Decarbonisation readiness in environmental permit applications
Updated 5 March 2026
Applies to England
1. Introduction
The introduction of ‘decarbonisation readiness’ supports the decarbonisation of the power sector by ensuring new build and substantially refurbishing combustion power plants are ready to convert to low carbon operation.
In July 2021, the UK government Department for Energy Security and Net Zero published a decarbonisation readiness joint call for evidence seeking initial views on reviewing the scope of the 2009 carbon capture readiness (CCR) requirements.
In March 2023, the Department for Energy Security and Net Zero conducted a decarbonisation readiness consultation to gather and analyse responses to the previous call for evidence. The decarbonisation readiness consultation response was published in October 2024.
The CCR requirements are replaced by decarbonisation readiness and now included in the Environmental Permitting (England and Wales) Regulations 2016 (EPR). The Environment Agency is the regulator.
This decarbonisation readiness guidance applies to England only. The current CCR requirements will continue to apply in Wales.
2. Who this guidance is for
This guidance applies to new and substantially refurbished electricity-generating combustion power plants in England. It offers practical advice for relevant environmental permit applications submitted to the Environment Agency on or after 28 February 2026.
This guidance is intended for use by:
- operators when designing their combustion power plants and preparing their application for an environmental permit
- regulatory staff
- any other organisation or member of the public seeking to understand how environmental regulations and standards are applied
This guidance uses terms such as ‘combustion power plant’ for readability. This should be interpreted in line with the statutory term ‘generator’ (and ‘in-scope generator’ where relevant) as defined in Schedule 25C of the Environmental Permitting (England and Wales) Regulations 2016.
Where obligations or scope under the legislation are concerned, the statutory definition prevails. For clarity on applicability, refer to:
- Sections 3.1 to 3.3 of this guidance
- Schedule 25C, paragraphs 1 and 2 (application and meaning of ‘in-scope generator’)
If you are still uncertain after reviewing these sections, you can seek clarification through the Environment Agency’s permit pre-application advice service (see Section 3.4)
This guidance will be kept under review and may be updated in future to ensure full alignment with legislative terminology.
The objectives of this guidance are to provide you, the operator, with the ability to demonstrate there are ‘no known barriers’ to decarbonise. This will minimise the risk of high carbon combustion power plants from becoming ‘stranded assets’.
This guidance is neither definitive, nor exhaustive. It is your responsibility to assess which sections of this guidance are applicable to your circumstances.
This guidance is supported by, and should be reviewed in conjunction with, the:
These studies provide the relevant technical information to assist you in your decarbonisation readiness assessment and are referred to within this guidance.
3. Overview
3.1 When decarbonisation readiness is required
If you operate a new or substantially refurbished electricity-generating combustion power plant in England, you are likely to need to demonstrate that it is ‘decarbonisation ready’ as part of your environmental permit application under the Environmental Permitting (England and Wales) Regulations 2016.
For the purposes of decarbonisation readiness, a generator is ‘substantially refurbished’ if the cost of refurbishing combustion plant in the generator exceeds 50% of the investment cost for comparable new combustion power plant, excluding the cost of abatement plant.
Decarbonisation readiness requirements apply only to new capacity or to the elements of a combustion power plant that are substantially refurbished. Existing plant that is not being refurbished is not required to demonstrate decarbonisation readiness. You should clearly identify which parts of the combustion power plant are new or refurbished and ensure the decarbonisation readiness assessment applies to those elements.
Decarbonisation readiness applies to the following plant types:
- fossil fuel combustion power plants, including combined heat and power plants
- biomass, biofuel and biogas combustion power plants, including plants that burn biogas or biomethane from anaerobic digestion
- energy from waste plant, including those that burn fuel products produced from waste through advanced thermal treatment (ATT) or advanced conversion technology (ACT), such as gasification or pyrolysis, where permitted as an incinerator
- combustion power plants which are already burning 100% hydrogen, capturing CO2, operating on blends of hydrogen, ammonia, or other low carbon fuels with methane or natural gas – no distinction is made between fossil and biogenic CO2 and you need to capture CO2 from both sources
As an operator, you are required to demonstrate decarbonisation readiness for the following new or substantially refurbished combustion power plants generating electricity that are:
- sized with a rated thermal input of equal to or greater than 50MWth (EPR Schedule 1, Part 2, Chapter 1, Section 1.1, Part A1)
- sized with a rated thermal input between 1 to 50MWth (EPR Schedule 25A)
- specified generators
- waste incineration or co-incineration plants with a capacity of more than 3 tonnes per hour of non-hazardous waste, or more than 10 tonnes per day of hazardous waste, where electricity is produced (EPR, Schedule 1, Part 2, Chapter 1, Section 5.1, Part A1)
- installations made up of multiple smaller units (for example, medium combustion plants or specified generators) that together have a total rated thermal input of 50MWth or more, even if individual units are below the threshold or not defined as medium combustion plants or specified generators under the regulations
Where multiple units form part of the same regulated facility under EPR, they may be considered together for the purposes of decarbonisation readiness. This typically applies to units located at the same site or with a technical connection. The decarbonisation readiness requirements do not alter how the Environment Agency defines a regulated facility.
Plants firing blends of methane with hydrogen, ammonia, or other low-carbon fuels remain in scope of the decarbonisation readiness requirements. This applies regardless of the proportion of low-carbon fuel used.
3.2 When decarbonisation readiness is not required
You are not required to demonstrate decarbonisation readiness for the following systems:
- existing combustion power plant until they undergo substantial refurbishment
- new combustion power plant with a rated thermal input below 1MWth that are not part of another permitted installation and do not participate in the capacity market or have balancing services agreements
- combustion power plant that are exempt from specified generator legislation unless they are also classed as medium combustion plant under an IED Chapter 2 installation
- combustion power plant burning gas generated from landfill waste only
- combustion power plant with a nuclear safety role, under a nuclear site licence issued by the Office for Nuclear Regulation
- combustion power plant that has anchor plant capability, as defined in the Grid Code, issue 6, revision 27 published on 1 October 2024 by National Energy System Operator – this exemption applies only to generating units that meet the Grid Code definition (the ability to start up independently and energise part of the transmission system) and does not apply to other units on the same site (for example, combined cycle gas turbines (CCGTs)) unless those units also meet the definition
- small waste incinerators (SWIPS) that generate electricity
- back-up combustion power plant that are operated only for maintaining power supply in an on-site emergency, where use for testing is no more than 50 hours per year and with a rated thermal input between 1 to 50MWth (including multiple units aggregated over 50MWth)
- combustion plant installed on an offshore platform (within the meaning of paragraph 2(2) of Part 1 of Schedule 25A)) situated on, above or below the sea adjacent to England
- combustion plant installed on a gas storage or unloading platform (within the meaning of regulation 2 of the Offshore Combustion Installations (Pollution Prevention and Control) Regulations 2013) situated in the sea adjacent to England; mobile generators other than one referred to in paragraphs 2(1)(a) or 2(1)(b) in Schedule 25B
3.3 Voluntary submissions
Operators of existing plant may wish to voluntarily apply for a permit variation to include decarbonisation readiness. For example, this could support potential investment or meet operators’ own net zero ambitions.
