Date: 21.03.2024
Mr. Ken Saito
Minister of Economy Trade and Industry of Japan
1-3-1, Kasumigaseki, Chiyoda-ku
Tokyo, 100-8901, Japan
Mr. Nik Nazmi bin Nik Ahmad
Minister of Natural Resources and Environmental Sustainability
Level 1 – 4, Podium 2 & 3, Wisma Sumber Asli No.25
Persiaran Perdana, Precinct 4Federal Government Administrative Centre
62574 Putrajaya, Malaysia.
Mr. Mohd Rafizi bin Ramli
Minister of Economy
Menara Prisma, No. 26, Persiaran Perdana,Precint 3, Federal Government Administrative Centre
62675 Putrajaya, Malaysia
Dear Honourable Ministers,OPEN LETTER
We must reduce carbon at the source
Japan should not dump carbon dioxide into Malaysia
We are writing to express our deep concern over recent developments regarding plans for the exportof Carbon Dioxide (CO₂) emissions from Japan to Malaysia for storage after the capture of theemissions.
We understand that the Japanese government is promoting carbon capture and storage (CCS) to capture
hard-to-abate carbon, and has set a goal of storing 120-240 million tons of CO₂ by 2050 (which isequivalent to approximately 10-20% of Japan’s current emissions) and commercialising CCS by 2030.
Two of the projects selected by Japan Organization for Metals and Energy Security (JOGMEC) assume
Japan would export CO₂ overseas. Malaysia is one of the countries mentioned many times in thepolicies as a potential destination of CO₂.
Recently, a consortium of companies signed a Memorandum of Understanding on March 1st, 2024, to
jointly study carbon capture and storage and the establishment of potential CCS value chains fromcarbon dioxide (CO2) capture and accumulation in Tokyo Bay, shipping, and CO2 storage in Malaysia.

FoE Japan: 1-21-9 Komone, Itabashi-ku, Tokyo 173-0037, Japan
SAM: No. 10, Jalan Padang Tembak, 11400 Penang, Malaysia

The amount of CO₂ to be captured is expected to be around 3 million to 6 million tonnes per year andis projected to start operation by 2030.1
This practice does not only exacerbate the climate crisis but is fundamentally against the principle ofclimate justice, particularly by dumping CO₂ in countries in the Global South like Malaysia. Further,
it is an unproven technology with high risk, high cost and comes with long-term liability. Relying onsuch technology will only delay real climate action in Japan.
Capturing CO₂ and transporting it to other countries results in significant problems such as raisingcosts and safety concerns. Japan must cut the emissions at source and should not export or dump CO₂
in other countries.
Firstly, there are significant technical and financial challenges associated with CCS.
CCS technology has been studied since the 1970s, but there are not many examples of this technology
being demonstrated in real-world applications. What has been implemented is a type of enhanced oil
recovery (EOR), in which captured CO₂ is injected into oil fields to increase the amount of crude oil
extracted, which promotes increased fossil fuel production, leading to further carbon emissions.
The Japanese government is considering exporting CO₂ as a "cheaper" option but this does not take
into account that the majority of projects globally using CCS have had unique engineering challenges
that have led to underperformance and cost blow-outs. This happened to the Gorgon CCS project inAustralia, which is around the same size as the proposed Kasawari CCS project in Malaysia. TheGorgon CCS project in Australia, by oil giants Chevron, was expected to capture at least 80% of thecarbon dioxide emissions from the production of LNG (liquefied natural gas).2 However, it has neveroperated up to its claimed capacity. The Guardian reported in April 2023 that emissions fromChevron’s gas project with the world’s largest industrial carbon capture system rose by more than
50%.3 Gorgon agreed to pay to offset its target shortfall of 5.23 million tonnes of carbon dioxide, whichis estimated to cost Gorgon between US$100 million and US$184 million.4
Who will account for this if this happens to the CO₂ exported from Japan to Malaysia? Who pays forthis although any payment will not guarantee safety for generations to come? This will certainly
undermine Malaysia's own emissions reduction efforts.
Many CCS projects in the past have failed. 43% of the CCS projects planned between 1995 and 2018
were either cancelled or postponed for various reasons such as lack of funding. Furthermore, 78% of1

Mitsubishi Corp. et al, “ENEOS, JX Nippon, Mitsubishi Corporation and PETRONAS to Evaluate and Establish CCS Value Chains fromTokyo-Bay to Malaysia”, March 1, 2024, https://www.mitsubishicorp.com/jp/en/pr/archive/2024/html/0000053068.html
2Adam Morton, “Emissions from WA Gas Project with World’s Largest Industrial Carbon Capture System Rise by More than 50%,” The
Guardian, April 20, 2023, sec. Environment, https://www.theguardian.com/environment/2023/apr/21/emissions-wa-gas-project-chevroncarbon-capture-system-pilbara-coast.
3
Morton, op. cit.
4
Bruce Robertson and Milad Mousavian, “Gorgon Carbon Capture and Storage: The Sting in the Tail” (Institute for Energy Economics
and Financial Analysis (IEEFA), April 2022), https://ieefa.org/sites/default/files/2022-04/Gorgon-Carbon-Capture-and-Storage-The-Stingin-the-Tail_April-2022.pdf.

