Representation by Mary Clayton
- Date submitted
- 13 August 2022
- Submitted by
- Members of the public/businesses
Dear Sir / Madam, I am writing to object to Drax’s application to add carbon capture technology to two of its wood-burning units. I understand that the Planning Inspectorate cannot go against government policy on classifying biomass as renewable; however this idea is under significant challenge, reasons for which I’m setting out here: 1) The National Planning Policy states that the Planning System should ‘help increase the use and supply of renewable and low carbon energy and heat’. Current policy requires that energy projects need to increase energy generation in classified ‘low carbon’ sectors; but Drax’s BECCS application does the opposite - by reducing energy generation and making it less efficient there’s a high chance that it will cause more fossil gas to be burned Burning wood in power stations adds to carbon dioxide in the atmosphere. It takes 44-104 years for replanted to trees to absorb the carbon emitted by burning them, which is time we do not have. Burning forests reduces their capacity to absorb carbon dioxide from the atmosphere, making it more difficult to keep global temperature rises below 1.5C BECCS has not been demonstrated at scale; Drax itself admitted last year that their BECCS assumptions are not based on trials and there are no examples of large-scale carbon capture for burning wood 2. Drax's Ecology Report shows that habitats will be disturbed or destroyed, including designated sites of international, national and county importance. The ecological surveys indicate species on red lists of being at risk of extinction are going to be impacted by this development. It’s devastating for me to see global acceleration of loss of biodiversity; and when it’s entirely avoidable, as here, it’s all the more so. 3. The development would lead to an increase in road traffic noise to well over the WHO recommendation of less than 53 decibels during the day and less than 45 at night. In fact, road traffic noise levels will increase both in construction (ranging from 66-75 decibels) and operation (66-74 decibels) . There will also be increased traffic including HDVs and abnormal loads during construction which will have a negative impact on local communities and land use in the surrounding area over several years 4. Drax has argued that the Drax BECCS plants could support a total of 4,940 direct jobs (ie manufacture and installation), 2,120 indirect jobs (ie in the supply chain), and 3,240 induced jobs (eg from Drax workers spending locally on food and drink). But in most of the construction phases the number of jobs is much lower - and in the operation and maintenance phase (2029 to 2050) the figures are 375 direct, 960 indirect and 1,800 induced. This looks like a jobs time bomb for the area with a rapid drop rather than long term increase in employment. 5. The High Court has ruled that the government's current Net Zero Strategy, of which BECCS makes up a large part, is unlawful - planning permission should not be given to Drax for something which may turn out to be unlawful The Department of Business, Energy and Industrial Strategy (BEIS) BECCS consultation is ongoing - this clearly should inform planning decisions about BECCS which is not possible at this current point in time. Although Planning Inspectors cannot challenge government policies, BEIS is currently drafting a new biomass policy which is due to be published later this year. The Government's classification of wood burning as 'renewable' and 'low carbon' energy may be subject to change given that increasing numbers of scientists are challenging the designation of biomass burning as 'carbon neutral.’ 6. Capturing and compressing CO2 uses a huge amount of energy, so there’s a high risk of the resultant shortfall in electricity production being met from increased fossil gas being burned elsewhere, leading to yet more CO2 emissions. And the process will also risk human health - Drax intends to use amines to ‘scrub’ the CO2 from other gases, but these chemicals release probable the carcinogens, nitrosamines and nitramines, In short, this proposal is not a sustainable development as defined in the National Planning Policy Framework. It doesn’t increase productivity, it doesn’t support community health, it doesn’t protect our natural environment, and it doesn’t improve biodiversity. Accordingly, I urge you to refuse permission for Drax’s BECCS application. Yours sincerely, Mary Clayton