Risks

LEAKAGE

79. Evidence to suggest that CO₂ storage in geological formations is safe and secure comes from a number of sources. POSTnote 238 on CCS points out that "Oil and gas have been 'stored' underground for millions of years" and there are natural CO₂ occurrences in the North Sea that demonstrate that storage can occur safely over millions of years.[128] In addition, experience from Sleipner, Weyburn and other CO₂ storage projects suggests that the gas can be securely stored in geological formations (see paragraph 47 and Box 3). A third strand of evidence is provided by industrial analogues for CO₂ storage. These include acid gas injection projects and underground natural gas storage projects which, as the IPCC report points out, "have operated successfully for almost 100 years".[129] According to the IPCC, the health, safety and environmental risks of CCS are comparable to existing hydrocarbon operations and practice, and the risk of leakage from geological storage is very low (99% retention over 1000 years for well chosen reservoirs).[130] Experience to date has demonstrated that, over the timescales studied, CO₂ can be safely stored in both depleted oil and gas fields and aquifers. Current and future large scale demonstration projects will play a key role in building the evidence base for, and public confidence in, geological storage of CO₂.

80. Nevertheless, risk of leakage of CO₂ from storage sites appears to be a cause of concern on the part of some environmental groups and a potential cause of concern to the general public. Green Alliance, for example, told us: "Acceptability of storage sites will depend on their gas leakage security", whilst the Greenpeace European Unit has said that "CO₂ leakage (both long-term slow seepage and short-term catastrophic releases) poses a risk to human health, the environment and the climate".[131] There are two main types of risk associated with leakage. Firstly, unintended release of CO₂ could have local health, safety and environmental risks. Secondly, longer term, ongoing, low-level release of CO₂ would undermine the climate change mitigation benefits of CCS.

81. Assessing the risks associated with CCS requires analysis of both the probability of leakage and the likely consequences of such leakage. The latter would depend heavily on the nature of any leakage, i.e. whether it was a short, intense burst or a slow but sustained release of low levels of the gas. CO₂ is not legally classified as a toxic substance and is present at ambient concentrations of around 380 parts per million, i.e. it comprises 0.038% of the earth's atmosphere. Research has demonstrated that CO₂ poses no risk to human health at concentrations of up to 1%.[132] Exposure to higher concentrations of CO₂ can be dangerous and, at airborne concentrations of greater than 3%, CO₂ can have toxic effects on the respiratory and cardiovascular systems. The greatest danger to humans posed by CO₂ is the risk of asphyxiation as CO₂ levels rise above 5%. Sensitive populations such as the elderly could also experience ill effects at lower levels of CO₂. Air-breathing animals have similar responses to CO₂ but plants, insects and soil organisms may have significantly higher tolerance thresholds.[133]

82. Because CO₂ is denser than air, leakage of CO₂ into the atmosphere may lead to accumulation of CO₂ in lower lying areas unless dispersed by wind action. The Cambridge Environmental Initiative argued that "One further area for research is to investigate the spread of CO₂ plumes in UK conditions and the wind conditions required to disperse them", whilst also pointing out, "This may be no worse than the risks associated with existing oil and gas pipelines".[134] The Royal Society of Chemistry was particularly concerned about the risks of high concentration leaks, calling for researchers to "focus on the potential impacts on both offshore and onshore ecosystems of spatially restricted but very high concentration CO₂ leaks", noting that this would help "to define site performance and safety criteria".[135] The BGS also said that assessing the localised impacts of CO₂ leakage on ecosystems was "a particular challenge".[136] In addition, the scientific consultancy Quintessa was concerned that the "Impact of CO₂ upon marine organisms was poorly-known".[137]

83. There are some instances of naturally occurring leakages of CO₂ which can provide useful sources of information on the impacts of CO₂ on ecosystems. One example would be the cold marine seeps off the coast of California.[138] However, the utility of such comparisons has been called into question on the grounds that the ecosystems surrounding these sources of CO₂ have had long time periods to adapt to the increased level of CO₂, which would not reflect the situation with sudden leakage of CO₂ from a geological storage site. Incidents such as the explosive release of CO₂ from Lake Nyos in Cameroon, which caused mass fatalities in the surrounding area, are certainly not comparable to the seepage that would be expected from a geological storage site.

