Representation by Wakefield Trades Council (Wakefield Trades Council )
- Date submitted
- 5 September 2022
- Submitted by
- Non-statutory organisations
I am writing on behalf of Wakefield Trades Council to comment on the planning application from Drax Power to retrofit CCS units to two furnaces. Because we have climate change policy, and because we have a legitimate interest in regional employment both now and in the future, we assume the right to comment on each of the areas below which we believe are relevant and ought to be examined. Green Jobs, apprenticeships and the local economy We believe the forecast of jobs supported by the BECCS project, based on the analysis by Vivid Economics appended to Needs and Benefits Doc 5.3, is inflated, insufficiently supported by evidence. It was commissioned by Drax and cannot be considered as an independent study. 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. • We will challenge in detail the forecast of jobs supported by BECCS at Drax and more widely across the economy (Vivid Economics report, appended to Document 5.3) • We see no just transition plan for workers affected by the dramatic drop in direct, indirect and induced jobs at Drax level, once the relatively brief construction period is over • The proposed Section 106 Agreement (Doc 7.1) provides no assurance of local provision by contractors of high quality construction and engineering roles; any local jobs are likely to be lower-skilled, and lower-paid (see Doc 5.3, para 5.2.6) • As regards training opportunities - para 6.1.3 of Doc 7.1 states only that “Dependent on the contractor appointed” such opportunities “may” be available to local people. • Vivid Economics projections (Doc 5.3) fail to consider alternative pathways for meaningful comparison. We will offer evidence to quantify the far greater green jobs opportunities lost through subsidising BECCS at Drax at the expense of other sectors vital to decarbonisation (eg renewable energy, homes retrofit). The role of Drax Power and BECCS technology in combating Climate Change. In paragraph 4.1.1 of the Needs and Benefits document (5.3), Drax Power references EN-1(2011) as justification, but we argue that the proposal is not fully aligned with this document or the National Planning Policy Framework (sustainable development criteria) because the development is not compatible with increasing productivity, supporting communities’ health, protecting our natural environment or improving biodiversity. We wish to challenge on grounds that: • The weight of evidence against industrial biomass burning being classified as carbon neutral is mounting, including its contribution to averting climate change [Redacted]; • The evidence questioning CCS as a mature, scaleable technology is accumulating [Redacted] ; • The Government’s Net Zero Strategy has been found to be in breach of the Climate Change Act; • The energy loss to operate the CCS plant will produce less energy not more. The interdependency between this application and the North Sea Pipeline and underground storage reservoir. Further projections in the Vivid Economics report refer to the anticipated development of the wider Humber and Teesside industrial clusters and subsequently the UK as a whole. Not only is this vision purely assumptive, but the report does nothing to substantiate the key assertion that BECCS at Drax will be vital to this, beyond the fact that the entire Humber cluster is dependent upon the concurrent construction of a common CO2 pipeline and undersea storage facilities. The projections for the Humber cluster are, in reality, dependent not on BECCS at Drax, but on investment on a massive scale for the pipeline and storage, each of which are required to be consented separately and on their own merits. Such consent cannot be assumed in the examination of the BECCS application, which is dependent upon them and therefore, at this stage, cannot be meaningfully examined. This view is further strengthened by Drax’s reassessment of the lifetime of the BECSS plant to end in 2050, far earlier than the Humber and Teesside clusters. Flood Risk Assessments 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”. We wish to challenge the flood risk assessment on the grounds that: • Drax and the surrounding area is a known area of flood risk with flooding becoming more frequent; • The flood risk assessment needs to be re-evaluated to take into account the latest Climate Change Risk Assessment (CCRA 2022); • Drax’s flood risk assessment fails to consider risks to the rail supply network which we believe is a major omission as it crosses both the Aire and the Ouse flood plains. Technical 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 gas elsewhere; or met by Drax’s own production further lowering the efficiency of an already old and inefficient plant. This is contrary to the Planning Systems aim to ‘help increase the use and supply of renewable and low carbon energy and heat’. Further, evidence is accumulating that the technical challenges of CCS will prevent its widescale roll-out and adoption, raising genuine financial and climate risks [Redacted] and undermining the provision of genuine and sustainable good green jobs. Indeed we can present evidence that there are better and more cost-effective ways to develop good green jobs, generate genuinely renewable electricity and provide long term economic sustainability well beyond 2050. Air pollution and Health The CCS system that Drax Power proposes uses amine solvents to separate the CO2 from the flue gases. We believe that the health risk assessments are lacking detail, in particular with respect to: • The loss of amines from the system and their subsequent degradation into probable carcinogens; • The lack of reliable research that would enable effective regulation and monitoring, as summarised by SEPA’s report [Redacted] Biodiversity We have two biodiversity concerns. Locally, we have concerns that 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 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: • Commitments made in the Environment Act 2021 to support the “conservation and enhancement of biodiversity in England” • 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 international designated areas that cannot be adequately mitigated or compensated for. The application for consent is deficient in that: • It relies on outdated species information, including species surveys from 2018, and therefore does not properly assess the impact of the proposed development. • It does not pay sufficient attention to the potential for damage to watercourses by sediment and accidental release of chemicals. • The proposals for Biodiversity Net Gain do not consider rivers. • The risk of nitrosamine deposition which could impact habitats within the surrounding protected sites is not recognised. Secondly, we have evidence that despite Drax Group’s assertions, their wood pellet supply is not sustainable and in some cases is open to legal challenge. We have evidence that Drax’s supply chain in Estonia may be in breach of UK sustainability standards, and that Drax’s supply chain in British Columbia threatens critical Caribou habitats and at least partly occupy indigenous lands that neither the Canadian nor British Columbian states are legally entitled to licence. These vulnerabilities undermine the business case and therefore the application.