Archived decisions

Decision Maker:

Regulatory Committee

Date of Decision:

26 November 2008

Decision Title:

Applicant: Star Energy Limited

Importation of Compressed Natural Gas by Trailer and Discharge to Generate Electricity Involving the Setting Out of a Trailer Discharge Area within Weston Common Wellsite, The Avenue, Lasham (Application No: BDB/67621)
(County Council Ref: BA057)

Decision Reference:

390

Report From:

Head of Planning and Development, Environment Department

Contact name:

Peter Chadwick

Tel:

01962 846728

Email:

[email protected]

EXECUTIVE SUMMARY

1) Background:

1.1. The proposal is to import compressed natural gas by trailer from the Singleton Oilfield, in West Sussex, and construct a new discharge area and equipment within the Weston Common site. The imported gas would be used to generate electricity in the two existing generators at Weston Common.

1.2. The application was considered at the Regulatory Committee meeting on 25 June 2008, when it was resolved to defer consideration as more information was required. Additional information has been provided on safety and risk issues, and additional consultation carried out with the Fire and Rescue Service and parish councils along the route to be taken by the lorries through Hampshire.

2) Issues:

2.1. The main issue is the transportation of the gas by road from Singleton and Weston Common, in terms of both principle and safety.

2.2. There are clear benefits to using the gas rather than flaring it. There is no suitable use in the immediate vicinity of Singleton, and there is suitable spare generating capacity at Weston Common to use the gas. The proposals within the Weston Common site would not have an adverse impact. The main issues relate to the importation by road, however the route uses principal roads which are suitable for this traffic, and the number of lorry movements is only 12 per day. An independent risk assessment has been carried out which concluded that Star Energy Limited had sufficient control measures to ensure the health and safety of its employees, contractors, other road users and members of the public during the project. It is recommended that permission be granted subject to conditions.

3) Recommendation:

3.1. That planning permission in respect of the importation of compressed natural gas by trailer and discharge to generate electricity involving the setting out of a trailer discharge area at Weston Common Wellsite, The Avenue, Lasham (BDB/67621) be granted for the following reason, subject to the conditions set out in Appendix 1.

4) Reason for Decision:

4.1. It is considered that the proposal would be in accordance with the development plan (summary attached in Appendix 2) as ancillary development within the oilfield, it would not materially harm the character of the area or the amenity of local residents and would be acceptable in terms of highway safety and convenience.

1) Site and Proposal:

1.1. The site, as shown on the attached plan, comprises an area of 0.4 hectares within the Weston Common wellsite. This is the main operational centre of the Humbly Grove Oilfield containing gas processing facilities, oil producing facilities, offices and control buildings. The Oilfield has operated since 1984, permission was granted for the gas storage infrastructure in 2003 and the site has planning permission until 2025. The Weston Common site is located within woodland, which is also a Site of Interest for Nature Conservation (SINC), the nearest houses are about 500 metres away, and access is via The Avenue.

1.2. The proposal is to import compressed natural gas by trailer from the Singleton Oilfield, in West Sussex. A new discharge area, measuring 20 metres by 15 metres, and equipment would be constructed within the Weston Common site. The imported gas would be used to generate electricity in the two existing generators, which currently have spare capacity.

1.3. The Singleton Oilfield produces about 500 barrels of oil per day. However in addition it also produces about 1.4 million standard cubic feet (mmscf) of gas per year. A small proportion of the gas is used on site for power generation but the majority is flared via two flare stacks. The applicant wishes to make beneficial use of this gas. This is not possible at Singleton, therefore the intention is to transport the gas to Humbly Grove where there is existing capacity for electricity generation.

1.4. The proposal would result in 12 lorry movements per day (6 in and 6 out). The proposed hours of operation for the lorries would be 0600 to 2200.

1.5. The applicant states that by not flaring the gas the proposals will result in reducing carbon dioxide emissions. It is estimated that, taking into account the carbon dioxide produced by the lorries transporting the gas, the proposals would save 30,000 tonnes of carbon dioxide as it would replace power taken from the national grid to operate plant at Humbly Grove. The gas will still be burnt, but by proposing to utilise it in the generator the energy will be captured that otherwise would be lost.

1.6. The application was considered at the Regulatory Committee meeting on 26 June 2008, when it was resolved to defer as it was considered there was the need for further information. The following issues of concern were raised:

(i) numbers of lorry movements to and from the site;

(ii) the need for independent risk assessment;

(iii) the possibility of temporary planning permission;

(iv) the relative economic, practical and planning merits of using the natural gas to generate electricity at its source, Singleton, rather than transporting it to Hampshire and generating electricity at Lasham;

(v) the need for consultation with the fire and rescue service on the potential dangers; and

(vi) the need for consultation with local communities along the route which would be used by the gas tankers.

