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?

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