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What comments were received during the Hydrogen Production Plant consultation?

The comments received during the Hydrogen Production Plant consultation are listed in the table below, categorised by theme, alongside responses to each comment from the project team.
Item Comment Consultee Response
Traffic impacts
1 Work starting in 2022, and leading to 6,000 jobs. What provision will be made to ensure the safety of children of Thornton le Moors who need to cross the A5117 safely to get to their school bus? It sounds like both the construction activity and the increase in local jobs is going to contribute significantly to the already heavy traffic travelling at 60 mph on the A5117 particularly at school bus times. We would like pedestrian traffic lights to ensure vehicles are aware that pedestrians are crossing, as children are vulnerable, and may not have a good awareness of when it is safe to cross. Not known The figure of 6,000 new jobs relates to the wider HyNet North West project. 

As part of the planning application, we have prepared a Transport Assessment and a Framework Travel Plan. These will assess any potential impact on the highway network and identify the full range of mitigation measures that will be required. 

It is anticipated that there will be a temporary increase in traffic whilst the HPP is being built through construction related traffic movements, such as construction workers travelling to / from the site and through the delivery of construction materials. 

Throughout the construction period the average size of the construction workforce would fluctuate depending on the activities being undertaken. It is anticipated that the workforce would peak at approximately 600 people. 

A range of mitigation measures will be put in place to ensure that any disruption on the local roads, particularly during peak periods, is kept to a minimum during the construction period. This is likely to include the following:
  • On-site working during construction primarily Monday to Friday.
  • All routine construction traffic travelling to the site via the motorway network and then via the A5117 from its nearest motorway junction in order to enter the site access at the existing Gate 6 entrance off Pool Lane.
  • All construction traffic will park on site.
  • Arrangements for shared transport for construction workers travelling to / from site will be put in place.
  • Staggered start / finish times for different trades of workers on site will be implemented.
  • Heavy vehicles would only arrive and depart the site outside of the hours when construction workers are scheduled to arrive or depart the site.
The number of oversized loads delivered to the site is expected to be low, but where needed they would be carefully managed and scheduled through agreement with the local highway authority. These deliveries would be made at a separate access off the A5117.

Once the HPP is operational there will be a very slight increase in traffic as a result of approximately 20 members of staff who will work at the plant over the course of a 7-day working week. This level of increase in traffic will not result in any observable change to traffic on the local roads close to the HPP site.
2 Firstly during the construction of phase 1, how will the plant and construction traffic be accessed onto the site, there has been a long period of time that the A5117 has been badly affected by the construction of the Cycle way. Further disruption for any length of time will be an added burden to the village and other travelers to Helsby and onwards. Once the site is active, how much extra traffic has been anticipated and how will the site employees access their work? Already we have extra traffic through the village. No more should be contemplated and any employees must be made aware that the village is not a short cut to work. We have only speed bumps in certain areas; these are often not effective as they can be and are straddled by vehicles, more traffic is not welcome or safe. The direct route to the site for employees would be via Parklands drive, there are no speed controls on this road and gets used as a speedway already; it will not take further traffic, it must be made clear that it is not a route to work. Not known See response to comment 1.
3 What traffic surveys have been carried out so far to forecast traffic loads during the build and beyond? The A117 is already gridlocked at peak times with run off traffic coming into the village and down the country roads?  Not known As part of the planning application, we have prepared a Transport Assessment and a Framework Travel Plan. These will assess any potential impact on the highway network and identify the full range of mitigation measures that will be required.
Environmental impacts
4 will be better if you run the plant in a a better manner that is in site not adding to it and stop all the noise and the pollution from the plant web site says you care about the residents of Elton village this farther from the truth this is an objection to this plan new plant is sited to close to Elton this plant may be of High risk to all member of Elton Elton’s Resident An Environmental Statement (ES) has been prepared to assess the environmental impacts of the proposed Development and will accompany the planning application. 

