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4.1 Legal framework and guidanceMain objectives
This Work Package will deal with the implementation of proposed EU legislation for CCS in the Netherlands, and recommend on a number of outstanding issues. In particular, it will:
Also recommendations will be made for further improvements to the legal framework, related to inter alia composition of the CO2 stream, transboundary CO2 transportation and storage and third party access. Support to the implementation of the EU CO2 Storage DirectiveThis work will identify pitfalls and possible choices in the implementation of the various regulatory regimes that apply to CCS, including notably the EU Directive on the Geological Storage of Carbon Dioxide, but also the National Greenhouse Gas Inventories and OSPAR. Questions to address include: Is it possible to develop more generic standards and criteria for safe site selection? What ways are conceivable to satisfactorily regulate CO2 streams with relatively high concentrations of associated compounds, and liability issues arising from it? Which party will be responsible for leakage arising from transboundary transport and storage of CO2 from a neighbouring Member State, both during injection and after closure of the site? How can safe storage be demonstrated legally so that governments can take on liability? Furthermore, large projects CCS chains will need a range of permits, including permits under the Mining Law, the Law Environmental Management, involving multiple permitting bodies. This implies several opportunities for stakeholders to delay permitting. How may delays following from law protection for stakeholders and possibly diverging rules with respect to monitoring, supervision be avoided?Monitoring and reporting: practical guidance and assessment of MRGs for EU ETSThis task aims to support the implementation of the Monitoring and Reporting Guidelines for CCS under the EU ETS, which are currently developed by the European Commission, as well as the opt-in of CCS demonstrations in phase 2 of the EU ETS (2008-2012). Inclusion of CCS in the EU ETS requires that CO2 streams along the entire CCS chain are monitored and verified according to these guidelines, and applicable ISO quality standards for measurements uncertainty, verification, etc.
This task firstly aims to implement the Monitoring and Reporting Guidelines for CCS under the ETS, and to translate these into practical guidelines for writing CCS monitoring plans in the Netherlands in general and more special for the pilot plants (WP2.1) and proposed demonstrations (WP4.1). Secondly, the proposed MRGs will be assessed for the accuracy they require in the measurement of the CO2 streams.
Measurement of fugitive emissions from transport and how to implement the monitoring system for storage in the monitoring plan are main issues in this evaluation. Work in this task will be carried out in contact with the Dutch Emission Authority and in cooperation with WP4.1 (Site specific activities).
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