If the decarbonisation readiness report submitted to the Environment Agency satisfactorily meets the tests, then the permit will be varied to include decarbonisation readiness conditions.
If your plant is subject to existing CCR conditions under the planning regime, you may voluntarily apply for a permit variation to include decarbonisation readiness conditions. Where a decarbonisation readiness permit is issued, the decarbonisation readiness conditions will supersede the existing CCR conditions. No further action is required to remove CCR conditions – they cease automatically once the decarbonisation readiness permit is issued. This transition allows you to adopt the conversion route which is the most appropriate for your site.
3.4 How to comply with decarbonisation readiness requirements
Not all parts of this guidance will apply to every applicant. You should consider which sections are relevant to your plant. If a requirement does not apply, you should provide reasoned justification in your decarbonisation readiness report. You may use the permit pre-application advice service to clarify how the guidance applies to your case.
To meet the requirements of decarbonisation readiness, you must demonstrate either of the following requirements:
- the combustion power plant shall be ready to operate as a ‘qualifying complete CCS system’ that can continuously operate at a minimum capture rate of 90%
- the combustion power plant shall be hydrogen ready – meaning it can be converted to operate on hydrogen as the primary source of fuel
For the purposes of decarbonisation readiness, ‘qualifying complete CCS system’ means a system of plant and facilities for:
- capturing some or all of the CO2 (or any substance consisting primarily of CO2) that is produced by, or in connection with, the generation of electricity by a generating station
- transporting the CO2 (or substance captured)
- disposing of it by way of permanent storage
You may wish to consider both potential routes to decarbonisation as part of your planning. However, for the purpose of your permit application a primary preferred route must be submitted and meet the requirements. As you review and maintain your plan you may change route preference.
You will need to address 4 tests to demonstrate that your decarbonisation readiness complies with the requirements. They are:
- space test
- technical feasibility test
- CO2 transport and storage test (for the carbon capture decarbonisation readiness route), or hydrogen fuel access test (for the hydrogen decarbonisation readiness route)
- economic feasibility test
The level of detail you provide in your decarbonisation readiness report should be proportionate to the scale and complexity of your proposed combustion power plant. You are not expected to submit designs at the level of a ‘preliminary front end engineering design’ (Pre-FEED) study.
Your report should demonstrate that you have considered all relevant points in this guidance and the carbon capture readiness and hydrogen conversion readiness technical studies for your chosen decarbonisation route.
You are not expected to meet fixed benchmarks for technical, economic, or pipeline feasibility. Instead, you should demonstrate that there are no known barriers to future decarbonisation.
Where detailed data is unavailable, you may use estimations, design assumptions, or narrative assessments. You may also refer to indicative values, original equipment manufacturer (OEM) statements, or other public domain sources to support your assessment. Where your approach deviates from the guidance, you should provide reasoned justification.
You may use the permit pre-application advice service to support your interpretation of the guidance.
3.5 If the requirements cannot be met
There may be specific circumstances where operators are not required to submit a decarbonisation readiness report. This includes:
- existing medium combustion plants (as defined in Schedule 25A) with a rated thermal input of 5MW or less
- Tranche A generators (as defined in Schedule 25B) with a rated thermal input of 5MW or less
In addition, operators of existing combustion power plant may wish to substantially refurbish but be unable to meet the decarbonisation readiness requirements due to either:
- the location of the power plant
- its technical characteristics
In line with Schedule 25C, paragraph 9(5), this applies only to variation applications for generators operating under an environmental permit granted before the decarbonisation readiness requirements came into force. Economic limitations alone are not sufficient grounds for exemption.
In these cases, operators may provide reasoned justification to the Environment Agency. An environmental permit may still be issued where the justification is accepted. You must retain supporting evidence and may use the permit pre-application advice service to discuss constrained cases.
3.6 Bespoke permits
For relevant generators, a decarbonisation readiness report must be submitted as part of your application for a bespoke environmental permit. During permit determination, the Environment Agency will assess the information you present on how the space and technical feasibility tests are met. You will self-certify that the CO2 transport and storage, or hydrogen fuel access, and the economic feasibility tests are met.
A charge will apply for assessing your decarbonisation readiness plan as part of a bespoke permit application. This charge reflects the cost of assessment and applies to both new permit applications and substantial variations where a decarbonisation readiness plan is submitted.
Additional time and materials charges may apply if the Environment Agency needs to review your decarbonisation readiness plan during the life of your permit (for example, when you change your decarbonisation route).
Standard rules permits are not subject to these charges unless the Environment Agency needs to assess representations made in an application for a substantial variation to the effect that meeting the CCR conditions or the hydrogen conversion readiness (HCR) conditions would not be reasonably practicable due to location or technical characteristics.
3.7 Standard rules permits
If you are applying for a relevant standard rules permit, then you should also follow this guidance. You must compile a decarbonisation readiness report covering all 4 tests as part of your planning and preparation. However, you will not be required to submit this as part of your application, and you will self-certify that all 4 tests have been met. You must be able to provide your decarbonisation readiness report upon request.
Standard rules permits are not normally subject to decarbonisation readiness charges. A charge may apply if the Environment Agency needs to assess, in the context of a variation application, a derogation on the basis that meeting the conditions would not be reasonably practicable due to location or technical characteristics.
Standard rules and bespoke permits follow different processes under EPR. This distinction reflects the broader permitting framework and does not affect consistency in decarbonisation readiness report assessments. All applicants must meet the same decarbonisation readiness requirements.
3.8 Planning and permitting interface
You may need to apply to the relevant planning authority for planning permission to carry out your activities. It is advisable to check with the local planning authority at an early stage.
