Scholarly article on topic 'International marine regulation of CO2 geological storage. Developments and implications of London and OSPAR'

International marine regulation of CO2 geological storage. Developments and implications of London and OSPAR Academic research paper on "Chemical sciences"

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Abstract of research paper on Chemical sciences, author of scientific article — Tim Dixon, Andy Greaves, Oyvind Christophersen, Chris Vivian, Jolyon Thomson

Abstract For the last four years a considerable amount of both legal and technical work on the storage of CO2 in sub-seabed geological formations has been developed under the London Convention and its 1996 Protocol and the OSPAR Convention. The technical and legal work included consideration of the risks and benefits to the marine environment within the context of increasing atmospheric CO2 absorption by the oceans. The conclusion of this work was that the Conventions should move to remove their prohibitions that applied to certain CO2 geological storage project configurations, so as to facilitate and to regulate environmentally safe CO2 geological storage. In timescales faster than most anticipated, the London Protocol was amended in November 2006 and OSPAR was amended in June 2007. The actual amendments include various provisions, conditions and restrictions so as to only allow environmentally sound CO2 storage. These provisions and their implications for CCS regulation and projects are described in this paper. In this process, three detailed guidelines were produced for risk assessment and management of CO2 storage. These guidelines and their implications for CCS regulation and projects are described. Some key principles from the London and OSPAR CO2 developments are now being reflected in the European Commission’s proposed directive on geological storage of CO2. These marine conventions are good examples of evidence -based regulatory development in a new area, which brought to gether environmental, climate and energy experts and regulators, and key principles established by them will have wider implications for future CCS regulation and projects.

Academic research paper on topic "International marine regulation of CO2 geological storage. Developments and implications of London and OSPAR"

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Energy Procedia 1 (2009) 4503-4510

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International Marine Regulation of C02 Geological Storage. Developments and Implications of London and OSPAR

Tim Dixona*, Andy Greaves b, Oyvind Christopherserf, Chris Vivian d, Jolyon Thomsonb

" IEA GHG R&D Programme, Cheltenham GL52 7RZ, UK (previously with UK Dept for Business and Enterprise - BERR) b UK Dept of Environment, Food and Rural Affairs (Defra), London, UK c'Norwegian State Pollution Control Authority, Oslo,Norway dCEFAS, UK

Abstract

For the last four years a considerable amount of both legal and technical work on the storage of C02 in sub -seabed geological formations has been developed under the London Convention and its 1996 Protocol and the OSPAR Convention. The technical and legal work included consideration of the risks and benefits to the marine environment within the context of increasing atmospheric C02 absorption by the oceans. The conclusion of this work was that the Conventions should move to remove their prohibitions that applied to certain C02 geological storage project configurations, so as to facilitate and to regulate environmentally safe C02 geological storage. In timescales faster than most anticipated, the London Protocol was amended in November 2006 and OSPAR was amended in June 2007. The actual amendments include various provisions, conditions and restrictions so as to only allow environmentally sound C02 storage. These provisions and their implications for CCS regulation and projects are des cribed in this paper. In this process, three detailed guidelines were produced for risk assessment and management of C02 storage. These guidelines and their implications for CCS regulation and projects are described. Some key principles from the London and OSPARCO 2 developments are now being reflected in the European Commission's proposed directive on geological storage ofC02. These marine conventions are good examples of evidence-based regulatory development in a new area, which brought to gether environnental, climate and energy experts and regulators, and key principles established by them will have wider implications for future CCS regulation and projects.

O 2009 Elsevier Ltd. All rights reserved.

Keywords: Legal. Regulation. Environmental protection. Marine environment. C02 geological storage. Ocean acidification.

