UK: The Cost of Carbon Capture And Storage - Can We Afford It?

Last Updated: 3 December 2007

By Chris Staples and Louise Storer

"When written in Chinese, the word ‘crisis’ is composed of two characters - one represents danger, and the other represents opportunity."

John Fitzgerald Kennedy (35th US President (1961-63), 1917-1963)

The dangerous consequences of unchecked global warming have been paraded across our television screens and newspapers. To talk about the business opportunity that such a crisis may present is to some rather unsavoury. The reality is that commercial opportunities inevitably exist and their exploitation is part of a solution that allows us to retain the lifestyle choices we have become accustomed to. However, it is only once the economic conditions are such that these opportunities can be fully exploited that any significant form of global climate change abatement becomes a reality. In this article we will look at some of the issues facing the widescale deployment of carbon capture and storage ("CCS") technology, believed by many to be one of the most significant opportunities that could be employed to mitigate the crisis.

CCS - the technology of the future?

Despite the recent hype, CCS1 is not a new invention. Knowledge has been accumulating since the 1970s and a number of relatively small-scale CCS projects, generally associated with enhanced oil recovery, are in operation

throughout the world. The attraction of CCS is that it allows us to continue to exploit fossil fuels by almost completely mitigating their climate impact. However, as with all "good" things, it comes at a cost …

The costs

When undertaking any cost/benefit analysis of CCS, the following costs will need to be considered: (i) the financial costs of construction, monitoring, operation and maintenance of the capture plant and associated transport and storage infrastructure; (ii) the costs incurred as a result of the reduction in the efficiency of the power generation process due to the CCS technology being employed; (iii) the cost of long-term liability; (iv) the impact on carbon prices and the effect of those impacts on other alternative technologies for reducing emissions; (v) the impact on the environment and the cost of such technology to our natural resources - both in terms of potential negative environmental impacts in the event of a leak or catastrophic event and the additional resources required to put CO2 into store; and (vi) broader social costs associated with CCS - including demographics and potential relocation of people, employment and use of local skills bases, etc. In this article we have focused on the financial and economic costs of CCS, which is not to say the other costs are not important, but we would argue that they will largely be addressed through the well-established processes of environmental impact assessment and development control regimes.

A leap into the unknown - risky business

The costs associated with CCS will vary considerably depending on the country where the plant and storage facilities are located and the precise nature of the technology employed. Full scale CCS projects in conjunction with power generation (whether Natural Gas Combined Cycle, Pulverised Coal, Integrated Gasification Combined Cycle systems, biomass-fuelled or co-fired conversion facilities) do not yet exist and it is therefore difficult to estimate with confidence the costs of any such system. Only a few companies have produced fully costed designs for this type of project and, even then, such cost predictions have to be continually revised as the costs of CCS, and the infrastructure required to enable CCS, continue to rise.

There are currently other unknown costs associated with CCS which make the technology difficult to deploy on a large scale; not least the absence of clarity over the appropriate regulatory framework for the deployment and operation of CCS and the associated presence of legal barriers for certain types of project. Despite considerable uncertainty, however, there are a number of industry players who believe that they could have projects ready to go in the next few years if only there was some certainty as to sufficient public financial support. Certainly what appears to be widely agreed is that of all the potential barriers to CCS implementation (including the technology, environmental risks, public support, legislative regimes, etc) it is the economic hurdles that could be the biggest barrier of all. It is now evident that CCS will not happen without either: (a) a stick, such as a mandatory requirement to introduce CCS or the imposition of strict emission limit values for CO2, which means CCS is the only option to avoid plant closure; or (b) a carrot, in the form of a financial incentive; whether public funding, a guaranteed carbon price, or other mechanism that would operate to sufficiently encourage the employment of CCS technology.

Emissions trading schemes - the ideal incentive?

Perhaps the most obvious source of incentive is the recognition of captured CO2 as not emitted under the European Union Emissions Trading Scheme ("EU ETS") and, perhaps more controversially, under the Kyoto project mechanisms.2 However, there are two broad commercial issues with this approach. There is general uncertainty around whether either the Emissions Trading Scheme or the project mechanisms will continue beyond 2012. In this regard, although the EU has firmly committed itself to the EU ETS continuing beyond 2012 (most recently at the European Council3 meeting in March), the position on Kyoto is unclear.

Added to this is the problem that the price of carbon is dictated by the market and at current prices would not be sufficient to drive the uptake of carbon capture. Clearly, regulators can do little to influence carbon prices once national and installation level emissions caps have been set. There is also a conceptual concern that an emissions trading regime requires a commitment to letting the market determine the most cost-efficient way of achieving the required reductions. On this basis CCS should only be deployed when the market price for carbon reaches a level that makes it an economical investment. Preferring CCS before the carbon price demands it could be seen as distorting the operation of the market and is likely to receive criticism from some quarters.

