Please write to Ms Davidson -WAG, Rhodri Morgan, Edwina Hart and HRH The Prince Of Wales - Crown Estates.
Use the arguments outlined in the comments of this Post - they have been submitted by the Gower Society and Gower SOS. Also add your comments here. . . .
4 comments:
Dear Ms Davidson
Application by Llanelli Sand dredging in Area 373
I am writing in response to the Government View and the report by the Inspector for the above application.
Mr Nield, was the Inspector who advised the Welsh Assembly Government on the Nobel Banks dredging application. He made assumptions based on evidence provided and paid for by the dredging company that the sand loss from Port Eynon was connected to the dunes and not to the Helwick sand bank. The evidence presented at the time I believe, was uncontested. The Gower SOS and other interested parties did not make representations at the Nobel inquiry as we believed that dredging further out to sea was preferable to the inshore dredging off Port Eynon point and if the Nobel licence was granted then there was no need to grant the Helwick licence.
We did not expect the Inspector to prejudge the Helwick Bank Inquiry. The Inspector commented on and accepted the dredging company’s interpretation of the data for the Helwick bank for the Nobel Inquiry, by prejudging the Helwick Bank before its inquiry, Clive Nield could not be persuaded that this argument might be seriously flawed without looking wrong footed in his summation of the Helwick Public Inquiry.
It concerns me that the Inspector acknowledges that there is little evidence to show what relationship there is between the Helwick sand bank and the beach at Port Eynon (3.3.1). This lack of evidence, as he points out, is due to a lack of research. Because of this the inspector recognises the difficulty in anticipating the affects of increased rates of dredging, he is not
confident that it would not effect sand levels on the beach, and therefore does not recommend an increase in the annual rate of dredging. The Inspector uses the lack of evidence and, the supposition by the dredging company with regard to the sand dunes, as a basis for allowing dredging to continue. (3.3.1) This appears to be a compromise of the interpretation of the phrase “lack of evidence”
A lack of evidence due to a lack of research is a decision based on ignorance.
The research into the interaction of sand between Port Eynon Horton and the Helwick Bank and
the role of the bank in coastal defence must be carried out by a company not associated with the dredging companies and paid for by the Welsh Assembly Government before dredging is allowed.
The Welsh Assembly Government have had several years to conduct their own research into the relationship between the bank and the beach. They have at their disposal a major University on their doorstep to involve in developing a research project. In their failure to initiate the independent research necessary they are guilty of a failure to protect one of their biggest natural asset.
The dredging company is part of a multi million pound conglomerate; they employed the best lawyer in the country at the Public Inquiry. If the monitoring conditions are not completely watertight the dredging company will yet again run rings around the CCW, Swansea Council and the Welsh Assembly and circumvent any unfavourable monitoring results. The Inspector has dismissed the advice of DEFRA in the monitoring conditions, the WAG would be wise not to take the Inspector’s advice on face value, but listen to the environmental specialists at their disposal.
The people of South Wales and their Government and Councils also need to decide where they want their sand on the beaches, or used in the construction of innumerable shopping centres and second home apartments.
Yours Sincerely
Susan Kent
Gower SOS Co-ordinator
Cc Edwina Hart
Jane Davidson AM
Wales Assembly Government
Cardiff Bay
Cardiff
CF99 1NA
12 September 2007
Dear Minister,
Aggregate Dredging from Helwick Bank, Gower. Area 373
We were disappointed to read the Inspector’s report, following last year’s Public Inquiry into dredging from the Helwick Bank and to learn that WAG had approved continued dredging from so close to the Gower shore, despite its policy to move dredging further west and further off shore.
During the time of the Inquiry and during WAG’s consideration of its position, we felt it inappropriate to comment. Nonetheless, we had and continue to have two major reservations about the inquiry.
The first is that the inspector appointed had also inspected the Llanelli Sand Dredging Limited’s earlier application to dredge from the Nobel Banks. That application was largely unopposed, but LSDL (a minor subsidiary of Boskalis Westminster) took the opportunity to introduce an argument, irrelevant to the Nobel Bank, that loss of sand from Port Eynon and Horton beaches was due to dune stabilisation procedures adopted by the Local Authority. With no opposing view offered and no sustained cross-examination, the inspector accepted that version of events and incorporated it into his report on the Nobel Banks.
At the Helwick inquiry, LSDL ignored all other possibilities (e.g. that the dredging from Helwick might be contributing to the loss of beach sand) and had made no efforts whatsoever to investigate any link between dredging and beach depletion. The inspector, having already publicly supported LSDL’s coincidental link between beach and dune levels in the previous inquiry, would have found it very difficult to do a U-turn in this inquiry.
