Keuper Gas Storage Project
The applicant requested comments on the draft interim consultation report. PINS provided the following advice:
The report is clear and structured in a way that makes it easy to understand how consultation has been approached, what issues have been raised and in what forum, and how KGSL has had regard to responses received. Chapter 3 is particularly helpful in placing the consultation in the context of the legislation. The summaries of the responses are concise without losing a sense of the issues raised under each theme.
In that context I hope you find the following suggestions helpful:
? It could be helpful to have an executive summary, and within that capture the key responses that have led to changes to your scheme / further considerations. I was able to get a sense that your on-going work has been directly and indirectly influenced by responses sought / received built up from reading each response. However, I think there is value in covering this at the start to reinforce the importance given to section 49 in the wider application process.
? Where you have had regard to comments and made commitments or changes, I recommend identifying how / where these have been secured. For example, in Health and Safety paragraph 5.4.4 ? you identify measures that would address the issues raised; will these form part of the COMAH licence or will they be secured through the DCO? I would encourage you to review Chapter 5 so that in addition to advising what you have done in response, you advise how any assurances will be carried forward. Where further work has been undertaken through the EIA / measures have been secured in the DCO, it would be useful to cross reference specifically. Where you rely on other licences / legislation, it would also be helpful to specify this / indicate whether this would happen in parallel to / post DCO consent.
? A separate section on the draft SoCC consultation with local authorities, and demonstrating how you have had regard to their comments would be helpful.
? The cross-referencing to evidence in appendices already in the document is particularly helpful and will be important for the Acceptance period. It may already be your intention to cover in the contents but you could usefully add a summary table of appendices so that we can see ?at a glance? where to find specific evidence such as s48 notice.
Please note that the above comments are without prejudice to any future decision the Secretary of State may make on the application but I hope you find them helpful.