Memorandum from the Environment Agency
The Environment Agency welcomes this opportunity
to provide written evidence on some of the issues surrounding
carbon and capture and storage (CCS).
The Environment Agency recognises that CCS,
providing it is validated as an effective technology in practice,
could make a significant contribution to stabilising global emissions
of greenhouse gases and preventing dangerous climate change. However,
it is important to recognise that it is not the whole solution.
We need to use a wide and integrated portfolio of clean technologies
and energy policies to achieve the necessary step change to a
low carbon economy:
We support the 2003 Energy White
Paper, which provides a long-term vision for sustainable energy
in the UK.
We want the current review of the
UK Climate Change Programme to re-enforce efforts to improve energy
efficiency and the development of renewable sources of energy.
We do not want investment in these core policies diverted to support
an UK CCS programme or to unnecessarily prolong the use of fossil
Nevertheless, we welcome the publication
of the Government's Strategy for Developing Carbon Abatement Technologies
for Fossil Fuel Use, particularly:
The £25 million ring-fenced for
demonstrations of CCS. It is crucial that some of this fund is
spent on understanding the impacts of carbon leakage to the surrounding
environment, providing information to inform environmental impact
assessment and developing cost-effective regulation.
Its commitment to establish a regulators'
group to give early consideration to the legislative and regulatory
framework for CCS activities. We want to see an effective system
that adequately protects the environment and human health.
Carbon capture and storage is a relatively new
area, and clarity is required on a number of areas. Currently,
it is generating broad interest in Government, industry and the
environmental sector as a means of tackling the emissions of greenhouse
gases from fossil fuels, which are a cause of climate change.
While CCS is already in use on a small scale in enhanced oil recovery
and other pilot projects, there remains a need to undertake full-scale
demonstrations of these technologies to better understand the
contribution that they could play in achieving cost-effective
action on climate change. Further, where policy-makers support
the use of these technologies that we need to consider any interaction
and impacts on existing policies and measures.
During Spring 2004 we undertook a mapping exercise
to assess how CCS activities could affect our operational activities.
This fed later into a legislative/regulatory gap analysis that
the Dti prepared for the Carbon Storage Leadership Forum and is
referenced in the Government's Strategy for Developing Carbon
Abatement Technologies for Fossil Fuel Use.
CCS is likely to impact our role in a number
As the Competent Authority for Pollution
Prevention and Control and the EU Emissions Trading Scheme in
England and Wales, we regulate large power plants and industrial
installations most likely to adopt CCS technologies. Further,
we may be called on to regulate carbon storage where it is sited
on land in England and Wales. This may have implications for water
abstraction licensing, environmental monitoring and, depending
on whether carbon dioxide is defined as waste, on waste regulation.
We are a statutory body tasked with
protecting and reporting on the state of the environment of England
and Wales, including limiting and adapting to climate change.
We have to be consulted on planning applications with associated
environmental impact assessments for new power plant or industrial
installations. This responsibility is likely to be extended to
planning applications for carbon storage sites within our jurisdiction.
Issues include protection of water resources, water and soil quality,
ecological status and wildlife.
We are supporting the delivery of
the 2003 Energy White Paper, which commits the UK to reducing
carbon dioxide emissions by 60% compared to current levels by
2050. We recognise that sometimes there is a conflict between
the urgent need to limit climate change by cutting emissions and
the desire to protect the local environment and quality of life.
Using an evidence and risk-based approach, we will not object
to measures and schemes where overall they can be shown not to
have an unacceptable impact on the environment.
In the remainder of this document, we concentrate
on areas relevant to the roles outlined above.
2. ISSUES FOR
Internationally, there is significant momentum
behind the use of CCS to help tackle climate change. Recent developments
New dialogues under the UK's presidency
of the G8 with the US and key developing countries on the shape
of future climate change action. Any agreement is certain to include
The Government has recently announced
a bilateral agreement with China, which includes a demonstration
of a zero-carbon power plant using CCS technology by 2020.
The International Panel of Climate
Change will release a Special Report later this year that will
review research on the technical and economic feasibility of CCS.
The UK has ring-fenced £25 million
for demonstrations of CCS. BP and partners have already begun
engineering designs for an enhanced oil recovery project in the
North Sea oil fields.
This inquiry by the Science and Technology Committee
is timely given these initiatives to explore and promote CCS technology.