1. Introduction

Carbon capture and storage (CCS) has increased in prominence as new and potentially significant option to reduce emissions of carbon dioxide, the primary greenhouse gas, to the atmosphere, and thereby tackle climate change. The main requirements which many have identified for CCS to reach wide deployment are in three main areas: technology development to reduce costs; economic incentives to en courage CCS when it is an additional cost on operations; and regulatory development to remove regulatory barriers whilst ensuring environmental protection. For

* Corresponding author. Tel.: +44 1242 680753; fax: +44 1242 680758. E-mail address :tim.dixon@ieaghg.org. doi:10.1016/j.egypro.2009.02.268

the last four years the London Convention [1] and the OSPAR Convention [2] have been undertaking aconsiderabl e amount of both legal and technical work on the storage of C02 in sub-seabed geological formations, which has contributed significantly to the third area.

2. London Convention and Protocol

The London Convention (1972) and its 1996 Protocol [1] is the global agreement regulating dumping of wastes at sea> The Convention consists of 85 countries, and the Protocol 35 countries (as of 12 September 2008). The Protocol is an updated and more rigorous version of the Convention. It was ratified by sufficient countries so as to come into force in March 2006, and in time is expected to replace the Convention. The Protocol prohibits dumping of wastes or other matter except that specified in its Annex 1, and these require permitting and regulation. Examples of wastes or other matter which may be dumped include dredged material, fish waste and inert geological material. However, it appeared that the Protocol, because it included the sub-seabed in its scope, could prohibit several CCS project scenarios including C02 from an onshore source to an offshore platform for injection into a sub -seabed geological formation. In 2004, a Legal Working Group on C02 was established to clarify theissue, in consultation with all London Convention Parties. The conclusion of this Working Group was that there was a problem for CCS because there was uncertainty with different legal interpretations on different aspects of the issue.

The London Convention and Protocol has a Scientific Group, which meets once a year in between the annual Convention meetings. This Scientific Group is used to assess and understand and make recommendations to the London Convention annual meetings on a range of issues, drawing upon best scientific knowledge in the area. In 2004 the Scientific Group was tasked to assess the potential risks and benefits for the marine environment of CCS, identify gaps in knowledge and reach a view on the implications of this technology for the marine environment. The Scientific Group's consideration of CCS started with a dedicated CCS workshop in London in May 2005 organised by the UK, followed by establishing a technical working group which met in May 2005, April 2006 and April 2007 (in Norway and UK). In this working group, CCS and marine environment experts provided information to assist the Scientific Group in its assessment of the risks and benefits to the marine environment within the context of increasing atmospheric C02 absorption by the oceans. Examples of the evidence used are shown here. Figure 1 demonstrates the changes occurring in ocean chemistry due to atmospheric C02 being absorbed [3]. Approximately 50% of CO 2 emitted since the industrial revolution has been absorbed by the oceans, and the scale of the effect is large with significant consequences for marine ecosystems, creating both known impacts such as on the calcifying phytoplankton, and impacts of a more unknown nature because of the complexities of interactions of the marine chemistry and ecosystem processes.

Simulated and observe d marine pH rang es till 2100

Fixed pipe

; m ■ m

280 ppm 370 ppm

500 ppm 700 ppm 1000 ppm

0 100 200 300

Distance from injection point (m) ApH: -3MMM^H_ -0.1

Figure 1 . Changes occurring in o cean chemistry due to atmospheric C02 [3]

Figure 2. pH changes due to simulated CO 2plume (875m depth, rate of 100 kgs)[4]

Injecting and storing C02 in geological formations beneath the seabed also could create risks of effects to the marine environment, particularly in the event of C02 leakage. Figure 2 provides an example of the potential risks, showing the effects of a large-scale prolonged C02 release on the deep ocean pH [4]. Work has also been undertaken to model the impacts of large-seal e release for a shallow sea environment [5] [6]. The conclusion of this assessment by the Scientific Group was that CCS was technically feasible, the risks were relatively small in perspective with the

impacts due to atmospheric C02, and potentially manageable with appropriate guidelines. During this process the working group prepared the detailed guidelines on geological storage of C02 as described later in this section.

