Consultation on modernising environmental permitting for industry
Carbon capture activities
In the transition to net zero the role of carbon capture is evolving with several types of carbon capture technologies emerging. Carbon capture needs effective regulation in the EPRs as capture technologies can use amine solvents in the process, which can create nitrosamines and other pollutants when released into the air.
Currently the permitting framework only covers one specific activity – capture of carbon for the purposes of geological storage. However, proposals for new plants, including both for storage and utilisation, are already coming forward.
The regulated activity under the EPRs Schedule 1 Part 2 Chapter 6 Section 6.10 Part A(1)(a) is defined as:
“Capture of carbon dioxide streams from an installation for the purposes of geological storage pursuant to Directive 2009/31/EC of the European Parliament and of the Council on the geological storage of carbon dioxide.”
Where carbon is captured for utilisation and the plant is part of an EPRs schedule 1 Part 2 installation, then the regulator can permit this as a directly associated activity (DAA).
However, certain carbon capture activities are not currently covered by the regulations, for example, carbon capture for storage or utilisation on standalone medium combustion plant (MCP), and direct air carbon capture (DACC). This means that operations that could have similar environmental risk are treated differently. A particular capture technology (such as amine absorption) will present the same environmental hazards whether the captured CO2 is going to geological storage or utilisation.
We are minded to consult on amending the EPRs to address these regulatory gaps and include different carbon capture activities in the regulations. These would include:
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carbon capture for geological storage
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carbon capture for utilisation
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carbon capture technologies such as DACC
This would provide a level playing field, support the deployment of carbon capture technology, and ensure environmental risks are appropriately managed. We would appreciate views on the case for and against extending regulation in this way.
Other emerging capture technologies, such as solid-state capture, may have different environmental risks. As different capture technologies emerge and develop, they too should be regulated in a way which is proportionate to the level of risk to the environment.