Clean Development Mechanism and Carbon Capture and Storage

The Clean Development Mechanism (CDM) allows industrialized countries required to reduce greenhouse gas emissions under the Kyoto Protocol (known as Annex I countries) to invest in projects that reduce emissions in developing countries, as partial fulfillment of their obligations. Carbon Capture and Storage (CCS) projects -- the proposed storage of carbon dioxide from power generation and other source in underground geological reservoirs -- are currently disallowed as CDM projects.

However, in November 2006 the Conference of the Parties (COP/MOP) of the United Nations Framework Convention on Climate Change (UNFCC) signaled their interest in the potential of accrediting CCS projects and requested that submissions from interested parties be made by May 2007.

Following the initial submissions and a further round of submissions, the UNFCC requested the secretariat to prepare a final "synthesis report" on the issues raised for consideration by the Subsidiary Body for Scientific and Technological Advice (SBSTA) at its December 2008 meeting.

Of particular relevance to the debate over whether CCS projects should be included or not is that the purpose of the CDM is set out in Article 12 of the Kyoto Protocol as being "to assist Parties not included in Annex I in achieving sustainable development and in contributing to the ultimate objective of the Convention, and to assist Parties included in Annex I in achieving compliance with their quantified emission limitation and reduction commitments under Article 3."

The coal industry and some pro-coal governments are keen to ensure the Clean Development Mechanism includes CCS. A report commissioned by the Global Carbon Capture and Storage Institute, a pro-CCS agency initiated by the Australian government, stated that "in the absence of a mechanism such as the CDM it seems unlikely that investment in CCS will be achieved in many developing countries within the timeframe proposed by the G8." (At its June 2008 meeting in Japan, the G8 agreed that "20 large-scale CCS demonstration projects need to be launched globally by 2010, taking into account varying national circumstances with a view to supporting technology development and cost reduction for the beginning of broad deployment of CCS by 2020.")

Country stances

In September 2007, the governments of Japan and Saudi Arabia submitted positions on including CCS projects in the CDM. Japan noted "the necessity for reservoir monitoring [of CCS projects] after the crediting period for leakage and safety." It suggested that "the liability for monitoring the reservoir after CDM projects ultimately should go to the Sovereign State within whose territory the storage takes place," by definition a developing country. To provide for possible leakage of stored carbon, Japan suggested using "insurance or establish[ing] funds" for remediation. Overall, Japan's submission was positive towards CCS, recommending "profound" study of including CCS in the CDM.

Saudi Arabia's submission declared CCS "the most promising and effective win-win (win to reducing emissions and win for reducing impacts on developing countries) technology for combating greenhouse gas emissions and welcomes all initiatives to promote and deploy this technology under the CDM."

Canada's October 2007 submission called CCS "a critical bridge towards a low-carbon world, given the forecasted global dependency in fossil fuel use in the near future." Canada further called CCS "critical to maximizing GHG [greenhouse gas] mitigation opportunities worldwide" and "an important element in furthering the transfer of CCS technology and expertise to developing countries." The submission added, "Considerable work undertaken by Canada and other countries over years concludes that geological storage of CO2 is secure." Like Japan, Canada suggested "post-project closure monitoring and remediation liability ... rest with the host country."

Norway's September 2007 supported CCS, "under the right site conditions ... for project activities under the CDM." Its submission noted that "CCS technology related to CO2 storage in geological formations is available and has been proven under full scale operational conditions for more than 10 years," including at the Sleipner Field in the North Sea. Norway flagged responsibility for long-term monitoring and liability for later problems as questions that need to be resolved.

Portugal's October 2007 submission on behalf of the European Union stated, "The EU does not support CCS projects involving the direct injection of CO2 into the water column because of high levels of uncertainty about levels of CO2 retention and the negative effects on ecosystems." However, the EU supported "environmentally and health safe CCS involving geological storage as a possible mitigation option ... provided that the necessary technical, economic and regulatory framework exists to provide maximum environmental integrity and ensure that any seepage is avoided." At the same time, the EU submission called joint CCS projects a "capacity building exercise" and noted an EU-China agreement "to develop and demonstrate near zero emissions coal (NZEC) technology through carbon capture and storage by 2020," along with the involvement of some EU member countries in the Carbon Sequestration Leadership Forum.

