Consultation outcome

Consultation response: Decarbonisation readiness proposed guidance

Updated 3 November 2025

Introduction

We consulted on our proposed guidance for implementing the new ‘decarbonisation readiness’ requirements, introduced through the Environmental Permitting (Electricity Generating Stations) (Amendment) Regulations 2025. These regulations amend the Environmental Permitting (England and Wales) Regulations 2016 to require that new or substantially refurbished electricity generating stations within scope must provide and maintain a plan to decarbonise.

These requirements will apply in England to environmental permit applications submitted to the Environment Agency on or after 28 February 2026. They replace and expand the scope of the previous ‘carbon capture readiness’ (CCR) provisions, moving the requirements from the planning consent process into the environmental permitting regime.

The consultation sought views on proposed technical guidance for operators to follow when preparing a decarbonisation readiness (DR) report. The guidance is intended to support consistent, clear, and effective implementation of the new requirements. We invited feedback from a wide range of stakeholders, including operators, businesses, trade associations, government bodies, regulators, non-governmental organisations (NGOs), academics, and community groups with an interest in decarbonisation.

This document summarises the responses we received and explains how we have considered and addressed the feedback to improve the final guidance.

How we ran the consultation

The consultation ran for 10 weeks from 28 February to 9 May 2025 and was hosted on Citizen Space, our online consultation platform. It was open to all stakeholders with an interest in decarbonisation and environmental permitting.

The consultation was run in line with our legal requirements to consult following the Cabinet Office’s consultation principles guidelines.

We promoted the consultation through direct engagement with industry stakeholders, including operators, trade associations, and public sector bodies. We also shared information through our existing networks and published details on GOV.UK to encourage broad participation.

Respondents were invited to provide feedback on the clarity, usability, and technical content of the draft guidance. Responses could be made by using the online consultation tool or by submitting a completed response form by email.

All responses received within the consultation period were reviewed and analysed. This document summarises the feedback and explains how we have used it to improve the final version of the guidance.

Summary of key findings and actions we will take

This section provides a high-level overview of the main themes raised during the consultation and the actions we have taken in response. It is a quick summary of the key issues and clarifications made to the guidance.

For full details, including the rationale for changes and responses to specific points, refer to the thematic summaries and the question-by-question analysis in Annex 1.

We received 20 responses to the consultation:

• 10 from operators
• 5 from trade bodies
• 3 from community groups and members of the public
• 2 from public sector bodies

Overall, respondents welcomed the guidance and its intent to provide a clear framework for demonstrating DR. However, several themes emerged where consultees sought clarification or raised concerns.

The main themes raised were:

• scope and definitions: requests for clearer definitions of which plants are in scope, exemptions, and what constitutes ‘substantially refurbished’
• proportionality and feasibility: concerns about the level of detail expected, particularly for smaller plants, and how to demonstrate economic feasibility
• permit process and regulatory criteria: questions on updating DR plans, charging, and ensuring consistency between our regulatory officers
• hydrogen pathway and transition: requests for clarity on ‘hydrogen-ready’ and phased conversion
• carbon capture requirements: queries on evidence thresholds and space requirements
• supporting tools and templates: calls for worked examples, templates, and diagrams
• post-implementation review and emerging technologies: assurance that the guidance will remain responsive to innovation and lessons learned
• policy and legislative decisions: feedback on scope and thresholds, which are set by government policy

Key clarifications and updates to the guidance

We have made targeted updates to the guidance to improve clarity, support proportionate assessments, and respond to specific queries raised during the consultation. These changes aim to ensure the guidance is practical, scalable, and operator friendly. As part of the changes, we:

• clarified scope, exemptions, and definitions
• reinforced proportionality and flexibility
• added clarification boxes on CCR to DR transition, charging and updating DR reports
• clarified hydrogen readiness and evidence expectations
• confirmed that indicative values and reasoned justification are acceptable for feasibility assessments

We have not made changes where feedback related to government policy decisions or requests for prescriptive templates. These areas will be addressed through supporting materials and future reviews.

Thematic summaries and changes to the guidance

This section summarises the main themes we identified in the consultation and what action we have taken. Each theme includes:

• a short overview of what respondents told us
• our response and any clarifications or updates made to the guidance
• references to relevant sections of the guidance for more detail

For a question-by-question breakdown, see Annex 1.

Scope and definitions

Summary

Respondents asked for clearer definitions of which plant types are in scope for DR, including exemptions, fuel blends, and how DR applies to new or refurbished combustion plant. Several queries related to terminology, exemptions, and component-level applicability.

Feedback received

Inconsistencies between terminology used in legislation (for example, ‘generator’ in Schedule 25C) and guidance (for example, ‘combustion power plant’).  

