible applicants to submit grant applications to fund measures contained in those plans. The EPA anticipates awarding approximately 30 to 115 grants ranging between $2 million and $500 million under the CPRG Competition. Applications are due on April 1, 2024. Entities eligible to apply for an implementation grant under the CPRG Competition include lead organizations that were direct recipients of CPRG planning grants and other State, municipal, tribal and territorial entities that seek to implement GHG reduction measures included in an applicable PCAP developed under a CPRG planning grant.
The CPRG Competition is designed to enable states, municipalities, tribes and territories to achieve the following goals:
1. Implement measures that will achieve significant cumulative GHG reductions by 2030 and beyond.
2. Pursue measures that will achieve substantial community benefits such as reduction of criteria air pollutants (CAP) and hazardous air pollutants (HAP), particularly in low-income and disadvantaged communities2
.
3. Complement other funding sources to maximize these GHG reductions and community benefits.
4. Pursue innovative policies and programs that are replicable and can be scaled up across multiple jurisdictions.
The Department has received a $3 million CPRG planning grant with which to develop a PCAP focused on reducing GHG and co-pollutant emissions from this Commonwealth's industrial sector. According to the 2023 Pennsylvania Greenhouse Gas Inventory Report, which the Department is statutorily required to prepare under the Pennsylvania Climate Change Act (Act 70 of 2008) and relies on emissions data from the year 2020, the industrial sector is the highest emitting sector, accounting for just over 30% of the Commonwealth's total GHG emissions. In 2020, emissions from the industrial sector totaled 73.56 million metric tons of carbon dioxide equivalent (MMTCO2e). The emissions come from 4 separate subgroups: combustion of fossil fuels (32.89 MMTCO2e); industrial processes (12.86 MMTCO2e); activities involving coal mining and abandoned coal mines (11.62 MMTCO2e); and activities involving natural gas and oil systems (16.20 MMTCO2e). The emissions related to electricity usage within the industrial sector are accounted for in the electricity production sector and amount to approximately 16.2 MMTCO2e,3
bringing the total potential GHG emissions impact reduction from the industrial sector to 89.77 MMTCO2e.
The emissions attributed to the combustion of fossil fuels subgroup result from fuels combusted to heat and cool industrial buildings and equipment within this Commonwealth and account for 36.6% of the total industrial sector emissions. Several factors influence the amount and type of a fuel being used, including the severity of the weather, efficiency of the heating or cooling system and fuel price and availability. The GHG emissions related to electricity usage within the industrial sector comprise 18.0% of the total GHG emissions. Some of the sources of GHG emissions within the industrial processes subgroup, which account for 14.3% of total emissions, include emissions from cement manufacturing, lime manufacturing, limestone and dolomite use, iron and steel production, substitutes for ozone-depleting substances and electric power transmission and distributions systems. Most emissions in the coal mining and abandoned coal mines subgroup, totaling 12.9% of industrial sector emissions, emanate from surface coal mining, coal processing and abandoned underground mines. Accounting for 18.0%4
of the total industrial sector emissions, the GHG emissions associated with natural gas production, transmission and distribution and oil production have been determined by means of emission factors based on the number of natural gas and oil wells, miles of transmission pipeline and number and types of services used for distribution in this Commonwealth. The natural gas and oil systems subgroup also includes emissions estimates from abandoned oil and gas wells.
Pennsylvania's Executive Order (EO) 2019-01 sets GHG emissions reduction goals for this Commonwealth at 26% by 2025 from 2005 levels and 80% by 2050 from 2005 levels. The year 2005 is used as a reference point for emissions reductions to maintain consistency with goals set forth in the Paris Climate Agreement. As of 2020, the Commonwealth has achieved a 25.9% reduction in net GHG emissions compared to 2005.
While this significant emissions reduction in 2020 nearly achieves the 2025 emissions reduction goal, this reduction was driven by the impacts from the novel coronavirus (COVID-19) pandemic and the drop in emissions in the Commonwealth may not be durable. In the National 2021 Inventory of the United States Greenhouse Gas Emissions and Sinks, overall nationwide emissions increased by 5.2% between 2020 and 2021. This increase was driven by economic activity rebounding after the height of the COVID-19 pandemic. The Commonwealth's emissions, significantly reduced in 2020, will likely follow a similar pattern to the national trend with expected increases in emissions in 2021 from 2020 levels.
