MP gets Peak Cluster answers

Tim Roca MP has shared a letter from Peak Cluster Limited’s chair, David Parkin, which provides responses to a number of questions raised by the local community.

Dear Tim,

Thank you for getting in touch and raising your constituents’ concerns with us.

We are early in the development of the project and alongside carrying out studies and assessments, our approach has been to speak to communities at the earliest possible stage to gain local knowledge from those who know their area the best. By undertaking engagement and consultation ahead of finalising the design we are enabling local communities and stakeholders genuine agency to influence.

However, this means that we do not yet have answers to every question or detailed plans that we can use to evidence the responses we are providing. This, as you identified, results in some residents looking elsewhere for information to fill the gaps. It also means that, as a host MP, your office is receiving a great deal of correspondence about the project, and we hope this response will help address some of the main concerns your constituents have raised.

Now that the first phase of consultation has ended, we are in the process of reviewing and considering the feedback provided by local communities and stakeholders to evolve the project design. The feedback we have received thus far has been invaluable, bringing things to our attention that we otherwise wouldn’t have been aware of, demonstrating that this approach is effective.

Over the coming months, we’ll use the feedback we’ve heard during the phase 1 consultation, alongside further engineering and environmental studies, to continue to build our proposals for the project. We’ll hold a more detailed phase 2 consultation later in the year, at which point we’ll have more specific information on our plans to share.

Between now and the phase 2 consultation our communication channels will remain open, and we will be providing regular updates on our progress. At the time of writing, over 3,000 people have signed up for our newsletter on our consultation hub, and we are continually working to expand the reach of our communications.

We have compiled a series of answers to the questions your constituents have raised below.

Best regards,

David Parkin

Chair of Peak Cluster

Project Safety

Can you share details of the risk assessment?

Our engineering design meets recognised standards and regulations, established best practice and proven design methods and robust control safety measures to ensure risks are minimised to levels required by the Health and Safety Executive (HSE) and the Environment Agency.

As is the case with high-pressure natural gas pipelines, the Peak Cluster CO₂ pipelines are being designed to BS PD8010 standards. These standards ensure our pipeline design considers an extensive list of risk factors, including corrosion, third-party damage, proximity to communities, flooding, ground movement and so on.

We’re also implementing industry-leading leak detection technologies along the pipeline. This would likely be a Distributed Fibre Optic Sensor (DFOS) system or similar, which would run the full length of the pipeline.

The Environment Agency and the Health and Safety Executive, as prescribed consultees, are also being consulted throughout the project.

The detailed risk assessment and safety case will be developed as project engineering progresses.

What is the likelihood of leaks occurring from the pipeline and what hazards do leaks cause?

The UK has a wealth of experience in designing, constructing and operating pipelines to transport gas. The practice is very well-established and robustly regulates technology, for which the UK has earned a global reputation for safety.

The Intergovernmental Panel on Climate Change (the international authority on all matters related to climate change and low-carbon technologies) estimates that just 0.00001% of carbon dioxide transported through the pipeline would be lost through accidental leaks.

The UKOPA Product Loss Report1

1 UKOPA Product Loss Report (1962 -2023). Edition 1 – UKOPA provides a comprehensive and independent dataset of leaks from UK Major Accident Hazard Pipelines. The latest version covers the period from 1962 -2023 and documents that leaks of any size on UK Major Accident Hazard Pipelines are rare. The report states that between 1962 and 2023, across the full UK network of 27,000km there is approximately one leak per year and that more than 75% of leaks on major accident hazard pipelines are small, or pinhole in size. If a leak of this size was to occur on a CO2 pipeline, the CO2 gas released would be quickly dispersed.

The report states that large leaks on steel major accident hazard pipelines are typically caused from damage by third-parties or by significant land movement. The use of thick-walled steel pipe, like that which would be used for Peak Cluster’s pipeline, is very effective at preventing large leaks from these external factors.

Are you aware of a pipeline leak in Mississippi, USA, and how is Peak Cluster different from this project?

Our team is aware of the leak on the pipeline near Sartartia which was operated by Denbury Gulf Coast Pipelines. Whilst this incident is an opportunity to learn, the regulatory context for pipelines in the USA is so different to the UK, so a direct comparison is misleading.

