APPENDIX B: TECHNICAL BRIEFING NOTE ON REVISED CCR ... - Scottish Power · DHC2 Environmental...

26
DHC2 Environmental Information Report 18-May-15 APPENDIX B: TECHNICAL BRIEFING NOTE ON REVISED CCR FOOTPRINT

Transcript of APPENDIX B: TECHNICAL BRIEFING NOTE ON REVISED CCR ... - Scottish Power · DHC2 Environmental...

DHC2 Environmental Information Report 18-May-15

APPENDIX B:

TECHNICAL BRIEFING NOTE ON REVISED

CCR FOOTPRINT

DAMHEAD CREEK 2 CCGT POWER STATION SECTION 36 CONSENT VARIATION

ENVIRONMENTAL INFORMATION REPORT

Technical Briefing Note on Revised Carbon Capture Readiness Footprint

May 2015

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 May 2015

REVISION SCHEDULE

Rev Date Details Prepared by Reviewed by Approved by

1 May 2015 Final Julian Schlosser

Richard Lowe

Director

Richard Lowe

Director

AECOM Infrastructure & Environment UK Limited 2 City Walk, Leeds, LS11 9AR, UK Tel. +44 (0) 113 2045000 www.aecom.com

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 May 2015

Limitations

AECOM, operating through its wholly owned subsidiary AECOM Infrastructure & Environment UK Limited (hereafter referred to as AECOM) has prepared this Report for the sole use of Scottish Power (“Client”) in accordance with the Agreement under which our services were performed, dated 11th March 2015). No other warranty, expressed or implied, is made as to the professional advice included in this Report or any other services provided by AECOM. This Report is confidential and may not be disclosed by the Client nor relied upon by any other party without the prior and express written agreement of AECOM.

The conclusions and recommendations contained in this Report are based upon information provided by others and upon the assumption that all relevant information has been provided by those parties from whom it has been requested and that such information is accurate. Information obtained by AECOM has not been independently verified by AECOM, unless otherwise stated in the Report.

The methodology adopted and the sources of information used by AECOM in providing its services are outlined in this Report. The work described in this Report was undertaken between April and May 2015 and is based on the conditions encountered and the information available during the said period of time. The scope of this Report and the services are accordingly factually limited by these circumstances.

Where assessments of works or costs identified in this Report are made, such assessments are based upon the information available at the time and where appropriate are subject to further investigations or information which may become available.

AECOM disclaim any undertaking or obligation to advise any person of any change in any matter affecting the Report, which may come or be brought to AECOM’s attention after the date of the Report.

Certain statements made in the Report that are not historical facts may constitute estimates, projections or other forward-looking statements and even though they are based on reasonable assumptions as of the date of the Report, such forward-looking statements by their nature involve risks and uncertainties that could cause actual results to differ materially from the results predicted. AECOM specifically does not guarantee or warrant any estimate or projections contained in this Report.

Unless otherwise stated in this Report, the assessments made assume that the sites and facilities will continue to be used for their current purpose without significant changes.

Copyright

© This Report is the copyright of AECOM Infrastructure & Environment UK Limited, a wholly owned subsidiary of AECOM. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited.

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 May 2015

TABLE OF CONTENTS 1. INTRODUCTION ................................................................ 1

2. PROPOSED 1,800 MW SCHEME ..................................... 2

3. OVERVIEW OF CCR WORK UNDERTAKEN TO DATE .. 3

4. WIDER CCR CONSIDERATIONS ..................................... 4

5. INDICATIVE SPACE REQUIREMENTS FOR CCR .......... 5

6. INDICATIVE SPACE REQUIREMENT FOR DHC2 CCR .. 7

7. CONCLUSIONS ............................................................... 11

ANNEX B1: LETTER FROM SCOTTISHPOWER TO DECC, APRIL 2014 ................................................................................. 12

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 1

1. INTRODUCTION

ScottishPower (DCL) Limited (‘ScottishPower’) proposes to construct and operate a Combined Cycle Gas Turbine (CCGT) Power Station - Damhead Creek 2 (DHC2) on land immediately adjacent to their existing Damhead Creek CCGT power station on the Hoo Peninsula, Kent (National Grid Reference 581250, 172830). The location of the site is shown on Figure 1, the application site boundary is shown on Figure 2. Figures are provided within the EIR, which this report accompanies.

