Representation by Carolyn Whitehead
- Date submitted
- 5 September 2022
- Submitted by
- Members of the public/businesses
I would like to object to the planning application for the Drax Bioenergy with Carbon Capture and Storage Project (BE with CC&S), on four grounds: the potential harm to the health and well-being of local people, the negative effect on the natural environment, the unsustainability of the proposed development and the probable infeasibility of the proposed facility. 1) The potential harm to the health and well-being of people living near the facility Construction phase: Drax’s submission document reference 6.1.6, chapter 6, warns about the negative effects of the construction phase, which in a project of this size will inevitably cause dust, noise and increased traffic, this traffic adding to roadside air pollution and increasing the likelihood of traffic accidents. (The same document mentions that a cluster of accidents have already occurred at a number of the junctions within the study area; increased traffic is likely to increase the frequency of such accidents.) All of these effects will have negative impacts on local people’s health and will increase their levels of stress. Mitigation efforts will not be able to wholly eliminate these problems and given that the construction phase will probably run until 2029, the Planning Inspectorate ought to be overwhelmingly confident that the project will be successful and in the public interest before imposing the misery of several consecutive years of construction work on local people. The experimental nature of the technology (CC&S technology applied to flue gases from wood burning has so far been tested only in experimental, small scale trials; there is no full-scale CC&S facility operating on any wood burning power station anywhere in the world) does not inspire such confidence in the project’s likely success or its benefit to the public. Operational phase: There are two likely detrimental effects on people’s health of the CC&S plant, once it becomes operational. The first is noise. The documents submitted to the Planning Inspectorate by Drax (5.1.9 Preliminary Environmental Information Report – Vol 3 – Non-Technical Summary) identify one daytime and two night-time sites of potentially high adverse noise impact locally, plus a further three sites that will be subject to moderately high adverse noise impacts. Noise is known to increase stress and cause sleep problems, both of which can have serious effects on health. Even more worryingly, the proposed technology for extracting CO2 from the flue gases involves the use of amines (nitrogen-based chemicals) which upon release can form compounds such as nitrosamines and nitramines that are suspected to be carcinogenic (cancer-inducing). Drax (in document 6.1.6 chapter 6) states that it will need to apply for a variation to the site’s existing environmental permit as a result of the use of amines and ammonia, and in their submissions regarding the environment, they accept that depositions of nitrogen-based chemicals will occur in the local area (section 6.2.9.9 of Drax’s submissions). Given the relatively poor air quality in some areas of Yorkshire and Humberside, and given the unpredictable effects of ‘cocktails’ of pollutants on the body, the risk of increased illness and even mortality as a result of the CC&S plant’s operation (and the consequent effects of such increased illness on an already over-stretched National Health Service) are very concerning. Since there is no working CC&S facility of this type to provide data, the estimates of the noise, pollution and other impacts on human health of the plant when operational are likely to involve a wider margin of uncertainty than for tried and tested, well-documented technologies, so the actual health effects of the plant when operational may be worse or better than predicted. It seems unwise where human health is concerned to assume the latter. Therefore, on the grounds of the possible threats to the health of local people, I believe permission for the CC&S facility should not be granted. 2. The potential harm to nature, both during construction and during the plant’s subsequent operation This area of the country is of considerable nature value. There are six non-statutory Designated Sites of County Importance within 2 km of the proposed scheme, plus a further six Designated Sites of National Importance within 5 km and 10 Designated Sites of International Importance within 15 km. Badgers, bats, otters, water vole, breeding and wintering birds, amphibians, reptiles, terrestrial invertebrates and rare plants have been identified within the Site during previous surveys, and surveys conducted for this planning application have confirmed the presence of otters at and adjacent to the Site and the presence of water voles within the Pipeline Area. In addition, the submissions relating to the environmental impact of the proposed project make it clear that bat roosting places might be affected, and an environmental report relating to badgers has been withheld