February 2024 Update
This page may have been quiet recently, but there has been plenty of activity!
Alongside everything detailed below, the government are currently in court defending a challenge by Friends of the Earth, Client Earth and the Good Law Project against the (new) Net Zero Strategy. The challenge claims that the new strategy is still in breach of the Climate Change Act.
The Secretary of State for Energy Security and Net Zero has given approval for the carbon capture and storage project to go ahead at Drax. This is not good news. However, our friends at Biofuelwatch have sent a challenge to the Secretary of State to indicate that her decision is wrong. (https://www.leighday.co.uk/news/news/2024-news/biofuelwatch-uk-threatens-legal-challenge-to-decision-to-allow-carbon-capture-installation-at-drax-power-plant/). We await response.
As well as the above challenge, The Lifescape Project are challenging the legality of the government’s Biomass Strategy. (https://www.leighday.co.uk/news/news/2023-news/environmental-charity-seeks-judicial-review-of-government-s-plans-to-promote-the-use-of-biomass-fuel-in-its-strategy-to-cut-greenhouse-gases/).
The Secretary of State has also consulted on giving “bridging subsidies” to the two largest biomass plants – Drax in Yorkshire and Lynemouth in Northumberland. These are to extend subsidies for unabated biomass (i.e. without CCS) until CCS units are built at some unspecified time in the future. There is no defined end date for these proposed subsidies.
This is a complex and technical consultation, but a number of groups have co-ordinated responses and shared understanding of the detail – a great collaborative effort. Our own response of course includes this technical detail, but also explains at length why these bridging subsidies will fail to deliver the intended outcome. You can read our full response here, and a much shorter MP briefing here, but the next paragraphs summarise the case.
DESNZ believes that a biomass power station with carbon capture and storage fitted (power BECCS) will deliver negative emissions, and also deliver “dispatchable” generation. Dispatchable means that it can be turned on and off at short notice to fill in at periods of high demand, or when renewables struggle becuase of (say) low wind speeds.
There are two problems with this. The first, already well rehearsed on this page, is that biomass is NOT zero carbon or carbon neutral, and so power BECCS will NOT be carbon negative, even if the CCS system works as claimed, which is not a given. The second, is that power BECCS is NOT dispatchable. Under questioning from the Planning Inspector, Drax made it clear that: because of the lengthy start up and shut down procedures for the CCS system, power BECCS is only suitable for baseload (continuous) generation and is NOT dispatchable. Only unabated (burning without CCS) biomass is dispatchable, yet it is government policy to phase out unabated biomass.
It would seem that either DESNZ are deliberately ignoring the truth in order to continue subsidising high emitting industries at the expense of the consumer, or simply do not understand the technicalities. There may be another explanation, but we haven’t yet thought of it.
With so many legal challenges in process or about to begin, it is clear to us that February – March 2024 is NOT the time to sign binding contracts between the government and biomass generators. Any one of three court cases, or the still unpublished biomass sustainability criteria, could stop the bioenergy industry in its tracks.
It seems to us that the Secretary of State is proceeding with undue haste, and will effectively tie the hands of any new government to lock in indefinite support for an unsustainable, climate wrecking, ecocidal industry, to be paid for by each and every one of us through the so-called “green levies” on our electricity bills.
July 2023 Update.
The Planning Enquiry comes to an end on Monday July 17th. For this deadline, we will be submitting our summary statement to the Examining Authority, which will reflect the huge amount we have learned and the changes that Drax have made to their application. We will post this summary statement here once it is submitted.
Recently, National Grid Pipelines have decided to put the pipeline project up for sale, before they have even started the planning process properly – they have not yet gone beyond the pre-planning consultation. They say they need to concentrate on getting the electricity grid ready to cope with renewables. We can’t disagree with that, but wonder why they haven’t been doing this for the last 30 years… They are hoping to sell to the Northern Endurance Partnership (big stake owned by BP) who will be applying to operate the carbon dioxide store in a saline aquifer under the North Sea.
Because of the pipeline is now up for sale, Drax have asked the Examining Authority for a delay. Initially, they asked for a 2 year delay. They have revised this to be allowed a commencement date up to 7 years from now – i.e. 2030. This gives them freedom to not even impose the compulsory purchase orders until 2030. This is a significant delay, and we have written to the Examining Authority with our concerns about the impact of this delay. You can read our submission here.
