A similar comparison as was presented in section 4.1.2 can also be performed for the MRF regulatory framework. Based on the World Resources Institute (WRI) dynamic web-based tool, key issues are compared and the following similarities/dissimilarities between 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 and the IEAInternational Energy Agency MRF were observed (WRI based tool):
- It can be recapitulated that both document are in agreement on many issues addressed such as: CO2 streamA flow of substances resulting from CO2 capture processes, or which consists of a sufficient fraction of CO2 and sufficiently low concentrations of other substances to meet specifications of streams permitted for long term geological storage constituents constraints, CO2Carbon dioxide definition and /or composition requirements, injectionThe process of using pressure to force fluids down wells pressure determination, riskConcept that denotes the product of the probability of a hazard and the subsequent consequence of the associated event analysis and contingency plans, updates of models, phased permitting, financial responsibilities, flexibility in monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions area delineation, 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 characterisation.
- Both models recognize that monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions should be focused on the outcomes rather than on specifying methods. Comparing the predicted and actual behaviour of CO2Carbon dioxide in the subsurface and detecting any unexpected migrationThe movement of fluids in reservoir rocks is also emphasised. 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 more detailed provisions for operational data collection.
- Both models include consideration of pressure within the storage(CO2) A process for retaining captured CO2, so that it does not reach the atmosphere complex. 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 focus is more general: instead of »area of elevated pressure«, the wording »pressure-volume behaviour and areal/vertical distribution of CO2Carbon dioxide-plume« is used.
- Estimating capacity is recognized as part of site characterization in both the IEAInternational Energy Agency MRF model 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, but only the later includes a specific mention of volumetric capacity estimates.
- In terms of monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions duration the CCSCarbon dioxide Capture and Storage Directive sets a 20 year minimum monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions period (after site closure and before transfer to a competent authority) while IEAInternational Energy Agency MRF contains only performance-based criteria for closure and no set duration. However, the CCSCarbon dioxide Capture and Storage Directive's 20 minimum can be shortened if specific conditions are met. There is no upper limit on monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions duration. In addition, the IEAInternational Energy Agency MRF allows for minimum periods between cessation of injectionThe process of using pressure to force fluids down wells and the issue of closure authorization. It can be summarized that both regulatory schemes remain flexible in setting monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions duration.
- As far as financial responsibility updating is concerned, both regulatory models are in agreement. 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 requires periodic updating of the financial security, while the IEAInternational Energy Agency MRF does not explicitly mention requiring updates of the mechanism on the "proof of the financial security," except in the case of a review of the entire storage(CO2) A process for retaining captured CO2, so that it does not reach the atmosphere authorisation, where a review of financial security of the applicant is implied.
- Minor differences exist in requirements for transfer of responsibilities. The CCSCarbon dioxide Capture and Storage Directive provides the clarity on 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 from an operator to a competent authority and outlines the criteria. A default 20-year waiting period is foreseen. This is consistent with the IEAInternational Energy Agency MRFs' criteria for the site can receive a certificationIn the context of carbon trading, certifying that a project achieves a quantified reduction in emissions over a given period of site closure. However, the IEAInternational Energy Agency MRF differs from 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 in that it allows for these activities to include 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 and does not specify a default time period prior to transfer.
- Major dissimilarity is found in terms of 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 registry should be created and maintained by national governments. IEAInternational Energy Agency MRF does not explicit mention such a registry.
- 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 is less strict about the presence of faults. It allows for the presence of faults and fractures, provided they are included in the geological model. However, the IEAInternational Energy Agency MRF model stipulates that the storage(CO2) A process for retaining captured CO2, so that it does not reach the atmosphere complex should be "free of faults, fractures, wells or other features that are likely to allow unintended migrationThe movement of fluids in reservoir rocks."
- Post-closurePeriod after transfer of responsibility to the competent authority definition is not consistent in the two regulatory frameworks either. The IEAInternational Energy Agency MRF has defined post-closurePeriod after transfer of responsibility to the competent authority as a period after a demonstration of non-endangerment has been made and after the point at which the operator is no longer 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, 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 defines the time period of post-closurePeriod after transfer of responsibility to the competent authority to include time after a site is closed, and before and after responsibility of the site is transferred.