You are advised to use the permit pre-application advice service to engage with the Environment Agency prior to submitting your applications for planning permission and environmental permit, so that issues which pertain to both regimes can be factored into the design of the scheme.
Planning and environmental permitting decisions are separate. Planning permission determines if the development is an acceptable use of the land. Permitting determines if an operation can be managed on an ongoing basis to prevent or minimise pollution.
You may need to consider and include in your planning application any additional land or other requirements you may need to meet decarbonisation readiness permitting requirements.
You can find further information through the guidance on developments requiring planning permission and environmental permits.
4. Carbon capture decarbonisation readiness route
This section is applicable to operators submitting decarbonisation readiness plans following the carbon capture readiness (CCR) route.
4.1 How to demonstrate carbon capture readiness in your EPR permit application with your decarbonisation readiness report
You must address 4 tests to be considered decarbonisation ready through carbon capture.
You must show that you have reasonable grounds to believe that all the criteria below can be met during the lifetime of the combustion power plant. Your assessment must demonstrate:
- that sufficient space is available on or near the site to accommodate the proposed carbon capture equipment
- that it is technically feasible to incorporate carbon capture into the combustion power plant and detail what modifications will be required
- that you have a suitable plan for CO2 transport and storage
- that the plan is economically feasible
For bespoke permits, you are required to submit the following documents to the Environment Agency:
- a report detailing your decarbonisation plans, demonstrating how you meet the requirements of the 4 tests
- a site plan
- a self-certification statement that the CO2 transport and storage and the economic feasibility of the plan has been assessed and is viable
Where a standard rules permit application is made, self-assessments and self-certification statements are required for all 4 tests.
Instructions on what to include and how to present this evidence are provided in the following sections.
The level of detail provided in the description may be proportional to the scale of the asset, with larger plants providing more detail. For smaller power producers, you may consider a modular carbon capture plant if the option is available and feasible.
Where data availability is limited, you should refer to the indicative values set out in the carbon capture readiness technical study, OEM statements, or other public domain sources to support your assessment.
Estimations, design assumptions, or narrative assessments should be provided where detailed data is unavailable.
4.2 How to demonstrate that sufficient space is available on or near the site to accommodate carbon capture equipment
Your plan must demonstrate that there are no known spatial barriers which might prevent installation or operation of your chosen technology. This section details the information you need to consider to pass the space test.
You will be required to set aside adequate space for additional equipment needed for carbon capture. The space set aside should also align with the plant’s plans for carbon storage and transport. More information regarding carbon storage and transport is provided in Section 4.4.
You can refer to standard examples of plant sizes to assist you in allocating space for equipment. You may use the information provided in the carbon capture readiness technical study as a reference for footprint requirements of carbon capture plants. You may use the indicative values provided in the technical study when calculating the space requirements for your carbon capture plant (CCP). You can propose an alternative space allocation where justification is provided.
To demonstrate sufficient space is available for carbon capture, your plan must:
- state the footprint of the allocated area for the CCP
- justify and give evidence for the availability of adequate space for the CCP
- justify that all technical requirements detailed within Section 5.3 have been addressed and can feasibly fit within the allocated space
- provide an equipment list and the footprints of individual items of equipment, the detail provided should be proportional to the scale of the power plant development
- list the safety considerations arising from the chosen location and corresponding mitigations, referring to any Control of Major Accident Hazards (COMAH) requirements where appropriate
- describe the level of formal project development that has been undertaken in support of your space requirement calculations
- provide adequate spacing to allow continued operation and maintenance of the combustion plant without excessive interruptions
Your site plan needs to be clear and must include the following where applicable:
- all the equipment required for the CCP
- modifications to the existing combustion plant, if applicable
- extension and addition of balance of plant systems to accommodate carbon capture equipment requirements, if applicable
- site roads for chemical unloading and equipment maintenance access
- the perimeter of the plant and any associated auxiliaries
- the scale used for the site plan
- the location of the CCP and its proximity to the combustion plant
- details of any off-site equipment and auxiliaries such as chemical storage, if applicable
- the exit point for captured CO2 from the site
- the proposed location and footprint for the construction laydown area
All major equipment must be easily identifiable on your site plan through labels, call outs, or other appropriate means.
Land ownership and availability
You should assess the suitability of your chosen land for carbon capture and must ensure that no known barriers exist for the land you have chosen to build your CCP on. You must consider the following factors in your plan:
- current ownership of the proposed land and any acquisition plans
- timeline for land utilisation (including legal liabilities and timeframes)
- potential land designations (such as Nature Reserve, Site of Special Scientific Interest (SSSI))
If your selected land is not directly adjacent to the combustion power plant, you must ensure the availability of suitable land corridors to connect to the site.
4.3 How to demonstrate the technical feasibility of fitting your chosen carbon capture technology
This section provides information regarding the technical feasibility details you should include in your decarbonisation readiness report. There are several methods of CO2 capture and you must consider which method is the most appropriate to fit to your combustion power plant.
You must include:
- process descriptions of proposed CCP equipment
- a description of which carbon capture method is considered the most appropriate to fit to your combustion power plant along with justification
- the proposed location of the equipment on the site plan
- preliminary sizing of the footprint for the CCP equipment and the sizing basis used
- an outline of operational specifications of the CCP equipment
- the health and safety considerations of the proposed equipment, proposed mitigations and how this effects the plant design
If pursuing post-combustion carbon capture, then you are expected to use Environment Agency guidance on post-combustion CO2 capture: emerging techniques.
Carbon capture equipment
You must include the technical details of the CO2 capture process and associated equipment in your design. This includes:
- the design CO2 capture rate of your CCP
- details of all major equipment within the CCP such as sizing, quantity and operational requirements (temperature, pressure, flow rate)
- process requirements for CO2 conditioning and compression before export
- the estimated demand of any utility requirements for the carbon capture equipment
- the estimated demand of any chemical requirements
- the cooling demand and any abstraction water demand
- any tie-in points between the CCP and the combustion plant and any balance of plant equipment
- the proposed export location of the captured CO2
-
any health and safety concerns of the chosen CCP location
- any emissions arising from introducing carbon capture and their corresponding mitigations
Thermal requirements
The CCP may require substantial thermal input, often in the form of steam. This requirement may be met through modifications to the power plant’s steam cycle or the installation of separate steam generators. Where appropriate, your report must:
- specify the thermal requirements of the CCP
- explain how these requirements will be met through modifications or the addition of new process equipment
Performance considerations
The introduction of the CCP may result in performance impacts to the combustion power plant. Where appropriate, your report must describe:
- the expected performance impacts of integrating carbon capture with the combustion plant – for example, net efficiency, electricity produced from site, and energy penalty
- any non-energy related performance impacts of adding the CCP – for example, turndown capacity, ramping rate or additional waste, effluent or emissions streams
Periods of start-up are not included when considering CO2 capture performance calculations. However, operators should explain in their decarbonisation readiness plan what measures they would take to maximise CO2 capture during periods of both start-up and shutdown.
