Dear Supporters - this will take just a few minute of your time....

URGENT – WE NEED YOUR HELP- DEADLINE FOR OBJECTIONS TODAY MON 15th JUNE
THIS SHOWS HOW CCS PROJECT COSTS CAN SPIRAL AND WE, THE PUBLIC, ARE ASKED TO PICK UP THE BILL. 

The Hynet CO2 Pipeline Project / Liverpool Bay CCS Ltd have applied to OFGEM to recover nearly £1million of costs to be paid to them because a proposed HYNET pipeline spur to Runcorn’s Viridor Waste Plant was cancelled.

Liverpool Bay CCS Ltd are looking to recover costs associated with them taking part in Runcorn’s TCPA (Town and Country Planning Act) Masterplan consultations and also consultations relating to a solar farm planning application / DCO (development consent order) – the Cubico solar farm is planned for Ince Marshes in Frodsham.

They are looking to recover £926,437 - not for actually building anything, this is simply what could be termed "consultancy costs" for taking part in some planning applications and engagement with Viridor, Cubico and the Department of Energy Security and Net Zero (DESNZ)

So, Liverpool Bay CCS Ltd is asking Ofgem to fund a “Change in Scope Reopener” essentially saying that circumstances have changed since their original funding package and they wish to recover these further costs.

OFGEM is consulting on whether these costs are justified before making a final decision.

This highlights how assumptions underpinning CCS projects can evolve after initial approvals and funding arrangements have been agreed. It suggests that private companies may face limited financial consequences for inadequate upfront planning, as they can subsequently seek to have additional costs covered by OFGEM.

IF OFGEM APPROVE THESE ADDITIONAL COSTS OF NEARLY £1MILLION THE COSTS WILL ULTIMATELY BE PASSED ON TO US THE ENERGY CONSUMERS

If you wish to comment on the application to OFGEM please do so urgently, as the closing date is today 15th June.

A template email is suggested below, simply copy and paste or send your own email:

Email to: ccus@ofgem.gov.uk

Dear Sir/Madam,
Response to Consultation – Phase 2 Tranche C Draft Determination: Liverpool Bay CCS Ltd
I am writing to object to Ofgem’s minded-to position to approve Liverpool Bay CCS Ltd’s Change in Scope re-opener application and allow recovery of additional costs associated with the ongoing Runcorn TCPA Application and participation in the Cubico Frodsham Solar Project Development Consent Order examination.

While I recognise the importance of achieving the UK’s decarbonisation objectives and the potential role of carbon capture and storage infrastructure, I do not believe that the proposed cost recovery represents an appropriate balance between consumer protection and developer risk.

My concerns are as follows:

1. Insufficient justification for additional cost recovery
The consultation proposes that costs arising from changes in project circumstances be recovered through the regulated framework. However, it is unclear whether these costs could reasonably have been anticipated and managed by the licensee as part of normal project development risk. Without clear evidence that these costs are genuinely exceptional and outside the control of Liverpool Bay CCS Ltd, consumers should not be expected to bear them.

2. Weak incentives for efficient project management

Allowing additional expenditure to be recovered through the Change in Scope mechanism risks reducing incentives for cost discipline. Regulated re-openers should be used sparingly and only where there is compelling evidence that the expenditure is necessary, efficient, and unavoidable. Otherwise, there is a danger that developers will face limited financial consequences for project delays, planning complications, or changes in project scope.

3. Consumer protection concerns
Any increase in regulated allowances may ultimately be borne by network users and consumers. Given ongoing concerns regarding energy affordability and public expenditure associated with carbon capture and storage projects, Ofgem should apply a particularly high threshold before approving additional costs. I do not believe the consultation demonstrates sufficient consumer benefit to justify the proposed amendments.

4. Regulatory precedent
Approval of this application may establish a precedent for future Change in Scope submissions across the CCS sector. If costs linked to planning processes, stakeholder engagement, or project scope adjustments are routinely recoverable, there is a risk of progressive expansion of allowable expenditure without corresponding accountability.

5. Need for greater transparency
Before any approval is granted, Ofgem should publish more detailed information demonstrating:
• why the costs were unavoidable;
• what alternatives were considered;
• what proportion of the costs should reasonably be borne by the licensee;
• how consumers will benefit from the proposed expenditure; and
• how Ofgem has assessed value for money.
For these reasons, I urge Ofgem to reject the proposed modifications in their current form or, at a minimum, require a more rigorous demonstration that the expenditure is efficient, necessary, and in the interests of consumers before allowing recovery through the regulatory framework.

Thank you for considering my response.
Yours faithfully,
[Name]
[Address]

Thank you for your support