Project: ACT Acorn Feasibility Study · The current assessment of both the onshore environmental impact and offshore environmental impact indicates minimal impact beyond current activities.

Project: ACT Acorn Feasibility Study

Terms of Use

The ACT Acorn Consortium partners reserve all rights in this material and retain full copyright. Any reference to

this material or use of the material must include full acknowledgement of the source of the material, including

the reports full title and its authors. The material contains third party IP, used in accordance with those third

party’s terms and credited as such where appropriate. Any subsequent reference to this third party material

must also reference its original source. The material is made available in the interest of progressing CCS by

sharing this ACT work done on the Acorn project.

Pale Blue Dot Energy reserve all rights over the use of the material in connection with the development of the

Acorn Project. In the event of any questions over the use of this material please contact [email protected].

mailto:[email protected]

D14 Outline Environmental Impact Assessment 10196ACTC-Rep-17-01

May 2018

www.actacorn.eu

ACT Acorn, project 271500, has received funding from BEIS (UK), RCN (NO) and RVO (NL), and is co-funded by the European Commission under the ERA-Net instrument of the Horizon 2020 programme. ACT Grant number 691712.

Acorn

D14 Outline Environmental Impact Assessment Contents

ACT Acorn Consortium Page 3 of 68

Contents

Document Summary

Client Research Council of Norway & Department of Business, Energy & Industrial Strategy

Project Title Accelerating CCS Technologies: Acorn Project

Title: D14 Outline Environmental Impact Assessment

Distribution: Client & Public Domain

Date of Issue: 31st May 2018

Prepared by: Frances Harding supported by Tim Dumenil, Charlie Hartley and Tiana Walker (all Pale Blue Dot Energy)

Approved by: Steve Murphy, ACT Acorn Project Director

Disclaimer:

While the authors consider that the data and opinions contained in this report are sound, all parties must rely upon their own skill and judgement when using it. The authors do not make

any representation or warranty, expressed or implied, as to the accuracy or completeness of the report. The authors assume no liability for any loss or damage arising from decisions

made on the basis of this report. The views and judgements expressed here are the opinions of the authors and do not reflect those of the client or any of the stakeholders consulted

during the course of this project.

The ACT Acorn consortium is led by Pale Blue Dot Energy and includes Bellona Foundation, Heriot-Watt University, Radboud University, Scottish Carbon Capture and Storage (SCCS),

University of Aberdeen, University of Edinburgh and University of Liverpool.

Amendment Record

Rev Date Description Issued By Checked By Approved By

01 29/05/18 First issue C Hartley T Dumenil S Murphy



Table of Contents

CONTENTS ................................................................................................................................................................................................................................................... 3

1.0 EXECUTIVE SUMMARY .................................................................................................................................................................................................................. 10

2.0 INTRODUCTION TO ACT ACORN .................................................................................................................................................................................................. 11

3.0 SCOPE ............................................................................................................................................................................................................................................. 16

4.0 ENVIRONMENTAL SCOPING REPORT ......................................................................................................................................................................................... 17

5.0 PROJECT DESCRIPTION ............................................................................................................................................................................................................... 19

6.0 ONSHORE ENVIRONMENTAL DESCRIPTION ............................................................................................................................................................................. 22

7.0 ONSHORE ENVIRONMENTAL IMPACT ASSESSMENT .............................................................................................................................................................. 26

8.0 OFFSHORE DESCRIPTION ............................................................................................................................................................................................................ 30

9.0 OFFSHORE ENVIRONMENTAL DESCRIPTION ............................................................................................................................................................................ 35

10.0 OFFSHORE ENVIRONMENTAL IMPACT ASSESSMENT............................................................................................................................................................. 42

11.0 PERMITS AND CONSENTS ............................................................................................................................................................................................................ 46

12.0 CONSULTATION ............................................................................................................................................................................................................................. 59

13.0 CONTENTS OF THE ENVIRONMENTAL STATEMENT ................................................................................................................................................................ 61

14.0 CONCLUSIONS AND NEXT STEPS ............................................................................................................................................................................................... 64

15.0 REFERENCES ................................................................................................................................................................................................................................. 65

16.0 ANNEX 1: CONSENT REGISTER ................................................................................................................................................................................................... 67



CONTENTS ................................................................................................................................................................................................................................................... 3

TABLE OF CONTENTS .................................................................................................................................................................................................................................... 4

FIGURES ...................................................................................................................................................................................................................................................... 9

TABLES ........................................................................................................................................................................................................................................................ 9

1.0 EXECUTIVE SUMMARY .................................................................................................................................................................................................................. 10

2.0 INTRODUCTION TO ACT ACORN .................................................................................................................................................................................................. 11

ACT ACORN OVERVIEW................................................................................................................................................................................................................... 11

ACORN DEVELOPMENT CONCEPT ..................................................................................................................................................................................................... 14

3.0 SCOPE ............................................................................................................................................................................................................................................. 16

PURPOSE ........................................................................................................................................................................................................................................ 16

SCOPE ............................................................................................................................................................................................................................................ 16

PROJECT SCHEDULE ....................................................................................................................................................................................................................... 16

4.0 ENVIRONMENTAL SCOPING REPORT ......................................................................................................................................................................................... 17

SCOPING OPINION ........................................................................................................................................................................................................................... 17

SCOPING OPINION QUESTION ........................................................................................................................................................................................................... 18

LAYOUT OF THE ENVIRONMENTAL SCOPING REPORT ......................................................................................................................................................................... 18

5.0 PROJECT DESCRIPTION ............................................................................................................................................................................................................... 19

ONSHORE FACILITIES ....................................................................................................................................................................................................................... 19

OFFSHORE FACILITIES ..................................................................................................................................................................................................................... 19

DESIGN BASIS ................................................................................................................................................................................................................................. 19

5.3.1 Existing CO2 Capture Plant .................................................................................................................................................................................................... 19

5.3.2 New CO2 Capture Plant ......................................................................................................................................................................................................... 20

5.3.3 Compression and Dehydration .............................................................................................................................................................................................. 20

5.3.4 Material Selection .................................................................................................................................................................................................................. 20



5.3.5 Utilities .................................................................................................................................................................................................................................... 20

5.3.6 Offshore ................................................................................................................................................................................................................................. 20

BLOCK FLOW DIAGRAM .................................................................................................................................................................................................................... 21

6.0 ONSHORE ENVIRONMENTAL DESCRIPTION ............................................................................................................................................................................. 22

LANDSCAPE AND TOPOGRAPHY ........................................................................................................................................................................................................ 22

SITE DESCRIPTION AND EXISTING LANDSCAPE CHARACTER ............................................................................................................................................................... 22

VISUAL RECEPTORS ........................................................................................................................................................................................................................ 23

GEOLOGY ....................................................................................................................................................................................................................................... 23

HYDROLOGY ................................................................................................................................................................................................................................... 23

DESIGNATIONS ................................................................................................................................................................................................................................ 23

7.0 ONSHORE ENVIRONMENTAL IMPACT ASSESSMENT .............................................................................................................................................................. 26

POTENTIAL LOCATIONS FOR A NEW BUILD CAPTURE PLANT ............................................................................................................................................................... 26

POTENTIAL IMPACTS ........................................................................................................................................................................................................................ 27

7.2.1 Ecology Rattray to Kirkton Head SINS .................................................................................................................................................................................. 27

7.2.2 Water Resources River Blackwater ....................................................................................................................................................................................... 27

7.2.3 Visual Impacts ........................................................................................................................................................................................................................ 27

7.2.4 Traffic and Transport .............................................................................................................................................................................................................. 28

7.2.5 Air Quality ............................................................................................................................................................................................................................... 28

7.2.6 Noise and Vibration ................................................................................................................................................................................................................ 28

7.2.7 Ecology .................................................................................................................................................................................................................................. 28

8.0 OFFSHORE DESCRIPTION ............................................................................................................................................................................................................ 30

LOCATION ....................................................................................................................................................................................................................................... 30

TRANSPORT .................................................................................................................................................................................................................................... 30

8.2.1 Facilities Re-use Versus New Infrastructure .......................................................................................................................................................................... 30

8.2.2 New 16” Infield Pipeline to the Acorn CO2 storage site Manifold .......................................................................................................................................... 32

APPROACH FOR OFFSHORE FACILITIES ............................................................................................................................................................................................. 32



8.3.1 Pipeline .................................................................................................................................................................................................................................. 32

8.3.2 Subsea ................................................................................................................................................................................................................................... 32

8.3.3 Control System and Umbilical ................................................................................................................................................................................................ 33

8.3.4 Wells ...................................................................................................................................................................................................................................... 33

8.3.5 Decommissioning of Existing Equipment ............................................................................................................................................................................... 34

9.0 OFFSHORE ENVIRONMENTAL DESCRIPTION ............................................................................................................................................................................ 35

INTRODUCTION ................................................................................................................................................................................................................................ 35

PHYSICAL ENVIRONMENT ................................................................................................................................................................................................................. 35

PLANKTON ...................................................................................................................................................................................................................................... 37

BENTHIC COMMUNITIES ................................................................................................................................................................................................................... 37

9.4.1 Fish Populations .................................................................................................................................................................................................................... 37

9.4.2 Seabird Populations ............................................................................................................................................................................................................... 38

9.4.3 Marine Mammals ................................................................................................................................................................................................................... 38

9.4.3.1 Cetaceans ................................................................................................................................................................................................................................................. 38

9.4.3.2 Pinnipeds ................................................................................................................................................................................................................................................... 38

9.4.4 Commercial Fisheries and Shipping ...................................................................................................................................................................................... 38

9.4.5 Conservation Designations .................................................................................................................................................................................................... 39

PROTECTED AREAS ......................................................................................................................................................................................................................... 39

SOCIO-ECONOMIC INTERESTS .......................................................................................................................................................................................................... 41

10.0 OFFSHORE ENVIRONMENTAL IMPACT ASSESSMENT............................................................................................................................................................. 42

INTRODUCTION ................................................................................................................................................................................................................................ 42

PHYSICAL PRESENCE ...................................................................................................................................................................................................................... 42

SEABED AND HABITAT DISTURBANCE ................................................................................................................................................................................................ 42

DISCHARGES TO SEA ....................................................................................................................................................................................................................... 43

UNDERWATER NOISE ....................................................................................................................................................................................................................... 43

ATMOSPHERIC EMISSIONS ............................................................................................................................................................................................................... 44

WASTE............................................................................................................................................................................................................................................ 44



ACCIDENTAL EVENTS ....................................................................................................................................................................................................................... 44

CUMULATIVE AND TRANSBOUNDARY EFFECTS .................................................................................................................................................................................. 44

DECOMMISSIONING AND PIPELINE RE-PURPOSING ......................................................................................................................................................................... 45

11.0 PERMITS AND CONSENTS ............................................................................................................................................................................................................ 46

ONSHORE CONSENTS REGISTER ...................................................................................................................................................................................................... 47

OFFSHORE CONSENTS REGISTER .................................................................................................................................................................................................... 49

12.0 CONSULTATION ............................................................................................................................................................................................................................. 59

INTRODUCTION ................................................................................................................................................................................................................................ 59

PREVIOUS AND ON-GOING CONSULTATION........................................................................................................................................................................................ 59

SUMMARY OF CONSULTEES ............................................................................................................................................................................................................. 59

13.0 CONTENTS OF THE ENVIRONMENTAL STATEMENT ................................................................................................................................................................ 61

14.0 CONCLUSIONS AND NEXT STEPS ............................................................................................................................................................................................... 64

CONCLUSIONS ................................................................................................................................................................................................................................. 64

NEXT STEPS ................................................................................................................................................................................................................................... 64

15.0 REFERENCES ................................................................................................................................................................................................................................. 65

16.0 ANNEX 1: CONSENT REGISTER ................................................................................................................................................................................................... 67



Figures

FIGURE 2-1: ACT ACORN CONSORTIUM PARTNERS .......................................................................................................................................................................................... 11

FIGURE 2-2: KEY AREAS OF INNOVATION ......................................................................................................................................................................................................... 12

FIGURE 2-3: ACT ACORN WORK BREAKDOWN STRUCTURE .............................................................................................................................................................................. 12

FIGURE 2-4: ACORN OUTLINE MINIMUM VIABLE DEVELOPMENT PLAN ............................................................................................................................................................... 14

FIGURE 2-5: ACORN BUILD OUT SCENARIO FROM THE 2017 PCI APPLICATION ................................................................................................................................................... 15

FIGURE 3-1: PROJECT SCHEDULE ................................................................................................................................................................................................................... 16

FIGURE 5-1: BLOCK FLOW DIAGRAM ................................................................................................................................................................................................................ 21

FIGURE 6-1: AERIAL PHOTOGRAPH OF THE ST FERGUS TERMINAL (TOTAL, 2009) ............................................................................................................................................. 22

FIGURE 6-2: ECOLOGICAL DESCRIPTION, (PEFROFAC ENGINEERING LIMITED, 2012) ......................................................................................................................................... 24

FIGURE 6-3: ECOLOGICAL DESIGNATINS, ADAPTED FROM (ERM, 2007) ............................................................................................................................................................ 25

FIGURE 7-1: APPROXIMATE BOUNDARIES OF THE FOUR OPERATIONS (ADAPTED FROM GOOGLE MAPS, 2017) .................................................................................................... 26

FIGURE 7-2: AVAILABLE LAND SOUTH OF THE NSMP PHASE 3 PLANT, (NSMP, 2017) ....................................................................................................................................... 27

FIGURE 8-1: PIPELINE ROUTE FOR ACORN CO2 STORAGE SITE (ATLANTIC PIPELINE IS SHOWN IN GREEN) ........................................................................................................... 31

FIGURE 8-2: INFIELD PIPELINE ROUTE FOR ACORN CO2 STORAGE SITE (NEW 16” PIPELINE SHOWN IN BLACK) ..................................................................................................... 32

FIGURE 9-1: HABITATS (CIRCLES REPRESENT PRE-DECOMMISSIONING ENVIRONMENTAL SURVEY STATIONS), (BG GROUP, 2016) ....................................................................... 36

FIGURE 9-2: SHIPPING DENSITY MAP, (BG GROUP, 2016) ................................................................................................................................................................................ 39

FIGURE 9-3: PROTECTED AREAS, (BG GROUP, 2016) ..................................................................................................................................................................................... 41

Tables

TABLE 2-1: ACT ACORN MILESTONES AND DELIVERABLES .............................................................................................................................................................................. 13

TABLE 8-1: UTM COORDINATES FOR ACORN CO2 STORAGE SITE MANIFOLD AND SUBSEA WELL ......................................................................................................................... 30

TABLE 11-1: ONSHORE CONSENTS REGISTER .................................................................................................................................................................................................. 48

TABLE 11-2: OFFSHORE CONSENTS REGISTER ............................................................................................................................................................................................... 58

TABLE 16-1: CONSENT REGISTER ................................................................................................................................................................................................................... 68

D14 Outline Environmental Impact Assessment Executive Summary


1.0 Executive Summary

With respect to an Environmental Impact Assessment (EIA), Pale Blue Dot view

the Acorn Project as a Schedule 2 project which may require an EIA.