Our particular concerns are that we already know that burning trees and wood at an industrial scale will increase emissions and is not actually renewable (see below), and that in this next 7 years, the world will see considerably more climate disruption. This increasing climate disruption will change the regulatory framework, will make false solutions unattractive even to mainstream politicians, and of course by then, the UK is legally required to have cut emissions by 68% from 1990 levels. Something will have to give.
March 2023 Update: a second round of oral hearings have been announced for the week beginning March 20th. There will be three hearings, each with a different focus. The first, on Wednesday March 22nd is on biodiversity. The second, on Thursday March 23rd is on the Compulsory Acquisition of land. The third, on Friday March 24th is on changes to the draft Development Consent Order. We will continue to make our case that the industrial burning of forests is neither sustainable nor carbon neutral; that it is wrong for the British Public to subsidise this directly through our bills when we are in a biodiversity and nature crisis, and that the Carbon Capture and Storage process is insufficiently reliable and unlikely to capture the promised emissions, further undermining the carbon negative claims.
February 2023 Update: The Planning process is now underway and the initial oral hearings have been held. We were there alongside friends from Biofuelwatch and the Stop Burning Trees Coalition.
We made a written submission to the preliminary hearing to ask that the hearing be delayed for the following reasons:
- The UK Government’s Biomass and BECCS policy is not in place. It was consulted in 2021/22 but it has still not been published.
- The Net Zero Strategy was found to be in breach of the Climate change Act, and is awaiting a re-draft by the end of March 2023. This is not yet in place.
- The policy framework is not in place. Energy policy EN-1 and EN-3 are awaiting an update and the old policies are not sufficiently up to date to apply in 2023.
- The Drax application to retrofit Carbon Capture and Storage to two of its generating units is not only linked to, but entirely dependent on, the applications for the Humber pipeline project and the undersea storage. The pipeline project is at least a year behind Drax’s application and the undersea storage application is not yet underway
We argue that the planning process should be paused until both the legal and the policy framework are in place and fully updated.
We also argue that the planning process should be paused and heard in parallel with the Humber Low Carbon Pipelines project AND the Undersea Storage project. All three projects are linked, and Drax’s BECCS application is entirely dependent on the other two. One cannot be approved or built until all are approved.
You can read the evidence we shared with the Examining Authority here and also here.
Here is the summary of why we are campaigning against industrial burning of forests in power stations.
This year, Drax power station between Selby and Goole, is seeking planning permission to add a carbon capture and storage system to two of its four biomass boilers claiming that this will be carbon negative and help control runaway climate change.
Put simply, we disagree. We argue that this is a false solution that will worsen both the climate crisis and biodiversity crisis, and at the same time divert vital investment from real renewables like wind, solar and energy storage, and from energy efficiency measures like retrofitting homes to make them safe, comfortable and affordable in an era of rising energy prices.
Over the coming weeks, we will go into much more detail about the problems with the industrial burning of forests to generate electricity, but here is a summary for starters with a few useful links at the end.
We are currently focusing on Drax for several reasons (see bullets below) but please be aware that this is a global industry and the UK has other biomass generator plants.
- Drax Power has a live planning application for a BECCS plant (BECCS = Bio-Energy with Carbon Capture and Storage)
- Drax Power Station is one of the biggest carbon dioxide emitters in Europe and is the UK’s largest emitter
- Drax receives approximately £2,600,000 in subsidy EVERY DAY
- Drax Group owns a significant share of the world’s wood pellet manufacturing capability, with a virtual monopoly in British Columbia (Canada) and further capacity in the Southern USA
The problems with Drax and Biomass
Climate Change
The UK Government and the EU currently classify biomass burning as “renewable” or carbon neutral, on the (simplistic) basis that trees burned can be replanted and will recapture the carbon emitted. Reality of course is not as simple as GCSE science, and this classification is increasingly being challenged by climate scientists. It is an administrative classification not a scientific one.
