Climate Emergency – What Climate Emergency?
The Peel Ports / Valaris Drill Ships Scandal
In June 2019 North Ayrshire Council declared a Climate Emergency. Laudable, I am sure, but what are the Council actually doing to implement remedial actions? At the Full Council Meeting of Wednesday 31 March 2021 I watched the Leader of the Council give a comprehensive listing of the actions which have been taken, and are planned, by the Council in its drive to combat Climate Change. Many high-capital spend and positive decisions such as solar energy schemes, electricity from waste scheme at Irvine, housing insulation improvements, and public consultation actions are some things which I particularly noted and all of which are appreciated.
These actions signal to me a genuine attempt by the Council to meet the stated aims outlined in its declaration of a Climate Emergency.
However there is a glaring anomaly in North Ayrshire which makes the Local Council, and also, by implication, the Scottish Government look absurd where Climate issues are concerned.
Two gigantic, currently redundant, Oil Drilling Ships which belong to Valaris plc are berthed at Peel Ports Jetty at Hunterston. Valaris is in Chapter 11 bankruptcy in the USA. Valaris have stated that the Drill ships may not be required for up to two years.
The Drill Ships came to Hunterston for long term storage and were inadequately moored at the Peel Ports Jetty. The mooring and manning arrangements were challenged by Fairlie Community Council. The Community Council also asked Peel Ports to give an assurance that shore power would be made available to prevent noise and fumes being produced for the on-board electrical requirements and also to reduce Climate Impact. Peel Ports responded that arrangements were being made to provide shore power. None has been provided to date, to my knowledge.
Just under two weeks after Fairlie Community Council had raised its concerns in writing, both ships broke free from the jetty and were in imminent danger of being grounded on the Cumbrae shore and causing a major environmental disaster in the Clyde Estuary.
During the week following the initial breakaway from the jetty, six large tugs were required to run at close to full power to keep DS8 on the berth. In addition two lifeboats and a pilot boat were on permanent standby at DS4, all burning large quantities of diesel fuel.
DS4 and DS8 are now again berthed at the jetty. The long-term arrangements appear to be that these ships will run their diesel generators to provide electrical power.
Much more importantly, DS4 and DS8 are both running a number of their main engines to provide power to the appropriate thrusters on the ships in order to prevent them from being blown off the jetty once more!
This is a completely unacceptable long term solution in terms of the effects on residents from constant noise, light pollution, exposure to oxides of nitrogen fumes, sulphur dioxide fumes and particulates. These ships are burning marine diesel fuel. The statutory limits applied to such a marine activity fall well short of those imposed on land based vehicles such as lorries, buses and cars. This is because the limits are based on the expectation that the ships are operating out at sea and well away from exposed populations.
For a Country and a Local Council who have declared Climate Emergencies the situation is frankly, farcical.
The First Minister stated in the recent election debate that 97.4% of Scotland’s electricity demand had been met by renewables in 2020. Sounds great, but look what is going on with these Valaris Oil Drilling Ships in Ayrshire!
Each ship has six diesel engines. Each engine has a rated output of 8,000kw. Marine diesel engines have a thermodynamic efficiency of 40 to 50% so if all engines were being deployed the input energy required to power both ships would be 192,000kw. In the more likely situation of only the three outboard thrusters on each ship being deployed to keep the vessel in position at the jetty, this still equates to 96,000kw at full power. Taking a conservative estimate of the engines being driven at half rated power we are still looking at 48,000kw of energy being required to be delivered from the burning of the diesel fuel to keep these vessels safely on the jetty. This is taking place 24 hours a day, seven days a week any time that there is any significant wind, i.e. nearly all the time. Even in flat calm conditions the on-board diesel generation sets are being used to provide electrical power.
An average house has a central heating system of around 20kw. Even if we assume the heating in the house is left on 24 hours a day we find the Valaris Oil Drilling Ships efforts to stay on the jetty equate to the heating energy required for 2,400 homes!
The emissions of course are much worse from the ships due to the fact that they are burning diesel fuel and not the much cleaner, natural gas!
How can this situation be tolerated by North Ayrshire Council in terms of their declared Climate Emergency?
