Written evidence submitted by Nicky Crosby (POW0062)
I am a member of the public who has concerns that recent energy policy has directed subsidy towards unproven Carbon Capture and Storage technologies and generation of blue hydrogen from fossil fuels. This strategy benefits companies that are, despite clear advice from the United Nations, expanding fossil fuel extraction.
A focus on local power generation, coupled with grid development in order to be able to utilise it; and insulation would both be more effective and contribute to combatting the cost of living crisis.
5.1. Hydrogen uses should be limited to the hardest to abate sectors as indicated by the Liebrich Hydrogen ladder. Only green Hydrogen production should be developed, close to its proposed use to limit issues around transport safety and leakage.
5.2. There is growing evidence that blue hydrogen is not a low-carbon fuel, and that investment in it is misplaced. Research by the National University of Australia, comparing both emissions and economics of blue hydrogen finds ‘Establishing hydrogen supply chains on the basis of fossil fuels, as many national strategies foresee, may be incompatible with decarbonisation objectives and raise the risk of stranded assets.’
5.3. Peer reviewed research found “the greenhouse gas footprint of blue hydrogen is more than 20% greater than burning natural gas or coal for heat”. Although this is challenged by the hydrogen industry; more recent research has confirmed that upstream emissions of blue hydrogen production are not acknowledged and / or are underestimated. concluding that as much as five times more methane is being leaked from oil and gas production than reported.
5.4. Large-scale CCS projects e.g. Gorgon CCS project in Australia, Quest, a blue Hydrogen Shell project in Canada, and many others globally have failed to meet projected sequestration targets by large margins. Any net zero strategy that depends substantially on even larger, untested projects is high risk.
5.5. Although it’s widely assumed that under-sea storage is secure, there is a risk of long-term escape of sequestered gas. Recent research by the Institute for Energy, Economic and Financial Analysis (IEEFA) into Sleipner and Snøhvit, two of the North Sea fields that are frequently cited as successful models of CO2 storage, shows that there are uncertainties around security and stability. A failure of storage doesn’t only negate climate mitigation aims. It also leads to oxygen depletion, acidification and elevated CO2 concentrations in the ocean.
5.6. At present regulation associated with storage monitoring is inadequate. In their written response to 2023 AGM questions, ENI indicates that they only guarantee to monitor emissions from storage in Liverpool Bay for 20 years after the closure of the storage site.
5.7. Risks associated with the public safety risks of transporting CO2 overland are poorly understood and regulation is out of date:
5.7.1. Risk of rupture will be exacerbated by climate-change related events impacting soil stability. Investigating the 2020 pipeline rupture in Satartia, Mississippi, which led to the evacuation of approx. 200 residents and 46 people treated in local hospitals, the US regulatory authority Pipeline and Hazardous Materials Safety Administration (PHMSA) implicated a landslide triggered by heavy rains. PHMSA listed 17 significant pipeline incidents in the US due to earth movement 2018 - 2022.
5.7.2. Risks associated with repurposing pipelines previously used to transport hydrocarbons, and mixing CO2 from many sources (as in many planned CCS projects) are poorly understood. The risk of corrosion and brittle fracture is exacerbated with higher water content and impurities. The Health and Safety Executive states: “With regard to the re-use of existing pipelines, any proposal to change the fluid conveyed will require a re-assessment of the original pipeline design to ensure that the pipeline is capable of conveying the fluid safely.”
5.7.3. Regulation and guidance has not kept up with recent interest in CCS systems and new large-scale pipelines associated with them. The Health and Safety Executive (HSE) states that “currently the behaviour of CO2, when released in its dense and supercritical phases, is not yet fully understood”, and that “detailed standards and codes of practice written specifically for the design and operation of dense phase or supercritical CO2 plant and pipelines are still being developed”.
A 2009 report concluded that CO2 used for CCS has sufficient toxicity to be regulated as a dangerous fluid under the Pipeline Safety Regulations (PSR) but regulations have not been updated since 1996.
A 2011 report concluded that CO2 has major accident hazard potential if released at, or above, its critical pressure. Yet CO2 is not currently defined as a dangerous substance under the Control of Major Accident Hazards Regulations 1999 (COMAH)
As part of a written response 24th July 2023 to my request for information about regulation of CO2 transport in pipelines, HSE responded: “HSE has initiated a four-year programme of work to develop modelling capability for CO2 pipelines, to support HSE’s role as a statutory consultee to the planning system.”
Similarly, US regulators PHMSA have initiated new R&D projects related to the safe transportation of carbon dioxide through pipelines which will not report for 2 years. It is clear that PHMSA is concerned not only with the under-regulation of CO2 pipelines, but also with the current lack of technical knowledge which is needed to create appropriate minimum safety standards.
5.7.4. Climate related sea level rise is likely to affect many CCS projects within their planned operating period.
August 2023