FoI request re 11/00310 Text of objections 37- 75 Objection 37 I am writing to object to the Babcock Proposal to create a Container Terminal at its site in Rosyth. This development will not make the published contribution to the economy because a container terminal services demand, it does not create demand. Any jobs created here will be lost elsewhere in the Scottish distribution business. The volume increase in traffic will significantly increase the risk of accident on the A985. Noise will be a significant issue, the banging of containers and noise of large lorries will create a significant distrubance for the residents of Limekilns. Objection 38 I write to lodge my objection to the above application and the development of a container terminal in Rosyth by Babcock. The reasons for my objections are as follows:-

1. Babcock are trying to undertake this development without following the democratic planning process thus avoiding public consultation

2. There is already a container port at Grangemouth which has better transport infrastructure than Rosyth and could be easily increased in size without detrimental effect

3. A container terminal in Rosyth would not in itself create growth in the local economy and will not create significant numbers of new jobs (reference the applicants transport assessment which states that “the impact of staff trips will be minimal due to the low number of staff required”.)

4. A container terminal in Rosyth would cause further traffic problems particularly during the construction of the new Forth Replacement crossing.

5. Despite many concerns raised by residents and the community council about the safety of the Limekilns junction on the A985, no assessment has been made on the impact of additional traffic. This junction is already a danger to residents due to the speed and amount of traffic on the A985.

6. Rosyth cannot accommodate ships any larger than those served by Grangemouth due to the limits imposed by the forth rail bridge.

7. Access to the new berths will require massive dredging which will cause irreversible damage to the stability of the sand and sediment on the sea bed with the consequent risk of damage to and undermining of sea walls, piers and houses in our village not to mention the bird and marine life which has special protection.

8. Loading and unloading operations 24/7 will cause intermittent loud and disturbing night time noise.

9. The granting of a harbour revision order would give the applicant a virtual free hand to do whatever they like with the site and the seas around it.

Item 7 is of particular concern as I live at ________which is across the road from the sea wall. I would be grateful if you could acknowledge receipt of my objection. Objection 39 I am writing lodge the deepest objection to the proposed ‘ Harbour Revision Order’ application by Babcock in order that they may develop their International Container Terminal. In the event that this application is granted, it is imperative that you understand the severely detrimental consequences for the local residents and the environment itself. I would first like to raise my objection to the lack of public acknowledgement of the real concerns voiced by community council during the ‘pre-application consultation period’, on behalf of the residents . There is little indication that any of our concerns have been taken into account. As a representative of our Scottish government, I would ask that you consider the individual and democratic rights of the people of Scotland over the avarice of ‘big business’. I have a significant number of concerns to raise but these can be conveniently categorised under the following headings: There no evidence that this project would contribute to the economy of Fife. It is well documented that container terminals service existing industry rather than make any significant economic addition to local economies. There is considerable evidence to suggest the promised jobs would not materialise. Since Grangemouth, the existing container terminal has generated only 50 jobs, it would seem logical to conclude the suggested figure of 200 jobs is a gross exaggeration. Traffic would inevitably increase at an already hazardous junction. This will significantly endanger the lives of the residents who have to use this junction regularly. This objection is directly related to a major concern that has been the subject of a sustained and lengthy local campaign to improve the level of road-safety on the A985 as a whole, and the area of the Limekilns junction in particular. There is considerable evidence to suggest this development would seriously undermine the piers and sea walls that protect the residences on the water front. Dredging of the area will cause irreversible damage to the geological composition of the sea-bed, sea walls and piers. This, in turn will endanger the safety and stability of our homes and ecologically damage the habit of both bird and marine life in the area. Residents would be subjected to an intolerable increase in industrial noise level not only during the day but at night as well, seriously affecting the quality of life of the residents. It is obvious that the economic viability of the container terminal will require it to be operational at times of high tide irrespective of what actual time this occurs. The estimated noise level of this operation gives rise to serious concerns about the health and safety of local residents with respect to their ability to sleep and indeed, relax.

In conclusion: It should be remembered and noted that the majority of the residents in the area have made an active choice for a residential life-style that is rural as opposed to urban, and this development will significantly alter their environment both physically and ecologically. In these times of serious environmental concern, it is surely unacceptable to force such an environmentally detrimental change on the local community. Objection 40 I would like you to record my objections to the above for the following reasons:

• It will allow the site to be developed without following the democratic planning process;

• Babcock say that they will handle 400,000 containers per year at Rosyth without taking business from other operators. This is flawed. 400,000 containers is more than currently goes through all Scottish ports and freight terminals in a year. This is no evidence of a significant additional requirement and to say that Grangemouth won’t be affected is pie in the sky;

• If there was a need, Grangemouth could easily double its capacity without significant upgrade;

• This terminal would significantly increase traffic on roads that would not support such increased traffic. No assessment of this increased traffic has been carried out;

• Rosyth will not be able to accommodate ships any larger than that which currently uses Grangemouth due to the restrictions imposed by the Forth Bridges;

• Access to the new berths at Rosyth would require dredging to open up a channel and to maintain it afterwards. This would have a massive effect on the sediment and sand on the sea bed with the consequent risk of damage to the sea walls, piers and houses in Limekilns as well as impact on the bird and marine life which have special protection;

• Loading and unloading operations will cause massive impact on the residents of Limekilns due to loud and disturbing noise.

