Friends of the Firth of Clyde Campaigning to Protect the Firth of - - PowerPoint PPT Presentation

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Friends of the Firth of Clyde Campaigning to Protect the Firth of - - PowerPoint PPT Presentation

May 21, 2023 254 likes •1.17k views

Friends of the Firth of Clyde Campaigning to Protect the Firth of Clyde & Environmentally Safe & Sustainable Development at Hunterston Peninsular Clydeport Oil Rig Decommissioning Proposals within Southannon Sands SSSI on the Firth of

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Friends of the Firth of Clyde

Clydeport Oil Rig Decommissioning Proposals within Southannon Sands SSSI

  • n the Firth of Clyde

email: secretary@friendsoffirthofclyde.org Facebook: Friends Of The Firth Of Clyde Web: https://friendsoffirthofclyde.org/ Feb19

Campaigning to Protect the Firth of Clyde & Environmentally Safe & Sustainable Development at Hunterston Peninsular

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Friends of the Firth of Clyde

Outline of the presentation

  • Who Are the Friends of the Firth of Clyde (FoFoC) ?
  • Geography and History of Hunterston Developments
  • Environmental Background
  • What Is The Project?
  • The Planning History
  • FOFOC Objections
  • What Next ?
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Friends of the Firth of Clyde - Who Are We?

Long Term Neighbours

  • f Clydeport

Residents who care about our environment, the welfare of

  • ur community and

sustainable economic development of the area.

Committee 5,000 Supporting call for EIA

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Friends of the Firth of Clyde – What Do We Want?

Sympathetic Development to Protect to Environment & Improve the Economy of the Region Raise Public Awareness Promote Engagement, Connect Communities & Influence Decision Making

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Friends of the Firth of Clyde - Geography

From Construction Yard Millport 1km Fairlie 1.5km Largs – 3-4km West Kilbride 3km Bute – 6km From Coal Jetty Fairlie 800m

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Construction Yard Coal Jetty

Friends of the Firth of Clyde - Geography

Coal Yard Dock

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SSSI

Friends of the Firth of Clyde - Geography

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History

Whistle-Stop Tour

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18th Century Glasgow was a huge trading port with North America, resulting in great wealth.

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Oceanspan - 1960

Grand Master Plan - Scotland's economic, industrial and social regeneration.

Ambition to create 20,000 jobs

  • Trade with USA
  • Build
  • Export to Europe
  • Worth the sacrifice
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1970 –Iron Ore Terminal

£98m invested in Terminal £60m in Reduction Plant Trans ship across the Atlantic Supply Ravenscraig and Motherwell Steel Works with coal.

Iron ore reduction never used as uneconomical

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1970 –Iron Ore Terminal

Protests from Fairlie So controversial required an act of parliament. Key condition to return the environment to original state

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1979 –Maureen Gravity Legs

Only 3 construction projects came to Fairlie in

  • ver 40 years
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1992 Ravenscraig Closes

Planning Permission demands that if iron

  • re terminal no longer

used Hunterston returned to original state. Terminal changed to Coal Handling. All coal to be moved via rail – but extensive road transport utilised.

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Clydeport

2003 1966 Clydeport Port Authority 1992 Privatisation of Clydeport

Port Authority: Controlled all shipping movement and activity on the Clyde from Irvine to the tidal weir in Glasgow.

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Friends of the Firth of Clyde – Neighbours of Clydeport

Apologies from Clydeport:

"We are currently focused on setting up the “formal” liaison group for the Marine Yard as required by our planning permission from April 2018". "We are also busy working on an “aspirational” master plan for Hunterston that we would like to share with all stakeholders in due course".

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History Lesson

Clydeport

Coal operations at Hunterston end 2016.

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Friends of the Firth of Clyde – Neighbours of Clydeport

Coal Dust Regularly Blown in on the Wind - Covering Surfaces in Fairlie

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Friends of the Firth of Clyde – Neighbours of Clydeport

Coal Slurry Leaking into the SSSI Litter & Debris in the SSSI Coal Dust Contaminating the SSSI

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Friends of the Firth of Clyde – Cesscon Decom

Potential Operators – Tenant's at Hunterston Clydeport Favour an OPEN PORT arrangement – any operator could come in.