Firstly, the world needs to attain zero carbon emissions by 2050, many would say much earlier. This is less than 30 years away. Any tree planted today will take decades, even centuries, to recapture the full carbon from a mature tree burned yesterday. So even with rapid replanting and proper care, burning trees cannot be carbon neutral within the timescale required to achieve net zero.
There are many other reasons why burning trees is not carbon zero, which we will expand on in later posts, but there are plenty of scientists, economists and others who recognise the reality. Currently the emissions from felling, road transport, processing, drying, shipping, etc are not counted. But those emissions are real.
This is clearly seeping into decision makers consciousness, with for example, Kwasi Kwarteng questioning whether biomass was actually sustainable (August 22) and with S&P Global Clean Energy Index dropping Drax in October 21, it is not just campaigners who recognise the reality.
Ecological Impact
Drax claims that the wood it burns is waste wood from the forestry industry. Evidence from the USA, Canada and Estonia says that this is simply not true, and that a considerable proportion of the wood pellets are made from whole trees. This means that Drax is both making and buying wood pellets from clear felled forests. The claim that only waste wood is used still seems like sleight of hand, with “forest waste” apparently meaning “trees/forests that have little commercial value as timber” not “the bits cut off” which is what the glossy videos say.
This is significant, because it means that forests are stripped of all life – from bears and deer down to decomposing fungi and bacteria deprived of the brushwood. When the forests are replanted, they become mono-culture plantations not biodiverse forests. Cut Carbon Not Forests have reported that they believe that Drax’s Estonian sources violate the UK’s sustainability standards for Biomass and we are beginning to hear concerns that Drax’s operations in British Columbia overlap with indigenous land and include land with protected Caribou herds
We know that biodiversity is collapsing globally, with critical species like insects experiencing major population collapses. The 2022 Living Planet Report told us that wild species have declined by a global average of 70% in the last 50 years. This is a human led devastation of the natural world.
Drax alone burns around 16,000,000 tonnes of wood, which when dried makes around 8,000,000 tonnes of pellets. This alone is more than the UK’s entire timber production, so is completely out of scale with our nation’s ability to sustain such an industry.
The UK has other industrial scale biomass plants at Lynemouth in Northumberland and new one in development on the Tees Valley Freeport, as well as other smaller power stations around the country, including Kent. Then there are biomass plants across Europe, and Drax uses its Canadian operations to supply to the Japanese and South Korean markets too. We can see that providing even a small amount of global electricity from burning forests is going to be catastrophic for the world’s forests (vital carbon sinks) AND the forest flora, fauna and micro-organisms (biodiversity).
Air Pollution and Environmental Justice
Burning wood, especially wood pellets, produces significant pollutant particles known as PM2.5. These are 4 times smaller than other typical pollutants produced, known as PM10, and far more dangerous. They travel further into the lungs and are linked to worse health outcomes. The World Health Organisation recognises that PM2.5 particles are associated with the greatest proportion of adverse health effects related to (caused by) air pollution.
The Carbon Capture and Storage (CCS) process uses solvents based on chemicals called amines. These will be emitted by the CCS plant at Drax, they will dissolve in rain, and will degrade in sunlight to form chemicals called nitrosamines which are of particular health concern being carcinogenic. Drax will claim that their emissions levels will be low enough to be legal, but the academic research is clear that no-one knows what a safe level of these compounds might be, they are difficult to measure, and there is insufficient data available for governments to regulate them. We think that this is playing roulette with our health.
Drax also have a poor pollution record inside their power station. They are being taken to court by the Health and Safety Executive, with the hearing scheduled for June 2023. This is because of the damage to the health of their workers from breathing in wood dust.
If that were not enough, Drax owns pellet mills in Canada and in the Southern US states. They were fined $2.5 million last year for air pollution breaches in the USA, and this year agreed a $3.2 million settlement to damaged communities. Greenpeace have recently released a report accusing Drax of environmental racism because of the harm their pellet mills cause to marginalised communities of colour.
A colleague in Mississippi in the USA has spoken to us in powerful testimony about the environmental racism her community experiences.
