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FoFoC 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.

Our 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.

 

Read the questions the FoFoC have submitted to the Clyde Marine Planning Partnership in advance of the Clyde Regional Marine Plan Public Consultation Event on 11th May 2019

The FoFoC have submitted the following questions to the Clyde Marine Planning Partnership in advance of the Clyde Regional Marine Plan  Public Consultation Event in Largs on 11th May 2019, 6-9pm.

Theme: Environmental Impact Assessment of Large Scale and Complex Development Proposals, including Decommissioning of Oil Rigs & Marine Structures

Question 1: The Clyde Regional Marine Plan clearly identifies Hunterston Peninsula as being the location of Southannan Sands Site of Special Scientific Interest (SSSI), which is a  rare eel grass meadow, natural carbon sink and an active shell fish site that is populated by a number of OSPAR Protected Species. How will the plan address the serious and imminent environmental threat of proposals by Peel Ports to develop Hunterston Peninsula for decommissioning of oil rigs and large marine structures with no Environmental Impact Assessment (EIA) of the overall project?

Question 2: The Clyde Regional Marine Plan states that it will place higher responsibility on the proposers of developments to show that they will not damage valuable marine features. How will the plan ensure that mitigation is not used as a proxy by which to avoid the requirement for full and independent Environmental Impact Assessment  (EIA) of large scale and complex proposals for decommissioning of oilrigs and large marine structures on the Firth of Clyde?

Theme: Balancing Business Against Environmental Conflicts of Interest. 

Question 3: Clydeport Operations Ltd, which is part of the much larger Peel Group, is the Statutory Harbour Authority for the Firth of Clyde. This means as an organisation with wide commercial interests, it has decision-making powers over a number of marine activities on the Firth of Clyde, such as potentially allowing oil rigs for decommissioning to be cold stacked in environmentally sensitive locations such as Loch Striven. How will the Clyde Regional Marine Plan ensure effective systems are in place to monitor and manage potential conflicts of interest where business and statutory powers could be viewed to be in direct competition with environmental safeguarding?

Theme: Reducing the Volume of Litter Entering the Marine Environment 

Question 4:  The Clyde Regional Marine Plan states that marine litter is found across the Clyde Marine Region with shallow coastal areas exposed to prevailing southwesterly winds being particularly at risk of becoming litter congregation areas or ‘sinks’. Evidence from the Waste Management Licence Application submitted by Clyde/Peel Ports to SEPA for oil rig decommissioning at Hunterston PARC shows that unprecedented volumes of scrap metal, asbestos, NORM, organic marine matter and a range of other toxic & high risk materials will be brought to the site. The coastal village of Fairlie is exposed to the prevailing  winds that come from the direction of Hunterston, and as such its shores are at risk of becoming a ‘sink’ for litter and potentially toxic waste that arises as a result of decommissioning activity. How will the plan ensure planners and licensing authorities fully and transparently assess these risks and reassure the local communities that the condition of the shoreline and health of residents will not be put at risk by any potential decommissioning developments?

Theme: Protecting the Tourism Industry Against The Impact of Industrial Development 

Question 5:  The Firth of Clyde is internationally known for its unique sailing waters and beautiful coast line, as such tourism makes a significant contribution to the economy of the region. What is the Clyde Regional Marine Plan’s policy for ensuring mechanisms are in place to undertake a full and comprehensive assessment of the economic impact of proposals for large scale industrial developments on tourism and related businesses? In particular, how will the plan ensure that an assessment of the economic impacts is undertaken with regard to Peel Ports’ proposals to develop Hunterston PARC for oil rig decommissioning and scrapping of large marine structures?

Theme: Meaningful Public & Community Involvement. 

Question 6: Those communities who will be most affected by planning decisions should play a part in the decision making process.  For far too long we have seen legislation requiring that bodies such as Clyde Marine Planning Partnership (CMPP) are required to consult with the general public, only to then see the views actually expressed by ordinary people ignored. Why is it that none of the community councils for the Clyde coastal areas are represented as stakeholders within the Clyde Marine Planning Partnership?  We would like to propose that you accept a grouping of the various coastal community councils, as a significant partner and player within the decision making process of CMPP? – it could be called C4 (Clyde Coastal Community Councils).
 
