Summary/Abstract
This paper identifies the legal, regulatory and economic challenges in the USA, Canada, EU, Australia, and Brazil that must be addressed if an enhanced oil recovery (EOR) project is to serve as a CCS project. The paper finds that there is a clear regulatory framework for CO2 EOR and for CCS in most regions but there are insufficient provisions that would allow a CO2 EOR operator to follow a clear transition pathway for legal and regulatory approval of a CCS project. Permitting requirements for design, commissioning, operational management, decommissioning and post-closure site stewardship, if any, differ for CO2 EOR and CCS projects. The paper recommends that specific guidance or regulation be provided setting out the specific requirements on new and existing CO2 EOR projects which may wish to transition to CCS.