“NO WAY WITHOUT AN EIA” – A Quick Guide to Southannan Sands SSSI & the Peel Ports Decom Proposal

 Postcard Signing Briefing Paper: Friends of The Firth of Clyde – No Way Without an EIA #SaveSouthannanSands

Read the full briefing document here>>>

Postcard Guide

 

What does the Briefing Say?

The sea shore from Fairlie to Portencross is very important for the welfare of the environment and the native wildlife.

It has been designated a SSSI – Site of Special Scientific Interest because of its importance to the Clyde environment.

The sea shore is a very gradual slope out towards the deep water channel which the large ships navigate – this makes the tide come in and out at Southannan Sands SSSI very gently – which in turn makes the perfect environment for protected species to grow including:

  1. Seagrass– we have the rarest protected form here, called Eel Grass and it is the only remaining Seagrass Meadow on the Firth of Clyde
  2. Shellfish – We have some very rare and protected shellfish here. Because of this the waters are also designated as Protected Shellfish Waters (PSW).

Both the seagrass and shellfish anchor to the seabed, trapping the intertidal sediments. This makes a perfect habitat for breeding fish and  provide a safe fish nursery. The baby fish provide food for the birds, which is why the area is visited by a huge range of birds including rare migratory birds, and is of interest to bird charities. Having a safe nursery for fish is also fundamental for larger marine life such as the seals, porpoise, dolphins and even killer whales we enjoy in the Clyde. We have our own world famous dolphin ‘Kylie’ who lives close to Hunterston and researchers have found she speaks porpoise!

We are in a Climate Emergency. Seagrass is one of the best carbon captures and Southannan Sands SSSI is a very rare Natural Blue Carbon Sink, which is 30-40 times more effective than the rainforest. There are charities and researchers dedicated to saving and growing seagrass, because of its fundamental importance and the fact that it is at massive threat from irresponsible developersacross the world.

Peel Ports have been working on plans to bring decommissioning of oilrigs and other marine vessels to Hunterston – slap bang in the middle of the SSSI since 2012.

It is an extremely complex planning decisionas there are so many government bodies involved and has the potential to negatively impact on the health and safety of residents, road traffic, heavy goods transport, marine life, fishing industry, leisure and the natural environmentas well as the future of our protected SSSI.

In a project as complex as this it is necessary to undertake an Environmental Impact Assessment (EIA)to understand the wider and cumulative effects of the development and what risks they pose.

In 2018, North Ayrshire Council (NAC) approved the land-based planning permissions without calling for an EIA, despite advice provided by other government regulators. We had a QC examine the process NAC undertook and he was highly critical.

In July 2019, the Scottish Environmental Protection Agency (SEPA) granted a Waste Management Licence to Peel for the decommissioning, which allows them to handle 1,000’s tonnes of very dangerous materials such as asbestos, PCB’s (which make holes in the ozone layer), rotting organic marine matter and radioactive waste. We have lobbied hard against this licence as Peel have applied for a blank cheque to handle anything and everything, and we’ve witnessed their appalling attitude to health, safety and the environment over the years, so we have little confidence.

In order to bring in the oilrigs, the area needs to be dredged to create a deep marine channel. The dredging will have significant environmental effects. In recent years the Largs Yacht Haven silted up and needed to be dredged. It is not a protected area, yet it required an EIA before the works began! The marine environment is dynamic and one change can have significant knock-on effects.

Dredging has a number of known knock-on effects:

  • The dynamics of the tidal energy are changed. The shellfish and seagrass only survive in low energy tidal environments; this risks destroying the seagrass meadow.
  • Digging up such a large amount of the seashore releases toxins trapped in the sand (including a lot of coal dust from the badly managed coal yard) as well as churning up the seabed. These toxins are then free to move through the waters and release the carbon stored in them.
  • Both Seagrass and Shellfish are sensitive to suffocation from this activity.

In addition, the water treatment works that will manage the large amounts of water used to clean and decontaminate the scrap from the site will pump the wastewater back into the waters of SSSI.

  • Without an EIA there be no assessment of the impact of this on the SSSI and the extremely sensitive active shellfish site that needs clean waters to survive.
  • Without an EIA there will no assessment of the negative cumulative effects on the Protected Shellfish Waters and nearby bathing beaches of combining the oilrig project with the additional proposals for fish farms by Great & Wee Cumbrae.

Peel Ports have used the number of licences and regulators to their advantage and over time have slowly extended the scope of the project. This is a well know strategy called ‘salami slicing’. When the land based planning was approved Peel had stated 200,000m3 of the seabed would be dredged. They then applied to Marine Scotland for removal of  2.4million m3!! And when that caused uproar they reduced their application to 615,000m3 which is still massive.

In addition they have changed their application to build a larger dock. Over the licenses we have witnessed crazy requests, major inaccuracies and false statements, with new changes creeping in constantly… that would give Peel free reign to operate as they want.

We know from the experience of communities in the North West of England that this is how large scale controversial Peel projects are implemented without full environmental scrutiny and at the expense of the communities and environment that live with the impacts for generations.

Last week Scottish Natural Heritage declared the SSSI at Menie Dunes in Aberdeenshire DESTROYED by irreparable damage caused by the Trump International Golf Course. Another irresponsible billionaire that lives off shore and promised jobs in place of the environment that never transpired.

We CANNOT let this happen to Southannan Sands SSSI.

This project involves the dismantling of huge quantities of dangerous materials in the marine environment, massive dredging, pile driving, huge increase in HGV road transport, massive quantities of polluted waste water, serious noise impact to residents and marine life, impact on tourism, fishing, leisure.

It should not go ahead without and Environmental Impact Assessment.

Marine Scotland are currently deciding if this is necessary and we need your help!!

THIS IS URGENT and we need you to send a post card and / or write to them in the next week: marinescotland@gov.scot.

 

 

#SaveSouthannanSands Needs Your Support Now! Send a letter to Marine Scotland today to tell them “SAY NO WAY WITHOUT AN EIA”

We are calling on everyone concerned about protection of the environment to email Marine Scotland NOW to tell them “NO WAY WITHOUT AN EIA!”

