EXECUTIVE SUMMARY 1 HUNTERSTON

Hunterston Master Plan Consultation Summary February 2020

More than Ports CONSULTATION SUMMARY 2 3

Foreword I would like to take this opportunity to thank everyone who participated in the Consultation process for the Hunterston Master Plan. We hope you found it insightful and the data and responses published from this useful.

The use of key assets that already has is essential in the future. Hunterston is one of those key assets, helping to deliver answers to our national and international issues whilst providing North and Scotland with a prosperous future.

We look forward to a continued collaboration with all stakeholders in a future iteration of the Master Plan and in the delivery of development projects.

Andrew Hemphill Port Director, Peel Ports Clydeport CONSULTATION SUMMARY 4 5

Executive Summary This report details the work to consult The Master Plan set out guiding principles the public and stakeholders on a new on how the site would be developed, poten- Master Plan for the Hunterston Port and tial uses of the site, the environmental and Resource Centre (PARC). It describes transport issues that need to be addressed, the content of the Master Plan, the the social and economic context for the consultation activities, and the feedback development, the policy framework for such received. sites and what would happen after the con- sultation. In recent years, the change in Government energy policy away from fossil fuels Most respondents said they understood the towards renewable sources has meant plan. A slight majority agreed that the site is there is no longer a role for Hunterston important to the economy of the area, with as a major import terminal for coal. one third disagreeing.

Hunterston PARC now has the potential There were criticisms of the Master Plan to transform Scotland’s prospects in a document and consultation process, largely variety of key economic sectors, providing based upon the lack of detail, the accuracy jobs, skills development and import and of some information, projected job figures export opportunities for decades to come. and questionnaire design. Perceptions of It can also support the recently announced Peel Ports and predecessor organisations Ayrshire Growth Deal, which will see new as a ‘bad neighbour’ due to historic devel- investment in the area. opments and practices also featured.

In May 2019 we published our Master Plan, There were concerns generally about the for a six-week consultation period, which impact any redevelopment would have on outlined our vision for the site and some of local people and the environment, including the critical issues we need to consider. noise, dust, air pollution, water pollution, Executive We prepared the Master Plan following visual impact and traffic. Summary the principles within “Guidance on the Preparation of Port Master Plans” which There was opposition to the proposed uses was published by the Department of a liquid natural gas (LNG) terminal and oil for Transport (DfT) in December 2008. and gas rig decommissioning. There was less opposition for some other proposed There is no requirement for a port to uses, such as aquaculture, manufacturing produce a Master Plan however we felt and plastics recycling. Many respondents it was an important part of explaining suggested that the site should be used for our plans and engaging with the local ‘green’ industry energy, or tourism. community and other stakeholders. CONSULTATION SUMMARY 6 7

Background

The site Hunterston Port and Resource Centre The latest official National Records of (PARC) is on the West Coast of Scotland in Scotland (NRS) population projections for . North Ayrshire show a decline in population over the next 25 years, driven primarily In recent years its primary trade of coal by natural change (i.e. more deaths than imports has ceased as legislation and aged births). power stations, such as Longannet, have made the use of coal for energy production East and have similar prohibitive. projections, whilst City Region is projected to grow significantly through net The site is currently being remediated and international migration. the time frame for the removal of obsolete equipment is predicted to be completed by Economic development through schemes mid-2020. such as Hunterston PARC is likely to be crucial, both in bringing jobs back to North National Planning Framework 3 was Ayrshire and by encouraging working age published in 2014 and identified that migration into the area. Hunterston was an area that required co-ordinated action for industrial and This in turn will help to maintain and boost employment use, with the key assets of the the viability of local services such as site being a driver for future developments. schools, doctor surgeries and retail centres.

