In July 2023, EJA made a submission to the federal Department of Industry, Science and Resources on its consultation on which areas should be allocated for bidding on future offshore carbon capture and storage (CCS) sites.
Capturing greenhouse gas emissions for permanent underground storage is a nascent technology that remains at an early stage of development worldwide. It carries known and potentially serious direct environmental risks, as well as the fundamental risk of technical failure resulting in the release of captured emissions to the atmosphere, contributing to harmful climate change.
The release of areas, or acreage, for bidding represents the moment at which the selected geological formations first become available for preliminary CCS exploration and appraisal activities. From this point, the legislative framework, the Offshore Petroleum and Greenhouse Gas Storage Act 2006 (Cth) (‘OPGGSA’) and its associated regulations comes into play. This legislative framework is the key protective measure in place to manage the immediate and long-term risks associated with large-scale CCS projects.
It is in this context, that EJA submits, that it is vital that the OPGGSA framework ensures that the risks associated with the serious and actual potential impacts of CCS are publicly identified, avoided or minimised , that residual risks are appropriate managed, and that liability for any future rehabilitation or compensation can be wholly and fairly apportioned.
EJA identifies three key aspects of the OPGGSA framework that falls short of this standard. These are that:
- The OPGGSA framework provides no assurance that CCS projects will result in a net reduction in greenhouse gas emissions,
- The calculation and attribution of long-term liability for CCS project failure may expose the Australian public to significant risk.
- There is inadequate public reporting and transparency around CCS project impacts and risk management.