White Rose Carbon Capture and Storage Project
Please find attached a letter sent to the applicant, providing s51 advice relating to the draft documents for the White Rose Carbon Capture and Storage Project
Further to our meeting yesterday, and on behalf of Iwan and the team, please find attached our comments on your draft documents submitted in August.
Thank you for hosting and helping to arrange yesterday?s round-table meeting and hope it proved worthwhile in identifying outstanding issues prior to your proposed submission.
Without prejudice to any decisions by the Secretary of State or Examining Authority, and notwithstanding all attached comments, the two key issues that we would recommend you address before submission are:
1) Air emissions modelling working closely with both EA (permitting) and Natural England, to ensure that the necessary information is available with the application
2) The mechanism to control the use of the power station under ?air mode?.
One additional matter I wish to raise further to the discussion on item 2) above is your consideration of the National Policy Statements. At the meeting we gave advice in relation to your reliance on the Energy Act 2013 legislation to limit any operation in ?air mode? to 6 months, notwithstanding your advice that the primary purpose of air mode is to enable start up to ?oxy-mode?. We advised that you explicitly cover how the Energy Act would act as a mechanism for limiting such operation, particularly in relation to the Habitats Regulations issues discussion, and also in general.
Having discussed the issue further following the meeting, I also wish to advise you to test your application against the National Policy Statements prior to submission to ensure you are consistent with the policy on carbon capture for coal fired power stations. In particular, please the NPS EN-2 for Fossil Fuels Electricity Generating Infrastructure paragraphs 2.3.6 ? 2.3.12.
We are happy to discuss this further and do contact the team if you wish to do so.