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Risk

The and (CCS Cross Country Pipeline) Development Consent Order

Under Regulation 5(2)(a) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Document 6.6.1 Relevant Legislation Document 6.6.2 Relevant Planning Policy Document 6.6.3 Watercourse Crossing Schedule Document 6.6.4 Water Framework Directive (WFD) Classification Information Document 6.6.5 Water Quality Baseline Data Document 6.6.6 Proposed Mitigation Measures for WFD Water Bodies Document 6.6.7 Water Framework Directive Assessment Document 6.6.8 Relevant Consultation Responses

Application Reference: EN070001 June 2014

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Relevant Legislation

The Yorkshire and Humber (CCS Cross Country Pipeline) Development Consent Order

Under Regulation 5(2)(a) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Application Reference: EN070001 June 2014 Environmental Statement Volume 6: Ch. 6 Water Resources and Flood Risk 1 Environmental Statement Document 6.6.1

Appendix 6.6.1: Relevant Legislation

Legislation Objective

European The primary objective of the WFD is to maintain the “high EC Directive status” of water bodies where it exists, prevent deterioration 2000/60/EC The in existing status of waters and to achieve at least “good ‘Water Framework status” in relation to all waters by 2015 (unless there are Directive‘ certain exceptional conditions). EC Directive The Priority Substances Directive (2008/105/EC), a daughter 2008/105/EC The directive of the WFD (see above) sets out ‘priority’ ‘Priority Substances substances that threaten the environment and has the aim of Directive’ reducing the pollution of water from these sources. EC Directive Sets outs standards of water quality for the protection of 2006/44/EC The coarse game and fisheries together with monitoring ‘Freshwater Fish requirements. There are two categories for designated (Consolidated) watercourses, ‘Salmonid’ (those suitable for salmon and trout) Directive’1 and ‘Cyprinid’ (those suitable for coarse fish). The Revised Bathing Water Directive (2006) has the purpose to preserve, protect and improve the quality of the environment and to protect human health. The directive EC Directive introduces a new classification system with more stringent 2006/7/EC The water quality standards and puts an emphasis on providing ‘Revised Bathing information to the public. The new directive classifies bathing Water Directive’ waters as either excellent, good, sufficient or poor. The water quality standards for the new classifications are much higher than those of the original bathing waters directive. This sets out a regime for the prevention and remedying of EC Directive environmental damage including from land contamination 2004/35/EC The which presents a threat to human health. Strict liability would ‘Environmental apply in respect of damage to land, water and biodiversity Liability Directive’ from activities regulated by specified EU legislation. This Directive seeks to reduce or prevent the pollution of water caused by the application and storage (i.e. from leaks EC Directive and spills etc.) of inorganic fertiliser and manure on farmland. 91/676/EEC The It is intended to safeguard drinking water supplies and ‘Nitrates Directive’ prevent wider ecological damage in the form of eutrophication of freshwater and marine waters generally.

1 The Freshwater Fish Directive was fully repealed by the Water Framework Directive in December 2013. It is considered that the classification of a watercourse as a Salmonid or Cyprinid fishery under the Freshwater Fish Directive still provides valuable information on the quality of a water feature and thus it will continue to be included within the determination of importance.

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Legislation Objective

European EC Directive Adopted by the European Union in 2008, this Directive seeks 2008/56/EC The to protect and improve the quality of the marine environments ‘Marine Strategy managed by Member States. Framework Directive’

National The Flood and Water Management Act 2010 intends to provide better, more comprehensive management of flood risk for people, homes and businesses. It will also tackle bad The Flood and Water debt, improve the affordability of water bills, and help ensure Management Act continuity of water supplies. In particular, it encourages the 2010 uptake of sustainable drainage systems by removing the automatic right to connect to sewers and providing for unitary and county councils to adopt SUDS for new developments and redevelopments. The Water Environment (Water Implements the requirements of the WFD in and Framework Directive) Wales. (England and Wales) Regulations 2003 Eels (England and The Eels (England and Wales) Regulations 2009 set out Wales) Regulations measures for the protection of the European Eel in England 2009 and Wales. Under the Water Resources Act 1991 it is an offence to cause The Water or knowingly permit poisonous, noxious, or polluting matter, Resources Act 1991, or any solid waste matter to enter controlled waters (which as amended by The include rivers). The Water Act 2003 is being progressively Water Act 2003) implemented and controls the use of water including abstraction and discharge consents to water bodies. The Land Drainage Act 1991 places responsibility for maintaining flows in watercourses on landowners. Classified watercourses maintained by the Environment The Land Drainage Agency (EA) are termed “Main Rivers.” The EA has powers to Act 1991 (as control works in, over, under, on the banks of, within 7 to 10m amended) of the top of the bank of the river, and of all floodplain areas under the Land Drainage Act 1991 (as amended) and Water Resources Act 1991 through the issuing of Land Drainage Consents. The Control of These regulations require anyone in England who stores Pollution (Oil more than 200 litres of oil, to provide more secure Storage) (England) containment facilities for tanks, drums, Intermediate Bulk

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Legislation Objective

European Regulations 2001 Containers (IBCs) and mobile bowsers. This is to prevent oil escaping into the environment. The Environmental The Environmental Permitting (England and Wales) (England and Wales) Regulations 2010 extend the permitting regime introduced in Permitting 2008, to include water discharge consents, groundwater Regulations 2010 (as permits and radioactive substances regulations. amended 2012) These regulations implement the Environmental Liability The Environmental Directive in England. There is liability for activities requiring Damage (Prevention Environmental Permits; discharges to water; groundwater and Remediation) discharges; water abstraction or impoundment, amongst (Amendment) others. ‘Environmental damage’ in relation to water quality Regulations 2010 refers to adverse effects on surface water or groundwater consistent with deterioration in the water’s status (WFD term). The Bathing Water Regulations implements the Revised The Bathing Water Bathing Water Directive in England and Wales. It sets out the Regulations 2008 management of bathing water quality. Marine Strategy The Marine Strategy Framework Directive was implemented Regulations 2010 in England by the Marine Strategy Regulations. The Wildlife and Countryside Act has a number of schedules Wildlife and listing species that are afforded enhanced legal protection: Countryside Act 1981 bird species requiring special protection are listed in Schedule 1, animal species requiring special protection are listed in (as amended) Schedule 5 and plant species requiring special protection are listed in Schedule 8.

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Relevant Planning Policy

The Yorkshire and Humber (CCS Cross Country Pipeline) Development Consent Order

Under Regulation 5(2)(a) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Application Reference: EN070001 June 2014 Environmental Statement Volume 6: Ch. 6 Water Resources and Flood Risk 1 Environmental Statement Document 6.6.2

Appendix 6.6.2: Relevant Planning Policy

Planning Policy Additional Information

Overarching Sets out policy considerations for energy infrastructure Planning Policy projects. This includes reference to assessing surface water Statement for Energy receptors and flood risk (see Table 6.4 in the Chapter 6 (EN-1) (July 2011) Water Resources and Flood Risk for further information). The Government’s planning policies for England are set out National Planning in the NPPF (and associated Planning Practice Guidance). It Policy Framework includes considerations relating to the surface water (March 2012) environment and flood risk that should be covered in the assessment of developments. The MPS provides the high level planning framework for decision making in the marine environment (which includes Marine Policy the intertidal area), policy objectives for key offshore Statement (MPS) activities, and the context and considerations that should be (September 2011) taken into account in the next stage of marine planning East Inshore Marine (regional level inshore and offshore Marine Plans). The Plan (expected East Inshore Marine Plan will be of relevance to the intertidal adoption: 2014) part of the Onshore Scheme. This was recently subject to consultation and responses are now being considered. The plan is expected to be adopted in 2014. Future Water sets out the Government’s sustainable Future Water approach towards water in England. This provides details on (February 2008) the protection of waters from pollution and physical damage. Not yet adopted, this document will set out the planning policy relating to the natural environment (and so surface water and flood risk). The draft plan indicates that the unprotected coast to the East Riding Local south of will be designated as a Coastal Change Plan (to be adopted Management Area (CCMA). late 2014) The following policy is of relevance here: • ENV6 – Managing environmental hazards – covers flood risk, coastal change and environmental pollution. Borough Local Plan was adopted in April 1999. Boothferry Borough Relevant (saved) policies applicable here are: Local Plan (adopted • EN27 / EN27A / EN28 – These policies all seek to 1999) protect sites of nature conservation or land in close proximity to them from significant adverse effects.

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Planning Policy Additional Information • EN30 – This policy states that the Local Planning Authority will seek to minimise the impact of developments on physical features (or valuable species). • EN65 – This policy states that developments must demonstrate there are adequate means for the disposal of foul and surface water. • Policy EN66 – This policy states that development will not be permitted if it adversely affects the function of a flood plain or has a detrimental effect on a water course. • EN67 – This policy stipulates that the Local Planning Authority will seek to prevent pollution to and enhance rivers, streams and groundwater. They seek to aid the EA in this target. • EN68 – This policy indicates that for developments beyond the use of public sewers, discharge of foul drainage would only be permitted should ground conditions indicate that there would not be an adverse impact on the water quality. • EN70 – This policy states that proposals for large permanent developments close to the Humber Estuary will be considered in the light of the possible need to implement a programme of managed coastal retreat in the future. • EN71 – This policy indicates that development adjacent (or on) the Humber Estuary will only gain permission should there be no significant adverse effects on the importance of the estuary (e.g. navigation, nature conservation). Borough Local Plan was adopted in June 1996. Relevant (saved) policies applicable here are: • Policy E1 – This policy states that development should preserve or enhance the natural heritage.

Beverley Borough • Policy E14 – This policy states that development Local Plan (adopted proposals should consider the effects upon the natural environment. A reduction in nature 1996) conservation should be kept to a minimum. • Policy E15 / E16 / E17 – These policies protects nature conservation sites (at local, national and international levels). • Policy E19 – This policy states that proposals that

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Planning Policy Additional Information have a significant adverse effect on (or will be affected significantly by) the water environment and streams (or hedgerows connected to them) will not be given approval. • Policy E20 – This policy supports development proposals that seek to enhance or restore the natural (or valuable man-made) features of the riverine environment. • Policy D18 – This policy specifies that drainage proposals to manage foul and surface water from developments must be satisfactory. • Policy D20 – This policy protects water resources. • Policy D21 – This policy protects fluvial and tidal defences from future developments and states that the defences should provide the development with acceptable protection. Developers will be expected to cover the costs of any appropriate enhancement and mitigation works. • Policy In11 – This policy stipulates that new hazardous installations will be carefully controlled and reviewed by the Health and Safety Executive. Approval will not be given if hazardous installations in the vicinity of existing hazardous installations cause demonstrable risks. East Yorkshire Borough Wide Local Plan was adopted in June 1997. Relevant (saved) policies applicable here are: • Policy EN4 – River Derwent Area of Habitat Protection - Developments must not result in pollution in the River Derwent Habitat. • Policy EN5 – and Headwaters Area of Habitat Protection – Developments must not result in pollution in the River Hull and Headwaters Area. East Yorkshire Borough Wide Local • Policy EN8 – International Nature Conservation Sites - This policy is in place to protect the integrity of Plan (adopted 1997) international nature conservation sites (designated or proposed) (e.g. SAC’s / SPA’s). • Policy EN9 – National Nature Conservation Sites - This policy protects national nature conservation sites (e.g. SSSI’s). • Policy EN10 – Local Nature Conservation Sites - This policy protects local nature conservation sites. • Policy EN16 – Foul and Surface Water Disposal -

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Planning Policy Additional Information This policy sets out water disposal requirements for foul and surface water. Development should connect to public sewers where practical or otherwise meet policy requirements regarding alternative options (e.g. septic tanks). • Policy EN17 Flood Risk – This policy states that where proposals would impede the flow of flood water or increase the flood risk they will only be permitted where protection measures contain the flood risk. The Selby District Core Strategy Local Plan was adopted in October 2013. Relevant policies applicable here are: • Policy SP2 Spatial Development Strategy – The policy will direct development to lower areas of flood risk. • Policy SP15 Sustainable Development and Climate Change – Aims to achieve no loss of flood storage capacity. Also, for 100% of new development to Selby District Core incorporate SUDS where feasible and practicable. Strategy Local Plan • Policy SP18 Protecting and Enhancing the (adopted 2013) Environment – This policy target the protection and enhancement of the environment (natural and man- made). Part of the target of this policy is to ensure that developments protect water quality from pollution. • Policy SP19 Design Quality – A requirement of this policy is that non-residential developments do not contribute to (or put the development at risk from) water pollution. The Selby District Council Local Plan was adopted in February 2005. Relevant (saved) policies applicable here are: • ENV 4 – This policy states that developments include the storage or use of hazardous substances are only permitted if there is no unacceptable risk to the Selby District Council natural environment (or public). Local Plan (adopted • ENV 12 – This policy states that should a 2005) development be likely to significantly watercourses (rivers, streams, canals corridors) they will not be given approval. Should the development importance outweigh the value of the features and adequate compensatory measures be in-place, then approval will be granted. • ENV 13 – This policy protects pond, including the

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Planning Policy Additional Information wildlife value (which is influenced by water quality).

Flamborough Head Head to Gibraltar Point Shoreline to Gibraltar Point Management Plan (SMP) presents the preferred Shoreline management options for units of this coastline in the short, Management Plan medium and long term. (2010)

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Watercourse Crossing

Schedule

The Yorkshire and Humber (CCS Cross Country Pipeline) Development Consent Order

Under Regulation 5(2)(a) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Application Reference: EN070001 June 2014 Environmental Statement Volume 6: Ch. 6 Water Resources and Flood Risk 1 Environmental Statement Document 6.6.3

Appendix 6.6.3: Crossing Schedule

Crossing Reference Crossing Type Crossing Name Camblesforth Multi-junction Site to Block Valve Site (including the Drax PIG Trap connection) DX 0/1 Drain Carr Dyke DX 0/1a Drain Carr Dyke DX 0/2 Drain Drain DX 0/3 Drain Lendall Drain DX 0/4 Drain Drain DX 1/1 Drain Drain DX 1/2 Drain Drain DX 1/3 Drain Drain DX 1/4 Drain Drain DX 2/1 Drain Drain DX 2/2 Drain Drain DX 2/3 Drain Drain DX 2/4 Drain Drain DX 2/4a Drain Drain DX 3/1 Drain Drain DX 4/1 Drain Willow Row Drain DX 4/2 Drain Drain DX 5/1 Drain Drain DX 5.1a Drain Drain DX 6/1 Drain Ditch Camblesforth Multi-junction Site to Tollingham Block Valve Site (including the Drax PIG Trap connection) DX 6/2 Drain Drain DX 6/2a Drain Drain DX 7/1 Drain Drain DX 7/2 Drain Drain DX 7/3 Drain Willow Row Drain DX 8/1 Drain Drain DX 8/2 Drain Drain DX 8/3 Drain Drain RVX 1 River River Ouse DX 8/4 Drain Drain DX 8/5 Drain Lowfield Drain DX 8/6 Drain Drain DX 8/7 Drain Fields Drain PDX1 Drain Drain DX 8/8 Drain Drain DX 8/9 Drain Drain DX 8/10 Drain Drain