Consent under the Electricity Act 1989 and deemed planning permission was granted for DHC2 in January 2011 for the construction and operation of a 1,000 MW CCGT power station adjacent to the existing Damhead Creek CCGT Power Station. Subsequently, ScottishPower has progressed with the discharge of planning conditions associated with that consent and with the detailed design of DHC2 and, as a result of changes made to the proposals during this process, the Section 36 Consent has been varied via applicable processes to accommodate a larger capacity power station. The currently consented development comprises the construction and operation of a 1,200 MW CCGT power station (the ‘1,200 MW scheme’).

Subsequent to obtaining consent for the 1,200 MW scheme in July 2014, ScottishPower has identified the potential need to further develop the proposals and seek to vary the consent for a larger capacity power station up to 1,800 MW in order to ‘future proof’ the DHC2 project and take account of developing and improving turbine technologies. The proposed development therefore now comprises a CCGT power station of electrical capacity of up to 1,800 MW (the ‘proposed 1,800 MW scheme’). This larger scheme requires an increased area of land for the siting of the CCGT.

This note considers the potential implications of the 1,800 MW scheme on the availability of land to be retained for potential future use for carbon capture equipment in order to fulfil the requirements of the UK Government’s Carbon Capture Readiness (CCR) Policy that “sufficient space is available on or near the site to accommodate carbon capture equipment in the future”. The Government has determined that “no new power station of a type covered by the EU Large Combustion Plant Directive (LCPD) at or over 300 MWe will be consented unless it can be demonstrated to be CCR”.

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 2

2. PROPOSED 1,800 MW SCHEME

As outlined in the EIR, the proposed development (DHC2) is the construction and operation of a CCGT of electrical output capacity up to 1,800 MW adjacent to the existing Damhead Creek CCGT Power Station site located on the southern side of the Hoo Peninsula, to the east of Chatham and Rochester. The plant would be fired on natural gas from the UK National Transmission network; no back-up firing on distillate fuel is proposed. As with the existing Damhead Creek CCGT, the plant will be air cooled.

The 1,200 MW scheme comprised a multi-shaft combined cycle arrangement with two gas turbines, each with a heat recovery steam generator (HRSG), and both connected to a single steam turbine. The total electrical output was 1,200 MW based on ISO conditions.

For the proposed 1,800 MW scheme, as detailed design and final technology selection of the CCGT have not been completed, the three most likely potential configurations that have been considered are:

• retention of the two unit multi-shaft arrangement but use larger gas turbines that may be available at the later design phase. This would be expected to give a total electrical output capacity of up to 1,550 MW (Option 1);

• installation of three gas turbine units (a gas turbine with an HRSG) in a single shaft configuration, with one steam turbine per train, and with each of the three modules generating 600 MW, giving a total electrical output capacity of up to 1,800 MW (Option 2);

• installation of three gas turbine units in a multi-shaft configuration with a single steam turbine (Option 3). This option is less likely than Option 2 but cannot yet be ruled out as the detailed design of the plant has not yet been completed.

Options 2 and 3 require a larger footprint for the CCGT within the overall application site than that which would be needed for Option 1, so both these options have been considered within this report to ensure that sufficient space is retained to meet the CCR requirements. Provided that sufficient space can be demonstrated for Options 2 and 3, the same conclusion would therefore apply to Option 1, particularly as a CCGT of lower electrical generating capacity would need a correspondingly smaller CCS plant as well.

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 3

3. OVERVIEW OF CCR WORK UNDERTAKEN TO DATE

To support the original Section 36 Consent application, a CCR report was prepared in June 2009, addressing the requirements of the DECC Guidance on Carbon Capture Readiness for Applications under Section 36 of the Electricity Act 1989, dated November 2009. This original CCR report was subsequently modified in May 2010 to respond to Environment Agency (EA) questions and updated in January 2013 to reflect a previously consented increase in plant capacity from 1,000MW to 1,098MW, which was approved by DECC in March 2013.

