This week, we’re bringing you a panel discussion from the Institute for Carbon Removal Law and Policy’s annual CDR conference. Our policy panelist, Wil Burns, hosted the conference and led this panel discussion on the role of mandates in growing CDR in the US.
The US government has stepped forward into the role of subsidizing and encouraging CDR in recent years, offering a ‘carrot’ to promote the new industry, in the form of large grants and tax incentives. But what could the government do to present a ‘stick’- requiring CDR using existing regulations?
That’s the topic of this policy panel featuring Dan Galpern, the Executive Director of the Climate Protection and Restoration Initiative, and Stephanie Arcusa, a researcher at the Arizona State University Center for Negative Carbon Emissions.
Dan spoke about using the Toxic Substances Control Act to regulate carbon emissions, including the possibility of mandating carbon dioxide removal as a condition for allowing ongoing emissions. He argues that the TSCA provides clear authority for such regulation, citing past precedents and legal interpretations.
Stephanie discusses the concept of a Carbon Take Back Obligation, which would require fossil fuel producers to sequester a tonne of carbon for every tonne they extract. This policy aims to gradually transition to net-zero emissions by creating a demand for carbon removal and applying the policy upstream in the fossil fuel supply chain.
Both approaches aim to address the challenges of scaling up carbon removal and mitigating climate change, but they also raise questions about political feasibility, environmental justice, and the impact on consumers, particularly those in lower-income households.
We hope you enjoy this high-level look at the policy levers that may one day lead to the scaling up of CDR.
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Full Transcript
Announcer: You’re listening to Carbon Removal Newsroom, a weekly show about current events in the world of carbon removal, from technology and innovation to policymaking and job growth. Brought to you by Nori, the carbon removal marketplace.
Asa Kamer: Hello, everyone. This is Asa Kamer, producer of Carbon Removal Newsroom. This week, we have a special episode for you. We’re bringing you a panel discussion from the Institute for Carbon Removal Law and Policy’s annual CDR conference. Our regular policy panelist, Wil Burns, hosted the conference and led this panel discussion on the role of mandates in growing CDR in the US. The US government has stepped forward into the role of subsidizing and encouraging CDR in recent years, offering a carrot approach to promote the new industry in the form of large grants and tax incentives.
But what could the government do to present a stick requiring CDR using existing regulations? That’s the topic of this policy panel, featuring Dan Galpern, the Executive Director of Climate Protection and Restoration Initiative, and Stephanie Arcusa, a researcher at the Arizona State University Center for Negative Carbon Emissions. We hope you enjoy this special episode of Carbon Removal Newsroom.
Wil Burns: And we think this will be an interesting discussion. And so as you can see, our topic is, is there a role for domestic mandates to drive CDR? The M word, right? If you look to date at what’s happening in terms of CDR, we’re largely relying on the voluntary markets to get us to where we need to be. And the reality is that if you look at CDR FYI as a site that tracks our progress in terms of CDR, we are at about 0. 04% of the goal of 10 gigatonnes of CO2 annually by 2050.
Now, we have a ways to go, obviously, but I think many do not believe that this bodes well for us ultimately achieving anywhere near that goal. And given the fact that the Intergovernmental Panel on Climate Change has emphasized again and again how critical it is to have a large scale CDR in addition to rapid decarbonization, It behooves us to look at what other approaches may be critical to get us there, right? In the face of no social cost of carbon to help drive and incentivize carbon removal in the face. Of still only largely a handful of hero companies purchasing especially durable technology-based carbon removal.
It leads to the question of whether we’re going to need hard regulatory mandates and approaches to scale up and to ensure that costs begin to come down as a consequence of sufficient demand. And the objectives are met. And so the purpose of this roundtable is to look at a couple of thoughtful approaches about how we might go there and try to assess. And so what I’m going to do initially is introduce our two participants in the roundtable, for which I will serve as moderator. And then I’m going to ask each one of them to outline the proposal that they’ve been working on, both of them have done this in the form of publications to date and contemplate more work on these proposals in the future.
So first of all, let me introduce Dan Gelburn, who serves as founder and executive director and general counsel for the NGO Climate Protection and Restoration Initiative. Since 2011, Dan has served as legal and policy advisor to the climate scientists, James Hansen, including with respect to administrative, criminal, and civil, state, and federal actions in an array of states. Including California, Iowa, Massachusetts, Minnesota, Nebraska, North Dakota, Oklahoma, Oregon, South Dakota, Washington, and the District of Columbia as well as several other nations including Columbia, New Zealand, the Philippines, Uganda, and the United Kingdom.
