World Coal Institute Response to UK Government Consultation on CCS
18 August 2009
The World Coal Institute (WCI) recently submitted its input into the UK Department of Energy and Climate Change (DECC) consultation on a framework for the development of clean coal.
The UK government outlined proposals for a new regime for new coal-fired power stations back in April this year. It highlighted that there is an urgent need to develop technologies that tackle emissions given that coal emits more carbon dioxide per unit of electricity produced than all other forms of generation and because the global use of coal as a fuel for electricity generation is expected to increase over the coming decades. The consultation specifically looks at the UK's plans for invigorating global action on carbon capture and storage (CCS).
WCI Submission
The WCI welcomes the Government's proposals for the development of clean coal and CCS in the UK. Through these proposals the UK Government has the potential to accelerate the commercialisation of CCS technologies both domestically and internationally. As a non-profit, non-governmental industry association working internationally on behalf of the world's major coal producers and stakeholders, the WCI sees CCS as the key technology towards allowing countries and regions endowed with coal resources to help maintain their energy security whilst making significant cuts to CO2 emissions.
The Government's commitment to delivering demonstration projects is commendable. However, the WCI believes that, rather than seeking to deliver "up to" four projects as the text specifies, the Government should commit to four projects as the absolute minimum number required. This will provide greater potential for the demonstration of the full suite of capture technologies, including pre-, post-, and oxyfuel combustion.
Demonstrating the full suite of capture technologies would allow the UK to determine the most technically and cost efficient method for its own needs, as well as providing valuable experience to share internationally. A national commitment to four projects would not be excessive for an economy the size of the UK. The Australian Government - with a far smaller GDP - has already committed itself to four CCS projects and the UK Government, as a member of the G8, has already pledged its support to a target of developing 20 large-scale CCS demonstration projects around the world by 2010, with a view to accelerating broad deployment of CCS by 2020.
In its response, the WCI has sought to address the two main questions posed in the consultation document:
- The design of a financial incentive to support the delivery of up to four CCS demonstration projects in the UK.
- A regulatory framework for coal power stations that would drive the development and deployment of CCS technologies and reinforce our expectation that emissions from coal power stations will be substantially reduced in the 2020s.
Incentives for Deployment
While the WCI agrees that there should be a point where all plants should be required to retrofit CCS, it does not believe that an emissions performance standard (EPS) should be introduced, nor should there be a need for a contingency measure should CCS never reach full commercialisation. The EU Emission Trading Scheme (ETS) should be improved in such a way that its cap level makes the need for an EPS redundant. Contingency measures should not be required if the Government is serious about developing CCS as an essential part of the UK's energy infrastructure.
The WCI believes that the Government should use its best judgement to choose the mechanism that will most efficiently deliver the CCS demonstration projects with minimal economic and power infrastructure disruption. In this regard, the WCI is fully supportive of the Government's initial preference to introduce a levy on electricity suppliers. In addition to the EU ETS, the levy should be seen as the extra financial incentive required to make widespread deployment of industrial-scale CCS a reality.
National Regulatory Framework
It is important that this demonstration phase of the widespread deployment of CCS within the UK builds confidence within the local community and industry and demonstrates potential to the international community. Transparency will be paramount. While the WCI has no specific comment to make on the precise nature of the UK regulatory framework, to enhance the transfer of lessons learnt from the UK experience to an international audience the WCI would be available to participate in any broader steering or oversight committee.
A Technically Proven Solution
The WCI believes the full range of technologies for the capture, transport and storage of CO2 have all been demonstrated individually and that the critical factor towards integrating these technologies is primarily economic and political. Extensive work has been undertaken around the world regarding any remaining technical and practical issues, and a series of references targeting these issues can be found as an appendix to this response. Based on questions posed by the UNFCCC in discussion regarding the viability of CCS as a legitimate Clean Development Mechanism (CDM) activity, we have identified the remaining issues as:
- Project boundary, leakage and permanence issues
- Long-term physical leakage (seepage) levels of risk and uncertainty
- Long-term responsibility for monitoring the reservoir
- Long-term liability for storage sites
- Accounting options for any long-term seepage from reservoirs
- Criteria and steps for the selection of suitable storage sites with respect to the potential for release of greenhouse gases
- Potential leakage paths and site characteristics and monitoring methodologies for physical leakage (seepage) from the storage site and related infrastructure - for example, transportation
- Operation of reservoirs (for example, well-sealing and abandonment procedures), dynamics of carbon dioxide distribution within the reservoir and remediation issues
- Environmental impacts
- Relevant work on regulatory approaches worldwide.
The WCI believes it is in the UK's interest for CCS to be accepted as a suitable CDM activity due to the low cost opportunities present in developing countries and the potential for the transfer of technology and experience between the UK and developing countries.
Further Issues to Address
In addition to the points covered in the consultation document, WCI believes that further consideration should be given to the following issues:
- Proposals for the transition from the demonstration phase to a nationally integrated CCS network, with considerations for how the second batch of projects will fit into the timeframe proposed in the consultation document.
- The need for the Government to develop an outreach programme to enhance public knowledge and acceptability of CCS. This need has been re-enforced by recent demonstrations from local residents in Germany opposed to the storage of CO2 captured from Vattenfall's Schwarze Pumpe oxyfuel project. WCI agrees with the decision to target the development of CCS clusters in areas of the country which have existing experience of heavy industrial development.
Consideration of these issues at this stage of the development process will allow for a more seamless transition between the demonstration and commercial deployment phases.
The WCI hopes that this response to the government's consultation document, along with support from other areas of industry and academia, will help accelerate the introduction of the necessary financial and regulatory measures to make commercial CCS in the UK a reality.
World Coal Institute
August 2009
