A Best-Case Scenario for Putting Carbon Back Underground

A Best-Case Scenario for Putting Carbon Back Underground

By Holly Jean Buck

Special Issue, Geoengineering

This article is co-published in Jacobin magazine.
Artwork by Matteo Farinella

The Need for Carbon Removal

Massive removal of carbon from the atmosphere—also known as negative emissions, carbon drawdown, or regeneration—could be a cornerstone of either dystopian or radically utopian futures. Some of the dystopian ones are well known: vast conversion of land to plantations for biofuels with carbon capture and storage, displacing people from the land, destroying habitats, and spiking food prices. But given what we know about climate change in 2018, it’s not enough to protest against dystopian versions of carbon removal. Too much warming is already locked in. We need a radically utopian way of removing carbon.

If we buy into thinking of carbon removal technologies as substitutes for reducing carbon output, then industrial interests have already won: they have set the narrative and the framing, where carbon capture exists so that they can continue to emit. But we should demand more from these technologies. Industrial carbon capture technologies could instead be used as an extension of decarbonization—mitigation to get us to zero, and carbon removal going a step further to take emissions negative and address some of the climate impacts already being felt. It won’t be easy. But climate science suggests it’s a challenge the Left must take up.

Climate change has already warmed the planet over 1°C relative to pre-industrial levels. Paradoxically, cleaning up the air pollution that’s currently masking some of the global warming in the pipeline would raise temperatures another 0.5 – 1.1 degrees.1 This means that if we waved a magic wand and suddenly (1) stopped using fossil fuels, and (2) cleaned up air pollution, we would already be breaching 1.5°C, the amount of warming that most climate advocates have argued for. The carbon budget is not an exact science, but it seems we are hovering at the point where 1.5°C of warming is locked in by what has already been emitted. Put differently, the most recent scientific evidence suggests we have zero to five years before every additional ton of carbon dioxide emitted would need to be compensated by a ton of negative emissions to stay below 1.5°C.2

In fact, the scenarios used in the fifth Intergovernmental Panel on Climate Change (IPCC) report rely on massive amounts of negative emissions to curb warming to 1.5°C, primarily via a method known as bioenergy with carbon capture and storage (BECCS). This led a team of modelers to try and see what it would take to achieve 1.5° without BECCS. Even a scenario where renewables, electrification, and energy efficiency were aggressively pursued—as well as replacing 80 percent of meat and eggs with cultivated meat, flying less, and eliminating tumble dryers—could not eliminate the need for carbon removal. This scenario still required about 400 billion tons (Gt) of carbon dioxide removed via reforestation.3 Reforestation sounds great and green, but it also has the potential to result in dispossession, conflict over land access, and smallholder livelihoods.

What about achieving a slightly less ambitious goal of 2°C? Two and 1.5 degrees might not sound all that different, but they are. The difference is one that threatens entire unique coral ecosystems, the homes of five million people4 (including entire countries), and high increases in the frequencies of extreme events. Rapid mitigation could still curb warming to 2°C without the use of negative emissions technologies. But that window is closing fast. If near-term emissions reductions follow the trajectory laid out in the commitments nations made under the Paris agreement, by 2030, 2°C scenarios will also depend upon negative emissions.5 That is, in the next decade, we would have to vastly exceed the Paris promises to not depend upon negative emissions.

We aren’t even making much progress towards these Paris targets, which if achieved would still produce 3°C of warming—an amount widely agreed to lead to massive disruptions. This is why negative emissions have become such a useful device for the models. By the end of the century, scenarios for 1.5°C or 2°C envision pulling out ten billion tons (10Gt) per year. For comparison, current levels of emissions are around forty billion tons of CO2 per year. So 1.5°C means not just zeroing out those forty billion tons, but then working to extract another 10 billion on top of that to be net-negative. This would require scaling up current carbon capture and sequestration efforts a thousand-fold.6

Negative emissions help maintain the narrative that although time is running short, we can still stop catastrophic global warming if we act now.7 Once we understand that this inventive arithmetic has been employed to “solve” for 1.5, what do we do?

Assuming there will be a complete about-face that puts us on a course towards 100 percent renewables, massive lifestyle changes, and drastic land use change for afforesting millions of hectares in the tropics8 within the next ten years strikes me as not only magical thinking, but thinking that puts many at risk of great suffering.

