North West & North Wales Coastal Group

North West and North Wales Shoreline Management Plan SMP2

Annex B12

Public Consultation Location Specific Responses and Comments: Sub-cell 11c

1 and Wyre Estuary – 11c 1 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_75 11c 1.5 Similar responses received from EA NW & Wyre BC, so Change to HTL, MR, MR to allow more proactive propose to revise the draft policy to HTL / MR / MR to allow managed change and revise Action Plan item 1.1. RSPB Stanah to Cartford Bridge (south bank) and Cartford Bridge to Shard Bridge (north bank) - MR flexibility in the approach to managing change. opportunities exist here. The current preferred policy of HTL then NAI takes a passive approach to seeking these opportunities. We would recommend MR for some sections of this Policy Unit. The Action Plan ref 1.1 in this section should highlight this specifically. 11c 1.6 Support for policy acknowledged. Rather than add to Action Add Action Plan item for 11c 1.6 Plan item 1.1, which is for the upper estuary, the review Shard Road (A588) to Golf Course - MR opportunities exist here. The current preferred policy of proposed in the draft SMP policy approach can be a separate HTL does reference need to review opportunities for MR, which we support. item. The Action Plan ref 1.1 in this section should highlight this specifically. PCR_11 If there was an incident on the Wyre Coastline similar to the recent problems in would our Y The Cumbria problems in 2009 were related to very heavy No action proposed existing coast protection system have worked? rainfall, resulting in very exceptional river flows. The SMP has Councillor for not considered in detail the standard of protection provided by Wyre Borough New Housing schemes are being considered on flood plains all the time and up to now the the existing defences, but there is certainly a chance that they Council, Environment Agency have not objected. Should they not be insisting no further housing can take place could be overtopped under very exceptional tidal surge events. & on flood plains. This is adding to the problems which are severe at present Nateby Wards PCR_113 11c 1.5 Similar responses received from RSPB & Wyre BC, so propose Change to HTL, MR, MR to allow more proactive to revise the draft policy to HTL / MR / MR to allow flexibility managed change and revise Action Plan item 1.1. EA NW The headline ‘Hold the Line’ policy for the first epoch could restrict opportunities for promoting in the approach to managing change. The stated approach for habitat creation in this location. A policy of managed re-alignment or revised wording around the the first epoch allows for earlier implementation and will policy for the first epoch should be considered to provide some flexibility in providing BAP habitat at recognise potential for BAP habitat creation. the locations identified in the Wyre Habitat Management Study. However, we accept that further discussions and stakeholder engagement / agreement would be required before any change to headline policy.

2 Knott End to – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_18 11c 2.4 N Response noted. A number of similar responses have also been 11c 2.4 received. Individual, Re; Changes to sea wall; Knotts End to Glasson Dock. I would like to register my concerns regarding Revise headline policy in the 2 nd and 3 rd epochs to Thurnham the proposal to re-align the sea wall between Knotts End and Glasson dock. I live in a house on The Environment Agency and Local Authorities have permissive “Hold the Line OR Managed Realignment” and Thurnham Moss which is protected from flooding by the sea wall about Plover Scar. Your proposal is powers to undertake flood risk management activities but do not the approach to indicate “either maintain existing to realign the wall behind my house, resulting in my house being flooded; it would appear, in the next have a duty to do so. Unfortunately there is no right to flood defences OR seek opportunities for managed 25 years. protection or continuation of management of existing flood realignment”, depending on further consultation and defences, and provided adequate notice is given, no right to studies. I do not think you should do this realignment without considering the consequences of it. My house compensation in relation to withdrawal from maintenance of has been here since 1658. It was renovated in 2003 and has been our home since then. You have in Amend Action Plan to allow for ongoing consultation defences. However, a claim for compensation may arise, for the flash of a keyboard and proposal document made my property worthless. No one will purchase it with the Parish Council. example if the existing defence were to be deliberately breached from me with the realisation that in 25 years it will be inundated by the sea. or dismantled and this was to expose properties to increased risk Your proposal did not include any compensation or financial support for the properties put at risk. I of flooding. have leukaemia with a life expectancy of about 10 year if treatment continues to be successful. It will During the consultation period meetings have been undertaken be worse if treatment fails. How will my widow be able to live if you have taken away the only with the public and with Parish Council at which significant resource we have left? local concerns have been raised and the issues discussed My preference is for you to review your proposal and continue to hold the line so protecting the regarding the difficulty of justifying long term affordability of the ancient monument of Cockersand Abbey, the acres of productive farm land and homes that exist on maintenance and improvements to the defences that would be Thurnham Moss. A clear statement has to be issue to that effect for the next 100 years. If you cannot required to hold the line that residents would prefer. do this then the very least is financial support in the form of market value of the properties and The draft SMP proposed that more detailed studies were compensation for having to move. I recognise the current policy regarding permissive loss. However required to determine the approach to management of this we moved here on the understanding of coastline protection as has been here for the last several frontage and this is still the case. hundred years. The Council did not withhold planning permission or offer advice regarding this change in policy. Realignment is not permissive. It is active. In recognition of the strong concerns raised at consultation and the need to consider alternative options for managing the existing In the meantime what do I do about my property? Please buy it off me, and compensate me for having defences into the medium term, whether or not the primary to move. defence is realigned, the headline SMP policy is now proposed to FEEDBACK FORM - property compensation. Managed realignment blights my property which I will change to “Hold the Line OR Managed Realignment” in the have to sell in 10 years (I got cancer) Who is going to buy it? 2nd and 3 rd epochs, The actual long term policy for this frontage and the approach will be developed during further consultation with local stakeholders and through studies proposed in the SMP Action Plan. PCR_29 (questionnaire response) No specific details of concerns provided. No action proposed Individual Identified an interest or concern with agricultural land. Cockerham PCR_46 (questionnaire response) N No specific details of concerns provided. No action proposed Individual, Cockerham Parish Council PCR_59 11c 2.4 N Response noted. A number of similar responses have also been 11c 2.4 received. Individuals, We strongly disagree with the long term plan to build a sea wall further back to where it is now. Revise headline policy in the 2 nd and 3 rd epochs to Cockerham See response to item PCR_18 above. “Hold the Line OR Managed Realignment” and We own a caravan park for 52 units, we own 2 houses here. We have 230 acres of prime agricultural the approach to indicate “either maintain existing land. We have a large dairy unit here with extensive buildings. The headline SMP policy is now proposed to change to “Hold defences OR seek opportunities for managed the Line OR Managed Realignment” in the 2 nd and 3 rd If the sea defence is not kept in good repair our whole life and business will be wiped out. 5 realignment”, depending on further consultation and epochs, The actual long term policy for this frontage and the generations of time and money invested into Bank End will be destroyed and then there will be studies. approach will be developed in further consultation and studies

3 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? nothing for the generations to follow. Bank End is a huge concern and I feel extensive thought should proposed in the SMP Action Plan. Amend Action Plan to allow for ongoing consultation be put into our investment and our future. with the Parish Council. PCR_63 11c 2.4 The weight that is given to farmland in flood and erosion risk 11c 2.4 management appraisals has increased very significantly over the Individual, Resident feels that the food security policy has changed over the last 12 months with Hilary Benn Revise headline policy in the 2 nd and 3 rd epochs to last few years. The approach to assessing the national economic Cockerham; advocating growing food at home in UK. He thinks this should be taken into account in the SMP and “Hold the Line OR Managed Realignment” and value of farm land has changed to reflect the changes in telephone give farmland more weight. the approach to indicate “either maintain existing agricultural subsidies. Previously, the approach was to take the response. defences OR seek opportunities for managed Apparently last year the EA/Lancaster City Council put in 4 new drainage outlets from his land into economic value as 45% of market value. This has now changed to realignment”, depending on further consultation and the to stop flooding to houses in Gardner Road, Warton. He thinks the SMP policy market value less £600/ha. Market values have also substantially studies. undermines this. increased and have been included in appraisals. Amend Action Plan to allow for ongoing consultation He has read a report (apparently on the website) that suggests it is OK to lose outlying farms and It has been recognised for many years that the coastal defences with the Parish Council. caravan parks to save Natterjack Toads and Cocker Sands Abbey. I asked him which report this was between Cocker Bridge and Glasson would need significant as I don't think we have made comparisons like that(?) but all he could say was it was on the website. investment if they are to be sustained into the medium to long I tried to explain that European legislation did have to come into consideration but then he wondered term. SMP1 indicated that a capital scheme would be required who was making the decisions as he thought we were trying to stay out of Europe (he has pounds in within 5 to 10 years to deliver the preferred Hold the Line policy his pocket) but yet we are letting them dictate how we manage the coast (I told him that was outside in this area. This is why the council and the EA have been trying the scope of the SMP). very hard over the last ten years to justify doing something. However, the 2004 studies were unable to justify improvements, He also thought that 8-10 years ago there were plans to increase the seawall in this area and is and found that the Hold the Line policy proposed by SMP1 was confused by such a turn around. I tried to explain about Strategies etc and that the realignment would uneconomic, with the benefit/cost ratio (BCR) less than 1. Under not necessarily be the whole line but that didn't matter. I also told him that nationally there was not government rules the BCR needs to be greater than 1 for public enough funding to defend everywhere but he didn't think building set back defences could possibly be investment to go ahead (and generally over the last ten years the cheaper than maintaining and improving current ones. BCR has needed to be over 5 to have a reasonable chance of a scheme qualifying for national grant aid). PCR_66 11c 2.4 N Response noted. Unfortunately there is no right to flood 11c 2.4 protection or continuation of management of existing flood Individual, We like many people have now had the value of our property slashed by your proposals, if we can Revise headline policy in the 2 nd and 3 rd epochs to defences. Following meetings with Cockerham Parish Council the Cockerham sell it at all. We have just spent over £100,000 on renovating a derelict cottage within 100m of the “Hold the Line OR Managed Realignment” and proposed SMP policy is now proposed to change to “ Hold the seawall. We have worked all our lives and paid our taxes all our lives (unlike a lot of others who will the approach to indicate “either maintain existing Line OR Managed Realignment ” in the 2 nd and 3 rd epochs, be protected). If this is how hard working people are rewarded no wonder we have a nation of lazy defences OR seek opportunities for managed The actual long term policy for this frontage and the approach scroungers, they're always better off. realignment”, depending on further consultation and will be developed in further consultation and studies proposed in studies. the SMP Action Plan. Amend Action Plan to allow for ongoing consultation with the Parish Council. PCR_68 11c 2.4 Clearly the properties on higher ground are at lower risk of 11c 2.4 inundation. However, the Environment Agency’s flood risk Individuals, We also believe that we are in a different situation to residents of Thurnham Moss in that a) we are Revise headline policy in the 2 nd and 3 rd epochs to mapping used to develop the SMP indicates that the whole of this Bank End in the middle of a house sale and b) our property at is situated on a raised bank at the “Hold the Line OR Managed Realignment” and area is already at flood risk, even with the existing defences. coastline, and is one of a number of residential properties within a hamlet. the approach to indicate “either maintain existing The SMP is a broad scale plan that has to be underpinned by defences OR seek opportunities for managed We therefore have questions we would like to discuss and explore relating to the following issues: strategies and local studies to develop the details. As a high level realignment”, depending on further consultation and * In view of the fact that our property dates to 1812 and our neighbour's property at Bank House policy document, the SMP must take a conservative approach, in studies. Farm dates to the 1600's (before any coastal defence would have been erected) would our hamlet order to derive a sustainable policy for the future managers of Amend Action Plan to allow for ongoing consultation remain (or do so for the long term) even if the Thurnham Moss area was eventually inundated and the coastline, and avoid an unsustainable burden on future with the Parish Council. allowed to become saltmarsh (as per Sunderland Village to the north of us)? generations. The SMP has to look at long term risks and consider the climate change allowances set by government. In past sea

level has been falling relative to land levels in Bay, in the future this is expected to change and sea levels rise, with the

4 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? rate of rise increasing exponentially in future. We have to plan for nearly a metre of sea level rise over the next 100 years. Without effective defences the flood risk or frequency of likely flooding will vary depending on the topography and flow paths for the flood water, which may change as the coast erodes. While the area around Bank Houses may be on slightly higher ground than the lower lying Thurnham Moss area there would still be flood risks during storm surges. The flood risks are expected to significantly increase in future due to sea level rise. There would also be an issue with the access roads to the hamlet as without defences they may become cut off at high tide, similarly to the road to . These issues would need to be considered in more detail than has been possible in the broad scale SMP study for such a large area. A more detailed study of Managed realignment options is proposed in the SMP Action Plan. This needs to consider potential options for realignment and the long term costs and benefits of doing this. The draft Action Plan proposes further studies and discussions with landowners and communities to develop a strategic approach for the policy unit. The Consultation draft Action Plan proposes that the studies are led by the Environment Agency, but this would be subject to agreement and partnership approaches will be encouraged. These studies would need to consider potential impacts at a local and regional scale taking into account current land use and risks and opportunities. The proposed studies will investigate the suitability of managed realignment and investigate options for the timing, location and nature of works along the overall frontage. Of course, local stakeholders will be formally consulted throughout this process and their views will be considered. * Would we be likely to be permitted to maintain our own coastal defences, as per the policy at The draft SMP policy for the first 20 years is to hold the line, Sunderland Village north of us. while looking at other options. During this time or until such time as a Strategy and Schemes implement another approach the

Environment Agency expect to continue with the level of routine maintenance of the defences that they do now. Beyond that period the draft SMP suggests a ‘managed re-alignment’ policy. The Environment Agency would expect to maintain or make arrangements for maintaining any new defences for the area which may be built in the future. An alternative option that could be considered would be for the EA to withdraw from maintenance (after serving notice of this intention) and allow landowners to do this instead. This is not proposed in the draft SMP at the moment, but could be allowed subject to consent. Government policy states that landowners may apply for consent

5 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? from their local planning authority to construct their own protection scheme but will need to demonstrate the likely impact on the adjacent coastline and take account of other potential impacts. They would then be responsible for all costs of construction and future maintenance. It would be unreasonable to withhold that consent unless the proposed works would give rise to clear and demonstrable disbenefits or adverse impacts on the environment or on the wider community. Any decision to withhold consent must be justifiable and the landowner must have the right to challenge the decision. Where defences are adjacent to a European designated site, as in this case, continued maintenance of that defence will also require Natural England consent. Consents are generally time-limited, so it is not possible to state whether present levels of protection will be permitted in the medium / long term. * The likely timescale of inundation. We understand that the hold the line policy would remain for 20 The Environment Agency advise that the level of most sea years, and have seen the projected erosion rates for the area around Bank End and on the western defences currently in place makes them capable of providing a area of coastline fronting Cockersands Abbey of 4m in 50 years and 9m in 100 years assuming a no good standard of protection, but various gaps and lower sections intervention scenario, and wonder if inundation is predicted to fall within this timescale. mean that the defences as a whole only provide a standard of protection estimated as 1 in 10 years. Therefore there is a real

risk that properties could flood in a major storm. Individual property risk may be lower than this, depending on local topography. Climate change is expected to increase this risk so that in 50 years time this standard could be as low as 1 in 1 year for overtopping of the sea defences. Clearly this isn’t enough to provide real protection to property and a long term solution needs to be found. Also, some of the defences may last for 20 years or more, but some have a shorter life. The Environment Agency indicative flood plain map (see image below) has been adapted and used in the Shoreline Management Plan No Active Intervention assessment. The floodplain used in the SMP shows the extent of an extreme flood , i.e. the extent of a flood with a present day 0.1% (1 in 1000) or greater chance of happening each year, where the probability or likelihood of flooding is described as the chance that a location will flood in any one year. The likelihood is expressed as a percentage i.e. 1%, or as a chance expressed for example as 1 in 100 chance in any given year (However, it is important to remember that the risk of a flood occurring is there at all times – this year, next year and future years). The likelihood of flooding has been calculated using predicted water levels and taking the location, type and condition of any flood defences into account. The maps show the likelihood and consequences of flooding that could happen now under a 1 in 1000 flood. It does consider climate changes that have already happened but it does not show how the risks will increase in the future due to climate change .

6 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies?

* We would like to better understand the concept of 'managed realignment' and how this would be Definition of Managed Realignment likely to be implemented in our area if the draft policy was approved. If more than one option is This policy allows the shoreline to move backwards or forwards, possible, we would like to know what these options are likely to be. in a managed way to control or limit risk (such as reducing erosion or building new defences on the landward side of the original defences). This policy typically applies to low-lying areas at risk of flooding, but can equally apply to cliffed areas, whereby the management intervention slows or limits cliff recession for a period of time. There are a large number of different options for managed realignment, for example: Realignment to high ground – e.g. removing defences for an area where the current flood defence provides protection to a limited area fronting high ground. Realignment of a defence to reduce the length to be maintained – e.g. where a coastal defence currently protects an undeveloped peninsula Coastal realignment – e.g. where an alternative alignment is identified to be more sustainable in the long term, such as between two headlands Realignment to create new habitat in mitigation for losses elsewhere The further studies proposed in the draft SMP would need to explore potential options for alignment of a set back defence. These would take into account the local topography, eg linking areas of high ground and the potential for shortening the length of defence while maximising the benefits that the defence provides. * Would this involve the actual removal of current defence walls? Implementation of managed realignment may or may not involve the removal of current defences, this will be dependant on the

design identified as most appropriate in the preceding studies. * Given that Glasson village is to be protected, and managed realignment wishes to take a more This could be a potential option that should be appraised during economic route for new defences, could this new route run back from Glasson to protect Bank further studies.

7 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Houses? The options for alignment and the timing of changes need to be developed in more detailed local studies than possible in a broad As you can see, our questions are complex and would be best answered within the context of a one- scale SMP. Managed realignment does not necessarily involve to-one meeting. Can I request that such a meeting be arranged? managed removal of the existing defences, it could involve Given that it seems that we might lose our house sale, or even eventually lose our property itself construction of a new set back defence with no further which was recently valued at £350,000, this seems little to ask. As a young family in our early thirties, improvements to the existing line. 20 years is not sufficient security for us to live out our days here peacefully, quite aside from the loss Further local meetings were undertaken subsequent to the of inheritance for our children, or the fact that we were desperate to move house before this news responses and the individuals were invited. was (indirectly) revealed. PCR_74 11c 2.4 N Response noted. A number of similar responses have also been received. Individual, Our ownership at Hillam house Cockerham comprises 3 residential properties, 130 acres of prime Revise headline policy in the 2 nd and 3 rd epochs to Cockerham agricultural land and a set of substantial farm buildings. Barkers Farm ltd operates a commercial herd See comment on other responses for PU 11c 2.4 above. “Hold the Line OR Managed Realignment” and of pigs and dairy and has an annual turnover of £1.2million. We supply local firms with agricultural the approach to indicate “either maintain existing See also the comment on PCR_187 commodities and employ a total of 7 full time employees. Our concerns include: defences OR seek opportunities for managed The headline SMP policy is now proposed to change to “Hold realignment”, depending on further consultation and • Community and local business - Having read the detail of the SMP2 on your website, it does the Line OR Managed Realignment” in the 2 nd and 3 rd studies. seem concerning that there is complete disregard to local people and businesses. It is epochs, The actual long term policy for this frontage and the fundamental that there is full recognition to people living, working and visiting the area which Amend Action Plan to allow for ongoing consultation approach will be developed in further consultation and studies is a thriving community. Between Cocker Bridge and Glasson there are large farming with the Parish Council. proposed in the SMP Action Plan. businesses as well as other commercial ventures including sizable caravan sites, model aircraft clubs and a skydiving centre to name a few. However there are also many non- commercial activities available which attract vast numbers of visitors such as walking, bird watching and sailing all of which make the most of this special landscape. This area is definitely not simply an area of isolated farms as referred to in your draft policy statement 11c 2 • Government Policy - Having spoken to FC we are concerned that our shoreline is to be governed by a European Directive to Defra. This raises 2 points (i) We question Defra's policy on food security and production which has been turned onto its head in the last 12 months. Hilary Benn changed his mind from a position where he stated food security was best guaranteed by importing the majority of the country's food needs. Then he stated at the 2009 Oxford farming conference that he wanted to encourage farmers in this country to produce as much food as possible. This was the result of the food price inflation of 2008 following world shortages. This is especially relevant in the Cockerham area which, due to the extremely fertile land, has the ability to produce an abundance of quality food. • (ii) Decisions should be taken by local people with local knowledge and not be civil servants or politicians in Brussels. • Prime Objectives - It is clear within the SMP2 that within the next 20-50 yrs a managed re- alignment of the existing sea wall between Cocker Bridge and Glasson is proposed. This will make use of existing areas of higher ground but will allow the flooding of a significant area which is currently protected by the existing seawall. • However, the driving force of SMP2 and in particular the proposed re-alignment of the sea wall between Cocker Bridge and Glasson is not clear. It is the need to reduce costs in maintaining the existing defences or the threat of global warming and rising sea levels? Or is it the ever increasing importance given to Natural England and English Heritage who champion the environment and history to the extent that less importance is given to communities living in these rural areas? Global warming and rising sea levels is still very much unknown and is being questioned more and more. The extent of changing sea levels is

8 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? therefore only speculation. As a result we would have thought that the most appropriate action would be to strengthen existing sea defences as proposed approx. 10 years ago by the EA. This would surely be the least cost solution as it involves enlarging an existing structure which incorporates existing watercourses, avoids flooding residential properties, valuable farmland and other commercial businesses and also protects some very important habitats and heritage. • Legal Statute - We are aware that there is legal statute available in the form of the CPA 1949 and the Acquisition of Land Act 1981 and we will be taking advice on our rights available under this statute. However in the mean time it would be helpful to have further information on the studies and investigations that have been carried out to date as well as details of your cost benefit analysis between maintaining the existing defences and re-aligning the sea wall between Cocker Bridge and Glasson. We would welcome the opportunity to meet to hear proposals in detail and let us explain our fears PCR_76 11c 2.4 N Depending on the approach to be developed at the more detailed stage, managed realignment would not necessarily preclude local Individual, Concerned by: Potential loss of the natural heritage site (Cockersand Abbey) and other listed Revise headline policy in the 2 nd and 3 rd epochs to defences to provide erosion protection to the scheduled Thurnham buildings. Loss of existing wildlife, farmland and other wildlife habitats. Loss of dwellings, farms, “Hold the Line OR Managed Realignment” and monument or indeed other properties. smallholdings and businesses including our home and field. the approach to indicate “either maintain existing The Environment Agency and Local Authorities have permissive defences OR seek opportunities for managed Cost of maintenance of current sea wall would be less than proposed new wall. Existing colonies of powers to undertake flood risk management activities but do not realignment”, depending on further consultation and skylarks which are becoming increasingly rare would be adversely affected to the point of destruction. have a duty to do so. Unfortunately there is no right to flood studies. No offers of compensation for loss of homes, farmland and businesses and destruction of same would protection or continuation of management of existing flood affect the human rights of all landowners involved. Seawater infiltration of aquifers would be seriously Amend Action Plan to allow for ongoing consultation defences, and provided adequate notice is given, no right to hazardous for livestock. with the Parish Council. compensation in relation to withdrawal from maintenance of The effects of sea water inundation on local properties and assets from either managed realignment defences. However, a claim for compensation may arise, for set back or non-active intervention on the current sea wall defences, its effect on the local example if the existing defence were to be deliberately breached community and the loss of areas of historical value. or dismantled and this was to expose properties to increased risk of flooding. Objections to the draft policies: The area is already at flood risk, with sea level allowances we We wish to express our strong objections to any plans arising as a result of conclusions drawn from have to plan for, the risks will increase substantially, but it is the draft SMP2 policy consultation process which will, either by managed realignment or non-active considered that the national priority ranking for a capital schemes intervention by any authority or agency, result in our property and lands on Moss Lane being flooded to improve the defences here will be low because the ranking by sea water and irreparably damaged. Our reasons are as follows: system focuses on maximizing the numbers of people protected • With the Managed Realignment option, no concrete evidence has been presented to date that and national priority habitat protected or created. Including indicates the costs of building and maintaining a new sea wall defence would be a more economically allowances for some habitat creation would be expected to viable option. It has been estimated that costs would be in the region of £12 million (Thurnham increase the national priority and hence affordability. Institute meeting 12/1/10) which, in our opinion would be a minimal figure. No information has been These questions were further discussed at the meeting at presented to indicate the life span of different sections of the current sea wall so the estimate is only Glasson on the 08/03/10. a general one and not based on our own current sea wall condition. If kept in good order especially by prompt and better quality maintenance, it would be much more cost effective. If the Set-Back It has been recognised for many years that the coastal defences option was chosen, there would be many compensation issues; again adding to the expense. between Cocker Bridge and Glasson would need significant investment if they are to be sustained into the medium to long • The building of a new wall would have a great impact on carbon footprint, be an intrusion and have term. SMP1 indicated that a capital scheme would be required a detrimental effect on the scenic landscape. Egress and ingress through the wall for residents, farm within 5 to 10 years to deliver the preferred Hold the Line policy traffic and visitors would need to be made. Also, the effect of construction traffic on Moss Lane in this area. This is why the council and the EA have been trying would cause considerable damage to its surface which would have to be made good. very hard over the last ten years to justify doing something. • Maintenance of the sea wall has been carried out over the years by the River Authority (now the However, the 2004 studies were unable to justify improvements, Environment Agency) so a precedent has been set for the Duty of Care towards residents, farms, and found that the Hold the Line policy proposed by SMP1 was businesses and livestock to protect them from inundation by flooding and the resulting contamination uneconomic, with the benefit/cost ratio (BCR) less than 1. Under