To support the currently consented 1,200 MW scheme, a further revision to the CCR report was prepared in February 2014 to demonstrate continued compliance with the requirements of the DECC CCR Guidance and Policy (Updated CCR Feasibility Note, ScottishPower, February 2014).

The Environment Agency (EA) requested some additional information from ScottishPower following review of the revised CCR note and this was supplied in a subsequent letter from ScottishPower to DECC on 22nd April 2014 (ref: UB – X0002) (see Annex B1).

Consent to construct and operate the 1,200 MW scheme was granted in July 2014.

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 4

4. WIDER CCR CONSIDERATIONS

In addition to an assessment of footprint requirements, the CCR Guidance requires consideration of other aspects of the potential future retrofit of CCS technology including:

• “The technical feasibility of retrofitting the chosen carbon capture technology;

• That a suitable area of deep geological storage off shore exits for the storage of captured CO2 from the proposed power station;

• The technical feasibility of transporting the captured CO2 to the proposed storage area; and,

• The likelihood that it will be economically feasible within the power station’s lifetime, to link it to the full CCS chain, covering retrofitting of carbon capture equipment, transport and storage”.

These aspects were considered and reported in the 2009 CCR report and reappraised in the 2014 revision and subsequent letter (see Annex B1). Table 1 shows the CO2 generation estimates for the 1,200 MW and 1,800 MW schemes, which are comparable. It is therefore considered that the CCS technology selection (amine based post combustion carbon capture equipment), transport route evaluation, potential storage locations and economic assessment remain valid for the purposes of this Section 36 Consent variation application and no further updates are provided here. Please refer to the previous reports for further information.

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 5

5. INDICATIVE SPACE REQUIREMENTS FOR CCR

Table 1 in the 2009 CCR Guidance provides an indicative CCR space requirement based on a 500 MW (net) power plant. For a CCGT power plant with post-combustion carbon capture, the indicative CCR space requirement was 3.75 Ha for 500 MW, which equates to 75 m2/MW.

The February 2014 CCR update considered the findings of the Imperial College report ‘Assessment of the validity of ‘Approximate minimum land footprint for some types of CO2 capture plant’ provided as a guide to the Environment Agency assessment of Carbon Capture Readiness in DECC's CCR Guide for Applications under Section 36 of the Electricity Act 1989’. Whilst the DECC has not updated the CCR guidance note to incorporate the findings of the Imperial College report, the report is published it on the DECC website.

This report concluded that the footprint estimates presented in the DECC CCR Guidance were overly conservative, as they were based on calculations undertaken for a 785 MWe CCGT (pre-retrofit) and not a 500 MWe plant. Consequently the paper recommended that the footprint estimates presented in the Guidance be reduced by “at least 36%, assuming the same list of equipment for a gas plant with an output of 500 MWe without capture”. On this basis, the corrected footprint is 2.4 Ha for 500 MW, which equates to 48 m2/MW. This was applied in the February 2014 revised CCR report.

The Imperial College paper goes on further to say that “there appears further scope to reduce the land footprint estimate for a CCGT with post-combustion capture by up to a total of about 50% (i.e. including the 36% reduction) considering technology advances and with layout optimisation”. However, “such a reduction can only be justified on the basis of a detailed engineering design (which is not a requirement for consent under Section 36)”. A 50% reduction in the footprint estimates presented in the DECC Guidance would equate to 1.875 Ha for 500 MW, which equates to 37.5 m2/MW.

In August 2014, a variation application for the Section 36 Consent for the Gateway Energy Centre (GEC) was submitted to DECC by the applicant to increase the generation capacity of GEC from 900 MW up to 1,250 MW. This application was supported by an Updated Carbon Capture Readiness Feasibility Study, which updated their previous 2010 CCR Feasibility Study to demonstrate continued compliance with DECC CCR requirements for the larger scheme.