Cooling system
The CCP and associated equipment may require additional cooling. Your report must:
- confirm the proposed cooling technology
- define the specification of the cooling technology for the CCP, in particular the cooling duty of the system
- describe the necessary space and tie-ins for cooling equipment for the CCP
- detail any existing site permits
You should refer to the Environment Agency’s evidence on Cooling Water Options for the New Generation of Nuclear Power Stations in the UK when considering options for cooling. This gives an overview of UK power station cooling water systems in use in the UK and abroad.
If you are proposing a river or sea water-based cooling system, your report must include:
- an estimate of the cooling water demands (flows, heat loads and temperatures) for the CCP
- the proposed cooling water source, availability, and what stages of treatment (if any) are necessary
- any emissions in terms of environmental returns (flows, return temperatures and temperature differentials)
Water use, treatment, and disposal
Additional water requirements may be needed to meet the demands of the CCP and associated equipment. Certain water streams may require additional treatment, such as raw water pre-treatment and demineralisation, to ensure they can be used within the CCP. Your report must describe:
- the water usage within the CCP in terms of operational requirements (supply and discharge rates)
- any treatment requirements for these water streams
- the facilities requiring water usage
- the location and spacing of any water treatment plants
You may also require a wastewater treatment plant to treat the effluent streams produced through the process. Your report must describe:
- the wastewater sources produced by the CCP
- an estimate of the flowrate of wastewater to be treated
- any treatment requirement for these wastewater streams
- the location and spacing requirements of the wastewater treatment plant, if applicable
- the facilities which will produce wastewater sources
If you plan to use existing on-site water and wastewater plants, then you must provide evidence of their capacity to meet the increased demands.
Electrical loads
Significant electrical loads may be introduced through CCP equipment being fitted. Your report must include:
- the estimated electrical load requirements for the CCP
- provisions that spacing is available for any additional transformers, switchgears, and electrical rooms in your site plan
Plant infrastructure
You must address the plant infrastructure in your report and site plan and where necessary make provisions to:
- widen roads and add new roads to handle increased movement of vehicles
- provide car parking to accommodate increased personnel and vehicle usage
- indicate where major pipework and cable routes would be required
- extend or introduce new administration and operational buildings to accommodate additional personnel
- extend or introduce new workshops and stores to accommodate increased equipment storage capacity
- identify a potential operational laydown and maintenance area and provide its location and footprint
- ensure a suitable temporary laydown area for construction is available and provide its location and footprint
Requirements for post-combustion carbon capture
This section details the additional technical feasibility criteria specific to post-combustion CCP.
You must address the handling of the flue gas exiting from the combustion power plant. The flue gas exiting the combustion power plant may require pressure elevation for its passage to the CCP, typically accomplished with a booster fan arrangement.
Your report must:
- confirm the requirements for a booster fan
- detail any energy penalties associated with the fan
- estimate the space required for the fan
If it is possible to add carbon capture equipment without pressure-boosting equipment, you must provide evidence of this within your report.
You must also consider provisions for any flue gas pre-treatment necessary for the CCP operation. Your report must include:
- details of all proposed flue gas pre-treatment equipment (such as selective catalytic reduction, wet scrubber installations, dry electrostatic precipitation installations, dry sorbent injection flue gas cleaning system)
- the proposed volume of flue gas to be treated
- details of the interconnection between the combustion plant and the CCP
Specific requirements for pre-combustion carbon capture
This section details the additional technical feasibility criteria specific to pre-combustion CCP.
You must address the change in flue gas composition and temperatures after the pre-combustion capture process, describing any necessary changes.
You must ensure that the CCP reduces overall CO2 emissions associated with the generation of power by a minimum of 90%.
You must address the utility requirements of the pre-combustion capture process and how this will affect existing or proposed equipment. Your report must include:
- a process description of the utility supply system and any modifications to existing equipment
- the utility requirements for the fuel conversion process
- a description of the thermal integration and overall plant efficiency
- the spacing required for utility supply, including modifications of existing equipment, if applicable
You must also demonstrate the power plant’s capability to operate with a hydrogen rich fuel gas. Your report must include:
- confirmation of the ability to use hydrogen rich fuel gas
- an estimate of the performance of the combustion power plant operating with hydrogen fuel
- any pre-treatment required for the fuel before entering the power plant
You must also explain how the power plant will meet non-CO2 environmental emission limit values. You may require equipment such as selective catalytic reduction (SCR) to meet these limits.
Specific requirements for oxy-combustion carbon capture
This section details the additional technical feasibility criteria specific to oxy-combustion CCP.
Your report must include:
- a detailed process description of your plant
- the anticipated oxygen generation technology
- adequate spacing for equipment, interconnecting piping, and safety zoning
- the utilities for the oxygen source and associated emissions penalties
If your project does not intend to generate oxygen on site, your assessment must include:
- allocation of space for the reception and storage of oxygen
- the anticipated frequency of deliveries
- the energy and emissions associated with the generation of oxygen
Specific requirements for carbon capture projects from solid fuels
This section details the additional technical feasibility criteria specific to solid fuel CCP.
You must consider the waste separation and disposal facilities. Use of certain fuels such as coal, petroleum coke, waste or biomass will give rise to by-product residue streams that do not occur on natural gas plants.
Your report must include:
- identification of any additional by-product streams
- procedures for handling and disposing of these by-product streams
Your plan must also address nitrogen oxides emissions control (DeNOx), particulate removal, and desulphurisation. If you require new equipment, or modifications to existing equipment you must include the relevant equipment within your plan.
Your report must include:
- the expected emissions output from using solid fuel and the equipment necessary to mitigate these emissions
- a process description of the proposed equipment
- the predicted performance of this equipment
- the compatibility of the equipment with the CCP solvent mixtures
4.4 How to demonstrate a suitable plan for CO2 transport and storage
Your plan must address the CO2 transport and storage test. For both bespoke and standard rules permits, this is a self-certified test. As part of your permit application, you must provide a statement confirming that a CO2 transport and storage assessment has been conducted and that your plan can feasibly accommodate the necessary CO2 transport and storage quantities.
