Comment for planning application SCC/0045/23SE

Application number
Name
Address
York House 23 Kingsway London WC2B 6UJ
Type of Comment
Comments
The Association for Renewable Energy & Clean Technologies (REA) is writing to register support for the following planning application. SCC/0045/23SE Construction and operation of an anaerobic digestion facility, associated infrastructure and new access road, connecting pipeline and covered digestate lagoons. Land to the north of Spring Grove Farm, Withersfield, Suffolk, CB9 7SW The REA represents industry stakeholders from across the sector and includes generators, project developers, heat suppliers, investors, equipment producers and service providers. Members range in size from major multinationals to sole traders. There are over 500 corporate members of the REA, making it the largest renewable energy trade association in the UK. A number of our members are particularly interested in anaerobic digestion plants and biomethane production pathways. We are writing to show our support for this application of our member Acorn Bioenergy, but also based on a need for the UK to meet net zero commitments and the contribution this application could have to support of the Governments energy strategies and targets. Anaerobic digestion plants are operated to create a biogas through the breakdown of organic matter into carbon dioxide, methane and water. The biogas generated can be used for energy generation creating electricity through CHP units or upgraded to biomethane gas which contributes to decarbonise the energy system and particularly the gas grid. Anaerobic digestion can contribute to the provision of a sustainable national energy security, particularly in light of recent impacts from the Russian war in the Ukraine as well as rising energy costs. Biomethane production can also be used to decarbonise the transport sector, with some plants already supporting the generation of biofuels to help meet Renewable Transport Fuels Obligations (RTFO). The process also creates a digestate `by-product` which is used in place of synthetically produced fertilisers or soil conditioners needed due to soil and nutrient erosion. This can not only help to reduce the need for costly chemicals but also provide carbon savings. In addition, feedstocks make use of waste material with current support schemes requiring a minimum of 50% of waste food and crops. The volumes of feedstock that will require processing is expected to increase significantly with the change to mandatory food waste collections for local authorities, as detailed on the link Government response - GOV.UK (www.gov.uk) and extracted below `Government's preference is for food waste to be collected for treatment by anaerobic digestion (AD), which presents the best environmental outcome for the treatment of unavoidable food waste, due to the generation of biofuel and digestate. This digestate can be spread to land, ensuring nutrients are recycled, creating a more circular economy` This is also an important route for waste material collected through government targets to recycle 65% of municipal waste by 2035 along with the plans for near elimination of biodegradable waste to landfill from 2028. Call for Evidence: Near elimination of biodegradable waste disposal in landfill from 2028 - Defra - Citizen Space The REA welcomed the publication of the Government's Biomass strategy in August 2023. In the strategy, biomethane production injected into the gas grid was reported at 6.2TWh in 2022 but with increased targets set of 8TWh by 2030 and 30-40TWH by 2050. Biomass Strategy 2023 - GOV.UK (www.gov.uk) The Biomass Strategy reported that `analysis indicates which elements of the whole could be prioritised for biomethane production in 2035 and 2050. Across the three modelled 2050 pathways and the Carbon Budget Delivery Plan scenario for 2035, feedstocks such as food waste, slurries and manures, sewage sludge, and the upgrade of landfill gas, are prioritised for biomethane production via AD. As biomethane can be used flexibly across many different end-uses, it has the potential to help decarbonise multiple distinct sectors`. The capture of CO2 is a feature of the Land to the north of Spring Grove Farm plant planning application. The biomass strategy also states the value on the process of upgrading biogas to biomethane where biogenic carbon dioxide is removed and either repurposed or captured for storage, also known as BECCS. The strategy also states that, `Capturing the biogenic CO2 removed from biogas as part of the upgrading process to biomethane can result in even greater carbon savings. This upgrading process generates a relatively pure stream of CO2, in comparison to other sources, that can be efficiently captured, and the technology to do so is currently being deployed on AD biomethane plants. In the future, this CO2 could either be geologically stored, with the potential to deliver negative emissions as a form of BECCS (Chapter 6) or treated for CO2 usage markets across a variety of sectors including agri-food and construction. Given the dispersed location of AD plants across the country and the need to diversify and secure sources of food-grade CO2 supply, much of the focus on AD CO2 capture has been to potentially service the agri-food utilisation market`. Furthermore, there would be a locational benefit of an anaerobic digestion plant to the community, not only in terms of providing a nearby route for waste food material collected from both residential and commercial properties, but also by providing green employment, in often rural areas where there may be a decline in industrial and agricultural employment. The construction and operation of anaerobic digestion is well practiced in the UK, with a wealth of industrial knowledge. Health and safety standards are maintained, with certifications schemes in place to ensure ongoing compliance. This is also considered through environmental management and operational considerations. In conclusion, to ensure that we are able to meet a sustainable future for agriculture and waste management whilst also meeting the policy objectives set by the government, anaerobic digestion will be needed in the future to decarbonise and help transition to net zero. For the reasons provided above, we submit this letter to support the planning application at Land to the north of Spring Grove Farm and ask that you consider approval.
Received
Attachments