Memorandum from EEEGR
The East of England Energy Group (EEEGR) is
pleased to make this contribution to the Science and Technology
Committee's investigation into Carbon Capture and Storage (CCS).
EEEGR believes that it is essential that existing
oil and gas pipelines are reused to provide transportation for
Carbon Dioxide (CO2) from shore to suitable depleted
offshore reservoirs. Failure to utilise these national assets
would likely make the positive benefits of carbon capture and
storage offshore both uneconomic and unobtainable.
The East of England Energy Group consists of
over 230 members across a wide spectrum of interests, whose common
objective is to stimulate economic growth and ensure that energy
in its broadest sense not only survives but thrives in the East
of England. It represents every aspect of the energy industry
from offshore oil and gas, through nuclear to renewable energy.
It promotes the wise use of energy.
We can summarise this submission as follows:
1. Pipelines can be reused to transport CO2.
2. Carbon Capture and Storage in underground
reservoirs is proven.
3. Southern North Sea (SNS) gas fields are
best placed to provide offshore storage due in part to their proximity
to shore relative to depleted oil fields further north.
4. The East Coast gas plants eg, Bacton,
Easington/Dimlington and Theddlethorpe could be used for reception
and transmission of collected CO2.
5. The SNS gas field offshore pipeline grid
is such that gas production and CO2 injection for storage
can be concurrent operations.
6. CCS to store CO2 is different
to the use of CO2 for Enhanced Oil Recovery (EOR).
Over the last 40 years, the international oil
and gas industry has invested some £170 billion in the infrastructure
needed to develop the UK's hydrocarbon resources in the UKCS.
Included in this is some 11,000 km of pipeline, installed at an
estimated cost of £11 billion. This investment will not be
repeated. As UK oil and gas production declines resulting in the
decommissioning of offshore facilities, it is generally accepted
that many of the offshore platforms have limited alternative uses
and will be removed; this may not be the case for the pipelines.
Many of these will remain in situ, with a potential lifespan of
200-300 years. Research undertaken by Cambridge and Cranfield
Universities for EEEGR (Note 1) has confirmed that there is no
technical reason why these pipelines cannot be reused to transport
Pipeline transport of CO2 is common
and the technology is proven. According to the International Energy
Agency (IEA), in Paris, some 3,100 km of pipeline are in use,
the majority of which is located in North America. The longest
pipeline covers 808 km and has been in use since 1984 carrying
19.3 mt of CO2 each year.
Geological storage of CO2 is being
undertaken by Statoil in its Salah field in the North Sea and
by BP in its Inshallah field in Algeria.
The practice of re-injecting CO2for
enhanced oil recovery (EOR)is also well proven in the US.
A major EOR project reusing an existing pipeline for CO2
transportation is being advanced by BP for its Miller oilfield
in the UK North Sea.
If carbon storage in geological reservoirs is
going to occur in the UKCS, the most likely area for this to happen
is the Southern North Sea (SNS) for number of reasons:
The fields were the first to be discovered
and developed and therefore will be amongst the earlier ones to
become depleted and subject to decommissioning. A number of fields
have already been decommissioned and others are currently in the
decommissioning planning stage thus releasing pipelines in the
near-term for reuse.
The geology of gas fields with non
associated gas is more suitable for long term storage of CO2
than fields that have produced either oil or gas associated with
In comparison to Central or Northern
North Sea fields, SNS fields are relatively close to onshore infrastructureaveraging
only 30-50 km from the coast.
There are three onshore gas processing
terminals connected with SNS gas fields, with three plants at
Bacton and one each at Theddlethorpe and Easington/Dimlington.
(Whilst we have focused on the SNS in this submission it should
be noted that there are also gas fields and plants in the Irish
Sea that could serve this purpose equally well.)
Each of the East Coast terminals
has a number of pipelines running into them from the offshore
fieldsfor example Bacton alone has 11 pipelines coming
into the area excluding the Interconnector from Belgium.
Some of the individual fields have
a number of pipelines connected to them and are independent of
other operations. Hewett, operated by Tullow Oil, for example,
has two pipelines from the field to Bacton, which theoretically
could allow CO2 to move in one line from Bacton to
part of the field for storage, while allowing another part of
the field that was not depleted to use the other pipeline for
gas transportation to Bacton. This would have the potential of
improving the economics of CO2 storage through the
sharing of costs with a producing facility.
According to the DTI, 60 small steel platforms
are due to be removed in the period 2008-2015, coinciding with
the period when up to 50% of UK electricity generating capacity
is due to be replaced, which would allow carbon capture technology
to be integrated in design.
