This viewpoint was approved at the Commission meeting on 21st June 2023.
At the highest strategic level, phasing out reliance on fossil fuels for energy and industries must be an overarching priority for the region’s future. Yorkshire and Humber Climate Commission (YHCC) led the collaborative production of the Yorkshire and Humber Climate Action Plan, which supports the greatly accelerated decarbonisation of energy supply. Carbon capture and storage (CCS) for industry is important because it enables decarbonisation to happen more rapidly in industrial sectors whose dependence on fossil fuel energy will take much longer to eliminate. There is increasing urgency to invest in the technology and skills to make this happen, and it is vital to seize the economic opportunity this presents.
Drax power station has long held a pivotal role in the UK’s energy production. Drax’s own net zero plan is based on converting its generators to burn wood biomass, imported from forests in North America, and to capture and store the resulting carbon emissions. This process is called bioenergy with carbon capture and storage (BECCS).
Our Climate Action Plan recognises that large-scale bioenergy could play a role in decarbonisation, but its sustainability is contested. There are serious and ongoing concerns about the global environmental and social impacts of the forestry to supply fuel for Drax, and potentially for other BECCS projects worldwide.
The transition of Yorkshire and Humber’s economy from its very high-carbon past to a very low-carbon future is of vital importance, but cannot be pursued in ways that compromise environmental or social justice. In our view, the ‘BECCS Done Well’ report, commissioned by Drax, sets out the challenge clearly, and therefore informs the YHCC perspective set out in this paper.
Our Climate Action Pledge
YHCC has developed a Climate Action Pledge to enable organisations of any type or size to signal their commitment to accelerating their action on climate. It is difficult for any organisation in any sector to truly do everything in its power to address the climate and nature emergencies – we are all on a challenging journey and we welcome any organisation that is committed to making that journey. Organisations taking the Pledge commit to making progress in at least one of four areas of action, and holding themselves to account on those commitments.
Drax have taken the Pledge, stating their plans to reduce emissions and reach net zero; to adapt and build resilience to climate risks; and to work with their stakeholders to improve their positive impact. We commend Drax for commissioning Forum for the Future’s ‘BECCS Done Well’ report without prejudice to its findings – indicating a willingness to take the kinds of courageous steps that the Pledge seeks to encourage.
Industrial sector CCS
The Humber Industrial Cluster is currently the largest CO2-emitting cluster in the UK and plans to become the world’s first net zero industrial cluster by 2040. A CCS scheme, utilising redundant gas fields and saline aquifers below the North Sea to store captured carbon is a key component of the plan. The Humber Low Carbon Pipelines project is intended to provide CCS infrastructure that will also service the Drax BECCS project.
CCS will enable a range of major industries to decarbonise, especially but not exclusively, in the Humber sub-region. These industries, including steel, chemicals and building materials, will be part of our regional economy for years to come. There are some concerns that CCS may allow delays in the phasing out of fossil fuels. However, those involved in CCS do not claim it to be carbon negative; rather it is widely accepted as a mitigation that is essential if industry is to decarbonise sufficiently within the necessary timescales.
YHCC supports the emissions reduction aspirations of the Humber Industrial Cluster, and will be undertaking further work through a ‘delivering impact’ workshop in mid July 2023, bringing together a range of experts to explore how regional projects, evidence and advocacy could assist in making CCS a successful component of climate action. A recording of the speakers from this session and a supporting paper will be made available for public comment via our Commonplace platform in September.
Drax and BECCS
There has been considerable public pressure on Drax concerning the merits of BECCS in general, but most significantly with regard to the environmental and social sustainability practices within the biomass fuel supply chain. Some stakeholders consider that BECCS should not be recognised as a sustainable part of the future energy mix. Following significant media attention, Drax responded directly to criticisms in a public statement in October 2022.
Drax have an independent advisory board to provide advice on sustainable biomass. This board recently recommended that Drax “reassess its criteria for determining carbon neutrality” and should “move away from…stating biomass is carbon neutral”. The energy regulator Ofgem has also initiated an audit into Drax’s wood fuel sourcing practices. These events have been reported in the media as indicating a threat to the future of Drax’s ambitions, though clearly this depends on the outcomes of the audit and of Drax’s actions on their advisory board’s recommendations. Drax have informed us that they and other biomass producers are working to improve their monitoring and reporting of the forest carbon.