Alternately, accepting that the earth will warm more than 1.5°C means accepting the loss of the world’s coral reefs and the half billion people relying on them, as well as other harms to communities living on the front lines of climate change.

So we need to ask: Is there a form of massive carbon removal that could be put towards socially just ends, pulling carbon out of the atmosphere as a form of collective social good? Can it work as an outgrowth of energy democracy? For if such a collection of technologies, practices, and institutions can exist, we should try to build it. Notably, carbon removal at what I’ll call climate-significant scale should not be thought of as a magic wand to wipe carbon away either. For one thing, it will not compensate exactly for emissions. The ocean, for example, currently takes up close to half of the carbon humans emit, and it’s possible that if carbon was removed at large scale from the atmosphere, the oceans would then give off carbon, perhaps replacing half of the carbon that had been removed.9 The prospect of carbon removal is fraught with complexity, and even peril—all of which we have to talk about.

The Necessity of Geological Sequestration

The best way to remove carbon immediately is through “natural climate solutions,” which employ nature’s processes to store carbon in ecosystems. Sequestering carbon in soil, restoring forests and planting new ones, and protecting wetlands can store carbon. These can forestall some amount of warming, in addition to other benefits for both humans and the environment.

Yet while it seems intuitive to simply let nature take up the carbon, carbon was put into the atmosphere unnaturally, and the available scientific evidence suggests ecosystem-based solutions simply don’t scale well enough to contend with the sheer amount of carbon that has been dumped into the atmosphere. Pursued vigorously, reforestation and soil carbon sequestration could each remove a few gigatons per year—for a while. After a few decades, a forest planted to remove carbon reaches a plateau where it becomes saturated and can’t remove any additional carbon, like a bathtub filling up, at which point the already-absorbed carbon must simply be held indefinitely. Similarly, a farm that has transitioned to regenerative practices to store more carbon in the soil can only remove additional carbon for a few decades. Moreover, forests can be ravaged by epidemics or fires, resulting in the sudden release of their stored carbon, which means they are vulnerable to global warming itself.

So while these projects can do important work in the near future, we also need to supplement these one-off, land-based carbon removal projects with systems that can continuously remove carbon and store it reliably over centuries — that is to say, with industrial carbon capture with geological sequestration. We need to build systems that capture carbon emissions from sources like power plants or factories, or even from ambient air, and transport it to underground reservoirs where it can be stored.

There are major technical and social obstacles to this. But these industrial systems for geological storage, used together and sequentially with natural carbon removal, could help ease the path to a climate-stable world.

Carbon capture and storage (CCS) technology is not a new technology. The first large-scale operations began in the 1970s, and there are around 17 CCS projects operational today. CCS is actually a collection of technologies: those needed to capture carbon emissions at a source; technologies to transport it, usually by pipeline, to a storage site; and technologies to inject it deep underground. It can be used with industrial operations like cement or steel production, with natural gas power plants, with biomass-fueled power plants (BECCS), or in tandem with devices that mine carbon from the air (“direct air capture”). But only in the latter two cases does CCS confer “negative” emissions and actually remove carbon—if it’s installed on a fossil fuel plant, all it’s doing is avoiding some emissions.

Its history is tainted by two things: its linkage with the coal industry, and its use for enhanced oil recovery, a technique which injects carbon dioxide into the ground to retrieve more oil from depleted wells. Understandably, this has predisposed people who care about the climate to be very skeptical of the technology and the actors who promote it. Recent experiences with fracking have also made people rightfully wary about injecting large volumes of fluid and gas underground. Once carbon is injected into reservoirs, moreover, it can be difficult to monitor.

We need to give CCS another look despite these reservations. Several decades of experience with the technology have improved monitoring technology dramatically and developed best practices for mitigating local risks. The IPCC finds that the local health and safety risks are on a similar scale to those of the current hydrocarbon infrastructure.10

It’s not ideal to replace one hazardous network of infrastructure with another—except in this case, putting the carbon back underground ameliorates the much greater risks of global climate change, which will be felt around the world. In short, it is safer to have the carbon back under the ground than in the atmosphere. The carbon removal technology that’s typically used as a stand-in for negative emissions in integrated assessment models is known as bioenergy with CCS (BECCS). BECCS refers to a system where carbon is captured from a power plant that runs on biomass like switchgrass or poplar trees; the captured carbon is then transported and stored underground.

