The World Resources Institute (WRI) developed a dynamic web-based tool that allows visitors to compare CCSCarbon dioxide Capture and Storage regulations and regulatory proposals across a number of key issues. The tool compares CCSCarbon dioxide Capture and Storage-specific regulations from EUEuropean Union (the EU CCS DirectiveDirective 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide), USA (the USEPA rules) and IEAInternational Energy Agency Model Framework (IEAInternational Energy Agency MRF) to each other to convey where key issues are managed similarly or differently and where they are not addressed. Based on this tool, major differences between the USEPA rules and the EU CCS DirectiveDirective 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide were found (WRI based tool):
- Both regulations set monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions durations (EPA 50 years and EUEuropean Union 20 years, but both are flexible in this respect) and anticipate to be decreased if evidence exist the storage(CO2) A process for retaining captured CO2, so that it does not reach the atmosphere project will not leak. However, the CCSCarbon dioxide Capture and Storage Directive applies stricter performance-based standards requiring that all available evidence indicates that the stored CO2Carbon dioxide will be completely and permanently contained.
- Major differences exist on the storage(CO2) A process for retaining captured CO2, so that it does not reach the atmosphere site registration: the EU CCS DirectiveDirective 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide specifically mentions that a publicly accessible registry should be created and maintained, while EPA does not specify anything like it.
- In terms of financial responsibility both require that the operator demonstrate financial responsibility for the expected costs of a storage(CO2) A process for retaining captured CO2, so that it does not reach the atmosphere project. However, the EU CCS DirectiveDirective 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide includes coverage for 30 years of monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions as part of the plan; under the EPA rule the default time period would be 50 years, although this is not mentioned explicitly. In addition, the EPA addresses neither the funding for long-term stewardship nor the transfer of responsibilityTransfer of all rights and obligations associated with a storage site to a designated authority; will normally be granted when the obligations in the site closure permit has been met with an adequate level of confidence of the site to a long-term caretaker. Both regulations anticipate funding security.
- EPA does not prescribe a mechanism for long-term stewardship after a site is closed, while the CCSCarbon dioxide Capture and Storage Directive requires the transfer of responsibilityTransfer of all rights and obligations associated with a storage site to a designated authority; will normally be granted when the obligations in the site closure permit has been met with an adequate level of confidence for a closed site to a competent authority.
- Major differences exist in terms of post-closurePeriod after transfer of responsibility to the competent authority definition. EPA defines it as a period of time after injectionThe process of using pressure to force fluids down wells, but before the site is closed, during which the operator is responsible for monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions and verification(CO2 storage) The proof, to a standard still to be decided, of the CO2 storage using monitoring results; (in the context of CDM) The independent review by a designated operational entity of monitored reductions in anthropogenic emissions. However, the CCSCarbon dioxide Capture and Storage Directive defines post-closurePeriod after transfer of responsibility to the competent authority as the time after the site is closed, including before and after responsibility of the site is transferred.
- InjectionThe process of using pressure to force fluids down wells pressure determination is also dissimilar: EPA states that operators cannot exceed 90% of the fractureAny break in rock along which no significant movement has occurred pressure while the EU CCS DirectiveDirective 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide does not impose specific restrictions - the key question is whether the available storage(CO2) A process for retaining captured CO2, so that it does not reach the atmosphere space would be significantly decreased by and whether certain cap rocks would fail at an injectionThe process of using pressure to force fluids down wells pressure greater than 90% of the fractureAny break in rock along which no significant movement has occurred pressure.
- Both rules include consideration about the area of elevated pressure as part of the project footprint that is monitored. EPA rules are much more definitive and specifically demand testing and monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions. However, the EU CCS DirectiveDirective 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide does not explicitly mention an area of elevated pressure, but instead more generally focuses on monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions "pressure-volume behaviour and areal/vertical distribution of CO2Carbon dioxide-plume."
- Both preview the model updates and include provisions for using a predictive model that is based on operational data, which is updated throughout the project. The detailed provisions on the model updates differ slightly as the EPA's regulation requires updates also after a fixed period of time (every five years and when the area of review is updated).
- Mixed approaches about monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions requirements exist. Both frameworks identify data requirements for operational monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions that are largely consistent and both recommend that the operator report the composition of the injected fluid, the volume injected, the flow rate, and reservoirA subsurface body of rock with sufficient porosity and permeability to store and transmit fluids pressure. Meanwhile, the EU CCS DirectiveDirective 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide focuses on the outcomes rather than on specifying methods. Moreover, the EPA rule does not specify reporting leakage(in CO2 storage) The escape of injected fluid from the storage formation to the atmosphere or water column emissions as an operational data requirement.
As concerns flexibility of monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions area, choice of monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions tools and sitting requirements focused on geological characteristics, both regulations are comparable.