The need to minimise environmental impacts is a key consideration and the work undertaken in preparing the technical assessments as part of the ES, Transport Assessment and Flood Risk Assessment has resulted in an iterative design process that has sought to minimise noise, air quality, flood risk / drainage and visual impacts in particular. The technical development of the proposed Development has included detailed risk assessments to eliminate risks where possible and otherwise mitigate against them, with process plant being located away from site boundary specifically to ensure that risks at the site boundary are strictly controlled as required by UK Health & Safety Executive.
5 What impact assessments have been carried out on the air quality bearing in mind the existing plant still covers the village from time to time with dust and a strong acrid odour in addition to late evening flaring?  Not known See above response.
6 your application is somewhat erroneous in so much as you are still proposing the use of fossil fuels to create the hydrogen. I am not against hydrogen production, but to get to a zero or carbon neutral deliverable is there not another way Not known The Climate Change Committee (CCC) which is an independent, statutory body established under the Climate Change Act 2008 estimates that blue hydrogen (which is derived from methane in natural gas) will reduce overall emissions by up to 85%, compared with direct use of fossil gas. According to CCC, blue hydrogen can “help grow the hydrogen option while also reducing emissions.”  The Government recently proposed a UK Low Carbon Hydrogen Standard alongside its UK Hydrogen Strategy.  We fully support the need for such a standard to ensure that low carbon hydrogen production in the UK delivers on the promise of making rapid and material reductions in Greenhouse Gas emissions.

As set out in the Prime Minister’s Ten Point Plan for a Green Industrial Revolution, working with industry, government is aiming for 5GW of low carbon hydrogen production capacity by 2030 for use across the economy. The Development uses “at scale” hydrogen production technology for two trains that together would produce ˜1 Gigawatt (GW) or 20% of the UK Government’s 2030 target. 

It is noted that other forms of hydrogen production such as electrolysis are not currently feasible at the scale required to start significantly tackling climate change this decade which is why the UK Government is proposing a twin-track approach, rolling out blue hydrogen now while supporting development of green hydrogen technology.

The hydrogen produced by the proposed Development will be made from natural gas and refinery off-gas, which are both fossil fuels. These fuels must be acquired and refined, and it is true that the processes necessary for these purposes give rise to greenhouse gas emissions (GHG).  However, these emissions are relatively small in comparison with the carbon dioxide (CO2) liberated when the fuels are burned, and it is in this latter regard where the proposed Development will make a substantial contribution to the UK government’s drive to net zero.  The plant will capture ˜97% of the carbon present within the fossil fuel – CO2 that would in the past have been released to atmosphere – and send it for permanent geological sequestration, while converting the fossil fuel to clean-burn hydrogen: hydrogen does not produce CO2 when burned. 

The proposed Development will also be an engine for the development of hydrogen distribution infrastructure, thereby helping the future deployment of other hydrogen production technologies.

Further background information to support this can be found at www.hynet.co.uk.
7 Your application wording is somewhat erroneous in that fossil fuels will be the main feed stock for the production of hydrogen. Whilst not being against hydrogen production I wonder why when trying to achieve net zero or neutral carbon emissions fossil fuels still have to be used? Not known See response to comment 6
8 https://onlinelibrary.wiley.com/doi/full/10.1002/ese3.956 Blue hydrogen does not support the transition to a net zero economy. "Similarly, we see no advantage in using blue hydrogen powered by natural gas compared with simply using the natural gas directly for heat. As we have demonstrated, far from being low emissions, blue hydrogen has emissions as large as or larger than those of natural gas used for heat (Figure 1; Table 1; Table 2). The small reduction in carbon dioxide emissions for blue hydrogen compared with natural gas are more than made up for by the larger emissions of fugitive methane. Society needs to move away from all fossil fuels as quickly as possible, and the truly green hydrogen produced by electrolysis driven by renewable electricity can play a role. Blue hydrogen, though, provides no benefit. We suggest that blue hydrogen is best viewed as a distraction, something than may delay needed action to truly decarbonize the global energy economy, in the same way that has been described for shale gas as a bridge fuel and for carbon capture and storage in general.43 We further note that much of the push for using hydrogen for energy since 2017 has come from the Hydrogen Council, a group established by the oil and gas industry specifically to promote hydrogen, with a major emphasis on blue hydrogen.5 From the industry perspective, switching from natural gas to blue hydrogen may be viewed as economically beneficial since even more natural gas is needed to generate the same amount of heat." Not known Hydrogen allows for decarbonisation of combustion processes and the generation of heat because it does not produce CO2 when burnt. HyNet has selected technology for the production of Low Carbon Hydrogen which maximises the recovery of CO2 and maximises efficiency to reduce the amount of feedstock required. The Johnson Matthey LCH™ process was developed in the UK, is based on an Auto-Thermal Reforming (ATR) approach as opposed to Steam Methane Reforming (SMR), and targets 97% CO2 capture for the HyNet HPP.  

