On 23rd January 2025, ADBA submitted its response to the UK ETS Scope Expansion – CCS: Non-Pipeline Transport of Carbon Dioxide consultation. We have set out our position on how non-pipeline transportation (NPT) of CO2 can best serve the UK’s net-zero ambitions. Our response focused on creating practical, cost-effective, and workable solutions for AD operators of all sizes.
For emissions factors, we strongly support Option 2. This approach would incentivise low-carbon transport while accommodating AD operators’ diverse needs. It enables zero-rating for electric vehicles and recognises biomethane as fuel. It also allows AD plants to use their own green gas for CO2 transport.
Small-scale operators and SOFAD (Small On-Farm AD) facilities face specific challenges such as limited storage space and continuous operations. That’s why we advocate for Option 3’s mixed regulation for intermediate storage. This framework provides the necessary flexibility in scale, financing, business operations, and network access for smaller operators while maintaining appropriate oversight.
The Government’s proposed timeline for implementing NPT regulations in the late 2020s significantly underestimates the AD sector’s readiness to contribute to the UK’s carbon reduction goals. Our sector is already capable of delivering 200,000 tonnes of CO2 annually through existing gas upgrader plants, with the technical capability to begin operations much sooner. Given AD’s potential to contribute to the UK’s carbon budgets and provide 10% of gas imports by 2030, ADBA advocates for earlier implementation to capture immediate negative emissions opportunities from our established sector.
AD, with its proven technology and established CO2 capture capabilities, offers a practical starting point for implementing NPT regulations. Our industry already delivers both economic and environmental benefits across multiple sectors – from agriculture to waste management and renewable energy. This cross-sector experience, combined with our diverse range of operators, provides valuable insights for developing effective NPT regulations.
For more information, contact our Policy Team at policysupport@adbioresources.org.
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