UK regulation places people and property central to the safety assessment of a pipeline. As a result, the Peak Cluster pipeline is being built to a different standard than the pipeline near Sartartia, which would significantly reduce the leakage risk:

• The Peak Cluster pipeline will operate in gas phase at between half and a quarter of the pressure of the Denbury liquid (dense) phase pipelines.
• The Peak Cluster pipeline will have a wall thickness up to twice that of the Denbury pipeline.
• The Peak Cluster pipeline will feature stronger leak detection and improved response plans than was the case at Sartartia.

Is there a threat to life if there is a leak?

Where pipelines are properly designed, built, operated and maintained they are a safe and reliable means of transporting gases over significant distances. Gas and liquid have been transported in the UK by pipeline for more than one hundred years and there are around 27,000km of major accident hazard pipelines in the country. Peak Cluster is being designed to comply with the UK’s robust Pipelines Safety Regulations (PSR) 1996, which require that the design, construction, operation and maintenance of pipelines must comply with recognised codes and standards. The UK standards for pipelines to transport CO2 are recognised as being the most thorough in the world, and the design and operation of pipelines is regularly scrutinised by the HSE.

For an individual to be affected by carbon dioxide they must be exposed to a high concentration of gas for a period. There are many layers of protection both in the design and operation of the pipeline. High concentrations generally require a large leak which would typically be the result of external impact. Thick-walled pipe is very effective at reducing the effect of pipeline damage and UKOPA have recorded no leaks caused by external impact on thick-walled major accident hazard pipeline.

How will Peak Cluster be held accountable if any leaks or other safety defects occur?

There is a clear regulatory framework within which the pipeline and capture facilities will be designed, maintained and operated:

• The Peak Cluster pipeline will be regulated by the HSE.
• The capture plants and operators will be regulated by both the HSE and the Environment Agency.

Failure to adhere to these regulations can result in improvement notices, legal consequences, fines or criminal charges for the most severe negligence or accidents.

Is there a mandatory distance separating the pipeline or AGIs from the community?

A key strength of UK gas safety regulation is its goalsetting approach, rather than a narrow focus on compliance. The Pipelines Safety Regulations (1996) require operators to design and operate their pipelines in a way that is as safe as is reasonably practicable. This means that designers and operators must deploy reasonable best practice and it allows flexibility to achieve and demonstrate safe operation. In the UK, there is no mandatory distance separating the pipeline or AGIs from the community. Instead, there is a requirement to demonstrate to the satisfaction of the HSE that the design and planned operation of the pipeline is safe. This regulatory approach has driven high standards and effective outcomes across the UK pipeline industry.

Can you provide evidence-backed reassurances that safety and leaks are not likely to occur?

Peak Cluster isn’t new technology. The UK has been injecting CO2 into offshore wells for decades to extract oil and gas. Carbon dioxide is a widely used industrial gas and the technology used to capture the carbon was developed in the 1930s. The UK has extensive experience with operating and regulating high-pressure gas pipelines with a strong safety record. Carbon capture and storage schemes are operational across the world – the closest outside of the UK being Norway where the Sleipner scheme has been running since 1996 – capturing about 1 million tonnes a year. We are building on this experience with the highly skilled UK workforce and strong regulatory standards to make a real difference to key strategic industries. Peak Cluster’s onshore pipeline will be made of steel with a wall thickness of up to 25mm and is a well tried and tested technology. There are approximately 27,000 km of similar pipelines across the UK transporting a wide variety of materials and recently there has been one small diameter leak per year across that asset base.

The UKOPA Product Loss Report referenced above provides a comprehensive and independent evidence-backed review of the safety of pipelines in the UK regulatory context.

Impact on Land

Will land affected and properties nearby be devalued by the project?

Where land is required for the pipeline or associated infrastructure, such as Above Ground Installations (AGIs) or Block Valve Stations (BVs), the project will seek to enter into agreements with affected landowners. These agreements will include compensation for the land or rights required, assessed in accordance with established industry practice and the statutory Compensation Code. Compensation is based on market value and is intended to ensure that landowners are not financially disadvantaged as a result of the project.

In the case of buried pipelines, experience from comparable infrastructure schemes indicates that, once construction is complete and land is reinstated, there is typically no measurable impact on the value of nearby land or property.

Where we are not acquiring land, but the operational project has an effect on value, the Compensation Code provides statutory mechanisms that may allow eligible property owners to seek compensation for certain types of loss in value. There are established rules on this and, whilst the existence of the project does not automatically give rise to a right to compensation, each case is considered on its own facts.

Affected owners are encouraged to seek advice from a suitably qualified chartered surveyor who can advise on their individual circumstances and the potential basis of any claim. Where a claim is eligible, Peak Cluster will reimburse reasonable and proportionate professional fees incurred in connection with the compensation process.