Even if the reductions seen in 2020 are durable, an additional reduction of 147.99 MMTCO2e is needed to reach the 2050 goal. This underscores the need for more and continued actions aimed at reducing the Commonwealth's GHG emissions. The CPRG Competition offers the Department the opportunity to apply for up to $500 million to reduce industrial sector emissions and help achieve the goals in EO 2019-01. The Department intends to apply for the maximum award size because the Commonwealth falls within the highest tier of emitters Nationally, ranking as the fourth highest emitter in the United States Energy Information Administration's 2023 State Energy Data System report and the Commonwealth's industrial sector emissions have increased from 2005 levels.
Under the CPRG Competition, the EPA encourages eligible applicants to seek implementation funds for GHG reduction measures that will significantly reduce cumulative GHG emissions by 2030 and beyond and that will accelerate decarbonization across one or more major sectors responsible for GHG emissions, including the industrial sector. The EPA will score grant applications based on multiple evaluation criteria, with an emphasis on the magnitude of near-term GHG reductions that will be achieved by the proposed measures. Applications that successfully address the specific evaluation criteria will also be consistent with the following program objectives:
• Stimulate transformation toward a decarbonized economy and demonstrate approaches that are replicable to unlock opportunities for even greater emissions reductions.
• Result in benefits and do not result in negative impacts, to low-income and disadvantaged communities, such as CAP and HAP reductions, equitable economic growth and improved quality of life outcomes, where applicable.
• Support measures for which dedicated funding or financing from other sources (for example, under other provisions of the 2022 IRA, the 2021 Bipartisan Infrastructure Law, the 2021 American Rescue Plan Act and the 2021 Creating Helpful Incentives to Produce Semiconductors and Science Act) is unavailable or that leverages other sources of public and private funding to the fullest extent possible prior to seeking CPRG funding.
• Achieve GHG emission reductions that are long-lasting and certain.
• Incorporate high labor standards, emphasize job quality and support equitable workforce development.
• Ensure accountability by providing clear assumptions, metrics, timelines, authorities and budget details.
The United States Department of Energy (DOE) identified the four decarbonization pillars in the DOE Industrial Decarbonization Roadmap, which represent interrelated, cross-cutting strategies that Greenhouse Gas Emission Reduction Projects (GERP) can incorporate individually or in parallel across one or more topic areas.
The Department will solicit proposals for GERPs that reduce emissions within one or more of the following topic areas:
The goal of RISE PA is to reduce the total industrial sector emissions by 5%, which equates to 4.5 MMTCO2e. The Department therefore proposes to offer $450 million6
at $100 million per MMTCO2e reduced over the 5-year period of performance for eligible GERPs that reduce 0.02 MMTCO2e or more from a single facility or cumulatively across a portfolio of facilities. The Department will solicit GERP proposals that address emissions from one or more of the five topic areas. Proposals will be evaluated on a rolling basis until all funds have been awarded. To provide applicants with flexible funding, up to 70% of the overall award will be made available as project costs are incurred. Remaining funds will be awarded upon completion of a measurement and verification analysis conducted by a third-party evaluator and will be subject to readjustment based on the participant's performance relative to their stated carbon reduction goal.
