SICCAR POINT

Our Reply

The initial drawings showed the outflow was 500mm below MLWS. Revised drawings submitted on 6 September (2 days after their supporting letter) show the new outflow at 2.4m below MLWS. It would be impossible to be any deeper as the pipeline is being laid on the sea bed. It's nowhere near 4m below MLWS as they claim.

Unless this location has suddenly acquired one of the largest tidal ranges in the UK, the pipe will not be 8m below high tide. The original drawings showed the outflow was 4m below MHWS, and the newly submitted drawings show it at 5.9m below MHWS.

As for the pipeline not being visible. If the pipeline is laid across the wave-cut sandstone bench as proposed, visitors for hundreds of years into the future will be able to tell EXACTLY where the pipeline is.

Our Reply

360 cubic metres doesn't sound a lot but that is 360,000 (three hundred and sixty thousand) litres, or a tad under 80,000 (eighty thousand) imperial gallons a day. If we extrapolate, that's 2,520,000 litres (557,000 gallons) per week, and almost 11,000,000 litres (2,389,380 gallons) per month. That is not an insignificant amount of water to be dispering into the sea.

A SEPA CAR licence does exist to discharge their waste water into Redheugh Burn, and that is what they do. So what difference does that make?

1. The waste water entering the burn is the end result of a long and effective environmentally friendly cleaning process. We have no issues with this.
2. The waste water is further diluted by the burn itself
3. The outflow (at Meikle Poo Craig), about 1KM east of the proposed outflow, is a natural fresh water outflow and the marine environment in that area is naturally acclimatized
4. The sandstone platform at Meikle Poo Craig, which is the same as that at the proposed pipeline location, shows significant erosion due to this fresh water influx in comparison to the area around it
5. Any potential organics or other compounds in the waste water is further filtered by soils and other strata.
6. Any nutrients in the waste water will be reduced by absorption by soils and plants along the natural course of the burn
7. Only a proportion of the original outflow from their process will reach the sea as the water in the burn is filtered into adjoining soils and is absorbed by plants. With the pipe it will ALL reach the sea.

If they already have an excellent environmentally friendly method of water treatment, then it leads to some other questions:

Why is a pipeline necessary?

1. They already have an excellent environmentally friendly method of water treatment, why does it need to change?
2. There appears to be no economic, environmental, or social benefit to the company by laying this pipeline given their existing treatment methods and licences. In fact, the pipeline represents a significant economic cost to the company.
3. Why go to the expense of laying a pipeline and installing a pumping station when their existing system works so well? We can see no pressing need to change the current arrangements unless plans are afoot to replace/remove parts of the existing waste-water treatment process.
4. Why disfigure an existing landscape that hundreds of professional people (academics, doctors, professors etc) are saying is important to the cultural and scientific heritage of this country, and the world, when their existing systems are excellent and extremely environmentally friendly?.
5. If any, or all, or the current waste water treatment process is removed, what difference will that make to the quality and consistency of the effluent outflow?
6. Information must be made available regarding the current influence of the Redheugh Burn opposed to directing their outflow out to the sea. For instance, measurements from the flow directly after their reed beds, compared with the measurements at the natural outflow at Meikle Poo Craig, would provide some detail about the changes in the water quality caused by further dilution within the burn and absorption by soil, plants, and other strata. This would be an excellent base-point to compare the changes with what will be dumped directly and sea and give clues to the effect on the marine environment.
   
   If changes are proposed in the treatment process (but not detailed in the application), then water-quality measurements should be taken from various points in their treatment process and compared to the burns current natural outflow to assess the changes likely to be seen if any stage of the current processes are removed or changed. This should be commissioned and carried out before any approval is granted and the Council should reject the application until further studies have been concluded.
7. Does the application address all the questions it raises? Is the application being open and frank about the reasons behind needing to build it? We can see no economic or other benefits to the company, and no plausible reason why the pipeline is needed has been put forward. The current system and arrangements, which are environmentally friendly, appear to be perfect for the job.
8. What would happen if ALL the current treatment processes were changed? Is that part of their short, medium, or long term plans?
9. The application cannot be taken at face value alone. The lack of economic or environmental benefits to this pipeline suggests there must be other reasons for requiring this pipeline that are not stated in their application. Until these questions are answered, the application should be rejected.

All of this is highly suggestive that something about the water treatment is going to be changed. There can be no other logical reason for it. Could it be:

Is there something they're not telling us?