Nationally, the site is identified in the UK The relatively high level of unemployment, Government’s ‘Maritime 2050 Navigating low economic activity rates and net out- the Future’ strategy, published in January commuting across the occupational 2019, as one of only two Scottish port spectrum also suggest that there is scope infrastructure projects. This highlights for greater utilisation and retention of the its importance to the country’s industrial existing resident workforce. capabilities. The projected decline in North Ayrshire’s We have developed a clear understanding population is not offset by increasing of how Hunterston PARC could once economic activity rates among the over again play a part in serving the economic 65s. Reducing unemployment, improving prospects of North Ayrshire, the West the net commuting balance and boosting Coast and indeed Scotland as a whole. population growth could all help to create capacity for job growth. Social and economic context As described in the Master Plan – in a Hunterston is acknowledged in national report produced by independent economic and recently adopted local policy as a key consultants - the long term decline in location of particular significance in growing population and jobs in North Ayrshire has a low carbon economy and as a priority for the potential to undermine future economic industrial and employment use. As such it prosperity, particularly in the context of an has a key role to play in delivering national ageing population. economic and planning policy. CONSULTATION SUMMARY 8 9

Master Plan content We have also considered a wide range Hunterston PARC can become a of potential facilities and activities for multi-modal centre for exporting, import- the site, which were described in the ing, processing, recycling, and distribut- Master Plan: ing resources that support the economic • Bulk handling for importing, processing growth of the North Ayrshire region, and distributing dry and liquid bulk Scotland and the UK as a whole. cargoes, including aggregates, agri- bulks and liquified natural gas (LNG) In achieving the goals set out above, • Development of the offshore wind and considering how we pursue them, sector the Master Plan set out six guiding • Construction for marine and offsite principles: manufacturing projects, from • Make it clean: focus on commodities aquaculture to civil engineering and technologies of the future • Decommissioning oil and gas structures • Support the circular economy: use our • Materials management to ensure reuse assets to play our part and recycling • Control risk: diversify the business, for • Power generation from LNG, Hydrogen the sake of us and the community and renewable sources • Create employment: re-establish a • Heat and power generation to support thriving place for the community energy-intensive operations • Exploit our special capabilities: make • Support for target industrial sectors, the most of the PARC’s special assets especially to reduce supply chain • Address the big challenges: prioritise carbon emissions activity that is valuable to all As well as this, the Master Plan consid- ered the history and context of the site, the various environmental and transport issues that would need to be considered, and the public policy framework that would influence the development of any specific proposals.

CONSULTATION SUMMARY 10 11

Consultation purpose

The Master Plan describes our vision for The Master Plan is not an application for the site and some of the critical issues we planning permission and will not in itself need to consider. grant approval for any works. The Master Plan provides a framework for setting We have prepared the Master Plan out the ports’ medium and long term following the principles within “Guidance aspirations. It will also assist in informing on the Preparation of Port Master Plans” the consideration of projects and planning which was published by the Department for applications made as and when necessary. Transport (DfT) in December 2008. Under the guidance there is no requirement for a We have consulted on the Master Plan as port to produce a Master Plan. The status detailed in the next section and the rest of of a Master Plan is non-statutory and this document summarises the responses. has limited ‘weight’ in terms of planning decisions at present.

The main purposes of a Port Master Plan are to: • clarify the port’s own strategic planning for the medium to long term; • assist local planning bodies and transport network providers in preparing and revising their own development strategies; and • inform port users, employees and local communities as to how they can expect to see the port develop over the coming years.

A Master Plan does this by setting out: • how the port expects to grow and develop its business over time; • where changes of land use are likely to be required to support growth areas; • what environmental measures will be taken to ensure that adverse effects are mitigated and that as far as reasonably possible the port makes a positive contribution to environment and amenity; • how people will be consulted both within the master planning process itself and beyond how the port’s development plans integrate with support and inform the regional and local economic, transport and planning policy context. CONSULTATION SUMMARY 12 13

