Further supplementary submitted by the
Department of Energy and Climate Change
At the oral hearing with Lord Hunt of Kings
Heath on 10 February 2010 the Energy and Climate Change Select
Committee requested further details on:
— rationale for non-location specific National
Policy Statements (NPSs);
— Carbon Capture Storage (CCS) and economic
feasibility;
— 50MW threshold for Energy from Waste
(EfW) stations; and
— carbon footprint of waste derived fuel
and waste hierarchy.
This note provides this information.
1. Rationale for non-location specific National
Policy Statements
To review and specify all potentially suitable
locations for energy infrastructure types in the non-nuclear draft
energy National Policy Statements (EN-2 to EN-5) would be a long,
complex and expensive task that would not deliver commensurate
benefits. There is potentially no limit to the detailed work that
would be needed to consider every possible potential site for
all types of energy infrastructure.
Such an exercise would also have considerable
risks that identification of potentially suitable sites could
chill potential future development of non-energy development (eg
housing) and raise fears that energy infrastructure would be built
on the identified sites without adequate local involvement.
The policy to identify potentially suitable
sites for new nuclear generating stations was set out in the Policy
Framework for New Nuclear Build—Consultation Document published
in July 2006. The Government gave a commitment that it would carry
out suitable siting assessments and so EN-6 on nuclear power is
location-specific. This was based on the need for industry to
have a reasonable degree of certainty as to which sites would
be potentially suitable so that they could reasonably commit investment,
the limited availability of sites that were technically suitable
for new nuclear generating stations and the desire to avoid "planning
blight".
2. Carbon Capture Storage and economic feasibility
The text in EN-1 reflects the requirements of
the EU Directive 2009/31/EC on CCS. Article 33 of the Directive
specifies that an assessment of economic feasibility is necessary.
DECC published guidance on CCR for Electricity Act S36 applicants
in November 2009. This guidance makes it clear that such economic
assessment should be based on reasonable assumptions made about
future market circumstances and CCS technology, given information
available at present.
Therefore an economic feasibility assessment
made at the time of an application cannot predict with complete
accuracy either in what circumstances it will be feasible to fit
CCS to a proposed power station nor when those circumstances will
arise. However, it ensures developers consider the possible costs
of retrofitting CCS to the power station during the application
phase and indicate potential circumstances where retrofitting
operational CCS may be economically feasible during the lifetime
of the proposed new station. We do not believe that the level
of information needed to demonstrate economic feasibility as required
by DECC's CCR guidance sets an unreasonable hurdle for applicants.
Although the IPC and applicants and applicants
are directed to follow DECC's CCR guidance, we will consider whether
the current draft in the NPS is sufficient or should include more
text from DECC's published guidance.
3. 50MW threshold for Energy from Waste stations
The Electricity Act 1989 sets the 50MW threshold
(s36). The Planning Act 2008 transferred consent decision-making
for 50MW and above electricity generating stations from the Secretary
of State to the Infrastructure Planning Commission; the 2008 Act
did not affect local authority powers with regard to energy infrastructure
thresholds.
Government is working with local authorities
(through DEFRA's Waste Infrastructure Delivery Programme (WIDP))
to encourage authorities to collaborate with each other over procurements
for waste treatment and disposal infrastructure in order to avoid:
— the duplication of investment by adjacent
local authorities; and
— the building of sub-optimally sized plant.
We have had success in promoting partnership
working amongst local authorities as evidenced by procurements
for waste facilities in, for example, Lancashire, Greater Manchester,
Northamptonshire/Milton Keynes and Essex/Southend.
The economics of small scale plant will reflect
in higher gate fees paid by local authorities for the delivery
of waste management services. However, it is also important to
understand that alongside recycling, Energy from Waste management
solutions usually combine a number of technologies which can include
Anaerobic Digestion (AD), Mechanical Biological Treatment (MBT)
and autoclave, all of which produce residues which can either
go to landfill, energy recovery or be spread on land (in the case
of AD). Where energy recovery is involved we want to see the most
climate change friendly outcome, namely Combined Heat and Power
(CHP).
CHP can be achieved in many ways, including
through the provision of waste derived fuels to industrial intensive
energy users burnt in Waste Incineration Directive (WID) compliant
plants in substitution for fossil fuels where the preparation
of those fuels has observed the waste hierarchy methodology.
4. Carbon footprint of waste derived fuel
and waste hierarchy
DECC and DEFRA are working on a cross-government
EfW strategy to provide guidance to waste managers, industry and
planners on the most carbon friendly and economically viable EfW
pathways. Part of this work will be to provide a hierarchy of
EfW outcomes including CHP. This work is on-going and will be
concluded in autumn 2010.
We are still looking into the issue raised by
Friends of the Earth and energy footprint of EfW and gas power
stations.
Department of Energy and Climate Change
9 March 2010
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