ExxonMobil CO2 Pipeline – Observations on the arguments and challenges

It’s been encouraging to monitor the spirited discussion on social media relating to ExxonMobil’s non-statutory consultation on its ‘Solent CO2 Pipeline’ proposal.

Like many contentious development proposals, this pre-planning consultation was launched during a holiday period, prompting sceptics to suggest that the company was aiming to limit the volume of the response.

If that was the intention, then ExxonMobil might have been taken aback by the public’s reaction, particularly on the Isle of Wight where discussion has been vocal and battle lines have been drawn-up by the community with their elected representatives working together. If the communities on the mainland appear less engaged, ExxonMobil should not conclude that their reaction has been any less.

With one week to go before the formal consultation period closes, it’s worth reflecting on what the community is commenting on, to whom they should be raising those comments, and who the key decision makers will be.

We cover those points below, but in summary, the community should perhaps consider the need for two separate responses:

The first is obviously to ExxonMobil, to respond to its fundamental question which, paraphrased, is “which pipeline corridor do you prefer?” The overwhelming response is clearly ‘none of the above’, which echoes our own view.

That response needs to be given by 6:00pm on Monday 30 September. Follow this link for details of how to respond.

It would be beneficial if responses urged ExxonMobil to revisit their plans, thoroughly reassess all available options for liquid CO₂ transportation, and submit a more comprehensive application in conjunction with the necessary upstream and downstream construction projects to allow all parties to make well-informed, comprehensive decisions.

The second response, which is probably best drafted by the leaders of local community groups, environmental organisations and local elected representatives, should be addressed to the government decision-makers and copied to local constituency Members of Parliament. That response should set out clearly worded arguments detailing why the ExxonMobil proposal, as currently drafted, is insufficiently detailed to be acceptable as a Development Consent Order application.

The arguments need to be presented in the first place to the Department of Housing, Communities and Local Government (DHCLG), into which the Planning Inspectorate (PI) reports. The Planning Inspectorate is the decision making body charged with determining whether to accept an application for a Development Consent Order. As an additional measure, it may be worth copying the response to the Department of State for Energy Security and Net Zero (DESNZ) although that department would not become the decision making body until the DCO application has been accepted, assessed and approved by the Planning Inspectorate.

There is less immediate urgency for this response since the Planning Inspectorate will not commence analysis of the application until ExxonMobil choose to submit it, which will be long after 30 September.

We set out our observations on the arguments and challenges below:

On the safety and viability of CO2 pipelines

As far as engineering goes, the Planning Inspectorate (PI) will see no insurmountable challenges and the Exxon/Jacobs team can demonstrate capability based on their experience and track record with the Esso Southampton to London Pipeline (SLP) project completed in 2023. That pipeline contains aviation fuel, a highly volatile and flammable liquid which could also cause significant environmental damage if leaked. The pipeline proposed in this consultation would contain liquid CO₂ under pressure, by comparison a relatively benign, non-flammable product but one which is transported at significantly higher pressure.

Despite the oft-quoted Satartia Mississippi pipeline rupture event, ExxonMobil will likely have effective responses and will argue that both of these fluids are safer when carried by pipeline than by road or rail tankers, where the risk of accident would be greater.

In summary: While the ‘exploding CO₂ pipeline’ risk provides a dramatic scenario for protestors, it is unlikely to sway any decision by either the Planning Inspectorate or, further down the line, by the Department of Energy Security and Net Zero (DESNZ).

On the lack of detail required to assess the CO2 Transport options (‘Corridors’)

From the outset, Solent Protection Society has maintained that this consultation is both flawed and incomplete. The documents present a fait accompli, expecting the respondent to chose between three completely unacceptable pipeline corridor options without presenting the facts necessary to properly inform that choice.

Even under the flawed assumption that a pipeline is the sole option for CO₂ transport, the available choices remain incomplete. The clear end-to-end underwater routes have been rejected without adequate explanation, and the equally apparent option of direct seaborne transport from Fawley’s own dock facility is completely ignored.