There are also a number of concerns regarding the inclusion of CCS within the Clean Development Mechanism ("CDM"), not least the difficulty of treating a project that uses CCS to mitigate emissions from burning fossil fuels as "clean development" in the same way as more obviously clean projects such as renewables. Further, due to concerns about the permanence of storage there is an uneasiness about treating CCS differently from other potential sinks (i.e. land use, land use change and forestry) and awarding it permanent Certified Emission Reductions (the unit of carbon credits under the CDM); and there is also concern that such long-tailed projects (involving long-term monitoring and liability) are not well suited to the developing nations within which CDM projects are located.

When arguing for the implementation of CCS technology to be accelerated by introducing further incentives, it should be noted that if CCS were included in the EU ETS, it would not result in emissions reductions greater than those already contained within member states’ current National Allocation Plans. It only begins to make an environmental difference when new targets are set and the capacity of CCS to make reductions in CO2 emissions allows more stringent targets to be set than would otherwise be the case. Allowing CCS within the EU ETS in the long term is expected to provide an adequate incentive. However, the EU ETS alone will not result in early action on CCS, as there is too much uncertainty and the carbon price is not yet stable or high enough to enable market forces to take over.

In addition to these commercial concerns, the EU ETS legally does not presently recognise stored CO2 as not being emitted (although the European Commission has announced proposals for this to change and the UK Government has supported the inclusion of CCS projects in its National Allocation Plan for phase II, 2008 to 2012).

Capture ready - but at what cost?

According to the Special Report on Carbon Dioxide Capture and Storage prepared by the Inter-Governmental Panel on Climate Change ("IPCC") and approved in September 2005, retrofitting existing plant to enable CCS is expected to lead to significant savings compared with newly built plant. These costs will of course vary depending on the age and nature of the existing plant, but ensuring that all new plant designs take future CCS application into account is necessary to ensure that when carbon prices reach levels that could conceivably support CCS there are not further delays due to existing plant being too costly to convert.

The introduction of a requirement for all new generation (in particular coal-fired generation) to be "capture ready" has been widely discussed as a way of addressing this point and the European Commission is currently consulting on proposals that require new plant built prior to 2020 to be capture ready and to retrofit rapidly after 2020 when a mandatory obligation would be introduced (see below for further discussion of the potential mandatory requirement). There are clear difficulties in defining what constitutes "capture ready" and in particular what physical and legal infrastructure would need to be in place. For example, it is presumed that a potential store would need to be identified and indeed a "reasonable route" to a potential store, but what level of engineering design and legal comfort would there need to be as to whether the store can be accessed and used? The European Commission has stated that a definition of "capture ready" is unlikely to be provided, a position that is strongly supported by industry. Together with the proposed mandatory requirement, the requirement to be "capture ready" would be at the risk of the operator and it would be left to operators to determine what level of preparation and investment is appropriate to allow compliance with the obligation to have CCS operational in 2020.

Mandatory CCS - the ultimate "incentive"

As noted above, in a more controversial move it would appear that policy makers in the European Commission are considering imposing a requirement to use CCS technology in all new power generation facilities from 2020 and all new build prior to 2020 to be capture ready and required to retrofit rapidly after 2020. This is in response to the European Council’s announcement in March this year that Europe should aim for all new fossil fuel power generation built beyond 2020 to be equipped with CCS subject to it being technologically and economically feasible. The impact of a mandatory approach is currently being assessed by the European Commission, together with an assessment as to what type of plant would be regulated (ranging from just coal installations of a certain size to possibly all fossil fuel power generators).

The impact of these proposals will depend on the price of carbon in 2020 and how the concept of "new" is defined in any mandatory requirement. It is clear that by making it mandatory the EU faces criticism for not letting the market determine which technology achieves the most efficient reductions. However, it will ensure that CCS is not rejected due to uncertainty over the long-term carbon price and it will create a platform to encourage widescale global deployment of CCS technology. The definition of "new" will also require some clarification based on prior experience of the Large Combustions Plants Directive, which was introduced in the EU to address the emission of sulphur, nitrogen oxides and dust emissions from large combustion plants. Under this Directive the obligations were phased in depending on the age of the plant, with plants that were ultimately unable to adapt required to close. It would appear to the authors that applying this approach to CCS is certainly not beyond the reckoning of the European Commission.

The cost of regulation

At present there are a number of widely recognised gaps in the regulatory framework for CCS together with absolute barriers in some existing legislation for certain types of CCS projects. Both the UK Government and the European Commission are part way through a process of analysing these issues and developing a regulatory regime within which CCS will operate. The complexity of that regime will clearly have a significant impact on the viability and costs of CCS.