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SSSI

Friends of the Firth of Clyde - Geography

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Friends of the Firth of Clyde

What Is Special About The Environment? Southannon Sands Site of Special Scientific Interest (SSSI)

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Friends of the Firth of Clyde

What Is The Oil Rig Decom Project?

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Friends of the Firth of Clyde

What Is The Project? ➢ What have we learned so far? ➢ Challenges to accessing timely reliable information ➢ Multiple statutory and regulatory bodies involved – complexity ➢ Regulatory framework running to catch-up with growth in demand

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Friends of the Firth of Clyde - SEPA Friends of the Firth of Clyde – SEPA

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Friends of the Firth of Clyde – What Is The Project?

In so far as we can gather…..

Semi-Submersible Rig

Is a marine vessel that moves around. Could be floated into the dry dock. Classified as a vessel – so can be legally moored at a port

Topside

Once disconnected the topside is the bit above water. Transported on a barge

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Friends of the Firth of Clyde – What Is The Project?

In so far as we can gather…..

Jacket

Structure previously been under water. Habitat for marine growth – within and attached

The Scale

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Friends of the Firth of Clyde – What Is The Project?

In so far as we can gather….. Prof Tom Baxter - Myths About North Sea Decommissioning Yes £17bn spend on oil rig decom, but only 3-5% on onshore work.

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Friends of the Firth of Clyde – What Is The Project?

In so far as we can gather…..

Dirty, Noisy, Smelly & Dangerous

https://www.youtube.com/watch?v=eV1qgmVeFv4

Oxyacetylene Cutting Drop Technique

Click to add text

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Friends of the Firth of Clyde – What Is The Project?

In so far as we can gather….. https://www.youtube.com/watch?v=eV1qgmVeFv4

Cut and Pull Technique: Dangerous, Noisy & Dusty – See time point 50mins for example:

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Friends of the Firth of Clyde – Where Is This Done?

In so far as we can gather…..

$3m paid for the scrap

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Friends of the Firth of Clyde – Where Is This Done?

In so far as we can gather…..

$1m paid for the scrap

“Blowtorch Beach” Turkey

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Friends of the Firth of Clyde – Where Is This Done?

In so far as we can gather…..

Narrowly averted environmental disaster.

Hunterston is 600 miles from Oil Fields and route is one of the worlds most exposed.

Transocean Winner –Grounded on Lewis

https://www.theguardian.com/business/2017/may/02/where-oil-rigs-go-to-die

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Friends of the Firth of Clyde – What Is the Project?

What does the Oil Industry say?

Transcript at 24m 36sec to 25m 10sec:

“We looked at 130 sites around the UK and the North Sea to bring the top-side to and we eventually selected Able UK on Teesside based on their track record, their safety track record, their environmental track record and the fact that this was a very heavily industrialised area so not creating noise, or dust or trucking material through communities.” https://youtu.be/6G7-JvhpCOM

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Friends of the Firth of Clyde – Decommissioning Fund

In so far as we can gather…..

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Friends of the Firth of Clyde – Decommissioning Funds

In so far as we can gather….. 2017 Fund of £5m

  • 1. Hunterston = £250k Feasibility
  • 2. Dundee – heavy lifting crane
  • 3. Kishorn – Upgrade dry dock
  • 4. Leith – make decom business.
  • 5. Decom Facility Methill, Fife
  • 6. Stornaway Port Decom
  • 7. Lerwick – equipment
  • 8. Lyness Decom – Orkney
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Friends of the Firth of Clyde – Decommissioning Funds

In so far as we can gather…..

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Friends of the Firth of Clyde – Jobs

In so far as we can gather…..

Employment? Clydeport (a section of Peel Ports) forecast up to 500 Job Equivalent Years The evidence of job creation from recent projects:

  • Brent Delta – V Large Rig

– 50 jobs

  • Dales Voe 35 jobs
  • Dundee 10 jobs
  • Methyl 30 + Jobs

​Five Myths About Decommissioning Oil Rigs - Prof Tom Baxter

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Smith

  • 1. Change from temporary to long term site license
  • 2. Decommissioning of the Coal Terminal
  • 3. Enlargement of the Dock
  • 4. Dredging around the Dock
  • 5. Caisson Gates
  • 6. Dredge entrance to dry dock
  • 7. Change of Use – 'Construction' to 'Decommissioning'

Friends of the Firth of Clyde – What is the project?