Marine Scotland (MS) have been asked by Peel Ports to provide an
Environmental Impact Assessment (EIA) Screening Opinion of their
plans to undertake marine dredging and construction work at
Hunterston. The site is in the immediate vicinity of Southannan Sands
Site of Special Scientific Interest (SSSI) which a rare seagrass
meadow, natural carbon sink and home to a number of OSPAR protected
species. You can read the letter we have written to Marine Scotland this week calling for an EIA by clicking here>>>

WHY IS THE EIA SCREENING OPINION SO IMPORTANT?

An Environmental Impact Assessment (EIA) is a tool used to assess the
significant effects of a project or development proposal on the
environment. EIAs make sure that project decision makers think about
the likely effects on the environment at the earliest possible time
and aim to avoid, reduce or offset those effects. This ensures that
proposals are understood properly before decisions are made.

The ‘Screening Opinion’ is the first stage of the EIA process which
decides if an EIA is required. You can find out more by clicking to
the mygov.scot website here >>>

HOW CAN YOU HELP?  We need as many supporters to reach out to Marine Scotland and tell them NO WAY WITHOUT AN EIA!

Email marinescotland@gov.scot  / ms.marinelicensing@gov.scot with the following message:


Dear Marine Scotland,

Both the Scottish Government & North Ayrshire Council have declared a climate emergency. The Southannan Sands SSSI is a protected zone because of its fundamental role in sustaining the environment and protecting the planet. From being a marine nursery to a carbon sink and home to a number of highly protected species. 

The Peel Ports application at Hunterston now poses a major threat to the environment. 

Mistakes have been made in the past as highlighted by the Friends of the Firth of Clyde QC. Even the Scottish Government has indicated the previous EIA Screeing was ineffective and could invite legal challenge. 

The plans have changed for an even more destructive project and we demand an EIA is undertaken. 

The SSSI at Menie has been destroyed by irresponsible developers, we must not allow this to keep happening! 

I support the Friends of the Firth of Clyde to #SaveSouthannanSands 

Yours Faithfully,  XXXXX


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Saturday 27th July 2019

“NO WAY WITHOUT AN EIA!” – FoFoC Write to Marine Scotland Calling For An Environmental Impact Assessment of Hunterston Plans

Following the shocking revelations about Peel Ports revised plans for dredging Southannan Sands SSSI . We now know that Peel Ports have submitted a request for a new EIA Screening Opinion to Marine Scotland (MS) and we have consulted with our QC and written to Marine Scotland calling for them to exercise their powers to require an EIA before any dredging or construction consents are granted.

Despite written assurances from Marine Scotland that FoFoC would
be kept informed of licence application developments; a number of
meetings with representatives of North Ayrshire Council (NAC), Peel
Ports representatives being asked directly about progress at the
Public Master Plan Exhibition in Fairlie; our public meeting in
Largs and the first meeting of the Hunterston Liaison Committee being held on 18th March 2019 both the FOFOC and Fairlie Community
Council remained completely unaware of these developments until FoFoC told them what we had discovered.

We have written an open letter to Marine Scotland (MS) which you can read in full below:

URGENT LETTER TO MARINE SCOTLAND

OUR MESSAGE TO MARINE SCOTLAND:

“NO WAY WITHOUT AN EIA” #SaveSouthannanSands

THE ORIGINAL DECISION  TO NOT REQUIRE AN EIA WAS FUNDAMENTALLY FLAWED AND A ‘SALAMI-SLICING’ STRATEGY IS BEING USED TO GET PLANS THAT ARE MUCH BIGGER IN SCALE AND SCOPE THROUGH THE PLANNING AND REGULATORY SYSTEM.  THIS NEW SCREENING ASSESSMENT PROVIDES THE OPPORTUNITY FOR PREVIOUS ERRORS AND OMISSIONS TO BE RECTIFIED AND WE CALL ON MARINE SCOTLAND TO ACCOUNT TO UNDERTAKE A FULL OBJECTIVE ANALYSIS OF THE  SIGNIFICANT AND CUMULATIVE IMPACTS OF THIS PROJECT AND REQUIRE A ENVIRONMENTAL IMPACT ASSESSMENT.

Friday 26th July 2019

Outrage At Freedom Of Information Request Revelation That Peel Ports Intended To Dredge 2,400,000m3 Of Sand Adjacent To Southannan Sands SSSI

The Friends of the Firth of Clyde (FOFOC) are OUTRAGED to discover that Peel Ports submitted a marine license applicationto Marine Scotland (MS) to dredge from the area of Southannan Sands Site of Special Scientific Interest (SSSI) that included dredging TWELVE TIMES the volume of sand that was declared by them in the Public Pre-Application Consultation (PAC) Event on 8th August 2018.

We thought there was nothing left to SHOCK us about the lengths to which Peel Ports will go to push their plans through the planning and licensing system without an Environmental Impact Assessment,  but  we were wrong having been HORRIFIED to learn this week through a Freedom of Information (FOI) request to the Scottish Government that Peel Ports submitted plans to MS in October 2018 to…

… dredge 2,400,000m3 of sand from the area adjoining  the SSSI, NOT  the previously advised 200,000m3 … this is TWELVE TIMES the volume of sand outlined in the plans presented to the public during the consultation process …

… This is equivalent to the volume of a tennis court 6miles high …

… This vast amount of dredging will do unknown damage to the Southannan Sands SSSI…

The FOI also reveals:

  • £10million of grant funding was awarded by Scottish Enterprise (SE) to Peel Ports for the decommissioning site in October 2018 despite MS knowing that the marine licence application contained serious deficiencies, which would lead to it being rejected. FOFOC Question: What due diligence was undertaken by SE before they granted £10million of public funding?
  • Marine Scotland met with Peel Ports on 23rd November 2018 to discuss the significant differences between work now being proposed and that which had been included in the original environmental screening which ruled out an EIA. This resulted in Peel Ports withdrawing their application pending a new application. FOFOC Question: Why was this new dredging figure not enough the trigger an EIA & why was this information not made available to MSP Ross Greer when he submitted questions to the Scottish Govt?
  • On the issue of ‘salami slicing’ NAC is known to have recommended to Peel Ports the approach of splitting the planning application for oil rig decommissioning in to three separate parts. FOFOC Question: Who made this decision and why?
  • The Scottish government received four requests for review of the screening opinion around August 2018. FOFOC Question: why did it take until 19th February 2019 – ie: the day before the FOFOC public meeting in Largs for the complainants to be notified of the decision to uphold NAC’s decision not to require an EIA? 
  • The Scottish Minister for Local Government, Housing and Planning
    was advised that the environmental review, undertaken by Envirocentre on behalf of Peel Ports, did not include Hunterston Port (ie the 400m Coal Jetty) as it was not part of the Hunterston proposals. If it had included the Port an EIA would have been required. However we know that Hunterston Port IS integral to Peel Ports’ proposals and this was known at the time – it’s use for ‘asset preparation’ was included in the WML application to SEPA (also submitted in October 2018) and featured front and centre in the infamous CessComDecom marketing video. Additionally, at the recent 20 year Master Plan public exhibition a number of residents were told by Peel Ports representatives that as the Harbour Authority they “can do what they want at the port”, including the storage of oil rigs awaiting decommissioning. FOFOC Question: why would this information not be included in the report for the minister?
  • The Scottish Government know there is significant public interest in the developments at Hunterston and they are aware of our Crowd Funding  to fund a legal challenge should it be needed. FOFOC Question: how can the authorities know so much about our activities whilst at the same time we know so little about theirs?
  • The Scottish Government have effectively side-stepped scrutiny of the original decision not to require an EIA and have handed responsibility to Marine Scotland for managing what is clearly the thorny issue of an EIA . Question: FOFOC Why are the Scottish Government and North Ayrshire Council so reluctant to require an EIA for the development of Hunterston. Surely it makes good sense to apply the precautionary principle?
  • The advice on which the Scottish Govt decision to support NAC’s original screening decision was based refers to the likelihood of legal action being taken by Peel Ports if the original decision was not upheld, and by community bodies if it was. FOFOC Question: Were Peel Ports regarded as a bigger “threat” in this regard and was this the overriding factor in the Scottish Government making the decision to uphold the original screening decision?

Read the FOI in full here:

NB: hover cursor over the bottom of the document to reveal click for next pages

EIR Request - Hunterston - Response letter - David Telford - Final_Redacted-2

 

So, what is our current understanding of the Marine License position?

  • Having rejected Peel Ports’ marine licence application, which was based on 2,400,000m3of dredged material, MS required new plans, along with a new EIA Screening request,to be submitted by Peel Ports (source of information – Scottish Government response to FOI requests)
  • A new EIA screening request with supporting plans and information has been submitted. These appear to indicate that the volume of dredged material now anticipated is 615,000m3 (still THREE TIMES greater than originally stated), whichwill be “produced as a result of dredging the approaches to the hammerhead quay (estimated 423,000m3) as well as the new caisson gates (estimated 192,000m3 tonnes)” (source of information – Marine Scotland website)
  • In the absence of any further publically available information we can only surmise that Marine Scotland are still considering the new screening request and are therefore still deciding whether to require Peel Ports to undertake an EIA.

What are we doing next?

We have written to Marine Scotland asking them to confirm that our understanding of the current position as stated above is correct and to let us know when they expect to issue their screening opinion.

Thursday 11th July 2019

The Scottish Planning & Regulatory Authorities Must Step Up To Protect Southannan Sands SSSI & The Communities That Surround Hunterston PARC

Following the publication of Peel Ports’ 20 Year Master Plan we have written to all the Scottish planning, regulatory and licensing authorities, along with local and national elected representatives, to tell them that the Friends of the Firth of Clyde (FOFOC) hold them responsible for the protection of Southannan Sands Site of Special Scientific Interest (SSSI) and the health and wellbeing of surrounding communities that will live the wider consequences of the development of Hunterston PARC for generations to come.

We also sent them a copy of the excellent response from West Kilbride Community Council which clearly articulates numerous issues of concern.

You can read both the FOFOC and West Kilbride Community Council letters in full below:

  1. FOFOC Letter to: Scottish Environmental Protection Agency / Marine Scotland / North Ayrshire Council / Crown Estates / Clyde Marine Planning Partnership / Scottish Enterprise / Scottish Natural Heritage / MSPs / Scottish Parliament 

 

The Friends of the Firth of Clyde - Message to Regulatory & Planning Authorities Re: Hunterston Parc - Peel Ports 20 Year Master Plan Public Consultation

 

2. West Kilbride Community Council Response to Peel Ports 20 Year Plan:

 

WKCC response to Peel Ports - end

 

We encourage all our supporters to keep reminding elected, planning, regulatory and licensing officials of their moral and statutory responsibilities to safeguard our local communities and protect the precious natural environment from reckless profiteering by Peel Ports.

 

Friends of the Firth of Clyde Formal Response To Peel Ports’ 20 Year Master Plan

On 28th June 2019 Peel Ports concluded their 6 week consultation on the ’20 Year Master Plan for Hunterston PARC.

We mobilised on a number of fronts by leafletting residents, conducting our own survey ; numerous supporters attended the public exhibitions in Fairlie and Milport and we concluded by sending daily emails to local councillors in the week running up to the North Ayrshire Council (NAC) Planning Meeting at which NAC’s formal response was to be agreed.

Below you can read the our formal written response on the 20 Year Master Plan sent to Peel Ports on 28th June 2019:

FOFOC Response to Peel Consultation 28June2019

Soberingly, we submit our response in the week that Scottish Natural Heritage (SNH) recommend that Menie links be removed from an existing site of special scientific interest (SSSI) as the controversial Trump golf course within which they are sited has damaged and “destroyed” one of the best examples of moving sand dunes in Britain, developed over 4,000 years.

A sincere thank you to everyone for your continued support and commitment to protect Southannon Sands SSSI and safety and wellbeing of the surrounding communities.