The Department intends to offer RISE PA to supplement by means of grant funding the incentive offered through the Internal Revenue Service's Advanced Energy Project Credit Allocation Program (Allocation Program) under section 48C(e) of the Internal Revenue Code. The Allocation Program offers a capped tax credit that is only guaranteed to have one additional round of funding in 2024. A project that applies for and receives the Advanced Energy Project Credit will be ineligible to receive an award under RISE PA; however, the requirements for eligible projects types under RISE PA will mirror those under the Allocation Program to provide additional opportunities to fund industrial decarbonization projects in this Commonwealth. Therefore, GERPs must satisfy the following requirements:
8 The term manufacturing facility means a facility that makes or processes raw materials into finished products (or accomplishes any intermediate stage in that process).
facility, including but not limited to energy-intensive manufacturing sectors, such as cement, iron and steel, aluminum, chemicals and other sectors, with equipment designed to reduce GHG emissions by at least 0.02 MMTCO2e through the installation of one or more of the following:
a. Low- or zero-carbon process heat systems.
i. Examples of eligible equipment include electric heat pumps, combined heat and power (CHP) systems, thermal storage technologies and other heating systems based on electricity, clean hydrogen, biomass or waste heat recovery.
b. CCUS systems.
i. Examples of eligible equipment include carbon capture equipment necessary to compress, treat, process, liquefy, pump or perform some other physical action to capture carbon oxides and specialized equipment and materials needed for the transport and storage of carbon oxides.8
ii. Additional examples include equipment to convert carbon oxides through mineralization, thermochemical electrochemical, photochemical, plasma-assisted or other catalytic process approaches to carbon-based products such as synthetic fuels, chemicals, solid carbon products and inorganic materials.
iii. Examples of ineligible property include the following:
1. Scrubbers for conventional air pollutants, except those that are required to remove pollutants upstream of carbon capture equipment for technical performance reasons.
2. Energy generation equipment, except as related to energy recovery at carbon capture systems.
3. Refining equipment.
c. Energy efficiency and reduction in waste from industrial processes.
i. Examples of eligible equipment include technologies that reduce direct fuel use, electricity use or waste in industrial applications, such as industrial heat pumps, CHP systems, insulation, sensors, controls, advanced recycling approaches, smart energy management and similar advanced efficiency technologies.
d. Other industrial technology designed to reduce GHG emissions, as determined by the Department.
i. Examples of other eligible industrial technologies include electrification of direct fuel use processes, adoption of renewable or low-emissions fuels and feedstocks and other equipment replacement or process redesigns that reduce process- or fuel-related emissions or otherwise contribute to reducing GHG emissions by at least 0.02 MMTCO2e.
ii. Projects in this category may qualify by installing equipment designed to achieve a minimum reduction in GHG emissions of .02 MMTCO2e in one or more of the following ways:
1. Achieve a direct (Scope 1)9
GHG emissions reduction of .02 MMTCO2e facility-wide or across a portfolio of facilities.
2. Achieve an indirect fuel or energy-related (Scope 2)10
GHG emissions reduction of 0.02 MMTCO2e facility-wide or across a portfolio of facilities.
3. Achieve a direct or indirect fuel- or energy-related GHG emissions reduction of 0.02 MMTCO2e at a facility subunit, such as a particular process step or fuel combustion unit.
iii. While facilities may be eligible under this project category by achieving a 0.02 MMTCO2e reduction threshold within a particular element of their process or emissions profile, overall combined Scope 1 and Scope 2 GHG emissions impacts for the full qualifying facility will be taken into account when evaluating each project.
2. Meets the prevailing wage requirement by ensuring that any laborers and mechanics employed by the project owner or any contractor or subcontractor in the re-equipping of a manufacturing or industrial facility that is part of a qualifying advanced energy project are paid wages at rates not less than the prevailing rates for construction, alteration or repair of a similar character in the locality in which this project is located as most recently determined by the Secretary of the United States Department of Labor.
3. Meets the apprenticeship requirements by ensuring that not less than 10%, 12.5% or 15% (depending on the beginning of construction date) of the total labor hours for the construction, alteration or repair work must be performed by qualified apprentices.
Evaluation Criteria
The Department proposes to issue awards under RISE PA on a rolling basis during the application period and is seeking comment on the following evaluation criteria. Respondents can provide feedback on the evaluation categories and suggest potential weighting structures for each of the following sections:
1. Over-all Project Summary and Approach
a. Description of GHG Reduction Measures
• Provides a detailed description of each of the proposed GHG reduction measures to be undertaken.
• Describes the major features, tasks, milestones and potential risks for each measure.
• Describes the roles and responsibilities of each project team member in the project design and implementation.
