Representation by PD Port Services Limited (PD Port Services Limited)
- Date submitted
- 15 January 2024
- Submitted by
- Members of the public/businesses
Application by Chrysaor Production (U.K.) Limited (“Chrysaor”) for an Order Granting Development Consent for the Viking CCS Pipeline ("the Project") 1. This Relevant Representation is submitted on behalf of PD Port Services Limited (Company Registration Number 01233997) of 17-27 Queen's Square, Middlesbrough, TS2 1AH (“PD Ports”). 2. PD Ports wishes to make this Relevant Representation on two initial grounds. Firstly, in order to protect its position in relation to land within and adjacent to the proposed Order limits which PD Ports has the benefit of a restrictive covenant ("the Covenanted Land"). Secondly, to ensure that access to and from the PD Ports warehousing site at Unit 7 Laporte Road, Stallingborough, Immingham DN40 2PR ("Laporte Road") is retained and PD Ports' operations from Laporte Road can continue unaffected from any impacts of the Project. 3. PD Ports is a subsidiary of PD Ports Limited. PD Ports Limited is a Middlesbrough headquartered port, shipping and logistics company. PD Ports Limited is the owner of Teesport, and ports at Hartlepool, Howden and Keadby; with additional operations at the Port of Felixstowe, Port of Immingham, and Port of Hull. PD Ports Limited employs around 1,500 people nationwide. PD Ports Limited's Immingham operations (which include those at Laporte Road) include 64,000 square feet of bonded covered warehousing and large open areas for storage of a diverse range of cargo such as metals, construction materials, forest products, agribulks and other cargo. Laporte Road benefits from the area’s road access, with the A180 nearby connecting to the East Coast with motorways heading both north and south (M18, M1 and A1) and west (M62). The Covenanted Land 4. The Covenanted Land is known as Unit 1 and Unit 2 Manby Road, South Killingholme North Lincolnshire and is registered under HMLR titles HS294686 and HS19809. The Covenanted Land is currently owned by Phillips 66 Limited (the "Landowner"). The Covenanted Land is subject to a covenant for PD Ports benefit restricting its use to those within Use Class B2 or B8 with an ancillary B1 user. 5. The Covenanted Land was originally owned by PD Ports and was transferred to the tenant at the time, ConocoPhillips, subject to this covenant in 2012. The covenant was included to recognise PD Ports interests if the Covenanted Land is subsequently developed. 6. Chrysoar is seeking to use the Covenanted Land for the construction of a 24-inch (610 millimeter) external diameter Carbon Dioxide pipeline section of approximately 1.1km length as shown on Work No.2 and Work No.3 of Sheet 1 of 36 of the Works Plan Part 1 [APP-014]. Compulsory acquisition powers are sought for the subsurface of plots 1/15, being the northern corner of the Covenanted Land and Plots 1/37, 1/46, 1/58, being the eastern tip of the Covenanted Land as shown on Sheet 1 of 36 of the Lands Plans [APP-016]. 7. PD Ports understands from the "Schedule of Negotiations and Powers Sought" [APP-012] that the Landowner has entered into negotiations for a voluntary agreement for the rights to construct and operate the Project. However, PD Ports considers that it is presently unclear as to how any rights given to Chrysaor through the DCO will take into account this covenant and that the location of the pipeline will not affect the future development potential of the Covenanted Land. 8. It is also unclear whether sufficient protections are within the draft DCO [APP-006] to ensure that the pipeline will only be used as a Carbon Dioxide pipeline and that after its installation, the pipeline will not be used for any other purpose. Laporte Road 9. PD Ports is concerned whether access to Laporte Road will be adversely affected by road closures and diversions associated with the Project. Access to Laporte Road will also be affected by the proposed Immingham Green Energy Terminal DCO ("IGET"). Road closures and diversions may be exacerbated if the impacts of the two projects overlap. 10. The IGET proposed road closures and diversions will restrict access to Laporte Road from the Immingham Dock to a three mile diversion route using the A1173 and Kiln lane during its construction phase. Egress from Laporte Road uses Kiln Lane to access the A180 and the wider national road network. 11. The Project proposes works along the A180 and A1173 as shown at Sheets 5 and 8 (at Point 8-SB) of the Public Access and Rights of Way Plan [APP-033]. These works may affect access to and from Laporte Road and potentially interfere with PD Ports' operations. It is unclear how access will be maintained while the IGET diversions are also in place and that these will not result in a further interference with PD Ports' operations. 12. Further, PD Ports considers there is a lack of information provided by Chrysaor with respect to vehicle restrictions, particularly regarding potential weight and height restrictions on the A180 and A1173. 13. Altogether, the lack of this information means that PD Ports cannot fully consider the impact on its own operations as a result of the Project or its impact alongside that of IGET. 14. In light of the above, PD Ports requests to be registered as an Interested Party to the examination and reserves the right to make further representations during the examination process in response to any further information provided by Chrysaor.