Consultation activities

The purpose of the Hunterston Port Master These meetings were an opportunity Plan consultation was to firstly inform to present the final document and brief the local community and all relevant stakeholders accordingly in terms of the stakeholders about the emerging plans and next phase of the consultation. seek their views on the initial proposals. There was also a Community Council The overarching objectives for the briefing on 20 June 2019. consultation were to: • Understand what the local community Media activities and stakeholders consider to be the key In order to maximise the reach of the issues and incorporate their suggestions announcement of the consultation going into the plans where possible; live, a considered media outreach plan was • Ensure that everyone living in the devised and implemented. immediate area felt informed, involved and listened to, and knew where to go In the weeks leading up to the launch, for reliable information and to give input; local and national print media, national • Ensure that all issues and concerns broadcasters and local radio stations were drawn out and addressed as early received an invitation to visit the Hunterston as possible and; site on 15 May, the day before the • Start a meaningful dialogue with announcement was issued publicly. relevant parties that would last throughout the development of the This gave the media an opportunity to plan period. photograph and film the site, interview representatives from Peel Ports, and Early on in the preparation of the draft prepare their stories in advance of the master plan, Peel Ports developed a beginning of the Consultation. strategy to meet these objectives and ensure effective engagement with relevant The production and distribution of external parties. media materials including a media release, drone footage and stills took place. This This strategy formed the backbone of the was followed by an extensive sell-in to engagement programme, and evolved as national print and broadcast media which feedback was received by local council resulted in 26 pieces of national and local officers and members. news coverage, and 19 pieces of trade coverage. The six week public consultation ran from 16 May to 28 June 2019. STV news aired a 3 minute segment on the launch of the Masterplan. MSP and North Ayrshire Council and Community Council Briefings BBC ran the story online prominently. Representatives of Peel Ports met Kenneth Gibson MSP and representatives from North Ayrshire Council on 15 May to brief them upon the draft Master Plan. CONSULTATION SUMMARY 14 15

Digital and print advertising more than 3,100 click-throughs to the Hunterston PARC website Community Council engagement As part of the multi-channel approach consultation page (above average for this We created a dedicated website for We recognised the important role that to ensure we were reaching as many type of campaign.) the public and stakeholders to visit community councils play in ensuring a people as possible with the news of the https://www.hunterstonparc.com/ to strong response to the consultation. consultation we took out a series of print We further took 30 radio advert slots on learn about the site and the proposed A total of 4500 executive summaries of and digital adverts in key local press. West FM and Westsound AM. developments. the Master Plan and print copies of the questionnaire were distributed to , There were ¼ page print adverts in the Drop-in events at Fairlie & Millport Visitors were able to access the , , Cumbrae and following newspapers: (4 – 6 June) masterplan document in full and download Fairlie community councils. This allowed • Kilmarnock Standard this if they wished. the local representative to distribute to • Ayrshire Post Public consultation events took place at interested parties in the best way possible. • Irvine Herald Fairlie Village Hall on Tuesday 4th June from Also available was a link to fill in the on- • Greenock Telegraph 2.00pm to 7.00pm, Wednesday 5th June line survey questionnaire. • Largs and Millport News from 10.00am to 4.00pm and Thursday • Herald 6th June from 10.00am to 2.00pm. An • Irvine Times additional consultation event took place at Garrison House, Millport on Thursday 6th There were also ‘skin’ or ‘wrap’ adverts, June from 10.00am to 2.00pm mobile adverts and Mid Page Unit Visual materials in the form of a large (MPU) on the websites of both the display board were available to view and publishing groups that produce the above representatives from Peel Ports were newspapers (Reach and Newsquest) on hand to discuss questions raised by targeted towards local readerships. members of the public.

There were more than 445,000 In total the drop-in events had over 200 impressions of these adverts, with visitors. CONSULTATION SUMMARY 16 17

Survey Data

There were 145 online and written responses to the survey. The vast majority of these were residents as opposed to businesses or stakeholders. (Please note for the figures below that some respondents did not answer every question and that totals may not tally because of that or rounding.)

66% said they had a good or full understanding of the Master Plan. More than half (54%) felt the redevelopment of Hunterston is important to the local economy, with around one third (32%) feeling the opposite.

When presented with the various environment and transport factors to be considered, no more than 40% felt the Master Plan considered these appropriately. On reflection, this question should have been worded differently. The intention was to capture if the issues highlighted were the right ones to address at later stages of development proposals. Unfortunately, this was not clearly expressed in the question. However, the strength of feedback and comments on environmental and transport issues are still worth acknowledging.

More than half of respondents opposed the LNG terminal and marine construction and decommissioning proposed uses. Combining all negative responses, the power station and concrete batching uses were also opposed by more than half of the respondents.

Aquaculture, modular construction, train manufacturing, and plastics recycling and storage were the uses with the most support, ranging from around 40-50%.