• The 200 forecast operational jobs is highly exaggerated and will not materialise. (Grangemouth has only around 50 operators);

• It is likely to be a third white elephant in the Dunfermline area following Hyundai and Lexmark together with irreversible damage to the environment;

• One of the criteria for the inclusion of a project in the National Plan is that there should be a full assessment of the carbon impact of the project. There is no assessment of the carbon impact in the Environmental Statement

Objection 41 I am writing to object to the Babcock Proposal to create a Container Terminal at its site in Rosyth. In my opinion the project:

1. Will not make the published contribution to the economy because a container terminal services demand, it does not create demand. Any jobs created here will be lost elsewhere in the Scottish distribution business. 2. The volume increase in traffic will significantly increase the risk of accident on the A985 3. The environmental impact has not been fully assessed. To add additional, unnecessary, capacity in a container distribution will INCREASE our carbon footprint, not reduce it!! 4. Noise will be a significant issue. Finally, Babcock are clearly looking to develop their site at Rosyth, should they not channel these efforts in to engineering related activities (their core business) which actually service demand. For example wind and wave turbine production. Objection 42 Objection: “Babcock: Harbour Revision Order” I am aware of the planned development of container terminal on the RD57 basin in Rosyth dockyard and that Babcock instead of pursuing full planning permissions for and new and invasive operation have instead chosen to pursue a “harbour revision order”. Having no detailed knowledge of the processes involved I can only presume that this path was chosen in the hope that this will “ease” their normal planning burden. As you may be aware Limekilns is a historic and rural village community on the coast of the river forth to the west of Rosyth dockyard. As Limekilns is a very quiet location the noise generated from the dockyard at night, particularly the drumming of ship engines when they are in final preparation after refit, is indeed annoying and can currently cause sleepless nights for me and my children. Rosyth dockyard has been a major employer in the area for a significant number of decades and in general has been sympathetic to the impact of their business on the local community. In recent years Babcock (current owner occupier) have continued in this vein and when there is planned construction work which may cause “night or weekend disturbance” to the village community (such as the recent works for the carriers) the community are generally informed in advance. As however this has been infrequent, short term, and usually coming with an apology, this has been tolerable. The planned development location (Figure 1) will introduce a 24hour a day, 7 days a week, “noise generation” at a site over 0.5km closer to the village than current nearest main dockyard operations and also moving the nearest “drumming” ship from A to B in Figure 1.

B

A

Figure 1 As all parties should be aware of the likely “noise impact” on Limekilns and it is quite plain from the photograph (Figure 1: taken from the Babcock submission) that Limekilns houses are visibly the nearest impacted community for the site: Even although some of the nearest housing has been covered by the “Site for international container terminal” label, which I do hope was placed without intent to misinform the viewer. I attended the Babcock RICT Exhibition on 30Sep2010 at Charlestown where I was informed that there had been a noise survey with headline “dB” figures and admitted that the highest noise recorded was that of the “Dawn Chorus”. The Babcock staff in attendance were not noise engineers and could not answer any queries put having left my details they promised to send me the raw data on which the survey was based. I also asked them that if they could to provide the current level of noise from existing platforms making ready for Sea which currently causes my family disturbance such that I could make a direct comparison. No such information has been provided. As you will be aware “disturbance” is not only related to average dB but also discernable changes in noise level. The health impacts of such disturbance on a quiet rural community are as yet unproven and I have no desire for myself or my family to be guinea pigs. I must therefore complain and formally object to the “Babcock: Harbour Revision Order” application on the grounds that: 1) The level of “night” noise from the dockyard in the last 15years has been

low and when “night working” does take place causes “disturbance” for me

and my family: in particular the drumming of ship engines when they are in final preparation after refit. The noise generation 24hours a day 7 days a week and being 0.5km closer to the village than current main dockyard operations will have a significant impact on both my family’s and the local communities sleep pattern and hence could affect overall health;

2) The 24hour a day illumination will cause light pollution further disturbing the nearest limekilns housing and providing and visual industrial eyesore on a rural part of the Forth;

3) That the increase in road traffic on the A985 will increase the risk at limekilns junction where there have already been significant accidents and fatalities;

4) That there is no “strategic” need for such a terminal as this has been stated quite clearly by Forth Ports who operate the current container terminal at Grangemouth who have excess capacity and can quickly develop more with much less environmental risk;

5) That the development will have a clear impact on the desirability to live in the village and hence value of my property;

6) That the proposed infrastructure “improvements” in support of the venture will cause further harm to the village and are out of proportion to the few jobs that are planned to be created;

Objection 43 I object to Babcock using a Harbour Revision Order rather than the normal planning procedure through Fife Council. The development of the Harbour into a Container Port would have a very large environmental impact on the surrounding area with noise and traffic, and this should be considered in a Planning Forum involving the local Community. There needs to be a more detailed and transparent analysis of the need for this Container facility, when the ones at Leith and Grangemouth are not at full capacity, and a less exaggerated estimate of the employment gain. I am aware that the local Community Council have submitted a detailed report which does not share Babcock's enthusiasm. Objection 44 Last year my wife and I attended a presentation in Charlestown by Babcock regarding proposed developments at their Rosyth terminal. We had no serious concerns then but having received further information we now have strong objections to the development. These are as follows: 1. It is accepted that there is a need for increased container capacity on the Forth. However, this could be provided by Grangemouth container port without significant upgrade. 2. Even with significant and regular dredging Rosyth does not offer any advantages over Grangemouth. 3. A Babcock representative stated that much of the freight traffic would be moved by rail. This was reassuring given that the Limekilns junction with the A985 is hazardous at peak times with existing traffic levels. It now appears