Friends of the Firth of Clyde Objections to North Ayrshire Council Adopting Peel Ports 20 Year Master Plan

North Ayrshire Council (NAC) Planning Committee will meet to ratify their response to Peel Ports Master Plan Consultation on Weds 19th June 2019.

You can access the response from NAC through this web link  https://north-ayrshire.cmis.uk.com/north-ayr…/Document.ashx…

We have very serious concerns about the weakness of NAC’s response and how will set the course of future planning decisions, particularly in the context of the stated intention of NAC to support Peel Ports to align with the ’emerging’ Local Development Plan (LDP2). 

“Para1.12 indicates the Master Plan is not an application for planning permission,  but provides a framework for setting out the port’s medium and long-term aspirations. LDP2 recognises that for Strategic Development Areas, masterplans may be either prepared by the planning authority or by another party. LDP2 makes it clear that only limited weight will be attached to proposals that have not been approved by Council as planning authority. We are happy to work with Peel Ports Group to explore how a revised Master Plan may be considered for support by the Council”.

Given the scale and influence of Peel Ports as part of the multi billion£ company Peel Group, a fundamental question is how will NAC ensure that the safety and wellbeing of the local community and the natural environment are protected. 

We have been writing to our elected counsellors and NAC officials every day over the past week to raise their awareness and stress our serious objections to Peel Ports Master Plan being adopted and the weakness of North Ayrshire’s response – you can read our emails below:

Email #1 – Thursday, June 13, 2019  

Subject: NAC Response to Peel Ports Master Plan Consultation 19 Jun 2019 Planning Committee

Dear Councillors,

We note that next week you will be asked to endorse the NAC response to the Peel Master Plan.

As respected Councillors who represent your communities, we ask for some time to outline our thoughts on the Peel Master Plan and to demonstrate the inadequacy of the response as currently prepared.

Our biggest concern is section 19 -where the council are indicating they will Approve, Support and Adopt the Peel Master Plan. The quality and the detail of the Master Plan is so poor, any endorsement would be a failure of governance. In case you have not had chance to read the Master Plan -it amounts to 110 pages – and only 9 pages detail what their plans are!

The plan is full of empty promises, which seem not to have been robustly evaluated by NAC. NAC in the executive summary para 2.5 state the redevelopment could support OVER 1,700 jobs. Peel were in the community last week and have stated, there are no operators, they know very little about the industries they are promoting as they are only planning to be the landlord. In fact the Master Plan is so flawed with basic errors it is obvious they have done limited research and have limited grasp of the industries. It is WHOLLY WRONG to state this could create over 1,700 jobs. If all these embryonic ideas eventually came to fruition we would be delighted to see job creation. However Peel know and we know that they will never deliver all of these and actually the industries proposed are completely incompatible with each other.

Friends of the Firth of Clyde welcome safe and sustainable economic development. To demonstrate our dedication to this we are at the moment working on alternative suggestions for Peel. We were heartened when it was mooted that the site was going to be used for high tech renewable and green energy. This is a perfect solution to harness the benefits of the connectivity to the grid, the western link and the skills and knowledge already available at Hunterston Parc. HOWEVER – this Master Plan could not have been further from this vision. In para 2 NAC reiterates its vision – to seek to be bold, innovative and pioneering. None of these aspirations are met with this plan.

Scotland has declared a Climate Emergency and rightly so. Liquid Natural Gas or methane is a fossil fuel, in abundance in the global market currently due to fracking! Although it burns cleaner than coal, the whole environmental cost is similar to coal. On a moral and ethical stance, we do not believe it would be appropriate to ban fracking in Scotland, but endorse the import from developing an other countries to their environmental cost. In fact today Ross Greer asked the First Minister this very question in Holyrood – please watch the 1 min video :

https://eur03.safelinks.protection.outlook.com/…

NAC state one of their main concerns is the tone of the section on Socio Economic Study – we find this surprising! This plan threatens the 10% or 4,000 local jobs in tourism. It threatens life – as the plans are totally incompatible with each other and unsafe and it threatens the environment. The tone of a report in inconsequential!

We must seek to be bold, innovative and pioneering for the good of NAC, and for this reason we suggest you reject this form of the response. Plans of this level of complexity and threat must be understood in far greater deal. NO ENDORSEMENT, APPROVAL or SUPPORT must be given.

Email #2 -Friday, June 14 2019 

Subject : Re: NAC Response to Peel Ports Master Plan Consultation 19 Jun 2019 Planning Committee

Dear Councillors,

*********** in agreement that the Masterplan MUST BE REJECTED, however we differ in our opinion to the NAC response.

We believe the NAC response is very weak, and on multiple occasions references the main concerns being the negative tone of the socio economic section. WOW! It totally fails to recognise the major safety concerns.

Friends of the Firth of Clyde and residents throughout the region are extremely alarmed at the SAFETY AND ENVIRONMENTAL RISK. Peel were all too quick to rush to the papers, predicting a housing boom. The LNG plans may indeed result in a EXPLOSIVE BOOM, but nothing NAC would want to associate with!

You only need to google LNG and accidents to find horrific stories. However we have a resident expert in Fairlie, how not only has a PhD in explosive Chemistry and a lifetime at ICI Ardeer, but has personally been the lead investigator to an LNG accident when a tanker ran aground.

Some LNG facts:

-LNG is Methane Gas – a Fossil Fuel, it is often ‘Fracked’ Gas, that is cooled to -165°C to make it a liquid and easier to transport. It is NOT carbon neutral.

-LNG is highly dangerous, if spilled it freezes, asphyxiates and is highly explosive especially when spilled on water, this puts residents in Fairlie Bay at direct risk.

-Disaster modelling shows asphyxiation occurring within 500m and explosion impact on buildings and people up to 3500m.

-The LNG terminal will be 400m from Southannan Estate and the majority of residents of Fairlie are within 1300m of the storage site.

-Four nuclear reactors, including those with cracked graphite bricks, which have been assessed as vulnerable to seismic risk, are within just 2400m of the terminal.

-The CCGT Power Station at Carrington cited by Peel uses 2.5 million tonnes of LNG per year – this is not compatible with Zero Carbon by 2050

-In the US LNG tankers are escorted by armed guards and helicopters due to the terrorist risk. Oil tankers have been attacked today, so this is no inconsequential risk!