Aberdeenshire Council’s provisional view is that, irrespective of being Schedule

1 or 2, the Acorn Project will need to complete an Environmental Impact

Assessment (EIA) and subsequent Environmental Statements which separately

cover onshore and offshore requirements.

A definitive view will be provided by Aberdeenshire Council upon submission of

an Environmental Scoping Report.

An Environmental Scoping Report would need to be submitted for review and

approval by Aberdeenshire Council between mid-2019 and mid-2020. If

confirmed as required, an EIA would then be completed in 2020/21 as part of

FEED.

As detailed within this report, the regulations, permits and consents influencing

the EIA are well understood as is the required contents and structure of the two

Environmental Statements.

The current assessment of both the onshore environmental impact and offshore

environmental impact indicates minimal impact beyond current activities.

The re-use of the Atlantic pipeline for the transportation of CO2 will result in a

lower environmental impact versus the need to install a new pipeline.

Beyond the main pipeline, the opportunity to re-use infrastructure is minimal.

This deliverable has established that an

Environmental Scoping Report will need to be

submitted to Aberdeenshire Council to confirm if the

Acorn Project is Schedule 1 or Schedule 2 under

the Building (Scotland) 2017 Regulation and if an

Environmental Impact Assessment (EIA) is required.

The provisional view from Aberdeenshire Council is

that an EIA will be required which will require the

EIA and respective Onshore Environmental

Statement and Offshore Environmental Statement

to be completed during the Front End Engineering

Design (FEED) stage of project development

The current assessment of both the onshore and

offshore environmental impact indicates minimal

environmental impact beyond current activities.

D14 Outline Environmental Impact Assessment Introduction to ACT Acorn


2.0 Introduction to ACT Acorn

ACT Acorn Overview

ACT Acorn, project 271500, has received funding from BEIS (UK), RCN (NO)

and RVO (NL), and is co-funded by the European Commission under the ERA-

Net instrument of the Horizon 2020 programme. ACT grant number 691712.

ACT Acorn is a collaborative project between seven organisations across

Europe being led by Pale Blue Dot Energy in the UK, as shown in Figure 2-1.

Figure 2-1: ACT Acorn consortium partners

The research and innovation study addresses all thematic areas of the ACT Call

including ‘Chain Integration’. The project includes a mix of both technical and

non-technical innovation activities as well as leading edge scientific research.

Together these will enable the development of the technical specification for an

ultra-low cost, integrated CCS hub that can be scaled up at marginal cost. It will

move the Acorn development opportunity from proof-of-concept (TRL3) to the

pre-FEED stage (TRL5/6) including iterative engagement with relevant investors

in the private and public sectors.

Specific objectives of the project are to:

1. Produce a costed technical development plan for a full chain CCS

hub that will capture CO2 emissions from the St Fergus Gas

Terminal in north east Scotland and store the CO2 at an offshore

storage site (to be selected) under the North Sea.

2. Identify technical options to increase the storage efficiency of the

selected storage site based on scientific evidence from

geomechanical experiments and dynamic CO2 flow modelling and

through this drive scientific advancement and innovation in these

areas.

3. Explore build-out options including interconnections to the nearby

Peterhead Port, other large sources of CO2 emissions in the UK

region and CO2 utilisation plants.

4. Identify other potential locations for CCS hubs around the North Sea

regions and develop policy recommendations to protect relevant



infrastructure from premature decommissioning and for the future

ownership of potential CO2 stores.

5. Engage with CCS and low carbon economy stakeholders in Europe

and worldwide to disseminate the lessons from the project and

encourage replication.

CCS is an emerging industry. Maturity improvements are required in the

application of technology, the commercial structure of projects, the scope of

each development and the policy framework.

The key areas of innovation in which the project will seek insights are

summarised in Figure 2-2.

Figure 2-2: Key areas of innovation

The project activity has been organised into 6 work packages as illustrated in

Figure 2-3. Specific areas being addressed include; regional CO2 emissions; St

Fergus capture plant concept; CO2 storage site assessments and development

plans; reservoir CO2 flow modelling, geomechanics; CCS policy development;

infrastructure re-use; lifecycle analysis; environmental impact; economic

modelling; FEED and development plans; and build out growth assessment.

The project will be delivered over a 19-month period, concluding on the 28th

February 2019. During that time, it will create and publish 21 items known as

Deliverables. Collectively these will provide a platform for industry, local

partnerships and government to move the project forward in subsequent phases.

It will be driven by business case logic and inform the development of UK and

European policy around infrastructure preservation. The deliverables are listed

in Table 2-1.

Figure 2-3: ACT Acorn work breakdown structure



Milestone Deliverable

1) St Fergus Hub Design

D01 Kick-off Meeting Report

D02 CO2 Supply Options

D17 Feeder 10 Business Case

2) Site Screening & Selection

D03 Basis of Design for St Fergus Facilities

D04 Site Screening Methodology

D05 Site Selection Report

D13 Plan and Budget for FEED

3) Expansion Options D18 Expansion Options

4) Full Chain Business Case

D10 Policy Options Report

D11 Infrastructure Reuse Report

D14 Outline Environmental Impact Assessment

D15 Economic Model and Documentation

D16 Full Chain Development Plan and Budget

5) Geomechanics D06 Geomechanics Report

D07 Acorn Storage Site Storage Development Plan and Budget

6) Storage Development Plans D08 East Mey Storage Site Storage Development Plan and Budget

D09 Eclipse Model Files

7) Lifecycle Assessment D12 Carbon Lifecycle Analysis

8) Project Completion

D21 Societal Acceptance Report

D19 Material for Knowledge Dissemination Events

D20 Publishable Final Summary Report

Table 2-1: ACT Acorn Milestones and Deliverables



The Consortium includes a mix of industrial, scientific and CCS policy experts in

keeping with the multidisciplinary nature of the project. The project is led by Pale

Blue Dot Energy along with University of Aberdeen, University of Edinburgh,

University of Liverpool, Heriot Watt University, Scottish Carbon Capture &

Storage (SCCS), Radboud University and The Bellona Foundation. Pale Blue

Dot Energy affiliate CO2DeepStore are providing certain input material.

Acorn Development Concept

Many CCS projects have been burdened with achieving “economies of scale”

immediately to be deemed cost effective. This inevitably increases the initial cost

hurdle to achieve a lower lifecycle unit cost (be that £/MWh or £/T) which raises

the bar from the perspectives of initial capital requirement and overall project

risk.

The Acorn development concept use a Minimum Viable Development (MVD)

approach. This takes the view of designing a full chain CCS development of

industrial scale (which minimises or eliminates the scale up risk) but at the

lowest capital cost possible, accepting that the unit cost for the initial project may

be high for the first small tranche of sequestered emissions.

Acorn will use the unique combination of legacy circumstances in North East

Scotland to engineer a minimum viable full chain carbon capture, transport and

offshore storage project to initiate CCS in the UK. The project is illustrated in

Figure 2-4 and seeks to re-purpose an existing gas sweetening plant (or build a

new capture facility if required) with existing offshore pipeline infrastructure

connected to a well understood offshore basin, rich in storage opportunities. All

the components are in place to create an industrial CCS development in North

East Scotland, leading to offshore CO2 storage by the early 2020s.

Figure 2-4: Acorn Outline Minimum Viable Development Plan



A successful project will provide the platform and improve confidence for further

low-cost growth and incremental development. This will accelerate CCS

deployment on a commercial basis and will provide a cost effective practical

stepping stone from which to grow a regional cluster and an international CO2

hub.

The seed infrastructure can be developed by adding additional CO2 capture

points such as from hydrogen manufacture for transport and heat, future CO2

shipping through Peterhead Port to and from Europe and connection to UK

national onshore transport infrastructure such as the Feeder 10 pipeline which

can bring additional CO2 from emissions sites in the industrial central belt of

Scotland including the proposed Caledonia Clean Energy Project, CCEP. A

build out scenario for Acorn used in the 2017 Projects of Common Interest (PCI)

application is included as Figure 2-5.

Pale Blue Dot Energy is exploring various ways and partners to develop the

Acorn project.

Figure 2-5: Acorn build out scenario from the 2017 PCI application

D14 Outline Environmental Impact Assessment Scope


3.0 Scope

Purpose

The purpose of the ACT Acorn Deliverable 14 (D14) Outline Environmental

Impact Assessment (EIA) is to provide a clear summary of the environmental

issues relating to the Acorn development scenario.

Scope

The scope of this deliverable is:

• Outline of development concept

• Assessment of the environmental impacts

• Summary of relevant permits and consents required

• Preliminary list of likely consultees

• Assembly of baseline information

This report draws heavily on a previous Carbon Capture and Storage (CCS)

study commissioned by CO2DeepStore, (Pefrofac Engineering Limited, 2012)

and the EIA completed by BG for the Atlantic and Cromarty Decommissioning

Programme, (BG Group, 2016).

Project Schedule

In respect to timing for this report, the current planned schedule for the Acorn

Project is for the project financial investment decision (FID) to be made in Q1

2020 with first injection at the start of 2023. Pre-FEED (Front End Engineering

Design) and FEED will need to be completed to enable FID. The EIA will be

completed as part of FEED, thus is likely to be developed and submitted for

review and approval by Aberdeenshire Council between mid-2019 and mid-

2020.

Figure 3-1: Project schedule

D14 Outline Environmental Impact Assessment Environmental Scoping Report


4.0 Environmental Scoping Report

An Environmental Impact Assessment (EIA) has been a legal requirement for

offshore developments since 1998. Current requirements are set out in the

Offshore Petroleum Production and Pipelines (Assessment of Environmental

Effects) (Amendment) Regulations 1999 (as amended 2007 and 2010),

hereafter referred to as the EIA Regulations. The purpose of the Regulations is

to require the Secretary of State for Business Energy and Industrial Strategy

(BEIS) to take into consideration environmental information before making

decisions on whether or not to consent certain offshore activities. As of 2010 the

EIA Regulations include CCS developments under the Energy Act 2008

(Consequential Modifications) (Offshore Environmental Protection) Order 2010.

Scoping Opinion

Screening is the determination of whether an EIA is needed and is a formal

requirement under the EIA Regulations. A formal Scoping Opinion can be

sought from the competent authorities concerning the need for an EIA. When a

competent authority receives an application for consent without an

accompanying Environmental Statement and there appears to be a possibility

that it is for a Schedule 1 or 2 development, the authority must adopt a Scoping

Opinion. Scoping is the process of determining the content and extent of matters

that should be covered in the environmental information to be submitted to a

competent authority. Good practice involves early consultation with statutory

consultees and other stakeholders. An Environmental Scoping Report enables

the competent authority to assess the project and provide a Scoping Opinion

summarising the specific advice the competent authority has concerning the

required coverage and content required for an Environmental Statement for an

application.

An Environmental Scoping Report would be submitted to Aberdeenshire Council

as the basis of a request for a formal Environmental Impact Assessment (EIA)

Scoping Opinion for the proposed Acorn development. This report forms the

basis of the Environmental Scoping Report. The scoping process allows

statutory consultees to comment on the proposed development, the scope of

the EIA and the proposed assessment methodology. It also provides an

opportunity for consultees to raise any issues that they consider may be

important to the EIA process providing direction on the topics on which the

Environmental Statement should focus. A scoping report aims to provide:

• A description of the proposed project

• A summary of the EIA process and approach

• Available environmental baseline information

• Identify any potential significant effects and those lesser effects that

may be able to be scoped out of the assessment

• Describe the proposed approach and methodologies to assess these

potential effects, and

• Propose the structure and content of the Environmental Statement

Aberdeenshire Council and other statutory consultees will be invited to provide

a formal scoping opinion on the proposed Acorn development and identify any

other relevant environmental information relating to the site and surrounding

area. The scoping opinion will be used to inform the EIA in addition to

consultation to be undertaken during the EIA process. The local planning

D14 Outline Environmental Impact Assessment Environmental Scoping Report


authority will determine whether the project is of a type listed in Schedule 1 or

Schedule 2 of the Building (Scotland) 2017 Regulations:

• If it is listed in Schedule 1 an Environmental Impact Assessment is

required in every case

• If the project is listed in Schedule 2, the local planning authority

should consider whether it is likely to have significant effects on the

environment

Schedule 1 projects include:

Installations for the capture of carbon dioxide streams for the purposes of

geological storage pursuant to Directive 2009/31/EC from installations referred

to in this Schedule, or where the total yearly capture of carbon dioxide is 1.5

megatonnes or more.

Schedule 2 projects include:

“(j) Installations for the capture of carbon dioxide streams for the purposes of

geological storage pursuant to Directive 2009/31/EC from installations not

included in Schedule 1.”

Acorn is therefore currently a Schedule 2 project. To confirm this a Scoping

Opinion question must be formally asked.

Scoping Opinion Question

With regards to the Acorn project and the planned modifications to the St Fergus

plant and associated offshore infrastructure, initial meetings have taken place

with Aberdeenshire Council (Buchan Area) to discuss requirements for

completing an EIA to support the planning application. Aberdeenshire Council

have confirmed that it is probable that an EIA will be required. To confirm this a

formal approach is required to extract a Scoping Opinion:

• Will the Acorn development require an EIA under the

Environmental Impact Assessment (Scotland) Regulation

2011?

A formal scoping report will be prepared to determine the EIA requirements for

the Acorn scope of work at St Fergus. An Environmental Scoping Report will be

issued by the end of 2018, and Scoping Opinion sought over Q1 2019.

Layout of the Environmental Scoping Report

The scoping report has been structured as follows:

• Section 5: Project Description

• Section 6: Onshore Environmental Description

• Section 7: Onshore Environmental Impact Assessment

• Section 8: Detailed Offshore Description

• Section 9: Offshore Environmental Description

• Section 10: Offshore Environmental Impact Assessment

• Section 11: Permits and Consents

• Section 12: Consultation

• Section 13: Contents of the Environmental Statement

For now, it is still assumed that a full EIA and associated Environmental

Statement will be required within FEED to support the Planning Application and

so the contents of the Environmental Statement have been outlined.

