Planetary Ocean Alkalinity Enhancement Trial Information Page

No. A local enforcement position is a decision relating to enforcement.  These decisions are based on public interest and potential harm to people and/or the environment and are not subject to consultation.  We may use local enforcement positions when proposed research or trials that involve the development of new ideas, techniques and processes aren’t covered by permits.  A local enforcement position would only be used for a short duration and where environmental risks are low.

However, this doesn’t mean we don’t value your opinions, views and questions and we do want you to feel able to contact us and ask us questions.  We are committed to being open and transparent throughout this process.

If Planetary and South West Water decide to apply for a full environmental permit, then we will, and are required to by law, hold a formal consultation in line with public sector consultation principles.  We will let you know how to take part in this, through our mailing list and this information page.  

The UK Government recognises that to address climate change a range of actions are needed, including removing greenhouse gases from the atmosphere and reducing our emissions.  They recognise that engineered Greenhouse Gas Removal (GGR) technologies will play a vital role in tackling climate change and achieving the UK’s net zero target.  The Department for Energy Security and Net Zero (DESNZ) recognise the potential for ocean-based carbon dioxide removal and have funded two ocean-based GGR projects through Phase 1 of the direct air capture and GGR removal programme. 

The World Meteorological Organisation (WMO) recently stated there is a 50% chance that average global temperature will reach 1.5 degrees Celsius above pre-industrial levels in the next 5 years.

Climate change is affecting the South West now.  Through 2022 and 2023 we experienced a period of drought lasting for 13 months, following 2022's summer of exceptionally low flows in our waterways, and changing rainfall patterns through the winter.  During this time, communities in Devon and Cornwall alternated between conflicting conditions of flooding or hosepipe bans.

Climate change will significantly affect our lives and the Environment Agency’s work. The Environment Agency is responsible for:

• acting to reduce greenhouse gas emissions.
• regulating low carbon and renewable energy schemes.
• helping people and wildlife adapt to the impacts of a changing climate. You can read more about this here: Environment Agency and climate change adaptation

The Environment Agency protects our air, land and water. Our regulation enables the UK’s transition to carbon net zero, ensuring we are sustainable and resilient to climate impacts.

We understand that innovative greenhouse gas removal techniques that are safe for people and wildlife need to be considered as part of the solutions to the climate emergency.  We need to ensure any trials are well regulated and happen in an incremental way to understand the risks to the environment.

We will ensure that novel technologies are subject to proportionate and risk-based regulation to provide the necessary level of environmental protection.

We have obtained information from Planetary and WRc to better understand and manage any environmental risks associated with Planetary’s proposal, and to better understand the greenhouse gas removal potential.

Edited April 2024 following comments from Defra:

The UK government is a signatory to the London Protocol, also known as the London Convention.  The London Protocol was originally formed to address dumping waste or other discarded material at sea.

Ocean Alkalinity Enhancement technologies, such as that proposed by Planetary, are not currently regulated by the London Convention/London Protocol. A statement has been issued by the Governing Bodies, which calls for the need for them to be deployed safely and with regard to the environmental impacts, and only for legitimate scientific research purposes at this stage.

We recognise South West Water (SWW) has been scored for being non-compliant with its permits at various sites across Devon, Cornwall and the Isles of Scilly.  Our regulatory officers are working hard to address these issues with SWW to ensure SWW is permanently compliant with its environmental permits.

Although Planetary are using SWW’s long sea outfall pipe and its associated environmental permit, Planetary will be controlling the magnesium hydroxide dosing. When we consider the proposal we will take account of the control measures Planetary propose and whether they, and any LEP conditions, are likely to be complied with when making our decision whether to issue an LEP. If we decide to issue an LEP, we will commit to actively regulating the activity.

If we agree to issue a Local Enforcement Position (LEP) we will require that the magnesium hydroxide dosing will be paused immediately if SWW’s storm tanks spill as the input of untreated sewage to St Ives Bay may affect the trial results.  We will ask for evidence that SWW and Planetary have set up a rapid communication pathway to ensure the trial is paused quickly.  The new event duration monitoring equipment installed on all combined sewer overflows in the country will also help with this.  This will enable Planetary to be confident that their results are not affected by untreated sewage in St Ives Bay.

The point where the magnesium hydroxide enters the ocean is just outside St Ives Bay, approximately 2.4km offshore, near Godrevy lighthouse.  The location is ideal because of the high mixing potential in the ocean at Hayle as well as good access to the harbour and outfall.

More information can be found on Planetary’s website.

We are supportive of the need to take carbon dioxide out of the atmosphere and it is likely that a range of different techniques will be required to remove carbon dioxide from the atmosphere. This trial would improve understanding of ocean alkalinity enhancement as a greenhouse gas removal technique. We are also leading on an ambitious, cross-Defra estuarine and coastal habitat restoration initiative known as Restoring Meadows, Marshes and Reefs (ReMeMaRe)” (pronounced “re-memory”), with a focus on restoring three priority habitats; seagrass meadows, saltmarsh and native oyster reefs.   

