SICCAR POINT

She spelled his name incorrectly.

Jim's Reply

Jim's reply can probably answer it more eloquently that we can...

Thank you for your note, but the location of the proposed sewage outfall will still be extremely intrusive even if it does not run right through Hutton's Unconformity.

To the east of Siccar Point , on the other side of the outfall, which will be quite visible from Siccar Point itself, is a small wave-cut bench. Behind it is a much larger wave-cut bench which runs south from the top of the cliff. Hutton recognized that these benches were both produced by wave action, the origin of the upper one by analogy with that of the lower one. Playfair discusses this situation and recognized that Siccar Point itself was an erosional remnant. At low tide this is very visible and makes a wonderful field exposition of the kind of thinking that Hutton undertook when he moved to Cockburnspath. So there is much more to the story than the Point itself.

I suggest they move the sewage outfall to the nearby Nuclear Power plant site where things have already been messed up.

We Say

Given the outrage expressed by other geologists and scientists, and the number of objections received, it's clear they don't agree with SNHs assessment. Are SNH just expressing an opinion or it is a fact that there is no "significant geological interest or value in that location"?

If we work on the basis that local SNH officers are not allowed (despite their stated corporate goals) to comment on areas outside SSSI or "National Scenic Areas", then surely it would have been more helpful just to say that they could only restrict their comments to the SSSI and therefore were unable to comment on the location of the pipeline? As it is they ARE commenting on it, and that cannot be helpful to them or the planners. Worse of all they are APPROVING of the plan, not taking a more neutral (or preferably negative) stance.

The location of the pipeline is not through "sub-vertical Silurian greywacke" as stated by SNH, it is through a gently sloping sandstone - thanks to Angus Miller of the Scottish Geodiversity Forum for these details. We're just members of the public, but SNH are the experts. Surely they should know the correct geology?

We say:

All the geologists from around the world sending objections to this plan should be a BIG CLUE that SNH's opinion regarding the importance may not be the correct one. SNH's corporate plans says they will "listen to the needs of others and try to see the world from different points of view". They need to do that.

This is where the disconnect between official policy and staff powers cause problems. If local staff are unable to comment on anything outside the SSSI unless it has an "impact" on it then they shouldn't comment on it at all. They say they can't comment, and then they do. If they are unable to state an opinion then surely that's what they should say and make it clear that their comments are ONLY relevant to the SSSI boundaries not the surrounding area because policy does not allow them. If they have no opinion on anything else - positive or negative - then that should be clear. It should not say "we have no objection" (or worse in this case - "we approve") it should say "we have no opinion".

The local planners rely upon the expertise on SNH when making decisions. SNH are simply confusing matters by doing what they have. Perhaps SNH could clarify their position. Something along the lines of:

"We are only able to comment directly on the SSSI of Siccar Point. Since the proposed pipeline route is outside the SSSI we are unable to make a comment either for or against this proposal. We delegate all decisions regarding this to the local planning committee".

That would have been nice and easy, no controversy, the truth (I hope), and no pressure on the planners to abide by SNH's decision. It would have made the planning process much more democratic. All SNH have done by their actions is to muddy the waters and create confusion because they have provided a reply to the planning committee that is "on record" saying they approve of the plan yet privately say they are not able (authorized?) to comment and therefore the reality is that they have no "comment". Their actions make no sense and that is what concerns us.

Perhaps SNH would be kind enough to clarify their statement?

SNHs stated policies do not restrict them to commenting only on SSSIs or National Scenic Areas as we'll show below.

Their corporate plan states that one of their functions is "to care for local nature and landscapes of national and international significance". SNH must step up to the mark they set for themselves and do their job.

