Our National Marine Planning Process – How to Make a Submission

Our National Marine Planning Process – How to Make a Submission

posted in: Environment | 0

1. What is Marine Spatial Planning?

Marine spatial planning is a process that brings together multiple users of the ocean to make informed and coordinated decisions about how to use marine resources sustain-ably. It is a process by which the relevant public authorities analyse and organise human activities in marine areas to achieve ecological, economic and social objectives.

National Marine Planning Framework FAQ

 

2. What governs this process?

DIRECTIVE 2014/89/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL : 23 July 2014

The main objectives of maritime spatial planning as laid out in the above EU Directive are as follows :

The Islands
  1. When establishing and implementing maritime spatial planning, Member States shall consider economic, social and environmental aspects to support sustainable development and growth in the maritime sector, applying an ecosystem based approach, and to promote the coexistence of relevant activities and uses.
  2. Through their maritime spatial plans, Member States shall aim to contribute to the sustainable development of energy sectors at sea, of maritime transport, and of the fisheries and aquaculture sectors, and to the preservation, protection and improvement of the environment, including resilience to climate change impacts. In addition, Member States may pursue other objectives such as the promotion of sustainable tourism and the sustainable extraction of raw materials.
  3. This Directive is without prejudice to the competence of Member States to determine how the different objectives are reflected and weighted in their maritime spatial plan or plans

 

3. Who can get involved and make submissions?

The marine plans are for anyone who has an interest in the marine plan areas. However, there are certain sectors that are immediately recognisable as playing a key part in marine planning, such as:

  • aquaculture
  • defence and national security;
  • offshore renewable energy;
  • oil and gas exploration and production;
  • fisheries;
  • local coastal communities and elected members;
  • local authorities;
    River Ilen Estuary
  • marine aggregates;
  • environmental organisations, including marine conservation;
  • cultural heritage;
  • marine dredging and disposal;
  • ports and shipping;
  • telecommunications and cabling;
  • tourism and recreation;
  • waste water treatment and disposal.

This is not an exclusive list and will be expanded as the process proceeds according to the Government.

 

4. How do I make a submission?

Anybody who wants to become involved in the MSP process may make contact in writing by email at :

Mussels on the seabed

msp@housing.gov.ie

or by post to :

Marine Spatial Planning Section,
Department of Housing,
Planning and Local Government,
Newtown Road,
Wexford,
Y35 AP90.

 

5. Are SOS making a submission?

Yes. We will be making a submission in the coming days. We have highlighted how the proposed Plastic Factory will create contaminated waste waters as a by-product of their production processes & their cleaning processes. The transport of Plastic Nurdles to and from the factory will also create many opportunities for contamination of the environment and waterways. We have written extensively on the damage that such Nurdles will do to the marine environment in both our rivers and seas. We have also highlighted the lack of reporting into the possible effects on the Special Areas of Conservation at Lough Hyne and Roaring Water Bay & the Islands. There are also dangers to existing economies, especially the shellfish industry based in Roaring Water Bay.

We will be highlighting in our submission the complete disregard for the potential damage this Thermoplastic Compounds Facility could cause to Marine life and the damage that could be done to existing jobs that are dependent on our healthy and thriving marine ecosystems.

These concerns and the lack of statutory oversight or investigation by local Government during this planning process have highlighted the need in Skibbereen and West Cork for stronger regulatory policies in protecting our Atlantic from developments that would adversely impact marine life and the many jobs that are sustained by the sea in food, tourism and leisure. It would be a disaster for West Cork and Skibbereen if the huge interest that has been developed nationally and internationally through the Wild Atlantic Way marketing campaign was squandered for a plastic factory. Especially now as awareness about plastics and the pollution they cause to our seas and shores is now the environmental topic of the day.

This is an opportunity for everyone concerned to make their voices known so that this process is one that takes into account the views, aspirations, fears and hopes of the local community.

If you have any questions or require any assistance in making a submission, please email us at info@saveourskibbereen.ie

 

6. What happens to our submissions?

Responses will inform the next steps in the process, including the development of objectives and policies in the draft plan.  All submissions received will be subject to the provisions of the Freedom of Information Act and Data Protection legislation.

