Negative Emissions Technologies (NETS): Feasibility Study - Technical Appendices

Appendix 3. Stakeholders feedback: key messages

There are several factors which need to be considered when evaluating the feasibility of NETs and developing NETs pathways for Scotland. These were based on information and data gathered via a comprehensive stakeholder consultation which was undertaken as part of the study. The stakeholder engagement is used to complement data gathering and to identify which stakeholders have a real intention to consider and develop NETs projects, to what extent, how would they seek to do this, and on what timescale. The engagement with stakeholders enabled a greater understanding of the drivers for the development of NETs projects and identified specific existing facilities that would be suitable or unsuitable for retrofit with CCUS. A comprehensive account of discussions with stakeholders is provided in this part of the report.

Stakeholder engagement process

The stakeholder engagement was based on a pre-developed online survey and interview questionnaire followed by targeted semi-structured interviews. Three different versions of the interview questionnaire, tailored to different groups of stakeholders – technology providers, industries with biogenic emissions, and industries without biogenic emissions – were developed. Key stakeholders were identified for further discussions. Key stakeholder interviews are described in this appendix.

We developed online survey and interview questionnaire in discussion with Scottish Government steering group. The aim was to use the online survey to gain initial information followed by targeted, semi-structured interviews to gather further information. Three different versions of the interview questionnaire were produced, tailored to different groups of stakeholders: technology providers, industries with biogenic emissions, and industries without biogenic emissions. We identified key stakeholders in discussion with Scottish Government, drawing on existing contacts and new suggestions. The survey was piloted with a selected group of stakeholders and the questionnaire and interview script adapted accordingly. From a shortlist of 48 stakeholders, 42 were formally approached to participate in this study. Of these, 14 participated in the online survey and 22 were formally interviewed.

Stakeholders engaged with

The 22 stakeholders that were formally interviewed as part of this process are as follows:

• E-on (Steven’s Croft power station) BECCS Power (inc. CHP)
• RWE (Markinch CHP plant) BECCS Power (inc. CHP)
• Drax Group (Drax Power Station) BECCS Power (inc. CHP)
• Shetland Heat and Power BECCS EfW
• FCC (Baldovie EfW, Dundee) BECCS EfW
• MVV (Millerhill EfW, Midlothian) BECCS EfW
• West Fraser (Norbord Europe Ltd, Cowie) BECCS Industry
• INEOS BECCS Industry
• Diageo BECCS Industry
• Carbon Capture Scotland BECCS Industry
• Scottish Water BECCS Industry
• Forth Green Freeport BECCS Industry
• Dunbar Cement BECCS Industry
• PetroINEOS BECCS Industry / BECCS Biofuels
• Future Biogas BECCS Biomethane
• Anaerobic Digestion & Bioresources Assoc. BECCS Biomethane
• University of Glasgow BECCS Hydrogen
• Carbogenics Biochar
• Climeworks DAC
• CO₂CirculAir DAC
• Bellona DAC
• CCS Association Trade Associations/Other

Key outputs from stakeholder engagement

The following sub-sections summarise the key findings from the various stakeholder groupings: industry, EfW, power, biomethane, biochar and DAC. The different sub-sections report on the specific questions outlined in the interview script and which were asked in the same way to different stakeholder groups. For the different types of NETs options, respondents highlighted similar issues and aspects which need to be taken into account and so some of the sections below (categorised by type of NET) are repetitive and emphasise the same message.

BECCS Industry

BECCS Industry – summary

Industry respondents came from the refining and petrochemicals, water treatment, pulp, paper and board, and food and drinks sectors. All with operating centres in Scotland, they included the following 5 organisations:

• INEOS
• PetroINEOS
• Scottish Water
• West Fraser (Norbord Europe Ltd, Cowie)
• Diageo

Of these, 4 of 5 were working to Net Zero targets with dates ranging between 2030-2050 for different aspects of business operations.

While there were no NETs projects either currently underway or planned in Scotland, overall perceptions of NETs were generally positive, with all respondents reporting that carbon removal was necessary to offset hard-to-abate sectors and was an area where they felt they either had an important role to play or could implement certain technologies, depending on a range of related developments and supporting measures.

