Notice

CCUS NPT Pathfinder selection process: clarification questions (updated 22 May 2026)

Updated 22 May 2026

Clarification questions (added 22 April 2026)

Q001: 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). 

Q002: What CCUS terminals are available at Teesside for projects to connect through?

The guidance does not designate or approve any CCUS terminals at Teesside for projects to connect through and the applicant’s proposal will be assessed through the application process. The applicant is responsible for 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 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: “If 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.” 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 “project minus baseline” 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: “Any 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”, reinforcing this assumption that the upstream plant is needed for its primary product.

Note that in the same section, the CRCF stipulates “Where 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.”

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? 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.  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.  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 ‘Red’ 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 “automatic downgrade” 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 – either a GGR Business Model contract or a TAA, not both.

Clarification questions (added 22 May 2026)

Q009: Are applicants expected to include sequestration and storage-side emissions and MRV within their Annex A4 submission? If yes, should applicants obtain this information directly from the T&S provider (or storage operator)? Does DESNZ intend to provide common assumptions, reference values, or standard data for these elements where they are shared across applicants using the same system?

Applicants under the GGR Business Model should include emissions associated with transport and storage within their Annex A4 submission, as part of full value chain greenhouse gas accounting, in line with approaches taken under the EU CRCF.

Applicants are responsible for ensuring that emissions and any losses across the capture, transport, and storage injection chain are appropriately quantified and transparently reported. For the purposes of supporting this approach, NEP have advised they can provide conservative network emissions estimates to applicants upon request. Where relevant data is not directly available, applicants should use conservative assumptions or appropriate default values and clearly set out the basis for these in their submission.

Applicants should note that the liability for any CO2 loss from permanent offshore geological storage sites remains with the storage operator under existing regulatory frameworks. Such losses are not required to be accounted for within the applicant’s Annex A4 emissions assessment, which covers emissions up to the point of injection.

Q010: Will the T&S network accept liquid or gaseous CO2 from NPT?

It is anticipated that non-pipeline transportation of CO2 may involve CO2 liquefaction. NEP can advise on temperature and pressure management principles and associated entry conditions for the ECC T&S network.
Applicants are responsible for ensuring that emissions and any losses across the capture, transport, and storage injection chain are appropriately quantified and transparently reported. Where relevant data is not directly available, applicants should use conservative assumptions or appropriate default values and clearly set out the basis for these in their submission.

Q011: One of the questions in the EOI asks “Will your application involve aggregation of CO2 from multiple emitters?” In the case that there are multiple locations operated by a single company is this considered multiple emitters or a single emitter?

This case, in which there are multiple capture locations operated by a single company, would be considered as ‘multiple emitters’ for the purpose of the Expression of Interest.

Q012: Who is responsible for arranging the CO2 receiving terminal for different transport modes? (train, truck) and if it is project is there a way these can be shared?

The Applicant is responsible for organising a full-chain solution, including the potential use of receiving terminals, from capture project to T&S network delivery point (as defined in the CCS network code).

T&S network delivery points cannot be shared between multiple projects. Please see also CQ033.

Q013: What are the estimated T&S costs per tonne?

Applicants can contact NEP for an indicative range of T&S fees. Applicants will need to enter into an NDA with NEP before T&S fee details are shared. These T&S fees are highly indicative and are very dependent on actual capacity allocated to the network.

Q014: Should the EOI be submitted on behalf of the Emitter or the potential overarching legal entity?

The EOI should be submitted by the Project Representative on behalf of the Applicant, which will be the legal entity which is responsible for the Project as a whole.

The Project Representative must be a person from the business / organisation which is leading the project development and will manage the application process including having access to the online Application Portal.

Q015: The minimum CO2 export capacity eligibility criterion requires projects to have an average annual CO2 capture of at least 30 ktpa. Is this averaged each year, over the full contract period or over another timeframe?

For the GGR Business Model allocation round in the NPT Pathfinder, one of the Core Eligibility Criteria states “Projects must have an average annual CO2 capture of at least 30 ktpa. Where Projects aggregate CO2 from multiple Capture Facilities, each individual Capture Facility must capture at least 5 ktpa. “ This refers to an indicative estimate of the project’s expected annual average CO2 capture across the subsidy period, rather than a strict requirement to meet the threshold in each individual year. However, under the GGR Contract, projects will be required to demonstrate a minimum Net Removal Capacity at Operational Conditions Precedent (OCP) stage and by the Longstop Date, with the firm expectation that a substantial majority of the project’s capacity must be operational before payments commence. The project COD date would be the date when the full CO2 capture capacity becomes available.