CONSULTATION SUMMARY 18 19

Survey comments

80 participants responded to question 8 Criticism of the draft Master Plan Environmental concerns Tourism in the questionnaire (“Do you have any document and community engagement Concerns about the environmental impact The most common theme with tourism was extra suggestions on maximising the local Criticism in this area centred on the level of the proposals and calls to complete respondents both raising concerns about economic and social benefits of Hunterston of detail provided in the draft Master Plan a thorough Environmental Impact the potential impact of the proposals on PARC?”) and a summary of the written and questions regarding its accuracy, Assessment were also mentioned multiple tourism and recreation and calling for the comments received is provided below. particularly in relation to the projected jobs times in the feedback. site to instead be developed in a way that figures. would enhance local tourism. In addition to the questionnaire, a small Transport infrastructure concerns number of local residents provided Some respondents were also critical of Respondents highlighted concerns Potential jobs impact comprehensive written responses to the the questionnaire design believing it to be regarding the impact of redevelopment Positive feedback tended to centre on the draft Master Plan, outlining their views on leading and urged Peel Ports to improve its on surrounding transport infrastructure or potential for redevelopment to increase the the proposals, and these comments are community engagement going forward. mentioned the need to improve transport number of jobs in the area. However, some also reflected below. infrastructure as part of any development. respondents qualified their feedback by Potential negative impact on including considerations that would need As well as suggestions on maximising neighbouring communities Opposition to Liquid Natural to be addressed such as the jobs being the local economic and social benefits Concerns regarding the potential impact of Gas (LNG) Terminal sustainable. of Hunterston PARC, many respondents the proposals on neighbouring communities Some respondents used this section to used this section to highlight their views or and the local area are another theme highlight their opposition to proposals for concerns regarding the draft Master Plan. evident in the feedback. These concerns a LNG Terminal citing concerns over centre on potential noise, dust, air safety, the proximity to local communities The summary below does not provide pollution, negative visual impact and traffic and Hunterston power station and every written comment received, but rather generation. potential environmental impact. identifies common themes and includes example comments illustrating those Peel Ports have been poor Prefer green tech alternatives themes. Many respondents also used this neighbours in the past Many respondents advocated for the site section to suggest alternative uses for Linked to the above, some respondents to be used as a Green Energy Hub or the site and these suggestions have been highlight a belief that Peel Ports (and as a base for renewable/green industry included below. predecessor bodies) have been bad and technology. Many also expressed neighbours in the past with activities at disappointment that the current plans do Hunterston negatively impacting local not reflect this vision. communities. CONSULTATION SUMMARY 20 21