Prior to his work in the legal field, Dan worked for 20 years as a public interest analyst and advocate for human rights and global security, including with respect to issues of poverty and income support services. So welcome, Dan. And then our second participant is Stephanie Arcusa, who is a postdoctoral research scholar at Lightworks, which is an innovation accelerator in the Global Institute of Sustainability and Innovation at Arizona State University. Dr. Arcusa is a climate and earth physical scientist by training, focusing on climate mitigation and carbon accounting. She has experience collecting large data sets from the natural world and using statistical methods and earth system modeling to make sense of this data.
Dr. Akusa holds a PhD in climate and environmental change from North Arizona University in the United States, a master’s degree in climate science from the University of Bern in Switzerland, and a bachelor’s degree in earth sciences from University College Corps in Ireland. And so with that, I will ask Dan to step forward and discuss his proposal for how to substantially scale carbon removal through federal regulation. Dan?
Dan Galpern: Thank you, Will. And I’m going to try to share a PowerPoint.
Unknown speaker: Okay.
Dan Galpern: Our proposal is actually in the context of a wider proposal, For deep decarbonization. And I would say that the aspect of it that speaks to CDR is a piece of that. But before diving directly into that, I just want to note that when I was listening to Joe Rahm’s Let’s Get Real presentation, it made me think of a report that was released just on Tuesday called the Production Gap Report. And in this report, the United Nations Environmental Program and the Stockholm Environmental Institute and a couple others. And this is a series of reports that have been issued, I think, roughly every other year, immediately prior to a one or another conference of the parties meeting to the United Nations Framework Convention on Climate Change.
And this report, similar to their prior reports, shows that there’s an enormous gap between where countries need to be in their nationally determined contributions, and even more importantly, in their actual policies and actions, and what is needed to secure the promise of The United Nations Framework Convention on Climate Change and the Paris Accords Temperature Limits. Here I just reprise their charts that are based on, with respect to their analysis of the United States, they analyze 19 other major emitting nations as well, and what this shows is that Even by 2050, according to the United Nations EIA, we are not going to be fully phased out of coal, but it will be substantially reduced.
But oil production will continue at a very high rate, accelerating through 2030 and continuing through 2040. And the same thing is true with respect to natural gas. So... Clearly, I think we have a problem not only in conceptualizing and figuring out how we’re going to ramp up DDR, but also how we’re going to phase out utilization of fossil fuels, given our current trajectories. All right, so what I’m going to talk about is partly contained in our petition from last year. Under Section 21 of the Toxic Substances Control Act to the Environmental Protection Agency, a petition that we are formulating now will supersede that, but many of the details that I’ll discuss right now were outlined in our prior petition.
Our new petition should be available and filed before the end of this year. And in order to talk about that, then I’m just going to review the relevant authorities on which we intend to rely on. Specifically, this is the Toxic Substance Control Act, a statute passed in 1970, 1976. And in Section 6 of the statute, Congress specified that if the administrator determines that the manufacture, processing, distribution and commerce, use or disposal of a chemical substance or mixture, and by the way, oil, gas and coal and CO2 and methane and the other Kyoto 6 gases are chemical substances as defined in this statute.
If any of those activities or any combination of those activities presents an unreasonable risk of injury to health or the environment, well then, The administrator, that is the head of the EPA, shall by rule, so not may, but shall, apply one or more of the following requirements to that substance or mixture to the extent necessary until the point that the substance no longer presents such risk. Okay then, so to those requirements. Most importantly, they include restriction, even the point of prohibition on the manufacture, processing, or distribution and commerce of such substance.
Manufacturing, by the way, in TSCA is defined to include production and importation. So the entire life cycle of the chemical substance is a suitable target for a rulemaking under the Toxic Substance Control Act. And a key point that I want to make here is that it’s not only a limitation or a prohibition, but it’s also an otherwise restriction. And so, and the same thing is true with respect to the commercial use of a substance. The agency is permitted to impose a requirement that prohibits or otherwise regulates any manner or method of commercial use.