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Crossing Reference Crossing Type Crossing Name DX 9/1 Drain Drain DX 9/2 Drain Marsh Drain DX 9/3 Drain Old Derwent DX 9/4 Drain New Drain DX 10/1 Drain Black Dyke DX 10/2 Drain Drain DX 10/3 Drain Drain DX 10/4 Drain Drain DX 11/1 Drain Drain DX 11/2 Drain Drain DX 11/3 Drain Drain DX 11/4 Drain Drain DX 12/1 Drain Drain Commonend Drain / DX 12/2 Drain Featherbed Drain DX 12/3 Drain Drain DX 12/4 Drain Carr Drain Commonend Drain / DX 12/5 Drain Featherbed Drain DX 12.5a Drain Drain DX 12/6 Drain Drain DX 12/7 Drain Drain DX 12/8 Drain Drain DX 13/1 Drain Drain DX 13/2 Drain Drain RVX 2 River DX 13/3 Drain Drain DX 13/4 Drain Drain PDX 2 Drain Drain DX 13/5 Drain Dunn's Drain DX 14/1 Drain Drain DX 14/2 Drain Drain DX 15/1 Drain Drain DX 15/2 Drain Drain Tollingham Block Valve Site to Dalton Block Valve Site DX 15/3 Drain Drain DX 16/1 Drain Drain DX 16/2 Drain Drain DX 16/3 Drain Drain DX 16/4 Drain Drain DX 17/1 Drain Drain DX 17/2 Drain Drain DX 17/3 Drain Drain

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Crossing Reference Crossing Type Crossing Name Disused RVX 3 River Canal DX 17/4 Drain Back Delfin Drain DX 17/5 Drain Drain DX 17/6 Drain Drain DX 18/1 Drain Culvert DX 18/2 Drain Drain DX 18/3 Drain Drain DX 18/4 Drain Drain DX 19/1 Drain Drain DX 19/2 Drain Drain DX 19/3 Drain Drain DX 19/4 Drain Drain DX 19/5 Drain Drain Dalton Block Valve Site to Skerne Block Valve Site DX 30/1 Drain Bracken Beck DX 30/2 Drain Drain DX 30/3 Drain Drain DX 32/1 Drain Drain DX 32/2 Drain Drain DX 32/3 Drain Drain DX 32/4 Drain Drain DX 32/5 Drain Drain DX 32/6 Drain Drain DX 33/1 Drain Drain DX 33/2 Drain Drain DX 34/1 Drain Drain DX 34/2 Drain Drain DX 35/1 Drain Drain DX 35/2 Drain Northfield Beck DX 35/3 Drain Drain DX 35/4 Drain Drain DX 35/5 Drain Knorka Dyke DX 35/6 Drain Drain DX 35/7 Drain Drain DX 36/1 Drain Drain DX 36/2 Drain Drain DX 36/3 Drain Drain DX 36/4 Drain Drain Skerne Block Valve Site to Barmston Pumping Station Site DX 36/5 Drain Drain DX 36/5a Drain Drain DX 36/6 Drain Drain

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Crossing Reference Crossing Type Crossing Name DX 36/7 Drain Drain DX 36/8 Drain Main Drain RVX 4 River River Hull CLX 1 Canal Canal DX 37/1 Drain Drain adjacent RDX 37 DX 37/2 Drain Drain DX 37/3 Drain Culvert DX 37/4 Drain Drain DX 37/5 Drain Highland Stream DX 37/6 Drain Drain DX 37/7 Drain White Dike DX 37/8 Drain Drain DX 37/9 Drain Drain DX 37/10 Drain Drain RVX 5 River Kelk Beck DX 37/11 Drain Drain DX 38/1 Drain Drain DX 38/2 Drain Nutholmes Dike DX 38/3 Drain Nutholmes Dike DX 38/4 Drain Drain DX 38/4a Drain Drain DX 39/1 Drain Drain DX 39/2 Drain Burton Drain DX 39/3 Drain Culvert DX 39/3a Drain Drain

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Water Framework Directive

(WFD) Classification Information

The Yorkshire and Humber (CCS Cross Country Pipeline) Development Consent Order

Under Regulation 5(2)(a) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Application Reference: EN070001 June 2014 Environmental Statement Volume 6: Ch. 6 Water Resources and Flood Risk 1 Environmental Statement Document 6.6.4

Appendix 6.6.4: Water Framework Directive (WFD) Classification Information

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Watercourse Reference WFD Water Body Type AECOM Crossing Watercourse WFD Watercourse / ID (see Water Body Type (Main River WFD ID Designation WFD Description Water Body Figures Name / Ordinary Name Responsibility Maps 1- Watercourse) 10) Camblesforth Multi-junction Site to Tollingham Block Valve Site (including the Drax PIG Trap connection) DX 0/1 and DX 0/1a Carr Dike (Carr The River Ouse is currently at Moderate Ecological Status (due to phosphates and Ordinary (Drain) / Selby IDB Dike) / quantity and dynamics of flow) and is failing to meet good chemical status (due to Watercourse Lendall Drain River Ouse from tributyltin compounds). It is not expected to meet Good Ecological Status until 2027 DX 0/3 GB20402706 to due to the implementation of mitigation measures being disproportionately (Lendall 4270 Drain) expensive and technically infeasible. This watercourse is also designated under Willow Row the Freshwater Fish Directive, the Habitats/Birds Directive and the Nitrates Ordinary DX 4/1 Selby IDB Drain Directive. Watercourse RVX 1 River Ouse Environment Main River Agency The River Foulness is currently at Moderate Ecological Status (due to invertebrates, ammonia and dissolved oxygen) and has not been assessed for Foulness from River GB10402606 chemical status. It is not predicted to meet Good Ecological Status until 2027 due Ouse and Humber Ordinary RVX 2 Black Beck to Foulness 6690 to it being technically infeasible to implement all mitigation measures. This river is IDB Watercourse Market Weighton also designated under the Freshwater Fish Directive and part of its catchment is within a Nitrate Vulnerable Zone. Tollingham Block Valve Site to Dalton Block Valve Site Weighton Beck / Canal is an artificial water body that is currently at Moderate Ecological Potential (due to ammonia and the Mitigation Measures Assessment) Market and has not been assessed for chemical status. It is not predicted to meet Good Market Weighton Environment RVX 3 Weighton GB70410031 Ecological Potential until 2027 due to it being technically infeasible and Main River Canal Agency Canal disproportionately costly to implement all mitigation measures. This river is also designated under the Freshwater Fish Directive and part of its catchment is within a Nitrate Vulnerable Zone. Dalton Block Valve Site to Skerne Block Valve Site Middleton on the Bracken Beck is currently at Good Ecological Status. It is expected to be at Good GB10402606 East Riding of Ordinary DX 30/1 Bracken Beck Wolds and Ecological Status by 2015. It is also designated under the Freshwater Fish 6980 Yorkshire Council Watercourse Watton Beck Directive and the Nitrates Directive. Northfield Beck is a HMWB that is currently at Moderate Ecological Potential (due to fish and invertebrates) and is at good chemical status. It is not predicted to meet Northfield GB10402606 Lower East Riding of Ordinary DX 35/2 Good Ecological Potential until 2027 due to it being technically infeasible to Beck 7040 to River Hull Yorkshire Council Watercourse implement mitigation measures. This watercourse is also designated under the Freshwater Fish Directive and Nitrates Directive. Skerne Block Valve Site to Barmston Pumping Station Site Main Drain / GB10402606 West Beck / River Hull is a HMWB (due to flood protection and wider Beverley and North Ordinary DX 36/8 West Beck Upper Wanlass 7080 environmental factors) that is currently at Moderate Ecological Potential (due to IDB Watercourse

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Watercourse Reference WFD Water Body Type AECOM Crossing Watercourse WFD Watercourse / ID (see Water Body Type (Main River WFD ID Designation WFD Description Water Body Figures Name / Ordinary Name Responsibility Maps 1- Watercourse) 10) Drain fish, invertebrates and the Mitigation Measures Assessment). It is not predicted to meet Good Ecological Potential until 2027 due to it being technically infeasible and River Hull Environment RVX 4 disproportionately expensive to implement mitigation measures. This watercourse Main River (West Beck) Agency is also designated under the Freshwater Fish Directive and Nitrates Directive. Driffield Canal is an artificial water body due to navigation that is currently at Moderate Ecological Potential (due to the Mitigation Measures Assessment). It is Driffield Driffield Environment CLX 1 GB70410028 not predicted to meet Good Ecological Potential until 2027 due to it being Main River Canal Navigation Agency technically infeasible to implement mitigation measures. This watercourse is also designated under the Freshwater Fish Directive and Nitrates Directive. Kelk Beck from Kelk Beck is at Poor Ecological Status (due to fish and the quantity and dynamics GB10402606 to of flow). The water body target is to be at Good Ecological Status by 2015. This Environment RVX 5 Kelk Beck Main River 7100 Froddingham watercourse is also designated under the Freshwater Fish Directive and Nitrates Agency Beck Directive. Gransmoor Drain is an artificial water body (due to land drainage) that is currently Gransmoor Drain at Good Ecological Potential. Parameters are all good or higher aside from fish Gransmoor GB10402606 Beverley and North Ordinary DX 38/4 ( to which are considered ‘Moderate (uncertain)’). It is expected to be at Good Drain 6630 Holderness IDB Watercourse Area) Ecological Status by 2015. Part of its catchment is also within a Nitrate Vulnerable Zone. Earls Dyke is an artificial water body (due to land drainage) that is currently at Bad GB10402606 Earls Dyke to N Ecological Potential (due to invertebrates and the quantity and dynamics of flow). It Beverley and North Ordinary Earls Dyke 6640 Sea is not predicted to meet Good Ecological Potential until 2027. This watercourse is Holderness IDB Watercourse NA also designated under the Bathing Water Directive and Nitrates Directive. The Yorkshire South / Lincolnshire coastal water body is a HMWB (due to flood Yorkshire protection) that is currently at Moderate Ecological Potential (due to phytoplankton South / and dissolved inorganic nitrogen). It is not predicted to meet Good Ecological GB64040249 Yorkshire South / Environment NA Lincolnshire Potential until 2027 due to it being disproportionately expensive to implement NA 0000 Lincolnshire Agency coastal water mitigation measures. This coastal water body is also designated under the Bathing body Water Directive, Freshwater Fish Directive, Natura 2000 (Habitats and/or Birds Directive) and Nitrates Directive.

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Water Quality Baseline Data

The Yorkshire and Humber (CCS Cross Country Pipeline) Development Consent Order

Under Regulation 5(2)(a) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Application Reference: EN070001 June 2014 Environmental Statement Volume 6: Ch. 6 Water Resources and Flood Risk 1 Environmental Statement Document 6.6.5

Appendix 6.6.5: Water Quality Baseline Data

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Active surface water abstraction licences Upstream / Nearest AEC Downstream Approximate Licence Start End Abstraction OM Use Source Easting Northing from the Distance from No. Date Date Point ID Onshore the Onshore Scheme Scheme (km) Carr Dike / 0 Spray 01/04/2 30/09/2 Tidal Lendall Upstream and (closest section A1* 2/27/24/ Irrigation - 466808 428396 013 013 Waters Drain – downstream of abstraction 194 Direct Tidal reach) 0.44 Spray 01/04/2 30/09/2 Tidal River Ouse Upstream and (closest section A2* Irrigation - 466915 429587 2/27/24/ 013 013 Waters - Tidal downstream of abstraction Direct 194 reach) Spray Tributary of 2/26/34/ 01/11/2 31/03/2 Surface Pond source / A3 Irrigation - Throlam 482370 436450 0.14 098 012 012 water upstream Direct Drain Spray 2/26/34/ 01/11/2 28/02/2 Surface Bowman Upstream and A4 Irrigation - 486920 439780 1.50 085 012 012 Water Beck downstream Storage Bowman Spray Drain - 2/26/34/ 01/11/2 31/03/2 Surface Upstream and A5 Irrigation - Houghton 487940 440010 0.13 151 012 012 water downstream Storage Farms - Scanton Fish Farm/Cres 2/26/31/ 01/01/2 31/12/2 Surface Driffield A6 s Pond 506750 455540 Downstream 0.10 116 012 012 Water Canal Throughflo w The Yorkshire and Humber CCS Cross Country

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* A1 and A2 permit abstraction from a reach of the listed source waters (A1 from 466300, 428000 to 467300, 428800 and A2 from 466300, 430300 to 467600, 428600). Central location of reach displayed in Table B.5 and on Figure 6.1 (Map 1) NB. The green columns correspond to AECOM assessment of location of active surface water abstraction licences in relation to the Onshore Scheme.

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Active discharge consents AECOM Application Date Northin Name Address Easting Type ID No. Issued g D1 WRA7761 30/11/2001 Gallon Goat Farm Mill Lane 468660 424670 Mixed Farming Sewage disposal works D2 WA 5858 21/12/1989 Plot 1 Hill Farm Newland 468800 424900 - other Domestic Property D3 WRA7599 07/06/2000 Corner Farm Riverside 468910 424850 (Single) The Cottages Sewage disposal works D4 C3859 26/07/2012 Newland 468100 428500 (Copper Cottage) – other Sewage disposal works D5 D114 07/04/1995 The Norwoods Sharp Hill 467600 427500 - other Sewage disposal works D6 647 27/12/1956 Ashgrove Farm Asselby 471050 428050 - other Sewerage Network - Asselby combined D7 27/24/0403 07/02/2007 Asselby 471940 428230 Sewers - water sewer overflow company Yorkshire Water Sewage Disposal Works D8 C4934 08/01/1988 Asselby 471950 428240 Asselby STW - water company NPSWQD002 D9 20/08/2008 Royal Oak Holme Road 478296 431857 Public Houses and Bars 773 Sewage disposal works D10 C4058 25/11/1985 Fir Tree Farm 478300 433300 - other Welham D11 H56 16/05/1957 Moors Farm 479000 434000 Mixed Farming Bridge Market Sewage disposal works D12 WRA7646 29/11/2000 River Head House 485160 438810 Weighton - other M.Humphries the Old Wold Market D13 WA6341 14/03/1991 490700 441300 Mixed Farming Farmhouse High Weighton

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AECOM Application Date Northin Name Address Easting Type ID No. Issued g Dwelling off Domestic Property D14 WA5988 04/04/1990 Wansford 506800 455300 Snakeholme Bridge (Single) Wansford new trout Snakeholme D15 2703 22/07/1997 506800 455500 Fish Farm farm outlet Lock County D16 WRA7293 31/01/1997 Gembling 510400 456600 Education Primary School Domestic Property D17 C5366 03/01/1989 Proposed dwelling Maun Street 510200 456900 (Single) Main Street Domestic Property D16 WA6204 16/10/1990 Proposed dwelling 510300 457900 Farm (Single) Domestic Property D17 WA5958 28/02/1990 Proposed bungalow Fourth Farm 512600 459900 (Single) D18 C4748 19/08/1987 Hill Farm Grasmoor 513400 459100 Mixed Farming Gransmoor Lodge D19 3820 01/04/1985 Gransmoor 513800 459300 Trade (Unknown/Other) Holiday Homes

Pollution incidents AECOM ID Reference Date Location Easting Northing Category Cause Pollutant Other Category 3 Sewage P1 304979 12/04/2005 Asselby 471475 428272 Authorised (Minor) Materials Activity Unauthorise Category 3 Sewage P2 44546 23/11/2001 Fox Farm 471970 428300 d Discharge (Minor) Materials or Disposal Newsholme, Category 3 Not Sewage P3 314115 20/05/2005 472994 428815 (Minor) Identified Materials Category 3 Not Pollutant P4 427855 16/08/2006 Parks Farm 472881 429085 (Minor) Identified Not The Yorkshire and Humber CCS Cross Country