.

http://www.legislation.gov.uk/european/directive/2009/0031

D14 Outline Environmental Impact Assessment Project Description


5.0 Project Description

Onshore Facilities

An existing gas sweetening plant has been separating CO2 from natural gas at

the St Fergus SAGE terminal for 20 years. Within the next few years it will no

longer be required for this purpose and could become available for separating

CO2 from flue gas. The potential for re-using the SAGE CO2 plant and, as an

alternative, the option of a new build capture facility is under consideration.

At this stage both capture options appear viable, although without detailed

information on the condition of the SAGE plant and further design studies, it is

not possible to be certain about the viability of the SAGE plant re-use. Additional

work is required especially regarding plant condition, throughput

capacity/constraints and the cost of re-purposing the facility.

Space exists to build a standalone capture plant, which would have the

advantage of being purpose built, new and in a location to optimise collection of

CO2 emissions from multiple sites.

More detailed technical engineering studies are required to assess the two

capture alternatives, which along with other commercial, risk and regulatory

factors, will enable an effective option selection prior to Front End Engineering

and Design (FEED).

Offshore Facilities

Currently there is the option to re-use one or more of three existing preserved

offshore pipelines connected to St Fergus for CO2 transportation. Several

appraised offshore CO2 stores can also be considered. The ACT Acorn project

reviews both the Captain and East Mey sandstone formations as potential

storage locations.

For the purpose of the EIA, the current base case for Acorn is to use a location

called the Acorn CO2 storage site, (yellow pin in Figure 8-1), which would be

accessed via repurposing the existing 16” Atlantic pipeline from St Fergus to the

Atlantic depleted condensate field. The Acorn CO2 storage site will be developed

subsea rather than using a platform, with an umbilical to shore as the base case

for providing power and control to the wellheads. Remote technology options

are currently being explored, which would eliminate the need for an umbilical to

shore.

Design Basis

The design basis draws heavily on previous conceptual studies commissioned

by CO2DeepStore, (Pefrofac Engineering Limited, 2012).

5.3.1 Existing CO2 Capture Plant

One of the two amine gas sweetening trains within the SAGE plant is being

decommissioned. The condition of the plant and whether it has been preserved

to allow future reinstatement is unknown. It is understood that the second train

will also be decommissioned over the next few years. Pale Blue Dot Energy will

continue to engage with the present terminal owners to determine the present

condition of the unit and identify any corrosion issues and missing piping,

equipment and instrumentation which may have been used as spares for the

operating unit.



The current assumption is that the existing operating SAGE gas sweetening

amine train will be suitable for re-purposing to capture CO2 from flue gas.

5.3.2 New CO2 Capture Plant

It is more likely that a new CO2 capture plant is required to accommodate the

volumes of CO2 for which a new amine (or similar) solvent capture system is

assumed. Key elements of a solvent capture system are:

• Flue gas cooling and compression (blowers)

• Waste heat recovery

• CO2 absorption

• Solvent regeneration unit

• Solvent storage and make-up

• Compression

• Dehydration

• Metering and monitoring the exported CO2

Upstream of the CO2 capture process, there is a need to cool and boost the

pressure of the flue gas stream. As far as practical, waste heat can be recovered

from the flue gas for use in the CO2 capture process to increase overall energy

efficiency and reduce CO2 emissions associated with solvent regeneration.

5.3.3 Compression and Dehydration

The CO2 from the capture plant will be water saturated and at around

atmospheric pressure. Prior to transport through the offshore pipeline for

geological storage the CO2 must be dehydrated and compressed to sufficient

pressure for transportation offshore in dense phase. A CO2 specification will also

be finalised which will include almost zero water content to ensure no free water

forms in pipeline or wells and that the system operates outside of the hydrate

region. Typically, dehydration is achieved by either glycol or molecular sieve.

Options for CO2 compression include centrifugal, reciprocating and integrally

geared. Drivers are likely to be electric with the requirement for high efficiency

variable speed drives to be considered. The export pressure of the CO2 is

assumed to be between 120-160barg.

5.3.4 Material Selection

Due to the potential for corrosion in the presence of amine solvents, CO2,

oxygen and any other degradation products, at this stage stainless steel is

assumed for the majority of the equipment and piping. The solvent storage tank

is assumed to be of clad carbon steel construction.

5.3.5 Utilities

The following site utilities are assumed to be required and will be available or

will be installed as part of the project:

• Electricity

• Hot oil system or steam system Cooling water

• Nitrogen

• Instrument air

• Drains

5.3.6 Offshore

The base case development plan is for CO2 transportation via existing and new

pipelines with subsea injection via one well into the Captain Fairway in the

vicinity of the Atlantic depleted gas condensate field.



Block Flow Diagram

Figure 5-1: Block flow diagram

D14 Outline Environmental Impact Assessment Onshore Environmental Description


6.0 Onshore Environmental Description

Landscape and Topography

The landscape surrounding the St Fergus Gas Terminal, Figure 6-1, is typical of

the northeast Scotland coast. A shore margin of sandy beach is backed by

dunes, behind which lies flat grassland rising into low hills. The St Fergus Gas

Terminal is located on a plateau 400m west of the coastline. Pipeline landfalls

and corridors pass through the beach and dune systems to the terminal facilities.

The western and southern sides of the wider St Fergus Gas Terminal have been

landscaped to reduce the visual impact of the site and shelter belts of deciduous

native trees have been planted.

Figure 6-1: Aerial photograph of the St Fergus Terminal (Total, 2009)

Within 2km of the St Fergus Gas Terminal, the landscape consists of two

distinctive natural landform sequences:

• A coastal zone: consisting of the nearshore, beach and dune

complex

• A landwards plateau: this surface slopes westwards (i.e. landwards)

and southwards towards the catchment of the Blackwater and

Annachie Burns

These two landform sequences are separated by a steep, seaward facing

escarpment, termed the inner escarpment, which marks the location of the

former cliff line and represents the boundary between the differing surface

geology and hydrology in this area.

The Acorn capture facility will be located entirely within the St Fergus Gas

Terminal on the plateau. The pipeline landfalls and corridors associated with the

existing SAGE plant pass through the beach and dune systems to the terminal

facilities.

Site Description and Existing Landscape

Character

The area is characterised by its open and exposed nature. There is little

vegetation other than planted shelter belts of trees, and screen planting around

the existing terminal.

The terminal itself comprises numerous large-scale structures, pipes and towers,

set with gravel and concrete roads, with a low existing landscape value and few

landscape resources of note.



Visual Receptors

The area is sparsely settled with a few small villages (St Fergus, Kirktow,

Inverugie, Crimond) all over 1km from the proposed development, scattered

farms and hamlets connected by rural roads.

There are views of the gas terminal from scattered recreational resources, such

as the Loch of Strathbeg Local Nature Reserve to the north, and St Fergus Links

picnic area and car park to the south. However, it is unlikely that the existing St

Fergus SAGE plant will be visible from the north.

Geology

The St Fergus terminal is situated on wind-blown sand overlying silts and clays

of approximately 10m thickness. Below these sediments, there are 2m to 3m of

glacial till which cover a 2m layer of pink granite bedrock which extends below

sea level.

Hydrology

The most significant water courses within 2km of the St Fergus terminal are:

• Blackwater Burn and its tributary

• Annachie Lagoon, at the mouth of the Blackwater Burn

• Winter Loch

Natural surface water drainage is away from the coast towards the Blackwater

stream in the north and the Annochie Burn in the south, both of which combine

near the coast to flow into a tidal lagoon. As all the gas receiving terminals are

sited on the plateau described above, site water drainage is also directed

landwards, downslope, to the Blackwater stream.

Designations

There are no Sites of Specific Scientific Interest (SSSIs), Special Protection

Areas (SPAs) or Ramsar (UNESCO Convention on Wetlands) sites within a 2km

radius of the St Fergus gas terminal (Figure 6-3), but there is a Site of Interest

to Natural Science (SINS) adjacent to the site along the coast. This area

includes the St Fergus Dunes and Winter Loch and is located outside the

perimeter fence of the St Fergus terminal. This SINS has been designated for

its botanical, entomological and ornithological interest. The Rattray to Kirkton

Head SINS is an Aberdeenshire Council local designation. The SINS is

protected through the Aberdeenshire Local Plan, (Aberdeenshire Council, 2017),

which states:

• Development will not be allowed if it fragments habitats or is not

designed to minimise any adverse impact on the sites environmental

quality, ecological status or viability.



Figure 6-2: Ecological description, (Pefrofac Engineering Limited, 2012)



Figure 6-3: Ecological designatins, adapted from (ERM, 2007)

(Note: In Figure 6-3, the circle designates the 2km buffer, the hashed area

designates the Rattray to Kirkton Head SINS and the magenta lines designate

the area of local landscape value.

D14 Outline Environmental Impact Assessment Onshore Environmental Impact Assessment


7.0 Onshore Environmental Impact Assessment

The environmental issues that are likely to arise from the installation and

operation of the Acorn Project CO2 capture and compression equipment are

very limited for the following reasons:

• There will be no continuous atmospheric emissions

• There will be no continuous aqueous emissions or discharges

• There will be no change to the surface water drainage regime

currently in place at the St Fergus terminal

• The new Acorn infrastructure will be small within the gas terminal

with little visible impact

• There are no international or national ecological designations within

2km of the site

• The nearest noise sensitive receptors are approximately 1km

beyond the site boundary

• The Acorn infrastructure will be located entirely within an existing

industrial setting of the St Fergus Gas Terminal

Potential Locations for a New Build Capture

Plant

The ACT Acorn project seeks to evaluate the repurposing of the existing SAGE

gas sweetening facility for CO2 capture whilst also assessing the option for a

new build capture plant. As shown in Figure 7-1 the Shell plant is located

between the SAGE facility (Ancala) and the North Sea Midstream Partners

(NSMP) complex, thus geographically ideally suited as the focal point for a flue

gas gathering network to either head north to SAGE or south to a new build

capture plant.

Figure 7-1: Approximate boundaries of the four operations (adapted from Google Maps, 2017)



NSMP have space within their fence line and potential for an “emissions

gathering network” that supplies a capture plant within their boundary.

Wayleaves exist which enable all three gas processing operators to run

pipelines etc. across all three complexes. More than sufficient land area can be

made available within the NSMP footprint for a new build capture plant including:

• A large rectangle of land just south of the Shell boundary fence

• A large rectangle of land just south of the NSMP Phase 3 plant,

Figure 7-2

• The decommissioned and cleared Miller processing areas where

concrete ground structures are retained

Figure 7-2: Available land south of the NSMP Phase 3 plant, (NSMP, 2017)

Potential impacts

This section provides an overview of the environmental issues relating to the

installation of the new infrastructure.

7.2.1 Ecology Rattray to Kirkton Head SINS

There will be no physical effects.

7.2.2 Water Resources River Blackwater

Operation

There are no continuous aqueous emissions from the plant that could have an

effect on the water environment. The drainage arrangements at the site will

remain as they currently are.

7.2.3 Visual Impacts

Residential

The St Fergus gas terminal is located in North East Scotland in a sparsely

populated area. NSMP are very keen for any development to occur within their

boundary, Figure 7-1. There is a big green space between the Shell Terminal

and NSMP’s Phase 2 operation, Figure 7-2. If any new capture plant is needed,

SMR etc. then this would be the logical location. A rectangular green space

adjacent to the south side of Phase 3 is the preferred location and the old Miller

Phase 1 processing area also offers a location. The latter has all been removed

bar the control room building, concrete foundations and the capped ends of the

two pipelines. The new plant and equipment will have a similar profile to the

existing gas processing towers and will be screened from the north and west by

the existing St Fergus Gas Terminal infrastructure and shelter belts of deciduous

native trees.

If the space between Phase 2 and Shell is the selected location, then there will

be limited visibility from the North and West and the view profile from the South

profile should be no different to what is already in place. However, if the space



south of Phase 3 or the old Miller location is used then this will not be correct.

The profile at Miller will have a visual impact from St Fergus village and the south

but likely to be no different from the Miller profile that previously existed. If the

rectangle adjacent to the south side of Phase 3 is used, the profile will match /

blend into the NSMP facilities behind.

Amenity areas

The new plant and equipment will be visible from the sand dunes and will present

a profile similar to that of the former MRF infrastructure.

The site is within an existing developed industrial complex and will not be out of

character with the rest of this industrial facility. As a result, the scattered villages,

isolated farms and hamlets are unlikely to be affected by changes in their views.

The residents in these areas and the people who travel through them, or spend

time participating in recreational activities at nearby locations do already have

views of the existing St Fergus Gas Terminal.

7.2.4 Traffic and Transport

The roads around the terminal are generally quiet.

Construction

A traffic management plan will be developed in conjunction with the local police

force to ensure minimal disruption from any extra construction traffic.

Operation

Operational traffic is not expected to be greater than existing vehicle movements

at the site. Exact requirements will be determined during FEED.

7.2.5 Air Quality

Operation

This project will remove a current venting stream by capturing the CO2 for

storage. There are no plans for continuous venting. There are no continuous

atmospheric emissions from the plant that could impact receptors.

At the Front End Engineering Design (FEED) stage of the Acorn Project, the

modelling of the emergency venting of CO2 will be completed to demonstrate

that there will be no serious threat to onsite personnel from ground level

concentrations of CO2.

7.2.6 Noise and Vibration

Construction

The concrete piling for the Miller facility at St Fergus all remains in place and

could be built upon to minimise noise and vibration impact.

A new pipeline is not anticipated. A new umbilical is planned to supply a power

and control line from onshore to the planned new offshore subsea installation

for which beach crossings as per for previous pipelines have required only

conventional trenching and ground restoration techniques.

Operation

Based on the current basis of design, there are no expected sources of noise

that would impact on receptors.

7.2.7 Ecology

Figure 6-3 shows the location of the key environmental designations within 2km

of the St Fergus site. The site sits within a locally designated Area of Landscape



Significance, which will be affected. It is, however, already within an existing

industrial complex. Similarly, it is adjacent to a stretch of coast designated as

Undeveloped Coast, but the coast adjacent to the site is affected by the existing

facility.

After previous pipeline trenching, in general, one or two annual cycles were

required for restoration to reach an acceptable varied ecological status but

between five and ten years are needed before the landfall and pipe‐trench are

more or less indistinguishable from contiguous areas.

D14 Outline Environmental Impact Assessment Offshore Description


8.0 Offshore Description

This section of the scoping report provides an overview of the base case for the

offshore design of the Acorn project.

The current base case for the Acorn CO2 storage development consists of

utilising the existing 18”/16” Atlantic and Cromarty (Atlantic & Cromarty) pipeline

from St Fergus to Atlantic, (via an acquisition from BG International, now Shell).