The annual meeting of the London Convention in October 2005 reflected on this work and the legal work already undertaken to interpret the Convention and Protocol, and in its conclusions it "(1) acknowledged that C02 sequestration had a role to play, as part of a suite of measures to tackle the challenge of climate change and ocean acidification; (2) agreed that the London Convention and Protocol were appropriate global instruments to address the implications of C02 sequestration for the marine environment; (3) recognized that there were varying interpretations of how both instruments apply in different circumstances to C02 sequestration; and (4) agreed to consider, how best to facilitate and/or regulate C02 sequestration in sub-seabed geological structures under the Protocol and the Convention " [7]. A working group then undertook legal work supported by technical experts to conclude on the best way to remove the uncertainty on the prohibitions. An amendment to the Protocol to the London Convention was drafted by this group and proposed in April 2006 by Australia and supported by UK, Norway, France and Spain. This was voted on and agreed in November 2006 and came into force on 10 February 2007. All of this was in timescales far faster than most anticipated. The key elements of this amendment are as follows: added to the list of substances that ca n be dumped is:

"C02 streamsfrom CO 2 capture processes for sequestration" With the important caveats that

"Carbon dioxide streams may only be considered for dumping, if:

1 disposal is into a sub -seabed geological formation; and

2 they consist overwhelmingly of carbon dioxide. They may contain incidental associated substances derived from the source material and the capture and sequestration processes used; and

3 no wastes or other matter are added for the purpose of disposing of those wastes or other matter."

[8, Annex]

This meant that the geological storage of C02 had its prohibition uncertainty removed, so long as it is geological storage, and the C02 can contain impurities but this cannot be used as route for dumping other wastes.

In addition, the Scientific Group produced two sets of detailed guidelines on geological storage of CO 2 in the marine environment. For risk assessment and management of such activities, they produced the Risk Assessment and Management Framework for C02 Sequestration in Sub-seabed Geological Structure (known as the RAMF) [9], which also helped them understand the processes and risks better themselves. They then produced Specific Guidelines for Assessment of C02 Streams for Disposal into Sub-seabed Geological Formation (known as the C02 Specific Guidelines or sometimes as the C02 Waste Assessment Guidelines - WAG) [10]. Both these guidelines provide an environmental impact assessment process, with factors to be considered specifically for C02 storage activities. These guidelines drew upon the best available knowledge from scientific experts and guidance from IPCC sources, including the IPCC Guidelines for GHG Inventories (2006), which had a new chapter on CCS [11].

The basic structure of the RAMF guidelines is as follows, with a brief summary of the content:

1. Problem Formulation — scope, scenarios, boundaries

2. Site characterisation — capacity, integrity, leakage pathways, monitoring options, surrounding area, modelling of CO 2 behaviour

3. Exposure assessment — properties of CO 2 stream, exposure processes and pathways, likelihood, scale

4. Effects assessment — consequences - sensitivity of species, communities, habitats, other users

5. Risk characterisation — integrates exposure and effects - environmental impact, likelihood

6. Risk management — leakprevention, monitoring of CO 2 streams within and above formations — linked to p erformance monitoring and migration detection, and monitoring seafloor, water and biological if leakage is suspected - mitigation

Regarding monitoring, the RAMF guidelines draw upon the information contained in the IPCC GHG Guidelines [11]. It places monitoring techniques into two categories - those for measuring performance within the geology, and those for monitoring when leakage is suspected. The latter are more detailed and also can measure impacts, and include monitoring of sea water chemistry and ecological effects. Emphasis is made that the monitoring activities have to be revised in the light of monitoring results, and following the IPCC GHG Guidelines, the frequency of monitoring can be reduced as confidence grows in the security of storage. Also following the IPCC Guideline, the RAMF recognises that each storage site will be different and so site characterisation and risk assessments should be on a site-by-site basis. The RAMF guidelines also provide a useful summary of some leakage mitigation options

(Section 6.18-6.19). Overall, the primary focus of the RAMF is on geological storage in depleted hydrocarbon reservoirs and saline aquifers. They explicitly do not cover coal beds, basalts and salt caverns. Also they recognise that storage in geological formations under deeper waters, eg 500m, would require revised guidelines.