 

7. More Information

 

Towards a Marine Spatial Plan for Ireland

National Marine Planning Framework Baseline Report

EUROPEAN UNION (FRAMEWORK FOR MARITIME SPATIAL PLANNING) REGULATIONS 2016

 

Skibbereen, West Cork & The Wild Atlantic Way

Skibbereen, West Cork & The Wild Atlantic Way

posted in: Environment | 0

Here are some of our favourite photos that show off the environment we are seeking to protect. If you read our other articles, you will see how the emissions and waste water from the proposed Thermoplastic Compounds Facility will have a destructive impact on the health and vitality of our waters, our land and our air.

This slideshow requires JavaScript.

Frequently Asked Questions

Frequently Asked Questions

posted in: About Us | 0

This document sets out the most frequently asked questions from the press, politicians and members of the public that campaign group members may regularly be called on to answer. The aim is to provide everyone involved with a regularly updated version of these to ensure that we are sending out a consistent message with clear fact based information in all our communications.

 

 

Question

 

Answer
But I have heard that this factory will bring around 40 much needed new jobs to Skibbereen for our young people….?

 

·        The exact number of jobs is very unclear.

·        What we know from other similar plants that this same company operate is that the operation can run with relatively low numbers of employees.

·        Some of the specialist jobs will be done by people brought in from elsewhere and although there will be some local employment opportunities, it may be less than 20 and the jobs may be unskilled and low paid.

·        This land space is large and could open up larger numbers of employment in our community positively impacting the values of Skibbereen (wild atlantic, fishing, food, technology etc).

·        An example of this is the Ludgate Hub and how this opened up job opportunities and put Skibbereen on the map.

·        We also see this with local food producers who have built successful businesses

 

Surely the Council would have carried out a thorough check on the environmental impact before agreeing it…..

 

·        No environmental impact assessment has been carried out.

·        Thus there is no information available to the planners of the possible negative effects to the Ilen Estuary which is home to many protected species of fish, birds and mammals and plants, nor to the Special Areas of Conservation of Roaring Water Bay and the Islands and of Lough Hyne.

·        Any destruction of these areas can negatively effect the tourist industry and the inland fisheries, possibly putting many jobs at risk.
Particularly at risk could be the shellfish farmers.

·        Roaring Water Bay employs 72 people in mussel farming; all of whom could be put at risk.

You can’t open a factory without a proper health and safety risk assessment, can you?

 

·        No fire risk assessment has been carried out despite the potential for the process involving potentially combustible materials and chemicals.

·        Skibbereen fire department have been given no detail and no supplementary training to deal with a fire in a thermoplastic compounding factory.

·        The Fish Factory fire in Baltimore, had to call in extra resources from Mallow, Middleton and Bantry.

·        The air born pollutants of a fire from a Polymer Compounding Factory are a serious health hazard and can include : Heavy Metals, Dioxins, Furans and Polyaromatic Hydrocarbons (PAHs).

 

 

It has been agreed, whether we like it or not we can’t really stop this now. It’s inevitable and just too late to do anything isn’t it?

 

·        We see this as just the beginning of our campaign and it is far from agreed.

·        If the appeals to An Bord Pleanála are not upheld, we aim to request a judicial review of the planning decision and process. 

·        As the campaign grows and public awareness increases, we will be lobbying our elected representatives and gaining mass support from individuals, businesses and politicians and using legal argument and process and public opinion to pressure the company and An Bord Pleanála to reconsider.

 

 

This is on the outskirts of town so it’s not going to have a huge impact on the local area?

 

·        The site is right next to the Retirement Village, Skibbereen Football Club, the Golf Course and the Ilen River and the Wild Atlantic Way.

·        Quite apart from the risks of pollution and fire, there is the increased traffic coming straight through Skibbereen, the danger of spillages in transit, the risk to water courses which flow into our rivers and into our coastal waters and the potential for damage to the marine environment and the seafood industry in the area.

 

It’s just light manufacturing, so its impact will be minimal?

