<a href=”https://friendsoffirthofclyde.org//wp-content/uploads/2018/11/Publication 2018 – Environmental Impact Assessment Handbook V5.pdf”>Download document here</a>Publication 2018 - Environmental Impact Assessment Handbook V5
We have however, some very serious concerns about this development:
- We are gravely concerned about the approval processes which have circumvented environmental assessment and regulation. Our concerns have been confirmed by senior legal counsel, who has reviewed the planning “paper trail” for us.
- This project involves significant dredging, pile driving, breaking up of 1000’s of tonnes of hazardous waste, including asbestos and radioactive materials, CFCs and the management of rotting marine matter.
- The decommissioning of the hazardous materials just 1km upwind from Fairlie could result in serious health impacts.
- The area proposed for the development is a designated under Nature Conservation Scotland Act 2004 as a Site of Scientific Special Interest (SSSI). The SSSI is designated for its sand flats and saline pools. Under that Act, it is an offensive for anyone to damage the notified features of a SSSI. The development will dredge half a million tonnes of sediment and destroy the SSSI’s notified feature.
- The SSSI is home to several OSPAR (Oslo/Paris Convention) Priority Marine Habitats and Species including rare molluscs and eelgrass beds. Under international agreement any threat of development to these PMF’s must be considered a significant environmental impact of national importance.
- Research on the coastal waters (Cumbraes Marine Consultation Area) adjacent to development site indicates persistent hotspots for European Protected Species and are a critical habitat for harbour porpoises. The famous solitary common dolphin ‘Kylie’ is resident within 500m of proposed the pile driving and construction site.
- There has been complete failure by planning authorities to assess the significant environmental impacts from the construction and operation of this port development. Environmental legislation has been circumvented and has been a manifest and systemic breach of Environmental Impact Assessment Legislation.
- All public bodies and officers have a duty to conserve biodiversity and uphold environmental legislation. North Ayrshire Council, SNH, SPEA and Marine Scotland are failing their legal responsibilities, the environment and surrounding communities. A Legal Opinion was sought from a leading Environmental Advocate QC who concluded that there have been serious flaws in the Public Bodies environmental decision-making processes.
- For the purposes of obtaining planning permission the site has been divided into small subsections to avoid critical scrutiny. A project of this complexity should have an Environmental Impact Assessment – which would assess the full impact to a protected area and be the minimum that Peel Ports should be willing to do in an area of outstanding beauty and environmental importance.
- We challenge the enormous use of tax payer’s money on this venture.
- Although rumoured to create 100’s of jobs, all other decom sites and industry experts indicate 25 to 50 jobs.
- Jobs in decommissioning are known to be very dangerous. Clydeport Operations have little to no experience, and it is a matter of record that they have a poor track record of safety. The Working Plan Clydeport have produced to support their SEPA application is exceedingly thin on detailed Health Safety and Environmental controls and is frankly lacking in substance.
- £10m is the first phase of the development. We feel an investment of this magnitude would be better spent advancing sustainable green industry that can sit alongside the tourism industry, the largest employer in North Ayrshire. Its is also stated that this is the first phase of investment, so we question how much government money could eventually be spend on this.
- Since 1974, accounting for inflation, a present day value of ~£1bn of public monies has been spent at Hunterston on failed industrial projects, netting no more than 100 jobs for a short number of years.****
- Supporters of industrialisation at Hunterston often quote it’s “unique deep water” jetty. Unfortunately, over the years as a trading coal port Peel Ports have allowed tonnes of coal to fall over the sides of the jetty, the deep water has gone from 35m of water to 16m. Peelports Coal slurry pollution continues to pollute Southannan SSSI.
- There have been many investigations into Peel tax arrangements over the years, they pay significantly less corporation tax than might be expected.
- The planning processes have been biased towards the developer and have given little to no consideration for residents and business which will be impacted by the development.
- Decisions were made during the planning approval on the clear understanding that environmental concerns would be addressed when Peel Ports applied for a Pollution Prevention Control licence from SEPA, a process open to public consultation. They have not done this but applied for a much less vigorous Waste Management License (WML) which does not require public consultation.
- All representations made by the developer to interested parties including North Ayrshire Council pre-planning permission were on the basis that decommissioning waste would be removed by sea and rail, with negligible effect on local roads. The WML application shows otherwise. The road infrastructure is totally unsuited to the proposed increase in heavy traffic.
- There are gross geographic scope anomalies between the area zoned for the planning permission and the SEPA application. Both the SEPA application and marketing videos demonstrate a much broader use of the Clyde. It has been consistently denied, even at public meetings, that the Hunterston Coal Jetty would form any part of the decommissioning project. The Waste Management Licence application clearly shows that it will be an integral part of the project. This will create even greater levels of noise and pollution directly affecting many homes. The Noise Assessment report which was relied on when planning permission was granted did not take the use of the Coal Jetty into account as the Coal Jetty is NOT included in the planning permission for the decommissioning. Therefore i) the Noise Assessment report is incomplete which is wholly unacceptable and ii) the Developer does not have planning permission for an essential element of their project.
- The approval of this planning consent will have a significant impact on residents, businesses and the environment. However, it is difficult or impossible to access information about the development. Peel Ports have not been forthcoming with any information. Residents have had to resort to Freedom of Information Requests in order to try to understand the magnitude of this project.
- Peel Ports dominate the Clyde having both interest as a private industry and as the port authority. Having board seats as both the Clyde Port Authority and as Industry on a number of quangos is certainly questionable.
Friends of the Firth of Clyde do not consider this to be a good investment for the people of Scotland. Laws put in place to protect the environment and residents must be adhered to. Jobs are welcome, but safe sustainable jobs with concern for the broader North Ayrshire economy and environment.
****The historic industrial investments since 1974 were:
- Bulk Iron Ore Terminal and associated facilities- £98m
- Direct Iron Ore Reduction Plants- £60m
- Oil Rig Construction Yard- £30m