In addition, the GGR Contract includes a Permitted Annual Sales Cap to ensure that annual subsidy remains within acceptable limits. This reflects the expectation that annual average performance should be broadly consistent over the subsidy period, while incorporating a 10% tolerance to accommodate year-to-year variability in production and sales of GGR Credits.

Q016: What is a single title CO2 stream?

A ‘single-title CO2 stream’ is a stream of CO2 which is generated by a single project and not mixed with that of other projects prior to the delivery point (i.e. there is no co-mingling). This means that at the delivery point to the T&S Network (as defined in the CCS Network Code), the CO2 belongs to the single legal entity which has legal title of the CO2.

Note that in the NPT Pathfinder Selection Process, a single project may be comprised of multiple separate capture facilities which are covered under a single application. This would still represent a single-title CO2 stream as all capture facilities would be part of the same legal entity which is responsible for the project as a whole. For further details please see chapter 4.1.3 “Projects aggregating CO2 from multiple Capture Facilities” in the NPT Pathfinder application guidance.

Q017: Will there be a formal consultation or stakeholder engagement process before the UK GGR standard is finalised, and is there an indicative timeline for that process?

The government is currently working with the British Standards Institution (BSI) to develop a GGR Standard and methodologies that projects supported under the business models will be required to use. 

The BSI standard development process is a structured, consensus-based approach designed to ensure that standards are robust, credible, and representative of industry, government, academic, and offtaker views. There will be an opportunity for all stakeholders to review and comment on the draft GGR methodologies before they are finalised and published in mid 2027. 

BSI has established a Steering Group/ Expert Group comprised of around 15 stakeholders from industry, academia, project developers and offtakers who will meet to steer the development of the methodologies and review early versions of the draft text. These meetings have already started.

In addition to meetings of the Steering Group/Expert Group, a public consultation on the draft methodologies, currently scheduled for January 2027, is open to all stakeholders. 

Q018: When it comes to assessment is this on deliverability alone? i.e. if you assess a site is 95% deliverable but GGR Ref price required would be £400/t would this be more likely to be selected than a site you have 90% confidence in but GGR Ref Price would be £200/t. How do vfm assessments work into this?

After the eligibility check and triaging process which is focussed on the NPT solution, DESNZ will progress the highest ranking projects through to deliverability assessment  to consider the technical, commercial and financial deliverability of the project only. In the deliverability assessment, the aggregated Project will receive a single RAG rating covering the whole Project (summer 2026).

Projects that pass the deliverability assessment will progress to the shortlisting stage. DESNZ will then assess each Project against value for money, affordability and supply chain criteria alongside the outcomes of the deliverability assessment. DESNZ reserves the right to assess any of value for money, affordability, and supply chain criteria in parallel to the deliverability assessment at the department’s discretion. Projects that do not pass shortlisting will not progress and Applicants will be notified of the outcome (Autumn 2026).

Projects that pass shortlisting will progress to cluster integration. This stage considers the shortlisted Projects as a portfolio to identify a configuration that can be taken forward for approvals, taking account of constraints such as available capacity and overall affordability.

Q019: Will DESNZ be making separate announcements for pipeline and NPT projects on successful outcomes in the process (Deliverability assessment, VfM etc) or would these be expected to be issued separately for each competition? How much will these two competitions become fully aligned?

DESNZ will notify NPT Pathfinder Applicants of their progression through the assessment process as described in Section 2 of the guidance documentation. This is separate to the ECC Selection process for pipeline projects.

From the cluster integration stage onwards, DESNZ may, where appropriate, consider shortlisted projects collectively across the NPT Pathfinder and the piped ECC Teesside Selection Process. This is subject to further decision making and the final announcements as to whether the programmes are integrated or remain discrete, will depend on the decision making.

Q020: Does having an application in the piped ECC Teesside selection process prohibit you for applying to the NPT Pathfinder process for the same site? And vice versa?

