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SPECIAL
REPORT 2006 Chapter 5
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5 CO2-storage in the ocean and under the sea floorGreat and growing hopes have been pinned of late upon the sequestration of CO2 as a means of climate mitigation (IEA, 2004). IPCC discussed this theme in depth in a recent Special Report (IPCC, 2005). Estimates expect carbon dioxide capture and storage (CCS) to be market-ready by 2015 (IEA, 2004). Within 50 years, 20–40 per cent of the CO2 emissions arising from the combustion of fossil fuels could be separated, captured and stored (IPCC, 2005), provided that research and development intensify significantly (IEA, 2004). Sequestration technology has direct relevance to the present report, as it also includes the storage of CO2 in the ocean and under the sea floor (Box 5.3-1).
5.1 CO2
sequestration
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Box
5.3-1 ![]() Figure
5.3-1 |
5.3.2 Risks and sustainability of CO2 storage in the seabed
Various
scenarios are imaginable for the escape of CO2 from formations under
the sea floor. If the CO2 emerges at a depth where it occurs as hydrate,
then the least damage can be expected. But when the CO2 dissolves in
water it contributes to acidification of the sea. The conceivable harmful
consequences of leaks for marine organisms have already been described
in Section 5.2.2. In cases of very large-volume leaks, the CO2 could
also reach the surface, which would, for one, contribute to the enrichment
of CO2 in the atmosphere and, for another, present a health risk in
the immediate surroundings. But as long as the storage site is not directly
on the coast near human settlements, the human health risk is significantly
lower than for storage on land. Even where people are in the vicinity,
the probability of dangerously high CO2 concentrations in the ocean
environment is extremely low because, in contrast to the situation on
land, CO2 lakes cannot form. As a rule, such CO2 lakes can only form
and persist in depressions on land that have no or poor drainage.
As
discussed in Section 5.1.2, a retention time for CO2 of at least 10,000
years is required for long-term sustainability.
5.3.3 Regulating sub-seabed geological storage
Considering
that global CO2 emissions are rising, the option of storing CO2 in geological
formations deep below the sea floor should not be dismissed completely.
However, such sub-seabed geological storage is not altogether unproblematic
(Section 5.3.2). For one thing, a release of CO2 to the atmosphere cannot
be excluded entirely. This can be caused by technical faults or by accidents
arising in the transport, injection and storage process. It may also
be due to the selection of inappropriate geological formations. Current
knowledge indicates that, under certain geological and technological
preconditions, leakage rates may be acceptable (<0.01 per cent per
year). There is a need for substantial further research, however, to
be able to verify this with sufficient certainty. Issues in particular
need of clarification include the criteria that geological formations
must meet, and how any escape of the gas to seawater could be monitored
and quantified.
Moreover,
an all too strong political and economic focus on the sequestration
option might cause neglect of far superior climate mitigation strategies,
such as improving energy efficiency and switching to renewable energies.
To attain the goal of sustainable energy systems, it is these superior
options that particularly require political support, innovation and
the employment of scarce resources (WBGU, 2004). A high renewable energy
potential is available in the ocean and above the sea surface (Box 5.3-2).
WBGU therefore views sub-seabed storage of CO2 as being, at most, a
transitional option complementing other options (WBGU, 2004). Its deployment
should be limited and regulated (Section 5.3.3.4).
Box
5.3-2
Utilization
of predominantly coastal marine areas that are currently regarded
as technologically accessible would offer a global total potential
of approximately 9000 TWh per year from wind, waves, currents
and osmosis, with wind power offering by far the biggest potential
and quickest implementation. However, the issue of concurrent
utilization of coastal marine areas through systems for power
generation from wind and waves would have to be examined in more
detail, because certain wave energy systems may be difficult to
combine with wind farms. In addition, high-density installation
of large numbers of systems would lead to significant habitat
changes, e.g. through noise emissions, increased shipping traffic
and other effects such as underwater cables, so that the overall
effect caused by concurrent utilization of several technologies
have to be regarded as unsustainable. |
5.3.3.1 Provisions
under the international law of the sea
The
1972 London Convention and its 1996 London Protocol permit the storage
of CO2 in sub-seabed geological formations if the sequestered CO2 originates
in the course of processing the mineral resources of the seabed (Section
5.2.3; the same applies to placement of CO2 in seawater). This is the
case, for example, with the Sleipner project (Box 5.3-1).