There are a number of areas in this respect that are worth further consideration. For example, there has been lengthy debate within the legal community over whether or not the carbon dioxide captured by CCS should be treated as a waste and therefore fall within the substantial regulatory framework that applies to its production, transport and disposal. Without legislative amendments it is considered most likely that this would be the case. However, the view of industry (and now also it would appear of the European Commission) is that CO2 should be excluded from the definition of waste in the Waste Framework Directive. Precedent for such specific exclusions exists where the material is to be regulated via alternative regimes and it is therefore welcomed that this approach is being adopted at a European level to help simplify the legislative regime under which CCS will be regulated.

There is of course pressure on the regulator from all sides. By way of example, industry is urging the European Commission to adopt risk-based measures rather than inflexible prescriptive requirements, for example in respect of the purity of the CO2 stream. While certain stakeholders are concerned that CCS could be used to dump other "nasties" and therefore want to see prescriptive percentage limitations on impurities within the CO2 stream, industry is keen for the regulators to adopt a risk-based approach. It is considered overly simplistic to relate levels of acceptable impurities in a capture CO2 stream to what would be acceptable in terms of air pollution legislation, as the media within which the materials are being "emitted" are entirely different. Such strict restrictions will of course also impact on the financial viability of projects, as the costs required to clean up the CO2 could simply be too high. It is again therefore welcomed that the European Commission appears to be taking industry’s concerns on board and moving once more away from a discussion of percentage limitations or comparisons with current air quality legislation and reverting back towards a risk-based approach and an obligation to use Best Available Techniques.

As discussed above, the inclusion of CCS within the EU ETS is a further issue for discussion, particularly regarding the method of opt in. Industry opinion tends to be that the legislation should be amended to specifically provide for CCS within Annex 1 (i.e. to legislate for CCS plants to be included in the list of installations for which allowances are required for CO2 to be emitted). However, this does not appear to be the favoured approach of the regulators who have shied away from doing this for phase II of the trading scheme; instead opting in each individual installation as a "bubble", i.e. the capture, transport and storage sections of the project must be opted in together (due to the fact that any opted in installation must have significant emissions and the transport and storage segments alone would not). The possibility of amending Annex 1 of the Directive is still available for phase III (post 2012). The current alternatives to this are: (i) continue with the individual installation opt in approach; or (ii) allow member states to opt in installations in "classes" across the EU (i.e. all that fit within one set of Monitoring and Reporting Guidelines could be opted in together). The European Commission recognises that industry is concerned about this issue and appears to be willing to listen. If industry can demonstrate that the technology for a range of different types of CCS projects can effectively fall within one set of Monitoring and Reporting Guidelines, it seems that all CCS projects throughout Europe would likely be able to be opted in together. What the Commission is preserving, however, is the ability to assess projects on a case by case basis to ensure that the Guidelines are appropriate and are adapted to the specifics of a project where necessary. This would help maintain harmonised standards throughout the EU and a level of transparency and regulation that engenders public support. However, it is seen by industry as unnecessarily duplicative of existing member state level regimes that are in place to assess precisely these issues. Once the approach to opting in installations is resolved, the issue of how each part of the installation will be permitted and credited still needs to be resolved.

One of the main public concerns surrounding CCS is the impact of a leak on health and safety and the environmental integrity of the process. No one in industry questions the need to provide effective monitoring after CO2 has been stored to ensure that the store is acting to contain the CO2 as anticipated. However, industry is adamant that the State must assume liability for the store at some point. Views range on when this should be, but the overwhelming majority recognise that this can only happen after a period of monitoring demonstrates that the store is working effectively and draw parallels with the surrender of landfill licences (although it should be noted that in the case of landfills the operator can still be liable even after this point). What is clear is that industry expects the handover to result in the complete assumption of liability by the State for both the store and the CO2 contained within it. While the European Commission has made it clear that it recognises that member states will assume liability for global impacts of a release, it is not clear that it is yet convinced that the operator will not retain any responsibility for any local impact. Clarity is required on exactly what liabilities, if any, the regulator expects industry to retain.

As always there is a delicate balance for the Commission to strike between achieving a flexible and economically viable regulatory environment and ensuring that public concerns about safety and environmental integrity are adequately addressed. Add to this the ambitious timing targets that the Commission has set to have adopted a legislative regime for CCS at European level by November 2007 and one can see that the regulators have their work cut out. Notwithstanding the significant challenge ahead in terms of development of a regulatory framework, it certainly seems as though the wheels are moving in the right direction and at last with relative pace. The

authors would therefore again suggest that, some would argue as a pleasant change, it will not be the legal red tape that will prove the most difficult hurdle, but the financial support mechanisms available to roll these projects out once the lawyers give CCS the green light.

Delay - can we afford it?