• Explains how each GHG reduction measure will meet the goals of the CPRG Competition outlined in the bulleted list in the Purpose section of this RFI.
b. Demonstration of Funding Need
• Demonstrates a strong need for RISE PA funding.
• Explains if and how other funding streams have been explored and why these sources are not sufficient.
• Lists Federal and nonFederal funding sources the applicant has applied for, has secured or will secure to implement the GHG reduction measures, if applicable.
c. Transformative Impact
• Demonstrates that the GHG reduction measures have the potential to create transformative opportunities or impacts that can lead to significant additional GHG emissions reductions.
• The extent to which the proposed project enhances the Commonwealth's leadership in low-emissions industry or manufacturing by advancing the commercial viability and uptake of replicable decarbonization approaches in major industrial applications.
• The extent to which the project promotes the competitiveness of this Commonwealth's industrial base through the adoption of innovative technologies or processes.
• The extent to which the proposed project aligns with one or more cross-cutting industrial decarbonization techniques, such as energy efficiency, electrification, low-carbon fuels, feedstocks and energy sources, material efficiency or substitution and CCUS.
2. Commercial Viability
a. Project schedule and time to completion
• Readiness to proceed with the proposed project as evidenced by firmness of site selection and progress towards securing required permits, contracts, reviews and agreements.
• Reasonableness of the timeframe required for construction and commissioning of the project, including interim milestones and overall timeline.
b. The extent to which risk management issues and mitigation strategies are identified and addressed, including the level of contingency proposed to address risk.
c. Strength of the proposed business plan, including:
• The source and certainty of funding for the equity that will be invested in the project, including private financing, Federal funding, State and local incentives and other sources.
• The strength of key arrangements, such as financing, acquisition/supply strategy and power purchase agreements for the proposed project, as well as offtake (sales) arrangements for the facility's product.
• The degree to which the application justifies the proposed project's economic viability, sustainability and potential growth.
• The degree to which the investment is profitable, based on the proposed budget and spending plan, as well as described cash flow analysis of the project.
• The levelized cost of measured reduction in GHG emissions.
• The potential for commercial deployment based on anticipated demand and cost premiums for lower-carbon industrial or manufacturing products.
d. Strength of the proposed management plan, including the management team's track record of success in areas relevant to the project and corporate health of the applicant.
3. Impact of GHG Reduction Measures
a. Magnitude of GHG Reductions from 2025—2030
• States the magnitude of cumulative GHG emission reductions and the durability of the reductions to be achieved by the proposed GHG reduction measures from 2025—2030, using appropriate methodologies and assumptions.
b. Magnitude of GHG Reductions from 2025—2050
• States the magnitude of cumulative GHG emission reductions and the durability of the reductions to be achieved by the proposed GHG reduction measures from 2025—2050, using appropriate methodologies and assumptions.
c. Cost Effectiveness of GHG Reductions
• States the cost effectiveness of the GHG reduction measures by means of a qualitative narrative explaining any factors that may affect the cost-effectiveness calculation.
d. Documentation of GHG Reduction Assumptions
• Provides comprehensive methodologies, assumptions and calculations used for developing the estimated GHG emission reductions for the GHG reduction measures included in the application, including GHG reductions from 2025—2030; GHG reductions from 2025—2050; and, the estimated cost per MMTCO2e GHG reductions to be achieved from 2025—2030 for the collection of measures in the application.
4. Environmental Results—Outputs, Outcomes and Performance Measures
a. Expected Outputs and Outcomes
• Identifies expected outputs and outcomes for each GHG measure, including listing GHG emission reductions and listing co-pollution (CAP and HAP) emission changes as outcomes, among others.
• The extent to which the proposed project accounts for its environmental impact to the surrounding community by having clear plans to avoid or reduce local air pollution, land contamination or water contamination, or both.
• The extent to which the applicant identifies specific, measurable benefits for disadvantaged communities and how negative environmental impacts affecting disadvantaged communities will be mitigated.
b. Performance Measures and Plan
• Provides a clear description of the proposed performance measures to track, measure and report progress toward achieving the expected outputs and outcomes for each GHG reduction measure.
