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…/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 :…

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:

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!
  2. Active Shell Fish Beds including OSPAR protected species , are all but extinct, but we have them on the SSSI – find out more here:

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.

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:
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 


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