84. The climate change mitigation risk stems from the fact that the key benefit of CCS, namely the reduction of atmospheric carbon dioxide levels, would be undermined if CO₂ injected into storage sites were to leak back into the atmosphere. A risk of leakage, or a perception that this was the case, could also jeopardise the inclusion of CCS in emissions trading schemes. Quintessa noted that "Implicit in the acceptance of specific leakage rates for geological reservoirs is that monitoring of storage operations is sensitive enough to detect [low] leakage rates […] so that mitigation strategies can be employed, and ratification of carbon credits can be achieved by regulators".[139]

Boreholes

85. There was a consensus in the evidence received that the most likely source of CO₂ leakage from geological storage sites was via boreholes. The BGS, for example, told us that "The main risk issue with CO₂ storage in hydrocarbon fields is the possibility that CO₂ may eventually leak upwards along pre-existing exploration and production wells".[140] This risk arises from the fact that the cement used to seal the boreholes can become corroded over time. If depleted oil and gas fields are being used for storage, pre-existing boreholes that may have been sealed several years previously could be particularly vulnerable. If a leak did occur at a borehole, the amount of CO₂ released would not be expected to be large relative to the total amount stored in the reservoir and, once it reached the seabed, it would be likely to escape to the atmosphere as bubbles rather than being retained in the sea.[141] The sealing of boreholes is a mature technology and, providing that appropriate monitoring and verification systems are in place, it is also expected that any leaks could be rapidly repaired. The main source of leakage from CO₂ storage sites is likely to be via boreholes, although it is expected that any breach of the borehole seal could be remediated quickly. Further R&D to develop cements and sealants optimised for CO₂ storage would nevertheless be valuable.

Site disruption

86. Although the evidence suggests that under normal circumstances the risk of leakage of geologically stored CO₂ is low, some people have raised concerns about the possible effects of unintended disruption of the storage site, for example due to accidental drilling. Dr Holloway, a Senior BGS Geologist, told us: "Drilling through high pressure accumulations of gas is an every day fact of life in the oil industry because when you discover gas fields they are under pressure and that pressure is retained by dense mud inserted in the well".[142] He went on to explain that "Drilling through an existing CO₂ storage site should not in itself necessarily promote leakage because you can control your well drilling process and plug your well with suitable materials afterwards".[143] On the subject of the likely consequences of an earthquake striking a region containing a CO₂ storage site, Dr Holloway told us: "the saline aquifer storage experiment in Nagaoka in Japan was hit by a magnitude 6.3 earthquake during the experimental period and this did not in any way damage the site significantly at all", whilst also pointing out that "One would try and store CO₂ away from earthquake prone zones".[144]

Site characterisation

87. Much of the evidence attests to the need for thorough site characterisation in order to reduce the risks associated with storage. Brian Morris from the DTI told us, for example: "one has to select each storage site carefully […] One will have to make sure that you survey the sites before you start doing it".[145] Although the main focus of the assessment will be the proposed storage reservoir (in terms of its geology, geochemistry, response to stress etc.), the rock layers above the reservoir should also be analysed to enable modelling of the behaviour of any CO₂ that did escape from the reservoir and migrate into these layers. There is currently no standardised methodology for site characterisation.[146] We recommend that the Government works both with other interested parties within the UK and, over the longer term, internationally, in order to develop a standardised methodology for site characterisation. More generally, there is a need for codes of practice to be developed to ensure good design and management of CO₂ storage facilities. Early experience from the first demonstration projects should assist considerably in these processes.