In
contrast, it has not yet been clarified unequivocally whether the 1972
London Convention or, in future, the 1996 London Protocol permits sub-seabed
storage, for instance in saline aquifers, of CO2 that was separated
on land (IEA, 2005). Article III, para. 3, of the London Convention
defines ‘sea’ as ‘all marine waters’. There
is some controversy as to whether this definition means that the seabed
and the subsoil thereof fall within the scope of the convention. In
response to a survey conducted by IMO, Germany argued in favour of construing
the term ‘all marine waters’ to include the seabed and the
subsoil thereof, as this would be in line with the history and purpose
of the convention. The 1996 Protocol defines in Art. 1, para. 7, the
term ‘sea’ more precisely, namely as ‘all marine waters
other than the internal waters of States, as well as the seabed and
the subsoil thereof; it does not include sub-seabed repositories accessed
only from land’. This definition, however, has also given rise
to controversy over the depth to which the subsoil reaches. In the above-mentioned
IMO survey, Germany argued in favour of construing the term as comprehensively
as possible, too.
When
construing the treaty wording, however, it needs to be taken into account
that the issue of CO2 sequestration, including CO2 storage in the ocean
or under the sea floor, was not on the agenda when the 1972 London Convention
was negotiated, nor when its 1996 Protocol was elaborated. It is therefore
not possible to draw conclusions from the wording of the treaty about
the will of the participating states with respect to how to handle CO2.
The parties to the London Convention are now addressing this issue intensively
(IMO, 2004), for instance at the 27th Consultative Meeting of the parties
held in October 2005. In view of the numerous gaps in knowledge and
the unresolved issue of whether placement of CO2 in the seabed should
be covered by the London Convention and/or the London Protocol, that
meeting agreed to debate the issue in greater depth at the 28th Meeting.
If the parties resolve to permit the placement in the seabed of CO2
sequestered from separation processes on land, Annex 1 to the London
Protocol may need to be amended; this would also be expedient in order
to provide clarification. The present state of knowledge thus indicates
that it would be necessary to take account of Art. 31, para. 1, of the
Vienna Convention on the Law of Treaties, according to which a treaty
shall be interpreted in good faith in accordance with the ordinary meaning
to be given to the terms of the treaty in their context and in the light
of its object and purpose.
5.3.3.2 UNFCCC
and Kyoto Protocol
The production of the national emissions inventories in accordance with
the United Nations Framework Convention on Climate Change and the Kyoto
Protocol is based on the IPCC Guidelines for National Greenhouse Gas
Inventories. At present, these Guidelines do not deal explicitly with
the issue of sequestration. However, the IPCC Special Report on CSS
(IPCC, 2005) provides for the option of applying the current framework
provisions, principles and methods to sequestration activities. The
Norwegian approach demonstrates how these general provisions could be
applied to sequestration in practice: Norway reports the quantities
of CO2 sequestered at the offshore Sleipner facility (Box 5.3-1) and
consistently factors any emissions leaked during the injection process
into its national emissions (IPCC, 2005). The sequestered CO2 is not
added to the emissions inventory but is treated, in effect, as non-emitted.