 

·        A Light Industrial building means an industrial building in which the processes carried on or the machinery installed are such as could be carried on or installed in any residential area without detriment to the amenity of that area by reason of noise, vibration, smell, fumes, smoke, soot, ash, dust or grit.

·        Plastics manufacturing is a major part of the chemical industry, and some of the world’s largest chemical companies have been involved since the earliest days, such as the industry leaders BASF and Dow Chemical

·        This facility will have 4 X17 metre chimneys to disperse the emissions of fumes, dust and particulate.

·        It will have machinery running 24 hours a day

·        Toxic chemicals need permanent refrigeration

·        There will be 4X16 metre silos being filled and emptied of plastic pellets regularly

·        The processing of toxic chemicals in such a sensitive area cannot legitimately be described as light industrial activity.

 

 

 

They will never agree this, will they?

 

·        If local residents had not raised objections and gone to considerable time and financial expense to appeal against the County Council Planning Decision the bulldozers would already be preparing the land for this factory to be built.

·        The more we can raise public awareness and support for our campaign the better chance we have to stop this.

·        Every poster, leaflet, tweet, facebook share and conversation can help.

You have to balance the economic benefits with the environmental impact. If we want zero impact we wouldn’t be able to do anything?

 

This campaign is not opposed to economic development in Skibbereen. In fact we welcome appropriate, sustainable and responsible inward investment.  We want to see jobs created in the tourism, food and technology sectors such as the work being done  by the Ludgate Hub and the growth of companies such as Spearline Lab which offer good quality skilled jobs that do not have an adverse impact on our environment.
This company have plants all over the world and the process doesn’t seem to have caused problems in these places?

 

·        The company headquarters in Winona USA is required to report via the Toxic Release Inventory and is set in a Non Attainment Area, which means air pollution levels are persistently high.

·        Indeed this area of Winona falls below National Ambient Air Quality standards for pollution levels for ozone, lead, sulphur dioxide and particulate matter.[i]

·        Particulate matter refers to small solid particles and liquid droplets found in the air and mostly formed as a result of complex reactions of chemicals such as sulfur dioxide.

·        Some particles, such as dust, dirt, soot, or smoke, are large or dark enough to be seen with the naked eye.

·        Others are so small they can only be detected using an electron microscope and can be made up of hundreds of different chemicals.

·        They are so small that they can be inhaled and cause serious health problems.

·        Winona includes a large area of Impaired Waters, which means the regulations and controls are not stringent enough to meet the water quality standards set by states for the quality of surface and ground waters. The factory is close to the banks of the Mississippi and pollutants found in the river include Mercury and Polychlorinated Biphenyls (PCBS).
The Mississippi River ranks 2nd in the nation for total toxic discharges.

·        The company will be manufacturing thermoplastic resins which it will ship as tiny pellets called ‘Nurdles’. The  University of Gothenburg have found that 60% of the identifiable plastic in the Rhine is ‘Nurdles’ and can be traced back to polymer compounding facilities along the banks of the river.

·        From one company alone the annual spillage into the environment was 3 billion nurdles. This one company was following industry best prcatice guidelines and it’s motto was not one nurdle spilled.

 

Who is behind the SOS campaign? What are their aims?

 

·        The campaign is made up of ordinary, local people who live and work in and around Skibbereen. They run businesses, raise families, play sports and take part in cultural activities all within the local community. Most of all, they all love the unique and special landscape and environment of this wonderful part of West Cork.

·        The aim of the campaign is to stop this thermoplastic manufacturer building a facility in Skibbereen and to promote development of skibbereen through more sustainable means such as tourism and technology, as is outlined in the agreed Local Area Plan.
West Cork is Special, Let’s keep it that way.

 

This is just a bunch of tree hugging “blow-ins” moaning to their celebrity friends.

 

The campaign is proud to have the support of many locals who were born and raised here and many locals who made the decision to move and live and work here. The campaign is very broad and involves everyone: from local teachers to business people, from young people and parents to the elderly and from farmers and food producers to film producers.

 

Young people will continue to leave Skibbereen if there are no decent jobs here?

 

We agree. That is why our campaign is not just calling for this unsuitable development to be stopped but is actively campaigning for more investment in high quality sustainable jobs that will enhance Skibbereen and not put our environment at risk.
This will not affect me personally, so why should I care?

