CO₂ NPT and cross border transportation of CO₂ are issues hot in the minds of many CCUS project stakeholders across the value chain. The issues are wide ranging – regulatory and commercial – with careful consideration needed at a national and international level.

Stakeholders will therefore welcome the publication of DESNZ's much-anticipated CCUS non-pipeline transport (NPT) and cross-border CO₂ networks call for evidence (CfE), giving the market the opportunity to input on future policy development and help the UK Government better understand the needed building blocks for an effective network of NPT for CO₂.

The future for NPT in the UK

DESNZ anticipates that the transportation of CO₂ from emitter to store by means other than pipeline (including road, rail, barge and ship) within the UK will likely take place during what it has coined the “market transition phase" between 2030-2035 - ahead of the establishment of a self-sustaining market phase from 2035 onward. 

DESNZ considers that the market is best placed “to effectively and efficiently resolve their specific NPT challenges” and intends to allow ‘self-organisation’ to occur, rather than mandating organisational and commercial structures through policy and regulation. This position will likely be welcomed by project participants, provided that the required regulatory certainty is in place to support these structures.

That said, the UK Government considers there to be three main NPT delivery archetypes and seeks feedback on these:

• Store Led – placing responsibility for CO₂ collection on the store.   
• Capture Led – capture project carries the responsibility for delivering the CO₂ to the store, providing flexibility to the capture project to select which store it connects with.
• Intermediary Led – a third-party entity facilitates the connection between the capture project and transport and storage company (T&SCo).

It also considers issues of operational flexibility and competition, as well as seeking views on NPT value chains.

Cross-border CO2

The UK has huge potential in a world of operational cross-border CO₂ transportation and storage (T&S) networks. A cross-border T&S network, including both NPT and cross-border pipelines, can facilitate international CO₂ imports to the UK, whilst also providing the option of UK exportation of CO₂ if needed. The UK Government is asking for input on how the international CO₂ market might develop and what the regulatory and commercial framework needed to support this may look like.

The DESNZ consultation is a strong starting point for setting out the current thinking of the UK Government on some of the key issues of CO₂ cross-border networks, including cross-border NPT. However, an obvious omission is specific mention of the London Protocol and the legal barrier to cross-border transportation of CO₂ that it creates.

The CfE closes for comment on 16 July 2024, with future policy decisions expected thereafter. 

Our team have advised the Carbon Capture and Storage Association (CCSA) in relation to potential NPT models for the UK CCUS sector and invested in seeing how this will play out in practice, having been a part of developing the three NPT business models currently under consideration by DESNZ.