The Guidelines are due to be revised in 2006. It is likely that the
current debate about standards for inventorizing sequestered CO2 will
flow into this process and relevant provisions will be adopted in the
near future. Apart from the practical question of how to inventorize
sequestered CO2 in the national reports, a further issue to be clarified
is whether, and how, sequestration projects should be integrated into
the flexible mechanisms – emissions trading, the Clean Development
Mechanism (CDM) and Joint Implementation (JI) (Bode and Jung, 2005;
IPCC, 2005). The inclusion of sequestered CO2 in the flexible mechanisms
raises a variety of issues (Bode and Jung, 2005) which shall not be
discussed in detail here. Matters become especially complicated in relation
to the CDM if, for example, an Annex B country ‘imports’
CO2 from developing countries which has been emitted on land and stores
it in sub-seabed reservoirs which are already in use. Strictly speaking,
such cases do not meet the CDM’s additionality criterion, which
means that in essence, no CDM emission credits can be issued. Nor does
it necessarily promote technology transfer to developing countries,
which is an explicit objective of the CDM. Similarly complex issues
arise in relation to emissions trading and JI.
5.3.3.3 Instruments
to regulate CO2 storage in the seabed
WBGU considers that in view of the leakage risk, regulations are required
for activities aimed at the storage of CO2 in the seabed. Firstly, more
rigorous minimum standards are needed, with mandatory compliance in
order to minimize risks. Secondly, the use of quantity restrictions
or liability-based instruments as a response to the risk of leakage
would help ensure that lower-risk sustainable emissions avoidance options
(e.g. increasing energy efficiency and the use of renewables) are not
neglected.
Geological and technological minimum standards
The rate of CO2 leakage over the long term must be very low and must
also be readily monitored and verified. Firstly, the retention period
for stored CO2 at the chosen site must be very long – at least
10,000 years. Our current state of knowledge indicates that it is possible
to meet this criterion, at least in deeper aquifers (Ploetz, 2003; IPCC,
2005). Secondly, the CO2 storage sites must be easily monitored, i.e.
it must be possible to record both the leaked and the sequestered amount
of CO2 on a reliable basis. At present, however, adequate technologies
to measure CO2 leaks are not available.
Indirect quantity restrictions
The leakage risk in particular indicates that sequestered CO2 cannot
be viewed as fully ‘avoided’ CO2 emissions in international
climate agreements. In the setting and implementation of emissions reductions
targets, storage should therefore only be eligible in part as avoided
emissions. Various approaches can be considered in this context, both
at international level (UNFCCC etc.) or solely for European climate
policy at first. In the following, WBGU outlines various instruments
which aim to restrict by indirect means the proportion of CO2 storage.
It offers an overview of possible approaches which could play an important
role in relation to sub-seabed storage as well as sequestration in general.
No conclusive evaluation of the instruments can be undertaken here,
firstly because no policy decision has been taken on appropriate limitation
targets, and secondly because there is still a considerable need for
research in many areas (Bode and Jung, 2005; IPCC, 2005).
• Adding leakage to total emissions: Sequestered CO2 would only be partly recognized as avoided emissions. The percentage of CO2 which would be considered as having been emitted ‘in practice’ and which would have to be designated as such in the national reports would be determined at political level. However, this percentage should not merely reflect but should significantly exceed the probable leakage, in order to take appropriate account of the impacts of leakage on the marine environment.
• Deductions in the context of the flexible mechanisms: Emission rights arising from sequestration could only be traded with substantial deductions. This would mean that a certificate based on one tonne of sequestered CO2 would give rise to an emissions entitlement of less than one tonne of CO2. The same principle would apply to CDM credits from sequestration activities in developing countries. CDM credits could also be granted for the storage of ‘imported’ CO2 from developing countries, especially as this type of cooperative project would reduce global CO2 emissions into the atmosphere – albeit without satisfying the current CDM criteria (Section 5.3.3.2), which is why a higher deduction would be justified. The decision which deduction rate would be reasonable in individual cases would largely depend on the climate policy assessment of the leakage risk and the impacts on marine ecology. There is a considerable need for further research in this area.
• ‘Traditional Action’: Countries would agree to meet a specific proportion of their emissions reduction commitments without recourse to sub-seabed or any other form of CO2 sequestration. This approach would be analogous to the concept of ‘domestic action’.
