Representation by Staffan Qvist
- Date submitted
- 24 September 2020
- Submitted by
- Members of the public/businesses
Dear Planning Inspectorate, My representation regards the flawed way in which EDF Energy and the Sizewell C (SZC) project have assessed the climate and emissions impacts of SZC. This representation relates specifically to the document “The Sizewell C Project, Volume 2 Main Development Site, Chapter 26 Climate Change”. The way in which emissions impacts have been calculated in this document (page 30-34), if generally employed, risks calling in to question the climate-related motivations for all future low-carbon energy projects that are planned and proposed in the UK, renewable and nuclear. The method employed to calculate the carbon savings from the project implies that the project reduces emissions per unit of electricity generated according to the difference between the project’s own lifecycle emissions and the integrated assumed grid-average emission level over its entire period of operation. This is an unrealistic and misleading way of calculating emission impacts in at least three major ways: 1. The calculation method assumes that every new project is additional to the capacity that is included in the counterfactual mix. This clearly can’t be true – if every new project is additional – what is providing the reduced emissions that are assumed in the model? Grid emissions are forecast to drop because the modelling assumes new projects will come online to deliver the modelled level of decarbonisation. In addition, the modelled counterfactual mix includes 9 GW of new nuclear after Hinkley Point C (HPC). Given the current situation, this very clearly already includes SZC. Therefore, according to the flawed calculation methodology, Sizewell C is actually displacing Sizewell C. 2. No account has been made for the supply stack in terms of marginal cost of power production. Once built, a low-marginal-cost generator (such as wind, solar PV or nuclear) will drive down the generation of higher-marginal-cost generators. In the UK context, a new wind, solar PV or nuclear plant will selective reduce generation from a high-emissions fossil power source such gas or coal. This happens simply due to the merit order and is the actual way in which a grid decarbonizes. A new nuclear plant will never “displace” generation from a near-zero marginal cost generation source such as wind, solar PV or run-of-river hydro, since their marginal cost of production is lower. Ignoring this basic fact of how the electricity market functions, drastically understates the actual emissions reductions. 3. Even in the hypothetical scenario where all domestic demand in the UK is already met by low-carbon sources, additional generating capacity can and would be used to displace higher-marginal-cost high-emissions fossil generation in the larger grid to which the UK is connected through its interconnectors. It is irrelevant for climate considerations whether the avoided emissions occur within UK borders or not. In the methodology employed, an assumption has been made that the UK grid very rapidly decarbonizes while also filling a higher total annual demand – this requires a very large expansion of low-carbon generation capacity. However, the emissions impact of any project that may contribute to this decarbonization is calculated as though the same decarbonization will happen without any such projects. The result is that there is little incentive to build the low-carbon capacity that will actually deliver the decarbonization. The method of calculating emissions reductions needs to be thoroughly revised to not be misleading and potentially very harmful to decarbonization efforts in the UK. Best wishes, Dr Staffan Qvist Managing Director, Qvist Consulting Limited Expert in low-carbon technologies and decarbonization