Clarification requested on whether the addition of new capacity to an existing permitted site triggers DR requirements for the whole site, or only for the new capacity.

Applicability to small combustion units, standby generators, and combined heat and power (CHP) components.

Whether standby generators are in scope, including:

• emergency-only use cases
• aggregation rules
• anchor plant capability

Clarification on fuel blends and site-specific exemptions.

Queries about whether internal regulatory frameworks (for example, for national security sites) can be extended to DR due to security implications.

Clarification requested on whether components of CHP plants for example, digester heat, thermal hydrolysis process (THP) boilers, are in scope.

Some queries were not listed individually where the guidance already provides clear answers. These have been reviewed and considered, and no changes were required.

Our response

We have added a clarification note at the start of the guidance to explain that terms such as ‘combustion power plant’ should be interpreted in line with the statutory term ‘generator’ (and ‘in-scope generator’) as defined in Schedule 25C.

DR requirements apply only to new capacity or to elements of a combustion plant that are substantially refurbished. Adding new capacity to an existing permitted site does not trigger DR obligations for the existing plant.

Small combustion plants (for example, existing MCPs with a rated thermal input of 5MW or less) and Tranche A generators as defined in Schedules 25A and 25B are excluded from DR requirements. CHP plants are in scope where the combustion plant meets the criteria in Schedule 25C.

Standby generators and anchor plant capability are excluded where explicitly exempt under Schedule 25C. Aggregation of thermal input follows the definitions of a regulated facility in the Environmental Permitting Regulations.

Plants firing blends of methane with hydrogen, ammonia, or other low-carbon fuels remain in scope if the combustion plant meets general criteria. This applies regardless of the proportion of low-carbon fuel used.

DR requirements apply to all in-scope combustion power plants unless exempt under Schedule 25C of the Environmental Permitting Regulations. Internal regulatory frameworks, such as those used for national security sites, do not override these statutory requirements. The Environment Agency will follow existing procedures for handling confidential information. Applicants may use the pre-application advice service to discuss site-specific considerations.

DR applies to combustion plant components that meet the scope criteria in Schedule 25C. Non-combustion elements of CHP systems (for example, digester heat or THP boilers) are not subject to DR unless they form part of an in-scope generator.

Where we have changed the guidance

Section 3.1 – Added a Terminology and Interpretation note.

Added clarification boxes on:

• fuel blends
• aggregation
• scope of refurbishment

Section 3.4 – Added a short clarification encouraging applicants to consider which parts of the guidance apply to their case.

Section 3.2 – Added clarification on the anchor plant capability exemption.

Proportionality and feasibility constraints in applying DR requirements

Summary

Respondents queried the level of detail expected in DR assessments, particularly for smaller or early-stage projects. They asked for clarity on how to demonstrate feasibility, what evidence is acceptable, and how constrained cases will be handled.

Feedback received

How to demonstrate economic feasibility, especially for small or medium-sized plants. Respondents asked what constitutes ‘economically feasible’ and what evidence is expected.

Unclear expectations on level of detail required for different plant types. Respondents asked whether Front End Engineering Design (FEED)-level detail is required and whether technical requirements are proportionate to feasibility stage.

How to proceed where data is limited, particularly for emerging technologies such as hydrogen combustion.

Whether small CHP installations should have lighter requirements, to avoid DR becoming a barrier to decarbonisation on constrained sites.

What happens if no viable decarbonisation route exists, or if the chosen route becomes unfeasible.

How the Environment Agency will assess constrained applications, especially where economic arguments are weak or space availability is limited.

Differences in how standard rules and bespoke permits are determined, and whether this affects consistency and transparency.

Guidance may be too technical for operators without in-house expertise, especially smaller operators.

Some queries were not listed individually where the guidance already provides clear answers. These have been reviewed and considered, and no changes were required.

Our response

Economic feasibility is assessed over the lifetime of the generating plant. Applicants are not required to submit detailed financial models but must demonstrate that their proposed decarbonisation route would be economically feasible within that period.

The level of detail required in a DR report should be proportionate to the scale and complexity of the proposed plant. Applicants should demonstrate that they have considered all relevant points in the guidance and supporting technical studies. Detailed engineering designs, such as preliminary front end engineering design (Pre-FEED) studies, are not expected unless submitted voluntarily. Where applicants are unsure how the guidance applies to their specific circumstances, the Environment Agency’s pre-application advice service is available to support interpretation.

Where data is limited – particularly for emerging technologies such as hydrogen combustion or carbon capture – applicants may use indicative values, OEM statements, or public domain sources. Estimations, design assumptions, and narrative assessments are also acceptable. The Environment Agency will take a pragmatic view where applicants demonstrate that there are no known barriers to future decarbonisation and provide a clear rationale.