We have a small window of opportunity to test whether CCS works
in practice and to ensure that its development and use in the
UK takes place in an environmentally sustainable and cost-effective
2.1 Meeting global and domestic emissions
Fossil fuels are likely to continue as a significant
part of the energy mix in the UK and worldwide until 2030. At
the same time, the Intergovernmental Panel on Climate Change (IPCC)
suggests that we need to reduce global emissions of greenhouse
gases by 80% to avoid dangerous climate change. Analysis of international
mitigation options suggest that we need to use the whole technology
portfolio, including CCS, to achieve the necessary emission cuts.
The projected growth in global emissions means
that we need to find cleaner ways to use fossil fuels. For example,
China will need to build about one coal or gas-fired power station
a month until 2030 to satisfy its anticipated energy demand. Making
these new power plants ready for CCS when it becomes more widely
available may be the only pragmatic way to mitigate these emissions
in the short to medium term.
In the UK there is a commitment to achieve a
60% cut in carbon dioxide emissions by 2050. In the short to medium
term this means using fossil fuels in cleaner ways. We recognise
that CCS could provide a bridging option that supports a transition
from our current dependence on fossil fuels to a future of more
sustainable energy choices.
2.2 Sustainable energy choices
Carbon capture and storage can only be part
of the solution to climate change. It is unlikely to make a major
contribution to emissions figures until at least 2015 and it is
only suitable for large point sources that make up about 35% of
UK emissions. In parallel we need to step up our efforts on improving
the energy efficiency in industry and public and domestic buildings
and promoting greater uptake of renewable energy. Both present
cost-effective and proven solutions that can deliver large emission
savings in the short term. Emissions from transport also need
to be urgently addressed.
We have concerns that the development and deployment
of CCS technology will:
distract effort from more cost-effective,
immediate and proven solutions
unnecessarily prolong our dependence
on fossil fuels, which is counterproductive for the environment
overall given the associated emissions of acid gases, heavy metals
and solid wastes
lead to unacceptable environmental
and social risks from slow or catastrophic leakage.
Nevertheless, we welcome the publication of
the Government's Strategy for Developing Carbon Abatement Technologies
for Fossil Fuel Use, that includes CCS, providing it works within
the vision of the 2003 Energy White Paper and is consistent with
the UK Climate Change Programme.
A key issue for the Environment Agency is the
legislative and regulatory framework for CCS activities. If these
technologies are to exist in the UK, we want to see an effective
system that adequately protects the environment and human health.
There is currently a lack of clarity over the
definition of carbon dioxide and whether it falls under international
and national waste legislation. There is also uncertainty over
the jurisdictions of the various regulators and their responsibilities
during the planning, permitting and operation of CCS activities.
One issue that needs to be considered is the regulation of offshore
injection where they could have implications for land-based water
resources (aquifers do not respect the land/sea boundaries). Long-term
liability for storage sites is also of issue: carbon dioxide may
need to be stored for hundreds of years, significantly longer
than the lifetime of most commercial companies. We suggest that
the Government commissions a desk study on these and other similar
issues and gets early involvement from the regulators in demonstration
and pilot projects.
The Environment Agency wishes to draw to the
Select Committee's attention to the lack of quality information
to support environmental impact assessments of storage sites.
We need to collect this data over relatively long timescales and
in a variety of geological environments. Currently, there is little
understanding of the interactions that can occur between injected
carbon dioxide and other chemicals/pollutants in the surrounding
material. Likewise, we do not fully understand the integrity of
different geological structures; the impacts on local water bodies
or how low levels of carbon dioxide can impact on ecology and
wildlife. We call on Government to ensure that these issues are
considered during their programme of demonstrations.
The Environment Agency recognises that CCS could
make a significant contribution to delivering UK and global emission
reductions. However, we consider that the technology requires
considerable validation to ensure it is cost effective and has
sufficient environmental integrity in the different circumstances
that it may be used. Further, we wish to emphasise that CCS can
not on its own mitigate the serious threat of climate change.
As such, it should not be allowed to divert attention or resources
from improving energy efficiency, the promotion of renewables
or efforts to tackle emissions from transport.
We also wish to highlight the need for early
consideration of the legislative and regulatory issues surrounding
CCS. Currently, there is a lack of quality information to support
environmental impact assessments. This needs to be addressed to
ensure that we locate and regulate carbon dioxide storage sites
in ways that minimise risks to the environment and human safety.