1. Does the company wants their outflow away from prying eyes - and easy effluent monitoring - by burying a pipeline offshore so no-one can see or measure what's coming out of it, and then be unable to halt it once it starts?
2. Do they have other plans that are not part of their application? Despite their willingness to correct what they considered "significant inaccuracies" on our web site, they haven't denied our suggestions that they plan to remove their reed-beds. Will this also include the active sludge process and settlement pond? Will there be a significant change to the effluent amount and composition? All this must be part of the Council's, SEPA's, and SNH's consideration of this application, not something to be dealt with at a later stage outside public scrutiny.
3. Are "all the cards on the table" or are Drysdales failing to reveal their real reasons for wanting to lay a pipeline?
4. We suggested on our web site there may be plans to remove the reed beds for further factory expansion and Drydales have not countered or denied this in their supporting comments.
   
   Removing the reed bed may also include the removal of the active sludge process and settlement lagoon although we don't know for sure. These processes are the most critical processes in their treatment for producing clean outflow. If you look at the pictures in their supporting letter of their "active sludge process" you get an idea of what will be flowing down that pipe if these processes are removed.
   
   Are there any plans - proposed, planned, discussed, or decided - for now or the future that will remove any of the current waste water processing features? What changes will there be and how will that impact on the quality or volume of their effluent?
5. We understand Drysdales approached the trust who own the land adjacent to their current facilities with a view to purchasing more land for future factory expansion. Since the land is in Trust it is not so easily sold and the Trust seem to be unwilling to sell. There is no room within their facilities to easily expand in the other direction away from the reed bed. The location of their waste-water processing facility - which does take up a lot of room - would be the perfect location for expansion. Is that their plans? - get rid of all or part of the current (excellent) waste water processing? Since that will result in less clean effluent, are their plans to get a pipe out to sea first (before changes are made to their waste water processing) so no-one can easily see, or easily measure, what will be pumped out? We don't know the answers, but we can't see any other reasons why it would be so because laying a pipeline doesn't seem to be the best solution out of the many that could be available.

Drysdales have not denied that there may be plans to remove parts of their treatment process, and that should concern the Council, SEPA, SNH and the public. Neither have they provided any explanation at all why this pipeline is needed, or what benefit it provides. The pipeline seems to be completely unnecessary unless there are other plans they aren't telling us about that they want to be kept from public scrutiny.

There would appear to be more to this application than meets the eye, and this should be an important part of the planners' consideration. The planners cannot tenably consider the application at face value. There are too many questions to answer and the application should be rejected on that basis.

If the council is minded, or is required, to take the application at face value, then they must reject it. The pipeline is an unecessary development in an Area of Great Landscape Value and brings no additional economic, social, or environmental benefits to anyone.

Is the Democratic Process being bypassed?

If there are plans to make changes to their waste-water treatment process, why can't the company be upfront about them? They haven't denied the suggestions in our website that they might be planning these changes, but were quick to point out where we'd missed out details of their current waste-water treatment process.

If planning approval is provided for the pipeline, and then the water treatment process is significantly changed this would become the sole responsibility of SEPA to decide what steps and environmental controls would need to be introduced. It would not require a planning application. Other stakeholders (the Council, Community Councils,SNH) would be consulted on this, but it wouldn't be subject to the same level of public scrutiny that their planning application is being given. Considering that the planning application almost went through unchallenged this gives us little hope that the public will be adequately represented or informed, and given that they (the public) would NOT be able to object so easily like they can to a planning application that scenario would be wholly unacceptable.

Given SEPA and SNHs lacklustre response to this planning application we do wonder about their abilities to provide robust policing when their decisions are not subject to the same level of public scrutiny the planning application process provides. When they (SEPA) are faced with an applicant citing job losses and other economic imperatives to force their hand mow much protection will they really be able provide?

If this is what is happening or is the plan, then it is underhand. We don't know what Drysdales strategy is or even if they have one, so everyone needs to make up their own minds about it. We just hope that SEPA are not aware that something like this is going on or is giving it their tacit approval as SEPA should be protecting the wider public's interest, not the interests and economic goals of a single company?

This is all amplified by the fact it might be taking place within 150m of Siccar Point. It's hard to see how anyone could not consider Siccar Point to be under threat. If it's not under threat from the existing effluent, then what about when changes are made? How much can be changed before it causes serious health concerns?