No - we will consider all applications. However, we can only contract with a capture plant once.

Q021: Given uncertainty on the terms of the TAA is it expected that TAA projects could move to another appropriate business model support (e.g GGR) should the terms of the TAA not be deemed suitable upon publication?

During the assessment process, DESNZ may consider whether a Project applying under the TAA would instead require Business Model support, or whether a project applying via the GGR Business Model could be deliverable via the TAA. Where DESNZ considers this relevant, we may request additional information from the Applicant to support that consideration. Note that Projects which would require Business Model support from CCUS Business Models other than the GGR Business Model would not be eligible for the NPT Pathfinder.

Q022: Is the expectation still that applicants will need to enter into an MOU with NEP, as it was in the piped process?

DESNZ would expect to see evidence of engagement between NEP and the Applicant at this stage and an MOU would be a strong example of evidence, however it is not mandatory at this stage.

Q023: What are the reasons for DESNZ position that TAA would not cover T&S fees?

The Transition Access Agreement is a new contract being introduced to enable projects that do not require the support provided by an existing CCUS business model to connect to the CO2 T&S Network. This is being developed within our broader ambition to move towards a self-sustaining CCUS industry, but recognises the importance of a market transition phase that reduces government intervention while continuing to support network efficiencies and wider DESNZ and government Net Zero and industrial targets. The intended design of the TAA is therefore to be aimed at Projects that require limited financial or risk support from government, and is viewed as an important stepping stone towards the introduction of fully merchant Users. 

The TAA is currently in active development. The principles guiding this design were set out in the Draft Commercial Principles document (published in February 2026) where we stated that DESNZ was considering providing limited support in relation to T&S Charges on a case-by-case basis, but only where certain conditions are met and it is clearly evidenced that an element of T&S Charges support is essential for a project to sign a TAA. Any support provided by the TAA would need to be consistent with subsidy control principles.

Q024: Has DESNZ given any consideration to NPT costs being covered (in whole or in part) within the TAA?

NPT costs are considered part of the cost of the capture project for the purpose of the NPT Pathfinder in both the TAA and GGR BMs.

Q025: Is there a minimum storage buffer for CO2 required at the receiving/injection point?  (eg. x days of CO2 flow to cover supply chain disruption)

There is nothing set out in guidance regarding minimum levels. This would be for projects to determine for themselves, as part of their planned operating schedule and risk management plans. However, appropriate buffer storage availability could form part of the Project’s proposal regarding operability and interface management within the NPT solution.

Q026: Would DESNZ be willing to match-make for NPT applicants who are looking to site injection points for NPT solutions and pipeline applicants?

No, this is a competitive process which includes the injection points. We can only sign post to NEP in the first instance.

Q027: Do DESNZ or NEP expect that quality measurement of NPT CO2 prior to T&S to be the same as per pipeline projects, or could bulk liquid sampling be used instead to reduce project costs and quality control risks?

Each T&SCo is responsible for their respective network safety and design, including setting the CO2 Specification and Measurement Requirements (Annexures B and C in the CCS Network Code). In line with the Code, NEP is currently developing the CO2 Quality Monitoring Procedure, which will become part of Annexure C, to provide greater operational detail to Users.

Measurement requirements can be changed via a formal Code Modification, and user-specific technical derogations may be agreed between a T&SCo and an applicant, during the Connection Application process. Any Applicant seeking revised requirements, either for itself or on a network wide basis, should engage early with the T&SCo.

DESNZ is analysing responses to the NPT Consultation on CO2 quality monitoring approaches for NPT, to understand risks and opportunities in the sector longer term.  However, Applicants are reminded of the eligibility criteria for NPT Pathfinder which include a requirement that Projects must be able to accede to the Network Code without the need for material modifications (4.1.2 T&S Connection, see also 3.8 CCS Network Code) and that dependency on material changes being successfully modified into the Code carries delivery risk.

Q028: Is there a hierarchy of criteria for assessment e.g. COD date, VfM, or scale of capture?

The assessment process is described in the NPT Pathfinder Selection Process Application Guidance. There is no specific hierarchy of criteria for prioritisation in the selection process and different elements of the process will consider different things.

