Representation by James Hewitt
- Date submitted
- 14 June 2024
- Submitted by
- Members of the public/businesses
This application appears flimsy in relation to the technologies proposed and to be primarily intent on enhancing sentiment and subsidy for the Riverside 1 & 2 incinerators. (1.1) The context includes controversies concerning existing energy from waste plants (notably: related local authority debt and operational under-performance) and a hastily introduced and soon removed moratorium on further expansion of the sector. The moratorium was introduced primarily in response to well-founded doubt about the need for further plants across the UK - there is already over-capacity in the market, a need for less waste (and more recycling), etc.. Further, consumption - and therefore related waste – will decline as the economy contracts in response to turbulence stemming from the Climate and other Emergencies. The profitability of energy from waste plants is likely to be determined largely by the consistency in quality and quantity of the waste they receive – as such, they can be expected to burn waste which could have other uses. (1.2) The proposal presents no evidence that post-combustion carbon capture rates at energy from waste plants of comparable scale in the sector achieve the (implausibly optimistic) rates proposed during routine operation. This is presumably to hide the reality - there is a lack of such evidence, worldwide. The most recent Judicial Review concerning the sufficiency of the UK government’s plans to achieve Net Zero by 2050 found those plans insufficient. (Those plans are also clearly insufficient given that 2050 is more than a decade too late - global emissions having considerably increased since it became a legal requirement under the Climate Change Act Amendment Order 2019). The plans assume that carbon capture facilities capture CO2 at rates of 90% or above – in routine operation. Rates anything like as much as that have been exceptional, despite well over a decade of operating experience, even with substantial government financial support. The 95% capture rate proposed by the Applicant presumably reflects Best Available Technology based on stripping CO2 from a fundamentally different (and more favourable) mix of gases flowing from geological formations exploited for fossil fuel. (1.3) The Applicant has a Memorandum of Understanding with Carbon8 to capture CO2 (from flue gas) and storing this as carbonate materials rather than as CO2 gas. [See the page “Cory signs MOU with Carbon8” 23 05 2024 on the Applicant’s website.] Its Technology Readiness Level is presumably too low to justify inclusion in this application, making it especially inappropriate to include any net positive contribution from this in the proposal’s greenhouse gas accounts. Inclusion of such material in products which would otherwise not be used (given their life-cycle emissions or environmental footprint) would - by definition - increase emissions. (1.4) The proposal indicates that amine-based solvents will be used in capturing CO2. Amine derivatives some of which are carcinogenic in low concentrations are likely to be formed during the process, and may be released or escape from the carbon capture facility. Methods of detecting these have yet to be established and monitoring for these appears to be a low priority for the government (through the now emasculated Environment Agency) - sewage in waterways reflects this. Giving the nod to the current status quo avoids questioning government reliance on amine-based post-combustion carbon capture technologies. (1.5) The proposal fails to explain how to compensate for the very substantial loss of dispatchable energy attributable to (the parasitic load of) operating the carbon capture processes. To recoup that loss, further carbon-based energy would need to be generated substantially increasing the proposal’s greenhouse gas emissions. The energy penalty would rise when the quality and quantity of post-combustion gases flowing into the carbon capture facility vary (as can be expected if the waste is truely residual) – and the cost of operating that facility at a constant capture rate would rise (perhaps prohibitively). As such, the CO2 emissions saving might well be one third or so lower than the Applicant forecasts. If, as it seems, “APP-062 6.1 - Environmental Statement - Chapter 13 - Greenhouse Gases” ignores this, a reason might be that it would jeopardise the proposal (which might imply an intention to dupe the Examining Authority). (1.6) The permanent storage of CO2 captured from the biogenic content of the waste being burned would probably not make incineration carbon negative. Incineration encourages both production of biogenic waste and its disposal by incineration. The latter represents a loss / leakage from a circular economy. Alternatives which do not involve such loss include manufacture for use within a circular economy (through recycling, repurposing and the like) and (industrial) composting. To meet legally binding carbon budgets under the Climate Change Act (2008), it would be inconsistent to approve proposals for energy from waste plants if only a fraction of that energy were genuinely carbon neutral – let alone carbon negative – taking the life cycle of the plant and its feedstock into account. The waste should not be produced in the first place. “Fig leaves” have no place in the Climate Emergency – and are a distraction from actions and policies likely to be both equitable and much more effective. (2.1) It presents no information concerning how the operation and commercial viability of the proposed facility would be affected by underperformance of any combination of the downstream transportation, CO2 injection and permanent storage underperform (or fail; or become prohibitively costly or otherwise cease to be available to the Applicant). Global experience suggests that under-performance is foreseeable. There is already concern that the Viking field storage sites on which the Applicant relies, will not be developed. The current DCO application process for the Viking CCS project seems to have been salami-sliced – presumably to mislead. As Clause 13.8.32 of “APP-062 6.1 - Environmental Statement - Chapter 13 - Greenhouse Gases” recognises, that DCO application excludes the offshore components - on which the Applicant relies. (2.2) “APP-062 6.1 - Environmental Statement - Chapter 13 - Greenhouse Gases” considers the emissions out to 2080 – more than double the length of time in which the UK is legally obliged to achieve Net Zero. Given that this proposal is specifically to help achieve Net Zero by 2050, the assessment of greenhouse gas flows should not extend beyond then. (2.3) The application is based on the false premise that burning biogenic carbon is immediately carbon neutral. However, much of that carbon will derive from trees and is consequently far from neutral – its carbon payback period / carbon debt would be much longer than the time available to reach Net Zero (and well beyond 2050). The only reason why burning that woody biomass is regarded by government and vested interests as carbon neutral is because it is convenient for government to deem that it is. The atmosphere knows better. Zero-rating the burning of woody biomass is inconsistent with common sense and should not justify subsidies. (3) The Applicant was recently (2018) acquired by a small number of investment funds. Their decision to invest may have been driven at least partly by the access to government subsidies which energy from waste plants attract / generate. Such subsidies considerably reduce investment risk – especially if government can be sued if the subsidies are withdrawn or decline (as is likely, given that incineration is a false solution and energy from waste plants are - as recent nationwide controversies tend to confirm – already becoming stranded assets). As such the proposal may primarily be “rent seeking” rather than a sincere endeavour to meet (out-of-date) climate targets in accordance with flawed assumptions (involving both technology unproven at scale and forecasts of future “demand”).