In the real world, BECCS lacks strong proponents. Critics point out that attempts to scale up the use of biofuels have already had major implications for land use, and consequently, for ecosystems as well as for people whose livelihoods depend on the land. One common estimate is that using BECCS to remove 600Gt by 2100 would require dedicated cropland of 430-580 million hectares—equivalent to one-half of the land area of the US.11 Using BECCS at climate-significant scales could have dramatic impacts on biodiversity and freshwater resources.

It also can’t be used in every situation: to actually be carbon-negative, BECCS has to meet stringent conditions regarding everything from supply chains to fertilizer. Socially and ecologically just supply chain management requires still more, including fair wages for workers, measures to safeguard biodiversity, and worker or communal ownership of land. These drawbacks and challenges mean that we shouldn’t rely on it as the primary mode of carbon removal, but BECCS could still be useful in specific contexts.

A method known as direct air capture, on the other hand, is potentially less land intensive, but it requires massive amounts of carbon-neutral energy. Direct air capture machines absorb carbon from ambient air through a chemical process; then the carbon must be removed and stored underground, as if the carbon had been captured at a power plant. But because direct air capture machines could be located at the site of underground injection, they could have less of an infrastructural footprint. The downside is that it’s currently very expensive, with estimates ranging between $100 and $600 per ton of carbon removed depending on the energy source used.12 So while direct air capture seems to have more potential to remove carbon at climate-significant scales than BECCS, far more work is needed to refine the technology.

All of these technologies require both more funding for research and development as well as strong policy incentives to mature, whether that means a robust price on carbon or government pollution controls. On the bright side, perhaps this means they are more likely to be an extension or complement to reducing carbon output rather than a substitute for it. Without heavy state intervention, it is impossible to imagine CCS scaling up over the century to climate-significant levels. The storage capacity of geological reservoirs is sufficient that there aren’t geological limits to carbon sequestration. Eventually, there would be systemic limits for inputs to CCS—land in the case of bioenergy; renewable energy supply in the case of direct air capture—and so the yearly rate of carbon sequestration would be constrained.

This means that a full carbon-clean up—that is, if the world wanted to bring greenhouse gas concentrations back to pre-industrial levels, as a restoration or recompensation project—could stretch over centuries. But the near-term practical constraints on CCS are grounded only by political will.

In a best-case scenario, carbon capture and sequestration would be the world’s most massive pollution clean-up operation, conducted as a public service. But if the public is paying for it, there’s an obvious problem: most of the technology for removing carbon currently lies in the hands of fossil fuel polluters who are already experienced in it via enhanced oil recovery (EOR).

With EOR, a well operator injects something—heat, chemicals, water, or gas like carbon dioxide—into an oil well that’s been depleted, which basically flushes the residual oil out, extending the life of the well. Perversely from a climate change standpoint, carbon dioxide is currently being mined for use in enhanced oil recovery from natural sources in Colorado and elsewhere, and piped to areas like West Texas for oil recovery. The US already has a 4,500-mile network of CO2 pipelines primarily for this purpose,13 and the carbon dioxide supply still can’t meet the demand of the oil producers.

The fact that the industrial tools for carbon clean-up are primarily in the hands of polluters means that worse-case scenarios for large-scale geologic carbon removal are likely: (a) that carbon capture remains used primarily for enhanced oil recovery and fails to scale and achieve net-negative emissions, or (b) that CCS will be a bailout or way forward for the very same industries that put the pollution there, who paradoxically may transform themselves over this century to, in the words of Gavin Bridge and Philippe Le Billion “stewards of underground carbon stocks rather than extractors of oil.” The oil production network could become a waste-carbon conveyer, dominated by actors who own or control carbon reservoirs.14

Carbon removal infrastructure isn’t only a matter of heavy, material capital, but of carbon data and platforms for managing it: tracking the farms and forests where it is stored, as well as the places it is emitted; monitoring the wells where it hopefully stays; and transmitting data for micropayments to carbon-storers, as well as data to regulatory agencies. Along with the Internet of Things, we would see the Internet of Carbon, made possible by emerging sensing and communication technology.

