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Representation by National Grid Ventures (National Grid Ventures)

Date submitted
23 November 2021
Submitted by
Members of the public/businesses

This is a Relevant Representation submitted by National Grid Ventures (NGV) requesting that NGV is treated as an Interested Party throughout the Examination process of the Development Consent Order (DCO) application for The Net Zero Teesside (NZT) Project (PINS ref: EN010103). NGV is a ringfenced division of National Grid plc, responsible for both developing and operating businesses in our UK and US territories. National Grid Carbon (NGC) as an NGV business is proposing to develop Humber Low Carbon Pipelines (HLCP); the deployment of a terrestrial pipeline network in the Humber region. THE HLCP PROJECT The HLCP Project intends to establish a pipeline network in the region to transport carbon dioxide (CO2) and hydrogen (H2) to facilitate Carbon Capture Usage and Storage (CCUS). NGV are currently investigating potential corridors within which separate CO2 and H2 pipelines could be routed and will be carrying out surveys and further public consultations to help inform the corridor selection process. HLCP is in the pre-application stage, with stakeholder engagement underway. This includes dialogue with the Planning Inspectorate over the potential form and content of its future Development Consent Order application(s), which will be inclusive of the terrestrial environment only to Mean Low Water Springs (MLWS). The CO2 export pipeline below MLWS and the CO2 storage site under the North Sea (known as the Endurance saline aquifer) will be the subject of separate consent applications, under the Petroleum Act 1998 and the Energy Act 2008. A non–statutory public consultation on potential onshore route corridors concluded in October 2021, with further public consultation and engagement planned for 2022. NGV is part of the East Coast Cluster (ECC) bid, combining the Humber and Teesside regions, as submitted to the department of Business Energy and Industrial Strategy (BEIS) as part of the CCUS cluster sequencing consultation. On 19 October 2021, government announced that ECC, along with HyNet north west cluster, had been confirmed as Track-1 clusters for deployment in the mid-2020s and would therefore now be taken forward into Track-1 negotiations. NGV’S INTEREST IN THE NET ZERO TEESSIDE (NZT) PROJECT The HLCP Project is being promoted separately to the NZT Project and there is no direct physical interface between them. For the avoidance of doubt, therefore, NGV is not seeking to agree protective provisions for its benefit in the NZT Project Order, nor does it consider it necessary to enter into a Statement of Common Ground with the applicants. However, as a key component of the ECC bid and because both projects would, if approved, make use of the storage opportunity provided by the Endurance offshore site and would also share some of the offshore infrastructure required to transport CO2 emissions to that store, the progress of this application is of wider interest and importance to NGV. For completeness, NGV would highlight that there is currently a factual error within the Project Need Statement, at paragraph 9.1.1, which states: “National Grid Ventures operate the current UK onshore pipeline transmission system and advanced the Yorkshire and Humber CCS pipeline to support the White Rose UK CCS demonstration project.” National Grid Gas Transmission owns and operates the high-pressure gas transmission pipeline network in the UK, as regulated by Ofgem. The Yorkshire and Humber CCS Pipeline project was promoted by NGC. That project was refused development consent by the Secretary of State in January 2017, as a result of concerns about the need case for the project, following the government’s decision to withdraw ring-fenced funding for the CCS Commercialisation Programme and the refusal of development consent for the associated White Rose project in April 2016. We trust that this relevant representation is of assistance and look forward, where appropriate, to participating in the forthcoming examination process.