Guidance on Carbon Capture Readiness and Applications under Section 36 of the Electricity Act 1989: consultation response

We welcome the broad thrust of the DECC’s draft guidance document on carbon capture readiness at new power stations, and of the Secretary of State’s proposals for additional requirements for carbon capture and storage. We suggest several clarifications that could usefully be provided, either in the guidance document, or in subsidiary documents. Specifically, we suggest the establishment of a process of continual review of the realistic capacity of carbon dioxide storage reservoirs and the criteria for introducing new carbon storage reservoirs. We further suggest that to allow for the rapid rate of generation of new scientific information, the following are needed. First, an explicit, quantitative statement of the timescale that government considers sufficient for a reservoir to store carbon dioxide securely. Second, the inclusion in the guidance document of plans to accelerate the release into the public domain of seismic, borehole log, well injection test, and drilling record data generated by the private sector. Third, an explicit statement of government’s view on the extent to which bio-fuel power stations should be covered by regulations requiring carbon capture readiness. Finally, the production of a companion document giving similar guidance for the retro-fitting of carbon capture and storage systems at existing power stations. We also suggest that the guidance document could benefit from being updated in a number of ways, in the light of the Secretary of State’s additional proposals. Specifically, we suggest that, if different regulations are to apply to coal and natural gas, it would be useful for the guidance document to mention the two fuels separately. If some electricity generators are to be required to undertake carbon capture and storage from start-up of new facilities, the advice in the guidance document, that they do not need to commit themselves to using a particular storage reservoir at that stage, is no longer correct. The guidance document could usefully include measures to counter any disincentives to private-sector funding of carbon capture and storage research. We propose that the same review process that continually reassesses the realistic capacity of carbon dioxide storage reservoirs and the criteria for introducing new carbon storage reservoirs, may also need to keep under continual review the list of issues that applicants for power station construction permits can usefully address. Finally, we suggest that it would be helpful for applicants to provide details of their plans for monitoring of CO2 during and after its injection into a reservoir.