Southampton To London Pipeline Project - Abode Group

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SouthamptontoPipeline ProjectPlanning Inspectorate Reference: EN070005Ark Data Centres Limited – Written StatementInterested Party Registration 2002263714th November 2019London

Commercial in confidenceWritten StatementContentsIntroduction . 2Pipeline Location . 2Final Route Order Limits. 3VERSION HISTORYDocument Reference:Filename:D2 ReferenceUncontrolled Document191114 ADCL Written Statement v1Date13 November 201914 November 201914 November mmentsFinal for IssueCopyright 2019 Ark Data Centres Limited. All rights reserved.The information contained in this document: represents the view of Ark Data Centres as at the date of publication only; is provided on an‘as is’ basis without warranty as to its accuracy; may be subject to revision without notice; and does not constitute an offer to provide goodsor services or accept any duty of care to the recipient or any third party.Ark Data Centres and third parties may have patents, patent applications, trademark, copyright or other intellectual property rights coveringor relating to the information contained in this document. The issue of this document does not give the recipient or any third party anylicence to these patents, trademarks, copyrights or other intellectual property.Ark, Ark Data Centres, The Arks, ArkNet, Cody Park and Spring Park are trading styles of Ark Data Centres Limited, registered in England andWales number 05656968.Registered and Head office: Spring Park, Westwells Road, Hawthorn, Corsham, Wiltshire, SN13 9GBPage 1 of 4Commercial in

Commercial in confidenceWritten StatementIntroduction1. This Statement is prepared by Ark Data Centres Ltd (Ark). Ark is registered as an interestedparty (ref. 20022637) in connection with the Southampton to London Pipeline ProjectDevelopment Control Order (DCO).2. The Inspector will be aware of Ark and its interest in the pipeline project from previousconsultation responses. As part of the consultations run by Esso Petroleum Company, Arkprovided comments as part of the corridor (April 2018) and route (October 2018)consultations and, since acceptance of the development consent order application by thePlanning Inspectorate, registered as an interested party (June 2019) and requested to appearat a Compulsory Acquisition Hearing and/or an Open Forum Session (October 2019).3. Ark and its group companies are the owner, developer and operator of the Cody Park DataCentre campus which sits to the north of the Cody Technology Park on the edge ofFarnborough. The existing pipeline passes to the south of Cody Technology Park and theproposal is for the new pipeline to continue to be located to the south of the Park.4. The project raises two main concerns. The first is the alignment of the proposed pipeline whichhas been the focus of our comments on the project so far. The second is the way in which thepipeline might be delivered or managed – with specific reference to issues of land control oracquisition (and the CPO powers sought).5. Neither of Ark’s concerns have been considered. This is not a criticism of either the EssoPetroleum Company or the Planning Inspectorate but is a quite understandable reflection ofthe vast range of considerations and the fact that Ark’s concerns relate to a very limitedstretch of the route and it is expected that once these issues are considered they will beaddressed to Ark’s satisfaction.Pipeline Location6. For obvious reasons, and up to this stage, Ark’s principal concern was the precise route of thenew pipeline. Once a corridor was identified that was centred broadly on the currentalignment, Ark’s objective has been to ensure that the Preferred Order Limit (and associatedPreferred Limits of Deviation) were drawn as tightly as possible and that the Possible PipelineLocation was located at the southern part of the Limits of Deviation. This would ensure that itis south of the Existing Pipeline and as far as it could be from the Cody Park Data Centrecomplex.7. Fortunately, the project’s sponsors have been able to respond positively and the proposedlocation or alignment of the pipeline, is now in the best location it can be. The map belowshows the various pipeline locations:Page 2 of 4Commercial in

Commercial in confidenceWritten Statement8. This is an extract from the Interactive Map on the Pipeline Project’s website and it shows TheFinal Route Possible Pipeline Location (number 3) as far south within the Preferred Limits ofDeviation as possible. This means that it is south of the Existing Pipeline (no.1) and thePreferred Possible Pipeline Location (no. 2) that was subject to consultation in Autumn 2018.9. If Ark were to appear at examination, it would be to reiterate the importance of the alignmentof the route as proposed (no.3) and to re-emphasise the concerns associated with analignment closer to the Technology Park.Final Route Order Limits10. The way the pipeline is delivered and operated (and the land rights that are secured inassociation with the project) are also of concern to Ark. This is a straightforward point andcomes from the need to ensure that Ark’s Date Centre campus operates reliably and securely.This is especially important for modern data centres where reliability and security areparamount to successful operation.11. Arks’ concerns in this respect come from the CPO plans and documents which describe thearea shown in blue below as land that will be affected by the CPO:12. It is not clear how the extent of the CPO area has been defined but from the approach takenelsewhere along the route it is likely that it is based on a fixed distance either side of theproposed pipeline rather than site specific analysis of operators that adjoin the pipeline.13. Whilst Ark is sure that there is no intention to this, work in the blue area could have thepotential to disturb operations at the Data Centre Campus, because it includes about 25% ofPage 3 of 4Commercial in

Commercial in confidenceWritten Statementthe communications cables serving the Data Centre campus, Victor Way which provides roadaccess to Ark’s campus, and the northern perimeter fence of Cody Technology Park.14. Furthermore, the DCO powers sought in this area include the ability to acquire and dischargeeasements. Ark would request that access or the provision of services to the Data CentreCampus are not at any time materially adversely affected by the exercise of the DCO powersand that appropriate qualifications are imposed in any development consent order in so faras it affects the Data Centre Campus:a. Preventing the extinction of any existing rights of access (via private land or publichighway) that benefit the Data Centre Campusb. Preventing of the creation of any rights of way or other new easement over the DataCentre Campus in favour of any third party other than the pipeline operator.c. Ensuring that any new easement created (i) does not materially adversely affect thesecurity of Data Centre Campus and (ii) is subject to Ark’s site access protocolsd. Ensuring that no easement may be extinguished or diverted without there first beingprovided at the cost of pipeline operator a suitable alternative easement withassociated new conduits cables etc.e. Ensuring that no less than six months’ prior notice is given prior to the diversion orextinguishment of any easement.15. We also note that there is an area shaded yellow immediately outside the Ark security fenceand the Data Centre Campus entrance date that may be used as a construction compound. Inconnection with this Ark would request that:a. The compound is kept tidy and properly fenced and managed.b. An appropriate stand-off between the compound and the Ark security fence ismaintained; ideally the compound itself would be located at least 3.5m from thesecurity fence.16. It may be the case that the Order Limits can be easily changed (which appears to havehappened to the West of Cody Park already).Page 4 of 4Commercial in

1. This Statement is prepared by Ark Data Centres Ltd (Ark). Ark is registered as an interested party (ref. 20022637) in connection with the Southampton to London Pipeline Project Development Control Order (DCO). 2. The Inspector will be aware of Ark and its interest in the pipeline project from previous consultation responses.

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