2. Introduction

By developing the first industrial CCS chain under the current European legislation the stakeholders have gained experiences that other CCS projects and their stakeholders can learn from.

In this report the regulatory issues and challenges and how these are solved for Longship are discussed and summarized in key learning points.

In the 2014 CCS strategy⁰²the Government set an ambition to realise a cost-effective solution for full-scale carbon capture, transport, and storage (CCS) demonstration in Norway, provided that this would result in technological development internationally.

In order to achieve this ambition, the full-scale CCS project “Longship” was launched by the Norwegian Government in 2020 after extensive pre-feasibility, feasibility, concept and FEED studies. Gassnova is a state enterprise established to promote technological development and build CCS competence, owned by the Ministry of Petroleum and Energy. Gassnova has been closely involved in the planning of the full-scale project since the beginning, producing early phase studies and later acting as a project integrator. Gassnova has administered the public funding to the industrial partners, coordinated the overall project schedule and managed the cross-chain risks and functionality. Gassnova has also established and coordinated a programme that aims to increase the probability of reaching the State’s objectives for Longship. Documenting and disseminating the experience and learning from Longship is an important part of this programme.

This report describes the development of Longship under the current Norwegian legislation. The CCS relevant laws and regulations are largely based on international frameworks and EU regulations. Several regulations are being applied for the first time on a full-scale CCS project. Both the industry and the state bodies have navigated unknown waters and needed to find common solutions for specific issues based on first-time interpretations of the regulations. Where relevant, Norwegian authorities have also consulted with the EU Commission on its legislative interpretations.

The commercial framework for the companies is defined by state aid agreements between the companies and the state. In this report, Gassnova will show how these agreements relate to the current laws and regulations.

This document is based on Gassnova’s experience as a project integrator and its ongoing engagement with the industrial partners in Longship: Hafslund Oslo Celsio (formerly Fortum Oslo Varme), Heidelberg Materials and Northern Lights. Gassnova has also incorporated important input from the Norwegian Environmental Agency and the Ministry of Petroleum and Energy.

2.1 About Longship

Longship is a CCS demonstration project. The project “shall provide the necessary development of CCS to ensure that Norway’s and the EU’s long-term climate targets can be achieved at the lowest possible cost ”⁰³.

Longship covers the capture, transportation and storage of CO₂. The Norwegian state is providing state aid to Heidelberg Materials for the first capture project in Longship. Northern Lights is a partnership between Equinor, Shell and TotalEnergies, which, with state aid, will implement the CO₂ transportation and storage parts of Longship. Construction of the Northern Lights CO₂ transport and storage infrastructure and the Heidelberg Materials plant is on schedule to start operation in late 2024 as planned⁰⁴.

The Government was also planning to make Hafslund Oslo Celsio (formerly Fortum Oslo Varme) a part of Longship, provided it secured sufficient financing. A new industrial joint venture of Hafslund Eco, Infranode, and HitecVision, named Hafslund Oslo Celsio, entered an agreement to acquire Fortum Oslo Varme in March 2022. In June the Minister of Petroleum and Energy Terje Aasland signed a funding deal securing the realisation of carbon capture operations at Hafslund Oslo Celsio’s waste incineration plant at Klemetsrud in Oslo. The plan is for the capture plant to be operational from 2026.

The captured CO₂ from Heidelberg Materials’s cement plant in Brevik, and from Hafslund Oslo Celsio’s waste-to-energy plant in Oslo will be transported in liquid form by ships to Northern Lights’ CO₂ receiving terminal in Øygarden on the Norwegian west coast. From there, the liquefied CO₂ will be transported by pipeline to an offshore storage location under the North Sea for permanent storage. Heidelberg Materials’s capture project, named Brevik CCS, and the Northern Lights project started construction in late 2020.

Longship is a first-of-its-kind project and will contribute to innovation in several ways⁰⁵:

■ Demonstration of a full and flexible CCS chain with carbon capture from cement production (and potentially from waste management), shipping to a receiving terminal, and CO₂ storage beneath the seabed on the Norwegian continental shelf.

