The role of CCS in Germany’s climate toolbox: Bellona Deutschland’s statement in the Association Hearing


Publish date: April 5, 2024

After years of inaction, Germany is working on its Carbon Management Strategy to resolve how CCS can play a role in climate action in industry. At the end of February, the Federal Ministry for Economic Affairs and Climate Action published first key points and a proposal to amend the law Kohlenstoffdioxid Speicherungsgesetz (KSpG). Bellona Deutschland, who was actively involved in the previous stakeholder dialogue submitted a statement in the association hearing.

We welcome the publication of both documents and the associated recognition of the relevance of CCS as a component of climate action in industry. The integration of CCS is of central importance for reducing process emissions. Together with the ETS1 and the end of certificate allocation, CCS sets a standard for profound emission reductions in emission-intensive industries. CCS is just one component of many in the climate protection portfolio — measures to avoid emissions must continue to have priority.

From our perspective, four points are particularly relevant:

  • To not neglect nature conservation and endanger the acceptance of CCS, the CMS must present more concrete figures on land use, contain clear rules for nature-compatible land management, and show ways to compensate for impairments. The CMS must contain clear rules for meaningful CCS applications and reflect the systemic conditions of these application scenarios, including the availability of alternatives.
  • It is crucial to ensure government support for the alternatives. Otherwise, there is a risk of justified loss of trust and acceptance for CCS as an important component of comprehensive climate protection. The core of the challenges in the area of financing is the economic risk mitigation and coordination of actors along the entire CO2 value chain in the initial phase of CCS development. Concrete governance solutions for complex economic problems must be developed within the framework of the CMS.
  • The “chicken and egg dilemma” necessitates starting implementation activities before other steps are conclusively clarified. The state must be financially prepared to act as a market facilitator if no private-sector solution is found for the complex organizational problems. In the storage sector, securing economic risks will also be necessary over a longer period. The CMS and KSpTG must provide clear organizational structures for effective and transparent coordination of infrastructure development. The project management envisaged in the KSpTG should be specified with regard to its scope of tasks and working methods. The goal must be to coordinate and plan the development of connected infrastructures (e.g., offshore wind parks and CO2 storage, or pipelines, (sub) cables, and conduits) together.

Read the explanation of these points in our statement (in German).