It is clear from the above that all these important plans are absent at this stage of the procedure. This fact, however, as is evident, does not pose any obstacle to make a submission for the European Commission opinion on the draft CCS storage permit. In any event this also represents a valuable procedural experience worth of further exploiting in any future cases relating to EC opinions on CCS draft storage permits.


In the light of the significance of the above deficiencies it could be seen as a little technical irregularity that, as the Commission observes in its opinion, contrary to Articles 8(1)(a), 9 point 8, 11 of the CCS Directive “the draft permit does not contain specific provisions on changes, review, updating and withdrawal of the storage permit”.