Representation by DFDS SEAWAYS PLC (DFDS SEAWAYS PLC)
- Date submitted
- 4 December 2023
- Submitted by
- Members of the public/businesses
DFDS SEAWAYS RELEVANT REPRESENTATION ON THE PROPOSED IMMINGHAM GREEN ENERGY TERMINAL PINS REFERENCE TR030008 1 Introduction 1.1 This relevant representation is made on behalf of DFDS Seaways (DFDS) in respect of the Immingham Green Energy Terminal (IGET) Development Consent Order (DCO) application. 1.2 DFDS is an international shipping and logistics company and one of the largest users of the Port of Immingham, with around 1000 employees involved in its operations there, both ferry-based and landside. 2 In-principle non-objection 2.1 In principle, DFDS does not object to Associated British Ports’ (ABP) plans for the IGET which comprises of a multi-user liquid bulk green energy terminal and its associated hydrogen production facility. DFDS has a target to reduce emissions by 45% by 2030 with the target of climate neutral by 2050. Greener fuels for vessels will be a large part of the green agenda. 2.2 However, DFDS has concerns around particular elements of the IGET application documents, primarily in respect of marine navigational safety. 3 Concerns in respect of marine navigational safety 3.1 DFDS has made extensive submissions during the Examination of ABP’s other live DCO project in the Port of Immingham, the Immingham Eastern Ro-Ro Terminal (IERRT) (PINS Ref: TR030007), and, while DFDS appreciates that these are entirely separate projects, it cannot ignore the geographical proximity of the two projects whose construction and operational phases will overlap and a few of the same issues relating to the navigational safety for all users of the Humber Estuary which it has raised in respect of IERRT and considers also to be relevant for IGET. These are: 3.1.1 Navigational Risk Assessment (NRA): The methodology adopted in the NRA lacks stepped changes in tolerability thresholds for high consequences, as well as an inconsistency between risk categorisation and tolerability. In essence, the basis upon which tolerability was derived is not set out. 3.1.2 Tidal direction: the tide as depicted in the simulations appears contrary to published data both locally and by the Admiralty in addition to varying from the daily experience of DFDS PEC holders. It also appears contrary to the tide data as set out in Chapter 16 (Physical Processes) of the Applicant’s Environmental Statement [APP-058]. 4 Concerns in respect of marine and onshore congestion and disruption 4.1 Tug availability: 4.1.1 We note that the Applicant includes the following response to this point which DFDS raised at consultation: “The provision of towage on the Humber is wholly driven by market forces and it is reasonable to assume – and indeed has been proven in the past – that should demand for additional towage become apparent, tug providers will increase vessel resourcing accordingly.” (ES Chapter 12, page 10) Adding more vessels and leaving the provision of towage to ‘market forces’, does not guarantee sufficient towage, especially in the short term, and so could lead to delays and disruption to business. 4.2 Onshore transport: 4.2.1 The local road network is sensitive to additional traffic. Caution should be exercised around conclusions of no or limited impact on the local road network and nearby residential, commercial or environmental areas. In light of this, DFDS would request that the Applicant justifies or clarifies any assumptions being made (i.e. distribution to the road network, times of movements, etc), and where applicable, undertakes suitable sensitivity analysis of potential variations in design parameters (i.e. for traffic distribution and assesses a range of options of traffic volumes along the applicable corridors). 4.2.2 The Applicant should state the source of material used for the Transport Assessment, such as the vehicle numbers identified for the committed developments which currently do not provide a source document or reference to the appropriate data table. This could lead to potential confusion and difficulty in assessing the accuracy of the IGET onshore transport element. It is not clear whether data corrected in a separate technical note for the IERRT Transport Assessment has been used within IGET’s cumulate assessment. 4.2.3 We note that works will be required in the vicinity of the East Gate entrance to the Port of Immingham. The East Gate has been identified as a key throughfare for access to the Port of Immingham for IERRT, with modifications to the approach to the Gate required. Access to IGET will principally be from a right hand turn just before the East Gate onto Laporte Road. This pinch point (the Queens Road and Laporte Road junction) needs careful consideration, including the approach to the East Gate, considering the cumulative impacts of both projects during construction and operations, to mitigate congestion of entering traffic. This is of concern to DFDS as their staff utilise this approach on regular occurrences. 5 Summary 5.1 DFDS does not object in principle to the IGET development but wishes to register as an Interested Party for the purpose of this DCO examination and notes concerns over the Applicant’s approach to its NRA for the IGET, which in DFDS’s opinion, does not provide a proper assessment of risk.