We cannot agree with the statement that the works will have "no impact" on the SSSI of Siccar Point. Will the trenching process, pipeline, and concrete backfill damage ("impact on") Siccar Point directly? Of course not. But what the plans will do is:

1. Cause an unsighly and highly visible scar across the landscape immediately adjacent to Siccar Point that will be seen by everyone visiting that location forever. It has a VISUAL impact on the enjoyment of future visitors.
2. The effluent, and the potential biological changes to its compostion - as stated elsewhere on this website - may directly affect Siccar Point. Modelling may be required, but if there is a potential danger then this should concern SNH because it will impact on it directly. That alone should cause a pause for thought and result in a request for further information, not an off-the-cuff "we approve".
3. The SSSI boundaries may be the extent of their local staff's direct concern, but SNH should not be ignoring the scientific importance of the rest of the landscape and it's connection to, and relationship with, Siccar Point. This is a location of significant world-wide importance and as such should be afforded the respect and protections it deserves, not dismissed because of some artifical boundary or restrictions on the ability of local staff not to carry out the stated purpose of the corporation they work for.
4. Not protecting this landscape will show Scotland in a bad light. The site deserves world-heritage status - it is THAT important. Petty bureaucracy and man-made artificial boundaries should not stand in the way of protecting this geological jewel and the landscape in which it stands. SNH must do more to protect that heritage.

We Say

Don't SNH say their job is to help protect the natural heritage wherever that may be?

Surely the boundary of the SSSI is, to a large extent, arbitrary? We agree that boundary has to have an edge or else it wouldn't be boundary, and while we're sure a lot of thought went into the decision of where to place it, it's still an artificial boundary - there's no actual line in the sand so to speak except the metaphorical one.

Does Siccar Point need to be put at risk because the chosen artificial boundary was only 150m too narrow at some random point? It's not as if we're talking about miles. 150m in an urban environment might be a couple of streets away, but in this massive and open landscape 150m is the equivalent to being on your doorstep. What if the proposed pipeline was 1m, or 1cm, outside this artificial boundary, would the same refusal to protect still be evident?

And what if the proposed line was 1m inside the boundary? Would the power to protect come crashing down on such a untenable suggestion or proposal? 1m inside, 1m outside, 150m outside are small numbers in the context of this area, and it is the context that we're talking about. This is not a property dispute about who owns what meterage, this is a scientifically important (nay, critical) location, and relying upon a measly 150m's as the excuse not to protect it could be viewed as the worse kind of petty, dogmatic, and bureaucratic nonsense.

We can understand the "context area" means the designated boundaries of the SSSI, but SNH can't claim it wasn't intended to include a "wider context" or "visual impacts" and then go on to say "as far as [they are] aware". If they aren't aware then they shouldn't be saying it wasn't supposed to include it. As the following paragraphs show, SNHs own guidelines suggest that they must consider the wider context.

The whole of the Berwickshire coastal region has been an Area of Great Landscape Value (AGLV) - p15 and p17 since the 1960's and includes the areas CO44, CO45, CO46 and CO47 as designated in that report. This is supported by SNHs newer landscape designation of Special Landscape Areas - that are supposed to compliment the National Scenic Areas - and include the same locations as the AGLV.

NPPG 18 - Planning and the Historic Environment, part of the Scottish Executive's planning guidance on local landscape designations, defines the historic environment as consisting of "the tangible built heritage - historic buildings and townscapes, parks and gardens, designed landscapes, ancient monuments, archaeological sites and landscapes. It also includes the wider setting of these features and areas as well as places important for their historic associations". Paragraph 1 of the same section suggests "locally significant buildings, townscape, landscape and other areas beyond the confines of formally designated areas are also an important local resource and often merit protection on that basis".

PAN (Planning Advice Note) 60 - Planning for the Natural Heritage, from the Scottish Executive states, that Areas of Great Landscape Value (of which Siccar Point is a part) are "of most value where they form part of a wider landscape and habitat framework and contribute to the realisation of Natural Heritage Strategy".

The European Landscape Convention describes landscape protection as "[the] actions to conserve and maintain the significant or characteristic features of a landscape, justified by its heritage value derived from its natural configuration...", and it's clear that the sandstone shelf is not only part of the "context area" but played and important part in Hutton's research and as such contributes massively to the world's scientific and cultural heritage.

SNH's own Guidance on Local Landscape Designations cover all the points in the 4 paragraphs above, and also state: "Valuing landscapes - Views on what is important in a particular local landscape will vary and reflect personal responses as well as more objective assessments. Some landscapes are recognised to be of national importance but people will also value their local landscapes as the places where they live and work. All these views should be respected and should be used to inform the planning and management of local landscapes."