-Maritime traffic will be subject to disruption and controls as an exclusion zone of approx. 2 nautical miles around LNG tankers coming and going each week. What impact with this have on ferries, fishing, tourism?

-There are significant infrastructure deficits at Hunterston:

The Scottish Government and Peel know the jetty is not suitable for this activity – as referenced in the Atkins Report attached. In fact this report rejects Hunterston as a location for LNG for a number of reasons in preference for alternative locations! The case study and Master Plan reference Hunterston as a distribution site with LNG leaving by road tanker.

We are calling on you as our elected representatives to take personal responsibility for being fully informed about the implications of bringing LNG to Hunterston PARC and hold you to account to put the wellbeing and safety of the communities you serve; the environment of Scotland and the future of our planet first. We are shocked and confused at the combination of activities they are proposing.

In the week it is announced that the UK will put into statute becoming Net Zero Carbon by 2050 the prospect of our community being subjected to Peel Ports proposals to locate a Liquid Natural Gas (LNG) Terminal and Power Station at Hunterston PARC horrifies us.

We urge you to exercise your duty to apply fully informed scrutiny of the impact of Peel Ports 20- year Plan on the safety and wellbeing of the surrounding communities and the wider environment.

We’ve done hours and hours of research, to allow us to form balanced opinions. A quick factual guide to LNG is this video: https://www.youtube.com/watch?v=uBAgvXPw1aI&t=4s

Email #3 – Sat, Jun 15, 201

Subject : Re: NAC Response to Peel Ports Master Plan Consultation 19 Jun 2019 Planning Committee

Dear Councillors 

Re: Destruction of Southannan Sands Site of Special Scientific Interest as a result of the Peel Master Plan.

Yesterday we wrote to you with our concerns over the LNG terminal and power station. Today we want to highlight the risks to Southannan Sands Site of Special Scientific Interest (SSSI) from the irreparable damage that will be caused by dredging and pollution from these proposed works.

You will be aware that the dry dock is derelict and requires substantial construction work, including the dredging of HALF A MILLION TONNES OF SSSI! The LNG terminal also requires substantial dredging as LNG tankers are the size of aircraft carriers -dredging is indicated in the case study we sent yesterday.

The SSSI is protected for a reason and has a number of notable environmentally threatened and important features. Here are 2 features to paint a picture:

  1. Seagrass – MSP Gail Ross (only 3 mins) describes the importance of sea grass for climate change, and the food chain here!  https://www.scottishparliament.tv/meeting/members-business-world-environment-day-2019-june-13-2019?clip_start=13%3A20%3A29&clip_end=13%3A24%3A03&fbclid=IwAR0bE60tiOv5w-zf30oc89eQoPz-R-IRnYNn_kOFGJ_Jw8W2g-0DFJdA5JY
  2. Active Shell Fish Beds including OSPAR protected species , are all but extinct, but we have them on the SSSI – find out more here: https://noraeurope.eu/

Crucially, in the context of our climate emergency and the target for the UK to become Zero Carbon by 2050, Southannan Sands is identified by the draft Clyde Marine Regional Plan as a rare Natural Carbon Sink, which forms a network of natural carbon storage around our coast line that is vital for the future of our environment.

Our case is well documented and our environmental QC has highlighted that the decision by North Ayrshire Council to not require an Environmental Impact Assessment (EIA) at the formal stage of the EIA Screening in 2017 was flawed as it did not apply the wide scope and broad purpose during the interpretation of Schedule 1&2 project descriptions.

The Scottish Government finally seem to be realising the impact of this work, and here you can see MSP Mairi Gougeon responding to a question in Holyrood about the need to an EIA when evaluating the Marine Application. https://www.scottishparliament.tv/meeting/portfolio-questions-march-6-2019?clip_start=14%3A34%3A40&clip_end=14%3A37%3A41&fbclid=IwAR20ecOZuHHL01JDcJJkgKdY6uHSAkBcNJ7r4uHYAY9LTs0JlkN8BHv7Nec

The Peel Master Plan is fraught with lack of detail, inconsistencies and obfuscation. There is no consideration for the suitability of co-locating oil rig decommissioning, that involves heavy-duty demolition equipment producing vibration and sources of ignition, alongside a Liquid Natural Gas (LNG) terminal and storage facility, or beside a nuclear facility that is currently suspended from operation due to safety concerns.

In October 2018 Peel Ports submitted an application for a Waste Management Licence (WML) for oil rig decommissioning to Scottish Environmental Protection Agency (SEPA) that included the use of the 400m coal jetty in Fairlie Bay for preparation of ‘assets’. This was despite it being clear that the jetty was not included in the decommissioning planning permissions. Peel openly stated at the consultation that they can moor oil rigs for as long as they want any time they want on the coal jetty, because they are a port and that is what ports do. We also now know that at the time of the submission of the WML an in-depth case study of Hunterston for handling LNG had been published which showed that if the jetty were used for LNG it could not be used for any other purpose because of safety risks. 

How can Peel Ports be so cavalier with environmental and safety issues in their Master Plan? How can we trust them with our future health and safety? What are their genuine reasons for avoiding an Environmental Impact Assessment?

Inflated estimates of jobs could be a distraction to thorough evaluation of the proposal. We urge you to look very carefully at Peel Ports Master Plan – the NAC response needs to be significantly tightened up to prove then direction, otherwise all adoption or approval of the Master Plan should never be considered!