So, on net then, what this means with respect to, one second here. And in addition, if the chemical substance presents what is deemed to be an unreasonable risk of serious or widespread injury to health of the environment, well, then the administrator can declare a proposed rule that the agency would issue immediately effective upon publication the federal register. So there’s no No need for a protracted 10 year period before something serious is done. So then what this means, I think with respect to CDR, is that under these authorities, the agency, at least with respect to activities within reach of US law, can impose a mandate For CDR in two different ways.
The first is that it can be imposed as a condition for allowing or neutralizing continuing or residual emissions. You want to continue to emit? Well, then the agency could compel you to remove an increasing share of your ongoing CO2 equivalent emissions. And the second way I think is that the agency can straightforwardly compel the removal of historical or legacy emissions. And so I think both of these things are available to the agency. Now, our 2020 petition Was submitted under the Section 21 of the Act, Citizens Petition, and it compelled EPA to respond within three months.
They did respond negatively, and so that we took them to court. But in the interim, the agency commenced its regulation, both with respect to autos and light duty vehicles, and then the power plant rules. So we actually dismissed our legal action to compel their regulation without prejudice, voluntarily. And so we have every right to go back to the drawing board, which is what we’re actually going to be doing in the next month or so. So I’ll stop there, Will, before in case you have any questions that I should clarify.
Wil Burns: Yeah, so I guess a couple of questions. One, it seems pretty clear that under this law, you can regulate things like fossil fuels. Does it provide for regulating fossil fuels?
Dan Galpern: The statute actually permits the regulation of the disposal of chemical substances as well. So CO2, methane, the rest, there’s no... Exemption for byproducts of commercial activities. So yes, there’s also a provision, which I didn’t notice here, that allows the agency to restrict the manner or method Well, how to date have we disposed of CO2 or methane and the others? We’ve just released them into the atmosphere as if the atmosphere is a free and open sewer. So that’s another authority that is available for the use of EPA to get after this problem in a comprehensive way.
Wil Burns: Is there a precedent for EPA in the past to regulate byproducts as opposed to the primary substances that were engaged in or being released into commerce?
Dan Galpern: Yeah, I mean, there’s off-gassing from formaldehyde has been regulated. And I should also say, although this is... Perhaps buried in recesses of people’s mind, but we actually commenced the restriction of CFCs under the Toxic Substance Control Act. And this was done in 1978. And interestingly, In both the draft rule and the final proposed rule, EPA cited the need to restrict products that released CFC, that utilize CFCs, not only because CFCs are powerful ozone depleting substances, but also on the basis that CFCs are powerful climate forcing agents. So there’s actually a 45-year agency precedent here for the utilization of TSCA for a gas that impacts the world that’s well distributed in this case, in the stratosphere.
Wil Burns: And I guess my other question is obviously the 10,000 pound elephant in the room, right? West Virginia versus EPA, right? If ultimately this were challenged, which assuredly it would be, right? By industry in some states. And it went to the Supremes. Is there any chance in hell that this gets past the major questions doctrine? And maybe explain what that is for everybody. For the uninitiated. And what do you think? Why might the Supreme Court uphold this incarnation? All right.
Dan Galpern: Well, great question. So last year, I think in June, the Supreme Court decided West Virginia versus EPA. And under it, they disallowed the Obama administration’s clean power. And notwithstanding the fact that it already had been Withdrawn by then the Trump administration and EPA assured the agency that they were not going to come back with another, they were not going to try to revitalize the Clean Power Plan as it was, but still they decided to, even though it was a moot, they decided to decide the question. And there the court was attempting to construe a particular provision that Section 111D of the Clean Air Act, 111D and 111A, to see, to discern whether those sufficiently supported EPA’s action in attempting to press for fuel switching in the electricity sector from heavy reliance on coal and natural gas to renewables.
And the court said, Those specific authorities were insufficiently clear, and the agency did not have clear authority from Congress to interpret them in the way it did to allow for such an expansive use of those sections to change a major industrial sector in the United States. They said a much more clear and direct conveyance of authority was required. And they said major questions are raised where an agency newly discovers a hidden authority buried deep in a statute and attempts to utilize that for the first time direct a substantial change in a major industrial sector.
All right, so to your question, is there a chance in hell That our proposal could survive a West Virginia major question scrutiny. And I think my answer is yes, there is a chance even on earth that it would do this. For one, as I indicated, there is agency precedent. Number two, the authority that I went over here is much more clear and direct than that which was relied on by the agency under the Clean Air Act Section 111. And the second is this, that it’s actually already been recognized by a court in 2017.