Theme:  Preserving the designation of the  Cumbraes Marine Consultation Area and a proposal that Cumbraes MCA and coastal SSSIs of the Clyde Region to be redesigned as Cumbraes Research & Development Marine Protected Area

Question 7:The Clyde Regional Marine Plan appears to be dropping the Cumbraes Marine Consultation Area (Cumbraes MCA) designation. The designation is important on account of the area having recognised ecological, cultural and historical significance. Cumbrae MCA is an important instrument to help protect and enhance our marine environment, which if used properly it could be used to help drive an eco tourism strategy for the North Coast and provide an alternative to the industrial focus for economic growth being led by the development of Hunterston PARC. The health and sustainability of the Southannan Sands Site of Special Scientific Interest (SSSI) is dependant on a coherent network of sites and whatever happens in the Cumbraes MCA will have a significant impact on the SSSI and coastline of Fairlie and North Coast.  What is the Clyde Regional Marine Plan’s position on preserving the designation of the Cumbraes MCA and what is its response to the proposal that the Cumbraes MCA and the coastal SSSIs of the Clyde Region be redesigned as Cumbraes Research & Development Marine Protected Area?

Scottish Natural Heritage advised it would be sensible to require an Environmental Impact Assessment of Peel Ports plans for oil rig decommissioning at Hunterston PARC before planning permission was granted

You will no doubt have seen the publicity that has spawned the Save Loch Lomond Campaign which is objecting to proposals to develop a Flamingo Land style holiday resort named ‘Lomond Banks’ on the shores of Loch Lomond.

Meantime, just 3o miles south west on the less well-known but equally beautiful shores of Fairlie on the North Ayrshire Coast, the Friends of the Firth of Clyde (FoFoC)  are battling to preserve the environmental treasure that is the precious Southannan Sands Site of Special Scientific Interest (SSSI), which is an increasingly rare eel grass meadow that provides vital nursery habitat for juvenile fish and  a number of OSPAR protected marine life, from being irreparably damaged by Peel Ports plans to dredge hundreds of thousands of tonnes of sand from the area to develop  Hunterston PARC for oil rig decommissioning.

In January 2019 we received a reply to a request for information to Scottish Natural Heritage (SNH) under the  Environmental Information (Scotland) Regulations 2004 (‘the  EIRs’).

We asked the following questions of SNH:

  • What  discussions have Scottish Natural Heritage (SNH) had to date with North Ayrshire Council (NAC)  regarding the need for an Environmental Impact Assessment (EIA) for this project?
  • What advice was  given to NAC by SNH?
  • Where the discussions documented?
  • What was the outcome?

The written response we received was unequivocal in indicating that SNH  advised an EIA was required, and states that:

“We (SNH) attended the screening meeting at the Hunterston site on  
23 January 2017. At the meeting we expressed the opinion that due  
to the scale, the introduction of new processes and complex nature  
of the entire project, that it would be sensible to request the  
production of an EIA. The structure of any EIA could be scoped to  
narrow down the range of environmental factors and impacts being  
considered. At the conclusion of the meeting the Council indicated  
that they would consider the change of use application for the yard  
without an EIA of the entire project. This meeting was not minuted,  
and North Ayrshire Council decided that an EIA would not be  
required.”

This shocking information begs a number of questions:

  • Why was this screening meeting between public bodies to inform such an important planning decision not minuted?
  • What is the rationale underpinning  “The short answer is of course not”, to Independant Counsellor Ian Murdoch when he asked a direct question at the NAC Council meeting on 27th March 2019 (Q5, 1:22:43) about whether  all meetings between NAC officers  and outside organisations should be minuted ?
  • What was the reasoning behind  NAC deciding not to take the advice from SNH that “it would be ‘sensible” to request an EIA be undertaken before planning permission was granted?
  • How will Marine Scotland rectify the situation when they consider Peel Ports long awaited Marine Licence application that has remained in the pre-application stage since August 2018?

…. and last, but by no means least ….

How do we get the same scale of publicity and support for protection of  the quietly beautiful Southannan Sands SSSI as there is for its celebrity neighbour Loch Lomond? 

 

Important Announcement – Dates of Public Consultation Events for Peel Ports 20-Year Plan for Hunterston PARC & the Clyde Regional Marine Plan

The Friends of the Firth of Clyde want as many people as possible to know about two important public consultation events that are taking place over coming weeks which will inform future developments at Hunterston Peninsula and the wider plans for the Firth of Clyde.

We are encouraging all our supporters to attend and to spread the word. This is an important opportunity to learn more and to have your voice heard!

