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CCS and the Environment

CCS and the Environment. Regulating Point Emitters. Dr. Kars de Graaf K.J.de.Graaf@rug.nl. Obligating Capture in EMA-permits?. Legal framework for reduction of emission Emissions Trade Scheme since 2005 Legal obligation for capturing of CO 2 ? IPPC and EMA  Best Available Techniques

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CCS and the Environment

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  1. CCS and the Environment Regulating Point Emitters Dr. Kars de Graaf K.J.de.Graaf@rug.nl

  2. Obligating Capture in EMA-permits? • Legal framework for reduction of emission • Emissions Trade Scheme since 2005 • Legal obligation for capturing of CO2? • IPPC and EMA  Best Available Techniques • Capturing CO2 is not (yet?) a BAT • Groningen: Capture Ready from 2010 • Impact of proposed Directive • Large Combustion Plants Directive (Art. 32) • IPPC Directive (Art. 30)

  3. Environmental Impact Assessment? • Legal framework EIA for (new) emitter • SEA/EIA Directive in EMA and EIA-Decree • No reference to capture-installation or CO2-pipeline • But: large combustion plan: > 200 Mw and storage of large amounts of waste • Impact of proposed Directive • Pipelines if longer than 40 km • Storage sites • Capture-installations

  4. Should CO2 be regarded as waste? • Legal framwork for waste • Waste Framework Directive: any substance or object [..] which the holder discards or intends or required to discard  CO2 • Possible consequence: storage is last resort • Recent amendments to London Dumping Convention and OSPAR-treaty makessub-seabed storage possible • Impact of proposed Directive • Captured CO2 is excluded from Waste Framework Directive

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