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Sinc nce 2018, CessCon n Decom have ve been based d at Hunt nterston

  • nClyd

ydepor

  • rt – This

is is their ir prom

  • motio

ional l vide deo

  • expla

xplain ining ing the pla lans ns for Hunt unterston Watch: h:

https://www.youtube.com/watch?v=AFMb9jmwgwU

Friends of the Firth of Clyde – What Is the Project?

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What will it take to get Hunterston fit for purpose? GMB Scotland (2016) Review of Capability & Capasity

  • f Decom Facilities in Scotland
  • Hunterston is ranked lowest out of total of 19 yards
  • 80,000 sqm of 'Capital' dredging
  • Extensive piling
  • Major construction work
  • All in the area of the SSSI

Friends of the Firth of Clyde – What Isn't Explained?

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Cold Stacking Where are the rigs kept whilst they are waiting to be decommissioned? ….. Loch Striven???

Friends of the Firth of Clyde – What Isn't Explained?

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CessCon describe the Coal Jetty as the 'Wet Storage & Asset Preparation Area' - This is a material change of use The planning permission specifically excludes the use of the Coal Jetty for any decom related activity

  • No assessment has been made of the environmental

impact of the inclusion of the coal jetty

Friends of the Firth of Clyde – What Isn't Explained?

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Transportation of the Scrap Metal & Hazardous Waste from the Yard? The Operational Plan shows use of roads for disposal – the planning application states sea and rail will be used. No assessment of the impact of road use by heavy vehicles through local communities

Friends of the Firth of Clyde – What Isn't Explained?

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Environmental Impact of Hazardous Wastes ? Vast amounts of Scrap and Hazardous Waste – how will they be managed? What is the health impact? A Pollution Prevention & Control (PPC) License was expected - a Waste Management License (WML) was submitted... so no public consultation required

Friends of the Firth of Clyde – What Isn't Explained?

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Friends of the Firth of Clyde – What isn't Explained?

SEPA Waste Management License Submitted 2018 Details unprecedented levels of toxic waste Asbestos CFCs PCB’s Glycol NORM Heavy Metals Marine Growth

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What will Be the Impact of Noise? On residents, marine and bird life Clear line of sight and therefore sound transmission across to the water to Fairlie & Millport. Noise assessment modelled against set of assumptions that construction nose is the same as decom noise Times of operation – 8am – 10pm early morning to late evening

Friends of the Firth of Clyde – What Isn't Explained?

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Decomposing Marine Growth: Smell & Disposal Decomposing marine matter is a recognised hazard What disposal routes will be used? Significant challenges identifying landfill or composting sites close by that are willing to accept marine growth remains a challenge for disposal yards (Oil & Gas UK 2013)

Friends of the Firth of Clyde – What Isn't Explained?

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Friends of the Firth of Clyde

The Call For An EIA

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Friends of the Firth of Clyde

EIA Process

  • Preparation of an EIA report
  • Completion of consultation, publication

and notifications

  • Examination of the EIA report and any
  • ther environmental information by the

competent authority or Scottish Ministers

  • Determination or conclusion of the

significant effects of the proposal on the environment

  • Integration of the conclusion into the

decision notice to be issued in terms of relevant regulations

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EIA Legislation & Procedure

EU Environmental Impact Assessment Directive Town & Country Planning EIA Regulations Marine Works EIA Regulations Is the project a mandatory Schedule 1 development ? Is the project a Schedule 2 development ?

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EIA Scoping & Screening

Peelports North Ayrshire Council Planning Marine Scotland Licensing Scottish Natural Heritage Scottish Environmental Protection Agency Terrestrial planning Marine planning EPS license Dredge license Waste Management License Environmental consultee Developer

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Is the project described in Schedule 1

  • f planning regulations?

EIA is required

Is the project described in Schedule 2

  • f planning regulations?