Clyde Marine Planning Partnership Public Consultation Event on The Clyde Regional Marine Plan, Saturday 11th May 2019, 6pm – 9pm, The Brisbane Centre, Bath Street, Largs

CMPP Public Meeting and Peel Liaison

 

You can read more about how the Clyde Regional Marine plan is relevant to our campaign for an Environmental Impact assessment to be required of Peel Ports plans for oil rig decommissioning at Hunterston on our news blog >>>

Events are being held all around the region and more information can
be found about the consultation from the Clyde Marine Planning
Partnership (CMPP) website

Please note questions must be emailed in advance to info@clydemarineplan.scot

Peel Ports 20-Year Plan Public Consultation Event, Fairlie Village
Hall, Tuesday 4th June – Thursday 6th June 2019 & Millport, Garrison 
House,  Thursday 6th June 2019 * times of both events to be confirmed*

PP 20 Year Plan Flyer

 

The existence of the Peel Port 20 Year Plan was first referred to in the Marine Scotland PAC event back in August 2018, however until now local residents and the wider community have heard little about Peel Ports aspirations for the site, apart from the controversial proposals for oil rig decommissioning.

 

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Information about Peel Ports’ vision for the site is now available on the Hunterston PARC website, and includes:

  • Oil Rig and Large Marine Vessel Decommissioning
  • Liquid Natural Gas Distribution Hub and Power Station
  •  Power Generation and Energy Intensive Industry
  • Specialist Chemical Import, Storage and Process.This is an important opportunity to hear more directly from Peel Ports representatives about their intentions for the site, ask questions and provide feedback to Peel Ports on the community’s aspirations for environmentally safe and sustainable developments at Hunterston PARC.

PLEASE PASS ON THE WORD ABOUT THESE TWO IMPORTANT CONSULTATIONS AND HAVE YOUR VOICE HEARD.

WE LOOK FORWARD TO SEEING YOU THERE!

 

Pre-Consultation Draft Of Clyde Regional Marine Plan Available For Public Consultation – Closing Date 27th May 2019

The pre-consultation draft of the Clyde Regional Marine Plan is now available on the Clyde Marine Planning Partnership website for public comment with a closing date of 27th May 2019.

There are also a series of public events being held around the region including at the Brisbane Centre, Largs on 11th May 2019, 6pm – 9pm.

Questions  must be emailed in advance to info@clydemarineplan.scot and include the event you are planning to attend. If you wish to attend from Cumbrae and need to leave to catch the last ferry back, let them know so that they can answer your questions first.

What is the Clyde Regional Marine Plan ?

The Clyde Regional Marine Plan is the regional response to  Scotland’s National Marine Plan which will provide a statutory policy framework to support decision-making and inward investment into the region.

Scotland’s National Marine Plan sets out the strategic policies for sustainable development of Scotland’s marine resources out to 200 nautical miles. The Marine (Scotland) Act 2010 allows for Regional Marine Plans to be developed to take account of local circumstances and smaller ecosystem units for inshore waters out to 12 nautical miles.

We are encouraging all our supporters, individuals and groups concerned about the future of the Firth of Clyde to scrutinise the plan, submit their comments and attend their local public event. The first draft of the plan will be revised in response to the public and stakeholder consultation, after which it will be open for the required statutory 12 week public consultation, prior to formal adoption by Scottish Ministers.

The plan covers the complex landscape of marine and economic interests, including oil rig decommissioning, across and along the Firth of Clyde. It is an interesting read and gives a helicopter view of the assets of our precious and unique marine environment.

What is it’s relevance to our campaign for an Environmental Impact Assessment (EIA) of proposals for oil rig decommissioning at Hunterston?

The plan has particular significance for FoFoC as it highlights the tension between balancing the desire to protect the natural assets of the Firth of Clyde alongside supporting opportunities for sustainable development which attracts investment and growth of the economy. This is the tension that is being tested in Fairlie’s own back yard by the current proposals to bring oil rig decommissioning to Hunterston.

The plan also illustrates how Clydeport Operations Ltd is the Statutory Harbour Authority for the whole of the Firth of Clyde (pg 67). This means that they have unilateral decision making powers over whether they can cold stack oil rigs and marine vessels awaiting decommissioning at Hunterston in environmentally sensitive locations such as Loch Striven.