The GEC updated study included a footprint estimate and concept design layout based on a Siemens PostCapTM reference project. Siemens had prepared an engineering concept design for the GEC development including process simulation and equipment sizing calculations based on a pilot plant installed in Germany.

Based on the PostCapTM technology, a concept layout was prepared for the proposed larger capacity GEC development. This demonstrated that the CCS technology could be accommodated into an area of 4.5 Ha for the 1,250 MW GEC scheme. An area of up to 4.7 ha was therefore reserved for CCR requirements on that scheme, which meets the 37.5 m2/MW indicated in the Imperial College paper

The CCS concept layout and concept design for GEC were independently reviewed by Imperial College Consultants (Assessment of the CCR Compliance of the Proposed Gateway Energy Centre, P.S. Fennell, N. MacDowell, N.H. Florin). The review concluded that there is

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 6

a requirement of 18,750 m2 for a 500 MW power plant with post-combustion capture retrofit and therefore that the approximate minimum land footprint requirement for the 1,250 MW GEC scheme is 46,875 m2 (4.69 Ha).

The authors further observed that “the technical maturity of the proposed Siemens PostCapTM CO2 capture system described in the document provided [to them] by Siemens appears sufficient to carry out the engineering calculations necessary to underpin the preliminary design work associated with the preparation of the proposed CO2 capture plant layout for Gateway Energy Centre’s CCS scheme. This is evidenced by the range of pilot studies conducted by Siemens.”

The authors therefore considered that the proposed CCR plans for that development were compliant with the 2009 DECC CCR Guidance as amended by the Imperial College Assessment 2010.

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 7

6. INDICATIVE SPACE REQUIREMENT FOR DHC2 CCR

The application site is shown in Figure 2 and the proposed general arrangement plan (2015) is shown in Figure 5. This shows that the application site consists of three main areas:

• Area 1 is where the majority of the new DHC2 CCGT will be constructed and lies to the east of the existing Damhead Creek CCGT Power Station (shown in Figure 2, also referred to as the ‘triangle site’). The developable area is 8.4 Ha in extent;

• Area 2 is 3.6 Ha in extent and lies to the north of the existing Damhead Creek CCGT Power Station (see Figure 2). This land consists of hardstanding and is not currently in use. The 2014 Section 36 Consent Variation application proposed no development in this area; and

• Area 3 in total is approximately 14 Ha in extent and lies to the north-east of the existing Damhead Creek CCGT Power Station (see Figure 2). Part of this plot was set aside to meet the CCR requirements for the plant in the 2014 Section 36 Variation application and will continue to be for the 1,800 MW scheme (orange on Figure 5), although a portion of Area 3 will now be required to accommodate the larger CCGT footprint (grey on Figure 5). The remaining part of Area 3 will be used as ecological enhancement and mitigation (green on Figure 5).

The basis of design for the sizing of the CCS plant is presented in Table 1 which also shows the previously reported 1,200 MW data for comparison. The 1,800 MW scheme data is derived from the gas flow rates and CO2 generation estimates developed for the 1,200 MW scheme increased pro rata to 1,800 MW using three H Class gas turbines in a multishaft arrangement with a single steam turbine, and three pressure level drum type HRSGs. It is assumed that 90% capture of CO2 is achieved in the CCS plant and that the ACC is sized for a vacuum level of 60 mbar at ISO conditions.

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 8

Table 1: Average CO2 Generation and Capture Volume Estimates

Parameter Units 1,200 MW plant 1,800 MW plant

CO2 generated kg/s 116.6 129.6 (2)

CO2 leak in Gas-Gas Re-Heater

kg/s 3.5 0 (3)

CO2 captured kg/s 101.8 116.6

CO2 stored (assuming 75% lifetime load factor for power station)

Mt/y 2.4 2.8

Total CO2 stored (assuming 35 years of carbon capture)

Mt 84.3 96.6

Notes:

(1) Based on design point at ISO conditions (15degC 60%RH)

(2) Based on calculated values from thermal model of plant with 20% safety margin applied

(3) Not considered in PostCapTM process

It can be seen from Table 1 that the CO2 generation and capture estimates for the 1,800 MW plant are not 50% larger than those presented in the modified CCR report for the 1,200 MW plant. This is because the 1,200 MW estimates were conservative. Note that the volume estimates presented in Table 1 are not used in the footprint calculations presented in Table 2.