Stakeholder responses

Written responses were received from of the next generation of offshore wind Also concern over any tall structures Crown Estate Scotland the following groups: assets’ is particularly exciting. The plan associated which might be visible from • No comments to make on the specific • Council could mean Hunterston is well placed to Bute. proposals but looks forward to playing • British Ports Association be at the forefront of Scotland’s strategic its part in the regeneration of this • Bute Community Council move towards a low carbon and circular Caledonian Maritime Assets Limited nationally important infrastructure • Caledonian Maritime Assets Limited economy. (CMAL) project. (CMAL) • Supports an LNG Facility at Hunterston • Clyde Marine Planning Partnership • The PARC’s focus on ensuring the as it would assist CMAL in its desire • Recognises that ports and harbours are • Crown Estate Scotland use of clean technologies for the future to increase the use of LNG on the strategically important for the economy • EDF Energy is admirable, not only supporting the CHFS Network as vessels are delivered of Scotland as well as being catalysts for • Fairlie Community Council Government’s sustainability objectives and further ones are built. Currently the economic development. • Friends of the (FOFOC) but providing innovative environmental source for LNG fuel would be the Isle of • North Ayrshire Council credentials that many ports strive Grain which is 465 miles from Ardrossan EDF Energy • North Ayrshire RSPB local group towards. which in turn is the southerly most route • Considers the plan a step forward • Offshore Renewable Energy (ORE) within the network. in relation to providing opportunities Catapult • The positive vision presented by the regarding the future plans for the • RSPB Scotland Master Plan signals not only a great Clyde Marine Planning Partnership Clydeport site. • Royal Yachting Association (RYA) boost to Hunterston PARC but also North • CMPP decided that at this point in time Scotland Ayrshire and Scotland as a whole. The it would not be appropriate to respond • Will submit a formal response when • Scottish Enterprise strategy rightly recognises the importance in detail to the Master Plan. appropriate and engage in the review • Scottish Government of maximising economic growth while of any formal proposals for the use • Scottish Natural Heritage retaining good environmental credentials, • Is currently developing the Regional of the site, via the planning application • SEPA ensuring a positive future for this project. Marine Plan and so it is not yet a process with a view to ensuring any • University of Strathclyde document that has been formally impact is consistent with the safe • UK Major Ports Group (UKMPG) • Expresses whole-hearted support for this adopted by Scottish Ministers and some operation of Hunterston B. • West Kilbride Community Council ambitious and exciting project. parts of it will be subject to considerable • West Kilbride Development Group change before it becomes statutory. Fairlie Community Council Bute Community Council • All of Peel Ports’ proposals come Summary of responses • Should be more focus on industries which • Referred to the National Marine Plan with some level of threat to the amenity Argyll and Bute Council support the circular economy and the UK and the pre-consultation draft of the of Fairlie and the local area, and it raises • On the basis that all of the proposed Government commitment to achieving net Regional Marine Plan to provide insight concerns regarding noise, dust and air activities will occur within the confines zero emissions by 2050. into the main issues concerned with in quality. of the masterplan area, and be subject to the Clyde Marine Region and the types further consents as necessary, Argyll and • Use of dry dock area for oil and gas of policy that may be introduced. • Would welcome jobs, but not at any Bute Council has no comments to make. rig decommissioning is not supported. • Would look forward to continuing to cost; these proposals would come at • Should further detailed proposals be The envisaged alternative use for the be involved as plans for the site develop a high cost to Fairlie and the wider area, made which may result in impacts construction of base units for offshore and as the Clyde Regional Marine Plan which depends on its natural beauty to beyond the Masterplan area, Argyll and wind turbines would be supported develops, and in particular its role as a bring people to live, work and visit. Bute Council reserve the right to in principle subject to further detail on statutory consultee for marine licence reconsider its position. proposals. pre-applications and applications. • State full support for the responses from Friends of the Firth of Clyde and West British Ports Association • Concerns over an LNG Terminal and • Concerned that the red boundary line in Kilbride Community Council. • The master plan’s aspiration which associated CCGT Power Station. These the plan entitled ‘Hunterston PARC site would see the existing features of the concerns centre on safety, given the boundary’ encompasses some parts of port enable the PARC to act as a host for close proximity of populated areas and the SSSI. the ‘scaled manufacturing and servicing the Hunterston Nuclear Power Station. CONSULTATION SUMMARY 22 23

• Environmental Impact Assessments, Friends of the Firth of Clyde (FOFOC) done independently and properly, survey voluntarily advocated by the company, would go a long way to improving Peel FOFOC believes the consultation Ports’ standing. questionnaire distributed by Peel Ports was ‘deeply flawed’ and therefore undertook its Friends of the Firth of Clyde (FOFOC) own online survey which received around • Supports the idea of using the site for 100 responses. high tech renewable and green energy, however this Master Plan could not be FOFOC survey asked respondents for their further from this vision. thoughts on each of the proposed activities. The sentiment of the narrative responses • The Master Plan, as it stands, presents was highly consistent with those returned a threat to the way of life and in Peel Ports own survey and some of the environment enjoyed by local stakeholder comments, and are therefore communities. covered elsewhere in this report. There was also a strong level of consistency between • Peel Ports should be open and the two surveys when responders were transparent, map out proposals in more asked about specific options (see page 24- detail and signpost communities to 25). existing case studies and documentation.

