German Advisory Council on the Environment

Avoiding a premature commitment: The need for a debate about the future before setting the course for CO2 storage

The Chair of the German Advisory Council on the Environment (SRU), Prof Martin Faulstich, comments on the proposed national bill on CO2 storage: "We caution against a premature commitment. The deployment of CCS at large scale can currently not be regulated in a satisfactory way. The bill would lead to a situation where the limited capacity for underground storage is reserved for CCS. But we need these geological formations also for other uses in the future, for example for the further development of renewable energy."

Date 2009.05.05

The Chair of the German Advisory Council on the Environment (SRU), Prof Martin Faulstich, comments on the proposed national bill on CO2 storage: "We caution against a premature commitment. The deployment of CCS at large scale can currently not be regulated in a satisfactory way. The bill would lead to a situation where the limited capacity for underground storage is reserved for CCS. But we need these geological formations also for other uses in the future, for example for the further development of renewable energy."

The SRU recommends a "research law" that only permits the testing of CCS technologies. Before any decision on the future of energy supply in Germany, there has to be time for a broad political debate.

On 1st April 2009, the German federal government has proposed a bill to regulate the capture, transport and permanent storage of carbon dioxide (carbon capture and storage, CCS). The SRU presents its Statement on the bill today at the occasion the first reading of the bill in the lower house of the German parliament (Bundestag). It is planned that the bill should be adopted in parliament before the end of the current election period. Given the importance of the law, the SRU considers this process to be inadequately hurried. Instead, the SRU recommends to only adopt a "research law" at this stage which permits the testing of CCS technology.

Many questions in relation to CCS are still unresolved. It is currently uncertain whether it is appropriate to store CO2 underground in Germany. The storage capacities for carbon dioxide are limited. There are already signs that there will be a competition of different uses of geological formations, but it is currently impossible to appropriately evaluate future use conflicts based on today's knowledge. The storage of CO2 would block large parts of underground rock layers indeterminately.

The ecological risks of the storage of CO2 are also largely un-researched. Furthermore, there are justified concerns whether CCS is a cost-efficient solution when compared to other mitigation options.

Given these uncertainties, a CCS law is - today and presumably also in the coming years - unable to provide an adequate regulatory framework for the commercial deployment of CCS technology. This concerns particularly the strategic and long-term balancing of conflicts between different possible uses of geological formations. In addition, problems with public acceptance are being underestimated.

The decision on the use of underground geological formations sets the course for the future development of the energy supply systems in Germany. Different uses such as CO2 storage, geothermal energy, compressed air energy storage and gas storage can mutually exclude each other. To avoid dangerous climate change with a temperature rise above two degrees Celsius, it can also become necessary to remove CO2 from the atmosphere. These "negative emissions" can only be achieved through a combination of energy supply from biomass with CCS. Storage capacity has to be reserved for this.

The "research law" as proposed by the SRU should therefore in the first instance only permit a limited number of demonstration projects for CO2 storage in saline aquifers with limited capacity. Accompanying research could produce insights about the behaviour of CO2 and the possibilities and risks of storage.

CCS is already supported at different levels with public funding. The proposed bill poses the risk that the operators of CCS facilities will in addition be indirectly subsidised. Access to the resource "storage capacity" will be granted free of charge, yet at the same time the liability of operators for damages and risks is limited in terms of time and scope. The possible transfer of responsibility already thirty years after the closure of a storage facility shifts the long-term costs to the concerned German Länder, particularly in the North and East of Germany. All this creates unjustified competitive advantages compared to competing climate mitigation options. The SRU holds the view that those causing the CO2 emissions should bear the full costs of storage.

The decision about the deployment of CCS should be made in a transparent political and societal process and after an assessment of the long-term ecological and economic consequences. Given the importance of the implications for the long-term development of energy supply in Germany, there has to be time for a thorough debate and consideration of trade-offs.

The SRU's Statement on "Capture, Transport and Storage of Carbon Dioxide - The Federal Government Bill in the Context of the Energy Debate" can be downloaded at www.umweltrat.de (in German only).

For further information, please contact Dr. Christian Hey on +49 (0)30-26 36 96-0

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