Monitoring and modelling

88. Although all the large scale projects where CO₂ storage performance has been monitored suggest that storage is viable and apparently safe, none of these have been monitored for more than a decade so it is too early to draw long term conclusions. The DTI's March 2005 Technology Status Report on monitoring technologies for the geological storage of CO₂ provides an overview of the main techniques used for monitoring and verification of storage and the challenges facing the UK.[147] These are, therefore, not discussed in detail here. However, we received evidence arguing that better tools and models for identification of storage sites and subsequent monitoring and verification are needed. Royal Dutch Shell told us that the "key R&D theme" should be "feasibility and integrity of storage".[148] E.ON UK also stated: "it is in the development of methodologies for verifying CO₂ storage that the majority of effort needs to be focussed".[149]

89. The evidence emphasised the difficulty of predicting what would happen to stored CO₂ over the very long term. The BGS called for models to be developed that could "assess the risks of CO₂ storage to both humans and ecosystems over 5,000-10,000 year timescales".[150] The BGS further pointed out:

"Simulators and models for CO₂ behaviour are still in their infancy. More field trials at laboratory and industrial scale are needed to history-match and refine these tools […] Tool testing, monitoring and verification at field-scale across the spectrum of geology, site conditions and ecosystems that could apply to storage operations is required".[151]

The Royal Society of Chemistry also highlighted the importance of studying the behaviour of CO₂ stored under a range of "reservoir conditions that include increased temperatures, pressures, and salinities, and account for the presence of other fluids and organics".[152] Further research is needed to improve the tools for site selection and subsequent monitoring and verification of CO₂ stored in geological formations. Although companies will be expected to take steps to improve monitoring and verification in the projects that they sponsor, the Government must take primary responsibility for commissioning research in this area in view of its significance for public safety and confidence in the technology. We recommend that the Government makes this an RD&D priority.

Transport

90. As discussed above, CO₂ pipeline technology is well established and experience in the US suggests that the risks associated with CO₂ transportation are comparable to those for natural gas transportation (and arguably lower since CO₂, unlike natural gas, is not flammable). George Marsh, adviser to the DTI, told us in oral evidence: "There are established ways of dealing with pipelines and potential catastrophic leaks. The US has over 1,000 miles of CO₂ pipeline, they pipe about 30 million tonnes a year. This is not cutting edge technology".[153] Mr Marsh also indicated that there was already a regulatory framework in place for CO₂ transportation, telling us that it would fall under the Pipeline Directive.[154]

91. Between 1990 and 2002, there were 10 incidences of failure of CO₂ pipelines in the US, resulting in property damage of around half a million US dollars but no fatalities or injuries. This failure rate is of the same order of magnitude for US onshore gas pipelines.[155] The consequences of leakage incidents are, of course, influenced by the population density in the areas though which the pipelines pass and this should be taken into account when planning the route. The fact that CO₂ is denser than air should also be a consideration in designing the pipeline network so as to avoid, in case of accidental release, an accumulation of the gas in low lying areas. Providing that the pipelines are designed and routes are selected in such as a way as to minimise risk, transportation of CO₂ by pipeline between capture and storage sites should not pose any greater threat to human health or the environment than natural gas transport and may indeed be lower.

92. Overall, the evidence suggests that for well-chosen sites the risk of leakage of CO₂ from geological storage reservoirs or pipelines is low. The risks associated with storage of CO₂ would be further mitigated by thorough site characterisation and management, monitoring and verification of storage sites.

PUBLIC CONFIDENCE

93. CCS is still a relatively unknown technology amongst the public and an adverse public response could pose a serious risk to its wide-scale deployment. The Royal Society of Chemistry perceived this to be the greatest threat to the development of CCS in the UK: "Although a number of technical issues dealing with storage safety, monitoring and longevity are still outstanding, the public acceptance of geological storage is probably the overriding issue".[156] In oral evidence, industry witnesses also emphasised the importance of public engagement and Gardiner Hill from BP described public acceptability as "a potential show stopper".[157] The environmental NGOs giving oral evidence were critical of the lack of Government action in this area. When asked how effective Government had been so far in communicating CCS technology to the public, Russell Marsh from Green Alliance said "not at all", while Doug Parr from Greenpeace asked "has there been any communication about it? I must have missed it".[158] By contrast, Dr Reiner from the Judge Business School and UKCCSC credited industry and Government with "active engagement with the non-governmental community".[159]

