Representation by CPRE North and East Yorkshire (CPRE North and East Yorkshire)
- Date submitted
- 5 September 2022
- Submitted by
- Non-statutory organisations
PRE North and East Yorkshire ('CPRENEY') would like to register their strong objection to this application for a DCO to be awarded for the Drax Bioenergy with Carbon Capture and Storage Project ('the project') submitted by Drax Power Limited ('the applicant') in North Yorkshire. CPRENEY are wholly supportive of the Government's commitments to reach net zero by 2050 and believe that appropriate carbon capture and storage ('CCS') can be beneficial, however, note that there can also be disadvantages to some CCS projects depending on the individual case. In this case CPRENEY object to the project on the grounds that the proposals are: 1. Fundamentally at odds with the requirement in the NPPF to 'shape places in ways that contribute to radical reductions in greenhouse gas emissions' para 152; 2. Biomass Plants which burn 'forest biomass' in power stations increase atmospheric CO2 levels at a higher rate per unit of electricity than from coal - therefore it makes no sense in a climate emergency to be pursuing this project. - Drax power station, already emits more CO2 than any other facility in the UK. 3. The loss of forest cover for 'biomass usage' depletes the ability of natural soil sequestration and any replacement tree sapling cannot store the same level of carbon as a mature forest, taking years to 'match' the equivalent carbon storage. 4. Cutting down forests from South-east USA, Canada and the Baltic region, to ship to the UK for use at Drax, causes a huge carbon footprint in its own right and local communities native to those forests are in complete objection. Drax Group plc stated in their annual report to investors (2019) that 'over 99.5%' of the more than 7-million metric tonnes of woody biomass burned annually at Drax Power Station comes from overseas forests; 5. The impact on local and major road networks are such that the safe and suitable tests in the NPPF are not met and should be refused - the NPPF sets out clearly at para 111, that 'development should only be prevented or refused on highway grounds if there would be an unacceptable impact on highway safety , or the residual cumulative impacts on the road network would be severe.' - The applicant has clearly stated in their submission documents that there will be a 'major adverse' impact on congestion and a 'minor adverse' impact on highway safety at junction 36 of the M62; and 6. The applicant has stated that there will be a 'moderate adverse' impact on the visual amenity of the nearest residents and users of the Public Rights of Way network surrounding the site - mainly due to the flat topography of the site and surrounding land allowing for long ranging views CPRENEY believe that the UK has abundant sources of cheaper and cleaner energy and does not need Drax or other bio-power stations in the transition to clean and renewable energy sources. The subsidies which are received by the applicant and other such companies should be diverted to enabling the proper retrofitting of existing building stock to ensure adaptability to renewable energy and resilience for climate change, whilst ensuring all new builds incorporate appropriate energy efficient materials and technologies such as rooftop PV as standard and community power generation schemes. In February 2021, more than 500 scientists wrote collectively as the European Academies Science Advisory Council, to world leaders -including the UK Government, stressing the detrimental impacts of cutting down trees and burning the wood for energy on climate change stating : “Regrowth takes time the world does not have to solve climate change. As numerous studies have shown, this burning of wood will increase warming for decades to centuries. That is true even when the wood replaces coal, oil or natural gas.” The applicant states that "emissions from biomass burning are counted as zero in official reporting to both UK authorities and under the UK Emissions Trading" as set out by the United Nations Framework Convention on Climate Change - However, the Intergovernmental Panel on Climate Change also make clear on their website in FAQs number 2-10 that “The approach of not including these emissions in the Energy Sector total should not be interpreted as a conclusion about the sustainability, or carbon neutrality of bioenergy.” [Redacted] Fundamentally, CPRENEY consider that large-scale biomass burning at Drax requires the significant harvesting of trees globally, therefore, massively reduces opportunities to remove atmospheric CO2 as opposed to letting forests grow and mature. Forests, grass, peat bogs, and wetlands are scientifically proven ways of sequestering carbon and thus their retention should be critical to the global response to the climate emergency. Specifically at Drax the proposed project will have significant detrimental impacts on the local and national road network, biodiversity and fundamentally the landscape character, in particular the impacts on visual amenity of nearby residents and users of the PROW network. In summary, the applicant states in their submitted planning statement (final para of the exec summary) that there is an "urgency of need for new CCS in order to decarbonise the power sector in the UK to meet the legally binding target of net zero by 2050" - setting out that the benefits of the proposed scheme outweigh the harm that it will cause. CPRENEY strongly object to this statement for the reasons set out above. Furthermore, during their pre-submission consultation process, the applicant clearly stated to other interested parties in December 2021 [Redacted] that: 1. The carbon capture technology developed by C-Capture, used in Drax’s first BECCS pilot project starting in 2018, is not a proven technology. 2. It has no data about the amount of energy required for carbon capture using the technology chosen (MHI technology). 3. It has no data on the reliability of the MHI technology. 4.It has not achieved continuous operation of carbon capture. 5. So far, all captured CO2 has been released into the atmosphere. CPRENEY, therefore, respectfully request that in such circumstances as set out above and admitted to by the applicant, the precautionary principle should be applied and for the sake of the environment and the global climate emergency this project should not be granted a DCO.