9 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? by sea water and sewage which would also cause a serious Health and Safety issue. government rules the BCR needs to be greater than 1 for public investment to go ahead (and generally over the last ten years the • There is no way to predict the actions and movements of tidal waters in the area with one hundred BCR has needed to be over 5 to have a reasonable chance of a percent accuracy. More finances would have to be spent on studies, technical consultations and the scheme qualifying for national grant aid). SMP 2 has been creation of a predictive model which would add considerably to the expense. informed by prior studies, so only now is the possibility of • The financial benefits to the area from farmland and tourism are considerable; these have been managed re-alignment in 20 years time being put forward as a estimated to be in the region of £6 million per annum (Thurnham Institute meeting 12/1/10). In the preferred policy for consultation. current economic climate, either managed realignment or no-active intervention would be false The RSPB response to the SMP consultation draft does not economy options. The loss of tourism, especially concerning the several caravan sites, would have a specifically comment on this policy unit, but generally indicates “knock-on” effect on local businesses, hotels and recreational venues. that they would prefer to see far more MR or NAI policies for • No evidence to date has been presented regarding the necessity for more salt marsh on ecological frontages in the short term, 0 to 20 years than included in the grounds as marshland already exists, or has been created, in nearby areas such as Cockerham Marsh draft. and Hesketh. Any benefit to wildlife would be minimal and also detrimental to existing wildlife, In recognition of the strong concerns raised at consultation and especially the local skylarks (Alauda arvensis) which are becoming an increasingly rare species and the need to consider alternative options for managing the existing have been accorded a “Red Status” (highest conservation priority) by the RSPB ( www.rspb.org.uk ). defences into the medium term, whether or not the primary • There is considerable interaction and cooperation between farmers on Thurnham Moss with the defence is realigned, the headline SMP policy is now proposed to local farmers living in the surrounding area who rely heavily on their assistance for the day to day change to “Hold the Line OR Managed Realignment” in the running of their farms. This would be lost if farms and farmland are destroyed as would the thriving 2nd and 3 rd epochs, The actual long term policy for this frontage community of Thurnham Moss itself. and the approach will be developed in further consultation and studies proposed in the SMP Action Plan. • Cockersand Abbey is a historic monument built in the 1100’s. Due to coastal erosion, only the Chapter House remains. It is an important part of our national heritage and as such should be See also the comment on PCR_187. protected, as should the listed buildings in the area. Once these are lost no change of policy or improved reassessment of sea defences will ever bring them back. We can fully understand that one’s personal and emotive issues carry little weight with governmental decisions but feel the need to express our own personal views and the effect on my husband and I that the loss of our home, garden and smallholding would have. Our cottage dates back to around 1710 and we have lived here for many years working hard and investing all our savings into its renovation and also on the surrounding land. We have sheep, geese and hens plus a productive vegetable plot and are part self sufficient. I am a passionate gardener and have created our own piece of paradise amongst the most beautiful scenery you could ever wish to live in. I worked nearly 42 years for the NHS and retired two years ago as Head Biomedical Scientist in Histopathology at the Royal Lancaster Infirmary. My husband, a local butcher, retires this Christmas. We have always strived to be good and honest citizens; we are debt free and the only benefits we have ever claimed was when I needed chemotherapy a few years ago for invasive cancer. We have experienced flooding throughout our home three times due to a problem with surface water run-off and installed a new drain at our own considerable expense. We have spent sleepless nights worrying about the situation we now find ourselves in. If the current sea wall ceased to be maintained as with the non-active intervention option, the value of our property would be severely reduced and possibly uninsurable. We would never know if or when we would be flooded and by how much. We would be living in a constant state of fear during times of high tides, especially if accompanied by strong winds. Our worst case scenario is that our home would become uninhabitable; we would lose everything and would have to leave. Depending on the circumstances, there may be no compensation offered to us. We would have very little money to find a new home and a mortgage would be impossible at our age. Added to this the fact that we may have to pay in the region of £20,000 to have our home demolished would bankrupt us, not just financially but both physically and emotionally too. I therefore ask you for the reasons stated above, and in the name of human decency, please don’t let

10 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? this happen to us. PCR_78 Concerned with Loss of farmland. N The SMP Action Plan proposes further studies to develop the Revise headline policy in the 2 nd and 3 rd epochs to approach, considering the impacts on agricultural land loss. “Hold the Line OR Managed Realignment” and Individual, I was very surprised and shocked to learn recently that there is currently a consultation process Managed realignment of the defences would provide continued or the approach to indicate “either maintain existing Aldecliffe taking place regarding the maintenance of the sea defence wall at Cockerham, as there is in many improved protection to the land behind the new defence line. defences OR seek opportunities for managed parts of the UK. As a member of that community it is my direct concern. As a farm business The land between the new defence line and the current defences realignment”, depending on further consultation and consultant I have a number of concerns regarding the potential loss of this farmland. would not necessarily be lost, and change in use would depend studies. I am sure you are more than aware that over the course of the next 40 yrs the world's population is on frequency of inundation. Amend Action Plan to allow for ongoing consultation set to increase by some 50% to 9 billion people, most of who will live in Asia and are already net In recognition of the strong concerns raised at consultation and with the Parish Council. importers of food. 60% of these people will also live in cities and the last time I checked they don't the need to consider alternative options for managing the existing produce much in the way of food there. defences into the medium term, whether or not the primary Additionally we are currently loosing approx 3% of the world's farmland each yr to construction, defence is realigned, the headline SMP policy is now proposed to deforestation and desertification and as they say they don't make it anymore, land that is. change to “Hold the Line OR Managed Realignment” in the 2nd and 3 rd epochs, The actual long term policy for this frontage Combine all these factors and the world is going to starve within the next generation, certainly and the approach will be developed in further consultation and before it drowns. studies proposed in the SMP Action Plan. The thought of loosing over a thousand acres of Grade 1 and 2 land to the sea for it to 'die' and then leak methane gas into the atmosphere needs careful consideration and I would urge the decision makers to undertake a deep and wide review of this matter and to include openly the residents and owners of the land as it would appear that so far this has been kept quiet as an issue. PCR_81 11c 2.4 N Expenditure on flood defences is subject to national prioritisation Revise headline policy in the 2 nd and 3 rd epochs to and unfortunately it is unlikely to be affordable to defend “Hold the Line OR Managed Realignment” and Individual, We do not agree with the SMP because our family has farmed at Bank End since 1936 and we wish to everywhere in future. the approach to indicate “either maintain existing Bank End continue farming for many more years. The proposed plans of the SMP would destroy our future defences OR seek opportunities for managed livelihood. We have worked extremely hard as a family over the last 70 years building a successful realignment”, depending on further consultation and business which hopefully will be continued by future generations. studies. Amend Action Plan to allow for ongoing consultation with the Parish Council. PCR_83 11c 2.4 N See the comment on PCR_187. Revise headline policy in the 2 nd and 3 rd epochs to “Hold the Line OR Managed Realignment” and Individual, Concerned about the Remains of Abbey in Cockerham. Byways, caravan site and Bank Houses. The the approach to indicate “either maintain existing Eccles Lancaster and Morecambe Model aircraft club @ Jeremy Lane defences OR seek opportunities for managed realignment”, depending on further consultation and studies. Amend Action Plan to allow for ongoing consultation with the Parish Council. PCR_84 11c 2.4 N See earlier comments including in response to PCR_187. Individual, I live and farm at Bank End Farm so the proposals are of great concern to me. I am 34 yrs old with a In recognition of the strong concerns raised at consultation and Cockerham wife and 3 children to support and need the farm as a means to do this. We are currently producing the need to consider alternative options for managing the existing 4 million litres of milk a year which puts us in the top 100 in the country. We have an annual turn defences into the medium term, whether or not the primary over of £1.2 million and employ 3 full time staff. Many local firms rely on the business we give them defence is realigned, the headline SMP policy is now proposed to from the farm. I believe to loose a farming business of this size a great loss to the country. change to “Hold the Line OR Managed Realignment” in the 2nd and 3 rd epochs, The actual long term policy for this frontage As the population grows I would think it vital to try and preserve as much agricultural land as and the approach will be developed in further consultation and possible. Once it is allowed to the sea it will cost a lot more to reclaim when necessary. I see it very studies proposed in the SMP Action Plan.

11 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? short sighted not planning for the future in this way. We have 230 acres of top agricultural land, the value of which is ever increasing, and with the set up we have worked so hard to achieve would value the land at £10,000 an acre. On the farm we have a bore hole so the recovery off water under ground is quite likely to get contaminated, which I believe a major concern. We also have a caravan park with 52 static caravans with an annual turnover of £50,000. The local shop and public houses rely on the trade the holiday makers bring not only from our site but also Cocker Side caravan park and Cockerham Sands caravan park. I hope you take into account the business which will be lost if the area is to flood. The lost revenue from tax would more than pay for the maintenance of the sea wall yet I am told it is not viable. The cost difference between building a new wall and maintaining the original wall seems very little with comparison to the huge loss. I believe that surly to properly maintain the existing sea defence would be beneficial to all parties concerned. PCR_85 11c 2.4 The draft policy in the SMP for this area is to hold the line in the Revise headline policy in the 2 nd and 3 rd epochs to short term (0-20 years) with the potential for Managed “Hold the Line OR Managed Realignment” and Individual, With reference to the notice recently displayed on the footpath near Cockersands Abbey: Could you Realignment in the following time periods (20-50 years and 50- the approach to indicate “either maintain existing Cockerham please send me information about the extraordinary idea to allow the present sea defence to decay 100 years). However there is no assumption in the SMP as to the defences OR seek opportunities for managed and building a new one further inland. extent of the Managed Realignment and therefore it is not realignment”, depending on further consultation and What would happen to the Abbey Charterhouse and the various structures above and below ground possible at this high level stage to say what will happen to the studies. and the other historical buildings close by? Abbey or the Chapterhouse. A more detailed study of the Amend Action Plan to allow for ongoing consultation Managed Realignment options is proposed in the SMP Action Who is behind this idea and do they have the power to implement such a move? This would destroy with the Parish Council. Plan. This study would need to consider potential impacts at a an abbey and environs which have remained little changed for over 800 yrs and which have been local (which would include implications for heritage assets) and at cared for by local people and national institutions alike. a wider scale taking into account current land use and risks and opportunities. The proposed study will investigate the suitability of managed realignment and investigate options for the timing, location and nature of works along the overall frontage. Of course, local stakeholders will be formally consulted throughout this process and their views will be considered. SMPs are strategic documents that are undertaken around the coastline of England and Wales following guidance from Defra (Department of Food and Rural Affairs). The and North Wales SMP covers the coastline from the Great Orme in Llandudno to the Scottish border and is being developed by the North West England and North Wales Coastal Group, which is a collaboration of the Coastal Local Authorities, who have responsibilities for coastal defence and the Environment Agency. Development of this SMP2 has been led by a Project Management Board made up of members of the North West and North Wales Coastal Group, including technical officers and representatives from Coastal Local Authorities, the Environment Agency, Natural England and English Heritage. The Project Management Board has been assisted by Client Steering Groups (covering the Sub-Cell shorelines) and an Environmental Sub-Group set up to oversee and review the environmental

12 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? aspects of the Plan. The plan sets out long term policy along the coastline in the context of national funding priorities. Once complete the SMP will need to be ‘adopted’ by all the coastal Local Authorities and then reviewed and signed off by the Environment Agency before the policies are implemented . PCR_87 11c 2.4 N See earlier comments including in response to PCR_187. Revise headline policy in the 2 nd and 3 rd epochs to “Hold the Line OR Managed Realignment” and Individual, Concerned with proposed retiring to second defence line at the area of interest (Cockerham). Bank In recognition of the strong concerns raised at consultation and the approach to indicate “either maintain existing Leigh House Farm, Thurnham, Caravan Site & Cockersand Abbey. the need to consider alternative options for managing the existing defences OR seek opportunities for managed defences into the medium term, whether or not the primary realignment”, depending on further consultation and defence is realigned, the headline SMP policy is now proposed to studies. change to “Hold the Line OR Managed Realignment” in the 2nd and 3 rd epochs, The actual long term policy for this frontage Amend Action Plan to allow for ongoing consultation and the approach will be developed in further consultation and with the Parish Council. studies proposed in the SMP Action Plan. PCR_88 11c 2.4 N Managed realignment of defences would not mean that the coast Revise headline policy in the 2 nd and 3 rd epochs to will be lost, but it could allow for a more natural adaptive “Hold the Line OR Managed Realignment” and Individual, Concerned with the whole bay area and the enjoyment by thousands of families. Loss of prime coastal response to changing tidal levels and coastal conditions and be the approach to indicate “either maintain existing Liverpool area, outstanding views, bird habitat and leisure facilities The livelihoods of farmers and workers who delivered in a way that is beneficial to the environment. defences OR seek opportunities for managed will suffer any loss of job opportunities. realignment”, depending on further consultation and studies. Amend Action Plan to allow for ongoing consultation with the Parish Council. PCR_90 11c 2.4 N This is why the council and the EA have been trying very hard Revise headline policy in the 2 nd and 3 rd epochs to over the last ten years to justify doing something to improve the “Hold the Line OR Managed Realignment” and Individuals, In 2003 we moved on to By ways next to Bank House Farm. At this time you had got along the top defences. However, studies were unable to justify improvements, the approach to indicate “either maintain existing Morecambe wall and we were told you were carrying on past us but you gave up. The big tides we have had over and found that the Hold the Line policy proposed by SMP1 was defences OR seek opportunities for managed the last years have had us all in a panic more times than we can count. Our van is downhill from the uneconomic. realignment”, depending on further consultation and gate so we will get it full on, so us and all the other 13 would benefit, that with all the others along studies. the sea line houses and bungalows. In recognition of the strong concerns raised at consultation and the need to consider alternative options for managing the existing Amend Action Plan to allow for ongoing consultation defences into the medium term, whether or not the primary with the Parish Council. defence is realigned, the headline SMP policy is now proposed to change to “Hold the Line OR Managed Realignment” in the 2nd and 3 rd epochs, The actual long term policy for this frontage and the approach will be developed in further consultation and studies proposed in the SMP Action Plan. PCR_95 11c 2.4 Expenditure on flood defences is subject to national prioritisation Revise headline policy in the 2 nd and 3 rd epochs to and unfortunately it is unlikely to be affordable to defend “Hold the Line OR Managed Realignment” and Individual Hi There, e-mail in response to your notices posted at Cockerham. everywhere in future. the approach to indicate “either maintain existing I was shocked to see that this is even being considered, to abandon the sea defences there would be defences OR seek opportunities for managed Setting back the defences could allow smaller defences. However, catastrophic folly in my opinion. realignment”, depending on further consultation and managed realignment would not necessarily mean abandoning the studies. I will reach my 50th birthday in June, and by then will have been a frequent visitor to that part of the existing front line defence entirely. For example, local defences coastline for 50yrs and 9 months!! I consider the area to be almost "spiritual" to me (perhaps literally could be utilised to reduce erosion risk to the Cockerham Abbey Amend Action Plan to allow for ongoing consultation in view of Cockersands Abbey). which is on raised ground. with the Parish Council.

13 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? I am sure I speak for many when I say that enjoying a walk along the sea wall is one of life’s seemingly In recognition of the strong concerns raised at consultation and more scarce rejuvenating pleasures, a brief respite from the madness of daily life in an enclave of the need to consider alternative options for managing the existing calm- poetic perhaps, but absolutely true!. defences into the medium term, whether or not the primary defence is realigned, the headline SMP policy is now proposed to I have witnessed with alarm, the damage to the sea defences in recent years, and the haphazard change to “Hold the Line OR Managed Realignment” in the "economy" efforts to repair them. 2nd and 3 rd epochs, The actual long term policy for this frontage There is no doubt that a lack of maintenance can quickly have disastrous results when a rough sea and the approach will be developed in further consultation and gets to work -but there is the key- financial pressure in Local Govt over recent years has doubtless studies proposed in the SMP Action Plan. caused maintenance to be cut back here, an "easy" option in a savage world of Public Spending

Economies. But this is obviously a "False” economy in view of the damage that quickly ensues due to that lack of maintenance, and the inevitable exponential upward curve of maintenance costs as damage goes unchecked,- "A stitch in time saves nine" . I cannot see any advantage in simply falling back to build/maintain a new set of defences further inland and incur what will surely, long term be the same problem, but with the sacrifice of that area to the sea. is spending millions on renewal/ upgrading sea defences, Southport similarly in recent years -surely the small strip at Cockerham can be saved? Why is there such a sense of capitulation? If it really came to it, and local volunteer work was needed to help repair the existing sea wall-you can count me in as a willing hand- I have enjoyed my walks there (and still intend to!) all of my life. Perhaps now is the time to "put back" effort into that environment, Best Of Luck, Support Assured PCR_97 Please send anything necessary for my parents (XXX) to become involved in the consultation process Response sent 26.01.10: Individual Please find attached a number of documents which will be a useful starting point for the consultation: 1. The main draft SMP document which gives an overview of the Shoreline Management Plan; 2. The Policy Statements for the Thurnham area which gives the draft policies proposed for the three time periods with limited information on the social, environmental and economic justification. It is worth noting that the lines on the maps do not relate to where we expect the coastline to be in the time periods but have been separated out so that the three policies can be shown. 3. The consultation questionnaire. This is not meant to be restrictive so comments do not have to fit into the boxes or relate to the questions if you do not feel appropriate. I think it would also be worth speaking to the Parish Council as I believe their next meeting is coming up soon and this may be discussed, although this is not a meeting arranged by the project. Further documents and appendices to support the draft SMP can be found on our website at mycoastline.org or if you would like any further information please get in touch. As discussed earlier the consultation end date is 14th February. Further communication: Response sent 09.02.10:

14 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Do I understand that the deadline for consultation has been extended again? When to? The consultation itself has not been extended. It was agreed at a meeting on Friday with some residents at Thurnham (chaired by Thurnham Parish Council) that comments would be received by 14th February 2010. Following this a further meeting is being arranged for 8th March where we can hopefully address some of the comments and further communications will be ongoing up to 31st March. This will of course apply to yourself but we do need to receive initial comments by 14th February in order that we are able to try and address them and have further clarification by the end of March. Further communication: Reply to response sent 15.02.10: Of course you messed up the Consultation- why else would you have extended the date? You failed Thank you for taking the time to comment on the Draft See actions below to put a notice in the Guardian (despite what you told me) and Ged McAllister has made public Shoreline Management Plan. I have passed your comments onto admissions of your mistakes. the project team and they will be considered as part of the consultation process. Following the end of the consultation You may think you have carried out the consultation in accordance with your guidelines; I will be period a consultation report will be written which will identify all asking the Judge in a Judicial Review to come to the opposite view, and have plenty of evidence to comments made and respond to them. This will be available on back me up. the website in due course. Objections to your proposals Having reviewed the concerns raised in your email of 11/02/10 The following sets out some of the reasons why your proposals are fundamentally flawed and which we are of the opinion that we have complied with the stated will give rise to a legal challenge against any decision not to fully maintain the sea defences at consultation requirements. Cockerham/Thurnham Moss, . To address your email of the 12/02/10 to Clare Nolan-Barnes: 1. Failure to Consult After a planned, lengthy and extensive consultation period, Your process is already flawed by not allowing adequate time for those affected to be properly contrary to the deadlines, we have agreed to continue consulted. In your own documentation the affected properties of Thurnham Moss number only 17, discussions with residents in this area for a further six weeks to one of those being that belonging to my parents, XXX who live at Crook Cottage, right on the sea the end of March as stated in my email to you on 09/02/10. wall. You have not bothered to contact them once, even though, as stated, they are one of only 17 I am sorry that you did not receive an out of office email and these considerations have been underway for 10 years. response but this email address is an external consultation email From your own consultation document the period of consultation should be three months- originally address not connected to any internal staff registers. 5 October 2009 to 10 January 2010. I see from both the Defra Guidance (volume 2) and Appendix B Testament to the consideration we are giving the Thurnham of your own consultation document detailed descriptions of who should be consulted, how and when Moss area we actually paid a specific visit to Bank End Farm to key bodies are to be consulted, which all sounds very laudable and thorough. Unfortunately, the collect the consultation response written by Cockersands Forum people actually affected by this process were not informed at all, and it simply is not good enough for on behalf of residents including XXX of Crook Cottage on them to be the ones with a truncated consultation period, just because someone at your office Thursday 16:00 (hence not being available to respond to your ‘messed up’. email). Fiona Crayston told me on 26 January 2010 that a notice had been placed in the Lancaster Guardian; We do not accept your contention with regards to yet I understand that Ged Mc Allister admitted to the meeting at Thurnham village Institute on 12 communication failures, and we understand that direct January 2010 that this had not occurred, and that this was an omission on your part and that similarly communication is taking place. an email to Cockerham Parish Council had not been successfully delivered. I have had confirmation from the Clerk to Cockerham Parish Council that no email was received. He also confirmed in an email to Fiona Crayston dated 11 January 2010 that the only advert in the local press was placed in July 2008 and no notification was made for the 8 December 2009 meeting. Ged McAllister also stated at the meeting at Thurnham Institute on 12 January 2010 that the first public consultation meeting was on 8 December 2009. However, as I have established above, no effective notice was given of this meeting so in my view the three month period should not run from then, but from when you opened the consultation properly. Given the complete mess you have made of it, there is an argument it

15 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? hasn’t even started yet. You have already accepted that your consultation process is flawed by extending the date for consultations to 14 February 2010; but this is not long enough for my parents and others to carry out the necessary investigations and will form part of their challenge to your recommendation. Your inadequate consultation will form part of any application for Judicial Review of your proposals. 2. YOUR LEGAL OBLIGATIONS TO CONSULT PROPERLY The manner in which a local consultation should be conducted has been laid out in the ‘Sedley requirements’ in R v Brent London Borough Council, ex parte Gunning (1986). These requirements provide four key provisions that local consultations should follow. Firstly, the consultation shall take place at a formative stage, before any substantive decisions have been taken. Secondly, sufficient reasons for the proposals to be understood shall be given. Thirdly, the consultation process must allow adequate time for consideration and lastly the consultation must conscientiously take into account the comments made in finalising any proposals. The consultation must be a genuine exercise – there should be no inference that the decisions have already been taken. The consultation must ask the views of appropriate people, and provide all the information necessary to consider the proposals. Failure to comply at all with an obligation to consult is often seen as a serious breach meriting the quashing of the decision taken without consultation, and courts are often unwilling to entertain a submission that consultation would in reality have made no difference (R v SSE, ex parte Brent LBC [1982]). The test formulated is whether part of the process has gone ‘clearly and fundamentally wrong’ (R (Greenpeace Ltd) v Secretary of State for Trade and Industry [2007]). In my view your approach to consultation could not have been more wrong. Case law has established that where the consultation has been partially flawed, the courts can uphold the decision (R (Capenhurst) v Leicester City Council [2004]), but such a course of action is relatively rare, ie, normally the decision is set aside. In addition to quashing, the court may grant a mandatory order requiring you to undertake adequate public consultation. Defra’s own website on consultation for coastal change says that the homeowner has the right to be engaged in the process, and for decisions to be made consistently and in an open and transparent manner. The Defra guidance notes also say the approach is to be participatory. You have clearly failed on both of these counts. Similarly, you will doubtless be aware of the many high minded principles encompassed in the ‘Creating Strong, Safe and Prosperous Communities’ Statutory Guidance published by the government in July 2008. The ‘duty to involve’ is described as ensuring that local people have greater opportunities to influence decision-making and get involved. This new duty to involve, which came into force on 1 April 2009, seeks to ensure people have greater opportunities to have their say and the guidance makes clear that this right is in addition to existing requirements such as statutory requirements to inform, consult with or promote the participation of users or citizens. You should be aware that the Aarhus Convention 2004, which the UK government signed up to in 2005 gave rise to Regulation 16 of the Environmental Information Regulations (EIRs) providing for the issue of a Code of Practice by the Secretary of State which clearly sets out your duties to facilitate the disclosure of information under the EIRs by setting out good administrative practice in proactive dissemination of environmental information and to ensure that third party rights are considered. You are also to encourage, as a matter of good practice, the development of effective review and appeal procedures of decisions taken under the EIRs. I will be relying on you to review your poor handling of information to the very people affected by your proposals, and especially in the light of how long this information has been in your domain. You are clearly in

16 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? breach of your duties under the Code when one compares your timetable for consultation, as set out at Appendix B (which is badly formatted and difficult to read) of your main SMP Consultation document to the pathetic number of days you have allowed to the affected residents and farms. No doubt having the Sedley requirements as mentioned above in mind, the March 2006 Defra SMP guidelines point out that you should only adopt the SMP and associated policies after considering all comments and responses from people who were consulted, which may result in the adopted policy being different from the preferred policy. You should thoroughly assess and compare other policies, including a broad assessment of the longer-term costs. The guidelines also say that you should consult your stakeholders and the general public to let them know that you have prepared an SMP; and to give them the opportunity to support or object to the proposals. It states you should include in your SMP full details of the methods you used, including the people you consulted, the responses you received and the actions you have taken. The rationale for this given in the guidelines is that it is necessary to show that the consultation you carried out has been effective, and that the decisions you have made are transparent and auditable, so that interested people can understand why a decision has been made and what information it is based on. Looking at your lamentable failures in contacting the affected residents, would you say that you have satisfied these requirements? The guidelines go on to say that the adoption of the SMP and associated policies should only be made after considering all comments and responses from people who were consulted, which may result in the adopted policy being different from the preferred policy. Considering the last Sedley requirement above (the consultation must conscientiously take into account the comments made in finalising any proposals); the requirement to have effective review and appeal procedures of decisions taken under the EIRs (paragraph 2 d above) and the March 2006 Defra SMP guidelines (paragraph 2 e above), you will have to show that you have taken into account each aspect raised by me and others in the consultation process and in order to show real transparency a full explanation of why our arguments will not prevail. The guidelines try to help you in making effective communication and consultation saying that you should use different types of communication (such as local consultation meetings and seminars, non- technical public-relations leaflets, newsletters to households, summary documents, public exhibitions and adverts in the press) depending on the target audience and the type of information. Can I suggest that as only 17 residents/farms are involved, as identified by the Jacobs Report, they should have been written to individually? Instead you failed to insert even one timely notice in the local paper. What if there are other elderly residents, who did not take the Lancaster Guardian, if that was to be your attempt at consultation? Local authorities and the Environment Agency are told to use their experience in public consultation to make sure the public is fully and suitably involved in developing the plan. You have failed lamentably in this. In the case of my parents and quite possibly other affected people, they are not computer literate. Given this you should have used your best efforts to communicate in ways other than merely publishing information online or directing people to various websites. Your failure here is a clear case of discrimination. 3. MY PARENTS HUMAN RIGHTS Your proposed actions give rise to a clear breach of my parent’s human rights, on which I have Response noted already taken preliminary legal advice. My father’s family have farmed this land since at least 1603 and my father has lived there all his life, with my mother since 1954. My parents have a right to protection, under Articles 1 (1st Protocol), 8 & 14 of the Human Rights Act. Article 1 gives rise to a duty to protect every citizen’s right to peaceful enjoyments of possessions and property. Article 8 is a

17 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? right not to have interference from a public authority in home/family life/correspondence and Article 14 prohibits discrimination on any ground. As to Article 14, looking at the map of your proposals along this coastline, it is self evident that the residents/farms in our small area are being discriminated against when compared to the other areas where the Environment Agency is committed to preserving the sea defences. 4. – A EUROPEAN SPECIAL AREA OF CONSERVATION The whole of Morecambe Bay is a European Special Area of Conservation and we will be able to General responses received from nature conservation bodies marshal voices of objection from much further afield in order to stop your proposed desecration of would favour policies of NAI and MR rather than HTL. this coastline. There will be many bodies willing to lend support to a campaign to stop what you propose. The Defra guidelines spell out the need to avoid damage to European sites. It states that maintaining and improving the current landscape is particularly important in areas that have been given official protection for their landscape importance, including national parks, areas of outstanding natural beauty and heritage coasts. The guidance says you must pay careful attention to developing a plan which, if put into practice, would maintain and improve the landscape. I cannot see that your proposals do this and will lobby all appropriate conservation bodies to ensure that they also put this message over to you. 5. THE DOCTRINE OF RELIANCE Response noted As the sea wall has been there for hundreds of years, maintained by a variety of government bodies, my parents will be able to rely on the doctrine of reliance as it is entirely reasonable that they should be able to rely on this state of affairs to continue. I also understand that there is in existence an old, but valid agreement dated 1949 between the Dalton Estate and the then statutory body, an agreement which will be binding on any succeeding body and which will reinforce your legal duty to maintain the sea wall. 6. A POTENTIAL CLAIM FOR DAMAGES FOR DISTRESS Regarding compensation, I will re-iterate that our powers regarding flood and coastal protection are 'permissive', so there I feel that your actions up to this point may give rise to a claim for damages for the distress you have would be no compensation payable as long as we exercise these already caused to my parents; no doubt if you carry on with the proposed desecration it will continue responsibly, for example by maintaining defences, or even by and most likely increase. I will hold you responsible should my parent’s health suffer as a result of withdrawing from maintenance (after giving appropriate notice). your actions. No-one has a right to be defended against flooding or erosion in As a result of your proposed actions you render my parents property unsalable. You therefore give all circumstances, whether on the coast or inland. Were we to them no option but to challenge your decision, if it is to eventually abandon the sea defences, as they deliberately do works which clearly caused a loss to others which will have nothing to lose in so doing. They will be unable to buy a property elsewhere. I will assist could be demonstrated, then we believe a valid claim for them in fighting your proposal for as long as it takes; I envisage a high profile media and fund raising compensation would then arise. Consulting on ways to best campaign in order to challenge your obviously erroneous proposal. I have already been in touch with manage sea defences in the Thurnham area, now and in the English Heritage and other bodies to elicit their support in our efforts. future, is the right thing to do and does not create a liability for compensation. If a future managed re-alignment were to be As my father is eighty five, I have to consider that it would not be out of the question that my parents implemented then some liability for compensation is likely to become housebound, because your actions mean they will be unable to sell their house and move arise, depending on the circumstances. closer to amenities. Again, I will do all I can to highlight that this eventuality has been brought about by your actions and I will hold you responsible for their predicament. About 10 years ago the Environment Agency placed Flood Maps on our website. It was considered appropriate that details about flood risk be in the Public domain so that people could make informed decisions and have some opportunity to manage their own risk. Flood Maps have in some cases had an effect on property values but this has not made the Environment Agency liable for compensation.

