Opinion of the European Economic and Social Committee on the Proposal for a Directive of the European Parliament and of the Council on the geological storage of carbon dioxide and amending Council Directives 85/337/EEC, 96/61/EC, Directives 2000/60/EC, 2001/80/EC, 2004/35/EC, 2006/12/EC and Regulation (EC) No 1013/2006 COM(2008) 18 final — 2008/0015 (COD)
Date: 2008-07-09
Institutions: European Economic and Social Committee
Subjects: ESC opinion, EU environmental policy, energy policy, energy storage, energy technology, environmental impact, greenhouse gas, reduction of gas emissions

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The Committee calls on the Commission to establish a
for

4.7
compliance regime, under which Member States would,
instance, be fined for exceeding the set emission levels.

4.8
Also, in terms of the equitable geographical distribution
of projects, Article 4(1)(c) is not specific enough as to the appli-
cation of measures on the purchasing of credits.

this decision,

To implement

the Commission should
4.9
provide the Member States with pointers for action, instruments
and other measures. A good first step could be to issue a guide
containing examples of successes already achieved in the EU.

To achieve the objective of this decision, the Committee
4.10
recommends that Member States make use of the Structural and

Brussels, 9 July 2008.

Cohesion Funds for projects that do not produce, or that even
reduce greenhouse gas emissions.

4.11
For ETS installations, provision has been made for the
auction of emission allowances during the next allocation round
from 2013 to 2020. This will secure the funds needed to reduce
greenhouse gas emissions from non-EU-ETS sectors. Part of the
funds obtained in this way should be directed towards economic
sectors that are making an effort to reduce greenhouse gas emis-
sions. The other part should be channelled into a solidarity fund
for developing countries, and allocated to climate change adap-
tation projects in those countries.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

Opinion of the European Economic and Social Committee on the ‘Proposal for a Directive of the
European Parliament and of the Council on the geological storage of carbon dioxide and amending
Council Directives 85/337/EEC, 96/61/EC, Directives 2000/60/EC, 2001/80/EC, 2004/35/EC,
2006/12/EC and Regulation (EC) No 1013/2006’

COM(2008) 18 final — 2008/0015 (COD)

(2009/C 27/17)

On 8 February 2008 the Council of the European Union decided to consult the European Economic and
Social Committee, under Article 175 of the Treaty establishing the European Community, on the

Proposal for a Directive of the European Parliament and of the Council on the geological storage of carbon dioxide and
amending Council Directives 85/337/EEC, 96/61/EC, Directives 2000/60/EC, 2001/80/EC, 2004/35/EC,
2006/12/EC and Regulation (EC) No 1013/2006.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing
the Committee's work on the subject, adopted its opinion on 4 June 2008. The rapporteur was Mr Wolf.

At its 446th plenary session, held on 9 and 10 July 2008 (meeting of 9 July), the European Economic and
Social Committee adopted the following opinion by 138 votes to one with four abstentions.

Contents

1. Summary and conclusions

2. Introduction

3. Commission proposal

4. General comments

5. Specific comments

1. Summary and conclusions

1.1
Capture and long-term storage (CCS) of carbon dioxide
(CO2) released by the use (combustion) of fossil fuels would

substantially help to combat climate change. This technology
should therefore be developed more rapidly and used as soon as
possible.

1.2
The Committee welcomes the Commission's proposed
directive as a prerequisite for the development and use of CCS,
and broadly endorses its content.

1.3
The directive addresses the most important aspects and
sets out provisions to deal with them. In particular, human and
environmental safety issues and the associated responsibilities
are covered, thus helping to secure public acceptance of the
directive and addressing safety concerns on the part of ordinary
citizens.

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1.4
The development of the overall CCS value-added chain,
involving the capture, transport and storage of CO2, is in an
early — and, in some cases, still exploratory — stage. The provi-
sions of the directive need to take this into account, and some
fine-tuning is still needed in certain areas.

1.5
To enable rapid implementation of initial projects, some
sections of the directive should be amended to make them more
manageable by both the relevant national authorities and poten-
tial
investors; this would also ensure planning certainty and
provide incentives for action. This applies for instance to liability
issues and the nature and extent of financial security payments.

tory framework to bring environmentally safe CCS to deploy-
ment;
the proposal under review represents one means by
which this objective is to be achieved. The proposal relates,
above all, to the establishment of the regulatory framework on
the basis of Article 175(1) of the EC Treaty. It also provides for
simplification of legislation and simplification of administrative
procedures for public authorities, be they EU or national.

