Dear ExxonMobil,
We are grateful for this early opportunity to provide our feedback on the proposal to transport CO2 from Fawley to a carbon capture site off the coast of the Isle of Wight.
The sites proposed for the Solent CO2 Pipeline Project lie within both the New Forest National Park and the Isle of Wight National Landscape (IWNL) (the new area name for the Area of Outstanding Natural Beauty (AONB)). All the options involve major development within nationally designated landscapes and will be determined through the Nationally Significant Infrastructure Project process by the Government’s Planning Inspectorate.
We were unable to use the proforma consultation forms in our response to you due to the nature of the questions posed and limited space for comments.
We do not consider the installation of this pipeline can happen without potentially devastating impacts to the National Landscape (NL) and its special characteristics.
These comments have been prepared on behalf of the IWNL whose role is to promote the conservation and enhancement of the NL in accordance with the Countryside and Rights of Way (CRoW) Act 2000. In formulating these comments, regard has been given to the Isle of Wight AONB Management Plan 2019-2024 (MP) adopted as Isle of Wight Council Policy in April 2019. On December 26, 2023, the CRoW Act 2000 was amended. Section 85 now states that all relevant authorities must seek to ‘further the purpose’ of conserving and enhancing the natural beauty of the area of outstanding natural beauty.
The National Planning Policy Framework July 2021 (NPPF) gives NL/AONB’s the highest level of protection when it comes to landscape and scenic beauty and aims to protect these areas as set out in paragraphs 11 (see footnote 7), 180, 182 and 183. (No change to this is proposed in the current NPPF consultation.)
11. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
- all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
- strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
- the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area (see footnote 7); or
- any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole. For decision-taking this means:
- approving development proposals that accord with an up-to-date development plan without delay; or d) where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date8, granting permission unless:
- the application of policies in this Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed (see footnote 7); or
- any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.
Footnote 7
The policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites (and those sites listed in paragraph 187) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets (and other heritage assets of archaeological interest referred to in footnote 72); and areas at risk of flooding or coastal change
180. Planning policies and decisions should contribute to and enhance the natural and local environment by:
- protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan);
- recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;
- maintaining the character of the undeveloped coast, while improving public access to it where appropriate;
- minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
- preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans; and
- remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.
182. Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.
183. When considering applications for development within National Parks, the Broads and Areas of Outstanding Natural Beauty, permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.
Consideration of such applications should include an assessment of:
- the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
- the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
- any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated. 184. Within areas defined as Heritage Coast (and that do not already fall within one of the designated areas mentioned in paragraph 182), planning policies and decisions should be consistent with the special character of the area and the importance of its conservation. Major development within a Heritage Coast is unlikely to be appropriate, unless it is compatible with its special character.
Enacted by a Labour Government, the Isle of Wight National Landscape (then named AONB) was designated under the National Parks and Access to Countryside Act 1949 to protect our finest landscapes for now and into the future. The Primary purpose of the designation is the conservation and enhancement of natural beauty (which includes wildlife and cultural heritage, as well as scenery). Therefore, it is considered that running a pipeline through a significant portion of this landscape is contrary to this purpose and will cause significant, permanent, harmful visual impacts upon landscapes protected for their intrinsic beauty which are limited resources in themselves. The impact, both temporary and permanent, from not only the easements, but also from the above ground apparatus, will be considerable.
There are questions that need to be addressed within any application documents which set out why investment is being made into burying CO2 rather than reducing its production, why placing the pipeline along the Solent has been discounted, how far and why directional drilling can and cannot be used and how have they considered avoiding nationally designated landscapes. It needs to be clear what distance directional drilling is achievable over and why any has been discounted along the terrestrial route.
Whilst there is mention of avoiding irreplaceable habitats such as Ancient Woodland, the National Landscape also contains other international, national and local designations for:
Coastal areas; both for their intrinsic beauty and enjoyment as well as ecological, geological and scientific value;
Protected species: 22 of which occur with the IWNL of which 2 only occur in the IWNL;
Together with SPA, SAC, MCZ, Ramsar, SSSI and SINCs.
Furthermore, the special characteristics of the Isle of Wight National Landscape are many, contrasting, varied and inspiring. They contribute greatly to the quality of life and well‐being of local communities and visitors. From majestic sea cliffs and sweeping beaches to the quiet solitude of ancient woodland; the ever changing patchwork of worked fields to the timeless and enduring presence of the downs; the intricate inlets of tranquil creeks to the long distance views from coastal heath and downland; the planned and manicured gardens of former Royal Estates and Victorian villas to the irregular undulating hedged fields of pasture; the dark starlit skies to the bustle and colour of festivals and events; the winding paths, shutes and hollow ways in the countryside to chines and steps down cliffs to the beach; place names and dialect to poetry, literature and art; isolated houses, hamlets and rural villages to harbour towns, castles and tumuli; plants and animals to fossilised trees and dinosaur footprints and the myriad archaeological deposits.
Any proposal within the IWNL needs to demonstrate how these characteristics will be maintained and enhanced. If the Inspector is minded to approve the application, the route of the pipeline should avoid the NL. If this cannot be achieved then any impacts need to be minimised, mitigated and as a last resort compensated for. We have no details at this time of what above ground installations will look like. These will also need mitigation measures to reduce visual impacts and we can discuss those at the appropriate time.
Three options have been put forward. Of the 3 options, the Isle of Wight North to West route, exiting at Afton Down, impacts the least amount of land within protected landscapes. However, there remains 6 nationally and internationally designated sites on this land:
National Landscape/AONB
Heritage Coast
SAC
SSSI
Open Space
SPA
Additionally, the internationally recognised and designated, delicate and exceptional chalk grassland habitat on the downs should be one of the foremost considerations after communities, ancient woodland and historic assets.
For the reasons set out above, it is therefore considered the proposals put forward are incompatible with the policies and protections laid out by government within these nationally designated landscapes and would fail to ‘further the purposes’ of the designated landscape as set out in Section 85 of the CRoW Act 2000.
You will appreciate these comments are made without prejudice to any further comments we may make in response to future consultation exercises and the Development Consent Order.
Yours faithfully
The Isle of Wight National Landscape Partnership
Unit 8/ Branstone Farm Park / Branstone / Sandown / Isle of Wight / PO36 0EQ