IRGC - International Risk Governance Council

Policy recommendations

Following discussion at an expert workshop in March 2007 and a conference hosted by the Swiss Re Cenrtre for Global Dialogue in November the same year, the project concentrated on developing recommendations for how to address the main challenges that CCS presents. These have been described in a Policy Brief published in February 2008 and are summarised below:

1. CCS regulation must:

Establish a framework encouraging responsible operation and investment; -*Balance stability and predictability with flexibility and adaptability to new scientific information;
Be based on solid technical findings; and
Provide ease of implementation for both regulators and industry.

2. A diverse portfolio of full-scale CCS demonstration projects should be brought online as rapidly as possible, with broad government support through appropriate incentives and regulatiory frameworks. For maximum learning value these projects should:

Provide scientific and technical answers to key regulatory and legal concerns;
Include a diverse portfolio of project types;
Take place in a variety of geological settings;
Operate transparently, with data fully available publicly;
Employ harmonised monitoring, measurement and verification standards to enable cross-comparison of technologies; and
Be subject to comprehensive and comparative assessment, with assessments made available to the public.

3. Site selection requirements for early sites must be especially rigorous. Furthermore, licensing of these early storage sites should include demonstration of long-term predictable containment.

4. An evolutionary approach to developing CCS regulations should be adopted. Early CCS projects should be regulated under modifications to existing regulations. Results from early projects can then be used to create generalised CCS regulations to efficiently manage commercial deployment.

5. With the objective of building a regulatory framework for CCS, the following activities should be undertaken now:

Public engagement and education;
Development of generalised site selection guidelines;
Development of generalised measurement and verification protocols;
Development of greenhouse gas accounting protocols for CCS;
Improvement and standardisation of modelling techniques;
Development of necessary modifications to existing regulations;
Negotiation of specialised arrangements for long-term liabilities at a limited number of early sites; and
Creation of financial incentives to get full-scale demonstration sites up and running.

6. The following activities, vital for creating a regulatory framework conducive to widespread commercial CCS deployment, cannot be completed until comprehensive, integrated technical results from early deployment are available:

Establishment of links to carbon markets;
Resolution of climate liability issues;
Passage of legislation to structure long-term responsibility and liability for CCS sites, including mechanisms to fund long-term stewardship; and
Establishment of an adaptive regulatory framework.

7. Full transparency and careful evaluation of results and experience from early full-scale CCS projects is crucial. An independent review group should be convened to provide a comprehensive, integrated summary of results from early CCS projects.

8. Political and economic conditions must be such that financial backers can have confidence that investment decisions made now will earn a satisfactory economic rent, that a predictable regulatory framework will apply, and that liability issues will be resolved.

9. Effective risk communication by both regulators and industry is vital for public acceptance of CCS. Also, the public should be immediately and transparently informed of any event that indicates a problem with CCS, in order not to damage its reputation in the long term.

10. Economic and political barriers will also need to be addressed to catalyse CCS deployment . In fact, regulations governing geological storage site performance, climate liabilities, and long-term stewardship cannot be finalised in the absence of an over-arching climate regime.