Representation by ClientEarth (ClientEarth)
- Date submitted
- 8 November 2021
- Submitted by
- Members of the public/businesses
We understand from the application, including the Environmental Statement, that the Applicant’s proposal is to operate the power plant commercially only when the associated carbon capture, transport and storage infrastructure are also in operation, with the effect that at least 90% of the carbon emissions generated by the power plant will not be emitted into the atmosphere and stored permanently underground. However, we are concerned that the terms of the proposed draft DCO do not appear to include any conditions requiring that the plant be operated in this way and that this minimum level of emissions be captured and permanently stored (notwithstanding para 31 of the draft Requirements Schedule). We would therefore suggest that a condition be inserted in the Requirements Schedule to the DCO, to include clear requirements that: (i) at least 90% of the total carbon emissions generated by the power plant must be captured at all times during the power plant's commercial operation, and (ii) captured emissions must be stored permanently in the proposed offshore geological storage site.