In summary: The shortlist of CO₂ transport options does not withstand basic scrutiny.

On the lack of detail required to assess the environmental impacts of the proposal

In terms of pipeline corridor selection, the key environmental principle must be to ensure protection of, or provide sufficient mitigation for, any harm to designated terrestrial or marine environments and habitats. Currently, there is not enough detail to evaluate these impacts. This creates a ‘Catch-22’ scenario, where ExxonMobil is pushing for the pipeline corridor to be chosen before the necessary environmental baseline surveys have been completed.

If pipeline transport turns out to be the only option, the construction and operational impacts on the natural environment and wildlife habitats must be taken into account. The consultation documents recognise the environmental designations of all three selected corridors and note the company’s obligation to produce their Environmental Impact Assessment (EIA) and Habitats Regulations Assessment (HRA). However, the company proposes to do this only after the route corridor has been chosen and finalised in a Development Consent Order.

At that stage, the company plans to ‘develop mitigation where significant adverse effects are identified’ and ‘identify opportunities for enhancements either within the DCO or elsewhere to achieve Biodiversity Net Gain.’ In our view, given the sensitivity of the three land corridors, the environmental analysis should follow an ongoing, iterative process throughout the preplanning phase, with an initial pass providing enough baseline survey data to guide the selection of appropriate route corridors for consultation. This has not been done, making valid feedback impossible.

Additionally, we would emphasise that the common developer tactic of offering environmental mitigation ‘out of area’ is unacceptable, particularly in the Isle of Wight’s ‘National Landscape’ or the New Forest ‘National Park’.

In summary: The assessment of environmental impact should follow an ongoing iterative process throughout the pre-planning stage, rather than be left until the corridor decision has been made.

On Carbon Capture and Storage as a climate change mitigation measure

There are several high-level arguments against carbon capture and storage (CCS) as a climate change mitigation measure:

Cost: CCS is often criticised for being expensive compared to other methods of reducing emissions, such as renewable energy sources like wind and solar. The high costs of capturing, transporting, and storing CO₂ can make it less economically viable.
Energy Intensive: The process of capturing and compressing CO₂ requires a significant amount of energy, which can reduce the overall efficiency of power plants and other industrial processes.
Moral Hazard: Some argue that CCS creates a moral hazard by allowing continued use of fossil fuels instead of transitioning to cleaner energy sources. This can potentially delay the adoption of more sustainable practices.
Limited Impact: Critics point out that CCS does not address the root cause of climate change, which is the burning of fossil fuels. Instead, it acts as a temporary solution that does not eliminate the need for a fundamental shift in energy production and consumption.
Environmental Risks: There are concerns about the long-term storage of CO₂, including the potential for leaks from storage sites, which could negate the benefits of capturing the carbon in the first place.
Inefficiency: Some studies suggest that CCS technologies are inefficient and may even increase air pollution in some cases. This inefficiency can undermine the overall effectiveness of CCS as a climate mitigation strategy.

In summary: These arguments certainly highlight the complexities and challenges associated with relying on CCS as a primary tool for combating climate change. However, these are arguments for a different forum.

What we’re dealing with here is a planning matter and we should be mindful that the UK Government has already decided that its strategy for industrial decarbonisation is for CCS. That decision, and the industrial lobbying in support of it, will inevitably frame the decision process.

On the lack of detail relating to carbon costings and the benefits case

The consultation documentation provides no data quantifying the amount of carbon that can be captured from the Fawley operation, the capacity of the proposed aquifer for storage, or the volume that can be compressed, liquefied, stored, and transported via the proposed pipeline.

Additionally, there is no information provided on the expected carbon costs associated with the construction and operation of the decarbonisation program at the Fawley site, the pipeline, or the offshore injection site facilities.

In summary: Without any quantifiable data on the costs, or clear statement of the benefits, no serious appraisal of the proposal can be made.