18 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? 7. COCKERSANDS ABBEY- GRADE 1 LISTED AND A SCHEDULED ANCIENT Revise headline policy in the 2 nd and 3 rd epochs to MONUMENT “Hold the Line OR Managed Realignment” and

the approach to indicate “either maintain existing Cockerham Abbey, which has stood there since 1184, is a grade 1 listed building and a Scheduled Adaptation to change under a Managed realignment policy would defences OR seek opportunities for managed Ancient Monument and therefore has a special right to be protected. The main legislation concerning support natural processes and allow for localised protection or realignment”, depending on further consultation and archaeology in the UK is the Ancient Monuments and Archaeological Areas Act 1979 which provides excavation and recording of Cockersands Abbey in future. studies. for nationally important archaeological sites to be protected as scheduled ancient monuments. The Defra Guidance document says you should always assess the historic environment when developing an SMP. This will involve systematically gathering readily available information on the historic environment. Can I ask what has been done in this regard? 8. CONTAMINATION OF EXISTING AQUIFER, POSSIBLY WITH RADIOACTIVE MATERIAL The Draft SMP policies for this area are Hold the Line in the I understand that an aquifer has been discovered on Thurnham Moss, the abandonment of which to short term (0-20 years) while conducting studies into the sea would presumably result in contamination to the local water supply. I also gather that there is opportunities for managed realignment in the medium (20-50 radioactive contamination of some of the mud flats (presumably due to the proximity of and years) to long term (50-100 years). These studies will directly Sellafield nuclear power stations), and assume many more people will become interested in protecting inform the medium / long term policy for this location and will Thurnham Moss when they realise that their water supply may be exposed to such contamination. include detailed economics, potential realignment positions as well as investigations into potential contamination issues. Please note that the Draft SMP policy of managed realignment in the medium and long term may therefore change if the studies conclude that this policy is not appropriate / viable. 9. YOUR FAILURE TO MAKE NECESSARY CALCULATIONS See PCR_187 comments & comments below. It is a matter of public record that you have admitted to not carrying out the necessary calculations in order to decide whether or not there is an economically viable argument for your proposals. I understand that at the public meeting on 12 January 2010 it was said by Mr Croft of the Environment Agency that the cost of maintenance of the sea defences was £12 million, yet when asked what the cost of the new proposed sea defence was, further inland, no one had any idea. The March 2006 Defra SMP guidelines state that you should thoroughly assess and compare other policies, including a broad assessment of the longer-term costs. This has clearly not been done if you have not costed the proposal of setting back a new sea defence. I would also question this quoted figure of £12m cost over the next 100 years to maintain the sea defences, where does this figure come from? Is £12m the net present value of future projected expenditure? If so what discount figure was used in the calculation, what inflation was factored in? It is beyond belief that you are causing so much anxiety to so many people’s lives and livelihoods when you have not even got the basic figures worked out. This fact alone renders your dealings in this matter incompetent and for reasons given above, potentially negligent. How can you possibly carry out such a wanton act of destruction without carrying out such a fundamental calculation? Furthermore, how can your consultation be said to be meaningful if the basis for the economic argument supporting realignment of the sea defences is not detailed and consequently not the subject of scrutiny? I also understand you have grossly exaggerated the amount already spent on maintaining the defences in order to arrive at your recommendation. I will be using the Freedom of Information Act to expose this, as those residents and farmers affected know the defences have had virtually no attention from you over the years. I will be asking to see the actual works orders to reveal the amounts you have spent on the defences. Perhaps the amounts quoted are for the salaries of those who sit behind desks pontificating about the coastline. Can I also remind you that the sea wall has been breached only once

19 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? in the recent past, in 1977, which is proof in itself that the defences work and are worth maintaining. 10. EVIDENCE OF PREDETERMINISM Your consultation document talks of further investigations and consultations after this first stage with Response noted, see comments below. a view to investigate the opportunities for managed realignment, or in layman’s terms, abandonment. There is evidence of your decision already having been determined, in clear breach of the first Sedley requirement, when you say in your consultation document that “the long term plan for the Lune is to continue to protect infrastructure and the historic , but other areas would not be defended”. In the same document you also state that you recommend “maintaining existing defences while undertaking studies to investigate opportunities for managed realignment and implement where practicable.” This is clear evidence of you already having come to a decision before you listen to what the consultees say, putting you in clear breach of the Sedley requirements. This also reveals that you have not given sufficient thought to what impact your proposals will do to those to whom you have a duty of care. You have, simply by publishing your proposals, blighted my parent’s property. They will be in the unenviable position of having to live in an area where the protective sea defences which have existed for hundreds of years are to be withdrawn. They find themselves in advancing old age, unable to sell and unable to afford to move anywhere else. 11. MATTERS YOU OUGHT TO HAVE CONSIDERED The Defra guidelines talks of the need for action to defend the coastline from flooding or coastal See PCR_187 comments and comments below. erosion and arises from the location of many important residential, industrial, commercial, nature conservation and agricultural sites in the coastal zone. It says that the communities and economy of coastal areas can be highly dependent on measures to reduce risks to people and their assets. It also goes on to say when reviewing policy, the SMP must take full account of the possible implications of any change in coastal defence, both on the economic assets and the communities they support. How does your recommendation defend the homes, farms and conservation site that comprise Thurnham Moss? I do not think you have paid sufficient heed to these guidelines. The guidelines also talk of patterns of development within coastal landscapes (including flood and coastal defences) affecting the scenic quality of an area, its ability to attract people, the quality of life for residents and the wellbeing of the local economy, saying that the social and economic value of many coastal landscapes for tourism and recreation is often very high. Have you considered this when coming to your recommendation? I hope you understand that you will have an enormous fight on your hands if your proposals for abandoning the sea defences go ahead. I am a solicitor and am quite prepared to devote all my time to fighting your proposals or ensuring full compensation is made to my parents. Further communications: Response sent 31.03.10: Following consideration of this and other responses, revise headline policy in the 2 nd and 3 rd epochs to Clare Nolan-Barnes told me by email on 12 February 2010 that I would receive a response to my The Environment Agency’s Chairman promised, by letter dated “Hold the Line OR Managed Realignment” and objections in full by 15 February 2010. I received an email from Fiona Crayston on the 15 February 10th March 2010, that John Lymer would provide a response to the approach to indicate “either maintain existing 2010 telling me how I was wrong in my criticism of the consultation process and how well it had gone your ‘further comments’ dated 28 th February. I am sending this defences OR seek opportunities for managed (saying it had been “ planned, lengthy and extensive ”). Apart from that, I have heard nothing. Mrs response from the Coastal Group, which is responsible for realignment”, depending on further consultation and Crayston also said that “we have agreed to continue discussions with residents in this area for a further six production of the Shoreline Management Plan (SMP), though John studies. weeks to the end of March” and I am availing myself of that opportunity. Some of the matters referred has provided much of the content. This response is in addition to to below could have been included in my original objections, but as I was pressed for time, having brief responses sent to you so far by e-mail, our formal written only a matter of days to respond on behalf of my parents, were not. response to the Cockersands Forum and the information/ answers provided in person and by telephone. I apologise for the Additional objections: delay in providing a full response, but following a telephone conversation and e-mails 3 weeks ago John Lymer had thought

20 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? 1. Calculations which bear no relation to the sea defences at Cockerham/Thurnham this was no longer required. (a) Having seen the Cockerham Forum paper, and your brief response to it, I have some further The costs of building, maintaining and re-building sea defences questions and points for you. I see that my assumption in point 9 c of my objections was correct, in if/when necessary are ‘unit costs’. Their derivation is described in that you calculate the annual cost of the sea defences by allocating all departmental costs on a per the handout provided at the meeting you attended on 8th March kilometre basis. The two consequences of this approach are firstly that the actual costs attributed to and in the SMP document, but in essence they have been the sea defences at Cockerham/Thurnham will bear no relation to the actual costs. And secondly that compiled from recorded costs of similar work done recently the future savings will, likewise be wholly inaccurate as, in reality the only savings will be the direct around the country. Unit costs are not “all departmental costs” costs attributable to this small section of sea defences and not the indirect and attributable costs that and are in this instance costs per metre length of defence which will have been included in your calculation, and it appears no one know what those direct charges relate only to the activities in question. They do not include staff are. costs for other flood and erosion risk management work, such as survey, or mapping of flood risk extents, nor do they include other maintenance and construction at unrelated locations. The SMP is a high level plan which looks at hundreds of (b) John Lymer ‟s reply to Mrs Weaver suggests that you have proceeded with the recommendation without troubling yourselves to undertake the most basic costing of the defences, ie, by totting up kilometres of coastline and estuary. It is not possible to use what has actually been spent on these defences. It seems particularly remiss of you to get to the stage detailed, locally specific costs for each place along the shoreline, of a recommendation without getting some pretty good cost estimates. It is an example of the worst but unit costs give a reliable indication of what the actual costs kind of bureaucratic insensitivity to suggest that these figures are to be calculated at some time in the are likely to be. An ‘optimism bias’ of 60% is, however, added to future, causing untold anxiety and uncertainty in the meantime. By purporting to carry out a the costs to account for uncertainty. More accurate costs will be consultation without these most basic of figures you are in breach of the Sedley Guidelines I compiled in future study work that the Environment Agency mentioned in my objections in that you have denied those you are supposed to be consulting a proposes to carry out and this will use records of recent chance to make a meaningful comment when you glibly say that all the figures can be looked at in the maintenance costs at Thurnham. The handout provided at the Final Action Plan, but crucially, will this not be after your recommendation has been implemented? meeting with Cockersands Forum on 8th March which you How can this consultation be meaningful when you have not provided working figures, and say you attended acknowledges that using actual costs and benefits will do so only in the final stage, i.e., after you have made your decision? specific to Thurnham will have some effect on the benefit/cost calculations, hence either of two policies (hold the line or You say in your email to Mrs Weaver “I would like to re-iterate that the SMP proposal for managed managed realignment) are now recommended for the period re-alignment, perhaps in around 20 years time, is just one option, albeit that it seems the most cost- beyond the next 20 years. The decision between these will be beneficial one according to analysis so far”. How can you say this when by your own admission you informed by a study which the Environment Agency propose to have not worked out what the current sea defences cost you and what any future realignment might undertake within the next 3 years. cost? Without these two sets of figures you have not carried out any meaningful cost benefit analysis. The Coastal Group are recommending a policy of ‘hold the line’ (c) Also, can you not see that simply by stating this „one option ‟, you render my parent ‟s house probably unsalable? You obviously should have attempted to justify, to the residents and farmers how (HTL) for the next 20 years and at the meeting on 8th March your future savings would be achieved by not maintaining these sea walls, and given your admission described what this means. that you have not carried out the most basic calculations in this regard I cannot see how you will be Environment Agency staff stated that the EA is confident it can able to defend your actions in causing such distress and plummeting property values by using allocated maintain the sea defences for the next 20 years. costs, although I appreciate these have been much simpler for you. 2. You accept that the sea defences are sound The sea defences are generally in reasonable condition, though this does vary along their length. Were just one breach to occur, In your „Policy Development and Appraisal Document Appendix F ‟ you describe a “large revetment this could result in flooding to a large area and affecting many constructed in recent years will provide protection well into medium term”, seemingly accepting the properties. SMPs are produced and reviewed in order to efficacy of the sea wall in this area. The fact that what work has occurred on these defences amounts establish the best way of managing such defences and to minimise to some grass cutting, rodent control and a sluice gate costing £3,000 and that the defences have held such risk to people and property. apart from one breach in exceptional circumstances in 1977 surely give rise to an argument that they are worth saving? Presumably these are part of the reasoning behind the outcome of Scenario A, Lancaster City Council maintain the frontage to the Cockersands which was HTL across all three epochs. In Scenario A it is stated: „in the short term the condition of Abbey, as this is high ground and therefore a coastal erosion the majority of the defences are such that the hold the line policy of Scenario A could be achieved issue. The rest of the coastline in the Thurnham area is lower and with only routine maintenance of the existing defences, with the exception of the defences around so the Environment Agency manage these raised defences with Cockersand Abbey where the poor condition of the existing defences would require remedial works particular regard to flood risk. Measures to protect the abbey

21 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? from erosion are not precluded by policies and actions in the imminently to avoid further erosion and retreat of the current shoreline ‟. draft SMP. I understand that the Environment Agency has not paid for the maintenance of this section of the wall since 2002, arguing that it is the responsibility of Lancaster City Council to do so. You will see from my arguments below that it goes against the rules of Natural Justice that decisions were made on the basis of this section of the wall needing repair by persons present from Lancaster City Council, who have a vested interest in avoiding paying for these repairs when there was no representation from those actually affected by these decisions. 3. Concealment of key data and predeterminism The draft SMP stated that a study would confirm managed re- alignment (MR) as the right approach, or show if it isn’t, in which All this goes to support an argument that you have already decided on what is going to happen at case another approach would be pursued if necessary. We have Thurnham, again, against the Sedley Requirements. The implication arises that maybe you have now chosen either of 2 policies – HTL or MR, so again, no purposefully failed to carry out meaningful consultation and have concealed key documents. For absolute decision has been taken yet. example- the Jacobs Report, on which you have chiefly relied to come up with your flawed recommendation, was only obtained by resort to the Freedom of Information Act. It was provided on The Jacobs Report provides modelling outputs and, were it not 13 January 2010 when the original consultation closed on 12 January 2010. Yet in your own that it gives addresses of properties potentially affected by consultation document you state, at 1.4 “it (the consultation document) does not provide all of the different scenarios it would be less contentious and informative information behind the recommendations; this (ie- all) is contained in the supporting Appendices” and than the Babtie, Brown & Root Report which was referenced and yet the Jacobs Report, the key document which blights the whole of Thurnham Moss, is not listed which shows alignments and flooded areas. Reference to the there. It is not even listed at Appendix D (9.2) of your SEA Environmental Baseline Report, where the Jacobs report was omitted in error, as we have stated at the local reports you rely on are listed. meetings for Thurnham. A common feature of your handling of this matter is to say how transparent and auditable your This will be rectified in the final SMP. actions are- whereas what you have actually done is the complete opposite. For example, you say “the supporting appendices provide all of the background information to the SMP2. These are provided to ensure that there is clarity in the decision-making process and that the rationale behind the policies being promoted is both transparent and auditable”. How can the appendices contain all the background information when they do not contain the Jacobs Report or the most basic figures on how much the relevant sea defences have actually cost over the years and when it took the persuasive powers of the Freedom of Information Act to extract from you one of the key documents? 4. Your own stated aims with regard to consultation At 1.6 of Appendix I – Strategic Environmental Assessment (SEA) you say: „effective external We should have involved people sooner in the way that we have stakeholder and public engagement is central to the development of the SMP (and SEA) in order to been doing between January and March 2010, though much of arrive at a SMP that is acceptable to as many parties as possible and to engage those parties in the that earlier work was fairly high level and looking at long lengths of coastline in each meeting.We believe that local people now process ‟ and „consultation has been undertaken throughout the SMP to ensure that the knowledge, experience and views of stakeholders and the general public are taken into account at all stages feel they have had a real say about the SMP and indeed have influenced the outcome. during its development ‟. The complete opposite has happened to those affected in the Cockerham/Thurnham group, and as far as I can see, this can be either incompetence or deceit on your part.

The Elected Member invite letter says, of the SMP: it “goes on to identify the main issues of concern We have sought local views and involvement and will continue to relating to erosion, flood risk and management of these natural processes. These issues will be do so after the SMP is adopted. obtained from those with an interest in the coast, be it as residents, businesses or those with a concern for the natural and built heritage. The issues will then be brought together to determine the policies”. In your own words you are seeking views of residents and businesses, with a view to them helping to determine the policies. 5. Failure to consult

22 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? This will form one of the bases for my application for Judicial Review and you will see that all the

evidence of failure is there in your own „consultation ‟ document. The following are examples of how you have failed to do this:

(a) Elected Members Forum 1 - 17 September 2008 I see from the minutes of a Elected Members Forum for Cell 11c on Wednesday 17th September Jean Yates was a local councillor living in Heysham and also 2008 Sam Box from Halcrow said that “it would be useful to have some people from Cocker Sands Lancashire’s representative on our Regional Flood Defence (sic) at the Stakeholder Forums”, to which Jean Young replied, quite incorrectly, that “Overton Parish Committee. Council covers this area”. Why was this error allowed to go unchecked? Sam Box was obviously quite correct in saying that someone from Cockerham should be present, and this was 16 months before the residents actually heard anything about it. It is yet another example of your ineptitude that this was not followed up. Because you are so remote from the process, you have probably not realised that although Overton is only a mile as the crow flies from Thurnham, across the river, it is over 12 miles by road and the communities have nothing to do with each other. As Jean Young is a Lancashire County Councillor, she is some very remote representation for us but as she obviously has no idea of the proximity of Overton and Cockerham her representation has been positively harmful to us. Ms Young lives in Heysham and later says of her section – Heysham to Roa Island; “the environmental impacts are most important. This area includes part of the AONB”. This is an example of self interest at these discussion forums, of naturally putting forward arguments for ones own constituents, whilst not even understanding the relative locations of Overton and Cockerham. This could have been remedied by someone taking up Sam Cox ‟s suggestion of having someone from Cockerham there, but no-one troubled themselves to do this. (b) Meeting 25 September 2008 Similarly, at the meeting of SMP2 Northern Sub Group on 25 September 2008 where Andy Parsons We have previously acknowledged that Thurnham and explained what a Key Stakeholder forum was, saying that “we need to make sure that we have the Cockerham Parish Councils were omitted from contact details in contact details of the right people”, and Lee Swift saying “the Parish Councils needed to be included”, the early stages of the SMP process and this led to an unfortunate nothing was done about contacting the very people affected or their representatives. gap in our consultation efforts. (c) Invite to Elected Members Forum 2 We have listened to consultation feedback and amended the Additionally, the example invite to the Elected Members Forum 2 states “the experience of pilot proposed policy for the period beyond the next 20 years. This SMP2s shows that Elected Members Forums are an effective means of engaging decision makers early outcome is probably as favourable as local residents could hope in the process so that contentious issues are highlighted and fully consulted upon, before it is too for – earlier consultation is unlikely to have improved upon this. late”. I would like to know exactly who was the Cockerham/Thurnham elected member at that The SMP Action Plan will include actions that ensure full local meeting? You highlight in your invite that these matters need to be consulted on, before it is too late. involvement in future. This is exactly what has happened - now it is too late - the Cockerham/Thurnham residents should have had a representative at these meetings, for the reasons you yourselves recognise- and this is why tagging a few weeks on at the end simply will not do. Sam Cox ‟s comment above, and the fact that Thurnham was not represented at this earlier stage, while the process was still evolving, will be another plank in my argument that the way you have gone about this process is fundamentally unfair to my parents and the other residents. (d) Elected Members Forum 2 - 15 December 2008 Ian Rowlands’ role was explained by Jonathan Croft at the At the meeting of the Elected Members Forum on 15 December 2008, looking at the list of meeting on 8 th March. Ian was the EA’s Area Flood Risk Manager attendees, it seems that no-one was present to represent Cockerham, and one can see from the for many years. Since restructuring he has now taken a sideways „minutes ‟ (they are too brief to be really described as such) how others might, in an entirely self move and is a Technical Manager. interested way, claim their own area needs full protection, and in an attempt to make savings

23 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? somewhere, pick on Cockerham, which has no representation at the meeting, saying that it can be The comments made by Sam Box that you have queried relate to the community to suffer Managed Realignment. For example, Ian Rowlands of the Environment comments about Pilling Marsh logged during a breakout session Agency says, in response to a question about Cockersands Abbey that “it is currently HTL, but are at the first Stakeholder Meeting: there other policies we should look at?” simply says: “Managed Realignment”. Is this how the fate of Stakeholder Forum 1 sub-cell 11c – Rossall Point to Haverigg 5th the area is sealed, by one person saying „Managed Realignment ‟? Who is Ian Rowlands and what is his November 2008, Lancaster House Hotel, Lancaster. See role and title within the Environment Agency? Brenda Woof, from South Lakes says: “if places are Appendix B, Annex B2 Stakeholder Forums pg B2-26. going to be below sea level in the future it is surely not economic to defend.” The breakout session involved the following group of Can you see how this illustrates how decisions have been made without involving those who actually stakeholders: live and work there? I also particularly want to know what was meant when Sam Box says of Cockerham: – “stakeholders have argued that it is causing issues in the Lune and should be returned GM – Ged McAllister (Lancaster City Council) to be a flood storage area”. I would like to know which stakeholders are these, what „it ‟ means SB – Sam Box (Halcrow) exactly and what are the „issues ‟ he refers to? (These are not rhetorical questions). The whole CH – Carole Hodgson (Country Land and Business Association) arrangement and decision making process stinks of unfairness and subterfuge. DC – D Clarke (Overton Parish Council) PG – PT Gilchrist (Sunderland Point) JC – Jonathon Croft (Environment Agency) DA – David Andrew (Sunderland Point Community Association) ‘It’ refers to the defending of the previously reclaimed area at Pilling Marsh. ‘Issues’ refers to the issue that since reclamation, this area has been protected from flooding and consequently, now the water floods up the Lune Estuary during surges instead of Pilling Marsh, which previously would have acted as a flood storage area in these circumstances.We do note however, that it is unclear whether this linkage between Pilling reclamation and tidal levels in Lancaster is based on speculation, anecdotal observations or factual scientific studies. (e) Invite to Stakeholder Forum Meeting 3 Recent consultation has ensured the SMP is recommending In the invite Fiona Crayston again confirms that the meetings present “an opportunity for you to policies that the Coastal Group believes are fair and local influence and inform the preferred policies set along the coast”. This shows that there was a very real residents now seem satisfied too. opportunity to influence/alter/change the decisions ultimately made, and again, shows why tacking a few weeks of consultation at the end will not work, unless it is to turn your recommendation to full protection. I think I have illustrated that we should have had a presence at all of these meetings, and were denied this. (f) Elected Members Forum 3 - 22 June 2009 As acknowledged above, Cockerham had no representative at Turning to the Elected Members Forum 3 on 22 June 2009, again, who was there to represent the Elected Members Forum in June 2009. Cockerham? Can I suggest that no-one was present who had the Cockerham residents interests at heart, as the only minuted reference is to Cockersands Abbey, saying it should be „kept dry ‟. I see that in the action column of the minutes of this meeting it is stated „change to HTL in Epoch 1 ‟- so at this meeting, where no-one was present to represent Cockerham residents and farmers a decision was made about this sub- cell. This in itself shows how key these meetings were and therefore how it was essential that a representative from Cockerham/Thurnham was present. There is absolutely no transparency in how and why this key change came about.