And as K. Sabeel Rahman observes, “If a firm controls infrastructure, it possesses arbitrary power over all those who rely on the infrastructure.”15 This raises important questions that go beyond those traditionally associated with fossil fuel politics: We live in an era of “platform capitalism,” in which a small number of tech companies dominate the platforms on which we all carry out all kinds of work. Will we see this kind of dominance in carbon capture, too? Is there hope for a more diffuse, decentralized system of carrying out this work?

Certainly not if there’s no one to advocate for it. But the green groups and climate justice advocates who would need to fight for a more just version of carbon clean-up are predisposed to dislike CCS. At precisely the moment when climate policy at the UN level is poised to revisit carbon capture and storage in the light of “negative emissions” discussions around the 1.5°C target, and when policymakers in a US context have actually passed bipartisan legislation to incentivize carbon capture (the 2018 FUTURE Act, reforming a tax credit for CCS), there is not enough engagement around what a progressive and justice-oriented use of these technologies could look like.

From Imagination to Action

Imagining a justice-oriented implementation of carbon removal would need to be designed through a collective and participatory process. On the capture side, carbon removal requires measures to ensure environmental justice throughout the value chain for biofuels, including social safeguards that actually work. It also requires full-circle, responsible waste disposal from direct air capture facilities and other industrial processes, and open-source platforms and technologies for tracking where the carbon goes. Most critically, a socially just carbon removal plan would require policies that help people access clean energy without higher costs, and fair wages for producers and workers throughout carbon removal systems.

On the sequestration side, just carbon removal projects would require just compensation for use of underground storage (pore) space, clear liability for damages caused by blowouts and accidents, and recognition, reckoning, and restitution for historical and current injustice surrounding extraction and fossil fuel production—including the injustices towards indigenous peoples and other groups whose land has been taken for extraction and production.

This is just a start. To achieve even a part of this agenda, social and environmental justice advocates will need to be extremely strategic. Here are five places to begin.

1. Engage in regulatory processes that are happening right now.

Right now, regulations are being drafted for how CCS will be treated in climate policy. In California, regulators are currently considering whether fuels produced with CCS for EOR will become part of California’s Low Carbon Fuel Standard—the strictest in the nation. On the national level, the USE IT act proposes to provide funding for research on direct air capture and pipeline development. The FUTURE Act, passed in February 2018, reforms Section 45Q, the US tax credit for carbon capture and storage—it increased the tax credits for CCS stored via EOR from $10 to $35, and for carbon storage from $20 to $50. Unsurprisingly, lobbyists from fossil fuel companies are actively working to weaken the monitoring requirements.

For example, to claim the 45Q tax credit, companies must verify and report to the EPA that the carbon stays underground. Yet Clean Water Action (CWA) found that while nearly sixty million metric tons of CO2 were claimed to the IRS as of mid-May, 2018, only three million metric tons of CO2 were reported to the EPA for verification.16 CWA’s demand is “No Sequestration Without Verification.”

The very idea of offering tax credits for EOR, moreover, illustrates a broader challenge: that polluters are first in line to benefit from carbon capture. A letter signed by organizations such as 350.org, Greenpeace USA, Clean Water Action, Friends of the Earth, and others called the FUTURE Act a “handout to oil companies,” because it extends tax credits for enhanced oil recovery. They also point out that EOR affects people of color and disadvantaged communities, who disproportionately live near oil fields.

These challenges illustrate why it’s critical for the left to be involved in shaping the means of developing and scaling up these technologies: we can’t leave them up to the oil companies.

2. Carefully target the worst industrial offenders—while discussing the problems of these stranded assets collectively and publicly.

Behind discussions of carbon removal lurks a key question: What do we do with fossil fuel interests? From the standpoint of these actors, “negative emissions” could be used to compensate for some amount of their “residual emissions”—continued emissions from fossil fuel-intensive sectors like heavy industry, aviation, or shipping. Carbon removal could provide a conceptual lifeline to these industries. Social justice advocates will have to articulate a view of carbon removal for the people, not for companies to avoid stranded assets.

According to a report by the Carbon Disclosure Project, just one hundred companies are responsible for 71 percent of the world’s emissions — and half of industrial emissions can be traced to just 25 companies, according to a report by the Carbon Disclosure Project.17 It then seems simple to say we could just shut these companies down.

