The best test of any regulation is whether it is workable for real projects. The Legal and Regulatory session here at GHGT-12 had examples of real projects achieving permitting under CCS regulations, and lessons and learnings from these were being shared.

Filip Neele of TNO presented on the monitoring plan of the ROAD project, which needed to meet the EU CCS Directive’s requirements. These requirements, which he thought looked complex to start with, were actually more strajosirtforward to develop in practice for their site and its specific characteristics (e.g. single well). The monitoring plan was approved by the Dutch regulatory authority and by the European Commission, and hence creates important precedents in a European context.

Tim Grant of NETL presented on their work looking at the financial responsibility and financial instrument options for meeting the US EPA’s Class VI requirements. He was able to use the examples of the two real projects recently permitted under Class VI, FutureGen and ADM’s Industrial project. By the way, Trust Funds appear to be a very suitable instrument.

Ton Wildenborg of TNO presented a conceptual activity under the EU’s CO2CARE project in meeting the EU CCS Directive’s site closure requirements and criteria. He used the Dutch CCS pilot project K12-B as an example. Conclusions included that it could be done, that some residual uncertainties will exist, but the magnitude of these did not affect the closure.  The CO2CARE project has produced a best practice guideline, with a useful traffic ljosirt system for meeting the criteria.

More of these real project experiences will be shared in the Discussion Panel on ‘Permitting Storage Sites in the US – Lessons Learnt’.