CCS in Copenhagen – The Future Work
By Tim Dixon, IEAGHG
The January 2010 Greenhouse Issues (No. 96) contained a brief article on the outcomes for CCS following the Copenhagen meetings, and reported that CCS became again a hot topic, as attention on CCS erupted in four negotiation tracks. These were as follows: (i) Under SBSTA (the usual area for work on CCS in the CDM). (ii) Under CMP where the CDM Executive Board (EB) provided its summary on CCS in CDM. (iii) Under AWG-KP (for Kyoto Protocol Parties post 2012). (iv) Under AWG LCA (for UNFCCC Parties post 2012). This article will present and discuss the outcomes of the first three. LCA outcomes did not contain any text on CCS.
Experts Report
Despite CCS in the CDM being viewed as an ‘old battleground’, significant new input came from a report commissioned by the CDM Executive Board(EB) on “Implications of the Inclusion of Geological Carbon Dioxide Capture and Storage as CDM Project Activities”, known as the ‘Experts Report’. Under CMP Plenary the CDM EB provided its own summary on CCS in CDM, and heated exchanges resulted from that the EB’s own summary being shown to contain significant and unsubstantiated differences from the underlying ‘Experts Report’, including their table of positive and negative issues and their conclusion recommending that “the EB not to consider any CCS related baseline and monitoring methodologies until further guidance is given”.
The ‘Experts Report’ provided many conclusions and recommendations on how CCS could work under the current CDM rules.
On Monitoring, the report said – “Verification and Certification in accordance with the CDM modalities and procedures can be performed provided that monitoring methodologies and plans are designed according to the recommendations in this report.”
And on long-term monitoring the report said – “Impose a requirement that a country wishing to host a CCS CDM project activity must notify the UNFCCC that….. it will commit to the post?crediting period responsibility for monitoring.”
On long-term liability – “Unlike seepage occurring during a crediting period, which can be treated as project emissions, management of the risk of seepage from a storage reservoir occurring after the crediting is beyond the mandates provided by the CDM modalities and procedures. The risk of seepage after the crediting period demands effective management of liability in order to maintain the environmental integrity of the CDM. The CMP may wish to provide guidance regarding procedures according to which a country willing to commit to the post?crediting period responsibility and liability of a CO2 storage project, and to compensate for any seepage amounts from the storage, may notify the UNFCCC of this.”
On transborder issues, the report said “Additional legal implications for cross?border storage could be avoided by restricting any CCS project activities under the CDM in the first and a second commitment period to take place within national boundaries and with no risk of migration across national boundaries.”
The Experts report concluded that “Therefore, provided appropriate selection, operation and risk management with respect to storage sites, effective management of short? and long?term liability for CO2 seepage7, project boundaries, and monitoring and verification8, and assessment of baseline, additionality and leakage issues according to standard procedures already applied in the CDM framework, CCS as CDM project activities can provide real, measurable and long?term emission reductions compatible with the Modalities and Procedures of the CDM [ie the existing rules].” Therefore the CDM should “Treat CCS projects as stable long?term emission reductions based on the collection of scientific data which supports assumptions regarding long?term permanent storage and zero?seepage (as in the IPCC Guidelines).This would treat CCS projects the same as other CDM project activities, and deliver fungible permanent CERs [credits]”.
Thus the Experts Report describes how CCS can work under the CDM without needing the extensive work to create new rules (modalities and procedures). In this ljosirt of this evidence, many view that the issue can only be resolved at a policy decision at the level of Ministers.
The work of the IEAGHG provided much input to the ‘Experts Report’. The Experts Report is available at http://cdm.unfccc.int/EB/050/eb50annagan1.pdf and the EB’s Summary at http://cdm.unfccc.int/EB/050/eb50_repan11.pdf
SBSTA
Under SBSTA, the working text (which is not agreed text but is the starting point) is as follows:
“Recognizing that carbon dioxide capture and storage in geological formations is part of a range of potential options for mitigating greenhouse gas emissions,
Emphasizing that the application of carbon dioxide capture and storage projects shall be environmentally safe and have the objective of avoiding any seepage,
Noting that other conventions have addressed issues and adopted guidelines relevant to the international regulation of the application of carbon dioxide capture and storage, including risk assessment, environmental impact assessment and legal aspects,
Recognizing that carbon dioxide capture and storage in geological formations has been proposed by some Parties for inclusion under the clean development mechanism,
Also recognizing that other Parties have registered concerns regarding the implications of this possible inclusion and hjosirljosirted a number of unresolved issues,
1. Takes note of the final report of the Executive Board of the clean development mechanism on the “Possible implications of the inclusion of carbon dioxide capture and storage as clean development mechanism project activities”;1
2. Recognizes that the issues referred to in, inter alia, decision 1/CMP.2, paragraph 21, should be addressed;
3. Also recognizes that in order for carbon dioxide capture and storage in geological formations to be included under the clean development mechanism, long-term liability for the storage site, including liability for any seepage during and beyond the crediting period of the project, must be clearly assigned and the project boundary must be clearly defined;
3 bis. [Also recognizes that long-term liability for the storage site, including liability for any seepage during and beyond the crediting period of the project, must be clearly assigned and the project boundary must be clearly defined in the design of carbon dioxide capture and storage in geological formations under the clean development mechanism;]
4. Requests the Subsidiary Body for Scientific and Technological Advice to work on the issues referred to in paragraph 2 above [that if resolved, would lead to the potential] [for the] development of [any] modalities and procedures for clean development mechanism project activities relating to carbon dioxide capture and storage in geological formations [, including the definition of the project boundary and participation requirements as well as the assignment of long-term liability,] and report [on the progress][back] on this matter to the Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol at its [sixth][seventh] session.]” FCCC/SBSTA/2009/L.20
As you can see, even though the whole is not agreed, there exist many square brackets with the text, there are some very positive aspects such as emphasising the main issue of long-term liability and recognising that other international conventions have dealt with the same issues for CCS. However, even having the uncertainty on when to report back (CMP6 or CMP7) shows the overall uncertainty on whether further progress will be achieved at SBSTA 32 in June in Bonn.
