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Clarification questions (added 22 April 2026)

Q001:聽What types of Greenhouse Gas Removal (GGR) Projects would be eligible to apply?

There is no limitation on what kind of CCS-enabled GGR Projects are eligible to apply for the NPT Pathfinder (for instance, what sub-sector they belong to or what technology they use), provided that all eligibility criteria are met (see Chapter 4 of the Application Guidance). The Project could apply via the Transition Access Agreement of the GGR Business Model. The Project could be made up of a single capture facility or aggregate CO₂ from multiple capture facilities within a single application. Any Projects which apply which do not meet the eligibility criteria will be excluded at the eligibility check stage (see Chapter 2 of the Application Guidance).聽

蚕002:听奥丑补迟 CCUS terminals are available at Teesside for projects to connect through?

The guidance does not聽designate聽or approve any CCUS terminals at Teesside for projects to connect through and the applicant鈥檚 proposal will be assessed through the application process. The applicant聽is responsible for聽identifying, assessing, engaging with, and securing access to any existing terminal(s) or alternative connection solution. Projects are welcome to propose their own solutions for connection, provided these meet the requirements set out in the Application Guidance and are adequately聽evidenced, including section 4.1.2 where DESNZ expects applicants to be the legal owner and operator of the delivery point.

Clarification questions (added 1 May 2026)

Q003: The EU CRCF BioCCS methodology does not include emissions arising prior to carbon capture from the normal operation of the underlying facility generating the biogenic CO₂ stream. Annex A4 Section 3.7 states: 鈥淚f the EU CRCF permanent carbon removal regulation provides insufficient details on any specific aspect, Applicants may supplement the CRCF requirements with guidance from existing methodologies from the voluntary carbon markets, with justification for their selection.鈥� Would it be appropriate to supplement the CRCF methodology with an allocation approach so that pre-capture emissions from a multifunctional BECCS process can be appropriately attributed between the valuable co-product and the captured CO₂ stream?

For the purpose of the application, we are requesting projects to apply the EU CRCF Permanent Carbon Removal methodology. Removals are generated when there is more carbon stored in the project than in the baseline scenario, using a consequential life-cycle analysis (LCA) rather than an attributional LCA. The CRCF methodology considers the removal project boundary starts at the carbon capture unit. The reason for this is that the CRCF is assuming that the biomethane plant would have existed anyway in the baseline. If it exists both in the baseline and in the version with carbon capture and storage, then the emissions associated with it, including from biomass, cancel out when computing the 鈥減roject minus baseline鈥� removals. For simplicity, the CRCF ignores the upstream plant (e.g. bioenergy, biomethane) and its biomass supply chain emissions. In section 4.3.1 of the Permanent Carbon removal delegated act, the CRCF says: 鈥淎ny biomass, biofuel, bioliquid or biomass fuel from which CO₂ emitted is captured shall be consumed with the primary purpose of generating a product other than CO₂ for capture鈥�, reinforcing this assumption that the upstream plant is needed for its primary product.

Note that in the same section, the CRCF stipulates 鈥淲here the feedstock processed at the installation from which CO₂ is captured includes food and feed crops or food and feed crop-based biofuels, bioliquids or biomass fuels, it is not permissible for energy derived from that feedstock to be used to operate the capture process, excepting the case of recovered heat.鈥�

For the purpose of the application, you should therefore follow the CRCF methodology and consider the life-cycle analysis within the boundary of the carbon capture and storage process. This will not include the biomass supply chain emissions which are fully attributed to the co-product (e.g. energy, biomethane). However, note the CRCF Permanent Carbon Removal delegated act section 4 includes biomass sustainability requirements applicable to all the biomass used to generate CO₂.

Clarification questions (added 8 May 2026)

Q004: What evidence is needed to demonstrate eligibility for TAA where financial support would not be needed for capital or operational expenditure, noting that projects are at concept stage at the point of application?

