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GLOBAL CCS INSTITUTE
OVERVIEW OF CCS LAW AND REGULATIONGlobal CCS Institute Members’ Meeting, Wednesday 5 October 2011
CCS Regulatory Test Toolkit in Romania
Author: Cristiana ION*, presenter: Constantin Stefan SAVA**
* Ministry of Economy, Trade and Business Environment - METBE
** National Institute of Marine Geology and Geoecology - GeoEcoMar
GLOBAL CCS INSTITUTE
• Developed by the Institute based on an exercise testing the existing regulatory and consenting framework for CCS in Scotland
• Enables the evaluation of the adequacy of pre-existing regulatory practices to regulate the entire CCS chain
CARBON CAPTURE AND STORAGE REGULATORY TEST TOOLKIT
regulate the entire CCS chain
• Assistance to regulators to address gaps and obstacles to the deployment of the technology
• Takes a CCS project application through the approval process in a regulatory test exercise
• Suitable for national and regional governments
• Published in February 20111
GLOBAL CCS INSTITUTE
CCS REGULATORY TEST EXERCISE OVERVIEW
1. PLANNING AND PREPARATORY PHASE
2. ‘PROJECT SIMULATION EXERCISE’ THROUGH A DEDICATED WORKSHOP
3. ANALYSIS OF THE PROCESS AND DEVELOPMENT OF AN ACTION PLAN
Resources and
Governance
Stakeholder
EngagementEvent Preparation Workshop Event
Operate Revised
Steering Group
Regulatory
Analysis
Spread the
word
Resources and Governance
Stakeholder Engagement
Regulatory Analysis
Workshop
GLOBAL CCS INSTITUTE
ROMANIAN EXPERIENCE
• Managerial level of support required from Government - Ministry of Economy, Trade and Business Environment
• Steering committee was created:
– Held four (4) meetings prior to CCS Workshop;
– Included external presentations by the EC, IEA and Scottish Government.
• Timeframe - six (6) months for completion of Toolkit:
– Three (3) weeks for preparing first draft of Matrix;
– Six (6) weeks for running the draft Matrix by steering committees;
– Four (4) weeks for organizing the CCS Workshop;
– Eight (8) weeks for drafting the workshop report.
• Consultant contracted on behalf of Government
• Used Romania’s Getica CCS Application for NER300
• Two (2) day CCS Workshop
GLOBAL CCS INSTITUTE
MAPPING INTERESTS AND STAKEHOLDERS
SafetyEnvironmental
impact assessments
Compression plant Chemicals
StorageExploration
Pipes
Safety
Environmental impact
assessments
Containment
Closure
License
Injection
LeasePermitting
Pipes Injection
National geological
survey
Regional planning
authorities
Energy ministryHealth and safety
regulatorEnvironment agency
Pipeline operators
Oil and gas operators
NGOs
Engineering firms
Local publics
Government planning
departments
GLOBAL CCS INSTITUTE
MATRIX (I)
• The structure of the matrix addresses the three components of the CCS chain: capture, transport and storage
• Each of the components is then divided into four phases: planning & construction, operation, decommissioning, post-decommissioning
• For each phase, the matrix lists the relevant e.g.,• For each phase, the matrix lists the relevant e.g.,
building/environmental/health & safety permits/licenses
• For each permit/license, the matrix lists the relevant applicable legal provisions, identifies authorities in charge, timeframe for obtaining the permits and comprises a section presenting implications of country specifics on the permitting process
• Next slide shows a sample of the Romanian matrix
GLOBAL CCS INSTITUTE
Place in CCS
Chain
Permit Area Covered Legal provisions Competent
Authority
Timing Work needed to complete
submission
Legislative
amendments
Comments
CAPTURE /
Operation
CAPTURE /
Decommissioning
Decommissioning
Permit
Decommissioning/Constr
uction&Planning
Law no. 50/1991;
Order 839/2009;
Local (Turceni) City
Hall
30 days Complete technical
documentation must be
submitted.
Same conditions as for
building permit.
