GCCSI CCS REGULATORY TEST TOOLKIT

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1 GCCSI CCS REGULATORY TEST TOOLKIT Mark Bonner, Principal Manager Policy, Legal and Regulatory 2 nd South African CCS Week, 27 October, 2011 Johannesburg

2 ROLE OF REGULATION/S ALLOWS GOVERNMENTS TO GIVE EFFECT TO THEIR CCS POLICY OBJECTIVES THROUGH: EFFICIENCY OF COMPLIANCE (STREAMLINING AND HARMONISING WITHIN AND ACROSS REGULATIONS) EFFECTIVENESS OF COMPLIANCE (INSTITUTIONAL ARRANGEMENTS) ENSURES EXPRESSION OF AFFECTED CONSTITUENCY VIEWS PROVIDES A SOCIAL LICENCE TO OPERATE CCS PROJECTS BY: PROVIDING FOR COMMUNITY ACCEPTABILITY ENSURING HEALTH, SAFETY AND ENVIRONMENTAL INTEGRITY DELIVERY ON GOVERNMENT POLICY OBJECTIVES INSTITUTIONAL COMPLIANCE (VERIFICATION/REPORTING) PROVIDES BUSINESS WITH INVESTMENT CONFIDENCE BY: ENSURING PREDICTABILITY OF LEGAL REQUIREMENTS CONDITIONS FOR COMMISSIONING AND DECOMMISSIONING IDENTIFYING MINIMUM BENCHMARKS OF PERFORMANCE

3 NATURE OF GOVERNANCE ARRANGEMENTS REGULATORY FORMS MINISTERIAL POWERS BESPOKE / FIT FOR PURPOSE STANDALONE RELIANT ON PRE-EXISTING ARRANGEMENTS COULD BE PROVIDING FOR: PROJECT SPECIFIC REQUIREMENTS REMEDIES TO TECHNOLOGY LIFECYCLE MARKET FAILURES RD&D FIRST OF A KIND DEMONSTRATION COMERCIALISATION AND DIFFUSION GOVERNANCE OF ENTIRE CCS CHAIN OR A COMPONENT THERE ARE CLEAR BENEFITS TO GETTING IT RIGHT THERE ARE REAL COSTS TO GETTING IT WRONG

4 EXAMPLES OF REGULATORY ISSUES (NON-EXHAUSTIVE LIST)

5 CCS REGULATORY TEST TOOLKIT BEST PRACTICE GUIDE TO TESTING SUFFICIENCY OF CURRENT REGULATORY REGIMES FOR CCS PROJECTS SIMULATES A CCS PROJECT (COULD BE A REAL OR HYPOTHETICAL ONE) APPLICATION THROUGH ALL OR PART OF THE APPROVALS AND PERMITTING PROCESSES APPLICABLE ACROSS INTEGRATED SYSTEM AND/OR SPECIFIC ASPECT OF PROJECT FOCUS IS ON PREPARATION; AND A QUALITY DIALOGUE ACROSS ALL KEY STAKEHOLDERS; AND FOLLOW UP GOVERNEMENT LED (APPLICABLE FOR ALL LEVELS OF GOVERNMENT: NATIONAL; PROVINCIAL; MUNICIPAL)

6 REGULATORY EXAMINATION FROM THE GROUND UP IMPLEMENTING THE TOOLKIT CAN HELP: GOVERNMENTS (3 TIERS AND ALL RELEVANT DEPARTMENTS) REGULATORS (ALL RELEVANT PRE-EXISTING REGULATIONS) INDUSTRY (CCS PROJECT PROPONENTS) AND CIVIL SOCIETY TO COLLABORATIVELY MAP OUT AND TEST THE ADEQUACY OF EXISTING REGULATORY FRAMEWORKS AND ASSOCIATED PROCESSES FOR THE PERMITTING OF A CCS PROJECT INCLUDING: WHO NEEDS TO BE INVOLVED RESOURCE REQUIREMENTS PERMITS REQUIRED INFORMATION REQUIREMENTS ANALYTICAL REAQUIREMENTS LIKEY TIMESCALES FOR DECISIONS HOW TO FOLLOW-UP ON LESSONS LEARNED

7 TOOLKIT OBJECTIVES ENHANCE THE UNDERSTANDING OF REGULATORY PROCESSES HELP REDUCE REGULATORY COSTS BY ASSISTING ALL INTERESTED PARTIES TO MEET PERMITTING MILESTONES CLEARLY IDENTIFY INTERESTED PARTIES ROLES IDENTIFY OPPORTUNITIES TO STREAMLINE AND/OR HARMONISE ACROSS REGULATORY SYSTEMS TO IMPROVE REGULATORY EFFICIENCY LESSEN REGULATORY BURDEN AND IMPOST ENSURE THAT VIABLE REGULATORY PROCESS PREVAILS FOR CCS PROJECTS IDENTIFY GAPS IN PREVAILING REGULATORY SYSTEM REVEAL ASSOCIATED ACTIONS NEEDED TO GIVE EFFECT TO REGULATORY EFFICIENCY AND EFFECTIVENESS APPRECIATION FOR INSTITUTIONAL CAPACITY (RESOURCES)

8 CCS REGULATORY TEST EXERCISE OVERVIEW 3 STEP FACILITATED PROCESS Stage 1: PREPERATION AND ANALYSES Stage 2: WORKSHOP DELIVERY Stage 3: FINDINGS AND FOLLOW-UP

9 CASE STUDY THE ROMANIAN EXPERIENCE (GETICA) SECURED SENIOR LEVEL SUPPORT FROM GOVERNMENT (MINISTRY OF ECONOMY) STEERING COMMITTEE (SC) ESTABLISHED: MET 4 TIMES PRIOR TO WORKSHOP INFORMED BY EXPERT PRESENTATIONS (EC, IEA; SCOTTISH GOVERNMENT BOTH EXTERNAL & INTERNAL) TIMEFRAME 3 WEEKS PREPARATION (DRAFT REGULATORY MATRIX) 6 WEEKS FOR SC TO APPROVE REGULATORY MATRIX 4 WEEKS TO ORGANISE CCS WORKSHOP 2 DAY WORKSHOP (80 PARTICIPANTS) 8 WEEKS TO DRAFT FINAL WORKSHOP REPORT FACILITATIVE CONSULTANT CONTRACTED BY GCCSI ON BEHALF OF GOVERNMENT CUSTOMISED TO SUIT ROMANIAN GOVERNMENT REQUIREMENTS

10 KEY LEARNINGS - ROMANIA FIVE KEY LEARNINGS : INSTITUTIONAL CAPACITY: has to be increased to improve the permitting process; authorities need a better understanding of the CCS technology PUBLIC ENGAGEMENT: the engagement of the local communities in the area of the project is crucial ENVIRONMENTAL IMPACT ASSESSMENT: integrated approach of the three (3) CCS components CO-OPERATION AND JOINT WORKING ACROSS GOVERNMENT departments and regulators will be essential EARLY STAKEHOLDER ENGAGEMENT is key to streamlining the regulatory process and improving design

11 TIMELINE FOR ROMANIA NOTE: TOOLKIT CAN CUSTOMISED AND EXECUTED TO FIT GOVERNMENT PREFERRED TIMELINE DAYS

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