The advantage of using blue hydrogen over natural gas for heating is that it does not result in the release to atmosphere of CO2.  As noted in one of the above responses, it is true that the proposed Development will not entirely eliminate Greenhouse Gas emissions from the energy (fossil fuel) supply chain, and it is also the case that it does itself release a relatively small amount of CO2 to atmosphere.  Nevertheless, the assertion that blue hydrogen has emissions as large as or larger than those of natural gas used for heating is incorrect as an unqualified statement. The Government recently proposed a UK Low Carbon Hydrogen Standard alongside its UK Hydrogen Strategy.  This standard will ensure that low carbon hydrogen production in the UK delivers on the promise of making rapid and material reductions in Greenhouse Gas emissions.

The production of hydrogen requires energy and that, in the case of blue hydrogen, energy is taken from the incoming fossil fuel feedstock. Essentially, less energy is available in the decarbonized hydrogen product than is available in the incoming natural gas.  Were one not concerned about greenhouse gas emissions, natural gas would, generally speaking, be the preferred fuel.

It is not the case that blue hydrogen provides no benefit as is claimed.  The proposed Development, like other blue hydrogen schemes, will be able to produce a decarbonised fuel in bulk from a relatively small plant.  By comparison, the facilities required to produce equivalent amounts of green hydrogen would occupy a substantially larger geographic area due to the lower density of energy inputs. This characteristic would also result in environmental impacts, although of a different nature. Blue hydrogen can thus be seen as one of the tools in the UK government’s drive to net zero.  It is not the only one, and the developers do not make this claim. However, as is also noted above, it is an important engine in the development of a decarbonised energy economy, and one that, paradoxically, can promote a more rapid transition.
9 I do support the plans for a new hydrogen production facility for the it allows the UK to be a world leader in innovative net-zero technology that will have major appliances in everyday life for every Britton and provides a local source of fuel that greatly increases our capacity and lowers the cost of adoption. Not known Thank you for your support.  We are genuinely committed to supporting the UK’s drive to Net Zero emissions as we fight climate change. 

