Non-paper on Carbon Capture and Storage (CCS)
By the Netherlands, Norway, Denmark and Sweden
CCS is one of many important technologies for achieving the EU’s goal of climate-neutrality
by
2050 at the latest. This paper highlights three policy recommendations targeted towards the
deployment of CCS across the EU:
Establish robust, transparent and consistent monitoring and reporting guidelines for
transportation of CO
2
by waterborne vessels, road vehicles and rail.
Further integrate CO
2
removals from negative emission technologies in EU climate policy
and analyse policy options for incentivising their development and deployment.
Consider broadening the Trans-European Networks
–
Energy (TEN-E) Regulation to
include geological storage and associated infrastructure as part of cross-border CO
2
networks. The TEN-E regulation should be compatible with the goals of the Paris
Agreement.
Through the proposal for a European Climate Law, on the 4
th
of March 2020, the European
Commission set forth a plan to enshrine the EU objective of climate-neutrality by 2050 in European
legislation. In the explanation of the proposal, the Commission states that whereas greenhouse gas
emissions should be avoided at source as a priority,
removals of greenhouse gases will be
needed
to compensate for the remaining emissions from sectors where decarbonisation is the most
challenging. It includes the notion that
‘carbon
removal technologies, such as
carbon capture and
storage (CCS)
and
carbon capture and utilisation (CCU)
should be made cost-effective and
deployed’.
We underscore the important role of CCS in achieving
the EU’s goal of climate-neutrality
by 2050 at
the latest.
CCS can realise substantial CO
2
emission reductions from some energy-intensive
industries,
where no other viable options exist. In this light, CCS could be a focus point of the
upcoming industrial alliance on low-carbon industries. Technologies like bio-energy CCS (BECCS)
and direct air capture of CO
2
(DACCS) have an important role in
providing negative emissions
for residual emissions that may remain in the economy and to achieve negative emissions thereafter.
Where CCU applications result in
permanent and verifiable emission reductions,
they too can
contribute to climate change mitigation.
In this non-paper, we highlight three policy matters which have been identified as warranting
increased attention by the Commission. Addressing these matters could have a positive influence on
the speed at which CCS projects develop, facilitating carbon removal technologies to contribute to
achieving the EU’s climate goals. Taking further action on implementing such policy measures could
be achieved under the revision of EU climate-related policy instruments under the European Green
Deal.
1) Establish robust, transparent and consistent monitoring and reporting guidelines
We welcome the clarification from the Commission confirming that the existing provisions of the ETS
Directive and Monitoring and Reporting Regulation (MRR) are compatible with different forms of CO
2
transport.
We would like to reaffirm the importance in maintaining flexibility in the forms of transportation to
be utilised as part of national and cross-border CO
2
transport infrastructure, and would welcome
collaboration with the Commission and other interested Member States in the development of
robust, transparent and consistent monitoring and reporting guidelines
for these alternative
forms of transport.
It is recognised that despite the interpretation of the MRR, there remains scope for affirming the
role of alternative forms of CO
2
transport in the EU’s legislative framework.
Hereby the transport of