Representation by Biofuelwatch (Biofuelwatch)
- Date submitted
- 5 September 2022
- Submitted by
- Non-statutory organisations
I am writing on behalf of the environmental organisation, Biofuelwatch, to respond to the application by Drax to fit carbon capture equipment to two of the power station’s wood-burning units. Biofuelwatch provides information and undertakes advocacy and campaigning in relation to the climate, environmental, human rights and public health impacts of large-scale industrial bioenergy. [Redacted] We believe the following issues are relevant and ought to be examined: 1. The proposed development will lead to a reduction in net electricity generation capacity and production in the UK, contrary to the following established and emerging Government policies, and contrary to the urgent need to maintain and improve UK energy security: a) Overarching National Policy Statement on Energy (EN-1), 2011 b) Draft Overarching National Policy Statement for Energy (EN-1), 2021 Making up the shortfall in electricity yield from the biomass units at Drax following implementation would potentially lead to increased fossil fuel burning elsewhere in the UK. 2. The technology proposed for the development is not efficient, contrary to Government guidance on post-combustion carbon capture (Best Available Technique (BAT) Review for Post Combustion Carbon Capture, V1.0 published July 2021: [Redacted] . 3. The proposed development relies on the continued supply of fuel from abroad, hindering the UK's drive to be more self-sufficient in energy. This is contrary to the government's commitment in October 2021 to decarbonise the UK's electricity system by 'building a secure, home-grown energy sector that reduces reliance on fossil fuels and exposure to volatile global wholesale energy prices." [Redacted] 4. The information provided in the Environmental Statement about the public health impacts of emissions to air of pollutant compounds known to cause cancer is inadequate. In our view, the Environmental Statement for this proposal does not provide sufficient detail for the pollution impacts to be fully and accurately assessed. 5. The proposal will lead to the disturbance and degradation of vital habitats and so risk harming a wide range of protected species. It is therefore not a sustainable development as defined by the National Planning Policy Framework. It fails to protect the natural environment or to enhance biodiversity, and is incompatible with: a) Commitments made in the Environment Act 2021 to support the “conservation and enhancement of biodiversity in England” b) The aims of the Defra Nature Recovery Green Paper (March 2022) “to address the drivers of nature’s decline including habitat deterioration, loss and fragmentation”. The proposed development will adversely impact nationally- and internationally-designated areas that cannot be adequately mitigated or compensated for. The application for consent: a) relies on some outdated species surveys from 2018 and therefore does not properly assess the impact on biodiversity of the proposed development. b) does not pay sufficient attention to the potential for damage to watercourses by sediment and accidental release of chemicals. 6. The design of the proposed development allows the operator to generate power from burning biomass even if the post carbon capture facility is not working. At such times, the development would be adding significantly to UK greenhouse gas emissions, contrary to government policy and jeopardising the UK’s statutory commitment to achieve Net Zero and to fully decarbonise the UK’s electricity system by 2035. 7. While we recognise that the Planning Inspectorate is bound by Government Planning Policy, we believe that the proposed development does not reflect the growing scientific consensus [Redacted] that the burning of woody biomass in power stations is not carbon neutral [Redacted], thus strongly calling into doubt Drax’s claims in its planning documents that it can become ‘carbon negative’ by installing BECCS.