The FoFoC have submitted the following questions to the Clyde Marine Planning Partnership in advance of the Clyde Regional Marine Plan Public Consultation Event in Largs on 11th May 2019, 6-9pm.
Theme: Environmental Impact Assessment of Large Scale and Complex Development Proposals, including Decommissioning of Oil Rigs & Marine Structures
Question 1: The Clyde Regional Marine Plan clearly identifies Hunterston Peninsula as being the location of Southannan Sands Site of Special Scientific Interest (SSSI), which is a rare eel grass meadow, natural carbon sink and an active shell fish site that is populated by a number of OSPAR Protected Species. How will the plan address the serious and imminent environmental threat of proposals by Peel Ports to develop Hunterston Peninsula for decommissioning of oil rigs and large marine structures with no Environmental Impact Assessment (EIA) of the overall project?
Question 2: The Clyde Regional Marine Plan states that it will place higher responsibility on the proposers of developments to show that they will not damage valuable marine features. How will the plan ensure that mitigation is not used as a proxy by which to avoid the requirement for full and independent Environmental Impact Assessment (EIA) of large scale and complex proposals for decommissioning of oilrigs and large marine structures on the Firth of Clyde?
Theme: Balancing Business Against Environmental Conflicts of Interest.
Question 3: Clydeport Operations Ltd, which is part of the much larger Peel Group, is the Statutory Harbour Authority for the Firth of Clyde. This means as an organisation with wide commercial interests, it has decision-making powers over a number of marine activities on the Firth of Clyde, such as potentially allowing oil rigs for decommissioning to be cold stacked in environmentally sensitive locations such as Loch Striven. How will the Clyde Regional Marine Plan ensure effective systems are in place to monitor and manage potential conflicts of interest where business and statutory powers could be viewed to be in direct competition with environmental safeguarding?
Theme: Reducing the Volume of Litter Entering the Marine Environment
Question 4: The Clyde Regional Marine Plan states that marine litter is found across the Clyde Marine Region with shallow coastal areas exposed to prevailing southwesterly winds being particularly at risk of becoming litter congregation areas or ‘sinks’. Evidence from the Waste Management Licence Application submitted by Clyde/Peel Ports to SEPA for oil rig decommissioning at Hunterston PARC shows that unprecedented volumes of scrap metal, asbestos, NORM, organic marine matter and a range of other toxic & high risk materials will be brought to the site. The coastal village of Fairlie is exposed to the prevailing winds that come from the direction of Hunterston, and as such its shores are at risk of becoming a ‘sink’ for litter and potentially toxic waste that arises as a result of decommissioning activity. How will the plan ensure planners and licensing authorities fully and transparently assess these risks and reassure the local communities that the condition of the shoreline and health of residents will not be put at risk by any potential decommissioning developments?
Theme: Protecting the Tourism Industry Against The Impact of Industrial Development
Question 5: The Firth of Clyde is internationally known for its unique sailing waters and beautiful coast line, as such tourism makes a significant contribution to the economy of the region. What is the Clyde Regional Marine Plan’s policy for ensuring mechanisms are in place to undertake a full and comprehensive assessment of the economic impact of proposals for large scale industrial developments on tourism and related businesses? In particular, how will the plan ensure that an assessment of the economic impacts is undertaken with regard to Peel Ports’ proposals to develop Hunterston PARC for oil rig decommissioning and scrapping of large marine structures?
Theme: Meaningful Public & Community Involvement.
Question 6: Those communities who will be most affected by planning decisions should play a part in the decision making process. For far too long we have seen legislation requiring that bodies such as Clyde Marine Planning Partnership (CMPP) are required to consult with the general public, only to then see the views actually expressed by ordinary people ignored. Why is it that none of the community councils for the Clyde coastal areas are represented as stakeholders within the Clyde Marine Planning Partnership? We would like to propose that you accept a grouping of the various coastal community councils, as a significant partner and player within the decision making process of CMPP? – it could be called C4 (Clyde Coastal Community Councils).
Theme: Preserving the designation of the Cumbraes Marine Consultation Area and a proposal that Cumbraes MCA and coastal SSSIs of the Clyde Region to be redesigned as Cumbraes Research & Development Marine Protected Area
Question 7:The Clyde Regional Marine Plan appears to be dropping the Cumbraes Marine Consultation Area (Cumbraes MCA) designation. The designation is important on account of the area having recognised ecological, cultural and historical significance. Cumbrae MCA is an important instrument to help protect and enhance our marine environment, which if used properly it could be used to help drive an eco tourism strategy for the North Coast and provide an alternative to the industrial focus for economic growth being led by the development of Hunterston PARC. The health and sustainability of the Southannan Sands Site of Special Scientific Interest (SSSI) is dependant on a coherent network of sites and whatever happens in the Cumbraes MCA will have a significant impact on the SSSI and coastline of Fairlie and North Coast. What is the Clyde Regional Marine Plan’s position on preserving the designation of the Cumbraes MCA and what is its response to the proposal that the Cumbraes MCA and the coastal SSSIs of the Clyde Region be redesigned as Cumbraes Research & Development Marine Protected Area?