It seems clear to us that SNH are reading from a completely different crib than we are. All these policies, guidelines, and directions are part of SNHs own guidelines on how local councils should carry out their landscape assessments. Is it a case of "do what I say, not what I do" by SNH? Are they ignoring their own guidelines for reasons that are not fathomable to anyone else? Does the economic requirements of a single company outweigh the opinions of eminent scientists and geologist throughout the world - and their own guidelines? Is SNH being intentionally misleading in their response when they write that the "wider context" cannot be considered when all the evidence and their guidelines say that it must?

Once again, we're stymied by the stated principles of SNH and the ability of their local officers to implement these policies. SNH MUST get involved with the larger landscape issues - as all the planning policies and guidelines suggest they must - or else they need to excuse themselves from the process. Their current non-committal, no-comment-but-we-will, confusing position is unacceptable from an organisation designed to protect Scotland's Heritage.

SNH need to clarify their position. Is it:

1. Do they approve the plan as the protectors of Scotland Natural Heritage?
, or it is
2. Do they approve the plan because it is outwith the SSSI, and they cannot comment on the pipeline route?
, or is it
3. Do they have no objections to the plan (rather than approve of it) because it is outwith the SSSI, so cannot comment on the pipeline route and delegate that to the Council
, or it it
4. Since the site is outwith the SSSI, are they unable to comment on this proposal and delegate the decsion to the local council planners?

SNH must clarify their position and the meaning of their statements. Stating that they "approve" rather than "don't object" are two completely different scenario's and reflect completely different positions. Approving because they don't object because they cannot comment is different too. We trust they will clarify their position because we cannot fathom how they can approve of it. We can understand "not objecting" and we can understand "not being able to comment", but actually APPROVING of this plan? .

The proposed pipeline is only 150m outside the SSSI. As my grandfather would say (please forgive him) "it's just spitting distance away with a good wind behind you". It's so close that anything within that vicinity is impacting on the SSSI by the very nature of its closeness, and as the potential "impact" on Siccar point as described in the section above is real, surely that should make them consider their response much more deeply?

We Say

Why is it difficult to consider the visual impact? This is largely what this is about (if we put the effluent discharge to one side). To geologists this trench and concrete infill - the VISUAL IMPACT - is tantamount to sacrilege. These people are not religious fanatics. They are grounded, intelligent, scientists who understand the critical importance of this globally significant site and its environs. It's the VISUAL IMPACT of this concrete filled trench that fills them with horror. They know it will impact badly on Scotland's global reputation if this landscape is scarred and not protected by the agenices set-up to do so, and it will spoil the site for every visitor in the future. How can SNH turn round and say it's difficult to consider?

As for saying they normally only comment on landscape impact that affect "National Scenic Areas", are we bumping against SNHs stated protections and the restricted ability of local officers to implement these goals?

Geologists and scientists from around the world are horrified by the plan being proposed. They all understand that it's outside the SSSI boundaries, but they also fully understand the importance of this whole landscape. SNH can't cop-out of taking responsibility and we cannot understand their approval of the plan. The SSSI of Siccar Point is part of a larger "Area of Great Landscape Value" and as such is afforded - and deserves - more protections and consideration, and absolute clarity from SNH.

Trying to shift the focus to the local authority as the "decision makers" is disingenuous. If SNH opposed the plan, it is certain the council would reject it too. In that context SNH has as much power as the council to reject and SNH must clarify their position.

SNH are aware of the value of their contribution and their ability to cause a plan to be accepted or rejected as shown here (p38 s5.8.1). They specifically mention Scottish Borders Council as being one of the councils that always consult them on applicatons within Areas of Great Landscape Value and state: "many councils have a high opinion of the advice that SNH provides and they tend to rely upon SNH to guide decisions where landscape is an important consideration. One council officer felt they were constrained by SNH in that if SNH offered no objection to an application on landscape grounds then the council could not raise an objection itself".

The understanding that the pipeline will be sunk to 500mm and backfilled with concrete is almost correct (it's actually 600mm), but their "understanding" that it would be "flush with the rock surface" is completely at odds with the evidence.