The CO2 Specific Guidelines [10] are the transposition and refinement of the RAMF into the standard structure of London Convention waste assessment guidelines to assist regulators in their permit decisions. These require an 'impact hypothesis' to be produced as a statement of the expected consequences of disposal. The basic structure of the Specific Guidelines is as follows, with a summary of the content:

1. Introduction —purpose and scope

2. Waste Prevention Audit - not directly pertinent to CCS

3. Consideration of Waste Management Options - not directly pertinent to CCS

4. Chemical an d Physical Properties - characterisation of the CO 2 stream

5. Action list — screeningfor acceptability of substances to be disposed, in this case the CO 2 stream including impurities.

6. Site selection and Characterisation — both of the storage formation and of the marine area, drawing upon the IPCC SR, including evaluation of potential exposure to CO 2 and other substances mobilised by the CO 2, identification of leakage pathways and probabilities, modelling of the CO 2 behaviour.

7. Assessment of potential effects — bringing all the above together into a risk assessment and producing an impa ct hypothesis.

8. Monitoring and risk management — to -verify the site mana gement and that permit conditions are being met, a detailed monitoring programme defined from the results of the impact hypothesis, including a mitigation plan in the event of leakage.

9. Permit and permit conditions — the information requiredfor and in a permit.

Refinements added to the C02 Specific Guidelines included a further definition of the C02 stream which clari fies that substances can be added to assist CCS. "the C02 stream, consisting of: .1 C02; .2 incidental associated substances derived from the source material and the capture and sequestration processes used: . 1 source - and process-derived substances; and .2 added substances (i.e. substances added to the C02 stream to enable or improve the capture and sequestration processes)" [10,section 1.3].

On C02 stream purity, the Scientific Group concluded that, rather than stipulating a generic standard for stream purity, given that the overall requirement is for environmental safety the levels of these impurities should be related to potential impacts on the integrity of storage and transport, and assessed on a case -by -case basis recognising the natural variation in storage site characteristics (as in IPCC SR [12] and IPCC GHG [11]) and different transport constructions. For example, an impurity of concern is H2S which can occur in small amounts from some CCS technologies, however, pipelines can be designed to resist H2S and some storage sites such as depleted oil and gas reservoirs may themselves be rich in H2S at levels far greater than in the C02 stream. Setting an arbitrary level for C02 would not necessarily improve the security of storage and could have perverse effects, for example purifying C02 streams further than necessary thus i ncreasing the energy penalty for C02 capture and increasing emissions from the capture processes. Setting an arbitrary level toohigh could also exclude certain CCS technologies, such as oxy-fuel and IGCC (Integrated Gasification Combined Cycle). This principle is described in the Specific Guidelines [10, section 5.3] and is why the general phrase " consist overwhelmingly of carbon dioxide" is used in the legal amendment.

The Specific Guidelines provide guidance on permitting and permit contents. A key requirement identified is that permits (and permit applications) should contain information on the C02 stream composition, and a risk management plan which has itsel f to inclide: a m onitoring plan (operational and long term) and reporting requirements; a m itigation and remediation plan (for in the event of leakage): and a s ite closure plan with post -closure monitoring [10, section 9.1]. Permits should be reviewed at regular intervals and should take into account any changes identified from the monitoring and updated risk assessments.

Both these guidelines are for guidance so as to encourage best practice in terms of protection of the marine environment, but there is no legal requirement for any country to have to use them, just encouragement and peer pressure from other London countries and stakeholders such as non -government al organisations (NGOs).