Applicants must meet the DR requirements to be issued a permit, unless they fall outside the scope of the DR report requirement. This includes:

• existing medium combustion plants (Schedule 25A) with a rated thermal input of 5MW or less
• Tranche A generators (Schedule 25B) with a rated thermal input of 5MW or less

In addition, Schedule 25C, paragraph 9(5) allows for constrained cases where existing permitted generators may be unable to meet DR requirements due to location or technical characteristics. Economic limitations alone are not sufficient. In these cases, operators may provide reasoned justification. A permit may still be issued where the justification is accepted. Supporting evidence must be retained, and operators may use the pre-application advice service to discuss constrained cases.

Standard rules and bespoke permits follow different processes under the Environmental Permitting Regulations. All applicants must meet the same DR requirements. Standard rules applicants must compile and retain their DR report and provide it to the Environment Agency upon request. Bespoke permit applicants must submit their report for assessment. This distinction reflects the broader permitting framework and does not affect consistency.

Where we have changed the guidance

Section 3.4 – Added a clarification box to reinforce the principle of proportionality and outline acceptable forms of evidence where detailed data is unavailable.

Section 4.1 and 5.3 – Added clarification that indicative values, OEM statements, and public domain sources may be used to support feasibility assessments for both hydrogen and carbon capture. Where detailed data is unavailable, estimations, design assumptions and narrative assessments should be provided.

Section 3.5 – Added clarification on when constrained applications may be considered and the conditions under which reasoned justification can be provided.

Section 3.7 – Added clarification on the difference between standard rules and bespoke permits and confirmed this does not affect consistency in DR assessments.

Where we have not changed the guidance

Some queries raised in this theme were already addressed in the existing guidance and legislation. These include the exemption criteria for certain plant types and the flexibility to tailor DR assessments to site-specific circumstances. We reviewed this feedback and concluded that no further changes were necessary to those sections.

Hydrogen pathway and transition

Summary

Respondents raised queries on how hydrogen conversion is addressed in the DR guidance, including definitions, phased approaches, and evidence expectations.

Feedback received

How to report phased hydrogen conversion or blending strategies

What ‘hydrogen-ready’ and ‘primary source of fuel’ mean in practice.

How to address uncertainty due to emerging hydrogen technologies and limited data.

What is meant by ‘hydrogen conversion equipment’.

What should be reported under performance considerations.

Inconsistencies in terminology; for example, volumetric capacity of firing hydrogen versus MWth.

Whether OEM declarations for hydrogen capability can include caveats (for example, component replacement).

Confirmation that all hydrogen sources meeting the Low Carbon Hydrogen Standard are acceptable.

Clarification on what constitutes ‘reasonable grounds’ for believing hydrogen supply will be feasible over the plant’s lifetime.

Our response

Phased conversion is acceptable if the DR report identifies the final state and demonstrates full hydrogen conversion is feasible.

‘Hydrogen-ready’ means the plant can be converted to operate on hydrogen as the primary fuel, not just blended use.

Uncertainty can be addressed using indicative values, OEM statements, or technical studies.

Hydrogen conversion equipment refers to modifications required to convert a combustion power plant to operate on hydrogen as the primary fuel. This does not include upstream hydrogen production or conversion processes (such as ammonia cracking or electrolysis).

Performance considerations may include efficiency, output, energy penalties, ramping rate, and emissions, reported proportionately to plant scale.

We acknowledge that blending hydrogen with natural gas is measured volumetrically, while hydrogen firing is assessed on a thermal input basis. Both metrics are relevant and will be considered where appropriate.

OEM declarations may include caveats about component replacement, provided these are clearly explained and justified.

Section 5.4 confirms that Hydrogen supply methods are acceptable if they meet the UK Low Carbon Hydrogen Standard.

Applicants must self-certify that they have reasonable grounds to believe hydrogen supply will be feasible during the plant’s lifetime. The guidance outlines acceptable forms of justification.

Where we have changed the guidance

Section 3.4 – Clarified definition of ‘hydrogen-ready’.

Section 5.1 – Added a clarification box in Section 5.1 to confirm that upstream hydrogen production and conversion processes are not considered part of hydrogen conversion equipment.

Section 5.1 – Added clarification that blending strategies must form part of a defined pathway to full conversion.

Section 5.2 – Expanded examples of performance considerations for hydrogen.

Section 5.3 – Added clarification that indicative values and reasoned justification are acceptable where detailed data is unavailable

Section 5.3 – Clarified that OEM declarations may include caveats, if clearly explained.

Carbon capture requirements

Summary

Respondents raised queries on scope (energy from waste (EfW) and biogenic CO2), performance considerations (start-up time), and the level of detail expected for the CO2 transport and storage test.

