Representation by Anglian Water Services (Anglian Water Services)
- Date submitted
- 4 December 2023
- Submitted by
- Members of the public/businesses
Immingham Green Energy Terminal - Anglian Water Relevant Representation Anglian Water Services is the statutory water wholesaler for non-domestic supplies and wastewater service provider for the Immingham area in North East Lincolnshire. Anglian Water’s response to the Scoping consultation submitted in October 2022 sets out the key issues which the applicant should consider and assess in the design and mitigation of the project. These include 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 the applicant and other developers on the South Humber about their potential water demands. The initial outcome of that work is that some 60 Mega Litres per Day (MLD) 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. The Water Resource Zone (WRZ) within which the project sits has headroom of 3.6MLD. That supply will decline due to abstraction reductions at the same time demand is forecast to increase. 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. It also sets out that applicants for water for non-domestic purposes must fund infrastructure required to maintain headroom for domestic customers. New non- domestic water demand requests are currently assessed on a first come, first served, and then connected basis. Demand requests are not prioritised based on 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 Immingham Green Energy Terminal (IGET) will require 4.4 MLD of water principally as cooling water for the green hydrogen production process. It is understood that the current private water supplies in the Immingham area, for example the borehole (Figure 21.3 in the application) are not able to meet this additional water demand. In early 2023 Anglian Water advised the project that a smaller water demand could potentially be met from a raw water supply served by abstraction at Elsham. Subsequent work on the WRMP established that this possible supply would not be available at the date in the future this is first required by the project. The applicant’s summary (6.2 Environmental Statement – Chapter 18: Water Use including page 18-25, 18-32 and 18-37 plus page 18-15 regarding the network connection location) have therefore been superseded. Anglian Water initially advised the project in March 2023 that they would need to progress other supply options. Those discussions are ongoing and given the timescales of the project and regulatory provisions a supply of water (specification to be confirmed) may (subject to commercial agreement) be delivered by an unregulated company within the Anglian Water Group or another non-appointed entity. The source, treatment facility and network which could supply water to the project does not form part of the application. One option may be for the project to source a final effluent water supply from the Pyewipe Water Recycling Centre (WRC) at Grimsby and to treat this in a new facility at a point between Pyewipe WRC and the project site. As a modular solution this option could provide significantly more volume than the project’s 4.4MLD demand. 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 deliverable and sustainable. AWS considers Chapter 18 of the Environmental Statement (ES), with further revisions, could constitute an acceptable WRA. AWS will work with the promoter to update the ES. When the supply, treatment and/ or transfer of that water supply requires separate planning consent and authorisations the detailed assessment of those project(s) would be within the assessment which accompany those separate applications. When the supply options are uncertain at application and Examination stage, AWS will seek to agree a pre -commencement Requirement with applicants in the DCO Order or planning permission which requires a final WRA to be agreed with AWS prior to its submission to the LPA (Local Planning Authority) who may then consult the Environment Agency. AWS considers the proposal by the applicant to set out these matters in a final post consent and pre commencement ‘Water Management Plan’ (page 18-6 of Chapter 18 of the ES) as part of the Construction Environment Plan (CEMP) provides a potentially acceptable approach for the promoter to resolve these matters. AWS requests that the ES (page 18-49 to 18-51) includes and considers the National Policy Statement for Water Resources designated on 18 September 2023. Water Recycling In addition to the possible supply option using final effluent from Pyewipe WRC, AWS are progressing discussions with the project (page 18-14 of Chapter 18 of the ES) on the treatment of trade waste from the project at the Immingham WRC. This may require an expansion of capacity at Immingham WRC and so consequent applications to the Environment Agency and North East Lincolnshire as the waste planning authority. Discussions with the project have the overall objective of seeking to maximise process efficiency and the options to re-use and / or further treat the wastewater either within the project and through its utilisation by nearby industrial users. Flooding and surface water AWS supports the project (Appendix 18.B) in managing surface water on site using Sustainable Drainage systems (SuDS). We note that Habrough Marsh Drain operated by the ELDB (Chapter 16: Physical Processes) and the North Beck Drain (Appendix 18.A) will be utilised in managing flood risks. AWS notes the planned updated to the Environment Agency flood models in 2024 which will include revised climate change allowances. If the revised model requires consideration 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 (Appendix 18.B) including the relevant DCO Order Requirements. Existing AWS assets AWS considers that the protection of existing network assets in and near the project site can be secured through Protective Provisions. The intention is that agreement on these and other matters will be covered by the bilateral Statement of Common Ground. Approved by [Redacted], Head of Sustainable Growth (4.12.23)