The UK has the opportunity to be a world leader in hydrogen systems, and to gain maximum benefit from the associated supply chains.  With HyNet North West starting here in Cheshire West, we have the opportunity to set the example to the world whilst protecting highly skilled employment locally, and creating clean job opportunities for our young people.
Disaster Risk Reduction / Health & Safety
10 As this plant is producing hydrogen and capturing carbon dioxide, what would be the environmental hazards and risks to Elton Village. for example is there a risk of explosion or pipe line breaches? You say it will transport carbon dioxide safely to depleted gas reservoirs in Liverpool Bay. Leaks in a pipeline could be devastating, explosion risks are of grave concern and as a resident I want to know what assurances will be given. Elton and its surrounds seem to have taken a large amount of industrial development over this last few years, is this further addition likely to bring more problems to the village? as part of an environmental strategy is sounds perfect in your letter, there is no mention of any downsides which of course there always are, Elton does seem to be a target for brown site development but a valid question is Why Elton and not in another area for a change. Not known A range of safety assessments have been carried out in accordance with industry practice, including a Hazard and Operability Study (HAZOP), and Environmental Impact Identification (ENVID). The detailed layout and engineering design of the proposed Development has been fully informed by a comprehensive range of safety considerations as part of the HAZOP study. Many of these are necessary if the Site is to obtain HSC (see response to comment 4). This includes, for example, detailed consideration of the internal composition of the Site, the separation of different industrial processes and storage areas, ensuring safe access and escape routes and a range of fire safety and protection measures. Maintaining an adequate separation distance to sensitive neighbouring sites fundamentally underpins the Site layout, also considering prevailing wind conditions, and with a particular focus on the storage arrangements for Liquid Oxygen (LOX) on the Site through pre-application engagement with the Health & Safety Executive (HSE). 

The Major Accidents and Disasters Assessment which we have carried out recognises that the proposed Development could be vulnerable to major accidents and also potentially natural disasters. The assessment outlines the work undertaken through Simultaneous Operations (SIMOPs) workshops and hazards reviews in order to influence Site layout, storage of materials and management principles, all of which will be considered in detail as part of the HSC and EP applications’ processes.
11 You have not stated what your emergency action plan is for this new plant. As hydrogen is volatile and running through underground pipes. What extra safeguarding measures are there for resident. The same question goes for the storage of Carbon dioxide, again this can be leathel is escapes occurs in high volume. I am very concerned about this new development being so close to a village. Not known The emergency scenarios have already been developed within the safety studies carried out to date on the plant.  Some have already been designed out, and the rest will be taken forward for further development and mitigation.  The major scenarios, along with the response plans, will be documented in the Control of Major Accident Hazards (COMAH) Report variation which will be submitted to HSE for review and approval prior to start-up, and the response plans will be rolled into Essar’s existing emergency response systems and procedures.  

It is also important to note that hydrogen has been produced and processed at Stanlow refinery at scale for decades, and so the refinery has decades of knowledge, experience and design standards to draw on in terms of preventing emergencies from happening in the first place and dealing with them before they can escalate.
12 The projects aim to produce hydrogen/low carbon gas to replace methane and other aliphatic hydrocarbon gases is to be applauded. However, my concern is for the long-term consequences of storing a gas (CO2) under pressure in "depleted" oil/natural gas cavities in Liverpool bay. Is there some magical process by which it is absorbed into the surrounding racks or will it remain there until diffuses to the surface in the coming decades? The first scenario is unlikely but the second is a potential formula for disaster: either you are buying time by shifting the carbon dioxide problem to future generations or are willing to risk a sudden eruption of CO2 from burst reservoirs blanketing the Wirral and Liverpool with poison gas. We have had the saga of Fracking where companies and government have been forced to cease activities in the face of public protests over pressurised cracking of rocks causing earth tremors. You are now proposing to introduce high pressure gas into cavities. What is the likelihood that similar geological problems will not arise? Not known The storage part of HyNet is a separate project which will have a separate planning consent.  This project is being delivered by other partners in the HyNet consortium. 

However, for information the storage of CO2 is not novel as there are existing Carbon Capture & Storage (CCS) projects currently in operation such as Snøhvit and Sleipner in Norway, where more than 23 million tonnes of CO2 have been safely captured and stored. The CO2 that will be stored in Liverpool Bay will be stored at below the original natural gas pressure in the reservoirs, which demonstrated the integrity of the geological structures. CCS has been widely studied and risk assessed in the UK; for example the UK Storage Appraisal Project undertaken by the ETI, LR Senergy Limited, British Geological Survey, the Scottish Centre for Carbon Storage (University of Edinburgh, Heriot-Watt University), Durham University, GeoPressure Technology Ltd, Geospatial Research Ltd, Imperial College London, RPS Energy and Element Energy Ltd.