Korea's November 2007 submission expressed some support for CCS but cautioned, "there is not enough data on CCS technology to quantitatively evaluate its risks and effectiveness. Therefore, efforts should be made to further develop different forms of CCS technology and to strengthen international cooperation so as to accumulate more knowledge." Korea suggested "joint responsibility," if a CCS project later required repairs to stop carbon leakage. For long-term project monitoring, Korea supported establishing an "independent monitoring agency under the CDM Executive Board."

Environmental Groups Position on CCS

The Climate Action Network has argued that CCS should not be included in the Clean Development on a number of grounds. Firstly, it states that the Marrakech accords setting out the rules for the Clean Developmernt Mechanism require that projects be environmentally "safe and sound". "Many concerns surround CCS, i.e. leakage, liability and monitoring, and unless such issues are resolved, inclusion in the CDM is not appropriate," CAN states. CAN also argued that, as the purpose of the CDM was to assist non Annex 1 countries acheive sustainable development, the mechanism should "help developing countries 'leapfrog' an unsustainable fossil fuel economy. However, if CCS – a risky and potentially expensive technology – were to be included in the CDM, it could divert much needed investments from renewables and energy efficiency as well as the many longterm benefits that accompany these energy strategies. In this context, CCS could easily serve as a dangerous distraction in efforts to deploy sustainable solutions that protect our climate." Nor did CAN support the suggestion by the European Union that CCS pilot projects designed to gain experience with the technology be included. "Countries advocating for CCS should seek to gain practical experience in their own countries before exporting it," CAN responded.

They also argued that "requirements needed to assure proper site selection, operating practices to guarantee permanent retention of injected carbon dioxide, monitoring, measurement and verification provisions, and responsibility for leakage of injected gas should be developed before any decision is taken on whether CCS should be a part of the CDM."

In its submission to the UNFCCC, WWF expressed its in-principle support for the development of CCS but opposed its inclusion in the CDM. "CCS if proven to be ‘safe’ needs to be implemented both in developed and developing nations as soon as possible to reduce CO2 emissions – but this is distinctively different from CCS in the CDM," it submitted. It argued that "the unresolved issues of including CCS in the CDM pose higher risks to the environmental integrity and effectiveness of the Kyoto compliance and post-2012 climate regime than the perceived advantages of including CCS."

Industry Submissions

In its May 2007 submission to the UNFCCC, the World Coal Institute implied that CCS technology was already well established, albeit more expensive. The WCI stated that there is already a "wide body of expertise developed through operational experience from; industrial-scale CCS projects, underground injection of CO2 for enhanced oil recovery, and the use of analogous technologies such as acid gas injection and natural gas storage. These practical experiences are complemented by numerous research-scale CCS projects, research programmes, stakeholder networks and partnerships." While acknowledging that CCS technologies "add to the cost of supplying energy services" it argued that "incentives and policies are needed that address these additional costs thereby enabling CCS to be deployed."

"Allowing CCS activities to be eligible to receive revenues generated by the CDM is an important step for the worldwide deployment of this vital mitigation technology, permitting developing countries to meet their development goals in an environmentally sustainable manner," it argued.

In June 2008 the International Chamber of Commerce made a submission to the SBSTA of the United Nations Framework Convention on Climate Change arguing that the as yet unproven Carbon Capture and Storage technology should be included in the Clean Development Mechanism. In its submission, the ICC argued that "should CCS fail to qualify as a recognised emissions reduction option under the CDM, the cost of achieving the required emissions reductions will increase and the chances of meeting climate change goals would likely fall as a result."

It also noted that "in practice it is a relatively costly, energy and capital intensive technology, albeit with the potential for future cost reduction. The adoption of CCS by the private sector will depend on the incentives provided by the carbon market and other emissions reduction policies that overcome the additional cost of CCS development and deployment."

