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Representation by VPI Immingham LLP (VPI Immingham LLP)

Date submitted
14 January 2024
Submitted by
Other statutory consultees

VPI Immingham LLP Representation This representation is made by VPI Immingham LLP in relation to the Viking CCS DCO Application. VPI Immingham LLP owns and operates the existing 1260 megawatt (MW) Combined Heat and Power (CHP) plant which is an important provider of heat and steam to local industry, and of electricity both locally and to the national grid. VPI Immingham is now bringing forward the Humber Zero VPI Immingham Post-combustion Carbon Capture project, which is a proposed anchor emitter project for the Viking CCS transportation and storage system. As such, VPI Immingham LLP strongly supports the development of the Viking CCS pipeline proposed by Chrysaor Production (UK) Limited (the Applicant) – the Viking CCS pipeline and Humber Zero are mutually dependent. There are however, certain land, programme and engineering conflict issues arising from the Applicant’s DCO application that must be resolved in order for the Viking CCS system and our emitter project to both proceed. We look forward to continuing to work with the Applicant in order to resolve all such issues. The Humber Zero project Humber Zero is a combined set of projects that aim to decarbonise the world-scale industrial complex at Immingham, comprising VPI’s CHP plant and the adjacent Humber Oil Refinery operated by Phillips 66. Humber Zero's initial phase focuses on the post-combustion carbon capture components of this strategy. At VPI Immingham, this phase will deliver up to 3.3 mega tonnes per annum (MTPA) of abated CO2 emissions via a post-combustion carbon capture retrofit to two gas turbines and two auxiliary gas boilers. The captured CO2 will be exported from the planned VPI Immingham Post-combustion Carbon Capture plant to the Viking CCS pipeline. The VPI Post-combustion Carbon Capture plant will be located between the existing VPI Immingham CHP plant and the proposed Viking CCS pipeline project’s AGI (Work No. 1). VPI’s planning process commenced in 2021, and preparation spanned two years with key activities including public consultation events, archaeological excavations, environmental surveys, data collection and analysis, all of which culminated in the production and submission of an environmental impact assessment. The application for planning permission for the VPI development was submitted to North Lincolnshire Council (the LPA) in March 2023, under the Town and Country Planning Act 1990. Permission is sought for “the construction and operation of a post-combustion carbon capture plant, including carbon dioxide compressor and metering, cooling equipment, stacks, substations, internal roads, partial ditch realignment, new and modified services, connections, accesses, maintenance and laydown areas”. The red line boundary for the VPI development overlaps in part with areas which are included in the Viking CCS pipeline DCO application Order limits. The LPA undertook public consultation on the application (reference PA/2023/421) which ended in June 2023, and the application is now in its final stages. Having satisfied all the requirements of the LPA and statutory consultees, we anticipate approval will be granted in January 2024. Project Interactions and Conclusion The VPI development and the Viking CCS pipeline proposal will need to come forward together in a co-ordinated way, allowing both to proceed and with overlaps and interactions of land, programme and engineering matters addressed via protective provisions and / or an agreement between the parties. The use of the powers in the DCO (such as those relating to land, access and highways) will need to be controlled as part of those documents. VPI Immingham LLP is strongly supportive of the Applicant’s proposed Viking CCS pipeline, and as noted above looks forward to continuing to work with the Applicant to allow both key decarbonisation projects to come forward.