2

large-scale projects (those that capture more than 30,000 tons of CO₂ per year) were either cancelledor postponed.5
Second, environmental and social risks are a further major concern, including the possibility ofinducing earthquakes as a result of ground injections, the risk of CO₂ leakage6, increased water stress,
and ocean acidification. Over 500 international, US and Canadian organizations sent an open letter topolicymakers calling on them to “reject carbon capture and storage” in July 2021.7 A CCS project inAlgeria where CO₂ had been injected into depleted gas fields from 2004 was suspended in 2011 whenmovement was observed in the layers of the ground that was supposed to prevent CO₂ from leakingout, provoking concerns of leakage.8 The same happened with the Norwegian’s Sleipner CCS where
CO₂ migrated upwards faster than expected.9 Compressed CO₂ is highly hazardous upon release andcan result in the asphyxiation of humans and animals.10 In 2020, a CO₂ transport pipeline that was partof an EOR project in Mississippi, USA was damaged, resulting in the evacuation of about 300 people.11
49 people were hospitalised with carbon dioxide poisoning.12
The technologies used to recover CO₂ from exhaust gas include the chemical absorption method(which separates CO₂ by chemically absorbing it into a solvent such as amine) and the physicalabsorption method (which separates CO₂ by absorbing it into a physical solvent under high pressure).
The amine absorption method generates harmful chemicals such as amine compounds in the processof absorbing, separating, and recovering CO₂, and there are concerns regarding the impacts it will haveon ecosystems and the environment.13
Thirdly, exporting CO₂ emissions perpetuates energy inefficiency with significant increase inenergy consumption. However, CCS is highly unreliable capturing only less than 1% of globalemissions currently14 or 0.1% of global energy-related carbon emissions in 202215.

5Nan Wang, Keigo Akimoto, and Gregory F. Nemet, “What Went Wrong? Learning from Three Decades of Carbon Capture, Utilizationand Sequestration (CCUS) Pilot and Demonstration Projects,” Energy Policy 158 (November 2021): 112546,
https://doi.org/10.1016/j.enpol.2021.112546; For more cost analysis of CCS, also see AIGCC “Carbon Capture and Storage in thedecisive decade for decarbonisation - The case for Asia” https://www.aigcc.net/wp-content/uploads/2021/12/AIGCC-CCS-Report_final.pdf
6“Deep Trouble: The Risks of Offshore Carbon Capture and Storage (November 2023),” Centre for International Environmental Law(blog), accessed March 19, 2024, https://www.ciel.org/reports/deep-trouble-the-risks-of-offshore-carbon-capture-and-storage-november2023/
7
Letter to Policy Makers Re: Carbon capture is not a climate solution (19 July 2021) - https://www.ciel.org/wpcontent/uploads/2021/07/CCS-Letter_FINAL_US-1.pdf and https://www.ciel.org/wp-content/uploads/2021/07/CCS-Letter_FINAL_CAN1.pdf
8Massachusetts Institute of Technology, “In Salah Fact Sheet: Carbon Dioxide Capture and Storage Project,” Carbon Capture andSequestration Technologies @ MIT, accessed February 19, 2024, https://sequestration.mit.edu/tools/projects/in_salah.html
9Grant Hauber, “Norway’s Sleipner and Snøhvit CCS: Industry Models or Cautionary Tales?” (Institute for Energy Economics andFinancial Analysis, June 2023), https://ieefa.org/resources/norways-sleipner-and-snohvit-ccs-industry-models-or-cautionary-tales
10
Centre for International Environmental Law (CIEL), “Carbon Capture and Storage,” Centre for International Environmental Law (blog),
accessed October 09, 2022, https://www.ciel.org/issue/carbon-capture-and-storage/
11
Dan Zegart, “Gassing Satartia: Carbon Dioxide Pipeline Linked to Mass Poisoning | HuffPost Impact” August 26. 2021,
https://www.huffpost.com/entry/gassing-satartia-mississippi-co2-pipeline_n_60ddea9fe4b0ddef8b0ddc8f; Delaney Nolan, “Louisiana
Rushes Buildout Of Carbon Pipelines, Adding To Dangers Plaguing Cancer Alley,” August 24, 2023,
https://theintercept.com/2023/08/24/carbon-pipeline-ccs-air-products-louisiana/
12
Zegart op. cit.; Nolan op. cit.
13
Ministry of Environment of Japan, “Commissioned Study Report on Environmentally Friendly CCS Introduction", 2014,
https://www.env.go.jp/earth/ccs/h26_report.html
14World Resources Institute, “7 Things to Know About Carbon Capture, Utilization and Sequestration | World Resources Institute,”
November 13, 2023, https://www.wri.org/insights/carbon-capture-technology.
15
Amandine Denis-Ryan, “Fact Sheet: Carbon Capture and Storage (CCS) Has a Poor Track Record” (e Institute for Energy Economics
and Financial Analysis (IEEFA) e, February 8, 2024), https://ieefa.org/resources/fact-sheet-carbon-capture-and-storage-ccs-has-poortrack-record3Any CCS project requires significant energy inputs and all of CCS infrastructure poses risks to thepublic and environment. Running carbon capture equipment is also energy-intensive and increases theoverall emissions of the facility where the capture equipment is installed.16 The most energy intensive
part is for the capture and compression of carbon, with additional amounts needed for transportationand storage. Capture and compression alone require 330–420 kWh per tonne of CO2 captured. CCS
projects increase the energy demand of the facility they capture carbon from by 15%–25% on
average.17
The fourth challenge is the issue of ensuring permanent storage. For CCS to be a viable option fordecarbonisation, it is important to make sure that carbon can be stored in a stable state permanently.
IPCC uses the word “durably” to describe the storing of CO₂ in geological, terrestrial, or oceanreservoirs, or in products for CDR (Carbon Dioxide Removal). There is no clear definition for thelength that “durably" entails, but some have suggested at least 200-300 years.18 A legal system thatcan guarantee the maintenance of sequestered carbon for such a long period is not feasible in practice.
After the monitoring period conducted by the utility company ends, if the government takes overresponsibilities and finances the management of the expected large amount of carbon at public expense,
we will only be leaving this problem for future generations to deal with. Why should Malaysian
taxpayers or the Global South bear such long-term liability for keeping the CO₂ dumped by richcountries?
Cross-border transport of carbon dioxide for permanent geological storage below the seabed is inpractice a dumping of waste. The need for such export in situations where a country does not havesufficient suitable geological storage capacity but may still wish to use CCS to reduce emissions
domestically is unjustifiable. We need rich countries to undertake deep, rapid and sustained emissionreductions at home and at the source.
Dumping CO₂ is irresponsible and only transfers the burden to the Global South and this is nothing
but carbon colonialism. The Global South is not Japan’s waste dumping site.
We urge the Japanese Government to recognise the grave consequences of exporting CO₂ emissions
and stop doing so.
Also, both governments should not subsidise CCS projects as it effectively transfers the responsibilityof polluters to taxpayers. Target 18 of the Global Biodiversity Framework requires governments toidentify by 2025 and eliminate, phase out or reform incentives including subsidies that are harmful tobiodiversity. We urge the Malaysian Government not to accept the CO₂.