All respondents expressed a preference for on-site BECCS as opposed to DAC (likely due to the relatively high costs and low TRL associated with DAC).

For 3 of the 5 respondents, using biomass for energy is already a well-established part of their business model. For the refining and petrochemicals sector, fuel switching to biomass is acknowledged as being possible at some point in the future, but preference is given to switch to low-carbon (blue) hydrogen.

Deployment of NETs for industry was projected to be a credible option from around 2030 onwards, with the Acorn CCS CO₂ transport and storage infrastructure project cited as a key enabler.

BECCS Industry - studies and projects

There were a number of complementary studies and projects that had either already been undertaken or were currently underway that could easily feed into future NETs activity. These included prefeasibility studies looking into: fuel switching to biomass, crop regeneration, DAC and biorefining options in the refining and petrochemicals sectors; CO₂ capture and upgrade to food standard, CCU for low-carbon building materials and biochar production in the water treatment sector; CO₂ capture in the pulp, paper and board sector; and bioenergy deployment in the food and drinks sector.

In terms of future plans and potential, too, there were a number of projects either in the pipeline or being considered that would also be well aligned with any future NETs activity. The refining and petrochemicals sector is focused of reducing emissions and low-carbon (blue) hydrogen production from natural gas but also sees potential in BECCS for either energy or fuel production, bioethanol and for CCU whereby CO₂ is sequestered in polymers. The water treatment, pulp, paper and board and food and drinks sectors see potential in BECCS from existing operations across a combination of bioenergy CHP and AD processing facilities.

BECCS Industry - NETs deployment timeline

While feedback on timelines varied, there was a general consensus that 2030 could mark the point at which NETs could begin to take root in Scotland. Timelines were influenced by a range of variables, including long lead in times for projects of around 4-5 years from conception to operational status, uncertainty around business models and support mechanisms, a general feeling that it would take around 10 years to see a positive return on any NETs project (which is also comparable to other industries of this scale), and the projected timeline for the Acorn CCS project to become operational. Thoughts on the timing of full feasibility studies differed, with the refining and petrochemicals sector suggesting that it was still too early for this while the water treatment sector indicated that these could be up and running by 2024.

BECCS Industry – support needed for NETs

Suggested supporting and facilitating measures to incentivise NETs for BECCS Industry were as follows:

• CCS and NETs
• Acorn CCS transport & storage infrastructure is a key enabler
• Policy changes to incentivise deployment of CCS, CCU and NETs including for example inclusion under the ETS, supporting the development of CCS infrastructure, etc.
• Clear policy to incentivise carbon capture on EfW and to ensure that new EfW are capture-ready
• Financial support from Government
• CAPEX and OPEX support
• Long-term financial support for CCS
• Credible and verifiable negative emissions standards
• Carbon markets
• Long-term confidence in carbon pricing mechanisms and timelines
• Other
• Strong research base (e.g., research needs in innovative CO₂ capture processes relevant to specific industries, e.g., chemical loping)

BECCSEfW

BECCS EfW – summary

All EfW respondents were active EfW plant operators in Scotland. They included the following 3 organisations:

• Shetland Heat & Power
• FCC (Millerhill EfW, Midlothian)
• MVV (Baldovie EfW, Dundee)

Of these, 2 of 3 were working to Net Zero targets of 2045.

While there were no NETs projects either currently underway or planned in Scotland, overall perceptions of NETs were generally positive, with most (2 of 3) respondents reporting that NETs were necessary to offset hard-to-abate sectors and all respondents agreed that it was an area where they felt they either had an important role to play or could implement certain technologies, depending on a range of related developments and supporting measures.

Most (2 of 3) respondents expressed a preference for on-site BECCS.

For 2 of the 3 respondents, using biogenic feedstock is already a well-established part of their operations. For the third respondent, this was not relevant as they did not have any biogenic feedstock and therefore no biogenic CO₂ emissions.

