Three context-setters for this extended blog:

1. On April 21st, the first day of Extinction Rebellion’s ‘The Big One’, I just happened to be listening in to an ‘open mic’ session when a young man came to the microphone and launched into a full-on attack on Drax. Not on fossil fuels, or nuclear power, or the utterly useless bunch of Tories that make up today’s Cabinet – but Drax. The litany of Drax’s climate crimes was long and impassioned – and a lot of it was just plain wrong. ‘Causing massive deforestation … burning old-growth forests … one of the worst contributors to climate change …’

I was saddened. I tried to find him afterwards, but he’d vanished into the crowd.

2. On May 15th, what is now known as the “Carbon Removal Market” chalked up one its most significant deals to date as Microsoft confirmed it had agreed to purchase 2.76 million Carbon Removal Credits from the Danish energy company Orsted from 2025 onwards. Orsted has committed to install Carbon Capture facilities at 2 of its biggest combined Heat and Power plants (one of which burns wood chips, the other straw), capturing 430,000 tonnes of CO2 a year, which will then be shipped for permanent storage to Norway’s Northern Lights storage reservoir in the North Sea. “Everyone’s a winner”, it was claimed.

“So why aren’t our proposals for a similar approach here in the UK also a winner?!” That pretty much summed up Drax’s response to the Microsoft/Orsted deal.

3. Lastly, back in March, the UK Government announced the first tranche of successful applicants for its Carbon Capture and Storage funding – amounting to many millions of pounds. With well-advanced plans for a massive Carbon Capture and Storage plant at its biomass-powered station at Selby in Yorkshire, Drax had been hoping to be included in that list. It wasn’t.

Having worked with Drax for the last year, I know that such a rebuff would have been met with a combination of frustration and weary resignation. This is a company that sees itself not just as ‘one of the good guys’, but as a critical pioneer in the world of sustainable energy futures. So it’s baffling for them to be seen by large numbers of campaigners and commentators as the undeserving recipient of huge amounts of public money, invested in ‘false solutions’ which worsen today’s Climate Emergency rather than make a substantial contribution to resolving it.

Psychologically, it’s not easy being an employee of Drax!

The origins of this particular standoff go back more than 15 years. At that time, Drax’s plant at Selby was one of the largest coal-fired power stations in Europe. In discussions with the Labour Government, the possibility of getting out of coal and burning biomass instead gradually took shape, to be confirmed by the incoming Conservative Government in 2012. The principal ‘plus’ was the idea that electricity from biomass would be ‘carbon neutral’, with all the emissions of CO2 subsequently absorbed by new forest growth from that point on. And by and large, most NGOs could see the logic in this, and were cautiously supportive of such an ambitious move.

By 2018, four of its six units were already burning wood pellets imported primarily from Canada and the USA, making Drax the largest generator of renewable electricity in the UK (at around 12% of the total at that time).

But a decade is a long time in energy policy terms! By 2020, those same NGOs were pointing to more and more critical research into the problems of burning such huge volumes of biomass at the Selby plant – around eight million tonnes a year – in terms of updated Life Cycle Assessments, of the whole value chain, and of Drax’s claim to be ‘carbon neutral’. The ‘craziness’ of shipping pellets all the way across the Atlantic was seen to be particularly offensive. The exchanges got more and more heated, with both sides shouting at each other across an ever-widening chasm.

And then, three years ago, Drax started planning to install a Carbon Capture and Storage plant at Selby – to stop those emissions from its bioenergy going into the atmosphere. Details of the £2bn investment (approximately) started to emerge – and the NGOs didn’t like this any more than they did the idea of unabated bioenergy.

It was into that seemingly intractable standoff that Forum for the Future ventured at the start of 2022 – with Drax commissioning the Forum to bring together a High Level Panel to explore what conditions would need to be met for a BECCS (Bioenergy with Carbon Capture and Storage) plant at Selby to be ‘done well’. We were up and running by the middle of the year, with interviews fixed up with a dozen Expert Witnesses, and a huge range of academic and campaigning material identified and fed into the Inquiry process.

