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A Response to DESNZ Call for Evidence on Greenhouse Gas Removals

Summary

This submission, authored by Dr Wassim Dbouk of the ¾ÅÉ«ÊÓÆµ Marine and Maritime Institute (SMMI), responds to the Department for Energy Security and Net Zero’s Call for Evidence on Greenhouse Gas Removals. It highlights the critical role of COâ‚‚ shipping infrastructure in enabling large-scale carbon capture and storage (CCS), particularly for industrial clusters without pipeline access. Ports must serve as multi-modal hubs for aggregating, storing, and transferring liquefied COâ‚‚ (LCOâ‚‚) to offshore storage sites.

The UK is well-positioned to become a cross-border CO₂ storage leader, but regulatory gaps pose serious barriers. Current legislation—including COMAH, DGHAR, and the Environmental Permitting Regulations—fails to address the risks and scale of LCO₂ port operations, creating uncertainty for investors and weakening public confidence in safety and environmental governance.

To address these challenges, Dr Dbouk recommends updating COMAH to include COâ‚‚, extending environmental permitting to cover LCOâ‚‚ handling at ports, and issuing a dedicated Marine Guidance Note. Without urgent reform, the UK risks undermining its CCS ambitions and missing out on a major climate and economic opportunity.

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Authors

Dr. Wassim Dbouk – Research Fellow, ¾ÅÉ«ÊÓÆµ Marine and Maritime Institute- University ofÌý
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