1. Underground Coal Gasification
Name John Henderson (Redacted)
Job title Senior Advisor, Fuel & Power
Date 2/02/2015
DECC UCG Working Group

2. Overview EA role in England Engagement Next Steps Planning
Environmental Permitting - BAT
COMAH & NORM
Engagement
Next Steps

3. UCG & Planning Sched.1 its not extraction of natural gas,
Complexity of planning = Costal Concordat
MMO, some coastal LPAs & EA signed
Demonstration phase may not require an EIA
Commercial scale will probably require an EIA
Sched.1 its not extraction of natural gas,
Surface industrial installation extract coal etc > 0.5 hectare
Combustion > 300 Mwe
Sched.2 – deep drilling
Because permitting, planning, Habitats & EIA needs are complex the Coastal Concordat nominates a lead authority to streamline the evidence needs.
The coastal concordat early adopters in the NE are Newcastle, Durham and Scarborough so if it’s in one of those LAs then the concordat would apply. We should be encouraging its use for UCG
Demonstration phase does not appear to be a Nationally Significant Infrastructure Project (NSIP) (including under the 2013 Regs) and planning applications would be dealt by the MPA (down to low water mark) and MMO (up to high water mark).
Note we are not the determining authority for whether an EIA is needed. Habitats Regulations Assessment may also be needed.
The terrestrial and marine regulations contain thresholds that either trigger a need for an EIA (Schedule 1 in the terrestrial) or trigger the need to ‘screen’ for an EIA (Schedule 2). The LPA has to decide if the project in question is likely, because of its size, nature or location, to have significant effects on the environment.  In sensitive areas an EIA may be needed for schemes below the thresholds. The most relevant (terrestrial) thresholds are shown on the attachment. Under the Coastal Concordat, the lead competent authority co-ordinates EIA requirements.

4. Environmental Permitting
Gasification of coal is an EPR Scheduled activity S 1.2 Part A(1)d. The Stationary Technical Unit (STU) includes above ground, onshore, bore holes & reactor / chamber.
Directly Associated Activities to the STU include
Flares, gas clean up, small combustion units
Effluent treatment, discharges to water
Waste containment & management
No BRef or established BAT for UCG – we do it.
Above ground processes – BAT is defined
BAT for bore holes & gasification is new
COMAH – yes, NORM - probably
EPR permitting – a single permit addressing the whole installation – no mining Waste Activity (its off shore), no consent to discharge, no Ground Water Activity – much simpler than Fracking and there are no gaps.
If the want to abstract they will require an Abstraction Licence
BAT above ground BAT – all processes are established – combustion, flares, H2S & Hg scrubbing, effluent treatment, containment, waste treatment & disposal.
BAT for UCG will be new & demonstration phase will help define this
Emerging Technology – in the absence of BAT & BAT-AELs the member state will set the necessary permit conditions to protect the environment & human health.
Permitting & BAT – what are the installation boundaries ?
Aquifers & distance from UCG, suitable & unsuitable geology, base line monitoring, ground water flow, monitoring of emissions into ground water, containment of boreholes – new standards will need to be developed, ignition of gasification, control of gasification – is CRIP BAT ? Gasifier shut down & safety
Decommissioning & permit surrender – is there an after care phase, do we need financial provision ?
COMAH – oxygen storage – likely to be lower tier in the demonstration phase
NORM – may require a permit

5. Engagement 2009 - 2013 EA Limiting Climate Change & UCG – Aug.2010
B9 Coal, Link Energy, UCG Association
2013 to date
Operators – Five Quarter & Cluff Energy
UCG Association
Regulators – Sepa & NRW, Coal Authority, HSE
MPs questions & FoIs

6. Next Steps - UCG Much depends on operator activity – we have no budget
Continuing watching brief – develop regulatory position
We would like 6 months notice before permit applications arrive
Update EA UCG fact sheet for gov.uk
UCG & CCS – we would like DECC to provide clear policy to ensure low C, clean coal etc.
Progress on UCG will depend on the priority & resources provided. There is no point in developing BAT if UCG will not happen
CCS is requires for UCG with combustion > 300 MWe but if the syngas is used for as a chemical feed stock there is no requirement for CCS. DECC should, as minimum, specify that CCS will be required beyond the demonstration phase.
UCG without CCS will be unacceptable to the public