Representation by Yorkshire and Humber Climate Justice Coalition (Yorkshire and Humber Climate Justice Coalition)
- Date submitted
- 5 September 2022
- Submitted by
- Non-statutory organisations
We are a coalition of groups in Yorkshire and the Humber concerned about the need to help workers transition to jobs that reduce GG emissions, and protect the health of people and environment in the UK and globally. We will object on several grounds Sustainability 28% of the energy generated by each BECCS unit will be needed to capture and compress CO2, reducing overall efficiency and likely causing more fossil gas to be burned in other power stations - this contradicts the Overarching NPS for Energy’s commitment to reduce the proportion of energy derived from fossil fuels. [Redacted] Burning wood emits more CO2 at the stack than coal per unit of energy generated. Even with CCS, research indicates that when the full lifecycle emissions are taken into account, power BECCS will add to rather than reduce atmospheric CO2 for some decades [Redacted] Hundreds of scientists and environmental NGOs have called for the true emissions from harvesting biomass and from the resulting foregone carbon sequestration to be taken into account and this false solution be dropped. [Redacted]. Biomass risks becoming another stranded asset. Whilst we recognise that the biomass has already been consented, and that current government policy is to increase bioenergy, the strong scientific case against biomass undermines the future viability of the technology. Health The chemicals used in the CC process form potentially carcinogenic atmospheric nitrosamines and nitramines [Redacted]. No safe levels for these compounds have yet been established. People living close to pellet processing plants in the USA - mainly people of colour in neighbourhoods with high poverty rates - are experiencing severe pulmonary and cardiovascular health impacts due to high PM 2.5 particle exposure. The EPA is currently reassessing the permitted levels of PM2.5 pollution. Biodiversity Drax’s Ecology Report [Redacted] states that this development could have significant adverse impacts on several rare and protected species in a number of internationally, nationally and locally important habitats. We will dispute the adequacy of their mitigation plans. On a global scale, evidenced deforestation of ancient woodland even if replaced with plantations of trees results in irreversible loss of vital diverse ecosystems. Jobs and subsidies Scrutiny of the Needs and Benefits Statement [Redacted] and of the proposed Section 106 agreement (Application Doc 7.1) suggests that jobs supported would be mostly of short duration, and unlikely to offer significant skilled and well-paid work to local residents. The fall in total jobs once the construction is complete (from ~ 10,000 to ~3,000) is a major economic concern for the area. In contrast, permanent jobs could be created if the huge subsidies sought by Drax were diverted to retrain the workforce in urgently needed skills such as homes retrofitting, solar installation, R&D in battery storage, the transition of the domestic heating systems, and the vast amount of skilled labour required for land restoration, flood defence and adaptation, and sustainable food growing. Pipeline and CCS This project will rely upon the construction of a pipeline to carry CO2 under pressure to storage under the North Sea [Redacted]. NPS EN-1 states “..... development consent applications for power CCS projects should include details of how the captured CO2 is intended to be transported and stored [and] how cumulative impacts will be assessed…” [Redacted]. The applicant is unable to provide these details. The possibility of risk to human life and health is underlined by reports of a rupture in a CO2 gas pipeline in the USA [Redacted] An IEEFA study reviewed the capacity and performance of 13 flagship carbon capture projects, accounting for about 55% of the world’s current operational capacity, and found that power CCS had without exception failed or performed significantly below its nameplate efficiency. There is no reason to suppose that BECCS at Drax would perform any better.