3.3
Existing provisions, such as those set out in Directives
96/61/EC, 85/337/EEC, 2004/35/EC and 2003/87/EC, are taken
into account or where necessary amended in the proposal.

2. Introduction

2.1
Following the Council decisions of March 2007 on
climate change and threats to the security of energy supplies,
the Commission proposed a package of measures in the form of
separate documents in order to meet the objectives set by the
Council decisions. These measures focus on energy efficiency,
promoting renewable energy sources and developing and using
the relevant innovative technologies. The Committee has drawn
up specific opinions on each measure (1).

2.2
One area of key importance in this context is the devel-
opment of methods to sustainably reduce greenhouse gas emis-
sions arising from the use of fossil fuels, which is the subject
discussed in this opinion, with particular
reference to the
Commission's proposal for a directive on the geological storage
of carbon dioxide (CO2).

3.4

Actual contents of the Commission proposal:

3.4.1
of the proposal. Definitions of terms are also set out.

Chapter 1 covers the subject matter, purpose and scope

3.4.2
Chapter 2 covers site selection and exploration permits.
The Member States are to determine the areas to be made avail-
able for storage and the rules governing the allocation of
exploration permits.

Chapter 3 covers

storage permits, conditions

for
3.4.3
the European
awarding them and the relevant powers of
Commission. An important element
the environmental
impact assessment, which includes impact assessments and
public consultations.

is

This opinion ties in with a Committee opinion (2) on the
2.3
same technology discussing the Commission's communication
on Supporting Early Demonstration of Sustainable Power Generation
from Fossil Fuels.

3.4.4
Chapter 4 covers operation, closure and post-closure
obligations, including CO2 acceptance criteria, monitoring and
reporting obligations, inspections, measures in case of irregulari-
ties and/or leakage, closure and post-closure obligations and
provision of financial security.

3. Commission proposal

3.4.5
and storage networks.

Chapter 5 addresses the issues of access to transport

3.1
On the basis of (i) the fact that the growing demand for
sources of energy at international level is likely to be met predo-
minantly by the use of fossil fuels and (ii) the objective of
achieving a global reduction of CO2 emissions of 50 % by 2050
and a reduction of between 60 and 80 % in the industrialised
states, the Commission considers that it is essential to exploit all
possibilities of bringing down the level of emissions. With this
aim in view, carbon dioxide capture and storage (CCS) (3) is of
major importance.

The European Council of March 2007 called for the
3.2
development of the necessary technical, economic and regula-

Chapter 6 covers general provisions relating to the
3.4.6
competent
cooperation, penalties,
cross-frontier
reporting to the European Commission, amendments and the
relevant comitology procedures.

authority,

3.4.7
legislation,
waste legislation. Additional conditions
authorisation of new power stations are also set out.

Chapter 7 sets out the required amendments to other
including the necessary adaptations to water and
the

in respect of

(1) CESE 1201/2008, CESE 1202/2008, CESE 1203/2008 of 9.7.2008,

not yet published in the OJ.

(2) COM(2008) 13 final.
(3) CCS: Carbon (i.e. carbon dioxide) Capture and Storage. TEN/340 —
CESE 562/2008 recommends using the abbreviation CCTS (Carbon
Capture, Transport and Storage) instead. This opinion sticks to CCS.

3.4.8
Annex I specifies detailed criteria for the requirements
on site characterisation and risk assessment. Annex II sets out
detailed criteria for
the requirements on monitoring. The
European Commission may amend the Annexes, in which case
the European Parliament also has a say.

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4. General comments

The EESC has drawn attention on a number of occa-
4.1
sions (4) to the fact that affordable energy is the life blood of
modern social market economies and a prerequisite for the
provision of all basic services. The need to step up the develop-
ment of new technologies is of particular importance in this
regard (5).

4.2
The Committee welcomes the Commission's proposed
directive on this subject as an important prerequisite for devel-
oping and using CCS as a technology to achieve this objective,
and broadly endorses its contents.

In this connection, the EESC has drawn attention (6) to
4.3
the fact that the fossil fuels coal, petroleum and natural gas are
currently the mainstay (7) of both European and global energy
supply and will perhaps retain their importance over the next
few decades.