Deployment of NETs for EfW plants was projected to be a credible option from around 2030 onwards, with the Acorn CCS CO₂ transport and storage infrastructure project cited as a key enabler.

BECCS EfW - studies and projects

There were a number of complementary studies and projects that had either already been undertaken or were currently underway that could easily feed into future NETs activity. One respondent reported NETs feasibility studies on EfW plants in Germany and a biomass plant in England, but nothing for Scotland. Two respondents intimated that they were currently involved in district heating network schemes (albeit at different stages of development) and, with CCS very much in mind, both were very aware of the potential to align with the Acorn CCS project and related projects and initiatives to better exploit the potential from EfW CHP plants. One of these respondents also reported that they had already spoken with a commercial CO₂ capture technology provider.

In terms of future plans and potential, the respondents were again split into two camps. Two of them have a strong preference for on-site BECCS and both are interested in revenues from negative emissions offsets. As mentioned above, both are involved in district heating schemes, with deployment of one of these imminent. One of the respondents also alluded to the potential for a small-scale CO₂ capture plant with a leading UK academic institution in the near future. The third respondent reported plans to explore CCU potential for agriculture (growing algae) and exploiting renewable sources for heat and power generation, including sea water heat pumps and wind.

BECCS EfW - NETs deployment timeline

Between the two respondents considering on-site BECCS, there was a consensus that 2030 could mark the point at which NETs could begin to take root in Scotland. Timelines were influenced by a range of variables, including long lead in times for projects (2 years for planning and permitting alone, to be followed by construction) and issues pertaining to plant ownership, and therefore future plans, e.g., one plant is co-owned by the City of Edinburgh Council under a Public-Private Partnership model. The projected 2030 timeline was influenced by the projected timeline for the Acorn CCS project to become operational.

BECCS EfW – support needed for NETs

Suggested supporting and facilitating measures to incentivise NETs for BECCS EfW were as follows:

• CCS and NETs
• Acorn CCS transport & storage infrastructure is a key enabler
• Policy changes re. CCS, CCU and NETs
• Financial support from Government
• CAPEX and OPEX support
• Long-term financial support for CCS
• Credible and verifiable negative emissions standards
• Carbon markets
• Long-term confidence in carbon pricing mechanisms and timelines, i.e., UK ETS
• Other
• Strong research base (need for R&D on new solvents to reduce energy requirements and optimise CO₂ capture performance and costs when deploying on EfW. Also, R&D needs to integrate EfW plants with CHP and DH systems to maximise efficiency.

BECCS Power

BECCS Power – summary

All power respondents were renewable energy providers. All were biomass power plant operators: 2 of them with operating centres in Scotland and 1 in England. They included the following 3 organisations:

• E-on (Steven’s Croft power station)
• RWE (Markinch CHP plant)
• Drax Group (Drax Power Station)

All respondents were working to Net Zero targets with dates ranging between 2030-2050.

While there were no NETs projects on currently underway in Scotland, the respondents reported being involved in a number of scoping/feasibility studies covering BECCUS applications. Overall perceptions of NETs were positive, with all respondents reporting that NETs will be necessary to offset hard-to-abate sectors and all agreeing that it was an area where they felt they either had an important role to play or could implement certain technologies, depending on a range of related developments and supporting measures.

All respondents acknowledged the importance of BECCS Power, with 2 of 3 expressing a preference for on-site BECCS.

Deployment of NETs for biomass power plants was projected to be a credible option from around 2030 onwards, with the Acorn CCS CO₂ transport and storage infrastructure project cited as a key enabler.

BECCS Power - studies and projects

There were a number of complementary studies and projects that had either already been undertaken or were currently underway that were either designed to or could easily feed into future NETs activity. Two respondents reported scoping/feasibility studies on BECCUS applications, including assessment of unspecified CCU, BECCS hydrogen production and CCU for sustainable aviation fuel (SAF). For the other respondent, NETs wis a core part of its business both in the UK and globally and it had been involved in numerous feasibility and pilot studies and demonstration projects with a view to large-scale NETs deployment.

