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Request for comments - Carbon Capture Usage and Storage policy proposals

The Department of Business, Energy and Industrial Strategy has launched a pair of consultations examining policy proposals around the development of a UK Carbon Capture Usage and Storage industry as part of the UK's decarbonisation commitments.

The Geological Society is preparing responses to these consultations, focusing on areas where expertise from geoscientists and industry can provide additional clarity and evidence, and is seeking expert input from Fellows. 

An overview of the relevant content and questions can be found below. Key questions are in red.

If you have any comments on any of the below that you think would be relevant to include in a Geological Society-led submission, please contact the Head of Policy and Engagement Florence Bullough at policy@geolsoc.org.uk before Friday 23 August.

BEIS Consultation - Carbon capture, usage and storage (CCUS) projects: re-use of oil and gas assets

This consultation focuses on the re-use of existing oil and gas infrastructure and how this might be re-purposed as part of a CCUS transport and storage network. The Department are seeking views on the following relevant areas.

  • The document states that the number of assets that could be reused as part of the transport and storage infrastructure of a CCUS project is small. Is this a consistent view across the oil and gas sector? (Paragraph 13)
  • The document details types of oil and gas infrastructure that have a potential for re-use. These are depleted oil and gas reservoirs, wells, trunk pipelines, platforms, other infrastructure (Paragraph 15). Have they identified the correct types of oil and gas infrastructure that are likely to be important for re-use in CCUS projects? 
  • There is a discussion on criteria that due consideration would need to be given to before deciding upon the re-usability, or otherwise, of a specific asset for the purposes of CCUS. These are location, size, age, condition, reservoir integrity and appropriateness, pressure, metallurgy and materials, pipeline integrity, data and costs. Are there additional or different criteria that would need to be considered when assessing whether a piece of offshore infrastructure is reusable as part of a CCUS project?
  • There is a preliminary assessment of the UK oil and gas infrastructure against the above criteria and this has resulted in a preliminary list of specific items of infrastructure that BEIS currently consider to be most likely to have potential for CCUS re-use. The list can be found at Paragraph 17. Do you agree with this preliminary assessment? Should any specific assets detailed in Table 1 (page 12) or in Annex A be removed?
  • There is a section detailing the potential challenges to overcome when considering the re-use of assets for CCUS projects. These include the potential for assets to be decommissioned before CCUS comes online, the need for ongoing monitoring and maintenance if the assets are fallow and where the responsibility for decommissioning lies. Are there any additional substantial barriers to the effective transfer of assets? Are changes to the current policy and legislative regimes needed to help facilitate the re-use of oil and gas assets for use as part of a CCUS project?
  • On the preservation of assets, are there any monitoring or data collection activities, such as intelligent pigging, that it would be essential to carry out before preserving an asset for CCUS re-use?
    • Evidence presented to the Government to date suggests that the costs of maintaining pipelines or wells for re-use are relatively low and so financial support for this will likely not be required. Do you agree with this?
    • Will plugging and abandoning wells to a standard which minimises the risks of carbon dioxide leakage in the associated field come at significant costs? And if so, who should bear that cost?

You can find the full consultation document on the GOV.UK website.

BEIS Consultation - Business models for Carbon Capture Usage and Storage

This consultation focuses on the potential new business models for a CCUS industry. This consultation is broadly looking at the following two questions:

  • Have the correct parameters been identified to guide the development of CCUS business models?
  • And views on how the business models might be integrated.

Relevant questions in this consultation focus on risks to assets, opportunities and allocation of risk between government and CCUS developers. Things that would be useful to gather evidence on are:

  • Comments on the potential for clustering, i.e. clusters of carbon capture and storage plants and CO2 usage industries but also proximity to sequestration infrastructure. Are there things missing in the report that need considering? Should the clusters also take into consideration the location of the required skilled professionals?
  • There are a number of CCUS risks set out in Chapter 1, is there anything missing in terms of proposals to mitigate CCUS-specific risks? Are there any other risks that need to be considered? How might these be mitigated?
  • The report sets out a plan to separate funding models for carbon capture from carbon dioxide transport and storage infrastructure. Do you agree that this is the best approach?
  • The report is also consulting on the potential use of CCUS to decarbonise hydrogen production due to hydrogen's potential role in a clean energy future both in the UK and internationally. The consultation is seeking views on the following:
    • Should there be a focus on hydrogen production at this stage? Or should the government focus on other parts of the hydrogen value chain next?
    • What might be the demand for hydrogen and how might plants be sized to accommodate?
    • The document sets out the role of hydrogen to decarbonise the gas grid but with limited benefit. Any comments on this?
    • Chapter 6 sets out the capabilities required to deliver CCUS in the UK. Is this a comprehensive list?

You can find the full consultation document on the GOV.UK website.