Representation by North Tees Rail Ltd (North Tees Rail Ltd)
- Date submitted
- 17 December 2021
- Submitted by
- Members of the public/businesses
Planning Act 2008 (as amended) – Section 55 Application by Net Zero Teesside Power Limited and Net Zero North Sea Storage Limited for an Order granting Development Consent for the Net Zero Teesside (“NZT”) project Land at and in the vicinity of the former Redcar Steel Works Site, Redcar and Stockton-on-Tees, Teesside. Planning Inspectorate Reference: EN010103 Registration to become an Interested Party I refer to the above application for an Order granting development consent made under section 37(2) of the Planning Act 2008 (PA2008) received by the Planning Inspectorate on 19 July 2021 and accepted for examination on 16 August 2021. The application seeks development consent to authorise the construction, operation, and maintenance of the NZT Project (specifically a carbon dioxide pipeline) on land at and in the vicinity of the former Redcar Steel Works Site, Redcar and in Stockton-on-Tees, on Teesside. North Tees Land Limited (“NTLL”), North Tees Limited (“NTL”) and North Tees Rail Limited (“NTRL”) hold various interests within the site boundary in relation to the application by the Promoters for a development consent order (“the DCO”). NTLL, NTRL and NTL are registering to become Interested Parties. I have provided an outline of the principal submissions below on behalf of NTLL, NTRL and NTL that we are making in relation to the application. 1. The extent of the site boundary/ easement area is simply too large (more than 40 times greater than what the NZT Project requires) and in part, inappropriate. Therefore, the sterilisation area is too large, and it is excessive for the NZT Project requirements. 2. The NZT Project requirements are minor in comparison to the development plans and proposals for the various interests across NTLL, NTL and NTRL sites. Proper consideration has not been made to the detrimental impact of our adjacent landholdings and consideration should be given to NTLL, NTL, NTRL plans and other wider plans. The extent of the site boundary would preclude greater plans being developed and it would blight our current landholdings and development plans. 3. Dealings with the NZT Project team have been unpropitious. It has led us to the belief that the NZT Project team have no legitimate intention to tangibly progress pragmatic matters on reasonable and proper terms commensurate with the relevant practices. Correspondence, at times, has been unhurried with re-established demands. 4. The nature of the rights being sought are too extensive, wide ranging and in part, inappropriate in the circumstances. For example, a right of perpetuity when the installations that the pipeline is going to serve will have a lifetime of say 30 years and therefore seeking a right of perpetuity is inappropriate. 5. Rights are sought over an established multi-user service corridor for which there is an established market. It is unsafe to grant the rights without controls and a CPO would give rise to an unregulated pipe with no basis for control and protection within a heavily regulated corridor where occupiers into specific covenants and obligations. 6. The excessive rights sought will blight and sterilise the established corridor for many years and adversely affect NTL NTLL, NTRL and other occupiers and tenants. 7. There has been inadequate consultation and engagement having regard to the complexity of laying such a pipe and the site specific complexity of the area within which the pipe is intended to be laid / routed in relation to NTL, NTLL and NTRL. 8. The safety and protective issues that need to be considered when seeking an easement for a pipe of this sort in its specific location have not been addressed. 9. We have concerns as to whether the relevant environmental considerations for a pipe of this sort in its specific location have been adequately addressed. 10. A compulsory purchase of rights is simply inappropriate in an established commercial pipeline corridor where commercial terms can be readily agreed where there is full engagement by the developer. Please note that we reserve the right to rely on other representations made. We have not undertaken a thorough review of the DCO application and as such, any matters arising will result in representations been made in due course. Kind Regards.