1.  * Greenpeace believes that the single greatest threat to the climate comes from burning coal. Coal-fired power generation is historically responsible for most of the fossil-fuel CO2 in the air today—about half of all fossil-fuel carbon dioxide emissions globally.

  (Dr. James E. Hansen, open letter to Gordon Brown, December 2007. http://www.greenpeace.org.uk/blog/climate/letter-to-the-prime-minister-20071219)

  2.  * The carbon intensity of coal explains why coal-fired power generation is the most environmentally damaging means of generating electricity. Burning coal is more damaging in climate terms than using oil or gas. Supercritical coal plants emit 710gCO2/Kwh compared to 404gCO2/Kwh for CCGT, for example. (IPCC Working Group III Fourth Assessment Report chapter 4 table 4.9)

  3.  * As the eminent climate scientist Dr. James E. Hansen, director of the NASA Goddard Institute for Space Studies, stated: "The only practical way to prevent CO2 levels from going far into the dangerous range, with disastrous effects for humanity and other inhabitants of the planet, is to phase out use of coal except at power plants where the CO2 is captured and sequestered." (Hansen, Testimony to the State of Iowa, 2007 http://www.columbia.edu/~jeh1/IowaCoal_071105.pdf)

  4.  * The Business Secretary, John Hutton, is currently considering whether or not to approve plans for an entirely unabated 1.6GW supercritical coal-fired power station at Kingsnorth in Kent that will emit around 9 million tonnes of CO2 per year[22]. E.ON's proposal for Kingsnorth is the first proposed coal plant in the UK for three decades. However, similar proposals for unabated supercritical coal plants are now being considered by a number of other utilities for at least another six sites: Tilbury, Blythe, Ferrybridge, Longannet, Cockenzie and High Marnham.

  5.  * Greenpeace is concerned that approval of the fleet of proposed new unabated coal stations—totaling 10.6 GW of additional capacity—will severely undermine the UK's efforts to meet existing carbon reduction targets in response to climate change. Further, if—as seems likely—the UK targets are revised in the light of the most recent climate science, from 60% overall reductions by 2050 to 80% by 2050, then Greenpeace estimates that the presence of this many unabated new coal fired power stations will account for half of the UK's entire annual carbon budget[23], putting considerable pressure on all other sectors of the economy to compensate for the emissions resulting from coal generation.

  6.  * The review into the economics of climate change conducted by Professor Nicholas Stern said:

"It is critical that governments consider how to avoid the risks of locking into a high-carbon infrastructure, including considering whether any additional measures may be justified to reduce the risks"[24]

  7.  The high emissions from any new coal plants would gravely undermine progress towards emission targets under the Climate Change Bill, and lock the UK into a high-carbon pathway for many decades.

  8.  * As CCS is not yet commercially proven, Greenpeace is concerned that the new coal-fired plant at Kingsnorth is being sold by BERR and E.ON as "capture ready".[25] In private, the company is more sceptical. In an email E.ON sent to officials at the Department of Business on 16 January 2008, they said that CCS technology at Kingsnorth "obviously ... has no current reference for viability at any scale."[26]

  9.  EON's competitor RWE has also sought to cast doubt on the immediate viability of the technology. In response to local opposition to its plans to apply for a new supercritical coal plant at its site in Blythe, Northumberland, RWE is quoted by the local media conceding that "proving this technology is a long way off"[27].

  10.  Even if the technology is technologically proven, question marks over its commercial viability will remain. Fully functional CCS retrofit will reduce the efficiency of the plant, which in turn will increase the cost per kilowatt hour of generation. Compounding this, investors will likely demand a large premium to compensate for the high risk and uncertainty of the long term performance of a new, still relatively unproven technology. The necessary price under the ETS to deliver this sort of risky investment therefore is extremely high. Investment bank Climate Change Capital has estimated that the range of carbon prices necessary within the ETS to ensure the cost effective retrofit of CCS range from 90-155 Euros/Tonne CO2[28]. To put this in to context, the most recent forecasts from Deutsche Bank now estimate a 2020 carbon price of 67 euros per tonne[29].

