Copyright © 2012 Save Siccar Point. All rights reserved
FIT FOR PURPOSE?
Scottish Natural Heritage - SNH - state that they are a government body charged with protecting and enhancing the natural environment of Scotland for future generations.
We want to be sure we aren't expecting more of SNH than they are capable of providing because their function and scope determines their ability to help or to be involved in the planning application. To do that, we need to look at their stated corporate goals and responsibilities.
SNH's Corporate Plan summarises their purpose and the way they work.
They state their purpose is to:
They claim that in their work they are:
And its extraordinary response
Jim Kelley is a Ph.D. Geologist and Oceanographer.
Jim was professor of Geology and Oceanography at the University of Washington and at San Francisco State University. At San Francisco State University, he served as Dean of the College of Science and Engineering for 27 years, and for 12 years was the President of the California Academy of Sciences.
When Jim talks, he talks from a position of authority and expertise.
Jim wants to save Siccar Point from this development. He knows how important this site is to modern geology and science, and to the world's heritage. He sent an email to Scottish Natural Heritage expressing dismay at their lack of response to this planning application.
He stated that, while the proposed pipeline may lie 150m outside the SSSI of Siccar Point, it will be highly visible from Siccar Point itself. He also recognized that this shoreline was an important - if not critical - factor in helping Hutton develop his theories, and as such should be afforded the same protections and respect given to Siccar Point just a few metres west.
His email explained the importance of Siccar Point and why it is widely revered throughout the world by scientists and geologists alike, and what the site meant to him.
The reply to his email by SNH was extraordinary in the way it dismissed his concerns, the inaccuracies it contained, the tone which suggested the closed mindset of someone who has already made up their mind, and the condescending way it assured him that Siccar Point "is not at risk".
The next page reproduces the entire email. We've added our own comments after each paragraph.
What it really thinks
"There is nothing in the literature to suggest any significant geological interest or value in that location [the platform ]" says SNH.
SNH also seems to think that Siccar Point just isn't pretty enough for them to try to save it from the development.
It has come to our attention that there may be some disconnect between SNHs stated goals and the ability of their staff to extend their comments outside areas
of SSSI. This was suggested by a post on the
Scottish Geodiversity Forum that provided an
update on their position regarding the planning application. It would be fair to say that they are probably much more aware of the inner workings of SNH
than we are so we have adjusted our response on that basis.
From: Anne Brown [mailto:Anne.Brown@snh.gov.uk]
Sent: Friday, August 31, 2012 8:23 AM
To: James C Kelley; email@example.com; firstname.lastname@example.org
Subject: RE: 12/00929/FUL Objection Comment
Dear Mr Kelly
thanks for your e-mail expressing your concerns about Siccar Point SSSI.
The route of this pipeline proposal does not go through the Siccar Point SSSI. It runs some 150m to the east of the site over a stretch of intertidal which does not support any remnant of the unconformity feature. All of the horizontal Old Red Sandstone in that area is eroded away, leaving only the exposed sub-vertical Silurian greywacke. There is nothing in the literature to suggest that there is any significant geological interest or value in that location.
We are obviously fully aware of the importance of this feature and this site. Our obligation to the site's interest extends only to the designated area itself and anything external that could potentially or actually have an impact on it. The current proposal does not.
The SSSI encompasses both the area of the JNNC Geological Conservation Review and the 'crucial area' which includes the specific formation on the north west side of the promontory, described in such excitement by Hutton and Playfair. The SNH Earth Science Site Management Brief gave the site a 'context area' and it was this that was used as the SSSI boundary, ie. it was not thought necessary to provide any wider context to the site. That context was set specifically in relation to the geological setting. As far as I am aware, it was not intended to include visual aspects.
It is difficult therefore for us to consider any visual impacts that the pipeline might present, specifically in relation to, say, the 'setting' of the feature. With regard to general visual impact, we normally only comment on landscape impacts where they affect a National Scenic Area, as opposed to the wider countryside. In our response to the planning authority (who are the decision makers), we have advised that if they are minded to approve the proposal, that a working method statement is requested to minimise damage to coastal and intertidal habitats. This would include visual aspects. It is our understanding that the pipeline in the intertidal rock will be sunk to 500mm, backfilled with concrete and be flush with the rock surface. It is probable that coverage by normal tidal rock movement and colonisation by marine flora and fauna, would very quickly soften the impact of the pipeline, if not obscure it completely over time.
I hope this gives you some reassurance that this important and iconic feature is not at risk. We shall in any case be keeping a close eye on developments and are in discussion with local authority staff.
Please let me know if you require any further information.
SNH - Southern Scotland
Market Street, Galashiels, Scottish Borders TD1 3AF
Tel 01896 756652 Fax 01896 750427
Since her response has been copied to Scottish Borders Council with the applicaton number, and to SEPA, it is probable that her reply will become an official part of the application's consultation paperwork (it now has become part of the record). We cannot emphasize enough how damaging this is to objectors.
SNH is seen as a "significant authority" and their words and actions have a significant impact on any decision made. It would probably be safe to say that if SNH objected then the application would fail. When SNH's opinions to the planning department contain misleading, incorrect, and mis-informed opinions, it is critical that these are responded to and corrected.
If you disagree with the points made in SNH's email, or have any comments to make in response, please let SNH, SEPA, and Scottish Borders Council know. If you do make any comments, please keep them polite and factual.
Update: The email above HAS become part of the official correspondence record for this application. If you wish to comment on this email in particular, and have your email considered as part of the official record, here's how:
CC SNH and SEPA into your email:
If you want to CC anyone else into your email, you might want to consider:
If you wish to correct any inaccuracies in these pages, or add to the comments made, please contact us and we will do our best to incorporate then.