The UK government today released a consultation on how to enact into law their commitment to phase-out unabated coal generation by 2025. 

It is good news that the government is still committed to the 2025 phase-out date.  BEIS propose this would be legislated by either a direct requirement for carbon capture and storage or by an emissions performance standard limiting instantaneous CO2 emissions to a gas plant.

There are only two small potential loopholes that may allow unabated coal generation post-2025.  First the law allows coal plants to only partially install carbon capture and storage, allowing some unabated coal generation post-2025; second it is likely the Secretary of State will have powers to postpone the date in the future if there are concerns over security of supply.  These clauses are small and well-intentioned, and we hope they are implemented to keep integrity to the initial government commitment.

However, the consultation has no solid proposals to restrict coal generation prior to 2025.  There are big benefits of ensuring coal generation prior to 2025 is constrained: a smoother transition to the phase-out, with more certainty given to low carbon investors, lower CO2 emissions, and less harmful SO2 and NOx emissions.

The initial government commitment was to restrict coal generation from 2023.  The consultation seeks views on how to do limit generation, but their lack of thoughts on this suggests that they are unlikely to implement it.

Having said that, we believe two tools are already in place to restrict coal generation prior to 2025: the carbon support price, and tighter SO2 and NOx emissions standards.  Whilst BEIS discuss these in the consultation document, they do not make clear how important they are in helping to deliver the coal phase-out.


To help deliver the coal phase-out we ask:

  • The Chancellor, in his Autumn Statement, freezes the carbon price support post-2020 to same levels as now.  Last week we sent our report to Philip Hammond on “Why the Carbon Price Support matters”, citing its role in reducing CO2 from coal by 66% in the last year alone, as well as helping to deliver subsidy-free renewables in the future.  It is clear that if the Chancellor ditches the carbon price support, then coal generation will rise back up again, undoing the good work done so far.
  • Defra to commit to tightening SO2 and NOx emissions limits.  Emissions limits in every EU country will be tightened now under “IED” and again in 2022 under “BREF”.  We ask that Defra commits to matching the European minimum limits, to force a clean up or shut down of the UK’s coal power stations.