Your plan should:
- consider which CO2 transport and storage route is the most appropriate for your circumstances
- identify a suitable permanent offshore geological storage site for captured CO2 from your combustion power plant and the potential route from your site to the storage area or.
- identify a suitable CO2 transport and storage network for captured CO2 from your combustion power plant and the potential route from your site to a connection point of the network
You must keep records of your assessment as evidence which must be made available to the Environment Agency upon request.
You may conduct an assessment in greater detail than outlined in this section. However, this is not a mandatory requirement of the decarbonisation readiness assessment.
As this is a self-certified test, your report only needs to include the following information:
- a description of your CO2 transport and storage plan. The level of detail provided in the description may be proportional to the scale of the asset, with larger plants providing more detail.
- a self-certification statement confirming that your plan is feasible at the level of detail outlined below
You may choose to submit further information as part of your application. However, this will be considered outside the scope of the assessment and will therefore not be examined by the assessor.
Direct connection to geological storage area
The CO2 transport and storage test will be self-assessed. When submitting your application, you must make a statement that you have reasonable grounds to believe that it will be technically feasible, during the lifetime of the relevant generator, for the relevant amount of CO2 captured to be transported to a named storage site for disposal by way of permanent storage.
As part of your statement, you must do one of the following:
- identify a North Sea Transition Authority (NSTA) licensed area for deep geological storage of captured CO2, and demonstrate that a possible route exists from the proposed combustion power plant to the storage area
- identify a suitable area of deep geological storage offshore for the storage of captured CO2 from the proposed power plant, and demonstrate that a possible route exists from the site to the storage area
- identify a suitable CO2 transport and storage network to connect with, to facilitate the onward transport and storage of CO2 from the proposed combustion power plant, and demonstrate that a possible route exists from the site to the transport and storage network
Your assessment should:
- identify an offshore geological storage area for CO2, and delineate the geographical extent of that area
- estimate the volume of captured CO2 during the lifetime of your CCP
- confirm that the chosen geological storage area has sufficient capacity to accommodate your captured CO2
- consider other parties’ contractual commitments to the geological storage area, using information that is available within the public domain
- consider any potential technical barriers and their mitigations
- ensure that a possible route exists from the CCP to the offshore storage site
- identify any obstacles within a 10km radius of the CCP and consider appropriate mitigations to these obstacles
- consider potential CO2 transport barriers and their mitigations
- consider methods which will minimise impacts to the coastline, such as advanced boring and drilling methods
You may use open-source sites such as the North Sea Transition Authority and the British Geological Survey to support your plans.
As part of your decarbonisation readiness assessment, you should be aware that:
- there is no obligation to obtain a storage licence or commercial agreement, and this will be treated as a commercial decision outside of the assessments scope
- the geological storage site you identify is non-binding
Selection of a geological storage site does not grant you priority for future carbon capture. You may reference existing or planned storage markets.
Your application cannot assume site identification will be outsourced during plant deployment, even for joint transport agreements. If you have evidence on which to base an outsourcing proposal, then it must be included in your plan.
Your self-assessment must also confirm the feasibility of transporting your captured CO2 to the geological storage site. You cannot assume that you will be able to outsource your transport arrangements at the time of future carbon capture and storage deployment.
You are not required to provide any Environmental Impact Assessments as part of your decarbonisation readiness plan or when conducting your self-assessment.
Connection to geological storage area via a transport and storage network
You are responsible for identifying a suitable transport and storage solution, which must be an existing or planned network.
The CO2 transport and storage test will be self-assessed. When submitting your application, you must make a statement that you have reasonable grounds to believe that connection to a geological storage area via a transport and storage network will be possible.
As part of your assessment, you should:
- estimate the volume of captured CO2 during the lifetime of your CCP
- confirm that the transport and storage network has sufficient capacity, or plans for expansion, to accommodate your captured CO2. This can be done through evidence of engagement with the relevant transport and storage network operator or Ofgem. This will ensure relevant up to date information has been used on the self-assessment.
- consider the viability of connecting to the transport and storage network at the connection location proposed through the selected transport method
- confirm that the final destination of your exported CO2 will be an offshore geological storage site
- consider other parties’ contractual commitments to the transport and storage network, using information that is available within the public domain
- address and mitigate any potential technical barriers
You must also assess the feasibility of transporting the CO2 to the connection location of the transport and storage network and the most appropriate method of transport. You can choose from the following transport methods:
- pipeline
- road
- rail
- ship
If you intend to use the developing carbon capture as a service market, you must provide a decarbonisation readiness assessment from the service provider that meets all requirements specified in this guidance.
For larger combustion power plants CO2 is expected to be transported via a pipeline which is regulated by the Health and Safety Executive. This can be done as part of an industrial cluster.
If you choose a pipeline CO2 transport method
Your self-assessment must:
- ensure that a possible route exists from the CCP to the connection point of the transport and storage network
- identify any obstacles within a 10km radius of the CCP and consider appropriate mitigations to these obstacles
- consider potential CO2 transport barriers and suggest their mitigations
- consider methods which will minimise impacts to the coastline, such as advanced boring and drilling methods, if applicable
You are not required to provide any Environmental Impact Assessments as part of your decarbonisation readiness assessment.
Your application cannot assume that you will be able to outsource your onshore transport arrangements at the time of future carbon capture and storage deployment unless you are using carbon capture as a service.
Smaller CCP may find it more appropriate to export their captured CO2 via a non-pipeline transport method.
If you choose a non-pipeline CO2 transport method
Your self-assessment must:
- ensure that a feasible route exists from the CCP to the connection point of the transport and storage network
- estimate the amount of CO2 to be exported and the tonnage capacity of your chosen transport method
- estimate the expected frequency of vehicles loading your captured CO2 per day
- consider the requirements, if any, for onsite or offsite storage tanks, their capacity, footprint, location, and appropriate safety considerations
- consider the requirements, if any, for CO2 liquefaction
5. Hydrogen decarbonisation readiness route
This section is applicable to operators submitting decarbonisation readiness plans following the hydrogen conversion readiness (HCR) route.
You must be aware that the government policy states that decarbonisation readiness through fuel conversion can only be demonstrated through the hydrogen route. Proposals to convert to other low carbon fuels are not currently acceptable to meet the decarbonisation readiness requirements.
