Bellona Europa greatly welcomes the launched call for evidence on the TEN-T Regulation in the wake of a new geopolitical reality and the REPowerEU strategy. In addition to the outlined changes in line with the “Solidarity Lanes” Commission Communication and the need to update the TEN-T maps and connectivity to Ukraine and Moldova, we urge that the important role of the green and just transition is not only kept in the proposal, but also expanded to include multiple transport modalities for transporting CO2 to storage from industrial emitters.

It was with disappointment we noted upon the adoption of the revised TEN-T Regulation guidelines on the 14th of December 2021 that multiple transport modalities for transporting CO2 to storage had not been included as eligible for PCI status. Neither had much needed wording recognizing the importance of such transport modalities been included. This leaves a vital part of the CCS value chain not covered by both the TEN-E and TEN-T Regulations. This is not only an opportunity cost in failing to spark market development and project deployment, but also a lack of recognition for multiple transport modalities that could risk sending a negative market signal to market participants. This, despite the crucial role to be played on Europe’s decarbonisation pathway of these transport modalities as part of the Carbon Capture and Storage (CCS) value chain.

Different options for inclusion of multiple transport modalities in the TEN-T Regulation:

• Option 1 : Full recognition, wording of encouragement and PCI status for full or parts of projects transporting CO2 to storage via multiple transport modalities such as rail, truck, barge and ship. No administrative support or funding included.
• Option 2: Full recognition, wording of encouragement and PCI status for full or parts of projects transporting CO2 to storage via multiple transport modalities such as rail, truck, barge and ship. Administrative support included, funding not included.
• Option 3: Full recognition, wording of encouragement and PCI status for full or parts of projects transporting CO2 to storage via multiple transport modalities such as rail, truck, barge and ship. Administrative support and funding included.
• Option 4: Full recognition, wording of encouragement and PCI status for full or parts of projects transporting CO2 to storage via multiple transport modalities such as rail, truck, barge and ship. Administrative support and funding included for parts of PCI projects in the TEN-E including multiple transport modalities.

For Bellona Europa and CATF’s brief explainer on the TEN-T Regulation and the need to include multiple transport modalities, please see here.

Read our full consultation response here.