Applicants should provide a clear description of the project concept and proposed use of the TAA including a statement of assurance that financial support would not be required from government. This may be supported by appropriate evidence of intent and capability to progress, such as sponsor backing or internal or Board level approvals and, where applicable (for example, for carbon removal projects), indications of engagement with carbon credit purchasers, such as letters of intent or support from voluntary carbon market buyers.

Q005: Are entities which purchase CO₂ from third parties and take ownership of the CO₂, but which are not receiving terminals or aggregation hubs, eligible to apply for the NPT Pathfinder?

No. Under the NPT Pathfinder, entities that purchase CO₂ from third parties and then take ownership of the CO₂ are not eligible to apply. The NPT Pathfinder requires Applicants (include those aggregating CO₂ from multiple Capture Facilities) to include all Capture Facilities which will export CO₂ to the ECC T&S infrastructure within the Project itself. The guidance explicitly excludes applications from entities that subcontract Capture Facilities to provide CO₂ or purchase CO₂ from third parties, regardless of whether they take ownership of the CO₂. Note that joint ventures (or equivalent commercial partnerships) between different elements of the Project can act as the Applicant in order to fulfil this requirement.

Q006: Under the contracts on offer for NPT Pathfinder (GGR BM and TAA), would an application be eligible for NPT Pathfinder if an intermediary were to develop and operate an intermodal facility looking to inject CO₂ into ECC?聽If such projects fall outside the current eligibility criteria, what is the reasoning and is a future process being considered to accommodate this type of project?

Intermediaries are not eligible to apply to the ECC NPT Pathfinder where they act as entities (e.g. receiving terminals or aggregation hubs) that purchase CO₂ from third parties or subcontract Capture Facilities, even if they take ownership of the CO₂.聽 Such intermediary-led projects fall outside the current eligibility criteria for the NPT Pathfinder.

The reasoning is that the Pathfinder is deliberately scoped to projects that are compatible with the existing CCS Network Code and current UK CCUS allocation and governance frameworks, requiring a single legal entity that includes all Capture Facilities and a single, unique T&S delivery point.聽 This scope is intended to accelerate near term deployment and avoid delays associated with changing the Code. However, as set out in the NPT Consultation, government acknowledges the potential benefits aggregation or intermediary models could deliver. The NPT Consultation sets out the preferred approach towards allowing intermediary approaches in the future, but confirmation of that position is subject to the outcomes of the consultation process. Should the preferred position set out in the NPT Consultation be confirmed, the anticipation would be that intermediary approach would be eligible for future selection rounds but would be subject to the design of any future, yet to be agreed, selection process.

Q007: How binary is the application process? In the event that an application requires CO₂ aggregation from a number of sites, each at different levels of readiness, the guidance is clear that an application with any 鈥楻ed鈥� rated supply, however small, will likely be unsuccessful. However, would a small portion of amber or amber/green similarly downgrade a predominately green-rated application?

The process is binary only at the point of a Red rating. For aggregated projects, a small proportion of Amber or Amber/Green Capture Facilities does not automatically downgrade an otherwise Green aggregated Project. The Application Guidance is explicit that a Red rating for any Capture Facility is likely to result in a Red rating for the Project as a whole, however there is no equivalent 鈥渁utomatic downgrade鈥� rule for Amber or Amber/Green elements. Instead, Amber or Amber/Green ratings are considered through an overall, holistic Project level judgement. Deliverability is assessed in the round, taking account of the relative scale, risks and mitigations associated with aggregating multiple Capture Facilities.

Q008: Are individual applications able to split capacity between the GGR business model and the TAA - for example, 130kt under GGR and 30kt under TAA (with T&S support)?

A single application cannot split capacity between the Greenhouse Gas Removals (GGR) Business Model and the Transition Access Agreement (TAA). Each Project application must proceed under one route only and, if successful, will enter into a single contract 鈥� either a GGR Business Model contract or a TAA, not both.