Representation by Anglian Water Services (Anglian Water Services)
- Date submitted
- 15 January 2024
- Submitted by
- Other statutory consultees
Anglian Water Services is the statutory water and wastewater services provider for the proposed pipeline route from Immingham to Theddlethorpe in North East Lincolnshire and East Lindsey District areas. Anglian Water’s response to the Scoping consultation April 2022 sets out the main issues which the applicant should consider and assess in the design and mitigation of the project. This includes matters required to be considered under relevant National Policy Statements. • Water Supply As part of our Water Resources Management Plan (WRMP) process for the AMP8 (2025 to 2030) period, Anglian Water has been in discussion with other developers on the South Humber about their potential water demands. The initial outcome of that work is that some 60MLD of additional water supply has been included in the draft WRMP. The final determination by regulators of the WRMP is anticipated to be concluded in or about December 2024. The need for an additional 60MLD of supply was identified through assessment of the existing and future water supplies. Currently the Water Resource Zone (WRZ) within which the project sits has a headroom of 3.6MLD. That is forecast to decline as housing growth, climate change and abstraction reductions increase demand and reduces supply. In June 2023, Anglian Water published a position statement on non- domestic water demands. In summary, this advises that where a request for a new or increased non- domestic water demand may compromise Anglian Water’s ability to supply existing and forecast new domestic customers that request is likely to be declined. New water demand requests are currently assessed on a first come, first served and then connected basis and requests are not prioritised on the basis of national policy such as the net zero transition or through cumulative assessment of the impacts and benefits of projects. Anglian Water Services is currently unable to enter an agreement to supply water which is for a connection and supply that is more than 12 months in the future. Anglian Water understands that the Viking CCS project will not require a water supply from Anglian Water for construction, operation or decommissioning. Instead the industries on the South Humber will require water for their carbon capture processes. The Environmental Statement (ES) submitted with the Viking CCS application states that for water supply: The potential impact on potable water supply throughout the study area includes reduced availability of water for abstraction within surface water bodies due to abstraction for construction activities associated with installation of the pipeline. The associated embedded mitigation (Section 11.6) states that all abstractions will be sought from the Environment Agency, Lead Local Flood Authority / Internal Drainage Board (IDB) / Canal and River Trust where necessary. Abstraction licenses are also temporary (less than 28 days per water feature). Therefore, the magnitude of impact of reduced availability of water for potable supply is considered to be Negligible, therefore the significance of the effect is Negligible and therefore Not Significant. This therefore explains why Anglian Water has not had an application for a new non- domestic water supply for construction and operation of the 55km long pipeline from the Viking CCS project. The ES advises that water for hydrostatic testing will be ‘sourced from outside of the local area and delivered to the site by road-going water tankers or from the P66 site’. Anglian Water requests that Chrysoar, as the Viking CCS project promoter, provide updates for the Examination and Secretary of State on the projects of the prospective pipeline customers (see paragraphs 11.11.2 to 11.11.5), their latest water demand calculations and the position on when, how and where this will be sourced as an upstream cumulative impact. To support appropriate water resource planning, Anglian Water Services (AWS) now requires that significant new non domestic water demands are set out in a Water Resources Assessment (WRA). For applications under the 2008 Act the WRA (or a summary of the WRA) will form part of the Environmental Impact Assessment sufficient to enable regulators including the Environment Agency to advise the Examining Authority and the Secretary of State that the supply of water to the project is potentially deliverable and sustainable. Given the current water supply proposals for the Viking CCS project its WRA may have limited inputs from Anglian Water. It will be for those seperate carbon capture projects as subsequent applications, to set out in detail their own and cumulative impacts on water supply and resources. AWS requests that the ES (Table 11-1 page 11-2 to 11-4) includes and considers the National Policy Statement for Water Resources designated on 18 September 2023. • Water supply surface assets AWS notes that potential impacts on Covenham reservoir are considered at 11.5.47 and wider water resources at 11.5.61 and also shown on Figures 11-1 to 11-4. These receptors are then assigned values in Table 11-21. Covenham is correctly ascribed a ‘Very High Importance’ given its role in public water supply. We note the conclusions in paragraphs 11.5.72 to 11.5.81 that no significant changes to baseline conditions are identified as a result of the three project stages. Anglian Water considers that the embedded mitigation and measures set out in Tables 11-22 and 11-23 including the development, use and monitoring (11.10.1) of the Construction Environment Management Plan (CEMP) at Appendix 3.1 and Water Management Plan at Appendix 11.6 are likely to provide sufficient safeguards for these water supply assets. AWS pipelines are a separate matter which required specific Protective Provisions. • Water Recycling AWS notes that the project at Table 11-4 proposes that ‘all foul drainage include collection of foul drainage, which would be self-contained and removed from site for treatment’. Table 11-23 later advises in relation to Anglian Water’s drainage network that foul drainage ‘will be mitigated through the embedded mitigation whereby there will be an independently managed foul drainage system at the construction compounds with the foul water contained on site, regularly pumped, emptied, and transported off site.’ On that basis AWS considers that the right to connect to the public sewer in the Part 4 of draft DCO Order is not necessary and should be deleted from the draft DCO Order. • Flooding and surface water AWS supports the project in managing surface water on site and along the pipeline route through the use of Sustainable Drainage systems (SuDS). AWS notes the planned update to the Environment Agency flood models in 2024 which will include revised climate change allowances. If the revised model then requires consideration by the project of the use of the public sewer network to manage additional surface water flows, AWS will require it to be included as a consultee to the Drainage Strategy (document number 6.4.11.3) including the relevant DCO Order Requirements. • Existing AWS assets AWS considers that the protection of existing network assets in and near the project site and so the protection of water and water recycling services can be secured through Protective Provisions. Template Protective Provisions were supplied to the project during the Pre-Application stage. Our intention is that agreement on these Provisions and other matters will be covered by the bilateral Statement of Common Ground. With regards to the AWS assets identified in the Book of Reference the crossing locations include pipelines varying in size and material from 4inches PVC pipe to twin 1000mm & 900mm steel mains. AWS requires that for mobilisation, pre construction and construction works: 1. Trial holes to be undertaken to confirm mains depth prior to works commencing 2. Safe dig techniques to be followed for the trial holes and main works (after 500mm depth hang dig is required until the AWS main has been located) 3. The use of excavators without teeth on the buckets 4. No more than 2m of the mains to be exposed 5. If a joint is found, AWS network teams may need to call in additional engineering advice to attend to review the need for pipeline support 6. Network Team representative to be onsite for the duration of the excavation works at crossing points or if works are to be undertaken within standoff distances Our standard approach on standoff distances requires that these are as a minimum starting point: (a) 4 metres both sides of the pipe where the diameter of the pipe is less than 250 millimetres; (b) 5 metres both sides of the pipe where the diameter of the pipe is between 250 and 400 millimetres, and (c) a distance to be agreed on a case by case basis where the diameter of the pipe exceeds 400 millimetres With reference to (c) for the eight locations where 400mm or more pipe sizes will be crossed by the project AWS considers that a 7 metre standoff distance is required on both sides of the AWS pipelines. This will enable the project to effectively programme ground investigation and excavation works and so ensure an AWS network representative is in attendance for works within the 7m standoff distances. 15.1.24 Approved by Jonathan Glerum, Head of Sustainable Growth, AWS