Carbon capture and storage method: proposed new method under the Emissions Reduction Fund

Comments on draft. PJC

Carbon Capture and Storage Method 2021 – Draft Simple Method Guide

Background of person contributing the comments.

Professor Peter J Cook More than 20 years of experience in CCS in Australia and internationally. This includes as Director of the British Geological Survey, CEO of the Petroleum CRC, CEO of CO2CRC, Professorial Fellow, Peter Cook Centre for CCS Research at the University of Melbourne, consultant to industry and governments. Extensive publications on CCS.

General comment

Overall I believe the draft guidelines for the application of ACCUs to CCS are appropriate and practical, and should serve to accelerate the implementation of CCS as a mitigation option for Australia.

Specific comments

Page 10 Taking the information available into account, the proposed CCS method provides for three per cent of ACCUs to be withheld refundable on evidence of successful site closure issued by the regulating authority.

It is unclear on what the 3% is based on, but the later mention of 3% ( page 14) suggests that it is based on the view that this a reasonable number to cover potential leakage of CO2. The number is too high (see later)

Page 12 For capture points where the capture of greenhouse gases would have been required and undertaken routinely without a CCS project, such as when carbon dioxide is removed during natural gas processing operations, the emissions associated with that activity are not considered capture related emissions.

I am unclear if the guidelines are implying that CO2 removal from gas processing operations cannot qualify for ACCUs? If this is not so, then perhaps the guidelines could be clarified. If it is so, then I would be of the view that this is a shortcoming in the guidelines. There should scope for inclusion of such emissions as ACCUs. In the absence of regulations requiring such emissions to be sequestered they will continue to be emitted to the atmosphere if there is no ACCU opportunity

Page 13 Storage site monitoring emissions

Project proponents will be required to undertake a range of monitoring and verification activities to ensure the underground storage of emissions remains secure including monitoring wells and undertaking seismic surveys.

I consider it inappropriate to specify particular monitoring techniques, such expensive techniques such as seismic profiling or involving a monitoring well. It should be left to the project proponent to prove to the regulator that whatever monitoring technique is used is adequate and reliable. In the coming years, new M&V techniques will undoubtedly evolve and projects should reasonably expect to use them if they are equally reliable and less costly.

Page 14 Risk of abatement reversal

The abatement calculation reduces abatement by three per cent in each reporting period to account for the risk that injected greenhouse gases are released from the storage site after the end of the crediting period.

The 3% figure used here appears to be arbitrary and of questionable merit. The IPCC Special Publication on CCS (of which I was a coordinating lead author) concluded that in a well -characterised geological site, the loss of CO2 would be 1% or less of total stored CO2 over 1000 years. The 3% figure proposed here, over say 50 years would be equivalent to an extrapolated loss of 60% of all stored CO2 over 1000 years! This would be equivalent to saying the site was a total failure and would serve to undercut confidence in CCS as a mitigation option. The draft guidelines say elsewhere that the risk of leakage is low. They should reflect this by using a figure much lower than 3%. Or if the guidelines want to use 3% (or an equivalent monetary value) as the figure they want to hold back as security, then this should not be related to an unrealistically high rate of leakage (or as referred to above, an ‘abatement reversal”!).

A final comment

In many jurisdictions there has been a tendency to see CCS, incorrectly, as a new and poorly known technology. Many aspects of CCS have been in operation within the oil and gas or chemical industry for decades. However, it is only in the last 20 years that it has been implemented as a mitigation option. Perhaps because of this lack of familiarity, there has been a tendency to more rigorously regulate it than would be the case for an oil and gas operation. If CCS is to attain its potential as an important mitigation option and be part of the ACCU process, it is important it is adequately and effectively regulated, but it is important that it is not over-regulated.

Professor Peter J Cook CBE FTSE

Centre for CCS Research

University of Melbourne

pjcook@unimelb.edu.au

0419490044

30/6/2021