As discussed in Section 5, Imperial College concluded that 18,750 m2 of space is required for CCS on a 500 MW plant (37.5 m2/MW). This is based on the use of hybrid cooling on the future CCS plant. However, DHC2 is an air cooled plant and similarly, any future CCS plant is likely to be air cooled due to constraints on the use of water for cooling at the site. The Siemens PostCapTM concept design for GEC is similarly an air cooled CCS plant and therefore this design concept has been used as the basis for the footprint estimate for the DHC2 CCR. It has been assumed that the plant is linearly scalable from the 1,250 MW GEC scheme to that required for the 1,800 MW DHC2. Linear scaling of the PostCapTM design is considered conservative, as while it is appropriate for the ACC, it will over-estimate the footprint requirement for absorbers and pipework.

Based on this PostCapTM design, a concept layout has been produced for both Option 2 and Option 3 of the proposed 1,800 MW scheme for DHC2 – see Figures B1 and B2. In summary:

• Area 1 will continue to be used for the majority of the DHC2 CCGT footprint, which is estimated to require approximately 10.4 Ha. Therefore the CCGT will also require part of Area 3 (see below);

• Area 2. For the proposed 1,800 MW scheme, up to 3.0 Ha of this area is allocated for the cooling system for the future CCS plant proposed, to be connected via overground or underground pipework to the rest of the CCS plant located in Area 3; and

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 9

• Area 3. Approximately 4.1 Ha of this plot will be set aside to meet the CCR requirements for the plant (orange on Figure 5), while 2.0 Ha of the plot will be required to accommodate the balance of land required to accommodate the 1,800 MW scheme (grey on Figure 5). The remaining area will be used as ecological enhancement and mitigation (green on Figure 5).

A summary of the proposed footprint areas for each component of the proposed 1,800 MW scheme is presented in Table 2 for the three unit single shaft configuration (Option 2) and the three unit multi-shaft configuration (Option 3). The results are very similar for both layouts.

Table 2: Footprint Estimates

Area of site Option 2 Option 3

CCGT CCR CCGT CCR

Area 1 8.4 ha 0 8.4 ha 0

Area 2 0 3.0 ha 0 3.0 ha

Area 3 2.0 ha 4.1 ha 2.0 ha 4.1 ha

Total 10.4 ha 7.1 ha 10.4 ha 7.1 ha

CCR footprint m2/MW n/a 39.3 n/a 39.3

Imperial CCR footprint requirement m2/MW (based on 1.875 Ha for 500 MW plant)

n/a 37.5 n/a 37.5

Imperial CCR footprint minimum requirement for 1,800 MW plant (Ha)

n/a 6.75 ha n/a 6.75 ha

Previous CCR footprint estimate for 1,200 MW DHC2

n/a 5.76 ha n/a 5.76 ha

The proposed DHC2 CCS concept layout utilises part of the undeveloped Area 2 for the location of the Air Cooled Condenser (ACC). Due to the ecological compensation land located between Area 2 and Area 3 (see Figure 5), pipe runs would run overground (or potentially underground) between the two areas.

With regards to the proposed area of the CCS plant, the following points are made:

• Potentially, Gas to Gas Heat (GGH) Exchangers could be used within the design which may further reduce the footprint required for cooling by up to 25%. While such a Heat Exchanger would have its own plot implications it is considered that there would still be a net saving in land take. Within the layouts shown, no use of GGH Exchangers is currently considered;

• It is assumed that demineralised water is provided from the CCGT for the CCS plant. Based on the PostCapTM amine selection, there is expected to be a lower degradation of amine than from the use of Monoethanolamine (MEA) for example, and therefore a lower make-up water requirement than for many alternative CCS designs. A demineralised water tank is identified in the DHC2 CCGT concept layout providing circa 1 month of supply to the CCGT. The CCS requirement of circa 1.5 m/h should therefore be able to be supplied from the DHC2 CCGT system;

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 10

• The PostCapTM CCS process will generate more water than actually required by the process. The excess water will be sent to the main CCGT WWTP plant, for which adequate capacity will be specified at the detailed design stage. This wastewater, although slightly acidic, will be suitable for normal processing in the WWTP prior to discharge. Alternatively it can be reused as demineralised make-up water after filtration and pH neutralization.

