Carbon capture and storage regulatory test toolkit

Topic(s): Carbon capture use and storage (CCUS), Domestic policy, Policy law and regulation

Large point sources of carbon dioxide are responsible for a significant proportion of the world’s greenhouse gas emissions – with fossil fuel power stations and other large-scale industrial activities responsible for around half of the total. Carbon capture and storage (CCS) is expected to make a major contribution to reducing these emissions.

Few CCS projects currently exist in the world – and a lack of experience in regulatory agencies and commercial entities of how regulatory systems would apply to such projects increases risk – potentially leading to delays and increased costs for emerging CCS projects.

This toolkit has been produced by Scottish Carbon Capture and Storage (SCCS) researchers on behalf of the Scottish Government and sponsored by the Global CCS Institute. It guides users through a regulatory test exercise, which provides a low-cost, low-risk approach to testing regional and national legislation and regulatory systems for CCS projects, and gaining the benefits in follow-up activities.

The toolkit recommends use of a real or simulated CCS project as part of this exercise to assist government agencies and other stakeholders to work together to test and improve understanding of regulatory systems. It explains how a simulated or real CCS project can be taken through the regulatory process from inception to decommissioning – a test of the regulatory process at much lower cost, time and risk than would be incurred under a real project application.

Implementing this toolkit will assist users to:

• improve understanding of their local regulatory process
  • the permits and consents necessary for a CCS project
  • the information required
  • the likely timescales for planning and approval
  • the organisations that need to be involved
• identify gaps, contradictions, and potential revisions to regulatory systems
• ensure a viable regulatory process is in place for potential CCS projects
• help to speed up the management of projects to meet demanding timescales for funding; and
• raise awareness amongst the key stakeholders of their role in the regulatory process

The test exercise seeks to be realistic and to maximise learning opportunities, by involving the actual organisations and people that would be involved in effective handling of a CCS project. The exercise should be led by a government body with the intensive involvement of relevant regulatory agencies. Other stakeholders to involve will include commercial organisations, NGOs, and advisory bodies in the context of regional, national, or cross-jurisdictional project planning.

By working together towards a common vision, and ensuring strong participation and input by key stakeholders, this toolkit will assist users to run a successful regulatory test exercise, identify follow-up actions, and gain the benefits sought.

This exercise will inform government policy and developing CCS regulatory frameworks. Additionally, it should reduce the regulatory risk to CCS project developers – accelerating the consenting process and reducing the burden to all participants involved in that process – as well as ensuring an appropriate balance with other policy objectives.

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