This hearing document was sent to the Norwegian Pollution Control Authority 7 January 2009

1. Introduction
Bellona has briefly reviewed the documents sent per e-mail for an informal hearing,
consisting of a collection of legal texts and assessments related to the development of
Monitoring and Reporting Guidelines for CO2 capture and storage (CCS). Due to time
constraint, Bellona has mainly focused its attention on the two last documents regarding theestablishment of an EU Scientific Panel.

Bellona is in favour of the establishment of an EU Scientific Panel and is positive to the
suggested draft Terms of Reference for a Scientific Panel on Monitoring Issues at CO2 storage sites. However, Bellona wishes to raise the following issues:

2. Current lack of knowledge to quantify CO2 leakage from storage sites
Although Bellona is positive to CCS as a tool to combat global warming, we are, as an
environmental NGO, concerned that CO2 is intended to be stored underground without
sufficient methods to measure and quantify any leakages. Indeed, the document called “Basic Framework for an EU-scientific advisory body supporting harmonized CO2-quantification approaches at CO2 storage sites” explicitly recognises that there is little knowledge on methods for the quantification of CO2 leakages from CO2 storage sites, and that the development of MRGs for CCS including specific quantification approaches does not seem feasible at this point of time. This statement confirms that the challenge remains to measure leakages from storage complex, and that such duty is more complicated than to measure emissions from industrial installations.

The new EU CO2 Storage Directive puts efforts both on the prevention of leakages (through site characterisation, risk assessment and the establishment and updating of monitoring plan), and through corrective measures in case of leakage. However, as technology to monitor, detect and quantify leakage is not sufficiently developed and is mostly left to the choice of the operator on the basis of the Best Practise available ( point 1.1 of Annex II of the CO2 Storage Directive), Bellona is afraid of the consequences that undetected, late detected, or underestimated leakages could have on the environment, on the public acceptance of CCS. Furthermore, lack of good monitoring techniques can also prevent CCS from being includedin international mechanisms for greenhouse gas emission reduction like the Clean
Development Mechanism (CDM).

We find it therefore crucial to insist on the rapid development of technology and methodology to quantify both vertical CO2 leakages but also lateral migration of CO2 (as such migration can also result in leakages).

In that respect, we support the establishment at the EU level of a Scientific Panel as it will contribute positively to gather practical experience, and will enable the development of future guidelines for monitoring and quantification of CO2. It is more appropriate to develop guidelines than a uniform set of requirements as measurement, monitoring and verification (MMV) are site specific.

A successful deployment of CCS as a strategy to combat global warming will not only require good technologies and guidelines for MMV, but also appropriate technologies and guidelines for remediation actions if leakages should occur.
We therefore emphasize that such Panel should also have the duty to establish guidelines for remediation actions in case of leakage.

3. Ensure Norway’s participation as observer in the Panel
According to the current wording of the proposed “Draft term of reference for a scientific
Panel on Monitoring Issues at CO2 storage sites” Member States shall be allowed to
participate as observers in the Panel’s meeting, with the aim of better understanding the Panel’s decisions as well as to enhance capacity building regarding monitoring and
quantification activities at the storage sites. Although Norway is not formally a Member State, we find it important for Norway to negotiate its participation as an observer to such Panel. This is crucial for EFTA countries as Norway, because the duty to review draft permits might probably belong to ESA with the challenge that ESA might not have the same competence than the EU Commission in that area.

4. Ensure a separate penalty for leakages
Leakage of CO2 from the storage site will result in liability to purchase credits under the EU ETS. This is not really a penalty as it simply puts the operator back to the EU ETS system with liability for climate change limited to the current carbon price. This creates an usual situation whereby if the carbon price is relatively low compared to the costs of monitoring and preventing leakages, the penalty to buy credits might be an inadequate tool. It is therefore important to ensure a separate penalty for leakage that will act as a warning to operators of storage sites and signal the importance of careful site management.