Representation by National Grid Carbon Limited (National Grid Carbon Limited)
- Date submitted
- 5 September 2022
- Submitted by
- Other statutory consultees
This is a Relevant Representation submitted by National Grid Carbon Limited (NGCL) requesting that NGCL is treated as an Interested Party throughout the Examination process of the Development Consent Order (DCO) application for The Drax Power Station Bioenergy with Carbon Capture Storage Extension Project (PINS ref: EN010120). NGCL, as part of National Grid Ventures, is a division of National Grid plc, responsible for both developing and operating businesses in our UK and US territories, and is proposing to develop Humber Low Carbon Pipelines (HLCP); the deployment of a terrestrial pipeline network in the Humber region. HUMBER LOW CARBON PIPELINES (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). 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 associated future DCO application, which will be inclusive of the terrestrial environment only to Mean Low Water Springs (MLWS) (PINS ref: EN070006). A non–statutory consultation was held in Autumn 2021 on a number of potential network configurations in respect of the proposed CO2 and H2 pipelines. A preferred route corridor was announced by NGCL in Spring 2022. NGCL is currently developing and carrying out further assessments to refine pipeline routeing and above ground installation siting within this route corridor, ahead of a statutory consultation planned for later this year. 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, being promoted by the licensed operator of the store, bp, on behalf of the Northern Endurance Partnership. NGCL is part of the East Coast Cluster (ECC) bid, combining 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, BEIS announced that ECC, along with the HyNet northwest cluster, had been confirmed as Track-1 clusters for deployment in the mid-2020s and would therefore be taken forward in to Track-1 negotiations. On 12 August 2022, BEIS announced that a short list of power CCUS, industrial carbon capture, waste and CCUS-enabled hydrogen projects to connect to the Track-1 clusters had been selected to proceed to the due diligence stage of the Cluster Sequencing programme. On 24 August 2022, BEIS also launched a call for submissions from power bioenergy with carbon capture and storage projects seeking to take part in Track-1 of the CCUS Cluster Sequencing programme. NGCL’s INTEREST IN THE DRAX POWER STATION BIOENERGY WITH CARBON CAPTURE STORAGE EXTENSION PROJECT NGCL’s role in the deployment of CCUS at scale in the Humber means that close working with emitters such as Drax is key. The HLCP network is the proposed infrastructure for transporting the CO2 captured at the power station that is the subject of this application to the interface at landfall with the offshore pipelines for onward transportation to the Endurance saline aquifer for storage. NGCL’s interest relates to the interface between the Drax project and HLCP, which includes the proposed CO2 export connection and associated Works. It is also proposed that the HCLP network will transport H2. Work No. 2 in the dDCO represents the point at which the authorised development would deliver pressurised CO2 to NGCL’s network. Work No. 2 is comprised of two potential options, but only one of these would be implemented. The first option would involve the construction of a CO2 delivery terminal compound and CO2 pipeline connecting that compound to a terminal point within the Order limits (Option 1). Option 1 would be delivered in full pursuant to this Order. The second option would involve the construction of a CO2 delivery pipeline to a terminal point within the Order limits (Option 2). Accordingly, Option 2 would not, if pursued, include the construction of a terminal compound, which would be delivered, outside the Order limits, on a separate basis to this application. Since the precise nature of the interface between the authorised development and the HCLP network is still to be defined, NGCL considers that the approach taken by the Applicant to the drafting of Work No. 2 is appropriate. Protective provisions are currently included in the dDCO for National Grid Gas and National Grid Electricity Transmission; NGCL would also wish to see protective provisions for its benefit, recognising the future interface between the authorised development and the HCLP network, and has provided a copy of its preferred Protective Provisions to the Applicant in April 2022. A response to these is awaited. NGCL would also be happy to conclude a Statement of Common Ground with the Applicant.