 

Anyone who has a job in tourism, who has children or grandchildren growing up here, or who just loves the beautiful environment here should care and get involved to ensure that the River Ilen remains one of the cleanest rivers in Ireland, that the South West Coast of Ireland stays free of micro-plastics, that our air remains free of toxic release emissions and our roads are not clogged with heavy goods vehicles.
Look I agree with you but I can’t get involved publicly in this because of my job, business, position, family situation etc?

 

There are lots of ways of helping the campaign. By signing a petition, putting up a poster, sharing social media posts or making a donation small or large to the campaign you will be providing great support and making a real difference. The campaign will be more effective if we can call on lots of people to do small tasks rather than relying on a few to do everything.
If this is going to end up in court, how can we compete with the Government and a huge corporation? We are learning from other campaigners all around the world about how you can change minds and challenge bad decisions.  As Nelson Mandela said: “It always seems impossible until it is done….”

 

 

[i] https://echo.epa.gov/detailed-facility-report?fid=110000426628

 

You can download this document here :

Save Our Skibbereen Frequently Asked Questions

Environmental and Health Impacts

Environmental and Health Impacts

 

Overview

 

RTP Company, whose headquarters is in Winona, Minnesota has applied for planning permission to build a Polymer Compounding Facility, under the name of a newly formed subsidiary, Daly Products, on the Baltimore Road Skibbereen.

The factory they hope to build in Skibbereen is planned with four 16 metre emissions stacks; nevertheless the planning authorities and EPA have decided that they do not require an Environmental Impact Study and the facility requires no Integrated Pollution Control licence nor even an Emissions Licence.

In the Cork County Council Ecologist’s report, 18th December 2017, there is no consideration of the possible impact on the environment of nurdle pollution nor is there any consideration of the impact of waste water that will contain microplastics that will be contaminated with heavy metals, volatile organic compounds and many toxins associated with the process of manufacturing RTP products.

Currently the planning decision rests with An Bord Pleanála. They have twice deferred their decision and the latest given date by which the decision will be made was 26th September 2018 though this has now been pushed back another 2-4 weeks. Should they find in favour of RTP Company/Daly Products Save Our Skibbereen intend to apply for leave to bring an application for judicial review.

We fear for the safety of the Environment in and around Skibbereen and West Cork and we fear for the Marine Environment should this planning application be approved and the factory be allowed to go ahead.

In the Irish Times article, below,  the EPA has classified microplastics as “a newly identified contaminant” in water sources, including drinking water, but said “the impact of them on people’s health has not yet been fully assessed and determined”. The EPA does not yet take into consideration the impact of microplastics in any assessment of planning applications by plastic manufacturers.

Link discovered between microplastics in rivers and wastewater treatment plants

That micro-plastics are a threat to our environment and our health is now becoming obvious. What is more serious, with regard to this proposed development, is the likelihood that these micro-plastics will contain many toxic chemicals and heavy metals due to the methods of production and the water based methods of removing contaminants from emissions.

 

The Air we Breathe

 

Interestingly, RTP Company in Winona does have to be licensed and is set in a Non Attainment Area, which means air pollution levels are high and persistently exceed the National Ambient Air Quality Standards (NAAQS).

Indeed this area of Winona is persistently sub-standard for pollution levels of ozone, lead, sulphur dioxide and particulate matter.[i]

Particulate matter refers to small solid particles and liquid droplets found in the air and mostly formed as a result of complex reactions of chemicals such as sulfur dioxide

Some particles, such as dust, dirt, soot, or smoke, are large or dark enough to be seen with the naked eye. Others are so small they can only be detected using an electron microscope and can be made up of hundreds of different chemicals.

They are so small that they can be inhaled and cause serious health problems both to humans and to animals. Particles can be deposited on the vegetation in the surrounding environment and in the water.

