Representation by Southern Gas Networks Plc (Southern Gas Networks Plc)
- Date submitted
- 8 March 2023
- Submitted by
- Other statutory consultees
Dear Sirs Highways England (Promoter) Application for an Order Granting Development Consent for the M3 Junction 9 Improvement project (Order). Planning Inspectorate Reference: TR010055 Objection on behalf of Southern Gas Networks Plc (SGN) 8 March 2023 Addleshaw Goddard LLP acts on behalf of SGN and is authorised to make this relevant representation on its behalf in objection to the proposed Order. SGN is the licensed gas transporter for the Order area, and objects so as to ensure the protection of its interests in land and apparatus and the safe and effective operation of its gas transportation network. As a responsible statutory undertaker, SGN's primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. The Promoter seeks powers within the Order for the compulsory acquisition of land and rights in which SGN is interested. SGN therefore wishes to protect its position in light of existing apparatus which is both within, and in the vicinity of, the proposed Order boundaries through suitable protective provisions being secured in the Order. SGN’s rights to retain its infrastructure in situ and rights of access to inspect, repair and renew such apparatus within the limits of the respective Order must be maintained at all times, and access by SGN and its servants and agents to that apparatus for the purpose of its undertaking must not be restricted. Accordingly, SGN will require appropriate protective provisions to be included within the Order to protect its statutory undertaking and to ensure that public safety is not compromised. Equally both the Examining Authority and the Secretary of State will need to be satisfied that the project will not cause a serious detriment to the carrying out by SGN of its statutory undertaking before granting consent to the proposed Order. In view of the above, and pending agreement with the Promoter, SGN objects to the Promoter's application and reserves its right to make further representations during the Examination process should that be so necessary. However, SGN is in the process of reviewing the draft Order and associated plans, and looks forward to engaging constructively with the Promoter in an effort to resolve all issues of concern. Should the Examining Authority require any additional information from SGN further to this representation, please contact Charlotte Jones of Addleshaw Goddard LLP, 3 Sovereign Square, Sovereign Street, Leeds LS1 4ER. Yours faithfully Addleshaw Goddard LLP