24 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? (g) 503 stakeholders invited, but not Cockerham or Thurnham Can I also point out that in your list of stakeholders invited to participate in the SMP process as part See answer to 5b. of the Initial Stakeholder Engagement plenty of Parish Councils are mentioned, some being tiny hamlets, but not Cockerham Parish Council. Other groups are invited - ramblers, canoeists, golfers, jet skiers, anglers, water skiers, rowers, windsurfers, cyclists, an „over 50 ‟s walking group ‟, a „watercraft club ‟ are all invited, but not the representatives of the very people whose lives you are blighting. There are 503 stakeholders listed, but not Cockerham Parish Council. Why is that? (This is not a rhetorical question). (h) Stakeholder Forum 1 - 5 November 2008 Presumably because you did not contact anyone at Thurnham or Cockerham, the area was not See answer to 5b. represented at Stakeholder Forum 1 meeting on 5th November 2008 at Lancaster House Hotel, Lancaster, yet a representative – a resident- from Sunderland Point was present, as well as someone from Overton parish Council (and someone from the Ramblers!). The minutes show that the person from Sunderland point made a reasonable job of putting his area forward for consideration, saying “The Sunderland Point conservation area forms part of the heritage in Lancaster”, yet nothing is minuted as representing the interests of Cockerham and Thurnham (apart from someone from the Environment Agency saying it is not responsible for the „high land ‟ at Cockerham as it is not considered to be part of the flood defence). (i) Stakeholder Forum Meeting 2 - 13 January 2009 Needless to say, I cannot see in the minutes a representative from the area at the Stakeholder Forum See answer to 5b. 2 meeting on 13 January 2009, and whilst one can see from the minutes others making representation for their own interest groups, nothing is said on behalf of Cockerham or Thurnham apart from a concern about the Abbey. The people who are most affected- whose houses, insurance prospects, livelihoods etc are on the line- have been given the least opportunity to be consulted; the people least affected- the canoeists, jet skiers etc- are consulted. What on earth is going on here? I am sorry to write in this level of detail, but I am trying to illustrate to you that what you have done is completely unfair: you have allowed consultation and decision making to go on by people and groups who have a vested interest in their own communities being protected, while ours has decisions made against it without any representation. Why did Ged McAllister not realise that no-one had been invited from Cockerham or Thurnham, and that this would explain their absence. Why did he not remedy this in time for the next stakeholder meeting? As we know this did not happen, and either he or Fiona Crayston failed to put a notice in the Lancaster Guardian heralding the opening of the public consultation (this has been admitted). As I said in my original objections, you could not have done a worse job of involving those whose lives you now ruin. 6. Judicial Review (a) I think I will be able to prove to a Judge that your handling of this matter has been, on a generous We have held 3 meetings with local people from Thurnham. view inept and incompetent, and possibly deliberately duplicitous. I will be relying, amongst other These and the written feedback that we have received have resulted in us changing the future coastal management policy things, on the ground of „unfairness or procedural impropriety ‟ due to your flawed consultation (against the guidelines and the regulations set out in paragraph 2 of my objections), the appearance of recommended in the SMP, so the accusation of predetermination bias and predetermination and breaches of the Human Rights Act in my application for Judicial and breaches of the Human Rights Act do not appear to hold up. Review, and have plenty of evidence furnished by yourselves of your many failings in this matter. I will Our previous approach specifically stated that a future study and argue that it will not be sufficient for the court to order you to carry out meaningful consultation further consultation would help to decide whether future now when decisions have been made over the years without consulting those who have a right to managed re-alignment was the right approach. give their input At no time did we state that such a policy would definitely be

25 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? implemented. (b) The very fact that the preferred options about Thurnham have changed, from „Scenario A and Local consultation has influenced changes to the proposed SMP policy. Scenario B ‟ (A = HTL across three epochs, B = MR in all 3 epochs), to „HTL while further investigations take place in epoch 1, MR for epochs 2 & 3 ‟, shows that there has been an opportunity to influence change, which you have denied the very people affected. (c) Looking at Appendix G (2.3.3)–Policy Scenario Testing, you have Scenario A and Scenario B. See answer to 5c Scenario A has HTL for each of these 4 sub-cells (Knott End, Knott End to Fluke Hall, Fluke Hall to

Cocker Bridge and Cocker Bridge to Glasson Dock) over all three epochs. Scenario B, predicated on the Jacobs Report, which took the Freedom of Information Act to get from you, has HTL for the first 3 of the sub- cells but for Cocker Bridge to Glasson Dock it has MR in all three epochs. Are you sure

that this would have been the same if there had been adequate consultation with the residents? Is this the result that was likely to occur precisely because they were not present? As by your own admission you have not costed these two scenarios, all you have achieved is uncertainty and property

blight- perhaps by blighting the land you fulfil your own prediction of its low value

(d) I cannot see that consultation now can alter decisions we should have been involved with in 2008. We cannot go back in time to that part of the process and therefore the only option for you is to See answer to 5c protect these defences. 7. The binding agreement 1948 You say that no-one has a right to be defended against flooding or erosion in all circumstances, and The 1948 agreement between the Catchment Board this is no doubt the case in most circumstances. However, not all residents of potential flood plains and Dalton Estates could only be provided to those people who have the benefit of a legally binding agreement (referenced in documents which again, had to be got own land included which was the subject of the agreement. The from you by FoI), which I think your lawyers will find on the most cursory examination of contract Environment Agency will respond to you separately regarding law, and in particular section 62 of the LPA, obliges you to maintain these defences. Your their legal opinion of this agreement. predecessor body signed a legally binding agreement, for a large amount of consideration in exchange Clearly it is for you to decide whether you wish to take legal for them maintaining this sea defence, and I have not seen or heard of any agreement which changes action. However, Judicial Review seems inappropriate given the this. The Coast Protection Act 1949 C74 (4.2) (possibly the very reason why the agreement was responses provided above and provided on other occasions in entered into) specifically states that “A coast protection authority may enter into an agreement with person and in writing to local residents. With regard to the any other person for the carrying out by that person or by the authority, on such terms as to Dalton Estates agreement, this is a matter that you should pursue payment or otherwise as may be specified in the agreement, of any coast protection work which the directly with the Environment Agency, through John Lymer in the authority have power to carry out under this Part of this Act”. first instance, if you decide there is merit in such action. Is it possible that you have picked the only patch of land with which you have a legally binding agreement, to attempt the renege on that agreement? I have already taken preliminary legal advice on this point and will bring an action to enforce the agreement. If you do not change your recommendation to protecting the sea defences, I will bring a claim for Judicial Review as well as a claim enforcing the 1948 agreement, with as much publicity as I can muster. I have tried to make you see that if you do continue with your recommendation, you leave us with no alternative but to fight it, as my parents have nothing left to lose if we do not. I am already in touch with Malcolm Kerby of NVCC (National Voice for Coastal Communities), who is very interested in how I get on in this regard. 8. Documents I require under the Freedom of Information Act The actual Agreement between the River Lune Catchment Board Authority and the Dalton Estate. The request for “documents I require under the Freedom of Information Act” and the other “information I require” was The Agreement by which you say the 1948 agreement was changed or bought out. withdrawn. All minutes of meetings of the River Lune Catchment Board Authority and its successor authorities

26 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? where this agreement was discussed All documentation- works orders, works schemes, completion forms- from 2000 to the present date, of works carried out to sea defences in cell 11c.

In your response to the Cockerham Forum you say: „Previous reports considered options but were

not adopted as firm proposals ‟. I would like copies of these reports.

All documents sent by way of instruction for the Jacobs Report.

This related to areas identified during the draft policy stakeholder All „further communication ‟ that you refer to at Appendix A 6.3 relating to the Thurnham cell, as well as the documents used when this further communication was „preceded by further review and / Elected Member meetings where policy units were split and consequently additional analysis had to be done or for areas consideration of the proposed preferred policies and the alternatives ‟ which had not been included and should have, eg Hilbre Island. None of this related to the Thurnham Cell. Similarly, I wish to see the documents referred to in Appendix A 6.3 where you say: „feedback from The request for “documents I require under the Freedom of the meetings, together with the conclusions from policy assessment, were used to modify the Information Act” and the other “information I require” was withdrawn. scenarios in order to develop draft „preferred scenarios ‟‟ for this sub-cell. 9. Information I require The actual amount spent on direct works, on the sea defences at cell 11c (2) (excluding central fixed costs or apportionments of overall departmental charges) from 2000 to 2010 The actual amounts spent on direct works, on the sea defences at cells 11c (1) and 11c (3) (excluding central fixed costs or apportionments of overall departmental charges) for the same period.

Have all the cells on this coastline been subjected to your „apportionment ‟ approach? If they have, I need to see your rationale for why the Thurnham cell is to be treated differently and not protected. If they have not, then why has the Thurnham cell been so treated? Who is Ian Rowlands and what is his role and title within the environment Agency? At the meeting of 15 December 2008 the list of attendees does not describe sufficiently who they were, eg, what area or group they represented. I require this information. Why Cockerham Parish Council were not invited to any of the Elected Member Forums or Stakeholder Forums The information Sam Cox was referring on when he said on 15 December 2008 “stakeholders have argued that it is causing issues in the Lune and should be returned to be a flood storage area”. I need to know exactly which stakeholders have identified exactly which issues and what „it ‟ means. PCR_104 11c 2.4 We have been in contact with the Parish Council in your area Revise headline policy in the 2 nd and 3 rd epochs to and there was a meeting arranged by local residents held at the “Hold the Line OR Managed Realignment” and Individual I have been looking at the consultation document regarding sea defences at Bank End. They are as Thurnham Institute that members of the project team attended. the approach to indicate “either maintain existing clear as mud. How is it that Bank End farm has only just found out about this. Is it then we can’t have The official consultation end date was the 14th February 2010, defences OR seek opportunities for managed any input whatsoever. We have only last week paid for and had sited a new caravan. So thanks a however response time was extended until the end of March for realignment”, depending on further consultation and million. Thurnham stakeholders. studies. In my Email earlier this week I asked questions about what you had in mind for the sea defences at In recognition of the strong concerns raised at consultation and Amend Action Plan to allow for ongoing consultation Bank end farm and the adjoining caravan sites. Also how is it that Bank end farm says they have only the need to consider alternative options for managing the existing with the Parish Council. just heard of this. These questions where totally ignored. Is this what you call consultation? An defences into the medium term, whether or not the primary explanation might help. defence is realigned, the headline SMP policy is now proposed to

27 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? change to “ Hold the Line OR Managed Realignment” in the 2nd and 3 rd epochs, The actual long term policy for this frontage and the approach will be developed in further consultation and studies proposed in the SMP Action Plan. PCR_107 11c 2.4 See other responses above and the response to the Cockerham Forum, 05/03/10. Individual, I am writing to express my deep concerns regarding the proposals contained in the SMP2 with direct Revise headline policy in the 2 nd and 3 rd epochs to Thurnham reference to the stretch of coastline from Bank End Farm, Cockerham to Glasson Dock. In recognition of the strong concerns raised at consultation and “Hold the Line OR Managed Realignment” and the need to consider alternative options for managing the existing the approach to indicate “either maintain existing The current proposals are to HTL for the next 0-20 yrs, after which to enter into a programme of defences into the medium term, whether or not the primary defences OR seek opportunities for managed MR. The preferred option is to have a set back defence from Thithebarn Hill, Glasson Dock to defence is realigned, the headline SMP policy is now proposed to realignment”, depending on further consultation and Norbreck Farm Cockerham. This will affect seventeen properties which includes domestic houses, change to “Hold the Line OR Managed Realignment” in the studies. farms and caravan parks, together with Cockersands chapter house which is a special monument. 2nd and 3 rd epochs, The actual long term policy for this frontage Amend Action Plan to allow for ongoing consultation Although I recognise that the EA guidelines in relation to caravan parks is that they are of low and the approach will be developed in further consultation and with the Parish Council. economic value and that they can be re-located. I would ask that a broader overview be adopted for studies proposed in the SMP Action Plan. several reasons. These parks were created many years ago and have been greatly improved, which has been achieved at considerable expense and effort by the owners. These sites provide a haven for people from the conurbations of Manchester and Liverpool to enjoy their leisure time. Indeed local businesses in the nearby villages welcome the influx of visitors during the spring, summer and autumn months as it provides a substantial financial boost. I strongly suspect that without these caravan sites the local pubs and garages would struggle to trade. In effect the closure of these sites would send a financial ripple effect across nearby villages. Domestic properties which would be affected in these proposals would be substantially reduced in value or lost. To their owner these houses are their main asset, having been achieved through prudent saving and physical toil. I am assured by the EA and Lancaster City Council reps that these proposals are necessary based on finances. The costs of maintenance of the existing sea defences have been calculated, but no figures are available for the costs of building a set back defence or for payment for compensation. To me it seems quite obvious that the costs of maintaining the current sea defence make financial common sense. The proposals, if approved, would mean that the aquifer would be contaminated by sea water. Is this not in direct contravention of current legislation and guidelines for which the EA has responsibility? This pollution is also likely to affect the bore holes in the surrounding area which are used to provide water for cattle. I also suspect that discharges from the Ashton with sewage works is also likely to contribute to the pollution of the aquifer. Cockersands Abbey (Chapter House) enjoys the status of SM and is thereby afforded legal protection. I note in the proposals that it would be a more appropriate setting if the area around it was reverted to salt marsh, as it would have been when it was erected. Although it is set on a piece of relatively high ground without sea defences in place the land on which it stands which consists of soft red sandstone, and erosion will mean that this monument will eventually be lost to the nation. The proposals also make mention of ecological benefits i.e. the opportunity to re-create salt marsh. By some this may be viewed as a benefit but I would point out that Thurnham Moss provides a valuable habitat for wildlife i.e. Barns Owls, Lapwings, Kestrels, Woodpeckers and other songbirds. This land in its current state provides winter grazing grounds for Pinkfeet Geese. There is also a healthy population of Brown hares and foxes. In conclusion I would suggest that it is wholly appropriate to maintain the existing sea defences beyond the 20 yr period and to adopt a policy of

28 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? HTL. PCR_108 11c 2.4 N Expenditure on flood defences is subject to national prioritisation Revise headline policy in the 2 nd and 3 rd epochs to and unfortunately it is unlikely to be affordable to defend “Hold the Line OR Managed Realignment” and Individual, I wish to protest in the strongest terms the plan under consideration to move the sea wall back to everywhere in future. the approach to indicate “either maintain existing Garstang allow flooding of the area around Bank End Farm and Bankfield Farm. defences OR seek opportunities for managed The SMP Action Plan proposes further studies to develop the These are two productive dairy farms on prime agricultural land which produce millions of litres of realignment”, depending on further consultation and approach, considering the impacts on agricultural land loss. milk per year. The farms support the livelihoods of the 3 families which own them and also of 3 full studies. Managed realignment of the defences would provide continued or time employees. There are also a large number of static caravans which could not be located to improved protection to the land behind the new defence line. Amend Action Plan to allow for ongoing consultation another area of the farm as the whole farm would be flooded. The land between the new defence line and the current defences with the Parish Council. My veterinary business would be adversely affected by this plan as these farms are among my biggest would not necessarily be lost, and change in use would depend

clients and the loss of business from this would decrease my turnover significantly. on frequency of inundation. There would be opportunities for alternative land use. In addition to the above reasons for my objection, I question whether the plan is economically viable. A new wall has to be constructed on purchased land and maintained. The land owners have to be The Environment Agency and Local Authorities have permissive compensated this would be a large sum. Surely the cost of this outweighs the cost of maintenance of powers to undertake flood risk management activities but do not the current wall many times! have a duty to do so. Unfortunately there is no right to flood protection or continuation of management of existing flood defences, and provided adequate notice is given, no right to compensation in relation to withdrawal from maintenance of defences. However, a claim for compensation may arise, for example if the existing defence were to be deliberately breached or dismantled and this was to expose properties to increased risk of flooding. The headline SMP policy is now proposed to change to “Hold the Line OR Managed Realignment” in the 2 nd and 3 rd epochs, The actual long term policy for this frontage and the approach will be developed in further consultation and studies proposed in the SMP Action Plan. PCR_109 11c 2.4 N See above responses and response to PCR_187 Revise headline policy in the 2 nd and 3 rd epochs to “Hold the Line OR Managed Realignment” and Individual, Areas of concern - our home and livelihood, wildlife - Ramsar site, Lune Estuary SSSI, SPA; Options for managed realignment would need to consider the the approach to indicate “either maintain existing Thurnham archaeology - Abbey Grade 1 listed building, Crook Farm Grade 2 listed building; bridleway and benefits of reducing flood risk to the area behind any new defences OR seek opportunities for managed footpaths. defence line, such as Glasson. realignment”, depending on further consultation and Cocker Bridge to Glasson Dock - objections to MR. Crook Farm has been farmed by the Gerrard The headline SMP policy is now proposed to change to “ Hold studies. family for several generations, always with the environment and wildlife at the forefront of policies. the Line OR Managed Realignment” in the 2 nd and 3 rd Amend Action Plan to allow for ongoing consultation (we entered into agreements with English Nature on management of SSSI and have higher level epochs, The actual long term policy for this frontage and the with the Parish Council. stewardship schemes on parts of our land.) approach will be developed in further consultation and studies proposed in the SMP Action Plan. At present 3 generations of the family are employed on the farm. There is a grade 2 listed farmhouse, barn and buildings as well as buildings to house animals and machinery. Cockersand Abbey is a scheduled ancient monument and listed as grade 1. This would all be endangered. We understand the proposal has arisen because of increased maintenance costs. From our perspective these costs have increased because there has been a lack of response to reports of minor damage resulting in a major repair because action has not been taken sooner. The major costs of flood defences will prove to be a waste of money at Glasson Dock if water comes overland. Glasson Dock could be completely inaccessible at high tide if Jeremy Lane cannot be used as an alternative route for buses and other traffic.

29 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? This proposal contravenes current government policy urging farmers to increase production of food, hence begs the question as to whether there is collaboration / communication between different departments and agencies. The cost implications of this proposal must be tremendous given the value of property and land in terms of compensation. There would also be the costs of creating a new bank on unstable foundations - buildings have required piling. We would be grateful for responses to our concerns and hope that maintenance of existing defences is chosen as the way forward. PCR_116 11c 2.4 The draft SMP policy allowed for maintaining the existing Revise headline policy in the 2 nd and 3 rd epochs to defences for up to 20 years. This is still the case, but further “Hold the Line OR Managed Realignment and Individual, I have read the above document and I am particularly concerned about the implications for Bank End studies are necessary to develop a long term approach beyond the approach to indicate “either maintain existing farm and caravan site. It would appear that if nothing is done to the sea defences along this stretch of this and these are proposed in the SMP. defences OR seek opportunities for managed coast they will fail within 6-10 years and the option of realigning them will result in flooding of the realignment”, depending on further consultation and farm and caravan site. As I own a caravan at Bank End I would appreciate some clarification of this studies. situation. Amend Action Plan to allow for ongoing consultation with the Parish Council. PCR_125 11c 2.4 Consideration has been given to residents and property owners. Revise headline policy in the 2 nd and 3 rd epochs to Additional consultation meetings have been arranged specifically “Hold the Line OR Managed Realignment” and Individual, Following the meetings at Lancaster House Hotel and at Thurnham Institute I feel the proposals for this SMP area. the approach to indicate “either maintain existing Glasson regarding the flood defence issue has been conducted very unprofessionally to date. No consideration defences OR seek opportunities for managed has been given to the residents, businesses and the holiday industry. I am now informed that residents In the past the bay has been subject to falling sea levels and realignment”, depending on further consultation and feel their homes are practically worthless. accretion of sediment and this has allowed reclamation and sea studies. defence to be undertaken fairly easily. When planning for the Being directly involved in agriculture I would be extremely interested to know what facts were made future we have to allow for accelerated sea level rise due to Amend Action Plan to allow for ongoing consultation aware as to the implications and effects this will have on the 10 dairy farms. Collectively these farms climate change, which will make maintenance of existing defences with the Parish Council. have approximately 1,500 milk producing cattle, plus all other stock i.e. calves, heifers and male cattle. increasingly expensive. In my own particular situation this would not only directly effect the milk producing enterprise but Expenditure on flood defences is subject to national prioritisation also my sheep business which accounts for some 1,000 ewes with lambs. Most of the farms in the and unfortunately it is unlikely to be affordable to defend effected area graze sheep for the hill farmers during the winter months. Perhaps you will make everywhere in future. available into the public domain the revenue generated against the actual cost of maintenance to the tidal bank from Bank End to Glasson taking into account that the last breach was in the late 1970's. PCR_126 11c 2.4 The SMP is a long term plan and has to allow for expected Revise headline policy in the 2 nd and 3 rd epochs to climate changes in the allowances stated by Defra. The draft SMP “Hold the Line OR Managed Realignment” and Individual, We are writing to you to strongly oppose your plan for this section of coastline. We personally have proposed to hold the existing defences for up to 20 years. In the approach to indicate “either maintain existing Thurnham almost finished renovating a 200/300 yr old Fisherman's cottage at Cockerham Sands at a cost in recognition of the strong concerns raised at consultation and the defences OR seek opportunities for managed excess of £100,000 (our life savings). We bought this house to retire to and now the uncertainty of need to consider alternative options for managing the existing realignment”, depending on further consultation and what the future holds is almost unbearable./ Your proposals have blighted 17 properties and 375 defences into the medium term whether or not the primary studies. caravan owners affected by this and made these properties and caravans un-saleable and thus of no defence is realigned, the headline SMP policy is now proposed to value. Not to mention hundreds of acres of productive farmland. Your proposal also has a profound Amend Action Plan to allow for ongoing consultation change to “ Hold the Line OR Managed Realignment” in the effect on farmers, businesses and other people who work in this area, which now cannot plan ahead with the Parish Council. 2nd and 3 rd epochs, ie up to 100 years. The actual long term policy or invest in their farms and businesses. Restaurants public houses, garages and a lot of other for this frontage and the approach will be developed in further businesses that cater for the residents, caravaners and tourists that come to this area will suffer. consultation and studies proposed in the SMP Action Plan. There is nothing to be gained for the wild life from your plan, for what you provide for one species Nature conservation bodies have developed national priorities will be a loss for another. There is also the question of the aquifer that runs beneath this area and its for wildlife habitats and species and creation of inter-tidal possible pollution. We are totally disgusted by the treatment we have had by the bodies concerned in habitats, which could be accommodated under a managed this plan. No local groups or individuals have been informed or represented in the years you have realignment option. been putting this plan together. I now believe that we have only until 14 Feb 2010 to put our views to you. We think you should extend this period to give people who are still unaware of you plan time to Policies for flood defences can change and recommendations by respond. We do not think many if any of the caravaners know of this plan. planning authorities will take into account the changing views on

30 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? We would like to know why people who have applied for planning permission to improve or build risk. The draft SMP has not yet been adopted as policy. properties in this area were not informed when planning approval was applied for. Surely the council The estimates were based on the same generic maintenance and has a duty of care to do this and why was it not revealed in the local searches when people purchased reconstruction costs rates used for the whole SMP. The SMP their property. We will be looking into this matter further. team do not have accurate costs on actual expenditure, which in You provided a figure of £12 million to maintain the sea defences in this area for the next 100 years. any case will not reflect future expenditure under the climate How have you reached this figure? Therefore I would like you to supply the method and calculations change allowances due to rising sea levels over the next 100 that you used to reach this amount, so that we may agree or disagree with you. Also could you please years. provide accurate figures of actual maintenance costs over the last 10 years? May I suggest that you Managed changes to the coastal defences could be designed to should take a look at the efficiency of your maintenance department? We have seen expensive benefit amenity usage. machines on hire standing idle for days and weeks. These sea defences are part of our seven-mile coastal walkway. This and our surrounding area are visited by thousand of walkers, bird watchers, photographers, cyclists, wind surfers, families and general tourists every year. The Cockersands Abbey attracts coach loads of tourists and historians alike. The farmland is of the very best quality where the local farmers are virtually self-sufficient growing their own crops and rearing livestock and dairy stock from these crops. We are a small- overcrowded country; we should be growing more crops and building more houses on our valuable land. Not flooding it! PCR_129 11c 2.4 See earlier responses including response to PCR_187. See above Individual, I wish to support whatever efforts are being made to resist the proposal to locate the sea defences Bolton on this stretch of the Morecambe Bay coast further inland. This is a very important and beautiful stretch of coastline which should not be allowed to become inundated. PCR_136 11c 2.4 See earlier responses including response to PCR_187. Individual, Firstly, may I say that it difficult to reply to a consultation document when I have never seen such a Invites to the public meetings were sent to stakeholders who Revise headline policy in the 2 nd and 3 rd epochs to Thurnham document, despite being affected by the outcome. My only knowledge that this process was in train have been involved throughout the process as well as Elected “Hold the Line OR Managed Realignment and was via a newspaper article and my subsequent call to you. Members and Parish Councils to disseminate the information. the approach to indicate “either maintain existing There were also Press releases drafted although we appreciate defences OR seek opportunities for managed It does appear that the “consultation” of “affected residents” has been carried out very selectively that this does not guarantee that a newspaper will run the story. realignment”, depending on further consultation and and that those responsible for the dissemination of the information have singularly failed in their duty, There have been some subsequent meetings following the public studies. in my view, to the point of maladministration. meeting on 8 th December, arranged by Sunderland Point Amend Action Plan to allow for ongoing consultation Whilst I live some distance from the coast, the flooding historically, when breaches have occurred, residents association, Thurnham Moss residents (David Ashurst) with the Parish Council. reach a level at the bottom of my property, where most of the land is at or below mean high tide, and Thurnham Parish Council which representatives of the and other residents on Moss Lane have, equally, not been informed of this debate. project team have attended. May I ask some questions please that I feel are pertinent: Defra Guidance states that policies need to be realistic, taking into account existing legislation and likely future funding, whilst 1 What is the justification for the loss of hundreds of hectares of agricultural land, when we are all also flexible enough to adapt to changes in legislation, politics and being told that we will need to grow more crops to produce biofuels [or are we to pray that the social attitudes. The policy of holding the line should not wind blows 100% of the time at the required strength to produce all our energy needs?], not to automatically be adopted. Other policies should be thoroughly mention the loss of livelihood, loss of property values and disruption for residents? assessed and compared, including a broad assessment of the longer-term costs and the effects on natural processes. Government policy is to take a risk based approach to managing coastal change and flood risk. It is not possible or sustainable to defend everywhere. The Environment Agency and Local Authorities have permissive powers to manage coastal and flood risks to communities and assets where it is technically feasible, environmentally sustainable and economically viable to do so.

