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 pagesEIR 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