Representation by Mablethorpe Flexible Generation Limited (Mablethorpe Flexible Generation Limited)
- Date submitted
- 12 January 2024
- Submitted by
- Members of the public/businesses
Introduction This is the representation of Statera Energy Limited (“Statera”) and its wholly owned subsidiary, Mablethorpe Flexible Generation Limited (“Mablethorpe”) to the application by Chrysaor Production (UK) Limited (“the Applicant”) for an Order granting Development Consent for the Viking CCS Pipeline Project (“the Application”), to enable Statera and Mablethorpe (together) to be registered as an Interested Party in the Examination. This representation concerns the following works proposed within the Application (as identified on sheet 3 of the Works Plan submitted with the Application): 1. Work 43 (Carbon Dioxide Pipeline Works); 2. Work 44a (Permanent Access Associated with Option 1 (preferred); 3. Work 45 (Electrical Connection), and 4. Work 46 (Temporary Access), (together “the Works”). To enable the Works to be carried out, the Applicant is proposing to compulsorily acquire various parcels of land (and new rights over land), which are currently owned by National Gas. The relevant compulsory acquisition plans are contained within the Application at sheet 35 of the Land Plan. Background Statera is a market leader in grid/system flexibility developing, building and operating projects including battery energy storage systems, pumped storage hydro, electrolysis, green hydrogen and thermal plant. It has been working with National Gas on plans to develop a thermal generating facility (or flexible power station) on land next to the decommissioned Theddlethorpe gas terminal (“the Proposed Facility”). Statera is currently engaged in negotiations with National Gas for Mablethorpe to take a long lease of the land on which the Proposed Facility is to be developed (“the Mablethorpe Land”). National Gas will be retaining land for the purposes of building a new gas terminal to feed the gas generated by the Proposed Facility into the mains gas transmission network. The Proposed Facility is therefore ideally situated given the proximity to the proposed new terminal. The Proposed Facility is likely to be made up of turbines to generate electricity that could be fuelled by natural gas from National Gas’ adjoining network and use carbon capture storage, or made up of turbines fuelled by hydrogen, which could be produced as part of the Proposed Facility. Statera’s plans include facilities in keeping with a large infrastructure power project including but not limited to: turbine halls, substations, accesses, welfare/operations buildings and balance of plant equipment. The development of the Proposed Facility will include the construction, installation, operation, repair, replacement, renewal and decommissioning of a possible combination of thermal generating facility with onsite gas or hydrogen storage and associated infrastructure (which will include a private electrical substation). This plant could use carbon capture, be fuelled with natural gas or hydrogen or a mixture of both and a National Grid Electricity Transmission (NGET) substation comprising all structures, frames, cables, switchgear, roadways and ancillary equipment reasonably necessary for the generation of electricity for export to the grid. Issue with the Application The Mablethorpe Land is currently included within the Order Limits as set out in the Application and on which the Works are to be carried out. The Application (as per Sheet 35 of the Land Plan) proposes the compulsory acquisition of the following areas of land to facilitate the Works: - The land shaded orange on sheet 35 of the Land Plan, which is proposed to be subject to permanent acquisition of the subsurface and which is purported to be required in respect of Work 43 and part of Work 45. - The land shaded blue on sheet 35 of the Land Plan, which is proposed to be subject to permanent rights and temporary use and which is purported to be required in respect of Work 44a, part of Work 45 and Work 46. The proposed compulsory purchase of these areas of land would materially impact Statera’s plans for the Proposed Facility, as these areas are required by Statera/Mablethorpe for the development of the Proposed Facility itself, including access. Relationship with National Gas Statera has been engaged in extensive negotiations with National Gas over the past 12 months in respect of the proposed lease of the Mablethorpe Land and negotiations are at an advanced stage. Statera has carried out detailed investigations and engaged relevant experts in respect of the development of the Proposed Facility and has accordingly incurred substantial costs to date in connection with this. It is also in receipt of a Connection Application Agreement with NGET. National Gas, as current owner of the Mablethorpe Land, is already known to the Applicant. National Gas is submitting its own representations in respect of the Application, and this submission by Statera and Mablethorpe should be read in conjunction with such representation. Statera and Mablethorpe’s position Statera and Mablethorpe’s position is that, whilst they do not object to the Application in principle, the Order Limits as proposed in the Application, insofar as these relate to the Works and the corresponding compulsory purchase measures referred to above, should be revised to take account of the Proposed Facility as follows: 1. In relation to the orange land shown on sheet 35 of the Land Plan (which the Applicant proposes should be permanently acquired for the purposes of carrying out Work 43 and part of Work 45), Statera and Mablethorpe consider that this area is a) too wide and b) in any event that permanent acquisition of this land is not necessary or justified. Instead, Statera and Mablethorpe propose that a narrower easement strip should be granted, such that the Applicant may be able to access this land to install the underground pipeline without the need to permanently acquire the land. 2. In relation to the blue shaded area on sheet 35 of the Land Plan (which the Applicant proposes should be subject to permanent rights and temporary use in connection with part of Work 45 and Work 46), Statera and Mablethorpe are of the view that this area is too wide and should be moved further East so as not to encroach on the Proposed Facility. Part of the blue shaded area follows the route of the main access to the site (comprised by Work 44a) and is also intended to be used by Statera/Mablethorpe as the main access to the Proposed Facility. Statera and Mablethorpe therefore propose that an arrangement be made with the Applicant such that this access road may be shared between the Applicant and Statera/Mablethorpe, in order for the two developments to co-exist, rather than this access road be subject to compulsory acquisition rights. Conclusion Currently, the limits of deviation in the Application are too wide and the proposed permanent acquisition of land and rights over the main access to the site are not justified. Statera and Mablethorpe are of the view that the two developments can co-exist, provided that the Applicant engages meaningfully with Statera/Mablethorpe to make suitable modifications to the Application as outlined above. Ultimately, if the Application were granted in its current form, this would significantly conflict with Statera’s plans for the Proposed Facility, such that it would impact on the ability to develop out the Proposed Facility. This would not be within the public interest, particularly given that the two schemes are capable of co-existing (and indeed this makes the most efficient use of the wider land). Statera has a strong track record of delivering on projects, having delivered 1GW of flexible and storage assets since its inception in 2015. Statera and Mablethorpe are open to further engagement with the Applicant and reserve their position to make further representation and submit additional detail in support of their position in due course.