On the dismissal of surface shipping as an option for CO2 transport

The key question regarding CO₂ transportation is why a pipeline is deemed necessary when direct seaborne transport by liquefied gas tanker is a viable option that is already in use or proposed by other operators around the North Sea and in other maritime nations around the world. Developing a liquefied gas shipment capability at Fawley’s existing oil tanker port would pose minimal challenges and provide the flexibility to transport CO₂ to the most cost-effective storage site, particularly as the undersea injection site market is likely to become increasingly competitive in the future.

While ExxonMobil might have already missed the boat on booking new CO₂ tanker construction slots with the Chinese and Korean shipyards, there are other Scandinavian and European CO₂ shipping operators who already have the capacity in plan and could provide the service.

The injection site being promoted by ExxonMobil, ‘south west of the Isle of Wight’, has yet to be licensed for exploration, let alone storage. Should it prove commercially unviable, then the proposed pipeline would prove something of an embarrassing white elephant.

In summary: ExxonMobil’s decision that ‘the answer is a pipeline’ should be challenged. It has likely been influenced by the existing commercial relationships established by the SLP project and the success that the company had in driving that through the Planning Inspectorate NSIP process. It is therefore seen as the easy default option by ExxonMobil.

On ExxonMobil’s objectives for this consultation

The primary purpose of this current non-statutory consultation is to satisfy the first ‘Pre-application’ step in the Planning Inspectorate’s ‘Nationally Significant Infrastructure Project’ (NSIP) process. With this ‘tick in the box’, ExxonMobil will register its entry on the Planning Inspectorate’s register of NSIP projects as an application for an ‘Energy’, ‘Other pipeline’ project, under code ‘EN07’. The application will then sit on the register at the ‘Pre-application’ stage pending detailed analysis by the Planning Inspectorate while they decide whether or not to accept it. The public responses to this current consultation must be submitted by ExxonMobil with the application and they will be considered as part of the analysis.

The secondary purpose of the consultation is to help ExxonMobil decide which corridor to select for its application to the Planning Inspectorate. This will be decided on grounds of projected cost and technical expedience, neither of which should provide difficulty as discussed above. While the company initially favoured an Isle of Wight route purely on length of pipe, it’s possible – just possible – that they might take into account strength of public opposition. On the Isle of Wight at least, that has been impressive. However, its value would have been far greater had the general thrust been a consolidated push-back against a pipeline anywhere. The planning applicant (ExxonMobil) will doubtless take advantage of its perception that one side of the Solent is playing the NIMBY card against the other, a ‘wake-up call’ to the New Forest communities.

In summary: ExxonMobil’s primary objective – and probably the company’s sole purpose for this consultation -is to get a ‘tick in the box’ to enable them to submit an application for a Development Control Order. Through the incomplete consultation scope, ExxonMobil is simply attempting to secure its preferred scope and context for the DCO application ahead of any in-depth analysis by the Planning Inspectorate.

On the declaration that the Solent CO2 Pipeline should be considered a ‘Nationally Significant Infrastructure Project’ in isolation from its corequisite upstream and downstream projects

The scope of the NSIP application is simply the length of pipeline between the Fawley location and the ‘DCO Boundary’, which is the line on the map at which the planning and development consent moves from the PI with the DESNZ to the NSTA (North Sea Transition Authority, aka the Oil and Gas Authority). As we argued in Post 4 the ‘upstream’ projects – including the work at Fawley to capture and liquefy the CO₂ from its own refinery – is not defined, quantified or scheduled. The ‘downstream’ projects, the pipeline offshore and the undersea storage site and its ‘CO₂ injection point’ are not defined either, meaning that the application which ExxonMobil intend to raise is, in effect, a pipeline ‘from nowhere’ ‘to nowhere’.

In summary: It is valid to question how this standalone pipeline could be considered a Nationally Significant Infrastructure Project without the provision of essential detail relating to the missing components of the end-to-end programme of work.

This is the seventh SPS post on the subject of the ExxonMobil ‘Solent CO2 Pipeline Project.
The full list of SPS Posts on the subject can be found by clicking this link.
To return to the ExxonMobil consultation summary page, click here