94. There is limited data available on public attitudes towards CCS but UKCCSC drew our attention to research carried out by the Tyndall Centre and the Judge Business School, Cambridge University, on this subject. UKCCSC told us that the results suggested that the public are not opposed, in principle, to CCS and "become more in favour as they learn more". According to this research, "acceptance of the technology is dependent on 1) acceptance of climate change as a serious and urgent problem and 2) that CCS would be implemented as part of a portfolio of measures (including renewables and energy efficiency) and not at the expense of other mitigation options".[160] It is also noteworthy, although perhaps not surprising, that CCS appears to be more acceptable to the public than nuclear power.[161]

95. Experience with other novel technologies has highlighted the importance of making clear and transparent information available. Our predecessor Committee took a longstanding interest in the Government's efforts to facilitate public dialogue and commented on more than one occasion on the need to initiate public engagement at an early stage in the development of a new technology.[162] We share our predecessor Committee's interest in this area. In the course of this inquiry, we heard similar messages from witnesses. Cambridge Environmental Initiative told us: "Transparency of information is essential to enable academic analysis and further research and to avoid a similar scenario to that of the nuclear energy age, when raw data was kept secret provoking public suspicion about the technology".[163] UKCCSC also argued that a coherent and concerted effort from Government in its public communications was vital to attract investment: "Government must consistently identify CCS as an energy technology area in the same way as 'nuclear', 'hydrogen', 'biomass', 'renewables' etc. and give it generally equivalent attention in official planning and communications if its possible contributions to UK energy supplies are to receive appropriate attention in R&D activities".[164] Clear and transparent information about CCS at an early stage will be crucial for securing public acceptance. The Government must therefore adopt a pro-active approach to communication.

96. We asked the Government what it had done to date to address this issue. The DTI response stated that there were "a number of current international initiatives focusing on public perception, public outreach and communications strategy" and that the "first step for DTI is to establish the content and range of these initiatives". The DTI also said that it would "draw together an expert group to define a communications strategy that will promote consistent and effective messaging, based on research into public perceptions and attitudes, and drawing from the best communications materials available".[165] The timescale for this would be first quarter 2006, with a provisional strategy available by late Spring 2006. Malcolm Wicks, Energy Minister, also told us: "I, myself, in my modest way, have discussed [CCS] on 30 or so radio and television programmes".[166] The Minister certainly has an important role to play in raising the profile of CCS, but an effective programme of communicating the features and risks of this technology to a wide audience will require more than the Minister discussing CCS in the course of his interviews with the media.

97. Having observed a marked increase in the media attention given to CCS between the start of the inquiry in July and the oral evidence sessions in November and December, we were interested to hear the views of witnesses on CCS media coverage. Rodney Allam from Air Products confirmed our perception about the dramatic increase in press interest, telling us: "We have had more exposure in the last seven days than we have had in the last seven years".[167] The witnesses appearing alongside Mr Allam also agreed that the quality of coverage was a source of concern. Mr Hill from BP was particularly uncomfortable with the description of CCS as 'carbon dumping'.[168] He told us: "I think there is a problem. If you want to choose to use that language, you could say, "What are we doing today?" and today we are dumping the CO₂ in the atmosphere".[169] The anxiety expressed by the witnesses from industry contrasts starkly with the Energy Minister's declaration that he was "very happy" and "very relaxed about where we are" in terms of public engagement and media coverage of CCS.[170] The Government has done little so far to engage the public in a dialogue about CCS technology. We accept that it is early days for the technology but previous experience has emphasised the value of early engagement. The evidence we have seen does not support the view that the Minister's confident and relaxed attitude towards the Government's performance on this issue is justified. This is a source of concern.