In terms of future plans and potential, the respondents all see NETs as an important part of continued business operations, and all were interested in potential revenues from negative emissions offsets. Two of them had a strong preference for on-site BECCS Power while the preferred options for the other site were maximising/exploring renewable heat and BECCS hydrogen production opportunities, followed by BECCS Power. The two Scotland-based facilities were open to third-party testing and pilot-scale demonstration projects.

BECCS Power - NETs deployment timeline

The two Scotland-based facilities suggested 2030 as an indicative timeline for NETs deployment, although neither gave details of any concrete project plans. This timeline was implied from their acknowledgements that a business-as-usual approach would simply not work and statements around the perceived longevity of the facilities, which were also aligned with the projected timeline for the Acorn CCS project to become operational. The England-based facility was operating to a very similar timeline, with concrete project plans in place for UK deployment by 2027 and feeding into geological storage provided as part of other UK-based CCS clusters, but not in Scotland. The US Inflation Reduction Act (IRA) was cited as a key enabler of NETs activity because it makes the business case clear, suggesting that something similar for Scotland/the UK would make a real difference.

BECCS Power – support needed for NETs

Suggested supporting and facilitating measures to incentivise NETs for BECCS Power were as follows:

• CCS and NETs
• Acorn CCS transport & storage infrastructure is a key enabler
• Policy changes re. CCS, CCU and NETs
• Clear policy on EfW + CCS
• Planning permission
• Financial support from Government
• CAPEX and OPEX support
• Long-term financial support for CCS
• Replacement for ROCs (ROCs preferred to CfD)
• Credible and verifiable negative emissions standards
• Industry grouping/collective
• Carbon markets
• Long-term confidence in carbon pricing mechanisms and timelines, i.e., UK ETS
• Other
• Strong research base

BECCS Biomethane

BECCS Biomethane – summary

Biomethane respondents were comprised of a UK-wide AD/biomethane producer with 1 facility in Scotland and the UK-wide trade body for AD and bioresources. While both are active in Scotland, they are both headquartered in England. They included the following 2 organisations:

• Future Biogas
• Anaerobic Digestion & Bioresources Association (ADBA)

Future Biogas was working with auditors to assess entire company emissions, i.e., scopes 1-3, and was following the Science-Based Targets Initiative (SBTI).

While there were no NETs projects currently underway in Scotland, the respondents reported a very tangible prospect of future growth in this area, with new AD plants very likely to have CO₂ capture technology designed in from the start and existing plants very likely to retrofit. Reasons given included a pressing need for NETs, increased recognition of the value of the additionality of capturing and sequestering biogenic CO₂ and a projected steady rise of the value of biogenic CO₂ over time compared to fossil CO₂. The issue of value was repeatedly mentioned in terms of the rise of the price of CO₂ in recent months, partly due to the situation in Ukraine. Both CCS and CCU were mentioned. Although, financial support was still deemed necessary to facilitate wider deployment.

Both respondents acknowledged the current roll out of CO₂ capture technology on new build plants, as well as retrofit to existing plants. It was also suggested that early movers could be in a position to offer a service for collecting biogenic CO₂ from other biomethane facilities in Scotland.

Future Biogas intend to develop 25 of their existing biomethane sites in England into NETs projects where the CO₂ is captured and transported for permanent storage not the Norther Lights storage hub. Deployment of NETs for AD/biomethane plants was projected to be a credible option for certain UK locations from 2024 onwards, such as Future Biogas’ to-start-construction-in-2023 plant. This example shows that domestic CO₂ transport and storage infrastructure is not a prerequisite for such projects to be considered financially viable.

BECCS Biomethane - studies and projects

In terms of future plans and potential, the respondents reported a healthy amount of activity for the sector which simply made good business sense. Underpinned by the current high value of CO₂ and a projected premium for biogenic CO₂ specifically, the sector is seeing new plants CCS-equipped from day 1 and retrofit for existing plants. An estimated 10% of biomethane facilities have CO₂ capture technology installed and this is expected to grow. One example given was a new build Future Biogas facility in an unspecified location in the north-east of England that will capture its CO₂, to then be transported from the Humber area to Norway for permanent offshore geological storage as part of the Northern Lights project.

