Updating the environmental regulation of liquified CO 2 storage in ports to support carbon capture and storage plans in the UK

Carbon capture and storage (CCS) is central to the UK's Net-Zero Strategy, with shipping and ports playing a key role in enabling flexible CO 2 transport and storage (T&S) where pipelines infrastructure is not available. However, the regulation of the temporary storage of liquified CO 2 (LCO 2 ) in UK ports remains underexplored, particularly under the environmental permitting (England and Wales) Regulations 2016 (EPR). In this paper, we critically assess the EPR's suitability for regulating temporary LCO 2 storage in ports in support of CCS. We examine the scope and limitations of the EPR's current CCS regime and explore whether other provisions can address the regulatory gaps that arise when storage occurs away from capture sites. We identify key barriers that risk delaying the environmentally safe deployment of port-based LCO 2 storage. Our findings show that, while the EPR provides a solid foundation for environmental protection, it lacks the clarity and flexibility needed to address the regulatory complexities of shipping-based CCS and non-pipeline transport (NPT). We propose targeted regulatory reforms to improve legal certainty, support infrastructure rollout, and align environmental safeguards with net-zero goals. Our analysis informs ongoing UK decarbonisation policy and highlights regulatory issues likely to emerge internationally as CO 2 shipping scales up.

CLARITY · Environmental regulation · Pipeline transport · Software deployment · Carbon Dioxide Capture Technologies · CO2 Sequestration and Geologic Interactions · Integrated Energy Systems Optimization