Carbon capture: open letter to the Scottish Government

We were disappointed to receive your short e-mail (‘This is a live application and it would be inappropriate to make detailed comment. A determination on the application will be issued in due course.’) in response to our letter to ministers during our attempt to get heard by decision makers on November 7^th 2024.

However, we do realise this is probably government policy in some way.  

Therefore, we are writing a more detailed letter to which we hope we receive a longer response.

Whilst the Peterhead Gas Plant proposals might be a ‘live application’ as you state, we are concerned  about the limited variety of input the government received from scientists and financial experts outside the fossil fuel industry.  We worry that ministers might have been overly influenced by lobbyists and made an ill-informed decision about Peterhead. Therefore, though it is ‘live’ it may still benefit from further input.

In particular we are concerned about the addition of a Carbon Capture Storage facility as a way of neutralising the carbon emissions of the additional gas plant.

Carbon capture at Holyrood

We are concerned not only about the new Peterhead gas plant with its proposed Carbon Capture facility, but also more generally about the Carbon Capture happening in the Scottish Parliament.  The fossil fuel industry with its immense financial clout, invasive lobbying tactics and natural self-interest in profit, has captured even the International COP process. For the second year running, the COP presidency itself was facilitating oil deals!

With such high level carbon capture at the international level, we are therefore not seeking to shame the Scottish government for its gullibility.

At the UK level we know for example, as reported in the Guardian in October this year that ‘the UK government’s move to award £22bn in subsidies to carbon capture projects followed a sharp increase in lobbying by the fossil fuel industry.’ Equinor alone we know  attended 16 meetings.

In fact, during a call in December with three Equinor executives, one of the company’s team told the then director of the Department for Energy Security and Net Zero (DESNZ), that Equinor “appreciate[d] the … collaborative approach to policy development”.

In contrast, researchers, climate advocacy groups and local councils were hardly represented. The transparency records show that no individual organisation from these sectors has attended more than three meetings with ministers on carbon capture since the start of 2020.

In the Scottish parliament similarly, we see both SSE and Equinor (the Peterhead proponents) lobbying with gusto – Equinor especially at the COP conferences and SSE being amongst the 4 companies who together successfully pursued MSPs nearly 400 times.

Given that during an average working week at the Scottish Parliament fossil fuel companies were meeting over six MSPs, well above one every working day, it is unsurprising that their efforts bear fruit.

Independent advice

We urge the Scottish Parliament to actively seek a balance of views.  Obviously the fossil fuel industry has had its say with ministers.   In the interests of the Scottish people and (in view of a responsibility towards climate mitigation) the whole world, we ask that for every fossil fuel lobbyist, there is an equal and balancing independent scientist, or  knowledgeable relevant research body from civil society to check the self-interest of the fossil fuel industry.

To be clear, we do not assume that the Scottish government are taking bribes.  We just assume that given the long established and sophisticated PR strategies of the fossil fuel industry, it is wise for the government to be cautious when listening to Equinor and SSE tell stories about themselves.

We note the following worrying aspects around the new proposed gas plant with its carbon capture attachment and urge caution:

Likely emissions have been under reported

New research has revealed that the climate emissions from the proposed Peterhead CCS gas station could be five times higher than developers SSE and Equinor have disclosed to your government in their planning application; estimating that the plant could cause an additional 1 million tonnes of CO2 each year than the developers claim.

The emissions from the proposed plant would have a “major adverse impact” on Scotland’s carbon budget, forcing other sectors of the economy to reduce emissions much more rapidly, and that the plant would continue burning fossil fuels for 14 years after Scotland is due to reach net-zero.

The Environmental Impact Assessment is defective

In light of the Sarah Finch Supreme Court case on Scope 3 emissions and the current court case on the same matter vis-à-vis Equinor in the Rosebank court case, we note it would be wise for you to instruct the developers to submit a new Environmental Impact Assessment, that addresses emissions excluded from the original EIA: namely the project’s upstream emissions (from the extraction and transportation of the gas to be burned at the power station); emissions during periods when the carbon capture plant is off for maintenance and outages; and an assessment of more realistic capture rates – noting that a 95% capture rate has never been achieved on a gas plant anywhere in the world.

Carbon Capture is expensive and inefficient

Institute for Energy Economics and Financial Analysis found that carbon capture was inefficient, and that has a very troubled history of cost overruns and delays.

‘Carbon capture and storage (CCS) is an expensive and unproven technology that distracts from global decarbonization efforts while allowing the oil and gas industry to conduct business as usual.

According to both the IPCC and International Energy Agency, we already hold the key to most CO2 mitigation: Renewable energy, energy efficiency, and eliminating fugitive methane emissions can address more than 80% of the world’s decarbonization requirements by 2030. CCS, even if its technical deficiencies can be overcome, can only provide minimal contribution to decarbonization. CCS does not deserve the equal billing that fossil fuel preservationists are giving it next to proven solutions. ‘

“Proponents of [CCS] projects are selling an unproven dream that in all likelihood will become a nightmare for unsuspecting investors.” Dennis Wamsted, Energy Analyst, IEEFA

Equinor’s Norwegian Carbon Capture and Storage units are not doing as well as they maintain.

Equinor presents itself globally as having built successful (small) carbon capture facilities in Norway.  However, extensive analysis of Equinor’s Sleipner and Snøhvit carbon capture facilities in Norway, casts serious doubt in particular over the viability of preventing CO2 escaping from the storage areas.

‘Sleipner and Snøhvit, rather than serving as entirely successful models for CCS that should be emulated and expanded, instead call into question the long-term technical and financial viability of the concept of reliable underground carbon storage. They cast doubt on whether the world has the technical prowess, strength of regulatory oversight, and unwavering multi-decade commitment of capital and resources needed to keep CO₂ sequestered below the sea – as the Earth needs – permanently.’

The presentation slide deck is available here.

Scotland holds power and leadership in its renewables: carbon capture is a distraction

We note that the Scottish government itself in an Update on Scotland’s renewables and wind power potential written on November 14 2023 details the enormous renewable potential of Scotland, punching way above its weight compared to the rest of Britain or even Europe, stating in summary : ‘Scotland has enormous strengths and huge potential in renewable electricity generation, and in particular wind power. With the right support in place, renewables and wind power will drive decarbonisation and sustainable, low carbon economic growth in support of Scotland’s transition to Net Zero.’

The same article states:   ‘Expanding onshore and offshore wind in Scotland could also have substantial economic benefits. In recent analysis,  estimates that renewable electricity production could support over 33,000 direct and indirect jobs by 2030 and generate £4.2bn GVA. Over 28,000 of these jobs and £3.6bn in GVA are from onshore and offshore wind.’

It would seem that Scotland does not need gas plants with or without so-called carbon capture.

Similarly, on the website Scotland.org in an article in February this year, the renewable potential of Scotland is detailed and extolled.  Gas plants and carbon capture get no mention at all.

In view, therefore, of the likely bias introduced by effective self-interested lobbying by both SSE and Equinor, the dearth of independent advice, and in the context of a Scotland moving into the fossil free era holding extremely strong cards, we ask the Scottish government to have a sensible rethink of Peterhead gas plant and carbon capture facility as it is likely to be a very, very expensive red herring in what otherwise appears to be Scotland’s sensible energy mix for the 21^st century.

In expectation of a response,

Extinction Rebellion, Scotland