31 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Investment in defences is subject to national prioritisation against outcome measures specified by central government and it is not affordable to defend everywhere. Policies have therefore been chosen by taking into account technical, environmental, social and economic factors, including whether the policy is practical and affordable in the long term, in line with the Government’s strategy for managing coastal flooding and erosion. Local factors have also been considered when deciding the most appropriate policy. 2 Who will make the decision – when and on what grounds, under what authority and what is their Development of this SMP2 has been led by a Project Management public accountability. I understand the asset team comprises multiple authorities and interested Board made up of members of the North West and North Wales parties, some [many?] of them unelected and pursuing individual interests. What are the criteria being Coastal Group, including technical officers and representatives considered in this case. The maintenance of the existing wall is hampered by the nature conservancy from Coastal Local Authorities, the Environment Agency, Natural interests, ignoring the fact that the natural species rely on the sea wall for protection and habitat. Try England and English Heritage. The Project Management Board has as I may, I cannot recall either the local or national governmental or quasi-governmental groups been assisted by Client Steering Groups (covering the Sub-Cell having a public debate on this policy or it being part of any government policy document or shorelines) and an Environmental Sub-Group set up to oversee manifesto. and review the environmental aspects of the Plan. More and more these policies are invented under “enabling acts” and not being scrutinised by our The SMP2 development has been greatly assisted by inputs from elected representatives. It is left to local individuals to reap the consequences. a large number of stakeholders, whose views have been sought at key decision-making points. Many of these stakeholders participated in the policy development process via Stakeholder Forums. A number of rounds of Stakeholder Forum meetings have been held at locations across North West England and North Wales. These have helped to identify and understand the issues, review the objectives, set direction for appropriate policy development, and review and comment upon the proposed SMP2 policies. In addition, all decisions made have been reviewed by a group of Elected Members (Local Councillors) and the Environment Agency’s Regional Flood Defence Committee where appropriate to get input into policy development from those who will ultimately need to adopt or support the SMP2 policies. The proposed policy in the draft SMP for Policy Unit 11C 2, Cocker Briddge to Glasson Dock, for the short term, 0 to 20 years is “Hold the Line – By maintaining existing defences while undertaking studies to investigate opportunities for managed realignment and implement where practicable. Further investigations should include assessing impacts on the Lune Estuary and agricultural impacts. Subject to investigations within this period, implement managed realignment policy where practicable.” The proposed policy for the medium term and long term are: “Managed Realignment – Depending on further studies, seek opportunities for managed realignment to create more

32 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? sustainable and economically and environmentally viable defence alignments in terms of both erosion and flooding.” The draft SMP2 therefore proposes that feasibility studies and consultation are undertaken to determine the best way forward and the decision to whether to realign the defences or not will be undertaken after these further studies have taken place. 3 Presumably, as always, cost is a factor in reaching the decision. Can I please see the cost The SMP2 covers a very large area and has used broad scale justification, and an assurance that the figures used are realistic, and will not increase exponentially as estimates of cost for different types of defence. The estimated time passes [ as the costs of the proposed Lancaster by-pass have done? ] What are the procedures costs and benefits for the preferred policy are given in the for compensation both for direct and indirect loss? appendices to the draft SMP. The total costs for frontage 11c 2.4 over the 100 year period is estimated as £12 million. The Environment Agency (and Lancaster City Council) has ‘permissive powers’ for sea defence, but this doesn’t confer a right to protection or a particular standard of protection. If we adopted a policy of ‘no active intervention’ (or ‘do nothing’ in other words) and withdrew from maintenance of a sea defence (after giving between 6 months and 2 years notice to those affected) no compensation would be payable. Others would need to then maintain the defences otherwise they would deteriorate. The least cost option to central and local government is therefore No Active Intervention. The benefits of provision of defence are accrued from avoidance of national economic damages to properties and infrastructure and avoidance of flooding or write-off of agricultural land. The benefit / cost ratio, after discounting future benefits and costs to present day values using the test discount rate specified by Treasury was determined by the SMP to be significantly greater than 1 and therefore a viable policy, but these estimates would be subject to review in more detailed feasibility studies recommended. 4 Presumably, again, the “managed retreat” will require substantial earthworks, with both short and The SMP has identified where there are managed realignment long term impact on traffic. The previous approved proposals – which envisaged REINFORCING the opportunities but has not attempted to confirm realignment wall, required some 250,000 tonnes of rock armour to be transported down Moss Lane – which extents. The SMP recommends that more detailed studies are would require “improving” What is the impact on the local infrastructure with this scheme? - and, as carried out at Strategy Study level, before any realignment policy a matter of interest, why the substantive change in policy? is implemented or realignment scheme is undertaken. These studies would need to consider potential impacts at a local and regional scale taking into account current land use and risks and opportunities. Details relating to groundwater and saline intrusion will also be taken into consideration at this time. A timetable of further studies to assess managed realignment opportunities will be included in the SMP Action Plan and we welcome responses to the draft Action Plans for each policy area in the consultation documents. The actual design of defence schemes etc will be considered at Strategy and Scheme level and therefore are not considered at the broad scale SMP level.

33 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? 5. The criteria seems to be somewhat flexible, seemingly dependant on population [ and it’s ethnicity Defra has national policy responsibility for flood and coastal ] – and cost benefit. Is this not discrimination of the worst kind? erosion risk management and provides funding through grant in aid to the Environment Agency which also administers grant for capital projects to Operating Authorities. In 2009-2010, the Environment Agency will spend £700 million managing flood and coastal erosion risk across the UK. This budget has more than doubled from 10 years ago, and is set to increase by an estimated £100 million in 2010- 2011. In Wales, the Welsh Assembly Government is responsible for developing flood and coastal risk management policy and largely funds flood and coastal activities undertaken by operating authorities across Wales. Despite this large commitment, the scale of coastal erosion and flood risks means we must prioritise projects to ensure we achieve the best possible results. Realistically, it is not possible to justify defending all locations to the same standard or in some cases at all. Coastal defences often protect against both coastal flooding and erosion. Inland flooding is also affected by how we manage coastal defences. Funding for coastal and flood defence is therefore linked. In each case, the Environment Agency employ a set of agreed indicators called 'outcome measures' to measure how effectively economic, social and environmental needs are met. Public money is used as effectively as possible to reduce the risk to coastal communities, their property, infrastructure and the natural environment. Decisions on where to defend are based on risk assessment using a transparent, auditable and understandable process. Factors considered include : • Number of households at risk. • Number of deprived households at risk. • Impact of our actions on agricultural land and the farming community. • Impact of our actions on the environment and wildlife. • Whether erosion affects local community infrastructure and transport. • Cost of building and maintenance. Source: http://www.environment- agency.gov.uk/homeandleisure/107641.aspx 6 The previous study showed higher than acceptable levels of radiation on the current shoreline, The Draft SMP policies for this area are Hold the Line in the suggesting that workers would require protective clothing. Is there a danger that this proposal would short term (0-20 years) while conducting studies into opportunities for managed realignment in the medium (20-50

34 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? allow leaching to marginal land? years) to long term (50-100 years). These studies will directly inform the medium / long term policy for this location and will include detailed economics, potential realignment positions as well as investigations into potential contamination issues. Please note that the Draft SMP policy of managed realignment in the medium and long term may therefore change if the studies conclude that this policy is not appropriate / viable. 7. I am sure that part of this process is promulgated by the theoretical potential for increased sea An important consideration in the SMP assessments is the levels. This is a dubious and controversial area and, whilst it is not acceptable to do so, open to possible long-term impacts of climate change and sea level rise. serious scientific challenge. Where is the evidence for this? Over the century timescale, these may include the complete loss of beaches due to intertidal squeeze and the need for I am sure that there are many more questions that could be asked, but I repeat, without being given substantially larger defences to maintain the current standards of the opportunity to discuss the plans it is difficult, at this time, to comment further. protection. The SMP2 has used the Defra (2006) guidance on climate allowances and sensitivity ranges, in support of Planning Policy Statement 25 (PPS25) ‘Development and Flood Risk’, which advised on how these allowances should be broadly applied in flood and coastal management. These updated Defra allowances are consistent with the estimated net sea-level changes described by UKCIP in the document “Updates to regional net sea level change estimates for Great Britain ” (December 2005), which was a supplement to the UKCIP02 scenarios. Sea level rise allowances (not predictions) that we are asked to work to are 2.5mm per year for the next 15 years, increasing to 7mm, then 10mm, then 13mm per year for 30 years each time. The allowances give: 290mm sea level rise by 2059 – 300mm in round figures 870mm sea level rise by 2109 – 900mm in round figures Actual sea level rise could be a bit less, or a lot more - the allowances are derived from scientific research and temperature increase scenarios. Observed sea level rise over the last century is about 100mm for the North West. These sea level rises, if they occur, would greatly reduce the standard of protection of existing defences unless they are raised. The draft SMP proposed to hold the existing defences for up to 20 years. In recognition of the strong concerns raised at consultation and the need to consider alternative options for managing the existing defences into the medium term, whether or not the primary defence is realigned, the headline SMP policy is now proposed to change to “Hold the Line OR Managed Realignment” in the 2 nd and 3 rd epochs, The actual long term policy for this frontage and the approach will be developed in further consultation and studies proposed in the SMP Action

35 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Plan. PCR_140 11c 2.4 N Depending on the approach to be developed at the more detailed Revise headline policy in the 2 nd and 3 rd epochs to stage, managed realignment would not necessarily preclude local “Hold the Line OR Managed Realignment” and Councillor, Concerned about the Cockersands Chapter House and foundations which are 3ft high under the defences to provide erosion protection to the scheduled the approach to indicate “either maintain existing Pilling and ground. monument or indeed other properties. defences OR seek opportunities for managed District The area was excavated in 1920 it extends to the present sea wall a very important monastic site. realignment”, depending on further consultation and Historical The draft SMP proposed to hold the existing defences for up to This area needs protection for future history. We feel this will cost more in the future if the sea wall studies. Society 20 years. In recognition of the strong concerns raised at is not put in place. Do the heritage people not have a say in the saving of the land etc. consultation and the need to consider alternative options for Amend Action Plan to allow for ongoing consultation We feel this needs protection and the sea wall needs to be in place what a great loss this would be to managing the existing defences into the medium term, whether with the Parish Council. the future we need our history even at a cost we have lost so many wonderful historical buildings. or not the primary defence is realigned, the headline SMP policy Also farms would be lost and land the government of the day need more growing areas we hope this is now proposed to change to “ Hold the Line OR Managed will be taken into consideration. Realignment” in the 2 nd and 3 rd epochs, i.e. up to 100 years. The actual long term policy for this frontage and the approach will be developed in further consultation and studies proposed in the SMP Action Plan. PCR_142 11c 2.4 N In the past the bay has been subject to falling sea levels and Revise headline policy in the 2 nd and 3 rd epochs to accretion of sediment and this has allowed reclamation and sea “Hold the Line OR Managed Realignment” and Individual, Concerned about caravan parks, the wildlife, the abbey, the walks, people who wish to jet ski, wind defence to be undertaken fairly easily. When planning for the the approach to indicate “either maintain existing Manchester surf on the estuary, the people who will lose their home's farms, and their livelihoods. future we have to allow for accelerated sea level rise due to defences OR seek opportunities for managed Some farms have been passed down from father to son. This is a way of life for these people, this is climate change, which will make maintenance of existing defences realignment”, depending on further consultation and part of the English way of life and you wish to destroy this way of life for this part of the country. My increasingly expensive. Expenditure on flood defences is subject studies. vote is no. to national prioritisation and unfortunately it is unlikely to be Amend Action Plan to allow for ongoing consultation affordable to defend everywhere in future. with the Parish Council.

PCR_150 11c 2.4 N See responses above. Revise headline policy in the 2 nd and 3 rd epochs to “Hold the Line OR Managed Realignment” and Engineering 1st epoch HTL followed by managed realignment causing uncertainty and property blight - further The headline SMP policy is now proposed to change to “ Hold the approach to indicate “either maintain existing and Projects, discussion required. the Line OR Managed Realignment” in the 2 nd and 3 rd defences OR seek opportunities for managed Lancaster City epochs, i.e. up to 100 years. The actual long term policy for this realignment”, depending on further consultation and Council frontage and the approach will be developed in further studies. consultation and studies proposed in the SMP Action Plan. Amend Action Plan to allow for ongoing consultation

with the Parish Council. PCR_151 11c 2.4 N This is not correct. Revise headline policy in the 2 nd and 3 rd epochs to “Hold the Line OR Managed Realignment” and Individual The affect this will have on established communities, absolutely no consultation with those affected by The consultation draft policy for Glasson, PU 11c 3.1 proposed the approach to indicate “either maintain existing these changes which clearly is a deliberate and cynical policy decision taken by unrepresentative to Hold the Line in short, medium and long term. For Cocker defences OR seek opportunities for managed quangos determined to stifle opposition in order to give legitimacy to what is effectively shabby, ill bridge to Glasson the proposed policy was to Hold the line for realignment”, depending on further consultation and informed and amateurish reports. up to 20 years while further consultation and studies were studies. undertaken to develop a long term plan for the frontage, which We have been informed, by Ged McCallister of Lancaster City Council, that the sea defences at was expected to involve managed realignment of at least some of Amend Action Plan to allow for ongoing consultation Glasson will be removed, and that affected residents will not be compensated for the impact this will the defences. with the Parish Council. have on their assets. The area is already at flood risk. The risks are expected to We bought this property in 2004, after receiving assurances from the Environment Agency that there increase in future due to rising sea levels. It is appropriate for the were no plans to change these defences. Environment Agency and Local Authorities to plan for long term In addition we believe that this property benefits from an agreement made in the early part of the last changes in coastal risks and it will not be affordable to continue century, between the Daltons, the then owners of the estate, and those whose responsibilities have to maintain all existing defences to the current standard of

36 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? now been inherited by the Environment Agency (EA), that they EA will continue to maintain the sea protection. defences, if they now or in the future renege on that agreement then we will expect to be The Environment Agency and Local Authorities have permissive compensated. powers to undertake flood risk management activities but do not Clarkson’s Farm is a listed building, and as such we have invested a considerable amount of our have a duty to do so. Unfortunately there is no right to flood money in renovating this building, to a standard required by the conservation office of Lancaster City protection or continuation of management of existing flood Council. defences, and provided adequate notice is given, no right to compensation in relation to withdrawal from maintenance of On several occasions we have been instructed by them to utilise materials and adopt designs that defences. However, a claim for compensation may arise, for would be inappropriate for any building that may be required to resist the impact of a flood being example if the existing defence were to be deliberately breached predicted in Jacobs 2008. or dismantled and this was to expose properties to increased risk The planning directorate at Lancaster City Council is fully accountable for decisions they take, and as of flooding. a consequence we would expect them to compensate us for the impact of any of those diktats. Additional consultation meetings have been held for this specific This highlights the duplicity of Lancaster City Council and its conservation office in that they are policy unit with the parish council, representing the Cockersands planning with the EA to increase flood risk into this area and then deny residence the opportunity to Forum. protect themselves against it. The draft SMP proposed to hold the existing defences for up to The area affected by this scheme includes two Grade II listed buildings, and one Grade I listed building 20 years. In recognition of the strong concerns raised at in Cockersands Abbey, which is in fact a National Monument and is protected in law, to suggest, as consultation and the need to consider alternative options for Jacobe 2008 does, that in the event of flooding Cockersands Abbey would become a quaint little managing the existing defences into the medium term, whether outpost, surrounded by water, that would in fact enhance its appearance, beggars belief, and we can or not the primary defence is realigned, the headline SMP policy only assume that this particular piece of poetry was in fact composed by an idiot. is now proposed to change to “Hold the Line OR Managed Realignment” in the 2 nd and 3 rd epochs, The actual long term The removal of the sea defences would considerably weaken the ground underpinning the policy for this frontage and the approach will be developed in foundations of the Abbey, and there is no question that in turn this would depreciate and eventually further consultation and studies proposed in the SMP Action destroy the structure. This in turn highlights the hypocrisy of English Heritage which obtains large Plan. amounts of taxpayers’ money in the guise of protecting the countries heritage, and then is found absent when such an opportunity presents itself. Presumably spending its ill gotten gains on fictitious garden projects. There is a claim that the removal of the current sea defences and rebuilding them further back would provide better protection, but in reality such a manoeuvre would put many more homes and businesses at risk of flooding, the costs of rebuilding such defences would be far in excess of that required to maintain the current scenario. The documentation (Jacobs 2008) lists Clarkson’s Farm as being one property, in fact it is a complex of three separate properties. Given that this information would be easy to accurately report suggests that other content has in fact been compiled with an equally unprofessional manner. This proposal would decimate the community of Thurnham, which would cease to exist, the loss of business and farming activity would also have a major impact on the surrounding area. We as residence affected by these proposals had not received any information relating to them till November 2009, where a poorly organised presentation was held at the Lancaster Hotel. Nobody was informed of this meeting through any official channel, although Lancaster City Council claim to have announced in the local press, our investigation failed to find any evidence to support this, and the newspaper it was supposed to have been announced has no record of it. These discussions have been ongoing in excess of ten years and not one person, or official representative of the Thurnham community has been invited to any of these meetings. Was this an oversight that those with most to lose, and most likely to oppose the scheme were not represented, almost certainly not, but a deliberate and cynical policy designed to stifle opposition till

37 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? it was too late to be properly organised. The organisers of these meeting whether they are Lancaster City Council or the Environment Agency should hang their heads in shame at this deliberate attempt to steal our assets without giving us the opportunity to speak. The economical arguments presented in this proposal do not add up, and we can only suspect that there is another agenda that the relevant authorities are keeping from the general public, yet again undermining the democratic process, the amount of representation given to organisations that have no demographic support would also support such an hypothesis. PCR_152 11c 2.4 N The draft SMP proposed to hold the existing defences for up to Revise headline policy in the 2 nd and 3 rd epochs to 20 years. In recognition of the strong concerns raised at “Hold the Line OR Managed Realignment” and Individuals, We were greatly alarmed to recently hear from our neighbours of your proposals to realign the flood consultation and the need to consider alternative options for the approach to indicate “either maintain existing Thurnham defences between Cocker Bridge and Glasson Dock. From what we are able to establish we believe managing the existing defences into the medium term, whether defences OR seek opportunities for managed at some future date this may well impact on our property which is situated in Moss Lane, Thurnham. or not the primary defence is realigned, the headline SMP policy realignment”, depending on further consultation and We must express our great concern, that despite the likelihood of some impact on our property in is now proposed to change to “Hold the Line OR Managed studies. the future, we have not received any communication from yourselves. On the basis of this lack of Realignment” in the 2 nd and 3 rd epochs, The actual long term communication on your part we feel we must express our objection, at least until such time as clear Amend Action Plan to allow for ongoing consultation policy for this frontage and the approach will be developed in information is provided to ourselves with regard to your plans. with the Parish Council. further consultation and studies proposed in the SMP Action Plan. PCR_153 11c 2.4 Acknowledgement of the existing flood risk is noted. The risks Revise headline policy in the 2 nd and 3 rd epochs to are expected to increase in future due to rising sea levels. It is “Hold the Line OR Managed Realignment” and Individual, My family have lived in our house on Moss Lane for nearly 50 years. Our home was flooded in the N appropriate for the Environment Agency and Local Authorities to the approach to indicate “either maintain existing Thurnham 1977 flood when the sea broke the sea wall. plan for long term changes in coastal risks as it will not be defences OR seek opportunities for managed Obviously any realignment of the flood defences around Cockersands would greatly affect us. affordable to continue to maintain all existing defences to the realignment”, depending on further consultation and current standard of protection. studies. Firstly, if as we do not get the Lancaster Guardian every week, could you or someone, please explain to me how we would have been made aware of your plans? Why have we not been informed? The Environment Agency and Local Authorities have permissive Amend Action Plan to allow for ongoing consultation powers to undertake flood risk management activities but do not with the Parish Council. Please note my objections to your plans, that they are submitted and will you also in the future make have a duty to do so. Unfortunately there is no right to flood sure the people who should be made aware who will be affected by your proposals are made aware. protection or continuation of management of existing flood Maybe you could start with my neighbours? defences, and provided adequate notice is given, no right to Our house is up for sale, despite the fact that it has stood here for hundreds of years, these compensation in relation to withdrawal from maintenance of proposals make it unsalable. I cannot help but think that you or someone is liable in your negligence defences. However, a claim for compensation may arise, for in your duty with regard to all this in how it all affects us. example if the existing defence were to be deliberately breached or dismantled and this was to expose properties to increased risk I would be very grateful if you would contact me to say this email has been received and that my of flooding. objections have been forwarded. Personally, ecologically, economically and environmentally. The draft SMP proposed to hold the existing defences for up to 20 years. In recognition of the strong concerns raised at consultation and the need to consider alternative options for managing the existing defences into the medium term, whether or not the primary defence is realigned, the headline SMP policy is now proposed to change to “Hold the Line OR Managed Realignment” in the 2 nd and 3rd epochs, The actual long term policy for this frontage and the approach will be developed in further consultation and studies proposed in the SMP Action Plan. PCR_155 11c 2.3 N The draft SMP proposed to hold the existing defences for up to Revise headline policy in the 2 nd and 3 rd epochs in 11C 20 years. In recognition of the strong concerns raised at 2.4 to “Hold the Line OR Managed

38 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Individuals, 11c 2.4 consultation and the need to consider alternative options for Realignment” and the approach to indicate “either Cockerham managing the existing defences into the medium term, whether maintain existing defences OR seek opportunities for Our Concerns for the proposals are as follows – or not the primary defence is realigned, the headline SMP policy managed realignment”, depending on further - The immense loss of valuable/productive agricultural land and property is now proposed to change to “Hold the Line OR Managed consultation and studies. Realignment” in the 2 nd and 3 rd epochs, The actual long term - The devaluation of further assts and property Amend Action Plan to allow for ongoing consultation policy for this frontage and the approach will be developed in with the Parish Council. - The detrimental effect upon leisure and tourism in the area further consultation and studies proposed in the SMP Action Plan. - The effect/loss of wildlife habitats - The loss of Cockersands Abbey – a scheduled monument - The effect upon the main A588 road from Lancaster to Blackpool – it will become tidal!!! - The cost implications as land owners would have to be paid compensation for the loss of land as each one contributed for the reclaimed land when the bank was built. Agricultural land does not come cheap! - These proposals are economically unviable and ill-conceived. Looking after the existing defences and clearing silt build up is far more viable and sensible PCR_166 11c 2.4 Adaptation to change under a Managed realignment policy would As above support natural processes and allow for localised protection or Individual, I would like to see the existing Cockerham Sands coastline preserved without new sea defences being excavation and recording of Cockersands Abbey in future. Lancaster built which will result in the loss of this very fine estuary site. I understand that erosion by the sea will in the course of time change the coastline, but I think this natural process should not be interrupted. I also think that it is important to retain the site as it is to preserve the remains of Cockersands Abbey for us to appreciate and perhaps to further excavate before it is inevitably lost to the sea. PCR_168 11c 2.3 Y – The SMP action plan allows for more detailed local consultation Add action to action plan to include PC as Epoch and studies to investigate opportunities into potential Managed stakeholders. Keep them informed of any changes etc Pilling Parish MR is an area of concern 1 Realignment for the epochs 2 & 3. and ensure they form part of the stakeholder group Council At present the problems facing Pilling are making sure the water from channels, farmland and water for any further studies undertaken. N – Managed realignment for this frontage could involve improving a courses gets away through the sea wall. But the silting up of the doors is a growing problem with the Epoch line of secondary defence seaward of the road or in a similar Amend policy statement wording to clarify that MR rising sand. The Parish Council is looking to the Environment Agency and Natural England to work 2 & 3 location to the previous historical defence line. In the long term, could involve a secondary line. together to alleviate this. withou with sea level rise this could become the primary line again. Amend headline policy in second epoch to be Since its construction the sea wall has settled and the Parish Council would need assurances that it t The standard of protection provided by the defences would need consistent with that of PU 11c 2.4, which shares that still has sufficient height to cope with the adverse conditions and protect Pilling. consult to be assessed at a more detailed level, so need to add this to the same flood cell. ation The Parish Council insists that through regular reviews there is dialogue with local Parish Councils Action Plan. with Add item to Action Plan to review the present and Agencies and that this is conveyed to residents. There must be regular dialogue with the 'new' local In order to be consistent with the approach for 11c 2.4, which standard of defence. landowners, that were created when the sea wall was built as they will be impacted most severely. residen shares the same flood risk cell the proposed approach in the

Protection of the highway, A588, must be protected and the cost should be weighed against the ts medium term will be revised to “ Hold the Line OR Managed continuing maintenance of the sea wall, should the tides ever be considered to breach the sea wall. throug Realignment ” h the This consultation should be followed by a by-annual consultation when the agencies inform and Parish update residents on the present and future situations concerning the shoreline. To include: local Counci Parish Councils, Wyre Borough Council, Natural England, Environment Agency, United Utilities and ls. Lancashire County Council The Parish Council and residents were most appreciative of the visit by Carl Green, Wyre Borough Council, when he explained the plan and took questions. His level of knowledge was conveyed well and easy to listen to.

