Summary
This submission, authored by Dr Wassim Dbouk of the Southampton 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 CO₂ 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 CO₂ (LCO₂) 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 CO₂, extending environmental permitting to cover LCO₂ 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.
Authors
Dr. Wassim Dbouk – Research Fellow, Southampton Marine and Maritime Institute- University of
Southampton