How will land be affected following the installation of the pipeline?

Once the pipeline is laid, we’d reinstate the land to its original use—for example for agriculture —wherever possible. We’d also reinstate farm tracks, fencing, drystone walls and hedgerows.

As with all major utilities, the pipeline would be protected by an ‘easement’ or similar legal arrangement. In broad terms, this means that new fencing, tracks or paths and some bushes may be built and planted directly above the pipeline but, in an area of land above the pipeline, it would not be possible to construct new buildings or to plant certain species of trees.

What approval and consent is required?

We are speaking with all potentially affected landowners about access to carry out surveys. When we have our final proposed route for the pipeline, we will speak to these relevant landowners about land rights.

For most land, we would simply require temporary possession to enable us to carry out construction, long-term rights of access and subsurface rights for the pipeline. We will aim to reach voluntary agreement with all landowners and will only seek to use compulsory acquisition powers (if granted to us within the Development Consent Order) where this is unsuccessful.

How will Environmentally Sensitive Areas, such as South West Peak, be impacted and protected?

The primary objective of Peak Cluster is to reduce the environmental impact of CO₂ produced by cement and lime production by capturing CO₂ and safely transporting it for permanent storage in stores under the East Irish seabed.

Throughout the development of the project, we are considering the environment. Our proposed route has, based on advice from bodies like Natural England and the Peak District National Park Authority, avoided the most sensitive habitats and landscapes wherever possible. We are continuing to refine our design to avoid, minimise and mitigate for any environmental harm.

This includes:

• Undertaking a comprehensive Environmental Impact Assessment as part of our project development to identify and address environmental considerations.
• Taking measures to minimise impact on the environment and sensitive habitats.
• Committing to increasing habitats for wildlife – known as biodiversity net gain – across the entire project area, including the Peak District and along the proposed route through Cheshire and the Wirral peninsula. We’re working in collaboration with local stakeholders, such as Nature North and local wildlife trusts, to identify the best ways to do this.
• After the pipeline is constructed, we would restore the land above to its original condition, including replanting or replacing any hedges, walls or fences.
• We would construct our new on-site carbon dioxide capture plants on brownfield land, wherever possible, and carry out construction and carbon capture operations in ways that protect wildlife and natural habitats.

Economics

Will CCS increase costs for the cement and lime industry?

For most industries in the UK and across Europe, there is now a cost to emitting carbon dioxide, which is delivered through the emissions trading scheme. The cost of emitting carbon through that scheme is forecast to rise substantially over time.

Not all governments around the world participate in this scheme, which means that the cost of materials from non-participating countries may be cheaper. To level the playing field, the UK government has introduced a carbon border adjustment mechanism (CBAM), which will come into effect from 2027. This will impose costs equivalent to those charged through the emissions trading scheme on imports from countries where carbon costs are not already in place. This means that from 2027, the cost of any imported material with high levels of embodied carbon (the amount of carbon created or used throughout the lifecycle of the material) will go up.

Cement and lime have high levels of embodied carbon due to the amount of CO₂ released during the manufacturing process and will be impacted by these price rises.

By capturing and removing carbon emissions from the cement and lime production process, this project will help to ensure that these British-made products remain competitive, both for UK markets and globally.

Is the motivation behind this project due to the fact that the companies involved will receive reductions in tax and financial rewards for their commitment to reaching net zero?

Without fitting CCS technology, the cement and lime industries would be subject to the total costs associated with the UK Emissions Trading Scheme. The UK Emissions Trading Scheme (ETS) is the UK’s key tool for driving toward Net Zero. Cement and lime

are critical products to the UK’s economy; so, to avoid the import of cheaper, but higher carbon alternatives, there is a Carbon Border Adjustment Mechanism (CBAM) which places an additional cost on materials being imported but with a higher carbon cost associated with their manufacture. The motivation is therefore to maintain an indigenous supply of cement and lime as well as driving down the carbon emissions associated with these industrial processes.

Sustainability

Is CCS the most appropriate and cost-effective method of disposing of this CO2 in this case?

Managing climate change will require a range of activities and technologies, which are all important. As part of our preliminary work to understand the best way to offset the carbon emissions from the cement and lime manufacturing plants, we explored a range of options, including capturing carbon through planting.