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AECOM ID Reference Date Location Easting Northing Category Cause Pollutant Identified Pollutant Spaldington Category 3 Not P5 707616 14/08/2009 477954 432150 Not Common (Minor) Identified Identified General Control Biodegrada Category 3 P6 822412 14/09/2010 Ivy House 478204 432536 Measure ble (Minor) Failure Materials and Wastes Agricultural Category 3 P7 26939 26/08/2001 Ivy House 478500 432300 Other Materials (Minor) and Wastes General Biodegrada Category 3 Drainage P8 564043 14/02/2008 Ivy House 478730 432360 ble (Minor) Failure Materials and Wastes Agricultural Category 3 Drainage P9 771990 20/04/2010 Ivy House 478739 432365 Materials (Minor) Failure and Wastes Welham Category 3 Not Oils and P10 744844 11/01/2010 479171 434300 Bridge Farm (Minor) Identified Fuel New Category 3 Other P11 871948 01/04/2011 481169 435740 Vandalism Farm (Minor) Pollutant Unauthorise Category 3 Sewage P12 482899 05/04/2007 Forest Farm 481696 436946 d Discharge (Minor) Materials or Disposal Agricultural Category 3 Normal P13 763751 22/03/2010 Duck Nest 484295 437529 Materials (Minor) Operation and Wastes

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AECOM ID Reference Date Location Easting Northing Category Cause Pollutant Pollutant Category 3 Not P14 529024 06/09/2007 Duck Nest 484334 437272 Not (Minor) Identified Identified Pollutant , Category 3 Not P15 338662 16/08/2005 484350 437585 Not York (Minor) Identified Identified Category 3 Not Contaminat P16 717235 18/09/2009 Duck Nest 484178 437949 (Minor) Identified ed Water Unauthorise Category 2 d Waste Contaminat P17 855304 03/02/2011 Duck Nest 484185 437947 (Significant) Managemen ed Water t Activity Pipe Failure Category 3 Oils and P18 662227 17/03/2009 Bracken 498220 450285 above (Minor) Fuel ground Cleaves Category 3 Natural Other P19 86764 24/06/2002 506140 454300 Farm (Minor) Process Pollutant Driffield Category 3 Other P20 151453 28/03/2003 506800 455300 Other Canal (Minor) Pollutant Category 3 Not Sewage P21 965925 29/02/2012 Gembling 510898 457065 (Minor) Identified Materials Category 3 Accidental Oils and P22 462291 16/01/2007 Gransmoor 512187 459515 (Minor) Spillage Fuel Other General Inadequate Biodegrada Hamiltonhill Category 2 P23 420253 24/07/2006 516773 461397 Control or ble Farm (Significant) Containmen Materials t and Wastes

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Proposed Mitigation Measures

for WFD Water Bodies

The Yorkshire and Humber (CCS Cross Country Pipeline) Development Consent Order

Under Regulation 5(2)(a) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Application Reference: EN070001 June 2014 Environmental Statement Volume 6: Ch. 6 Water Resources and Flood Risk 1 Environmental Statement Document 6.6.6

Appendix 6.6.6 Proposed Mitigation Measures for WFD Water Bodies AECOM River Basin Relevant to Proposed Mitigation In Watercourse Crossing Management the Comment Measures place ID Plan ID assessment Bank reinstatement to be Preserve and where used where necessary. possible enhance However, a trenchless ecological value of Yes No technique is to be utilised marginal aquatic habitat, so we do not anticipate banks and riparian zone. this to be required. A Biosecurity Plan will be Market Weighton RVX 3 GB70410031 in place during the Canal Appropriate techniques construction works. No No (invasive species) However, a trenchless technique is to be utilised. Preserve and, where Trenchless method to possible, restore historic No Yes preserve aquatic habitat aquatic habitats. at crossing location Appropriate techniques to align and attenuate flow to Yes No - limit detrimental effects of these features (drainage). Appropriate timing Yes No - Northfield Beck DX 35/2 GB104026067040 (vegetation control) Bankside improvements / reinstatement (if Appropriate vegetation Yes No necessary) will plant control technique species in keeping with the riparian habitat at the The Yorkshire and Humber CCS Cross Country

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AECOM River Basin Relevant to Proposed Mitigation In Watercourse Crossing Management the Comment Measures place ID Plan ID assessment crossing point. However, a trenchless technique is to be utilised so we do not anticipate this to be required. Selective vegetation Yes No - control regime Sediment management strategies (develop and No No - revise) Embankments were not noted during the site visit, however opportunity to Improve floodplain No No investigate enhancement connectivity. of the local riparian corridor at the relevant consent stage. Should embankments be necessary or present at Set-back embankments No No the crossing point location these could be maintained / set back. Appropriate techniques to align and attenuate flow to Yes No - Main Drain limit detrimental effects of DX 36/8 GB104026067080 / Wanlass Drain these features (drainage). Appropriate timing Yes No - (vegetation control)

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AECOM River Basin Relevant to Proposed Mitigation In Watercourse Crossing Management the Comment Measures place ID Plan ID assessment Bankside improvements / reinstatement (if necessary) will plant species in keeping with Appropriate vegetation the riparian habitat at the Yes No control technique crossing point. However, a trenchless technique is to be utilised so we do not anticipate this to be required. Selective vegetation Yes No - control regime Awareness raising / information boards (boat No No - wash / sources of fine sediment) Vessel Management No No - Modify vessel design No No - Structures or other The crossing technique mechanisms in place and of Main Drain / River Hull managed to enable fish to will be trenchless and River Hull No No RVX 4 access waters upstream thus have no impact on (West Beck) and downstream of the fish passage in the impounding works. channel. Trenchless method Bank rehabilitation / utilised to have no direct No No reprofiling. effect on the bankside environment

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AECOM River Basin Relevant to Proposed Mitigation In Watercourse Crossing Management the Comment Measures place ID Plan ID assessment A Biosecurity Plan will be in place during the Appropriate techniques construction works. Yes No (invasive species) However, a trenchless technique is to be utilised. Appropriate timing Yes No - (vegetation control) Bankside improvements / reinstatement (if Appropriate vegetation necessary) will plant Yes No control technique species in keeping with the riparian habitat at the crossing point. CLX 1 GB70410028 Selective vegetation Yes No - control regime Awareness raising / information boards (boat No No - wash / sources of fine sediment) Vessel Management No No - Modify vessel design No No - Structures or other The crossing technique mechanisms in place and of Driffield Canal managed to enable fish to (Driffield Navgiation) will No No access waters upstream be trenchless and thus and downstream of the have no impact on fish impounding works. passage in the channel.

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AECOM River Basin Relevant to Proposed Mitigation In Watercourse Crossing Management the Comment Measures place ID Plan ID assessment Trenchless method Bank rehabilitation / utilised to have no direct No No reprofiling. effect on the bankside environment

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Water Framework Directive

Assessment

The Yorkshire and Humber (CCS Cross Country Pipeline) Development Consent Order

Under Regulation 5(2)(a) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Application Reference: EN070001 June 2014 Environmental Statement Volume 6: Ch. 6 Water Resources and Flood Risk 1 Environmental Statement Document 6.6.7

Appendix 6.6.7: Water Framework Directive Assessment

Method

The Humber EA River Basin Management Plan (RBMP) (EA, 2009) (Ref 6.22) was reviewed to identify Water Framework Directive (WFD) designated water bodies and obtain data about their current status and target objectives. Where water bodies are designated as Heavily Modified Water Bodies (HMWB) or Artificial Water Bodies (AWB), information on any mitigation measures were also identified using the Humber RBMP. This information was used to inform a qualitative assessment of compliance with the objectives of the WFD, principally that the Onshore Scheme should not cause deterioration and it should not prevent the water body improving to meet its targets, whilst taking into account adjacent water bodies and any European Protected Areas (e.g. SACs).

Due to the nature of the proposed development being linear there is the potential for cumulative effects within the catchments of WFD designated water bodies from multiple crossings, including those across tributaries that themselves may not be designated under the WFD. To understand the risk to each WFD designated watercourse posed by cumulative effects, a cluster analysis has been undertaken to group crossings within each WFD water body catchment. The number and proximity of crossings can then be used to assess the risk and where this is high, ensure that appropriate mitigation measures are implemented to prevent water pollution and ensure compliance with the WFD (see Figure 6.4 (Maps 1 and 2)).

A number of assumptions have been made as part of this cumulative effect cluster analysis. All Main Rivers and Ordinary Watercourses were considered as part of the analysis. Contours on OS maps were used to interpret drainage flowpaths and assess which WFD water body the crossed watercourse discharges to. Although the Derwent and Aire are both WFD designated water bodies non-designation crossings that drain to these systems have been included within the wider River Ouse catchment cluster that the River Derwent and discharge into. Assessment

WFD Assessment

This impact assessment has also assessed whether or not the Onshore Scheme is compliant with the objectives of the WFD for those watercourses that are designated under this European Directive. An assessment of compliance with groundwater bodies designated under the WFD is considered separately in Chapter 7 Geology, Soils and Hydrogeology (Document 6.7).

There are 12 WFD watercourses along the route of the Pipeline Envelope, with a total of 14 crossings (Carr Dike which in turn becomes Lendall Drain is crossed three times). Table 24 1 summarises the WFD designated water bodies that are crossed by the Pipeline Envelope (Please refer to Appendix 6.6.3 (Document 6.6.3) for a full outline of all WFD designations):

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Table 1 WFD Designation Watercourses crossed by the Pipeline Envelope

Onshore Scheme WFD Designation Section Watercourse Name WFD Watercourse Name Carr Dike (becoming River Ouse from River Wharfe to Trent Lendall Drain) – Falls, GB204027064270 three crossings River Ouse from River Wharfe to Trent Willow Row Drain Drax to Falls, GB204027064270 Tollingham River Ouse from River Wharfe to Trent River Ouse Falls, GB204027064270 River Foulness from Black Beck to River Foulness Market Weighton, GB104026066690 Tollingham to Market Weighton , GB70410031 Dalton Canal and Watton Bracken Beck Beck, GB104026066980 Dalton to Skerne West Beck Lower to River Hull, Northfield Beck GB104026067040 Main Drain West Beck Upper, GB104026067080 River Hull West Beck Upper, GB104026067080 Driffield Canal Driffield Canal, GB70410028 Skerne to Barmston Kelk Beck from Harpham to Kelk Beck Froddingham Beck, GB104026067100 Gransmoor Drain (Burton Agnes to Gransmoor Drain Lissett Area), GB104026066630

In addition, in-between Barmston Pumping Station and LMWS, the Pipeline is being installed in the intertidal and nearshore regions. This therefore includes the Yorkshire South / Lincolnshire coastal water body (GB640402490000).

Trenchless Crossings

All of the WFD designated watercourses are to be crossed by trenchless crossing techniques, with the exception of Bracken Beck where there are engineering difficulties.

According to the EAs ‘Interim Water Framework Directive Assessment and Statement of Compliance’ (version used received September 2013, but no issue date as it is a live document subject to updates) trenchless techniques for the

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Environmental Statement Volume 6: Ch. 6 Water Resources and Flood Risk 3 Environmental Statement Document 6.6.7 installation of utilities that are more than 1.5 m below the natural bed line of the river are unlikely to have any direct or indirect effects on the watercourses and thus the Onshore Scheme will not cause deterioration or prevent improvement. These crossings are therefore compliant with the objectives of the WFD and no further assessment is required.

Similarly, once the Pipeline is installed in the intertidal / nearshore environments it is expected that the Onshore Scheme would not cause deterioration or prevent improvement in the Yorkshire South / Lincolnshire coastal water body.

Open Cut Crossings

The remaining WFD watercourse that may be crossed by the open cut method, in a worst case scenario, is Bracken Beck. This method may result in direct impacts on the water body, although with appropriate reinstatement there is unlikely to be any long term permanent effects that could result in non-compliance with the objectives of the WFD.

The EA’s interim WFD guidance identifies temporary works such as temporary clear span bridge with abutments set-back from bank top, temporary coffer dam and temporary flow diversion (if fish / eel passage not impeded) such as flumes and porta-dams as construction activities that are unlikely to result in non-compliance with the objectives of the WFD.

The proposed activities include temporary fluming of small watercourses and temporary dams, most likely using soft engineering options such as sand bags of different sizes. The works are also temporary and each crossing shall be completed within three days (only one day for installation). The stream bed will be reinstated in the layers as excavated and the banks re-profiled and reseeded. If invasive plant species are present (such as Himalayan balsam) appropriate biosecurity measures will be implemented to prevent the propagation of invasive plants. Furthermore, fish rescue will be implemented before the working area is dewatered.

Bracken Beck was observed during a site visit and was analogous to typical head waters of lowland watercourses in arable locations. It was less than a few metres wide (wetted width ~1 m wide) impacted by field drainage (i.e. straightened). Where this type of temporary works is proposed the EA’s guidance states that where Atlantic salmon (Salmo salar) and European eel (Anguilla anguilla) migrations are not affected WFD compliance is anticipated. The following summarises the baseline for this water body:

Bracken Beck (included in the Middleton on the Wolds and Watton Beck WFD designation) is currently achieving Good Ecological Status (Chemical Status does not require assessment). Despite being designated under the FCD as a salmonid fishery at the point of crossing, Bracken Beck appears to have been artificially straightened and the channel contains a significant amount of vegetation, making it unlikely to be suitable for European eel or salmonids at the proposed point of crossing. In addition, EA data did not state that these species are likely to be present (based on surveys on similar watercourses) (see Document 6.6 Section 6.1.73). Based on this the potential for European eel and Atlantic Salmon is

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Environmental Statement Volume 6: Ch. 6 Water Resources and Flood Risk 4 Environmental Statement Document 6.6.7 considered to be low in this reach of Bracken Beck and since the works will be for a short duration only (a few days) no significant effects are predicted.

When watercourses are crossed by open cut techniques an excavation of the order of 2 m wide will be required. As the depth of the pipe will be laid at least 1.7 m below the bed level, the excavation through the bed and the banks of the watercourse may be 2 m wide. Although the impact of this work will be short term, temporary and localised, there remains the possibility of morphological effects on the channel bed and banks. However, these features will reform and this impact is not likely to have any significant effects on other WFD parameters locally or at the water body level. Overall, it is considered that the proposed open cut works to Bracken Beck will be compliant with the objectives of the WFD and no further assessment is required.

Hydrostatic Test Waters

Hydrostatic testing of the Pipeline will be required prior to operation. Water will be abstracted from one southern source (reasonable worst case is considered to be the River Ouse) and from one other northern source which is to be confirmed under a Water Abstraction Licence from the EA which will define the volume, rate, duration and timing of the abstraction including any conditions that need to be met. For the purpose of this appraisal assessment it has been assumed that the abstracted water will be discharged back to the same source at a rate agreed with the EA together with any pre-treatment.

The contractor will discuss the discharge of test waters will be discussed with the EA for advice on whether or not this can be discharged safely, and whether there are options for pre-treatment that might be required. If it is decided that the hydrostatic test water cannot be discharged safely, with or without treatment, then the water will be pumped into tankers and disposed off appropriately at a suitable licenced waste facility.

This abstraction and discharge are singular events, and although a considerable amount of water may be required, they are unlikely to have any long term permanent effects on biological quality elements and physico-chemical parameters. Likewise, no new permanent structures are proposed at the temporary abstraction or discharge points, although baffles may be required to ensure that the discharge does not cause any scour of the river bed or erosion of the banks.