Liability
mechanisms
When applying the above-mentioned instruments to limit CO2 sequestration,
countries implicitly make their own assessment of the scale of the leakage
risk and the likely damage that leakage would cause. By contrast, liability
mechanisms are an alternative or supplementary approach relying on the
market mechanism. An effective liability regime for sequestered CO2
means establishing a transparent and credible system to determine who
is responsible for discharged CO2 and who is therefore liable to pay
compensation: either through ex post adding to overall emissions, ex
post acquisition of emission rights, or penalty payments which are used
for climate and ocean protection. As long as the operator still exists,
it may be comparatively easy to enforce liability. However, the long
time scale of climate protection means that the issue of liability must
be clarified and safeguarded over the long term. The issues surrounding
the cleanup of contaminated sites at national level have shown that
it is often the state which ultimately shoulders the financial burden.
This applies similarly to cases involving private operators, especially
if a defunct polluting company has no legal successor or the successor
lacks the resources to pay damages.
‘Carbon
sequestration bonds’ have emerged as a market-based solution in
this debate (Edenhofer et al., 2005). Here, a firm which intends to
sequestrate or store CO2 has to deposit a sum of money with a designated
authority, equivalent to the amount of sequestered CO2 multiplied by
the CO2 certificate price (Edenhofer, 2003). The company would obtain
interest for the bond, equivalent to the normal market rate of interest
on long-term bonds. The authority – this could be the Climate
Central Bank already proposed by WBGU (WBGU, 2003) – devalues
the bond according to the fraction of leaked CO2. The balance could
be used to pay for emissions prevention measures, such as the promotion
of renewable energies, or even the purchase and withdrawal of emissions
rights. In the case of leaks from marine disposal sites in particular,
the funding of marine conservation measures from these resources would
be justified. As the value of the bond falls, the interest paid also
decreases. No fixed price for the devaluation of the bond is set in
advance; instead, the devaluation increases over time in line with the
actual amount of leaked CO2. The
idea is that the company tries to sell the right to the interest accumulating
on the deposit as a ‘bond’ on the financial markets. This
can only be achieved if potential purchasers are offered a rebate on
the value of the bond which is high enough to offset the risk of devaluation
by the authority. During trading, the market value would reflect not
only the devaluation of the deposited amount but also the capital market’s
assessment of the likely leakage risk in future. The concept of ‘carbon
sequestration bonds’ is a very interesting and innovative approach
to risk assessment and liability, and merits further research.
5.4 Recommendations
for action: Regulating CO2 storage
5.4.1 Prohibiting CO2 injection into the ocean
WBGU firmly
rejects the storage of CO2 in the ocean, i.e. in the water column and
on the sea floor. The ocean is in permanent exchange with the atmosphere,
with the result that this option does not mitigate the long-term consequences
of CO2 emissions for future generations. It is therefore not a sustainable
option. The risk that ecosystems will suffer appreciably under an elevated
CO2 concentration in the water is a further argument against the disposal
of this greenhouse gas in seawater (Section 5.2.2; IPCC, 2005; Pörtner,
2005). Moreover, the international community will scarcely be able to
control CO2 lakes on the sea floor, and the release of this CO2 to the
atmosphere over the long term cannot be excluded. WBGU therefore recommends
a full and comprehensive ban on CO2 injection into the ocean, regardless
of the territorial status of waters.
The
1972 London Convention on the Prevention of Marine Pollution by Dumping
of Wastes and Other Matter, in conjunction with its London Protocol
(Section 5.3.3.1; the protocol has not yet entered into force) prohibit
in principle the placement of CO2 in the ocean. Both agreements, however,
contain an important exception that needs to be firmly rejected in light
of the above: both permit in their current wording the injection of
CO2 that arises from the production of mineral oil or natural gas, as
long as the associated processing operations take place at sea. The
prohibition on the injection of CO2 arising from processing operations
on land that is already implicitly in place should therefore be extended
explicitly to such CO2 that is separated in the course of seabed resource
exploration and processing operations at sea. Such a prohibition could
possibly be complemented by a corresponding arrangement under the Framework
Convention on Climate Change; this could also serve to cover those states
that do not ratify the London Protocol.