4.4
This is not at variance with the declared goal of bringing
about a dramatic increase in the share of renewables, since, even
bearing in mind the EU's target of achieving an at least 20 %
share of renewable energies in overall EU energy consumption
by 2020 (8), there will, for many decades to come, continue to
be a considerable need for energy produced from other sources
in order to cover the remaining 80 % — by 2050 still approxi-
mately 50 % — of energy consumption.

4.5
In the case of renewables, up until now it has only been
possible to use hydropower and biomass (9) to generate electri-
city at the level dictated by demand, whereas wind and solar
energy are characterised by a limited, weather-dependent avail-
ability. Nevertheless, considerable efforts should be put
into
continued development and use of such energy sources, while
working out
storage options.
However,
is dealt with in separate Committee
opinions.

and economical

this subject

adequate

4.6
It therefore follows that to ensure base load supply — as
a supplement to and/or replacement (10) for nuclear energy — a
large number of power stations running on fossil
fuel will
remain a necessity. In addition, if we are to have adequate —
positive or negative — reserve capacity available, more power
stations will be needed whose output can be adjusted sufficiently
quickly to compensate for fluctuating levels of energy generated
by wind power.

(4) e.g. OJ C 162, 25.6.2008, p. 72.
(5) See CESE 1199/2008 of 9.7.2008, not yet published in the OJ.
(6) See,

and, more

643/2005

example,

CESE

for

recently,

CESE 1246/2007. Not yet published in the OJ.

(7) Initially, the use of CCS is mainly envisaged for electricity production
from fossil fuels. In the EU, about 30 % of electrical energy currently
comes from nuclear power, with practically no emissions of carbon
dioxide.

(8) See the Presidency conclusions of the March 2007 European Council.
(9) Biomass only has a positive impact on overall CO2 emissions if the
energy input for production, transport and processing does not exceed
the energy yield. Article 24(a) of the ETS Directive provides for the
option of appropriate support for biomass power plants equipped with
CCS facilities.

(10) In Member States which have decided not to produce nuclear energy.

4.7 With regard to providing peak capacity and reserve capa-
city, gas-fired and pump-fed hydroelectric power stations are the
main options. However, there is limited scope for the develop-
ment of pump-fed hydroelectric plants, as the specific geogra-
phical features which they require have to a large extent already
been used.

4.8
For base load and intermediate load supply, coal-fired
power stations are mainly used, in addition to nuclear power
stations. In Member States which decide not to produce nuclear
for electricity generation
energy themselves, the use of coal
becomes of even greater importance for these types of electricity
supply.

4.9
There is therefore a need to reduce CO2 emissions to the
lowest possible level, including when coal-fired power stations
are used. With this aim in view, two lines of development —
characterised by varying degrees of technical maturity and a
variety of
impacts — are being pursued: on the one hand,
power stations are being developed with even greater efficiency;
and, on the other hand, power stations are being developed
which have recourse to CCS (11). In the case of the latter, whilst
by far the greater part of the CO2 emitted no longer goes into
the atmosphere, the process inevitably involves a noticeable loss
of efficiency,
in order to cover the additional energy require-
ments brought about by CCS. There is also a need for continued
development of technologies to capture CO2 from manufac-
turing processes.

The development of CCS, involving the capture, trans-
4.10
port and storage of CO2, remains at an early — and, in some
cases, still at an exploratory — stage. While it is true that
measures to increase the efficiency of conventional power
station technology are, by contrast, gradually making progress,
they are already approaching the limits of what is physically
feasible. Bearing in mind the urgent need to replace power-
station capacity over the next few decades, the EESC recom-
mends that a pragmatic approach be adopted under which both
technologies are developed side by side. Whilst the development
of a higher level of efficiency may be largely market-driven,
CCS technologies — for both power stations and infrastructure
— require additional
the demonstration and
support at
marketing stages.

4.11
CCS technology is being pursued along various devel-
opment paths: (a) integrated power station technology involving
the capture of CO2, where,
in the coal gasification process,
carbon is captured before the combustion process, or,
in the
oxyfuel process, CO2 is enriched by the process before capture;
and (b) post-combustion technology, which involves washing
out CO2 from the flue gas after combustion (CO2 washing).
Once it has undergone suitable development, method (b) would
be suitable for deployment
in highly efficient new power
stations provided that they are designed accordingly (‘capture
ready’). A common feature of these development paths is the
fact the CO2 so captured has to be brought from the power
station to a suitable storage site.

(11) See also CESE 1246/2007. Not yet published in the OJ.