Cumulative Effects

A cluster analysis has been undertaken to assess the risk to each WFD water body where there are multiple crossing within their catchment but of tributaries that are not designated under the Directive. Providing the mitigation measures identified in this Chapter 6 Water Resources and Flood Risk (Document 6.6) are implemented the constructions works will be compliant with the objectives of the WFD. Please refer to Section 9.1.112 for more details regarding mitigation measures.

WFD Mitigation Measures

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It is good practice to consider even when all crossings are compliant with the objectives of the WFD the potential for the Onshore Scheme to help deliver improvements to WFD water bodies. Appendix 6.6.6 (Document 6.6.6) lists the mitigation measures that have been proposed by the EA for those water bodies that are not meeting Good Ecological Status / Potential. A review of mitigation measures indicated that the majority are not relevant to the scheme due to the crossing technique used to preserve the features. The one measure of relevance was the preservation, and where possible, restoration of Market Weighton Canal. Due to the transitory nature of the works it is beyond the scope of the development Onshore Scheme to support this improvement measure. However, it should be noted that the proposed crossing method to drill beneath the canal will avoid adverse effects to the current water body. Following completion of the works at Bracken Beck (that will be crossed using an open cut technique) the banks will be reinstated and replanted / reseeded. Where possible, opportunities to improve the quality and diversity of riparian habitat will be considered and detailed in future Flood Defence and Land Drainage Consent applications.

WFD Cluster Analysis

A cluster analysis was carried out to consider the cumulative potential effect of multiple watercourse crossings on the relevant WFD watercourses. Please see the ‘Method’ section above for the cluster analysis method. Watercourse crossings were grouped to the relevant WFD designated watercourse into which they discharge. Table 25 outlines the number of watercourse crossings per cluster (WFD designated watercourse or watercourse reach):

Table 2 WFD Designation Watercourse Clusters

Number of Crossed Receiving WFD Cluster Title Watercourses within Watercourse Cluster* River Ouse Cluster River Ouse 47 River Foulness Cluster River Foulness 25 Market Weighton Cluster Market Weighton Canal 18 Middleton on Wolds and Bracken Beck 3 Watton Beck Cluster West Beck Lower to River Northfield Beck 26 Hull Cluster West Beck Upper Cluster River Hull 1 Driffield Navigation Cluster Driffield Canal 7 Kelk Beck from Markham to Kelk Beck 7 Froddingham Beck Cluster Gransmoor Drain (from Gransmoor Drain 7

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Table 2 WFD Designation Watercourse Clusters

Number of Crossed Receiving WFD Cluster Title Watercourses within Watercourse Cluster* Burton Agnes to Lissett) Cluster Earls Dyke to N Sea Cluster Earls Dike 1 *Figures include WFD crossing itself and all other Pipeline Envelope watercourse crossings that drain to that particular WFD water body.

The risk to each WFD designated system has been qualitatively based on the following: • The WFD designation crossing (where applicable); • The number of Pipeline crossings that ultimately drain to that designated watercourse; • The proximity of a crossing to the WFD designation; • The potential to intercept a spillage / silt-laden runoff at a crossing; • The dilution potential of a watercourse;

The significance of a spillage / silt-laden runoff is considered to be of Neutral significance. Open cut techniques result in a morphological effect with a significance of effect no greater than Small adverse (see Section 4 of Chapter 6 Water Resources and Flood Risk (Document 6.6) for methodology). Where trenchless techniques are to be utilised (see Appendix 6.6.3 (Document 6.6.3)) no direct effects are expected. The River Ouse has the largest number of crossed watercourses that ultimately drain to it. Some crossings are adjacent to the Ouse, yet others are beyond 1 km and will discharge into the Ouse via the River Derwent or River Aire, for example. When considering the cumulative propagation of pollutants from open cut techniques, in-combination with the large dilution capacity of the Ouse, leads to the judgement that there will not be a significant cumulative effect upon this water body. In the case of other larger watercourses (Market Weighton Canal, River Foulness, River Hull and Kelk Beck) there will also be a large dilution capacity and therefore no cumulative effect.

Bracken Beck, Northfield Beck, Driffield Canal, Gransmoor Drain and Earls Dyke all have low crossing numbers in their respective clusters. Therefore, it is considered that the dilution potential in each case would be sufficient to ensure that there is no cumulative effect.

As the disturbance at a crossing point is small and localised (with an open cut trench estimated to be 2 m wide) the number of crossings per WFD water body is considered to be satisfactory in comparison to the size of the WFD designated water body that it discharges to / is part of.

Based on the above, a thorough understanding of the baseline environment and professional judgement it is considered that the number of crossings per cluster

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Relevant Consultation

Responses

The Yorkshire and Humber (CCS Cross Country Pipeline) Development Consent Order

Under Regulation 5(2)(a) of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Application Reference: EN070001 June 2014 Environmental Statement Volume 6: Ch. 6 Water Resources and Flood Risk 1 Environmental Statement Document 6.6.8

Appendix 6.6.8: Relevant Consultation Responses

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Mr Richard Gwilliam - Consents Officer Our ref: RA/2011/118140/02-L01 National Grid Your ref: CCS1 Land and Development Group 1100 (Century Way) Thorpe Park Date: 08 August 2011 Leeds West Yorkshire LS15 8TU

Dear Mr Gwilliam

YORKSHIRE & HUMBER CARBON CAPTURE AND STORAGE (CCS) PROJECT - PUBLIC CONSULTATION. UNDECIDED ROUTE FROM HATFIELD TO NORTH SEA.

Thank you for consulting us on the routing options for this project. We would like to make the following comments.

Flood Risk and Drainage It will have to be demonstrated that any permanent or temporary works within floodplain (Flood Zones 2 and 3) do not adversely affect floodplain mechanisms. This includes ensuring that activities and structures, in the eventuality of a flood, do not displace flooding extents or obstruct flood flow routes.

All infrastructure should be made adequately resilient from flooding to ensure operability in adverse conditions. Given the nature of the floodplain that the pipeline could traverse through, in the event of a flood, standing water could be encountered for prolonged periods of days or even weeks. In most locations, flooding would only occur if flood defences were overtopped or failed. However, the pipeline options do coincide with designated washland areas, designed to flood preferentially to reduce flooding elsewhere. The corridors and areas affected are listed below.

We do not support open-cut methods for pipe crossings on Main River/ We are pleased that non-open cut methods have been specified in the Route Corridor Study document and during the Environment Agency meeting with National Grid in Leeds on 28/07/11.

Given the subterranean nature of the pipeline, provided you are able to demonstrate that any permanent or temporary works within areas at risk from flooding will not adversely affect the floodplain, and that the pipeline will be capable of remaining operational during flood conditions, we consider that limited weight should be afforded to floodplain as a spatial constraint to routing options. You would be advised to consult other interested parties such as Yorkshire Water, the relevant Internal Drainage Boards and the relevant Lead Local Flood Authorities. It should also be noted that mapping of flood risk areas (from all sources) is subject to change. You are advised to periodically check that you are using the best available information on any environmental constraint.

Table 8.1 has some inaccuracies:

Environment Agency Phoenix House, Global Avenue, Leeds, LS11 8PG. Customer services line: 03708 506 506 www.environment-agency.gov.uk Cont/d..

Corridor section:  C1-C2, C4 Sub-section 1f Watercourses – Back Delfin Beck should be listed as Mill Beck (Main River)  D2 - This corridor will have to unavoidably cross 3 sections of the Main River network – this is not accurately reflected in sub-section 1f. From south to north: - The corridor crosses Beck/Bryan Mills Beck (Scorborough is currently listed but not Bryan Mills Beck), but is also very likely to have to cross Beck Diversion and its associated embankment(s), which is not currently listed. - Watton Beck will have to be crossed. It is currently listed under ‘minor’ sensitivity. However, as this watercourse is an embanked high-level carrier, we would suggest it is best placed in ‘moderate’. - Scurf Dyke/River Hull, although currently listed under ‘minor’, these watercourses are also embanked high-level carrier, so we suggest they’re best placed in ‘moderate’.  D3 Catchwater South (Main River) is not listed under 1f.

Tables 8.2 and 10.1 should be rechecked to ensure that these corrections are carried through.

Below are listed, per corridor length and AGI area:  Main Rivers within potential corridors and AGI option areas. Although, realistically not all will be affected, they are listed for completeness. Works in Rivers Consent, under the Water Resources Act 1991 and Yorkshire Land Drainage Byelaws 1980, will need to be applied for, applicable to all permanent and temporary works associated with each crossing.  The Internal Drainage Board areas which are crossed by the corridors and AGI areas. This list is indicative only, based on our GIS information. The IDBs would have to be directly consulted for wholly accurate boundary information.  Historical flooding within potential corridors and AGI option areas. This information is not identified to individual historical flood events, but is rather an indicative amalgam of the information the Environment Agency holds. The exception is the flooding caused in June 2007 in East Riding and Hull areas, which is identified as a separate indicative GIS layer.

Table 1 – additional flood risk related information

Corridor/AGI A1 A2 A3 A4 Main River Don Don Don Don Aire IDBs Dun (sic) Rawcliffe Goole & Goole & Airmyn Black Drain Selby Area Rawcliffe Rawcliffe Black Drain Thorntree Dempster Black Drain Thorntree Black Drain Historical flood Yes Yes Yes Yes

Corridor/AGI B1 B2 B3 B4 Main River Derwent - Ouse - IDBs Ouse & Derwent Lower Ouse Lower Ouse Market Lower Ouse Selby Area Weighton Selby Area Lower Ouse Historical flood Yes Yes Yes Yes

Corridor/AGI B5 B6 C1 C2 Main River - Foulness Mill Beck Mill Beck IDBs Market Market Market Market Cont/d.. 2

Weighton Weighton Weighton Weighton Lower Ouse Lower Ouse Historical flood Yes* Yes* Yes* Yes*

Corridor/AGI C3 C4 C5 C6 Main River Mkt Weighton Mill Beck - - Canal Foulness IDBs Mkt Weighton Mkt Weighton - - Historical flood Yes* Yes* Yes* Yes*

*= flooding indicated in June 2007

Corridor/AGI C7 D1 D2 D3 Main River - - Scorborough - Beck; Diversion; Bryan Mills Beck; Beverley & Barmston Drain; Watton Beck; Scurf Dyke; Hull IDBs - - Beverley & - North Holderness Historical flood No No Yes* Yes*

Corridor/AGI D4 D5 D6 D7 Main River - Skerne Beck Holderness Barmston Sea Drain Drain; Drake Drain Frodingham Beck & Kelk Beck; Lanswick Branch Drain; Millingdale Branch Drain; Old Howe; Pitwherry Drain IDBs Beverley & N Beverley & N Beverley & N Market Holderness Holderness Holderness Weighton

Historical flood No No Yes* Yes*

Corridor/AGI E1 E2 E3 Main River - Barmston Sea - Drain IDBs Beverley & N. Beverley & N. Beverley & N. Holderness Holderness Holderness

Historical flood No Yes* No

*= flooding indicated in June 2007

Corridor/AGI AGI Area A AGI Area B AGI Area C North & South Main River Ouse Foulness - Aire Cont/d.. 3

IDBs Selby Mkt Weighton - Lower Ouse Goole & Airmyn Historical flood Yes* Yes* No

Corridor/AGI AGI Area D AGI Area D north south Main River Creke Dike; Arram Drake Drain; Catchwater Driffield Canal; North & Arram Frodingham Beck; Beck & Kelk Arram Beck; Catchwater Hull; South; Hutton Beck; Beverley & Lanswick Barmston Branch Drain; Drain; Mickley Dike; Holderness Nafferton Drain; Highland Hull Stream; Old Howe; Skerne Beck; White Dike IDBs Beverley & N. Beverley & N. Holderness Holderness

Historical flood Yes* Yes*

*= flooding indicated in June 2007

Corridor A2 cuts across the Ings Washlands. It is not entirely unavoidable but does occupy approximately 50% of the corridor width. AGI Area A includes approximately 50% of Rawcliffe Ings washlands and approximately 75% of a washlands area upstream of Airmyn. The implication for locating the pipeline in these washlands is that the surface may be waterlogged for longer periods, while these areas hold floodwaters before, during and after flood events.

Risk of flooding from reservoirs According to the Environment Agency ‘Risk of flooding from reservoirs’ GIS layer, a number of the corridors and AGI areas are at theoretical risk. This data provides a general indication of the largest area that might be flooded if a reservoir were to fail and release the water it holds. It is taken from a national assessment and displays a worst case scenario. The map is only intended as a guide and is not a prediction of what will happen.

Corridors A1-A4 and AGI Area A are shown to be partly overlaid by the flood outline for various controlled flood washlands, and in the case of the AGI Area, an industrial cooling pond.

B1-B3 are shown to be partly within the outlines of a reservoir and washlands. C1-3 are partly affected by the Mill Beck Flood Storage Reservoir outline, at Market Weighton.

D2, D6 and D Northern Area could be affected by Top Hill Low reservoir.

Potential impacts from our long term plans to manage flood risk in East Riding

Cont/d.. 4

The Environment Agency has produced a draft River Hull Flood Risk Management Strategy. The Strategy found that we cannot continue to fund the long term maintenance of three pumping stations in middle catchment of the River Hull – , and pumping stations. It is the same case for some flood banks in the upper catchment.

The reasoning is that the assets do not protect people and property from flooding or there would not be enough benefits compared to the cost of maintaining or improving them. We can only commit to maintaining them until 2015. Until then, we are working with others to review future management options, such as alternative management or the securing of funding arrangements.

If the pumping stations were to cease operation, more agricultural land would be flooded and become increasingly waterlogged. However, much of this land floods following heavy rainfall and is already overwhelmingly situated in medium (flood zone 2) and high (flood zone 3) risk areas.

Modelled and mapped outlines have been produced to show the possible extent of flooding after 2015 if maintenance was withdrawn as envisaged. Corridors D2 and D6 and AGI Areas D north and south are shown to be partly affected by the outlines, in 50% (1 in 2 years), 4% (1 in 25 years) and 1% (1 in 100 years) floods. The outlines do not extent beyond the current outline of Flood Zones 3 and 2.

Consent requirements For all permanent and temporary works on, over or under Main River will require prior consent from the Environment Agency under the Water Resources Act 1991. Any permanent or temporary works within an 8 metres byelaw distance measured horizontally from the landward limit of main river banks, or if the bank includes a wall or embankment, 8 metres from the landward foot thereof, will need consent under the Yorkshire Land Drainage Byelaws.

The consenting determination process takes 2 months. Therefore, we recommend that consent is applied for well in advance of proposed scheme commencement. We also recommend pre-consent discussions between applicants and our Development & Flood Risk team in York.

For works on ordinary watercourses (i.e. every river, stream, ditch, drain, cut, dyke, sluice, sewer [other than public sewer] and passage through which water flows and which does not form part of a main river) consent will be required under the Land Drainage Act 1991 for any works that permanently or temporarily restrict flow in watercourses.

In IDB areas, consent will be required from the relevant IDB. Outside IDB areas, the Environment Agency is currently the consenting authority. However, the Flood and Water Management Act 2010 makes provision for Lead Local Flood Authorities (LLFAs) to take over this responsibility. This part of the Act is yet to be commenced. We anticipate that powers will be transferred in early 2012.

In this future scenario, consent will be required from Council, in their role as LLFA, for crossings on ordinary watercourses outside of IDB areas.

Further data acquisition To better understand the exact spatial locations of Main Rivers, ordinary watercourses, historical flooding and risk from reservoirs, we suggest that the relevant GIS layers are

Cont/d.. 5

requested from the Environment Agency, via the following email address [email protected]

Pollution Prevention We would strongly advise that our guidelines on pollution prevention during the construction period be followed. Details can be found here http://www.environment- agency.gov.uk/static/documents/Business/pipes.pdf.