98. A number of contributors to the inquiry commented on the fact that the first demonstration projects in the UK could have a major impact on public attitudes towards CCS. Dr Reiner from the Judge Business School at Cambridge University and UKCCSC highlighted the fact that "Given low public levels of recognition of CCS and broad support for renewables, public attitudes towards CCS will be influenced by early successes (or failures) of major CCS projects".[171] The first demonstration projects will need to give careful consideration to public engagement—early successes or failures are likely to have a disproportionate impact on subsequent public attitudes.

99. Dr Reiner also made the point in oral evidence that "The public, at least based on our surveys, have no knowledge or virtually no knowledge of this issue so it really ends up being the press and the non-governmental community that you need to engage".[172] Brian Morris from the DTI also emphasised the critical role of the environmental NGOs, telling us: "we recognise that the NGOs are opinion formers".[173] To our great surprise, Friends of the Earth seemed reluctant to accept this mantle, saying: "we do not have influence over what the general public will ultimately think".[174] We disagree. Environmental NGOs can make a major contribution to ensuring that public debate about CCS is conducted in a responsible way. Their suggestion that they do not have influence over public opinion was perplexing and unconvincing. We call on the NGOs and the Government to work collaboratively to inform public perceptions of the risks and benefits associated with CCS.

Regulatory framework

INTERNATIONAL CONVENTIONS

100. The London Convention 1972 is an international treaty that limits the discharge of wastes that are generated on land and disposed of at sea.[175] There are currently 81 Parties to the Convention (i.e. states that have signed, ratified, and otherwise acceded to it). Contracting Parties must take effective measures to prevent pollution of the marine environment caused by dumping at sea. The 1996 London Protocol is a separate agreement intended to update the London Convention. The Protocol is also more restrictive than the Convention: application of a precautionary approach is included as a general obligation; a 'reverse list' approach is adopted, which means that all dumping is prohibited unless explicitly permitted; incineration of wastes at sea is prohibited; and export of wastes for the purpose of dumping or incineration at sea is prohibited. Upon its entry into force, the Protocol will replace the Convention. So far, 22 states have acceded to the 1996 Protocol, including the UK; four more parties are needed for the Protocol to enter into force.

101. The 1992 OSPAR Convention is a regional treaty guiding international co-operation over the protection of the marine environment of the North-East Atlantic. The name OSPAR derives from the Oslo and Paris Conventions which it replaced when it entered into force in 1998. The UK is one of 16 signatories to the Convention.[176]

102. The overall objective of both the OSPAR Convention and the London Convention/Protocol was to prohibit the dumping of waste into the marine environment. They were not designed to apply specifically to CCS and, as a result, there is uncertainty over whether long term storage of CCS in rocks under the seabed would constitute 'dumping'. RD&D activities are permissible under the treaties but there is a question mark over how large a demonstration project would be acceptable. EOR would be permitted on the grounds that the CO₂ is being injected under the seabed as part of the hydrocarbon recovery process and not solely for disposal purposes. Similarly, as the Government pointed out, projects "in which the CO₂ placed in geological storage is produced with the oil or gas being extracted (as with the Norwegian Sleipner project" are allowed.[177] EOR can provide a useful stepping stone to CCS by enabling early proving of offshore CO₂ injection without contravening the multinational environmental agreements governing the disposal of waste in marine environments.

103. The Government has acknowledged that the OSPAR and London Conventions need to be clarified or amended to allow CCS in geological structures under the seabed. Due to its global reach, the initial focus has been on negotiations to amend the London Convention/Protocol. The Government told us that the 27th Consultative Meeting of the London Convention had "established a process to consider whether the Convention, and/or the Protocol that will eventually replace it, need to be clarified and/or amended in order to facilitate or regulate CCS in sub-seabed geological structures".[178] Energy Minister Malcolm Wicks told us that he was "relaxed" that the OSPAR and London Conventions would be amended to allow CCS.[179]

104. The Royal Society expressed concern in its memorandum over the timescale entailed in securing amendment of such multinational environmental agreements, noting that "it may take several years to secure international agreement for the widespread storage of CO₂".[180] According to DEFRA, which leads the negotiations for the UK, "The whole process could take two or three years to complete".[181] DEFRA noted that the legal status of CCS projects could be unclear in the meantime: "since the Convention and/or Protocol as they stand were not drafted with the needs of carbon capture and storage in mind, trying to apply their current provisions to CCS is correspondingly complex, and views differ widely on the legality in these other cases".[182]

