Representation by Dorothy Stein
- Date submitted
- 16 June 2024
- Submitted by
- Members of the public/businesses
I raise a number of concerns with the CCS technology, and question assumptions that are made in the ES 6.1 Chapter 13. It should be noted that in 2018 there was widespread opposition from the GLA, Mayor of London, local councils and local MPs to the construction of the Riverside 2 incinerator, on grounds of over-capacity and increase in local pollution. Riverside 1 is already taking waste brought in from outside the local area. Riverside 2 would not meet current planning regulations for incinerators, on grounds of over-capacity. ES 6.1 Chapter 13 makes an assumption of a 95% CO2 capture rate. The Applicant will be aware that Carbon Capture projects worldwide have an extremely low success rate, have universally underperformed and are frequently abandoned. The Applicant offers no evidence of such a high Carbon capture rate ever being achieved on an incinerator. The Applicant shows a similar attitude towards the transport and storage stages of the plan. The UK has no track record in either of these processes, which pose multiple risks to public safety, risks of emissions leaks and very high costs. Undersea storage has very rarely been tried, worldwide. When the process was trialled, it showed unexpected problems (ie leakage) and a high risk of failure. For Cory’s project, failure would mean emissions returning to the atmosphere affecting current or future generations and very high financial costs, possibly born by the taxpayer. The Applicant’s lack of acknowledgement of the unproven state of transport and storage technologies seems reckless. There are ongoing concerns about the planned use of amine-based solvents, which are carcinogenic in low concentrations. The risk to workers, local populations and wildlife has not been recognised. ES 6.1 Ch 13 does not account for the reduction in dispatchable energy from the incinerators, due to the load of the carbon capture processes. This should be included in the calculations, alongside the impact of the diesel backup. The assumption that burning biogenic waste is carbon neutral is not accepted under all carbon accounting regimes. There is a further question about whether this waste could and should be reduced. As noted above, the issues of over-capacity and low recycling rates in London boroughs were raised during the planning process for Riverside 2. If the Applicant’s assumptions are incorrect, then the project will not achieve its purpose. In addition to pollution and emissions of the project, the Applicant plans to build on the “protected” Crossness Nature Reserve. The damage the project would cause, would not be justified by the emissions reduction benefits.