We would advocate adopting similar pollution prevention principles to those used during the recent gas pipeline project. We would expect a Construction Environment Management Plan (CEMP) to detail the techniques to be used for each section, along with how the relevant information will be disseminated to contractors and monitored accordingly in due course. Particular attention should be paid to river crossings and areas within Source Protection Zones, if present. We are likely to request a condition to cover this issue.

Given that there is very little experience of transporting Carbon Dioxide in the proposed manner, we would like to request that supporting information is provided to describe the likely risks posed to the environment by this operation in the event of a leak or breach of the pipeline. We are particularly interested:-  Impact on air quality;  Impact on water quality – e.g. pH;  Resultant impact on aquatic and terrestrial ecology;  Likely duration of leak/breach;  Likely quantities released during leak/breach;  Ability to detect leak/breach;  Potential for impurities in CO2. Other parties are also likely to be interested in the human health implications of a leak/breach; this could include potential impacts on drinking water supplies.

Groundwater A number of routing options dissect or pass near to Source Protection Zones. It is imperative that robust mitigation measures be incorporated in these sensitive areas where water resources are used for human consumption. Significant weight should be afforded to SPZs as a spatial constraint to routing options. If it is not possible to avoid them, full pollution prevention details must be included in a CEMP.

You should also be aware that work is currently being undertaken to improve the conceptual modelling used to map areas of SPZ. It is possible that a number of the SPZs identified as being in close proximity to some of the proposed corridors may change as a result of this piece of work. It is possible that they might get bigger or smaller, or even change in shape. The work may also result in the formation of new SPZs, although we do not believe that any of these will affect your area of interest. The results of this work should be available in around September. We recommend that you contact us then to request an update.

Landfill A number of routing options pass near to active or historic landfill sites. We consider that significant weight should be afforded to these sites as spatial constraints to routing options, given the pollution and gas migration risk they are likely to pose.

Contaminated Land

Cont/d.. 6

It is possible that the pipeline route may pass through areas suffering from historical land contamination. We would advise that such areas are identified through undertaking a Preliminary Site Investigation prior to finalising the pipeline route. This may help you to identify historic land use and thereby assess the risk of contamination being present. Laying a pipeline through contaminated land is likely to pose a pollution risk and incur potentially significant additional cost to the necessary works.

Water Resources If water will be necessary during the commissioning of the pipeline you will need to identify and secure a suitable source. An abstraction licence from the Environment Agency may be needed to undertake this work. Any licence may impose restrictions on abstractions during periods of low flow or drought. You should provide an indication of the likely source of this water and the quantities likely to be involved at the earliest opportunity.

It may also be necessary during commissioning for water to be discharged from the pipeline. An Environmental Permit from the Environment Agency may be required to undertake this work. Ideally water should be returned to the same system from which it was abstracted. Transfer of water from one system to another may also pose ecological problems such as the inappropriate transfer of fish eggs. There may also be water quality issues should commissioning water accrue sediment or pollutants during the testing/commissioning phase. It may be necessary to provide treatment or settlement before any discharge. You should provide an indication of the likely discharge points and quantities likely to be involved at the earliest opportunity.

Coastal Change Zones We would advise you to consult with East Riding of Yorkshire council who hold a great deal of information about coastal change zones. Infrastructure should be sited and designed to withstand the predicted impacts of coastal erosion, taking into account climate change and its associated sea level rise. PPS25 and its Coastal Supplement should be taken into account.

Off-Shore Whilst the current consultation only directly considers onshore routing options, you have requested our initial views on the presence of any significant offshore constraints which might dictate routing options both on and offshore

We advise that you consult the JNCC and Natural England regarding the draft Marine Conservation Zones, in particular the Net-Gain project. Whilst it is unlikely that the findings of this project will be available before the end of 2012, some of the mapping and data collection may be available beforehand. In addition, a useful source of information may also be other commercial projects which have taken place recently in the area which may have been required to undertake survey work as part of their application process. It may be possible to attain relevant information through such sources.

Should you require any additional information or clarification, please do not hesitate to contact me on the details below.

Yours sincerely

Mr Sam Kipling

Cont/d.. 7

Planning Liaison Technical Specialist Direct dial 0113 213 4652 Direct fax 0113 213 4609 Direct e-mail [email protected]

End 8

Mr Richard Gwilliam - Consents Officer Our ref: RA/2011/118140/03-L01 National Grid Your ref: CCS1 Land and Development Group 1100 (Century Way) Thorpe Park Date: 16 May 2012 Leeds West Yorkshire LS15 8TU

Dear Mr Gwilliam

YORKSHIRE & HUMBER CARBON CAPTURE AND STORAGE (CCS) PROJECT UNDECIDED ROUTE FROM HATFIELD TO NORTH SEA.

Following our meeting on 2 April 2012 and the latest routing information we have the following comments.

Flood Risk Many of the general comments contained in our previous letter dated 8 August 2011 (our ref: RA/2011/118140/02-L01) are still relevant. Otherwise, now supplied with a preferred route, we have tailored some more detailed information, using the previously submitted GIS shapefiles and their identification system (1A-D7 etc) in comparison with the newly submitted pdfs showing the preferred route.

Paragraphs 1-4 on page 1 of the previous letter, under Flood Risk Drainage heading could be reiterated.

Table 1 amended to reflect latest proposed route: Corridor/AGI A1 A2 B2 B5 Main River Don Don - - Aire IDBs Dun (sic) Rawcliffe Lower Ouse Market Black Drain Selby Area Weighton Black Drain Lower Ouse Historical flood Yes Yes Yes Yes*

Corridor/AGI B6 C1 C4 C5 Main River Foulness Mill Beck Mill Beck - IDBs Market Market Mkt Weighton - Weighton Weighton Lower Ouse Historical Yes* Yes* Yes* Yes* flood

Environment Agency Phoenix House, Global Avenue, Leeds, LS11 8PG. Customer services line: 03708 506 506 www.environment-agency.gov.uk Cont/d..

Corridor/AGI D1 D4 D7 E1 Main River - - Barmston Sea - Drain; Drake Drain Frodingham Beck & Kelk Beck; Lanswick Branch Drain; Millingdale Branch Drain; Old Howe; Pitwherry Drain IDBs - Beverley & N Market Weighton Beverley & N. Holderness Holderness Historical No No Yes* No flood

Corridor/AGI AGI Area A AGI Area B AGI Area C AGI Area D North north Main River Ouse Foulness - Creke Dike; Aire Drake Drain; Driffield Canal; Frodingham Beck & Kelk Beck; Hull; Hutton Beck; Lanswick Branch Drain; Mickley Dike; Nafferton Highland Stream; Old Howe; Skerne Beck; White Dike IDBs Selby Mkt - Beverley & N. Lower Ouse Weighton Holderness Goole & Airmyn Historical Yes* Yes* No flood *= flooding indicated in June 2007

Background information:

Cont/d.. 2

Deliverables\Final Deliverables\6.6 Water Resources and Flood Risk\6.6.8 Relevant Consultation Letters\2. EA_corres-2012-05-16.docx

 Main Rivers - all potentially affected are listed above. Works in Rivers Consent under the Water Resources Act 1991 and Yorkshire Land Drainage Byelaws 19080, will need to be applied for, applicable to all permanent and temporary works associated with each crossing.

 The Internal Drainage Board areas which are crossed are listed but this is only indicative, based on our GIS information. The IDBs would have to be directly consulted for wholly accurate boundary information and their consenting requirements.  Ordinary watercourse crossings (which have not been listed), outside of IDB areas, may need consent under the Land Drainage Act 1991 from the relevant Lead Local Flood Authority - East Riding of Yorkshire, Doncaster and North Yorkshire County Council (covering Selby District) are the 3 possibles.  Historical flooding is listed, it is not identified to individual flood events but is rather an amalgam of the information the Environment Agency holds. The exception is the flooding caused in June 2007 in the East Riding and Hull areas, which are identified with an asterix.

Flood storage areas - the previous options submission showed that some designated flood storage areas could be affected. The newly submitted preferred route does not affect any flood storage areas.

Risk of flooding from reservoirs According to the Environment Agency ‘Risk of flooding from reservoirs’ GIS layer, a number of the corridors and AGI areas are at theoretical risk. This data provides a general indication of the largest area that might be flooded if a reservoir were to fail and release the water it holds. It is taken from a national assessment and displays a worst case scenario. The map is only intended as a guide and is not a prediction of what will happen.

Corridors A1-A2 and AGI Area A are shown to be partly overlain by the flood outline for various controlled flood washlands, and in the case of the AGI Area, an industrial cooling pond.

B2 is shown to be partly within the outlines of a reservoir and washlands. C1 is partly affected by the Mill Beck Flood Storage Reservoir outline, at Market Weighton.

D Northern Area could be affected by Top Hill Low reservoir.

Potential impacts from our long term plans to manage flood risk in East Riding The Environment Agency has produced a draft River Hull Flood Risk Management Strategy.

The Strategy found that we cannot continue to fund the long term maintenance of three pumping stations in the middle catchment of the River Hull – Wilfholme, Hempholme and Tickton pumping stations. It is the same case for some flood banks in the upper catchment.

The reasoning is that the assets tend to protect land rather than people and property from flooding or there would not be enough benefits compared to the cost of maintaining or improving them. We can only commit to maintaining them until 2015. Until then, we

Cont/d.. 3

Deliverables\Final Deliverables\6.6 Water Resources and Flood Risk\6.6.8 Relevant Consultation Letters\2. EA_corres-2012-05-16.docx are working with others to review future management options, such as alternative management or the securing of funding arrangements.

If the pumping stations were to cease operation, more agricultural land would be flooded and become increasingly waterlogged. However, much of this land floods following heavy rainfall and is already overwhelmingly situated in medium (flood zone 2) and high (flood zone 3) risk areas.

Modelled and mapped outlines have been produced to show the possible extent of flooding after 2015 if maintenance was withdrawn as envisaged. AGI Areas D north is shown to be partly affected by the outlines, in 50% (1 in 2 years), 4% (1 in 25 years) and 1% (1 in 100 years) floods . The outlines do not extend beyond the current outline of Flood Zones 3 and 2.

Consent requirements For all permanent and temporary works on, over or under Main River will require prior consent from the Environment Agency under the Water Resources Act 1991. Any permanent or temporary works within an 8 metres byelaw distance measured horizontally from the landward limit of main river banks, or if the bank includes a wall or embankment, 8 metres from the landward foot thereof, will need consent under the Yorkshire Land Drainage Byelaws.

The consenting determination process takes 2 months. Therefore, we recommend that consent is applied for well in advance of proposed scheme commencement. We also recommend pre-consent discussions between applicants and our Development & Flood Risk team in York.

For works on ordinary watercourses (i.e. every river, stream, ditch, drain, cut, dyke, sluice, sewer [other than public sewer] and passage through which water flows and which does not form part of a main river) consent will be required under the Land Drainage Act 1991 for any works that permanently or temporarily restrict flow in watercourses.

In IDB areas, consent will be required from the relevant IDB. Outside IDB areas, Lead Local Flood Authorities (LLFAs) determine consent.

Further data acquisition To better understand the exact spatial locations of Main Rivers, ordinary watercourses, historical flooding and risk from reservoirs, we suggest that the relevant GIS layers are requested from the Environment Agency, via the following email address [email protected].

Groundwater & Contaminated Land The most recent pipeline route does pass through two groundwater public supply source protection zones at Springwell (SPZ2) and more significantly at (SPZ1). We would like you to reconsider the proposed pipeline route through Hutton Cranswick SPZ1 and preferably move the route towards the south-east in order to miss the SPZ altogether. The Hutton Cranswick SPZ will be redefined in the next year and is likely to change in shape, becoming wider and shorter, but it is unlikely to extend much in the south-easterly direction.

The main concerns for groundwater protection are during the construction phase. This

Cont/d.. 4

Deliverables\Final Deliverables\6.6 Water Resources and Flood Risk\6.6.8 Relevant Consultation Letters\2. EA_corres-2012-05-16.docx principally involves the location and management of areas/compounds to be used for the temporary storage of fuels and vehicle re-fuelling sites.

Ecology Our Martin Fuller recently attended the ecology working group meeting on 15 March 2012 to discuss proposed route.

Of the major river crossings the one under the Hull (West Beck & Driffield Canal) is of greatest concern and will need a site meeting involving ourselves and Natural England amongst others.

All route clearance work (involving trees, hedges etc.) should be carried out outside the bird nesting season.

A survey for invasive species must be undertaken and post project management be arranged so as to prevent invasives spreading along the corridor from one catchment to another.

Water used for testing pipes or other uses must be returned to the point from which it was taken to prevent the spread of pathogens etc. Untreated water must not be transferred between water courses.

In terms of protected species please note that there are cetaceans recorded in tidal sections of the Yorkshire rivers. Vibrations and sonic disturbance should be kept to a minimum in tidal reaches.

In addition, migratory fish species may also be sensitive to noisy construction works. Sensitive migratory periods, particularly the spring, should be avoided where possible.

Should you require any additional information or clarification, please do not hesitate to contact me on the details below.

Yours sincerely

Mr Sam Kipling Planning Liaison Technical Specialist Direct dial 0113 213 4652 Direct fax 0113 213 4609 Direct e-mail [email protected]

End 5

Deliverables\Final Deliverables\6.6 Water Resources and Flood Risk\6.6.8 Relevant Consultation Letters\2. EA_corres-2012-05-16.docx

Mr Richard Gwilliam - Consents Officer Our ref: RA/2011/118140/04-L01 National Grid Your ref: CCS1 Land and Development Group 1100 (Century Way) Thorpe Park Date: 13 August 2012 Leeds West Yorkshire LS15 8TU

Dear Mr Gwilliam

YORKSHIRE & HUMBER CARBON CAPTURE AND STORAGE (CCS) PROJECT CCS ROUTE FROM HATFIELD, DONCASTER TO BAINBRIDGE, EAST RIDING OF YORKSHIRE.

I apologise for the delay in responding to your latest consultation. Please find our comments below:-

Flood Risk In addition to comments we have made previously, we advise that any subsequent Flood Risk Assessment demonstrates that all above ground installations will, from FEED stage (front end engineering design), be designed such that:  Installations are resilient to potential flooding without employing measures that increase flood risk to others. This resilience will enable assets to remain operational during flooding or recoverable immediately after flooding recedes.  Access and egress routes to installations remain safe for users during flooding.  Any bunding used for landscaping purposes is arranged so as not constitute a detrimental barrier to flooding i.e. does not displace flood flows onto others.  Surface water drainage from sites is dealt with in a sustainable manner, with adaptation for expected climate change increases in rainfall intensities. Hardstanding areas should be kept to a minimum.

In specific regard to borehole location - if these are maintained outside of the Environment Agency's byelaw distance (8 metres from the landward toe of raised flood defences) then Works in Rivers consent will not be required from the EA. On all other watercourses (i.e. non Main River) consent could be required from the relevant IDB if boreholes are located within proximity to watercourses. The relevant IDB should be able to advise in more detail.

Groundwater Protection We have reviewed the AECOM report on the White Rose CCS Project Route Corridor Study.

The section of the pipeline route from Hatfield to Drax crosses SPZ 2 and SPZ3 of the Gooshouse Drain Public Water Supply, but this is acceptable as long as SPZ1 is avoided. Forthcoming changes to SPZ delineation are not expected to increase the sizes of the current SPZ1 and SPZ2, or move SPZ1 into the path of the current pipeline

Environment Agency Phoenix House, Global Avenue, Leeds, LS11 8PG. Customer services line: 03708 506 506 www.environment-agency.gov.uk Cont/d.. route.