TRANSPORT /
Design &
Construction
TRANSPORT /
Operation
TRANSPORT /
Decommissioning
Presentation memorandum,
notification for hazardous
substances, safety report.
In practice, timing may
exceed 4 (four) - 5 (five)
months.
Environmental
agreement
Decommissioning/Environ
ment&Water
Order no. 135/2010;
GD no. 445/2009;
EO no. 195/2005;
Regional authority
for environmental
protection
30 days All documents requested by
urbanism certificate.
One building permit per
section of the pipeline per
county.
[Maximum 60 days.] ANRE should develop
corresponding legislation.
Issued upon
completion EIA
Building Permit Design&Construction/Con
struction&Planning
Law no. 50/1991;
Order 839/2009; Law
no. 350/2001; Law
10/1995.
County Councils
Regional authority
for environmental
protection
6 (six) months Location report, safety report.
CAPTURE /
Design &
Construction
In practice, timing may
exceed 4 (four) - 5 (five)
months.
GD no. 445/2009
should be amended
to cover CO2
capture, transport
and storage.
Presentation memorandum,
notification for hazardous
substances, safety report.
Issued upon
completion of the
EIA
Order no. 135/2010;
GD no. 445/2009;
EO no. 195/2005;
Regional authority
for environmental
protection
Transport license Operation/Energy &
Infrastructure
EGO no. 64/2011 ANRE
EO no. 152/2005;
Order no. 818/2003;
Order no. 36/2004
Design&Construction/Envi
ronment&Water;
Construction&Planning
Environmental
agreement
IPPC permit Operation/Environment &
Water
MATRIX (II)
Exploration permit Design&Construction/App
raisal/Construction&Plann
ing
EGO no. 64/2011 ANRM [90 days from
submitting the final
exploration report.]
[ANRM should
develop
corresponding
legislation.]
The exploration permit should
include any requirements for
workover approvals.
STORAGE/
Operation/Injecti
on
STORAGE/Decom
missioning
Opinion of the EC
on operator's
report for approval
of the transfer
Post-
decommissioning/[xxx]
European
Commission
Transfer of liability
to ANRM
Post-
decommissioning/[xxx]
[xxx] ANRM Approval of transfer report. [ANRM should
develop
corresponding
legislation.]
The issue of the financial
security should be
addressed.
The environmental approval for
decommissioning is required.
Maximum 90 days
as of submission of
complete file
Layout, location plan, minutes
ascertaining compliance with
obligations in the
environmental agreement.
It may include a conformity
programme.
Environmental
permit
Operation/Environment&
Water
Order no. 1798/2007 Regional authority
for environmental
protection
substances, safety report. months.
Storage Permit [xxx]Design&Construction/Inje
ction/Construction&Planni
ng; Energy &
Infrastructure
EGO no. 64/2011 ANRM
EO no. 195/2005; protection
Decommissioning
clearance
Decommissioning/Energy
& Infrastructure
[xxx] ANRM
Appraisal
Injection
STORAGE /
Design &
Construction /
Appraisal
STORAGE /
Design &
Construction /
Injection
GLOBAL CCS INSTITUTE
CCS WORKSHOP - OVERVIEW OF THE TWO DAYS (I)
• Eighty (80) people attended:
– Managerial level of public authorities representatives
– Delegates from the EC, IEA, GCCSI, UCL
– Schlumberger and Alstom (members of the technical consortium for Romania’s Getica CCS Application) gave presentations on capture technology and site characterization
• The event was held in Romanian; English translation was provided
• Main facilitator: Mr. Nicolae Anastasiu, PhD, geology high profile academic
• Associated facilitator: Mrs. Cristiana Ion, representative of the Ministry of Economy, Trade and Business Environment
GLOBAL CCS INSTITUTE
CCS WORKSHOP - OVERVIEW OF THE TWO DAYS (II)
• The workshop was held outside of Bucharest to make sure all attendees stayed for the two days
• Used Romania’s Getica CCS Application for NER300 - different from Scottish test - all the project proponents attended and gave presentations
• The workshop was structured into four (4) working sessions:
– Capture
– Transport
– Storage
– Final remarks
• Summary remarks after each session
GLOBAL CCS INSTITUTE
CAPTURE (I)
• Presentation by CEN Turceni (major power producer) on permits, and by ISPE and ALSTOM on technology
• Competent authority: environmental authorities
