National Mining Association Carbon Capture and Storage - Barriers to CCS

http://www.nma.org/pdf/fact_sheets/ccs.pdf Read entire article here

I find this to be an interesting statement - Avoiding application of the federal Superfund program to in• jections of CO2;

At present, uncertainty over siting requirements and long-term liability issues associated with the underground storage of CO2 have deterred project developers, financiers and insurers from moving forward with CCS. However, CCS as a tool for mitigating CO2 emissions and ensuring a secure and affordable energy supply for America represents a vital public interest that merits a federal-level program to clarify and resolve these long-term liability issues and to clear the way for the rapid and widespread commercialization of the technology. Some of the key issues that must be resolved in order to foster widespread commercialization of CCS include:
Determining responsibility for post-closure monitoring;•
Avoiding application of the federal Superfund program to in• jections of CO2;
Avoiding characterization of CO• 2 as a waste and CCS activities as waste disposal to avoid triggering expensive “cradle to grave” regulations of the Resource Conservation and Recovery Act (RCRA); and
Resolving property rights issues, including pore space owner• ship, trespass and interstate issues relating to CO2 transportation and placement.