We had to put a particular emphasis on that material, as almost all the NGOs and think tanks involved in this area refused to take part in the Inquiry. Some said the whole process would inevitably be biased since we were being paid by Drax (an insult that still rankles somewhat!), and for others, their distrust of Drax was just too deep. But most didn’t even give a reason. It was hard not to assume that they’d come to a collective decision to boycott the whole thing.

I sincerely hope that won’t remain the case. Drax has now published its detailed Response to our Report here. Out of the 30 Conditions we put forward, they’ve accepted 21, with a further 4 “accepted in principle”. They have rejected 1, and have indicated they need more time to respond to the remaining 4, whilst being “minded to accept” them.

For the High-Level Panel, that’s a good outcome. At Appendix 1, you’ll find the press release that accompanied the publication of Drax’s Response, and at Appendix 2, you’ll find the Panel’s overall commentary on that Response.


This was the opening premise in our Inquiry: if managed properly, commercial forests can be a sustainable, genuinely renewable resource to be used indefinitely for the benefit of humankind.

OK, that’s a big ‘IF’! We hear all the time of examples where commercial forests are not being managed properly, with negative consequences for biodiversity, water, soil quality, local communities and so on.

Predictably, we hear a lot less about forests that are being managed responsibly, and are capable of providing lumber for construction, furniture and a host of other purposes on an ongoing basis. Almost all of the forests from which Drax sources its woody biomass in the USA and Canada (exported to the UK as pellets) fall into that category.

Our High Level Panel ended up making all sorts of recommendations regarding forest management (on certification, protection of biodiversity and water, the avoidance of logging old growth and High Conservation Value forests, on community engagement – it’s a long list!). But there was nothing in those recommendations that Drax wasn’t already addressing, and there was certainly no deal-breaker for them on the ‘done well’ front.

However, one of the arguments raised most strikingly against Drax in the USA is that they shouldn’t be using woody biomass at all – that these commercial forests are more valuable as carbon sinks and biodiversity reserves, and should, in effect, be left untouched. It’s called ‘proforestation’ and it’s a voice that seems to be gaining ground in the USA.

For me, this is a bit bonkers. Once policymakers are clear about the distinction between forests that need to be protected for conservation, recreation and climate purposes, and forests that can be managed for commercial purposes (not as clear cut a distinction as it sounds, by the way!), then we have an obligation to put all that sustainable fibre from well-managed commercial forests to good use. In fact, it’s clear to me we’re going to need more and more high-quality timber in the future, primarily in construction to help reduce today’s wholly unsustainable reliance on concrete and steel.

Beyond that, mainstream NGOs in both the UK and the USA, are rightly focused on the forest management and certification story, and on the various supply chain issues – getting all those timber products to market with as low a carbon footprint as possible. This is a particularly complex story for Drax, which depends on turning its different feedstocks (sawmill residues – sawdust, bark etc; tree branches and tops; thinnings and commercially useless roundwood, often diseased or deformed) into pellets – which can then be much more cost-effectively (and safely) shipped to the UK than would be the case with woodchips.

Those feedstocks are the next cause of concern for NGOs arguing that we should ‘stop burning trees – full stop’. This is also a bit bonkers as far as I’m concerned! If the timber is being harvested and milled commercially, why not use all the ‘leftovers’ as efficiently as possible – including the thinnings which need to be extracted as a young forest matures to ensure that the strongest trees grow on to their full potential.

(Declaration of interest here: when I was in my early 20s, I planted tens of thousands of commercial radiata pine on a small tree farm in New Zealand. Thirty years later, those trees were ready to harvest. Along the way, we carried out two thinning operations to ensure the best trees had enough room to grow and access more of the soil’s nutrients. It made total sense to me then – and it still does today.)

