IOGP Europe key principles on a future regulatory framework for CO2 transport infrastructure

General comments:

For CCS to reach commercial scale, it is crucial to develop a reliable infrastructure, both onshore and offshore, to ensure the transport of captured emissions from the source to storage. To facilitate this, risks and rewards between entities operating along the value chain need to be properly allocated, including through long-term contractual arrangements. In addition, dedicated funding and de-risking mechanisms will be needed at least during the industry build-up phase to complement incentives from the EU ETS. (Please see also IOGP Europe’s policy brief ‘Creating a sustainable business case
for CCS value chains – the needed funding and de-risking mechanisms’).

The Communication Industrial Carbon Management (ICM) recognises the crucial role of CCS in reaching climate neutrality and includes a list of actions to ensure its deployment at scale. In particular with regard to CO2 transport infrastructure, the Communication indicates that the Commission plans to start already in 2024 working on a possible future CO2 transport regulatory package.

In this context, we recommend the Commission to take a balanced approach when developing such a regulatory framework: some investments may benefit from regulation, while others may be hampered or even not done at all because of unfit-for purpose-regulation.

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