A key finding is that the legal and regulatory regimes pertaining to CO2 EOR and CO2 storage sites contain significant differences that need to be addressed in order to facilitate the transition in use from one type of site to the other. Site evaluation, monitoring, postclosure liability and conformance with national GHG inventory guidelines are the main areas of divergence which require attention from policymakers and regulators. The CCP study – Best Practice in Transitioning from CO2 EOR to CO2 Storage – examined the legal frameworks for CCS and CO2 EOR sites across the US, Canada, Europe, Australia and Brazil. It found that while there is a clear regulatory framework for both types of sites in most regions, there are insufficient provisions that would allow a CO2 EOR operator to transition to a CCS project to receive credit for long-term storage. The report does not identify any specific technological barriers or challenges to transitioning from CO2 EOR to CO2 storage. Neither are there any existing policies or regulatory provisions in the regions studied that explicitly prohibit the prospect of CO2 EOR projects transitioning to CCS projects. Arthur Lee, CCP Policy & Incentives Team Lead, comments: “Current legal and regulatory frameworks apply to the specific and different needs of oil and gas production and CO2 storage. Operators of existing or new CO2 EOR projects who wish to transition to CCS will need to work with regulators to develop further guidance. The report is the first step to help with this development”.
The legal and regulatory frameworks governing the transition from CO2 enhanced energy recovery ( EOR ) to CO2 storage capacity offer the sector " insufficient provision " , according to a study by the CO2 management Project . The report , which looked at the prospects for CCS and CO2 EOR in the US , Europe , Canada , Australia and Brazil , concluded there were " significant differences " in conforming with national greenhouse gas policy , monitoring and site evaluation , among other things , between one regime and the other .