Feedback received

How EfW plants are defined and whether biogenic CO2 is in scope.

Whether start-up time should be included under performance considerations.

Concerns that transport and storage requirements implied detailed studies beyond the intended ‘no known barriers’ approach.

Clarity requested on whether outsourcing CO2 transport is permitted and whether it can be assumed or must be evidenced.

Our response

EfW plants are in scope where they meet DR criteria, and both fossil and biogenic CO2 must be considered.

Start-up periods are excluded from CO2 capture performance calculations, but operators should describe measures to maximise capture during start-up and shutdown.

The transport and storage test is a feasibility-level, self-certified assessment. Detailed engineering studies or commercial agreements are not required; indicative evidence is acceptable.

Outsourcing CO2 transport is permitted under the DR guidance, including use of third-party providers or carbon capture as a service. However, applicants must provide indicative evidence that a feasible route exists and cannot assume availability without justification. This ensures the feasibility assessment reflects realistic options and avoids reliance on speculative infrastructure.

Where we have changed the guidance

Updated Section 3.1 to confirm EfW scope and inclusion of biogenic CO2.

Added clarification in Section 4.2 on start-up and shutdown measures.

Re-drafted Section 4.4 to make flexibility clearer by softening prescriptive language and removing references that implied detailed studies

Supporting tools and templates

Summary

Respondents requested additional tools to help prepare DR reports, including templates, worked examples, and diagrams to support consistency and reduce rework.

Feedback

Requests for worked examples and example reports.

Suggestions for templates for DR reports and permit applications.

Calls for diagrams, flowcharts, and illustrative permit conditions.

Proposals for scaled expectations or minimum requirements for smaller plants.

Our response

The DR requirements are intended to support proportionate, feasibility-level assessments across a wide range of plant types and scales. The guidance provides a structured framework for demonstrating that there are no known barriers to future decarbonisation, while allowing flexibility in how applicants meet the requirements.

We acknowledge stakeholder requests for supporting materials to assist with the preparation of DR reports. While we have not made changes to the guidance in response to these queries, we recognise the potential value of supplementary tools, such as templates, worked examples, or diagrams, and may consider providing these in future to support consistent implementation.

Permit process and regulatory criteria

Summary

Respondents raised queries about how DR requirements will be implemented through the environmental permitting process. They asked for clarity on charging, exemptions, updates to DR plans, and how self-certified claims will be assessed.

Feedback

How commercially sensitive information will be handled.

What constitutes a ‘reasoned justification’ for exemptions.

How to update DR plans after a permit has been issued.

Whether air quality modelling is required when changing decarbonisation routes.

Charging arrangements for DR assessments, including for substantial variations.

How the Environment Agency will assess applications with economic or spatial constraints.

Environment Agency capacity to assess varied submissions.

How capacity categories will be used in charging.

Steps for notifying changes to DR plans.

How CCR conditions transition to DR conditions.

Whether DR land and corridors can be outside the permit boundary.

How self-certified claims will be verified.

Expected permit determination timelines.

Measures to ensure consistent interpretation by Environment Agency officers.

Our response

DR requirements will be implemented in line with the Environmental Permitting Regulations and the DR guidance. The permitting process is designed to be proportionate, flexible, and transparent, with clear expectations for applicants and safeguards for regulatory integrity.

Commercially sensitive information may be withheld from the public register where legally protected, but emissions-related data must be disclosed.

DR requirements must be met unless the application is a variation to an existing permit granted before the DR requirements came into force. In such cases, the Environment Agency may accept reasoned justification where meeting the requirements is not reasonably practicable due to location or technical characteristics. Economic limitations alone are not sufficient and will not be assessed. Narrative assessments and indicative values may support justification where appropriate.

DR plans must be reviewed every two years. Changes to the preferred decarbonisation route do not require a permit variation unless they involve substantial refurbishment of the combustion plant or the addition of an in-scope generator.

Air quality modelling is not required as part of the DR assessment unless the operator is adding the decarbonisation activity to their environmental permit at the same time.

Assessment charges will apply to both new bespoke applications and substantial variations. The proposed charging arrangements will be subject to a separate consultation. Standard rules permits are not subject to these charges unless we need to assess a reasoned justification for a constrained case.

The Environment Agency will assess DR submissions in line with existing permitting procedures. Charging arrangements reflect the time and expertise required to review varied applications, with proposed tiered charge bands supporting scaled fees for bespoke permits.

CCR conditions automatically cease to apply when the Environment Agency grants a permit or variation that includes DR conditions. DR land and corridors do not need to be within the current permit boundary but would need to be included once the carbon capture activity is permitted.