• The community have suggested other uses, although FOCOC does not necessarily endorse these: • Research & education park • Battery farm for renewable energy storage • A solar array • Seaweed Farm • Recycling of plastics to make beads for road surfacing • Large-scale green houses for high value food production • Manufacturing and construction plant powered entirely by green energy • Processing of seaweed for food, plastic alternatives, extraction of nutrients and materials • Warm water shellfish

• FOFOC also propose restoring the land to its original state, re-wilding the site and creating a Carbon Capture Forest to build on the existing Natural Carbon Sink of the Seagrass meadows of the Southannan Sands SSSI. CONSULTATION SUMMARY 24 25

FOFOC survey responses Hunterston PARC responses

Fully Do not Support Neutral Object Support 4 3 2 Support EXECUTIVE SUMMARY 26 27

North Ayrshire Council • More prominence could be given to the As well as responding directly to the potential of Hunterston as an ‘energy consultation, North Ayrshire Council also hub’ in relation to Scotland’s wider submitted the minutes from a meeting of aspirations for a low carbon economy. the Planning Committee on 19 June 2019, during which the Council’s draft response • Main concerns with the Master Plan to the Masterplan consultation was surround the Socio-Economic Study. discussed. The tone of this section and discussion of population decline and employment • Support the re-development of is overstated and overly negative. Hunterston PARC, which is recognised as having the enabling capability to • Important that the masterplan does bring international levels of investment recognise the environmental sensitivities to Scotland and Ayrshire, via the of the site. Would also welcome Proposed Local Development Plan and consideration of how the development Ayrshire Growth Deal. of Hunterston PARC could enhance the local environment, including for • Local Development Plan (LDP) 2 local residents, and detail on any identifies Hunterston as a Strategic ongoing or proposed monitoring of Development Area and supports a wide environmental impacts. range of future uses for both the port and marine yard and the nuclear estate. • Robust community engagement must be at the heart of the successful • Draft Master Plan would benefit from regeneration of Hunterston, working some refinement to form a document in partnership with local people and that is more concise, more engaging organisations to deliver shared in its presentation and clearer in its outcomes and supports Peel Ports’ message of the overarching strategy intentions in this regard. and opportunities for Hunterston PARC. One local councillor also provided • Happy to work with Peel Ports Group feedback separately which aligned with to explore how a revised Master Plan most of the points raised in West Kilbride could be supported by the Council, Community Council and Friends of the taking account of Local Development Firth of Clyde’s responses and looks Plan 2, which they expect to adopt forward to working with Peel Ports and the towards the end of 2019. rest of the Liaison Committee to achieve a solution to use the site for a purpose that • The Planning Committee outlined is acceptable to all. opposition to LNG storage and would encourage a renewable energy activity North Ayrshire RSPB local group as a suitable replacement to accord with • Would like to see a commitment to our commitment to a low-carbon working with groups such as RSPB circular economy. to improve the habitats for wildlife. The marine habitat of the lagoon, with • Support the six principles outlined in the its limited tidal movement and sheltered Business Vision section. Key interest waters, certainly needs expert study. is in the creation of a variety of jobs, including those in skilled and emerging sectors. CONSULTATION SUMMARY 28 29

• Has a good working relationship with RSPB Scotland local staff, who have been very helpful, • Welcome the recognition of the nature and would hope to see that continue. conservation interests of the site and in particular the need to protect • Access to the lagoon needs to be Southannan Sands SSSI. Noted that a improved if a “visitor centre” is to be a large section of Southannan Sands SSSI reality. The current system for managing is included within the Hunterston PARC access is only suitable for a small group site boundary and are concerned about of regular visitors. the implications of this. We request that the boundary be redrawn to exclude the • Would have concerns about how the SSSI. cooling system for a power station would affect the local marine environment. [Peel Ports additional note: the boundary shown on the map is just • Raised concerns about the issue of the site boundary, reflecting the area airborne dust in relation to a cement under Peel Ports’ ownership and factory. responsibility. There is no intention to develop upon the SSSI.] Offshore Renewable Energy (ORE) Catapult • Would in principle support the proposal • Is working with Peel Ports Group on for a visitor centre to showcase the the potential for Hunterston PARC to wildlife, but would question whether it play a role in the establishment in would attract sufficient numbers of Scotland of facilities for the large-scale people to justify the investment and manufacture, assembly and servicing suggest that there may be other more of floating assets for offshore wind appropriate ways of making the site more generation. accessible.