In the event that DESNZ receives a large number of applications to the NPT Pathfinder Selection Process, DESNZ may implement an ‘application triage’ to prioritise applications to be taken forward to the full deliverability assessment stage. The application triage will be assessed on the project’s schedule to COD and on the deliverability of the project’s NPT Solution. See also CQ018.

Q029: Should all transport and intermediate storage costs and tech details i.e. at a CO2 terminal, rail, road etc, be included as 3rd party service costs to the main applicant, and not separate EOI or applications?

Yes - all costs should be included in one application following a single Expression of Interest.

Q030: Can relevant information be updated between the EOI submission and the full bid submission?

Yes and please make clear where there is a change.

Q031: Given that intermediaries are currently not eligible, is there a planned or forthcoming process to accommodate Option E intermediaries, as referenced in the CCUS NPT Consultation?

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.

Q032: Are reasons required for info changes between EOI and full bid submission, or does “continued bid development” suffice, whilst pointing out where there are changes for ease of DESNZ understanding?

Yes, relevant information can be updated between the Expression of Interest submission and the whole Application submission. The Department understands that Applicants may for example have refined their plans or refreshed technical understanding within the application window. Applicants should make clear where there is a change and note the reason as ‘continued bid development’ or similar, for ease of DESNZ understanding.

Q033: Could NPT Pathfinder solutions that utilised sub-contracted terminal services be made to work under the CCS Network Code?

Sub-contracting for terminal services can be compatible with the CCS Network Code where it respects the Code’s existing design basis.

A capture project that has sub-contracted for terminal services is most likely to remain compliant, where the capture project is the Party to the Code, signs the Code Agreements, and retains the relevant risks, liabilities and obligations.

Compliance with the existing Code is highly unlikely if a terminal services sub-contractor sought to service more than one Code Party utilising the same CO2 handling infrastructure (i.e. where infrastructure was shared across Code Parties).

Projects may nevertheless pursue proposals they consider compliant, at their own risk. Please see the guidance section 4.1.2 “T&S Connection” for more information.

Q034: Could applicant ‘XZY company’, name a terminal and transport solution, with services only designed for that single entity project,  as service provider to the NPT Pathfinder project? In this instance, would a Receiving Terminal be required to submit and EOI, or would they be named or included as data and service to the main application of XYZ company?

The government would not expect you to submit an EOI on behalf of the receiving terminal in isolation. As per the guidance, a project will need to demonstrate a full-chain solution, from the capture project through to the point at which CO2 is delivered into the piped T&S network, in order to be eligible for the selection process. At this stage, the EOI itself only requires an organisation to submit on behalf of the wider Project, and name a representative that will engage with the Department on behalf of the project going forward. As such, it will then be up to projects to determine which organisation within it will submit the EOI on behalf of the project and which organisation will be named as their representative.

Q035: Regarding the NPT Pathfinder eligibility criteria our understanding is that a project would not be eligible for consideration in this selection process where the CO2 captured, is stored on site, collected by a third party and then transported to a terminal or hub facility for onward transport to the T&S pipeline. The terminal or hub facility would essentially be an aggregating facility which would receive CO2 from other emitters. Is this correct?

Applicants to the NPT Pathfinder Selection Process must put forward a proposal for the entire project, including capture, interim storage, transportation and delivery to the T&S network.

As explained in the Application Guidance eligibility criteria (see Chapter 4), the capture facility itself (or multiple capture facilities where the project will aggregate CO2 from multiple capture facilities under a single application) must be included in the Project. Applications from entities (e.g. receiving terminals or aggregation hubs) which subcontract Capture Facilities to provide CO2 or purchase CO2 from third parties will not be eligible.  

Projects could subcontract transportation services from a dedicated logistics company. Please also see CQ033 for issue related to subcontracting terminal services.

Q036: Is it possible to get GGR Business Model support on completion of an individual part of a project? Or does the GGR Business Model support only apply when the whole system is operational?

Please see CQ015.

Q037: How will the wider sector benefit from the learning gained through this government supported initiative?

All information received during the NPT Pathfinder Process will help inform future NPT policy design, supporting the outcomes of the NPT consultation.

To help benefit the wider sector, the Economic Benefits section of the Guidance documentation includes supply chain and UK opportunities, plus skills development and training opportunities such as through partnering with local educational institutions. Unlike the Innovation Programmes, however, there is no specific requirement for the publication of reports.