And so let me explain the Mexican floor versus EPA decision. Under the Clean Air Act, Title VI, the agency is... Directed to compel manufacturers to replace ozone-depleting chemicals in products with safer chemicals. And under this authority, specifically Section 612 of the Clean Air Act, EPA then decided that to, by rule, To compel manufacturers to further replace some of those safer chemicals that were then no longer found to be so safe. So they initially compelled under the section of law manufacturers to replace CFCs with HFCs. And then EPA discovered or learned or appreciated that HFCs also are powerful climate forcing agents.
They then attempted to utilize that section of the law to compel a replacement of HFCs with safer chemicals. And the Supreme Court, it went to the Supreme Court, it was challenged by industry. And the court said, no, you can’t do that under Title VI because Title VI only exists to convey authorization for you to get after ozone-depleting chemicals and to compel their replacement with safer chemicals. But you can’t use the same authority to replace previously deemed safer chemicals with really safer chemicals. But, the court said, Nonetheless, there’s ample authority for EPA to get after climate forcing agents under other statutes, including especially the Toxic Substances Control Act.
So that determination was important for a number of reasons for what it said. And secondly, for the court that said it, because that was the D. C. Circuit Court of Appeals, The second most important court in the United States. And third, for who actually wrote the majority opinion. It was then Circuit Judge Kavanaugh, now on the US Supreme Court.
Wil Burns: Yeah, it’ll be, if we ever get there, it’ll be interesting to see if he has a change of heart, but point taken. All right. Thanks so much for that, Dan. So let’s move on to Stephanie’s approach and discuss carbon take-back obligations. So Stephanie, the floor is yours.
Stephanie Arcusa: Wonderful. Well, thank you for having me here. And it was really nice to hear from Dan first, because I think what I’m about to describe is very much But let me step out of the US context for just a little while, because we can add those nuances when we actually discuss this proposal. So we are in a situation where we are spending our carbon allowance very fast at a rate of 40 gigatonnes. So 40 billion tonnes per year. This is because of oil, gas. Coal, as well as the lime that we’re using in concrete.
We imagine that our future is going to be one where we solve climate change by reducing our emissions, and that should be absolutely the goal. However, as we are embarking in that transition to zero emissions, we are still producing And these emissions are spending down our finite carbon budget. Now, we also have the issue that we know we will need carbon removal. And as Will first introduced, carbon removal right now is being bought by a handful of volunteers who are willing to pay luxury prices for that service. Volunteers are absolutely necessary to get a new industry off the ground, but volunteers do not support an industry and do not create the stable foundations of an industry.
So how do we solve the fact that we are exceeding soon our carbon limits and also ramping our carbon removal? One policy idea that is really just the translation in a practical sense of what net zero means is that for every tonne of carbon emissions that enter the atmosphere, we have a tonne of carbon that’s being sequestered. That is the practical meaning of net zero. There is a policy that embodies exactly that. And it is popularized under the name, the carbon take back obligation. And all it means is that for every tonne of carbon that is extracted, a tonne of carbon is sequestered.
Now net zero, once we reach that point is Pretty simple to conceptualize and maybe simple to implement, but that transition to that point is quite challenging. There are several ways to handle this transition. One way would be to increase the percentage of sequestration that is required for every tonne of carbon that’s extracted. This would increase gradually from Zero today, all the way to 100% when we reach net zero and could even go beyond that so that we have negative emissions. The problem with increasing that percentage in this way is that it creates a moral hazard.
It creates the incentive that the fossil fuel industry would try and spend down their fossil reserves as fast as possible, given this moratorium that’s coming for them. The alternative might be to start the carbon liability today. Every tonne of carbon that is emitted today has that liability to be sequestered. Of course, here the problem is reversed. We still do not have enough sequestration options to sequester 40 gigatonnes per year today. So we need something to ramp it up. And that something might look like permits to cover the emissions that continue to be emitted, as well as futures that would be provided to companies who are storing carbon and eventually exchanged for a certificate of sequestration when they demonstrate that they have sequestered the carbon.
By demanding that the liability for carbon extraction starts today creates a demand for carbon removal. Because we know that from today onward, the amount of carbon that will need to be sequestered. Now, the other thing I would add to this idea is that To simplify and make the carbon accounting as accurate as possible, this policy needs to be implemented as far upstream in the fossil fuel supply chain as possible. This means applying it on the fossil fuel producers. Demanding that they pay for sequestration for every tonne of carbon that they are extracting from the ground starting today.
