APPENDIX 6
Memorandum from E.ON UK
SUMMARY
1. E.ON UK believes that full-scale demonstration
power plants with pre-combustion carbon capture and storage (CCS)
or post combustion CCS could and should be built now. However,
the demonstration of these technologies would require some form
of financial support from Government for such plants to operate
successfully in the UK electricity market. Full-scale demonstration
is vital to the establishment of these technologies in the longer
term to enable them to contribute to delivery of the UK's carbon
emission reduction objectives.
2. The UK electricity industry requires
a massive investment in capital over the next decade to deliver
reductions in carbon dioxide emissions, energy supply security
and affordable prices. By 2015 up to 8GW of nuclear (subject to
life-extension decisions) and 19GW of coal and oil-fired plant
will need to be replaced.
3. Much of this plant will need to be replaced
with low or zero carbon generating plant if the UK is to make
effective progress toward its 2020 and 2050 carbon reduction goals.
4. While we and other energy companies are
already investing in renewable technologies, and are considering
further gas-fired CCGT construction, replacement of all closing
plant by CCGTs will not deliver the Government's 60% CO2
emission cuts by 2050 given that much capacity built in the next
decade is likely to be still operating in 2050. It would also
increase UK gas import dependency.
5. We therefore want to consider a wider
range of options to achieve reductions in emissions and to diversify
our portfolio of generating plant.
6. The Government has a crucial role in
ensuring that a range of low-carbon technological options including
CCS is available to companies investing in future power generation.
We believe this role is to:
provide the right market framework
to achieve government objectives within a competitive market environment.
This should increasingly rely on long term broad ranging market
based mechanisms, such as the EU emissions trading scheme, as
the main driver to incentivise the most economic low carbon investments,
encourage innovation in energy supply and support UK competitiveness.
Carbon capture and storage is only likely to be deployed if there
were to be a belief in the long-term market value of avoiding
carbon emissions. Such incentives must be sufficiently long term
(>10 years) to stimulate major capital investment;
aim to achieve a broad international
commitment to action to tackle climate change which shares responsibility
across the major emitting economies; with any post-2012 agreement
being consistent with investment timescales10-15 years
seems appropriate;
resolve specific policy, legal and
institutional constraints which are limiting the choice of technologies.
For CCS this covers establishing the legal and regulatory framework
(including monitoring requirements), ensuring that the relevant
international agreements (the London Convention, London Protocol
and the Ospar Convention) recognise the legality of CCS, and establishing
how the long term liabilities arising from geologically stored
CO2 will be handled; and
encourage the development and demonstration
of emerging technologies with capital grants or similar support.
INTRODUCTION
7. E.ON UK is the UK's second largest retailer
of electricity and gas, selling to residential and small business
customers as Powergen and to larger industrial and commercial
customers as E.ON Energy. We are also one of the UK's largest
electricity generators by output and operate Central Networks,
the distribution business covering the East and West Midlands.
We are also a leading developer of renewable power plant.
8. E.ON UK is part of the E.ON Group which
is the world's largest privately owned energy service company.
In addition to the UK, the Group has electricity and gas interests
in Germany, Central and Eastern Europe, Italy, the Netherlands,
Scandinavia, the United States and Russia.
9. The UK electricity industry requires
a massive investment in capital over the next decade to deliver
reductions in carbon dioxide emissions, energy supply security
and affordable prices. By 2015 up to 8GW of nuclear (subject to
life-extension decisions) and 19GW of coal and oil-fired plant
will need to be replaced.
10. We believe much of this plant will need
to be replaced with low or zero carbon generating plant if the
UK is to make effective progress toward its 2020 and 2050 goals.
While we and other energy companies are already investing in renewable
technologies, and are considering further CCGT construction, replacement
of all closing plant by CCGTs will not deliver the Government's
60% CO2 emission cuts by 2050 given that much capacity
built in the next decade is likely to be still operating in 2050.
In fact, replacing by CCGTs would keep CO2 emissions
from the sector approximately constant (assuming no demand growth)
since replacement of coal by gas offsets replacement of nuclear
by gas. It would also increase UK gas import dependency.
11. We will want to consider a wider range
of options to achieve reductions in emissions and to diversify
our portfolio of generating plant. Investment options could include
coal and gas plant with carbon capture and storage, as well as
nuclear plant, renewable technologies such as wave or tidal power
and the increased use of biomass. Given the scale of challenge
both in the UK and overseas, it is likely that most if not all
of these options will be needed.