  11.  * Greenpeace believes proposals to approve new coal stations that are "capture ready" are a dangerous distraction from the significant risk they pose to the climate and the taxpayer. CCS technology has not yet been proven at scale on an integrated power plant and CCS may well prove not to be technically or economically feasible. Building "capture ready" stations now would therefore impose unacceptable risks both to the climate and to the taxpayer, who may well be trapped into footing the bill for any future CCS retrofit.

  12.  * The Government's apparent attempts to conflate the approval of new coal plants with the competition to fund a carbon capture and storage demonstration are a cause for concern. If E.ON wins the competition with a view to demonstrating the technology at Kingsnorth, the 300MW capacity envisaged by the competition will represent little more than one sixth of the overall capacity of the plant. Any demonstration plant that is established should not be used as an excuse to build plants that operate mainly as unabated coal plants, and should therefore focus solely on exploring technical feasibility and full price discovery at an appropriate scale, and should be fully equipped with CCS abatement. Safe, responsible storage of captured carbon dioxide emissions would also be essential components, ensuring that the lifetime oversight of waste CO2 is guaranteed.

  13.  * Whilst it is clear that CCS is years away from viability on any significant scale, renewable energy and energy efficiency can close the so-called "energy gap" right now, thereby improving the UK's energy security and slashing our climate change emissions. Greenpeace is united with WWF, FoE and the RSPB in the view that the absolute priority for UK energy policy should be the sustainable delivery of the EU target for renewable energy in 2020 and the aggressive promotion of energy efficiency measures.

  14.  * With regards to securing our energy future, research commissioned by Greenpeace and conducted by energy consultancy Poyry has identified a potential for 16GW of currently untapped electricity generation potential at sites of industrial heat demand around the UK. In terms of securing the UK's future energy supplies, exploiting opportunities to meet demand for heat and electricity in the most efficient way possible should be prioritized. High carbon, inefficient plants should be ruled out.

  15.  * Greenpeace is also united with WWF, FoE and the RSPB in support for new legal standards that set a limit for greenhouse emissions per kilowatt hour produced for all new generating plant which has yet to secure planning consent. A similar policy is already successfully in force in the State of California. A UK standard should be set at 350g/kWh, a level which could be achieved by an efficient gas-fired power station which makes some use of waste heat. The standard should be tightened significantly if CCS technology is proven to be technically and economically viable. Equally, given the urgency of the climate change challenge, it will be important to apply an emission limit to existing stations from 2020, or earlier if plant undergoes significant upgrade.

2 June 2008

http://ccs-association.com/docs/2008/23%20April%202008/2%20Tony%20White%20-%20Climate%20Change%20Capital%20%20%2023%20April%202008.ppt

http://uk.reuters.com/article/environmentNews/idUKL3049225320080530

23   In December 2007, Gordon Brown said he aspired to an 80% cut in emissions by 2050. That would give us a carbon budget of 117.8mt/CO2/per year. The new coal plants currently proposed-10.6 GW of capacity-would emit more than 54 million tonnes of carbon dioxide which represents almost half of that quota. (10.6 GW x 7884 hours of generation per year, assuming 90% operational = 83.57 TWH/y. 83.57 TWH/y x 0.65 = 54 mt/CO2/y) Back

24   Stern Review on the Economics of Climate Change-Professor Jonathan Stern, October 2006 Back

25   "capture ready" essentially means a plant that is able to incorporate CCS should the technology ever become safe and commercially viable in the future Back

26   Emails obtained by Greenpeace under the Freedom of Information Act-available to view at www.greenpeace.org.uk/coalsecrets Back

27   "Another question mark on carbon"-The New Castle Journal, 23 May 2008 Back

28   Research conducted by Climate Change as part of the Zero Emissions Platform project sponsored by the European Commission. See: Back

29   "Deutsche ups EU carbon price to 40 Euros"-Reuters News Agency quoting Mark Lewis, Deutsche Bank Carbon Analyst, 30 May 2008. See: Back