Today, the Clean Development Mechanism (CDM) dialogue on carbon dioxide capture and storage (CCS) in the COP/MOP (Item 5) will be addressed as a possible technology to mitigate climate change.

Article 12 of the Kyoto Protocol states the purpose of the CDM shall be to assist Parties not included in Annex I in achieving sustainable development. The CDM should provide an important opportunity to help developing countries “leapfrog” the unsustainable fossil fuel economy.

However, it has so far failed to deliver this. In many cases only the climate benefits of projects are credited under the CDM, but sustainable development in a more general sense is not. If CCS – an expensive technology – were to be included in the CDM, it could for example divert investments from renewables and energy efficiency, and the multiple long-term benefits they provide, including sustainable development opportunities. This would allow large point sources, or major projects, to become attractive targets for this technology. Smaller projects with direct benefits for local communities but may deliver fewer Certified Emission Reductions will lose even more ground.

Proponents of CCS are looking at the CDM to incentivise the technology. However, there is no regulatory framework in place in either Annex I or non-Annex I countries which addresses the monitoring and verification of emissions reductions and ensures the carbon dioxide will be safely stored.

CAN believes the requirements needed to assure proper site selection, operating practices to assure permanent retention of injected carbon dioxide, monitoring, measurement and verification provisions, and responsibility for leakage of injected carbon dioxide should be developed before any decision is taken for CCS to be included in the CDM.

Further, CAN has specific concerns regarding CCS that should be addressed before any decision for its inclusion in the CDM takes place. They include:

• Sustainable development: The lack of adopted requirements for selection, operation and monitoring of CCS projects required to demonstrate that use of the technology will be environmentally “safe and sound”. (The Marrakech Accords make this a requirement for inclusion in the CDM.)
• Accounting and crediting: Key issues remain about what happens if leakage occurs during the project once it has been already issued with credits.
• Other issues: Issues such as permanence, responsibility and insurance against leakage need to be addressed in an adequate framework that ensures environmental integrity. CCS project operators will need to demonstrate to duly constituted regulatory authorities that storage sites have suitable geological characteristics for indefinite retention and have emergency remediation plans in place.

Given these concerns, the fate of CCS in the CDM should not be decided until these issues are resolved.

Without appropriate safeguards, certainty and establishment of a strong regulatory framework to minimise risks and liabilities to future generations and the environment, CCS could compromise the sustainable development objectives of CDM.