from the public on grounds of confidentiality: 6.3.8.5 Environmental Statement Volume 3 Appendix 8.5: Badger Summary Report (Confidential). According to Drax’s submissions to the Planning Inspectorate, “Potentially significant residual effects are anticipated on commuting and foraging bats, breeding and wintering birds and terrestrial invertebrates as a result of short-term habitat loss during the construction phase. These effects are likely to extend into the early operational phase while reinstated and replacement habitat matures.” Clearly, the years-long construction phase is likely to have a negative impact on local wildlife, and ecological systems, once disturbed, cannot always regain their original richness or stability. In addition, once the facility is operational, there will be further negative effects on local nature as a result of the deposition of nitrogen compounds. Section 6.2.9.9 of Drax’s submissions states that the effects of nitrogen deposition on some designated ecological sites are considered to be “potentially significant”. Considering these negative effects on the local natural environment, which is recognized as including areas of county, national and international importance, I believe that the application should be rejected on the grounds that it contravenes both local and national development and environmental plans such as ENV9 (Selby District Local Plan) and the 25 Year Environment Plan, in which the Government committed to leaving nature in a better state than they found it. Moreover, the negative effects of the proposed plant on the natural world are not limited to the UK: approving this planning application would give Drax the ‘green light’ to continue for the foreseeable future burning millions of tonnes of wood pellets per year; these pellets are produced by the clearcutting of mature and biodiverse forests elsewhere in the world (currently mainly Canada, the Baltic states and the Southeastern USA where Drax owns and operates three pellet mills). This clearcutting is damaging the world’s climate, reducing biodiversity and perpetuating climate injustice by polluting the land, air and water of local communities. Thus, considering the negative impact of the CC&S facility on nature both during construction and from the operation of the plant, some of these effects being manifest locally in the UK and others, internationally, I consider the application should be refused on environmental grounds. 3) The unsustainability of the proposed development 3a) The unsustainability of the proposed CC&S plant itself It is unclear whether or not the proposed CC&S plant can operate in a sustainable way. Energy will be needed to run the CC&S plant, to pressurise and transport the gas along the pipeline and then inject it into the North Sea underwater storage. This is termed the ‘energy penalty’ of the facility: - the amount of energy that the proposed new plant will use, which will reduce the amount of energy Drax power station contributes to the national grid. In a written reply to questions in 2021, Drax stated that it did not have a figure for the energy that will be required to operate the plant [Redacted]. (Since this is a crucial factor in both the cost-effectiveness and the overall success or failure of the CC&S project, it seems odd that Drax do not already have an estimate of this to underpin their planning for this facility.) Other sources estimate the likely energy consumption of the CC&S plant at around 28% of the power output of Drax’s nos. 1 and 2 biomass boilers. This means that an estimated 28% of the current generating capacity of Drax 1 & 2 will need to be generated in addition to the current amount of power being generated, in order to run the new plant that will remove the CO2 from the flue gases. Since the demand for electricity to replace gas to heat homes and commercial premises and to replace petrol, diesel and kerosene for transportation is increasing dramatically, it is likely that for the short and medium-term future there will be a shortage of electricity from renewable sources; it is therefore quite possible that the additional 28% of Drax’s current generating capacity needed to run the CC&S facility will be generated by power stations burning fossil fuels, thus adding to the UK’s overall greenhouse gas emissions rather than reducing them. This would clearly contravene the UK’s commitment in the Overarching National Policy Statement for Energy (EN-1) to reduce the amount of energy production in the UK from fossil fuels; it would contribute further to global warming and would thwart our attempts to reach net zero by 2050. To potentially increase the amount of fossil fuel burned in the UK in order to run the CC&S plant is not a sustainable strategy. Furthermore, the greenhouse gas emissions involved in the construction of the CC&S plant and in the construction and running of the pipeline and CO2 storage facility do not seem to be taken into account in the assessment of how much this project will contribute to our greenhouse gas emissions. 