Select Committee on Science and Technology Written Evidence


APPENDIX 10

Memorandum from the Environment Agency

SUMMARY

  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 fuels.

    —  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.

1.  INTRODUCTION

  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 of ways:

    —  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 THE ENVIRONMENT AGENCY RELATING TO CARBON CAPTURE AND STORAGE

  Internationally, there is significant momentum behind the use of CCS to help tackle climate change. Recent developments include:

    —  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 technology-based solutions.

    —  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 way.

2.1  Meeting global and domestic emissions targets

  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.

2.3  Regulation

  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.

3.  CONCLUSIONS

  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.

September 2005





 
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