16

CIEL “Deep Trouble: The Risks of Offshore Carbon Capture and Storage (November 2023), https://www.ciel.org/wpcontent/uploads/2023/11/Deep-Trouble-The-Risks-of-Offshore-Carbon-Capture-and-Storage.pdf
17
Angela Carter, Laura Cameron ”Why Carbon Capture and Storage Is Not a Net-Zero Solution for Canada’s Oil and Gas Sector
The Bottom Line: Unpacking the future of Canada's oil & gas”, February 9, 2023, https://www.iisd.org/articles/deep-dive/carbon-capturenot-net-zero-solution
18Article 6.4 Mechanism Information note, Removal activities under the Article 6.4 mechanism Version 04.0,
https://unfccc.int/sites/default/files/resource/a64-sb005-aa-a09.pdf

4Both governments should cooperate for a just and fair transition prioritising investments in renewableenergy, energy efficiency, and sustainable development that benefit both local and global environment.
Thank you for your attention to this critical matter and we seek your timely response in this regard.
Yours sincerely,

Meenakshi Raman
President
Sahabat Alam Malaysia / Friends of the Earth Malaysia
Email: foemalaysia@gmail.com

Ayumi Fukakusa
Deputy Executive Director
Friends of the Earth Japan
Email: info@foejapan.org

CC:
Mr. Fumio Kishida, Prime Minister of Japan
Dato' Seri Anwar bin Ibrahim, Prime Minister of Malaysia and Minister of Finance
Ms. Yoko Kawakami, Minister of Foreign Affairs
Ms. Shintaro Ito, Minister of Environment
Mr. Shunichi Suzuki, Minister of Finance
Mr. Nobumitsu Hayashi, Governor of Japan Bank for International Cooperation (JBIC)
Mr. Ichiro Takahara, Chairman and CEO of Japan Organization for Metals and Energy Security(JOGMEC)
Mr. Atsuo Kuroda, Chairman and CEO of Nippon Export and Investment Insurance (NEXI)
Mr. Katsuya Kananishi, Representative Director, President and CEO of Mitsubishi Coorporation
Tan Sri Tengku Muhammad Taufik Tengku Kamadjaja Aziz, President & Group Chief Executive
Officer, Executive Director of Petronas
Mr. Tomohide Miyata, Representative Director and Executive Vice President of ENEOS Corporation
Mr. Toshiya Nakahara, President and CEO of JX Nippon Oil & Gas Exploration Corporation

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