How can North Ayrshire Council possibly defend this situation? To effectively allow a medium sized power station, powered by diesel fuel, to be constructed at the Hunterston site which they are promoting along with Peel Ports as a potential ‘Green Energy Parc’!
This situation should really form the basis of a presentation at the forthcoming COP26 meeting in Glasgow.
It could illustrate perfectly the divide that exists between what organisations say they will do in hyped terms of Climate Change and what they do in reality.
The running of diesel generators and main engines on the vessels is also causing an unnecessary noise nuisance for many local residents. Constant noise 24 hours per day has been taking place since the vessels arrived on 27 December 2020. Local Council personnel have measured the total noise level and stated that it is below the allowable statutory value. My personal view is that for some proportion of the population, this is not adequate to provide protection against disturbance. Some people are being affected and have reported a constant low frequency noise. I would suggest that the low frequency sound is being generated by a ‘Beat Frequency’ effect caused by the interaction between the exhaust sound from two or more main engine exhaust stacks. Two similar exhaust frequencies, but which are only slightly different in frequency, will be amplified and will generate sound at a frequency which is equal to the difference in frequency of the two sources. This could readily explain the reported low frequency sound complaints. The solution is obviously to provide shore power and fix the problem at source.
Regarding underwater noise it is also totally unacceptable that these ships should be allowed to run their thrusters day and night. The adjacent waters are home to many cetaceans, all of which rely on sound for navigation and detection of food sources.
If these vessels cannot be safely berthed at Hunterston Jetty without running their main engines, then it is clear to me that there is no option other than to request Peel Ports to move these vessels to a proper secure location where there is no need for constant main engine power to deliver safe berthing.
North Ayrshire Council must assert their authority over the location and activities of these vessels.
Locals have been calling for a proper investigation of the February incident and have met with an extremely poor response from all those who should be taking this event seriously.
A state of confusion over the status of the ships and who should be responsible for conducting a proper independent incident enquiry exists.
The Marine Accident Investigation Branch has stated that they do not intend to investigate the major incident of 2nd February when the vessels were blown off the jetty. They state that at the time the Valaris DS4 and DS8 were not ‘ships’, due to their de-manned state and Flag State paperwork. In that case these ‘things’ are ‘Deposited Structures’ and fall under the jurisdiction of land based authorities such as the Health and Safety Executive and the Local Council.
As a result of the misleading CGI video produced by the Decontamination Operator, CessCon Decom, who was at the time located on the Peel Ports site, and whose video showed Oil Rigs moored at the Hunterston Jetty, North Ayrshire Council informed local residents that this could not take place since no planning permission existed for such an activity.
Given that the marine Accident Investigation Branch have confirmed that the Valaris assets are not ‘ships’ it would appear to me that Peel Ports do not have planning permission to store these assets at the Hunterston Jetty, since they must be similar in definition to the Oil Rigs discussed above.
In terms of the lease for the Hunterston Jetty pertaining to the sea-bed below MLWS and which was granted to ClydePort by the Crown Commissioners
Clause 4.4 states:
‘not to use the subjects of let other than as or for a terminal for the handling of iron ore and coal and other commodities comparable with such use and for all operations normally associated with the proper and usual enjoyment of such use, including without prejudice to the foregoing generality for anything reasonably necessary to deal with an accident, malfunction or emergency.’
This, I believe, was written to align with the Secretary of State Planning Approval of the Hunterston Terminal which envisioned a Bulk Handling Facility and which had been the subject of a full Public Enquiry and Parliamentary Debate at Westminster. One might assume that the current Crown Commissioners Scotland would take cognisance of this in any request to amend the conditions of lease.
In my opinion it would appear that Peel Ports do not have planning permission for the current activity, and Peel Ports are not in compliance with the terms of the lease for the sea-bed on which the Hunterston Jetty is constructed.
If this is indeed the correct interpretation then it would appear to me that the Local Council would be in a strong position to instruct Peel Ports to resolve this issue immediately and stop this ridiculous state of affairs from continuing, with damage to the environment, damage to the health of local residents, damage to the well-being of sea creatures, and crucially, damage to the Local Council’s reputation in terms of its stance on its declared Climate Emergency.