5.5 United Nations Framework Convention on Climate Change

As a starting point, the UNFCCC and its Kyoto Protocol seek to stabilise CO2 emissions in the atmosphere at levels that will prevent dangerous interference with the climate system. CCS may assist in meeting this objective.

Parties to the UNFCCC must report emissions that are released into the atmosphere. If CO2 is captured and injected before any emissions are released into the atmosphere, then arguably no emission occurs. Yet if CO2 leaks many years after its original storage, the requirement to report on, and account for, emissions liability for those emissions may not crystallise until many years after injection.

If CCS is to be considered a viable mitigation technology in the context of the UNFCCC, it will be important to provide States with guidance on how to measure, monitor, verify, account for and report CCS activities. Consistent international guidelines on monitoring, verification and reporting are needed for both developed and developing countries that are binding under the UNFCCC.

If CCS is to be considered a viable mitigation technology in the context of the UNFCCC, it will be important to provide States with guidance on how to measure, monitor, verify account for and report CCS activities

5.5.1 Treatment in the Clean Development Mechanism

There is currently debate as to whether CCS activities should be included within the Clean Development Mechanism (CDM) under the Kyoto Protocol, to provide CCS projects in developing countries with a means to generate CERs, which can be traded in the international carbon market.

Whilst the views of the UNFCCC Parties are divergent, particularly as to whether the international rules for the CDM allow such projects to take place or should be amended to facilitate CCS, the CDM may provide incentives that would make CCS projects in developing countries viable.

The UNFCCC’s Subsidiary Body for Scientific and Technological Advice has been considering issues related to the inclusion of CCS in geological formations as CDM project activities since 2006. As a result of these deliberations, a number of issues have been raised about the appropriateness of CCS in the CDM, including:

  • risks and uncertainty of long-term physical leakage levels;
  • project boundary issues (such as reservoirs in international waters, several projects using one reservoir);
  • long-term responsibility for monitoring the reservoir and any remediation measures that may be necessary after the end of the crediting period; and
  • other relevant matters, including environmental impacts.

Under the Kyoto Protocol CDM is a private sector activity. This raises particular issues around the appropriateness of CCS under the CDM given the timelines required for monitoring, reporting and liability for damage and emission units if leakage occurs.

It seems likely, however that if CCS is included in a revised version of the CDM after the Meeting of Parties to the Kyoto Protocol in Copenhagen in late 2009 there may be an acceleration of investment in CCS projects in non-Annex 1 countries.

In the absence of a mechanism such as the CDM it seems unlikely that investment in CCS will be achieved in many developing countries within the timeframe proposed by the G8.

5.5.2 Post-2012

In the absence of a mechanism such as the CDM it seems unlikely that investment in CCS will be achieved in many developing countries within the timeframe proposed by the G8

The Fifteenth Conference of the Parties to the UNFCCC will take place in Copenhagen at the end of 2009 and is intended to be the end of a two year commitment to shape an effective international agreement to guide climate change action beyond 2012. This provides an opportunity for the role of CCS as a climate change mitigation measure within the CDM to be redefined. However, notwithstanding general support, States recognise that CDM rules will need to be developed regarding the distribution of risk between private entities and States. There also appears to be general recognition that capacity building is needed in non-Annex I Parties to ensure effective regulation of CCS projects.