The permits, the futures, and the certificates handle the transition to a 100% carbon debt payback, let’s say. And with it creates that demand for carbon removal. The second part of that proposal is that by placing this policy all the way upstream, it means that everyone downstream purchases a product that is now neutralized. So even though we should be additionally incentivizing to reduce our consumption of fossil fuels, we also need to take care of that transition. And the way we take care of a transition like this is by disarming the product before it gets to the consumer.
It means that every consumer would then have a certain percentage of their carbon footprint already neutralized before it gets to them. This simplifies net zero goals for absolutely everybody else downstream of the fossil fuel producers. It holds them accountable. And then the last part, going back to the simplicity and the accuracy, when fossil fuels are extracted, this is the last time in their supply chain that we know how much carbon was there. If we go downstream, either to the end consumer, where there are eight billions of us, the accounting and the tracking of those emissions get incredibly complicated.
If we go midstream, as we are currently attempting to do by requiring businesses to track their emissions, again, we are making the carbon accounting, the tracking, and the accuracy of that system much more difficult. Upstream is where the fossil fuel producers are already recording their products in national databases for Tax purposes for royalties. And this is where we know where all of the carbon is with accuracy. So this idea of a carbon take back obligation is really just saying that we need to sequester a tonne of carbon for every tonne of carbon that is produced.
It’s very simple, but it’s also very effective. And all we need to do is handle that transition, which will be tricky, just like it will be tricky, no matter which policy we’re going to try and implement. I think I will stop here and would take questions on any of the parts that were not clear.
Wil Burns: All right. Thank you so much for that, Stephanie. And I want to encourage anybody in the audience that has any questions to populate the Q&A box, because we’ll have a few minutes at the end to answer those questions also. So a couple of initial questions, Stephanie. One is... I don’t know if this is entirely a fair question, but do you think this is a politically feasible approach, right? It’s my understanding that this was tried in the UK a few years ago, for example, and beaten back largely due to, you know, understandable industry opposition.
Do you think there’s a way to make this politically palatable and viable in 2023?
Stephanie Arcusa: Yes. So let me try and address that. You are absolutely correct that it was beaten back by the industry in that particular case. Since then, we have seen some interesting developments both in Europe and in California. So the European Commission has introduced a proposal called the Industrial Net Zero Act. And in that proposal, which covers the fossil fuel producers, they have a quote unquote soft version of the carbon take back obligation. And I mean soft because it doesn’t cover all of the fossil fuel producers. It’s also very weak in terms of it’s only requiring a very, very modest percentage of their emissions to be covered by such a requirement, but it’s there.
And I think the fact that it’s there is an interesting development. It is currently being fought by the fossil fuel industry, once again. So that is a fight that will really need to be watched. The other region that’s been thinking about this is California. California also introduced a bill called SB 308, and I think it was The Carbon Dioxide Removal Market Development Act. And they similarly have something like the carbon take back obligation. It’s also kind of a soft version because it’s applied way downstream and not quite upstream, but the spirit of it is there.
So in my view, the options for the fossil fuel industry are dwindling. We, the people, want climate action. The options on the table are becoming increasingly unpalatable for the fossil fuel industry, right? Right now we’re considering a complete ban on fossil fuels. It is not in their interest to support that, right? But the alternative is that they continue to produce emissions and Just seeing the devastation of this year’s climate impacts, which are only going to be increasingly worse, it seems to me that there are days are numbered on that front too.
And a carbon take-back obligation is a weird in-between position because it is pretty much neutral. It doesn’t eliminate them. But it also doesn’t let them continue the way they have been operating today. And so as a compromise, it seems pretty strong. I think it’s only a matter of time before that discussion really becomes into the public space. And from the point of view of civil society, this is the kind of policy that We’ll get the job done because it is targeting, neutralizing the emissions and it is not, let’s say channeling, it is not channeling an economic instrument to try and curb behavior.
So the impacts are much different for civil society.
Wil Burns: Okay. All right. One other question. Environmental justice implications of this, right? If you’re the fossil fuel industry and you can meet your net zero obligations through sequestration, then arguably it allows you to continue to produce fossil fuels that have lots of negative effects. And the environmental justice community, you know, in general, one of its objections to CDR is this very issue, right? And it doesn’t seem like a CTBO gets us past that, or indeed it might even structuralize it in some ways. What would you say in response to that challenge?