3b) The unsustainability of the means of power generation on which the proposed CC&S plant depends The development of a CC&S facility at Drax is not a genuinely sustainable strategy for a further reason: because the underlying means of power generation is not sustainable. Although wood-fired power generation is currently classed by the UK Government as renewable energy – we can grow more trees – it is certainly not a carbon-free source of energy at the time the wood is burned and it takes upwards of 40 years for a newly planted forest to sequester the same amount of carbon as was sequestered in mature forests felled for wood pellets. Research published by UK think tank Chatham House confirms that there is no certainty that the carbon emitted by burning wood will be re-sequestered by new forest growth in the coming years or even decades; the regrowth of trees takes time, and younger trees that are regularly harvested in plantations may never store as much carbon as older, bigger trees in natural forests. [Redacted] Thus, by the UK’s ‘net zero’ target date of 2050, the carbon debt incurred by burning wood pellets now may well not have been paid off by reforestation, and that is ignoring all the wood that may be burned in the intervening years between now and 2050. The emitted carbon will, meanwhile, be contributing every year to global warming. Certainly, therefore, the idea that any carbon captured and stored by the proposed plant can be counted as ‘negative emissions’ because burning wood is carbon-neutral is untrue; CC&S would simply be partially compensating for the carbon sequestered by the original forest that has now been released by burning the wood in the power plant. Indeed, the classification of wood burning as a sustainable source of energy generation is increasingly being called into question, both in the UK and globally. In autumn last year, S&P Global Dow Jones removed Drax from the S&P Global Clean Energy Index. Also last year, more than 500 scientists wrote to President Biden and other world leaders, urging them to end subsidies for biomass burning because of the harm it does to the climate. The UK’s Department for Business, Energy and Industrial Strategy is developing a new policy on biomass, due to be published in late 2022. This may mean there will be a change in the Government’s view of biomass as low carbon. In the light of that possibility, it seems unwise to give permission for the BE and CC&S project at Drax to go ahead since wood may, in the future, be reclassified as a high-carbon source of electrical power. Moreover, in the carbon accounting system currently in use, greenhouse gas emissions from the felling, transportation and processing of the trees are counted in the carbon budget of the country where the trees grew, not in the country where the wood is burnt [Redacted]. Again, it is quite possible this way of accounting for carbon emissions may be changed in the future, thus weakening or even removing the justification for the wood-fired power generation on which the proposed project would depend. A further aspect of the unsustainability of the project is that the volume of wood pellets consumed by Drax power plants 1 and 2 each year exceeds the total supply of all wood from UK sources, so the continued operation of Drax cements the UK’s dependency on foreign supply chains for its energy. The transportation of wood pellets overland and by sea involves greenhouse gas emissions which are currently being ignored in the carbon budgets, and recent events have shown the danger of countries not being self-sufficient in energy. To summarise: the proposed development may prove to be unsustainable for a variety of possible reasons: • the unknown size of the ‘energy penalty’ required to run the new CC&S plant; • the possibility that this ‘energy penalty’ will be compensated for in the national grid by energy from fossil fuel power stations, thus increasing the UK’s CO2 emissions; • the unaccounted-for energy required to build the CC&S plant and to build and run the pipeline and storage facility upon which Drax’s proposed scheme depends; • the oddities in carbon accounting, for example, the failure to take account of when emissions occur: adding a quantity of CO2 to the atmosphere now then gradually removing this same quantity through tree growth over the next several decades is not ‘carbon neutral’; rather, it will serious add to global warming. The timing as well as the quantity of emissions matters; • the possible official reclassification of biofuels in terms of their impact on the environment; • the neglect of the environment cost (including but not limited to carbon emissions) of felling and clearing the forests, processing the wood into pellets, and land and sea transportation of logs and wood pellets; • the sustainability of the project may be compromised if the UK has to fall back on fossil fuel power generation because of interruption or threatened interruption to the supply of wood pellets from abroad. In view of its unsustainability, I consider the project should not go ahead. 