The carbon emissions from the cement and lime manufacturing process are around 3 million tonnes of carbon per year – almost all of which this project will eliminate from entering the atmosphere. Our calculations suggested that to get an equivalent carbon benefit to Peak Cluster through tree-planting, for example, we would need to plant trees across an area of the size of the Peak District National Park, roughly every two and a half years. The UK does not have that space available.

We also looked at different ways to remove carbon emissions from cement and lime plants to find the most efficient approach. The three options were:

1. Move the cement and lime plants to the coast. This would necessitate transporting the raw materials (e.g. limestone rock) from where they’re found naturally in Derbyshire and Staffordshire, by rail or road in many thousands of journeys.
2. Capture and transport the carbon dioxide emitted by road in trucks. The estimated number of truck movements added to the roads is 400 each day.
3. Capture and transport the carbon dioxide emitted via a buried pipeline.

Carbon capture and storage, the technology the Peak Cluster project will use, has been identified by the Committee on Climate Change as an essential component in the reduction of carbon emissions for large-scale, carbon-intensive manufacturing processes, such as cement and lime production.

After reviewing both, we decided that the option with the least disruption and the most long-term environmental and economic benefits was to build an underground pipeline to carry carbon dioxide from plants in Derbyshire and Staffordshire to a storage site under the East Irish Sea.

Why are you not able to reduce the amount of CO2 at the source or recycle CO2 on site?

Reducing the carbon dioxide: Peak Cluster will capture around 3 million tonnes of CO₂ from the cement and lime plants each year. The plants are located in an area where the

geology is such that the raw materials for cement and lime are present in these areas and hence are quarried and the processed close to where the rock is extracted. There are no stores in the area which would be able to store this level of carbon dioxide. However, the carbon store beneath the East Irish Sea has the capacity to safely hold around 1 billion tonnes of CO₂. For the four Peak Cluster cement and lime plants—capturing around 95% of their current emissions—it would take roughly 330 years to fill the store on their own.

Recycling the carbon dioxide: CO₂ is generated as the quarried rock is heated, which results in calcium carbonate becoming calcium oxide, with carbon dioxide being released to the atmosphere. Cement and lime are largely produced in the same way all over the world, resulting in the emission of carbon dioxide. Carbon dioxide in these volumes is difficult to recycle. Although there are uses for it in different sectors, it would need to be further processed, stored and then transported to the relevant industries. There are some projects looking at potential applications for use of CO₂, for example Holcim’s Lägerdorf plant in Germany where captured CO₂ will be repurposed into industrial raw materials, however, this application is not suitable for the scale of carbon produced by the Peak Cluster partners.

What is the lifetime of the pipeline?

The lifespan of the carbon capture facilities that will be installed at the cement and lime plants will vary depending on the technology chosen by the operators, but each facility will be operational for at least 25 years. The pipeline’s lifespan will significantly exceed this with appropriate monitoring and maintenance.

Can you provide an explanation of the decommissioning process, such as when you expect it to begin and how it will be undertaken?

The design life for the capture facilities is 25 years; this design life is an estimate and provides a reasonable timeline against which to assess impacts. However, the design life is not a specific deadline or milestone and there are numerous examples of infrastructure which, when maintained and operated appropriately can continue to function well beyond the design life.

To decommission the above ground infrastructure and capture facilities, the structures and materials would be emptied, where necessary, of any chemicals and fluids and then dismantled in a controlled manner.

Materials which can be re-used or recycled would be identified and separated from materials which would have no further useful purpose. Some of the infrastructure may be repurposed for other future uses.

How much CO2 can Morecambe Bay (MNZ) hold and how long do expect it to take to reach capacity?

The carbon store beneath the East Irish Sea has the capacity to safely hold around 1 billion tonnes of CO₂. For the four Peak Cluster cement and lime plants—capturing around 95% of their current emissions—it would take roughly 330 years to fill the store on their own.

Consultation and Decision-Making Why haven’t local or parish council’s been consulted individually on this project before or during the Phase 1 Consultation.

In November 2025, before we launched the phase 1 consultation, we contacted all host and neighbouring parish councils to make them aware of the project proposals to invite them to one of three online information sessions which were held on the 26th and 26th of November. Parish councils and their representatives were subsequently sent the following pieces of correspondence in the run-up to and during our phase 1 consultation:

• The first edition of our Peak Cluster newsletter – 3rd December
• An invite for parish councillors to attend one of our parish council focused phase 1 consultation webinars, grouped by county – 13th, 14th and 19th January
• Our general public webinar on 11th February
• Our phase 1 consultation launch email – 12th January
• The second edition of our Peak Cluster newsletter – 24th February
• A phase 1 consultation close reminder – 27th February

Throughout the project, we will continue to engage with parish councils to provide them with updates and opportunities to speak with us directly.

