On December 8, 2023, the Japanese government released the Draft Interim Summary on the institutional measures for carbon dioxide capture and storage (CCS), the practice of capturing CO2 emissions and storing them underground, and solicited public comments.

The topic was discussed and summarized by the Subcommittee on Basic System for Industrial Safety, the Sectional Committee on Safety and Consumer Product Safety, the Industrial Structure Council / Subcommittee on Carbon Management, the Sectional Committee on Energy Resources, and the Advisory Committee for Natural Resources and Energy under the Energy Resources Development Division, New and Renewable Energy Division, Agency of Natural Resources and Energy (ANRE), Ministry of Economy, Trade and Industry (METI).

The draft interim report summarizes the results of the discussion on institutional measures for CCS, positioning the capture and storage of CO2 emitted from hard-to-abate sectors as a solution to achieve carbon neutrality by 2050. However, CCS projects are facing implementation issues such as lack of stable and suitable storage sites in Japan, future monitoring risks, and high costs, as well as legal issues such as where responsibility for leakage lies. This draft interim report falls short in addressing these issues.

Problems with the draft interim report:

1. The continued use of fossil fuels (including fossil fuel-derived compounds such as hydrogen and ammonia) is contemplated based on the use of CCS in the power generation sector, which is not appropriate as a climate change countermeasure.
2. The method of calculating the necessary amount of CCS itself needs to be reconsidered, but the continued use of thermal power generation with CCS should not be considered in the first place.
3. The technologies to separate, capture, transfer and store CO2 have not been established yet. Since safety of these technologies (stability or storage sites, health effects due to exposure to high concentrate CO2 leakage, etc.) has not been ensured, these technologies should not be relied upon.
4. It is not clear who conducts assessment and bears responsibility for the impacts of CCS projects and post-injection monitoring.
5. It is an attempt to move ahead with financial and legal arrangements to promote CCS, even though the legislative details are not finalized yet.

Details are explained below:

Very few successful examples of CO2 storage (mechanism issues)

There are very few examples of CCS projects implemented worldwide, and it cannot be said that the CCS business has been successful. The few cases that have been found are those using the enhanced oil recovery (EOR) method, and although demonstration tests have been conducted in various parts of the world, some have been canceled due to problems related to cost and permanent CO₂ sequestration. There are no successful cases of large-scale, long-term CO2 storage.

According to a survey by the Japan CCS Co. (JCCS), there are 11 possible sites that can store approximately 16 billion tons of CO2 in Japan (interim summary, p.5), but the summary neither describes specific locations, nor data on how the survey JCCS conducted judged whether or not a site was capable for long-term stable storage. Four factors will be considered in order to narrow down possible sites: 1) Capacity, 2) Injectivity, 3) Containment, and 4) Integrity. However, the impact assessment on the surrounding area (including sea area), consideration for local communities or affected industries (e.g. the fishing industry) and evaluation of cost for injection must also be taken into account.

Risk Management – Monitoring System and Responsibilities

Regarding the monitoring of the long-term storage site, although there is a statement that the storage operator should be obliged to monitor the stored CO2 (p.18), in the section titled “Conclusion of the Project and Subsequent Responses” (p.14), it is stated that “the operator will close the storage site and transfer management operations to the competent authority after receiving permission and approval from the competent authority,” when operators complete the CO2 injection into the ground. This description makes it unclear as to where the responsibility lies after sites are closed. It should be clarified that a certain level of responsibility remains with the operator, and a system should be established to ensure that the operator is aware of the long-term risks involved in the project.

Institutional measures for CCS

CCS projects will involve multiple operators at each stage of separation and capture, transportation, and storage. In particular, when it comes to CO2 transport and storage to sites outside of Japan (storage in Malaysia is already included among the seven advanced CCS projects), it will be necessary to design an institutional system that transcends national boundaries. As noted in this interim summary report, at present there is no legal mechanism to enable semi-permanent and stable storage of CO2. It is necessary to consider not only domestic prospecting and storage rights, but also an international system. Similarly, it is necessary to develop an international legal system for marine pollution and maritime disasters.

The report notes, “In order to ensure the stable operation of storage projects, it is essential to properly address risks that may be of concern in the execution of the project, maintain public safety, and prevent the occurrence of disasters” (p.20).  However, it is concerning that the report does not mention disclosure of information regarding the risks of the projects, and responses to those risks, to the public.   

High costs of CCS

Cost is also an important factor in CCS projects. The IPCC Sixth Assessment Report, Working Group III Report points out that the lifetime cost of CCS is high and this technology will not contribute to emission reductions by 2030. The lifetime cost of CCS should be presented not only for domestic storage as stated in the interim report, but also for storage outside of Japan, with more concrete and clear estimates.

Additionally, an enormous amount of money is needed to establish the CCS business environment. Based on the GX sector-specific investment strategy, the government has stated that it will promote the development of the business environment, focusing on upfront investment support and institutional measures for CCS so that CCS projects can be promoted in an internationally competitive manner (p.31), and aims to commercialize CCS in 2030 (p.35). However, it makes no sense to calculate the annual CCS storage volume according to Japan’s emission rate from the annual global CCS storage volume shown in the International Energy Agency’s report “World Energy Outlook 2021,” and set this as the target.

The government not only considers CCS important as a last resort in sectors where emission reductions are difficult to achieve, but also as the key part of an energy policy that includes the continued use of fossil fuels. Even if CCS is technically feasible, it would be a mistake to neglect efforts to reduce CO2 emissions by relying on measures that have not even determined where and how much CO2 can be stored.

The draft interim report: Institutional measures for CCS (PDF, written in Japanese) (PDF)

For your reference, the Submarine CCS System Expert Committee, Water Environment and Soil Pesticide Subcommittee, Central Environmental Council, under the Marine Environment Division of the Water and Atmospheric Environment Bureau of the Ministry of the Environment (MOE), has completed discussion and solicited public opinions on “The future conservation of marine environment related to CCS under the seabed (Draft proposal).”

The future conservation of marine environment related to CCS under the seabed (Draft proposal) (PDF, written in Japanese) (PDF)

Although the government claims that public understanding is indispensable in deciding on such important energy policy, the fact that they were quietly conducting public commentary over the year-end and New Year holidays suggests a disregard for the public’s understanding.