3. OSPAR Convention

OSPAR (1992) is the convention protecting the marine environment in the North East Atlantic, with 15 nations and the EC as Parties [2]. Similarly to the London Protocol, OSPAR was drafted without CCS in mind. Like the London Protocol, OSPAR specifies what is allowed to be dumped in its Annexes, and is consi dered more restrictive than the London Protocol. Unlike London, the legal consideration of CCS reached more certain conclusions [13], and concluded that certain CCS project configurations were prohibited depending on the route taken by the C02 to the storage site. It prohibited onshore C02 going to a storage site via an offshore petroleum-related platform (a likely CCS project scenario for the North Sea for example) and transport by ship for offshore injection. Transport via a pipeline from land that to a storage site that did not require use of a platform placed in the maritime area for oil and gas exploration was permissible.

OSPAR started considering CCS following a seminar in October 2003 in the UK on the implications of CCS forthe marine environment. In 2004, a dedicated OSPAR workshop on CCS was held in Norway. There was subsequent production of two information papers on associated issues; a technical review and a review of the environmental impacts of C02 [1 4]. In the light of the work on the London Protocol amendment, in 2006 OSPAR started legal work to consider its own amendment, and started a technical group to assess and refine for OSPAR purposes the London RAMF. This work resulted in guidance called the OSPAR Framework for Risk Assessment and Management of Storage of C02 Streams in Geological Formations (known as the FRAM) [15].

The structure of the OSPAR FRAM mirrors that of the London RAMF, with the same purpose. The principles established for CCS in London were also repeated in the FRAM. Again, the focus was on geological storage and explicitly not on storage in coal beds, basalts, oil and gas shales, or salt caverns. Refinements included the addition of an 'impact hypothesis' in the risk characterisation, providing more information on monitoring requirements, and identification of areas benefiting from further research (in Appendix II).

Once the FRAM was developed, an OSPAR legal working group meeting in the Netherlands considered and drafted appropriate legal amendments. Two amendments were required, for Annex II dealing with dumping and Annex III dealing with offshore sources. These amendments were proposed in 2007 by Norway and co-sponsored by UK, Netherlands and France. As well as the FRAM, guidelines were produced on how to use the FRAM, these were the OSPAR Guidelines for Risk Assessment and Management of Storage of C02 Streams in Geological Formations (known as the OSPAR Guidelines), which included the FRAM as an integral annex [16].

OSPAR was amended in June 2007 by consensus. The leg al amendments were similar to London's but with an additional condition:

"C02 streamsfrom CO2 capture processes for storage ....provided:-

• Into a sub-soil geological formation

• Consist overwhelmingly of C02. May contain incidental associated substances derived from the source material and capture and sequestration processes used

• No wastes or other matter are added for the purpose of disposal

• They are intended to be retained permanently and will not lead to significant adverse consequences for the marine environment, human health and other users " [17]

The permanent retention point means that sites with even low enough levels of leakage for climate benefit cannot be used.

At the same time, OSPAR Parties adopted a 'Decision' (a legal decision) to make use of the OSPAR Guidelines obligatory [18] when issuing permits for geological storage of C02. In London, the similar guidelines are for guidance only (though the London Protocol includes more detailed provisions on the issuing of permits within an overarching annex). This OSPAR Decision (2007/2) includes permit requirements similar to those in the London Specific Guidelines, but in more detail.

Any permit or approval issued shall contain at least:

1. a description of the operation, including injection rates;

2. the planned types, amounts and sources of the CO2 streams, including incidental associated substances, to be stored in the geological formation;

3. the location of the injection facility;

4. characteristics of the geological formations

5. the meth ods of transport of the CO2 stream;

6. a risk management plan that includes:

i. monitoring and reporting requirements ;

ii. mitigation and remediation options including the pre -closure phases; and

Hi. a requirement for a site closure plan, including a description of post-closure monitoring and

mitigation and remediation options; monitoring shall continue until there is confirmation that the probability of any future adverse environmental effects has been reduced to an insignificant level.

