Continuous storage may be subject to multiple regulatory regimens (and varied siting, licensing, and monitoring requirements) at various government levels. Moreover, storage rights to the large amount of belowground space that needs to be set aside to hold the lifetime emissions of a facility like a coal plant presumably need to be acquired at the start of a project. That involves a cost that is usually not recognized in storage-cost calculations. Depending on the details of the regulations and the degree of isolation from human settlements that is ultimately required for storage-well fields, surface-land costs may also exceed initial expectations.

One feature of CCS that improves the odds that deployment will evolve without major disruption is that many of the early CCS projects will be enhanced oil-recovery projects. These would be at sites where the general population is already familiar with and generally favorably disposed toward the oil and gas industry and where revenue streams will benefit all royalty holders, including local and state governments (Anderson and Newell, 2004; Socolow, 2005). One can expect less resistance to CCS in such instances.

Each of the aforementioned risk factors may be anticipated rationally, handled smoothly, and reflected in the cost of capital and insurance for storage operators. Or they may be ignored by all parties until experience establishes them as low risks or they cause systemic disruption of operations on a wide scale, as occurred in the United States in the case of nuclear-power-plant construction and long-term waste disposal and to a lesser extent in nuclear-power-plant operation.

There are examples of cases in which risks associated with storage were handled in the normal course of events—with smooth and reliable licensing, operation, and monitoring—and regulatory delays did not cause a serious financial burden or were appropriately recognized and incorporated in planning. CO2 is routinely transported over long distances, injected underground, and stored without much attention being paid by the public or policy makers. Natural-gas storage and chemical storage are long-time facts of life (Reiner and Herzog, 2004), and even serious accidents and leaks do not threaten operations, at least on an industry-wide basis. But counter examples, from Bhopal to Three-Mile Island to Yucca Mountain, are also easily cited. Furthermore, the proposed scale of CO2 storage puts it in a class by itself, and the public reaction to failure may be unique and unpredictable. Such uncertainty needs to be reflected in estimates of the cost of implementation of this technology.



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