39 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_169 11c 2.4 The Environment Agency and Local Authorities have permissive Revise headline policy in the 2 nd and 3 rd epochs to powers to undertake flood risk management activities but do not “Hold the Line OR Managed Realignment” and Individual, I write as the daughter of XXX and a past resident of Crook Cottage, Thurnham, to protest in the N have a duty to do so. Unfortunately there is no right to flood the approach to indicate “either maintain existing Lancaster strongest terms over the plans not to maintain the current sea defences from Cockerham to Glasson protection or continuation of management of existing flood defences OR seek opportunities for managed Dock. defences, and provided adequate notice is given, no right to realignment”, depending on further consultation and After becoming aware of the predicament that my parents find themselves in, little more than 3 compensation in relation to withdrawal from maintenance of studies. weeks ago, it is clear that we have a very unsatisfactory situation where the findings of the research defences. However, a claim for compensation may arise, for

and investigations are highly questionable. There are serious flaws highlighted in the presentation by example if the existing defence were to be deliberately breached the Cockersands Forum (being submitted this week), which highlights many incompetencies in the or dismantled and this was to expose properties to increased risk handling of this matter. of flooding. It seems the Environment Agency has not acted reasonably and they have seriously breached the The draft SMP proposed to hold the existing defences for up to human rights of my parents and many other residents of the Thurnham and Cockerham area. They 20 years. In recognition of the strong concerns raised at have not allowed sufficient opportunity to make representations before the closing date of 14th consultation and the need to consider alternative options for February 2010. Also, “No one can be deprived of the unimpeded use of his or her land except in the managing the existing defences into the medium term, whether public interest”. or not the primary defence is realigned, the headline SMP policy is now proposed to change to “Hold the Line OR Managed It would seem that insufficient research has been undertaken to ensure that the agency does not have Realignment” in the 2 nd and 3 rd epochs, The actual long term a case brought against them for this very reason, as it has not been thorough enough to prove that policy for this frontage and the approach will be developed in the proposed changes are in the public interest. further consultation and studies proposed in the SMP Action It is quite astounding that there has been such disregard for the residents of the Thurnham and Plan. Cockerham area who have had the sea wall maintained for hundreds of years and to then potentially See comment on PCR_187. have this removed without proper consultation or consideration is beyond belief. The financial consequences are clearly not only for the residents and business owners but for the county as a whole in terms of the potential lost income generated by the businesses in this area. As for the environmental benefits, these have clearly not been considered thoroughly either, as the impact on the existing wildlife would be catastrophic and there would be no guarantees that the area either in front or behind the proposed new sea wall would be improved in terms of habitat. All these points I refer to are contained in the Cockerham Forum document being submitted this week. The proposals will be a complete desecration of a hugely important part of the UK coastline, with implications for the history and heritage of the north west of England, impacting many people, not just the residents and business owners in the area. I will not rest on my laurels and let this happen and whilst you will no doubt be receiving objections from the local people, I can assure you there is a much wider audience that would object to the desecration of this coastline should the need arise. PCR_172 11c 2.4 It has been recognised for many years that the coastal defences Revise headline policy in the 2 nd and 3 rd epochs to between Cocker Bridge and Glasson would need significant “Hold the Line OR Managed Realignment” and Individual, We write in regard to the proposed Shoreline Management Plan 2 and in particular the Cockerham N investment if they are to be sustained into the medium to long the approach to indicate “either maintain existing Cockerham /Thurnham area. term. SMP1 indicated that a capital scheme would be required defences OR seek opportunities for managed Like everybody else in the area we can not believe the sheer audacity of this scheme with very little within 5 to 10 years to deliver the preferred Hold the Line policy realignment”, depending on further consultation and consultation with local people in what clearly has been a scheme that has been considered for several in this area. This is why the council and the EA have been trying studies. years, we find it totally unacceptable that no consideration at all has been given to the devastating very hard over the last ten years to justify doing something. In Amend Action Plan to allow for ongoing consultation effect that this hair brained project will have on the lives and incomes of many families. 2004 studies were unable to justify improvements, and found that with the Parish Council. the Hold the Line policy proposed by SMP1 was uneconomic, The agricultural land is high quality and there is no justification at all especially when British food with the benefit/cost ratio (BCR) less than 1. Under government production is rapidly becoming a high priority for it to be destroyed by this scheme. rules the BCR needs to be greater than 1 for public investment Common sense which is obviously sadly lacking from the proposers of this scheme should prevail and to go ahead (and generally over the last ten years the BCR has the continued maintenance and indeed even improvement of the existing banks would be the needed to be over 5 to have a reasonable chance of a scheme

40 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? cheapest and easiest proposal. qualifying for national grant aid). We all live here, we DO NOT NEED out side interference from misinformed government agencies See comment on PCR_187. and councils trying to organize and manage things they know little about, from the madness of not being able to work on the seaward side of the walls to maintain them because of strict environmental rules to the obvious high cost of all the feasibility and consultation we have had enough, and we will fight to defend all that we own and love for as long as it takes. PCR_187 11c 2.4 N Coastal defence “Operating Authorities”, such as the Revise headline policy in the 2 nd and 3 rd epochs to Environment Agency, and its predecessors and Lancaster City “Hold the Line OR Managed Realignment” and Cockersands 1/ There have been over 10 years of activities (e.g., Morecambe Bay Shoreline Management Plan Council have permissive powers such that they can undertake the approach to indicate “either maintain existing Forum Partnership, 1999) concerning the possible realignment of historic flood defences around public works to manage coastal risks where they can justify doing defences OR seek opportunities for managed Cockersands, co-ordinated by The North West England and North Wales Coastal Group (SMP2) and so. realignment”, depending on further consultation and its forerunner, without any representation of the Thurnham parishioners, either businesses or studies. inhabitants (see e.g., B2-24 to B3-18: NWE&NWCG, 2009; hereafter referred to as SMP2, 2009). Justification of public funding of works to manage coastal defences has to be approached in accordance with government Amend Action Plan to allow for ongoing consultation

guidance developed in accordance with Treasury rules. For with the Parish Council and the Cockersands around 20 years or more the government rules have required Forum . consideration of a wide range of options when considering public investment in coastal defence, including a baseline case of Do Nothing, which under the latest SMP guidance is now referred to as No Active Intervention. This Do Nothing baseline is then compared against alternatives such as Managed Realignment, Sustain or Improve Defences. The reality is that national funding for coastal defence schemes is limited and schemes have to compete for funding. The ranking of schemes seeking funding takes into account the national economic return on the investment and potential contributions towards a number of other national outcome measures set by government, such as numbers of houses protected and the area of habitats preserved or created. It has been recognised for many years that the coastal defences between Cocker Bridge and Glasson would need significant investment if they are to be sustained into the medium to long term. SMP1 indicated that a capital scheme would be required within 5 to 10 years to deliver the preferred Hold the Line policy in this area. This is why the council and the EA have been trying very hard over the last ten years to justify doing something. However, the 2004 studies were unable to justify improvements, and found that the Hold the Line policy proposed by SMP1 was uneconomic, with the benefit/cost ratio (BCR) less than 1. Under government rules the BCR needs to be greater than 1 for public investment to go ahead (and generally over the last ten years the BCR has needed to be over 5 to have a reasonable chance of a scheme qualifying for national grant aid). SMP 2 has been informed by prior studies, so only now is the possibility of managed re-alignment in 20 years time being put forward as a preferred policy for consultation. Different policy options remain as ‘options’ until the SMP is finalised - no decisions affecting these were taken in the last few years.

41 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? We have accepted that our approach in SMP2 of trying to contact Parish Councils to disseminate information has not worked as well as it could have and that some contact details have been omitted from our lists. However, we have tried to address this as far as possible by continuing to invite responses and to have discussions in this area beyond the official consultation period. 2/ As stated within SMP2, the area behind the current Cocker Bridge to Glasson coastal defences is a Currently, No Active Intervention (NAI) is not being put forward ‘...Large flood risk area therefore NAI [No Active Intervention] not appropriate...’ (F-27: SMP2, 2009). in the SMP2 as a recommended policy. NAI can mean simply ‘do nothing’, or it can mean that no major works are proposed with ECONOMIC VIABILITY OF PROPOSED MR SCHEMES large sums of capital funding from government sources. This 3/ The proposed Managed Realignment (MR) schemes (for the area currently protected by defences would, though, allow some localised small scale privately funded along the Cocker Bridge – Glasson coast) highlighted within the SMP2 document (11c2 CDPS: SMP2, works. In relation to Thurnham the scale of appropriate work 2009; G-76 to G-80: SMP2, 2009), was released to the public on 5th October, 2009. This has had a could be larger, so it is more likely to be a form of Hold The Line large impact on the value of properties and viability of businesses within the area, for MR schemes (HTL). One possible way forward discussed at some meetings is that do not have sound evidence of economic viability and/or environmental viability, and have serious allowing landowners and residents to undertake works to social consequences – see Points 4-33. maintain defences (as long as the relevant consent is obtained), or the EA doing a minimum level of maintenance. Alternatively, if an increase in flood risk is to be accepted over time then such actions could be loosely described as Managed Re-alignment. Unfortunately, the policy labels do not fully describe the range of actions possible, so it is important that the Action Plan in the SMP describes what actions are intended, or to be investigated. Actions which allow reduced maintenance could only be adopted after a great deal of consideration as to their implications, especially with regard to public safety and flood risk to properties and we must remember that sea levels are expected to rise. 4/ The most vulnerable sections of the Cocker Bridge – Glasson coastal defences is the 0.78 km earth We agree that these two sections are the most vulnerable. When embankment east of Bank End farm and the 0.92 km earth embankment east of Crook farm around considering the probability of failure it is necessary to allow for Janson Pool, indeed these are the defences that failed on 11th November 1977 during extreme wave action as well as the static water level. The length of conditions, where a high tide combined with storm force westerlies and excessive rainfall (both in this defence between Bank End and Bank Houses is more exposed, area and the upper reaches of the River Lune) caused extensive sea flooding along the whole Fylde and the post SMP1 studies estimated the standard of defence to Coast (and the sole failure of the Cockersands defences in more than two generations). Both be around 1 in 10 years, allowing for some low spots in defences defences rise to 8.2 m AOD (Morecambe Bay Shoreline Management Plan Partnership, 1999), where and small gaps. This has not been reassessed during SMP2 studies, the static height of the 1-in-200 year event is 6.7 m (pers. comm. Environment Agency). although we are presently undertaking a new regional assessment of the joint probability of waves and water levels that will be available to feed into more detailed studies across the whole region in future. For a HTL policy it is also necessary to consider the coastal defences for the whole section, not just the embankments near Bank End and Janson Pool, as a failure anywhere could result in more extensive flooding. 5/ The MR scheme to construct an new 1.2 km earth embankment between Norbreck Hill and We will correct the reference list in the final SMP2 to include the Kendal Hill is ‘Option 4’ within Jacobs (2008) and is specifically referred to within SMP2 (G-79: SMP2, missing reference cited in the text. Rather than relying on 2009; Figures A5-A8 in Jacobs, 2008). Note that within Babtie Brown and Root (2004), Norbreck Hill previous studies, the SMP2 has used generic costs and national is incorrectly described as ‘Thursland Hill’, probably because of the poor map resolution used. This data sets for property locations and values to check if proposed policies across the whole SMP2 area are likely to be economically

42 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? latter reference is cited within the Jacobs (2008) report, though not included within the reference list. viable. During SMP2 development, previous studies such as Jacobs (2008) were reviewed for this Policy Unit and the economic 6/ The Jacobs (2008) report is the only study cited within SMP2 as providing a) any details of the MR testing of Managed Realignment (MR) assumed the Norbreck Hill vs. Hold The Line (HTL) schemes proposed, or b) any sources of independent evidence for the to Kendall Hill alignment, which had performed best in the earlier economic viability of the considered schemes. Despite this, the Jacobs (2008) report was not listed studies. However, the economic assessment in Appendix H of within any of the reference lists within the main SMP2 document or its appendices the SMP2 used the SMP2 generic costs and damage data, not that (http://mycoastline.org). Furthermore, this Jacobs (2008) document had not been publically available, of Babtie (2004). so that the newly formed ‘Cockersands Forum’ had to make formal a request for its release on 13th January 2010. Note that the first the representatives of Thurnham/Cockerham Parish knew of the SMP2 process was on 27th November, 2009, and then attending the SMP2 Stakeholders’ Forum

meeting at Lancaster House Hotel on 8th December 2009.

7/ Upon receipt of the Jacobs (2008) report (1st February, 2010), a simple modelling study with little context, it was clear this was based upon 4 MR scenarios investigated by Babtie Brown and Root (2004). Again the cited report was not listed within a reference list. The representatives of

Cockersands Forum requested this Babtie Brown and Root (2004) report 4th February, 2010 and received it on 5th February 2010, only 6 working days before the formal SMP2 Stage 4.4 Consultation We are not aware of any other managed re-alignment routes Process closes (14th February 2010). considered for the area other than those in the reports by Babtie Brown and Root and by Jacobs. The local topography is key to 8/ At the time of the Jacobs (2008) report, it is clear that the 4 MR scenarios investigated by Babtie how many possible routes there are and where these could be. Brown and Root in 2003 (Published in Jan 2004), were the preferred and only MR options being One element of any future study into the feasibility of managed investigated. Indeed, SMP2 only identifies the MR options of Jacobs (2008; G-79: SMP2, 2009) as a re-alignment could be to look at whether there are other routes basis for saying that MR is a viable option. If alternative schemes have been investigated by the North not yet considered. West England and North Wales Coastal Group then these have been hidden. 9/ The Babtie Brown and Root (2004), on which Jacobs (2008) is based (and then cited within SMP2 Over the last ten years the rules for appraisal of coastal defence G-79), concluded that the MR scheme involving dismantling the 0.78 km Bank End and 0.92 km Janson schemes have changed several times. An example is the way Pool defences (see earlier Point 4) and constructing a new earth embankment 1.2 km long between national economic assessments have to account for artificially Norbreck Hill and Kendal Hill has an incremental Benefit-Cost Ratio, BCR of less than unity and raised land values due to agricultural subsidies. With the phasing consequently a Defra Priority Score of zero (p19:Babtie Brown and Root, 2004). By contrast, the in of the Single Farm Payment Scheme the rules for appraisal option involving improved maintenance of existing defences would give an incremental Benefit-Cost changed in 2006 and 2008. Land and property values and Ratio of 6.40, the best of all options, and consequently the one that Babtie Brown and Root (2004) construction costs have also changed and this is why it is recommended. sometimes necessary to re-evaluate the economics. For SMPs, most costs and benefits are generic to ensure consistency around the country as much as possible, though some outputs from the Babtie/Jacobs reports have also been used for Thurnham because they provided more detail. The SMP recognises that generic costs and benefits may not be wholly appropriate, so future work, as shown in the final Action Plan, will provide/use only details specific to Thurnham. At that later stage we can be completely confident that costs and benefits are fully accurate. Meanwhile, it was our intention that details used are sufficient to indicate a preferred option, but with the proviso that further analysis is done. It is important to note that the average Benefit Cost Ratio (BCR) has to be robustly greater than one to justify schemes, irrespective of the incremental BCR which compares increases in benefits to increases in costs when against another option. The average BCR was significantly less than one for the “improvements to Safety and maintenance” option in the Babtie (2004) report, so even this do-minimum option could not be

43 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? justified at the time. The Babtie report does not show incremental BCR. This report recommends Option 7 – managed retreat to high ground. You appear to be referring to a different report? 10/ The SMP2 report states a BCR for the Cockersands MR schemes of 3.84 (H-39: SMP2, 2009). It is As noted above, the 3.84 BCR given in Appendix H was derived not clear where this figure has come from, given that the only study cited is Jacobs (2008; which cites during the SMP2 development, using generic cost rates, and the economic study of Babtie Brown and Root, 2004). Given that Jacobs (2008) is the only national mapping of assets as described in the introduction to independent evidence cited, the figure looks like an average for the BCRs for the small MR schemes Appendix H. As there is a very extensive flood plain, the at Bank End and Janson Pool (1 km2 and 0.5 km2, respectively) and the failed BCR for an economic benefits for PU 11c2.4 are linked with the adjacent embankment between Norbreck Hill and Kendal Hill (4.7 km2). frontage in the Lune, PU 11c 3.1 as shown in Appendix H, p H- 39. It is recognised that this is only an approximation and there are a number of uncertainties, which should be addressed by further site specific studies recommended in the Action Plan. 11/ We have evidence that figures used within Babtie Brown and Root (2004) and SMP2 (H-39) The maintenance costs used by the SMP2 broad scale economic grossly underestimate the true economic costs of the MR schemes versus maintaining 0.78km and analysis are based on nationally derived average figures, and 0.92km earth embankments at Bank End and Janson Pool – see subsequent Points 12 to 15. recognise that risks will increase in future (Appendix H, Annex 2- 2). 12/ First, the SMP2 benefit-cost ratio analysis assumes a cost of earth embankment maintenance of £12/m/yr or £12,000/km/yr (Table at start of Annex H.2, SMP2: 2009). This would amount to a cost Although the Bank End and Janson Pool embankments are the of £12,000 per year for the earth embankment at Bank End and £6,000 per year for that at Janson most vulnerable lengths of defence, as noted in your (4), the total Pool, or £120,000 and £60,000, respectively, for a 10-year period. Yet, we know that over the last 10 length of shoreline to defend for a HTL option for this Policy years, the only maintenance activity seen along these two critical embankments has been: a) grass Unit is over 6km, whereas the length of a potential managed cutting, b) some vermin control, and c) at the Janson Pool embankment specifically, replacement of realignment option from Norbreck Hill to Kendal Hill is, as you one 1.2m2 sluice gate at a cost of £3,000, and a repair of a rear section of bank affected by foxholes. say, about 1.2km, although to prevent outflanking the 1.5km of Given that these banks are grazed by sheep and require very little mowing, the actual length mown is defences at the south to Cocker Bridge are needed under both more like 1 km. So taking the maintenance costing supplied recently by the Environment Agency of options too. 82p per metre, which includes mowing and vermin control, it is difficult to understand how this Using the generic SMP cost data for capital improvements to would have cost more than £10,000-£15,000 for both embankments for 10 years (particularly given upgrade the defences at the end of estimated residual life and that the Environment Agency’s activities are audited). annual maintenance, as given in Appendix H, we estimate that the 13/ Within SMP2, the stated cost of maintenance of embankments following MR along the Cocker 100-year current cash cost of HTL for PU11c2.4 would be in Bridge – Glasson coast is £3.6 million / 100 years (at current value) (Annex 2-7, SMP2, 2009). This is excess of £25 million, more than double the £12.1 million cash clearly considerably larger than the £100,000-£150,000 for the same 100 year period that we cost of the Preferred policy option (£8.478 million capital + estimate for maintaining both the 0.78 km and 0.92 km embankments. If built and maintained £3.620 million maintenance). Note that the Preferred policy correctly (with riprap etc), earth dams have a lifetime well in excess of 100-years of the SMP2 option costs allow for HTL for 20 years followed by MR. assessment period (e.g., Goldin and Rasskazov, 1992). 14/ The lack of uncertainty in the £8.478 million capital cost estimate of MR in SMP2 (Annex 2-7: Uncertainty allowances for costs are added to the cost estimates SMP2, 2009), is difficult to understand given: a) Jacobs (2008: using Babtie Brown and Root, 2004) and by applying a 60% Optimum Bias uplift factor. However, although subsequently citied in SMP2: G-79) evaluated 4 MR schemes of a range in size from ca. 0.5 km2 to 4.7 there have been previous studies, the draft SMP2 does not km2, and b) that local clays are known to be rheologically weak and not suitable for embankment commit to any particular alignment, or indeed to MR in 20 to 50 construction, thus requiring import of puddle clay and other materials. or 50 to 100 year epochs. The draft, on which we have been consulting, indicates that the medium and long term policy will be

subject to confirmation following further consultation and further investigations. The draft SMP2 Action Plan indicates that these further studies are required. As well as consultation this would include confirming a preferred alignment, which would need to allow for site investigations and sourcing of suitable fill and armour.

44 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? 15/ The commercial value of the 141 residential, commercial and agricultural premises within the area The assessment uses national economic values, not commercial that could be affected by failure of defences along the Cocker Bridge – Glasson coast (i.e., an area of values. Residential properties are valued based on estimates > 9 km2) is given as £32.294 million (Table 3, Appendix H: SMP2, 2009). We believe this is a gross contained in the EA’s National Property Database, which uses underestimation at current prices, as using independent valuations we calculate the total residential, Ordnance Survey Address Point data, as described in Appendix commercial and agricultural value of the 22 premises directly affected by the proposed Norbreck to H3.1.1. Kendal Hill MR alone (4.7 km2) to be £30.065 million. This value emphasises the need to maintain the defences (see Point 2 earlier) and also to re-evaluate the potential compensation costs of the proposed MR schemes. 16/ Rather disconcertingly, the Jacob (2008) flood modelling study considers the effect of new set- Government guidance for appraisal of flood and erosion risk back embankments (around the 1 km2 Bank End area, 0.5 km2 Janson Pool area and 4.7 km2 management schemes requires the economic appraisal to Cockersands area west of a line from Norbreck Hill and Kendal Hill) against a 1-in-10 year tide (p1 consider and justify a preferred design standard. However, this and p5 in Jacobs, 2008). First, they describe this as an ‘extreme’ event, which it is not under any detailed appraisal is not undertaken at SMP stage as it is scientific definition. Secondly, and most critically, if the new set-back defences (under MR) are to be undertaken at the scheme design stage. The guidance, Defra’s designed only to contain events smaller than the 1-in-10 year event, then the new defences would FCDPAG3, gives ranges of indicative standards for different land lead to regular inundation of > 9 km2 of Thurnham and Cockerham Parish, and many more use types. For example, for Category A land use, urban coastal businesses and households probably not considered by the Benefit-Cost Ratio analyses in SMP2. defences the indicative standard of defence range is from 1 in 100 Given the sea flooding event of 11th November 1977, set-back flood defences designed only to to 1 in 300. For rural areas, Category D the indicative range is protect against a 1-in-10 year event would certainly have overtopped and led to the flooding of the from 1 in 1.25 to 1 in 20. (Category D is described in FCDPAG3 village of Glasson Dock via the area east of Tithe Barn Hill. This would undermine the stated HTL as “ Typically mixed agricultural land with occasional, often policy for Glasson Dock village, a policy set because of the assets of the dock itself and adjacent agriculturally related, properties at risk. Agricultural land may be prone infrastructure (11c3.1 CDPS Glasson Dock to Conder Green Farm). to flooding, waterlogging or coastal erosion. May also apply to environmental assets of local significance.”). Improvements above the indicative range are allowed, but need to be economically justified. ENVIRONMENTAL VIABILITY OF PROPOSED MR SCHEMES Further study would address this. 17/ From a consideration of the evidence cited within SMP2 (2009) and within Babtie Brown and Many of the points here will need to be addressed in further Root (2004) we also question the robustness of the environmental assessments within the benefit- study and this will be acknowledged in the final SMP with changes cost ratio analyses – see subsequent Points 18 to 28. to text where necessary. 18/ First, the dismantling of the 0.78 km Bank End and 0.92 km Janson Pool embankments would The risks to the Aquifer are noted in the SMP policy assessments, Update Action Plan to add consideration of impacts allow sea water to migrate inland during particularly high tides and during storm surges. By the and included in the summary table giving the “Predicted on the aquifer in more detail before finalising policy. Environment Agency actively breaching the existing defences in this way would lead to the Implications of the Draft Policies being Adopted in this Location” contamination of the northern part of the Fylde Aquifer with salt water. At several places behind the in the draft policy statement. Further investigations are Cocker Bridge – Glasson defences, the surfical drift is known to be shallow and including areas of recognised by the SMP to be required into the feasibility of MR coarse sediments, thereby allowing vertical percolation of seawater if ponded on the land surface. and the Water Framework Directive issues are a further The groundwater body beneath the Cockersands-Thurnham area is part of the contributory area of justification for not recommending NAI or MR in the short term, the boreholes abstracted by United Utilities for public water supply, and is consequently classified as a even though the EA has previously found it very difficult to justify Source Protection Zone ( http://www.environment-agency.gov.uk ). By dismantling the 0.78 km Bank maintaining these defences. To further highlight this issue we now End and 0.92 km Janson Pool embankments would directly lead to the contamination of the Source propose to add a specific item to the draft Action Plan. Protection Zone by salt water. Furthermore, by removing these two embankments to allow salt water to migrate inland over the ground surface (where it would infiltrate and percolate to the aquifer) would result in a deterioration of the groundwater status in direct contravention of the Water Framework Directive (K-52: SMP2, 2009) that is close to implementation in the UK. The Environment Agency is the key agency within England with regulatory responsibility for management of Source Protection Zones and in the near future for implementation and regulation of the ecological standards established by the Water Framework Directive. 19/ Secondly, SMP2 notes that ‘...Land reclamation has taken place at Cockerham Sands. These The SMP does not make an assumption that the existing defences modifications have also impacted on the estuary’s ebb and flood regimes which have resulted in a would be dismantled. They could be left to deteriorate over time,

45 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? trend of net accretion [of the area of salt marsh]...’ (C-401: SMP2, 2009). Further, a representative of with the EA transferring maintenance to new setback defences. the Environment Agency has noted the potential impact of moving the defences upon the location of The delay in implementation of MR allows for further studies, site the Lune Channel and the serious consequences that this would cause. He noted ‘...effect the whole investigations, modelling and monitoring. If considered necessary of the [Morecambe] Bay if Lune Channel moves. Could be sufficient reason to maintain the training walls or armouring could be used to limit the extent of a defences...’ (B3-16: SMP2, 2009). The FutureCOAST study (Halcrow, 2002) noted uncertainties in the breach. response of Morecambe Bay to sea level changes, stating ‘...There is a high level uncertainty...sea level rise...the response of Morecambe Bay estuary complex...’. They went on to say ‘...Frontage is also sensitive to changes to channels and banks positions, which are not possible to predict...’ (C-421: SMP2, 2009). Indeed, the study of Aldridge (1997) similarly demonstrates complexity in the flow structures within Morecambe Bay. Thus, there is a possibility that the dismantling of the 0.78 km Bank End and 0.92 km Janson Pool embankments could lead (during the next storm surge) to the loss of the existing salt marsh and a shift in the location of the Lune Channel. Any such risk would be unacceptable given: a) that the existing salt marsh forms part of the SSSI, SAC and SPA within Morecambe Bay, which is protected under UK law, and 2) shifts in the location of the Lune Channel could affect navigation to the port at Glasson Dock village. The port is seen as a critical economic asset that should be protected (11c3.1 CDPS Glasson Dock to Conder Green Farm). These impacts might be evaluated by commissioning organisations such as HR Wallingford to construct physical (hydraulic) models of Morecambe Bay, but these would be extremely costly (possibly in excess of £1 million) and the uncertainties may still remain, leaving the problem impossible to predict with any accuracy, as Halcrow (2002) note (C-421: SMP2, 2009). 20/ Within SMP2, the possibility of climate change affecting sea levels (by 0.3 m) in Morecambe Bay The sea level rise allowances considered in the SMP2 are those and reducing the exposure of the existing salt marsh (the so called ‘coastal squeeze’ hypothesis) is recommended by Defra and given in Table C4 of Appendix C. highlighted. However, it is acknowledged ‘...There is a high level of uncertainty with regard to when This indicates an allowance of 988mm of relative mean sea level sea level rise will start to impact on this coastline and the response of Morecambe Bay estuary rise over the 1990 to 2115 period. complex...Frontage is also sensitive to changes to channels and banks positions, which are not possible to predict...’ (C-421: SMP2, 2009). Given these (unpredictable) uncertainties, it is therefore plausible that the negative effects on the salt marsh extent caused by removal of the 0.78 km Bank End and 0.92 km Janson Pool embankments could be worse than those associated with a small +0.3 m sea level rise). 21/ The shoreline and channel muds along the Cocker Bridge – Glasson coast are known to have Contamination issues would need to be considered during a Add consideration of impacts on radioactive levels of radioactivity, far in excess of background. For example, the activity of Caesium-137 and more detailed local study than possible at SMP level. contamination to Action Plan. Amercium-241 are known to be in excess of 300 and 100 Bq/kg respectively, at this point in Morecambe Bay (e.g., Radmil, 1993). Despite this, no consideration is given to the effect of dismantling the 0.78 km Bank End and 0.92 km Janson Pool embankments that would result in the inland transgression of seawater containing suspensions of radioactive muds and its subsequent environmental impact. Yet, a key objective of the Strategic Environmental Assessment (SEA) of the national SMP is ‘...To manage and minimise risk of pollution from contaminated sources...’ (I-25: SMP2, 2009). 22/ SMP2 assumes that the proposed MR schemes can create new salt marsh via dismantling the 0.78 Present day Mean High Water Springs at Glasson is 4.6mOD and km Bank End and 0.92 km Janson Pool embankments, yet no evidence is presented to suggest that sea from the map it appears that substantial low lying areas may be transgression in to these areas will be of sufficient frequency and duration that this will be likely in the below the 5m contour. As noted above, nearly a metre of mean medium or long-term (i.e., 100-years). sea level rise needs to be allowed for in planning coastal defences over the next 100 years, so in the long term low lying areas would be expected to be flooded regularly. However, if a planned defence removal was to be undertaken to encourage early habitat creation, inundation modelling could be undertaken that would help assess the habitat that would be created. If a scheme were to be taken forward specifically to create intertidal habitat,

46 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? creeks could be excavated to encourage water flow to the low lying areas and the development of pools. This approach has been taken on habitat creation sites elsewhere and, if suitable the excavated soil can be used within new embankments around the site. 23/ Furthermore, SMP2 makes no mention of the negative impacts of embankment removal and The RSPB response to the SMP consultation draft does not subsequent sea transgression on the freshwater areas currently supporting large and important specifically comment on this policy unit, but generally indicates populations of bird life. For example, the Fylde Bird Club note the importance of fields in the that they would prefer to see far more MR or NAI policies for hinterlands of Cockersand Abbey for attracting large flocks of Lapwing, Golden Plover, Curlew and frontages in the short term, 0 to 20 years than included in the Redshank. Within the vicinity of Crook Farm (behind the sea defences), a recent survey by the RSPB draft. Volunteer and Farmer Alliance reported 32 bird species including red list species of Grey Partridge, Skylark, House Sparrow and Starling (RSPB V&FA, 2008). The ground nesting species (e.g. Grey Partridge and Skylark) would be likely to suffer complete nesting failure as a result of inundation by high spring tides during the breeding season. 24/ The presence of colonies of Great Crested Newt (Triturus cristatus) are reported within the Impacts on protected and other species would be subject to Add protected species to list of considerations for area of Thurnham at risk from inundation by the 1-in-200 year coastal flood event. Failure to maintain more detailed consideration at the next stage. If a managed further studies in Action Plan. embankments or the removal of embankment that protects the freshwater habitat of the Great breach were to be proposed then impacts on protected species Crested Newt could be an offence under the Wildlife and Countryside Act 1981 and The would need to be managed. Conservation (Natural Habitats & c.) Regulations 1994. 25/ Additionally, the fields surrounding Crook Farm are known to support a large population of Brown Hare (Lepus capensis) that would be affected by dismantling the 0.92 km Janson Pool embankment and allowing sea water to inundate their habitat. 26/ The FutureCOAST study (Halcrow, 2002) states that ‘...Loss of defences in this area [Pilling to The erosion risks to the scheduled monument could potentially Plover Scar] would reactivate erosion of the low sandstone cliffs...’ (C-405: SMP2: 2009). This is be managed by local defences even under a MR scenario, such further acknowledged in section G-289 of SMP2 where it is stated that MR would lead to ‘...increased expenditure would require English Heritage to assist Lancaster erosion of Cockersand Premonstratensian Abbey SM...’. This Grade 1 listed building and Scheduled City Council and the EA to make a business case for doing so. Monument is protected under the Ancient Monuments and Archaeological Areas Act 1979 and This would be part of the further studies. As you have highlighted European Convention on the Protection of the Archaeological Heritage (Valetta Convention). Indeed, the issue we now propose to add it as a specific item on the the BBC News recently reported that ‘...This is a very significant building as Cockersand is thought to Action Plan. be the only example of an octagonal chapter house in that kind of abbey in this country...’ (BBC News, 21 June 2007). The architectural text by Hartwell and Pevsner (2009) describe it as ‘an unforgettable sight’. The cliffs of soil and drift in front of the chapter house are already in a precarious state, and any activity (i.e., removal of existing defences) that leads to accelerated erosion could have severe consequences for the remains. It should be noted that the sandstone outcrops along the shore at Cockersand Abbey are a Notified RIGS site (E-89: SMP2, 2009; i.e., Regionally Important Geodiversity Site), and any accelerated erosion would negatively impact on their status. 27/ A further environmental impact of the proposed MR schemes would be the carbon footprint of These issues would need to be considered in a more detailed the works needed to construct new embankments from Bank End to Thursland Hill and Norbreck appraisal than possible at SMP level.