Operators must retain supporting evidence for self-certified claims. DR permits include a condition requiring biennial review.

Determination timelines will be proportionate to plant scale and  complexity. Timelines may also vary depending on the quality of the report submitted and any site-specific considerations

We are preparing internal guidance and delivering training to ensure that our permitting officers are ready to assess DR applications consistently and confidently ahead of the go-live date.

Where we have changed the guidance

Section 3.3 – Added a clarification box explaining the transition from CCR to DR.

Section 3.6 – Added new content confirming that DR charges apply to both new permit applications and substantial variations involving a decarbonisation readiness report.

Section 3.7 – Clarified that standard rules permits are not normally subject to DR charges unless a reasoned justification is submitted for a constrained case.

Section 7, Reviewing decarbonisation readiness – Provided clarification explaining how DR plans can be updated and when permit variations are required.

Where we have not changed the guidance

Sections 3.3, 3.5, 3.6, 3.7, 8.1, 8.2, and the Reviewing decarbonisation readiness section (7) already address the queries raised, including exemptions, updates, confidentiality and permit boundaries.

The guidance reflects the legislative framework and allows for flexibility, proportionality, and case-by-case assessment, whilst also supporting consistency and transparency in how expectations are applied.

Post-implementation review and emerging technologies

Summary

Respondents asked how the guidance will remain responsive to technological innovation and practical experience. They raised queries about review frequency, changing decarbonisation routes, and the level of evidence expected for emerging technologies.

Feedback

Whether the five-year review cycle is frequent enough to reflect rapid innovation.

How operators can propose new technologies or change route between formal reviews.

What level of evidence is expected when changing route or adopting emerging technologies.

Whether some requirements are premature or not applicable to all plant types.

How procurement uncertainty and lack of benchmark data affect feasibility assessments.

Whether the guidance should defer to technical studies for detailed treatment of emerging technologies.

Whether the guidance will be updated based on lessons learned post-implementation.

Our response

The guidance is designed to support flexibility, proportionate assessment, and pragmatic implementation. It will be reviewed and updated periodically to reflect technological developments and practical experience.

Operators are expected to demonstrate that there are no known barriers to future decarbonisation but are not required to provide detailed engineering designs or firm procurement commitments.

Applicants may update their DR report at any time, including between formal review periods. Notification is required, but a permit variation is only needed if the change involves substantial refurbishment of the combustion plant or the addition of an in-scope generator.

Separate justification is not required when changing decarbonisation route, provided the revised report demonstrates technical feasibility.

References to COMAH, nuclear safety, and offshore installations reflect the full scope of Schedule 25C but do not apply to all applicants.

Feasibility assessments for emerging technologies may use indicative values, OEM statements, or other available technical studies.

Existing technical studies will be reviewed periodically and expanded to include other emerging technologies alongside updates to the guidance

Where we have changed the guidance

Section 7 – Reviewing decarbonisation readiness – Added a clarification box explaining how operators can update their DR report between formal review periods, how to notify the Environment Agency, and when a permit variation is required.

Where we have not changed the guidance

Sections 3.4, 4.3, 5.3, 7, and the Economic Feasibility section already allow for proportionate assessment and the use of indicative data and justification where detailed information is unavailable.

Section 7 already outlines the requirement for biennial review and allows operators to propose changes based on technological, economic, or infrastructure developments.

The guidance already refers operators to the supporting technical studies for detailed technical information.

The guidance reflects the legislative framework and is designed to remain responsive to implementation experience and evolving decarbonisation opportunities.

Policy and legislative decisions

Summary

Some respondents queried the scope and flexibility of the DR requirements, including the inclusion of specific plant types, the 90% carbon capture threshold, and the exclusive focus on hydrogen and carbon capture as decarbonisation routes.

Feedback

Inclusion or exclusion of specific plant types (for example, standby generators, water industry sites).

Rationale for the 90% carbon capture threshold.

Why only hydrogen and carbon capture are permitted as decarbonisation routes.

Treatment of fossil versus biogenic CO2.

Whether DR report updates are required once a plant has fully transitioned to 100% hydrogen.

Definition of ‘substantially refurbished’.

Our response

The Environment Agency’s role is to implement the requirements set out in the Environmental Permitting (England and Wales) Regulations 2016, as amended. Scope, thresholds, and permitted decarbonisation routes are based on government policy decisions and were established through the Department for Energy Security and Net Zero’s (DESNZ) consultation process.