4) The probable infeasibility of the proposed development Permission for a Nationally Significant Infrastructure Project should surely require that the proposed project has a high probability of success. The evidence available to the public does not suggest this project will be successful. Drax’s proposed application of CC&S technology is experimental and untried. There is no large-scale CC&S plant operating on the flue gases from a wood-burning power station anywhere in the world. (The only two large-scale, operational BE with CC&S plants are a coal-fired power station in Canada and a plant manufacturing ethanol in the USA.) This is despite CC&S technologies having been in development for over 45 years [Redacted]. Drax has run short, small-scale CC&S pilots and has succeeded in extracting one tonne of CO2 per day from its flue gases [Redacted]. Thus, massive scaling up (very approximately 40,000 times, if my calculations are correct) would be required to extract most of the 13-16 million tonnes of CO2 the wood-burning generators at Drax emit each year and in terms of the engineering and technology involved, there is no guarantee that such scaling up would be successful: scaling up industrial processes of this nature is certainly not straightforward. Furthermore, Drax has recently stated that the full-scale CC&S plant will not use the same technology (C-capture) used in Drax’s pilot project [Redacted], raising further questions about the likely success of the proposed, full-scale NSIP project. It seems unwise to plan an NSIP on the basis of such unproven technology. Not only does the plan to use unproven technology call into question the viability of the entire project, but regarding the planning application specifically, it means that most of the assumptions made in Drax’s submission are based on very little, if any, real-world data about how a full-scale BE with CC&S plant actually operates. In particular, assumptions about the percentage of CO2 that can be captured and the ‘energy penalty’ required to do so might be significantly inaccurate and render the entire project infeasible, either in energy or economic terms. Furthermore, there is as yet no pipeline and no storage facility for transporting and safely storing any CO2 extracted by the plant. Such a facility is proposed by National Grid Ventures but only outline details are available (a preferred route was announced in April this year) and as far as I understand, work has not yet started on construction. I cannot find any information about the likely cost to Drax of using this proposed pipeline and storage facility, should it be developed. Again, the costs might render the entire Drax BE with CC&S project economically unviable. The reason I raise these points about the probable infeasibility of the project is that permission for the project would give implicit approval for Drax to continue burning wood pellets (for which it gets subsidies from the Government as a renewable and purportedly low carbon energy source). The granting of permission, therefore, not only risks the development of an NSIP that may turn out to be a white elephant, but it will result in the continued operation of a power station that is damaging our ability to fulfil our net zero commitment, that is a drain on the country’s economic resources, and that is making global warming worse. In addition, the granting of permission for the project would mean that BE with CC&S would continue to be included in climate modelling. This would disincentivise acting now to increase truly sustainable energy supplies and to reduce greenhouse gas emissions, because the models would assume that at some stage in the future, CC&S would work and we would then somehow be able to remove all the extra greenhouse gases emitted up to that date. This would legitimize ‘business as usual’ for biomass burning, with its consequent negative effects on forests, biodiversity, human health, communities and, crucially, the climate. It seems premature and unwise, therefore, to grant planning permission for a Nationally Significant Infrastructure Project which does not yet have any ‘proven at scale’ technology to implement, which does not yet have much reliable data on which to base its proposals, and which does not yet have anywhere to store its product when storing its product is the whole point of the project. I understand that it is one of the obligations of the planning system to help increase the use and supply of renewable and low-carbon energy. In approving this application, the Planning Inspectorate would instead be encouraging the continued supply of high-carbon energy in the hope that CC&S technology that has been under development since the late 1980s will suddenly bear fruit. In addition, there are the concerns I have outlined above regarding human health, the natural environment, the sustainability of the project and its feasibility, which I believe should prevent an NSIP of this nature from going ahead. I am very grateful for your time in considering these points and would respectfully urge you to refuse Drax’s BECCS application.