5.4.2 Limiting CO2 storage in the seabed
The
disposal of CO2 in the seabed poses substantially less risk than its
injection into the water column or on the sea floor. For that reason,
and in view of the almost unavoidable rise in energy consumption especially
in developing and newly industrializing countries, WBGU considers it
acceptable for a transitional period to use injection into the geological
sub-seabed as an option complementing more sustainable emissions reduction
strategies.
WBGU accordingly recommends clarifying the issue of conformity of sub-seabed
geological storage with the London Convention or London Protocol in
the relevant bodies of the convention and protocol in such a way that
CO2 sequestration in sub-seabed geological formations is permissible
regardless of the location of processing operations. If it should not
prove possible to generate consensus on construing these legal provisions
to mean that sub-seabed CO2 disposal is permissible, then modifying
or supplementing the London Protocol should be considered. WBGU also
argues that such activities should only be permitted from the outset
for a limited period, such as several decades.
Before
the international law of the sea can be construed or supplemented in
such a way, universal minimum technological standards would first need
to be defined and complied with. These need to be developed specifically
for marine transport, for CO2 injection and storage, and for the characteristics
and monitoring of geological disposal sites. As long as the problems
currently associated with the measurement of CO2 releases persist, WBGU
advises applying exceedingly strict requirements upon geological disposal
sites. WBGU takes the view that in this respect, too, the London Convention
or London Protocol provides an appropriate framework for setting standards,
underpinned by more comprehensive rules governing sequestration activities
under the Framework Convention on Climate Change.
The
IPCC Guidelines play an important role in this context. These guidelines
govern the preparation of national emissions inventories. Their review
is currently pending. WBGU shares the view of the IPCC Special Report
(2005) that the present regulatory structure, including the flexible
mechanisms, can in principle also be applied to sequestered CO2. WBGU
does not consider this expedient in all situations, but does regard
it as purposeful in the case of CO2 disposal in verified sub-seabed
geological formations. WBGU recommends, however, that when sequestered
CO2 is integrated into inventories and into the flexible Kyoto mechanisms
the risk of leakage be taken into account. This can be done through,
for instance, deductions in emissions trading or from CDM credits, or
through liability rules (Section 5.3.3.4).
Risks
posed by the use of geological formations for CO2 storage
There is a need for further research on the permanence of marine CO2
storage in deep geological formations. The associated monitoring procedures
also need further development. Furthermore, research should be conducted
on the potential impacts of CO2 leakage upon marine ecosystems and organisms.
The long-term effects of storage upon atmospheric CO2 concentrations
should also be studied. An issue of particular importance in this respect
is which specifications a storage site needs to meet in order to ensure
stable atmospheric CO2 concentrations at a low level over the long term.
This will require an improved understanding of the carbon cycle on a
millennial time scale.
Legal setting
The instruments of international law governing the permissibility of
CO2 storage in deep sub-seabed geological formations need to be studied
comprehensively. Not only the London Convention with its 1996 Protocol
should be taken into account. It is equally important to analyse links
to other regimes in international law – notably the Framework
Convention on Climate Change with its Kyoto Protocol, and the United
Nations Convention on the Law of the Sea (UNCLOS).
Regulating CO2 storage in the seabed
The manner in which geological storage of CO2 in the seabed (and, it
is worth noting, on land) may be eligible as a climate mitigation measure
under the international climate protection regime needs to be clarified
unequivocally in the near future. There is a need for research in the
social sciences and economics on the issues surrounding the flexible
mechanisms. Identifying which instruments for the limitation of sequestration
are effective, efficient and enforceable in international law and policy
is an issue of particular importance.
Marine renewables
Great uncertainties still attach in some instances to the renewable
energy potential of marine sources such as offshore wind, wave energy,
salt gradient energy or ocean thermal energy conversion. There is a
considerable need for further research in order to identify the sustainable
global potential. This concerns both the methods and the impacts that
need to be taken into account.
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