• The PostCapTM CCS process will also include a re-claimer for treatment of solvent in order to remove degradation products and solids formed in the process. This will generate a small liquid waste stream for which treatment provision will be made in the CCGT WWTP. The exact details of the waste stream, quantities and process requirements will be finalised at the design stage and included in the design specifications. If necessary, some solid or liquid waste could be generated during the reclaiming process which could be tankered off site by contractor for treatment and disposal.

• It is assumed that the control room for the CCS plant is centralised with the main CCGT control room within the CCGT footprint;

• No additional flue gas treatment is proposed within the PostCapTM CCS plant layout. As noted in the Imperial College review, Siemens have tested their solvents for a number of years, and have stated in their report that they have “good solvent stability against various degradation mechanisms”. In addition, the detailed design of the CCGT layout will include space for the potential retrofit of secondary NOx abatement (such as Selective Catalytic Reduction technology), in the event that such technology is eventually required for ongoing compliance with the Industrial Emissions Directive. Such technology would then be able to treat the flue gases prior to them passing to the CCS plant, if necessary;

• Laydown for the future installation of CCS equipment would be determined and secured at the time of installation and would depend on the year of construction. By that time, the Damhead Creek 1 power station may no longer be operational for example, and the nearby Kingsnorth power station will have been demolished; both of which could potentially be available for use at that time. Alternatively, there are large areas of agricultural land in the vicinity of the power station which may be available for lease.

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 11

7. CONCLUSIONS

Based on the CCS PostCapTM concept layout developed by Siemens, a concept layout has been prepared to demonstrate that the proposed increase in capacity of Damhead Creek 2 power station up to 1,800 MW still complies with the minimum available footprint requirement for land to be retained for potential future use for Carbon Capture equipment, in order to fulfil the requirements of the UK Government’s Carbon Capture Readiness (CCR) Policy.

Two potential CCGT plant configurations up to 1,800 MW in capacity have been considered together with a linearly scaled up footprint estimate for the CCS plant. On this basis, 7.1 Ha of land remains available within the application site for future CCS, which is larger than the 6.75 Ha indicated by Imperial College to be the minimum footprint needed for CCS, derived from their calculated footprint of 1.875 Ha for a 500 MW CCGT plant. Should a smaller capacity CCGT be developed, this would require a smaller footprint for both the CCGT and the corresponding CCS plant, so the same conclusions would apply.

On this basis therefore, it is considered that the footprint retained for future CCS is compliant with the DECC's Carbon Capture Readiness (CCR) Guidance 2009, as amended by the Imperial College Assessment (Florin and Fennell, 2010), and that the land available at site for the proposed 1,800 MW scheme for DHC2 is sufficient to meet the approximate minimum land footprint requirement.

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 12

ANNEX B1: LETTER FROM SCOTTISHPOWER TO DECC, APRIL 2014

Scottish Power – Damhead Creek 2

CCR Footprint Requirements Phase 1 Environmental, Health & Safety Due Diligence Report

47072152 / LERP0001 May 2015 1

ABOUT AECOM

In a complex and unpredictable world, where growing demands have to be met with finite resources, AECOM brings experience gained from improving quality of life in hundreds of places.

We bring together economists, planners, engineers, designers and project managers to work on projects at every scale. We engineer energy efficient buildings and we build new links between cities. We design new communities and regenerate existing ones. We are the first whole environments business, going beyond buildings and infrastructure.

Our Europe teams form an important part of our worldwide network of nearly 100,000 staff in 150 countries. Through 360 ingenuity, we develop pioneering solutions that help our clients to see further and go further.

www.aecom.com

Follow us on Twitter: @aecom