For Drax, however, this is always going to be an area of controversy. Back in October 2022, the BBC’s Panorama programme broadcast what it saw as a big ‘gotcha exposé’ on Drax’s feedstock sourcing in British Columbia. Its allegations were roundly rebutted by Drax, but the damage had been done. And the company’s claim at that time that it only used forest ‘wastes’ from timber mills, and not ‘whole trees’, was indeed shown to be false: a thinned tree is still a whole tree, albeit one that has little commercial value unless it can be used for pulp (for making paper or cardboard) or for pellets.

One of our Panel’s strongest recommendations was that Drax should change the narrative and be much more up-front about the importance of these thinnings – both as a source of fibre for its pellet plants and as an important source of income for forest owners and managers.


So, let’s assume (as we did on the High Level Panel) that commercial forests can be managed responsibly and sustainably, simultaneously protecting biodiversity and water quality; that woody biomass can be sourced responsibly and sustainably from these forests (as thinnings, tops and branches) and from sawmills (as bark and sawdust); and that the plants that turn all this woody biomass into pellets can be managed safely and efficiently, ensuring total compliance with local pollution standards on water and air quality.

The High Level Panel bought into all that. And saw no reason why Drax shouldn’t be the go-to exemplar of best practice at every point in that value chain.

Ironically, that’s where things get even harder!

Over the last decade, a huge amount of research has been done regarding the carbon footprint of burning biomass to produce electricity. Many of the assumed benefits (in comparison to burning coal, for instance) have been put under the spotlight, primarily because fossil fuels (both coal and gas) are so much ‘denser’ as the fossilised versions of today’s woody biomass. So you need a lot more woody biomass (with all its embodied CO2) than you do coal or gas to produce the same amount of energy.

That said, woody biomass still has one massive advantage over coal and gas as a source of electricity: unlike those fossil sources, all its CO2 emissions will eventually be sequestered by new forest growth, creating in essence a closed-loop system which can go on and on indefinitely, with only marginal leakage of CO2 into the atmosphere.

Which means that a claim of being ‘carbon neutral’ is technically correct, not least as such a claim is entirely compliant with the metrics mandated under the UN Framework Convention on Climate Change (UNFCCC) and, subsequently, endorsed by the UK Government’s Committee on Climate Change.

But the big problem is this: how long will it take for those emissions to be reabsorbed by new forest growth? How long will that CO2 be up in the atmosphere (having exactly the same ‘warming impact’ as CO2 from fossil fuels) before it’s fully sequestered into the next generation of forest growth?

It is, after all, a Climate Emergency that we face! And as we all know, the Intergovernmental Panel on Climate Change continues to remind world leaders (with growing desperation!) that we have to halve emissions of greenhouse gases within the next seven or eight years. But we’ve yet to see global emissions peak, let alone start to decline. We don’t have decades to play with.

Which means a lot depends on the ‘forest cycle’ – the length of time it takes from planting to clear felling. This is the most important factor in thinking about how quickly the CO2 emissions from burning biomass will be sequestered by new forests. With loblolly pine in the South East USA (and radiata pine in New Zealand), it’s around 30 years; with mixed forests in British Columbia, it can be 80 years or more. This is often referred to as the problem of ‘carbon debt’, and it has real intellectual heft.

That’s what makes it correspondingly uncomfortable for Drax, even though Drax is doing everything at the moment ‘by the book’. It cannot unilaterally deviate from the international standards and metrics that underpin every government’s carbon balance sheet: that can only be done by governments agreeing that it’s time to look again at the standards that they first agreed under the UNFCCC many years ago.

But attitudes and government policies are beginning to change. With the EU leading the pack. Under the new RED III reforms, it’s clear that there will be much less financial support for bioenergy projects, with a final cut-off date for any further support looming in the not too distant future. The UK’s current subsidy regime supporting renewable energy by burning biomass will end in 2027. The judgement of the High Level Panel was that these policy developments indicate a significant shift in the debate about what constitutes an acceptable source of renewable energy (ie worthy of financial support). It seemed highly possible to us that there would soon be no support either in the EU or in the UK for ‘unabated’ (i.e. without CCS) bioenergy plants.

