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01.03.2023: Guiding principles for a CCS application as part of a CDR-strategy

Four possible guiding principles as a first design for a responsible application of CCS technologies

Main Author: Aniek van den Berg
Co-authors: Maximilian Lauer and Sam Williams


Since 2022, carbon capture and storage (CCS) technologies in Germany has boomed. CCS has never been high on the political agenda, which explains the lack of a suitable legal and strategic framework, including minimum storage targets and a plan for the required infrastructure. In all IPCC scenarios, CCS is crucial for reaching climate neutrality targets. Current worldwide CCS capacity needs to grow 175 times if we want to reach the net zero target, which shows an urgent need to upscale related technologies in the near future. In the second evaluation of Germany’s current carbon storage law, released on 22 December 2022, the government is addressing this scale up by considering the possibility of offshore CO2 storage in the Dutch and Norwegian seabed as well as storing CO2 in domestic sites. This was followed by an announcement from Germany’s Minister for Economy and Climate Protection Habeck, that a carbon storage law can be expected later this year.

CCS will soon become an important part of Germany’s industrial policy, but environmental concerns remain. The majority of current CCS projects in the world focus on CCS for commercial purposes, primarily developed to produce carbon dioxide as a resource, rather than to fight climate change. We should prevent CCS technologies to be applied as a 'quick fix' for climate protection, distracting us from the expansion of renewables, thereby indirectly supporting the conventional industrial agenda focused on extending the life cycle of the fossil fuel infrastructure. Reflecting on what applying CCS ‘responsibly’ means is an important starting point, particularly when looking ahead to the release of the German Carbon Storage Law and an EU guiding strategy on Carbon Dioxide Removal (CDR), to be released in 2023.

The application of CCS should prioritise offsetting non-abatable emissions.

Despite the current CCS technologies in use, there still is a huge knowledge-gap on the potential and planning strategy of new CCS technologies, which lead to uncertainties of the potential scale up of CDR capacities. Even if Germany would immediately start with a ramp-up of CCS, the scale-up potential is limited. The CO2 value chain requires large amounts of renewable energy on top of the energy needed to build the required infrastructure. It would be irresponsible to use CCS capacities for emissions that can be mitigated with renewables. Priority should be given to residual emissions from industries that cannot be fully decarbonized, such as process emissions in the cement and chemical industries, or where direct electrification is not possible.

CCS applications should be part of a comprehensive CDR strategy, which distinguishes different forms of CCS activities.

CCS as applied in Bioenergy Carbon Capture and Storage (BECCS) and Direct Air Capture and Storage (DACS) is different from carbon capture at the power plant. The post-combustion process reduces emissions by industrial plants, while BECCS and DACS can be categorized as technology-based carbon dioxide removal activities, extracting CO2 directly from the atmosphere, just like reforestation stimulates natural carbon dioxide removal. Both CCS focusing on emission reduction and CCS focusing on carbon dioxide removal capture and store CO2. Yet, they deliver different climate benefits looking at industrial processes. Emission reduction activities target real-time emissions, leading to lower GHG emissions directly related to an industrial process, while CDR activities compensate for past GHG emissions or indirect emissions. This urges an articulation of separate definitions that pay attention to these different forms of CCS activities, something that is lacking in the latest European Commission Carbon Dioxide Removal Certification Framework proposal. These definitions should also clearly refer to a minimum storage period. This will ensure that carbon remains stored permanently, contributing directly to climate change mitigation. Clear definitions avoid confusion about the criteria for future carbon credits related to CCS, and facilitate the right policy integration with the Emission Trading System (ETS). Any German CCS framework should be able to follow clear EU guidelines accordingly.

BECCS and DACS should be developed in parallel with 'end-of-pipe' CCS.

Since DACS and BECCS have the potential of generating negative emissions, they are a central part of CCS strategies. Producing negative emissions is necessary to reach net zero. While the scale-up of CCS should start today rather than tomorrow, these technologies are still in an early development and research stage. Cutting off residual emissions with ‘end-of-pipe’ technologies in power plants has been happening since the 1970s. These capturing technologies are available on the market and can be scaled up much faster compared to BECCS and DACS, which are still very costly and energy intensive. The processes required for DACS need two to five times more energy than capturing CO2 from natural gas combustion, coal combustion, and coal gasification, hence still way less efficient than ‘end-of-pipe’ technologies. BECCS and DACS technologies might only make significant contributions to climate mitigation from 2050. They offer new opportunities for the German economy and its competitiveness, but a tunnel vision for economic reasons should never slow down the expansion of available CCS technologies targeting climate change mitigation.

High-quality certification for CCS should take into account its negative externalities.

The application of CCS itself is not climate neutral, it comes with high energy consumption, and impacts on the environment. CCS value chains require a lot of energy and raw materials to develop the infrastructure needed, and to keep the processes running. The indirect emissions that will be produced by those processes should be taken into account from the very beginning of the design of any kind of CCS certification, to guarantee the technologies bear climate benefits. As long as these emissions are not calculated and assessed with life cycle assessments, a certification scheme for CCS could lead to greenwashing. For example, cutting CO2 directly from the air, which is done in the case of DACS, is an extremely energy-intensive process, as CO2 is much more diluted in the atmosphere compared to the flue gas coming from power plants. The nett climate benefits of DACS will therefore be much smaller than the carbon capturing capacity of a DAC plant. BECCS comes with additional local environmental impacts. If the organic material needed for BECCS is grown on monocultures, or imported from developing countries where it limits local farming and food production, BECCS might contribute to GHG neutrality, but it is not a just solution.

Next steps

These four guiding principles provide a first design for a responsible application of CCS technologies. While there is a sense of urgency in developing a CCS regulatory framework, priority should be given to hard to abate sectors, in order to prevent any slowdown in the increase of renewable energy sources. CCS is essential to reach carbon neutrality, but only through a responsible approach that considers the possible side effects of CCS, and recognises a clear difference between reducing emissions and CDR activities. The next steps should focus on how a just ramp-up of CCS can be incentivized. These should include risk management strategies to prevent harm to local communities and ecosystems, and financial and legal requirements for developing CCS projects and an open infrastructure, accessible for both EU and non-EU countries.