These decisions include:

• the requirement for DR to demonstrate either carbon capture readiness (CCR) or hydrogen conversion readiness (HCR)
• the use of a 90% capture threshold for CCR, as defined in Schedule 25C
• the inclusion or exclusion of specific plant types (for example, backup generators, landfill gas, anchor plant capability)
• the treatment of all CO2 emissions equally, regardless of fossil or biogenic origin
• the exclusion of alternative low-carbon fuels (for example, ammonia, synthetic methane) as standalone decarbonisation routes
• the requirement to review DR reports every two years, even where a plant has already transitioned to 100% hydrogen
• the definition of ‘substantially refurbished’ as refurbishment exceeding 50% of the investment cost of a comparable new plant

Where we have not changed the guidance

These matters are stipulated within the Environmental Permitting Regulations and are outside the scope of this consultation and guidance. Interested stakeholders seeking further detail on the rationale behind these decisions should refer to the government’s October 2024 consultation response published by DESNZ.

Further work

We acknowledge stakeholder requests for templates, worked examples, and other supporting materials to assist with implementation. While these are not included in the statutory guidance, we may consider developing supplementary tools to support consistent application. Other suggestions, such as changes to review frequency or policy scope, fall outside the Environment Agency’s remit and would need to be considered by government

Next steps

We have reviewed all consultation responses and made targeted updates to the guidance where clarification was needed. These changes aim to improve clarity and support proportionate, site-specific assessments, in line with the requirements set out in the 2025 amendment to the Environmental Permitting (England and Wales) Regulations 2016.

The Environment Agency has now published the guidance on decarbonisation readiness in environmental permit applications.

The final guidance will apply to relevant environmental permit applications submitted to the Environment Agency on or after 28 February 2026. This includes applications for new or substantially refurbished combustion power plants that fall within scope of the DR requirements.

We recognise that some respondents requested templates, worked examples, and other supporting materials to assist with implementation. While these are not included in the statutory guidance, we may consider providing supplementary tools in response to feedback received during the implementation phase.

Operators are expected to interpret the guidance in line with their specific circumstances and provide reasoned justification where appropriate. This approach supports flexibility and ensures assessments remain proportionate to plant scale and complexity.

We will continue to monitor feedback during implementation and may update the guidance or provide additional support materials in future to reflect how it is being used in practice.

If you would like to discuss your consultation response or the points made within this document, you can contact us at: decarbonisationreadiness@environment-agency.gov.uk

Annex 1: Consultation questions and how we responded

Annex 1 summarises responses to each consultation question and outlines how we have considered this feedback. It provides an overview of the main issues raised, the actions taken in response, and where no changes were made.

This section supports transparency by showing how individual questions relate to the broader themes. It is intended to help stakeholders understand how their feedback has informed the final guidance.

For more detailed and specific responses to grouped queries, refer to the thematic summary sections.

Question 1

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

Summary of responses

• 33% Yes
• 44% No
• 6% Don’t know

Follow-up question

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

Main issues raised

Terminology: ‘combustion power plant’ versus ‘generator’.

Scope: Whether DR applies only to new/refurbished elements.

Exemptions: Small plants, standby generators, anchor plant capability.

Aggregation: Whether it applies only to co-located units.

Technology types: CHP components, fuel blends, hydrogen users.

Special cases: National security sites, OEM caveats.

How we addressed this

See thematic sections: Scope and Definitions, Permit Process and regulatory criteria.

Where we have changed the guidance

Section 3.1 – clarified use of ‘combustion power plant’ as a readable synonym for ‘generator’.

Section 3.2 – clarified exemptions for small plants, standby generators, and anchor plant capability.

Section 3.5 – clarified how constrained applications may be justified.

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?

Summary of responses

• 43% Yes
• 46% No
• 5% Don’t know
• 5% Did not answer

Responses were divided, with some finding the guidance clear and others seeking more detail on how to apply it in practice.

Follow-up question

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

Main issues raised

Proportionality: Unclear expectations for different plant types, especially small or early-stage projects

Economic feasibility: Lack of clarity on what constitutes ‘economically feasible’ and acceptable evidence

Limited data: How to demonstrate compliance where data is unavailable or uncertain.

Hydrogen supply: What counts as ‘reasonable grounds’ for believing supply will be feasible.

Sensitive information: How commercially confidential data will be handled.

Exemptions: What qualifies as ‘reasoned justification’ for constrained applications.

Emerging technologies: How procurement uncertainty and innovation affect feasibility.

Special cases: Application of DR to USVF sites and small CHP installations.

Policy assumptions: How to handle expectations of future government support.

Post-permit barriers: What happens if chosen decarbonisation route becomes unfeasible.

How we addressed this

See thematic sections: Proportionality and Feasibility, Hydrogen Pathway and Transition, Permit Process and Regulatory Criteria, Post-Implementation Review and Emerging Technologies.

Where we have changed the guidance

Section 3.4 – clarified proportionality and acceptable evidence.