that access to main rail routes is very limited by the existing junction configuration and rail is not a viable option. 4. He also stated that most terminal road traffic would be routed East and over the Forth road bridge. With the scheduled construction of the Forth replacement crossing this will not be possible. 5. Babcock said the terminal would provide approximately operational 200 jobs. Given that Grangemouth has just 50 operators and the Transport Assessment states that 'only a low number of staff will be required' this is questionable. 6. Babcock have now applied for a Harbour Revision Order which will allow them to develop their site irrespective of the interests of local communities. 7. Our view of this is: a. Babcock management have doubts about the viability of their proposed Container Terminal and are seeking insurance should it fail. b. The proposed development will cause considerable disruption locally with no compensating improvements to the wider economy. c. Babcock management lack the integrity to argue their case openly and honestly. d. Babcock should be denied the Harbour Revision Order and be required to make Planning Applications for all developments on the Rosyth site. Objection 45 We write to add our strong objection to this "planning application" which seems to be proceeding with little or no regard to the democratic planning processes and without addressing the many significant concerns of the community in Rosyth, Limekilns and Charlestown and Pattiesmuir areas. The local Community Council have spelled out their objections in great detail and in a well constructed manner. My wife and I are very happy to support the Council and endorse their objections. Objection 46

Objection 47

Objection 48 I write to lodge my objection to the above application and the development of a container terminal in Rosyth by Babcock. The reasons for my objections are as follows:-

1. Babcock are trying to undertake this development without following the democratic planning process thus avoiding public consultation.

2. There is already a container port at Grangemouth which has better transport infrastructure than Rosyth and could be easily increased in size without detrimental effect.

3. A container terminal in Rosyth would not in itself create growth in the local economy and will not create significant numbers of new jobs

(reference the applicants transport assessment which states that “the impact of staff trips will be minimal due to the low number of staff required”.)

4. A container terminal in Rosyth would cause further traffic problems particularly during the construction of the new Forth Replacement crossing.

5. Despite many concerns raised by residents and the community council about the safety of the Limekilns junction on the A985, no assessment has been made on the impact of additional traffic. This junction is already a danger to residents due to the speed and amount of traffic on the A985.

6. Rosyth cannot accommodate ships any larger than those served by Grangemouth due to the limits imposed by the Forth Rail Bridge.

7. Access to the new berths will require massive dredging which will cause irreversible damage to the stability of the sand and sediment on the sea bed with the consequent risk of damage to and undermining of sea walls, piers and houses in our village not to mention the bird and marine life which has special protection.

8. Loading and unloading operations 24/7 will cause intermittent loud and disturbing night time noise.

9. The granting of a harbour revision order would give the applicant a virtual free hand to do whatever they like with the site and the seas around it.

Item 7 is of particular concern as I live at ___________ which is across the road from the sea wall. I would be grateful if you could acknowledge receipt of my objection. Objection 49 We ask that the condition in Section 1 be attached to the order. If this will not be applied, then please consider this representation as an objection. Please also note the advice provided below. Advice for the planning authority 1 Pollution Prevention Plans

1.1 Within the Environmental Statement (ES) a number of management plans and pollution prevention documents (see list below) are proposed to minimise the potential for pollution to the environment from the proposed development.

Paragraph 5.6.9 – Environmental Management Plan Paragraph 5.6.9 – Construction Code of Practise Paragraph 5.6.23 – Pollution Prevention Plan Paragraph 5.6.26 – Pollution Incident Response Procedure Paragraph 9.8.14 – Emergency Pollution Response Plan Paragraph 11.11.30 – Environmental Management System for contaminated

land Table 15-5, ME8 – specific site construction method statements and environmental management plans

1.2 We would recommend that for ease of production and maintenance that the

documents listed above are condensed into fewer documents or a single Environmental Management Plan.

1.3 The ES does not provide a commitment that all the documents listed in Section 1.1 will be developed prior to construction. However, in order to minimise the risk of environmental pollution to the sensitive receiving water environment from the construction phase onwards all environmental management documents should be completed by the start of the development. We therefore seek that a condition be attached to the Order to ensure the document(s) are developed and submitted prior to the commencement of works on site. We recommend the following wording:

No works shall be commenced until the Scottish Ministers have, following consultation with the Scottish Environment Protection Agency, approved an environmental management plan (and any other relevant pollution prevention documents required to cover the issues in section 1.1 above) for the works. 1.4 We note with approval that commitments are made within the ES in Section 5.6

and 9.8 that mitigation will include adherence to best practice and confirmation with SEPA and other relevant guidelines and that an Environmental Clerk of Works will be on site during construction (paragraph 5.6.10). The strict adherence to pollution prevention measures and best practise guidance during the construction and operation of this site is of particular importance due to the potential for this development and the construction of the new Forth crossing to be occurring simultaneously within a short stretch of the sensitive River Forth.

2 Marine Non-Native Species

2.1 Accidental introduction of marine non-native species has been highlighted as a risk for waterbody degradation under the Water Framework Directive. We therefore recommend that the current commitment for vessels to comply with the International Maritime Organisation guidance (paragraph 9.8.18) is extended to minimise the risk of non native species being introduced due to attachment to boat hulls and legs of apparatus during construction in line with Water Framework and Marine Strategy Framework Directive objectives.