12. Carbon Capture and Storage (CCS) has
the potential for making a significant contribution to CO2
emissions reduction world-wide. The large geological storage capacity
offshore, coupled with its potential use in Enhanced Oil Recovery,
make it particularly favourable as an option for the UK. CCS technology
is also an option for the developing economies such as China or
India and this provides an opportunity for the UK to become a
world-leader in technology development with potential benefits
to UK Exports.
COMMENTS ON
SPECIFIED ASPECTS
OF CCS
Viability of CCS as a carbon abatement technology
for the UK:
The current state of R&D in, and deployment of,
CCS technologies
13. E.ON UK has been tracking the development
of CCS technologies since the early 1990s and is currently participating
in eight Clean Coal and CCS collaborative R&D projects. E.ON
UK has an annual low carbon R&D programme of about £3
million. The R&D of CCS technologies is being extensively
pursued world-wide and a number of technologies are sufficiently
well developed to enable full-scale power generation with CCS
to be demonstrated. These technologies do not represent the final
most efficient or cost-effective designs, but are at a sufficiently
advanced stage to enable such plant to be built.
14. The EU and a number of Governments,
including Canada and the US, have already developed programmes
to examine some of the more important issues facing CCS and several
of these are longer-running than the UK Government's current Carbon
Abatement Technologies (CAT) strategy. UK companies are already
active in a number of EU projects. The common goal of all these
projects is to move towards reliable, and significantly lower
cost, CCS.
15. CCS technologies can be applied to power
generation from coal , gas and other fossil fuels. It is possible
to remove the carbon (as CO2) either before the fuel
is combusted, known as pre-combustion capture, leaving a fairly
pure hydrogen stream as the fuel, or after combustion before the
flue gas is vented via a chimney, known as post-combustion capture.
The two capture processes are fundamentally different and would
be integrated into power plant in different ways.
16. Pre-combustion technologies involve
the chemical conversion of fossil fuels to hydrogen, with oxidation
of the contained carbon and separation of the resulting CO2
. This process requires the gasification of the fuel as a first
step, and hence, the power plant is essentially a type of Integrated
Gasification Combined Cycle (IGCC) plant with a capture technology
included.
17. Historically, IGCC sites have predominantly
been utilised within the chemical and liquid fuel industries.
However a resurgence of interest in the technology for electricity
production has come about directly from the debate on CCS. Large
capacity is yet to be proven and there remains an issue of reliability.
Despite these factors IGCC remains one of the most attractive
technologies for accomplishing CCS demonstration.
18. Post-combustion technologies involve
the separation of CO2 from products of combustion either
by solvent washing (eg using a chemical known as an "amine")
or by pressure separation in a selective membrane filter. Only
the former is sufficiently developed to be considered available
for a full-scale demonstration plant at present. The process may
be facilitated by combustion of the fuel in pure oxygen ("oxyfuel
firing").
19. Amine scrubbing is the most advanced
technology for post combustion capture of CO2 from
power plant. A plant for one 500 MW coal fired unit would capture
around 8,000 tonnes per day. The technology has been used for
over 80 years for gas sweetening in the petrochemical industry
and there are hundreds of plants in service today. Although CO2
capture from flue gas presents additional problems due to the
presence of oxygen and other contaminants in the raw gas, the
technology has been used in this way for over 25 years and 23
commercial scale plants have been built. The technology could
be adopted for use on a large coal fired unit today if required.
However, the largest plant built so far was designed for 1,000
tonnes per day. There would therefore be technical and commercial
risks in fitting the technology to a 500 MW coal fired unitwhich
would require an increase in scale by a factor of about eight.
20. E.ON UK believes that both pre-combustion
CCS and post combustion CCS full-scale demonstration power plant
could be built now. This could be as a retro-fit to existing plant
or in a new plant.
Projected timescales for producing market-ready,
scalable technologies
21. E.ON UK believes that power plant with
CCS could be developed to be a candidate for a significant fraction
of the new plant required to entered service over the next 10
years.
22. There are currently no full-size (.300-500
MWe) power plant with CCS operating world-wide. There are no IGCC
plant (which would form the basis for a pre-combustion CCS power
plant) operating commercially with the load factors required to
be competitive in the UK electricity market. However, both post-
and pre-combustion technologies are sufficiently developed for
full-size plant to be built.
23. E.ON UK believes that both pre-combustion
CCS and post combustion CCS full-scale demonstration power plant
could be built now. However, the first such demonstrations would
be of less than optimal design and efficiency, using technology
that would be improved upon well within the lifetime of the plant.
24. Demonstration plants are vital in establishing
the viability of CCS for several reasons. A full-scale demonstration
project is the most effective way of identifying and addressing
all the transport and storage issues associated with large scale
CO2 production from power plant. These issues include:
Amendment of legal and regulatory
regimes to enable CO2 storage.
