The CMPP team, represented by Isabel Glasgow, Fiona Mills & Madlaina Michelotti, hosted an informative meeting that described the role of CMPP, including membership and governance of it’s Board; followed by an overview of the Clyde Regional Marine Plan and a lengthy question and answer session.
The Clyde Regional Marine Plan, once adopted by Scottish Government in 2020, will ‘provide a statutory policy framework to support effective decision-making and appropriate inward investment, enabling delivery of the Plan’s long-term vision and aims’. The Clyde regional plan, which interprets and supports Scotland’s National Marine Plan in a regional context over the next 20 years, is the first along with the Shetland Isles to take up the development of a Regional Plan.
The current draft Clyde Regional Marine Plan signals positive intent to shape future decision making on developments that affect the marine environment. Guided by an ‘eco-system approach’ its objective being to achieve balance between environmental, economic and social objectives for development of the Clyde Region.
We learned that the Clyde Region is complex with a large number of public and statutory authorities; environmental protection & enhancement organisations ; commercial organisations; and recreational interests within its boundaries – for instance 9 different planning authorities have a boundary with the Clyde Region, which covers the vast marine area that stretches from Glasgow, into the lochs of the northern reaches, across and beyond Bute to Loch Fyne, around Arran, down to the Mull of Kintyre and across to the mouth of Loch Ryan. The photo of the slide below shows the organisations that are members; it is interesting to see how Peel Ports/ClydePort is situated within both Public Authority (as the Statuary Harbour Authority) and Commerce.
Disappointingly, for our campaign for an Environmental Impact Assessment (EIA) to save Southannan Sands Site of Special Scientific Interest the timeline for adoption of the Clyde Regional Marine Plan is out of step with the current proposals that are on the table for Hunterston PARC. The plan has a number of stages to still go through, including a further public consultation phase, before it is adopted by the Scottish Parliament in 2020.
If the plan had been available to North Ayrshire Council at the start of the period when they were in consultation about Peel Ports’ proposals for decommissioning at Hunterston, it should have helped inform their decision making by requiring them to consider the implications of their land based planning approval on the marine environment.
Going forward it is clear that much more education is needed about planning responsibilities in the intertidal zone (ie between Mean High and Low Water Marks) and significant behaviour change will be needed in local councils once the plan is adopted to enable them to shift from a purely ‘landcentric’ to an ‘eco-system approach’ to reviewing planning applications.
Despite learning that the Clyde Regional Marine Plan at this point in time will not reduce the imminent threat to Southannan Sands SSSI, or help with the range of other questions that the FoFoC submitted about littering & hazard waste pollution and impact on the tourism economy, it was a useful opportunity to publicly air a number of our questions in the hope that raising CMPP’s awareness of our serious concerns about the imminent risk of irreparable damage that the decommissioning project will cause to Southannan Sands SSSI and the surrounding marine environment. Which in turn will help inform their thinking as a Statutory Consultee for the long awaited Marine Licence Application for the dredging required for the decommissioning project.
In response to our question about management of Clydeport / Peel Ports potential for conflicts of interest, we were referred to the CMPP Operational Guidance which outlines a risk matrix for mitigation of conflicts of interest. This is helpful to know, as it is clear that Peel Port / Clydeport should remove themselves from any discussions about Hunterston PARC and in particular those regarding CMPP being consulted as a Statuary Consultee on planning or licensing applications.
Our proposal about community membership of CMPP was met with some reservation on the basis of how this could be effectively organised over such a large and varied geographical area. But our suggestion that the community council infrastructure could be harnessed was met with some interest.
The suggestion that the Cumbraes Marine Consultation Area and the coastal SSSIs of the Clyde Region could be redesigned as Cumbraes Research & Development Marine Protected Area was met with interest and support – all be it with caveat that it would require a lot of work to achieve this.
We shall submit our formal response to the consultation by the 27th May 2019 and encourage you attend a meeting, take a read of the plan and submit your own comments by this date too.
At the end of the session Counsellor Ian Murdoch thanked the CMPP team for the way that the session had been ran, which was echoed by FoFoC. The manner in which the team provided the opportunity to ask challenging questions and were prepared to discuss ideas and suggestions made a refreshing change to the adversarial lack of transparency that we have grown to expect when raising questions about Hunterston.
Written Response to the Public Consultation
Following the public meeting we submitted our response in writing through the formal consultation route. You can read this below:CMPP Consultation_consultation-form_3March2019_Friends of the Firth of Clyde FINAL
We will watch with interest progress of the Clyde Regional Marine Plan, and in the meantime continue to campaign against Hunterston becoming a salutary case study in the future regional plan that serves to illustrate what happens when a fully integrated environmental assessment of complex projects, such as decommissioning, is not undertaken.