All of which has huge implications for Drax’s business model.


As I said earlier, a decade is a long time in energy policy terms. Just as opinions on bioenergy have shifted dramatically during that time, so too have opinions about what are called Carbon Dioxide Removals (CDRs) from the atmosphere. This is how we set out to capture the dramatic implications of that shift in our Report’s Executive Summary:

‘UN experts tell us we are on track to an average temperature increase of 2.5oC by the end of the century, with a vanishingly small prospect, at this very late stage, of restricting that temperature increase to no more than 1.5oC – still seen by climate scientists as the best chance we have of ensuring a reasonably stable climate for ourselves and for all future generations.

That cumulative, collective political failure all but guarantees what is called ‘overshoot’: with such high concentrations of greenhouse gases already in the atmosphere, the only sustainable way of avoiding a cataclysmic outcome for humankind will be to draw down billions of tonnes of CO2 back out of the atmosphere. Dealing with overshoot means Carbon Dioxide Removals – with billions of tonnes of removals and storage needed every year by 2050. A number of Negative Emissions Technologies – both nature-based and technology-based – will be required to make that possible. And BECCS (Bioenergy with Carbon Capture and Storage) is very much in that mix.’

I know this will sound strange, but it’s hard to express the anger that I felt in having to draft those words for our Report. After the UN Framework Convention on Climate Change was signed up to back in 1992, political leaders had an opportunity systematically to reduce emissions of greenhouse gases over the last 30 years. They didn’t. They did the opposite: 50% of current greenhouse gas concentrations in the atmosphere have been emitted since 1992.

I hate the idea of society having to pay for these Carbon Dioxide Removals in the future, when it’s the fossil fuel companies that have benefitted so handsomely over those three decades – during which they consistently set out to obscure the science which they all knew about at the time. And I particularly hate the idea that it will inevitably be future generations that end up bearing the lion’s share of these costs – perhaps the most egregious of all the examples of ‘intergenerational injustice’ that our generation is currently inflicting on young people today. Equivalent to the financial costs of future generations having to deal with vast amounts of nuclear waste for hundreds of years to come. Equivalent, one might say, to our generation waging a de facto war against all future generations, simply to protect our insanely destructive way of life.

But there really is no alternative to facing up to that reality. Even if today’s world leaders suddenly got serious about a genuine emergency response in the next couple of years (along the lines that they did in response to the Covid-19 pandemic), and even if we got close to reducing greenhouse gas emissions by 50% in the next decade, we will still need to commit to removing billions of tonnes of CO2 from the atmosphere by the end of the century.

The inevitability, scale and cost of these carbon removals have as yet barely impinged on political (let alone public) awareness. The vast majority of people are in for a very rude shock indeed. But in the not too distant future, we’ll all get pretty familiar with weighing up the merits of biological removals (afforestation, restoration of wetlands, peat bogs and so on, plus a whole host of marine options, including mangroves, swamps, kelp, seagrasses) as compared to chemical/engineered removals (Direct Air Capture being the favoured option here – however insanely expensive it is).

It sounds like alien territory. Because it is. We shouldn’t be in this dark place. As the eminent climate scientist Kevin Anderson put it to the Panel in his evidence to us:

‘The allure of BECCS and other negative emission technologies is that they substitute immense political, economic and social challenges of mitigation today for highly speculative removal of CO2 from the atmosphere tomorrow. This proposed transfer of responsibility between generations has been one factor in weakening the pressure on policymakers to face mitigation challenges head on.’

For all that, as we pointed out in our Executive Summary, BECCS is very much part of that overall mix, representing as it does a rather unique hybrid option – part biological, part chemical.


Drax is one of a small number of pioneers in this area. As the company became more and more aware of the writing on the wall (‘there may soon be no social licence and diminishing Government support for continuing to burn biomass to generate electricity’), its thoughts turned to an elegant and potentially highly significant way out of that trap: why not capture the emissions of CO2 from the plant at Selby, and sequester them immediately and permanently in geological deposits in the North Sea, rather than having to wait for them to be sequestered in new forest growth, over different periods of time, given all the problems associated with that kind of carbon debt?

