The inclusion of CCS in the CDM has been discussed since 2005 after the publication of a report by the IPCC. It was solicited by CCS projects developers that hoped that the CDM would provide a framework at an international level. However this inclusion has been questioned on several points that we listed hereunder.
Risks
Since the beginning, CCS has been seen as a young and controversial technology. The capture technology is a safe process, however some actors still consider risky the storage of CO2 deep under the earth.
There is first a risk of leakage at several levels: during the transportation process as well as at the point of injection, pipes can break due to the heavy pressure applied on the liquified CO2.
The other risk is the degasification of the storage site. Such phenomena have been observed in the past, such as the degasification of Lake Nyos in Cameroon in 1986. A large amount of CO2 was stored under the lake, which was suddenly liberated due to environmental conditions. The emission of a large cloud of CO2 led to the suffocation of 1700 people and 3500 livestock in the vicinity of the lake.
Given those risks, many actors have called countries to increase their expertise and knowledge of CCS technologies before the inclusion.
Site selection and management
To avoid accidents such as Lake Nyos, assessment criteria for the selection of a site for a CCS plan must be clarified. Some actors such as the European Union and Norway notably expressed their opposition to the burying of CO2 under marine soil.
Once the site has been selected according to proper criteria, standards for the management of the site must be established. As carbon storage plants are to be watched over several decades, a tight monitoring, control, and verification process of these plants has to be implemented.
Liability
Risk managing is a crucial aspect of a CCS project. If an industrial accident is caused by CCS, guidance should be given as to decide who is liable for this accident between industrial or public entities for instance.
Legal framework
The inclusion of CCS in the CDM was first requested in order to foster the development of a legal framework for CCS projects.
The actors of this controversy have been debating on how deeply this legal framework should be developed by the CDM. They have also questioned whether it should be partially developed at a national level rather than by international entities in its entirety.
Cost
CCS is an extremely costly technology. It is estimated that if it costs $1.5 billion to build a power plant, it would cost an additional $700.000 to just build the adapted capture equipment. This would then impact on the electricity bills of consumers, who might not be ready to incur a higher cost for a greener energy.
By emitting CER credits, the CDM hopes to lower the cost of CCS projects for developing countries, giving incentives for Annex I countries to finance them. However, CCS projects are to last for decades while CER credits are rather short-term.
Helping developing countries achieving a greener development
As we just saw, CER credits in the frame of the CDM are meant to alleviate the cost of implementing a CCS project in a developing country. Even if it does, it might not be sufficient, as such a project has to be developed on a large scale to be profitable.
Some actors also deem that the inclusion of CCS could impact on the equitable distribution of other CDM projects, as a great deal of the funds provided by the CDM might be required for this one project.
A fake solution to climate change mitigation
CCS does limit the emission of CO2 in the atmosphere, however it has been heavily criticized for not reducing the emissions of CO2 by the industry in general. For some, developing CCS hinders the development of cleaner energies and technologies, contradicting with the principles of the CDM and the Kyoto Protocol.