Our submission to the Scottish Government Energy Consents Unit regarding the Peterhead gas fired power station project.

Friends of the Earth Scotland is calling on Scottish Ministers to reject the application by SSE Thermal Generation (Scotland) Ltd for the Peterhead Project (ECU00003433).

Climate science is clear that use of fossil fuels must be rapidly phased out if we are to meet the critical 1.5oC threshold enshrined in the Paris Agreement, and the principles of equity under the UN Framework Convention on Climate Change require that rich, historical polluters like Scotland act fastest to curb emissions.

Scotland’s 2019 Climate Change Act establishes in law the concept of a “fair and safe Scottish emissions budget”. Extrapolating from remaining global carbon budgets for 1.5oC and 2oC, leading climate scientist Professor Kevin Anderson has made clear that such a budget “is inconsistent with any realistic interpretation of the roadmaps of CCS-based power generation”.

There is a clear historic failure of delivering Carbon Capture and Storage – which this application relies on – at the capture, transportation and storage stages of the process. The proposed development assumes highly optimistic capture rates and timeframes for operation which are not backed up by the evidence. The knock on impact of failure to deliver projected capture rates on our ability to meet climate targets is too high a risk to approve this development.

The minor and short term benefits of the proposed project are far outweighed by the real risk that it could pose to Scotland exceeding its constrained carbon budgets. Furthermore, research shows that renewables and energy efficiency offer far better value for money in terms of job creation than fossil fuel generation.

This development does not clearly have national development status under the current National Planning Framework (NPF3) since it is for a new power plant rather than retrofit of the existing power station at Peterhead. The draft NPF4, due to be finalised in the coming months, demonstrates a substantial shift in Scottish Government policy that should rule out this development on the basis that it does not “demonstrate decarbonisation at pace”, it could potentially “be used to justify unsustainable levels of fossil fuel extraction or impede Scotland’s just transition to Net Zero,” and it is not clear how it will “ensure the highest possible capture rates in the deployment of these technologies”.