And that’s exactly what’s now happening at Selby. Over the last few years, Drax has been trying out a small number of capture technologies, settling eventually on a full commercial partnership with Mitsubishi Heavy Industries, primarily because of the perceived superiority of the solvents on which its technology depends.

It’s a huge project, with an estimated cost of around £2bn. Hence the need for Government support. Hence its disappointment at not having made that first cut of preferred CCS partners. (By the way, the principle of government support for BECCS to remove and store CO2 is very different from the support it currently gives Drax for its unabated bioenergy – and the Panel concluded that this is just fine given the ‘overshoot challenge’ referred to above).

I find myself in a particularly nuanced position here. I support the idea of BECCS as a hybrid removal technology – part biological (in terms of forests drawing down the CO2 from the atmosphere), and part chemical/engineered, in terms of capturing emissions from the flue gases and sequestering that CO2 in spent oil and gas reservoirs.

At the same time, I’m strongly opposed to the widespread use of CCS when retrofitted to existing fossil fuel plants – or indeed to hydrogen manufacturing plants with a view to producing so-called ‘blue hydrogen’. (It has to be said that other members of the High Level Panel did not share my very strong views on that score!)

But there’s no real inconsistency here. The CO2 that those coal and gas plants are seeking to capture and sequester was already permanently sequestered underground before those oil and gas companies caused it to be released into the atmosphere. There’s a world of difference between ‘fossil CO2’ of that kind, and ‘biogenic CO2’ originating from the burning or degradation of biomass of one kind or another.

‘Keep it in the ground’ should be an absolute rule of thumb here.

Moreover, the likelihood of those captured emissions from fossil fuel plants being permanently sequestered is rather remote. All of the successful CCS facilities to date (of which there are very few – the 30-year operational record of this industry is appalling) have used the captured CO2 for what is known as Enhanced Oil Recovery, pumping it back into oil and gas assets to facilitate increased production! Not exactly what we want at this stage of the Climate Emergency, and a classic example of what is often referred to as Predatory Delay (as explored in my blogs here, here and here).
What this means is that oil and gas companies are seeking every opportunity they can find to prolong the lifespan of their existing assets. Using captured fossil CO2 for “Enhanced Oil Recovery” is nothing more than another production subsidy for companies that already extract hundreds of billions of dollars in illegitimate, Earth-trashing subsidies every year.

I should point out that our Panel was asked to look at conditions for BECCS done well at Selby, with no remit to explore issues regarding proposals for new BECCS in the USA. Despite our differences on CCS, members of the Panel were of one mind when it came to the implications of future BECCS plants. We felt there was certainly a role for some new BECCS plants in the USA, and the general idea of ‘taking the plant to the forest rather than the forest to the plant’ – constructing new BECCS plants in or very close to heavily-forested areas rather than processing and transporting pellets from the forest to BECCS plants elsewhere – makes good sense. Proximity to appropriate storage facilities (in saline aquifers or depleted oil and gas reservoirs, for instance) will also be critical. (Drax itself has recently announced plans for substantial investments in new BECCS plants in the USA, and this is likely to be just the tip of a very deep iceberg).

In this regard, we were persuaded by the evidence which we received from the Energy Transitions Commission – providing us with what we saw as the most realistic assessment of future availability of land for producing the necessary biomass. It’s crucial to factor in several conditions here to avoid this becoming a massive problem in itself: that no standing forest should be converted for energy crops, avoiding all direct and indirect conversion pressures; that food production should remain the key priority for land use, ensuring that increased demand for biomass does not trigger damaging land use changes elsewhere; that protection of biodiversity and the growing need for ‘nature recovery strategies’ of one kind or another should not be set aside in a rush for what would be ‘BECCS done very badly indeed’.