[17 Section 3.2.6]

The point in part 6.iii on monitoring means that monitoring may cease when confidence exists in the security of the C02 storage, reflecting the IPCC GHG Guidelines [11]. The OSPAR Decision also included the requirement for reporting, includingpost-closure reports, and a reporting template (Appendix 1).

The OSPAR Guidelines summarise the FRAM, describe when to use the FRAM in the project life cycle, and lists the reporting requirements in more detail [15]. The reporting requirements list the elements which can be included as performance criteria to be reported on against the impact hypothesis. These OSPAR Guidelines also repeat the permit requirements from the OSPAR Decision. These OSPAR Guidelines should be evaluated, and if necessary revised, in the light of experience every 5 years. In terms of using the OSPAR Guidelines, they describe themselves as providing " generic guidance " and " not all elements of these are necessary applicable to every C02 storage project" but they should be " applied to the extent possible" [15 Section 6.]. The guidelines are not written so as to provide yes/no answers or thresholds but to aid the regulator in understanding which issues should be considered and how. So the OSPAR Guidelines are required to be used by OSPAR Parties, but their detail is for 'guidance' and their application therefore allows some flexibility.

In addition, at the same meeting, OSPAR adopted another Decision to adopt a German proposal to prohibit ocean storage "The placement of carbon dioxide streams in the water column or on the seabed is prohibited" [19]. Thus ruling out ocean storage for OSPAR countries, unless for experimental purposes.

In terms of timescales, the OSPAR Decision to use the OSPAR Guidelines, and the Decision on oce an storage, came into force on 15 January 2008, for all C02 geological storage projects in the marine environment except those for enhanced oil recovery or from normal operations or experimental purposes, which fall outside the OSPAR cover. However, the legal amendments to remove the prohibitions only come into force after seven OSPAR Parties have ratified them. So far only Norway has, and other Parties appear to be waiting for the EU CCS Directive to be finalised, as it is likely that transposition of this Directive will enable their ratification of the OSPAR convention.

OSPAR Press Release 28 June 2007

The OSPAR Commission has ta ken decisive action towards reducing the negative effects of climate change at this year's Commission meeting in Ostend by adopting amendments to the Annexes to the Con vention to allow the storage of carbon dioxide in geological formations under the seabed. This follows publication last year by OSPAR of reports on ocean acidification, which confirmed that high levels of carbon dioxide (CO 2) in the atmosphere are changing ocean carbon chemistry at least 100 times faster than at any time in the last 100 000 years, and detailed consideration of technical aspects of CO 2 capture andstorage (CCS) in geological formations under the seabed. In association with this OSPAR has adopted a Decision to ensure environmentally safe storage of carbon dioxide streams in geological formations and OSPAR Guidelines for Risk Assessment and Management of that activity. The Commission has also adopted a Decision to legally rule out placement of CD 2 into the water -column of the sea and on the seabed, because of the potential negative effects.

4. Unresolved issue - London and transboundary movement of CO 2

Article 6 of the London Protocol [1] prohibits exports of matter for disposal in the marine environment. This includes if it is permitted matter, and therefore means that CO 2 is not allowed to be exported to another country for geological storage in the sub -seabed. When the CO 2 legal working group of the London Convention was considering what amendments were required, it decided to 'park' this issue, as changing an Annex was quicker and easier than

changing an article in the body of the convention, which requires two thirds majority voting in favour (as with an annex) to be adopted and then two thirds of all Parties to ratify. To ratify, many Parties consider that they have to show how the amendment would be implemented in its national law. This is not necessarily straightforward for C02 storage, as new or adapted regulation may be required.

