Decarbonisation Readiness: What New Power Plant Developers Need to Know
A practical explainer for operators, consultants, and project teams.
The UK is tightening expectations on how new and substantially refurbished combustion power plants prepare for a low-carbon future. From 28 February 2026, environmental permit applications in England must show that a plant is “decarbonisation ready” - meaning it can be converted in future to run with carbon capture or hydrogen.
This isn’t about installing the technology today. It’s about proving there are no known barriers to doing so later. The aim is simple: avoid building assets that become stranded as the power sector decarbonises.
Below is a clear breakdown of what the new rules mean in practice.
What Counts as a “Substantially Refurbished” Plant?
The definition is precise. A plant is considered substantially refurbished when:
The cost of refurbishing the combustion plant exceeds 50% of the investment cost of building a comparable new plant - excluding abatement equipment.
If you cross that threshold, the decarbonisation readiness requirements apply to the refurbished elements.
Which Plants Are in Scope?
The rules apply to a wide range of combustion power plants, including:
Fossil fuel and CHP plants
Biomass, biogas, and biofuel plants
Energy-from-waste facilities
Installations made up of multiple smaller units totalling ≥50 MWth
Specified generators <1 MWth participating in the Capacity Market or Balancing Mechanism
Existing plants are exempt unless they undergo substantial refurbishment.
What Operators Must Demonstrate
To be “decarbonisation ready”, every plant must pass four or five tests:
1. Space Test
Show that sufficient land exists on or near the site for future carbon capture or hydrogen conversion equipment — including cooling, utilities, access, and safety zones.
2. Technical Feasibility Test
Demonstrate that the plant can technically integrate:
A carbon capture system or
Hydrogen firing equipment
This includes burner changes, flue gas handling, utilities, emissions control, and safety.
3. CO₂ Transport & Storage Test (CCS route)
Self-certify that a feasible route exists to:
An offshore geological storage site, or
A CO₂ transport and storage network
4. Hydrogen Fuel Access Test (Hydrogen route)
Self-certify that the plant can access a sufficient supply of low-carbon hydrogen — either produced on-site or imported.
5. Economic Feasibility Test
Self-certify that decarbonisation will be economically feasible over the plant’s lifetime.
Learn more about the guidance on this in this “Decarbonisation readiness in environmental permit applications” gov.uk
What Counts as “Low-Carbon Hydrogen”?
The guidance requires hydrogen to comply with the UK Low Carbon Hydrogen Standard (LCHS).
The standard sets a lifecycle emissions threshold (currently <20 gCO₂e/MJ HHV in the LCHS itself). Only hydrogen meeting this standard qualifies for decarbonisation readiness.
Two Routes to Compliance
1. Carbon Capture Route
You must show:
Space for capture plant
Technical feasibility of chosen capture technology
A feasible CO₂ transport and storage plan
Economic feasibility
2. Hydrogen Conversion Route
You must show:
Space for hydrogen equipment and storage
Technical feasibility of hydrogen firing
A viable hydrogen supply plan
Economic feasibility
Hydrogen is the only acceptable fuel-switch route under the new rules.
Permit Types
Bespoke Permits
Full decarbonisation readiness report required
EA assesses space + technical tests
Operator self-certifies transport/storage or hydrogen access + economics
Additional charges apply
Standard Rules Permits
Operators must complete all four tests
Report kept on file but not submitted unless requested
Self-certification for all tests
Normally no additional charges
Why This Matters
For developers, investors, and operators, decarbonisation readiness is now a core permitting requirement — not an optional future consideration. Early planning avoids redesigns, delays, and costly land constraints later.