• Has already presented intention to • Concerns that the proposal for a work with Peel Ports, the University of plastic recycling and storage facility risks Strathclyde and those in the renewables contaminating the marine environment sector to arrive at a blueprint for how the with waste plastics and plastic feedstock, PARC can be used to support subsidy- were there to be any spillage from the free power generation. These plans will facility. rest on development of the dry dock and marine yard. • Decommissioning is an activity with potential risks to the marine environment, • Is committed to the development particularly if contaminated infrastructure in Scotland of a supply chain for new is being transported over long distances renewable energy opportunities and are and through sensitive areas. excited by the mission and strategy that Peel Ports is offering in this area. CONSULTATION SUMMARY 30 31

Royal Yachting Association (RYA) activity in building the large-scale • The planning system in Scotland is Scottish Natural Heritage Scotland assets for the floating offshore wind fully devolved, legislation relating to • Fully recognises the economic • Notes the proposals in the Master Plan industry and the decommissioning of the planning system in England does importance of the port facility and the and welcomes the opportunity for growth floating assets from the oil industry. not apply to this site. Given that LNG potential for a broad range of associated and development arising from it. handling and use is identified within the development. The Master Planning • Recognise that some of the potential masterplan we would also highlight our approach is a well-recognised method • Asks to note that the area of Fairlie, uses of the site will need consents ‘Circular 3/2015: Planning Controls for for setting out aspirations and seeking Largs Channel, and the waters and that continued work to engage with Hazardous Substances’. to integrate with local, regional and around the two Cumbraes are probably stakeholders and the wider community national strategies. the busiest waters for recreational is essential. • Highlights ‘Planning Advice Note boating in the whole of Scotland. The 83: Masterplanning’ which states: ‘An • May be advantages in undertaking waters around Cumbrae are the • Has been involved in the formulation effective masterplan should explain how a Strategic Environmental Assessment only waters in Scotland designated for of the strategy for the PARC and keen a site, or series of sites, will be (SEA) to support this plan. An SEA international sailing events by World to work with Peel Ports and partners to developed, describing and illustrating would demonstrate that the potential Sailing. Major events are held in these see this plan realise positive outcomes the proposed urban form in three impacts arising from the different waters every year and support both the for the Ayrshire and Scottish economy. dimensions. It should show how that development options have been local marine and tourism industries. Any form will achieve the intended vision anticipated and that mitigating factors detrimental marine and industrial activity • Recognises the low carbon and for the place, and how a distinct and have been considered in the could jeopardise this status. circular economy potential outlined in appropriate character will be created. final allocations. the masterplan and the opportunity It should also describe how the project It would also assist • Aware of the potential for conflict arising that this creates for dynamic future will be implemented through a delivery statutory agencies from possible severe visual intrusion in facing employment opportunities. strategy which sets out phasing, timing with the adoption the landscape, noise, and escape of and funding.’ of the master plan. dust or water pollution, which could Scottish Government have a damaging effect on all forms • Hunterston is identified in National • Particularly when derived from of recreational boating in these waters, Planning Framework 3 as a key location bio-sources demand for alternative particularly for international events, in relation to the marine renewables hydrocarbon resources such as LNG and an adverse impact on the clubs sector. could potentially reduce emissions. and the commercial operation of Largs The Scottish Government is supportive Marina - all of which would have • It is not clear how the uses proposed of the uptake of these energy streams, economic consequences. have been co-ordinated with other where the current infrastructure is able development interests in the wider to meet the expected growth in Scottish Enterprise Hunterston area. Similarly is it not clear demand. Investment could support • Have already publicly announced support how the approach taken really responds economic development, safeguarding for the completion of the dry dock and to sensitive land uses around the and creating jobs in the energy sector. quay at the marine yard which will give site and the sensitivities created by Notes that detailed site considerations Scotland the capability to support new the proposed uses. need to fully considered as part of any consenting process. CONSULTATION SUMMARY 32 33

• Development of the site will likely be opportunity to provide further comment phased over a long period of time on these issues as the proposals are and that this will mean that large areas refined. of the site will remain un-managed. Such temporarily vacant land can have • Support the requirement of a Flood considerable potential as a wildlife Risk Assessment (FRA) where information habitat. indicates there may be a risk of flooding to the site or where development of the • Note the company’s commitment to site may increase risks elsewhere. its internal environmental policy. The plan also makes reference to statutory duties University of Strathclyde to take environmental considerations • The Hunterston PARC Masterplan and responsibilities into account. provides a number of opportunities for It would be useful if the environmental the application of new technologies requirements set out in the NPF and methodologies which will both Hunterston policies were specifically benefit the regional economy and benefit referenced. the environment.

