Representation by CATS North Sea Limited (CATS North Sea Limited)
- Date submitted
- 16 December 2021
- Submitted by
- Members of the public/businesses
1 INTRODUCTION 1.1 This representation is made by CATS North Sea Limited (“CNSL”) in respect of the Net Zero Teesside Project (Planning Inspectorate Reference: EN010103). This representation is submitted to allow CNSL to be registered as an Interested Party in the Examination. An outline of the principal submissions CNSL wishes to make are detailed below. These will be expanded upon in Written Submissions. 1.2 CNSL is the operator of the Central Area Transmission System (“CATS”). CATS is a gas transportation and processing system that transports gas from the Central North Sea to a terminal at Teesside. CATS includes the CATS terminal on Teesside situated within a 29-hectare site and the CATS pipeline, which is a 36 inch diameter pipeline that is 404 km long. CATS is essential national infrastructure necessary for the operation of natural gas fields in the North Sea. 2 INSUFFICIENT ENGAGEMENT 2.1 The Applicant’s pre-application consultation was insufficient. The Applicant should have carried out more detailed consultation with CNSL to find a solution that could facilitate the Applicant’s scheme without harming CATS. 3 COMPULSORY PURCHASE OF LAND OCCUPIED BY CNSL IS UNNECESSARY AND COULD CAUSE MATERIAL DISADVANTAGE 3.1 The rights required could be granted on a voluntary basis by agreement between CNSL, the Applicant and the landowner. CNSL made this clear during the limited pre-application engagement. Transfer of the land that the Applicant seeks to acquire through the DCO will have an adverse impact on CNSL’s current and future operations, including published development plans. 4 COMPULSORY PURCHASE PLOT 112 4.1 Schedule 7 of the CPO states that plot 112 is being acquired in connection with Work No.2A and Work No.2B. Schedule 1 of the DCO details that Work No.2A is an underground high pressure pipeline. Work No.2B is above ground installations, including a compound for National Grid Gas plc’s apparatus. 4.2 Plot 112 is occupied by CNSL and forms part of the CATS terminal site. Acquisition of this plot will harm current operations of CATS and limit flexibility to make modifications and improvements, including for HSE reasons. 5 THE COMPULSORY PURCHASE ORDER PLANS 5.1 The compulsory purchase order plans are insufficient. They have omitted relevant existing infrastructure, such as the CATS pipeline. 6 SAFETY ISSUES WITH THE DESIGN OF THE SCHEME 6.1 The scheme may have severe operational impacts and safety implications for the CATS “Major Hazard” gas pipeline, Beach Valve Station, and associated infrastructure. There are concerns with the proximity of the proposed development, including pipeline crossings, cable crossings, and sterile zones required for the compressor station. No firm details of the scheme are available to review. 7 THE PROTECTIVE PROVISIONS ARE INSUFFICIENT 7.1 Part 5 of Schedule 12 of the DCO includes certain protective provisions for the CATS pipeline corridor. In their present form these are not considered adequate given the particular risks associated with the CATS pipeline. 7.2 Any incident resulting in damage to CATS, or requiring the CATS pipeline to shutdown would have considerable impact upon UK gas and electricity supplies to the commercial and domestic UK markets.