A new 8km 16” pipeline will be laid between Atlantic and the injection site located

above the Captain aquifer, approximately midway between the Atlantic and

Cromarty developments. The new 16” pipeline will be surface laid (laid on the

seabed) and stabilised/protected with concrete weight coating.

The Acorn CO2 storage site development will take the form of a seabed manifold

and injection well. The manifold will be piled to the seabed and will incorporate

a fishing friendly protection structure. It is anticipated that dense phase CO2 will

be injected into the Captain aquifer via one subsea well over the 20-year design

life.

The well will be controlled from shore via an umbilical run directly to the Acorn

CO2 storage site injection well location.

Location

The optimum platform location for the Acorn CO2 storage site manifold and well

has been determined through geomechanical studies and is approximately 8km

north west of the Atlantic manifold location. UTM coordinates are presented in

the table below.

Subsea Development UTM coordinates

Eastings (m) Northings (m)

Acorn CO2 storage site Well and Manifold

6,440,500 263,000

Table 8-1: UTM coordinates for Acorn CO2 storage site manifold and subsea well

Transport

8.2.1 Facilities Re-use Versus New Infrastructure

There is a 12km 12” export pipeline from Cromarty to Atlantic that passes in the

vicinity of the Acorn CO2 storage site injection location, however it has been

assumed that a new pipeline section from the end of the Atlantic pipeline to the

injection manifold will be required for the following reasons:

• Smaller diameter/reduced ullage (12” versus 16”)

• The 12” Cromarty pipeline was specified for a design life of 10 years

(2016) whilst the 16” Atlantic pipeline was specified for a design life

of 20 years (2026). Extending the design life until 2056 years may

not be feasible

• Trenched and buried therefore it would require excavation and

cutting at the manifold location to facilitate tie-in

• It will not be possible to inspect the line via intelligent pig due to large

internal diameter changes (18”/16”/12”)

Consideration was initially also given to utilising the existing 20” Goldeneye

pipeline. The Goldeneye field is located approximately 100km north east of

Aberdeen, and approximately 30km west of the existing Atlantic facilities. The



selected location for the Acorn CO2 storage site injection well is approximately

8km west of the Atlantic development and as such the existing Atlantic pipeline

is the preferred choice, (8km new pipeline versus a 38km new pipeline),

provided its integrity can be confirmed. Furthermore, the original design

pressure of the 20” Goldeneye pipeline is 132barg, which would likely lead to

operability issues given the required tubing head pressures for CO2 injection in

the Captain aquifer. The Goldeneye pipeline has therefore not been considered

further at this stage.

The existing 16” Atlantic & Cromarty pipeline connected between the St Fergus

terminal to the Atlantic manifold is proposed to be reused. The Atlantic and

Cromarty development was commissioned in 2006. The 16” pipeline was

specified for a 20 year design life based on transporting hydrocarbons (and

water) at relatively high pressure, however production ceased in 2009 (after less

than 4 years) and formal Cessation of Production (CoP) was granted by the

Department of Energy and Climate Change (DECC) in 2011. In 2012 the

pipeline was filled with a mixture of produced water, MEG (mono ethylene glycol),

corrosion inhibitor and hydrocarbons, before the pipeline was cleaned and

rendered hydrocarbon free.

The UK Government Department of Business Energy and Industrial Strategy

(BEIS) decommissioning website, (UK Government, 2018), has a copy of the

decommissioning programme that was submitted in 2016. Since this submission

Shell acquired BG and Shell have since indicated that they plan to resubmit the

decommissioning programme for Atlantic and Cromarty.

Adoption of the pipeline following decommissioning may still be possible.

However, the pipeline integrity may be compromised and would require

extensive inspection, reconnection and testing thus leading to the high likelihood

of re-use becoming commercially unfeasible.

Figure 8-1: Pipeline route for Acorn CO2 storage site (Atlantic pipeline is shown in green)

Commercial considerations and decisions will not be discussed in this report but

will be informed by any environmental effects influencing the decision to re-use

or re-lay pipework. It is worth noting that any acquisition will also take on liability

for decommissioning some, or all, of the remaining Atlantic and Cromarty

transportation facilities.



A full pipeline integrity and life extension study will be required to confirm

suitability. This will involve detailed internal and external inspection to requalify

the pipeline and verify that it is suitable for re-use to transport CO2 for up to 20

years. Requalification shall comply with the same requirements as for a pipeline

designed specifically for transportation of CO2. This work will be carried out as

part of FEED.

8.2.2 New 16” Infield Pipeline to the Acorn CO2 storage site

Manifold

A new 16” pipeline will be required to connect the existing 18”/16” Atlantic-

Cromarty pipeline to the Acorn CO2 storage site termination skid, via tie-in

spools. This infield pipeline is shown in Figure 8-2. The 8km 16” pipeline route

has been selected to minimise route length while avoiding existing facilities.

There are two pipeline crossings, where it crosses the existing Cromarty pipeline

and umbilical.

Figure 8-2: Infield pipeline route for Acorn CO2 storage site (new 16” pipeline shown in black)

A full study will be required to confirm the pipeline route and ensure that all

seabed obstructions (wells, platforms, pipelines, umbilicals, cables etc.) and

seabed features (rocks, sandwaves, pockmarks, mud slides, etc.) are identified

and accounted for appropriately.

Approach for Offshore Facilities

8.3.1 Pipeline

The existing 16” pipeline from Atlantic to St Fergus is believed to be capable of

being used in reverse flow at an operating pressure of up to 170barg. The

landfall comprises 1.2km of 18” pipeline (17.5mm wall thickness).

Running parallel to the 16” pipeline is a 4” MEG pipeline. This line can be tied

into the new system and can be used to depressurise the 16” line from the

Atlantic end should the facility ever be required, for example, to help clear a

hydrate blockage. It is not considered necessary to internally inspect this

(smaller) line. External inspection of the 4” line will be completed by ROV at the

same time as the 16” line is inspected. The pipeline will require an external and

internal inspection prior to the final investment decision.

8.3.2 Subsea

The existing production manifold, jumpers and wells are considered unsuitable

for reuse for CO2 injection. A new injection distribution manifold will be installed

at the Acorn CO2 Storage Site. A new 16” pipeline will be installed from the end

of the 16” Atlantic pipeline to the new manifold. The existing 16” and 4” rigid

spools at Atlantic connecting the two pipelines to the Atlantic manifold will be

removed and two new flexible spools will reconnect the 16” and 4” lines to the

new pipeline. These will be protected by mattresses.



The 4” line will be connected to the injection manifold through a remotely

operated block valve and choke. This will enable the manifold and 16” line to be

depressurised back to St Fergus should a hydrate blockage occur.

The subsea configuration proposed for the Acorn project is based on a long

distance tie-back from the gas capture facility to the injection reservoir and is

similar to Statoil’s Snøhvit CO2 project in the Barents Sea. The key input

parameters used to size and cost the installation for the Acorn CO2 storage site

are listed below.

Subsea well and manifold:

• 115m water depth

• 20-year design life

Manifold:

• Pig receiver or tie-in point for a temporary pig receiver

• Filter (optional)

• Subsea umbilical termination unit (SUTU)

• Pipeline monitoring

• Fishing friendly protection structure

To ensure a robust system design given the early level of engineering definition

and to maximise overall system availability, a modular approach is

recommended with the manifold being designed to allow additional wells to be

connected via a daisy chain arrangement.

8.3.3 Control System and Umbilical

The subsea power and control system is assumed to be an electrohydraulic

design. The base case is for an 80km umbilical with high and medium pressure

hydraulics and communications between the onshore control room and the

injection manifold. Control of the injection tree will be via the subsea control

modules (SCMs) located on the injection tree.

8.3.4 Wells

The Captain sands are very permeable and the injectivity potential is high. The

key design criteria for the injection wells is that they must be capable of injecting

between 0.1 and 2MT/yr CO2 in liquid phase throughout the project life and

require minimal intervention during that time.

A single injection well is envisaged, but this may change as the development

expands in the future.

The manifold will be connected to the well by a 6” flexible jumper and a

control/instrumentation flying lead.

The key elements of the well design assumptions are summarised as follows:

1. Reservoir 1500-2005m (tvdss)

2. Water depth 115m

3. Well deviated at 60o in the target formation

4. The wells will consist of 95/8’’ production casing with 5½” stand

alone sand screens.

5. The well will be completed with a upper dual completion with 27/8’’

and 41/2’’ tubing string

6. All flow wetted surfaces will be 13% chrome material

7. Maximum injection rates will be 2MT/yr

8. Minimum FTHP will be 44.5barg

9. Maximum FTHP will be 160barg or pipeline limit, if lower

10. Maximum WHT will be 6°C during injection



8.3.5 Decommissioning of Existing Equipment

Before the new infrastructure associated with CO2 disposal is installed and

commissioned, existing equipment that is now redundant must be removed. It is

assumed that this work will be completed by the current Operator.

D14 Outline Environmental Impact Assessment Offshore Environmental Description


9.0 Offshore Environmental Description

Introduction

The key environmental sensitivities in the area are described in the Atlantic and

Cromarty Decommissioning EIA (2016), (BG Group, 2016). The following

provides a summary of that information. A full updated environmental description

will be provided in the Acorn Project Environmental Statement.

A pre-decommissioning environmental survey carried out in August 2015 found

the environment at the Atlantic and Cromarty (Atlantic & Cromarty) fields to be

typical of much of the Central North Sea. The water depth at Atlantic is 114m

and at Cromarty 113m. The maximum tidal flow is 0.51m/s, with residual

currents moving to the southeast. Sea surface temperatures range from 8.5°C

in the winter to 15°C in the summer. At the seabed, temperatures range between

8°C and 9°C. The seabed between the Cromarty field and the Goldeneye

platform primarily comprises muddy sand with shell fragments that is typical for

the ‘circalittoral muddy sand’ habitat widespread in the Central North Sea at

water depths above 100m. The benthos, fish, marine mammals and seabirds

associated with the area are typical of the Central North Sea and occur over the

wider North Sea region.

The seabed in the shallower part of the Atlantic & Cromarty export pipeline route,

up to approximately 45km from shore, comprises a ‘circalittoral mixed sediment’

habitat, in which sandy areas occur that exhibit low biodiversity, and areas

where shell material, gravel, pebbles, cobbles and boulders occur that exhibit

relatively high biodiversity. The mixed stable sediment in the latter supports the

tube worm sabellaria spinulosa at the extreme of its geographic range and depth

tolerance. This species can form biogenic reefs, but a habitat assessment

concluded that the sabellaria spinulosa accumulations along the pipeline route

do not form a contiguous reef.

The Atlantic & Cromarty pipeline passes through an area that is being

considered for designation as a possible Marine Protected Area (MPA), the

Southern Trench MPA proposal. The Atlantic & Cromarty pipeline is 30km from

the biodiversity and seabed geological features for which the site may be

designated in the future, but it passes through an area where the thermal

characteristics are associated with nursery grounds for fish.

Commercial users of the area are mainly associated with the oil and gas industry,

shipping and fishing.

Physical Environment

The pre-decommissioning environmental survey of the Atlantic & Cromarty

fields and the pipeline routes, (Fugro, 2015), distinguished three biotopes (or

biotope complexes) as defined by the European Nature Information System:

• The ‘circalittoral muddy sand’ biotope complex (EUNIS type A5.26)

was found at all the survey stations beyond 45km from the shore.

This is typical for the seabed with over 90m water depth and is a

widespread habitat in the Central North Sea.

• The ‘circalittoral mixed sediments’ biotope complex (EUNIS type

A5.44) was found at survey stations up to 45km from the shore (see

Figure 9-1. The seabed in these areas comprises quantities of shell

material, gravel, pebbles, cobbles and in some places areas of

numerous boulders. In the first 16km from shore, the sediments are



Figure 9-1: Habitats (circles represent pre-decommissioning environmental survey stations), (BG Group, 2016)



predominantly cobbles and boulders with gravel and sand. Beyond

16km from the shore sand predominates with some pebbles and

cobbles.

• Patches of a biotope ‘sabellaria spinulosa on stable circalittoral

mixed sediment’ (EUNIS type A5.611) 3-16km from the shore.

The seabed in the 500m exclusion zones at Atlantic and Cromarty consists of

muddy sand with shell fragments, typical of the widespread ‘circalittoral muddy

sand’ habitat. Genesis observed that the seabed at Goldeneye comprises silt

sediment over very soft, silty/sandy clay and soft to firm clay, (Genesis, 2002).

Fugro, (Fugro, 2015) examined three camera transects in the ‘circalittoral mixed

sediments’ and ‘sabellaria spinulosa on stable circalittoral mixed sediment’

habitats. Two of the transects coincide with the section of the pipeline route

between 6.4 and 8.9km from the shore, where the pipe was laid on the surface.

The combination of indicators including elevation, the presence of cobbles and

visible biota, allowed patches with moderate potential as stony reef to be

identified. Review of transect data suggested that sabellaria spinulosa

aggregations are likely to occur throughout the ‘circalittoral mixed sediment’

biotope complex, but assessment against indicators for elevation, area and

patchiness concluded that that the aggregations in the nearshore pipeline area

do not form a contiguous sabellaria spinulosa reef.

Plankton

The project area currently has the common North Sea phytoplankton species,

dominated by the dinoflagellate ceratium and the diatom skeletonema.

Water currents cause continual movement of individuals through the area (North

Sea Task Force (NSTF), 1993) and the rapid maximum doubling times of the

phytoplankton cause blooms to occur in the North Sea each spring with a

smaller peak in the autumn. The timing and species composition of these

blooms can be variable, (Bresnan, 2009).

Throughout the North Sea, the previously dominant population of cold water

zooplankton species (e.g. calanus finmarchicus) have declined in biomass by

70% since the 1960s, and species with warmer-water affinities (e.g. calanus

helgolandicus) have been moving northward (Edwards, 2013).

Benthic Communities

The pre-decommissioning environmental survey of the Atlantic & Cromarty

fields found to constitute a tiny part of habitats that are widespread throughout

the Central North Sea. It supports species that are found throughout the region.

9.4.1 Fish Populations

More than 330 fish species are thought to inhabit the shelf seas of the UKCS

(Pinnegar et al., 2010).

• Pelagic species (e.g. herring (clupea clupea), mackerel (scomber

scombrus), blue whiting (micromesistius poutassou) and sprat

(sprattus sprattus) are found in mid-water and typically make

extensive seasonal movements or migrations.