Pollution We have no specific concerns in relation to the location of the boreholes, provided best practice on pollution control is followed. We have previously referred you to the relevant pollution prevention guidance notes relating to the installation of major pipelines.

We should be contacted in the event of any dewatering activities to determine whether water is of a quality suitable for discharge to watercourse.

Biodiversity We would like you to identify and incorporate opportunities for providing biodiversity enhancement as a result of the project. We would encourage improvements to green infrastructure, especially along watercourses. Sympathetic riverside planting can provide valuable habitat and useful shade and can help to counteract the predicted impacts of climate change. Improvement areas could perhaps be focused in the location of any river crossings where disruption may be caused.

Should you require any additional information or clarification, please do not hesitate to contact me on the details below.

Yours sincerely

Mr Sam Kipling Planning Liaison Technical Specialist Direct dial 0113 213 4652 Direct fax 0113 213 4609 Direct e-mail [email protected]

End 2

Project Deliverables\Final Deliverables\6.6 Water Resources and Flood Risk\6.6.8 Relevant Consultation Letters\3. EA_corres-2012-08-13.docx

Mr Richard Gwilliam National Grid Land and Development Group 1100 (Century Way) Thorpe Park Leeds West Yorkshire LS15 8TU Our ref: RA/2011/118140/08-L01 Your ref: CCS1

Date: 12 July 2013

Dear Mr Gwilliam

YORKSHIRE & HUMBER CARBON CAPTURE AND STORAGE (CCS) PROJECT CCS ROUTE FROM HATFIELD, DONCASTER TO BAINBRIDGE, EAST RIDING OF YORKSHIRE.

I refer to the letter from AECOM regarding flood risk which we received on 5 June 2013. Some of the information you have requested will have incurred a charge so you should have been in contact with our Customers & Engagement team. We have attempted to answer the questions you have asked and have provided the relevant information on the enclosed CD/DVD.

Flood Risk Assessment We are pleased to hear that you are liaising with PINS to agree the vulnerability classification of the project. If you need any assistance on this matter, please let us know. You should be aware that irrespective of the agreed vulnerability classification (water compatible, essential infrastructure or less vulnerable), the proposal will need to be subject to the Sequential Test and must be provided with a flood risk assessment demonstrating that the proposed development will be safe throughout its lifetime, accounting for the predicted impacts of climate change, and demonstrating that flood risk will not be increased elsewhere. Where possible flood risk overall may be reduced by using appropriate mitigate measures or by contributing to schemes which may defend the development. It is also important to note that the issue of coastal erosion should be considered for the pumping station near Barmston. The only implication of the development being considered „essential infrastructure‟ is that it would need to be subject to the Exception Test and should be designed so that it will remain not only safe, but operational during flooding. Sir Michael Pitt‟s review of the summer 2007 floods also suggested such infrastructure should consider a more extreme flood such as a 1 in 200 event.

We feel it would be prudent for a single Flood Risk Assessment document to be produced to cover all flood risks to and from all elements of the project during both construction and operation phases. We disagree that the NPPF does not require an assessment of flood risks during the construction phase of development. It has the potential to be complicated and confusing to split any assessment of flood risk between FRA and EIA. It would be preferable for it to be in a single location.

Provided it can be demonstrated that the completed pipeline would not be vulnerable to

1 flooding, we agree that the flood risks associated with the pipeline‟s operational phase are negligible. We would however recommend that a brief section justifying this rationale is included in the Flood Risk Assessment.

Lifetime of the Developments and Climate Change Q1. We would draw a distinction between a pipeline‟s warrantied lifetime and its likely asset lifetime, with its asset lifetime being the period for which the pipeline‟s safe operation can be sustained with regular and routine maintenance and minor repairs. Similar rationale could also apply to AGIs. The period for most commercial developments is taken to be 75 years. A period of between 60 and 75 years would seem reasonable for assessing the climate change risks to this type of development. Given the potential impact of climate change on the long-term operability of AGIs, you may wish to take a corporate decision to build-in resilience beyond that suggested by the NPPF

Fluvial Flooding - Standard of Protection Q2. The generally accepted „design event‟ for development is the 1 in 100 plus climate change event (1 in 200 plus climate change where risk is from a tidal source). Sir Michael Pitt‟s report advocates consideration of a more extreme event for critical infrastructure, with this suggested as the 1 in 200 event (assumed for fluvial sources). The extant PPS25 Practice Guide merely advocates consideration of a range of return periods.

Your proposed 1 in 1,000 plus climate change event therefore appears to be conservative and precautionary, which we would support.

Fluvial Flooding – Estimation of 0.1% Climate Change Level Q3. You are correct to identify that flood levels for the 1 in 1,000 plus climate scenario are rare. It may therefore be a more practical solution for you to adopt the 1 in 100 plus climate change (or 1 in 200 for tidal sources) scenario, for which more data exists, with the addition of a cautious free-board on top of any such levels.

We would be similarly comfortable with the addition of a free-board to any 1 in 1,000 levels where these exist. Perhaps this approach can be further discussed and finalised when it is established what existing data is already available.

Flooding from Sewers and Drains Q4. It will need to be demonstrated, as part of any application that satisfactory means of surface water disposal are available at each relevant location. In the first instance, run-off should be controlled by minimising areas of hard-standing to an absolute minimum. Where hard surfacing is needed, permeable paving should be incorporated provided this will not pose an unacceptable pollution risk.

We agree that surface water discharged to sewer would be the least preferable option and is likely to be refused by Yorkshire Water. SuDS techniques should be incorporated with discharge to soakaways being the preferred option in most locations. Percolation testing will need to be undertaken and results submitted as part of the FRA to demonstrate feasibility of this method. If soakaways are unlikely to work you will need to demonstrate the availability of an appropriate watercourse and will need to manage any discharge to replicate green field run-off rates, with appropriate allowances for climate change and storage provided on site.

Q5. The climate change allowances in the NPPF Technical Guidance should be used when designing any surface water system. Depending on the receiving watercourse, permission may be needed from any relevant Internal Drainage Board. It is worth noting that as part of the Flood and Water Management Act, Sustainable Drainage Approval

Boards will be formed in each Lead Local Flood Authority to assess the implications of development on surface water flooding. This approval would be required alongside planning consent. This specific part of the act is due to be in-acted in April 2014.

Surface Water (Pluvial) Flooding Q6. When considering the risk to the proposed development and the adequacy of any resultant mitigation measures, you should consider the combined effect of all sources of flood risk, including surface water flooding where relevant. Provided surface water is managed as described in the above answers to questions 4 and 5, there should be no increase risk of flooding elsewhere as a result of the development.

Q7. We have provided two national maps, under our Strategic Overview for flooding, to the relevant Lead Local Flood Authorities North Yorkshire County Council and East Riding of Yorkshire Council, who are responsible for local flood risk, (i.e. surface runoff, ground water and ordinary watercourse), which alongside their existing local information will help them to determine what best represents surface water flood risk in your area.

We are not able to confirm if the Lead Local Flood Authorities for your area have decided what best represents surface water flood risk. You should contact them to confirm the latest position.

Please find attached the maps we provided to your Lead Local Flood Authority for your location:  Flood Map for Surface Water (2010)  Areas Susceptible to Surface Water Flooding (2009).

Flood Map for Surface Water is our new surface water flood map and provides a general indication of areas that may be at risk of surface water flooding. It takes broad account of underground drainage and typical storms which are likely to cause flooding, but these are only typical national figures and are not appropriate everywhere. The map indicates two depths of flooding: greater than 0.1m deep, and greater than 0.3m deep.

Areas Susceptible to Surface Water Flooding was produced in 2009 using a simple method that assumes that underground sewerage and drainage systems, and smaller over ground drainage systems are full to capacity. Generally these assumptions are oversimplifications, but in a few locations these assumptions are realistic. It shows three bands, indicating which are 'less to more' at risk of flooding from surface water.

Which map is right? Generally the Flood Map for Surface Water is the more realistic dataset as it takes better account of typical conditions that lead to surface water flooding. Lead Local Flood Authorities, will consider all the available data and agree, with the Environment Agency, Water Companies, Internal Drainage Boards and other interested parties, what surface water flood data best represents local conditions. This is known as locally agreed surface water information. It‟s very important to remember that neither map can be considered accurate down to an individual property level. Our surface water flood mapping is useful for identifying broad areas at risk of surface water flooding, but it‟s vital that local knowledge and information is used to interpret the maps.

As a rule of thumb the types of locations where the Areas Susceptible map might be a better representation of surface water flood risk that the Flood Map for Surface Water are where:

. local sewer capacity is able to drain closer to 0mm/hr than 12mm/hr in the 1.1hr storm event; . or areas are very flat and longer storm durations are more likely to cause flooding than shorter durations. As a rule of thumb the types of locations where the Flood Map for Surface Water might be a better representation of the surface water flood risk that the Areas Susceptible are where: . local sewer capacity is able to drain closer to 12mm/hr than 0mm/hr in the 1.1hr storm event; . or areas are steeper and flooding is more likely to be caused by short duration storms rather than longer durations.

Is my location at risk? All or part of the location you are interested in is in an area that our Flood Map for Surface Water shows at risk of surface water flooding.

All or part of the location you are interested in is in an area that our Areas Susceptible to Surface Water Flooding Map shows at risk of surface water flooding.

Each map can only give an indication of areas at risk from surface water flooding from a national assessment. They cannot provide detail on individual properties. Therefore the information above should not be interpreted as stating that the location you are interested in will or won't actually flood, but simply that it is in or not in an area shown at risk on the maps.

Who else is using this data? We have already provided these maps to our other partners (such as emergency services, local authorities, water companies) to use for emergency planning purposes. We have also provided this map to Local Planning Authorities for land use planning purposes. We have advised all our partners that they will need to make a local decision as to what information best represents local conditions.

Limitations of use Please read the attached copyright statement and disclaimer which explains what you can/cannot do with the Areas Susceptible to Surface Water Flooding data, and the attached Standard Notice which explains what you can/cannot do with the Flood Map for Surface Water data. If you have requested this map for use in a Flood Risk or Consequence Assessment please speak with your local Environment Agency Development & Flood Risk team who will advise on its use. For more information about how surface water flood risk is managed in your area, please contact your local authority.

Historical Flooding Q8. We can confirm that we are not aware of any historical flooding from Main River or tidal flood risk in the locations identified, beyond that shown on the historical flooding GIS layer. You are advised that other bodies such as the Lead Local Flood Authorities (relevant County Councils or Unitary Authorities), Yorkshire Water, or Internal Drainage Boards may also have records of local flood risk. It would be advisable to contact them for advice on this matter. We can provide you with contacts if required.

Reservoir Flooding and Other Artificial Sources Q9. Whilst the probability of reservoir flooding is likely to be low, the consequences may be serious. You are advised to consider whether any infrastructure in this particular area could be made resilient from the likely nature of flooding which would occur in the event of a reservoir breach – i.e. fast onset, probably fast-flowing etc. The incorporation of such measures may provide added protection and assist in the recoverability of the pipeline should it be subject to this type of flooding. We would not insist on any particular measures but it may be advisable to discuss this matter with PINS in the context of the proposal‟s vulnerability classification, the strategic importance of the infrastructure and any need for it to remain operational during periods of flooding.

Q10. You are advised to consult with the relevant Strategic Flood Risk Assessments for advice on the presence of other sources of flooding. Any site investigation works you undertake and associated discussions with landowners may assist you in identifying any localised flood risks which should be considered in your FRA.

Further Consultation Q11. You would be advised to visit http://www.shiregroup-idbs.gov.uk/map.aspx for information about IDBs in the area.

 The Tollingham site is within the Market Weighton Internal Drainage Board:

Name: Mr Andrew Morritt Address: 91 Bridgegate, , Goole, Humberside, DN14 7JJ Telephone: 01430 430237 Email: [email protected]

 The and Barmston sites are not covered by an IDB. You should contact the Lead Local Flood Authority to discuss drainage and surface water discharge at the sites.

Name: Neil Ager (ERYC) Email: [email protected]

 The Skerne site is covered by the Beverley Internal Drainage Board:

Name: Mr Bill Symons Address: York Consortium of Drainage Boards, Derwent House, Crockey Hill, York, YO19 4SR Telephone: 01904 720785 Email: [email protected]

 The Camblesforth site is covered by the Selby IDB.

Mr N Everard Selby Area IDB 12 Park Street Selby North Yorkshire YO8 0PW

Tel: 01757 702583 Email: [email protected]

Q12. You are also advised to consult the Lead Local Flood Authorities in the area – Selby District Council and East Riding of Yorkshire Council – regarding flooding from sources other than main rivers or the sea. East Riding of Yorkshire Council should also be consulted in respect to coastal erosion. Yorkshire Water should be consulted with respect to sewer flooding, foul and surface water disposal and water supply availability. In relation to any emergency planning related issues, you may wish to consult with the Councils‟ emergency planning teams and the emergency services.

Other General Issues Q13. The Risk Management Authorities listed above will be able to give you information on localised flood risk such as pluvial, ground water and ordinary watercourses.

Q14. There are no proposed schemes or investigations affecting any of the sites.

Camblesforth Multi-Junction A1. The best available information at present shows the site is within Flood Zone 3 in its entirety. It is also identified as lying within an area at risk from potential reservoir flooding. The site is also denoted as lying within functional floodplain Flood Zone 3b according to Selby DC‟s SFRA. The Environment Agency do not designate areas of functional floodplain (Zone 3b). This information can be found within the relevant Local Authority‟s Strategic Flood Risk Assessment. Please consider however, that Selby District Council have taken a conservative approach to designating functional floodplain by assuming that any areas of Flood Zone 3 lying outside development limits constitute functional floodplain. We would be happy to discuss specifics if this designation is apparent on any of your sites within Selby DC area. We hold no records of flooding on the proposed site.

The site lies within the Selby Area Internal Drainage Board (IDB). You are advised to contact the IDB to discuss any works that will affect any watercourses classified as non main river as formal consent will be needed from them under the Land Drainage Act 1991. The IDB is the responsible authority for any works that would affect any watercourses (classified as non Main River) within the site. The applicant should also contact the IDB regarding their requirements regarding surface water runoff and to ascertain whether or not they have any local records of the site having flooded.

You should be aware of the proposals of the Lower Aire Flood Risk Management Strategy. The strategic direction for the Lower Aire is that we will continue to maintain some 55km of defences and reduce flood risk to over 14,000 properties. However, there are lengths of the existing defences which do not have sufficient benefit to attract enough funding to allow us alone to continue maintaining them in the longer term.

We will continue to work with councils, IDBs, landowners, communities, and others to investigate options for maintaining these defences into the future. But if an alternative means of providing additional funding / reducing costs cannot be found we will have to follow national policy and withdraw from maintaining them.

More information can be found at our web page. The link for the Lower Aire Flood Risk Management site is: http://www.environment-agency.gov.uk/homeandleisure/floods/115320.aspx

A2. The Environment Agency do not designate areas of functional floodplain (Zone 3b). This information can be found within the relevant Local Authority‟s Strategic Flood Risk Assessment. Please consider however, that Selby District Council have taken a conservative approach to designating functional floodplain by assuming that any areas of Flood Zone 3 lying outside development limits constitute functional floodplain. We would be happy to discuss specifics if this designation is apparent on any of your sites within Selby DC area.

