Review of Project Permits under the London Protocol – An Assessment of the Proposed P18-4 CO2 Storage Site

Abstract

The London Protocol (1996) is a global agreement to promote the protection of the marine environment by prohibiting the dumping of wastes and other matter into the sea. Under the Protocol all dumping is prohibited, with the exception of a limited number of selected wastes on the so-called “reverse list”, which can be considered for dumping. In 2007, an amendment entered into force which permitted CO2 streams to be considered for dumping under the London Protocol. The amendment was shortly followed up with a set of “Specific Guidelines for Assessment of Carbon Dioxide Streams for Disposal into Sub-seabed Geological Formations”, developed to support the National Authorities of Contracting Parties in evaluating permit applications for CO2 disposal activities in their marine territories. The objective of this report is to assess to what extent the proposed P18-4 CO2 geological storage site in the Dutch North Sea, originally part of the ROAD CCS Project, complies with the aforementioned guidelines, and therefore the 1996 London Protocol itself. The assessment has been achieved through a simple, but systematic, cross check of the requirements of the guideline against the contents of the application material provided by the operator to the National Authority. This assessment finds that the material submitted to the National Authority is broadly sufficient to allow an evaluation of the planned CO2 storage activities in a manner consistent with the provisions of the 1996 London Protocol. The assessment indicates overall technical compliance with the CO2 Specific Guidelines, with no information sufficiently absent to indicate clear non-compliance. There are, however, eight areas from within the application material whereby the information or justification is partially sufficient, but may require further clarification, and one area of non-compliance from within the permit conditions, which is the responsibility of the National Authority. A number of recommendations are provided.