Defining CCS Ready: An Approach to An International Definition

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Chapter 2: Capture Ready Plant Definition• New laws or technical developments do not make selected capture technologiesredundant or unviable;• Economic scenarios and considerations do not prevent implementation of identifiedtechnology, or a viable lower-cost methodology is identified whenever possible;• Selected capture technology is still relevant and valid given plant specifics, and no majormodifications have been made that would make it inapplicable;• Space and capacity needs around the plant for retrofitting and other infrastructuraldevelopments are still relevant based on technical developments;• Equipment, environmental, safety, and other approvals and permits for eventual CCShave not changed—and if they have changed, revised necessary approvals have beenidentified;• New approvals or permits for maintenance of status are obtained or renewed asnecessary;• Business relationships and agreements with suppliers and purchasers remain sound andare furthered if necessary; and• Public opposition remains absent or minimal, and ongoing public engagement preventsany barriers though public resistance.For example, the UK CCR Guidance requires all approved applicants to present periodicreports after the initial assessment to confirm that all the technical requirements are still inorder for CCS deployment of a plan/facility. If an applicant defaults on capture readinessafter being approved—for example, by not having enough land available for the CO 2 captureequipment—the applicant will be considered in breach of the consent and may be subject tolegal action. This directive also requires applicants to “retain an appropriate degree ofcontrol over the ownership and use of the additional space on or near the site set aside forthe carbon capture equipment” in order to prevent any barriers to retrofitting, and also topresent periodic compliance reports. 56Filing periodic reports (e.g., every year or once every two years) helps to ensure that theplant remains CCS Ready, particularly in situations where the plant changes ownership orthe organizational structure of the plant’s owner changes. Although the developer incurs acost to file periodic reports, reporting can help the developer assess whetherimplementation of its CCS Ready plan is still feasible. This type of periodic review will alsoreduce the risk that investments are wasted (e.g., ensuring that suppliers of commercial CO 2transport are still in business). Recordkeeping and reporting provide a good indication ofcapture readiness to the government and assure it of a plant’s ability to become CaptureReady if legislation makes CCS mandatory.2.5 RecommendationsGovernments can cooperate with industry to provide technical information for capturetechnologies, their applicability, performance and costs. This information could also include56 Page 30 of U.K. Department of Energy and Climate Change (U.K. DECC). (2009a). Carbon capture readiness (CCR): Aguidance note for Section 36 Electricity Act 1989 consent applications (Publication no. URN 09D/810). London, UK: Author.23 February 2010 34
Chapter 2: Capture Ready Plant Definitionsupplier lists, bibliographies, case studies, and engineering software. As capture technologiesevolve over time, this information could be updated and revised.Another point of cooperation for government and industry could be to fund capture R&Dand demonstration plants to improve capture technologies and to provide more reliableperformance and cost data. This funding be may necessary to help build knowledge andprovide accessible data to use in assessing relevant technologies to be Capture Ready whilethe gap between the cost of CCS and the price of carbon is closing. Government andindustry funding and resources may also contribute to regional geologic prospectivity studiesand planning efforts for CO 2 pipeline networks to aid project developers in plant sitingdecisions. (See Chapters 3 and 4 for more information on prospectivity studies and CO 2pipeline networks.)In addition to working with industry on the above points, governments can review whatenvironmental and safety laws might be applicable to capture retrofits, and provideguidelines to project developers. The benefits in doing this would include:• Reduced delays due to permitting and compliance;• Potentially reduced burden for project developers;• Increased confidence about the safety of plants that are retrofitted with capturetechnologies; and• Assurance of limited environmental impacts.Because there is limited industry experience with capturing CO 2 , training and capacitybuilding programs offered by schools, professional societies, and private companies can trainengineers to do Capture Ready and CCS Ready studies. Such programs would acceleratethe spread of knowledge and information about capture technologies and being CaptureReady. Governments can also provide for training of regulators on the technical aspects ofCCS Ready filings. This would improve the quality of the oversight and expedite the processof reviewing applications and reports when CCS Ready regulations are in place.23 February 2010 35
Page 1: Defining CCS Ready: AnApproach to A
Page 4 and 5: PrefacePrefaceThe Global CCS Instit
Page 6 and 7: Acknowledgements and CitationsThe c
Page 8: Executive SummaryThe components spe
Page 12 and 13: Executive SummaryExhibit ES-3: Illu
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Appendix E: Referencesfrom http://w
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Defining CCS Ready: An Approach to An International Definition

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