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ARTICLE · 10 NOVEMBER 2026

CNRA Seeks Comments On Draft Framework For Carbon Sequestration Unitization Agreements

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California's Natural Resources Agency has released a draft framework under Senate Bill 905 that outlines how carbon sequestration project operators can aggregate underground pore space across multiple properties through unitization agreements. The framework establishes a 75% consent threshold, compensation requirements, and liability provisions, while raising potential legal questions around property takings, subsurface trespass, and environmental review obligations.

United StatesEnergy and Natural Resources
Myles Culhane
Myles Culhane

Comments due Nov. 13, 2026

The California Natural Resources Agency (CNRA) is seeking comments on its June 2026 Draft Framework for Governing Agreements Pertaining to Carbon Sequestration, prepared under Senate Bill 905 (SB 905) (Caballero, Ch. 359, Statutes of 2022). The Draft Framework recommends how operators may aggregate underground “pore space” (the open spaces within rock formations where carbon dioxide can be stored) across multiple land tracts to develop carbon capture, removal, and sequestration (CCRS) projects.

SB 905 directs CNRA to publish a framework for agreements among owners of two or more tracts of land overlying the same geologic storage reservoir. These agreements allow CCRS projects to be managed, developed, and operated as a single unit – a process known as unitization. Unitization is intended to prevent individual property owners from holding out, either to block a project or seek disproportionate compensation. The framework also seeks to provide landowners

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