Implementation of Directive 2009/31/EC on the Geological Storage of Carbon Dioxide

The Zero Emissions Platform (ZEP) provided feedback on the EU’s draft guidance documents for implementing Directive 2009/31/EC on the geological storage of CO2. ZEP emphasized the need for flexibility during the demonstration phase of Carbon Capture and Storage (CCS) projects to ensure their viability.

Key recommendations include:

• Flexibility in CCS Demonstration Phase: Ensure adaptable approaches to support the viability of early-stage CCS projects.

• Risk-Based Site Characterization and Monitoring: Implement risk-based methodologies for assessing and monitoring CO2 storage sites.

• Criteria-Based Responsibility Transfers: Use criteria-based frameworks (rather than fixed timeframes) for transferring responsibility for CO2 storage sites.

• Address Financial Security and Liability: Develop balanced financial security and liability measures to avoid excessive burdens on operators.

• Incorporate Industry Best Practices: Leverage lessons learned and best practices from existing CCS projects.

• Periodic Updates to Guidance: Regularly revise guidance documents based on real-world project experiences and advancements.