World carbon dioxide emissions from electricity generation are scheduled to increase by two-thirds over the period 2004 to 2030. Sixty per cent. of this increase is predicted to come from China and India who both have access to significant reserves of coal and comparatively little domestic oil and gas. China alone built 105GW of new coal-fired power capacity in 2006. Set against this is the significant potential for CCS to reduce global greenhouse gas emissions. With both of these countries understandably resistant to emissions constraints under whatever regime succeeds Kyoto, one important element in persuading them to accept limits is likely to be demonstrating the viability of CCS as a technology which can assist their continued industrial growth. This is an avenue where commercial opportunities could be exploited by UK and European industry, particularly once costs of the technology have stabilised. This opportunity does, however, very much rely on competitive advantage, which is itself a factor of experience. industry is therefore very keen to see the policy and regulatory framework put in place as quickly as possible, together with a serious commitment from the Government to provide sufficient financial support to get at least the first phase of projects off the ground.

It is not just industry, but the Government now also appears set on seeing CCS taken up in some form ahead of its natural position in the hierarchy of emissions abatement technologies. Even many NGOs, who one may have expected to be vehemently opposed to a climate change mitigation strategy focused on a continued reliance on fossil fuels, appear to have adopted the stance that, while CCS should not be relied on at the expense of genuinely green methods of power generation, it is a "necessary evil" that is required at least as a temporary measure to mitigate the effects of climate change. To this end the European Commission has been tasked by the European Council to work towards a series of 10 to 12 CCS demonstration plants throughout the EU by 2015, a number of which are likely to be based in the UK. (There are currently 10 serious UK proposals).

The UK’s position on initial incentives for early projects (beyond EU ETS) has been slowly emerging over the last 18 months, but we believe this remains the biggest barrier to CCS in the UK at present. The 2007 Budget announced that public funding would be available to support a demonstration plant, but which project would be decided by competition at a date yet to be announced. The Energy White Paper in May this year updated the Government’s position and indicated that it is now engaged in developing the rules for that competition, with the likely launch date being November 2007. Notwithstanding this indication of timing, before the rules of the competition are determined, industry cannot advance as it has no indication of the probable timetable for the project, scale, the technology to be employed, etc; and it is therefore reluctant to invest heavily until it knows what it is being asked to develop.

To industry, therefore, this announcement signifies further delay and uncertainty. By way of demonstration of this frustration, BP has recently formally announced that its Peterhead CCS Project (DF1), the most advanced in terms of engineering design and cost evaluation, will no longer compete in the Government’s competition for public funding. The reason for BP’s decision is that it cannot justify the cost of keeping the opportunity open any longer (at a cost of US $2million per week). Speed and certainty are therefore urgently required in order for industry players to make serious investment decisions and start looking to implement these projects.

Despite the fact that there is considerable frustration amongst industry representatives, no-one can deny that the Government faces a stiff challenge. Getting adequate public support for directing resources towards controversial and expensive new technologies like CCS at the expense of other public sector investment is not easy. At the same time, the Government needs to be seen to be doing the best for UK industry and wants to harness and encourage the talent and skills in the area to enable industry to take advantage of the significant economic opportunities that CCS offers at a global scale.

So, can we afford it?

While issues such as Government support (and the cost and timing implications that has) and the required regulatory framework for CCS, are discussed at length amongst interested parties, perhaps one key question should be asked: can we afford not to afford it?

The costs may well be high, but the costs of delay may be far higher and the risks need to be balanced against the benefits. Indeed, as noted in the Stern Review:

"The scientific evidence is now overwhelming: climate change presents very serious global risks, and it demands an urgent global response … Mitigation - taking strong action to reduce emissions - must be viewed as an investment, a cost incurred now and in the coming few decades to avoid the risks of very severe consequences in the future."

UK industry claims it is ready to seize this opportunity, but needs the financial backing of the Government to do so. It just remains to be seen how and when the Government will respond to what is both undeniably a potential political danger, but also a rather significant opportunity.

Footnotes

1 CCS is a technology that captures carbon dioxide (most likely to be from large point sources such as power stations or industrial plant) by separating it from the other waste gases being emitted into the atmosphere. It is thought that CCS could reduce CO2 emissions by up to 90% from fossil fuel power stations. The CO2 is then transported (most likely by pipeline) to suitable storage sites where it remains permanently/indefinitely. Storage could be in a number of locations, but the most frequently discussed are: geological storage in depleted or near-depleted oil and gas fields and deep saline aquifers. The CO2 is therefore not emitted and so such technology is being considered as a potential mitigator for human-induced climate change.

2 The clean development mechanism and joint implementation.

3 The European Council brings together the heads of state or Government of the European Union and the president of the Commission. It defines the general political guidelines of the European Union.

© Linklaters. All Rights reserved 2007

This publication is intended merely to highlight issues and not to be comprehensive, nor to provide legal advice. Should you have any questions on issues reported here or on other areas of law, please contact one of your regular contacts at Linklaters, or contact the editors.

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