Carbon Capture and Storage projects: navigating the licensing maze

Carbon Capture and Storage | Consents and Licensing

With the growing importance of Carbon Capture and Storage on the path to Net Zero, how can developers navigate the complex licensing requirements to achieve project consent?

Carbon Capture and Storage (CCS) is seen as a critical contributor to the UK’s Net Zero target, ensuring carbon dioxide emissions from industrial processes, power plants and other sources are either reused or stored, rather than entering the atmosphere and contributing to climate change. Experts from the Committee on Climate Change warn that “CCS is a necessity not an option” (CCC, 2019).

Considering this, the North Sea Transition Authority (NSTA) has launched the UK’s second offshore carbon storage licensing round, offering 14 new storage sites in depleted gas fields and saline aquifers across English and Scottish waters. These sites could collectively store up to 2 gigatonnes of CO₂, a huge boost to the UK’s carbon storage capacity.

The importance and challenges of the second licensing round

For developers and investors, the current licensing round (open until March 2026) is a chance to secure prime CO₂ storage locations and tap into government-backed decarbonisation initiatives. The first round in 2022–23 saw 21 licences granted, with some projects, like the Endurance and HyNet stores, already progressing towards the first CO₂ injection which could be as early as 2027 (NSTA, 2024).

Momentum is building, but securing a licence is just the beginning. Each CCS project must navigate a maze of environmental permits, consents, and compliance obligations before any carbon can be stored offshore.

The complexities of project permitting

CCS permitting in the UK is a multi-layered and technically demanding process. While securing a Carbon Dioxide Appraisal and Storage Licence from the North Sea Transition Authority (NSTA, formerly the Oil and Gas Authority) is a critical first step, developers must also obtain a suite of additional consents and environmental approvals before any offshore appraisal or injection activities can proceed.

The specific permits required vary depending on the scope and location of the project. For example, marine licences may be required from the Marine Management Organisation (MMO) for certain seabed activities within 12 nautical miles of the English coast, under the Marine and Coastal Access Act 2009. However, most environmental and operational consents for offshore CCS projects fall under the remit of the Offshore Petroleum Regulator for Environment and Decommissioning (OPRED), particularly where activities are regulated under oil and gas or carbon storage legislation.

OPRED administers a range of permits that are project-specific, including consent to locate (under the Energy Act 2008), chemical discharge permits (under the Offshore Chemicals Regulations 2002), and oil discharge permits (under the Oil Pollution Prevention and Control Regulations 2005). These consents are typically submitted via the UK Energy Portal’s Environmental Tracking System (PETS), which is operated by the NSTA and integrates multiple application streams through a Master Application Template (MAT) framework.

Given the number of statutory consultees involved—such as Natural England, the Joint Nature Conservation Committee (JNCC), Cefas, and others—early and proactive engagement with regulators is essential. This not only helps to clarify project-specific requirements but also supports a more efficient and coordinated permitting process, reducing the risk of delays.

Securing these approvals variously means:

• Understanding the permitting requirements in relation to the project scope (permitting mapping)

• Survey work: gathering data on the physical and ecological environment through on-site surveys and monitoring

• Completing Chemical Risk Assessments (CRAs), Environmental Impact Assessments (EIAs), Environmental Assessment Justifications (EAJs) and Habitats Regulations Assessments (HRAs with understanding of the compensation and derogation process)

• Specialistic geophysical studies, such as seabed mobility, Unexploded Ordnance (UXO) Risk Assessment and geohazard assessment

• Specialistic ecological studies, such as comparative assessments and habitat mapping

• Modelling (e.g. plume dispersion, oil spill modelling, underwater noise and navigational collision risk assessments)

• Coordinating with numerous stakeholder and regulators at each step

Ensuring all these pieces fit together requires deep knowledge of the regulatory landscape and OPRED’s licensing framework, as well as the input of a wide range of specialists who understand the physical, chemical, biological and human (cultural and navigation) dynamics of offshore environments.

It is also important to plan deliverables carefully and holistically, so gaps or delays do not impact the wider project timeline, and duplication, inconsistencies and oversights are avoided.

An integrated approach

An integrated approach ensures that all permitting aspects are handled cohesively, saving time, reducing risk, and improving the quality of submissions.

ABPmer has a proven track record supporting developers through the complexities of marine consenting. Our specialist toxicologists, ornithologists, marine mammal surveyors, benthic ecologists, compensation and derogation experts, oceanographers, geomorphologists, GIS and data architects and regulatory consultants each bring critical knowledge to ensure regulatory compliance and environmental integrity.

We tailor our support to your needs: whether you require a full end-to-end service or targeted input on specific issues, ABPmer can step in at any stage.

Want to learn more about our integrated CCS permitting services, or discuss your project requirements? Get in touch.