Review of Project Permits Under the London Protocol – As Assessment of the Proposed P18-4 CO₂ Storage Sites

Publication Overview

The London Convention and Protocol is one of the first global agreements to protect the marine environment. The Protocol promotes the protection of the marine environment by prohibiting the dumping of wastes and other matter into the sea. Under the Protocol all dumping is prohibited, with the exception of a limited number of selected wastes. In 2007, an amendment entered into force which permitted CO₂ streams to be considered for dumping under the London Protocol. The amendment was shortly followed up with a set of “Specific Guidelines for Assessment of Carbon Dioxide Streams for Disposal into Sub-seabed Geological Formations”, developed to support the National Authorities of Contracting Parties in evaluating permit applications for CO₂ disposal activities in their marine territories. As few offshore CO₂ storage sites have been permitted in the territories of Contracting Parties, there is no evidence of the application of the above mentioned guidelines to actual permitting processes. The P18-4 field is a near-depleted gas field at a depth of 3.5 km under the seabed, located approximately 20 km off the Dutch coast in the North Sea. The operator of the gas field applied for a CO₂ storage permit to the Dutch authorities in 2011, for the storage of a maximum of 8 Mton CO₂. An irrevocable storage permit for P18-4 was provided to the operator in September 2013, however the project has been postponed indefinitely due to economic constraints. The objective of this report is to assess to what extent the proposed P18-4 storage site, originally part of the ROAD CCS Project, complies with the London Protocol’s 2012 Specific Guidelines for Assessment of Carbon Dioxide Streams for Disposal into Sub-seabed Geological Formations, and therefore the 1996 London Protocol itself. The assessment has been achieved through a simple, but systematic, cross-check of the requirements of the Specific Guidelines against the contents of the application material provided by the operator to the National Authority. This involves the appraisal of approximately 1100 pages of submitted material in order to identify evidence of compliance

Publication Summary

• The material submitted to the National Authority is broadly sufficient to allow an evaluation of the planned CO₂ storage activities in a manner consistent with the provisions of the 1996 London Protocol.
• This compliance assessment indicates overall technical compliance with the CO₂ Specific Guidelines, no information was sufficiently absent that would indicate clear non-compliance with the CO₂ Specific Guidelines.
• There are eight areas from within the application material which would benefit from further clarification. In addition, there is also one area of partial compliance and one of non-compliance from within the permit conditions which is the responsibility of the National Authority.
• A number of recommendations are provided to address some areas that have been identified by this assessment. The recommendations are relevant both for this specific case study, but also for future CO₂ storage permits in marine territories of contracting parties.