1.7. Following the Committee resolution, consultation letters were sent to all town and parish councils along the route in Hampshire. In addition the Hampshire Fire and Rescue Service was consulted. The comments received are included under Consultations.

1.8. Further information has also been received from Star Energy. This included a Gas Container Transportation Report which concluded:

(i) the proposed design of trailer is the same as is currently being used in the UK by all the major transporters of high pressure inflammable gases. There are over 300 such trailers operating currently in the UK and this basic design of trailer has been operating for over 30 years in the UK; and

(ii) it is estimated that over three million trailer miles are currently covered in the UK by high pressure flammable gas trailers. In the past 10 years there has been one reported incident involving a high pressure gas transportation trailer carrying flammable gases, which was a collision resulting in minor injuries to the driver.

1.9. In addition a report providing a Numerical Chance Assessment of a Major Accident was submitted. This concluded that the numerical chance of a major accident (one resulting in single serious injuries through to multiple fatalities) occurring during Compressed Natural Gas (CNG) road transfer operations to be:

(i) 1 in 47 years for CNG vehicle road crashes where there is no loss of containment of the CNG load. This would be the same for other HGVs operating in UK;

(ii) 1 in 164 years for CNG vehicle road crashes where there is loss of containment of the CNG load which results in fire;

(iii) 1 in 3,115 years for CNG road crashes where there is loss of containment of the CNG load which results in a gas explosion;

(iv) 1 in 10,500 years for major accident that results in loss of gas containment due to system defect, wear or damage which results in a fire; and

(v) 1 in 199,800 years for major accident that results in loss of gas containment due to system defect, wear or damage which results in a gas explosion.

1.10. Star Energy also comments that it was served with a statutory improvement notice by the Environment Agency to explore all possible means to reduce the flaring of gas at the Singleton site and put it to beneficial use. Power generation at Singleton, over and above the needs of the site operations, would require connection to the grid. Feasibility studies were carried out which concluded that an electricity connection would not be viable because of prohibitive cost.

2) Development Plan:

2.1. Hampshire Minerals and Waste Core Strategy (2007) Policy DC22 concerns ancillary plant and proposals at active sites.

3) Consultations:

3.1. Basingstoke and Deane Borough Council raises no objection.

3.2. East Hampshire District Council raises no objection.

3.3. Environmental Health Officer, Basingstoke and Deane Borough Council comments has read the application and Environmental Noise Assessment for proposal and agrees in principle that the report findings confirm there should be no adverse impact on the local residents and therefore raises no objection.

3.4. Environment Agency raises no objection.

3.5. Highway Authority comments the route proposed includes the A272, A3, A32, A31, A339 and The Avenue. With the exception of The Avenue, these roads are all A-Classified roads, already widely used by a large number of HGVs. The number of trips proposed by the application represents only a very minor increase in terms of traffic impact. It is demonstrated that the lorries associated with this use will be able to successfully and safely negotiate the route proposed. The provided accident analysis does not identify any safety issues that will be materially exacerbated by the additional movements associated with this proposal. Therefore raises no objection subject to maintenance of visibility splays.

3.6. Health and Safety Executive raises no objection.

3.7. Hampshire Fire and Rescue Service comments that the transportation of hazardous materials legislation permits the carriage of CNG as long as correct labelling, training and handling of the material is carried out. These regulations also extend to storage, etc. Provided these regulations are complied with the proposed transportation of CNG by road tanker to Humbly Grove does not pose a greater risk than the transport of Liquid Petroleum Gas, chemicals and petrol by road tanker which already exists on the roads and highways.

3.8. South Warnborough Parish Council states it has no comments.

3.9. Weston Corbett and Weston Patrick Parish Council no comments have been received.

3.10. Alton Town Council - concerned at proposed increase in the number of HGVs using Whitedown Lane, a residential road, with a bottleneck at one end by virtue of the railway overbridge. Proposals such as these highlight the need for western bypass.

3.11. Lasham Village Committee objects on the grounds of the traffic and safety impact. The A339 is a black spot which will be exacerbated by additional traffic, road too narrow and used for recreation purposes, and concern about noise at night.

3.12. Herriard Parish Council fully endorses the use of otherwise wasted natural gas from Singleton to generate electricity, however it would be more satisfactory if the generating plant was at Singleton. In respect of road transportation concern at vehicles turning across flow of traffic from the A339 onto The Avenue. As proposed movements are day and night, seven days a week, concern that intensification of use between 12 am and 8 am could be significant and lead to a loss of amenity for residents on The Avenue. Concern at the suitability of the width of The Avenue for taking these tankers.

