4.1.8 Comparison between the IEA-MRF and the EU CCS Directive

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 Directive and the IEA MRF were observed (WRI based tool):

  • It can be recapitulated that both document are in agreement on many issues addressed such as: CO2 stream constituents constraints, CO2 definition and /or composition requirements, injection pressure determination, risk analysis and contingency plans, updates of models, phased permitting, financial responsibilities, flexibility in monitoring area delineation, choice of monitoring tools and sitting requirements focused on geological characterisation.
  • Both models recognize that monitoring should be focused on the outcomes rather than on specifying methods. Comparing the predicted and actual behaviour of CO2 in the subsurface and detecting any unexpected migration is also emphasised. However, the EU CCS Directive includes more detailed provisions for operational data collection.
  • Both models include consideration of pressure within the storage complex. However, the EU CCS Directive focus is more general: instead of »area of elevated pressure«, the wording »pressure-volume behaviour and areal/vertical distribution of CO2-plume« is used.
  • Estimating capacity is recognized as part of site characterization in both the IEA MRF model and the EU CCS Directive, but only the later includes a specific mention of volumetric capacity estimates.
  • In terms of monitoring duration the CCS Directive sets a 20 year minimum monitoring period (after site closure and before transfer to a competent authority) while IEA MRF contains only performance-based criteria for closure and no set duration. However, the CCS Directive's 20 minimum can be shortened if specific conditions are met. There is no upper limit on monitoring duration. In addition, the IEA MRF allows for minimum periods between cessation of injection and the issue of closure authorization. It can be summarized that both regulatory schemes remain flexible in setting monitoring duration.
  • As far as financial responsibility updating is concerned, both regulatory models are in agreement. The EU CCS Directive requires periodic updating of the financial security, while the IEA 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 authorisation, where a review of financial security of the applicant is implied.
  • Minor differences exist in requirements for transfer of responsibilities. The CCS Directive provides the clarity on the transfer of responsibility from an operator to a competent authority and outlines the criteria. A default 20-year waiting period is foreseen. This is consistent with the IEA MRFs' criteria for the site can receive a certification of site closure. However, the IEA MRF differs from the EU CCS Directive in that it allows for these activities to include monitoring and verification and does not specify a default time period prior to transfer.
  • Major dissimilarity is found in terms of storage site registration. The EU CCS Directive specifically mentions that a registry should be created and maintained by national governments. IEA MRF does not explicit mention such a registry.
  • The EU CCS Directive 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 IEA MRF model stipulates that the storage complex should be "free of faults, fractures, wells or other features that are likely to allow unintended migration."
  • Post-closure definition is not consistent in the two regulatory frameworks either. The IEA MRF has defined post-closure 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 monitoring and verification, while the EU CCS Directive defines the time period of post-closure to include time after a site is closed, and before and after responsibility of the site is transferred.