Representation by Calor Gas Limited (Calor Gas Limited)
- Date submitted
- 15 January 2024
- Submitted by
- Members of the public/businesses
Calor Gas Limited are the owners and operators of the Calor Cylinder Distribution site, which is located off Manby Road (A1173) and is used for the storage and distribution of liquefied petroleum gas and the repair of trunking vehicles. The site comprises a mix of storage, workshop and office buildings, associated staff parking and areas of hardstanding for tanker parking. It is accessed / egressed via Manby Road through a one-way system. Calor are generally supportive of the proposed Viking CCS Pipeline project and recognise its role in reducing carbon emissions to meet the UK’s target of net zero emissions by 2050. However, given the proximity of the proposed pipeline to their site, Calor wish to make the following representations: 1) Preference for ‘Option 2’ pipeline route at Section 1 Section 1 of the DCO boundary (Immingham Facility to A180) shows the following two options for the pipeline route: - Option 1 shows the pipeline running from the Immingham Facility and parallel to Manby Road before heading South West towards Immingham Golf Club. This option routes the pipeline / DCO boundary alongside the roadside frontage and southern boundary of the Calor site; - Option 2 shows the pipeline running through the Humber Refinery site and exiting west of Houlton’s Covert. This would route the pipeline approx. 300m to the west of the Calor site away from Manby Road. Having reviewed the two options, Calor are concerned that Option 1 may have an adverse impact on its operations during the construction phase given the proximity of the pipeline / DCO boundary to the Calor site and the site access / egress. Option 2 is unlikely to have any adverse impacts on the operations of the Calor site and, therefore, should be selected as the preferred option (subject to the outcome of ongoing discussions with Phillips 66). 2) Potential impact on Calor’s operations during the construction phase The Calor site is a distribution facility and currently operates 24 hours a day without restriction. As such, it is vital that vehicle access (via Manby Road) is maintained at all times during the construction period. In this regard, NPS EN-1 is clear that applicants of energy NSIPs should ensure any impacts on transport infrastructure (including during construction) should be mitigated. Paragraph 5.13.6 states: ‘A new energy NSIP may give rise to substantial impacts on the surrounding transport infrastructure and the IPC should therefore ensure that the applicant has sought to mitigate these impacts, including during the construction phase of the development’. Calor have previously raised concerns with the Applicant regarding the potential impact of the construction works on the operations of the Calor site. In this regard, Calor welcomes the Applicant’s comments within the Consultation Report (Appendix E - Ref: EN070008/APP/5.2.5) which note (amongst other things) that the Applicant will seek to maintain access to the Calor site during the construction period. However, despite this, it is noted that the Draft Construction Traffic Management Plan (‘CTMP’) (Ref: EN070008/APP/6.4.12.5) does not make any reference to the Calor site or indicate how access will be maintained during the construction phase. Whilst the Draft DCO requires the submission and approval of a CTMP prior to the commencement of each stage of development (Schedule 2, Part 1, Para 6), Calor remains concerned that the Application documents do not clarify how access arrangements will be maintained during the construction period. Calor requests that this information is submitted during the examination process to provide certainty that their business operations will remain unimpeded during the construction period. 3) Potential impact on future development at the Calor site during the operational phase Paragraph 3.7.31 of the Description of Development (Ref: EN070008/APP/6.2.3) notes that a permanent pipeline easement (minimum width 8m) will be established to allow access to the pipeline for inspection, maintenance and repair. Paragraph 3.7.32 goes on to state: ‘Once the pipeline has been installed, normal agricultural practices will be able to resume above the pipeline. Restrictions will be imposed on other activities over or in close proximity through the pipeline. Landowners and occupiers will need to seek consent from the undertaker to carry out activities that might interfere with the authorised development’. Given the proximity of the proposed pipeline to the Calor site (under Option 1) and taking into account the degree of flexibility that may be considered appropriate within a DCO application, Calor seeks assurance that their site would not fall within the easement widths of the pipeline and that future development of the site is not stymied.