Given that it takes three to four years of planning
and approvals before actual decommissioning takes place, reuse
for CO2 storage needs to be built into the decommissioning
process now. The forthcoming Energy Review should consider this
EEEGR hopes that this submission will add to
the knowledge gathered by the Committee in this vitally important
IN SUPPORT OF THIS SUBMISSION THE FOLLOWING
NOTES ARE PROVIDED
EEEGR will shortly be releasing a report sponsored
by the DTI and Industry and undertaken by the Universities of
Cambridge, Cranfield and East Anglia, entitled "Enabling
the Reuse of Offshore Pipelines", which includes use for
CO2 storage. The report contains a number of recommendations
for further action, including;
Changing the 1998 Petroleum Act to
permit re-use for CO2 and to resolve the perpetual
residual liability issues.
Resolving London Convention and OSPAR
issues pertinent to CO2 re-injection underground (ie"dumping")
as quickly as possible.
Building potential re-use for CO2
into the DTI decommissioning process as a requirement.
Considering setting up a Re-Use Unit
in the DTI to enable specific pipeline ownership transfers and
the resolution of residual liability issues.
Intensifying work to identify geological
structures suitable for long term CO2 storage.
Identifying fields in the SNS that
might be suitable for CO2 storage.
Undertaking a major study of fields
approaching end of field life as possible candidates for CO2
Undertaking a study on how to move
captured CO2 from source to established onshore gas
processing terminals for onward transmission offshore.
The end of field life process is managed by
the Decommissioning Unit of the DTI located in Aberdeen. Current
legislationprincipally the 1998 Petroleum Actdoes
not consider the use of North Sea infrastructure in general and
pipelines in particular for anything other than hydrocarbon production
and the DTI's structures and procedures reflect this legal requirement.
Thus the presumption is that all facilities will be decommissioned
relatively quickly after their use for oil and gas production
is over, with infrastructure being removed in line with international
obligations covered by the London Convention and OSPAR. Moreover,
most oil and gas companies, through the mechanism of perpetual
residual liability clauses in their original exploration licenses,
would have an incentive to reduce this potential liabilityhowever
smallto as little as possible by removing as much infrastructure
over and above the legal requirement as quickly as possible.
In their decommissioning proposals, companies
are currently required to carry out a comparative assessment to
determine the best decommissioning options. Reuse is considered
as part of this assessment, but no extra weighting is given to
it. However, current legislation provides a disincentive for reuse
for CO2 storage, due to ownership and liability issues
attributed to a change of use.
Through its current Presidency of both the G8
and EU, the UK government has highlighted environmental issues
in general and global warming in particular during its term. This
environmental focus has also been a major theme running through
UK domestic energy policy for the last few years, in particular
as outlined in the 2003 Energy White Paper.
As part of this focus, the UK has made a number
of stretch targets to reduce its emissions of CO2 in
excess of that required by the Kyoto Protocol. The latter requires
the UK to reduce its greenhouse gas emissions by 12.5% below the
1990 level by 2010, but the domestic goal is 20%. However, the
UK has also stated in the Energy White Paper that it intended
to show global leadership by putting itself on the path to a 60%
reduction in CO2 emissions by 2050.
Given the widespread recognition that achieving
these goals will not come through a significant and short term
reduction in fossil fuel burn, attention has been drawn to the
potential for using carbon capture and storage as a way of reducing
emissions of CO2. This potential has been recognised
in the UK through the publication by the DTI in September 2003
of its "Review of the Feasibility of Carbon Capture and Storage
in the UK" and by "A Strategy for Developing Carbon
Abatement Technologies for Fossil Fuel Use" in June 2005. Scottish
Enterprise has highlighted the market opportunities offered by
CCS in its report in September 2005. Internationally, the
IEA published "CO2 Capture and Storage in Geological
Formations" and most recently, the Intergovernmental Panel
for Climate Change (IPCC) assessment concluded, with a number
of caveats, that CCS could play a major role in minimising climate
These reports highlight many issues but two
points relevant to this submission are identified:
There are few technical reasons why
CCS cannot be undertaken, but there are many political, economic
and legal reasonsboth national and internationalwhy
it may not happen for a long time to come.
From a UK perspective, if the country
is going to have any chance of meeting even part of its 2050 target,
CCS has to be up and running to a significant extent by 2020 at
the latest. In this context, it is significant that up to 50%
of the UK's current installed electricity generating capacity
is due to be retired between 2008 and 2015. This capacity will
need to be replaced during this period.
EEEGR believes strongly that the re-use of existing
North Sea oil and gas infrastructure as outlined in this submission
to recover and store CO2, is required to meet the 2020
target. However, for this to happen, the window of opportunity
must not be missed and decisions regarding North Sea infrastructure
need to be taken sooner rather than later.