While acknowledging the technology would be expensive, the ICC signalled its clear intention that governments would underwrite its initial funding. "It is expected that most of the near-term CCS plants will be commissioned in Annex 1 countries and will receive the support that is required from host governments of those countries. However, it is also important that CCS obtains recognition as a valid abatement option in non-Annex 1 countries so that the legitimacy of the technology is established and that financial support measures are available at an early date," the ICC argued.

In June 2008 submission to the United Nations Framework Convention on Climate Change, the Carbon Capture and Storage Association (CCSA) argued in favour of the inclusion of CCS projects in the Clean Development Mechanism as "the primary method for incentivising low-carbon projects in the developing world."

It argued that "the threat of climate change cannot be addressed without CCS – the scale is too great and the window of time in which action is required, is closing fast. Each year of delay in bringing CCS to deployment represents an increase in million tonnes of CO2. Climate change is a global challenge, therefore both developed and developing countries must apply CCS as part of the solution ... This is particularly important in China and India where massive economic development is already resulting in escalating energy consumption, the majority of which is being met by fossil fuels."

While noting that "CCS has yet to be deployed at a widespread, large scale commercial level and first-mover projects are needed to demonstrate costs and technology, to enable learning-by-doing" they argued that "CDM is currently the only method to provide such incentives in developing countries" to overcome the costs of developing the first CCS projects.

In its submission the International Emissions Trading Association (IETA) argued that "delaying its use risks large GHG emissions to the atmosphere that could have been captured and stored, thereby reducing our ability to tackle global climate change" and that "CCS is a proven technology. The oil and gas industry has gained considerable experience over several decades relating to the capture, transport and storage of CO2 and the monitoring of CO2 injected in geological formations".

The International Petroleum Industry Environmental Conservation Association (IPIECA), was more matter of fact in its submission, simply stating that carbon dioxide capture and storage has been used to enhance oil recovery in some oil and gas fields and that over "the past several decades have stored roughly half a billion tonnes of CO2 in oil reservoirs." This experience, it stated, was relevant to consideration of risks of leakage, the operation of reservoirs and other potential environmental risks.

In a May 2007 submission, the International Risk Governance Council stated general support for the inclusion of CCS in the CDM "provided appropriate modalities and procedures for considering CCS projects are established. However, questions arise about whether the emission reductions as a consequence of CCS are measurable and predictable with sufficient certainty. Although there are remaining unknowns, the level of existing knowledge in the field of site selection and characterization, risk assessment and management, and monitoring techniques is substantial, and should not be downplayed. Bringing CCS under the CDM should be done in a careful manner, and the approval processes should be designed in such a way as to allow for flexibility of improvements as the knowledge and experience on CCS increase."

While noting the potential of CCS to store large volumes of carbon dioxide over long periods of time, it acknowledged that the financial issues arising from it for developing countries were substantial. The high cost of CCS projects, it stated, "are beyond the ability of many developing countries - potentially requiring a different CDM budget to attract new types of industry participation and enable independent technical assistance to referee licensing and site assessment", that the costs of long-term monitoring may need to be borne by the developer and that there could be the need to "remove risk from the developing country" by way of "novel forms of long-term financial bond, or insurance, from the project developer."

Negotiations at COP14 and Beyond

CCS at the December 2008 COP14 meeting

At the COP14 meeting in Poznan, Poland in December 2008, a number of countries were strongly pushing for the inclusion of CCS within the CDM. At the outset of COP14, the Umbrella Group argued in its opening statements to the Subsidiary Body for Scientific and Technological Advice (SBSTA 29), that there was a need to make progress on methodological aspects of including CCS in the CDM. The following day, Saudi Arabia, Norway, the European Union, Japan and others supported including CCS under the CDM. Jamaica, Venezuela and Micronesia "noted that although CCS has potential, it has not been fully tested or proven. Brazil said CCS is incompatible with the CDM." It also noted that a contact group had been established to canvass the issue further. Other countries opposing the inclusion of CCS were the Alliance of Small Island States and India.