BECCS Biomethane - NETs deployment timeline

While the Future Biogas example shows that projects may be considered financially viable as early as 2024 even in the absence of domestic CO₂ transport and storage infrastructure, international shipment of CO₂ was not deemed to be a sustainable long-term option for the sector or indeed for Scotland-based facilities, given the added cost of transport to the Humber area. An indicative sector-level timeline for NETs deployment was therefore suggested to be closer to the late 2020s and aligned with the UK’s CCUS cluster sequencing programme. For Scotland – and the Acorn CCS project – this means an implied timeline of around 2030.

BECCS Biomethane – support needed for NETs

Suggested supporting and facilitating measures to incentivise NETs for BECCS Biomethane were as follows:

• CCS and NETs
• Acorn CCS transport & storage infrastructure is a key enabler
• Policy changes re. CCS, CCU and NETs
• Financial support from Government
• CAPEX and OPEX support
• Long-term financial support for CCS
• Replacement for Green Gas Support Scheme (GGSS): should consider incentivising CO₂ capture and permanent storage of the captured CO₂. For example, through providing higher payments for sites which become NETs.
• Power BECCS CfDs
• Regulated carbon removals market
• Credible and verifiable negative emissions standards backed by Government
• Carbon markets
• Long-term confidence in carbon pricing mechanisms and timelines, i.e., UK ETS
• Other
• Strong research base to identify innovative capture technologies

Biochar

Biochar – summary

Biochar respondents were comprised of a single organisation: Carbogenics. Carbogenics is a Scotland-based producer of specialist bio additive charcoal called cre-char for AD processes and is currently without any direct competitors.

• Carbogenics

While there were no NETs projects – or indeed even a market - currently underway in Scotland, the respondents reported a very tangible prospect of future growth in this area, with over 700 AD plants across the UK that could use their product to improve efficiency and increase biogas yield. Reasons given for anticipated growth included a general pressing need for NETs aligned to the climate imperative and significant levels of support across Europe. Certified, verifiable negative emissions credits were considered vital for the sector. Other char products and AD additives such as carbon black are part of a wider nascent char market that Carbogenics aims to develop.

Biochar - studies and projects

Carbogenics reported ongoing trials with around 10 different AD companies. In what is a highly specialised, niche sector with no extant market, activity is aimed at demonstrating the efficacy of the product and creating a biochar market in the UK. Selling carbon credits is considered another important potential revenue stream for the sector.

Biochar – NETs deployment timeline

Carbogenics is currently building a new 400t biochar/year production facility, which would serve between 10-20 individual AD plant customers. It is expected to be operational by early 2024. While the timeline for delivery of this facility might be near term, no date was suggested as to when the UK sector might be able to support a functioning NETs market. In addition to firstly having to prove the concept through trials, barriers to development included policy (i.e., policies currently do not support development), regulation (regulation is needed to facilitate use of biochar) and finances (projects are not viable without financial support).

AD and biogas sites are target customers for biochar and growth of the AD sector will affect development of biochar plants. Currently, biogas production targets (as a % of total gas demand) across Europe are much more ambitious than in the UK, which currently has no mandated target (and sits at 1% of total gas demand), e.g., Denmark, Poland (100%) and Germany (25%). Despite a favourable wind in Europe, the outlook for the UK, and Scotland, is therefore uncertain. Carbogenics, however, project that the UK biochar sector will double in the next 3 years and that the UK biogas sector will double in less than 10 years. Taking this projected growth as a proxy for establishing a market, a timeline of around 2030-2035 could be proposed for NETs development.