Stephanie Arcusa: Yeah, I mean, I’m very sympathetic to that point of view because it is true. It doesn’t slay that dragon. It doesn’t slay the fossil fuel dragon in any way. But what it does do is that it does hold them accountable for at least one aspect of their defective product. The one aspect that’s causing climate change. Now, other aspects that are harming communities around the world also need to be Addressed, but they do not need to be addressed by the same instrument. And I think that’s where oftentimes there is a tendency to try and lump things together to try and get things done.
But in this context, I’m afraid it just slows everything down because it’s so easy to be against the policy because it doesn’t include something else or because it does include something else. So by Separating out this carbon problem, holding fossil fuel industry accountable for their carbon and defective products solves that one issue. The issues of air pollution, water pollution, or any harm that are being done in how the projects are implemented are also needing to be addressed, but with their own efforts and their own solutions. So I would say that there is nothing stronger than having finally a tool that holds the carbon, the fossil fuel industry accountable.
And by pressing on that, I think the results could be surprising in terms of their viability to remain in operations.
Wil Burns: Yeah. All right. So I think we only have one remaining question in the box as we wind down. And so I’m going to ask that and we’ll call it a day. And it’s for you, Stephanie. It says, could you please elaborate how a CTBO would affect consumers, including lower income households who spend a larger share of their incomes on still fossil based energy? Another justice question.
Stephanie Arcusa: Yeah, and I think that’s a fascinating question because in a climate action context, if we only rely on carbon taxes to change behavior, given that our goal is zero emissions, the carbon tax would have to climb to over a thousand dollars per tonne. And that gets passed on to consumers on purpose, right? Because we want to absolutely stop the consumption of fossil fuels. So that cost is enormous when we think about what it actually will do to everyday lives. Now, if that’s the model we are pursuing, that we are trying to change behavior, then this is where it will have to go.
The CTBO, which Can actually be done in parallel with a carbon tax if we really want to. The CTBO is only saying that the price increase will be what the cost of removal is. So if we think about, you know, and this is quite optimistic, but if we think about a cost of removal of $100 per tonne, this would equate to something like 30 to 40%. And that would equate to a price increase of about $1 at the pump per gallon. Since the Ukraine Russia war, We have seen a $1 per gallon increase in prices at the petrol station.
And this is what we’re talking about here. But now this increase would actually directly go towards neutralizing the fossil fuels that we’re consuming. So in some sense, it is taking care of the carbon problem in a way that will be cheaper than if we are to go the carbon tax route. If we were to actually want to stop consumption of fossil fuels, which would require over a thousand dollars price increase. Now, the thing I will say is that no matter what we choose, it doesn’t have to be implemented in a way that doesn’t consider vulnerable communities.
There can be other instruments or other laws that are considered that would help, you know, financially Vulnerable communities or groups. So it doesn’t have to be all or nothing. There can be other programs set in place to actually make the burden less so on those communities.
Wil Burns: Yeah. I mean, when it comes to carbon taxes, for example, we have rebates for people at certain income levels, right? Though it’s harder when, of course, you’re imposing this not at that level, right? And you’re imposing above. So there’s just trade-offs, right? And it’s definitely a good question, though, and a thing to consider if we were crafting this to operationalize it. So I’m inclined to close out this session. I think these are both really interesting sort of proposals. And again, in my opinion, we’re ultimately going to have to start talking about hard regulatory mandates if we’re ever going to tenably scale up to the massive levels that we’re going to have to.
We’re just not at We’re going to get to where we are relying on the kindness of strangers, right? And so I think these are both very creative sort of proposals, Dan and Stephanie, that you’re discussing and I encourage you to continue with this work. It’ll be interesting to see what happens with your petition, Dan, and your work, Stephanie, with I know I want to thank everyone. I want to give a special shout out to Jen Brown, who is our project manager at the Institute, who operated all of the back end of this conference, to everyone who served as moderators, obviously to all of our wonderful speakers.
And I look forward to seeing many of you Both virtually and live in the future as we continue to scrutinize the role of carbon removal in terms of climate change. So once again, thank you to everyone and goodbye now.
Unknown speaker: Thank you.
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