The challenge is, of course, that fossil fuels aren’t just a corporate asset—they’re also embedded in public revenues worldwide. Three-quarters of oil extraction is not done by oil “majors” like Exxon and Shell, but by national oil companies. Even where private companies are prevalent, oil producer governments still capture a large part of revenues—on average, 70 percent of revenues, from 40 percent in the US to 95 percent in Iran.18

Consumer governments also raise revenues from taxing fossil fuels. And privately held companies are largely owned by pension funds, meaning that all kinds of citizens are caught up in their fates. If oil prices went back up to $100 a barrel, the 1700 billion barrels of oil in reserves add up to $170 trillion of unburnable carbon—two years’ worth of global GDP.19

The infrastructure at stake is also worth tens of trillions. “Negative emissions” to stretch out continued emissions for the life of these infrastructures will be enticing not only to corporate interests, but to governments. The entanglement of states, citizen investors, and fossil fuel producers also means that if the turn away from fossil fuels truly happens, the public will be left holding a lot of debt and liabilities. Getting off of fossil fuels may mean we’re headed for bailouts that make the post-2008 bank bailouts look like crumbs.

This implies two things: (1) if private firms like oil companies are the vehicle for providing carbon removal services but they go bankrupt, the carbon won’t get removed after all, and (2) transforming these firms into publicly run carbon removal entities might be the best option out of a host of dismal options.

Nationalization also needs to be on the table, though done poorly it can bolster corrupt regimes without power going to workers.20 There needs to be a broader discussion that recognizes how entwined these companies are with the state, anticipates bailout actions or clean-slate bankruptcies in a forward-thinking, offensive way; and conceptualizes and legislates carbon removal in ways that clearly mandates that farms, forests, and carbon capture plants aren’t removing carbon just so that industrial interests can continue to profit and save assets from being stranded.

3. Create our own narrative around carbon removal, and formulate demands.

There are already NGOs, educators, and environmental and social justice advocates working to change the narrative around climate change to one of proactive action around drawdown, regeneration, and carbon removal. They have different approaches, but a shared message is that it’s necessary and possible to reduce climate risk and make a better world by removing carbon from the air. The Left can take this narrative further by examining the possibilities for restorative justice—for example, that emitters with historical carbon responsibility pay for carbon removal. Reconceptualizing CCS in particular leads the way to make use of these techniques for redistributive ends.

Of whom do we demand carbon removal? The state, first and foremost. History provides an example of the role of the state in providing investment—including the construction of the automobile and oil infrastructure we have now. The demands need to be both very specific and very broad. We are just at the beginning of public debate, but demands could include public funding for R&D, public ownership of carbon removal technologies and data, public sector jobs in carbon removal, and more.

4. Work in solidarity with rural organizations and producers.

A society dedicated to carbon removal at climate-significant scales could be an opportunity for rural re-invigoration—or one for rural oppression, dispossession, land grabs, and a continued transfer of wealth out of the countryside, furthering inequality and environmental injustice, in both developed and developing world contexts. In either case, carbon removal should be seen through the lens of a rural economic development issue.

Carbon removal policy could provide economic opportunities for farmers who take up regenerative agriculture, with support from urban consumers. On the infrastructure side, building out carbon capture and storage with direct air capture or BECCS would offer jobs with a similar skillset as those from the oil and gas industry, provided an effort was made to retrain workers into this similar field.

Connecting with unions and workers would be key here, as part of a wider just transition—though at present, the policy discussion on carbon capture virtually ignores workers of all kinds, with the exception of the work of alliances like Trade Unions for Energy Democracy.

5. Redirect subsidies and investments towards carbon removal and environmental justice.

Changing the subsidies for fossil fuels are what people point out as the first and most obvious step to decarbonization—the world currently subsidizes fossil fuels at $500 billion per year,21 or $15 per ton of carbon dioxide emissions. We should be paying for the damages instead of subsidizing what’s driving them. We should also be continuing the pressure to divest in fossil fuels, while pointing out social investment opportunities in carbon removal.

In California, Assembly Bill 1550, building on Senate Bill 535, requires that 25 percent of funds from California’s cap-and-trade program go to projects within disadvantaged communities, and another 10 percent go to benefit low-income households and communities.22 These types of legislative action, driven by many environmental justice advocacy groups, can provide ideas for how carbon removal funding could proceed—actions like these would be initial steps in making sure that the benefits from carbon capture programs accrue to people who have suffered from environmental injustice, and to alleviate inequality while transitioning to a carbon-negative society.

