Sweeping Europe’s emissions under the rug

Enthusiasm for CCS has waned across much of Europe as the technology has failed to advance and renewables have convincingly demonstrated their ability to cost-effectively decarbonize the energy system. But don’t tell that to Norway.

The country remains firmly committed to proving CCS works. Norway’s devotion to CCS is readily explained by the country’s grand vision for the technology, which essentially boils down to Norway serving as the continent’s carbon dioxide (CO₂) emission repository and reaping significant financial benefits as a result.

Norway’s most recent attempt to sell CCS to Europe is dubbed the Northern Lights initiative. Led by Equinor (formerly Statoil), Shell, and Total – with financial and political support from the Norwegian government – Northern Lights initially aims to inject carbon dioxide captured from two industrial facilities located in the south of Norway – a cement factory and waste-to-energy plant – under the North Sea. If successful, the Northern Lights initiative could be expanded to accept CO₂ emissions from industrial sources across Europe. A final investment decision on the project is expected in 2020/2021 with operations potentially commencing in 2024.

Northern Lights is Norway’s second major effort to demonstrate the viability of CCS in support of its vision. The country’s first flagship CCS project was Mongstad, a full-scale capture project that would have collected CO₂ from a gas-fired combined-heat-and power plant and oil refinery. The hype surrounding the Mongstad project was substantial – when announced in 2007 it was labelled by then-Prime Minister Jens Stoltenberg as Norway’s “moon landing”. But Mongstad was a bust. After delays and significant cost-overruns, Norway pulled the plug on the project in 2013.

As with Mongstad, Norway is once again peddling an overly optimistic assessment of what the project could deliver. Even at this early stage of development, Northern Lights faces significant economic and legal challenges. Northern Lights’ business case, for example, entails collecting fees for transport and storage services to cover the project’s costs. However, Norway doesn’t generate enough CO₂ to make the project economic. The only way for Northern Lights to be economically self-sufficient is to import large volumes of CO₂ from facilities located in other countries.

The only problem with this plan is that transporting CO₂ from one country to another for storage is not permitted under international law. More specifically, Article 6 of the London Protocol  prohibits contracting parties from exporting CO₂ for sub-seabed storage. Article 6 was amended in 2009 – under extreme pressure from Norway – to allow such activities but the amendment has yet to be ratified by a necessary two-thirds of contracting parties. So far, only Norway, the United Kingdom, and the Netherlands have ratified the amendment. Another 28 countries will need to do so before it can take effect. This is highly unlikely in the short to medium term, which means Northern Lights will not have access to Europe’s CO₂ emissions for the foreseeable future.

Northern Lights’ supporters often make bold claims about the “practically unlimited” storage potential underneath the Norwegian North Sea that could store “all European emissions for hundreds of years”.  Some have even claimed the North Sea can store 1,000 years of emissions.  These claims are proffered as proven facts but they are really only best guesses based on top-down assessments that tend to overestimate storage capacity because they do not account for actual pore space ability and varying characteristics across storage formations.

When such factors are evaluated, top-down capacity estimates are frequently revised drastically downwards. For example, Norway and CCS proponents were previously fond of claiming that the Utsira formation where the Sleipner CO₂ storage project operates had “practically unlimited” storage potential and could handle CO₂ emissions from “all power stations in Europe for the next 600 years”.  However, after an in-depth study, the Norwegian Petroleum Directorate downgraded the storage capacity estimate for the Utsira formation from “able to store all European emissions for hundreds of years” to “not very suitable”.

As with most CCS projects, Northern Lights’ ability to safely and permanently store CO₂ is largely presumed. Concerns about safe storage are downplayed, with CCS proponents pointing to natural analogues as evidence that humans can permanently store CO₂ underground. Norway and others also tout the Sleipner project as proof of concept. Never mind that Sleipner, as well as other non-CO₂ storage projects in the Utsira formation, have experienced issues that call that claim into question.  

A more sober assessment raises significant questions about the ability to ensure safe, permanent storage, and whether our regulatory frameworks can appropriately manage and allocate risk throughout every phase of a CO₂ storage project. The answer to many of these questions is we simply do not know. The world has limited experience with CO₂ storage (particularly sub-seabed) and we remain in the learning phase; our regulatory frameworks are largely untested; and monitoring technologies cannot track CO₂ or detect leakages to the necessary resolution.