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4.12
CO2 can only be stored in suitable, safe geological
formations. Existing research suggests that deep saline aquifers
and depleted oil and gas deposits would be the best options,
whereas abandoned coal mines are probably less suitable. It is
vital to have largely intact rock sealing in the CO2 so as to
prevent leakages, with as few surface outlets as possible.

4.17
In general, the EESC welcomes the European Commis-
sion's proposed directive and sets out its views on a number of
individual points in the proposal in the following section.

4.13 When a storage site is selected by experts in compliance
with the proposed rules set out in the directive, it must be estab-
lished that the risks associated with storage are minimal. In the
case of suitable storage formations, sudden escape of large quan-
tities of CO2 is practically impossible (12). It should also be estab-
lished that induced seismic shocks do not pose a threat, with
the maximum storage pressure chosen so as not to destroy the
rock layers used for storing and sealing (13), as these must be
preserved in order to ensure storage.

The issue of the safe,

long-term storage of CO2 is a
4.14
matter of decisive importance for the social and political accep-
tance of this process.

4.15
The Committee therefore feels it is very important for
the public to be fully informed by the Commission, and — in
particular — the Member States and potential operators, of all
aspects of this new technology, and for them to be involved
through transparent dialogue in the associated decision-making
processes. Appropriate procedures should be developed to this
end.

as

in unforeseeable

4.16
The Committee would like to advocate a further
preventive measure at the end of this section. This relates to the
possibility of CO2 being needed in the more distant future,
a basic
either
chemical
applications
substance, or as a variable within ‘natural’
long-term climate
cycles (14). As an additional preventive measure to ensure
sustainability, the EESC therefore recommends that, whilst the
storage of CO2 should indeed be carried out, consideration
should however be given to the possibility of at least partial
re-emission under the closure plans, or that documentation on
potential
re-emission options be required from particular
storage complexes. Of course, the priority must be to ensure
that storage sites are as safe as possible and leak-proof.

5. Specific comments

The proposal contains the fundamental provisions which
5.1
are necessary to provide operators of CCS installations with the
requisite legal framework, though in a small number of cases
they go beyond what is necessary to achieve this objective.

Some points in the proposal are, however,

5.2
in need of
clarification in order to make it possible to implement the
provisions and to ensure legal certainty.

5.3
Under the Commission's proposal, CO2 captured and
stored is to be credited as ‘not emitted’ under the Emissions
Trading Scheme (ETS); consequently, no CO2 allowances have to
be surrendered in this case (see recital 23 which refers to Direc-
tive 2003/87/EC). As a result there is a useful market-based
incentive to invest in CCS installations, albeit an as yet inade-
quate incentive in the case of the demonstration stage.

5.3.1
The EESC therefore welcomes the proposed inclusion
of these measures in the ETS; a market-based approach is clearly
preferable to compulsory CCS, particularly as, given the current
stage of development of CCS technology, such an obligation to
carry out CCS would be clearly premature.

5.3.2
It is, however, the right course of action to oblige new
power stations to make available suitable space for the equip-
ment necessary to capture and compress CO2
(Article 32,
amendment of Article 9a in Directive 2001/80/EC). These
measures, which systematically give rise to increased costs,
should, however, always be backed up by corresponding market
economy incentives (15)
the
allocation of CO2 allowances on favourable terms or using part
the ETS for
of
promoting CCS).

the options held under

(in the form of,

the proceeds of

for example,

(12) Only if this happened would there be any danger for people living in
the immediate vicinity, as CO2, unlike CO, is not toxic, and is not
life-threatening until it reaches a concentration of over 8 % (at present,
the average concentration of CO2 in the air is around 380 ppm
(ppm: parts per million)).

(13) In contrast to the use of geothermal energy.
(14) Ice-core samples, obtained from drilling, provide evidence relating to
global climate development over the last 600 000 years. This evidence
shows that in the past there has been a succession of warm periods
and ice ages, alternating at regular intervals of typically 100 000 years,
with a sawtooth variation of temperature over time, together with
correlated changes in CO2 levels in the atmosphere. Given that there
has, at the moment, been a prolonged warm period, with temperatures
at the top end of the sawtooth cycle, and that the end of the last warm
period was over 100 000 years ago, a gradual drop in global tempera-
tures and CO2 levels is again likely in the foreseeable future, unless
current greenhouse gas emissions due to human activity have precisely
the opposite effect.

