Representation by Deborah Clare Cobbett
- Date submitted
- 4 September 2022
- Submitted by
- Members of the public/businesses
Many aspects of the proposal concern me, not least the highly questionable claim that burning trees is a sustainable way to produce energy when this is causing deforestation around the world, increasing greenhouse gas emissions through the whole logging and transportation process as well as at Drax itself. Claiming that trees are renewable ignores the length of time trees take to grow, as well as the loss of carbon sinks in the meantime. The proposed carbon capture process will require yet more trees to be burnt, producing more greenhouse gas emissions, which appears inefficient to say the least. Construction and implementation of the current proposal also involves health impacts on local residents, both humans and other species. These impacts arise from factors such as pollutants, noise and vibration, suggesting failure to meet objectives set out in 2021 in the National Planning Policy Framework, chapter 8 ‘Promoting Healthy and Safe Communities’ because the proposals will damage the local environment, with impacts on mental and physical health. The Drax BECCS Examination Library helpfully lists 231 documents, with reference numbers I will quote in what follows, summarising some of my objections on health and biodiversity grounds, including the impacts of pollutants, noise and damage to habitats. Environmental Statement - Volume 1 - Chapter 8: Ecology [APP-044] refers to impacts on local biodiversity and humans and to pollutants affecting air and water quality around Drax. It includes the following oddly contradictory statement ‘8.9.115. Given the nature and scale of the modelled air quality impacts and potential hydrological impacts, these are predicted to lead to impacts that are of minor magnitude, long-term, reversible, and are considered to be significant at up to a National geographical scale.’ The last part of that sentence is in bold in the original, yet suggests that impacts which are of ‘minor magnitude’ are ‘significant’: either the author has failed to proof-read or we should remember that small incremental improvements can lead to significant outcomes, such as in the performance of Olympic cyclists! If the writing has been sloppy, how many other errors are there? If not, then it seems wrong to dismiss the risks for air quality and hydrological impacts mentioned here. On water impacts, these are summarised (also in APP-044) as ‘the risk of accidental pollution from the leakage of amine, chemicals and oil, entering the Carr Dyke and River Ouse’ [para 8.9.102], which ‘could lead to a deterioration in water quality of these watercourses’. These drainage pathways ‘could provide an impact pathway affecting the local otter population, for example via the transport of water-borne pollution following a pollution incident or increased silt run-off’ [para 8.9.63] and if otters might be affected, why not other species? This should surely be considered in conjunction with all the other ‘incremental’ factors undermining water quality across our region. Taken together these pollutants, together with vibrations and noise, imply impacts on both people and the habitats of many species. Document APP-055 [6.1.19 Environmental Statement - Volume 1 - Chapter 19: Summary of Significant Effects] lists a large number of major adverse effects of the proposal including flood risks: ‘Increased flood risk associated with an increase in the rate and volume of surface water runoff from an increase in impermeable areas at Drax Power Station Site, impacting the Site and local people and properties.’ Concerns for working conditions at Drax are dismissed in a statement from document APP-053, 6.1.17 Environmental Statement - Volume 1 - Chapter 17: Major Accidents and Disasters. ‘Drax Power Station employees and their contractors are out of scope of the assessment as their health and safety (H&S) is managed through other regulatory regimes’ although such risks are of great concern when it appears that ambient temperatures for some workers can reach 50 degrees C. This seems to suggest inefficient heat loss as well as dangerous health risks. Environmental Statement - Volume 1 - Chapter 15: Greenhouse Gases [APP-051] recognises the supply chain emissions involved in fuelling Drax (listed as ‘a. Processing at origin; b. Feedstock transport; c. Drying; d. Pelleting; e. Transport to Port; f. Shipping; g. Rail to Drax; and h. Combustion of CH4 and N2O’ in para 15.5.27) and in constructing and operating Carbon Capture (para 15.1.9). However, it excludes emissions relating to ‘transport and final storage of captured carbon beyond the Carbon Dioxide Delivery Terminal Compound’ (para 15.4.3) and rules out any suggestion that carbon emissions from biomass combustion itself should be included. Nor does it consider practices involved in sourcing timber, managing forests and pellet production, or other such aspects of the supply chain. This suggests total disregard for social responsibility. Overall, the tone of many of the documents is dismissive of adverse impacts, as might be expected. For example, the Environmental Statement - Volume 1 - Chapter 8: Ecology [AP044] suggests that noise impacts are only considered significant if they occur for more than 10 days or nights in any consecutive 15, yet elsewhere [para 8.9.38] states that 1,000 construction workers will be involved and heavy machinery, such as excavators and piling rigs, will be in use. Common sense suggests that this will create more than ‘visual disturbance’ mentioned in that paragraph. My own experience of living near a small building site for a whole year was that noise, vibrations and dust made staying at home during working hours quite intolerable. Some of these impacts were ongoing and constant, while others were unpredictable and intermittent, making them an unbearable combination. For housebound neighbours of such sites, not to mention wildlife, the disturbance seems difficult to quantify, and certainly not insignificant. There seems to be much wishful thinking behind these impact assessments, and little discussion of the untried technology of BECCS. Comparisons with coal and other fossil fuels seem less relevant than assessing Drax against genuinely renewable energy sources, solar, wind and tidal. For all these reasons, I oppose the application and urge you to reject it.