Biochar – support needed for NETs

Suggested supporting and facilitating measures to incentivise NETs for Biochar were as follows:

• Access to capital to facilitate growth (public sector capital could be matched by private sector)
• Regulation: Scotland’s permitting system is restrictive even compared to England
• Targets: establish mandatory targets for biogas production as % of total gas demand to 10% or 25%
• Biomass classification: formal classification of secondary biomass for biochar
• Allow biochar created from sewage sludge to be returned to the soil (like Sweden and Denmark)
• Support farming communities
• Strong research base (education, training & skills)

DAC

DAC – summary

DAC respondents included two DAC developers and an environmental NGO:

• CO₂CirculAir (developer)
• Climeworks (developer)
• Bellona (NGO)

There is currently no operational DAC sector in Scotland. The respondents’ comments, while often in agreement in principle, were very often diametrically opposed to each other. For example, all agreed that DAC would not play a significant role in helping to meet Net Zero or any other major near-mid-century climate targets. They also agreed that DAC would probably be better used for CCU rather than CCS as this is likely to provide a better and more viable economic case. On the principle of whether or not Scotland could support a DAC sector, they agreed that it technically could but disagreed that DAC would actually be the best use of (renewable) resources where other and better alternative uses for those resources existed’. Neither of the developers have actively researched DAC in Scotland but were aware of the fast-tracked nature of the Acorn project with geological storage being the most important factor for future deployment of DAC operating as a NETs facility.

DAC - studies and projects

CO₂CirculAir reported that a pilot plant facility trialling its novel Smart-DAC technology, a natural wind-based technology using membrane gas absorption, was currently under construction in Northern Ireland and that it would soon be operational. Climeworks operates project Orca in Iceland^[199] which can capture ~4,000 tCO₂/year and has plans to scale this up to have a ~0.4 MtCO₂ plant operational by the late 2020s and a mega-tonne project operational by the mid-2030s.

DAC - NETs deployment potential

Both respondents reported that DAC would most likely play only a very limited role in helping to meet Net Zero and/or any other significant climate targets. There was therefore no discussion about a timeline for NETs deployment on DAC. Rather, their responses were focused on the pros and cons of DAC deployment in Scotland, the key themes from which are outlined below.

• Themes/Issues on which respondents agreed included:
  • Scotland could in principle support a DAC sector
  • Scotland’s surplus renewables from wind could in principle be used for DAC
  • Scotland’s spare land could in principle be used for DAC
  • Waste industrial heat could in principle be used for DAC
    • The heat requirements for the various technologies varies significantly – whilst using waste heat is always advantageous – Climeworks indicated that the vast majority of the energy demands required are in the form of power (carbon neutral / renewable electricity)
  • DAC will not contribute meaningfully to 2045/2050 net-zero targets
  • DAC is scalable (In theory, the plant set up can be replicated and scaled up by adding several smaller plants in series but the main issue is the cost associated with scaling up the technology and identifying and resolving integration issues to maximise performance)
  • DAC is better applied to CCU than CCS (that is, it makes more sense to use CO₂ from DAC to produce sustainable aviation fuels, SAF, e-kerosene or other fuels where green hydrogen is also available. If the right incentives are available, it may also become attractive to permanently store CO₂ from DAC)
  • NETs on DAC will require large-scale CO₂ transport and storage infrastructure
  • DACCS makes sense if there’s an economic return on geological storage of CO₂
  • Plans for 1Mt/year DAC facilities are very unclear
• Themes/Issues on which respondents disagreed included:
  • Scotland’s surplus renewables would be best used for DAC
  • Scotland’s spare land would be best used for DAC
  • Waste industrial heat would be best used for DAC
  • DAC is expensive
  • DAC can be scaled up sufficiently to make a meaningful contribution to decarbonising air travel via CCU for sustainable aviation fuel (CO₂ from DAC is a focus for the aviation industry (for example, this study ). Using CO₂ for making SAF or e-kerosene (rather than storing it in geological formations) provides a route for the aviation industry to decarbonise. Scaling up DAC is possible in theory as the designs can be modular, but systems need to be integrated and optimised. These additional build-up costs can be offset by creating additional revenue streams from SAF production

DAC – Support needed for NETs

Suggested supporting and facilitating measures to incentivise NETs for DACCS were as follows:

• CCS and NETs
• Acorn CCS transport & storage infrastructure is a key enabler
• Policies to facilitate granting planning for new projects
• Policies to prioritise incentivises for permanent storage of CO₂ from DAC rather than using it for making sustainable aviation fuels