• Plan correctly identifies the key specially • In particular, the University of Strathclyde protected sites within the immediate is supportive of those ideas in the vicinity of the port. It should be noted ‘masterplan’ which could have a that it may be possible that impacts from significant impact on Scotland’s status development proposals, both individual as a beacon for the floating offshore wind and cumulative, may have impacts on sector and the circular economy. specially protected sites beyond the 5km threshold. These will require • As these ideas move forward would look consideration on a case by case basis. forward to working with the site owners, North Ayrshire Council, Ayrshire College • Plan should recognise the special and other parties around R&D and skills, protected status of marine mammals to ensure the benefits of this living in the area and acknowledge that development are felt locally. disturbing impacts may require licensing. Coastal living otters (another European UK Major Ports Group (UKMPG) protected species) are also present in • The positive benefit of ports extends the plan area. to their surrounding areas. The areas surrounding the traditional ship to shore SEPA activities benefit as the port’s • A number of the indicative proposals development catalyses and acts as a listed in the masterplan will require critical mass for a range of productive environmental authorisation from and job creating activity. SEPA and the site as a whole is likely to require a Controlled Activities Regulations • The Hunterston PARC Masterplan is (CAR) construction site licence for the an excellent example of this potentially management of surface water run-off. catalysing effect, illustrating how the port development itself is just one aspect • Will welcome pre-application of a vision for creating jobs and attracting engagement and look forward to the investment for a range of industries. CONSULTATION SUMMARY 34 35

• Hunterston PARC Masterplan considers • Peel Ports and its tenants do not have Annex A the sustainability aspects of the a perfect record with SEPA and HSE – proposed development in significant this raises questions as to contracts Stakeholder Responses Stakeholder (Non) Responses depth. with possible tenants as to ensuring future compliance with environmental • Argyll & Bute Council • MP/MSP • Specifically notes and commends two controls regardless of which industrial • British Ports Association • Local Councillors aspects of the proposals: activity is being proposed. • Bute Community Council • Cumbrae/Largs/Skelmorlie 1. Returning a post-industrial brownfield • Caledonian Maritime Assets Ltd Community Councils location to productive and job creating • Transportation to and from the site is one • Clyde Marine Planning Partnership • Marine Scotland use. Ports and port operators of the main concerns. The only • Crown Estate Scotland • Field Studies Council throughout the UK have demonstrated acceptable transportation of materials • EDF Energy • HSE their capacity to successfully is by sea or rail. Any other method is • Fairlie Community Council • Magnox regenerate brownfield sites and bring unacceptable to the local communities. • Friends of Firth of Clyde (FOFOC) • Utility Companies them back to productive and job Re-industrialisation must be • North Ayrshire Council creating use. accompanied by improved access as the • ORE Catapult A78 is now at the limit of its capacity. • RSPB 2. Potential to provide a substantial • RSPB North Ayrshire Group cornerstone to regional / local • Highlights that no consultation events • RYA Scotland economic development plans. The took place in Largs or West Kilbride, both • Scottish Enterprise proposed developments would be of which will be significantly affected by • Scottish Environment Protection highly coherent with other strategies the proposals. Agency focused on boosting investment and • Scottish Government Planning prosperity in the North Ayrshire region. West Kilbride Development Group & Architecture • Takes the view that it is necessary for an • Scottish Natural Heritage • The masterplan is an excellent example Environmental Impact Assessment of the • UK Major Ports Group of what ports can do to not only provide plan as a whole - not the discrete • University of Strathclyde Scotland’s and the UK’s gateways to the elements - to be carried out once proper • West Kilbride Community Council world but act as engines of investment, detailed proposals have been produced, • West Kilbride Development Group jobs and prosperity for local and prior to any consideration of specific communities. planning applications. It is entirely desirable that an area, which is in effect West Kilbride Community Council an industrial site, should be put to good • A better plan would be to promote green use but it is also necessary to ensure that energy technologies and other industries environmental considerations are given which address challenges such as due weight. climate change or which de-industrialise the Hunterston peninsula and create a tourist bias approach to the site.

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Peel Ports Group Maritime Centre Port of Liverpool L21 1LA

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