2.2 We therefore seek that the best practise guidance contained within the Marine Non-Native Species Guidance (http://www.ogp.org.uk/pubs/436.pdf), SNH website http://www.snh.gov.uk/land-and-sea/managing-coasts-and-sea/marine-nonnatives/ and leisure boat advice www.thegreenblue.org.uk/youandyourboat/alienspecies.asp is incorporated into the proposed Environmental Management Plan for the site. Further detail on this issue is provided for the applicant in section 7 of this letter.

3 Contaminated Land and Hydrogeology

3.1 The site has not been designated as a Special Site under Part IIA of the Environmental Protection Act (1990), and the site has not been identified as Radioactive Contaminated Land under Part IIA of the Environmental Protection Act (1990). The Local Authority is the lead regulator for Contaminated Land and should be contacted for information in this respect.

3.2 It is agreed that it is reasonable to assume that the made ground located within the West Tip should be considered a potential source of contamination. (paragraph 11.3.17)

3.3 We welcome the proposal for a soils re-use management plan (paragraph 11.11.14) to be developed for the site and recommend that the guidelines set out in the SEPA document Land Remediation and Waste Management Guidelines are adhered to. http://www.sepa.org.uk/waste/waste_regulation/idoc.ashx?docid=567836f1-dfa6-4d13-a6d0-0b07f4b2d614&version=-1

3.4 We agree with the text in paragraph 11.11.8 that there is the potential for contaminated groundwater to be present on the site and that further assessment is required to establish the risks, with remedial action potentially required to protect the water environment if contaminated groundwater found on site.

3.5 The ES states in paragraph 11.10.2 that historic groundwater level and quality data is currently not available and also that groundwater monitoring wells are required on site. It is considered essential that a detailed investigation of contamination on site, including hydrogeological impacts, monitoring and testing should take place before construction commences, in order that appropriate mitigation is developed and the findings inform the design.

3.6 We have been in contact with the applicant’s agent during the consultation process and now understand that the commitment in paragraph 11.6.5 is to undertake a detailed site investigation prior to the commencement of construction on site (please see the letter from Jacobs dated 21 February 2011 which is attachment 1 of this letter and the amended text is reproduced below). We therefore seek that the ES is amended accordingly to make this commitment, including Table15-1 point W18.

Altered wording on paragraph 11.6.5 A detailed ground investigation, however, should consider hydrogeological impacts and monitoring and testing of groundwater should take place as part of this. However, further detailed ground investigation will be undertaken prior to construction to assess hydrogeological conditions. The investigation will be sufficient to provide information on the depth of groundwater, flow direction and local groundwater quality, which will in turn inform the proposed design.

3.7 It is for the Scottish Ministers to be satisfied with regards the scope of the

detailed ground investigation and we note that Fife Council is the lead authority with regards land contamination. The applicant should be aware however that if they are to understand the groundwater regime on the site, due to seasonal variation in ground water levels data gathering would be required over an extended period to inform the proposed ground investigation.

3.8 We agree that additional representative sampling and analysis of sediments will be required to confirm the suitability for use onshore as part of the scheme to inform disposal options and welcome the analysis for leachates to assess the risk to the water environment (paragraph 11.3.21). We recommend that the guidelines set out in the SEPA document Land Remediation and Waste Management Guidelines are adhered to. The weblink is provided in

paragraph 3.3 above.

3.9 The points raised above highlight that there is a lack of information regarding groundwater on the site at the current time. We therefore believe that the statement in paragraph 11.7.6 which states that there is a potential negligible/ slight significant impact in relation to hydrogeology and therefore no mitigation is required is premature prior to detailed ground investigation in the Jacobs letter as attached. Furthermore this does not appear to accord with Table 11-13 which states that there is a moderate to slight significance of impact.

3.10 We therefore seek that the applicant amends the ES to more accurately record that at the current time risks to groundwater from the development are not quantifiable but will be established through the detailed ground investigation prior to development. As revisions are proposed for the ES, alteration to the wording of Article 17 of the draft RICT order will be required as it refers to the ES dated January 2011.

4 Dredging

4.1 Paragraphs 9.7.43 - 9.7.46 conclude the proposed dredging works have the potential to have a significant effect upon the Zostera habitats at Bruce Haven and Windylaw due to smothering effects. It is noted that Table 9-8 of the ES details a number of options for mitigation to reduce turbidity during dredging operations. Further detail should be provided in the EMP to ensure that adequate mitigation is provided to ensure that the extent of these habitats is maintained in line with UKBAP and WFD objectives.

4.2 Paragraph 5.6.5 states that the majority of dredging will be carried out by suction dredging but some rock dredging using a backhoe dredger will be required. It is not clear what proportion of the capital dredging will be carried out using the backhoe technique. Further detail should be provided in the EMP with regard to minimising the higher levels of resuspended sediment which are likely during this phase of the project. We understand that a dredging method statement will be included in the licence application to Marine Scotland.

4.3 It is understood that the area of the dredging equates to approx 27ha (paragraphs 9.7.71 – 9.7.72). We have considered this with regard to existing pressures in the lower Forth water body and feel that it is unlikely to result in a downgrade in hydromorphological status in line with RBMP objectives. Since the footprint of the capital dredging works will be maintained by maintenance dredging the footprint area will be incorporated into the RBMP classification on completion of the project.