Section 3.5 – outlined constrained applications and reasoned justification.

Section 5.3 – confirmed use of indicative values for hydrogen feasibility.

Section 7 – clarified update process for DR reports.

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?

Summary of responses

• 40% Yes
• 45% No
• 15% Don’t know or did not answer

Follow-up question

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

Main issues raised

Capture performance: Unclear whether 90% capture must be continuous; definition of ‘overall’ performance.

Transport and storage: Lack of clarity on feasibility thresholds, outsourcing, and level of detail expected.

EfW scope: Uncertainty around inclusion of EfW plants and treatment of biogenic CO2.

Start-up/shutdown: Whether start-up time should be included in performance calculations

Proportionality: Concerns that expectations are not scaled for smaller plants; need for clearer minimum evidence thresholds.

Transition from CCR: Further clarity needed on how CCR conditions transition to DR.

Air quality modelling: Whether modelling is required when changing decarbonisation route.

Tools and support: Lack of practical tools to support DR report preparation.

How we addressed this

See thematic section: Carbon Capture Requirements, Proportionality and Feasibility
Scope and Definitions, Permit Process and Regulatory Criteria.

Where we have changed the guidance

Section 3.1 – confirmed EfW scope and inclusion of biogenic CO2.

Section 4.2 – clarified treatment of start-up and shutdown periods in performance assessments.

Section 4.4 – reworded CO2 transport and storage section to emphasise feasibility-level assessment and allow narrative evidence.

Section 3.4 – reinforced proportionality and clarified acceptable evidence types.

Section 3.3 – added clarification on transition from CCR to DR.

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?

Summary of responses

• 57.9% Yes
• 31.6% No
• 10.5% Don’t know

1 respondent did not answer

Follow-up question

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

Main issues raised

Definitions: Lack of clarity on ‘hydrogen-ready’ and ‘primary source of fuel’.

Blending and phased conversion: Uncertainty around how blending strategies fit into DR requirements.

Evidence expectations: What is acceptable where data is limited or technologies are emerging.

Performance reporting: What should be included under performance considerations.

Hydrogen conversion equipment: What this term includes or excludes.

How we addressed this

See thematic section: Hydrogen Pathway and Transition, Proportionality and Feasibility, Post-Implementation Review and Emerging Technologies.

Where we have changed the guidance

Section 3.4 – clarified definition of ‘hydrogen-ready’.

Section 5.1 – clarified that blending strategies must form part of a defined pathway to full hydrogen conversion.

Section 5.1 – clarified what is meant by ‘hydrogen conversion equipment’.

Section 5.2 – expanded examples of performance considerations.

Section 5.3 – confirmed that indicative values and reasoned justification are acceptable where detailed data is unavailable.

Question 5

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

Summary of responses

• 47.4% Disagreed or strongly disagreed
• 21.1% Agreed or strongly agreed
• 15.8% Neither agreed nor disagreed

Follow-up question

Why do you think this?

Main issues raised

Proportionality: Lack of clarity on how expectations scale by plant size or complexity.

Constrained cases: Unclear how economic or spatial limitations will be assessed.

Templates and tools: Requests for worked examples, templates, and illustrative permit conditions.

Emerging technologies: Concerns about premature or irrelevant references for smaller or non-nuclear plants.

Charging: Questions about whether charges apply to substantial variations as well as new applications.

Post-implementation: Recognition that guidance may need refinement over time.

How we addressed this

See thematic section: Proportionality and Feasibility, Supporting Tools and Templates, Permit Process and Regulatory Criteria, Post-Implementation Review and Emerging Technologies.

Where we have changed the guidance

Section 3.4 – reinforced proportionality and clarified acceptable forms of evidence.

Section 3.5 – clarified how constrained applications may be justified.

Section 3.6 – confirmed that DR charges apply to both new applications and substantial variations.

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?

Summary of responses

• 76.5% No
• 17.5% Yes

Follow-up question

What further information is required?

Main issues raised

Proportionality: Lack of clarity on how expectations scale by plant size or complexity.

Capacity categories: Need for clearer definitions and distinctions between categories.

Standard rules versus bespoke permits: Concerns about consistency in expectations and assessment.

Environment Agency capacity: Questions about the Environment Agency’s ability to assess varied submissions.

Requests for fixed MWth thresholder for plant size.

How we addressed this

See thematic section: Proportionality and Feasibility, Permit process and regulatory criteria.

Where we have changed the guidance

Section 3.4 – reinforced proportionality and clarified acceptable forms of evidence

Section 3.5 – clarified how constrained applications may be justified

Section 3.7 – clarified the difference in DR report requirements between standard rules and bespoke permits

Question 7

Operators may change their preferred decarbonisation route 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?