Identifying suitable storage sites.
Establishing the true potential of
EOR as a driver for CCS.
Practicalities of sourcing CO2
for EOR.
Monitoring and verification methods.
Long-term ownership of CO2.
Authorisation and planning.
Co-ordinating industry stakeholders.
25. The potential cost benefit of using
CO2 for EOR in the North Sea has been widely promulgated
as a driver for CCS in the UK. This potential needs to be assessed
in detail but is likely to be site/project specific. There are
timing issues associated with CCS storage via EOR because many
oil fields are reaching the end of production within the next
few years and will then be de-commissioned. EOR would not be an
option once this has occurred. Demonstration projects with EOR
would enable the economics to be evaluated and also demonstrate
the technical feasibility of EOR using land-based CO2
sources.
26. Although some capture technologies have
been demonstrated at reasonable scale, integration of these technologies
into the power plant cycle at full-scale has not been demonstrated
and it is expected that there will be considerable challenges
to overcome. A demonstration plant would address these issues,
establish the UK as a world leader in advanced technology, and
provide valuable operational experience.
27. Finally, building full-scale demonstration
plants provides a signal to manufacturers that investment in CCS
technology development is worth undertaking, hence stimulating
competition and improvements in design.
28. We anticipate that the pre-construction
phase of project development would take at least two years from
the decision to proceed by the generator, and the construction
phase would be about three years. Therefore we expect that CCS
full-scale demonstration plant could be in operation by 2010-12.
It is unlikely that these prototype plants would be commercially
viable without Government capital grants or similar support.
Cost
29. The current costs of CCS projects are
uncertain. The development of practical projects will reduce this
uncertainty and experience is expected to reduce costs over time.
30. For example, our current estimate is
that an amine scrubber plant retro-fitted to a 500 MW coal-fired
unit would cost approximately £120 million to build and would
reduce the power output of the unit by 20% to 30%. This equates
to a cost of about £30/te CO2 abated. However
the technology is the subject of world-wide R&D at present
and refinements to the process and plant designs are being claimed
regularlywith the expectation that costs and operational
efficiency penalties will fall considerably over the next few
years.
31. The table below sets out the estimated
costs of power plant with CCS technologies fitted compared to
some other generation types. These costs relate to new-build plant.
32. The estimated life-time cost of different
technologies is each dependent on a range of estimated input prices
and business risks. Therefore, the table below shows a range of
lifetime cost estimates for plant commissioned in the next decade:
|
Generation Type | Cost range p/kWh (2005 prices)
| |
|
Carbon capture & storage | 3.3-5.6 gas
3.9-5.1 coal
| |
CCGT | 2.2-4.9
| |
Coal with FGD & SCR | 2.8-5.2
| |
Wind Onshore
Offshore | 4.2-5.2
6.2-8.4
| Excludes costs of back-up capacity
|
Nuclear | 2.5-4.0
| |
|
33. These estimated costs exclude any additional benefits
or costs which might arise from Government support, fiscal or
regulatory measures. Carbon capture and storage is only likely
to be deployed if there were to be a belief in the long-term market
value of avoiding carbon emissions, which would increase the cost
of plant types which emit CO2 to the atmosphere. At
present a carbon price is generated through the EU Emissions Trading
Scheme. An explanation of the ranges provided above is given in
the Annex.
Geophysical feasibility
34. Geological storage is being actively investigated
in many projects world-wide. Injection of CO2 into
hydrocarbon reservoirs and its use in Enhanced Oil Recovery (EOR)
is well established, particularly on mainland USA, where EOR using
CO2 has been in operation for several decades. However,
EOR using CO2 has not been commercially undertaken
in the North Sea. There are also a number of field projects looking
specifically at the injection of CO2 underground for
storage purposes. All these projects have demonstrated that it
is feasible.
35. Current evidence based on several large-scale CO2
storage projects, laboratory based experiments and theoretical
studies, suggests the risk of significant CO2 leakage
from saline aquifers or hydrocarbon reservoirs can be very low.
However, leakage risk can be very site specific and further work
needs to be done on how to assess this risk. There are also some
issues to be resolved relating to the extent of likely local environmental
impact (eg through leakage to the surface or into the ocean).
36. The geophysical issues that need further study are
those relating to:
the long-term effectiveness of geological storage;
the effectiveness of storage when injecting for
enhanced oil recovery;
the technologies for monitoring the stored CO2;
and
Other obstacles or constraints
37. CCS is a complex process with many involved stakeholders.
Of major concern to E.ON UK, as the potential operator, is the
current absence of a mechanism for crediting the operator with
the CO2 emissions reduction that CCS would bring about.
