Representation by Stop Burning Trees Coalition (Stop Burning Trees Coalition)
- Date submitted
- 5 September 2022
- Submitted by
- Non-statutory organisations
Dear Sir/Madam, As the Stop Burning Trees Coalition (SBTC), we are highly concerned with a number of issues within Drax’s Bioenergy Carbon Capture and Storage (BECCS) application. Drax’s application is not a sustainable development as defined in the National Planning Policy Framework (NPPF) [Redacted] : it is not compatible with increasing productivity, supporting communities’ health, protecting our natural environment or improving biodiversity. We believe the following issues ought to be examined: Technical Issues BECCS has not been demonstrated at scale; Drax admitted last year that their BECCS assumptions are not based on trials [Redacted] and there are currently no examples of large-scale BECCS working at scale [Redacted] Capturing and compressing CO2 takes a lot of energy: there’s a high risk of the resultant shortfall in electricity production being met from increased fossil fuel burning elsewhere; or by Drax’s own production further lowering efficiency. This is contrary to the NPPF aim to ‘help increase the use and supply of renewable and low carbon energy and heat’ [Redacted] Interdependency between this BECCS application and the North Sea CCS Pipeline This proposal depends on the North Sea pipeline and storage, each of which are required to be consented separately and on their own merits. This consent cannot be assumed. Therefore, we are concerned that this BECCS application cannot be meaningfully examined in isolation. Government Policy The High Court has ruled that the government's current Net Zero Strategy, of which BECCS makes up a large part, is unlawful [Redacted] The BEIS ‘Business model for power bioenergy with carbon capture and storage’ consultation is ongoing while BEIS is currently drafting a new biomass policy. These should inform any planning decisions relating to BECCS and biomass power stations. [Redacted] Even if wood burning is deemed to be carbon neutral in the National Policy Statements, biodiversity loss implied by the continued burning of biomass at Drax is an unacceptable adverse effect [Redacted] Health There is a lack of detail in the Environmental Statement about the public health impacts of the amines which Drax plans to use to separate the CO2 from the other flue gases. These chemicals release by-products, including nitrosamines and nitramines, which are known carcinogens. [Redacted] Local There will 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 [Redacted] Green jobs The Applicant (Doc 5.3, para 2.1.10) places considerable weight on the argument that its BECCS proposal will support employment and economic development locally and in the wider region. SBT sees no plan for workers affected by the dramatic drop in direct, indirect and induced jobs at Drax level, after the relatively brief construction period The proposed Section 106 Agreement (Doc 7.1) provides no assurance of local provision by contractors of high quality construction and engineering roles (see Doc 5.3, para 5.2.6) nor of local training opportunities (para 6.1.3 of Doc 7.1) The Drax-commissioned Vivid Economics projections (Doc 5.3) fail to consider alternative pathways for meaningful comparison. Given that Ember estimates this development will require £31.7 billion in public subsidy, [Redacted], this misses the many other pathways for sustainable development in the area (retrofitting homes, jobs in genuine renewables etc). Flooding On page 21 of the Flood Risk Assessment Document (Appendix 12.1, Document Reference Number: 6.3.12.1 ) it is stated “there are no records of historical flooding in the area of Drax Power Station or within the carbon capture location boundary”. Drax and the surrounding area is a known flood risk area which has previously impacted operations [Redacted] The flood risk assessment needs to be re-evaluated to take into account the latest Climate Change Risk Assessment (2022); Drax’s flood risk assessment fails to consider risks to the rail supply network which passes through flood plains. SBTC is not clear that the loss of flood plain detailed on p.47 of the Flood Risk Assessment, compensated by lowering the ground outside the floodplain by an equivalent amount, fully compensates for this loss, and what the impacts will be on biodiversity Biodiversity Concerns Drax’s planning documents concede that the proposal will lead to the disturbance and degradation of important wildlife habitats. The development could consequently risk harming a wide range of protected species and undermine the Government’s biodiversity goals. Areas likely to be impacted include ten international and 12 national statutory designated sites within 15 km of Drax Power Station and nine non-statutory designated sites of county importance within 2 km of the Proposed Scheme. A number of the surveys for protected species are from 2018. These species are mobile, raising concerns that the development could impact populations of local or county value. The mitigation proposed may not be sufficient for many of the species. Insufficient attention has been paid to the potential for damage to watercourses by sediment and accidental release of chemicals. Climate Concerns We understand that the Planning Inspectorate is bound by government policy on biomass. However, the Proposed Project will not "meet the challenge of climate change" as required by the NPPF because BECCS is based on incorrect assumptions about the carbon neutrality of burning woody biomass. [Redacted] The Proposed Project will harm the health of communities in the southeast US who live close to the wood pellet mills [Redacted] Logging and burning forests for energy reduces the capacity of forests to absorb carbon dioxide from the atmosphere: adding CCS does not solve this problem [Redacted] Yours sincerely, Stop Burning Trees Coalition