• Describes the plan for effectively tracking and measuring progress implementing each GHG reduction measure.
c. Authorities, Implementation Timeline and Milestones
• For each measure, describes whether the applicant has current permitting authority to carry out the measure, and if they do not, articulates the plan and timing for obtaining it.
• Provides the detailed implementation timeline for each measure, including key milestones for specific task and discusses the key action needed to meet the project goals and objectives.
5. Low-Income, Disadvantaged and Energy Communities
a. Community Benefits
• Provides a comprehensive discussion and assessment of expected benefits or avoided disbenefits, or both, to low-income and disadvantaged communities from the proposed GHG reduction measures.
• Lists Climate and Economic Justice Screening Tool Census tract IDs or the EPA's EJScreen Census block group IDs for areas that may be affected by GHG reduction measures.
• Describes the plan to assess, quantify and report a more thorough quantitative analysis of associated community benefits, including co-pollutant (CAP and HAP) emission reductions.
• The extent to which a project will generate economic prosperity in the local community.
b. Community Engagement
• Explains how input from low-income and disadvantaged communities was incorporated into the application.
• Describes how meaningful engagement with low-income and disadvantaged communities will be continuously included in the implantation of the GHG reduction measures.
• The extent of current and planned efforts to engage community stakeholders, including as it relates to the ability to execute the project on schedule and with adequate workforce.
• The extent to which community support for the project has been strengthened through benefit-sharing agreements, consideration of environmental impact, use of local resources and improved access to employment opportunities for the local workforce.
c. Energy Community Transition
• The extent to which the application includes specific and high-quality actions to support energy communities, including transition opportunities for workers in the coal and other energy sectors into clean energy transition opportunities.
• The extent to which a project will utilize existing local and regional resources that previously supported the local or regional coal industry or repurpose existing infrastructure/assets that have been abandoned due to closing of coal mines or coal plants.
6. Workforce and Job Quality
a. Describes concrete strategies and commitments to ensure job quality, strong labor standards and a diverse, highly skilled workforce for the implementation of the GHG reduction measures.
b. The number of jobs created in this Commonwealth (both direct and indirect): (a) during completion of the project (the credit period) and (b) during operation of the facility after it is placed in service, including jobs within energy communities (if applicable) attained by locals or individuals previously employed by the local or regional coal industry.
c. The quality and manner in which the proposed project will create or retain, or both, high-quality, good-paying jobs (both direct and indirect) with employer-sponsored benefits for all classifications and phases of work.
d. The extent to which the applicant engaged key stakeholders to develop partnerships to better serve local and diverse workforce through training and support.
e. The extent to which the project provides employees with the ability to organize, bargain collectively and participate, through labor organizations of their choosing, in decisions that affect them and that contribute to the effective conduct of business and facilitates amicable settlements of any potential disputes between employees and employers, providing assurances of project efficiency, continuity and multiple public benefits.
f. The extent to which the applicant demonstrates that they are a responsible employer, with ready access to a sufficient supply of appropriately skilled labor and an effective plan to minimize the risk of labor disputes or disruptions.
7. Programmatic Capability
a. Past Performance
• Demonstrates that the applicant has past performance in successfully managing and completing a project of similar scope and size.
b. Staff Expertise
• Demonstrates that the applicant has the requisite organizational experience, including staff expertise and qualifications, staff knowledge and resources or ability to obtain them, to successfully achieve the goals of the proposed GERP.
8. Budget and Timely Expenditure of Award
a. Budget Detail
• Provides a detailed breakout for each activity for which the applicant is requesting funding.
b. Expenditure of Awarded Funds
• Demonstrates that the approach, procedures and controls described in the application will ensure that awarded funds will be expended in a timely and efficient manner.
c. Reasonableness of Cost
• Provides justification for the extent to which the proposed budget is reasonable for accomplishing the proposed goals, objectives and measurable environmental outcomes described in the application.