105. It is commendable that the Government has taken a lead in international negotiations to amend the London Convention/Protocol to ensure that CCS projects are permissible. Whilst we appreciate that it may take time to secure international agreement, it is vital that the UK does its utmost to expedite this process: industry needs to have one hundred per cent confidence that multinational environmental agreements are not going to serve as barriers to future deployment of CCS technology. In addition, we urge the Government to take steps to clarify the legality of the various types of CCS project to ensure that uncertainty and ambiguity in this area does not hinder the progress of CCS demonstration projects in or around the UK unnecessarily.

LIABILITY FOR STORED CO₂

106. A strong message that emerged during the course of the inquiry was the need for clarification of the status of stored CO₂. The Environment Agency told us of its concern about the "lack of clarity over the definition of carbon dioxide" and the "uncertainty over the jurisdictions of the various regulators and their responsibilities during the planning, permitting and operation of CCS activities".[183] Most of the evidence argues that the Government will ultimately need to take responsibility for the long term storage of CO₂. Dr Sam Holloway from the BGS asserted that "In terms of the long term liability, I think the state is probably the only organisation that believes it will exist in a few thousand years' time. In my view, they will have to accept the responsibility in some form or another".[184] BP's Gardiner Hill told us: "I would envisage some conditions in place so that as you hand the licence back, you would be satisfied that all reasonable precautions and measures had been taken to ensure complete integrity of the storage site and hence the liability would be transferred back".[185]

107. We asked DTI whether Government was willing to act as a long term guarantor for CO₂ stored in geological reservoirs. The response was as follows: "The proper domestic framework for regulation is under consideration and no decision on this question has been made".[186] However, in oral evidence the Minister appeared to acknowledge that the Government would ultimately need to take on liability for stored CO₂, saying "it is just plain common sense that in terms of the very long term […] it would be unrealistic to think that a company, even a very powerful company that was a big player in the 21st Century, may necessarily be there to manage it three million years later".[187] The private sector should take responsibility for CO₂ during the injection phase of any CCS project but we believe that Government will have to take responsibility for the stored CO₂ thereafter. We are pleased that the Minister appeared to acknowledge this, but it is essential that the Government makes an explicit commitment to serve as the long term guarantor, and makes it very soon. Industry will not proceed with CCS projects in the absence of such a commitment. We are also working on the assumption that insurance for CCS will be available as part of normal business practice.

DECOMMISSIONING OF NORTH SEA INFRASTRUCTURE

108. The DTI estimates that the UK North Sea contains around 1.5 billion barrels of oil which could be recovered using CO₂-EOR.[188] If this is not produced by EOR during the next 10-20 years, these assets could be stranded, with no prospect of production. The time constraint arises because decommissioning of the North Sea oil and gas fields has already started and will increase in rapidity and scope over the next 5-10 years.[189] The East of England Energy Group (EEEGR) has recently conducted a study to examine the possibility of reusing the North Sea infrastructure, including for the purposes of CCS and EOR. EEEGR told us: "Over the last 40 years, the international oil and gas industry has invested some £170 billion in the infrastructure needed to develop the UK's hydrocarbon resources in the UKCS", including "11,000 km of pipeline, installed at an estimated cost of £11 billion".[190]

109. BP also told us that "recycling the North Sea pipeline infrastructure could play an important part in enabling cost effective access to these reservoirs", noting that "the UK's window of opportunity to gain material benefit from CCS technology will close as that infrastructure is removed".[191] Dr Nick Riley from the BGS commented in oral evidence on the "considerable costs in decommissioning" and argued: "it is just crazy not to consider reusing that infrastructure for carbon management in the future". However, the Snohvit CCS project in Norway does not depend on reusing existing equipment and pipes, reflecting the fact that if other incentives are available, the cost of new infrastructure may not be a deal breaker. We return to the issue of incentives in chapter 6.

