Select Committee on Science and Technology Written Evidence


Memorandum from WWF UK



  WWF-UK are currently engaged in a review of carbon capture and storage (CCS) policy and as a result are not submitting a full, detailed response to this inquiry. However we welcome the inquiry, which is indicative of the increasing attention being paid to CCS in political circles, and hope the Committee find this summary paper helpful.


  Any responsible approach to climate change will be based on the rapid reduction of atmospheric pollution of greenhouse gases at the point of source. As a priority, WWF-UK supports policies that rely on clean renewable energies (such as renewable heat, wave, solar, biomass and wind energy), energy efficiency and energy conservation (such as energy services) as the ultimate solutions to climate change mitigation. However, there is an ongoing debate about carbon capture and storage as a theoretical means to "decarbonise" fossil fuels, which must be addressed.

  The attractions of CCS technology are understandable, particularly when applied to rapidly emerging economies such as China, where demand for energy is spiralling and a ready supply of coal means an extensive programme of new coal station building is well underway. However, WWF-UK is apprehensive and concerned about the dangers of seeing CCS as a solution to climate change in itself, rather than as a potential short-medium term "bridging technology", which could be employed under certain conditions in order to gain time in the switch to a genuinely carbon free energy supply system. CCS involves a range of environmental risks and uncertainties that are currently poorly understood, and require further research and discussion.

  The Intergovernmental Panel on Climate Change (IPCC) formally adopted a new "Special Report on Carbon Capture and Storage" this month, which finds that CCS will only truly take off when the right policy frameworks, including implementing carbon dioxide (CO2) reduction targets, are in place. Governments must not take their "eye off the ball" of achieving deep cuts in emissions, as well as funding and implementing strong laws and programmes on energy efficiency and renewable energy. It is these aspirations and measures that underpin the UK Government's own Energy White Paper (2003).

  WWF-UK would like to highlight a set of principles and key concerns that must be addressed by Government and industry, which are central to the CCS debate, and the outcome of which will determine the extent to which CCS should play a part in global climate change policy. An informed public debate on CCS focussing on the key issues outlined below is critical.


    —  Commit to climate targets: The UK Government must continue to commit to the short-term and long term emission reduction targets (20% by 2010; at least 60% by 2050 but optimally 80%), and adopt medium-term targets (ie 30% by 2020) to reduce carbon dioxide emissions.

    —  Climate and energy policy to prioritise renewable energy and energy efficiency: Responsible climate policy must be centred on a combination of robust energy efficiency, renewable energies, energy demand reduction and sustainable land use policies, as a top priority to achieve these deep cuts in emissions required to combat climate change. This must include increased research and funding for renewables and energy efficiency, which are proven, presently less risky and have many additional benefits such as increased security of supply (eg less import of fossil fuels from unstable areas). If CCS is to be included in climate and energy policy, it should only be an "add on" for more rapid stabilization of atmospheric concentrations of greenhouse gases at environmentally safe levels, after thorough and rigorous assessment of its need and role within the mix. This should not be at the expense of other more environmentally proven and feasible solutions to climate change that are available for deployment today.

    —  No diversion of resources: Government support for energy efficiency and renewable energy technologies in terms of promotion, dissemination, and overcoming market barriers is an essential step towards decarbonising the energy sector. However, mature industries like coal and nuclear power do not need this support and merely benefit at the expense of taxpayers. The government must not divert public funds away from renewable energy and efficiency technologies to support CCS. Application of CCS should be funded by the fossil fuel industry (in recognition of the "polluter-pays" principle) and be subject to independent scientific evaluation. Pre-combustion CCS for hydrogen production is still a nascent technology. Government support of independent and transparent research on this technology may be necessary but should not replace or delay government support for hydrogen from renewable energy sources, and should be part of a package with a clear priority for energy efficiency and renewables.

    —  Assessment of application to existing and new plants: In the case of new power supply, the feasibility of tapping potentials of energy conservation technology and/or renewable energy supply should be assessed before considering new fossil-fuel powered stations. If a new fossil fuel plant is the only viable option, CCS devices should be required if it can be shown that permanence and safety concerns are met.

  Before extending the life of existing fossil fuel power stations by equipping them with CCS technology, feasibility of replacement with energy efficiency technology and renewable energy generation should be analyzed. Application of CCS could result in the continued (and possibly increased) reliance on fossil fuels with a range of social and environmental impacts associated with fossil fuel extraction, transport and production (for power and transport). We must avoid extending the life of existing power generators and locking in a generation of new investment in energy infrastructure with high carbon emissions.

