Closed consultation

Decarbonisation readiness: proposed guidance

Published 28 February 2025

Applies to England

Foreword

The Environment Agency is the environmental regulator for combustion activities in England.

The Department for Energy Security and Net Zero has expanded the scope of the current ‘carbon capture readiness’ requirements through the Environmental Permitting (Electricity Generating Stations) (Amendment) Regulations 2024.

The new requirements, called ‘decarbonisation readiness’, will amend the Environmental Permitting (England and Wales) Regulations 2016 so that new or substantially refurbished electricity generators within scope must provide and maintain a plan to decarbonise.

This will apply in England to permit applications submitted to the Environment Agency on or after 28 February 2026.

This consultation will be of interest to operators of in scope electricity generators and others that have an interest in decarbonisation. This includes:

• operators and other businesses
• trade associations
• national and local government
• non-governmental organisations
• other regulators
• academic institutions
• individuals and community groups

This consultation is asking for your feedback on the draft guidance to be followed in preparing a decarbonisation readiness report as part of a permit application. We will use the responses to amend and improve the guidance before final publication so that it is clear and easy to follow.

Background

In October 2024, the government published its response to the consultation they conducted on expanding and updating carbon capture readiness requirements, which will now be known as decarbonisation readiness requirements, and moving the requirements from the planning consent process to environmental permitting.

What we are consulting on

Decarbonisation readiness is a new requirement, so the Environment Agency has drafted technical guidance for operators to follow when preparing to submit a permit application where this applies.

We would like your feedback and views on the proposed decarbonisation readiness guidance to help us improve it, so that the final version is clear and easy to follow.

Scope of comments

We will consider comments that are related to the draft decarbonisation readiness guidance, and related issues as outlined in the questions.

For other concerns outside of this, please email enquiries@environment-agency.gov.uk and they will forward these to the appropriate team.

Responding to this consultation

Important dates

The consultation will start on Friday 28 February and end on Friday 9 May at 11:59pm.

How to respond

To view the document and respond to the questions online, use our Citizen Space consultation website.

Respond online

Please submit your response using our Citizen Space website, as it helps us to:

• gather and summarise responses quickly, accurately and in one place
• reduce the costs of the consultations by avoiding unnecessary printing

Respond by email

If you cannot respond through Citizen Space, you can submit your response by email to decarbonsationreadiness@environment-agency.gov.uk. Use the response form that’s provided in the ‘Related’ section of the consultation on Citizen Space. Please email your response form with the subject ‘Consultation response: decarbonisation readiness guidance’.

Ask for a printed version

Please contact us if you would like a printed version of the consultation document sent to you.

You can do this by contacting:

Environment Agency helpline

Email enquiries@environment-agency.gov.uk

Telephone 03708 506 506

Monday to Friday, 8am to 6pm.

Data protection

How we will use your information

We will use your information to help shape the decarbonisation readiness guidance.

The Environment Agency will make all responses publicly available after the consultation, unless you have specifically requested that we keep your response confidential.

This includes comments received online, by email and by post unless you have specifically requested that we keep your response confidential. We will not publish names of individuals or personal data. We will publish the name of the organisation for those responses made on behalf of organisations.

We will not respond individually to responses unless you have specifically asked us to do so by providing us with an email address, in which case we will acknowledge your response. After the consultation has closed, we will publish a consultation response document on GOV.UK. We will contact you to let you know when this is available.

In line with the Freedom of Information Act 2000, we may be required to publish your response to this consultation but will not include any personal information. If you have requested your response to be kept confidential, we may still be required to provide a summary of it.

Privacy notice

The Environment Agency would like to keep you informed about the outcomes of the consultation. If you would like to receive an email acknowledging your response and telling you when we have published the consultation response document, please provide your email address with your response.

By giving us your email address, you consent for us to email you about the consultation. We will keep your details until we have notified you of the response document publication.

We will not share your details with any other third party without your clear and full consent, unless required to do so by law.

You can withdraw your consent to receive these emails at any time by contacting us at decarbonsationreadiness@environment-agency.gov.uk.

The Environment Agency is the data controller for the personal data you provide. For more information on how we deal with your personal data please see our personal information charter on GOV.UK. You can contact the Data Protection team at dataprotection@environment-agency.gov.uk for more information.

Consultation principles

We are running this consultation in line with the guidance set out in the government’s consultation principles.

If you have any queries or complaints about the way this consultation has been carried out (the process), please email consultation.enquiries@environment-agency.gov.uk.

For all other queries relating to this consultation, please email decarbonsationreadiness@environment-agency.gov.uk.  

What happens next

Once the consultation closes, we will publish a consultation response document on GOV.UK within 12 weeks of the consultation closing date.

We will use the responses to help refine the decarbonisation readiness guidance. We aim to publish the guidance on GOV.UK in the middle of 2025.

Consultation questions

Throughout the following questions, ‘the document’ means the draft decarbonisation readiness guidance.