Summary of responses

• 55.6% Yes
• 44.4% No

2 respondents did not answer

Follow-up question

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

Main issues raised

Lack of clear steps for updating a DR report or notifying the Environment Agency.

Uncertainty around whether a permit variation is required when changing route.

Risk of inconsistent interpretation by Environment Agency officers.

How we addressed this

See thematic section: Post-Implementation Review and Emerging Technologies

Where we have changed the guidance

Section 7 – Added a clarification box explaining how operators can update their DR report between formal review periods, how to notify the Environment Agency, and when a permit variation is required.

Section 3.7 – Confirmed that revised reports must demonstrate technical feasibility but do not require separate justification for the change.

Section 3.6 – Clarified notification requirements for standard rules and bespoke permits.

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 adequately reflect this intention?

Summary of responses

• 68.8% Yes
• 25.0% No
• 12.5% Don’t know

3 respondents did not answer

Follow-up question

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

Main issues raised

Review cycle may be too infrequent to keep pace with emerging technologies.

Lack of transparency around how lessons learned will inform updates.

Unclear whether hydrogen fuel cells and other technologies are included or excluded.

Supporting technical studies may be more appropriate for detailing specific technologies.

No examples of what evidence is required to justify a change between reviews.

How we addressed this

See thematic section: Post-Implementation Review and Emerging Technologies.

Where we have changed the guidance

Section 7 – confirmed that operators may update their DR report between formal review periods to reflect new technologies or changes in decarbonisation route.

Section 7 – reaffirmed that the guidance will be reviewed and updated periodically to reflect technological developments and implementation experience.

Section 5.4 – confirmed that all hydrogen sources meeting the Low Carbon Hydrogen Standard are acceptable.

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?

Summary of responses

• 41.2% Yes
• 41.2% No
• 17.6% Don’t know

2 respondents did not answer

Follow-up question

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

Main issues raised

Charges should consider both application type and complexity, not just plant size.

Proposed banding may place disproportionate focus on smaller facilities.

Lack of clarity on charges for permit variations and whether standard rules applicants will be charged.

Concerns about the Environment Agency’s technical capacity to assess varied submissions.

Supporting examples would help operators understand how charges are applied.

How we addressed this

See thematic section: Permit Process and Regulatory Criteria.

Where we have changed the guidance

We have not made changes to the guidance in response to this question.

Charging arrangements will be addressed through a separate consultation on permit charging.

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?

Summary of responses

• 77.8% Yes
• 22.2% No

Responses were generally positive, with most agreeing that the language is clear and accessible. However, some felt the guidance is highly technical and assumes a level of expertise that some operators may not have.

Follow-up question

How could we improve this?

Main issues raised

Guidance may be too technical for operators without in-house expertise.

Lack of diagrams, flowcharts, and worked examples to support understanding.

Inconsistencies in how technical terms are used (for example, hydrogen metrics, MWth versus volumetric capacity).

Suggestions to group content by plant size or technology type.

Concerns that some requirements appear to go beyond feasibility-level detail.

How we addressed this

See thematic sections: Proportionality and Feasibility, Post-Implementation Review and Emerging Technologies.

Where we have changed the guidance

Section 3.4 – reinforced proportionality and confirmed that deviation is acceptable with justification.

Section 5.3 – confirmed that indicative values and reasoned justification are acceptable where detailed data is unavailable.

Section 7 – added clarification on updating DR reports and when permit variations are required.

Question 11

Is there any information missing from the document?

Summary of responses

• 58.8% Yes
• 5.9% No
• 35.3% Don’t know

Most respondents felt that additional information would improve the guidance, particularly around definitions, practical application, and consistency.

Follow-up question

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

Main issues raised

Lack of clarity on how to transition from CCR to DR requirements.

Unclear if DR land and corridors can be outside the permit boundary or used temporarily.

Definition based on 50% investment cost is vague.

No distinction made between fossil and biogenic CO2.

Unclear how Environment Agency will verify self-certified DR claims.

Unclear whether DR replaces or supplements planning consent.

Unclear whether a DR permit is a variation or a new application.

Lack of clarity on expected DR permit determination timelines.

How we addressed this

See thematic sections: Scope and Definitions, Permit Process and Regulatory Criteria, Supporting Tools and Templates, Post-Implementation Review.

Where we have changed the guidance

Section 3.1 – clarified the definition of ‘substantially refurbished’.

Section 3.3 – added a clarification on CCR to DR transition.

Section 3.4 – reinforced proportionality for smaller plants.

Economic Feasibility section – confirmed that detailed cost-benefit analysis is not required.

Section 7 – added a clarification box on updating DR reports and notifying the Environment Agency.