Is the project described in a sensitive area as defined in the EIA Regulations Does it exceed any of the thresholds in Schedule 2 planning regulations Is it likely to have significant environmental effects on the environment? EIA is not required EIA is not required EIA is not required

No No Yes No No Yes Yes Yes

EIA is not required EIA is not required EIA is not required

No No No Yes

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What is the project?

  • The ‘project’ will involve the development of a trading port in 840,000 m2 yard
  • Vessels over 20,000 tonnes engaged in loading, unloading & trading of scrap
  • The port will handle asbestos up to 1000 tonnes
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Is the project described in Schedule 1 of planning regulations? YES – A mandatory Schedule 1 EIA should be instructed as falls within Schedule 1 project descriptions

EIA Project Category Project Description Project Threshold Schedule 1 (5c) Asbestos: other uses of asbestos >200 tonnes per year Schedule 1 (8b) Trading ports, piers for loading and unloading Vessels > 1,350 tonnes Schedule 1 (24) Change or extension of a project where extension meets threshold All developments

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EIA Project Category Project Description Project Threshold Schedule 2 (1e) Reclamation of land from sea All developments Schedule 2 (4d) Processing of metals Area exceeds 1000m2 Schedule 2 (4e) Installation and modification of metals Area exceeds 1000m2 Schedule 2 (4g) Shipyards Area exceeds 1000m2 Schedule 2 (10m) Coastal Works All developments Schedule 2 (11e) Scrap storage Exceeds 0.5ha within 100m of controlled waters Schedule 2 (13) Any change or extension of a project When development will have significant environmental effects

Is the project described in Schedule 2 of planning regulations?

YES

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Is the project described in Schedule in a sensitive are as defined in EIA Regulations?

YES

  • Southannan Site of Special

Scientific Interest

  • Cumbrae’s Marine Consultation

Area

  • Protected Shellfish Waters
  • Portencross SSSI, Kames Bay

SSSI, Ballochmartin Bay SSSI

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EIA Project Category Project Description Project Threshold Schedule 2 (1e) Reclamation of land from sea All developments Schedule 2 (4d) Processing of metals Area exceeds 1000m2 Schedule 2 (4e) Installation and modification of metals Area exceeds 1000m2 Schedule 2 (4g) Shipyards Area exceeds 1000m2 Schedule 2 (10m) Coastal Works All developments Schedule 2 (11e) Scrap storage Exceeds 0.5ha within 100m of controlled waters Schedule 2 (13) Any change or extension of a project When development will have significant environmental effects

Does it exceed any of the thresholds in Schedule 2 planning regulations

YES

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Is it likely to have significant environmental effects on the environment?

YES

Nature Conservation Scotland Act 2004 The destruction of a SSSI notified feature (sand flats & saline pools) is without question a significant environmental impact of national importance. OSPAR Priority Marine Features Any development threat to OSPAR listed priority marine feature (eelgrass, maerl, mussel habitats etc) is considered a significant environmental impact of international importance.

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Removal of sediment is contrary to North Ayrshire Council Policy

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80,000m2 of sandflat and saline pools to be dredged Contrary to Joint Nature Conservation Commitee guidelines Contrary to SNH guidlines

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Friends of the Firth of Clyde

Overview of Planning

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Friends of the Firth of Clyde – Planning Timeline

2012

EIA Screening Request

2017

EIA Screening Mtg NAC SNH Marine Scotland Dock Extension Change of USE – addition of decommissioning Dock Extension Caisson Gates

2016

Removal of 5 year temporary license conditions to permanent SNH agree SO LONG AS THE CONDITIONS OF USE DO NOT CHANGE

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Friends of the Firth of Clyde – Planning Timeline

Freedom of Information Request to Scottish Natural Heritage (SNH) EXTRACT FROM SNH LETTER:

"We attended the screening meeting at the Hunterston site on 23 January 2017. At the meeting we expressed the opinion that due to the scale, the introduction of new processes and the complex nature of the entire project, it would be sensible to request the production of an EIA…. …We are aware of the risks to the SouthannanSands Site of Special Scientific Interest (SSSI), however dust and other potential sources of pollution are under the control of SEPA through their Pollution Prevention Control and Waste Management licensing systems. We have requested that SEPA take these risks into consideration when they consider the Waste Management License Application.