4.4 Sheet 7 in the deposited plans shows the dredging limits which cover a greater area than the dredged approach channel shown on sheets 2, 3, 5 and 6. In order that we can update the classification for the RBMP to include the impact of the development please can the applicant confirm the full extent of the dredging footprint to us in due course.

4.5 Within the EIA Scoping Report, attached as an Appendix to the ES, on page 15 it is stated that the creation of an additional mudflat habitat within the firth will be explored. We would consider this to be a beneficial use of dredged material which could provide mitigation for loss of subtidal habitat. We understand that this will be further considered as part of the BPEO assessment at the marine licence application

stage.

4.6 Paragraphs 3.7.4, 3.7.5 and 5.5.4 discuss the maintenance dredging requirements and estimates that maintenance dredging will be required every 2 to 5 years. We question this as Table 3-6 details that the adjacent site of Rosyth is dredged annually while Grangemouth is dredged monthly. We understand that this issue will be covered in detail by the FEPA licence application.

4.7 We recommend that the applicant consider the fact that capital dredging should be defined as a residual impact of the proposed development and added into Table 9-9 of the ES.

5 Flood Risk

5.1 Review of the Indicative River and Coastal Flood Map (Scotland) shows that the development site is at risk of coastal flooding.

5.2 We commented on this application at the scoping stage and highlighted that our estimate on the 1 in 200 year still water level is 4.52mAOD. Jacobs have carried out there own assessment of the 1 in 200 year still water level which was found to be 4.80mODN (Ordnance Datum Newlyn). No allowance for wave action has been taken into consideration as stated with the flood risk assessment. An allowance of 0.28m was provided for sea level rise as part of climate change.

5.3 The proposed stacking and handling area will be located at 4.66mODN and will be subjected to a limited degree of flooding during the 200 year flood event. Jacobs recommends a finished floor level of 5.58mODN (which includes 500mm freeboard plus an allowance for climate change) for any buildings and items to be stored which we are in agreement with. Within the Jacobs Scoping Report dated December 2009 (reference B1180100) states that the development site lies at approximately 4.3mODN. Therefore there will be a degree of landraising associated with the development however as the flood risk is tidal, no compensatory storage is required.

5.4 It is noted that the ES states in paragraph 5.6.32 that the finished floor levels will be set in accordance with the Flood Risk Assessment with an appropriate allowance for wind generated waves. As the area may be subjected to a degree of wave spray the developer may wish to take this into consideration with regards development design.

Caveats & Additional Information for Applicant 5.5 The Indicative River & Coastal Flood Map (Scotland) has been produced following a consistent, nationally-applied methodology for catchment areas equal to or greater than 3km2 using a Digital Terrain Model (DTM) to define river cross-sections and low-lying coastal land. The outlines do not account for flooding arising from sources such as surface water runoff, surcharged culverts or drainage systems. The methodology was not designed to quantify the impacts of factors such as flood alleviation measures, buildings and transport infrastructure on flood conveyance & storage. The Indicative River & Coastal Flood Map (Scotland) is designed to be used as a national strategic assessment of flood risk to support planning policy in Scotland. For further information please visit www.sepa.org.uk/flooding/flood_map.aspx.

5.6 Please note that we are reliant on the accuracy and completeness of any information supplied by the applicant in undertaking our review, and can take no responsibility for incorrect data or interpretation made by the authors.

5.7 The advice contained in this letter is supplied to you by SEPA in terms of Section 72 (1) of the Flood Risk Management (Scotland) Act 2009 on the basis of information held by SEPA as at the date hereof. It is intended as advice solely to Fife Council as Planning Authority in terms of the said Section 72 (1). Our briefing note entitled: “Flood Risk Management (Scotland) Act 2009: Flood risk advice to planning authorities” outlines the transitional changes to the basis of our advice inline with the phases of this legislation and can be downloaded from www.sepa.org.uk/flooding/flood_risk/planning__flooding.aspx

6 Air Quality

6.1 We note that Fife Council is the lead authority with regards air quality and transport. However we would like to highlight the fact that as HGVs emit a disproportionately high amount of nitrogen dioxide and particulate matter in relation to cars, and therefore a small increase in HGVs can result in a significant rise in roadside pollution. Studies in Cupar (Fife) have shown that whilst HGVs account for only 6% of the through traffic, they are responsible for almost half the NO2 in the Bonnygate. It is therefore important to ensure that HGVs are discouraged from passing through the residential areas in Rosyth.

6.2 Paragraph 13.4.7 refers to a rail link that exists between Inverkeithing Station and Babcock Rosyth. We agree that this option should be investigated further, as it would reduce the number of HGVs and help reduce emissions greenhouse gases.

6.3 Fife Council has recently identified high levels of nitrogen dioxide that are exceeding the annual mean air quality objective in the north of Dunfermline (Appin Crescent). Routing of the HGVs from this development should ensure that they do not exacerbate existing air quality problems.

This advice is given without prejudice to any decision made on elements of the proposal regulated by us, which may take into account factors not considered at the planning stage. Detailed advice for the applicant 7 Marine Non Native Species

7.1 In order to minimise the risk of non-native species being transported into or out with the area of work on the hulls of vessels or legs of apparatus we suggest that the proposed Environmental Management Plan is expanded. Relevant commitments include that records of antifouling coating be required and inspections on marine growth using drop down video be carried out prior to vessels and apparatus being brought into or leaving the area. If the applicant’s agent requires further discussion on this issue contact should be made with SEPA.

