Representation by EDF Energy (Thermal Generation) Limited (EDF Energy (Thermal Generation) Limited)
- Date submitted
- 5 June 2023
- Submitted by
- Non-statutory organisations
This relevant representation is submitted on behalf of EDF Energy (Thermal Generation) Limited (“EDF”) requesting that EDF is treated as an Interested Party for the Examination of the DCO application for the West Burton Solar Project (PINS reference EN010132) (the “Project”). EDF owns West Burton A Power Station, a closed coal-fired power station in close proximity to the proposed Order Limits, through which part of the proposed cable corridor of the Project will run. The station ceased generating in March 2023 and EDF has responsibility for the safe decommissioning and demolition of the power station assets. West Burton A Power Station houses critical third-party live infrastructure, including those of West Burton B CCGT Power Station which remains operational. While EDF is, in principle, supportive of the Project, it has concerns regarding the interface between the Project and West Burton A Power Station which require to be resolved. The Book of Reference (“BoR”) identifies plots 10-183, 10-184 and 10-185 (the “EDF Plots”) as land owned by EDF over which compulsory acquisition powers to permanently acquire new rights are sought. To safeguard EDF’s interests, the safety and integrity of current operations, the ongoing decommissioning, and potential future development, EDF objects to the inclusion of the EDF Plots in the DCO and the compulsory powers in respect of such plots. EDF will require appropriate protection to ensure that the Project does not jeopardise continuing or future operations or site decommissioning and demolition. EDF’s rights of access to inspect, maintain, renew and repair such infrastructure must also be maintained at all times and access to inspect and maintain such apparatus must not be restricted. There is existing third-party critical infrastructure on the site (two Exolum Oil Pipelines, the West Burton B Gas Pipeline, numerous 132kV and 400kV cables, underground and overground cables owned by National Grid and potable water supplies owned by Severn Trent Water). Any infrastructure or operations associated with the Project must protect this third-party infrastructure and be undertaken in full compliance with the terms of existing legal agreements and obligations. The West Burton A site has also been selected by the UK Atomic Energy Authority for the development of the UK’s first Nuclear Fusion Plant, with the potential to yield significant quantities of low carbon energy, generate employment opportunities and encourage investment in the region. EDF wish to facilitate the implementation of this project and other potential future development opportunities at the site. It is therefore imperative that the proposed cable route for the Project does not sterilise development land or detract from future development plans. EDF will require protective provisions to be included within the draft DCO for the Project to ensure that its interests are adequately protected and to ensure compliance with relevant safety, decommissioning and third-party obligations. Additionally, EDF recommend that a pre-commencement requirement be imposed under the DCO, if granted, related to the approval of the final cable routing and that EDF be a named consultee for subsequent discharge of such a requirement. EDF is liaising with the Promoter in relation to the proposed route and such protective provisions, along with any supplementary agreements which may be required. EDF reserves the right to make further representations as part of the Examination process but in the meantime will continue to liaise with the Promoter with a view to reaching a satisfactory agreement.