    —  Storage permanence: Any CCS initiative must prove robustly permanence of storage. Carbon dioxide must be stored safely and permanently in locations that do not allow any leakage rate or "gassing out" that would be higher than those from conventional natural gas fields. This would mean a permanence time of longer than 100,000 years. This permanence must be assessed and confirmed through independent scientific review.

    —  No ocean disposal: Storage of carbon dioxide must not interfere with or have negative direct or indirect impacts on biodiversity, which must be assessed by independent scientific review. These criteria strictly rule out any carbon storage in the open ocean, open aquifers, lakes or on the sea floor. Where geological storage is undertaken in the marine environment, CCS should minimise impacts to the marine environment, including risk analysis and plans for unplanned release through well head blow outs.

    —  Independent research and verification: Research is needed to improve the gaps in knowledge on CCS, particularly with regard to storage and assessment of the environmental implications of this technology. Funding in CCS research should not divert funds away from renewables and energy efficiency as a top priority. Research on all aspects related to protection of biodiversity, geological suitability, security and permanence of carbon stored in geological strata must be tested through independently verified pilot projects. Stakeholder processes to allow for review, comment, and addressing concerns should be built into all pilot projects. Any research undertaken should cover: environmental consequences including those associated with fossil fuel extraction; capacity of safe, long term underground storage of carbon; risks to public safety; characteristics of the currently much less understood saline formations. Such research should also determine the realistic scale of using these technologies within the large portfolio of carbon abatement options.

    —  Monitoring and verification of storage: There must be internationally agreed procedures for independent verification and monitoring of storage and related activities before CCS technologies are allowed to count against greenhouse gas reduction targets.

    —  Regulation: The government must set up stringent and unambiguous regulatory principles which have involved full public consultation for CCS projects, to cover the range of risks and uncertainties surrounding CCS. This should include commitment to develop with proponents Emergency Management Plans for site specific projects. CCS should be included in the Marine Act process. CCS should have SEA and or EIA and this should include full impacts of the use of oil and gas on the climate.

    —  Liability: The government must also establish a stringent legal framework for regulating CCS facilities, which addresses legal liability issues relating to the economic, social and environmental costs of the project and leakage over the lifetime of storage, and those legally responsible. This framework must ensure that future corporate insolvency or restructuring should not diminish the effectiveness of the liability regime.

    —  Public dialogue: CCS will face hurdles of public acceptability and will require a fully informed public debate on CCS, so that the public are educated on this technology. Inclusion of NGOs and the public in discussions about carbon technologies is absolutely necessary, and including specific projects on the ground and the policies affecting their development. Assessment processes for projects which go ahead in the future should involve public consultation.

    —  Use of CCS credits: Credits from CCS should not count toward meeting Kyoto Protocol targets in the first commitment period as CCS was not considered when the first commitment period targets were set. If CCS is to be allowed to count in future commitment periods, the theoretically large reduction potential must be taken into account in target-setting. Among developed countries, only those with absolute CO2 caps should be allowed to receive credit for CCS.

    —  Net environmental gain: Carbon dioxide capture usually requires up to 30% more energy to produce a given amount of power than what would be needed without capture. In order to avoid an increase of conventional pollution such as from sulphur, nitrogen oxides, heavy metals etc, carbon capture must be based on gasification or similar technologies which ensure a net environmental gain compared to a non-capture case eg net reduction in carbon dioxide emissions over the life cycle of the project.

    —  UK policy frameworks: In the UK, WWF is aware that there is a live debate about the possible policy frameworks the government could establish to support and incentivise CCS projects that may offer good demonstration examples for this emerging technology. The government should refrain from establishing any additional obligations or measures (for example, similar to the Renewables Obligation), since the European Emissions Trading (ETS) Scheme offers the opportunities for such technologies amongst other carbon abatement technologies to become financially viable, as long as the scheme is set up tightly and robustly. It is in the interests of government and projects proponents to ensure that the scheme is functioning properly in the next phase (2008-12) and subsequent phases in order to provide the strong and long-term price signal necessary. As a precondition of support for CCS, the regulatory and legal frameworks discussed above must be in place, particularly to address storage issues.

November 2005

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