Hill (1.9 km), or Crook Farm to Kendal Hill (1.2 km) or Norbreck Hill to Kendal Hill (1.2 km). Environment Agency scheme appraisals now always include Difficulties with foundation establishment have been reported within this area due to the weakness of consideration of carbon foot print. the local clays. Consequently, the construction of the new embankments for MR could necessitate

the transport of all materials to the site. Given the length of these proposed new embankments, this could result in a significant carbon footprint.

SOCIAL VIABILITY OF PROPOSED MR SCHEMES Creation of wildlife habitat is a long term option that requires 28/ The MR schemes are presumably attempting to turn productive agricultural land into wildlife consideration, but the key driver consideration of alternatives to habitat. It is difficult to envisage that the disused oil pipeline that crosses the Thurnham area from HTL is the difficulty in justifying the significant long term

47 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? near Crook Farm to near Hillam Lane Farm could be left in situ. We suspect that the significant costs expenditure that would be required to improve the defences. Add consideration of the oil pipeline to the action of excavating and removing this 3.5 km length of oil pipeline have not been included with the MR plan. Consideration of the disused oil pipeline would have a bearing on costs included within SMP2; they were certainly not identified in the more transparent calculations of the alignment of any new defence embankments. Babtie Brown and Root (2004). 29/ The social consequences of abandoning up to +9 km2 of productive agricultural land behind the Substantial areas of grazing could continue if managed re- existing Cocker Bridge – Glasson coastline (see Figure 1, i.e., much of the area west of the A588) alignment of defences were to be implemented. We have not yet would obviously devastate the social integrity of the local community. The agricultural land supports identified particular areas of land and considered possible future 1485 head of dairy cattle, producing 12.645 million litres of milk per year, 1400 fat lambs and 80 beef land use or habitat type. Again, this would be investigated in cattle, as well as arable feed crops, and consequently provides this community and many neighbouring detail if managed re-alignment were to be pursued. Clearly communities with essential agricultural products and services. In particular, the milk from the though, I am not wishing to play down the magnitude of the productive dairy herds in this area supply a much wider region, when the self-sufficiency ratio of change potentially proposed. domestic production to consumption has been in noticeable decline over the last decade. Additionally, food security has become increasingly discussed as a matter of concern in the UK, as domestic agricultural production continues to decline (Defra, 2006a). 30/ There are 4 caravan parks providing 347 static caravan holiday homes for regular visitors, as well The reports recently provided to the Cockersands Forum as 30 units for hire during the holiday season which operate at a 70% occupancy rate and generate in highlight the vulnerability of the caravan sites to sudden the region of 700 letting weeks per year. These businesses contribute considerable income to the inundation in the event of any failure of the sea defences. The wider economy of North Lancashire. The MR schemes would directly affect the viability of these future management of defences in the area should balance this caravan parks. with other factors, including economics, perhaps seeking a gradual change to reduce risk. 31/ SUSTRANS and the Lancashire County Council have begun investigation into the extension of the SUSTRANS have been consulted on the SMP. National Cycle Network from Glasson Dock to Cocker Bridge and beyond (North West Coastal

Forum, Sept 2008). They would like to create the ‘Morecambe Bay Cycle Route’ stretching between Fleetwood and Barrow. The existing flood defences between Cocker Bridge and Glasson Dock support permissible routes adjacent to the sea. If these defences were not maintained, then collapses or deliberate breaches could stop such a new cycle route from following this attractive stretch of coastline. 32/ The transfer of the responsibility (under the Land Drainage Act, 1930) for the maintenance of the The Environment Agency is considering the legal position arising Cockersands flood defences passed from the Dalton Estate to the local Catchment Board in 1949 from the 1949 agreement between Dalton Estates and the River (River Lune Catchment Board, 1948: meeting minutes, 13th July). These responsibilities subsequently Lune Catchment Board. transferred to the River Board, then River Authority, then Regional Water Authority (North West Water), then National Rivers Authority and finally to the Environment Agency. 33/ If a change to a policy of MR for 11c2.4 Cocker Bridge to Glasson Dock (20-100 years) were to Regarding compensation, I will re -iterate that our powers go ahead, then all of those affected by a loss of asset value (e.g., value of home, farm etc) will require regarding flood and coastal protection are 'permissive', so there immediate financial compensation. Twenty years ahead, if MR were to take place, then those directly would be no compensation payable as long as we exercise these affected by MR operations would require further compensation payments. responsibly, for example by maintaining defences, or even by withdrawing from maintenance (after giving appropriate notice). No-one has a right to be defended against flooding or erosion in all circumstances, whether on the coast or inland. Were we to deliberately do works which clearly caused a loss to others which could be demonstrated, then we believe a valid claim for compensation would then arise. Consulting on ways to best manage sea defences in the Thurnham area, now and in the future, is the right thing to do and does not create a liability for compensation. If a future managed re-alignment were to be implemented then some liability for compensation is likely to

48 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? arise, depending on the circumstances. About 10 years ago the Environment Agency placed Flood Maps on our website. It was considered appropriate that details about flood risk be in the Public domain so that people could make informed decisions and have some opportunity to manage their own risk. Flood Maps have in some cases had an effect on property values but this has not made the Environment Agency liable for compensation. 34/ As reported in Point 1, there have been over 10 years of activities (Morecambe Bay Shoreline Previous reports considered options but were not adopted as Management Plan Partnership, 1999) concerning the possible realignment of historic flood defences firm proposals. The SMP represents the right way of considering around Cockersands by the North West England and North Wales Coastal Group and its short and long term coastal policies, so now is the most forerunner, without any representation of the Thurnham parishioners, either businesses or appropriate time for consultation. No decisions have been taken. inhabitants (see e.g., B2-24 to B3-18: SMP2, 2009). This complete lack of involvement of local We believe we have released all evidence relating to the change businesses and local inhabitants is not compatible with the national SMP process detailed in Defra in policy, either in the SMP document itself or in documents (2006b). Furthermore, the failure to have released all of the appropriate evidence for the proposed supplied separately to the Cockersands Forum. change in policy, and the lack of engagement of local businesses and local inhabitants (of the Cocker Bridge to Glasson coast) over the last 10 years of investigation is not compatible with the As the SMP2 is a review of SMP1 it is recognised that the Environment Agency’s Corporate Strategy on ‘Evidence’ and the interaction with ‘People and information in SMP1 is out of date and therefore it does not Communities’ (e.g., Environment Agency, 2009). seem relevant to make information used at that stage available. The Coastal Group cannot make all information used by Given that we have been left out of the decision making process over the last 10 years, until the last consultants of the subsequent reports available, since it is not in few days, we now expect that the North West England and North Wales Coastal Group will invite a our domain. However, where this can be done without breaching representative of the ‘Cockersands Forum’ to all subsequent SMP2 Stakeholders’ Fora and all ad hoc any copyright/commercial property rights or incurring any charge meetings pertinent to the Cocker Bridge to Glasson coast, and provide a full reference list of all we will endeavour to do so. studies undertaken addressing SMP and SMP2 for the 11c2.4 Cocker Bridge to Glasson Dock coast, to make up for past deficiencies in the process. The Environment Agency and Lancaster City Council wish to engage and involve local residents and businesses and openly investigate future options for management of the coast in your area. To this end they would like to establish regular meetings with the Cockersands Forum and pass on relevant future studies and undertake to keep you informed of and involved in any relevant stakeholder meetings as appropriate. Much of this longer term liaison would be after the SMP has been completed, so it would not be a Coastal Group responsibility. Instead, it is likely that the Environment Agency would lead meetings with the Cockersands Forum, with involvement from Lancaster City Council, Natural England and NFU. Finally, we would like to re-iterate that the SMP proposal for managed re-alignment, perhaps in around 20 years time, is just one option, albeit that it seems the most cost-beneficial one according to analysis so far. Local residents, farmers and caravan site owners clearly view this as a worst case. We understand this. We therefore propose to explore other options too in meetings with the Cockersands Forum, and in future studies. Subject to further responses to the Draft Plan, we expect that the final SMP will reflect uncertainties about MR and leave scope for other options to continue to be considered.

49 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_190 11c 2.4 Knott End to Glasson Dock N Response noted. Revise headline policy in the 2 nd and 3 rd epochs to “Hold the Line OR Managed Realignment” and NFU There are serious concerns being expressed by our members in the Cockersands area. These The consultation draft SMP proposed to hold the existing the approach to indicate “either maintain existing concerns are driven by previous proposed changes to the Environment Agency’s management of the defences for up to 20 years, followed by Managed realignment, defences OR seek opportunities for managed seawall which were muted in 2006/07. the extent and timing of which would be subject to further realignment”, depending on further consultation and studies and consultation. There are a number of highly productive dairy farms in the area where the ‘Do Nothing’ option was studies. previously considered. Farm businesses of this type often have a lot of capital tied up not only in the In recognition of the strong concerns raised at consultation and Amend Action Plan to allow for ongoing consultation land they occupy but in buildings and infrastructure which supports the business. They are carefully the need to consider alternative options for managing the existing with the Parish Council and the Cockersands balanced operations for which the loss of or reduction in quality of valuable land could prove defences into the medium term, whether or not the primary Forum . catastrophic. defence is realigned, the headline SMP policy is now proposed to change to “Hold the Line OR Managed Realignment” in the We are aware that this idea was withdrawn and that the current position remains as per the ‘Hold 2nd and 3 rd epochs, The actual long term policy for this frontage the line’ policy in the SMP. This is a particularly contentious issue for all the reasons that we have just and the approach will be developed in further consultation and outlined in our general commentary on this consultation document. studies proposed in the SMP Action Plan. We reiterate that it is absolutely imperative that early and genuine consultation takes place where The decision on the actual long term policy for this frontage and managed realignment is considered in future to look at the range of options available to land owners. the approach will be developed in further consultation and studies proposed in the SMP Action Plan. PCR_192 11c 2.3 Fluke Hall to Cocker Bridge We agree that the previous line of defence would not protect the Revise policy approach description to make it clear A588. The proposed draft policy allows for holding the line of that improvement of the previous defence line as a Pilling Parish The inconsistency in policy, managed realignment / realign to previous line of defence or setting back the existing defence for the first 20 years, followed by managed secondary defence should be investigated and the Council the defence line to A588. realignment in the medium term. The actual approach to details of the approach to managing the defences will At the meeting I was informed that you propose to realign behind today’s sea wall and defend the realignment could take the form of an improved secondary line of be developed in subsequent studies. A588. To fall back to the previous line of defence and then HTL would not defend the A588. I would defence to deal with rising sea levels, with the existing front line like someone to clarify the position of the seawall after realignment. defence still maintained, but not improved. However, the details of the approach will need to be investigated in more detail.

PCR_122 11c 2.4 Response noted. Revise headline policy in the 2 nd and 3 rd epochs to “Hold the Line OR Managed Realignment” and Individual, It has come to our attention that there is consideration not to preserve the existing sea defences in N The consultation draft SMP proposed to hold the existing the approach to indicate “either maintain existing Herts the Cockerham and Glasson Dock area of Lancashire. This action will have a severe impact on local defences for up to 20 years, followed by Managed realignment, defences OR seek opportunities for managed businesses servicing the farms in this area as hundreds of acres of prime agricultural land will be lost. the extent and timing of which would be subject to further realignment”, depending on further consultation and We are just one of several businesses that service these farms and the rural economy and studies and consultation. studies. employment of the area will be severely damaged. In recognition of the strong concerns raised during consultation Amend Action Plan to allow for ongoing consultation After the impact of the foot and mouth outbreak of 2001, surely the UK should be looking at being as on the draft plan and the need to consider alternative options for with the Parish Council and the Cockersands near self sufficient in food production as it is possible. At least if we grow our own food in the UK we managing the existing defences into the medium term, whether Forum . are in charge of the bio security of it. How long before the biosecurity of food becomes an issue for or not the primary defence is realigned, the headline SMP policy extremists and terrorists to exploit? With the population projected to grow to 70 million in the next is now proposed to change to “ Hold the Line OR Managed twenty years surely we should be looking to reclaim land rather than letting it go to wetland. Realignment” in the 2 nd and 3 rd epochs, i.e. up to 100 years. After World War 2 farmers were encouraged to produce food to feed the country and overcome The decision on the actual long term policy for this frontage and the food rationing at that time. Grants were available for drainage projects and for farmers to the approach will be developed in further consultation and improve their businesses; now it appears that we should allow good fertile land to revert to wetland studies proposed in the SMP Action Plan. and import food from places around the globe - at what cost to the UK economy not to mention the

Carbon footprint. I think the issue of the sea defences should certainly be given more consideration in view of the above facts. PCR_195 I am concerned that the remains of Cockersands Abbey will be destroyed and since the Chapter Adaptation to change under a Managed realignment policy would As above House was used as a burial place for the Dalton family, I think attempts should be made to protect it, support natural processes and could allow for localised Individual

50 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Lancaster even removing it to higher ground, or at least a chance be given for a full archaeological survey. protection or excavation and recording or indeed relocation of the remains of Cockersands Abbey in future. The coastal walk is great and I hope a similar walk can be re-created. PCR_198 There is already a sea wall reaching Bank End farm. Further along the shore there is a large banking In recognition of the strong concerns raised during consultation As above about 20 ft high or more, where the Black Knights parachutes operate. This runs for quite a number on the draft plan and the need to consider alternative options for Individual, N of miles. It would be less costly to bridge this gap and save farmers from losing their farms and managing the existing defences into the medium term whether or Lancaster homes. not the primary defence is realigned, the headline SMP policy is now proposed to change to “Hold the Line OR Managed Realignment” in the 2 nd and 3 rd epochs, i.e. up to 100 years. The decision on the actual long term policy for this frontage and the approach will be developed in further consultation and studies proposed in the SMP Action Plan. PCR_201 As one of the many residents and stakeholders who will be affected by these future plans none of us The existing SMP, which is now being reviewed, has a Hold The Revise headline policy in the 2 nd and 3 rd epochs to have been informed or invited to any meetings and discussions regarding our future homes and Line policy. The Environment Agency has tried to justify “Hold the Line OR Managed Realignment” and Individual N livelihoods. We understand that these plans have been in the pipeline for a number of years and yet, undertaking improvement works in line with the policy, but the the approach to indicate “either maintain existing Cockerham this is deplorable, why did we have to find out by accident? I have a number of questions and would frontage has not been found to compare favourably with other defences OR seek opportunities for managed appreciate some answers. schemes that are competing for national funding, so other realignment”, depending on further consultation and alternatives do need to be explored. studies. 1. Why has this been a big secret to the people who are going to be most affected by these plans? No one has been contacted in any shape of form and this would still be the case if Previous reports considered options but were not adopted as Amend Action Plan to allow for ongoing consultation someone had not pricked up their ears. The last information we had was that the sea wall firm proposals. The SMP represents the right way of considering with the Parish Council and the Cockersands was to be lifted in 2003 or 2004. It really does appear that the powers that be are trying to short and long term coastal policies, so now is the most Forum . slip under the radar. appropriate time for consultation. No decisions have been taken prior to this consultation. 2. Economic argument. Maintenance verses new wall does not add up! Apparently it would cost a huge amount less to maintain the existing wall and keep it in good order for the next 100 It has been recognised for many years that the coastal defences years from the figures that have been made available to us. As far as maintenance is between Cocker Bridge and Glasson would need significant concerned little has been done over the last 40 years. Over the that 10 year period the only investment if they are to be sustained into the medium to long work that has been carried out on the two embankments is a) grass cutting, b) some vermin term. SMP1 indicated that a capital scheme would be required control, c) at the Janson Pool embankment specifically, replacement of one diameter sluice within 5 to 10 years to deliver the preferred Hold the Line policy gates and repair of the rear section of bank affected by foxholes. It is difficult to understand in this area. SMP 2 needs to consider viability of policy over the how this would have cost more money for both embankments for 10 years (particularly next 100 years. We have to plan for sea level rise of nearly a given that the Environment Agency’s activities are audited). metre, whereas in the past sea level has been falling relative to land levels in Morecambe Bay. 3. Humanitarian. If this project is carried out good productive farm land would be lost forever. This at a time when we are being encouraged to take up small farming and grow our own If new set back defences were built, the land behind the new seems to be counter productive. The number of farms that would be affected in one way or defences would benefit from improved protection. Although another is about 15 plus a number of private houses. These farms have been in families for there would be considerable change, substantial areas of grazing generations well farmed and very productive to feed the population. We are told by the could potentially continue in front of re-aligned defences were specialists in this field that in years to come we will not be able to feed our population on they to be implemented. We have not yet identified particular the farm land we will have available. I ask you does this make sense? The farmers in question areas of land and considered possible future land use or habitat have put more than 3 generations hard work into building a good business for them and type. their children and grandchildren; I feel someone has to see sense here. No-one has a right to be defended against flooding or erosion in 4. Property. Some one intimated that the bird life would improve. Would this help towards all circumstances, whether on the coast or inland. Were we to compensation. I think whoever estimated the value of all this land and property has grossly deliberately do works which clearly caused a loss to others which underestimated. On top of farmland we have caravan sites, a parachute club and various could be demonstrated, then we believe a valid claim for other properties amounting to an enormous amount of money. I ask where is the compensation would then arise. Consulting on ways to best compensation coming from in the present financial climate? manage sea defences in the Thurnham area, now and in the future, is the right thing to do and does not create a liability for 5. Sea levels. It is difficult to believe what is the truth about the levels of the sea. We are told

51 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? by the scientists that the sea level is going to rise in the near future and on the other hand compensation. If a future managed re-alignment were to be other scientists are telling us that this is not the case. If the sea rises, as it does, about 1 in implemented then some liability for compensation is likely to 10 years maintenance would seem to be the best option and then reassess the situation arise, depending on the circumstances. down the line when and if there is more cause for concern. In recognition of the strong concerns raised during consultation 6. The situation for everyone concerned is desperate and I can only hope that common sense on the draft plan and the need to consider alternative options for prevails when everything is taken into consideration for the land, environment and managing the existing defences into the medium term whether or population of this part of the NW coast. Trusting you will read and consider this letter not the primary defence is realigned, the headline SMP policy is carefully being only one of the people concerned. We trust we shall receive an early reply now proposed to change to “ Hold the Line OR Managed with answers to the points in question. Realignment” in the 2 nd and 3 rd epochs, ie up to 100 years. The decision on the actual long term policy for this frontage and the approach will be developed in further consultation and studies proposed in the SMP Action Plan. PCR_196 I wish to make several references and opinions to the consultation draft and hope that you may be It has been noted from your response that there is a Shell Oil Add oil pipeline to the list of further considerations able to answer some queries. pipeline, which runs along the line from Kendall Hill to Norbreck required for further study in the Action Plan. Individual Hill. This information will help inform the future more detailed Thurnham 1.If the option is taken to build a set back sea defence on the line from Kendall Hill in Thurnham to studies recommended by the SMP which will need to assess the Norbreck Hill in Cockerham (Jacob's report Figure 8), has consideration been given to the Shell Oil most appropriate medium and long term options for this pipeline which runs along a similar route? Legalities, purging and possible removal along with disposal frontage. could have serious environmental implications. These issues which have not been raised in the report would also increase costing to the option. 2. What would the top level A.O.D. of the option set back tidal defence be, and also its cross section. The crest level and cross section of any potential realignment The size of this would no doubt have weight issues on the sub-strata which is known to be a soft options is not considered at the level of the SMP. These will need organic silty clay that are inadequate for the satisfactory support of structural loads. to be looked at further in the more detailed studies proposed. If the option were to be taken forward the crest height and cross section would not be known until after site investigations and detailed scheme design. 3. Where would the material be sourced for this option given that the on site clay would not be As discussed at the meeting on 8th March the source of any appropriate? material for building set back defences has not been investigated at this high level stage. This would need to be looked at following a study if the managed realignment option were to go ahead as only then will it be known what quantities of what materials will be needed. 4. Has there been an evaluation of the carbon footprint that would be created should an option to The carbon footprint of defences is not something that is build a set back defence be taken up? currently covered in the SMP assessments but more detailed studies for strategies and scheme development do need to consider carbon footprint and this is now a standard requirement for Environment Agency scheme appraisals. 5. At the Thurnham Parish Council meet on the 5th Feb. I asked a member of the EA to what level As was discussed at the meeting on 8th March the SMP took into A.O.D. would the area flood, should the worst event occur and was told it would be 6.7m A.O.D. account over 100 properties, which would be at risk of flooding Should this be the situation, then a greater area would flood that that shown in figure A4 of the under a No Active Intervention policy in the area. The SMP NAI Jacobs report. The ground levels relative to ordnance datum of the canal vary from 5.93m which is assessment is based on extreme flood mapping as shown in the the O.B.M. at Cliffedale Bridge, 5.89m O.B.M. at Brickcroft Bridge and 6.3m road level near the draft SMP. The modelling in the Jacobs report shows flooding Victoria Hotel in Glasson. These levels indicate that the water height of 6.7, A.O.D. would flood over single tides and uses a less extreme flood levels (1 in 10 properties in the lower area of Glasson which would include the Silencer factory, shops, offices and chance of occurring each year). When looking at the benefits of a some residential property. It would also flood the factory units at Brickcroft along with business Managed Realignment scheme many of these properties in the premises and homes near the Mill Inn at Conder Green, and furthermore the water would be lower area of Glasson would be protected and therefore they

52 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? retained behind the recently constructed Glasson to Conder Green embankment, the very same form part of the benefits of the option. Therefore we do not which was built to protect the aforementioned properties. The Bank End and Janson Pool believe there would be a change in the BCR given in the SMP. embankments are protecting far more properties than is stated in Jabobs thus the incremental BCR would no doubt be higher than that stated in the BBR report of 2004 which recommends improved maintenance of the existing defences. 6. I believe that the length of the optional set back tidal defence to be greater than the combined As noted in our response to the Cockersands Forum (see above) lengths of the earth defences at both Bank End and Jansons Pool and so could you provide a break a Hold the Line option would require defence to over 6km, down of costs that could prove the former being more cost effective. whereas a potential realignment option could be about 1.2km. Both would require additional defences to prevent outflanking. A breakdown of the costs of defences was given out at the meeting on 8th March, and was also enclosed with the direct response. 7. Could you provide evidence that the area of Thurnham and Cockerham, in question, was The below text is an extract from the coastal processes report historically a tidal saltmarsh along with the frequency of tidal flooding and its extent. for the SMP, which states that historical Ordnance Survey maps show the accretion of Saltmarsh in this area. ‘Historical Ordnance Survey maps show that accretion along the frontage between Pilling and Bank End has resulted in a net seaward advance of the mean high water mark and sustained growth of saltmarsh over the past 150 years. Creeks and channels within the saltmarsh and intertidal areas have changed position over time, resulting in localised erosion which is exacerbated during storms. Embankments have been constructed along the majority of this shoreline to reduce the risk to the low-lying and reclaimed land from flooding. Further marsh was reclaimed in the 1970s, following severe storms, when new defences were constructed seaward of original defences. The upper reaches of the Cocker Channel have been trained, resulting in the restriction of channel movement and a reduction in sediment volatility in that area, reducing the potential for sediment to be transferred northward; consequently, saltmarsh development has increased in this location. Between Bank End and Bank Houses, where saltmarsh development has been limited, net change along the shoreline has been negligible. Over the past 30 years saltmarsh has developed further west towards Bank Houses where it now covers some 100 to 200 metres in front of the caravan park. In the past, the position of mean high water has, however, fluctuated in line with movement of the Cocker Channel, which in general has moved northwards at this location (Shoreline Management Partnership, 1999). To the immediate north of the frontage the scars have helped maintain the seaward position of the headland, however, since the late 1800s there has been a net retreat of mean high water associated with a gradual erosion of the scars.’ 8. There has been some concern that the responsibility for maintenance of the tidal defences be We do not believe a precedent has been set with regards to the passed from the EA to the landowners. In 1976 some farmers attempted to build tidal defences Environment Agency maintaining the defences and there is across the salt marsh at Pilling to reclaim the land for agricultural purposes. However, due to the currently no right to flood or coastal protection. Although we