Earth Negotiations Bulletin reported that in discussion on the possible inclusion of CCS in the CDM "delegates considered draft text setting out various options, including an EU proposal for a pilot phase. Some parties supported CCS under the CDM, while others said it should not be included in the current commitment period, but might be considered at a later stage." The following day it was noted by Earth Negotiations Bulletin that "during informal consultations, delegates discussed the various options set out in the Co-Chairs’ draft text. However, differences remained over including CCS under the CDM. Informal consultations will continue," it reported.

At a LWG-LCA Workshop on Research and Development of Technology, the Australian government proclaimed its work on the Global Carbon Capture and Storage Institute and the Asia-Pacific Partnership as examples of how it was taking action on CCS while Norway highlighted CCS as an option to allow a "climate-friendly transition to a low carbon society. Despite the lobbying for the inclusion of CCS, the opposition remained steadfast. By December 10, the lobbying push for CCS had made little progress, with ENB reporting that "informal consultations on this issue ended without agreement on draft decision text, which remained bracketed. Delegates then considered whether to forward the bracketed text to the COP/MOP or to SBSTA 31. However, they were unable to agree on where to forward the text."

In its concluding statement, the Subsidiary Body for Scientific and Technological Advice (SBSTA) simply noted that they had "considered the conclusions and the draft decision proposed by the Chair. However, it did not agree to adopt these conclusions and therefore could not conclude its consideration of this issue."

At the conclusion of COP14, Earth Negotiations Bulletin noted that the discussion would be taken up again at the next SBSTA meeting. It also reported that "The EU, Saudi Arabia, Australia, Norway and Japan expressed regret that agreement had not been reached. Jamaica noted that CCS technology is not ready for use in an offset mechanism such as the CDM. Brazil highlighted concerns relating to long-term permanence and host-country liabilities."

Earth Negotiations Bulletin also reported that supporters of the inclusion of Carbon Capture and Storage projects in the Clean Development Mechanism gained agreement for the matter to be referred to the Executive Board of CDM who would "report back to COP/MOP 5." ENB also noted that in the final plenary meeting "Venezuela proposed that the Board set up a working group to study the technical and legal aspects of CCS, and delegates agreed to reflect Venezuela’s statement in the meeting’s record."

The specific resolution stated that the conference of parties "requests the Executive Board to assess the implications of the possible inclusion of carbon dioxide capture and storage in geological formations as clean development mechanism project activities, taking into account technical, methodological and legal issues, and report back to the Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol at its fifth session."

The CDM Board Ponders Its Options

Subsequently. the CDM developed terms of reference for the consultant's report. In September 2009 the Executive Board considered the consultant's draft report and expressed it's concern that major aspects have not been adequately covered. "Although the report provided a broad review of carbon capture and storage in geological formation as mitigation option based on guidelines and reports of international institutions, it has not addressed the core element of the terms of reference, about a detailed assessment of the implications of possible inclusion of carbon capture and storage in geological formation as CDM project activities," the report of the board meeting states.

In October 2009, the Executive Board of the CDM reviewed the final report and recommended that the "Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol to request the CDM Executive Board not to consider any CCS related CDM baseline and monitoring methodologies submission until further guidance is provided."

In the summary of the pro and cons of including CCS plants in the CDM, the Executive Board noted many of the unresolved issues with a technology that has not yet been resolved at a commercial scale in developed countries, let alone developing countries. In particular, the summary noted potential problems spanning from technical issues through to legal, environmental and financial issues.

Technical issues

In the summary, the board noted that under the Kyoto Protocol any emissions reductions would need to be real, measurable and of long-term benefit. Supporters of the technology argue that CCS projects can be designed to meet these criteria "through proper site characterization and selection process, procedures for operation and monitoring and seepage remediation options." However, the summary also noted there were potential downsides, including that "detailed criteria for assessment of the site characterization is still lacking" and that "carbon capture and storage does not necessarily mean long term emission reduction because the storage might not be permanent." "Stored carbon is not measured but modelled," the summary cautioned.

Environmental issues

Supporters of the technology also argue that potential environmental problems can be addressed by requiring a "comprehensive Environmental Impact Assessment." Here too, the summary noted there were potential problems. "The lack of experience on CCS compared to the current eligible CDM projects, the lifetime of the projects and the uncertainty on the risk of seepage make the Environmental Impact Assessment challenging for CCS," the summary stated.

