Ms Rebecca KnightonPeak District National Park Authority
Aldern House
Baslow Road
Bakewell
Derbyshire DE45 1AE
planning.service@peakdistrict.gov.uk
Dear Ms Knighton
I am writing on behalf of Hope Valley Climate Action to comment on planning application NP/HPK/1020/0929, for permission to construct additional facilities at Hope Cement Works for unloading and storing imported shale substitute, as well as permission to increase the tonnage of imports.
Hope Valley Climate Action has been established to campaign for effective action to address climate change. It consists of individual village and themed action groups, with overall coordination provided by a Support Group. Our aims are to raise local awareness of climate change and related issues, encourage people and organizations locally to change behaviour so as to reduce carbon emissions, and to lobby for change in the wider world. An application for charitable status is under consideration by the Charity Commission.
Overall context
We recognize that the Hope Cement works is by far the largest source of greenhouse gases (GHG) locally, being responsible for emitting almost 1.2 million tonnes of CO2 in 2019. For it to continue to operate in the way it currently does is therefore incompatible both with the UK legal obligation to reach net zero emissions by 2050, as well as a more general moral obligation to eliminate emissions for the sake of the future of life on the planet. Our understanding is that the permit to operate currently extends to 2042, but we do not believe that this should be interpreted as giving licence to continue to emit CO2 at the current rate until that date. Rather, we believe that consideration needs to be given urgently to ways in which the emissions can be reduced dramatically over a much shorter timescale.
There is consensus that achieving net zero by 2050 will require dramatic reductions in emissions now. The Government has recently set out an ambition of reducing UK emissions by 68% by 2030 in comparison with 1990 levels. We think the reduction in emissions at Hope Cement Works should be commensurate with this. We note in passing that the overarching trade body, the Mineral Products Association, has produced a ‘Road map to beyond net zero’, but this is dependent on the introduction of carbon capture and storage from cement plants, which is a technology that is as yet unproven.
The enormous emissions of carbon dioxide from cement manufacture derive almost entirely from the manufacturing process itself. The carbon emissions attributable to the transport of raw materials are only just over 0.1% of the total. For this reason, the changes in practices planned by Breedon, which are dependent on the changes for which permission is being sought, will have a tiny impact on their overall emissions, so long as the overall amount of cement produced does not increase as a consequence.
Hope Valley Climate Action does not, therefore, object to the application made. We do, however, note that there are some elements of the proposed building works, and changes in practice that will follow, that have the potential to impact on carbon emissions, and we request therefore that conditions are applied to any permission given, as described below.
Construction works
The construction works are said to be expected to take 18 months, and will clearly necessitate the importation of raw materials onto the site. The expectation appears to be that this will come in by road. We think that as much as possible ought to be imported by rail, since this generates significantly less CO2 per tonne moved, and request that an ambitious requirement should be set for the minimum proportion of the overall tonnage imported to be brought in by rail.
Further, we believe that a detailed analysis of the carbon dioxide emissions caused by the construction should be carried out, and proposals put forward by Breedon as to how they will minimise these, ideally to carbon neutrality.
Import of raw material (ARM)
We welcome the intention to import ARM by rail, rather than road, but note with concern that Breedon wish to continue to use their rights to import by road in the event of blockage or difficulty importing by rail. In light of the significantly higher carbon emissions generated by road transport rather than rail, we do not think this is justified, and request therefore that as a condition of the approval of this application, this permission is rescinded.
The Hope Valley rail line, and the branch line to the plant, are not electrified. Electrification of the Hope Valley line could significantly reduce, potentially almost eliminate, carbon emissions associated with transport of raw material by rail, as well as having other benefits in terms of air quality, etc. We believe that a significant increase in tonnage of raw materials moved on the line adds force to the argument for electrification of the line, and therefore request that a condition of the approval of this application should be that Breedon work with the relevant rail authorities to produce, within a short time period to be determined, a costed proposal for the electrification of the Hope Valley line, with the necessary investment made available. We recognize that there are significant technical issues that would need to be overcome, including the headroom in tunnels, but nevertheless believe that this is a challenge that has to be met.
Reducing greenhouse gas emissions from the plant
Although the requested changes to practice do not significantly impact on the overall greenhouse gas emissions from the plant, they do nevertheless provide an opportunity to commit to exploring ways in which emissions may be reduced, and to set out plans to do that. We recognize that this is perhaps more of a matter for the wider industry, rather than the Hope Cement Works alone, but we would nevertheless want to see a serious exploration of ways in which emissions could be reduced rapidly, with the Hope works acting as a trailblazer for the wider industry. In this context we are aware not only of the MPA report referenced above, but also the EU funded LEILAC (Low emissions intensity lime and cement) project and the International Energy Authority Technology Roadmap on low carbon transition in the cement industry, which is advocating a similar approach.
We therefore request that a condition of approval of the application should be that Breedon commit to reducing the carbon emissions from the Hope works in line with the Government target by the end of 2030, and draw up plans to do so by the end of 2021. We would be very pleased to work with them on these plans.
Carbon offsetting
Carbon offsetting is never going to eliminate the need dramatically to reduce greenhouse gas emissions. (To offset 1.2M tonnes of CO2 would require approximately 1.2M trees to be planted and allowed to grow for 100 years, and the carbon then captured in the wood sequestered so that it is not re-released to the atmosphere. This would need to be done each year, for each year’s output of 1.2M tonnes of CO2!) Nevertheless, there is merit in planting as many trees as possible, and it appears to us that the amount proposed is very modest in the context of the amount of land managed by Breedon. We therefore request that a condition of the approval of this application is that Breedon commission a landscape design study to explore options for increased tree cover and biodiversity on the site, with the intention of planting 1000 trees of a suitable species mix per year during their continuing management of the site. (This number of trees, if grown to maturity, would approximately offset the carbon emissions due to transportation in and out of the site.) Again, we would be willing to explore with Breedon working jointly with them on this.
Summary of conditions requested
- That an ambitious requirement should be set for the minimum proportion of the overall tonnage of construction materials imported to be brought in by rail.
- That a detailed analysis of the carbon dioxide emissions caused by the construction should be carried out, and proposals put forward by Breedon as to how they will minimise these, ideally to carbon neutrality.
- That permission to import shale substitute by road in the event of blockage or difficulty in importing by rail, is rescinded.
- That Breedon work with the relevant rail authorities to produce, within a short time period to be determined, a costed proposal for the electrification of the Hope Valley line, with the necessary investment made available.
- That Breedon commit to reducing the carbon emissions from the Hope works by 50% by the end of 2030, and draw up plans to do so by the end of 2021.
- That Breedon commission a landscape design study to explore options for increased tree cover and biodiversity on the site, with the intention of planting 1000 trees of a suitable species mix per year during their continuing management of the site.
Planning Committee
Please could you send us details of the planning committee at which this application will be considered? We would like if possible to be able to address that committee.
Yours sincerely
Dr Jeremy Wight, Chair
Hope Valley Climate Action
