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

https://www.facebook.com/groups/NORIGSINFAIRLIE/?ref=group_header


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


Coal Yard

Dock

SSSI


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.


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


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



What Is Special About The Environment?

Southannon Sands Site of Special Scientific Interest (SSSI)


What Is The Oil Rig Decom Project?


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


Prof Tom Baxter - Myths About North Sea Decommissioning

Yes £17bn spend on oil rig decom, but only 3-5% on onshore work.

https://www.scotsman.com/news/opinion/tom-baxter-myths-about-north-sea-decommissioning-1-4384732

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



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


$1m paid for the scrap

“Blowtorch Beach” Turkey


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

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

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

https://www.shetnews.co.uk/2018/09/10/decommissioning-boost-for-dales-voe/

https://www.energyvoice.com/oilandgas/decom/186729/cesscon-edging-closer-to-decom-base-in-methil/?fbclid=IwAR1oCmgg7o0QztlEON4sRP_FsVyAyhGyOhj0FHhK58XBuziv3dhIEEzZbY8

https://theconversation.com/five-myths-about-dismantling-north-sea-oil-rigs-76063

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?

https://www.cesscon.com

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

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?

https://www.gmbscotland.org.uk/assets/media/documents/pressreleases/GMB-SCOTLAND-REPORT-Status-capacity-and-capability-North-Sea-Decommissioning-Facilities-final-web-GMB-cover.pdf

Cold Stacking

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


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


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


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?

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


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)


https://oilandgasuk.co.uk/wp-content/uploads/2015/05/OP086.pdf


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


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


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


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


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.


2012


2017

EIA Screening Mtg


Dock Extension Dock ExtensionCaisson GatesChange of USE

Formal EIA Screening Request

NACMarine Scotland

2017

Dock ExtensionCaisson GatesChange of USE


2016



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


2012


2017

EIA Screening Mtg


Dock Extension Dock ExtensionCaisson GatesChange of USE

Formal EIA Screening Request

NACMarine Scotland

2017


2018

3 Town and Country Planning Permissions

NAC


PLANNING GRANTED APRIL 2018NO EIA REQUIRED

2016



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.


2018

Cesscon Decon Video

Asset Preparation Jetty

From Cesscon Website


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



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



Licence

SEPA

2018

4. Unprecedented levels of toxic waste

AsbestosCFCsPCB’sGlycolNORMHeavy MetalsMarine Growth



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.



Licence

SEPA

2018

SEPA will advise update

• SEPA have confirmed no WML only applied to Construction Yard.

• Aim for this to be a benchmark


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.


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

NEXT STEPS


✓ 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


✓ 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

https://friendsoffirthofclyde.org/support-us/

https://www.change.org/p/save-clyde-dolphins-porpoises-seals-stop-the-peelports-oil-rig-decommissioning-facility

https://friendsoffirthofclyde.org/what-do-you-need-to-know-about-the-marine-scotland-licence-application/

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 · friends of the firth of clyde –what is the project? what does...

Documents