Representation by Cut Carbon Not Forests (Cut Carbon Not Forests)
- Date submitted
- 1 September 2022
- Submitted by
- Non-statutory organisations
The Cut Carbon Not Forests (CCNF) coalition represents environmental and social justice groups from the U.S., Canada, and the UK concerned about the impacts of the UK’s wood-based bioenergy industry on the climate, on biodiversity, and on communities near the affected forests. Bioenergy is the dominant form of renewable energy across Europe and in the UK. Woody biomass, relying in large-part on material logged from forests, has serious impacts on those forest ecosystems and on the climate, failing to deliver low-carbon energy. Existing bioenergy does not function without large-scale imports of wood - currently in the order of 8 million tonnes per year by Drax. In order to capture as much carbon, Drax power station could need to burn at least as much, or more, woody material as it currently does. The only alternative to large-scale imports of wood is UK-based production of energy crops. Growing the quantity of crops required to achieve the Government's BECCS objectives may require up to 31% of all the UK's current agricultural land. With either path, or a combination of imports and domestic production, the implications for land use are substantial. This is all expected to come at significant cost to the public, with the Government proposing to use a Contracts for Difference mechanism to pay for BECCS. The projected strike price for new BECCS is £179/MWh in 2027 (while new offshore wind is already down at £68/MWh today). Such a cost to the public should at least deliver the purported benefits. But this project will not. It will not deliver negative emissions, it will harm biodiversity, and it will put communities at risk of harm. CCNF is extremely concerned about Drax’s application to add carbon capture technology to two of its wood-burning units (hereinafter referred to as “the Proposed Project”). The principle concerns of CCNF are: --The Proposed Project will not "meet the challenge of climate change" as required by the National Policy Planning Framework (NPPF). --The Proposed Project will have significant adverse effects on local biodiversity that cannot be avoided, adequately mitigated or compensated for. --The Proposed Project will have significant adverse effects on internationally-designated areas that cannot be adequately mitigated or compensated for. --The Proposed Project will have significant adverse effects on nationally-designated areas that cannot be adequately mitigated or compensated for. -- The Proposed Project will undermine the UK's biodiversity goals and further harm the UK's reputation and leadership on nature. --The Proposed Project will have significant adverse impacts on international biodiversity, especially the significant forest harvesting that will be required to provide feedstock for the Proposed Project. --The Proposed Project will harm the UK’s ability to achieve net zero because Bioenergy with Carbon Capture and Storage is based on incorrect assumptions about the carbon neutrality of woody biomass. --The Proposed Project will harm the health of communities in the southeast US that live close to the wood pellet mills. --The Proposed Project application relies on outdated species information, including species surveys from 2018, and thus does not properly assess the Proposed Project's impacts. --The Proposed Project application does not pay sufficient attention to the potential for damage to watercourses by sediment and accidental release of chemicals. --The Biodiversity Net Gain proposals for the Proposed Project do not cover river units. --The application for the Proposed Project fails to recognize that there may be increased NOx deposition which could impact habitats within the surrounding protected sites.