Friends of the Firth of Clyde · Friends of the Firth of Clyde –What Is the Project? What does...
Transcript of Friends of the Firth of Clyde · Friends of the Firth of Clyde –What Is the Project? What does...
Friends of the Firth of Clyde
Clydeport Oil Rig Decommissioning Proposalswithin Southannon Sands SSSI
on the Firth of Clydeemail: [email protected]
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
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 ?
Friends of the Firth of Clyde - Who Are We?
Long Term Neighbours
of Clydeport
Residents who care about our
environment, the welfare of
our community and sustainable economic development of the
area.
Committee
5,000 Supporting call for EIA
Friends of the Firth of Clyde – What Do We Want?
Sympathetic Development to Protect to Environment & Improve the Economy of
the Region
Raise Public AwarenessPromote Engagement, Connect
Communities & Influence Decision Making
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 JettyFairlie 800m
Construction Yard
Coal Jetty
Friends of the Firth of Clyde - Geography
Coal Yard
Dock
SSSI
Friends of the Firth of Clyde - Geography
HistoryWhistle-Stop Tour
18th Century
Glasgow was a huge trading port with North America, resulting in great wealth.
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
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
1970 –Iron Ore Terminal
Protests from FairlieSo controversial required an act of parliament. Key condition to return the environment to original state
1979 –Maureen Gravity Legs
Only 3 construction projects came to Fairlie in over 40 years
1992 Ravenscraig Closes
Planning Permission demands that if iron ore 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.
Clydeport
20031966
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.
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".
History Lesson Clydeport
Coal operations at Hunterston end 2016.
Friends of the Firth of Clyde – Neighbours of Clydeport
Coal Dust Regularly Blown in on the Wind - Covering Surfaces in Fairlie
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
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.
SSSI
Friends of the Firth of Clyde - Geography
Friends of the Firth of Clyde
What Is Special About The Environment?
Southannon Sands Site of Special Scientific Interest (SSSI)
Friends of the Firth of Clyde
What Is The Oil Rig Decom Project?
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
Friends of the Firth of Clyde - SEPAFriends of the Firth of Clyde – SEPA
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
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
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.
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
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:
Friends of the Firth of Clyde – Where Is This Done?In so far as we can gather…..
$3m paid for the scrap
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
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
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
Friends of the Firth of Clyde – Decommissioning FundIn so far as we can gather…..
Friends of the Firth of Clyde – Decommissioning FundsIn so far as we can gather…..
2017 Fund of £5m1. Hunterston = £250k Feasibility2. Dundee – heavy lifting crane3. Kishorn – Upgrade dry dock4. Leith – make decom business.5. Decom Facility Methill, Fife6. Stornaway Port Decom7. Lerwick – equipment8. Lyness Decom – Orkney
Friends of the Firth of Clyde – Decommissioning FundsIn so far as we can gather…..
Friends of the Firth of Clyde – JobsIn 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
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?
Since 2018, CessCon Decom have been based at Hunterston Clydeport – This is their
promotional video explaining the plans for Hunterston
Watch:https://www.youtube.com/watch?v=AFMb9jmwgwU
Friends of the Firth of Clyde – What Is the Project?
What will it take to get Hunterston fit for purpose?
GMB Scotland (2016) Review of Capability & Capasity of 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?
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?
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?
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?
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?
Friends of the Firth of Clyde – What isn't Explained?
SEPA Waste Management
License
Submitted 2018
Details unprecedentedlevels of toxic waste
AsbestosCFCsPCB’sGlycolNORM
Heavy MetalsMarine Growth
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?
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 UK2013)
Friends of the Firth of Clyde – What Isn't Explained?
Friends of the Firth of Clyde
The Call For An EIA
Friends of the Firth of ClydeEIA Process
• Preparation of an EIA report• Completion of consultation, publication and notifications• Examination of the EIA report and any other 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
EIA Legislation & ProcedureEU Environmental Impact Assessment Directive
Town & Country PlanningEIA Regulations
Marine Works EIA Regulations
Is the project a mandatory Schedule 1 development ?
Is the project a Schedule 2 development ?