• Discussion centered around • Discussion centered around the environmental impact assessment: integrated or divided approach
• Lack of understanding of the technology by many of the authorities
GLOBAL CCS INSTITUTE
CAPTURE (II): SUMMARY
• Following discussions, the following points emerged as requiring further consideration:
– One environmental impact assessment for the entire CCS chain or one environmental impact assessment per each component of the CCS chain
– Water management approval
– Greenhouse gas permit
– Level of impurities
10
GLOBAL CCS INSTITUTE
TRANSPORT (I)
• Presentation by Transgaz (gas national transport company) on permits, and by ISPE on technology
• Competent authorities: local public authorities, public authorities, environmental authorities and water authorities
• Discussion centered around land use and urbanism considerations as the project is of national interest
11
GLOBAL CCS INSTITUTE
TRANSPORT (II): SUMMARY
• Following discussions, the following points emerged as requiring further consideration:
– Zonal Regional Spatial Plan
– Law no. 255/2010 on expropriation for public utility purposes should be amended to declare CCS projects as projects of public utility which would reduce the bureaucratic burden of the terms and procedures for obtaining required permits/approvals/authorizations
– Coordination between local public authorities
12
GLOBAL CCS INSTITUTE
STORAGE (I)
• Presentation by Romgaz (gas exploitation and storage national company) on permits, and by Schlumberger and GeoEcoMar on storage site characterization
• Competent authorities: National Agency for Mineral Resources Agency for Mineral Resources (NAMR), environmental authorities and water authorities
• NAMR is confronted with a need of increasing institutional capacity
• The crucial role that the drafting of the secondary legislation will play
13
GLOBAL CCS INSTITUTE
STORAGE (II): SUMMARY
• Following discussions, the following points emerged as requiring further consideration:
– Improvement of access to data on existing wells
– NAMR will draft secondary legislation for the issuance of the storage permit and management of relationship with the operatoroperator
– Hydro-geological studies should be drafted
– Jiu River Management Plan should be consulted
– Collaboration Methodology: NAMR and national agency for environmental protection have to determine the methodology for their collaboration on GHG monitoring plans
14
GLOBAL CCS INSTITUTE
KEY LEARNINGS
• The workshop debates led to the following five (5) key learnings:
– Institutional capacity: has to be increased to improve the permitting process; authorities need a better understanding of the CCS technology
– Public engagement: the engagement of the local communities in the area of the project is crucial
– Environmental Impact Assessment: divided or integrated – Environmental Impact Assessment: divided or integrated approach of the three (3) CCS components
– Co-operation and joint working across Governmentdepartments and regulators will be essential
– Early stakeholder engagement is key to streamlining the regulatory process and improving design
15
GLOBAL CCS INSTITUTE
ACTIONS
• The following actions were identified:
– Targeted briefings on the technology to the different agencies by technology providers
– Increased engagement with the Project Company (3 stakeholders) and the regulators(3 stakeholders) and the regulators
– Follow-up event on a specific topic (rather than another workshop with all) e.g.,: developing secondary legislation
– Public information campaigns in the local areas that will be affected by Romania’s Getica CCS Project
16
GLOBAL CCS INSTITUTE
NEXT STEPS
• The following next steps were decided upon:
– Continued activities of the inter-ministerial working group on CCS
– The development of action plans assigning responsibilities at – The development of action plans assigning responsibilities at ministerial level
– Creation of small inter-ministerial working group on regulatory issues
– Improvement of existing CCS specific legislation
17
GLOBAL CCS INSTITUTE
THANK YOU!
18
THANK YOU!
www.globalccsinstitute.com