"... A faulty EIA could have regional or international implications, if it leads to poor site selection or operating practices that result in leakage," the summary also cautioned.

Methodological issues

Supporters also argued that proper modeling and simulation of carbon dioxide could be undertaken to ensure that the C02 stayed within the project boundary. They also argued that by having the injection point wholly within one country, the risk could be minimized that the project boundary would move beyond the host country's borders. "A reservoir may cover different countries or international waters and after storage the plume may migrates irrespectively to plans or political borders," the project summary states. "Project boundary is difficult to define in a situation in which potential leakage or seepage may result in international impacts," the summary noted.

The summary also noted that "project emissions as well as leakage can occur over a long time after the crediting period." While supporters argue that monitoring techniques are already available for most potential storage sites, "protocols for long-term monitoring are not established" and the period for "monitoring activity is not determined."

While supporters argue that the amount of Co2 can be modelled and verified, opponents aren't persuaded. The summary notes that "only the quantity of carbon captured and injected can be monitored and verified."

Legal problems

The summary also notes that there are numerous legal issues associated with CCS projects. Supporters of the technology argue that long-term liability could be assumed by the host country via various credit options or a "long-term institutional arrangement" or that investor countries could "also assume the long-term liability." Here too, opponents of including the CCS in the CDM flagged major concerns. The summary noted that some of those raised were that "the transfer of liability to host countries may not be guaranteed because they may not accept to assume the long-term liability" and that what happens to liability after the crediting period expired is not currently defined.

The summary also noted that "stable political, economic and institutional structures are required to be liable for surrendering credits. Stability does not necessarily exist in the liable institutional structure in the long term."

Economic issues

Another concern is the prospect that the inclusion of CCS in the CDM could undermine the carbon market. Supporters of CCS argue that the price of Certified Emission Reduction "would only be affected if CCS projects would affect the marginal price in the market." Critics of CCS are unpersuaded. "There are no studies to assess possible impacts of CCS in the CDM market but credits from CCS coming to the market may affect the CERs prices. It may also affect the development and deployment of renewable energy and energy efficiency technologies," the summary states.

Another point of dispute is over the potentially uneven geographic distribution of CDM funds. Supporters of including CCS in the CDM argues that while the distribution of CDM projects is not yet known, "it is likely that it will benefit mainly countries that are fossil fuel producers and/or users, some of which are currently underrepresented in the CDM." Opponents of including CCS in the CDM agrees that the beneficiaries are likely to be those countries that are either producers or consumers of fossil fuels.

CCS supporters also argue that for "the power sector in developing countries, additional financial incentives combined with market-based mechanisms are needed to stimulate investments in CCS." However, opponents point out that "the only mature market technology for geological storage listed by IPCC in the Special Report on CCS is the enhanced oil recovery and this type of projects may not depend on CDM incentives and/or may not be additional." The summary also note that enhanced oil recovery (EOR) projects may "result in breakthrough of CO2 and may bias site selection against more stable geological sites."

The summary also states that "policies to promote CCS may be challenging to be considered under (E+/E-) CDM rule". The refers to a decision by the CDM Executive that "as a general principle, national and/or sectoral policies and circumstances are to be taken into account on the establishment of a baseline scenario, without creating perverse incentives that may impact host Parties’ contributions to the ultimate objective of the Convention."

Negotiations at COP15 in Copenhagen

In the initial meeting of the Subsidiary Body for Scientific and Technological Advice (SBSTA) during the COP15 negotiations, Saudi Arabia, Australia, Japan, Kuwait, Qatar and the European Union all argued in favour of including CCS in the Clean Development Mechanism. However, Brazil, Paraguay and Granada, the latter speaking for AOSIS, opposed the proposal.