Plants firing or intending to fire blends of methane with hydrogen, ammonia or other defined low carbon fuels remain in scope of the decarbonisation readiness requirements, with no distinction between fossil and biogenic CO2.
5.1 How to demonstrate hydrogen readiness in your permit application with your decarbonisation readiness report
You must address 4 tests to be considered decarbonisation ready through hydrogen conversion.
You must show that you have reasonable grounds to believe that all the criteria below can be met during the lifetime of the plant. Your assessment must demonstrate:
- that sufficient space is available on or near the site to accommodate any equipment associated with conversion to hydrogen combustion
- that it is technically feasible to convert the combustion power plant to hydrogen firing and detail what modifications will be required
- that you have a suitable plan for hydrogen fuel access
- that the plan is economically feasible
For the purposes of this guidance, hydrogen conversion equipment refers to any equipment required to convert a combustion power plant to operate on hydrogen as the primary fuel. This includes modifications to the combustion power plant, emissions control systems, fuel supply infrastructure, and associated safety systems. It does not include upstream hydrogen production or conversion processes, such as ammonia cracking, electrolysis, or other hydrogen generation technologies. These may be addressed separately under permitting requirements for hydrogen production facilities.
To meet the requirements of decarbonisation readiness, the combustion power plant must be capable of operating on hydrogen as the primary fuel. Where an operator proposes a phased approach to hydrogen conversion (for example, initial blending followed by full conversion), the decarbonisation readiness report must clearly identify the final intended state and demonstrate that full hydrogen conversion is technically feasible.
Blending strategies alone do not meet the hydrogen readiness requirement unless they are part of a defined pathway to full conversion. The Environment Agency will take a pragmatic view where reasoned justification is provided.
For bespoke permits, you are required to submit the following documents to the Environment Agency:
- a report detailing your decarbonisation plans, demonstrating how you meet the requirements of the 4 tests
- a site plan
- a self-certification statement that the hydrogen fuel access and the economic feasibility of the plan has been assessed and is viable
Where a standard rules permit application is made, self-assessments and self-certification statements are required for all 4 tests.
Instructions on what to include and how to present this evidence are provided in the following sections.
The level of detail provided in the description may be proportional to the scale of the asset, with larger plants providing more detail.
Where the approach you propose deviates from published technical guidance you should provide reasoned justification for the Environment Agency to assess.
5.2 How to demonstrate sufficient space is available on or near the site to accommodate any equipment necessary to allow conversion to hydrogen
Your plan must demonstrate that there are no known spatial barriers which might prevent installation or operation of your chosen technology. This section details the information you need to consider to pass the space test.
You will be required to set aside adequate space for additional equipment needed for hydrogen combustion, both internally and externally, to accommodate your chosen hydrogen technology. The space set aside should also align with the plant’s plans for accessing hydrogen. More information regarding hydrogen supply is provided in Section 5.4.
You can refer to standard examples of plant sizes to assist you in allocating space for equipment. Table 11 in the hydrogen readiness technical report provides indicative values for the land footprint requirements for combustion power plants and additional requirements for hydrogen infrastructure. Where you are proposing allocating less space, you must provide justification for this in your decarbonisation readiness report.
To demonstrate sufficient space is available for hydrogen conversion, your plan must:
- state the footprint of the area allocated for any equipment associated with the conversion to hydrogen
- justify and give evidence for the availability of adequate space for hydrogen conversion
- justify that all technical requirements detailed within Section 5.3 have been addressed and can feasibly fit within the allocated space
- provide an equipment list and the footprints of individual equipment – the detail provided should be proportional to the scale of the power plant development
- list the safety considerations arising from the chosen location and corresponding mitigations, referring to any COMAH requirements where appropriate
- describe the level of formal project development that has been undertaken in support of your space requirement calculations
Your site plan needs to be clear and must include the following where applicable:
- fuel gas supply infrastructure comprising of hydrogen delivery, as well as any dual fuel provisions
- hydrogen fuel gas production facilities, if applicable, including any pre-treatment conditioning, cooling, and supporting utilities
- storage and handling of hydrogen, oxygen, and any utilities
- modifications to the existing combustion power plant
- extension or addition of emissions control equipment and diluent, such as SCR reagent, additional catalyst, nitrogen, steam, or water injection
- provisions to facilitate vehicle movement and access to equipment
- labels for the major equipment suppliers of equipment for conversion to hydrogen
- the perimeter of the plant and any associated auxiliaries
- details of any off-site equipment and auxiliaries such as chemical storage
- the entry point for hydrogen to the site and a note detailing the method of transportation
- the proposed location and footprint of the operations and maintenance area
- the proposed location and footprint of the construction laydown area
Land ownership and availability
You should assess the suitability of your chosen land for any equipment to support hydrogen conversion and must ensure that no known barriers exist for the land you have chosen to build this hydrogen conversion equipment on. You must consider the following factors in your plan:
- current ownership of the proposed land and any acquisition plans
- timeline for land utilisation (including legal liabilities and timeframes)
- potential land designations (such as nature reserve, SSSI)
If your selected land is not directly adjacent to the combustion power plant, you must ensure the availability of suitable land corridors to connect to the site.
5.3 How to demonstrate the technical feasibility of conversion to a hydrogen fuel fired plant
This section provides information regarding the technical feasibility details you should include in your decarbonisation readiness report for a hydrogen fired combustion plant. Your report must include:
- process descriptions of proposed equipment required for hydrogen conversion
- the proposed location of the equipment, provided in the site plan
- preliminary sizing of the footprint for the hydrogen conversion equipment and the sizing basis used
- outline of operational specifications of the hydrogen conversion equipment
- the health and safety considerations of the proposed equipment, proposed mitigations and how this effects the plant design
You may refer to the detailed technical information is described in Section 3.1 and 3.2 of the hydrogen readiness technical study for further clarifications.
You may choose to submit process flow diagrams and block flow diagrams to support your application. However, this is not an explicit requirement.
OEM declarations may include caveats or conditions relating to component replacement, provided these are clearly explained and justified in the decarbonisation readiness report. Where data availability is limited, you should refer to the indicative values set out in the hydrogen readiness technical study, OEM statements, or other public domain sources to support your assessment.
Estimations, design assumptions, or narrative assessments should be provided where detailed data is unavailable.