There must be no increase in surface water runoff from the site. As a minimum the Agency would want to see any surface water discharge restricted to the existing greenfield runoff rate. If not calculated, then the greenfield run-off from a 1 in 1 year storm (1.4l/s/ha) should be used. The applicant must also provide sufficient attenuation and long term storage at least to accommodate a 1 in 30 year storm. The design should also ensure that storm water resulting from a 1 in 100 year event, plus 30% to account for climate change, and surcharging the drainage system can be stored on the site without risk to people or property and without overflowing into the watercourse.

The Agency is keen to promote the use of Sustainable Urban Drainage systems (SUDs). SUDs tackle surface water run-off problems at source using features such as soakaways, permeable pavements, grassed swales, infiltration trenches, ponds and wetlands, and, green roofs to attenuate flood peak flows, produce water quality improvements and environmental enhancements. We seek to promote the use of SUDs techniques to this site and expect the developer of the site to submit detailed investigations such that the use of SUDs has been fully explored.

A3. We do not have any modelled flood levels for this area.

A4. N/A

A5. N/A

A6. See attached.

A7. This is predominantly a matter for the relevant Local Authority‟s emergency planners. Any proposals for emergency flood access/egress can only be considered in light of a Flood Risk Assessment demonstrating what the nature of the flood risk is, taking account of factors such as the speed of onset, depth, velocity, duration, availability of a flood warning etc. If facilities are un-manned and would not need to be accessed during a flood event to ensure continued operation, we agree that there is no need to make provision for safe access/egress. If however, this is not the case, an assessment should be made of the implications of sites being inaccessible, and if serious, opportunities to provide safe routes of access/egress during periods of flooding explored.

A8. We do not have any specific information to support or refute your assertion. The onus will be on you to demonstrate that risks have been adequately considered. It seems likely that the significance of these smaller watercourses is minor when compared to the larger sources such as the rivers Aire or Ouse, but local circumstances, such as topography or constrictions may dictate otherwise. It may be that the risk of local flooding may be at a much greater frequency than a larger event from Main River therefore this may be something you want to address. We would recommend the undertaking of a high-level assessment of the risk from these smaller watercourses, with a more detailed assessment following if deemed necessary.

A9. Given that the site benefits from flood defences from the Rivers Ouse and Aire, provided you can demonstrate that land-raising would not block or deflect important flood flow routes from these main rivers or unacceptably increase flood risks associated with local watercourses, we would not object to some land-raising in this location without the provision of compensatory storage. However we would likely object to the land-raising of the whole site as it risks setting a precedent for land raising in the flood plain. Land-raising

should be avoided where possible, with our preference being for specific sensitive buildings and other infrastructure raised rather than land wholesale. Where necessary any land raising should be kept to a minimum. Any impact of land-raising on the local drainage regime would need to be assessed and properly managed.

A10. Please see comments above. The footprint of any mounding should be kept to a minimum. An assessment of the impact of these mounds on flood flow routes and the local drainage regime must be provided. It may be necessary to leave gaps or conduits in the mounds to ensure flood waters are able to pass freely through them.

A11. Wherever possible any site compound should be sited outside the floodplain in the interests of both flood risk and pollution prevention. If this is not possible it should be sited on the highest ground available to minimise the risk of flooding. Comprehensive pollution prevention measures linked to the storage of fuels/oils and any other potentially polluting materials must be provided which will remain effective during flooding. An emergency flood plan may also serve to further reduce the risk of both flooding and pollution.

A12. We are content that there will be no need for compensatory floodplain storage for any loss of floodplain caused by the temporary storage of materials and equipment during the construction phase for Main River flooding. You should seek confirmation from the Internal Drainage Board as to local flood risk. Any excess spoil must be removed from the flood plain.

Block Valves – Tollingham B1. We can confirm that our records suggest the site is predominantly in Flood Zone 1, apart from the south east corner which lies within Flood Zone 3.

B2. We have no modelled flood levels for this area.

B3. N/A

B4. N/A

B5. We do not have any specific information to support or refute your assertion. The onus will be on you to demonstrate that risks have been adequately considered. It seems likely that the significance of these smaller watercourses is minor when compared to the larger sources such as the Rivers Foulness, but local circumstances, such as topography or constrictions may dictate otherwise. We would recommend the undertaking of a high-level assessment of the risk from these smaller watercourses, with a more detailed assessment following if deemed necessary. It may be that the risk of local flooding may be at a much greater frequency than a larger event from Main River therefore this may be something you want to address.

B6. You will need to demonstrate that any mounding will not affect the local drainage regime and that surface water will be properly managed.

B7. The construction compound should be sited in Flood Zone 1. Given the apparent availability of land in Flood Zone 1 for this purpose, you would need to justify why it has not been possible to avoid areas of floodplain. Please also refer to the above answer to question A11.

B8. As above, we expect any compound to be sited in Flood Zone 1 in this location. If this is not possible we are content that there will be no need for compensatory floodplain storage for any loss of floodplain caused by the storage of materials and equipment during the construction phase.

Block Valve – Dalton B9. We can confirm that our flood map records appear to mirror those included in your letter. The site appears to lie predominantly in Flood Zone 1, although the area of floodplain to the south of the site is certainly in close proximity. It would be advisable to use local topographical information to better understand the extent of any flood risk. Including ground water as this area can be susceptible to ground water flooding.

B10. We have no modelled flood levels for this area.

B11. N/A

B12. If the site and any associated mounding are located within Flood Zone1, we would have no concerns about loss of floodplain. Any impact on the local drainage regime would have to be assessed with surface water properly managed.

Block Valve - Skerne B13. The flood map included within your letter appears to accurately mirror our records. No new flood models have been released covering this site. Surface water flooding may be an issue in this location.

B14, 15 & 16 Modelled data in the River Hull has been provided from the ongoing 2011 River Hull Strategy output. Levels are given in meters above ordnance datum (mAOD) and flow values are given in metres³ per second (m³/sec). These are in the process of being updated as part of the River Hull Flood Risk Mapping study, which will be complete by July 2013. This study will supersede the previous values.

B17. We do not have any specific information to support or refute your assertion. The onus will be on you to demonstrate that risks have been adequately considered. It seems likely that the significance of these smaller watercourses is minor when compared to the larger sources, but local circumstances, such as topography or constrictions may dictate otherwise. The major flood risk for this area may be pluvial. We would recommend the undertaking of a high-level assessment of the risk from these smaller watercourses, with a more detailed assessment following if deemed necessary. It may be that the risk of local flooding may be at a much greater frequency than a larger event from Main River therefore this may be something you want to address.

B18. If the site and any associated mounding are located within Flood Zone1, we would have no concerns about loss of floodplain. Any impact on the local drainage regime would have to be assessed with surface water properly managed.

Barmston Pumping Station C1. The main risk to this site is coastal erosion. As suggested for C4 we strongly suggest you look at the coastal erosion rates, the best place for this is ERYC‟s own data: http://www2.eastriding.gov.uk/environment/sustainable-environment/looking-after-our- coastline/about-our-coastline/?locale=en#how-quickly-coast-erodingThe Shoreline Management Plan policy for this section of coastline is no active intervention and managed realignment. This means that the natural processes of coastal erosion will continue in this location and the lifespan of the asset will be significantly reduced.

C2. The maps in your letter appear to be up to date and consistent with our records. No recent modelling has been undertaken in this locality.Please see response to above. The site in question is not at risk of tidal flooding but the coastal erosion rates must be considered. We have provided plans showing the areas susceptible to surface water flooding and the flood map for surface water for the Barmston area. We have no modelled flood levels for this area.

C3. In respect to assessing risk from tidal flooding, we are content with your proposed methodology, assuming appropriate tidal flood levels are available.

C4. We would advise detailed discussions with the coastal engineers at ERYC. You do not appear to have taken any account of the impacts of sea level rise on rates of coastal erosion. Coastal erosion in this area can be extreme. We have seen instances where an 8m section can go in one storm event. It would be environmentally unacceptable to defend the facility should it become directly exposed to coastal erosion in the future as it would go against the existing SMP policy. The areas where the policy is “hold the line”, where defences are present, are the existing settlements along the coast line, Should the facility be closer to these areas it may benefit from the defences and therefore as a beneficiary of the defences ERYC and ourselves may expect a contribution towards the future upkeep. Your proposal appears broadly consistent with the advice in the NPPF, but you may wish to consider a more precautionary approach based on business risk, taking account of the cost and operational implications of any necessary future re-location.

Drax PIG TRAP D1. It appears that your floodplain information is correct. You should also be aware that this area lies within an area benefiting from flood defences.

There must be no increase in surface water runoff from the site. As a minimum the Agency would want to see any surface water discharge restricted to the existing greenfield runoff rate. If not calculated, then the greenfield run-off from a 1 in 1 year storm (1.4l/s/ha) should be used. The applicant must also provide sufficient attenuation and long term storage at least to accommodate a 1 in 30 year storm. The design should also ensure that storm water resulting from a 1 in 100 year event, plus 30% to account for climate change, and surcharging the drainage system can be stored on the site without risk to people or property and without overflowing into the watercourse.

The Agency is keen to promote the use of Sustainable Urban Drainage systems (SUDs). SUDs tackle surface water run-off problems at source using features such as soakaways, permeable pavements, grassed swales, infiltration trenches, ponds and wetlands, and, green roofs to attenuate flood peak flows, produce water quality improvements and environmental enhancements. We seek to promote the use of SUDs techniques to this site and expect the developer of the site to submit detailed investigations such that the use of SUDs has been fully explored.

D2. The Environment Agency do not designate areas of functional floodplain (Zone 3b). This information can be found within the relevant Local Authority‟s Strategic Flood Risk Assessment. Please consider however, that Selby District Council have taken a conservative approach to designating functional floodplain by assuming that any areas of Flood Zone 3 lying outside development limits constitute functional floodplain. We would be happy to discuss specifics if this designation is apparent on any of your sites within Selby DC area.

D3 & 4. We have provided you with modelled levels from the 2009 Ouse Model Update Study. Levels are given in meters above ordnance datum (mAOD) and flow values are given in metres³ per second (m³/sec). Two sets of flood levels have been provided for each node point on the updated River Ouse model.

D5. See attached.

D6. This is predominantly a matter for the relevant Local Authority‟s emergency planners. Any proposals for emergency flood access/egress can only be considered in light of a Flood Risk Assessment demonstrating what the nature of the flood risk is, taking account of factors such as the speed of onset, depth, velocity, duration, availability of a flood warning etc. If facilities are un-manned and would not need to be accessed during a flood event to ensure continued operation, we agree that there is no need to make provision for safe access/egress. If however, this is not the case, an assessment should be made of the implications of sites being inaccessible, and if serious, opportunities to provide safe routes of access/egress during periods of flooding explored.

D7. Given that the site benefits from flood defences from the Rivers Ouse and Aire, provided you can demonstrate that land-raising would not block or deflect important flood flow routes from these main rivers or unacceptably increase flood risks associated with local watercourses, we would not object to some land-raising in this location without the provision of compensatory storage. Land-raising should be avoided where possible, with our preference being for specific sensitive buildings and other infrastructure raised rather than land wholesale. Where necessary any land raising should be kept to a minimum. Any impact of land-raising on the local drainage regime would need to be assessed and properly managed.

D8. Please see comments above. The footprint of any mounding should be kept to a minimum. An assessment of the impact of these mounds on flood flow routes and the local drainage regime must be provided. It may be necessary to leave gaps or conduits in the mounds to ensure flood waters are able to pass freely through them.

D9. Wherever possible any site compound should be sited outside the floodplain in the interests of both flood risk and pollution prevention. If this is not possible it should be sited on the highest ground available to minimise the risk of flooding. Comprehensive pollution prevention measures linked to the storage of fuels/oils and any other potentially polluting materials must be provided which will remain effective during flooding. An emergency flood plan may also serve to further reduce the risk of both flooding and pollution.

D10. We are content that there will be no need for compensatory floodplain storage for any loss of floodplain caused by the temporary storage of materials and equipment during the construction phase.

Should you require any additional information or clarification, please don‟t hesitate to contact me on the details below.

Yours sincerely

Mr Sam Kipling Sustainable Places Planning Specialist Direct dial 0113 819 6386 Direct fax 0113 819 6299 Direct e-mail [email protected]

Mr Richard Gwilliam - Consents Officer Our ref: RA/2011/118140/11-L01 National Grid Your ref: CCS1 Land and Development Group 1100 (Century Way) Thorpe Park Date: 15 April 2014 Leeds West Yorkshire LS15 8TU

Dear Mr Gwilliam,

YORKSHIRE & HUMBER CARBON CAPTURE AND STORAGE (CCS) PROJECT - DRAFT ES CHAPTERS. CCS ROUTE FROM DRAX TO BARMSTON, EAST RIDING OF YORKSHIRE.

Thank you for consulting us on your draft ES chapters in advance of the submission of the DCO. We would like to provide the following comments:-

Geology, Hydrogeology & Ground Conditions

On page 8 the definitions used in table 2 for the „criteria to determine the sensitivity of receptors‟ are incorrect, as Source Protection Zones are not correlated to aquifer designations. Here is the correct definition, taken from the Environment Agency‟s GP3:-

“SPZs are used to identify those areas close to drinking water sources where the risk associated with groundwater contamination is greatest. SPZs have three subdivisions depending on the proximity to the drinking water source: Inner protection Zone (SPZ1); Outer Protection Zone (SPZ2); and Source catchment protection zone (SPZ3).”

For the table on page 8, we recommend using the Source Protection Zone and aquifer designations as two different examples of varying sensitivities. SPZ1 could be considered of very high sensitivity, SPZ2, SPZ3 and principal aquifers of high sensitivity with secondary A and B aquifers of medium sensitivity.

Furthermore it would be sensible for Sites of Special Scientific interest to be mentioned as a criterion of very high sensitivity in this table as well, as they might be groundwater dependent.

Environment Agency Coverdale House Aviator Court, York, North Yorkshire, YO30 4GZ. Customer services line: 03708 506 506 www.environment-agency.gov.uk Cont/d..

On Page 28 of the document it is mentioned that ‘No geological Sites of Special Scientific Interest (SSSI) have been identified.’ However, the pipeline crosses the SSSI of „River Hull Headwaters‟ at two points, at the River Hull/Driffield canal crossing and at the Kelk Beck crossing. The SSSI is mentioned in the previous chapter 6, and is not considered in chapter 7. Since there is a possibility that the site is supplied by groundwater, the impacts of dewatering on the SSSI must be assessed in regards to hydrogeology as well. This omission is also repeated in figure 7.12 on page 161.

(Pages 74, 79,106-107) The report mentions that dewatering will be required from the sand and gravel and Glacial Till deposits underlying the River Hull and Driffield Canal crossing. It also illustrates the risks from dewatering in the River Hull/Driffield canal area, and identifies the Main Drain as the water body more at risk of drying up from dewatering. In order to address the risk of the Main Drain drying up, the report proposes the monitoring of the water levels before and during dewatering to assess the effect on the drain as mitigation measures. It also proposes that water levels in the Main Drains could be maintained at a previously agreed level by discharging the abstracted groundwater into the Main Drain via a series of settlement lagoons.

We agree that the Main Drain is probably mainly fed by the secondary aquifer in the sands and gravel and believe that it is important to protect it from drying up. We agree with the recommendation to maintain the water levels in the drain through the discharge of the abstracted water. However, it would be useful to specify the rate of abstraction and the proportion of the volume which is going to be discharged into Main Drain and the exact point of discharge into the drain. It would also be useful to specify the season of the abstraction, as there is higher possibility of the drain drying up during the summer or early autumn period.