■ Practical implementation of European and Norwegian regulations in projects involving a complete CCS chain consisting of different stakeholders. The project demonstrates, among other things, the use of the EU ETS and the EU Directive on CO₂ storage.

■ A flexible transport and storage solution that will have the capacity to receive CO₂ from many different sources.

■ A commercial framework that provides incentives for further development of CCS in Europe.

Although Heidelberg Materials, Hafslund Oslo Celsio (called Celsio in the following), and Northern Lights have received state aid throughout the project development phase, each industrial partner has been responsible for their own project. In the realisation phase the industrial stakeholders own, construct and operate their own facilities. However, the state continues to provide state aid and assumes some of the risks, including risk related to the interfaces between the industrial partners.

In the first phase, Longship has an annual storage capacity of 1.5 million tonnes of CO₂. This exceeds the 800,000 tonnes of CO₂ allocated to Heidelberg Materials and Celsio. This means that Northern Lights will have the capacity to receive CO₂ volumes from other sources. The pipeline from the onshore facility to the storage site has been built with an annual capacity of 5–7 million tonnes. Northern Lights intends to expand its storage capacity to 5–7 million tonnes per year. The European Commission has announced that EU countries have agreed to support Northern Lights under the Connecting Europe Facility (CEF) funding scheme, earmarked for Front-End Engineering Design (FEED) studies for the expansion.

The goals of Longship

THE SOCIETAL GOAL:

“The demonstration of CCS shall provide the necessary development of CCS to ensure that Norway’s and the EU’s long-term climate targets can be achieved at the lowest possible cost.”

FOUR IMPACT GOALS

The project shall:

■ generate knowledge to show that fullscale CCS is feasible and safe

■ provide productivity gains for future projects through learning and economies of scale

■ provide learning related to regualtion and incentivisation of CCS activities

■ facilitate business development

Public sector bodies involved in Longship

The principal responsibility of the Ministry of Petroleum and Energy is to achieve a coordinated and integrated energy policy⁰⁶.

Gassnova is a state enterprise established to promote technological development, competence building and cost effective CCS solutions. Gassnova reports to the Ministry of Petroleum and Energy⁰⁷.

The central tasks and responsibility of the Norwegian Environmental Agency⁰⁸ are to manage Norwegian nature and prevent pollution. The Norwegian Environmental Agency reports to the Ministry of Climate and Environment.

The Norwegian Petroleum Directorate⁰⁹ is a specialist governmental directorate and administrative body. The directorate’s primary objective is to contribute to the greatest possible values from the oil and gas activities to the Norwegian society, through efficient and responsible resource management The Norwegian Petroleum Directorate reports to the Ministry of Petroleum and Energy.

The overall task of the Norwegian Directorate for Civil Protection¹⁰ is to maintain a complete overview of various risks and vulnerability in general. The Norwegian Directorate for Civil Protection’s responsibilities cover local, regional and national preparedness and emergency planning, fire safety, electrical safety, handling and transport of hazardous substances, as well as product and consumer safety. The Norwegian Directorate for Civil Protection reports to the Ministry of Justice and Public Security.

The Petroleum Safety Authority¹¹ is a government supervisory and administrative agency with regulatory responsibility for safety, the working environment, emergency preparedness and security in the petroleum sector. The Petroleum Safety Authority reports to the Ministry of Labour and Social Inclusion.

The EFTA Surveillance Authority (ESA) monitors compliance with European Economic Area (EEA) rules in Iceland, Liechtenstein and Norway, enabling them to participate in the European Internal Market.

Key documents

Environmental Impact Assessment (EIA)¹² is a tool for integrating environmental concerns and considerations into the decision-making processes of governments at all levels.

Plan for development and operation of a petroleum deposit (PDO) and plan for installation and operation of facilities for transport and utilisation of petroleum (PIO):¹³

A PDO describes the development of a petroleum deposit, or several petroleum deposits taken together, and the consequences the planned development measures will have (impact assessment).

A PIO is a plan for construction, placement, operation and use of facilities for petroleum activity, including shipment facilities, pipelines, cooling facilities, facilities for production and transmission of electricity and other facilities for transport or utilisation of petroleum.