The Highland Council response was a touch more sanguine than other consultees but none the less useful. You can read it HERE. The issue did not go to the full council but was discussed at the Planning, Development & Infrastructure (PDI) Committee a week after the deadline – it had been agreed with the MCA that the Highland Council response could be updated to reflect comments from the PDI committee. It should be noted however, that Highland Council officials had already decided to take a neutral stance prior to committee discussion. This will no doubt be a reflection of their existing relationship with the CFPA and the 2013 Memorandum of Understanding that exists between the two organisations (see www.highland.gov.uk/download/meetings/id/19986/ped2713pdf) – although we would like to highlight the following line:
“To work closely together in ensuring a safe and attractive environment for the benefit of all residents and stakeholders.”
The Highland Council should remember that a significant number of residents and stakeholders are extremely hacked off at the prospect of losing that “safe and attractive environment.” To be fair this is reflected in point 2 of their letter:
- There has been considerable local community and media interest in this application. The local community has prepared assessments of the proposals and the potential impacts of an incident involving oil spillage into the marine environment. In addition, Professor Paul Thompson has detailed information outlining his key concerns with the application, particularly in relation to the local cetacean population. The Council has these assessments and has taken them into account in preparing the response submitted.
This is highlighted again under “Potential Considerations”:
- Local Members are also keenly aware of the significant concerns raised by local residents and Community Councils, particularly the Cromarty Community Council.
Aye, scaremongerers that lot in Cromarty. Other considerations highlighted are also of interest:
- the importance of adherence to ballast water procedures to prevent the spread of marine invasive non-native species;
- in the event of a collision, the proximity and limited availability of emergency towing vessels and tugs requires careful consideration;
- in the event of a spill or collision, the Council’s Emergency Response Team and Environmental Health officers will be required to assist with clean-up operations
- the application report appears to have taken no account of mitigation measures required in the event of a large scale oil spill. Only small scale spills are considered; and
- there appears to be little evidence of local community consultation or how local concerns have been addressed by the applicant. Measures to address wide spread local concerns will be an important consideration in the MCA’s determining the application.
Some interesting issues raised – ballast water procedures, availability of ETV’s in the event of collision (remember collisions are a real issue for insurers so this must be a very real possibility), confirmation of the council’s involvement in clean up, no consideration of a large oil spill and a lack of community consultation. Well the last part is something we are well aware of – it is the refusal of the CFPA to attend a public meeting and answer their questions that has really angered the public in this process. But then again, how do you defend the indefensible?
In the end the Highland Council’s actual response ran to 2 pages. However, we were glad to see this:
- The increase in marine traffic and related ship to ship transfers as a result of the proposed activity has the potential to have significant environmental and biodiversity effect due to the increased risk of ballast water issues, collision, oil spill and noise. These effects therefore require careful consideration as they could in turn have a significant impact on coastal and terrestrial assets, along with economic and social impacts.
It would seem like the Highland Council have some concerns. Are they naysayers too? They raise the issue of oil spill modelling:
- this is based on 1000kg realised over 10 minutes. This would appear to be unrealistic given that oil would likely be pumped at around 2 tonnes per second.
Which is what we’ve been saying all along – if a hose spring a leak or is wrenched apart (as happened in February this year at Southwold) – you have 1 tonne (1000kg) of oil in each hose. There will be at least 2 hoses. You have a reaction time to realise there is a problem, then time for the pumps to shut down. Even if all this could take place in 10 seconds – that would represent the loss of 20 tonnes of oil. Then look at the scenario where transfers are done at night, the wind gets up, the guy on watch falls asleep, goes to the toilet, goes to make a coffee or get’s drunk – the hoses on the ships are torn apart (as happened recently) or bursts open – you could be looking at a minute, 10minutes or more before you notice anything is wrong – for 2 hoses that’s 200 tonnes of crude oil going into the sea every 10 seconds that goes by. You can’t fail to recognise that this is at least of some concern!
It also mentions:
- in the event of a collision, the proximity of emergency towing tugs requires careful consideration, In this case you may be aware of the council’s commitment to work with the Scottish Government to press the UK Government for the same less of protection as previously provided by two emergency towing vessels with fire fighting capability covering the Minch and the Northern Isles. This type of activity in close proximity to the Highland coastline demonstrates the need for such provision, and we ask that significant efforts are made to ensure that such cover is available should any incident occur.
An interesting point – if a collision occurs the Cromarty harbour tugs are simply not big enough to pull a stricken tanker of the rocks. That was the whole point of having the emergency towing vessels in the first place – Lord Donaldson’s report finding that the common theme was harbour tugs not being able to properly attend to a stricken tanker – they just don’t have the bollard pull. The need for fire fighting capability as also interesting – what would happen in the event of explosion or fire? Would out fire brigade be expected to put a fire out on a burning tanker? I hope not. Could a harbour tug cope? Unlikely.
The rest of the representation generally covers point made already, however, given the potential for “significant environmental and biodiversity effect” the need to ensure “a safe and attractive environment for the benefit of all residents and stakeholders” we feel that it would be more appropriate for the Highland Council to object to this application. This is what we will be encouraging our Highland Councillors to do. If you think STS is a bad idea, please do so also – they are are our elected representatives and they need to be aware that local people do not want this or need this. There is no benefit to the community, there is only danger. Who will come to the Highlands and the Moray Coast to watch oil tankers?
.