Objection 50 We, the undersigned, wish to lodge a strong objection to the above application on the grounds that the proposed Rosyth International Container Terminal could be developed without following the normal democratic planning process and without addressing the legitimate and significant concerns of the Limekilns and Charlestown community. There will be considerable congestion on the roads of West Fife if large container transport joins the already busy A985. No assessment of the impact of this additional traffic on the Limekilns junction with the A985 has been carried out. Construction of the Forth Replacement Crossing will cause severe disruption to the present traffic flow and if large and heavy contaner lorries are also included, there will be further overloading of the system. Between Rosyth Harbour and the Forth Road Bridge , the new extension of the Ferry Toll road requires all traffic to negotiate 2 tight roundabouts and then to pass under the M90 before joining the latter. Has there been any assessment of the relative heights of that underpass and the container transporters? Has there been an assessment of the carbon impact of this project on the environment in the Environmental Statement? If this Harbour Revision Order is granted , Babcock would have a virtually free hand to develope the site as they wished. Everyone living in the vicinity would be subjected to significant disruption and noise day and night during the construction phase. Even when this ends there is no guarantee that a new terminal facility is required. Babcock`s estimate of 400,000 containers per year being handled at Rosyth seems to us to be unrealistic. We respectfully suggest that further investigation, thought and assessment should be carried out before this application is finally considered / granted. Objection 51 My wife and I as residents of Charlestown object to the Minister granting the above order. The first general objection is that it would allow Babcocks or successors, in the future, to do as they wish to the area without taking into account the rights and normal living patterns of local residents. It would not allow a democratic decision. In specific terms, we object since a container terminal is not required in this location because of the following:- 1. Grangemouth can increase its capacity as an terminal without the major social and enviromental disruption. 2. It would not, in itself, improve the economy of Fife. 3. The proposed terminal would not be able to use the rail network. This would result in a totally unacceptable increase in the use of road transport. The A985 junction from Limekilns is dangerous and stressful enough, at present, without an increase in traffic. No assessment has been made on the impact on this junction. 4. The proposed container terminal would not accommodate bigger ships than these which use Grangemouth and even then extensive dredging and maintenance of a deepened channel would be required. This dredging is likely to cause problems for our seawall and the foundations of our house. 5. The propose terminal will only be useable for two hours on either side of the high tide and not as stated as 24/7. 6. Loading and unloading could take place at any time of the day or night, thus disrupting the peace and quiet of the local residents.

7. The number of extra jobs anticipated at 200 seems exaggerated. RICT says there will be a low level of staff required. 8. There has been no assessment of the carbon impact of this proposal. In conclusion, the project and the method of seeking approval is totally unacceptable because: · It would allow Babcock and/or successors to made social and structural changes which would ignore the rights and wishes of local residents. · Would not significantly improve the number of jobs and the economy in Fife. · It would increase the congestion on the surrounding roads. · Would damage the seafront and seawalls of many local properties. · Would disrupt the peace and quiet of the villages with noise and light pollution · This method of obtaining approval for the terminal could ignore the rights of the local residents. My wife and I are not against change or making radical alterations which would improve job prospects and the general economy of Fife. However, a balance should be made between the advantages of such a project and the adverse consequences of the disruption to the local community. Objection 52

Objection 53 I write to state my objection to the proposed use of Rosyth as a container Terminal, by Babcock. I do not believe we need another terminal, when Grangemouth is just up the river, is under-utilized, and is far better suited to the transport network than Rosyth. Investment, though probably not by Babcock, could be put into Grangemouth if you believe more capacity is required, which clearly it is not. The impact on the Forth and surrounding environment, land-side and in the river, would be catastrophic should the terminal go ahead. The ability to use it 24/7 is not realistic due to tides. Loud and intermittent noise would pollute the surrounding communities (unnecessary when when Grangemouth already exists...) as would traffic using the overloaded and dangerous road infrastructure to head west. It is unlikely to create the jobs mentioned (a smaller carrot than trying to portray). Damage done will be irreversible once it becomes known this isn't a viable operation. I ask you to support this objection, and highlight Grangemouth as the Container Terminal in which to be invested if necessary, Objection 54 Proposed Rosyth International Container Terminal (Harbour Revision) Order and Proposed River Forth (Port Babcock Rosyth Port Limits) Harbour Revision Order - OBJECTION I write to register my objection to the Harbour Revision Order submissions by Babcock, and to ask those responsible for the decision to fully consider the many justified concerns raised by the Charlestown, Limekilns and Pattiesmuir Community Council. Democratic process and consultation The HRO submissions are part of Babcock’s continuing efforts to develop a container terminal at Rosyth. After a difficult PAC phase, Babcock has decided to avoid further involvement with the community and Fife Council, and opt for the HRO route. Granting a HRO would allow Babcock to continue this (or any other project) with little restriction. Given the risk of damage to the environment (both in the River Forth and on the land), the impact on the lives of people living in the area, the likelihood of damage to the shoreline and the significant stresses on the road network, it seems irresponsible to grant a HRO when it will mean the many land based regulations and controls will be avoided. The area identified in the HRO is considerably larger than the area first put forward as part of the RICT plans. It includes much of the land designated as SSSI and, as such, should be protected. Granting an HRO which covers this area, when it would mean any activity would not require planning consent, causes me great concern.

