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The UK Government is conducting a consultation process with industry on its future Carbon Abatement Strategy to be published early in 2005.  The consultation document produced by DTI can be found at Consultation Document on CAT.

The submission was prepared from the standpoint of a newly formed small company providing consultancy and project management services on underground coal gasification in the UK and overseas. The specific responses relevant to UCG are as follows.

Do you think the UK has strengths and weaknesses in any particular areas of CATs? Are there any particular areas of CATs that you think we should focus on?

Answer:  The UK is strong in mining related, oil and gas technologies as well as process and power island design and construction. UK coal resources are vast, both on and off shore. The UK is the world leader in underground coal gasification in deep coal seams as a result of DTI support for the European trial and the subsequent UK initiative. The export potential for underground coal gasification in China and India is potentially huge and the global reductions in CO₂ that would result (from higher efficiency and lower cost CO₂ capture) would dwarf any UK initiatives on carbon reduction. 

Given that the power sector is becoming increasingly global in ownership and operation do you consider that the UK should itself develop CATs or should it leave this to other countries (such as the USA) and buy these in when required?

Answer:  The UK relies on the export of its technology to survive in a competitive world, but much of its traditional manufacturing base is being eroded by overseas competition. CATs and underground coal gasification are emerging technologies well suited to the UK’s design, consultancy and project management skills.   

Given the opportunities for hydrogen production from fossil fuels, how do you think this should feature in the Strategy?

Answer: The gasification of fossil fuels (coal, gas and oil) when combined with CO₂ capture naturally produces hydrogen. This is a strong reason to promote gasification over thermal processes for power generation, such as underground coal gasification because it provides a route to high efficiency power generation through fuel cells and zero emission transportation at the point of use. The CAT strategy is a bridge to zero emissions and hydrogen, generated initially from fossil fuels and later by renewable or nuclear energy.

What do you consider to be the potential barriers to the development and introduction of CATs? In your view how can the Government help to address them, for example through pricing of CO2 emissions through emissions trading or similar policies?

Answer: The CAT strategy for fossil fuels is competing for funding in a playing field which is tilted towards renewable energy and possibly in the future nuclear power.  One tonne of CO₂ avoided is the same whether from fossil fuels or other sources of energy.  There is little prospect that the UK Government will be able to use the European Emission Trading scheme to encourage the introduction of CAT. Extension of the Renewable Obligation to all CO₂ savings is likely to be a better way forward. Underground coal gasification with CCS offers one of the lowest cost route to CAT, and its introduction should be stimulated in the same way as renewable energy.

What do you think are the key features for CCS systems? How do you think CO2 storage should be monitored in the long term?

Answer: Successful monitoring of international environmental schemes, where large amounts of money are involved, is usually very weak and often subject to abuse and fraud. CO₂ monitoring of storage probably would be no different, even if it was technically feasible and economically viable. The CAT strategy needs to be designed much more broadly than gaseous storage in underground structures, as there is a real possibility that it will fail technically. Mineralisation with CO₂ (which requires high pressure gasification process such as underground coal gasification) and forestation are known routes to CO₂ storage that should be included in the CAT programme.

To what extent do you think that a strategy should focus on CATs for coal plant and natural gas plant? Should it, for example, give equal weight to reducing CO₂ emissions from both fuels?

Answer: The emphasis for the CAT strategy should be on coal, because:

• Coal will dominate power generation worldwide for the foreseeable future and solutions will have greater export market potential for UK industry.
• Coal has the highest carbon content per unit production of energy, and solutions to coal will have the largest impact on worldwide emissions of CO₂.
• Once coal is gasified, the downstream solutions for reducing CO₂ (higher efficiency turbines, lower cost CO₂ capture) apply equally to the product gas and natural gas.

What businesses and organisations do you think we should involve as stakeholders in a new CAT Strategy?

Answer: Because of the global implications of the strategy, priority should be given to those businesses and organizations engaged in the export of low carbon technology. In addition to the main equipment suppliers (turbines, thermal plant) efforts should be made to engage the engineering consultancies, process designers and SME’s (like UCG Engineering Ltd) in the process. The support and encouragement of Government (DTI, UK Trade & Investment, DEFRA) to secure UK demonstrations of the technology (CCS, UNDERGROUND COAL GASIFICATION, HYPOGEN) and have these supported in overseas collaboration programmes (IEA, EU Framework 7) is very important.

In your view, what should be the main components making up the scope of a CAT Strategy?

Answer: In addition to those identified in the Consultation Document, an examination of the fiscal regime for efficiency improvements and CCS should be included.:  A CAT strategy is essential but the greatest weight should be on efficiency improvements and demand management. The currently uncertain technologies of CCS should be considered as Research & Development options. By comparison with CCS, the document relegates underground coal gasification to a paragraph in an Appendix, when in fact it offers the possibility of lower cost capture of CO₂ and utilisation efficiencies for power generation comparable with natural gas.

What do you see as the critical technologies for development over the next 15 years?

Answer: The technical component of the strategy should involve:

• A demonstration programme of high efficiency power generation with capture, supported by R&D from industry and academia.
• Pilot plant scale investigations of new forms of CO₂ capture, e.g. membranes
• A semi commercial of high pressure and deep underground coal gasification with capture ready CO₂.
• An international collaboration programme on gaseous storage of CO₂ in oil and gas reservoirs, possibly including EOR
• More pilot scale research of other forms of CO₂ storage such as saline aquifers, mineralisation including verification.

Do you think the CAT Strategy should follow a two-track approach supporting incremental improvements to fossil fuel combustion technologies as well as CCS?

Answer: Yes, but the emphasis should be placed on efficiency improvements and demand management and how these can be implemented by Government and used to maximize CAT exports. It should be noted that the Chinese Government is embarking on the development of underground coal gasification in deep coal seams, and UK technology on underground coal gasification is at the forefront of this initiative.

Do you think we should have a further programme of supported R&D activity in the UK alone or should we place the emphasis more on international collaborative projects with some UK funding?

Answer: The R&D programme should be undertaken on an international basis, unless UK industry can benefit by securing IPR and using the knowledge to export the technology. CO₂ storage is particularly suitable for internationally collaboration, while better capture processes and the development of more efficient power plant is an area that should be led by UK industry for the purpose of developing export markets.

Do you think there are any specific actions needed to ensure that there is effective cooperation between academic and industrial research programmes on CATs?

Answer: While cooperation at project level between industry and academia is essential, there is little evidence from the Research Councils that CAT programmes rank highly, and Government needs to take initiatives to address this issue.

Do you think a large-scale demonstration project would be worthwhile in the near future? What do you think should be its objective and scope?

Answer: Single large scale demonstration could select the wrong technology and divert funding from more promising RDD. A series of pilot studies at reasonable scale and involving significant industrial support is amore cost effective way to demonstrate and test new CAT developments. The proposed pilot study of underground coal gasification in coal under the Firth of Forth, with support from a power utility is a good example of the type of project that should be supported.

What if any, additional actions do you think the UK Government should be undertaking to assess risks associated with CCS, either alone or in collaboration with other countries?

Answer: The risks of CO₂ storage are mainly site very specific and do not easily transfer to other projects. There may be opportunities to develop internationally agreed criteria for risk assessment, including leakage, and an opportunity for the UK to lead such a project should be taken if possible. A much wider view of CO₂ storage should be taken than simply storage in underground structures. The possibility of using cavities from underground coal gasification, and adjacent unmineable coal needs to be examined in detail.