Carbon Capture Ready consultation

I was asked to put together a response to question 15 of the governments CCS consultation.

Here's what I wrote - it's not exactly brief.

What might be the impact of the potential costs of CCR [carbon capture ready] for 100% biomass power plants and so the implications for their future build? Should the Government explore excluding 100% Biomass schemes from the proposed Article 32?

The implication of a CCR requirement is that the plant will, one day, be required to fit CCS technology.
As a fuel biomass contains more hydrogen and oxygen than coal – meaning that it contains much less carbon (perhaps only 45% for Switchgrass whereas a bituminous coal may contain 85% carbon). Equally the calorific value of biomass is normally lower than that for coal. BCURA report a calorific value of approx 34 Mj/Kg for Pittsburgh No. 8 (daf basis), whilst Bridgeman et al (2007) report a value of around 17 Mj/kg for switchgrass.
This suggests that the flue gas coming from a 100% biomass plant is likely (on a constant energy out basis) to not only be of substantially greater volume (perhaps twice the volume) but also to be of lower CO2 intensity. Both these factors will combine to make CCS with amines more difficult and expensive.
As such it is likely that the cost associated with any CCS (and therefore by extension CCR) requirement for 100% biomass plants would be – when compared against the cost of the plant – greater for a biomass plant than for a coal fired plant.

This suggests that power generation companies may choose to spend their capital by investing in co-firing facilities (where the small biomass component will have a marginal effect on the CO2 stream) rather than dedicated biomass plants.
This decision will of course be influenced by many other parameters (including the RO) upon which I don’t feel qualified to comment.

I know of 5 reasonably sized proposed / existing 100% biomass plants in the UK. Lockerbie (44MW, Eon), Ely (38MW, EPR), Sheffield (Proposed 25MW, Eon), Bristol (Proposed 150MW, Eon), Port Talbot (Consented / Under construction 350MW, Prenergy Power).
I would suggest that to date there is no conclusive evidence as to the optimum size of a 100% biomass power station (largely it depends on what fuel can be made to be available). As such any requirement for 100% biomass plants to be CCR (and by extension for future CCS) may have the effect of limiting the size of such plants to sub 300MW.
As such it is probably desirable for the government to investigate excluding 100% biomass plants from the mandatory CCR requirement.

This assumes that 100% biomass plants continue to be seen as carbon neutral whereas they should probably be seen as low carbon (especially the Port Talbot and Bristol 100% biomass plants which may emit large quantities of green house gasses in the transport of their fuel from North America).