110. According to EEEGR,

"As UK oil and gas production declines resulting in the decommissioning of offshore facilities, it is generally accepted that many of the offshore platforms have limited alternative uses and will be removed; this may not be the case for the pipelines. Many of these will remain in situ, with a potential lifespan of 200-300 years. Research undertaken by Cambridge and Cranfield Universities for EEEGR has confirmed that there is no technical reason why these pipelines cannot be reused to transport dry CO₂".[192]

One of the obstacles to reuse of the pipeline network is the fact that "Current legislation - principally the 1998 Petroleum Act - does not consider the use of North Sea infrastructure in general and pipelines in particular for anything other than hydrocarbon production and the DTI's structures and procedures reflect this legal requirement".[193] Moreover, "current legislation provides a disincentive for reuse for CO₂ storage, due to ownership and liability issues attributed to a change of use".[194] The Government must take steps to enable and promote the reuse of existing North Sea infrastructure for the purposes of EOR and CCS. The window of opportunity for the pipelines and platforms is time-bound so rapid action is required. This action should include ensuring that reuse of pipelines for CO₂ transportation is permissible under the OSPAR and London Conventions/Protocol.

A CARBON CAPTURE AND STORAGE AUTHORITY

111. It became apparent during the course of the inquiry that a number of different parts of Government have an interest in, and/or expertise of relevance to, CCS. The DTI has led much of the work on CCS through its Cleaner Fossil Fuels Programme and has responsibilities for energy and the hydrocarbon industry. DEFRA is the lead Department for climate change and multilateral environmental agreements (such as the OSPAR and London Convention). George Marsh, a DTI adviser, highlighted a role for the Health and Safety Executive (HSE) in pipeline regulation: "As far as the engineering aspect of carbon capture and storage is concerned, in other words the power plant, the pipeline and the operation of the platform, the regulatory standards for safety exist and are operated through the Health & Safety Executive".[195] E.ON UK also noted that "existing implementation of the EU ETS already involves the EA [Environment Agency], DEFRA and the DTI".[196]

112. In oral evidence, Dr Gibbins from UKCCSC, proposed a solution to streamline the regulation of CCS: "It has been the thought of the UK Carbon Capture and Storage Consortium that it would be useful to have a carbon capture and storage authority which is an independent, national body that assesses the risks, monitors the appropriate operation of a storage scheme and, in the longer term, assumes responsibility, not without payment, but I think that is the way we have to move ahead".[197] We subsequently put the idea to a number of other witnesses, most of whom were supportive of the concept. Air Products told us: "We would actively support the establishment of a Carbon Capture and Storage Authority", while Nick Otter from Alstom Power described it as "a good idea".[198]^, [199]

113. At present, multiple Government Departments and agencies, including the DTI, DEFRA, Environment Agency and the Health and Safety Executive, have expertise and functions that would be required for the regulation and monitoring of CCS. In the absence of a Department of Energy, we propose the establishment of a CCS Authority to bring together all the relevant functions. We believe that a single body in this area could make regulation more transparent, thus building public confidence, as well as minimising bureaucracy for companies engaging in CCS projects. In order to ensure that these objectives are met, it is essential that all the relevant onshore and offshore functions be subsumed into the CCS Authority, leaving no residual responsibilities in other Departments, and that the Authority has a clearly defined line of accountability to a single Secretary of State.

114. The CCS Authority would fulfil all the key regulatory functions pertaining to CCS. The initial priorities for a CCS Authority would include taking a lead in the establishment of: a clear legal framework for onshore and offshore CO₂ storage; planning and regulatory guidelines for granting consent for CCS projects; clear requirements for monitoring and inspection of CO₂ storage sites; and an appropriate process of transferring liability from the private sector to the Government once the injection phase is complete. The CCS Authority could also play an important role in advising Government on the development of incentive frameworks to promote investment in CCS (see chapter 6). In addition, an early task for the CCS Authority would be to review the 1998 Petroleum Act to examine whether and how it should be amended to facilitate CCS (paragraph 110). Once the relevant regulatory and market frameworks were in place, the CCS Authority would then take responsibility for implementation, including monitoring and verification. In view of the wide range of tasks required to put in place the necessary regulatory frameworks for CCS, and the urgency with which they need to be undertaken, the Government should not delay in taking steps to establish the CCS Authority. Indeed, the Energy Review provides an ideal opportunity to set this process in motion. Clearly, the process of establishing the Authority must not lead to any delays in granting approval for the first demonstration projects.