3.13. Shalden Parish Council raises objection on the grounds that the traffic density, and size of vehicle involved, would represent a grave danger to local existing traffic on the minor C-class roads approaching the Humbly Grove site.

3.14. Farringdon Parish Council raises objection as it is opposed to movement of pressurised gas by road, on grounds of safety to the villages/towns and road users on the proposed route and, irrespective of cost, insists on pipeline delivery.

3.15. Langrish Parish Council raises objection to the transportation of gas through their Village Street. Objects to increase in number of heavy vehicles using country roads not designed or made to transport large vehicles. Objects to the transportation of dangerous substances through the villlage, where houses adjacent to the roadside and some very dangerous bends.

3.16. Petersfield Town Council commented that whilst the vehicle's journey will take it through part of the town, the details of the proposal were noted as having only a very slight impact.

3.17. West Sussex County Council raises no objection, and planning permission has been granted for the installation of a compressed natural gas unit, trailer loading area and associated plant and the export of gas by road from the Singleton Oilfield.

3.18. The Avenue Residents' Association (TARA) comments that whilst agrees with principle of not flaring-off gas, there are concerns:

(i) The risks associated with transporting the material between Singleton and Humbly Grove, with the worst case scenario clearly documented, particularly at Weston Common and urban areas such as Alton. Expects an independent risk analysis including an assessment of the possible consequences of a road accident leading to gas leakage and ignition.

(ii) Had all alternative solutions been sufficiently investigated. Not satisfied that it has been proven that to use the gas at Singlerton is not feasible and fundable?

(iii) The environmental safety and loss of amenity effects of regular lorry transport in a rural area.

(iv) The issue of existing planning use and `planning creep'.

3.19. Councillors McNair Scott, Glen and Kemp-Gee have been informed. Following Liaison Panel meetings, their comments are:

(i) The County Councillors on the Humbly Grove Liaison Panel should only support the application if it is catagorically established that there is no untoward danger to local residents and the towns and villages along the proposed route.

(ii) The Liaison Panel County Councillors would suggest that only an 18 month temporary permission is granted so that it can be judged whether the application is working well and safely with minimum annoyance to local residents.

(iii) The Liaison County Councillors should request that Star Energy Limited provides a Section 106 annual payment of a minimum of £10,000 per annum towards Hampshire Highways expenses in maintaining local roads because of increased lorry traffic.

(iv) Most importantly there should be a schedule of lorry movements that avoids turning right manoeuvres off the A339 into The Avenue during rush hours. The schedule should also specify days and hours of operation, ie avoiding weekends and bank holidays and early morning and evening or night-time periods.

(v) The Liaison Panel County Councillors wish to express their concern to the Regulatory Committee about the continuing breakdown of the oil pipeline from Humbly Grove necessitating a whole separate series of lorry movements to shift the oil that is being pumped.

(vi) The Liaison Panel County Councillors wish to remind the Regulatory Committee that the original planning consent is for oil extraction and not the storage of gas. Once gas storage becomes the only major activity at Humbly Grove the planning consent should be withdrawn or subject to a completely new Planning Application.

4) Representations:

4.1. Forty letters of objection have been received, 25 letters from local residents, raising the same issues as TARA, and 15 letters from wider afield, the majority being from the Alton area, concerned about the route between Singleton and Weston Common.

5) Commentary:

5.1. There are clear benefits commercially and environmentally from using the gas produced at the Singleton Oilfield rather than flaring it, and the applicant considers that it is not financially viable to utilise this gas at Singleton as there is currently no connection to the grid. The additional works at Weston Common and use of the gas in the existing turbines would not cause any adverse impact for the locality or local residents. The main issue is the transportation of the gas by road from Singleton and Weston Common, in terms of both principle and safety.

5.2. Concern has been raised to the principle of bringing the gas to Weston Common because of perceived changes in planning status of the site from initially oil and gas production, then more recently gas storage and now proposed importation of gas for power generation. However, there is already power generation at Weston Common for producing electricity for operating the oilfield with surplus going to the National Grid; this uses gas produced from the oilfield. There is spare generating capacity and this proposed importation would not require additional capacity to be provided. At the proposed level of importation it is considered the use is ancillary, and would not give a precedent for other development. There is also concern that importation by road is contrary to the original principles of the operation of the oilfield, which was to use pipelines to transport oil and gas to minimise the impact. However this proposal involves a low number of lorry movements, six in and six out per day only. Moreover, the proposal would not change the temporary planning status of the oilfield which expires in 2028.