EIA Scoping & ScreeningPeelports
North Ayrshire Council
Planning
Marine ScotlandLicensing
Scottish Natural Heritage
Scottish Environmental Protection Agency
Terrestrial planning Marine planning EPS licenseDredge license
Waste Management License Environmental consultee
Developer
Is the project described in Schedule 1
of planning regulations?
EIA is required
Is the project described in Schedule 2
of 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
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
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
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
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
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
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.
Removal of sediment is contrary to North Ayrshire Council Policy
80,000m2 of sandflat and salinepools to be dredged
Contrary to Joint Nature ConservationCommitee guidelines
Contrary to SNH guidlines
Friends of the Firth of Clyde
Overview of Planning
Friends of the Firth of Clyde – Planning Timeline
2012
EIA ScreeningRequest
2017
EIA Screening Mtg
NACSNHMarine Scotland
Dock Extension Change of USE – addition of decommissioning
Dock ExtensionCaisson Gates
2016
Removal of 5 year temporary license conditions to permanent
SNH agree SO LONG AS THE CONDITIONS OF USE DO NOT CHANGE
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 Southannan Sands 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.
Friends of the Firth of Clyde – Planning Timeline
2012
EIA ScreeningRequest
2017
EIA Screening Mtg
NACSNHMarine Scotland
Dock Extension Dock ExtensionCaisson GatesChange of USE
Formal EIA Screening Request
NACMarine Scotland
2017
Dock ExtensionCaisson GatesChange of USE
SNH agree SO LONG AS THE CONDITIONS OF USE DO NOT CHANGE
2016
Removal of 5 year temporary license conditions to permanent
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
Friends of the Firth of Clyde – Planning Timeline
2012
EIA ScreeningRequest
2017
EIA Screening Mtg
NACSNHMarine Scotland
Dock Extension Dock ExtensionCaisson GatesChange of USE
Formal EIA Screening Request
NACMarine Scotland
2017
Dock ExtensionCaisson GatesChange of USE
2018
3 Town and Country Planning Permissions
NAC
Dock ExtensionCaisson GatesChange of USE
PLANNING GRANTED APRIL 2018NO EIA REQUIRED
2016
SNH agree SO LONG AS THE CONDITIONS OF USE DO NOT CHANGE
Removal of 5 year temporary license conditions to permanent
Friends of the Firth of Clyde – Notable Planning Conditions
Removal of Temp Restriction1. Restricted to large marine vessels2. 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 NAC6. If the site is disused for > 1 year all buildings and scrap will be removed.
Use to Allow Decom1. 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 SSSI5. 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 Gates1. Provide a Construction Method Statement to include:• Risk to Marine Mammals• Prevent SSSI Pollution
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)
MembershipThe 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;
Cumbrae Community 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
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.
Construction Yard
Friends of the Firth of Clyde – Planning Permission
Dock
Planning Permission Only for Construction Yard and Dock as below in Red.
Friends of the Firth of Clyde – Planning Timeline
2018
Cesscon Decon Video
Asset Preparation Jetty
From Cesscon Website
Friends of the Firth of Clyde – Planning Timeline
Unique Deep Water – not 40m, but 18m due to coal build up.
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 on the road network would be negligible.”
Significant reference to road transport in WML
Friends of the Firth of Clyde – Planning Timeline
SEPA Waste Management
Licence
SEPA
2018
4. Unprecedented levels of toxic waste
AsbestosCFCsPCB’sGlycolNORMHeavy MetalsMarine Growth
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.
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
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 twoworks, 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 Peelports by 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 or 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 publicise the following ‘scoping’ stage, at which the necessary studies and assessments are agreed, on our webpages.
Friends of the Firth of Clyde
Campaigning to Protect the Firth of Clyde & Environmentally Safe & Sustainable Development at Hunterston Peninsular
NEXT STEPS
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 open communication and trust with the community
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
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
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 OgilviePamela ArmstrongDavid Walker
Scottish Environmental Protection Agency (SEPA)
Anne Carson Largs Community Council
Ian MurdochAlex Gallagher
NAC Councilors
David NairnClare BaguleyCaroline de Jong
Friends of the Firth of Clyde