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Friends of the Firth of Clyde – Planning Timeline

2012

EIA Screening Request

2017

EIA Screening Mtg NAC SNH Marine Scotland Dock Extension Dock Extension Caisson Gates Change of USE Formal EIA Screening Request NAC Marine Scotland

2017

Dock Extension Caisson Gates Change of USE SNH agree SO LONG AS THE CONDITIONS OF USE DO NOT CHANGE

2016

Removal of 5 year temporary license conditions to permanent

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Friends of the Firth of Clyde – Planning Timeline

Marine Scotland – Email NAC to suggest joint approach. SNH frustrated as understand decommissioning to be only a pre-application discussion NAC issue Negative EIA Screening without Marine Scotland Marine Scotland – under pressure 4 weeks later to issue EIA Screening for Phase 1

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Friends of the Firth of Clyde – Planning Timeline

2012

EIA Screening Request

2017

EIA Screening Mtg NAC SNH Marine Scotland Dock Extension Dock Extension Caisson Gates Change of USE Formal EIA Screening Request NAC Marine Scotland

2017

Dock Extension Caisson Gates Change of USE

2018

3 Town and Country Planning Permissions NAC Dock Extension Caisson Gates Change of USE

PLANNING GRANTED APRIL 2018 NO EIA REQUIRED

2016

SNH agree SO LONG AS THE CONDITIONS OF USE DO NOT CHANGE Removal of 5 year temporary lice nse conditions to permanent

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Friends of the Firth of Clyde – Notable Planning Conditions

Removal of Temp Restriction

  • 1. Restricted to large marine vessels
  • 2. Operations must minimise nuisance noise, dust, smell, vibration and pollution.
  • 3. No blasting or pile driving from 10pm until 7am.
  • 4. No operations from 10pm -7am without NAC permission.
  • 5. Hours of operation and lighting to be agreed with NAC
  • 6. If the site is disused for > 1 year all buildings and scrap will be removed.

Use to Allow Decom

  • 1. Decom = Oil Rigs, platforms or similar.
  • 2. Storage only for those being actively decommissioned.
  • 3. Agree with NAC disposal of excavated material and effluents.
  • 4. Agree methods to prevent pollution of SSSI
  • 5. Noise <5dB(A) over background noise. –but excludes SEPA and Marine Scotland works.
  • 6. Within 3 months a draft Code of Practice for the operation to be issued to NAC to

include a liaison committee. – Clydeport took 8 months. Caisson Gates

  • 1. Provide a Construction Method Statement to include:
  • Risk to Marine Mammals
  • Prevent SSSI Pollution
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Friends of the Firth of Clyde – Liaison Committee

Planning Conditions Require the Establishment of a Liaison Committee within 3 Months of Planning Approval in April 2018 - !st Meeting Scheduled for 18th March 2019 (ie: 11 Months) Membership The members of the Liaison Committee to be limited to the following: North Ayrshire Council – 2 named Local Councillors and their nominated deputies when they are unable to attend in person; CumbraeCommunity Council – a named representative and their nominated deputy when they are unable to attend in person; Fairlie Community Council – a named representative and their nominated deputy when they are unable to attend in person; West Kilbride Community Council – a named representative and their nominated deputy when they are unable to attend in person; Peel Ports/Operator – up to 3 representatives between the landowner and the site operator. Attendees flexible subject to matters to be discussed; Chairperson – the appointment of a named independent chairperson; Secretariat – Peel Ports to act as secretariat

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Friends of the Firth of Clyde – QC Opinion

Douglas Armstrong QC Highly respected planning matters. He has particular expertise in large- scale infrastructure projects and waste management projects. Four key issues :

  • NAC / MS do not explain the reasons why this is not

‘Schedule 1’ development.

  • the test the Council should look at is whether the

development is likely to have significant effects on the environment... There does not appear to be any consideration of the wider effects in the assessment by NAC

  • NAC stated an EIA could be avoided through mitigation - a

planning authority should decide whether an EIA is needed based on the "characteristics and effects of the proposal as presented to the authority , not by reference to steps subsequently taken to address those effects".

  • Significance of the combined adverse effects on the

environment of the three separate planning applications.

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Construction Yard

Friends of the Firth of Clyde – Planning Permission

Dock Planning Permission Only for Construction Yard and Dock as below in Red.