Does PC intend to use the extensive local knowledge held by local Councils, Councillors and Parish Councils to assist their decision-making?

Local authorities and parish councils are key stakeholders with whom we will continually engage throughout this process to seek their input Local councils, councillors and parish councils have, and will continue to be, directly invited to participate in our consultations.

Gawsworth Parish Council

Why has Gawsworth been chosen?

The route of the pipeline is an iterative process, and we anticipate that there will be changes to the final proposed pipeline route. This will be informed by the feedback we receive during our consultations and our ongoing environmental and engineering studies.

To develop the proposed scoping corridor, which will connect the cement and lime plants in Derbyshire and Staffordshire to the Morecambe Net Zero (MNZ) stores in the East Irish Sea, initially, the Peak Cluster and MNZ teams used publicly available data to identify and consider the best options.

We investigated the entire coastline from North Wales to Cumbria to identify suitable locations for the onshore pipeline to connect to offshore infrastructure. We then mapped any constraints (things that may influence the project location) between the capture plants and the potential shore areas. These constraints included:

• existing built-up areas
• topography
• ecologically designated sites
• scheduled monuments
• listed buildings
• other factors which are identifiable using national-level records and databases

When we completed this review and accounted for these constraints, we arrived at the route shown in the phase 1 consultation.

We recognise that national-level data alone cannot provide all the information that we need to finalise the pipeline route. That’s why we consulted at an early stage of the design process. The phase 1 consultation enabled us to gather important feedback from stakeholders, communities and landowners. We’ll use this feedback, alongside our ongoing environmental and engineering studies, to refine the route and develop more detailed proposals for the next stage of consultation. This will include:

• refining the potential pipeline corridor to 100m
• identifying more specific locations for aboveground infrastructure
• defining any temporary construction requirements, such as compounds and off-route access roads

Will Phase 2 of the consultation have a focus on Gawsworth?

We are still in the process of collating and reviewing all feedback from our phase 1 consultation. The feedback we have received during this initial period of consultation will help inform what we consult on later this year.

For a project like Peak Cluster, which spans over 200km and passes several towns and villages, it would not be possible to focus on the potential impact of one settlement over the rest. This being said, we did receive a large amount of feedback from residents of Gawsworth and best endeavours will be made to ensure an appropriate level of information is provided at our phase 2 consultation to explain how this influenced our design.

Throughout the project, we will work closely with communities and organisations to develop an approach that minimises disruption and impact, and ensures work is delivered safely and efficiently. We will listen closely to those who are interested or may be affected by Peak Cluster to hear their thoughts, views and suggestions and let you know how your feedback has shaped our thinking. We will consider all feedback carefully and assess how this might impact our proposed design. We will write a detailed report at the end of our consultation process, which will explain how the feedback has been considered.

Will the pipeline disrupt any water source?

We have identified a series of rivers, canals, and other waterways across our pipeline route, and as we work to determine the best route, we will seek to avoid as many of the waterways and water sources as possible.

However, where we cannot avoid them, we will undertake a thorough assessment for each of these, which will consider the best way to cross these rivers, canals, and waterways.

As it is a buried pipeline, it will most likely be placed beneath these crossings, but we will remain open to all options throughout our assessments.

Prestbury Parish Council

Their main concerns are with the destruction of local ancient woodlands and wildlife habitats. How will these be protected and restored if affected?

We will avoid sensitive habitats and ensure land restoration and increase biodiversity across the entire project area – including the Peak District and along the proposed route through Cheshire and the Wirral peninsula.

We will construct our new on-site CO₂ capture plants on brownfield land wherever possible and carry out construction and carbon capture operations in ways that protect wildlife and natural habitats.

After the pipeline is installed, the land above it will be restored to its original condition, including replanting or replacing any hedges, walls or fences. We will work carefully and in close collaboration with local stakeholders, using restoration activities to have a positive influence on the landscape.

What will you do to protect farms, farmland, livestock and will there be a loss of agricultural land?

The pipeline would be buried at a minimum depth of 1.2 metres to the top of the pipe, or below the depth of normal agricultural activity

Once the pipeline is laid, we’d reinstate the land to its original use—for example, agriculture, wherever possible. We’d also reinstate farm tracks, fencing, drystone walls and hedgerows.