Our second concern is that the inspector allowed the inquiry to continue despite the fact that the Countryside Council for Wales’ barrister was unable to be present for most of the inquiry. While we understand his concern that a delay would have inconvenienced others taking part in the inquiry, the result of that decision was that there was no effective cross-examination of LSDL’s case. The City and County of Swansea, despite its publicly perceived position, mounted, at best, a half-hearted opposition; and the Coalition’s spokesman was new to such inquiries and had taken on the case at late notice. The very experienced barrister for LSDL (voted shortly afterwards as “silk of the year”), not surprisingly, made the most of these shortcomings. While this might make for good court-room drama, it did not further the search for a balanced outcome.
The Coalition submitted comments on mitigating conditions, but did not take part in any discussion of conditions. Representing a large body of opinion most closely connected with the dredging area, we think we should be allowed to take part in these ongoing discussions and should receive copies of all monitoring studies. Two conditions that we consider essential are: 1. that independent research should be carried out to ascertain the physical links between Helwick Bank and local beaches – this is much more than simply monitoring beach levels, which can only tell us changes in beach levels but not what causes the changes. 2. that if a link between Helwick and the beaches is found which shows the dredging to be contributing to beach deprivation, then LSDL should be required to carry out, at their expense, a programme of beach replenishment.
Yours sincerely,
Malcolm Ridge
Chairman
NOTE:
The Gower Society is one of the oldest and largest local amenity societies in the country, its aims including, inter alia, to encourage an appreciation and love of Gower and to protect its natural environment and landscape beauty.
The Coalition includes The Gower Society, The National Trust, The Campaign for the Preservation of Rural Wales, The Civic Trust for Wales, Save Our Sands, all Gower Community Councils, (and Town Councils as far west as Tenby), local businesses, the Penrice Estate, landowners and individuals.
cc
Martin Caton MP
Edwina Hart AM
Alun Cairns AM
HRH The Prince of Wales
Clarence House
London
SW1A 1BA
12 September 2007
Your Royal Highness,
Sand dredging off Helwick Bank, Gower, South Wales
For more than a decade, The Gower Society has been concerned that sand dredging from Helwick Bank (less than one mile from the first designated Area of Outstanding Natural Beauty in the United Kingdom) might be contributing to the important loss of sand from some of the local beaches, particularly at Port Eynon and Horton.
A public inquiry was held last year, when The Gower Society led a coalition which included The National Trust, Campaign for the Preservation of Rural Wales, The Civic Trust for Wales, Save Our Sands, all Gower Community Councils, local businesses, landowners and individuals, in opposing the application. The Countryside Council for Wales, the government’s own advisory body on environmental matters, opposed any further dredging because of potential harm to the South Gower marine Special Area of Conservation (in which Helwick lies) and because of the possible reduction in coastal protection if the Bank were to be lowered.
The inquiry was frustrating from the point of view of the ‘opposition’, because of the absence, through illness, of CCW’s barrister for most of the inquiry and of our own preferred advocate because of a clash of inquiry dates. We were disappointed at the inspector’s decision in favour of the dredging company and the Wales Assembly Government’s ‘Government View’ to allow continued dredging from Helwick.
The final decision as to whether to grant a licence or not, now rests with the Crown Estates. We appreciate that you could not take any part in the earlier stages of the process because they were political and quasi-judicial. This stage of the process has now ended and the final decision is a purely commercial one and we would respectfully ask you to use what influence you have to protect the Gower coast, by urging the Crown Estates not to issue a licence in this case.
Since sea-dredged aggregates form 87% of all aggregate used in South Wales, and all sea-dredged aggregates are used locally, the total return for the Crown Estates will be unaffected by which particular areas of the Bristol Channel source this aggregate. The dredging company involved with Helwick Bank has a licence (which it has not yet used) to dredge double the Helwick tonnage from Nobel Banks, further off-shore. Other companies have licences to dredge large quantities of aggregate from deeper water in the Bristol Channel, with other applications in the pipeline. There is therefore no need for the Helwick Bank aggregate, while the potential damage to the Gower environment and its tourism economy is huge.
We have hesitated to approach you, but are very aware of your deep concern for the environment; and we humbly request your support in safeguarding the beauty of Gower for future generations.
Yours sincerely,
Malcolm Ridge
Chairman
why is this dredging still going on....time the Assembly got thier act sorted out.....its shambolic!
I am a Chartered Civil Engineer and have studied inshore Coastal Processes, it doesnt take a Rocket Scientist to recognise the fact that by removing sand from this area, less energy is dissipated from the waves and hence the waves then continue to shore and dissipate more energy, which in turns starts the natural process of regeneration of the outer sand banks, by scouring the inshore beaches and moving the sand back out to the sand banks!
Yes the banks do recover....but this is at the expense of our beaches.
We should be importing our sand from mre sustainable sources and be prepred to have to pay more for it! I hear there is loads of sand out in the sahara! Plus africa could do with a boost in thier continents financnes!!!!!
James
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