Water and air quality report for RTP in Winona, Minnesota[ii]

https://echo.epa.gov/detailed-facility-report?fid=110000426628

 

Surface, Ground and River Water Contamination

 

RTP Company headquarters is in Winona, Minnesota. Winona includes a large area of Impaired Waters, which means the regulations and controls are not stringent enough to meet the water quality standards set by states for the quality of surface and ground waters. The RTP Company polymer compounding facility in Winona is close to the banks of the Mississippi and pollutants found in the river include Mercury and Polychlorinated Biphenyls (PCBS).
The Mississippi River ranks 2nd in the nation for total toxic discharges. Along its course in Minnesota, 703,019 pounds of toxic chemicals were dumped by industrial facilities into the Mississippi River in 2010.[iii]

The planners assessment for the factory proposed for Skibbereen states that the Main impact (will be) on local flora and fauna populations located downstream in the SAC from contaminated surface water on site”. This  report states that surface water run off will be discharged into an ‘existing drain’. However this drain is currently a stream that runs into the ‘Assolas Stream’ that travels alongside the Baltimore Road towards Skibbereen and into the Caol Stream. The Caol Stream runs into the River Ilen which flows out to the Roaring Water Bay SAC just 7 kms away from the proposed site.Indeed the planners report also states that all surface and process water will be discharged through Skibbereen Waste Water Treatment Plant, which in turn discharges into the River Ilen.

What contamination will be in the discharged water?

The company have not verified what toxins may be in the water discharged through the Skibbereen Waste Water Treatment plant or found in the run off from contaminated surface water on site, however we do know from the planning reports that they will be using

  • Cadmium
  • Bromine
  • Cobalt
  • Nickel
  • Tin
  • trace amounts of other Class II compounds
  • Antimony
  • Copper
  • other Class III compounds will be used
  • and that there is likely to be sulphur oxide released.

Looking at the parent company in Winona Toxics Release Inventory History of Reported Chemicals Released in Pounds per Year at the Site. [iv] shows that the greatest toxic release in 2017 was from Antimony Products.

Finely dispersed particles of ANTIMONY form explosive mixtures in air and there is a risk of fire and explosion on contact with acids or halogens.[v] This risk of fire also poses an even greater air-borne pollutant risk, via deposition to the surrounding area and the SACs of Roaring Water Bay and Lough Hyne.

We do not know if RTP/Daly Products intends to create the same end use polymer in Skibbereen as they do in Winona. They have supplied scant information in their planning application. That the EPA have not requested that they apply for an Integrated Pollution Control or an Environmental Impact Assessment Licence then is all the more puzzling.

 

The Massive Impact of Toxic Nurdles

Plastic Nurdles

Adding to the risk of heavy metals and other toxins entering the River Ilen and the Marine Environment is the risk of plastic micro-bead pollution.

The factory will ship in tiny pellets of raw polymer called Nurdles. Each bulk truck can carry about 2 billion nurdles per load
Around the world these pre-production polymer pellets or Nurdles regularly get spilled in production, in road and rail transport and in shipping.
This is such a big problem that the industry itself has an initiative called ‘operation clean sweep’ which publishes ‘best practice’ to keep Nurdles out of the environment.Operation clean sweep has been running for 25 years and yet if you Google Nurdles, or Nurdle Spills you will find pages upon pages of reports of current spills, of volunteer clean up operations and of devastation to wildlife.

Many clean up specialist brought in for large spills state that a large Nurdle Spill is worse than an oil spill.

One polymer compounding factory in Sweden stated “our aim is to not lose a single pellet.”

However a study by the university of Gothenburg and published in Marine Pollution Bulletin  estimated  the total release of 5mm preproduction pellets (NURDLES) from this very same site into the surrounding environment is 36 million pellets annually. If fragments of pellets (down to 300 μm) are counted there is an hourly runoff, of over 500,000 plastic particles per hour released into the environment.

The same study showed that wherever there were compounding sites there were greater numbers of nurdles and fragments in the environment; and there were also spills around areas of subcontracted companies involved in transport, storage, cleaning and waste management.

A study in the river Rhine in 2015 showed that 60% of the identified plastic particles were 5 mm spherules (Nurdles) with a linkage to different industries along the river.

A recent study in the UK indicates a national yearly loss of around 53 billion pellets even when there are no major Nurdle spill reported anywhere.

