CCS readiness at Šoštanj: Ticking boxes or preparing for the future?
New report finds that EU CO2 Capture and Storage (CCS) requirements were breached by Slovenia.
Two European NGOs have submitted a complaint to the European Commission about a construction permit for a new 600 MW unit of Šoštanj Thermal Power Plant in Slovenia, backed by a first-of-its-kind report on how CCS feasibility assessments should be carried out<>. According to the complaint by the NGOs Environmental Law Service and Focus, Slovenian authorities failed to meet the requirements of article 33 of the so-called CCS Directive 2009/31/EC that the planned power plant unit be permitted only after the feasibility of a CCS retrofit has been assessed.
The new expert report "CCS readiness at Šoštanj: Ticking boxes or preparing for the future?" published on 9 November was drawn up by The Bellona Foundation together with Environmental Law Service and suggests how Article 33.1 – requiring the feasibility of CCS retrofit to be assessed – should be interpreted in a meaningful way. It then applies this methodology to the Šoštanj case through a detailed analysis of the documents submitted by the project sponsors as evidence that it was "CCS ready". The report reveals that these documents submitted by the operator do not exhaust what can reasonably be expected under article 33.1 of the CCS Directive, as they lack a number of project-specific assumptions and data concerning economic feasibility of the capture, transport and storage. Furthermore, there is a lack of consideration of local geographical conditions’ impact on technical feasibility, in particular for building pipelines, etc.
The outcomes of The Bellona Foundation and Environmental Law Service’s report show that there is a clear contradiction between the statements made by the European Investment Bank, the European Bank for Reconstruction and Development, which have pledged financial support for the project and the operator’s claim that the proposed power plant unit will be CCS ready and that the criteria of the Directive were met.
Eivind Hoff from The Bellona Foundation says: "We conclude that instead of a real preparation for the future CCS retrofit at Šoštanj, the process rather turned into a "box-ticking exercise" based on desk-top research and carried out well after the unit was designed."
The project promoters claim the unit will increase the efficiency of the plant, but in fact, this one lignite-fired power plant alone will create a huge carbon lock-in by swallowing up almost the entire carbon budget of the country by 2050. The Slovenian Ministry of Economy issued in April 2011 a damning report about the project, pointing to a huge risk of it being unprofitable.
The project is to benefit the financial support from the European Investment Bank in the amount of EUR 550 million and from the European Bank for Reconstruction and Development in the amount of EUR 100 million with a further EUR 100 million syndicated to commercial banks.
*Notes to the editor:
CCS is the strategic technology that is planned to be broadly used in the future on large CO2 emission points in order to prevent emissions into the atmosphere. That is the reason why the EU agreed in 2009 that every new power plant unit above a certain capacity will have to undergo an assessment whether the suitable storage sites are available, and transport facilities and retrofitting for CO2 capture are technically and economically feasible. Although the exact wording of article 33 of the CCS Directive (2009/31/EC), which sets forth these requirements, is very brief, it is clear that it is important to be done correctly and sufficiently, thus becoming a tool potentially contributing to the attainment of the aims of the CCS Directive and EU climate policy in general.
The Šoštanj project is the first case where a CCS feasibility assessment was carried out as a result of the CCS Directive, and the content of this CCS assessment was then challenged directly in front of the Commission. Unless the Commission provides further guidance to the interpretation of article 33.1 of the CCS Directive, there is a risk of new coal-fired power plants being built across the EU without real plans and conditions for CCS retrofit, locking in huge CO2 emissions for several decades.
With the aim to contribute to this interpretation, the new report prepared by The Bellona Foundation and the Environmental Law Service draws on CCS readiness definitions to identify which questions can reasonably be addressed – at low cost – already prior to permitting of a power plant, in order to comply with the Art. 33.1 of the Directive.
In particular, this report sets out key project-specific information that should be provided in order to assess technical and economic feasibility. It contains a proposal for a methodology to assess compliance with Art. 33.1 of the CCS Directive and progress towards full CCS readiness. This report is the first detailed proposal on the content of CCS feasibility assessments and it could create a basis for European best practice. The report aims to provide constructive ideas for public authorities, investors as well as project promoters in order to avoid lock-in of long-lived carbon-intensive assets, which would hold risks both to the climate, investors and consumers alike.
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 Directive 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide and amending Council Directive 85/337/EEC, European Parliament and Council Directives 2000/60/EC, 2001/80/EC, 2004/35/EC, 2006/12/EC,
2008/1/EC and Regulation (EC) No 1013/2006.