5.3. A significant concern from local residents is about risk due to the nature of the gas, and its transport by road. In response to these concerns Star Energy has commissioned risk assessments and provided additional information. This concluded that Star Energy has considered the risks to its employees, contractors, other road users and members of the public and has planned sufficient control measures to ensure their health and safety during the project. The company has also appraised its legal obligations and taken adequate steps to ensure compliance with applicable legislation. The risks, taking into account current and planned risk control measures, will be as low as reasonably practicable. Additional information has also been submitted by the applicant assessing the potential route in detail to show it is acceptable in highway terms for the proposed traffic. The highway authority has considered this information, as well as the original submission, and is satisfied, raising no objection in terms of highway safety. The Hampshire Fire and Rescue Service considers that, provided the regulations are complied with, the transportation of CNG by road tanker poses no greater risk than other materials such as LPG, chemicals or petrol. In conclusion there is shown not to be an exceptional risk from transporting the CNG.

5.4. Concerns were also raised about the amenity impact of traffic at night, as originally the proposals were for a 24 hour operation. The applicant has responded to this concern by restricting the proposed importation to between 6 am and 10 pm only, therefore not running overnight. Star Energy comments that these hours are required to make the project viable because gas is produced continually at Singleton. Otherwise there is the need for additional storage and flaring.

5.5. In conclusion there are clear benefits in using the gas rather than flaring it. There is no suitable use in the immediate vicinity of Singleton as it is not connected to the grid, and there is suitable spare generating capacity at Weston Common to use the gas. The Humbly Grove oilfield has permission for both oil and gas production, and gas storage to 30 September 2025. The proposals within the Weston Common site would not have an adverse impact. The main issues relate to the importation by road, however the route uses principal roads which are suitable for this traffic, the number of lorry movements is only 12 per day and the risk assessment classified the risk associated with the transport of the compressed natural gas as low. This is confirmed in the additional information provided. A limited trial period is not considered appropriate given the low number of vehicles involved and the costs of the necessary infrastructure, and the applicant has amended the operating hours to avoid night time movements. It is recommended that permission be granted subject to conditions.

Section 100 D - Local Government Act 1972 - background documents

The following documents discuss facts or matters on which this report, or an important part of it, is based and have been relied upon to a material extent in the preparation of this report.

(NB: the list excludes published works and any documents which disclose exempt or confidential information as defined in the Act.)

Document

Location

Importation of Compressed Natural Gas by Trailer and Discharge to Generate Electricity Involving the Setting Out of a Trailer Discharge Area within Weston Common Wellsite, The Avenue, Lasham (Application No: BDB/67621)
(County Council Ref: BA057)

Environment Department

Castle Avenue

Room G, Lower Ground Floor

CONDITIONS:

Commencement:

1) The development hereby permitted shall be begun before the expiration of three years from the date of this permission.

Reason: To comply with Section 91 (as amended) of the Town and Country Planning Act 1990.

Timescale:

2) All plant, structures and hardstandings hereby approved shall be removed at the end of the life of the oilfield, or by 30 September 2025 whichever is the sooner.

Reason: To ensure the restoration of the site.

Noise:

3) Noise levels arising from the operations at Weston Common shall not exceed 40dB(A)L10 between 0700 and 2200 hours and 35 dB(A)L90 between 2200 and 0700 hours when measured outside the nearest dwelling throughout the life of the development.

Reason: In the interests of local amenity.

4) Prior to commencing work on the site a noise monitoring procedure shall be submitted to the Mineral Planning Authority for approval in writing. The procedure will cover the phases of site construction, commissioning and operation and will be implemented as approved for the duration of the operation of the site.

Reason: In the interests of local amenity.

Hours of Working:

5) Construction work shall only take place between the hours of 0700 and 1800 Monday to Friday (except recognised public holidays) and between 0700 and 1300 on Saturday.

Reason: In the interests of local amenity.

6) Lorries associated with the importation of gas shall only enter or leave the site between the hours of 0600 and 2200.

Reason: In the interests of local amenity.

Highways:

7) Lorry movements to and from the site shall be restricted to 12 (6 in and 6 out) per day. A daily record of lorries entering and leaving the site shall be kept at the site and made available to the Mineral Planning Authority on request.

Reason: To limit the volumes of traffic in the interests of the amenity of residents on and near the approaches to the site.

8) Visibility splays of 3 metres by 225 metres at the junction of the access road with The Avenue shall be provided and maintained. These splays shall be kept free of obstacles.

Reason: In the interests of highway safety.

HAMPSHIRE MINERALS AND WASTE CORE STRATEGY DPD 2007

Policy DC22 - Additional Plant, Buildings and Minor Development

Additional plant, buildings and minor developments at active minerals and waste sites, or the exploration of minerals (except oil and gas), will be permitted provided, where appropriate, they do not extend the timescale for completion of the development , they are ancillary to the operation of the site or they provide for the co-location of complementary minerals and waste activities.