Memorandum submitted by Scottish and Southern Energy (NPS 85)



SSE fully supports the submission by the United Kingdom Business Council for Sustainable Energy (UKBCSE)


However, one issue not covered in the response was the issue of Carbon Capture and Storage Readiness. This is covered below.


What has the Government actually said?


Section 4.7 of the overarching National Policy Statement deals with Carbon Capture and Storage and Readiness.


The key section is as follows (with the most worrying sections underlined):


"4.7.1 To ensure that no foreseeable barriers exist to retrofitting carbon capture and storage (CCS) equipment on combustion generating stations, all applications for new combustion plant which are of generating capacity at or over 300 MW29 and of a type covered by the EU's Large Combustion Plant Directive (LCPD)30 should demonstrate that the plant is "Carbon Capture Ready" (CCR) before consent may be given. The IPC must not grant consent unless this is the case. In order to assure the IPC that a proposed development is CCR, applicants will need to demonstrate:

that sufficient space is available on or near the site to accommodate carbon capture equipment in the future;

the technical feasibility of retrofitting their chosen carbon capture technology;

that a suitable area of deep geological storage offshore exists for the storage of captured CO2 from the proposed combustion station;

the technical feasibility of transporting the captured CO2 to the proposed storage area;

the economic feasibility within the combustion station's lifetime of the full CCS chain, covering retrofitting, transport and storage."


Later on, the document says:


"4.7.3 If the IPC, having considered these assessments and other available information, concludes that it will not be technically and economically feasible to retrofit CCS to a proposed plant during its expected lifetime, then the proposed development cannot be judged to be CCR and therefore cannot receive consent".




"4.&.11 In addition to satisfying the CCR criteria, new coal-fired generating stations in England or Wales must have Carbon Capture and Storage on at least 300 MW net of the proposed generating capacity. Coal-fired generating stations of less than 300 MW net capacity should show that the proposed generating station will be able to capture CO2 from their full capacity"


See here for full document:


SSE's opinion


SSE has already stated that Government must do two things: commit the UK to having no new coal without full capture, and to develop a funding mechanism for developing CCS demonstration projects.


This CCR policy, however, does nothing more than create an illusion of progress in CCS developments, and deflects focus from the more important measures needed to actually take CCS forward. However, it is actually far more serious than this for the reasons below.


Put simply, given the immaturity of CCS as a technology, making an assessment on the technical and economical feasibility of retrofitting the technology to a Planning Application is impractical and likely to produce a meaningless assessment. Without knowing the costs it is impossible to specify objectively what is "economically feasible". In fact, it may even be the case that it will never be possible to economically retrofit CCS.


The result of these regulations (if taken literally) may be that no application (coal or gas) may be capable of compliance with the regulations meaning that these stations will simply not be able to be built. In fact, even if the Government or Infrastructure Planning Commission (IPC) treats these sections flexibly for applications, they may face legal challenge from objectors.


There is another added challenge for gas plant because CCS financial support is currently proposed only for the demonstration coal stations, meaning that gas applicants will have to effectively prove economic feasibility without subsidy. As the regulations apply to applications going through the planning process currently, this has ramifications for a number of applications, including SSE's Abernedd Plant in Wales.


Around 12GW of coal and oil will have to close by the end of 2015 due to the Large Combustion Plant Directive (LCPD), and a further 7GW of nuclear is due to close by 2018. Therefore the UK is entering a period where investment in new capacity is vital to ensure secure energy supplies. Without a contribution from new gas plant over the next 10 years the UK will face power cuts. This CCR policy could hamstring the Government's ability to keep its peoples' lights on.


The Government needs to remove this proposal for CCS Readiness, if not for all plant then at least for gas plant, or defer it until CCS is proven as a technology, perhaps keeping the need to specify a route and ensure adequate space for retrofit at each plant. This, coupled with a commitment to no new coal unless fully abated today and a strong carbon price through the EU ETS, is the only sensible way to proceed in a way which tackles emissions while not compromising security of supply.


While a CCR type approach may be workable with Government as the decision-maker, given that the decision-maker will now be independent (the IPC), this area of the NPS needs to be made clearer to prevent later misinterpretation.


January 2010