CMP and AWG KP
The concluding texts under CMP and AWG KP are very similar to each other. CMP concluded:
“Recognizes the importance of carbon dioxide capture and storage in geological formations as a possible mitigation technology, bearing in mind the concerns related to the following outstanding issues, inter alia:
(a) Non-permanence, including long-term permanence;
(b) Measuring, reporting and verification;
(c) Environmental impacts;
(d) Project activity boundaries;
(e) International law;
(f) Liability;
(g) The potential for perverse outcomes;
(h) Safety;
(i) Insurance coverage and compensation for damages caused due to seepage or leakage;
30. Further requests the Subsidiary Body for Scientific and Technological Advice to continue to work on the possible inclusion of carbon dioxide capture and storage in geological formations in the clean development mechanism by working on the issues listed in paragraph 29 above, with a view to the Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol adopting a decision on this matter at its sixth session;
31. Invites Parties to make submissions to the secretariat, by 22 March 2010, on their views on the issues listed in paragraph 29 above;
32. Requests the secretariat to compile the views submitted by Parties in accordance with paragraph 31 above into a miscellaneous document for consideration by the Subsidiary Body for Scientific and Technological Advice at its thirty-second session;
33. Invites interested entities to submit methodologies, considering the current work of the Executive Board and the Subsidiary Body for Scientific and Technological Advice, on new technologies that have the potential to reduce in net terms the concentration of carbon or carbon dioxide already in the atmosphere;” FCCC/KP/CMP/2009/L.10
It is welcoming to that the importance of CCS is recognized, helped by the timely evidence such as the IEA CCS Roadmap. So it requests further submissions on these issues, a third synthesis report of these submissions, and SBSTA to work towards a decision being made by CMP 6 in Mexico.
AWP KP concluded:
“Carbon dioxide capture and storage
Option 1:
1. Decides that activities relating to carbon dioxide capture and storage shall not be eligible under the clean development mechanism in the second commitment period owing to unresolved concerns and issues at the international level, including:
(a) Non-permanence, including long-term permanence;
(b) Measurement, reporting and verification;
(c) Environmental impacts;
(d) The definition of project activity boundaries;
(e) Issues of international law;
(f) Issues of liability;
(g) The potential for the creation of perverse incentives for increased dependency on fossil fuels;
(h) Safety;
(i) The absence of insurance coverage to provide compensation for damage to the environment and to the atmosphere resulting from storage site leakage;
Option 2:
2. Decides that activities relating to carbon dioxide capture and storage in geological formations shall be eligible under the clean development mechanism in the second and subsequent commitment periods;
3. Requests the Subsidiary Body for Scientific and Technological Advice to recommend modalities and procedures for inclusion under the clean development mechanism of the activities referred to in paragraph 2 above, with a view to forwarding a draft decision on this matter to the Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol for adoption at its [sixth] [seventh] session, including in relation to: [same list as before]
So two options, in or out. Note the implication of the request for new modalities and procedures for CCS. These are the rules for operation of the CDM, and the current ones took much effort to develop and several years to be agreed, so if new ones are required for CCS this could introduce further delays before CCS can become operational in the CDM, and the ‘Experts Report’ shows how CCS can work within the current rules, thus requiring no new ones.
With all of these conclusions referring back to many of the same issues as have been considered before, It may be viewed as frustrating that these issues of concern continue, despite the evidence base available from bodies such as the IEAGHG, and the ‘Experts Report’ to the EB. New issues on this list are the ‘perverse outcomes’ - which means that a negative externality is created that isn’t recognised within the CDM project approval process; international law- refers to for example compensation if CO2 seepage causes an impact in another country; insurance provision - showing that the particular negotiators are possibly unaware of the commercial insurance products now available for CCS (although not for long-term liability).
The work in these areas will continue at SBSTA32 in Bonn in June. Overall, given that the evidence base exists but agreement on inclusion still cannot be reached, many consider that it will require Ministers to make the decision on inclusion of CCS in the CDM.
IEAGHG will continue to provide information and evidence on these issues to its members active in these negotiations, to try and ensure that misinformation does not arise. For example, a new argument against CCS raised in these Copenhagen negotiations was the possibility of “large-scale catastrophic release of CO2” creating a Bhopal-like incident (when the mechanisms for such a release are not possible).
For the outcome texts and explanation of acronyms see http://unfccc.int/2860.php/ and for background information on the CCS work see http://cdm.unfccc.int/about/ccs/index.html .