• Demersal species (e.g. cod (gadus morhua), haddock

(melanogrammus aeglefinus), sandeels (ammodytes sp.), sole

(solea solea) and whiting (merlangius merlangus) live on or near the

seabed. Many demersal species also migrate between areas during

their lifecycles.



9.4.2 Seabird Populations

The large seabird colonies on the coast of Aberdeenshire support important

populations of:

• Gulls including herring gull (larus argentatus), kittiwake (rissa

tridactyla), gannet (morus bassanus), fulmar (fulmarus glacialis),

• Auks including guillemot (uria aalge), razorbill (alca torda) and puffin

(fratercula arctica).

• Shags (phalacrocorax aristotelis),

The birds forage at sea for fish and occur throughout the Atlantic & Cromarty

project area of influence. Some species depend on particular fish species, for

example puffin breeding success is closely associated with the availability of

sand eels. Seabirds in nearshore areas spend much of their time in the water

and are vulnerable to pollution throughout most of the year. Species such as

fulmar spend more time on the sea surface, than herring gull, great black-backed

gull (larus marinus) and kittiwake and are consequently more vulnerable to

pollution, (Stone, et al., 1995).

After the breeding season ends in June, auks disperse into offshore waters

including the Atlantic & Cromarty decommissioning project area of interest. The

auks spend much of their time on the surface of the water and raft in large

numbers to moult, at which time they are flightless. Any auks at the Atlantic &

Cromarty Fields are therefore particularly vulnerable to surface pollutants

between July and September.

The Joint Nature Conservation Committee’s (JNCC) Offshore Vulnerability

Index maps monthly seabird vulnerability to surface pollution taking account of

seasonal changes in the species and number of birds present in each UKCS

offshore block.

9.4.3 Marine Mammals

9.4.3.1 Cetaceans

The cetacean species that are most likely to be observed at the Atlantic Fields

are Atlantic white-sided dolphin, harbour porpoise, bottlenose dolphin, white-

beaked dolphin and minke whale (Reid, 2003). These same species are also

the most regularly sighted cetacean species throughout the North Sea. Risso’s

dolphin and large baleen whales are also occasionally sighted.

9.4.3.2 Pinnipeds

Large populations of grey seal (halichoerus grypus) occur along the east coast

of Scotland. Tracking of individual grey seals has shown that they can feed up

to several hundred kilometres offshore although most foraging tends to be within

approximately 100km of the coast (Sparling, 2012), (Thompson, 2010). Mapping

completed indicates the Atlantic & Cromarty export pipeline passes through an

area where grey seals are present at medium densities, whereas the density is

low at the Atlantic & Cromarty Fields, (BG Group, 2016).

The foraging range of the harbour seal (phoca vitulina) (also known as common

seal) is typically 40-50km from their haul-out site. Results from telemetry data

indicate that harbour seals are unlikely to occur in the project area of interest,

(BG Group, 2016).

9.4.4 Commercial Fisheries and Shipping

There is a concentration of coastal shipping on routes rounding Rattray Head a

few kilometres north of St Fergus. The vessels entering or leaving the Moray

Firth typically pass by several kilometres out to sea. Commercial shipping traffic



is less dense on routes from the UK to continental ports or to supply offshore oil

and gas operations.

DECC categorised the coastal shipping activities in the UKCS block off Rattray

Head as having a high density, Figure 9-2. The average effort by UK fishing

vessels in the ICES rectangles encompassing the Atlantic & Cromarty

decommissioning project between 2010 and 2014 was 956 vessel days per year,

(BG Group, 2016).

Figure 9-2: Shipping density map, (BG Group, 2016)

9.4.5 Conservation Designations

The Scottish Government designates Nature Conservation Marine Protected

Areas (MPA) under the Marine (Scotland) Act. Marine Scotland, Scottish Natural

Heritage, the Joint Nature Conservation Committee and other organisations put

forward MPA proposals for designation. The nearest designated MPA to the

Atlantic & Cromarty project area of interest is the Turbot Bank, located

approximately 66km south of the Fields. However, the Atlantic & Cromarty

export pipeline passes through the boundaries of an area that has been

identified for possible future designation as an MPA (the Southern Trench MPA

proposal).

The EU Habitats Directive (92/43/EEC) lists habitats in Annex I and species in

Annex II whose conservation requires the designation of special areas of

conservation (SAC) sites of community importance (SCI). The habitat

assessment carried out as part of the Atlantic and Cromarty Pre-

Decommissioning Environmental Survey, (Fugro, 2015), determined that no

Annex I habitat occurs in the project area of influence. Marine mammals listed

in Annex II (cetaceans and pinnipeds) have been observed in the outer Moray

Firth where the Atlantic & Cromarty Fields are located (bottlenose dolphin,

harbour porpoise) and along the export pipeline route (common seal). However,

the Atlantic & Cromarty Fields are approximately 125km from the nearest SAC

for marine species which is the Moray Firth SAC designated for bottlenose

dolphins.

Protected Areas

The area extending for 12nm from the Aberdeenshire coast between Buckie and

Peterhead is being studied by Scottish Natural Heritage regarding potential



future designation as a Nature Conservation Marine Protected Area (MPA). The

Atlantic & Cromarty export pipelines pass through this area that is termed the

Southern Trench MPA proposal. The Southern Trench, after which the site is

named, is an enclosed glacial seabed basin 200m deep located 10km north of

Fraserburgh. The Atlantic & Cromarty pipeline passes about 30km southeast of

this basin. A thermal front extends round Rattray Head towards Peterhead that

is associated with plankton richness and juvenile fish. The proposed boundary

of the MPA proposal would encompass this front. The Atlantic & Cromarty

pipeline passes through the part of the site where the front occurs, Figure 9-3.

Three Special Protection Areas (SPAs) designated under the EU Birds Directive

are in the vicinity of the Atlantic & Cromarty export pipeline landfall at St Fergus.

• Buchan Ness to Collieston Coast SPA: the northern boundary of the

SPA is approximately 6km south of the pipeline landfall. Its

designation protects a seabird assemblage (guilliemot, kittiwake,

herring gull, shag, puffin and fulmar) of international importance.

During the breeding season the area supports 95,000 seabirds

(JNCC, 2001a)

• Loch of Strathbeg is a dune loch approximately 4km north of the

pipeline landfall. Gulls, terns and wading birds nest there in summer.

In winter, thousands of wild geese, swans and ducks fly in, including

20 per cent of the world's population of pink-footed geese

• The Troup, Pennan and Lion’s Heads SPA: the eastern boundary of

the SPA is located approximately 20km west of the pipeline landfall.

It was designated for its breeding guillemot population of European

importance and seabird population (razorbill, kittiwake, herring gull,

fulmar) of international importance. The SPA supports 150,000

seabirds during the breeding season (JNCC, 2001b).

The Turbot Bank Marine Protected Area located approximately 30km south of

the Atlantic & Cromarty export pipeline and 50km south of the Atlantic &

Cromarty Fields is a site of particular importance for sand eels which are an

important source of food for seabirds including puffins and kittiwakes (JNCC,

2014).

Annex I to the EU Habitats Directive lists stony reefs and biogenic reefs as

protected habitat types. During the Atlantic & Cromarty pre-decommissioning

survey, BG commissioned a habitat assessment which evaluated the

‘circalittoral mixed sediment’ habitat against ‘reefiness’ against criteria for stony

reef and biogenic reef. Although the reef-forming species sabellaria spinulosa

was observed, the assessment concluded it did not form a contiguous reef in

this area.



Figure 9-3: Protected areas, (BG Group, 2016)

Socio-Economic Interests

Socio-economic activities in the offshore area where Atlantic & Cromarty

decommissioning activities will take place include commercial shipping and

fishing.

D14 Outline Environmental Impact Assessment Offshore Environmental Impact Assessment


10.0 Offshore Environmental Impact Assessment

Introduction

This section of the scoping report outlines the key potential offshore

environmental impacts from the proposed Acorn Project. It should be

emphasised that these are potential impacts only. Whether or not they are likely

to occur, and the level of significance will be assessed during the EIA. Possible

mitigation measures are also included. Benefits from the proposed project will

also be addressed during the EIA as appropriate, and through the consideration

of alternatives.

Physical Presence

The Acorn Project will involve the installation of a new seabed manifold at the

location of the Acorn CO2 storage site injection point. An 8km length of new

pipeline will connect the end of the existing Atlantic & Cromarty pipeline to the

manifold and a new umbilical will be installed from the St Fergus terminal to the

Acorn CO2 storage site manifold. The EIA programme will include:

• Review of subsea infrastructure and physical footprint

• Review of installation/commissioning vessel schedule and ongoing

reservoir support/supply vessels

• Review of any specific environmental effects noted in the Atlantic &

Cromarty Environmental Statement

Seabed and Habitat Disturbance

Seabed and habitat disturbance is expected to be minimal with re-use of most

of the subsea infrastructure. Some short-term disturbance will be seen from the

installation of the new pipeline and tie-in point at the Atlantic pipeline, the new

umbilical and the installation of the manifold and wellhead and tree at the new

well site. An Environmental Identification (ENVID) Summary will be completed

during FEED once the Basis of Design for the Acorn Project has been finalised.

The overboard disposal of oil or synthetic based drilling muds was eliminated

after the OSPAR Decision 2000/3 came into effect on 16 January 2001.

Therefore, the only drill cuttings that will be disposed of to the seabed will be

water-based drill cuttings and disturbance from the deposit of cuttings during

drilling, as has been demonstrated by post drilling surveys, will be limited to the

immediate vicinity of wellheads.

New subsea infrastructure and any associated disturbance will be fully

addressed within the EIA as appropriate.

The EIA programme will include:

• Assessment of disturbance from subsea infrastructure installation

and vessel activities

• Assessment of disturbance from installation of the new pipeline and

associated activities e.g. mattressing and rock dumping activities

• Assessment of disturbance from installation of the new umbilical and

associated activities e.g. trenching, mattressing and rock dumping

activities



Discharges to Sea

Discharges to sea from drilling operations including drill cuttings, drilling mud

and associated chemicals will occur. Drill cuttings contaminated with water-

based mud (WBM) will be discharged from the mobile drilling rig into the sea

following mud recovery operations. Most chemicals in WBM pose little or no risk

to the marine environment. Discharge of drill cuttings can cause a temporary

plume in the water column that may have short-term localised impact on

plankton and pelagic fish species, e.g. irritation of gills.

Results of seabed surveys at Atlantic have demonstrated that there are no

significant long-term cumulative impacts from the discharge of WBM

contaminated cuttings. Oil based mud (OBM) contaminated drill cuttings are

shipped to shore for treatment and disposal.

Chemicals, used mainly for drilling and workover operations, may enter the

marine environment through several routes including subsea control systems

and drainage systems. They can affect the marine environment in different ways,

mainly through immediate toxic effects (acute toxicity) or over long periods

(chronic toxicity).

Other discharges associated with the routine operation of the subsea control

system, will also be included in the EIA. For example, control of subsea valves

is usually via a water-based hydraulic fluid which is discharged to sea during

standard valve operations.


• Identification and quantification of all sources of discharges to sea

• Risk assessment and dispersion modelling of WBM contaminated

cuttings

Underwater Noise

Noise can come from many sources associated with exploration, construction,

installation and production of offshore developments. There are two main types

of noise:

• Continuous and intermittent noise sources which include drilling and

injection operations; noise from ships such as supply vessels,

installation vessels and guard vessels; and transponders.

• Temporary impulsive noise sources which include seismic surveys

and piling operations.

It is important that noise/vibration impacts are assessed during the EIA process

and a mitigation strategy developed to minimise disturbance. In recent years

there has been increasing concern about the effects of noise on marine

mammals. There may be a range of effects from industrial noise, including direct

effects such as hearing damage and disturbance and indirect effects such as

displacement of prey species or stress.


• Identification of potential noise sources and application of noise

reduction opportunities in design;

• Identification of noise control and noise management measures;

• Underwater noise modelling as appropriate;

• Assessment of disturbance, in particular any potential disturbance to

marine European Protected Species.



Atmospheric Emissions

The main source of atmospheric emissions from the Acorn offshore operations

is the combustion of diesel during installation of the subsea installation, with the

associated release of carbon dioxide (CO2), carbon monoxide (CO), unburnt

hydrocarbons (UHC), sulphur oxides (SOx) and oxides of nitrogen (NOx). The

subsea installation will subsequently be powered from shore.


• Identification and quantification of all sources of atmospheric

emissions (including shipping)

• Best Available Technology (BAT) assessment of power generation

options

• Dispersion modelling CO2 emissions from unplanned release

Waste

Waste generated from offshore operations comprising: special waste (including

oils, paints, chemical drums, and hazardous waste) and general waste with non-

hazardous properties, which requires being shipped to shore, will be addressed

as appropriate in the EIA. Strict legislation governs the separation, handling and

disposal of such wastes generated from subsea infrastructure maintenance

operations and the Environmental Statement will detail the compliance

measures and waste management strategy in place.


• Identification and quantification of all potential waste sources

• Waste management strategy based on the hierarchy of remove,

reduce, reuse, recycle

Accidental Events

All marine activities carry with them some risk of accidents which can result in

the spillage of harmful substances into the sea. Small oil and chemical spills

may originate from bunkering and chemical transfer operations, subsea

operations and drilling operations. There is a remote risk of CO2 loss from

pipeline damage.


• Identification of potential leak sources and spill pathways and

associated risks

• Leak prevention and review programme during design

• CO2 release modelling

• Review of knowledge transfer documents from UK CCS

programmes 1 and 2, CO2 modelling and risk evaluation

Cumulative and Transboundary Effects

Potential cumulative effects of the various impacts identified such as water

quality and global warming will be considered in the EIA. This will involve

examining the activities and potential impacts, both positive and negative of the

Acorn Project in the context of existing and known planned developments in the

area.


• Assessment of the potential cumulative impacts to ecological

habitats especially those of rare and protected species

• Socio-economic impacts including presence, fishing and fishing

grounds



• Shipping and navigational risk

Decommissioning and Pipeline Re-purposing

The circalittoral mixed sediments in the nearshore sections of the Atlantic &

Cromarty export pipeline are relatively biodiverse. The communities appear to

have recovered after the installation of the Atlantic pipeline and adapted to its

presence. BG completed stakeholder engagement with the JNCC, (BG Group,

2016), which suggested that further disturbance of the habitat in this area, for

example by removing a buried pipeline, would be undesirable as it would initiate

a further recovery period. The presence of sabellaria spinulosa accumulations

at the extreme of their geographic and depth range, even if they are not

considered at present to form a continuous reef, suggests that unnecessary

disturbance of this habitat should be avoided. Thus, consideration of the above

must be made within the Acorn EIA to address the impact of laying the umbilical.