A moment of opportunity

This is the time for the Left to shape the agenda proactively rather than reactively. We need decarbonization—and then more. Settling for more warming when we have the capacity to lower carbon dioxide concentrations amounts to rich-world complacency.

The longer we wait to engage, the more likely that a big tech company will have built out the platform for carbon removal on its own terms, not public ones; the more likely that policymakers will have instituted a complex accounting scheme for “residual emissions” that lets industrial corporations keep polluting while small farmers are driven off their land so it can be forested to compensate. Or—more likely—these high tech and high ecomodernist visions will never materialize, and the world will simply warm, and species and lives and islands and ice will be lost forever.

The establishment’s ambiguity about CCS over the past few decades—the reluctance of elites to actually build the clean-up infrastructure they themselves suggest is possible, as they wait for the moment when they are forced to—leaves an opening for citizens in fields, factories, and labs to shape the development of these technologies. This is a moment where we might be able to shape the platforms upon which they are organized, where their benefits flow to, and who pays for it all. We can start this work as an extension of decarbonization, right now.

References

  1. Samset et al, ‘Climate Impacts From a Removal of Anthropogenic Aerosol Emissions’. Geographical Research Letters, 2018. https://doi.org/10.1002/2017GL076079
  2. Jan C Minx et al 2018 Environ. Res. Lett. 13 063001.
  3. Van Vuuren et al. Alternative pathways to the 1.5 °C target reduce the need for negative emission technologies
  4. Rasmussen, DJ, et al (2017). Extreme sea level implications of 1.5 °C, 2.0 °C, and 2.5 °C temperature stabilization targets in the 21st and 22nd centuries. Environmental Research Letters 13(3). http://iopscience.iop.org/article/10.1088/1748-9326/aaac87/meta
  5. Minx et al, 2018.
  6. National Research Council, Climate Intervention: Carbon Dioxide Removal and Reliable Sequestration. National Academies, 2015, p. 86.
  7. Geden, Oliver. ‘Politically informed advice for climate action.’ Nature Geoscience, 2018, https://doi.org/10.1038/s41561-018-0143-3.
  8. Why in the global south? Because afforestation for carbon storage is far more effective in the tropics – afforesting boreal forests means that the land cover is darker, which has a warming effect.
  9. See NAS, 2015, p. 25.
  10. IPCC Special Report on Carbon Dioxide Capture and Storage (2005). IPCC WGIII, p. 12.
  11. Williamson, Phil (2016). Emissions reduction: Scrutinize CO2 Removal Methods. Nature, https://www.nature.com/news/emissions-reduction-scrutinize-co2-removal-methods-1.19318.
  12. Fuss, Sabine, et al (2018). Negative emissions—Part 2: Costs, potentials and side effects. Env. Res. Lett. 13, https://doi.org/10.1088/1748-9326/aabf9f.
  13. https://www.energy.gov/sites/prod/files/2015/04/f22/QER%20Analysis%20-%20A%20Review%20of%20the%20CO2%20Pipeline%20Infrastructure%20in%20the%20U.S_0.pdf
  14. Bridge, Gavin, and Philippe Le Billion. Oil. Polity, 2013, p. 66-67.
  15. Rahman, K. Sabeel (2018). The New Octopus. Logic no. 4. https://logicmag.io/04-the-new-octopus/
  16. Noel, John. Carbon Capture and Release: Oversight Failures in the Section 45Q Tax Credit for Enhanced Oil Recovery. Pub. Clean Water Action, Spring 2018.
  17. CDP Carbon Majors Report 2017. Cdp.net
  18. Bridge, Gavin, and Philippe Le Billion. Oil. Polity, 2013, 136.
  19. Berners-Lee, Mike, and Duncan Clark (2013). The Burning question. P. 86. http://www.burningquestion.info/notes/
  20. See http://www.leftvoice.org/Nationalization-or-Buyout-What-Should-be-Done-with-the-Fossil-Fuel-Companies; https://www.jacobinmag.com/2018/03/nationalize-fossil-fuel-companies-climate-change
  21. https://www.imf.org/en/Publications/Policy-Papers/Issues/2016/12/31/Energy-Subsidy-Reform-Lessons-and-Implications-PP4741
  22. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160AB1550