Marine Scotland (MS) is the directorate within Scottish Government that is responsible for leading the protection of Scotland’s coastal waters and seas with ‘the duel aim of building sustainable economic growth from Scotland’s marine assets, and to safeguard its valuable marine ecosystems’. Marine licences are issued by Marine Scotland Licensing Operations Team (MS-LOT) which are required for activities including:
- the removal of substances or objects from the sea bed
- construction, alteration and improvement works
Hunterston Construction Yard requires all of the above to become a viable site for decommissioning. In 2016, GMB Scotland commissioned a review entitled ‘Status Capacity and Capability of North Sea Decommissioning Facilities‘, in this detailed analysis of decommissioning sites in the UK and Norway, Hunterston is evaluated (pg 55) as having the worst decommissioning readiness out the total 19 facilities across the UK (17) and Norway(2)
The scale of development required to make the site fit for purpose, is reflected in the scale and extent of the work expected to be applied for in the marine licence application. The dry dock is delict and requires substantial dredging, piling and construction work; plus there is the need for extension of the hammerhead quay. This work will include thousands of tonnes of sand being dredged from the area of Southannon Sands, which is the location of a Site of Special Scientific Interest (SSSI) that is of national importance for its sandflats, with intertidal seagrass meadows and active shell fish bed, all of which are Priority Marine Features.
In addition, the construction work will require substantial and prolonged piling required for the installation of caisson gates. This work will produce high levels of vibration and noise in the marine and land environment, which is known to be harmful to the health of marine mammals and invertebrates. The area is home to a range of marine life including porpoise, seals and a very special solitary dolphin nicknamed ‘Kylie’, who inhabits the waters immediately next to the proposed construction area. Kylie has recently received international recognition in the scientific community for being the first dolphin to be discovered directly communicating with the porpoise that he lives with, you might have seen his story recently featured on the BBC One Show
All of this means it is essential that we hold Marine Scotland to account, to make sure that they fully scrutinise the marine licence application in light of all the facts of the development and assess its risks as part of the larger whole of the decommissioning project; rather than each separate element of planning and licensing being ‘salami sliced’ to avoid the full impact being scrutinised. Crucially we are calling on Marine Scotland to now require a full Environmental Impact Assessment (EIA).
We understand that the Marine Licence for ‘Hunterston Marine Construction Yard’ has been submitted, but it currently is still showing as in pre-application stage on the planning portal. We have asked to be informed when it is open for public consultation.
On 20th December 2018, in advance of the licence application, the FoFoC sent a formal letter to Mike Bland (CEO MS) outlining the significant flaws in the planning processes and explaining our reasons for requesting that that no decision be made about the application without the full environmental effects being considered and an EIA being undertaken.
You can read our full letter to Marine Scotland below.
What’s Next? Here’s where we need your help.
As soon as the Marine Licence Application is open to public consultation we will be asking all FoFoC supporters, their friends, family and concerned citizens to help strengthen the case for an EIA by writing to Marine Scotland expressing their concerns.
We know that many of our supporters are very busy and don’t have time to read and digest all the information in this complex and challenging case, so we are currently working on a Brief Guide to Objecting to a Marine Scotland Licence Application, so you can object with confidence that you are covering the important areas. As soon as we have this prepared we will share it with you.
Friends of the Firth of Clyde Letter of Objection to Marine Scotland 20th December 2018Marine Scotland Letter (Final)
*Contact us direct for more information on the supporting appendices
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