To provide protection to the UK public the UK’s Oil and Gas Authority (OGA) regulates offshore carbon dioxide storage – they are the licensing authority who review, approve and issue storage permits. The OGA adhere to UK law: The Energy Act 2008 (the Act) provides for a licensing regime that governs the offshore storage of carbon dioxide. It forms part of the transposition into UK law of EU Directive 2009/31/EC on the geological storage of carbon dioxide. The Carbon Dioxide (Licensing etc.) Regulations 2010 (SI 2010/2221), which transpose many other requirements of the directive. The OGA have already awarded the first stage of consenting, the Appraisal & Storage Licence, to Eni in October 2020.

https://www.ogauthority.co.uk/news-publications/news/2020/energy-integration-in-action-eni-project-awarded-carbon-storage-licence/
13 What fire risks are associated with this work and ongoing storage? Not known The detailed layout and engineering design of the proposed Development has been fully informed by a comprehensive range of safety considerations as part of the HAZOP study. This includes:
  • Detailed consideration of the internal composition of the Site
  • The separation of different industrial processes and storage areas
  • Ensuring safe access and escape routes and a range of fire safety and protection measures
  • Maintaining an adequate separation distance to sensitive neighbouring sites fundamentally underpins the Site layout
  • Considering prevailing wind conditions, and with a particular focus on the storage arrangements for Liquid Oxygen (LOX) on the Site through pre-application engagement with the HSE.
Economic Impact
14 The government currently is predicting a total of 9000 jobs to be generated so if this proposal is likely to bring on 6000 jobs the scope of the plant appears to be far larger than currently being discussed. Please provide details of the discrepancy. It is mentioned in supporting docs that only 20 jobs will be on the Stanlow site, where are the other 5880 likely to be? How many jobs will be created at Stanlow and over what period of time? What roles will be created at which locations? Not known The figure of 6,000 new jobs relates to the wider HyNet North West project. Further detail on the wider HyNet project can be found on the ‘About’ page of the website (www.hynet.co.uk).
Site Selection
15 Are there alternatives to situating the site away from the A117 ie on the opposite side of the site?   A site selection process was undertaken as part of the HPP. The site selection considered:
  • Area (that required for the safe operation of the facilities)
  • Consenting (including Planning Application and Permits)
  • Connectivity (to pipelines, Stanlow Complex and power supply)
  • Plant Design
  • Construction
  • Impact on the Stanlow Complex
The most significant criteria was sufficient area for locating the plant which shortlisted to a small number of sites, and development plans for other areas of the Stanlow Complex. ALCs was favoured because it was previously occupied by a similar process plant, is close to connecting units on the Stanlow Complex, and is a good location of the connection of the pipelines and power supply.
Objection to the proposed development
 16  I object    Noted, no response needed.
Request for further details on the proposed development
 17  I think this is a great idea as I believe Hydrogen is the best fuel for the future. Will you also be building a hydrogen fuelling station alongside the hydrogen production? Im also aware of a proposal to build a Hydrogen production from waste plastic site at Protos nearby, will you have any involvement in this also as it sounds like a win/win process to turn a problem (plastic waste) into a solution (hydrogen)?    Hydrogen will play a central role in our future low carbon energy system, alongside renewable power and bio-energy sources.  The conversion of energy intensive industry and flexible power generation facilities from fossil fuel, mostly natural gas, to hydrogen offers the opportunity to make the fastest reductions in CO2 emissions.  Therefore, we are working with a range of industrial partners across the region to ensure that they can make the switch as readily as possible once the hydrogen production and associated infrastructure are ready.

We have no current plans for hydrogen fuelling adjacent to the production site, but instead anticipate that the HyNet hydrogen pipeline network will enable low carbon fuelling stations to be developed at the most appropriate transport and logistics locations.

This development is separate from Protos, but the HyNet project is working closely with the developers of Protos to ensure that all opportunities for clean growth to the benefit of the area are taken.
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