Submission to the United Nations Framework Convention on Climate Change (UNFCCC) - Modalities and procedures for carbon dioxide capture and storage in geological formations as Clean Development Mechanism (CDM) project activities

In September 2011, the Global CCS Institute attended the UNFCCC's technical workshop on CCS in the CDM in Abu Dhabi. The workshop helped facilitate the UNFCCC Secretariat's drafting of the draft modalities and procedures (M&Ps) for CCS in the CDM that were ultimately considered and adopted by the CMP in December 2011.

While transboundary issues were comprehensively covered at this meeting, there was no substantive discussion on or any specific need identified for a global reserve provision to address the issue of non-permanence. Similarly, the consolidated views of Parties and accredited observers as expressed in the CMP 6 call for submissions in February last year (FCCC/SBSTA/2011/MISC.10) has no reference to any need of a global reserve to accommodate what should be, if due processes on site selection are observed and upheld, a relatively low risk of a non-permanence event occurring.

In summary, the Institute's position is that: 
- transboundary CCS projects should be considered eligible under the CDM and that the M&Ps be developed as soon as possible to provide for such projects; and 
- the financial provisions contained within the existing M&Ps are adequate and the need for a global reserve is unnecessary.