Since we formed the Gawsworth Residents Group, we have made formal representations to everybody with a legal role in the Peak Cluster approval process. Below is a plain-English record of each letter we have issued, who it was addressed to, and what we asked for — in the order we sent them.
All letters have been simultaneously placed on the Planning Inspectorate’s public project file for EN0710001 and copied to the necessary parties, so there is a permanent, public record of our engagement.
Letter 1: Formal Pre-Application Representation to Peak Cluster Ltd
Sent 25th March 2026 to Peak Cluster Limited (developer) Copies to: National Wealth Fund, Planning Inspectorate, Tim Roca MP, Cheshire East Council, HSE Gas and Pipelines Unit, Gawsworth Parish Council
Key demands:
- Publish the full documented alternatives assessment for Section 4 of the pipeline — specifically why a southern corridor avoiding Gawsworth was examined and found inferior, or if it was not examined, carry out that assessment immediately.
- Publish why the Above Ground Installation (AGI) cannot be sited outside the Green Belt. An alternative area would avoid the Green Belt entirely.
- Publish a societal risk (FN curve) comparison between the current Gawsworth route and the southern alternative, as required by BS PD 8010-3. The Gawsworth valley terrain can accumulate CO₂ in a leak event — this must be quantified.
- Address the proximity of the proposed AGI to Gawsworth Church of England Primary School and provide exclusion zone data for a loss-of-containment event.
- Publish a heritage setting assessment for Gawsworth Hall (Grade I listed), St James’ Church (Grade I listed) and Jodrell Bank Observatory (UNESCO World Heritage Site).
- Clarify which legislative regime governs Peak Cluster’s consultation obligations — the Planning Act 2008 or the Planning and Infrastructure Act 2025 (enacted 18 December 2025, mid-process).
- Confirm whether a dedicated Gawsworth-specific Phase 2 engagement event will be held, with detailed mapping, safety data and technical staff present.
- Deadline given: 28 days for a substantive written response.
Letter 2: Letter to Tim Roca MP — Request for Written Parliamentary Questions
Sent 26th March 2026 to Tim Roca MP, Member of Parliament for Macclesfield Copies to: Planning Inspectorate, National Wealth Fund, HSE Gas & Pipelines Unit
Key demands:
- Table eight Written Parliamentary Questions (WPQs) across three departments — DESNZ, HM Treasury/NWF, and the DWP (HSE sponsor) — before end of April 2026, so answers are on the public record before Peak Cluster’s alternatives chapter is finalised.
- WPQ 1 (DESNZ): What Statutory Instrument gives legal effect to the HSE’s reclassification of CO₂ as a ‘dangerous fluid’? Peak Cluster’s published FAQ says this was ‘announced’ on 12 March 2026, but no amending SI has been identified — this appears to be a material factual misrepresentation to the community.
- WPQ 2 (DESNZ): Will the Environmental Statement be required to include a documented assessment of alternative junction locations under Schedule 4 of the EIA Regulations 2017, and what steps is DESNZ taking to verify compliance before the application is accepted?
- WPQ 3 (DESNZ): Has Peak Cluster submitted a societal risk FN curve comparison between the Gawsworth route and any alternative? Will one be required as a DCO condition?
- WPQ 4 (DESNZ): Is the proposed AGI within the Cheshire East Green Belt, and what ‘very special circumstances’ analysis has Peak Cluster provided under NPPF paragraph 154?
- WPQ 5 (HM Treasury / NWF): Is the NWF’s factsheet — which describes Peak Cluster as ‘wholly owned by Progressive Energy Peak Ltd’ — still accurate? Companies House shows the NWF itself holds 25–50% of shares, and Progressive Energy Peak Ltd ceased to be a Person with Significant Control on 14 July 2025, seven days after the NWF announcement. The factsheet has never been corrected.
- WPQ 6 (HM Treasury / NWF): What due diligence did the NWF conduct on alternative route and junction location options before committing £28.6m of public equity? Was an independent engineering assessment of alternative junction locations carried out?
- WPQ 7 (DWP / HSE): Has the HSE been formally consulted by Peak Cluster on the proximity of the pipeline and AGI to Gawsworth Church of England Primary School? If so, what guidance was provided?