Importantly, the plan appears to place higher responsibility on the proposers of developments to show that they  will not damage the valuable features outlined in the plan and where their actions might, that they can be effectively mitigated. This should mean that a full and comprehensive assessment of environmental impacts will be expected as a default, unlike the current situation with Hunterston where the planning and regulatory authorities have been satisfied, on the basis of a single environmental report commissioned by Clyde/Peelports, for one aspect of their own development (ie the extension of the jetty and construction of caisson gates) that any risks to the SSSI that can be mitigated.

How does the Clyde Regional Marine Plan support our case for an EIA to be undertaken at Hunterston?

  • Southannon Sands SSSI is a Natural Carbon Sink

The first objective of the plan highlights the need for natural carbon sinks to be maintained and enhanced in the Clyde Marine Region. This is significant for Hunterston as the Southannon Sands SSSI, that surrounds the proposed decommissioning area, is protected for its eel grass and shell fish populations, which make it one of a very small number of the precious natural carbon sinks within the curtilage of the Clyde Marine Region (see page 18/19, Map CC1). This area will be subjected to the effects of the required dredging 100’s of 1000’s of tonnes of sand from the sea bed to make the derelict dry dock fit for purpose.

  • Southannon Sands SSSI is the only active shellfish site on mainland Firth of Clyde

Significantly, the plan highlights that Southannon Sands SSSI is the location of the only Active Shell Fish Site along the whole of the mainland coast of the Firth of Clyde (see page 56).

  • Bio-Security – transfer of non native species

The plan highlights the risks of introducing or spreading marine non-native species and terrestrial non-native species affecting seabirds, particularly when this involves moving equipment, boats and materials or from one water body to another,  for example introducing structures which may inadvertently facilitate the settlement of non-native species. Oil rigs will need to be transported significant distances for them to reach the Firth of Clyde. The risks to bio-security and the potential impact on shell fish stocks of Southannon Sands SSSI has not been assessed as part of the  current plans.

  • Local Landscape Area Designation – encouraging communities to have a sense of pride in their surroundings

In addition, the plan highlights that the coastline between Largs and Portencross is designated as a Scottish Natural Heritage (SNH)  Local Landscape Area – previously known as an ‘Area of Great Landscape Value’.

The aim of local landscape designations is to:

  • help to protect a landscape from inappropriate development
  • encourage positive landscape management
  • play an important role in developing an awareness of the landscape qualities that make particular areas distinctive
  • promote a community’s sense of pride in its surroundings

It is reassuring to see our area being recognised as a highly valued area of natural beauty rather than, as it is often characterised by those who wish to see decommissioning at any cost, as industrial waste land.

Finally the plan asserts that ‘a community’s sense of pride in its surroundings’ is to be valued and encouraged. A sense of pride and concern to protect our local environment is at the very heart of FoFoC motivation for holding the authorities to account about developments at Hunterston. This statement gives validation to our campaign and it is heartening to see that for once our efforts are considered as something to be positively valued, rather than cast as ‘nimbyism’.

For more information on the Clyde Regional Marine Plan go to the Clyde Marine Planning Partnership Web Site >>>

 

Peelports Announce Public Consultation on ‘Master Plan’ for Hunterston PARC

It is with interest that FoFoC have received notification from Peelports that they have published their ‘Master Plan’ for Hunterston PARC and that a six week public consultation will be held between 16th May – 29th June 2019.

Public exhibition events where members of  the Peelport team will be available to discuss the “aspirational plans” will be held at:

  • Fairlie Community Hall: Tuesday 4th to Thursday 6th June
  • Garrison House, Millport: Thursday 6th June.

Its not clear what the aim of the public consultation will be and how much influence the opinions of the local community will actually have, but the FoFoC will actively engage in the process and we hope that as many supporters and people with an interest in the development of Hunterston will also make time to attend and share your views.

A website for Hunterston Parc has also been developed and can be found at www.hunterstonparc.com The website contains a summary of basic information about the site including a question and answer section.

Interestingly all of the questions have been posed by the FoFoC to the planning and regulatory authorities over the past 6 months – not direct to Peelports as the option was not available until now. So, whilst it is useful to hear Peel’s responses, it highlights how closely the authorities are linked into Peelports behind the scenes.

Also noticeable is the absence of any reference to oil rig decommissioning in any of the information apart from the Q&A section.

See below for more information from Peelports about the consultation and public exhibitions:

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