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Friends of the Firth of Clyde – Planning Timeline

2018

Cesscon Decon Video Asset Preparation Jetty From Cesscon Website

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Friends of the Firth of Clyde – Planning Timeline

Unique Deep Water – not 40m, but 18m due to coal build up.

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Friends of the Firth of Clyde – Planning Timeline

SEPA Waste Management Licence SEPA

2018

  • 1. Can only apply for WML for

location with planning permission.

  • 2. Reference to Asset

DISMANTLING on the Coal Jetty.

  • 3. During Planning Permission

process the Clydeport Stated “The resulting scrap materials would be transported from site via the sea or rail. Any impact

  • n the road network would be

negligible.” Significant reference to road transport in WML

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Friends of the Firth of Clyde – Planning Timeline

SEPA Waste Management Licence SEPA

2018

  • 4. Unprecedented levels of

toxic waste Asbestos CFCs PCB’s Glycol NORM Heavy Metals Marine Growth

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Friends of the Firth of Clyde – Planning Timeline

SEPA Waste Management Licence SEPA

2018

  • 5. HSE Assessment of the Working Plan
  • Significant Health, Environmental and Safety risk in

the activities

  • Limited experience of the names Responsible

Persons.

  • Open Port Arrangement - No clear lines of

responsibility

  • Emergency Plans – don’t address decom activities.
  • Concerns about Clydeport attitude to safety and

track record.

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Friends of the Firth of Clyde – Planning Timeline

SEPA Waste Management Licence SEPA

2018 SEPA will advise update

  • SEPA have confirmed no WML only applied to

Construction Yard.

  • Aim for this to be a benchmark
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Friends of the Firth of Clyde – Planning Timeline

Extract of Statement from Marine Scotland: …licensable marine activities including capital dredging and construction. EIA Regulations-MS-LOT was of the view that the project as described constituted Schedule two works, which are works likely to have significant effects on the environment by virtue of factors such as their nature, size or location. Following consultation with Scottish Natural Heritage, a negative screening opinion concluding that an EIA was not required was issued to Peelportsby MS-LOT on 13 June 2017. MS-LOT is yet to accept valid applications for the proposed works and is liaising with the applicant to establish if the current proposal remains in line with that screened in June 2017. Where any application is received for works which are considered to differ in terms of nature, size

  • r location to the proposal on which screening was based, MS-LOT would mandate a new

screening process. Should any subsequent proposal differ to that screened, to the extent to which it is screened in to EIA, it would be MS-LOT’s intention to publicisethe following ‘scoping’ stage, at which the necessary studies and assessments are agreed, on our webpages.

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Friends of the Firth of Clyde

Campaigning to Protect the Firth of Clyde & Environmentally Safe & Sustainable Development at Hunterston Peninsular

NEXT STEPS

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Friends of the Firth of Clyde

✓ We firmly believe this complex and high risk project should have an EIA. ✓ There has been significant change since initial requests for the EIA screening. ✓ Clydeport and Authorities need foster

  • pen communication and trust with the

community

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Friends of the Firth of Clyde

✓ Sign-up as a Supporter of the Friends of the Firth of Clyde ✓ Sign our Petition ✓ Marine Licence Application – Public Engagement – Read This ✓ Lobby Your Public Officials – Community Councillors; Elected Officials & MSPs ✓ Ask NAC who your Liaison Committee Member is - have they been informed are they attending on 18th March 2019? ✓ Get involved & ask questions and tell your neighbours, family & friends about what is happening

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Friends of the Firth of Clyde - SEPA

Name Position David Ogilvie Decom Sector Lead Pamela Armstrong Unit Manager – Waste Team West Scotland David Walker Environmental Protection Officer

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Friends of the Firth of Clyde - Panel

Name Position Karen Yeomans North Ayrshire Council (NAC) Executive Director (Economy & Communities) Jim Millar Head of Planning NAC David Ogilvie Pamela Armstrong David Walker Scottish Environmental Protection Agency (SEPA) Anne Carson Largs Community Council Ian Murdoch Alex Gallagher NAC Councilors David Nairn Clare Baguley Caroline de Jong Friends of the Firth of Clyde