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 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 >>>


4 thoughts on “Pre-Consultation Draft Of Clyde Regional Marine Plan Available For Public Consultation – Closing Date 27th May 2019”

  1. Many thanks for all your hard work FoFoC …We on Bute are involved in Dawnfresh fish farm proposal at the moment and this is also going to harm the environment on the Firth …good to be kept up to speed on what’s happening a stones throw from us across the water at Hunterston and of course, Loch Striven. Our Argyll and Bute Council are apparently not involved in the oil rig commissioning issue. Sadly.

    1. Hi Liz,
      The issue of how Argyle & Bute are included in consultations on marine projects that have wide reaching implications such as decommission is a really important and recurring question.
      We have just had our attention drawn to new legislation ‘Islands (Scotland) Act 2018’ “An Act of the Scottish Parliament to make provision for a national islands plan; to impose duties in relation to island communities on certain public authorities; to make provision about the electoral representation of island communities; and to establish a licensing scheme in respect of marine development adjacent to islands”

      Also the Marine Plan consultation roadshow is going to be at Rothesay on Thursday 9th May 2019 which an important opportunity to bring this up as an issue and get asking them how the new legislation will be integrated in the plan.

      This could be the way to pursue this issue – contact us by the FoFoC email if you want to follow this up and I’ll put you in touch with our contact our contact.

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