D14 Outline Environmental Impact Assessment Permits and Consents


11.0 Permits and Consents

An initial consents register has been prepared for the capture plant, onshore

infrastructure and offshore infrastructure. The register forms part of D14 ACT

Acorn Outline Environmental Impact Assessment (Pale Blue Dot Energy, 2018).

This register is reflective of the current stage of the project and therefore may

not represent a comprehensive list of all permit, licences, application

notifications and consents that would be required through the full life cycle of the

project. Many of these are developed and understood through design

development of the project. It is recommended that this register provides a basis

to understand the project needs from business planning to concept select stage.

This document should be subject to detailed review at each project stage gate

to allow it to be updated and brought in line with the project concept and

understanding at that stage.

The onshore element of the project will take place on an existing Control of Major

Accident Hazards (COMAH) regulated industrial site. The consents register

covers key terrestrial authorisations required to construct and operate the

capture plant in terms of planning, environmental and health and safety based

on the current regulatory framework. At this stage, 13 key terrestrial

authorisations have been identified. These are listed in Table 16-1.

The offshore element of the project will take principally at the Acorn injection site

which is currently planned to be approximately 80 north west of St Fergus. The

consents register covers key terrestrial and marine authorisations required to

construct and operate the capture plant in terms of planning, environmental and

health and safety based on the current regulatory framework. At this stage, 26

key terrestrial and marine authorisations have been identified. These are listed

Table 16-1.



Onshore Consents Register

Aspect Requirement Determining Body Comment

Planning Permission

Planning permission for capture plant under the Town and Country Planning (Scotland) Act (TCPA) 1997 (as amended by the Planning etc. (Scotland) Act 2006).

Aberdeenshire Council (AC).

Planning permission for the transmission pipeline under the Pipeline Act 1962 and TCPA 1997.

AC.

Due to the small scale of the pipeline ~1km and low environmental sensitivity we assume that the pipeline would not be EIA development and could either be rolled up into the application for the capture plant or be subject to its own planning application.

Based on the assumption that the proponent is not a public gas transporter and the proponent can apply under the Gas Transporter Pipe-line Works (Environmental Impact Assessment) (Amendment) Regulations 2007.

Environmental Impact Assessment (EIA)

Subject to the EIA screening opinion / direction EIA for the capture plant under the Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2011.

AC. It may be possible to screen the capture plant out of the need for EIA particularly if the existing SAGE facility is used. This will be confirmed during the next phase.

Environmental Permit

Environmental Permit for the operation of the capture plant under the Pollution Prevention and Control (Scotland) Regulations 2012.

The Scottish Environment Protection Agency (SEPA).

Application to vary an existing permit or a new permit subject to agreement with SEPA.

Habitats Regulations Screening Assessment

Habitats Regulations Assessment (HRA) the Conservation (Natural Habitats, &c.) Amendment (Scotland) Regulations 2012.

The competent authority will vary for planning and permitting. For planning AC; for permitting SEPA.

The need for, and level of assessment will vary depending on potential (if any) pathways for effects to occur on nature sites.

Water Abstraction

A water abstraction license is subject to the Water Environment (Controlled Activities) (Scotland) Regulations 2011 more commonly known as the Controlled Activity Regulations (CAR).

SEPA. On the assumption that there is not sufficient ‘headroom’ within the existing license it may also be possible to use the existing terminal operator extraction license.

Hazardous Substance Consent

Consent for Hazardous Substances under the Planning (Hazardous Substances) (Scotland) Regulations 2015.

AC. Subject to the capture technology included within the project e.g. amines.

European Protected Species

European protected species license (i.e. for badgers, bats, Great Crested Newts etc.) under The Conservation of Habitats and Species Regulations 2010 and Habitats Regulations 2010

Scottish Natural Heritage (SNH) and if applicable Marine Scotland

May be required depending on which species, if any are present within and around the project area and the effect of the projects upon those species present.

Building Regulations Approval

Building Regulations Approval under Building (Scotland) Regulations 2017 (as amended).

AC. Detailed design to be completed before Building Regulations application(s) can be made.



Aspect Requirement Determining Body Comment

EU ETS Permit EU ETS Greenhouse Gas Emissions Trading Permit under the Greenhouse Gas Emissions Trading Scheme Regulations 2012.

The Greenhouse Gas Emissions Trading Scheme Regulations 2012.

Installations covered by the Scheme are required to monitor and report their emissions. At the end of each year they are required to surrender allowances to account for their installation’s actual emissions. They may use all or part of their allocation and have the flexibility to buy additional allowances or to sell any surplus allowances generated from reducing their emissions below their allocation.

REACH Registration Evaluation, Authorisation and restrictions of Chemical Regulations.

The Competent Authority is hosted by the Health and Safety Executive (HSE), working with SEPA and other government departments.

Subject to the capture technology included within the project. There could be a requirement to register as a downstream user of chemicals, e.g. amines.

COMAH Variation to COMAH Safety Report under the Control of Major Accident Hazards Regulations 2015.

The HSE and SEPA are jointly the Competent Authority (CA) for COMAH in Scotland.

The CO2 stripping process uses chemicals such as amines that, depending upon the characteristics and the volumes stored and used in process, may be a qualifying substance under COMAH. The CA has published guidance on the storage of bulk hazardous materials. If the amine to be used falls under the COMAH regulations, the detailed design will need to incorporate specific consideration on secondary and tertiary containment provisions.

Pipeline Operational Safety

SI 1996/825 The Pipeline Safety Regulations 1996 (PSR) - Major Accident Emergency Plan and notification prior to construction.

HSE.

PSR require a local authority to prepare emergency plans for pipelines which have the potential to cause a major accident for pipelines conveying ‘dangerous fluids’, defined in Schedule 2 of the Regulations. The Regulations also require a pipeline operator to establish emergency procedures for such pipelines.

CDM The Construction (Design and Management) Regulations 2015.

HSE.

During the design and construction phase of a project there are key responsibilities for safety management that lie with the Client, the appointed Construction Design and Management Coordinator (CDMC), designers and the appointed principal contractor. Provided that these responsibilities are implemented in line with regulation, all relevant safety management considerations should be met.

Table 11-1: Onshore consents register



Offshore Consents Register

Reference Consent / License Title

Statutory Instrument

Consent to: Key

Project Elements

Determining Authority

Summary of Key Consent / License Aspects

S01.0 Planning Permission

Town and Country Planning (Scotland) Act 1997 (as Amended by the Planning etc. (Scotland) Act 2006).

Add new pipework / new pipeline

St Fergus to Atlantic & Cromarty link

Aberdeenshire Council

S02.0 Pipelines Work Authorisation

Petroleum Act 1998

Add new pipework / new pipeline

St Fergus to Atlantic & Cromarty Link

Department of Business, Energy and Industrial Strategy (BEIS)

Need to provide Pipeline/flowline details, details on rock dumping, chemical discharges etc. Approval of PWA may be linked to Environmental Statement approval, therefore approval period may be extended.

S03.1 PON15C Approval

Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (SI 1999/360)

Change Atlantic & Cromarty pipeline to CO2 duty

CO2 export pipeline

OGREP/EMT

1. Uncertain if required for change of use of pipeline to CO2 duty.

2. Linked to Environmental Statement for overall Project. Even if the pipeline was included in an approved Environmental Statement, a PON15C may still be required.

3. OGA currently advise 6 months maximum approval process for oil and gas Environmental Statement.

4. PON15C also used for Chemical Permit application. Currently, if a preliminary environmental investigation indicates that the project or modification is unlikely to have a significant adverse effect on the environment, and none of the mandatory conditions apply, then the operator may apply for a dispensation from the requirement to undertake the full Environmental Statement process (i.e. a Direction). The procedure for doing this is to complete a Petroleum Operations Notice 15 (PON15) and submit this to BEIS.

The PON 15 requires detail about the proposed project and the environmental sensitivities of the area. It may be useful to prepare a preliminary environmental assessment as background to the PON. If a Direction is wanted, then it must be explicitly requested as part of the PON 15 submission.

Relevant Considerations will be included within the Offshore Environmental Statement.

S03.2

Chemical Permit (PON15C Approval)

Offshore Chemicals Regulations 2002 (SI2002/1355)

Use / Discharge of chemicals during pipeline installation, commissioning, maintenance, repair and

Atlantic & Cromarty export pipeline

OGA





Consent to: Key

Project Elements



decommissioning operations.

S03.3

Approval of updated Major Accident Prevention Document

SI 1996/825 The Pipeline Safety Regulations 1996 (PSR)

Re-use Atlantic & Cromarty pipeline


Health & Safety Executive (HSE)

1. Existing MAPD to require update/ re-development and submission to reflect changes due to CCS.

S03.4

Notification before use / re-use of a major accident hazard pipeline

S1 1996/825 Pipeline Safety Regulations 1996 (PSR) Reg 21

Re-use Atlantic & Cromarty pipeline



1. Notification anticipated to be required prior to commencement of re-use of pipeline

2. Minimum 14-day notification required.

S03.5 Notification in other cases

SI 1996/825 The Pipeline Safety Regulations 1996 (PSR) Reg 22



1. Notification anticipated to be required for change of use to CO2 duty.

2. Minimum 3-month approval period.

3. Some uncertainty surrounding requirements for change of use from natural gas to CO2 and associated legislation.

S04.0 Greenhouse Gas Permit

Greenhouse Gas Emissions Trading Scheme Regulations 2012

Transport Greenhouse Gas

Combustion activity

SEPA





Consent to: Key

Project Elements



S05.1 Exploration Licence

Energy Act 2008 / Petroleum Act 1998

Explore the store OGA

1. Non-intrusive exploration activities, in areas below the low water mark, are already regulated under the Petroleum Act 1998. Since the activities involved in such exploration do not depend on its ultimate purpose, BEIS have adapted the existing Exploration Licence, issued under the Petroleum Act, so that it becomes a combined licence issued under the Petroleum Act and the Energy Act 2008;

2. The amended exploration licence covers any combination of exploratory activities relating to petroleum, carbon dioxide storage, or storage and gas unloading of natural gas as applicable (e.g. cover seismic, gravity and magnetic surveys, sample collection and shallow drilling).

3. An Exploration Licence is currently valid for three years, and it is renewable on request. The cost of the licence is currently £500, which covers the internal departmental costs of administering the regime.

4. Agreement to the award of an Exploration Licence does not in any way replace the need for consents, in relation to these activities, required by the Offshore Marine Conservation (Natural Habitats &c.) Regulations 2007.

5. For the purposes of such exploration a developer will not be required to have a Crown Estate lease or a carbon storage licence.

6. Non-intrusive exploration activities (seismic, gravity & magnetic surveys, sample collection & shallow drilling)

S05.2

Consent to Survey (PON14A Approval)

Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001, (SI 2001/1754)

Store data gathering

OGA

1.These Regulations cover seismic survey or geological survey in offshore waters and require written consent from the Secretary of State before undertaking a seismic or geological survey.

2. Amendments made under the 2007 Regulations extend this requirement to include all UK waters. New Guidance incorporating the 2007 amendments is currently being drafted.

3. Consent for survey is required for all seismic surveys and high resolution seismic site surveys on the UKCS. Additional requirements may also apply within licence conditions.

4. Application for Consent must be made using the PON14A. If the survey involves several survey techniques, a single PON14A should be submitted.

5. Relevant Considerations will be included within the Offshore Environmental Statement





Consent to: Key

Project Elements



S05.3 Combined Operations Notification

SI 2005/3117 Offshore Installations (Safety Case) Regulations 2005 (SCR05)

Operation of mobile drilling rig alongside existing fixed installation

Acorn


1. Required for use of mobile drilling rig during workovers ops and drilling.

2. Required at least 21 days prior to combined operation.

S06.1

Chemical Permit (PON15B Approval)


Chemical use / discharge when drilling for new or sidetracked wells, including exploration, appraisal, injection and monitoring wells

Drilling new wells

OGA 1. Submission of PON 15B.

2. WONS notification (PON 4 - Consent to drill) also required prior to drilling.

S06.2 OPPC Permit

Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (SI2005.2055), as amended

Discharge or reinjection of any aqueous well work-over, intervention and service fluids contaminated with reservoir hydrocarbons when drilling new or sidetracked wells, including exploration, appraisal, injection and monitoring wells

Drilling new wells

OGA 1. Submission of OPPC Permit Application. 2. WONS notification (PON 4 - Consent to drill) also required prior to drilling.





Consent to: Key

Project Elements



S06.3 PON15B Approval

Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (SI 1999/360) (and Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001, (SI 2001/1754))

Drilling new or sidetracked wells, including exploration, appraisal, injection and monitoring wells

Drilling new wells

OGA

1. Linked to Environmental Statement for overall project. Even if the wells were included in an approved Environmental Statement, a PON15B will still be required in support of each of the well consents. 2. Uncertain if drilling for CO2 injection / monitoring several years into the project will trigger requirement for full Environmental Statement. 3. WONS notification (PON 4 - Consent to drill) also required prior to drilling. 4. PON15B also used for chemical permit application. 5. Conservation of Habitats Regulations require that an environmental assessment identify any habitats or species covered by the Conservation (Natural Habitats &c) Regulations 1994, determine the likely impacts on them and where an adverse impact on a site integrity are likely, propose mitigation and propose an appropriate system to manage the mitigation measures and other commitments identified to remove of reduce the potential impacts. These findings should be documented in the Environmental Statement as well as providing sufficient information to inform any Appropriate Assessment which may be undertaken by BEIS.

Currently, if a preliminary environmental investigation indicates that the project or modification is unlikely to have a significant adverse effect on the environment, and none of the mandatory conditions apply, then the operator may apply for a dispensation from the requirement to undertake the full Environmental Statement. process (i.e. a Direction). The procedure for doing this is to complete a Petroleum Operations Notice 15 (PON15) and submit this to BEIS. The PON 15 requires detail about the proposed project and the environmental sensitivities of the area. It may be useful to prepare a preliminary environmental assessment as background to the PON. If a Direction is wanted then it must be explicitly requested as part of the PON 15 submission.





Consent to: Key

Project Elements



S07.1 Carbon Storage licence

Storage of Carbon Dioxide (Licensing etc) (Scotland) Regulations 2011

Appraisal of the store. Drilling and test injection of CO2

Intrusive exploration and test injection activities

OGA

1. Further to the obligations of the EU CCS Directive the UK Government made provisions in the 2008 Energy Act for a regulatory regime for carbon dioxide storage in the UK offshore area. The Act also provides for certain relevant existing offshore oil and gas legislation to be applied to facilities used for carbon storage.

