Proposed Submission Development and Site Allocations (DaSA) Local Plan

Thank you for your email asking for comments on the Proposed Submission Development and Site Allocations (DaSA) Local Plan and its accompanying Sustainability Appraisal. SGN is preparing for the next Price Control Period (RIIO-GD2), due to commence 2021, and welcomes all input from Local Authorities that provides intelligence on proposed development within their respective areas. This information will assist us in identifying potential growth and associated reinforcement requirements.
SGN has carried out a high level assessment of the impact of developments contained within the Development and Site Allocations Local Plan ("DaSA") and the accompanying Sustainability Appraisal documents and can comment as follows:
NETWORK OVERVIEW
SGN's network within Rother area is energized by the South Local Transmission System (LTS) with and supported by the integrated IPMP system. Transmission Regulator Stations (TRS) are located across the center of the region, reducing pressure to the High Pressure (HP) Intermediate (IP) and Medium (MP) pressure systems. In some instances pressure is reduced from IP to MP by means of District Pressure Governors (DPG). In turn, the IP/MP systems are further broken down to Low Pressure (LP) systems directly supplying the majority of existing domestic customers.
STRATEGIC DEVELOPMENT AREAS
We have assessed our infrastructure and do not envisage any issues in general, however specific connection locations may require localized reinforcement. There is no new reinforcement required from the latest local plan or sites which may have significant impact, compared to the potential existing ones. SGN's infrastructure will not be severely affected from the additional developments described on the latest local plan.
Below is a short synopsis of the networks supplying these areas where reinforcement will may be required in the medium and long term.
For the Rother district, reinforcement of the IP/MP Grid will be required, if gas is to play a major role in meeting the energy requirements of any potential developments identified in the local plans. If said developments are phased as set out in the various LDPs, then the reinforcements will be necessary in ensuring that security of supply is maintained. It is of paramount importance to stress that the timelines and capacities that are quoted in the various LDP documents are not concrete and are, therefore, subject to change such as the reinforcements accompanying them.

STATUTORY OBLIGATIONS
Where required, SGN will look to manage the provision of any off site infrastructure improvements, in line with the overall development growth and/ or timescales provided. The full extent of these works will be dependent on the nature and location of the requested load(s), potentially requiring LP reinforcement in addition to that required for IPMP networks, and will only become clear once a developer's request has been received. Reinforcement solutions are likely to involve the provision of a new pipeline in parallel to SGN's existing mains system, but may also include the installation of above ground apparatus involving land purchase.
As this is a high level assessment and response, the information provided is indicative only and should be used as a guide to assist you on your assessment. While information obtained through consolation and / or engagement on Local Development Plans is important to our analysis, it only acts to identify potential development areas. Our principle statutory obligations relevant to the department of our gas network arise from the Gas Act 1986 (as amended), an extract of which is given below:-
Section 9 (1) and (2) which provides that:
9. General powers and duties
(1) It shall be the duty of a gas transporter as respects each authorized area of his:-
(a) to develop and maintain an efficient and economical pipe-line system for the conveyance of gas; and
(b) subject to paragraph (a) above, to comply, so far as it is economical to do so, with any reasonable
request for him -
(i.) to connect to that system, and convey gas by means of that system to, any premises; or
(ii.) to connect to that system a pipe-line system operated by an authorized transporter.
(1A) It shall also be the duty of a gas transporter to facilitate competition in the supply of gas.
(2) It shall also be the duty of a gas transporter to avoid any undue preference or undue discrimination -
(a) in the connection of premises or a pipe-line system operated by an authorized transporter to any pipeline system operated by him; and in the terms of which he undertakes the conveyance of gas by means of such a system.
SGN would not, therefore, develop firm extension or reinforcement proposals until we are in receipt of confirmed developer requests.
As SGN is the owner and operator of significant gas infrastructure within the Rother area and due to license holder obligations;
Should alterations to existing assets be required to allow development to proceed, such alterations will require to be funded by a developer.
Should major alterations or diversions to such infrastructure be required to allow development o proceed, this could have a significant time constraint on development and, as such, any diversion requirements should be established early in the detailed planning process.
SGN would therefore request that, where the Council are in discussions with developers via the Local Plan, early notification requirements are highlighted.
Additionally, SGN are aware of the advances being made in renewable technologies, especially those related to the production of biomethane. Should any developer be proposing to include such technology within their development, then we would highlight the benefits of locating these facilities near existing gas infrastructure. Again, where the Council are in discussions with developers via the Local Plan, we would hope that these early notifications requirements are highlighted.
Please let me know if the above information is sufficient for your requirements at present.