When we delivered our Report to Will Gardiner (Drax’s CEO) in November last year, we were conscious that we’d covered a vast terrain, a terrain historically mired in almost limitless controversy. With our 30 Conditions (determining exactly what it would mean for BECCS to be ‘done well’), we made no claim that we had dealt adequately with the whole of that terrain. But we were confident that we’d covered enough of it to encourage Drax to move forward substantively on a number of these controversies – and, in the process, to reinforce the importance of building bridges between Drax and the many NGOs and think tanks that continue to oppose much of what it stands for.

Whether that will happen or not is a moot point! As I mentioned at the start of this blog, there was a marked reluctance on the part of the majority of NGOs involved in the bioenergy and wider BECCS debates to have anything to do with our Inquiry. Even informal attempts on my part (as someone personally familiar with many of the key people in these NGOs) to encourage participation were rebuffed. We heard nothing more from them during the course of our Inquiry (apart from an extremely helpful interview with Michael Norton, the Environment Programme Director at the European Academies Science Advisory Council), and absolutely not a word on publication of our Report – even though all of them were asked for some kind of critique of what we’d pulled together – and of our 30 Conditions in particular.

I have to admit by being baffled by this. As I experienced before in my ten years working with the palm oil industry (an even more hotly contested area than woody biomass!), little is gained by simply refusing to engage. I hate to put it like this, but for me, that’s just not ‘grown up’.

So I still hope, now that Drax’s detailed response to the Panel’s 30 Conditions has been released, that it will be possible to move things forward more positively.

Debates about various carbon removal options and the whole area of Negative Emissions Technologies are going to be absolutely critical in ensuring that we have the best possible policymaking processes in place. The truth of it is that there are already some truly shocking CDR options out there; fossil fuel companies are already manipulating the debate to protect their own totally self-interested positions; and governments are just blindly going along with their well-established hydrocarbon prejudices.

But we won’t get to see off these threats to good policymaking if we don’t engage. Carbon removals, at a huge scale, are going to happen, like it or not. So it’s incumbent on all of us to ensure that the technologies that make those removals possible represent best value for taxpayers, delivering the best prospect for maintaining some kind of ‘safe operating space for humankind’ by restoring a sufficiently stable climate.



Drax responds to Jonathon Porritt’s ‘BECCS Done Well’ report

The report, ‘BECCS Done Well: conditions for success for bioenergy with carbon capture and storage’, presents thirty conditions for bioenergy with carbon capture and storage (BECCS) which, if met, will enable BECCS to be ‘done well’, delivering positive outcomes for climate, nature, and people.

Drax Group Chief Sustainability Officer, Alan Knight, said, “If the world is to meet the global climate challenge, carbon removal technologies like BECCS need to be up and running at scale, as quickly as possible. However, what is arguably more important than the quantity of BECCS required is the quality of the BECCS delivered. To realise the transformational benefits BECCS could bring, we need to ensure it is implemented well – adhering to strict criteria and carefully monitored.”

“In our response to the ‘BECCS Done Well’ report, we have addressed the criteria presented by Jonathon Porritt and the High Level Panel on how to implement BECCS in a way that delivers positive outcomes for climate, nature and people.”

The ‘BECCS Done Well’ report was prepared at the request of Drax Group CEO, Will Gardiner, who invited Jonathon Porritt, environmental campaigner, to convene a High-Level Panel to conduct an independent inquiry into BECCS. The panel, chaired by Jonathon Porritt, convened Brad Gentry of the Yale School of Environment, Stuart Haszeldine of the University of Edinburgh and Clare O’Neill acting as an independent consultant, with Forum for the Future serving as secretariat.

Jonathon Porritt, Co-Founder of Forum for the Future said, “As members of the High-Level Panel, we’re impressed at the level of detail in the responses from Drax to the 30 Conditions we put forward in our Report in November last year. And we’re pleased that the vast majority of these responses are positive.”

