Securing the Australian CCS project rollout by improving aspects of the GHG storage legislation: a discussion paper

The respective Federal petroleum and greenhouse-gas (GHG) storage legislation was examined in detail to understand the interactions between the technical requirements in the legislation, the overarching emissions-policy framework and the existing and likely future technical capabilities of the carbon capture and storage (CCS) industry. Key elements of the GHG legislation were then stress-tested using CCS project examples to determine applicability. The number of CCS projects required to meet the nation’s emission reduction targets over the next 5–25 years is high (probably between 20–40 projects of 4 million tonnes per annum (Mtpa)), but the existing 8–10 year approvals timeline provides only a maximum of 2.5 full project cycles to undertake 20–40 projects, a goal not considered possible without substantial regulatory reform. Opportunities for improvement should focus on facilitating a robust and rapid CCS project rollout and could include the following: changing the legislation to facilitate the accelerated utilisation of depleted petroleum fields to storage facilities, including allowing the progressive expansion of the awarded injection licence (IL); changing the concept of containment to emphasise carbon dioxide (CO2) plume management via assessing risk and potential impacts, not by artificial constraints into GHG permits and licences; including unitisation and combination pathways in the GHG legislation; ‘CO2 plume’ is not defined in legislation, even though the spatial location of a plume is central to numerous approvals, such as declaration of storage, demonstrating containment and all measurement, monitoring and verification (MMV) programs; developing a framework to manage future CCS project interactions at a basin scale, as is undertaken in groundwater management onshore.