In order to prevent unnecessary restrictions being placed
5.4
upon storage, the ban stipulated in Article 2(3) of the Commis-
sion's proposal should apply not to ‘storage of CO2 in geological
formations’ but rather to ‘storage site’. This amendment is being
proposed since ‘geological formations’, as defined in Article 3(4)
can easily extend beyond the area defined in Article 2(1),
whereas the likelihood of a corresponding extension of a
‘storage site’ is clearly less great. A clause could be included to
provide for additional storage options through reliable contrac-
tual agreements with non-EU states.

(15) See, in this context, the general recommendations set out in point 3.3

of OJ C 162, 25.6.2008, p. 72.

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5.5
The definition of the term ‘storage site’ in Article 3(3)
should really refer to that ‘part’ of a ‘specific geological forma-
tion used for the geological storage of CO2’.
(A geological
formation can extend over millions of km2 in terms of surface
area; only part of such a geological formation can therefore be
designated as a ‘storage site’). It is perfectly possible — and
indeed probable — that several storage sites will be situated in a
given geological formation.

5.7.4
Should there be any plan during subsequent day-to-day
operation to set maximum permitted leakage levels, the level
chosen could be one at which there is no threat to safety or
climate, and therefore one which is of no relevance to emissions
certificates, for example leakage of 0.1 %/100a.

Under Article 4(1) of the proposal, the Member States
5.6
reclaim the right to designate suitable storage sites. It should be
clearly stipulated in this context that the areas which are in prin-
ciple suitable for the storage of CO2 must actually be designated
by the Member States, provided that there are no important
reasons standing in the way of such designation.

5.7
The EESC welcomes the fact that the proposed provisions
call for a maximum level of security. This is essential both to
protect human beings, the environment and climate (16) and
also to ensure the integrity of the trade in emission allowances.

5.7.1
This goal must be achieved by making use of appro-
priate, state-of-the-art monitoring systems. This requirement
needs to be taken into account when permits are being issued
by the Member States (17).

5.7.2 Monitoring systems require and must also ensure that
processes in the actual storage site can be understood and
modelled as accurately as possible (measurements taken at or
near surface level do not provide sufficient information on this).
For this reason, the models which are used should if possible be
tested or certified using two independent simulation/modelling
systems.

The term ‘leakage’ should be defined as follows:

5.7.3
‘Any
release of CO2 from the storage complex which can be verified
using state-of-the-art monitoring systems’. It is not possible to
provide absolute (i.e. 100 %)
leak-tightness, nor could such
tightness be proved because of the natural release of CO2 from
the ground. Nor is such leak-tightness essential on grounds of
safety or climate protection (18). This definition, based on state-
of-the-art technology available at a given time, would ensure
increasingly precise monitoring systems, which would also
benefit from development of CCS, thus making a dynamically
developing contribution to further improvements in safety.

(16) Often also an HSE (Health, Security, Environment) requirement.
(17) See also Article 13(2) and Annex II of the proposed directive.
(18) If this were not the case, emissions certificates would be needed

(emission trading scheme).

in order to implement

5.8
The duration of exploration permits, as proposed by the
Commission in Article 5(3), is too short. Experience shows that
a period of at least four years is necessary, even under optimal
circumstances,
the exploration work
programme. We must, on no account, be faced with a situation
in which exploration work has to be halted solely because the
prescribed duration, including the extension period, has expired,
even in cases where very little data have still to be obtained.
Provision should therefore be made for flexible rules, taking
the same time
account of
requiring operators to proceed apace with the exploration
programme,
in order to prevent potential storage sites from
being blocked because of delays in exploration.

the local conditions whilst, at

5.9 Whilst the exploration of a potential storage site requires
know-how, skilled staff,
time and money, success is by no
means guaranteed. A decisive incentive to carry out exploration
would therefore be lost if this commitment on the part of enter-
prises were not to be backed up by a prior claim to the use of
storage sites. The provisions proposed by the Commission in
Article 5(4) should therefore be backed up by the granting of
first right of access to storage, for instance by including the
following sentence (already under discussion):
‘After this time,
the CO2 storage exploration permit shall either be converted
into a CO2 storage permit or else be relinquished for the total
area covered’.

5.10
The Commission rightly proposes that a corrective
measures plan be drawn up. This plan (see Article 9(6) and
Article 16(1)) should, however, only be applied in line with the
requisite changes
the term ‘leakage’
to the definition of
(Article 3(5)).

Articles 6 to 9 of

5.11
the proposal set out provisions
governing applications for storage permits, the conditions for
granting such permits and the contents of these permits. It is
clear
from these provisions that several operators may be
working in one geological formation.

