“Further to the submission of the above proposals which have recently been accepted, I have reviewed the submission and on the basis of my review to date, I have the following comments. Please note that the general point to these comments is to avoid SP Manweb assets being adversely impacted on and to engage as much as possible with the applicant to avoid such impacts. Comments have previously been sent to the applicant in March and July 2022 and these are attached. I also attach 5no. plans sent over in separate emails which show the affected SPM network and the pipeline proposals. General These comments are made by SP Energy Networks which acts on behalf of SP Manweb, the licenced Distribution Network Operator (DNO) for the area covered by the proposed scheme. SP Energy Networks operate and manage the electricity network up to 132kV. In general, SP Energy Networks has no objection in principle to the proposed pipeline scheme, however, it must ensure the avoidance of any adverse impact on its network as we all drive to maintain a network that is capable of meeting the increase in demand from an all-electric economy. SP Energy Networks has started a process of developing investment targets from 2023 to 2028 to meet the UK and devolved Governments ambitious decarbonisation targets for Net Zero. The next decade will be crucial in preparing the grid for these changes and this is why we are very interested in being able to comment on the proposals which may undermine maintaining and developing a suitable future grid network. In relation to this scheme, to date, SP Energy Networks has initiated engagement on various matters relating to the impact of the proposals on its network assets including the s42 stage and so considers to be at the early stages of working with the applicant to avoid impacts on its network. SPM Network assets Based on the plans prepared by SP Manweb, it is unclear where there will not be an impact on those SPM assets which are within the DCO limits. The current position is that SP Energy Networks has recently asked the applicant to provide an overlay plan showing SPM assets and the proposed DCO limits which seems the clearest way of showing the crossover points in detail with a schedule explaining what the crossover is. The key crossover points of interest to SP Manweb where there are existing high voltage 132kV and 33kV assets, which in some cases include the sites of the later proposed changes, are as follows: 1. North west Chester services 2. West of Backford 3. Saughall 4. Sealand Road 5. South of River Dee 6. South Queensferry 7. Connah’s Quay 8. Halkyn SP Energy Networks would like to resolve matters as much as possible and would like to see clarification on the crossover points/SPM assets as soon as further details can be provided. Impacts and consenting SP Energy Networks needs assurances that any affected network requiring to be diverted is, once identified, included in the EIA and properly assessed and reported. Where necessary, any related consents for diverting network is included in the DCO. The applicant should clarify these matters as soon as possible. Measures for agreed working (DCO) Having carried out an initial review of the draft protective provisions in the draft DCO, these are not consistent with the provisions SP Energy Networks has secured in similar DCOs. As such, the applicant is asked to continue to work with SP Energy Networks and agree as many areas of possible through the application stages. Land Rights SP Energy Networks will require all SPM land rights affected by the scheme that need to be amended to be agreed in full agreement with SPM. Reference is made to the Book of Reference where SP Manweb interests are included. Reviewing the BoR and confirming existing and proposed rights is likely to be an expansive task and the applicant is asked to engage with SPM regarding a timetable and cost undertakings to support working with SP Energy Networks in this regard. There are a number of key areas to resolve in relation to SPM network, which is critical to protect as it is this network that will be relied upon to distribute the generation into local homes and businesses. Any adverse impacts on the SPM network that need to be resolved by SPM would impact on the benefits of delivering this proposed scheme. The applicant should discuss the above with SP Energy Networks as soon as possible as they have been requested to do for over the past year but without making much progress. Given the extent of the information prepared and submitted, it is a reasonable expectation for there to be a plan produced showing the SPM asset as likely to be most affected and how, and an SPM network diversions worksheet that outlines how this network will be managed within the proposed development. SP Energy Networks will continue to review the DCO application and may wish to raise further matters in due course. In order to progress the above, SPEN has identified a need for the applicant to address the following: - to show on suitable plans where direct and indirect impacts from the new development on SPM network will arise - to ensure that where there are impacts these can be managed in an appropriate way through agreed protective provisions - to ensure the agreed measures are made clear to contractors working on site through required method statements and impacts on SPEN network are avoided - to ensure that where existing land rights are interfered with then these are replaced with new rights which retain SPEN’s existing rights or new rights are created as required for SPEN Please let me know if you would like any other information.”