Brazil proposed deferring consideration of the topic until a future meeting of SBSTA. Australia cited the consultants report prepared for the Executive Board of the CDM and claimed that it "clearly shows that CCS is a mature technology that will be progressively deployed across developed and developing countries over the coming decade". The government representative argued that "business and host governments need to receive a clear early signal before they commit to such large scale early investments. We should send that signal at Copenhagen." (Australia had also made a late submission to the UNFCCC, which parties to the SBSTA meeting had not received in time to read).)

Saudi Arabia claimed that CCS was "the most promising technology" to reduce greenhouse gas emissions. He also stated that his country had its own self-interest at heart in promoting CCS. "For my country we have zero projects, zero projects in our country for the CDM because we are heavily dependent on the exporting of the oil. So the only opportunities we have CMD projects in our countries ... is the CCS under the CDM".

AOSIS restated its ongoing opposition to the inclusion of CCS in the CDM and objected to "the amount of valuable time that we are allocating to this subject." "AOSIS reiterates that CCS has potential but there are fundamental problems associated with bringing this immature technology with long-term liabilities surrounding non-permanence into the CDM." As for the consultant's report referred to by both the representatives of Australia and Saudi Arabia, the AOSIS representative bluntly emphasised that the report was "never accepted by the board" of the CDM.

Paraguay's representative argued that "what this technology implies is that emnissions can continue to take place at a rate which will be infinite ... I think this type of thinking and approach, quiote simply, will stand in the way of the real plans aiming at ... the reduction of our dependence on fossil fuels".

The chair of the committee, Helen Plume, proposed that an informal group be established to consult interested parties on how best to proceed. She said that the group would report back to the reconvened meeting a few days later.

However, little progress was made. As a result SBSTA agreed to adopt only heavily qualified draft text which reflected the divergent views and agreed to continue discussions at its next meeting in June 2010. The supporters of CCS were proposing that, after several general introductory paragraphs, the text include the statement that the conference "also recognizes that in order for carbon dioxide capture and storage in geological formations to be included under the clean development mechanism, long-term liability for the storage site, including liability for any seepage during and beyond the crediting period of the project, must be clearly assigned and the project boundary must be clearly defined". Those objecting to CCS wanted this paragraph deleted in its entirety.

More importantly, the final paragraph of the text proposed that SBSTA continue to discuss the issue. However, this too included numerous brackets reflecting the disagreements over what CCS_related issues the committee should focus on and when it should report back. CCS supporters argued that the issue should be on the agenda for the 2010 Conference of Parties in Mexico while others preferred the December 2011 conference.

Earth Negotiations Bulletin reported that Saudi Arabia and Australia "expressed disappointment that agreement was not reached. GHANA proposed requesting that SBSTA establish a programme for CCS as a mitigation technology and activity."

The Australian government representative stated that "We believe that there is now a wide base of scientific, technical and practical understanding and experience with CCS technologies and many developed and developing countries have active CCS programs. We know also that industry is ready to mobilise large scale investment in CCS. What is needed, in conjunction with appropriate policies and frameworks at the national level, are economic incentives that could assist those developing countries interested in doing so to cover the incremental cost of deployment. Registration of CCS projects in the CDM will provide just such an incentive. Given the long lead time associated with large projects it is important that we send the signal now so that we can catalyse the private sector and support developing countries."

Committee Chair's Draft to the Rescue of CCS?

While the promoters of CCS suffered a rebuff on Saturday at the SBSTA plenary, their hopes were kept alive in the draft text released by the chair of Ad Hoc Working Group on Further Commitments for Annex I Parties under the Kyoto Protocol. The draft presented two options.

The first reflected the view of those opposing CCS. The proposed text stated that the conference:

"decides that activities relating to carbon dioxide capture and storage shall not be eligible under the clean development mechanism in the second commitment period owing to unresolved concerns and issues at the international level, including:

(a) Non-permanence, including long-term permanence;
(b) Measurement, reporting and verification;
(c) Environmental impacts;
(d) The definition of project activity boundaries;
(e) Issues of international law;
(f) Issues of liability;
(g) The potential for the creation of perverse incentives for increased dependency on fossil fuels;
(h) Safety;
(i) The absence of insurance coverage to provide compensation for damage to the environment and to the atmosphere resulting from storage site leakage".