- WPQ 8 (DWP / HSE): Does the HSE consider that Peak Cluster has demonstrated ALARP compliance under HSWA 1974 in respect of route selection? Has the HSE received a quantitative risk assessment comparing the societal risk profile of the Gawsworth route with any alternative?
We explained to Mr Roca why Parliamentary Questions are the right mechanism for these specific issues: questions about NWF ownership structure and due diligence can only be authoritatively answered by DESNZ and HM Treasury, not by Peak Cluster itself. If the HSE has not been consulted on school proximity, that is a regulatory gap Parliament should know about. And crucially, written answers create a dated, public parliamentary record that becomes material evidence in the Planning Inspectorate’s examination of the DCO application.
We offered to meet with Mr Roca’s office to provide further technical briefing and enclosed our formal letter to Peak Cluster (25 March 2026) together with the peer-reviewed academic papers by Schueler et al. (Stanford University, 2026) and Wang et al. (2019) that underpin our safety arguments.
Letter 3: Formal Letter to the Health and Safety Executive (Gas and Pipelines Unit)
Sent 31st March 2026 to HSE Gas and Pipelines Unit, Aberdeen (Samantha Peace & Matthew Blackburn) Copies to: Planning Inspectorate, National Wealth Fund, Tim Roca MP, Cheshire East Council
Key demands:
- Use the HSE’s independent statutory role — separate from and alongside the DCO process — to require Peak Cluster to publish a full ALARP route comparison before any Safety Case is accepted.
- Require Peak Cluster to demonstrate, with published FN curve data, that the Gawsworth alignment is ALARP when compared against the southern alternative. The GRG’s analysis is that the current route scores worse on every applicable HSE metric: societal risk profile, proximity to population, terrain-induced CO₂ accumulation, AGI footprint, failure mode risk and emergency access.
- Note that CO₂ was formally designated a ‘dangerous fluid’ for pipeline design purposes by the HSE on 12 March 2026. This strengthens — and in the GRG’s view triggers — the obligation to carry out a full comparative safety risk assessment before the route is fixed.
- Confirm HSE’s position on proximity of the proposed AGI to Gawsworth Church of England Primary School.
- Note that the ALARP obligation under the Health and Safety at Work etc. Act 1974 (ss.2–3) and Pipelines Safety Regulations 1996 (Reg. 5) applies independently of the DCO process and cannot be satisfied by the DCO examination alone.
Letter 4: Formal Letter to Cheshire East Council (Host Authority)
Sent 1st April 2026 to Cheshire East Council — Chief Executive / Strategic Planning / Development Management Copies to: all ward councillors with wards in or adjacent to the pipeline corridor in Cheshire East, Tim Roca MP, Planning Inspectorate
Key demands:
- Discharge the Council’s Host Authority obligations under the Planning Act 2008 — actively and on the public record, not passively.
- Disclose the Council’s formal response to Peak Cluster’s EIA Scoping consultation (requested under the Environmental Information Regulations 2004 — 20 working day deadline).
- Formally represent to Peak Cluster and the Planning Inspectorate that Phase 1 consultation was inadequate: only six weeks, no confirmed route, no published safety data, and many residents unaware until days before the close.
- Write to the National Wealth Fund drawing attention to the failure to assess junction location alternatives — given the NWF explicitly relied on the DCO process to manage all environmental and governance risks.
- Require independent hydrogeological assessment of pipeline impacts on Danes Moss SSSI and the Gawsworth Hall fishponds before any route is confirmed.
- Require a heritage setting assessment for Gawsworth Hall, St James’ Church and Jodrell Bank Observatory before Phase 2 consultation.
- Hold a formal committee consideration of Peak Cluster and make its position publicly available to residents.
We noted that the Council’s window to influence the Environmental Statement is now — before the DCO application is submitted in September 2027. Active engagement at this stage is far more effective than representations made during the Examination, when the route will effectively be fixed.
What we are waiting for
As of the date of this blog post, the GRG is awaiting substantive responses from:
- Peak Cluster Ltd — 28-day deadline from 25 March 2026
- Cheshire East Council — 20 working day deadline under the Environmental Information Regulations 2004
- HSE Gas and Pipelines Unit — no fixed statutory deadline, but a response has been requested
We will publish an update when responses are received, and will make clear whether Peak Cluster and the Council have met their obligations. All correspondence is being placed on the Planning Inspectorate’s public project file for EN0710001.