5.11.1
In principle, the EESC welcomes the idea that access
should be free of discrimination. Difficult questions relating to
delimitation, however, arise with regard to the responsibility for
leakages and the transfer of responsibility to the State.

5.11.2
For this reason, there should be a rule that only one
operator can be granted a permit for each storage complex, thus
ensuring that responsibilities are clearly identified. Article 20
would also ensure that access to storage sites is free of
discrimination.

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5.12
Under the Commission's proposal a national authority
has to notify the Commission before finally awarding permits
(Article 10 and Article 18) and then await the Commission's
opinion for a period of up to six months. The Commission's
opinion has then to be taken into consideration when granting
the permit or, where appropriate, the authority has to state the
reasons if it deviates from the Commission's opinion.

The proposed provisions would bring about delays
5.12.1
and lead to heightened bureaucracy. Furthermore, they are out
of step with the subsidiarity principle.

The Committee therefore recommends amending
5.12.2
these provisions of the regulation in such a way as to ensure
sufficient uniformity in national procedures while avoiding
preventable delays and ensuring sufficient compliance with the
subsidiarity principle. To this end, one possible approach would
be to limit the licensing process to an obligation on the part of
national authorities to notify the Commission. If infringements
take place, the Commission could have recourse to the tried-
and-trusted instrument of an infringement procedure under
Article 226 of the EC Treaty. The text of Article 10 could there-
‘The competent national authority shall notify the
fore read:
Commission of its decision on storage permits, for the purpose
of verification’.

5.13
The EESC believes that the national authorities require
effective instruments and also need to carry out regular checks
in order to ensure the safety of storage sites at all times. The
EESC does, however, doubt whether this goal is furthered by the
for an additional review of storage
Commission's proposal
further
permits every five years. This provision would not
enhance safety but would give rise to additional bureaucracy
affecting all stakeholders.

5.14
Article 18 of the proposed Directive sets out stringent
demands in respect of the transfer of responsibility for storage
sites to the respective Member State. The EESC welcomes these
provisions which are the right course of action.

5.14.1
Article 18(1) of the proposal calls, however, for all
the stored CO2 will be
available evidence to indicate that
‘completely’ contained for the indefinite future. Absolute leak-
tightness cannot, however, be assured, and should not therefore
be made a requirement. In this context, the EESC would, there-
fore, refer to its comments in points 5.7.3 and 5.7.4.

Brussels, 9 July 2008.

5.14.2
To avoid creating insurmountable obstacles to the
transfer of responsibility, the passage in question should read:
‘… all available evidence indicates that leakages are not to be
expected for the indefinite future (19)’. (This is in line with the
definition referred to in point 5.7.3 above).

5.15
Under the Commission's proposal, it is essential for the
undertaking to lodge a financial security when developing
storage sites and starting storage operations (Article 19). The
EESC endorses this provision and welcomes the fact that respon-
sibility for determining the form of this financial security is to
be in the hands of the Member States.

In the EESC's view, it is not, however, appropriate for
5.15.1
the security in question to be provided,
in full, prior to the
submission of the application for a storage permit. Rather, the
financial security payment should in principle be geared to the
security required at that particular stage of the project. Failing
this, the financial incentive for companies to invest in this new
technology, which has in any case been insufficient up to now,
will be even lower.

In the event of

5.15.2
leakages which could impact on
climate change, additional emissions certificates will have to be
purchased subsequently. In view of the extensive investigations
preceding awards of storage permits,
it is unlikely that such
leakages will occur. Proof of sufficient assets which are accessible
even in the event of storage operators becoming insolvent
should therefore suffice as financial security. Given the remote
probability of such an eventuality, requiring more than this
would place a disproportionate burden on companies' invest-
ment capacity.

Some of

the procedures

for
5.16
characterisation and assessment of storage sites are still at the
R&D stage. To ensure the manageability of such procedures in
practice,
to
‘state-of-the-art’ technology.

required in Annex I

documentation

requirements

should

refer

In Annex I and in the risk assessment of potential
5.17
storage sites,
the concept of biospheres should be clarified.
Biospheres in which no negative impact is permitted should
include not only biospheres on the earth's surface but also
biospheres down to the level of drinking water aquifers.

Details

5.18
should also be given of membership and
working methods of the expert group responsible for ongoing
revision of the Annex.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

(19) Translator's note: footnote does not apply to the English-language

version.