Babcock’s regard for the residents I would have fewer concerns if Babcock had demonstrated a genuine willingness to engage with the community. However, it has repeatedly shown little regard for the community’s concerns. As the Rosyth International Container Terminal (RICT) documentation shows, there are many omissions, inconsistencies and there is clear evidence that Babcock does not understand the likely ramifications of its actions. (These, I understand, are documented in the Charlestown, Limekilns and Pattiesmuir Community Council objection.) Granting a HRO to Babcock, when it has demonstrated such little regard or respect for the planning process, seems foolhardy at best. The avoidance of the basic planning processes could be potentially catastrophic for the environment and for the lives and wellbeing of the local residents, some of which live less than 1 km from the proposed site. Employment potential The ridiculous employment estimates seem to have blinkered many in the area. If these figures are to be believed the container terminal would have proportionality more employees that in the existing container facility in Grangemouth. Two successful container terminals, on the same stretch of the River Forth, who offer the same facilities in terms of accessibility and size of ship, and who, between them would handle the vast majority of container traffic in Scotland seems fanciful. Democratic process If a HRO was granted, Babcock would be permitted to continue its development of the RICT. This HRO application is, in effect the last democratic gate for this development. For this reason, the HRO application must consider the all underlying reasons for the application and the detailed objections from the Charlestown, Limekilns and Pattiesmuir Community Council. Rejection request I object to the proposals and application made by Babcock for the development of a container port and urge you not to grant the HROs. Objection 55 As a resident of the village of Limekilns, I would like to state my objection to the Babcock Container Terminal proposal. My main areas of objection are: 1) By applying for a Harbour Revision Order, Babcock are attempting to by pass the democratic planning process without addressing the significant concerns of the community. 2) Babcock say that they will handle 400,000 containers per year at Rosyth. If there was indeed an increased need for this type of activity then the container port at Grangemouth could more than double its capacity without significant infrastructure upgrades. Rosyth will not be able to accommodate ships any bigger than are currently accommodated at Grangemouth. The Forth Bridge limits the size of ships that can enter the Forth. 3) The 200 promised operational jobs seems to be an overestimate and are unlikely to materialise. Grangemouth has just 50 operators. Babcocks own Transport Assessment states that the "impact of staff trips to and from the RICT will be minimal due to the low number of staff required". 4) Container terminals do not, in themselves create growth in the local economy. They merely service such growth.

5) The Rosyth terminal was supposed to be multimodal with the resulting benefit of much freight traffic being transported by rail. However, due to the transport assessment conclusions that access to main rail routes through Inverkeithing Station is severely limited by the junction configuration; it is clear that rail freight is no longer considered to be an option. 6) Due to point 5) This means that transport in and out of the port will be by road. Earlier promises that traffic would almost always travel east and over the Forth Road Bridge are now thrown into doubt because of the construction of the new Forth Replacement Crossing. This will mean a major diversion of container traffic along the A985 for a number of years. 7) The community has previously raised concerns about the effect of additional traffic on the Limekilns junction with the A985. Assessment of the impact of additional traffic has not taken place. 8) Access to the new berths on the RD57 site will require massive dredging both to open up the channel and then to maintain it thereafter. 9) Dredging will cause irreversible damage to the stability of sand and sediment on the sea bed, with the consequential risk of damage to, and undermining of, the sea walls, piers and houses in the villages. There is also likely to be damage to the bird and marine life that currently has special protection. 10) Has the risk been assessed of dredging up radioactive material, if so, who is liable for the clear up / remediation costs and costs of disposal. What impact could this have on the people / flora and fauna in the surrounding area. What could the consequential damages be - has this been assessed? 11) Loading and unloading activity could happen at any time during the day or night. The villages would be subject to intermittent loud and disturbing night-time noise as well as the potential of significant light pollution. 12) There is no assessment of the carbon impact in the Environmental Statement - this is one of the criteria for the inclusion of a project in the National Plan. 13) Proof of viability - the Dunfermline area already has the unenviable reputation of having 2 white elephants in the area - Hyundai and Lexmark. Do we really want a third, given the impact on the environment and the queries regarding the assessment of likely job provision over the longer term. 14) The granting of a Harbour Revision Order would give Babcock a virtual free hand to do whatever they like with the site and the seas around it. In summary, this proposal should not be approved as: - it would not make a contribution to the Fife economy; - would not provide the promised jobs; - would increase congestion and traffic on the A985 and Limekilns junction; - would undermine the piers and sea walls; - would have serious environment impact; - could pose a radioactive risk; - would generate noise and light pollution during the day and night: - would have a detrimental impact on the lives of the surrounding villages with the

