A snapshot of the CCS PP 14 of 2024, Indonesia.

The website:?www.ipa.or.id recently published a concise note on the new Presidential Regulation (PP) No 14 of 2024 regarding The Implementation of Carbon Capture and Storage Activities”. An English translation has also been prepared by INVESTINDO (supporting legal professions).

News Item; The Government of Indonesia has finally released the highly anticipated Presidential Regulation on carbon capture and storage (CCS) hub. “The eagerly awaited CCS presidential regulation has been released on January 30, 2024. This regulation is anticipated to serve as a promising foundation for Indonesia’s journey towards becoming a regional CCS hub,” Belladona Troxylon Maulianda, Executive Director of the Indonesia Carbon Capture and Storage Centre (ICCS), said on Wednesday. Presidential Regulation No 14/2024 would allow non-oil and gas industries to store CO2 in depleted oil and gas working areas. The new regulation would also facilitate cross-border CCS implementation to support the country’s ambition of developing CCS hubs that would store CO2 transported from emitters overseas.

This following is a personal short overview from a non-oil & gas geologist perspective. This note should not be used for commercial decisions. I apologize for any errors, omissions or misunderstandings herein.

·??????? The regulations are laid out in the usual logical manner to provide assurances going forward, but also most chapters apply the regular qualifier that further implementing provisions are yet to be developed by the Minister. Note that the minister holds all the authority to approve or disapprove a wide range of activities. The permit procedures for Aceh are slightly different. Permits often require coordination with departments related to spatial planning, environment & forestry, and maritime & fisheries. SKK Migas are a key player in to the permit process.

·??????? Carbon Captured as applies from processing activities at upstream Oil and Gas facilities Natural Gas, refineries in Oil and Gas business activities Earth, power generation activities, industrial activities, and other emission producing activities, both internal and external overseas. Carbon Injection and Storage can be carried out in Depleted Reservoir, Saline Aquifer Storage, or coal seams.

·??????? Present Oil & Gas Cooperation Contracts that do not include CCS provisions shall be amended.

·??????? CCS underground storage areas are seen as a contractor business, whereupon licenses are to be auctioned by the Minister, along with Right to Match provisions etc. Licenses are accompanied with various ESG reports, financial guarantees, and tax compliance. Exploration of underground CCS is confirmed by a feasibility report, further guarantees, certification etc before a storage Operation Permit license is issued for up to 30 years. Thereafter an annual work plan is required, along with training and maintaining an emergency response team for up to 10 years post closure. Post operative collateral is required. There are clauses that relate to the monetization of CCS through fees for storage. All goods acquired for the CCS enterprise become State Property.

·??????? In the event that a leak results in addition greenhouse gas inventory, in addition to corrective measures the permit holder is required to carry out emission offsets.

·??????? Several articles relate to the permitting for transportation of CO2 (truck, pipe, boat or other) for 20 years with extensions. Cross border transport of CO2 requires government to government support.

·??????? Carbon Storage Capacity are obliged to allocate amounting to 70% (seventy percent) of the total capacity Carbon Storage as Domestic Carbon Storage. CCS businesses can allocate 3O% ?of the total capacity Carbon Storage for use as Storage of Carbon originating from abroad.

Comment for coal miners.

1)???? I might assume this regulation may not have significant overlap with the research efforts & future commercialization of insitu coal gasification projects. Insitu coal gasification typically target coal at depths of around 300m, while coal CCS targets may be much deeper. However, the need for CCS may add unrealistic costs and impositions on future commercialization of insitu coal gasification projects.

2)???? Coal upstreaming of coal to DME etc, may look to this PP as a guide to their CCS requirements for capital and permitting process. To date the sighting for future coal conversion plants tends to favour short coal hauling, but future provisions on CO2 gas transport may need to be also taken into account.

3)???? Several operating coal leases have developed workable protocols with overlapping with oil & gas leases. Now some oil & gas business may need further cooperation with coal companies for their development of new CCS lease areas.