Yours faithfully the Friends of the Firth of Clyde

Email #4 – Sunday, Jun 16, 2019

Subject : Re: NAC Response to Peel Ports Master Plan Consultation 19 Jun 2019 Planning Committee

Dear Councillors,

As members of the NAC Planning Committee you find yourselves at the pivotal edge of significant decisions, which will affect the health and wealth of our area for generations to come. 
Friends of the Firth of Clyde whole heartedly support safe and sustainable development of Hunterston – and by Tuesday we aim to have alternative suggestions for the Master Plan as well as suggestions of how the NAC response should be amended.
We applaud NAC for their continued doggedness with Peel about consultation and collaboration, but the Peel efforts so far are somewhat wanting. I don’t know if you have had a chance to review the Peel consultation survey? We find it a very poor survey, with leading questions and irrelevant questions. Very little useful information could be gathered from this document, and so for this reason we have commissioned our own survey, at our own cost, to help you understand the feelings of the communities impacted. The survey has been published electronically and in paper form and distributed widely to gain true community opinion regardless of residents positions.
We still have 1 week to run with responses and aiming for 200 completed surveys, which I think you will appreciate is quite an achievement. Responses are from Fairlie, West Kilbride, Largs, Bute and other surrounding communities.
Please view the results of the survey so far with this link: https://www.surveymonkey.com/stories/SM-QTJWBN9V/
Here are some highlights from the responses to date:
  • The community believe the Master Plan is superficial PR without any level of critique of the real impacts.
  • around 10% of respondents support LNG Terminal, Power Station or Decomissioning, 80% oppose it and some don’t have enough information.
  • There is support for cleaner industries such as train manufacturing or house building.
  • There is huge support for true renewables, high tech and rewilding.
We asked them  -what would you like NAC, your Councillor, the Community Council, FoFoC, and the protection agencies to do? The results don’t fit nicely on the analysis so we have attached as a PDF. (please note these are the raw comments from respondents)
Yours faithfully the Friends of the Firth of Clyde

Email #5 – Monday, Jun 17, 2019

Subject : Re: NAC Response to Peel Ports Master Plan Consultation 19 Jun 2019 Planning Committee

Dear Councillors,

The need for Gas to keep the lights on is a myth propagated by oil companies, and in direct conflict with the Paris Agreement and the Climate Emergency. Gas is a fossil fuel, which may burn slightly cleaner than coal, but total environmental cost from extraction to electricity is not that different. Gas or Methane, is a major contributor to global warming.
The simple fact is we have already moved on from these dirty industries and it would be ludicrous to invest in them. North Ayrshire Council are worried about the negative tone of the Peel Master Plan, I think they should worry about the negative image they might get if they do not condemn these proposals!
In 2018, the UK sourced 53% of its electricity from low carbon sources, with 33% from renewables and around 20% from nuclear. Coal-fired power stations generated just 5% of electricity, the remainder (39.4%) was generated by burning natural gas which, although cleaner than coal, is not a low-carbon fuel. Reliance on natural gas also leaves the UK vulnerable to supply shocks and rising import dependence.
Investment in renewables is a much more attractive proposition:
1. There has been a dramatic fall in the cost of renewables.
2. There is no fuel cost, so the cost to generate electricity is lower.
3. Under EU law renewables get priority access to the grid, providing profit advantages to renewables over fossil fuel.
The key to success with renewables is interconnetors (present at Hunterston) and storage (batteries). Attached is a report written in May19 detailing why LNG is not an investment that we should be making.
NAC seek to be BOLD, INNOVATIVE AND PIONEERING. It’s time to embrace confidence in this conviction and call out dirty industry and operators with no consideration for the environment, safety and the impact of their profit seeking on others.
Peel have neither considered the full value of the assets at Hunterston, nor considered the impact of their potential business ideas on anyone other than those public bodies they wish to extract monies from.
The Master Plan is so so wrong, it must be strongly rebuffed by NAC. The current NAC response is a wholly inadequate appraisal. Tomorrow we will provide our suggestions.
Yours faithfully The Friends of the Firth of Clyde

Email #6 – Tuesday, Jun 17, 2019

Subject : Re: NAC Response to Peel Ports Master Plan Consultation 19 Jun 2019 Planning Committee

Dear Counsellor,

The Hunterston Master Plan is arguably the most complex and dangerous development to be brought to the area in recent years. We have written to you expressing our ALARM at the proposals. Peel have unprecedented power as a commercial organisation and the Port Authority, we need you to represent and protect the needs of our communities.

We propose the following amendments to the NAC response:

  1. Initially we assumed it was no more than a private company’s strategy, if any of it is to be approved or adopted, to be incorporated into regional planning strategy we would like to insist on full involvement following a CITIZENS ASSEMBLY APPROACH.  In the meantime, references to ‘Approval and Adoption’ should be removed.
  2. The LNG Terminal and Power Station need to be rejected. – It is not safe for communities or the environment and inhibits other  activities.
  3. Transparent critique and information of impacts needs to be at the heart of any Master Plan including:
  • The jobs claim is exaggerated. Peel and should provide realistic job expectations and be prepared to substantiate them.
  • Potential impact to the environment, communities and local infrastructure must be provided transparently. For instance, there has been significant work undertaken in the Atkins Case Study demonstrating significant heavy goods transportation. Communities should not have to spend hours hunting for this level of information. Peel must freely share information to allow reasonable understanding .

4. Impact on other industries and future developments must be considered. The ONR has not even been consulted on the prospect of LNG! The LNG would lead to significant exclusions which need to be broadly understood. There is no discussion on tourism impact etc.

5. Reference to main concern being the tone of the socio-economic should all be removed as this is misleading. – Negative tone is not a concern for communities. 

In addition, we’d like to know what are NAC and Peel’s intentions for this Master Plan? Prior to future publications communities would like to be assured of:

  • Residents’ safety and quality of life
  • Protection of the environment inc SSSI will be paramount and prioritised before profit 
  • Heavy goods transportation is honestly appraised and avoided.
  • High quality, safe, skilled and sustainable jobs are actually likely. 
  • Development will promote & enhance the outstandingly beautiful natural assets of the area and support rather than detract from the existing economy.
  • All developments are compatible with the Scottish Government target of achieving a Net Zero Carbon Future by 2045
  • Investment of public money from NAC is conditional on meeting the above tests 

We hope that our communication with you over the past five days has stimulated you to think carefully about VERY SERIOUS implications of what might appear to be a simple bureaucratic tick box vote at the NAC Planning Committee Meeting tomorrow. 

We urge you to not to agree to Peel Ports Master Plan without significant development and involvement of innovators, environmental experts and entrepreneurs from across the country and beyond.

