Captain Drawdown’s daily logbook on every CDR story, paper, and expert voice — so you don’t have to read them all.

Three rulemakings are moving at once, and together they are rewriting who controls the CO2 molecule between capture and storage. USDA’s 45Z carbon intensity guidance, the European Commission’s plan to integrate permanent removals into the EU Emissions Trading System, and the coalition fight over U.S. CO2 pipeline safety are each being drafted in isolation. Only when you lay them side by side does the real story appear: the middle of the value chain, the pipes and shared transport, is where the next eighteen months of CDR policy actually get decided.

Start with the credit. USDA’s new technical guidelines for regenerative biofuel feedstocks finally give ethanol-with-CCS producers a defensible carbon intensity score under 45Z. A defensible score unlocks the tax credit, and the tax credit is what makes ethanol BECCS (bioenergy with carbon capture and storage) pencil out. The market read was almost immediate: Frontier Infrastructure Holdings and Carbonfuture signed the largest ethanol BECCS off-take to date the same week. One rule change repriced an entire pathway overnight.

But a good carbon intensity score is worthless without a pipe you’re allowed to build. That is where the second rulemaking lands. More than 75 organizations are pushing the Senate to stiffen federal CO2 pipeline safety rules, arguing the current draft is too weak for the volumes 45Z will now unleash. The private sector is already positioning around this choke point: ExxonMobil is absorbing Williams’ CO2 transport assets, consolidating who owns the pipe and, more importantly, who carries the liability when something leaks.

And leakage is not one problem, it is several. As I noted last week, “mineralized carbonate and dissolved bicarbonate are chemically stable, unlike pressurized injected fluids”. Supercritical CO2 in a trunk line is a fundamentally different regulatory object than basalt-bound carbonate or ocean bicarbonate. A pipeline safety bill written for the first pathway will bind or exempt the others in ways the drafters may not intend. Enhanced weathering and ocean alkalinity enhancement do not need trunk pipelines. Ethanol BECCS and DAC absolutely do. Any bill that ignores that difference will distort the pathway mix. (For readers new to the chemistry side, see my primer on enhanced weathering.)

The third rulemaking closes the loop from the demand side. The European Commission has proposed integrating permanent carbon removals into the EU ETS from 2031, with 250 million allowances earmarked to buy durable removals. That turns Brussels into the world’s largest single CDR buyer, but only for pathways whose transport and storage chain the EU’s Carbon Removals and Carbon Farming (CRCF) framework actually recognises. Same middle-of-chain question, different flag.

Here is the tension. Federal and supranational agencies are simultaneously making capture more lucrative (45Z), storage more mandatory (ETS integration), and transport more contested (pipeline safety). The three rules only make sense together. They are being written apart.

Oxford Net Zero’s Myles Allen has been arguing for the missing spine. As the group put it, Allen proposes to require the fossil industry to permanently dispose of a rising share of the CO2 their products emit. That carbon takeback obligation is the policy logic that would harmonise USDA, ETS, and pipeline safety into one coherent obligation on whoever moves the molecule. As I argued in response, “the stored share must reach 100% by net zero” for the design to hold together. Without that spine, you get three rules pulling in three directions.

So what does this mean if you are building in engineered CDR right now? The pathway math you built last year is hostage to whichever rulemaking lands first. A generous 45Z score means nothing if the pipe cannot be permitted. An EU ETS off-take means nothing without a CRCF-recognised transport chain. Trunk lines, shared storage hubs, and cross-border transport are the real bottleneck. If you are modelling projects, model the middle, not the endpoints.

What to watch: whether the Senate pipeline safety markup adopts the coalition’s stricter provisions before the USDA 45Z guidance drives the next wave of ethanol BECCS final investment decisions. If safety rules lag, U.S. BECCS scales on a patchwork of state terms. If they lead, it scales on federal terms. Sequencing is the whole game.

Citations

  1. Usda — technical guidelines for regenerative biofuel feedstocks — government source
  2. Puro.earth — Frontier Infrastructure Holdings and Carbonfuture signed the largest ethanol BECCS off-take to date
  3. Govinfo — stiffen federal CO2 pipeline safety rules — PDF
  4. Carbon Herald — ExxonMobil is absorbing Williams’ CO2 transport assets
  5. Bluesky — “mineralized carbonate and dissolved bicarbonate are chemically stable, unlike pressurized injected fluids” — Bluesky post
  6. LinkedIn — proposed integrating permanent carbon removals into the EU ETS from 2031 — LinkedIn post
  7. Bluesky — require the fossil industry to permanently dispose — Bluesky post
  8. Bluesky — “the stored share must reach 100% by net zero” — Bluesky post