APPENDIX 31
Memorandum from WWF UK
WWF-UK POSITION SUMMARY
INTRODUCTION
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.
BACKGROUND AND
CHALLENGES
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.
CONCERNS THAT
MUST BE
ADDRESSED
— 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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