We are spearheading climate change mitigation solutions that involve capturing, transporting, and injecting greenhouse gases into geological storage sites.
In April 2022, HEREMA was appointed as the licensing authority for the geological storage of CO2, including the issuance of exploration and storage permits. This also includes the overall management of the rights of the Hellenic state for the storage of CO2 and other gases and liquids, such as natural gas and hydrogen (Law 4920/2022, Government Gazette A '74/ 15.04.2022).
WHAT IS CCS TECHNOLOGY?
CCS refers to several processes that capture and store carbon dioxide emissions, generally from industrial processes. CCS stands for “Carbon Capture and Storage,” comprising three general steps: Carbon dioxide is first captured at the source, then transported – primarily via repurposed gas pipelines or ships – and finally stored underground within the bedrock, including depleted oil and gas reservoirs.
CCS is a critical climate change mitigation technology because it limits the quantity of CO₂ emissions released into the atmosphere by hard-to-abate industries by capturing CO₂ and then storing it securely. As a technically mature technology, CCS can enable the decarbonization of heavy emitting industrial sectors, while it is also set to play a crucial role in the development of a hydrogen economy.
Clean hydrogen includes blue hydrogen – derived from natural gas and carbon sequestration – and green hydrogen – produced from renewable electricity and electrolysis. As a result, CCS projects will be key in the development of a long-term hydrogen development strategy.
HEREMA’S MAIN RESPONSIBILITIES
As the licensing authority for CCS projects within the Greek territory, HEREMA’s responsibilities include:
Reviewing and evaluating CO₂ storage applications for licensing approval ensuring all technical, economic, environmental, and legal conditions are duly satisfied.
Evaluating potential subsurface storage locations to assess potential storage structures leveraging existing and up-to-date geological data.
Guiding potential applicants through the licensing process.
Collaborating and engaging with project developers for the successful completion of CO₂ storage projects.
REGULATORY FRAMEWORK
Carbon Capture and Storage projects are regulated by Directive 2009/31/EC of the European Parliament and of the European Council dated 23 April 2009 on the geological storage of carbon dioxide, as well as by the amending Council Directive 85/337/EEC, European Parliament and Council Directives 2000/60/EC, 2001/80/EC, 2004/35/EC, 2006/12/EC, 2008/1/EC, and Regulation (EC) No 1013/2006.
Said regulations were implemented into national Greek law by virtue of Joint Ministerial Decision 48416/2037/2011. This decision sets forth the procedure for the obtainment of (1) exploration permits for the purpose of selecting carbon dioxide storage sites, and (2) carbon dioxide storage permits.
In April 2023, HEREMA, in collaboration with KPMG, released an extensive White Paper focusing on Carbon Capture and Storage (CCS) technology. The White Paper explores the intricacies of CCS technology, highlighting its capacity to significantly reduce greenhouse gas emissions. It emphasizes the need for a holistic approach to CCS adoption to align with EU and national climate goals. The regulatory landscape within the EU is thoroughly scrutinized, with an emphasis on the necessity for regulatory harmonization and clarity in CCS policies. A comparative analysis of national legislation across EU and EEA countries is presented, advocating for increased cooperation and standardization in CCS policies and regulations. Furthermore, the White Paper offers an in-depth assessment of CCS projects at both EU and global levels, showcasing successful projects and a diverse array of business models applicable to the CCS sector. A qualitative assessment is also conducted to gauge the compatibility of these business models with the Greek context.
In conclusion, the White Paper provides a comprehensive overview of CCS technology, regulatory challenges, and viable business models within the EU and Greek markets. It underscores the urgency of CCS adoption as a pivotal tool in mitigating climate change and achieving both EU and national climate objectives. The findings and recommendations outlined in the White Paper serve as a roadmap for policymakers, industry stakeholders, and investors, guiding them towards a more sustainable and carbon-neutral future.
LICENSING PROCEDURE
1
Designation by HEREMA of areas within which potential CO2 geological storage sites could be located.
2
Interested parties submit an application to HEREMA for the issuance of an exploration permit for a specific potential storage site
3
After the review and evaluation, and in case of approval of the application, HEREMA issues an exploration permit for the specific potential CO2 storage site. The exploration permit holder has exclusive rights for exploring the potential CO2 storage site
4
During the exploration stage and prior to the expiry of the relevant exploration permit, the relevant parties are entitled to apply for a CO2 storage permit, subject to the satisfaction of certain economic and technical criteria and the submission of the relevant technical and environmental reports. The holder of the exploration permit has priority for the submission of a storage permit application for the specific site.
5
If the storage application is appoved, based on a series of technical and economic criteria, a CO2 storage permit is issued for the specific site, along with a series of requirements regarding the storage work plan, monitoring and site closure procedures
It should be noted that the CO2 storage permit application must duly comply with all the legal requirements set out in Article 8 of Joint Ministerial Decision 48416/2037/201. Likewise, the future operator must prove the fulfilment of the requirements for storage operation including the total quantity of CO2 authorised to be geologically stored, reservoir pressure limits, the maximum injection rates and pressures, requirements for the composition of the CO2 stream and the CO2 stream acceptance procedure, measures to prevent significant irregularities, in addition to the proposed monitoring plan.
The European Commission can issue a non-binding opinion on the proposed storage plan in order to ensure the consistent application of the Directive's requirements across the EU, thereby enhancing public confidence in carbon capture and storage.
