Building a resilient, low carbon gas system: ADBA’s perspective on the Government’s Security of Supply Consultation

As the UK navigates the transition to a decarbonised energy system, the question of gas security has never been more important. In our response to the Government’s Gas System in Transition: Security of Supply consultation, which closed yesterday, 18 February, ADBA sets out a clear message: domestic biomethane is essential to a resilient, affordable, and low‑carbon gas future.

The UK Continental Shelf (UKCS) is declining, and with it our historic buffer against global volatility. As we note in our submission, “as UKCS output declines, the UK becomes increasingly dependent on imports and LNG, which introduces volatility and exposure to global market shocks.” Biomethane offers a strategic alternative, home‑grown, dispatchable, and storable.

Biomethane: the UK’s largest future source of domestic gas
Our modelling and that of the Green Gas Taskforce shows the UK can produce between 100TWh and 120 TWh of biomethane by 2050, overtaking the UKCS as the country’s largest domestic gas source by the mid‑2030s. This would cut cumulative gas imports by 1,875 TWh by 2050, equivalent to “75 LNG tankers per year out to 2050.” The security benefits are profound. With biomethane fully deployed, import dependency falls to 23% by 2050, compared with 94% in a scenario where biomethane is not expanded.

Why the market alone won’t deliver resilience
The consultation rightly highlights the need for resilient infrastructure. But as we emphasise, market‑only approaches cannot deliver the redundancy and long‑term investment required. Resilience requires assets that may be under‑utilised in normal years – something private investors cannot justify without policy support. We point to the closure of Rough gas storage facility as a clear example: “commercial returns were insufficient despite clear system‑wide resilience value.” Distributed biomethane injection, supported by reverse compression and strategic storage, strengthens the system far more than reliance on a handful of large LNG terminals.

A strategic case for domestic storage
We strongly support the creation of a strategic gas reserve, prioritising low‑carbon domestic gas. As we state, reserves should be “filled with as much domestic gas as possible including purchasing of biomethane from injection sites as a priority.” Depleted offshore hydrocarbon fields offer the most practical and scalable storage option, with new capacity deliverable before 2029 if decisions are taken soon.

Regulatory reform is essential
Current gas quality regulations – particularly GS(M)R – are no longer fit for purpose. They reflect a North Sea‑era gas mix and now act as barriers to biomethane growth. For example, “GS(M)R does not specify a CO₂ limit yet one is placed on biomethane injection,” and oxygen and calorific value limits are applied more rigidly than intended. We call for a simple, outcome‑based gas quality framework aligned with European standards to unlock investment and ensure interoperability.

A coherent policy framework for biomethane
Finally, we stress the need for long‑term certainty. The upcoming DESNZ Future Framework for Biomethane must avoid the “start‑stop nature of more recent schemes” and enable revenue stacking, including digestate valorisation and bio‑CO₂ for carbon removals.