One can also never eliminate the potential for human error in applying and enforcing regulatory frameworks and guaranteeing responsible management and oversight of CO₂ storage activities by private sector actors. Failures experienced at existing CO₂ storage projects, like Sleipner, demonstrate the potential for something to go wrong.

The European Union (EU) established “a legal framework for the environmentally safe geological storage” of CO₂ in 2009.  Article 2 defines “environmentally safe” as “permanent containment of CO₂ in such a way as to prevent and, where this is not possible, eliminate as far as possible negative effects and any risk to the environment and human health”. In short, the EU’s CCS Directive creates a risk-based approach for CO₂ storage to prevent and eliminate environmental and public health risks as much as possible. This is a laudable goal but will be difficult to achieve in practice.

All member states have transposed the CCS Directive into national law. However, as of 2017, only 16 members states have done so in a manner that fully conforms with the Directive.  To date, the Directive’s permitting framework for CO₂ storage has been infrequently used with a handful of permit applications submitted to the Commission for review and only two storage permits issued.  

It’s far too early to tell whether the EU’s regulatory framework for storage will work in practice over the long term. However, several ambiguities, vague language, potentially conflicting objectives in the Directive in combination with a lack of experience and technological limitations will complicate efforts to effectively implement the framework. For example:

1. Leakage: A consistent and appropriate definition for leakage is essential because it relates directly to other measures in the Directive, such as corrective measures, potential liabilities (including surrendering ETS allowances), and transferring storage site ownership. The Directive falls short on this front. Leakage is defined as “any release of CO₂ from the storage complex”. The term “storage complex” refers to “the storage site and surrounding geological domain which can have an effect on overall storage integrity and security”. These ambiguous definitions create several uncertainties, making it difficult to determine what actually constitutes leakage.
2. Quantifying the risk of leakage. Applying quantitative approaches to assess the risk of leakage is difficult due to wide ranges in key parameters, multiple methodological approaches, significant technical uncertainties, and the long timescales involved. Limited case studies and published literature exist to guide regulators and project operators in this exercise and assist with permitting decisions.
3. Significant. “Significant” appears in several important aspects of the Directive. For example, in Article 4, a storage site should only be permitted if “there is no significant risk of leakage, and if no significant environmental or health risks exist”. This language seems to be in conflict with the objective in Article 1 of preventing and eliminating any risk to the environment and human health. What’s more, “significant” is tied to one of the triggers for corrective measures and could be underprotective depending on how that language is applied to individual projects.
4. Corrective measures. The need for corrective measures requires the detection of “significant irregularities” or leakages through monitoring approaches capable of detecting issues wherever they may occur. Previous experience with Sleipner and non-CO₂ storage projects in the North Sea demonstrate that modeling and monitoring regimes can fail to accurately predict CO₂ movement, prevent overpressurisation, detect fractures, and identify leakages. What’s more, corrective measures, such as relief wells, can take several months to deploy in the event of a catastrophic leakage.
5. Financial security and funding mechanism. Articles 19 and 20 rightly include provisions to ensure storage operations provide funding to maintain storage sites through their operation and post-closure phases. How much funding will be needed, however, is unknown. The risk of inadequate funding is significant with the industry lobbying for lower funding requirements.

Northern Lights is at least several years away from determining if the proposed storage location is practical, safe, and likely to be permitted.  It remains to be seen if the project will ever get off the ground. But contrary to what Norway would have us believe, there’s no such thing as a safe bet when it comes to CO₂ storage. Measures can be taken to reduce overall risk, but the risk of leakage can never be eliminated.

Maintaining a healthy skepticism about the potential to permanently store gigatons of CO₂ is the prudent approach rather than giving into the unfounded optimism that CCS will solve Europe’s CO₂ problem. Even better is implementing solutions that avoid the need for CCS in the first place and ignoring the hype. We’ve been here before with CCS in Europe and it got us nowhere. Let’s not make the same mistake twice.

Emily Rochon

She is a Brussels-based Lawyer (US qualified) and Energy Consultant and lead author of Greenpeace International’s 2008 report on CCS – False Hope: Why carbon capture and storage won’t save the climate?