Firstly she said: “Systemic and structural racism determines our lives at so many levels. Structural racism determines everything from our infant mortality to our life expectancy. Structural racism determines the quality of our education. Structural racism determines the quality of our health, our healthcare, and our ability to even access healthcare. Structural racism determines the value of our homes and the proximity of our homes to toxic sites. Structural racism determines our ability to prepare for and recover from inevitable climate events. Structural racism positions us to be the least contributors to climate change, but the most impacted. So when we talk about the need to keep global warming well below 1.5C, it is so important that we take a holistic approach to ensure justice and equity in the process. Yes, we must get well below 1.5C warming, but we must not do so by any means necessary, turning a blind eye to those who are harmed in the process.”
She finished by saying to us: “Right now, the UK is harming us in the pursuit of what they call ‘renewable energy’. Biomass is destroying communities, forests and our climate. We are becoming a sacrifice zone!“
Subsidies
Drax receives huge subsidies which change as the price of energy fluctuates. They used to receive between £2 million and £2.4 million every day (about £880 million every year). Last year, this went up to over £2.6 million every day. These subsidies are guaranteed until 2027, even though Drax is making huge profits.
However, they are seeking ADDITIONAL subsidies to build and run the Carbon Capture and Storage (CCS) plant, which will cost us all even more, indefinitely into the future. We do not think that we should pay Drax or anyone else to destroy thousands of hectares of forest in the middle of the climate and ecological emergencies. These additional subsidies will be paid whether Drax captures CO2 or not – they are not linked to success!
If this were not bad enough, these subsidies do not come from the taxes we pay. They come from our electricity bills – even if you have a 100% renewable electricity supplier who does not buy electricity from Drax, you are still paying these subsidies to Drax through the standing charge on your bill. We pay Drax personally – each and every one of us. We object to this.
Carbon Capture and Storage
Despite the subsidies, we do not have any confidence that the Carbon Capture and Storage (CCS) technology will work effectively. There is a long history of CCS plants failing to deliver. Academic studies show that globally, the majority of CCS projects are either cancelled before being built, or scrapped or mothballed after a few years because they are too expensive, too unreliable and do not capture the quantity of carbon promised in the brochures! The bigger the project, the less likely it is to succeed. In other words, the success of scaling up from pilot projects to full industrial scale does not have a track record to boast about. As we say above, there are better ways to use the subsidies.
Just Transition
We want to be clear that we recognise that Drax is an important local employer. However, many Drax employees and contractors have high level, transferable skills, including the engineers, electrical engineers, specialist plant operators, etc.
When (if) operational, Drax power station with CCS fitted, will require 375 jobs at the plant. Some of these will be new, some will be existing roles. During construction, it is clear that most jobs will be recruited nationally, and any local jobs that are advertised will be low skilled and therefore low paid.
The vast subsidies could be redeployed to domestic (home) retrofit which could have a far greater benefit to the local economy and jobs market, and Drax could use its profits to invest in genuine renewables and grid storage with proven market value. They could even invest in research and development of tidal energy in the Humber.
We therefore contend that a managed, just transition for Drax Power Station and its staff, using redeployed subsidies, could be of even greater benefit to the local and regional economy than the BECCS operation already planned.
At the moment, the UK government classify the industrial burning of wood as carbon neutral. As we have already explained, we strongly believe that this is wrong, and it is a bureaucratic classification not a scientific one. We are not alone in thinking this.
In February 2021, 500 scientists wrote to demand that the US, the EU, Japan and South Korea stop burning trees. In October 2021, S&P Global Clean Energy Index dropped Drax because their operations could no longer be regarded as sustainable. In August 2022, Business Secretary Kwasi Kwarteng told MPs that he did not believe that shipping wood half way around the world to burn in the UK could be sustainable.
If we have whetted your appetite to find out more about this counter-productive, unsustainable and frankly dangerous (to climate, to nature and therefore to us) industry, you might like to have a look at these other organisations. You might also like to get in touch to join our campaign to save the forests, create real jobs and improve people’s lives.
Biofuelwatch: https://www.biofuelwatch.org.uk/
Stop Burning Trees Coalition: https://stopburningtrees.org/
NRDC: https://www.nrdc.org/
Dogwood Alliance: https://www.dogwoodalliance.org/
Stand.Earth: https://www.stand.earth/
Save Estonia’s Forests on Twitter: @s_estonia
EASAC (European Academies Scientific Advisory Council): https://easac.eu/
Conservation North: https://conservationnorth.org/