Yours sincerely,

The Friends of the Firth of Clyde 

 

Hunterston PARC Development Proposals – Master Plan or Disaster Plan?

Help Inform Our Response to Peel Ports Public Consultation

If you weren’t able to get to the public exhibitions in Fairlie or Millport, Peel Ports consultation is running online until 28th June 2019 and you can find more information about the 20-year Plan at www.hunterstonparc.com

We have been canvassing opinion about the way the consultation has been conducted and many people have fedback to us that Peel Ports’ online survey doesn’t allow enough opportunity for comments. It is really important that the views of the community are fully captured and to support this we have put together our own survey.

It would be great if you could take a few minutes to complete the survey; its completely anonymous and we will use the results to inform the responce to the consultation from the Friends of Firth of Clyde.

Tell us what you think – good bad or indifferent?

Click here to complete our survey to tell us what you think

Door to Door Flyer

Friends of the Firth Of Clyde Thoughts on Peel Ports’ ‘20-Year Vision’ for Hunterston PARC Public Consultation

Peel Ports have finally released their 20-Year Vision for the development of Hunterston PARC and a 6 week public consultation period commenced on 16 May 2019 with a deadline of Friday 28 June 2019 for submission of comments.

Public consultation events will be held at just two locations over 3 days:

  • Fairlie Village Hall between 4- 6 June 2019
  • Garrison House, Millport on 6 June 2019 .

Details of times of the public consultation, the full 20-year Plan and the online consultation can be found on the Hunterston PARC website https://www.hunterstonparc.com

Residents of Fairlie and the surrounding areas have been awaiting the publication of the Plan having first learned of its existence at the Pre-Application Consultation for the marine licence for construction work to commence for oil rig decommissioning back in August 2018.

Since this time we have learned that Peel has a reputation for approaching large scale plans, with potential for significant environmental and social impacts, in such a way that it can be difficult for local communities to gain a full picture of what is happening. This has certainly been our first hand experience of their proposals for oil rig and large marine vessel decommissioning at Hunterston.

This  can make it difficult for the public to develop a fully  informed opinion of the potential risks and impacts on the health, safety and wellbeing of residents and the wider environment. So we need look beyond the glossy images and ambitious statements contained in the  promotional materials and bring a critically informed eye to all the proposals that Peel Ports put to community.

Master Plan or Disaster Plan?

Door to Door Flyer

From a standing start we have learned a lot about oil-rig decommissioning, planning and regulation, but the 20-year Plan introduces concepts and industries that are new to us, so we are researching like mad to see how they stand up to the FoFoC test of Safe and Sustainable’, and Fairlie Community Council have asked Peel to present a guide to each industry for residents.

At this stage there is a lot we don’t know, so we are starting with two fundamental questions:

“What does all this mean – for now and the future?”

 “Are the proposals safe and sustainable for the community and the environment?”

We also want to know “how will the existing contamination from the coal yard that is leeching coal slurry into the SSSI be safely cleaned up? Peel states on the Q&A section of their Hunterston PARC web site that they have been advised by SEPA that it is safer for it to be left where it is. But we have asked SEPA direct if this is the case and they have replied saying they no recollection of giving this advice.

So, onto Peels new ideas for the site. The 20-year Plan outlines a proposal to bring a selection of 8 separate industrial, decommissioning and construction proposals. At first sight it looks like a pick and mix proposal of industries that wouldn’t normally sit along side each other – perhaps this is why the plan is described as ‘ambitious‘?

  1. Liquid Natural Gas Storage (LNG) This would involve large tankers on the coal jetty loading and unloading. There are significant safety issues which have to be very carefully managed. Based on the figures provided  the volumes of storage would make this the largest LNG facility in THE WORLD that we know of! We have supporters who are familiar with the management and storage of LNG and will be putting together more information on this over the coming weeks.
  2. Combined Cycle Gas Turbine Power Station (CCGT) It’s not clear if this is linked to the LNG storage facility and how this meets the stated ambition of Peel to move away from fossil fuels?
  3. Train Manufacturing– Could this refer to the high-speed trains that Peel were bidding for last year but didn’t get shortlisted for?
  4. Modular Manufacturing– On first sight  this could be units for housing, but more information is needed?
  5. Concrete Batching– This refers to construction of large concrete structures.
  6. Marine Construction and Decommissioning– This is a live and highly controversial proposal that refers to oil-rig and large marine structure decommissioning requiring dredging in the area of  Southannan Sands Site of Special Scientific Interest (SSSI) for which no Environmental Impact Assessment (EIA) has been undertaken. As FoFoC supporters know we have secured the services of a environmental QC and are actively involved in holding the regulatory and planning authorities to require an EIA of the whole project before this is progressed.
  7. Aquaculture– This usually refers to fish farming on land.
  8. Plastics recycling and storage – Could this be linked to the bottle deposit and recycling scheme that is being launched in Scotland and the need for the UK to recycle more of its own plastics since the world markets radically changed following China stopped taking exported waste from the UK and the rest of the world?

So what does this all mean for residents?

The honest answer is on the basis of the information provided so far it is difficult to know. This is why we have asked Peel Ports to provide more detailed information about the different industries at the public consultation event and over the coming weeks we will be doing our own research.

What are the questions we need to ask?

To reach a fully informed opinion we need much more information about the short and long-term impact of each of the 8 elements in the following areas:

  • Health and Safety of residents and the local community?
  • Environmental Safety – both land and marine?
  • Road Safety, volume of traffic and increase in heavy goods vehicles?
  • Risks to Southannan Sands Site of Special Scientific Interest (SSSI)?
  • Risks to the marine mammals, bird population, active shell fish and OSPAR protected species that surround the yard?
  • Impacts on tourism, recreation & leisure sectors of the local economy?
  • Impact in noise pollution?
  • Impact in light pollution?
  • Impact Litter and waste management?
  • Safety of the neighbouring Nuclear Power Station?
  • Impact on MOD activity in the area and security of the area?

We also want to know:

  • How compatible are all the industries when taken as whole?
  • What are the planning requirements for each of the industries and how are they regulated?
  • How do each of the industries fit with existing planning consent conditions?
  • How would planning, licensing & regulation be co-ordinated and by whom?