Hydrogen firing
You must demonstrate that it will be possible to modify your combustion power plant to allow firing on hydrogen as the primary source of fuel.
You must address the following:
- ensure the location of the combustion power plant does not pose any constraints towards the supply of hydrogen fuel
- the volumetric capacity of firing hydrogen
- materials issues and embrittlement
- impact on NOx generation
- leak detection and safeguarding
- differences in combustion properties of hydrogen compared to the current fuel fired by the combustion power plant
- any utility requirements for the hydrogen readiness equipment
- the startup and shutdown process
- any emissions arising from hydrogen conversion and their corresponding mitigations
You must provide a statement from the Original Equipment Manufacturer (OEM) that the chosen generation equipment can already burn hydrogen as its primary source of fuel if there is no intention to replace this equipment when converting.
You must ensure that any proposed modifications to the combustion power plant are compliant with any environmental restrictions. If you fall outside the boundaries stipulated by environmental restrictions, then you must provide mitigations to bring your plans back into compliance, such as introducing selective catalytic reduction (SCR) to manage NOx emissions.
Hydrogen storage
Depending on your specific circumstances, you may choose to store hydrogen on-site, or near to the site of, your combustion power plant. If you choose to do this, then you must include:
- the chosen method of storage
- the designated location and spacing allocated for hydrogen storage
- the total mass of hydrogen to be stored
- any health and safety considerations and their corresponding mitigations
Where hydrogen is stored in off-site geological storage facilities, these may have their own unique owner or operator (separate from the power facility) which will likely be responsible for any health and safety considerations and their corresponding mitigations.
There are various methods available for hydrogen storage, including, but not limited to:
- geological storage
- above ground storage:
- liquid hydrogen
- compressed hydrogen
- liquid organic hydrogen carriers (LOHC)
- porous materials
You must provide a statement justifying your choice of storage method and why it is most suitable for your combustion power plant.
This list is not exhaustive, and with ongoing technological advancements in this field, new hydrogen storage methods may emerge.
The Environment Agency will review storage of potentially hazardous materials in line with hazardous substances consent, environmental permits and licences, and COMAH regulations.
Performance considerations
The conversion to hydrogen firing may result in performance impacts to the combustion power plant. Where appropriate, your report must describe the expected performance impacts of converting to hydrogen fuel. These may include changes in net efficiency, electricity output, energy penalties, turndown capacity, ramping rate, or additional waste, effluent, or emissions streams.
The level of detail should be proportionate to the scale and complexity of your proposed plant. Where your approach differs from published technical guidance, you should provide reasoned justification.
Cooling system
The conversion to hydrogen may require additional cooling, particularly if hydrogen is produced onsite. Your report must:
- confirm the proposed cooling technology
- define the specification of the cooling technology for the combustion power plant and hydrogen production facility, if applicable, the cooling duty of the system
- describe the necessary space and tie-ins for cooling equipment
- details of any existing site permits
You should refer to the Environment Agency’s evidence on cooling water options for the new generation of nuclear power stations in the UK when considering options for cooling. This gives an overview of UK power station cooling water systems in use in the UK and abroad.
If you are proposing a river or sea water-based cooling system, then your report must include:
- an estimate of the cooling water demands (flows, heat loads, and temperatures) for the hydrogen
- the proposed cooling water source and what stages of treatment are necessary
- any emissions in terms of environmental returns (flows, return temperatures, and temperature differentials)
Water use, treatment, and disposal
Additional water requirements may be needed to meet the demands of the hydrogen fired plant and associated equipment, such as any hydrogen production facility or emission control system. Certain water streams may require additional treatment, such as raw water pre-treatment and demineralisation, to ensure it can be used within the converted combustion power plant. Your report must discuss:
- the water usage within the plant and associated equipment in terms of operational requirements (supply and discharge rates)
- any treatment requirements for these water streams
- the facilities requiring water usage
- the location and spacing of any water treatment plants
You may also require a wastewater treatment plant to treat the effluent streams produced through the process. Your report must include:
- the wastewater sources produced by the hydrogen converted plant
- an estimate of the flowrate of wastewater to be treated
- any treatment requirement for these wastewater streams
- the location and spacing requirements of the wastewater treatment plant
- the facilities which will produce wastewater sources
You may choose to reuse any existing on-site water plants to accommodate the additional demands for the hydrogen converted plant. In this case you must provide evidence that the capacity of the existing water and wastewater plants are sufficient to handle the increased demand of the hydrogen converted plant.
Electrical loads
Modifications to the existing combustion plant and the introduction of a hydrogen production facility, if applicable, may lead to additional electrical load. Your report must include:
- the estimated additional electrical load requirements
- provisions that spacing is available for any additional transformers, switchgears, and electrical rooms in in your site plan
Plant infrastructure
You must address the plant infrastructure in your report and site plan and where necessary make provisions to:
- widen roads and add new roads to handle increased movement of vehicles
- provide car parking to accommodate increased personnel and vehicle usage
- indicate where major pipework routes would be required
- extend or introduce new administration and operational buildings to accommodate additional personnel
- extend or introduce new stores to accommodate increased equipment storage requirements
- ensure a land plot has within the proposed site perimeter has been identified as an operational laydown and maintenance area and provide its location and footprint
- ensure a suitable temporary laydown area for construction is available and provide its location and footprint
5.4 How to demonstrate access to hydrogen fuel
The third test that your plan must address is that of hydrogen fuel access. For both bespoke and standard rules permits, this is a self-certified test. When submitting your permit application, if you choose the HCR decarbonisation route, you will be required to include a ‘hydrogen fuel readiness certification’ statement. This will be a statement that you have reasonable grounds to believe that it will be possible, during the lifetime of the relevant plant to ensure access to a sufficient supply of hydrogen.
Methods to access a hydrogen supply include:
- direct on-site production
- importing from off-site production
For in-depth insights into considerations regarding hydrogen supply, please consult Section 3.5 of the hydrogen readiness technical study.
You may choose to also include a hydrogen fuel access diagram and any letters of engagement or expressions of interest with suppliers.
You must keep a record of your assessment as evidence which must be made available to the Environment Agency upon request.