2. Intrusive exploration, including test injection, may be undertaken during the agreed appraisal phase of a carbon storage licence. This licence will allow deep drilling and test injection of carbon dioxide in addition to the activities permissible under a general Exploration Licence (above).

3. The potential award of a carbon storage licence will require prior assessment under the Habitats Regulations as is the case for Petroleum Production Licences. Drilling and test injection would also need to be assessed and approved under the Habitats Regulations and the Offshore Petroleum Production and Pipe-lines (Assessment of Environmental Effects) Regulations 1999 “the EIA Regulations” (as extended to include carbon storage) as is also the case for petroleum drilling.

4. Where the licensee intends intrusive exploration, the licence will specify a work programme to be undertaken within the appraisal term defined by the licence. The work programme will be agreed with the developer at the time of the award of the licence and will be detailed in a Schedule appended to the Licence. This phase of the licence corresponds to the “exploration permit” within the meaning of the Directive and will be issued for a limited time period to prevent unnecessary blocking of territory for potential developments.

5. Subject to the outcome of an ongoing consultation BEIS propose that the duration of the appraisal period of the carbon storage licence could have a benchmark period of four years where a depleted petroleum reservoir is in question.

6. In addition the Operator will also need to enter into an agreement with The Crown Estate (Scotland) to secure a corresponding 'Agreement for Lease'. It is the intention of The Crown Estate (Scotland) and BEIS that the lease will not be issued until the terms of the licence are agreed, and that the licence will not be issued until the terms of the lease are agreed.

S07.2 PON15D Approval

Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (SI 1999/360)

Injection of CO2 OGA

1. Linked to Environmental Statement for overall Project. Even if the facilities development/ operations were included in an approved Environmental Statement, a PON15D may still be required.

2. BEIS currently advise 6 months maximum approval process for oil and gas Environmental Statement.

3. Issues of timing related to CO2 Storage Licence to be resolved.

Currently, if a preliminary environmental investigation indicates that the project or modification is unlikely to have a significant adverse effect on the environment, and none of the mandatory conditions apply, then the operator may apply for a dispensation from the requirement to undertake the full Environmental Statement process (i.e. a Direction). The procedure for doing this is to complete a Petroleum Operations Notice 15 (PON15) and submit this to BEIS. The PON 15 requires detail about the proposed project and the environmental sensitivities of the area. It may be useful to prepare a preliminary environmental assessment as background to the PON. If a Direction is wanted then it must be explicitly requested as part of the PON 15 submission. Relevant considerations will be included within the Offshore Environmental Statement





Consent to: Key

Project Elements



S07.3

Chemical Permit (PON15D Approval)


Use or discharge of chemical offshore

OGA

1. Permit currently required for use and discharge of production chemicals offshore.

2. Anticipated to be required for use of MEG offshore as a pressure control fluid. Requirements needs clarifying as proposal is for MEG use in a closed system.

S07.4 PON 6 Metering 'non-objection'

Petroleum Act 1987 and in the Petroleum (Production) Regulations 1988, as amended

Determination that our proposed metering is adequate

CO2 injection

OGA

1. Depends on terms of CO2 Storage Licence

2. Model Clauses of the Schedules in the Petroleum Act 1987 and in the Petroleum (Production)

Regulations 1988 currently set requirements on metering oil and gas production. The PON6 sets out the procedure to be followed by Licensees in order that their proposals for a 'Method of Measurement' may be reviewed by BEIS.

S08.1

Carbon Storage Permit (new legislation)

Storage of Carbon Dioxide (Licensing etc) (Scotland) Regulations 2011

Store Carbon Dioxide

Licensed area, surface facilities and CCS operations

OGA

1. A storage permit would convey permission to construct facilities, including any offshore installation which might be necessary and to conduct storage operations. It would also provide the necessary legal framework for obligations to ensure that the storage operations will secure permanent geological containment of the carbon dioxide, that the facilities are properly decommissioned after use, and that the behaviour of the stored material is adequately monitored during and after storage operations.

2. In accordance with the requirements of the Directive, the consultation document makes clear that obtaining a storage permit will be conditional upon BEIS approval of the following from the applicant:

• Storage Development Plan

• Environmental Impact Assessment

• Monitoring Plan

• Corrective Measures Plan

• Financial security

• Site closure / post-closure plan

In addition, BEIS will need to approve the proposed Operator and will need to be satisfied that the applicant(s) have secured a seabed lease from the Crown Estate.

3. The potential award of a consent for storage operations will need to assess under the EIA and Habitats Regulations and may require approval under other environmental regulations that will be applied to carbon storage. The procedure will be similar to that applied in the case of oil and gas Field Development Plans.





Consent to: Key

Project Elements



S08.2

Environmental Statement & PON16 Approval

Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (SI 1999/360) (and Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001 (SI 2001/1754)

Develop the project, as designed within the constraints of the EIA

Licensed area, seabed and surface facilities including pipeline

BEIS

1. Environmental Statement approval anticipated to be required prior to Storage Permit issue

2. BEIS currently advise 6 months maximum approval process for oil and gas Environmental Statement

3. Conservation of Habitats Regulations require that an environmental assessment identify any habitats or species covered by the Conservation (Natural Habitats &c) Regulations 1994, determine the likely impacts on them and where an adverse impact on a site integrity are likely, propose mitigation and propose an appropriate system to manage the mitigation measures and other commitments identified to remove of reduce the potential impacts. These findings should be documented in the Environmental Statement as well as providing sufficient information to inform any Appropriate Assessment which may be undertaken by BEIS.

Currently, if a preliminary environmental investigation indicates that the project or modification is unlikely to have a significant adverse effect on the environment, and none of the mandatory conditions apply, then the operator may apply for a dispensation from the requirement to undertake the full Environmental Statement process (i.e. a Direction). The procedure for doing this is to complete a Petroleum Operations Notice 15 (PON15) and submit this to BEIS. The PON15 requires detail about the proposed project and the environmental sensitivities of the area. It may be useful to prepare a preliminary environmental assessment as background to the PON. If a Direction is wanted then it must be explicitly requested as part of the PON15 submission.

Relevant Considerations will be included within the Offshore Environmental Statement

S09.1 Marine Licence (new legislation)

Marine and Coastal Access Act 2009 & The Marine (Scotland) Act 2010

Locate drilling well or deposit substances in the sea or under the seabed (FEPA) Surface facilities (CPA)

Marine Scotland

The Marine Licensing regime came into force on 06 April 2011 and relates to all activities within Scottish Seas. The Licence subsumes all previous consenting requirements under the Food and Environmental Protection Act (FEPA) and Coastal Protection Act (CPA).





Consent to: Key

Project Elements



S09.2

Environmental Impact Assessment Approval

Marine Works (EIA) Regulations 2007, as amended

Locate Drilling Well or Deposit of any articles or substances in the sea or under the seabed (FEPA) Surface facilities (CPA)

Marine Scotland

1. Considered unlikely to apply on assumption that EIA Rags (SI199/360) would apply to full scope of project.

2. Would only be required to support applications under the Marine & Coastal Access Act 2009 / Marine (Scotland) Act 2010, and Harbour Works 1999 involving deposits in the sea and works to ensure navigational safety if the activity is not sufficiently covered by other EIA legislation.

S10.1

Agreement for Lease for Carbon Storage

Energy Act 2008 / 1982 United Nations Convention on The Law of the Sea

Scotland Act 2016

Storage of carbon dioxide

Licensed three-dimensional subsurface volume, seabed and surface facilities

Crown Estate Scotland

1. The Energy Act 2008 provides for a regulatory regime for carbon dioxide (CO2) storage within the limit of the territorial sea and beyond into a newly designated Gas Importation and Storage Zone (GISZ). The exclusive right to store CO2 offshore has been vested in the Crown within an area extending from the seaward limits of the territorial sea to the boundaries of the GISZ. The Crown Estate already has the right to grant leases for any purpose within the area of the territorial sea.

2. Crown Estate Scotland was established following the Scotland Act 2016. The vesting provisions of the Energy Act allow Crown Estate Scotland to grant similar authorisations in respect of carbon storage activities beyond the territorial sea but within the area of the GISZ. The new licensing scheme will operate in parallel to the leases and authorisations granted by Crown Estate Scotland, by regulating those activities within both the territorial sea and the GISZ.

3. Crown Estate Scotland has confirmed its intention to lease specific sub-seabed formations defined by three-dimensional coordinates, together with related areas of the seabed and water column for the platform/subsea infrastructure (The position will therefore differ from traditional oil and gas licences which give exclusive rights for petroleum exploitation within an area defined by reference to a two-dimensional plan view).

4. The Agreement for Lease will cover intrusive drilling, test injection and other exploration activities covered by a concurrent Carbon Storage Licence.





Consent to: Key

Project Elements



S10.2 Lease for Carbon Storage

Energy Act 2008 / 1982 United Nations Convention on The Law of the Sea

Scotland Act 2016

Storage of carbon dioxide

Licensed three-dimensional subsurface volume, seabed and surface facilities


1. The Energy Act 2008 provides for a regulatory regime for carbon dioxide (CO2) storage within the limit of the territorial sea and beyond into a newly designated Gas Importation and Storage Zone (GISZ). The exclusive right to store CO2 offshore has been vested in the Crown within an area extending from the seaward limits of the territorial sea to the boundaries of the GISZ. The Crown Estate already has the right to grant leases for any purpose within the area of the territorial sea.

2. Crown Estate Scotland was established following he Scotland Act 2016. The vesting provisions of the Act allow Crown Estate Scotland to grant similar authorisations in respect of carbon storage activities beyond the territorial sea but within the area of the GISZ. The new licensing scheme will operate in parallel to the leases and authorisations granted by Crown Estate Scotland, by regulating those activities within both the territorial sea and the GISZ.

2. Crown Estate Scotland has confirmed its intention to lease specific sub-seabed formations defined by three-dimensional coordinates, together with related areas of the seabed and water column for the platform/ subsea infrastructure (The position will therefore differ from traditional oil and gas licences which give exclusive rights for petroleum exploitation within an area defined by reference to a two-dimensional plan view).

3. Lease granted by Crown Estate Scotland will have defined geographical boundaries. As a condition of the lease, the developer will be required to apply to OGA for a licence for storage which will provide the framework for regulatory consent for the physical activities at the site, for example drilling and facilities construction.

4. The Lease will cover construction activities, carbon injection and storage operations, and the post closure monitoring phase of a project. The lease, and responsibility for long-term liabilities, will return to Crown Estate Scotland only when the project developer has satisfied the conditions for handover.

S11.1 Pipeline Crossing Agreements

General Property Law

Atlantic export pipeline


1. Confirmation required that existing agreements will remain in place.

2. Any specific new requirements for the CO2 storage project will be progressed in parallel with negotiations for the CO2 storage lease for the Acorn site.

S11.2

Crown Estate seabed lease for pipeline section in Scottish Territorial waters

General Property Law

Offshore CO2 pipeline within Scottish Territorial Waters


Co-ordinate with lease for storage.

Table 11-2: Offshore Consents Register

D14 Outline Environmental Impact Assessment Consultation


12.0 Consultation

Introduction

A key component of the EIA process is communication and stakeholder

consultation. Legislation such as the Public Participation Directive prioritises this

even further. Pale Blue Dot Energy recognises the benefits of stakeholder

consultation to ensure that all relevant concerns and opinions regarding a

particular project are integrated into the project decision making process and

are adequately addressed in the EIA process.

Previous and On-going Consultation

An initial consultation meeting was held with BEIS early in the project concept

phase. The objective of this meeting was to make BEIS aware of Pale Blue Dot

Energy’s plans regarding the Acorn Project, to solicit feedback on any future

changes/additions to legislation which may affect the development, and to

discuss the consenting process for the project.

The next phase of consultation provides stakeholders with an opportunity to

enter a discussion about the proposed project so that any issues and concerns

can be identified and clarified at an early stage. This scoping report provides a

basis for this dialogue. Consultation will not be limited to the scoping phase of

the project but will be ongoing as part of the EIA process. In this way, issues are

‘worked through’ to ensure that there are no ‘surprises’ on submission of the

Environmental Statement. This ongoing consultation will take the form of

meetings as needed with relevant organisations or individuals on key issues. In

addition, a close-out meeting will be held in Aberdeen to present feedback on

the consultation and EIA process prior to submission of the Environmental

Statement to the Oil & Gas Authority.

Pale Blue Dot Energy has established a web link to key documents to facilitate

the consultation process (www.pale-blu.com/acorn). This outline report will be

made available via the project website, www.actacorn.eu.

A database will be maintained to document all responses received from

consultees and track the project’s responses. A summary of the consultee and

project responses will be included as part of the Environmental Statement.

Summary of Consultees

The following provides a list of consultees for the Acorn Project EIA:

• Aberdeenshire Council

• Council Archaeologist

• Crown Estate Scotland

• Department of Business Energy and Industrial Strategy (BEIS)

• Grampian Fire Brigade

• Health & Safety Executive (HSE)

• Historic Scotland

• Marine Scotland

• Natural Heritage Team, Planning

• North of Scotland Water Authority (NOSWA)

• Oil & Gas Authority (OGA)

• RSPB Scotland

• St Fergus Coastal Environmental Committee

D14 Outline Environmental Impact Assessment Consultation


• St Fergus Community Council

• Scottish Environmental Protection Agency (SEPA)

• Scottish Executive Development Department (SEDD) Roads

Network Management and Maintenance Division (RNMMD)

• SEDD Planning Division

• Scottish Natural Heritage (SNH)

• Scottish Wildlife Trust

D14 Outline Environmental Impact Assessment Contents of the Environmental Statement


13.0 Contents of the Environmental Statement

As outlined in Section 4, it is assumed that a full EIA and associated

Environmental Statement will need to be completed during FEED. Two separate

Environmental Statements will be required:

1. Onshore: All onshore and intertidal works to the Mean Low Water Spring

(MLWS) are covered under a submission as set out under the Town and

Country Planning (Environmental Impact Assessment) (Scotland)

Regulations 2011.

2. Offshore: All offshore activities associated with the CCS project as set out

in the Offshore Petroleum Production and Pipelines (Assessment of

Environmental Effects) (Amendment) Regulations 1999 (as amended 2007

and 2010).

In preparation the contents of the more comprehensive Offshore Environmental

Statement have been outlined below based on the Environmental Statement

completed by Shell for the Peterhead CCS Project, (Shell, 2016).