Question 1

If you are an operator, does the document make it clear if the new requirements apply to you?

Please choose one of the following:

• Yes
• No
• Don’t know
• Not applicable

Is there any further information about the new requirements that you would like us to provide?

Question 2

A decarbonisation readiness report should set out how the decarbonisation readiness requirements have been met. Does the document clearly set out what is required by the new regulations?

Please choose one of the following:

• Yes
• No
• Don’t know
• Not applicable

Is there any further information would you like us to provide to make the requirements clearer?

Question 3

Refer to section 4, carbon capture decarbonisation readiness route.

Does this section clearly describe all the topics a decarbonisation readiness report following the carbon capture route should cover?

Please choose one of the following:

• Yes
• No
• Don’t know
• Not applicable

Are there any topics not covered or any topics lacking clarity?

Question 4

Refer to section 5, hydrogen decarbonisation readiness route.

Does this section clearly describe all the topics a decarbonisation readiness report following the hydrogen route should cover?

Please choose one of the following:

• Yes
• No
• Don’t know
• Not applicable

Are there any topics not covered or any topics lacking clarity?

Question 5

The document provides the right level of detail to guide an operator (or their agent) when applying for environmental permit with decarbonisation readiness.

Please choose one of the following:

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Prefer not to answer

Why do you think this?

Question 6

We expect the level of detail in decarbonisation readiness reports to be proportionate to the scale and complexity of the asset. Does the document provide sufficient information on what is expected for different sizes and types of plant?

Please choose one of the following:

• Yes
• No
• Don’t know

What further information is required?

Question 7

Operators may explore both the carbon capture and hydrogen routes to decarbonisation but we expect decarbonisation readiness reports to present a primary choice that we will assess as part of the permit application. Operators may change this preference in response to changing technology or conditions and update their report accordingly, provided a valid decarbonisation readiness report is maintained according to permit conditions.

Does the guidance make this clear?

Please choose one of the following:

• Yes
• No
• Don’t know
• Not applicable

Is there further information would you like us to provide to provide clarity?

Question 8

We recognise that new and emerging technologies will develop that apply to decarbonisation by carbon capture or hydrogen conversion. We will regularly review this document so that it reflects significant changes in technology. However, we intend it to have sufficient flexibility that operators can include the use of such technologies within the decarbonisation readiness report if appropriate.

Does the document adequality reflect this intention?

Please choose one of the following:

• Yes
• No
• Don’t know
• Not applicable

Is there any further information would you like us to provide?

Question 9

There will be a supplementary charge made for the assessment of a decarbonisation readiness report as part of the permit determination process. The specific costs will be consulted upon as part of a wider permit charging consultation.

For bespoke permits, the proposed charges will be based on the number of extra hours needed to assess the decarbonisation readiness report. A scaled approach is suggested according to the size and type of the power plant and the expected complexity of the decarbonisation technology being presented for assessment.

These would be:

• combustion electricity generating power plant equal to or greater than 0MWth or less than 20MWth
• combustion electricity generating power plant equal to or greater than 20MWth or less than 50MWth
• combustion electricity generating power plant equal to 50MWth or greater, or an energy from waste plant of any size

 Do you agree with this approach?

Please choose one of the following:

• Yes
• No
• Don’t know
• Not applicable

If you answered ‘No’, why do you think this?

Question 10

Is the language used in the document easy to understand, bearing in mind the technical nature of the subject matter and the intended audience?

Please choose one of the following:

• Yes
• No
• Don’t know

If you answered ‘No’, how could we improve this?

Question 11

Is there any information missing from the document?

• Yes
• No
• Don’t know

If you answered ‘Yes’, please tell us what you would like to see included.

Question 12

After reading the document and answering these questions, are there any other questions you have or suggestions you would like to make?

Additional questions

Are you responding as an individual or on behalf of an organisation?

Please choose one of the following:

• Individual response
• Response on behalf of an organisation or group (for example, charity, not-for-profit organisation, trading body)
• Other

If you are responding on behalf of another organisation or group, please state its name. For example, business, environmental group etc.

If you selected ‘other’, please explain your area of interest.

What sector do you represent?

Please choose one of the following:

• Government and regulators
• Environment
• Agriculture and horticulture
• Public water supply
• Navigation
• Recreation
• Energy
• Business
• Industry
• Other

If you selected ‘other’, please tell us your sector.

Do you want to be kept informed?

We would like to keep you informed about the outcomes of this consultation. Would you like to receive emails acknowledging your response and telling you when we have published the summary of responses?

Please choose all of the following that apply:

• Yes, I would like to receive an email acknowledging my response
• Yes, I would like to receive an email to let me know the consultation response document is published
• No, I would not like to receive any emails regarding this consultation

If you selected either ‘yes’ option, please provide your email address.

Refer to the privacy notice section.

Can we publish your response? We will not include personal information.

This is a required question. Please select one of the following:

• Yes
• No

If you answered ‘No’, please tell us why as we will need to understand this when responding to any Freedom of Information requests.