Bellona provided a response to the consultation in July 2014, and is now pleased to see that several of our points were taken aboard. Particularly welcome is the recommendations of an Emission Performance Standard (EPS), to set an emissions ceiling for fossil power plants that can in effect only be achieved with CCS. Bellona is a strong advocate for the establishment of an EU-wide EPS for CO₂ from power plants and sees it as an important measure to prevent lock-in to the worst-polluting infrastructures and a catalyst for CCS deployment. Bellona commends the already existing EPS in countries, such as the US, Canada and the UK.

Another key recommendation is for a CCS target to be set for 2030. And finally, for the Member States’ national decarbonisation plans to include CCS (or else explain how they are going to meet 2050 climate targets without it). Both these measures will help to build clarity on the future development of CCS in Europe; this is required to enable the investments required to drastically cut CO₂ emissions from industry and energy production.

The report lists a number of recommendations on the basis of the stakeholders’ inputs:

• Member States should be requested to develop national 2050 roadmaps, based on an 80% emission reduction target and including an assessment of whether or not CCS is required;
• An EU roadmap for CCS with binding targets for 2030 should be developed and CCS should be integrated into the ongoing 2030 national roadmaps if needed;
• The successor of the NER300 should be finalised as soon as possible, drawing on the experience and lessons learnt from NER300;
• An EU-wide “CO₂ storage: appraisal of CO₂ injectivity and storage capacity” document should be developed;
• The ETS should be substantially strengthened to support the business case for CCS;
• The use of an EPS under diverse scenarios and its relationship to the ETS should be explored;

Apart from calling for the aforementioned steps, Bellona also made the point that a lack of CCS projects in Europe has meant the Directive has not really had a chance to ‘work’. In other words, the overall impact of the CCS Directive has been underwhelming, not primarily because of its content, but because of a lack of CCS projects on which to apply it. The consultation has correctly identified the lack of progress on CCS deployment is a result of an almost total lack of policy support measures to enable CCS deployment. According to the final report, the majority of stakeholders share this view.

The stakeholders views, as summarised in the report, also see the Directive as having had some positive effects on addressing health and environmental concerns and harmonising between EU Member States.

However, as the Directive deals primarily with the practicalities CO₂ storage, it alone does little to help establish CCS infrastructure or define the role of CCS in the EU’s climate and energy policy. The consultation shines a spotlight on this huge policy omission. Bellona fully welcomes the consultations call for an EU-wide EPS, CCS national plans and an EU CCS target. Bellona also agrees with the need for detailed CO₂ storage appraisal, a debate Bellona has contributed to in detail (Scaling the CO₂ storage industry: A study and tool).

Bellona is currently preparing its response to the EC consultation on the ETS Directive which seeks inputs with regards to establishing the legal basis for the innovation fund, or so-called NER400.

Bellona’s full response to the CCS Directive Review Survey can be viewed here.