The Irish EPA has looked at plastic pellets in freshwater streams and has listed molluscs, fish, crustaceans, amphibians and mammals that are at risk from micro-plastic pollution, and 13 different birds of conservation concern that are at risk of micro plastic pollution. The plastic get into these freshwater streams and rivers from production spills into storm drains as well as spills from transport.

In April 2018 a single trailer turned over on a bend in the the road near Pocono creek which runs into the Delaware River in Philadelpia.  49,000 lbs of nurdles were spilled. That was 1,125,000,000 x5mm spherules of plastic released into the environment. Local volunteers were left to do the clean up.
One pound of pelletized HDPE contains approximately 25,000 nurdles

 

The Threat to Fisheries

The EPA in Ireland in their studies of plastic in the fresh water environment showed how the water slows down as it reaches the lower courses and so many of the plastic nurdles are deposited in the estuaries.

Nurdles in waterways

These are hard enough to pick up from sand; if they were in the mud of the estuary you would need a beak to pick them up.

This is a picture of them in clusters in the water. They look like fish eggs and so fish and birds eat them.
These plastic pellets attract persistent organic pollutants. They are called persistent because, like the pellets they don’t disappear over time. They are mostly endocrine disruptors and affect fish, birds and mammals ability to breed and to lactate.

A study on behalf of The EPA in Ireland  found manufacturing industries involved in the primary production and compounding of polymers, regulated under the IPPC licensing scheme, were found to emit micro-plastics (5 mm or smaller) to sewers. In one instance the EPA found that even though on a site-visit to the Plastic Compounder there was NO evidence of spillages, yet there was micro-plastic from that plant in the waste water treatment plant.

The waste water treatment plants use a system of screens to filter out large particles, however in most instances even their fine screens would not filter out 5mm nurdles, let alone the smaller pieces of plastic. Much of this plastic will go through into the discharge water – straight into the River Ilen and will rapidly travel the 7KM to mouth of the Estuary and into the Marine Environment there.

These deposited volatile organic compounds and particulate, heavy metals, nurdles and their associated persistent organic pollutants will enter the Ilen Estuary and the protected areas of Roaring Water Bay and the islands; on which we depend for :

  • Mussel and Oyster farming
  • Crayfish and Crabbing
  • Food tourism
  • Eco tourism

And on which we depend as a beautiful diverse and restful area to live in and to visit.

Too Much Is At Risk


The environment of West Cork is at risk. Too many jobs are at risk. Too much is already invested in this beautiful part of the world to be wrecked by a poor planning decision that brings no money in to Skibbereen and very few jobs.

We remain amazed that no Environmental Impact Statement has been asked for and that the EPA have not stated a requirement for the facility to be licenced or registered. The private arrangement made with Irish Water for discharge of waste appears to negate the need for the company to be regulated for waste water emissions, yet no mention has been made in the planning documents of the Skibbereen Waste Water Treatment Plant’s ability to adequately process and remove the risk of Toxic Release Emissions nor whether it holds the correct licence for industrial emissions from a petrochemical based industry.

The river Ilen is classed as a grade ‘A’ river. It is amongst the cleanest Waters in Ireland. A very recent study involving collecting water samples from 75 sites around the world during the Volvo Ocean Race showed that The West of Ireland is one of only three sites sampled with no trace of microplastic particles.[vi]

West Cork is special; Let’s keep it that way.

 

 

[i] https://echo.epa.gov/detailed-facility-report?fid=110000426628

[ii] https://echo.epa.gov/detailed-facility-report?fid=110000426628

[iii] https://environmentminnesota.org/news/mne/over-14-million-pounds-toxic-chemicals-dumped-minnesota-waterways

[iv] https://echo.epa.gov/detailed-facility-report?fid=110000426628

[v] http://www.inchem.org/documents/icsc/icsc/eics0775.htm

[vi] https://afloat.ie/sail/events/volvo-ocean-race/item/40385-west-of-ireland-among-only-three-ocean-sites-free-of-microplastic-in-volvo-ocean-race-data#.W4lKBBGWDZQ.facebook

1 2 3 4 12