On-site production
If you select the on-site hydrogen production option, then you must ensure that the hydrogen production method you have selected for your site is compliant with the UK Low Carbon Hydrogen Standard (LCHS). The LCHS sets out the criteria for hydrogen produced via:
- electrolysis
- natural gas reforming with carbon capture and storage
- biomass and biowaste conversion to hydrogen, with and without carbon capture and storage
When carrying out your assessment you must consider the following parameters:
- the location and spacing required for your hydrogen production facility
- the production capacity of hydrogen at your facility
- any emissions arising from the production methods and proposed mitigation strategies
- any health and safety considerations and their corresponding mitigations
For your decarbonisation readiness application, you are advised to refer to the Environment Agency guidance on:
- hydrogen production with carbon capture: emerging techniques
- hydrogen production by electrolysis of water: emerging techniques
You need to be confident that you could meet the criteria required of the permittable activity should you implement the readiness plan.
Importing from off-site production
Depending on your specific circumstances, you may decide to import hydrogen from an off-site location. If you choose this approach, then you must ensure that the hydrogen supply is compliant with the LCHS.
There are various potential methods of importing sufficient and reliable supplies of hydrogen to your site. You can choose from the following supply methods:
- pipeline
- rail
- road
- ship
If you choose to import hydrogen through a pipeline, your assessment must:
- ensure that a feasible route exists from the combustion power plant to the connection point of the pipeline
- estimate the daily hydrogen fuel demand of the plant, including daily hydrogen fuel demand for any plant expansion proposals to ensure future expansion of the plant is also catered for
- consider the location and spacing requirements of any above-ground installations to receive the hydrogen
- consider the location, spacing requirements, and capacity of any on-site storage, if applicable
- consider any health and safety considerations and their corresponding mitigations
In your plan you cannot assume that a pipeline will be constructed to meet your demands. You must reference an existing or proposed infrastructure project which you can tie into.
If you choose to import hydrogen through a non-pipeline method, your assessment must:
- estimate the daily hydrogen fuel demand of the plant, including daily hydrogen fuel demand for any plant expansion proposals to ensure future expansion of the plant is also catered for
- consider the hydrogen carrying capacity of your non-pipeline transport option – for example, a single vehicle or single freight train delivery and the minimum daily traffic required to meet the plant’s fuel demands
- assess whether local road or rail connections and onsite roads or rail can accommodate the expected traffic
- consider the location, spacing requirements, and capacity of any on-site storage, if applicable
- consider any health and safety considerations and their corresponding mitigations
6. How to demonstrate economic feasibility
The final test that you must address is the economic feasibility of your chosen decarbonisation route. For both bespoke and standard rules permits, this is a self-certified test. When submitting your permit application, you will be required to include an ‘economic feasibility certification’ statement as part of your application. This will be a statement that you have reasonable grounds to believe that it will be economically feasible during the lifetime of the relevant plant to decarbonise by your chosen route.
When you assess the economic feasibility of your plans, you must investigate the capital and operational costs associated with your proposed decarbonisation route. This investigation must conclude whether the proposed actions to reach decarbonisation readiness are economically feasible within the combustion power plants lifetime. You do not have to demonstrate that your proposed decarbonisation readiness plan is feasible at the date of assessment.
The level of detail you conduct in your assessment should be proportional to the scale of the proposed works. Detailed economic models are not required; however, you must follow a clear methodology for estimating capital and operating costs.
During your economic feasibility assessment, you must consider the following:
- capital and operating costs for your decarbonisation readiness plan
- the methodology used in obtaining these figures
- any assumptions used in your investigation
- the economic feasibility of the proposed plan within the plant’s lifetime
You can use your own methodology to conduct the economic feasibility assessment. However, you are advised to investigate the following parameters:
- assumed currency conversion rate, where required
- hurdle rate or internal rate of return
- fuel price
- carbon price
- cost of transport (construction and operation)
- cost of converting to hydrogen or fitting carbon capture equipment (construction and operation – if applicable)
- cost of storage
You must keep a record of your assessment as evidence, which must be made available to the Environment Agency upon request.
7. Reviewing decarbonisation readiness
Your environmental permit will include conditions relating to decarbonisation readiness. You must review your decarbonisation readiness report at least once every 2 years and, where appropriate, update your plans. An up-to-date decarbonisation readiness report must be made available to the Environment Agency upon request.
The purpose of the review is to encourage you to regularly assess the decarbonisation potential of your plant and to identify whether circumstances have evolved such that your original plans are no longer achievable.
The review will assess the plant’s decarbonisation potential, and the suitability and effectiveness of your chosen decarbonisation pathway. It will also assess whether any new barriers to decarbonisation have been identified, or whether any alternative decarbonisation pathways may be more appropriate.
Where appropriate you should update the approach to meeting decarbonisation readiness requirements when there are:
- new technological or economic developments
- wider infrastructure changes such as the installation of hydrogen or carbon capture infrastructure close to the plant
- other material changes
You may update your decarbonisation readiness report at any time, including between formal review periods, to reflect new technologies or changes in your preferred decarbonisation route (for example, switching from carbon capture readiness to hydrogen readiness).
If you hold a bespoke permit, you must submit your revised report to the Environment Agency for assessment. A charge will be applied if they have to review your revised decarbonisation readiness report.
If you hold a standard rules permit, you must notify the Environment Agency that your report has been updated. Submission for assessment is not required.
You do not need to apply for a permit variation when changing your decarbonisation route, unless the change relates to either:
- the substantial refurbishment of an in-scope generator
- the addition of an in-scope generator
You do not need to provide separate justification for the change. Your revised report must demonstrate that the new route remains technically feasible and meets the relevant requirements.
If your review identifies a barrier to implementing your chosen decarbonisation technology, you should explore and propose alternative solutions.
8. Disclosure information
8.1 Public register
The Environment Agency is required by law to maintain and make available public registers of information. For all permits that you apply for, the Environment Agency will place the permit application form and supporting information, the decision document and, if granted, the permit on the public register. This includes information submitted to meet the decarbonisation readiness requirements.
Under EPR, the Environment Agency can exclude commercial or industrial information from the public register where its confidentiality is provided by law to protect against a legitimate economic interest. However, if the information relates to an emission to the environment, the Environment Agency must place the information on the public register.
You can find more detailed information on the how the Environment Agency will hold and share the information you provide in the EPR core guidance.
8.2 Environmental information regulations
Members of the public can request information from the Environment Agency under the Environmental Information Regulations 2004 (EIR). The public can also request information that has been withheld from the public register as being commercially confidential.
The Environment Agency is bound to comply with the legislation, under which there is a presumption in favour of disclosure. Therefore, you should consider the level of detail of information that you provide and whether the information provided is greater than required to conduct the decarbonisation readiness assessment.