HVCA Response to Peak Cluster Phase 1 Consultation

HVCA’s view is that there is an urgent need to decarbonise the cement industry in general, and the Hope Cement works in particular. This must be done in the context of a concerted move to reduce the amount of cement used. Demand reduction cannot wait for CCS to be proven, and CCS cannot be used to justify business as usual. We cannot say whether the particular proposals put forward by
Peak Cluster represent the best way to achieve decarbonisation unless and until a comprehensive cradle-to-grave Life Cycle Assessment of GHG emissions is completed and made publicly available, and until there is clear evidence that government policy will drive the substantial reductions in cement demand that are essential alongside any technological fix. The project should not move beyond the consultation phase until this happens.

Hope Valley Climate Action (HVCA) was established to raise awareness, take local action, and advocate for policies to address the climate emergency. As a local climate action charity, our response addresses the broader climate implications of the Peak Cluster proposals rather than the specific pipeline route.

Carbon dioxide emissions from cement manufacture account for a high proportion of greenhouse
gas (GHG) emissions worldwide, reflecting the widespread use of cement and concrete. The elimination of GHG emissions, as quickly as possible, is essential to address the climate emergency and avoid climate breakdown. Cement manufacture represents a very particular problem, because CO2 generation is inherent in the chemistry of cement manufacture. Even with fully decarbonised
electricity, it is not possible to produce conventional cement without generating CO2.

HVCA has always been aware that by far the largest local producer of GHG is the cement works in Hope. We have in the past collaborated with others within the Derbyshire Climate Coalition to produce a position paper on decarbonising the cement and lime industries. This argues for active exploration of ways to reduce our use of conventional cement, through a combination of repurposing buildings rather than demolition and rebuilding, the development of low carbon cements, and the use of alternative building materials. HVCA remains strongly of the view that these avenues must be pursued with urgency and reducing overall demand for conventional cement must be a national
priority. Carbon capture and storage (CCS) must not be seen as a substitute for urgent action to reduce material use, improve building standards, incentivise reuse, and accelerate the development and adoption of low-carbon alternatives. Decarbonising cement requires multiple routes pursued simultaneously.

HVCA is mindful of the risk that significant capital investment in CCS infrastructure could create commercial pressure to sustain or increase cement production levels over time or extend the plant’s operating life beyond existing permissions. CCS cannot be used to justify business as usual. Buildings, roads, and infrastructure built with cement lock in patterns of energy use, transport, and land use for decades; capturing kiln emissions while maintaining or increasing production volumes is not compatible with the urgent systemic change the climate emergency demands.

Even with ambitious demand reduction and reform of construction practices, cement production is expected to continue for some years. This means that there is a particular urgency to find ways inwhich the emissions from existing lime and cement plants can be mitigated. The Hope Cement works, the largest in the UK, has an operating licence to 2042 and will continue to release 1.2MT of CO2 to the atmosphere annually unless action is taken. Both the Climate Change Committee and the UN Intergovernmental Panel on Climate Change see carbon capture in ‘hard to abate’ industries, which includes cement manufacture, as part of the pathway to net zero. However, with
the technology still largely unproven and the real costs unclear, alternatives must continue to be considered.

Because of the catastrophic implications of uncontrolled global heating, and its contribution to connected nature and biodiversity crises, the critical first question regarding the Peak Cluster proposals is what the net impact will be on overall GHG emissions. If successful, the process may capture a high proportion of the CO2 generated by cement and lime manufacture, and if successfully stored, avoid its release. Against this benefit, however, must be considered the carbon cost of the manufacture of the carbon capture plant and pipeline, as well as the considerable energy requirements for running the process.

We understand that a formal, detailed carbon accounting has not yet been undertaken, and will only be available as part of Stage 2 of the Environmental Impact Assessment, expected to be completed at the end of 2026. Detailed cradle-to-grave Life Cycle Assessment of GHG emissions must take into consideration the realistic effectiveness of the carbon capture as well as the probability of achieving long term storage without loss. This Life Cycle Assessment should be independently verified, transparent, and publicly available, and must include clear and justified assumptions. In the absence of such evidence, HVCA cannot determine a position on the proposals at this stage.

We are aware that the construction and running of a carbon capture plant at the Hope Cement works site, and the construction of the pipelines, would have considerable short term implications, including environmental ones. These impacts must be mitigated as much as possible, and we will certainly want to engage with Breedon and Peak Cluster to ensure that local nature damage,
including to local biodiversity, is minimised if the project progresses beyond consultation. While uncontrolled global heating represents a far greater systemic risk, this does not remove the obligation to avoid, minimise and fully mitigate damage to local habitats and landscapes.
Biodiversity impacts must be transparently assessed and made publicly available.

In conclusion, HVCA’s view is that there is an urgent need to decarbonise the cement industry in general, and the Hope Cement works in particular. This must be done in the context of a concerted move to reduce the amount of cement used. Demand reduction cannot wait for CCS to be proven, and CCS cannot be used to justify business as usual. We cannot say whether the particular proposals put forward by Peak Cluster represent the best way to achieve decarbonisation unless and until a comprehensive cradle-to-grave Life Cycle Assessment of GHG emissions is completed and made publicly available, and until there is clear evidence that government policy will drive the
substantial reductions in cement demand that are essential alongside any technological fix. The project should not move beyond the consultation phase until this happens.

Submitted on behalf of Hope Valley Climate Action trustees
26 February 2026
Contact: Davina Ripton, HVCA Co-Chair
Email: Info@hopevalleyclimateaction.org.uk

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