Without a mechanism of accreditation, an operator would not be
in a position to offset the capital costs and running costs of
the additional plant required for CO2 capture.
38. In order for the EU Emissions Trading Scheme to recognise
CCS-based CO2 reductions, the European Commission would
need to be assured that CO2 reductions were robust
and not likely to be significantly offset by future leakage from
geological reservoirs. Methods for auditing CO2 reductions
from a power station with CCS would be relatively straightforward.
Likewise, leakage from pipelines is simple to measure, so it is
in the development of methodologies for verifying CO2
storage that the majority of effort needs to be focused.
39. The purpose of the EU ETS is to enable overall CO2
reductions within the sectors participating to be achieved in
the most cost efficient way, with the market carbon price acting
as the driver for the deployment of a particular reduction technology.
CCS technology represents a very significant additional investment
cost to power production. In order for a power company to invest
in CCS , the company needs confidence in the long-term value of
carbon emissions, and this would be much improved if the EU ETS
rules were firmly defined over the 2008-12 and ensuing periods.
40. Without an accepted mechanism for the inclusion of
CCS-based CO2 reductions into international carbon
frameworks such as the EU ETS or the Kyoto Flexible Mechanisms,
it is unlikely that CCS technologies would be deployed on a large-scale.
41. Most of the UK's resources for storing CO2
in geological formations are located offshore. The treaties governing
the injection of CO2 , as relevant to the UK, are the
London Convention, the London Protocol, and the OSPAR Convention.
Because CCS technologies are relatively new, the storage of CO2
underground for purposes other than as the incidental result of
Enhanced Oil or Gas Recovery, is not included explicitly in these.
It is important that these Conventions are amended to allow the
injection of CO2 when it is not for the purposes of
EOR.
42. It is not clear at present what entity would be legally
responsible for the management of the stored CO2 .
During the lifetime of the CO2 injection, this might
be expected to be a company. However over the long term, this
responsibility and liability would be best placed with the Government.
43. Finally, the large-scale storage of CO2
will need to find acceptance with the general public. At present
public awareness in the UK of CCS is low and it will be important
to increase this significantly over the next few years in order
for informed public debate to ensue.
44. In summary, the role of the Government is crucial
for there to be a range of low-carbon technological options including
CCS available to companies investing in future power generation.
We believe this role must be to:
provide the right market framework to achieve
government objectives within a competitive market environment.
This should increasingly rely on long-term broad ranging market
based mechanisms, such as the EU emissions trading scheme, as
the main driver to incentivise the most economic low carbon investments,
encourage innovation in energy supply and support UK competitiveness.
Such incentives must be sufficiently long term (>10 years)
to stimulate major capital investment;
aim to achieve a broad international commitment
to action to tackle climate change which shares responsibility
across the major emitting economies; with any post-2012 agreement
being consistent with investment timescales10-15 years
seems appropriate;
resolve specific policy, legal and institutional
constraints which are limiting the choice of technologies. For
CCS this covers establishing the legal and regulatory framework
(including monitoring requirements), ensuring that the relevant
international agreements (the London Convention and Protocol and
the OSPAR Convention) recognise the legality of CCS, and establishing
how the long-term liabilities arising from geologically stored
CO2 will be handled; and
encourage the development and demonstration of
emerging technologies with capital grants or similar support.
UK GOVERNMENT'S
ROLE IN
FUNDING CCS R&D AND
PROVIDING INCENTIVES
FOR TECHNOLOGY
TRANSFER AND
INDUSTRIAL R&D IN
CCS TECHNOLOGY
45. The role of UK government funding is essential in
moving forward both the development and the demonstration of low
carbon technologies.
46. UK RD&D activities should recognise the considerable
R&D taking place worldwide and seek to ensure that R&D
work carried out in the UK complements international programmes.
However, different worldwide markets may well produce different
optimum solutions for low carbon futuresgiven their power
market, fuel portfolio and existing technology mix. UK Government
R&D funding should be used to underpin the UK's CO2
reduction targets.
47. UK Government funding should be targeted at the development
of technologies which will be deployable in the timeframes required
by the UK market and which, in the long term, will be capable
of operating within a fully competitive power market. Funding
is necessary to promote expertise in the fundamental aspects of
CCS technologies (within equipment suppliers, users and universities)
to promote long-term sustainable expertise in the UK.
48. In addition, CCS systems are likely to require that
links are forged between existing areas of expertise within UK
industry, (which may include boiler system optimisation, amine
scrubbing, pipeline design, petroleum engineering, shift reactor
design etc) which allow an optimisation of a whole CCS system
to be undertaken. R&D funding should be used to foster links
of this type.
September 2005
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