NON-TECHNICAL SUMMARY

ACRONYMS

GLOSSARY

1. INTRODUCTION

1.1. Environmental Impact Assessment: Requirements and Purpose

1.2. Scope of the Environmental Statement

1.3. Legislative Overview

1.4. Environmental Management System

1.5. Contractor Interface

1.6. Acorn CCS Project HSSE Plan and Environmental Commitments

1.7. Environmentally Critical Elements

1.8. Areas of Uncertainty

1.9. Consultation Process

2. PROJECT DESCRIPTION

2.1. Carbon Capture and Storage Proposal

2.2. Project Background

2.3. Development Options

2.4. Onshore Project Scope

2.5. Pipeline Project Scope

2.6. Existing Infrastructure

2.7. Offshore Project Scope

2.8. CO2 Storage at the Acorn CO2 Storage Site

2.9. Environmental Performance

2.10. Key Permits and Consents

2.11. Decommissioning

3. BASELINE ENVIRONMENT

3.1. Surveys



3.2. Metocean Conditions

3.3. Climate

3.4. The Seabed

3.5. Habitats and Species of Conservation Concern

3.6. Marine Flora and Fauna

3.7. Socio-Economic Environment

3.8. Overview

4. ENVIRONMENTAL ASSESSMENT METHODOLOGY

4.1. Impact Assessment Approach

4.2. Assessment of Potential Impacts and Control Measures

5. USAGE OF SPACE

5.1. Physical Presence

5.2. Seabed Disturbance

6. GASEOUS EMISSIONS

6.1. Pipeline Installation Phase

6.2. Well Completion, Subsea Installation & Umbilical Replacement

6.3. Injection and Storage

6.4. Total Emissions

6.5. Mitigation Measures, Safeguards and Controls

7. DISCHARGES TO SEA

7.1. Pipeline Installation Phase

7.2. Works at the Acorn CO2 storage site

8. UNDERWATER NOISE

8.1. Introduction

8.2. Impact Assessment Method

8.3. Potential Impact of Underwater Sound associated with the development

8.4. Modelling Results

8.5. Noise Impact Assessment


9. WASTE GENERATION

9.1. Waste from Vessels

9.2. Pipeline Installation

9.3. Subsea Installation & Umbilical Phase

9.4. Well Completion Phase

9.5. Injection Phase

9.6. General Waste

9.7. Special Waste


10. ACCIDENTAL HYDROCARBON RELEASES

10.1. Overview of Potential Hydrocarbon Releases



10.2. Oil Spill Regulations and Risk on the UKCS

10.3. Hydrocarbon Release Modelling

10.4. Modelling Results

10.5. Impact Assessment


11. ACCIDENTAL CO2 RELEASE

11.1. Impacts Associated with CO2 Release

11.2. Sources of CO2 Release

11.3. Injection Strategy

11.4. Monitoring

11.5. Corrective Measures

12. CONCLUSIONS

12.1. Environmental Impacts

12.2. Cumulative Impacts

12.3. Transboundary Impacts

12.4. Socio-Economic Impacts

12.5. Commitments

12.6. Overall Conclusions

13. REFERENCES

APPENDIX A - REGISTER OF ENVIRONMENTAL LEGISLATION

APPENDIX B - ENVIRONMENTAL IMPACT ASSESSMENT

A.1. Subsea Activities - Planned Activities; A.2 Subsea Activities - Unplanned

Events; A.3 Offshore Activities - Planned Activities; A.4 Offshore Activities -

Unplanned Events; A.5 Onshore Activities - Planned Activities; A.6 Onshore

Activities - Unplanned Events

APPENDIX C - SEDIMENT MODELLING

C.1. Pipeline Installation; C.2. Methodology; C.3. Modelling Results; C.4.

Environmental Impacts; C.5. Conclusions

APPENDIX D - UNDERWATER NOISE ASSESSMENT

D.1. Introduction; D.2. Sound Sources Associated with the Project; D.3. Impact

Assessment Method; D.4. Underwater Sound Modelling; D.5. Species

Sensitivities; D.6. Modelling Results; D.7. Mitigation Measures, Safeguards and

Controls; D.8. Impact Assessment; D.9. Conclusions

APPENDIX E - OIL SPILL MODELLING

E.1. Introduction; E.2. Oil Spill Regulations and Risk on the UKCS; E.3. Spill

Risks; E.4. Modelling Results; E.5. Environmental Sensitivities; E.6. Response

Measures; E.7. Conclusion

D14 Outline Environmental Impact Assessment Conclusions and Next Steps


14.0 Conclusions and Next Steps

Conclusions

1. With respect to an Environmental Impact Assessment (EIA), Pale Blue Dot

view the Acorn Project as a Schedule 2 project which may require an EIA.

2. Aberdeenshire Council’s provisional view is that, irrespective of being

Schedule 1 or 2, the Acorn Project will need to complete an Environmental

Impact Assessment (EIA) and subsequent Environmental Statements which

separately cover onshore and offshore requirements.

3. A definitive view will be provided by Aberdeenshire Council upon submission

of an Environmental Scoping Report.

4. An Environmental Scoping Report would need to be submitted for review

and approval by Aberdeenshire Council between mid-2019 and mid-2020.

If confirmed as required, an EIA would then be completed in 2020/21 as part

of FEED.

5. The regulations, permits and consents influencing the EIA are well

understood as detailed within the report. The contents and structure of two

Environmental Statements are also well understood.

6. The current assessment of both the onshore environmental impact and

offshore environmental impact indicates minimal impact beyond current

activities.

7. The re-use of the Atlantic pipeline for the transportation of CO2 will result in

a lower environmental impact versus the need to install a new pipeline.

8. Beyond the main pipeline, the opportunity to re-use infrastructure is likely to

be minimal.

Next Steps

1. Submission of the Environmental Scoping Report to Aberdeenshire Council

confirm if Acorn is Schedule 1 or 2 and whether an EIA is required.

2. On the assumption that an EIA is required, the completion of an EIA and the

subsequent, linked but separate, Onshore Environmental Statement and

Offshore Environmental Statement.

D14 Outline Environmental Impact Assessment References


15.0 References

Aberdeenshire Council. (2017). Aberdeenshire Council. Retrieved from Local

Development Plan 2017 Part 2:

https://www.aberdeenshire.gov.uk/media/20619/local-development-

plan-2017-part-2.pdf

BG Group. (2016). Atlantic & Cromarty Decommissioning Programme:

Environmental Impact Assessment.

Bresnan, E. H. (2009). Seasonal and interannual variation in the phytoplankton

community in the north east of Scotland. Journal of Sea Research, 61:

17-25.

Edwards, M. B. (2013). Impacts of Climate Change on Plankton. Marine Climate

Change Impacts Partnership: Science Review, 97-112.

ERM. (2007). DF1 Project: St Fergus CO2 Compressor Plant Planning

Application Supporting Statement.

Fugro. (2015). Atlantic & Cromarty Fields Pre-Decommissioning Survey.

Genesis. (2002). Atlantic and Cromarty Environmental Statement. DECC

reference number: D/1530/2002.

JNCC. (2001a). SPA Description: Buchan Ness to Collieston Coast. Retrieved

from JNCC: http://jncc.defra.gov.uk/default.aspx?page=1922

JNCC. (2001b). SPA Description: Troup, Pennan and Lion's Heads. Retrieved

from JNCC: http://jncc.defra.gov.uk/page-1921

JNCC. (2014). Turbot Bank MPA Site Summary Document. JNCC. Retrieved

from JNCC: http://jncc.defra.gov.uk/page-6490

JNCC. (2017, October 04). Turbot Bank MPA. Retrieved from JNCC:

http://jncc.defra.gov.uk/page-6490

North Sea Task Force (NSTF). (1993). North Sea Subregion 2b Assessment

Report. Quality Status of the North Sea. NSTF.

NSMP. (2017). 7th December 2017 Site Visit by Pale Blue Dot Energy.

Pale Blue Dot Energy. (2018). D03 ACT Acorn Basis of Design for St Fergus.

ACT Acorn Consortium.

Pale Blue Dot Energy. (2018). D14 ACT Acorn Outline Environmental Impact

Assessment. ACT Acorn Consortium.

Pefrofac Engineering Limited. (2012). Caledonia Clean Energy Project

Conceptual Study Report (Internal report for CO2DeepStore).

Reid, J. E. (2003). Atlas of Cetacean Distribution in North West European

Waters. Peterborough: JNCC.

Ritchie, W., Kingham, L., & Livingston, J. (2013). A Glossary of Coastal

Environmental Features at the Pipeline Landfalls at St. Fergus.

University of Aberdeen.

Scottish MPA Project. (2013). Data Confidence Assessment: Southern Trench

MPA Proposal.

Shell. (2016). Peterhead CCS Offshore Environmental Statement. Shell UK

Limited and Genesis Oil and Gas Consultants Ltd.

D14 Outline Environmental Impact Assessment References


Sparling, C. R. (2012). Baseline Seal Information for the FTOWDG Area. SMRU-

FDG-2012-0.

Stone, C., Webb, A., Barton, C., Ratcliffe, N., Reed, T., Tasker, M., . . .

Pienkowski, M. (1995). An atlas of seabird distribution in north-west

European waters. ISBN 1 873701 94 2.

Thompson, D. D. (2010). Berwickshore and Northumberland Coast European

Marine Site: Grey Seal Population Status. Natural England 20100902-

RFQ.

Total. (2009). Retrieved from Offshore Europe: https://www.offshore-

europe.co.uk/__novadocuments/29214

UK Government. (2018). Oil and Gas Decommissioning of Offshore Installations

and Pipelines. Retrieved from www.gov.uk:

https://www.gov.uk/guidance/oil-and-gas-decommissioning-of-

offshore-installations-and-pipelines

UK Government. (n.d.). EIA Thresholds.

D14 Outline Environmental Impact Assessment Annex 1: Consent Register


16.0 Annex 1: Consent Register

Aspect Requirement Determining body Comment

Planning

Permission

Planning permission for capture plant under the

Town and Country Planning Act (TCPA) 1990. Aberdeenshire Council (AC).

Planning permission for the transmission pipeline

under the Pipeline Act 1962 and TCPA 1990. AC.

Due to the small scale of the pipeline ~1km and low environmental sensitivity we assume

that the pipeline would not be EIA development and could either be rolled up into the

application for the capture plant or be subject to its own planning application.

Based on the assumption that the proponent is not a public gas transporter and the

proponent can apply under the Gas Transporter Pipe-line Works (Environmental Impact

Assessment) (Amendment) Regulations 2007.

Environmental

Impact Assessment

(EIA)

Subject to the EIA screening opinion / direction

EIA for the capture plant under the Town and

Country Planning (Environmental Impact

Assessment) (Scotland) Regulations 2011.

AC. It may be possible to screen the capture plant out of the need for EIA particularly if the

existing SAGE facility is used. This will be confirmed during the next phase.

Environmental

Permit

Environmental Permit for the operation of the

capture plant under the Pollution Prevention and

Control (Scotland) Regulations 2012.

The Scottish Environment

Protection Agency (SEPA). Application to vary an existing permit or a new permit subject to agreement with SEPA.

Habitats

Regulations

Screening

Assessment

Habitats Regulations Assessment (HRA) the

Conservation (Natural Habitats, &c.) Regulations,

1994 and Habitats Regulations 2010.

The competent authority will vary

for planning and permitting. For

planning AC; for permitting SEPA.

The need for, and level of assessment will vary depending on potential (if any) pathways

for effects to occur on nature sites.

Water Abstraction

A water abstraction licence is subject to the Water

Environment (Controlled Activities) (Scotland)

Regulations 2011 more commonly known as the

Controlled Activity Regulations (CAR).

SEPA. On the assumption that there is not sufficient ‘headroom’ within the existing license it may

also be possible to use the existing terminal operator extraction licence.

Hazardous

Substance Consent

Consent for Hazardous Substances under the

Planning (Hazardous Substances) (Scotland)

Regulations 2015.

AC. Subject to the capture technology included within the project, e.g. amines.

D14 Outline Environmental Impact Assessment Annex 1: Consent Register


European Protected

Species

European protected species licence (i.e. for

badgers, bats, Great Crested Newts etc.) under

The Conservation of Habitats and Species

Regulations 2010 and Habitats Regulations 2010

Scottish Natural Heritage (SNH)

and if applicable Marine Scotland

May be required depending on which species, if any are present within and around the

project area and the effect of the projects upon those species present.

Building

Regulations

approval

Building Regulations Approval under Building

(Scotland) Regulations 2017 (as amended). AC. Detailed design to be completed before Building Regulations application(s) can be made.

EU ETS Permit

EU ETS Greenhouse Gas Emissions Trading

Permit under the Greenhouse Gas Emissions

Trading Scheme Regulations 2012.

The Greenhouse Gas Emissions

Trading Scheme Regulations 2012.

Installations covered by the Scheme are required to monitor and report their emissions.

At the end of each year they are required to surrender allowances to account for their

installation’s actual emissions. They may use all or part of their allocation and have the

flexibility to buy additional allowances or to sell any surplus allowances generated from

reducing their emissions below their allocation.

REACH Registration Evaluation, Authorisation and

restrictions of Chemical Regulations.

The Competent Authority is hosted

by the Health and Safety Executive

(HSE), working with SEPA and

other government departments.

Subject to the capture technology included within the project. There could be a

requirement to register as a downstream user of chemical, e.g. amines.

COMAH

Variation to COMAH Safety Report under the

Control of Major Accident Hazards Regulations

2015.

The HSE and SEPA are jointly the

Competent Authority (CA) for

COMAH in Scotland.

The CO2 stripping process uses chemicals such as amines that, depending upon the

characteristics and the volumes stored and used in process, may be a qualifying

substance under COMAH. The CA has published guidance on the storage of bulk

hazardous materials. If the amine to be used falls under the COMAH regulations, the

detailed design will need to incorporate specific consideration on secondary and tertiary

containment provisions

Pipeline operational

safety

SI 1996/825 The Pipeline Safety Regulations 1996

(PSR) – Major Accident Emergency Plan and

notification prior to construction.

HSE.

PSR require a local authority to prepare emergency plans for pipelines which have the

potential to cause a major accident for pipelines conveying ‘dangerous fluids’, defined in

Schedule 2 of the Regulations. The Regulations also require a pipeline operator to

establish emergency procedures for such pipelines.

CDM The Construction (Design and Management)

Regulations 2015. HSE.

During the design and construction phase of a project there are key responsibilities for

safety management that lie with the Client, the appointed Construction Design and

Management Co-ordinator (CDMC), designers and the appointed principal contractor.

Provided that these responsibilities are implemented in line with regulation, all relevant

safety management considerations should be met.

Table 16-1: Consent Register

Project: ACT Acorn Feasibility Study · The current assessment of both the onshore environmental impact and offshore environmental impact indicates minimal impact beyond current activities.

Documents