(Pages 74, 79,106-107) It is also mentioned in the report that the impact on the River Hull/West Beck will be insignificant, as it is fed by groundwater upstream and due to the large volume of water at the crossing point. Although impact from dewatering to the water flow of the River Hull might be insignificant, we believe that the impact of dewatering to the SSSI “River Hull Headwaters” needs to be assessed. Monitoring of water levels in the River Hull is proposed as a mitigation measure for the risks from dewatering. It might be useful to establish a minimum water level for the River Hull/West Beck as well, to protect the SSSI.

We agree that the Driffield canal is lined and therefore not connected to the secondary aquifer. We also agree that nearby groundwater abstractions are supplied by the deep Chalk aquifer underneath the deposits, and will not be impacted by the dewatering processes. However, there is a surface water abstraction about 1 km to the south of the crossing, which is supplied by the River Hull, and the impact from dewatering to this abstraction should be assessed.

(Pages 74, 79,106-107) There is no mention in the report about the methodology of crossing Kelk Beck to the east of West Beck/Driffield Canal. The sensitive SSSI “River Hull Headwaters” is also present at Kelk Beck at the point of the pipeline crossing. If the pipeline crossing of Kelk Beck does not require dewatering, this should be stated in the report. If dewatering is needed, the potential impacts to Kelk Beck and the SSSI should be assessed and mitigation measures should be proposed as for the River Hull.

On Page 28 of the document it mentions a detailed Crossing Method Statement to be developed for the crossing of the River Hull (West Beck/Driffield Canal). As stated above, since Kelk Beck is located in a SSSI at the point of crossing, it should be included in the report.

Cont/d.. 2

Regarding potential land contamination and groundwater quality and quantity issues, we agree with the methodology proposed in the report and the mitigation measures proposed. We believe that the report identified the potential contamination risks to groundwater and that those risks are minimal if managed by a Construction Management Plan.

Ecology & Nature Conservation

Table 9.3 on page 8 references 5.3.4 of EN-1 and the requirement to take advantage of opportunities to conserve and enhance biodiversity. It is crucial that this is fully explored and supporting evidence provided. We are currently involved in the pre-inquiry process for a number of other local NSIPs and the Examining Authority (ExA) has questioned compliance with 5.3.4 of EN-1 and in all cases asked for further information from the applicant to evidence the provision of ecological enhancements. In light of this, it would be prudent to pro-actively provide a detailed summary of ecological enhancements incorporated into the scheme which would deliver a biodiversity gain commensurate with the scale of the proposal.

Page 10, section 2.4.9 makes reference to a number of saved policies from historic Local Plans but dismisses the importance of emerging Local Plans. Given that historic plans such as the Beverley Borough Local Plan (1996), Boothferry Borough Local Plan (1999) and East Riding Borough Local Plan (1997) are in the process of being replaced by the emerging East Riding Local Plan (which is now at submission stage), we believe that significant weight should be given to the draft policies contained therein. Policy ENV4 in the submission Local Plan document reflects the requirements of the NPPF and the local aspirations for nature conservation, specifically those for ecological enhancement.

Furthermore, in order to clarify the local policy requirements regarding biodiversity, it would be useful to provide not just a list of relevant policies, but a summary of the relevant requirements of each. This would assist the reader in understanding the ecological considerations required for the project, and may be of particular use to the ExA during determination.

Based upon the summary information provided on page 26 in table 9.8 (Ecological Surveys – Methodology Summary), it appears that otter and water vole surveys have been undertaken in accordance with best practice.

We note from table 9.13 (Summary of Consultee Responses relevant to Ecology) on Page 40 that details of enhancement measures provided by the onshore scheme are set out in the Planning Statement – which we have not been provided with. We feel it is essential that this information is included within this ES chapter as it is a key ecological consideration. It is vital that sufficient information is provided to allow the ExA to properly assess and consider these issues as mentioned above.

We are pleased to see from section 6.1.55 on page 171 that information is provided to show how much potential water vole habitat will be impacted by the watercourse crossings. However, this section should be supported by further indicative details as to the temporary nature of the disturbance, and reference made to the relevant mitigation section. A loss of 468m of bank-side habitat, even if only temporary in nature, would require adequate mitigation.

Cont/d.. 3

We are pleased to see from section 6.4.20 (Bats, water vole and otter) on page 187 that operational noise has been identified as a cause of disturbance to water vole and otter. Again, as above, this section could be improved by linking to relevant mitigation, in order to ensure that the reader is confident that mitigation is directly targeted to specific impacts.

Section 7.1.2 on page 195 lists enhancement as a form of ecological mitigation. Whilst enhancement should be considered when producing mitigation plans, it is important to retain the distinction between mitigating for adverse effects, and enhancement of the ecological value of the site. As highlighted earlier in this response, in other NSIP determinations, the ExA has been keen to ensure that enhancement has been fully considered and incorporated into schemes, distinct from mitigation measures.

Section 7.2.84 (Water voles) on page 211 gives indicative timescales for disturbance which are somewhat misleading. Whilst construction works on minor watercourses may only take a week, disturbance will inevitably be far more extensive. Where water voles are present, pre-construction displacement and fencing, and the time required for regeneration of bank-side habitat will extend the period of disturbance. This must be factored into mitigation measures.

We support the proposals, set out in section 7.2.248 (Water voles) on page 240, to create compensatory ditch habitat to replace that lost at the Barmston Pumping Station. However, this section needs more detail as to the quantity of compensatory habitat that will be provided.

In sections 8.2.35 to 8.2.42 on page 252, and many others, reference is made to mitigation measures contained in section 9.8. This section does not refer to mitigation measures. As outlined above, there must be adequate mitigation provided for the loss, albeit temporary, of nearly 500m of water vole habitat along the pipeline route, and these mitigation measures should be clearly highlighted within the ES. Given the scale of this scheme, we do not believe it is sufficient merely to argue that the effects of displacement and habitat loss are temporary and therefore no further mitigation is required.

During previous meetings and consultation responses, we have repeatedly raised the issue of ecological enhancement. And as mentioned throughout this response, it is an issue which the ExA is likely to show considerable interest in. As a result, we would strongly urge you to explore all avenues available to you to ensure that the scheme delivers ecological enhancement commensurate with its considerable scale. It is unfortunate that we have not been consulted on this occasion regarding the enhancement measures outlined in your Planning Statement. We are keen to work with you to ensure the scheme delivers the best practicable environmental outcomes. If, as previously discussed, it is not possible to deliver adequate ecological enhancement within the application boundary, we would be pleased for you to work with our Environment Programme team to help deliver relevant off-site enhancement in partnership with other organisations.

Water Resources & Flood Risk

The information provided appears to have given due consideration to potential impacts on water quality.

Cont/d.. 4

We are pleased to see suitable reference to all relevant Environment Agency pollution prevention guidance notes.

WFD classifications and WFD objectives appear to have been given due consideration.

Consideration of the control of silt as part of a Silt Management Plan is noted. Issues likely to be encountered during both open cut and HDD crossings appear to have been identified and given due consideration with reference to mitigation measures. Open cut methodologies should contain specific detail regarding the isolation of the section of watercourse to be crossed, with measures in place to minimise the displacement of solids downstream. It should be acknowledged however, that sediment minimisation measures are unlikely to be 100% effective and that there will remain a residual risk to the watercourses in question.

Likewise, with any dewatering we would anticipate that appropriate treatment measures, e.g. settlement facilities, be put in place to minimise the impact of any discharged water. If water can be treated to an appropriate standard, it may constitute an uncontaminated discharge and would therefore not require a formal permit. If appropriate standards cannot be achieved, discharge to land must be considered, provided this option does not increase any localised flood risk, and the appropriate permissions from any landowners are obtained.

One area of concern is the option for a potential discharge of biocide, following hydrostatic testing of the pipeline. The River Hull and Driffield Canal, which are both specified watercourses in the pipeline corridor, support commercial trout farms, rearing and providing fish for the food production industry. In view of this, we would be minded to oppose the discharge of biocide into the water environment, and would anticipate that other disposal routes, e.g. containment and off-site disposal, discharge to sewer, or discharge to land (within a non sensitive receptor area) are given preferential consideration. Any discharge to the environment of water containing biocide is likely to result in the need for an Environmental Permit from the Environment Agency.

The following comments are based on the information in document 6.6, chapter 6 Water Resources and Flood Risk.

Sections 6.1.173, 7.2.23, table 18 and page 179 contain an incorrect spelling („Gipsey Race‟) of the water course . This should be corrected.

Section 6.1.172 states that the Driffield Construction Compound is a temporary compound at risk of groundwater flooding, however concludes that because this flooding is considered slow it does not require further consideration. We would rather this stated that as the temporary compound is also at high risk of fluvial flooding as indicated on the Flood Map, mitigation measures will already be in place which will address both forms of flooding. This should negate the need for additional measures for ground water specifically.

Section 6.1.204 should be amended to include a more detailed explanation of the 1.64m/yr erosion rate. This amount is not an annual occurrence on a consistent basis along the coast. Some years and in certain locations, the erosion rate will be less and in some area up to 10 metres could erode in 1 night.

Leading on from the comment above, we are aware that it has been considered, but recommend that you explicitly state in section 6.1.205, that you have taking into account the coastal erosion effects on the infrastructure leading from the onshore pumping

Cont/d.. 5

station. We have many examples along this coast of pipelines emerging from the clay cliffs, becoming exposed and requiring extensive remediation works, as the erosion rates were not adequately considered when looking at the depths of the infrastructure.

The reference in section 7.1.3 needs completing.

In relation to section 8.1.36 appropriate requirements will be needed to control the detail of any dewatering of excavations.

Sections 8.1.40, 8.1.47, 8,1.67, 8.1.73, 8.1.76 and 8.1.82 refer to the risk of reservoir flooding. We feel the sentence that reservoir flooding would be slow because of topography is misleading and suggest that it instead states that the distance of the sites from the source is such that it is felt there would be adequate warning time.

In relation to section 8.1.45 we can confirm that the Environment Agency could issue a temporary insert into our incident manual for when you are working in these areas, in order to ensure that you receive any relevant warning.

Section 8.1.71 explains that the drainage design for the Barmston pumping station can be submitted post DCO. We feel you could mention that it is likely that the drainage design will need Sustainable Drainage Approval Board approval. This should be in place in October 2014 but as the details and specifications for this are not yet in place you could state that you are just using the principles that surface water from the site will be restricted to an appropriate rate. We also suggest that further information is added here to confirm who will maintain the drainage system on this site.

Flood Risk Assessment We are unclear of the benefits of having both a Flood Risk ES chapter and a free- standing FRA. We strongly recommend, in the interests of simplicity, that these two documents are combined into one, drawing together into a single location the assessment of flood risks and drainage matters and setting out those mitigation measures deemed necessary. At present, the two documents could unnecessarily confuse the reader and introduce uncertainty about what measures are actually proposed.

In relation to the dewatering of land adjacent to the River Hull, we agree with the calculations demonstrating the requisite size of the lagoons - 8500m2 on the southern (right bank) and 6000m2 on the northern (left bank) - to store water from the temporary dewatering process. These lagoons must be in place prior to any works commencing on the River Hull crossing. During periods of high-flow in the River Hull where a Flood Alert has been issued in the area, discharges from the lagoons should be halted until the Flood Alert has been lifted, meaning there will be capacity in the system again. The lagoons should be maintained by the applicant throughout the works. Once the works have completed there may be an opportunity to maintain the lagoons as habitat creation or flood storage. This could form part of your ecological enhancement strategy. We would be pleased to discuss this in more detail.

Sections 7.4.3 and 7.4.4 should be amended to explain that whilst NAFRA takes into account the probability of flooding, it does not consider the consequences. Therefore the sites are shown at low likelihood because of the presence of flood defences but the consequence of defences breaching or overtopping is why the site is at high risk in the Flood Zone maps.

Cont/d.. 6

There is a reference missing from section 13.3.1.

Section 13.11.9 deals with surface water run-off from Barmston pumping station. We are assuming that the surface water will have to go Earls Dyke and then discharge to the sea. Might there be some more local drainage ditches which go direct from site to the sea which could be utilised? The calculations need to take into account that the system may be tide-locked at times of high tide and the storage of any surface water needs to take this into account. The FRA should confirm that tide-locking has been considered and accounted for.

Should you require any additional information or clarification, please don‟t hesitate to contact me on the details below.

Yours sincerely

Mr Sam Kipling Sustainable Places Planning Specialist Direct dial 0113 819 6386 Direct fax 0113 819 6299 Direct e-mail [email protected]

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Mr Richard Gwilliam - Consents Officer Our ref: RA/2011/118140/12-L01 National Grid Your ref: CCS1 Land and Development Group 1100 (Century Way) Thorpe Park Date: 14 May 2014 Leeds West Yorkshire LS15 8TU

Dear Mr Gwilliam,

YORKSHIRE & HUMBER CARBON CAPTURE AND STORAGE (CCS) PROJECT - RIVER HULL/DRIFFIELD CANAL CROSSING ASSESSMENT. CCS ROUTE FROM DRAX TO BARMSTON, EAST RIDING OF YORKSHIRE.

I refer to the recent information provided in relation to the River Hull and Driffield Canal crossing and would like to provide the following comments:-

It is stated in the report that a borehole was drilled into the Chalk aquifer and recorded a water head of 3 metres above ground. Prior to capping the borehole the flow was found to be 0.5-0.6m3/hr, which is about 14m3/day. This value was used to calculate the worst case scenario volume of dewatering as 20,000 m3 for 16 wells and 100 days of pumping. However, this value of flow used in the calculations is the artesian flow of groundwater within the Chalk aquifer.

In order to lower the levels to 6mbgl, the dewatering process would need to abstract a much larger volume of water to generate a head decrease of 9 metres. Since the worst case scenario assumes that the Chalk aquifer will need to be dewatered, the volume will be much greater than 14m3/day and consequently 20,000m3 in total.

We know that the Chalk in the area has very high transmissivity and in the case it is found to be shallower than estimated, the volume of water, which will need to be pumped for dewatering the pit areas, will be very high and may have adverse impacts on water features nearby. The report’s calculations therefore seem to underestimate the potential worst case scenario volume of groundwater which will need to be pumped to lower the water table to the desired levels in the two thrust pits areas.

In order to set up a correct worst case scenario, an investigation needs to establish the necessary volume of water that needs to be abstracted, so that the water levels drop to approximately 6mbgl in the two areas of the thrust pits north and south of the crossing. As the presumed worst case scenario volume is underestimated, we cannot comment on the rest of the calculations of the report, as the sizes of the lagoons and the impacts on the River Hull will need to be reassessed.

We agree that if it can be demonstrated that the dewatering will be from the secondary

Environment Agency Coverdale House Aviator Court, York, North Yorkshire, YO30 4GZ. Customer services line: 03708 506 506 www.gov.uk/environment-agency Cont/d.. sand and gravels aquifer, the proposed mitigation measures should minimise the risk to Mains Drain and the River Hull. However, it should be established whether there is any risk of encountering the Chalk aquifer during construction and re-estimate the potential dewatering volume and the impacts dewatering the Chalk aquifer would have on the SSSI and the River Hull.

We would be pleased to review a revised report whereupon we will undertake further assessment of the potential flood risk and ecological impacts.

Yours sincerely

Mr Sam Kipling Sustainable Places Planning Specialist Direct dial 0113 819 6386 Direct fax 0113 819 6299 Direct e-mail [email protected]

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