What Drysdales Should Have Done

Drysdales haven't helped themselves with this application. They should have been more upfront about what was planned (not just the laying of the pipeline) and provided a lot more information about their immediate plans and potential changes to their treatment process. Maybe they thought it would just sail through planning and wasn't necessary, but that isn't so likely to happen now.

The could have told everyone WHY the pipeline was necessary and WHY their existing arrangements, or the outflow through the burn (changes or no) couldn't be retained. It might be more of a case of bad PR that mailicious intent, but doing what they have is making people question their motives.

The location of the pipeline was always insensitive, but the effluent itself is a big concern too. It would be so easy to tell people about it, what changes they wil be making or are planning, and what these will mean for the quality of effluent, but they haven't done that. It could have saved them a lot of grief.

Our Reply

That is all highly commendable and an excellent thing to do. We've heard from visitors to the site that Drysdales have been friendly, the local farmers say they are good neighbours, and we have no issues with them at all. We just don't like the application.

To stop a planning application you need to object to it and you need to present the facts as you find them. We've always cited any figures we've used so people can check for themselves, and we've only stated opinions based on information we have found (cited again). No one has shown our figures or opinions to be wrong, and in light of evidence to the contrary, we have to assume they have some accuracy.

So, given that Drysdales are aware of the significance of the area - not just Siccar Point as an isolated area - the only question is, "WHY?".

There's no economic benefit to Drysdales' to build a pumping station and pipeline as their existing waste water processing methods are excellent. There's no evironmental benefits to them (in fact there's the opposite), and there's no social benefit to doing this, so what's the reason?

We said on our Web Site

"At the moment, the way their water is treated seems extremely commendable. Their waste water is piped to reed-beds on their site, and the reed-beds filter the water and clean it up. This is an environmentally friendly process and should be applauded. The only thing that's wrong with this method is that the waste water contains a lot of silt and vegetable matter and the reed beds can be expensive to maintain. "

There was another sentence at the end of the paragraph above, but it wasn't refering to the waste directly.

Our Reply

We were being complimentary when we said their current water treatment methods were "extremely commendable" and used reed beds to clean the water. We may not have had all the details, but it's difficult to see where we were "significantly inaccurate".

The inclusion of the words "at the moment" may be significant. Does it means they DO have plans to change the way their waste-water is treated? What are the changes? How does this impact on the effluent? How does it change the planning application? We don't know, but the Council has to ask the questions.

The addition of the cationic polymer is interesting. These are the sort of things that are added to hair and body care products to increase the "feel" and moisturisation - that's what the "smooth and silky" feel is. Unfortunately the toxicity of cationic polymers is well documented although their toxicity is diminished by sorption ("sticking") to dissolved and suspended organic matter and clay (the soil and vegetable matter). We assume they are monitoring this closely, but they don't say.

No one could have a problem with their existing environmentally friendly water treatment methods.

We said on our Web Site

Untreated agricultural waste containing silt and chipped vegetable matter - that may contain herbicides and pesticides - should not be dumped directly into the sea. SEPA (Scottish Environmental Protection Agency) and Scottish Borders Council should be requiring more investigation and assessments before providing even tacit consideration or approval.

Our Reply:

Drysdales appear to be of the opinion that the "auger" stage is where chipped vegetable matter are removed, and they make a point of saying this process will be kept, BUT - and it is a big one - why are they not so specific about saying that their activated sludge process and their reed bed system will continue to be kept?. These are the critical stages in the waste water processing. The first couple of stages just remove some dirt. The auger is like using a colander with much bigger holes. There must be a huge amount of organic matter being passed on to the activated sludge and reed bed processing stages.

We don't know the size of the holes in their auger and what size of matter they stop, but we do know the strainer on the end of the proposed pipe will have 8mm diameter holes. That sounds small, but here's what 8mm looks like:

   

What you see might depend on your screen resolution. 8mm is marginally bigger than the thickness of an average pencil. That's the size of chippings that could potentially flow down the pipe.

There are some photographs in their letter that show the water after it has undergone the "silt removal stage". Some silt may have been removed but the photographs show it is not a 100% effective process. It's unlikely that many people would want to bathe in that water.