With the restoration of these habitats, we restore the multiple benefits that they provide, including biodiversity, flood defence and coastal resilience, carbon storage, water quality, human health and wellbeing, recreation and fisheries. In doing so, we help address the twin crises of climate change and biodiversity loss.

We assess all applications to the Environment Agency in a fair, independent and objective way, based on their merits and the evidence presented to us in the application.

We would need to consider the monitoring data and undertake a review.  We would share as much information as we can with you.  Approval would only cover this trial and any future projects would need to go through a new application process.  We are not aware of any next phase or stage currently.  We would objectively consider any further proposals we receive, as we are required to by the Regulator’s Code.  We would hold a full and extensive consultation on any application to vary the permit.

We are awaiting proposals from Planetary on their monitoring plans.  These will be considered when deciding whether to issue an LEP.  It is important to appreciate that Mg(OH)₂ is of low toxicity and the quantity planned to be introduced is low.  It is likely that the risk to marine species from Mg(OH)₂ in this trial is very low.  We will need to be satisfied that the proposed monitoring is designed in such a way that any impacts on species and the environment are detectable.  The trial aims to test how the magnesium hydroxide will be dispersed and dissolved, rather than increasing dosing and carbon sequestration.

In making our considerations we also need to account for adverse weather and consider any contingencies if monitoring is impacted.

If the trial goes ahead, we will require that Planetary carry out careful monitoring and reporting in accordance with specified conditions set out in an LEP. They have stated they will make the results of this monitoring available to the public.

When conducting their investigation, WRc aimed to calculate the concentration of Mg(OH)2 that would not impact marine life or organisms. This is called the Predicted No Effect Concentration (PNEC). It is calculated from data obtained for the most sensitive species, therefore protecting other marine organisms.

There was limited marine species data on magnesium hydroxide, so WRc used data from only one taxonomic group to calculate the PNEC. This included:

• Acute data for the most sensitive freshwater species.
• Long term-data for the most sensitive marine species.

This has led to the prediction of a highly precautionary PNEC value.  This concentration can be changed when long-term data on other marine species are made available.

Taking this into consideration, as well as other factors like:

• the fate and behaviour of Mg(OH)2 in the environment
• its low short-term toxicity to organisms such as crustaceans and fish that are more sensitive than larger species like seals,

It is likely that the risk to marine species from Mg(OH)2 in this trial is very low.

We regard this trial to be very low risk given the scale, low dose rates proposed and the protective measures we will require to be put in place should the trial go ahead.  We do not envisage any impact on marine life, fishing, or tourism.  We will require the monitoring to be designed in a way to detect any impacts.  If Planetary’s monitoring is not adequate or identifies a problem, then the dosing will be stopped immediately.

We understand there is concern about the impact this trial may have on the wildlife of St Ives Bay, particularly it’s seal population.

We have asked for advice from the Water Research Centre. It is intended that their final report will provide reassurance that we have investigated this in detail.

When conducting their investigation, WRc aimed to calculate the concentration of Mg(OH)2 that would not impact marine life or organisms. This is called the Predicted No Effect Concentration (PNEC). It is calculated from data obtained for the most sensitive species, therefore protecting other marine organisms.

There was limited marine species data on magnesium hydroxide, so WRc used data from only one taxonomic group to calculate the PNEC. This included:

• Acute data for the most sensitive freshwater species.
• Long term-data for the most sensitive marine species.

This has led to the prediction of a highly precautionary PNEC value.  This concentration can be changed when long-term data on other marine species are made available.

Taking this into consideration, as well as other factors like:

• the fate and behaviour of Mg(OH)2 in the environment
• its low short-term toxicity to organisms such as crustaceans and fish that are more sensitive than larger species like seals,

It is likely that the risk to marine species from Mg(OH)2 in this trial is very low.

Given the low dose rates, it is highly unlikely that there will be any visible difference around the outfall.  In the unlikely case that a change could be detected, it would be small, very limited in scope and temporary.  Please contact Planetary for further information on this issue.

This could theoretically happen but would only occur if dosing rates were too high or mixing is inadequate.  The deposition would be undissolved calcium compounds, which are of very low risk to marine organisms, but it is one of the issues we need to consider.  We will require unexpected settling to be strictly monitored as part of this trial should it go ahead.  Monitoring of both dose rates and the area around the outfall would ensure the risks are minimised and any deposits are detected at an early stage.  Planetary consider that, given the highly turbulent environment and the low dosing rates, the risk of any substantive seafloor deposition is very low.

We are confident that there will be minimal impact on the wastewater treatment works and final effluent quality because dosing will be after treatment.  SWW are still required to comply with all permit conditions.  We will also require that dosing is stopped immediately if there are any pollution incidents or storm tank discharges as these events may interfere with monitoring results.

There are some vehicle movements that will be associated with this trial but this is not expected to be significant.  Any concerns about traffic should be addressed with the Local Authority.

We are not party to any financial arrangements between Planetary and South West Water, but we understand Planetary are funding this trial.  Please contact them with any questions regarding funding.

Please refer to the WRc report for information about the carbon footprint of the trial and direct any further questions to Planetary.