The trench is being cut at almost a 90 degree angle to the sedimentary layers in the rock. The surface is irregular and the different coloured banding will be impossible to match. The concrete filled trench will look like a concrete filled trench no matter how well it is constructed or how careful the developers are.

Worryingly, there is nowhere in the plans that says the concrete will be smoothed with the rocks. It does say the trench will be filled with concrete, but that's all it says. Are mis-informed opinions being presented as facts when there is no evidence to support these statements or opinions? The council must decide on the planning application, not misleading whispers, rumours, or PR that takes place behind closed doors and that is adjusted to suit the question. We believe there is much more to this application than just laying a pipeline and that MUST be considered. Everything relevant must be "put on the table" so everyone can see the truth behind the reasons for the application for themselves.

To suggest it is probable that "coverage by normal tidal movements and colonisation by marine flora and fauna would quickly soften the impact of the pipeline, if not obscure it completely over time" isn't supported by what exists at the platform just now..

The platform remains largely as it has been for thousands of years - it may have eroded some more since then. There are some "marine flora and fauna" on the site (it's slippy with seaweed) but they haven't managed to obscure or hide the different coloured layers in all that time. We can't see how it will hide or obscure a concrete trench that will be a completely different colour from the rest of the platform.

Visitors will also know that there is no permanent rubble field along the route of the proposed pipeline except at the high-tide mark. Considering the amount of loose rubble at the high tide mark, the platform itself is remarkably bereft of it. Random scatterings of rubble do exist, but it tends to be sparse and temporary, eventually being washed to the high-tide mark or over the edge of the platform. There's no evidence to suggest the trench will end up being obscured by this sparse and temporary rubble.

Again, SNH appears to be substituting their own opinions for facts that are not in evidence. This is unacceptable when these unsupported opinions become part of the application's official record.

SNH must clarifiy their position - do they approve, not object, or object? Is their position based solely on the SSSI or does it include the wider landscape? Are they able to take a position on the location of the pipeline or not? If they cannot take a position on the pipeline location will they delegate that responsibility to the planners or committee and state that they are?.

We Say

It gives us no reassurance at all. We don't understand why the policies and concerns of SNH are not being applied to this application.

Given the massive international outcry against this development, if a local officer is unable to comment on features outside the SSSI then the decision must be passed further up the corporate ladder to someone who can. This isn't just about whether the trench will damage Siccar Point directly. There are wider and far-reaching concerns here, and they must be addressed.

SNH also need to be clear on whether they actually "approve" of the application or "don't object". Approving of the application does not portray them in a good light to the international community. "Not Objecting" would be understandable, but ultimately unacceptable given their stated corporate function and responsibilities.

A fair assessment of this application, the long-term implications for Siccar Point and its environs, and a more sensitive consideration must be undertaken by SNH. To only consider if digging a trench will in ,and of itself destroy/damage Siccar Point, is not enough. This planning application doesn't just have immediate repercussions in respect to digging a trench. There are wider issues about what it will mean for the site, for future visitors, and the reputation of Scotland in the eyes of the world. The effluent, and potential changes to existing water treatment processes must also be considered as these could affect Siccar Point directly.

This site is too important to be confined by internal restrictions on the scope that a local officer can comment on. The full might, power, and protection of SNH must be brought to bare on this application and SNH's decision.

SNH cannot ignore geologists and scientists from around the world who are complaining. Objections are being received from doctors, academic, professors, and other respected and notable people. They are professionals who aren't prone to hysteria or knee-jerk reactions, and come with a wealth of experience, qualifications, knowledge and expertise that gives their opinions more weight and authority than a single officer within SNH could ever match. They truly understand the importance of Siccar Point and the need to protect not just it but it's immediate surroundings too. SNH, as a protector of HERITAGE, cannot reasonably dismiss or ignore this huge international concern.

If SNH is genuinely representative of a democratic process and charged with protecting Scotlands Natural Heritage, they must cast off the fug and inactivity they have surrounded themselves with, and protect this landscape. This location deserves their full and undivided attention with careful analysis of the long term impact to this wonderful place by this heinous plan.