However, the 2007 meeting of the London Convention and Protocol decided that this issue should not be left unaddressed. A working group was set up to consider this, including both legal and technical expertise, and met in February 2008 in Bonn. This considered transboundary movement both prior to injection and after injection by migration within the geological formation. The group concluded that an amendment was the best option to allow transboundary movement, and drafted text for a possible amendment. Any such amendment has not yet been proposed, and would need to be proposed six months before the London Convention's annual meeting. With the requirement also for ratification, it will be some time before any such amendment will be seen coming into force.

5. Ongoing work

The 2008 meeting of the London Convention's Scientific Group developed a draft reporting format for C02 sequestration formats. This was not completed and work will continue and will be considered at the annual meeting of the London Convention and Protocol in October 2008. This annual meeting will also consider the outcomes of the transboundary working group. Both London and OSPAR require that Parties update them on permitting and CCS activities relating to storage of C02 in the sub -seabed on an ongoing basis. Forexample the 2007 London Convention meeting was informed that the UK proceeding with its CCS large -scale demonstration, which specifies storage in the sub -seabed, because of the London amendment. Norway and the Netherlands also provided updates.

6. Impl ¡cations and principles established for CCS

These two marine conventions are very significant for CCS. The legal uncertainties on certain CCS project configurations being able to store C02 in the sub -seabed have been removed for the London Protocol and the legal prohibitions removed for OSPAR (when the amendments are ratified). The removal of the prohibition also brings with it a requirement for the activity to be regulated and subject to apermitting process. Considerable guidance has been developed to assist with this regulating and permitting process: London's RAMF and the C02 Specific Guidelines, and OSPAR's Guidelines and FRAM. These guidelines mean that operators and regulators have clear guidance on what information and procedures are required to un dertake CO 2 geological storage in the marine environment. They establish several key principles for CCS:

• A detailed site characterisation and risk assessment should be undertaken in advance of permitting and operation, including modelling of the C02 behaviour.

• Risk assessment should be undertaken on a site by site basis.

• The C02 stream can contain impurities from the CCS process, but at levels governed by their impacts on integrity and set on a case-by-case basis.

• Detailed monitoring programmes are requ ired.

• Monitoring can reduce and cease when the likelihood of adverse environmental effects has reduced to an insignificant level.

• Mitigation and remediation plans are required.

• Site closure plans are required.

In addition, these guidelines and the legal amendments are specifically for storage only in geological formations, not in coal beds, oil and gas shales, basalt, salt caverns or water column. If these were to be used, further guidelines and principles would be required. Storage in the water column or on the seabed is explicitly prohibited by OSPAR.

Further, both the London RAMF and the OSPAR FRAM provide glossaries which to ensure consistency of terminology with the IPCC SR and GHG Guidelines. However, one striking example of a difference is in the title terminology. The London Convention uses 'sequestration' and OSPAR uses 'storage' The term sequestration was used initially at the outset of work in London, it was thought better to avoid confusion by keeping the original term.

Some might view this also as reflecting the North American influence in the chairing. OSPAR chose to use 'storage', following the IPCC terminology, and reflecting a more European influence

7. Conclusions

These marine conventions are good examples of evidence -based regulatory development in a new area which brought together marine, climate and energy scientists and regulators, and key principles determined within them will have wider implications for future CCS regulation and projects. Whilst not too prescriptive quantitatively, these allow flexibility in application and therefore allow learning from experience in this new activity.

The pace of change of these conventions reflects the sense of urgency arising from the evidence of environmental damage to the marine environment from C02 emissions, as well as the change to the climate.

Following the success of these conventions, the key principles established by the London and OSPAR C02 developments are now being reflected in the European Commission's proposed Directive on Geological Storage of

Acknowledgements

Full acknowledgements are made to Marit Solheim from Norway Ministry ofEnvironment and Aart Tacoma from the Netherlands Ministry of Transport, Public Works and Water Management, who, with the authors, were very involved in leading muchof this work. Acknowledgements also to the working group s' chairmen and all the experts and participants who contribut ed to the numerous working group meetings.

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