Following the Government’s decision not to include Drax BECCS in its Track 1 process for supporting large-scale carbon capture projects in March this year, Drax wrote to inform YHCC of their concerns that, despite forthcoming discussions between Government and Drax, the project may be at risk. Drax posit that failure of the project would jeopardise significant investment and job creation, and undermine York & North Yorkshire’s ambition to be England’s first carbon negative region by 2040.
YHCC’s position on BECCS
YHCC is an independent advisory body set up to promote ambitious actions on climate, nature and a just transition for the region. We bring together people and organisations across a wide range of interests, to build the collaborative capacity to meet our shared climate objectives. We are non-partisan, and we are neither a regulator nor a platform for commercial lobbying. We are open and inclusive, and our engagement with any particular organisation is not an endorsement of their policies, products or performance.
We have forty Commissioners, one of whom is an employee of Drax and another is from Friends of the Earth – reflecting the wide range of perspectives YHCC embraces. Commissioners provide their expertise to YHCC on an individual basis, not as representatives of their organisations. Our terms of reference are clear that no Commissioner should use their role to advance campaigning or commercial interests, and happily none of them has sought to do so. Our approach also relies on trust – all our partners must trust in the transparency and good intentions of the others. In light of strongly-held views both for and against BECCS, it is testament to all our Commissioners that this mutual trust continues to build.
As mentioned above, Drax has sought to address its challenges in a constructive way. In 2022 it commissioned an independent panel, convened by Forum for the Future, to determine what ‘BECCS Done Well’ would mean. Its report does not support BECCS as a sustainable or cost-effective means of generating renewable energy, but it does find that BECCS could, if done well, be an appropriate mechanism for reducing atmospheric carbon – using forestry to absorb carbon dioxide and then using CCS to transfer it into storage facilities. The report states that “companies like Drax can make a significant and relatively rapid contribution to net zero targets through delivering ‘negative emissions’”.
The strategic case for BECCS is therefore contingent on its effectiveness in drawing down atmospheric carbon in a sustainable way.
Concerns about how the forests that supply the fuel are managed pose a challenge to that strategic case. Done well, commercial forestry can be beneficial for nature, soils and for their local communities; done poorly, it can be extremely damaging on all counts. The Forum for the Future report states that “independent third party monitoring, verification and certification is a critical part of this process, especially in terms of protecting biodiversity, water resources, soil carbon, old growth forest, and so on. Proactive engagement with local communities is equally fundamental… The implications of any significant expansion of BECCS plants globally [require] the strictest independent monitoring and governance arrangements to ensure positive outcomes for people, the environment and the climate.”
If the huge up-scaling of forestry needed to supply not just Drax, but also any other power stations worldwide wishing to follow Drax’s lead on BECCS, is to be genuinely sustainable, then the standards, governance, community engagement and quality control in the supply chains need to be beyond reproach. At present, the effectiveness of these arrangements is contested. On the one hand, the Sustainable Biomass Program provides a certification scheme which, although voluntary, is recognised by the European Union. On the other hand, research for the UK government has found that the range of variables and methodologies involved in analysing the effect of biomass production on forest carbon makes it very difficult to form a definitive position; and concerns about biodiversity loss and other impacts remain. In this context it is not possible to be confident that BECCS will not risk unacceptable impacts.
Our vision for our region is of a future where people and nature can thrive in the changing climate, and decarbonisation has been achieved at pace and scale and in a fair and just way. Achieving this is an unprecedented challenge and we are starting with an imperfect system. We must remain open and curious about all technologies. The regional Climate Action Plan recognises a potential role for bioenergy, when combined with CCS, and as part of the energy mix in the context of accelerating the net zero transition.
The ‘BECCS Done Well’ report indicates that an effective and just approach is possible. However, our position must be informed by the complex ethical challenges society faces. If any decarbonisation project were to come at the expense of harm to nature or to people’s wellbeing, locally or globally, then it should not be supported. Achieving a just transition means ensuring that historical examples of exploitation in the extractive industries are not repeated – however unintentionally – in the drive to net zero.