129   IPCC, Special Report on Carbon Dioxide Capture and Storage, Autumn 2005. Back

130   As above. Back

131   Ev 179 and http://eu.greenpeace.org/issues/climate.html Back

132   IPCC, Special Report on Carbon Dioxide Capture and Storage, Autumn 2005. Back

133   As above. Back

134   Ev 167 Back

135   Ev 144 Back

136   Ev 73 Back

137   Ev 67 Back

138   JP Barry, RE Kochevar, CH Baxter, "The influence of pore water chemistry and physiology on the distribution of vesicomyid clams at cold seeps in Monterey Bay: Implications for patterns of chemosynthetic community organisation", Limnology and Oceanography, vol 42 (2), pp 318-328, March 1997. Back

139   Ev 67 Back

140   Ev 72 Back

141   Michael A. Celia et al, "Quantitative estimation of CO₂ leakage from geological storage: analytical models, numerical models, and data needs", paper 228, Proceedings of the Seventh International Conference on Greenhouse Gas Control Technologies, Volume 1: Peer-Reviewed Papers and Plenary Presentations, IEA Greenhouse Gas Programme, Cheltenham, UK, 2004. Back

142   Q 98 Back

143   Q 98 Back

144   Q 98 Back

145   Q 20 Back

146   IPCC, Special Report on Carbon Dioxide Capture and Storage, Autumn 2005. Back

147   DTI , Monitoring Technologies for the Geological Storage of CO₂, Technology Status Report,TSR025, March 2005. Back

148   Ev 109 Back

149   Ev 81 Back

150   Ev 70 Back

151   Ev 71 Back

152   Ev 144 Back

153   Q 24 Back

154   Q 24 Back

155   IPCC, Special Report on Carbon Dioxide Capture and Storage, Autumn 2005. Back

156   Ev 144 Back

157   Q 143 Back

158   Q 215 Back

159   Q 103 Back

160   Ev 149 Back

161   Ev 149 Back

162   E.g. Third Report from the Science and Technology Committee, Session 2003-04, The Work of the Biotechnology and Biological Sciences Research Council, HC 6, paragraphs 63-65 and Fifth Report from the Science and Technology Committee, Session 2003-04, Too little too late? Government Investment in Nanotechnology, HC 56-I, paragraphs 101-107. Back

163   Ev 167 Back

164   Ev 149 Back

165   Ev 183 Back

166   Q 312 Back

167   Q 144 Back

168   Ministers back carbon dumping, The Guardian, 15 June 2005. Back

169   Q 147 Back

170   Q 310 Back

171   Ev 160 Back

172   Q 103 Back

173   Q 311 Back

174   Q 217 Back

175   www.londonconvention.org/ Back

176   www.ospar.org/ Back

177   Ev 185 Back

178   Ev 184 Back

179   Q 319 Back

180   Ev 132 Back

181   Ev 184 Back

182   Ev 185 Back

183   Ev 94 Back

184   Q 105 Back

185   Q 139 Back

186   Ev 187 Back

187   Q 314 Back

188   DTI, Our energy future-creating a low carbon economy, Energy White Paper, February 2003, p 90. Back

189   www.dti.gov.uk/energy/eid/offshore_decom.shtml Back

190   Ev 180 Back

191   Ev 137 Back

192   Ev 180 Back

193   Ev 181 Back

194   Ev 181 Back

195   Q 307 Back

196   Ev 199 Back

197   Q 101 Back

198   Ev 199 Back

199   Ev 202 Back