The alternative text, reflected the text preferred by the promoters of CCS. The draft text stated that the conference:

"Decides that activities relating to carbon dioxide capture and storage in geological formations shall be eligible under the clean development mechanism in the second and subsequent commitment periods;

"Requests the Subsidiary Body for Scientific and Technological Advice to recommend modalities and procedures for inclusion under the clean development mechanism of the activities referred to in paragraph 2 above, with a view to forwarding a draft decision on this matter to the Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol for adoption at its seventh session, including in relation to

"Requests the Subsidiary Body for Scientific and Technological Advice to recommend modalities and procedures for inclusion under the clean development mechanism of the activities referred to in paragraph 2 above, with a view to forwarding a draft decision on this matter to the Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol for adoption at its seventh session, including in relation to:

(a) Non-permanence, including long-term permanence;
(b) Measuring, reporting and verification;
(c) Environmental impacts;
(d) The definition of project activity boundaries;
(e) Issues of international law;
(f) Issues of liability;
(g) Insurance to compensate for leakage;
(h) The potential for perverse outcomes;
(i) Safety".

Reaction to decision

Svend Soyland, from the Bellona Foundation -- a Norwegian think tank supporting CCS -- stated after COP15 that "the inclusion of CCS in the CDM was fairly unrealistic from the outset. However, CCS was bracketed and kept within the draft text until the final stages of the negotiations. This reflects the fact that there is a going acceptance of CCS as part of the solution to climate change, both by the developed and the developing world. Unresolved issues such as financing or liability must now be addressed in in preparation for COP16 in December 2010".

Groups which made submissions

Non-governmental organizations

• Bellona Foundation
• Carbon Sequestration Leadership Forum (CSLF)
• Carbon Capture and Storage Association (CCSA)
• Greenpeace International
• International Chamber of Commerce (ICC)
• International Emissions Trading Association (IETA)
• International Petroleum Industry Environmental Conservation Association (IPIECA)
• International Risk Governance Council (IRGC)
• Norwegian Forum for Environment and Development
• Sustain US
• World Coal Institute (WCI)
• WWF

Contact details

Website: http://cdm.unfccc.int/about/ccs/index.html

Articles and resources

Related GEM.wiki articles

• Clean Development Mechanism
• Carbon Capture and Storage: Reports and Submissions
• Carbon Capture and Storage in India
• Carbon Capture and Storage in China
• Climate change

External resources

• Dirty Business (film about carbon capture and storage)
• United Nations Framework Convention on Climate Change, "Carbon dioxide capture and storage in geological formations as CDM project activities", United Nations Framework Convention on Climate Change website, accessed November 2009.
• "Workshop on carbon capture and storage as CDM project activities", United Nations Framework Convention on Climate Change, May 20, 2006. This page lists the agenda, a link to the webcast and the background papers from the Secretariat.
• "In-session workshop on carbon dioxide capture and storage", United Nations Framework Convention on Climate Change, May 20, 2006, Hotel Maritim, Plenary II. (This webpage includes links to submissions from various parties including the governments of the USA, United Kingdom, Canada, Norway, Australia, China and others. Submissions were also made by representatives from Chevron, Shell, BP and Statoil, who were attending as representatives of International Petroleum Industry Environmental Conservation Association.)
• CDM Executive Board, Annex 1: Implications of the Inclusion of Geological Carbon Dioxide Capture and Storage as CDM Project Activities: An assessment: Draft Final Report, A report for the UNFCCC, October 2009.
• CDM Executive Board, "Possible implications of the inclusion of CCS as CDM project activities", EB 50 Report, Annex 1, October 16, 2009.
• "Contact Group on Mitigation: Subgroup on paragraph 1 (b) (vi) of the Bali Action Plan", Revised annex III E to document FCCC/AWGLCA/2009/INF.2 Non-paper No 23], October 9, 2009.

External articles

• Greenpeace, "Clean Development Mechanism: no place for Carbon Capture and Storage", Greenpeace International, December 2008.
• Morten Andersen, "Carbon capture is put on hold", UNFCCC, December 15, 2009.