What next? 

We urge everyone to take time to read the information from Peel Ports, to attend the public exhibition to ask questions and seek more information about Peel Ports proposals. It is vital that the community takes up this opportunity to scrutinise the plans in order that we can continue to hold Peel Ports and the planning and regulatory authorities to account as these plans go forward.

The Friends of the Firth of Clyde are committed to campaigning for environmentally safe and sustainable development of Hunterston PARC, this is our opportunity to make sure Peel Ports understand that the communities of the Firth of Clyde who will live with the consequences of developments have the right to form an informed view of the opportunities and have alternative positive ambitions for the way the site is developed.

For example what about an ambition for Hunterston PARC to be Scotland’s Green Energy Technology & Enterprise Park?

Between us we a vast amount of personal skill, environmental and industrial knowledge please do come forward to share your experience and expertise with us. If you would like to help contact us at secretary@friendsoffirthofclyde.org

 

Report on Clyde Regional Marine Plan Public Consultation Meeting – Largs 11/05/19

CMPP Public Meeting and Peel Liaison

 

The Friends of the Firth of Clyde attended the Clyde Marine Planning Partnership (CMPP) public consultation about the Clyde Regional Marine Plan in Largs on 11th May 2019.

The CMPP team, represented by Isabel Glasgow, Fiona Mills & Madlaina Michelotti, hosted an informative meeting that described the role of CMPP, including membership and governance of it’s Board; followed by an overview of the Clyde Regional Marine Plan and a lengthy question and answer session.

The Clyde Regional Marine Plan, once adopted by Scottish Government in 2020, will ‘provide a statutory policy framework to support effective decision-making and appropriate inward investment, enabling delivery of the Plan’s long-term vision and aims’. The  Clyde regional plan, which interprets and supports Scotland’s National Marine Plan in a regional context over the next 20 years, is the first along with the Shetland Isles to  take up the development of a Regional Plan.

The current draft Clyde Regional Marine Plan signals positive intent to shape future decision making on developments that affect the marine environment. Guided by an ‘eco-system approach’ its objective being to achieve  balance between environmental, economic and social  objectives for development of the Clyde Region.

We learned that the Clyde Region is complex with a large number of  public and statutory authorities; environmental protection & enhancement organisations ; commercial organisations; and recreational  interests within its boundaries – for instance 9 different planning authorities have a boundary with the Clyde Region, which covers the vast marine area that stretches from  Glasgow,  into the lochs of the northern reaches, across and beyond Bute to Loch Fyne, around Arran, down to the Mull of Kintyre and across to the mouth of Loch Ryan. The photo of the slide below shows the organisations that are members; it is interesting to see how Peel Ports/ClydePort is situated within both Public Authority (as the Statuary Harbour Authority) and Commerce.

Disappointingly, for our campaign for an Environmental Impact Assessment (EIA) to save Southannan Sands Site of Special Scientific Interest the timeline for adoption of the Clyde Regional Marine Plan is out of step with the current proposals that are on the table for Hunterston PARC.  The plan has a number of stages to still go through, including a further public consultation phase, before it is adopted by the Scottish Parliament in 2020.

If the plan had been available to North Ayrshire Council at the start of the period when they were in consultation about Peel Ports’ proposals for decommissioning at Hunterston, it should have helped inform their decision making by requiring them to consider the implications of their land based planning approval on the marine environment.

Going forward it is clear that much more education is needed about planning responsibilities in the intertidal zone (ie between Mean High and Low Water Marks) and significant behaviour change will be needed in local councils once the plan is adopted to enable them to shift from a purely ‘landcentric’ to an ‘eco-system approach’ to reviewing planning applications.

Despite learning that the Clyde Regional Marine Plan at this point in time will not reduce the imminent threat to Southannan Sands SSSI, or help with the range of other questions that the FoFoC submitted about littering & hazard waste pollution and impact on the tourism economy, it was a useful opportunity to publicly air a number of our questions in the hope that raising CMPP’s awareness of our serious concerns about the imminent risk of irreparable damage that the decommissioning project will cause to Southannan Sands SSSI and the surrounding marine environment. Which in turn will help inform their thinking as a Statutory  Consultee for the long awaited Marine Licence Application for the dredging required for the decommissioning project.

Click here to read our questions >>>>

In response to our question about management of Clydeport / Peel Ports potential for conflicts of interest, we were referred to the CMPP Operational Guidance which outlines a risk matrix for mitigation of conflicts of interest. This is helpful to know, as it is clear that Peel Port / Clydeport should remove themselves from any discussions about Hunterston PARC and in particular those regarding CMPP being consulted as a Statuary Consultee on planning or licensing applications.

Our proposal about community membership of  CMPP was met with some reservation on the basis of how this could be effectively organised over such a large and varied geographical area. But our suggestion that the community council infrastructure could be harnessed was met with some interest.

The suggestion that the Cumbraes Marine Consultation Area and the coastal SSSIs of the Clyde Region could be redesigned as Cumbraes Research & Development Marine Protected Area was met with interest and support – all be it with caveat that it would require a lot of work to achieve this.

We shall submit our formal response to the consultation by the 27th May 2019 and encourage you attend a meeting, take a read of the plan and submit your own comments by this date too.

At the end of the session Counsellor Ian Murdoch thanked the CMPP team for the way that the session had been ran, which was echoed by FoFoC. The manner in which the team provided the opportunity to ask challenging questions and were prepared to discuss ideas and suggestions made a refreshing change to the adversarial lack of transparency that we have grown to expect when raising questions about Hunterston.

Written Response to the Public Consultation

Following the public meeting we submitted our response in writing through the formal consultation route. You can read this below:

CMPP Consultation_consultation-form_3March2019_Friends of the Firth of Clyde FINAL

We will watch with interest progress of the Clyde Regional Marine Plan, and in the meantime continue to campaign against Hunterston becoming a salutary case study in the future regional plan  that serves to illustrate what happens when a fully integrated environmental assessment of complex projects, such as decommissioning, is not undertaken.