interruption of sleep patterns etc. Objection 56 To Whom it May Concern: As a resident of the village of Limekilns, I would like to state my objection to the Babcock Container Terminal proposal. My main areas of objection are: 1) By applying for a Harbour Revision Order, Babcock are attempting to by pass the democratic planning process without addressing the significant concerns of the community. 2) Babcock say that they will handle 400,000 containers per year at Rosyth. If there was indeed an increased need for this type of activity then the container port at Grangemouth could more than double its capacity without significant infrastructure upgrades. Rosyth will not be able to accommodate ships any bigger than are currently accommodated at Grangemouth. The Forth Bridge limits the size of ships that can enter the Forth. 3) The 200 promised operational jobs seems to be an overestimate and are unlikely to materialise. Grangemouth has just 50 operators. Babcocks own Transport Assessment states that the "impact of staff trips to and from the RICT will be minimal due to the low number of staff required". 4) Container terminals do not, in themselves create growth in the local economy. They merely service such growth. 5) The Rosyth terminal was supposed to be multimodal with the resulting benefit of much freight traffic being transported by rail. However, due to the transport assessment conclusions that access to main rail routes through Inverkeithing Station is severely limited by the junction configuration; it is clear that rail freight is no longer considered to be an option. 6) Due to point 5) This means that transport in and out of the port will be by road. Earlier promises that traffic would almost always travel east and over the Forth Road Bridge are now thrown into doubt because of the construction of the new Forth Replacement Crossing. This will mean a major diversion of container traffic along the A985 for a number of years. 7) The community has previously raised concerns about the effect of additional traffic on the Limekilns junction with the A985. Assessment of the impact of additional traffic has not taken place. 8) Access to the new berths on the RD57 site will require massive dredging both to open up the channel and then to maintain it thereafter. 9) Dredging will cause irreversible damage to the stability of sand and sediment on the sea bed, with the consequential risk of damage to, and undermining of, the sea walls, piers and houses in the villages. There is also likely to be damage to the bird and marine life that currently has special protection. 10) Has the risk been assessed of dredging up potentialy hazerdous waste material, if so, who is liable for the clear up / remediation costs and costs of disposal. What

impact could this have on the people / flora and fauna in the surrounding area. What could the consequential damages be - has this been assessed? 11) Loading and unloading activity could happen at any time during the day or night. The villages would be subject to intermittent loud and disturbing night-time noise as well as the potential of significant light pollution. 12) There is no assessment of the carbon impact in the Environmental Statement - this is one of the criteria for the inclusion of a project in the National Plan. 13) Proof of viability - the Dunfermline area already has the unenviable reputation of having 2 white elephants in the area - Hyundai and Lexmark. Do we really want a third, given the impact on the environment and the queries regarding the assessment of likely job provision over the longer term. 14) The granting of a Harbour Revision Order would give Babcock a virtual free hand to do whatever they like with the site and the seas around it. In summary, this proposal should not be approved as: - it would not make a contribution to the Fife economy; - would not provide the promised jobs; - would increase congestion and traffic on the A985 and Limekilns junction; - would undermine the piers and sea walls; - would have serious environment impact; - could pose a risk from hazerdous materials unearthed by excavation; - would generate noise and light pollution during the day and night: - would have a detrimental impact on the lives of the surrounding villages with the interruption of sleep patterns etc. Objection 57 I am writing as a private individual to object to both of the above Harbour Revision Orders. I also fully support the objections raised by Charlestown, Limekilns and Pattiesmuir Community Council in their detailed submission. Any attempt to stimulate sustainable economic development and create employment is to be applauded. However, as these are the major positive impacts on locality being suggested in this proposal, it is important that they stand up to objective scrutiny. I am firmly of the opinion that they do not and I do not believe that this proposal will deliver either. My reasons are as follows:

• Babcock plan to process 400,000 TEU containers per annum through Rosyth. This is more than is presently handled through all Scottish Ports in total. Given long term GDP and population forecast trends for Scotland, it is in the realms of the 'highly improbable' that the market can ever grow to make this container port viable, particularly as Scotland is a small subset of the wider European container shipping market. This is even more pertinent given that there is already an under utilised container port on the same river at Grangemouth which has the ability to expand its operations with arguably better configured multi-modal networks and closer to the major population centres.

• I have asked the question to both Babcock and civil servants responsible for NPF2 of why two competing container facilities on the same river can be perceived as being in the National Interest. I cannot say that I have been

given any persuasive answer other than told that 'the market' will decide. • I would be quite happy for 'the market' to decide which Ports prospered or

failed were it simply a question of private commercial enterprises risking their own investment capital. However the reality is that what is at stake here are the permanent and irreversible social costs which will be imposed on the local communities regardless of whether the proposal succeeds or fails. The Community Council provides a detailed analysis of the impacts that will be borne by local communities arising from 24/7operation, noise, dredging, increased traffic etc. In addition, I understand that the HRO would give Babcock a free hand to do whatever they wish in future with the site without the requirement to engage in the democratic planning process.

• Modern Container shipping is a highly automated process with low labour needs. Babcock claim that they will create 200 operational jobs which would make it highly inefficient. For comparison Grangemouth has 50 operators. In addition, any employment gains at Rosyth are likely to be at the expense of jobs in Grangemouth as they will compete for the same business, in the same markets and effectively source from the same labour pool. At a Regional/National level it is difficult to see any material new jobs being created.

• Babcock confirmed at the consultation exhibition in Charlestown that they would not be running the Container Port as they have no expertise in this area. This will be leased to another port operator. Their future involvement in the Container Terminal will therefore be that of a landlord. Given the significant technical expertise and high skilled workforce which currently resides in Babcock, I am surprised that they have not 'aimed higher' at developing an alternative use for the RD-47 site.

In, summary, I strongly object to these proposed Harbour Revision Orders for the reasons outlined and would be gratefully if my objections were placed before the Ministers who will determine this application.