As for vegetable chippings, it's difficult to say. The auger shown in one of their photographs will clearly remove larger vegetable trimmings. It will also do an excellent job of turning some of these vegetable trimmings into vegetable chippings that will then flow through the holes in the auger. Their existing CAR licence from SEPA allows the discharge of "vegetable washing and dicing effluent" and the licence wouldn't be so specific if dicing effluent were not part of their outflow. However, it would be fair to say that the specifics of the licence could have been before some of their current waste-water processing facilities were added. As we've said many times, we have no issue with their current water treatment methods.

We can only take their word that no herbicides or pesticides are present, but they don't mention any monitoring or measuring they carry out on their incoming vegetable deliveries, so perhaps that statement should be accepted with caution.

Many freshly picked vegetables are covered in earth when they arrive at the plant. Unless every batch is monitored and measured, how is it possible to be absolutely sure that no pesticides or herbicides have been used on the vegetables, or are not present in the attached soil. When SEPA have concerns regarding Faecal Coliform concentrations (naturally present in soil but enchanced with organic manures or even groundwater flow from other fields or farms) then it is reasonable to assume pesticide and herbicide residues could exist too. Some pesticides have a half life of over 15 years, so they can "hang around" in the environment for a long time.

Without monitoring every batch, or a percentage of batches, of their waste, how can they know? Even if current production methods don't use them, what about previous ones (and the residue they have left) or future cultivation methods that re-introduce them. It would be beneficial for Drysdales to describe what steps they are taking to measure and monitor these levels. It's a fact that any land used extensively for non-organic farming is likely to have pesticide residues present in their soil. Levels may be low, and well below toxicity levels, but to say that none are present is hard to believe.

Their statement that if these chemicals were present they would have a detrimental effect is true, but detrimental is the key word. It doesn't mean they would stop them working. They might just not work so effectively. Since the vegetables and soil are washed by vast quantities of water, any pesticides or herbicides will be diluted further and the effect on their system will be reduced too. Any levels that are left may have a small effect on their processes but that doesn't mean the reaction of the marine environment would be the same. Nobody knows for sure, which is why an assessment must be carried out before the application is considered.

Drysdales should provide a lot more information about their monitoring methods and frequency before giving assurances that there are defiintely no pesticide or herbicide residues in their waste water at any stage of their processing. It would also be important to know at what stage they might be introduced, and how the levels are potentially reduced at each stage of processing and, if any stage of processing is removed, what effect that would have.

With regards to the chemical oxygen demand (COD) we have no idea of the relevance of the statement. It would be helpful if Drysdales could explain what this means to the uneducated and non-expert in waste water treatment processing.

It's also unclear on this point where the comments on our web site were "significantly inaccurate".

We said on our Web Site

The company process over 14,000 tonnes (source: Drysdales web site) every year. Vegetable processing generates 10%-60% of the raw material as solid waste (Source: Report).

That means Drysdales could dump up to 1400 tonnes* per year at 10% wastage (3.8 tonnes per day on average) and up to 8400* tonnes at 60% wastage (23 tonnes per day on average) of raw vegetable matter into the sea. That's not taking into account seasonal variations in output or even the amount of silt and water. Even the smallest figure - 3.8 tonnes of vegetable matter per day - is a huge amount, all floating along on the currents waiting to be washed up or carried into protected marine environments.

The World Bank (Source: Report) recommend that waste water from raw vegtable production should be treated to remove all solid organic material, yet they plan to dump this untreated waste into the sea. This is supposed to be an advanced industrial economy with environmental protections from this sort of behaviour, not a 3rd world backwater.

This Report states "The vegetable processing industry generates significant quantities of wastes in some regions. These wastes usually contain high levels of organic matter, nutrients, moisture, and sometimes salts, and are not suitable for disposal in municipal landfills because of their physical, chemical and biological properties. " yet SEPA thinks it's OK to dump this at sea near protected marine habitats.

Our Reply

It seem like they're not disputing our figures at all, and as such cannot claim any "significant inaccuracy". Our figures were taken from Drysdales' own site and from academic research into raw fruit and vegetable processing. The source of our figures were cited on our web site to enable people to check for themselves.

As non-experts we do not understand what Drysdales' response means or whether that is good or bad.

We'll also note they didnt quote our whole paragraph where we said....

This Report states "The vegetable processing industry generates significant quantities of wastes in some regions. These wastes usually contain high levels of organic matter, nutrients, moisture, and sometimes salts, and are not suitable for disposal in municipal landfills because of their physical, chemical and biological properties. " yet SEPA thinks it's OK to dump this at sea near protected marine habitats.