RFI Questions
The Department requests information on the following topics to inform the development of program solicitation guidelines for RISE PA. Responses are limited to 10 pages or fewer:
1. Should RISE PA give preference to one or more Topic Areas?
2. Is the 5% industrial sector emissions reduction target feasible?
a. Is 0.02 MMTCO2e a feasible minimum threshold for a GERP?
3. Does offering an award structure of $100 million per MMTCO2e provide adequate incentive to fund GERPs?
a. Should the incentive be increased or decreased?
b. Should the Department consider an alternative award structure?
4. Should the Department consider adding or removing any evaluation criteria?
a. How should the proposed evaluation criteria be weighted?
b. Should applications be evaluated on a rolling basis?
c. If an application does not satisfy the evaluation criteria, should the applicant be allowed to revise their application and resubmit it for consideration?
5. Beyond those identified in the evaluation criteria, what additional goals or priorities should RISE PA seek to accomplish?
6. What are the most important results and associated metrics that communities impacted by industrial emissions would want to see generated from projects funded under RISE PA?
7. How should RISE PA encourage or give preference to projects that provide significant benefits to low-income, disadvantaged and energy communities beyond those identified in the evaluation criteria?
a. What types of benefits should flow to low-income, disadvantaged and energy communities?
b. How can these benefits be measured?
8. Should RISE PA give preference to equipment that is partially or wholly produced in this Commonwealth as part of the application review criteria beyond IRA Federal requirements?
a. If yes, how and to what extent?
b. How should this be documented and verified?
9. What other program details, requirements, considerations or flexibilities should the Department incorporate into RISE PA?
10. Would you be willing to submit a letter of support for the RISE PA program for the Department to include in its application to the CPRG Competition?
Interested persons may submit information by e-mail at RA-EP-CPRG@pa.gov. Information must be received no later than Monday, January 22, 2024. Use ''Request for Information: Proposed RISE PA Grant Program'' as the subject line in written communication.
Questions concerning this RFI should be directed to Louie Krak at lkrak@pa.gov or (717) 787-6107.
JESSICA SHIRLEY,
Interim Acting Secretary
[Pa.B. Doc. No. 23-1796. Filed for public inspection December 29, 2023, 9:00 a.m.]
_______
1 Although the total amount funding available for Implementation grants is $4.6 billion, $300 million has been set aside for a separate competition in which tribes and territories are the only eligible applicants.
2 A disadvantaged community may be either: (1) a group of individuals living in geographic proximity (for example, a census tract identified using the Climate and economic Justice Screening Tool): or (2) a geographically dispersed set of individuals, where either type of group experiences common conditions.
3 According to the United States Energy Information Administration's Form EIA-861 Annual Electric Power Industry Report, Pennsylvania's total electric power industry emission rate was 713 lbs/MWh in 2022. When multiplied by the 50.00 TWh of electricity the industrial sector consumed as reported in the 2023 Pennsylvania Greenhouse Gas Inventory Report and converted to MMTCO2e, this equates to 16.2 MMTCO2e.
4 The subgroup percentages do not exactly equal 100 15ue to rounding errors.
5 These percentages are calculated by dividing the total emissions by 89.77, which is the sum of the industrial sector emissions (73.56 MMTCO2e) plus the estimated emissions from industrial electricity usage (16.2 MMTCO2e), multiplying by 100 and rounding to the nearest whole number.
6 This award structure is contingent on RISE PA receiving $500 million of funding under the CPRG Competition and reserving 10% ($50 million) of the total award for administrative costs.
7 The term industrial facility means a facility that produces, processes or refines materials or products from raw or manufactured inputs.
8 This includes carbon dioxide (CO2) pipelines, monitoring equipment and injection equipment and well components such as packers, casing, strings, CO2-resistant cement, steel tubulars, well heads, valves and sensors suitable for use in Underground Injection Control Class VI wells.
9 Direct greenhouse gas emissions that occur from the sources at the facility associated with the proposed project (for example, emissions from fuel combustion or chemical processes).
10 Indirect greenhouse gas emissions that are associated with the use of energy or fuel at the facility, but do not occur at that facility (for example, emissions from a power plant that generates electricity for the facility).
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