“As is now beginning to be recognised, the whole area of ‘Bioenergy with Carbon Capture and Storage’ is becoming more and more material in the debate about Carbon Dioxide Removals and Negative Emissions Technologies. We believe Drax has positioned itself in the vanguard of this debate, ensuring both policy-makers and potential competitors understand fully what ‘done well’ really means.”

BECCS exists in a complex ecosystem of land use, biodiversity, social factors, economics, carbon reduction and now, carbon removal. Each of these factors must be considered, and trade-offs carefully managed if BECCS is to play a meaningful role in achieving our climate change targets.

Drax aims to become a leader in global BECCS with the aim of removing 14 million tonnes of CO2 a year by 2030 . The technology has a critical role to play in helping nations reach their decarbonisation goals, while also supplying jobs and boosting economies – but this potential is not yet being met.

Drax Group CEO, Will Gardiner, said, “This work by Jonathon Porritt and an independent panel of experts shows that BECCS can be done well and is a prime example of the progress we can make when we engage in constructive conversations on potentially vital climate solutions.”

“Our commitment to this work underscores our ambition to be a world-leading, sustainability-driven company, at the forefront of the fight against climate change and it will inform our strict sustainability, socioeconomic and environmental standards for future global BECCS projects.”

Drax is currently accelerating progress on the development of global BECCS projects. We are in formal discussions with the UK Government to secure the right support from them to deliver BECCS at Drax Power Station, and have selected two sites in the US, with nine more under evaluation.

Our full response to “BECCS done well: conditions for success for bioenergy with carbon capture and storage is available here.





As the four members of the High Level Panel which produced the ‘BECCS Done Well’ Report, in November 2022, we feel it’s appropriate to round out this year-long process with some concluding comments, having now received the Response from Drax to our Report:


We are all very impressed by the in-depth consideration that the Drax team has devoted to fashioning this Response. The level of detail is comprehensive, and its readiness to engage with each of the proposed 30 Conditions in our Report should be reassuring for all those stakeholders involved in this critical area of debate and policy-making. In addition, we feel that the decision to prepare and publish a detailed ‘Evidence Book’ (regarding Drax’s plans to scale up its BECCS activities) is extremely welcome.


Although this may not command much external interest, we have particularly taken note of the various changes Drax has made to the ‘sustainability governance architecture’ within the company. We believe the high standards for transparency and accountability to which Drax is committed will benefit significantly from these internal processes.


We are pleased to see that Drax has been able to respond positively to almost all the recommendations embodied in the 30 Conditions, in a way which will entail significant shifts within Drax in both policy and practice. Some of these changes were already under way when we published our Report in November last year, but many commitments are both new and material. We see this as a strong indication that critical sustainability considerations are now having a major influence on Drax’s strategy and business model.


The High Level Panel completed its work with the publication of its Report in November last year. It was not part of our brief to track the detailed responses from Drax to the 30 Conditions in our Report, and we will not therefore be doing any kind of ‘Condition-by-Condition’ analysis or response of our own. We believe there are others better placed to follow up in that way, including those in Forum for the Future who provided the Secretariat for the entire Inquiry process in 2022.


The one area where we feel Drax’s response could have been more robust relates not so much to the specific wording of Drax’s responses to the Conditions, but to an occasional reluctance to engage more fully with the broader narrative in our Report – from which all these Conditions emerged. We feel it would be helpful for Drax to expand its current engagement on difficult issues like carbon accounting and carbon debt – if for no other reason than to indicate its willingness to engage with stakeholders on these less black-and-white issues.


A large part of the motivation for members of the Panel in taking on this challenge was the hope that it would help ‘build bridges’ between Drax colleagues on the one hand, and the many NGOs and think tanks that have been critical of Drax over the last few years on the other. Several of the recommendations embodied in the 30 Conditions will require proactive engagement on Drax’s part with those critical stakeholders, with a view to establishing more common ground even when agreement remains elusive.


Brad Gentry
Stuart Haszeldine
Claire O’Neill
Jonathon Porritt (Chair)