Our submitted response follows, but we have been advised today (3rd October) that ExxonMobil is abandoning its controversial scheme to build a pipeline from Fawley Refinery across either the Isle of Wight or the New Forest carrying liquefied carbon dioxide for undersea disposal. The company has decided that, in the absence of any long-term, stable Government plan, the £5 billion investment involved is currently uncompetitive.
September 2024
The New Forest Association (NFA) is one of the oldest conservation and environmental groups in the UK. Founded in 1867 with the aims to protect the unique quality of the New Forest and the practice of commoning in the Forest. Those aims remain as relevant today. The NFA objects to the proposal to route a new pipeline to transport CO2 from Fawley refinery across New Forest National Park and out into Christchurch Bay just west of Milford on Sea. The pipeline is proposed to transport CO2, both generated at Fawley and also imported from other industries across the Solent area. The pipeline mainland route runs a distance of around 38km, 34km in the National Park. The objections of the New Forest Association are set out below:
The New Forest is one of the most nature rich places in England and covered by protections flowing from environmental legislation including Site of Special Scientific Interest (SSSI), Special Area of Conservation (SAC), National Nature Reserve (NNR) and the Special Protection Area (SPA) together known as Natura 2000 sites and Ramsar protections. These designations often overlap both in area and substance. And there is the additional designation as a National Park and the statutory protections that cover the area. The 500m search corridor for the pipeline passes through nearly every national and international environmental designation found within the National Park.
It should be noted that not only the principal river valleys, the Beaulieu and Lymington rivers, but also the minor river valleys feeding into the Solent have great environmental importance which may not be fully recognised. The Stanswood and Darkwater river valleys are also of particular importance. The proposed route of the pipeline passes through at six environmentally significant, and protected, watercourses for which no explicit mitigation is proposed.
There is a strong likelihood that parts of the route are under-surveyed and so desk-exercises such as Exxon Mobil have carried out are of limited value. Systematic field survey is required to inform route-finding. It is recognised that whilst engineering can find solutions to many challenges it is not possible to restore soils after gross disruption. All areas of important habitat should therefore be treated through ‘no dig’ options.
The impact on the New Forest would arise both within the construction phase when the damage would be extensive, and continue when completed. During the construction phase large numbers of contractors undertaking extensive excavations with large machinery in a sensitive environment would inevitably lead to irreversible damage. This would be compounded by the need for excavation beneath significant watercourses/rivers and numerous other streams and ditches. The consultation document states ‘the corridor includes areas of habitat which would be technically very difficult to restore, recreate or replace’.
At no point in the consultation documents is there consideration of the impact of the construction on the agricultural economy of the New Forest and how these proposals would affect the practice of commoning. The noise, disturbance and intrusive activities in those areas that are normally quiet and peaceful would be immensely disturbing to wildlife and the grazing of livestock in the Forest, necessary for Commoners farming activities on the Open Forest. It would also compromise the availability of back-up grazing for hay and silage making and grazing in fields that would be crossed by any route within the 500m area of search.
Once construction is complete there would remain a 50m wide corridor along the length of the pipeline which it appears would be kept clear for maintenance. There would also be 2 further built structures of an unknown number – valve stations with a footprint of 40m x 40m fenced area and pigging stations 90m x 90m fenced area with structures up to 4m high. There is no indication where these would be located. The long-term visual impact in this sensitive area would be significant and detrimental. The visual impact of introducing a number of industrial type compounds at regular intervals across the New Forest, with high fencing, poles and cables for communications, buildings and limited vegetation within the compounds would be significant.
There would also be the need, not acknowledged by Exxon, for increased vehicular access points across the Forest to service these industrial compounds and vehicle movements in areas which can only be reached by foot and horseback.
In the absence in the consultation of any detail about the consideration of alternative routes it is very hard to explain why the mainland route has been considered at all. It is understood that the DCO process does not allow for consideration of alternative schemes and that this consultation process is designed to take three options to a preferred one. Why has no route beneath the Solent been fully examined? For non-experts it would appear that the technical difficulties of the tides and seabed at Hurst Point are no more difficult than putting a pipeline through the heart of one the most unique and nature rich environments in England.
Net zero and carbon capture In principle the NFA supports efforts to reduce carbon emissions and to find more sustainable solutions to the challenges facing us all. This support is not at the cost of irreversible damage to the New Forest. We are also concerned that there no incentive for industries to reduce their carbon emissions at source if there is a technology that captures it for them and removes it. Comparable to waste generation – CO2 needs to be reduced at source and for the polluter to take responsibility.
The consultation does not give any evidence or information on the carbon footprint of the construction of the new pipeline. There is no evidence put forward about the lifetime carbon impact of both the continuation of activities at Fawley refinery or the potential for increase in carbon generating activities at the Fawley refinery and elsewhere in the Solent region if the pipeline were to go ahead.
We understand that the technology behind carbon capture is not fully tried and tested in the type of situation being proposed. At what point will ExxonMobil share their understanding of the technology to give an opportunity for the local community to do their own research and have an informed conversation? Launching a DCO consultation without this other information is very unhelpful for the local community and those who depend on the New Forest for their livelihood.
There is no evidence being put forward to explain the need for the pipeline or the long term demand from other industries in the Solent region to use the pipeline. We are aware of government support for carbon capture and storage in consultations carried out in 2022. The technology is part of the current government’s ‘green technology’ investment programme.
In the absence of ExxonMobil justifying the need for this pipeline in the consultation documents we researched ExxonMobil’s activities regarding CO2 pipelines elsewhere. It may be that the pipeline is part of a project at Fawley Refinery to develop a ‘Blue hydrogen’ plant similar to one in they are developing in the US. Blue hydrogen is sourced from hydrocarbons and generates large amounts ofCO2 waste gas. If this is the case then our concerns about carbon footprint and long term sustainability become very serious. Climate scientists have raised this concern with government in a recent letter to the DESNEZ Minister – Ed Miliband.
The 2022 government consultations include a map showing carbon storage in a submarine aquifer in the English Channel. Although it is unclear the exact location of the aquifer we understand that it is located around 20 miles south of the Isle of Wight.
The technology and safety aspects of carbon capture and storage in a marine aquifer (particularly a chalk aquifer) are still the object of on-going scientific research as many questions remain unanswered. The injection of highly pressurised CO2 into a natural marine aquifer pose potentially significant risks to the marine environment. The potential seepage of large amounts of pressurised CO2 into the sea, would lead to acidification, harm to marine life and potential contamination of underground drinking water. The impact on the South coast of Hampshire and Dorset could be catastrophic for current and future generations. Much of this coast is environmentally protected with various designations.
The proposed mainland route of the pipeline would pass close (within 500m) to residential areas. There is no mention of safety of the pipeline anywhere in the consultation. NFA is aware of accidents in the US relating to CO2 pipelines. When a consultation is limited solely to what is needed for a DCO application it is inevitable that local residents will ask much broader questions about the proposal. It is quite reasonable to expect that ExxonMobil would have been clear from outset about the risks and mitigations of a pipeline for transporting CO2.
ends
3rd October 2024 – We have been advised today that ExxonMobil is abandoning its controversial scheme to build a pipeline from Fawley Refinery across either the Isle of Wight or the New Forest carrying liquefied carbon dioxide for undersea disposal. The company has decided that, in the absence of any long-term, stable Government plan, the £5 billion investment involved is currently uncompetitive.
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