53 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? poor nature of the workmanship and materials, the defences were breached thus destroying a large are aware that people have suggested that the Pilling defences amount of the embankment and causing some property to flood. The following year the NRA took may have had an impact on flows in the Lune, no evidence to over responsibility and rebuilt the tidal defence to a higher standard and level. Could you confirm if a support such an assertion has been put forward to the SMP team. precedent has been set, which, in my opinion has. Furthermore the EA have upgraded and maintained the original defences further inland. Could you please enlighten me as to the reason? I as do many others believe that constructing this embankment has had a detrimental effect on tidal flows in the Lune estuary. 9. If NE require more salt marsh why do they not request the set back of the above defences to Natural England have not specifically commented on any areas adjacent to the A588, thus retrieving what was historically tidal salt marsh void of property and which they require for salt marsh. However there are targets set business (confirmed in BBR Report page G-78 Scenario 20-50 years, Policy Assumptions). In fact this for habitat creation, which need to be met in the North West. is one area that could be brought forward. The same could be asked of the area of Hesketh Bank The draft SMP does propose realignment for the Fluke Hall to which was reclaimed in recent times. Cocker Bridge frontage, subject to more detailed feasibility studies. You mention the area at Hesketh and there has already been a scheme completed in this area in 2009 for habitat creation. The draft SMP proposes the possibility that this will be extended in the future as well. 10. The EA have on their web site a map which shows the area of land protected by the Glasson to As discussed at the meeting on 8th March, much of the defences Conder Green defence and is included in SMP2 as HTL policy. As you will be aware, this was recently in the area are currently offering a good standard of protection. constructed to withstand a 1 in 200 year flood and have a minimum life span of 50 years. Given the However there are low spots such as drive ways which would nature of the construction and general view of earth embankments it generally accepted the life span need to be improved if the standard of protection is to continue will greatly exceed this. Included in this map is the embankment at Janson Pool, which must therefore into the medium term. The areas on the maps on the EA website mean it too is of the same standard i.e. HTL quality, which is of supposedly low maintenance. This which give the areas benefiting from flood defence show only the then should reduce the costings further and make maintenance to the remainder more cost effective. area benefiting from flood defences for the Glasson Scheme. It is acknowledged that the Glasson to Condor Green defences were recently reconstructed, but as noted earlier they can potentially be outflanked and the other defences in the area would either need to be substantially rebuilt in 20 years time or realigned. 11. Could you confirm if the area in question were to become a 'saltmarsh' would then NE pursue a The management of the area would be considered further in the de-foliage policy to create a salt marsh appearance. If so could you also advise on the effects of the more detailed study which is proposed to be undertaken. The existing wildlife. In this area the Barn Owl population is quite stable and appears to be on the study will look at many different options and would include some increase, and which is more than a coincidence given that some local farmers have provided nesting consideration of how any habitat created could be managed. boxes. In the plantation of trees adjacent to my house at Haresnape there have been placed several nesting boxes to increase the survival chances of the Tree Sparrow, which was declining in numbers. Through monitoring and a ringing policy it has now shown to be successful with an increase in survival rate of 95% among the batches that are breeding in these boxes. All this voluntary work would be to no avail. 12. Could you please confirm the funding arrangements for work carried out on both Morecambe Grant in Aid for sea defence and coastal protection works is and Blackpool sea fronts and is this part of the overall allocation for Cell 11c of SMP2. Also would prioritised on a national basis; as such there is no ‘allocation for you be able to show if none structural elements are in these allocations. Cell 11c’. The national Grant in Aid pot made available from Defra does include for non-structural funding. Following a consultation in Summer / Autumn of 2009, Defra is presently funding several coastal adaptation pilot projects that will help set policy for future funding of flood and coastal risk management options where traditional forms of defence are not economically viable or affordable. There are complex funding arrangements at both Blackpool and

54 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Morecambe which have come from past national prioritisation, and more than one funding source. When the SMP is appraising the potential policies, the budget for the whole SMP is not considered. Each policy unit is appraised individually and an indication of whether the BCR is less than 1 or more than 1 is given. In reality this often needs to be greater than 5 to gain national funding but due to the lack of detail in the SMP this figure is not used. 13. Incorporated in the coastal works at Blackpool are newly constructed headlands of significant size, The Blackpool Scheme includes headlands which required which through tidal currents, could have an adverse effect on the coastline to the north. Do you have significant modelling to test prior gaining necessary consents to the relevant information to prove otherwise? proceed with construction. There is some sediment trapped by the headlands which helps to maintain the beach and the amenity value of the area but are not considered to have a significant impact elsewhere. The beach along the full length of the Blackpool frontage is monitored on a quarterly basis so any adverse impact of the headlands would be picked up. 14. Is there any evidence that areas like these at Thurnham and Cockerham are being financially Capital expenditure on coastal defences for all areas is subject to neglected in favour of high profile schemes such as those at Blackpool and Morecambe and if so is this a national prioritisation system developed by Defra and the a Government policy which could be backed up by legal documentation. Would it be possible to say Environment Agency. The national system gives greatest priority how the members of the NWCG were decided upon and that they look at the coastal issues without to protection of people and households. By their nature rural discrimination given that some have a vested interest in the high profile schemes. areas have less households and therefore do not score as highly on the ‘Outcome Measures’, which are used to prioritise national funding. Further details on the Outcome Measure targets can be found on the Defra website at http://www.defra.gov.uk/environment/flooding/funding/targets.ht m. The coastal group is not an elected body but merely a collaboration of all the Local Authorities, the Environment Agency, Natural England and Welsh counterparts who share knowledge on coastal issues. The government has encouraged the formation of these voluntary groups and the guidance for the SMP uses these coastal groups to promote a strategic approach to coastal management. Again more information on coastal groups can be found on the Defra website at http://www.defra.gov.uk/environment/flooding/who/coastalgroups .htm. 15. In my opinion, although I stand to be corrected, I believe there could be an issue under the The coastal group do not believe there is an issue under the Human Rights Act 1988….Article 8: the right to respect for private and family life. Maybe I could have Human Rights act as such. As mentioned above the Environment your opinion on the matter. Agency currently maintains the defences in this and other areas under their permissive powers but has no general obligation to carry on in the future, providing sufficient notice is given. If a flood defence scheme was taken forward in this area and the works were to cause increased risk to some properties or require purchase of property on the line of defences or the work site then there would be a case for compensation, which would arise under the Water Resources Act which gives the Environment Agency its permissive powers.

55 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? 16. In the small print at the front of the Jacobs report it states….'Opinions and information provided As stated at the meeting on 8th March the SMP has not relied on in the report are on the basis of Jacobs UK Limited using due skill, care and diligence in the any of the figures in the Jacobs report to come to its conclusion. preparation of the same and no warranty is provided as to their accuracy'. This I can accept given the The costs and benefits calculations and the flood plain mapping briefness of the work carried out but am of the impression that both the EA and the NWCG are have used information from national databases. It has always been treating the report as 'gospel'. Issues like climate change effect are not conclusive, in fact some parties stated in the SMP that further studies would be needed to now say it is not happening and could be in reverse. Would you be able to advise on how and to what confirm the policy choice and the latest suggested amendments accuracy the EA and the NWCG evaluate these reports. that were discussed at the meeting on 8th March further reflect our commitment to undertake such. 17. In the event of a set back option becoming a reality, would the NWCG and the EA envisage that This was raised at the meeting on 8th March and as discussed it all inhabited properties to the seaward side of this line be abandoned or would it be reasonable to would need to be looked at in more detail in the further studies. accept that those which benefit from being on more elevated positions and less vulnerable may still Whilst the properties themselves may remain inhabitable for remain inhabited. If the latter were the situation then how would the infra-structure be affected and some time there would be issues around access and would access for the various services be of concern. infrastructure, which could not be known until a preferred alignment is considered. To finalise this matter covered in the Consultation draft for Cell 11c of the SMP2. As discussed at the meeting on 8th March we are leaving the policy option open and are now proposing that we have an either I feel both saddened and disappointed that I along with many other families in the Thurnham and Hold the Line or Managed Realignment policy in the medium and Cockerham area have now been placed in an uncertain and stressful situation which has been brought long term. It has always been stated that further studies will be upon us as a result of issues contained in the above draft. Furthermore our predicament has been needed in the area which will go into much more detail than the made worse by the poor and un-professional way that this information was brought to our attention SMP. I hope you therefore appreciate that many of your and the lateness of it. questions can not be answered satisfactorily at this stage, but I I am of the opinion that the making awareness of this information and documentation has not been hope you will continue to work with the Environment Agency without deception. My opinion is heightened as a result of a conversation with a staff member of and Coastal Group as the detailed studies are undertaken Babtie who did the defects survey on my house in and around 2002/2003 whilst gathering information following adoption of the SMP so that all your information can be for the BBR report of 2004. In the conversation I was told that purpose for the survey was to check used and your queries answered. the structural condition of properties adjacent to Moss Lane prior to the possible strengthening of the road in readiness for the transporting of material to strengthen the embankment from Bank End to Jansons Pool. It now appears that whilst all this was happening, BBR and the EA were fully aware that a set back defence was a possible option. Is also appears that the possibility of trying to flood this area has been raised even further back in time and if this is correct why was permission given for new domestic development. It would be appreciated if you could find the time to respond in writing to my listed questions. May I also apologise if some answers to the queries have already been addressed in the Jacobs report and the SMP2 consultation draft, but due to the time scale and my own commitments to work and family, I have not read all the reports in depth. Further correspondence Response noted. Thank you for taking the time to reply to the issues on the above subject, however I do feel that In recognition of the strong concerns raised during consultation Revise headline policy in 11c2.4 for the 2 nd and 3 rd some of the questions may not have been understood and I also feel some of the answers have been on the draft plan and the need to consider alternative options for epochs to “Hold the Line OR Managed given without committal. managing the existing defences into the medium term whether or Realignment” and the approach to indicate “either not the primary defence is realigned, the headline SMP policy is maintain existing defences OR seek opportunities for Points 1-4. I can value your answers at this stage of the proceedings but feel until these and many now proposed to change to “ Hold the Line OR Managed managed realignment”, depending on further other points are addressed, which can be influential in costings, it is in my view wrong to try to Realignment” in the 2 nd and 3 rd epochs, i.e. up to 100 years. consultation and studies. promote the set back option. The decision on the actual long term policy for this frontage and Amend Action Plan to allow for ongoing consultation Point 5 appears to have been misunderstood. The information that is given in the Jacobs report only the approach will be developed in further consultation and with the Parish Council and the Cockersands refers to 28 properties, it was only on the 8th March that it was stated by the E.A. that 100 studies proposed in the SMP Action Plan. Forum . properties had been used in the evaluation factor. My question on the 5th Feb to John Limer was to what level A.O.D. would the area shown on fig A4 of Jacobs Report ( No Sea Defence Case Extreme The 6.7m level would refer to the maximum expected level in the

56 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Tide 1-10 year ) flood . I was told 6.7m ,which , if this should be the case fig A4 is incorrect thus tidal channel. Inundation modelling, like that undertaken in the further bringing in to doubt the credibility of the Jacobs report and how B.C.R. was achieved . Babtie report, has to take into account the frictional resistance Perhaps a explanation could be given why this number of properties was not referred to in the Jacobs on the flow of water through the breach and across the report and only included in B.C.R on the “Rough Update “ which in the small print at the bottom of hinterland; it is not as simple as a horizontal projection as the the page makes reference to “further details 09 03 10 “. shallow depths slow the propagation of the tidal wave. However, as you say the worst case flooding of a sustained breach over

several tides would be much more widescale. The approach taken for the SMP and the BCR ‘Rough update’ for the Glasson meeting takes this into account.

We agree that the natural defence formed by the higher ground Point 6 . Of the 6 km that you refer to, approx. 4.1 km is the higher outcrop forming a natural makes flood defence of the area significantly cheaper. However, defence which has had only mediocre spasmodic repairs done over a long period of time. The two the Hold the Line option at SMP scale has to allow for future sections at Bank End and Jansons are, according to the E.A., the weakest points and the areas that erosion protection works to that length too. One option that would be most vulnerable. The length of these two sections is comparable or less than an optional set could be considered in future studies for a Managed Realignment back. This again brings in to doubt the evaluations and the method of how they are achieved. options is to hold the Bank End and Janson Pool embankments and allow the area of higher ground to naturally erode.

Point 7. The answer given is not relevant to the question. The area in question that I refer to is that Although the marsh has increased in the past, we have to allow between Bank End and Janson Pool. Can you provide evidence that it was ever a salt marsh and how for relative sea level rise in the future, which is expected to halt frequent was it tidal. You do state that salt marsh is increasing, is this for certain? I believe that the or reverse accretion in general in the Bay in future. spread of Spartina (if that’s how spelled) could be giving a false impression. The areas benefiting from defences shown on the EA website Point 10. The E.A. website print that was shown to myself indicated the H.T.L. policy not only flood maps are basically the areas which stay dry in a 1 in 100/200 included the Glasson – Conder Green section but also Jansons Pool length. If this is the case, the year flood due to the presence of defences. They do not indicate Jansons Pool earth bank should not be included in maintenance costs around to Bank End. that there is any greater requirement on the EA to maintain these defences than any others which are not shown. The maps

do not set policy for, or commit to, future management of these There are other points that I would like to discuss in the future if this is possible, but at this moment defences. in time I would like to clarify one other issue. I have been told that the initial Babtie report The key issue that the SMP team has been aware of is that the recommended a H.T.L. policy for the Bank End to Jansons Pool section but the decision for M.R. is a HTL policy promoted in SMP1 has been difficult to deliver due to late change of strategy. Could you tell me what has influenced the change of policy, has it been from the need to compete for national funding. To score well on the other parties and is it on ecological issues rather than economical values. government’s “Outcome Measures” to compete for national funding requires a combination of high BCR, delivery of protection of people and property and protection or creation of ecological habitats. PCR_207 Whilst I fully understand the principles surrounding this kind of managed realignment of salt marshes, Response noted. See above. I feel I must draw your attention to the situation that this would leave our business in. Farm Feeds While options for alignment of new defences under a Managed (NW) Glasson As a local business based at Glasson Dock, this will have a pronounced effect on our ability to trade realignment policy would require more detailed study, the Dock profitably in the future. As you can no doubt tell from the address of the business, we are involved in assumption should be that a significant proportion of the coastal providing feed and nutritional solutions to the surrounding dairy, beef and sheep farmers. Many of flood plain would be protected behind a new defence, which these farmers, indeed many of our customers, conduct their business in close proximity to the would as you say be a reduction in land area rather than coastline around Cockerham and Glasson (and all along this stretch of coastline). complete loss. The planned re-alignment of the sea wall would reduce the land they have available for doing just that. In recognition of the strong concerns raised during consultation This is pure agricultural land, which suits its current brief very well. Some of our largest volume on the draft plan and the need to consider alternative options for customers farm in this way, I am sure you will have also received correspondence from them. If these managing the existing defences into the medium term whether or large accounts become smaller we will start to lose throughput through the Farm Feeds plant. If they not the primary defence is realigned, the headline SMP policy is decide they can no longer sustain their business we lose all their custom immediately. I expect these now proposed to change to “ Hold the Line OR Managed

57 Knott End to Glasson Dock – 11c 2 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? customers account for 10-15% of the business from Farm Feeds and without them we would struggle Realignment” in the 2 nd and 3 rd epochs, i.e. up to 100 years. to remain competitive, having to travel much further to re-gain the business we had lost. The decision on the actual long term policy for this frontage and This potentially means that Farm Feeds (NW) would cease to trade in the area. With the loss of the approach will be developed in further consultation and employment for what currently stands at around 15 local people, plus the knock on effect further studies proposed in the SMP Action Plan. down into the village of Glasson where these employees (and those from Glasson Grain who would also be affected) put money back into the local economy in shops etc. With this in mind, I strongly urge you to reconsider the realignment of the sea wall in this area, perhaps also reconsidering some of the other options available to you, such as holding the line or even advancing it. PCR_232 I write in response to the SMP2 on which the public are currently being consulted. I understand the N Response noted. initial consultation period has been extended until the end of March. MP for As noted above, capital expenditure on coastal defences for all Revise headline policy in 11c2.4 for the 2 nd and 3 rd Lancaster & As the Member of Parliament for Lancaster and Wyre I write specifically about the recommendations areas is subject to a national prioritisation system developed by epochs to “Hold the Line OR Managed Wyre which have been put forward in relation to Sub-Cell 11c which covers the coastline between Rossall Defra and the Environment Agency. The national system gives Realignment” and the approach to indicate “either Point and Haverigg. greatest priority to protection of people and households. By their maintain existing defences OR seek opportunities for nature rural areas have less households and therefore do not managed realignment”, depending on further While I recognise the increasing pressures on our coastal defences as a result of the age of the score as highly on the ‘Outcome Measures’, which are used to consultation and studies. existing defence mechanisms and the risks associated with climate change, I would also wish the prioritise national funding. Further details on the Outcome concerns expressed by my constituents, particularly those in the areas most affected by the Amend Action Plan to allow for ongoing consultation Measure targets can be found on the Defra website at proposals, to be given strong consideration. with the Parish Council and the Cockersands http://www.defra.gov.uk/environment/flooding/funding/targets.ht Forum . The proposals put forward in the consultation document advocate holding the line along the majority m. of the coastline in my constituency. However, significant concern has been expressed by my For the Thurnham areas the consultation draft SMP proposed to constituents living between Cocker Bridge and Glasson Dock, particularly those in Thurnham, where hold the existing defences for up to 20 years, followed by the SMP recommends HTL for the next twenty years after which consideration will be given to MR of Managed realignment, the extent and timing of which would be the coastline. Those living in the area are anxious about the implications this will have for their subject to further studies and consultation. properties and for the investments they have made in purchasing these. In recognition of the strong concerns raised during consultation I ask the North West England and North Wales Coastal Group to reconsider the proposal in the on the draft plan and the need to consider alternative options for light of the potential loss of land in this area and commit to retaining the coastal defences beyond the managing the existing defences into the medium term, whether next 20 yrs. or not the primary defence is realigned, the headline SMP policy is now proposed to change to “ Hold the Line OR Managed Realignment” in the 2 nd and 3 rd epochs, i.e. up to 100 years. The decision on the actual long term policy for this frontage and the approach will be developed in further consultation and studies proposed in the SMP Action Plan.

58 Lune Estuary – 11c 3 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_28 N Individual PCR_30 Insufficient rigour of analysis. N The responses were received at the Lancaster House consultation meeting in December. Following this, a further Individual, Yes, but we have invited you to come to a meeting to explain - the logic, the implications, and to give meeting was held for Sunderland Point residents on the 6 th Sunderland us the opportunity to fill in gaps in your analysis. January 2010. Point Community Association PCR_33 11c 3.7 N The consultation draft SMP2 proposed MR in 11c 3.7 to allow Revise policy approach to remove reference to the for future re-alignment of the road and the defence together. road and show HTL/HTL/MR Individual, Overton to Sunderland Village - prefer HTL as in SMP1. However, there is no clear source of funding for realigning the Sunderland road and concerns expressed during consultation have Point indicated a desire for the road to remain where it is, see PCR_43 11c 3.7 PCR_227 below. Therefore the proposed policy for Overton Cattle Grid to Sunderland Village should be revised to HTL / Individual, Concerned about managed realignment. HTL / MR. Subject to further studies the defences would be Middleton realigned to the existing set back defence protecting Overton PCR_44 11c 3.7 in the long term. Individual, Concern over realignment and new road to Sunderland Point. Overton

PCR_150 11c 3.7 N Engineering Specifically Sunderland Point but other areas are also still being discussed (Overton) - further and Projects, discussion required. Lancaster City Council PCR_191 11c 3.7 & 11c4 N Although the original SMP recommended HTL it has not been Remove reference to realigning the road and change possible to justify or afford to do so and the actual policy that PU11c 3.7 to HTL/HTL in 1 st 2 epochs . Individual I have examined the SMP documentation and note that Policy units 11c3 and 11c4 are proposed for has been implemented could be viewed as No Active policy change from the present HTL recommended in the original SMP. I apologise for making this Propose to split the PU into 4: Intervention. representation outside your consultation period but I have been overseas for several weeks. PU 11c 4.1 Sunderland Village NAI/NAI/NAI The draft SMP2 documents recognised that there is uncertainty As you are aware I have worked on the Lune estuary and Morecambe Bay since 1983 and have in the physical processes and we are aware that there are PU 11c 4.2 Sunderland Point MR/MR/MR therefore gained knowledge of shoreline evolution over the period. Having project-managed the Lune conflicting views on the impact of erosion at the point on the estuary study (undertaken in part by Halcrow) on behalf of Lancaster CC I have also gained a PU 11c 4.3 Sunderland Point to the secondary overall coastal risks in the estuary. We also acknowledge that thorough technical appreciation of the physical process regime. From the information available on embankment NAI/NAI/NAI sea level rise may not yet be being realised, but the allowances your web site I have to advise you that in my opinion the evidence-base is inadequate and the data that we have to plan for show exponentially increasing rates in PU 11c 4.4 Secondary embankment to Potts Corner interpretation flawed with regard to sufficient understanding of the Lune estuary and its shoreline future. HTL/HTL/HTL evolution to justify policy change. Bearing in mind also that the DEFRA guidance on sea level rise from 1990 to present is clearly incorrect for the and overestimates sea level rise by a factor of Following review of concerns raised and consideration of Add to action plan need to monitor & consider in two it would appear premature to adopt policy change in this area at this time. information put forward during the consultation process the more detail the impacts of the training walls on both policy for 11c 3.7 is proposed to change to HTL/HTL/MR flood risk and evolution of the designated habitats, Further studies and monitoring are recommended and once these are taken forward then I anticipate with the road left where it is. Unit 11c 4.1 will be subdivided – including an action to determine responsibility for the my reservations would be reduced although the recommended policies may change also. In the mean the proposed policy for the Point is to be revised to structures. time I have to challenge the policy recommendations made and request reinstatement of HTL policies MR/MR/MR and that for Sunderland Village will remain for the first two epochs until the evidence-base is robust enough to justify the raising of anxiety in the NAI/NAI/NAI . This will allow for limited intervention to be local community. undertaken at the point in the short term whilst further

59 Lune Estuary – 11c 3 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? I shall be pleased to discuss any matters arising at your convenience. monitoring and studies are undertaken. PCR_206 As a resident of Ashton with Stodday and living directly on the south side of the estuary (Penny Hill), FC comment provided directly on 24 th February 2010. No action proposed I would be grateful to know what the current position is in regard to the proposed SMP. To my Individual Thank you for your interest in the Shoreline Management Plan. As knowledge we received no notification of the consultation process and have simply picked up on the Ashton with you state the consultation process is now over and the project team issues following the publicity regarding Sunderland Point. Stodday is now considering the responses received and how to respond to I have gleaned from various websites that the consultation process is over however it is difficult to them. Also there is consideration of the draft policies that were determine what is now happening. It appears that further investigations are to be undertaken suggested and where they need to be looked at again in light of regarding the Conder Green to Management Unit (9/4) to determine which "policy information received in the consultation process. A consultation definition" is to be adopted. The current coastal defence policy is to Hold the Line, whereas the report will be available on the website in due course to outline what Short Term Future Preferred policy is to Do Nothing. Am I correct in assuming that this means no responses have been made and where changes have been made in repairs to the sea wall between Ashton and Conder Green. There are to be further local studies - the documents. This is likely to be available in mid May. what does this entail? The information which you are quoting regarding Management Unit The Plan Documents are quite difficult to understand and it is unclear which are up to date and which 9/4 is actually from SMP1 which was undertaken and adopted are not. I should therefore be grateful to know the current position and to no what are the around 10 years ago. perceived risks (over what time scale) to our home. We are currently reviewing this in SMP2 and the documentation relevant to this is on the website under the Shoreline Management Plan 2 tab on the home page. In the main documents the area that you are interested in is included in the Lune Estuary documentation. As you state in SMP1 the preferred policy was 'Do Nothing' which would mean that no significant public money should have been invested in coastal defence. In the draft SMP2 the proposed policy for the area is No Active Intervention. This would essentially be keeping the policy as it currently is. I hope that this answers your queries. If you have further questions regarding the SMP2 documentation please let me know. PCR_227 11c3.7 Overton Cattle Grid to Sunderland Village Response noted. Revise policy approach to remove reference to the road and show HTL/HTL/MR Sunderland The proposal for this section is for managed realignment in the second epoch (20 – 50 years), and the We agree maintaining the existing alignment in the short to Point justification for this includes improving access to the village. medium term could be more cost effective, but at the broad Community scale analysis for the SMP even this is not justified. However, The residents of Sunderland Village have always lived their lives around the fact that access to the Association realigning the embankment could potentially lead to creation of village is cut off most days over high tide, and they accept that access will be restricted for slightly habitats required for environmental targets and therefore be a longer periods in the future. However, being cut off by the tide is one of the essential characteristics trigger to enabling a scheme that would allow adaptation, and of life at Sunderland Point, as it is on Holy Island and St Michaels Mount. removing the road from the marsh may be beneficial for the Furthermore, it appears quite illogical to propose rerouting access to the village when in the internationally designated sites. There would be economic subsequent section, 11c4, abandonment of the village is being suggested. benefits from improving the environmental features. Justification for the proposal is also based on economic grounds. See other responses on PU 11c4.1 It is stated that there is an inadequate economic case to hold the existing line and that realignment In the light of the issues raised during consultation the could be more cost effective. We question the calculations which suggest that to realign the banking proposed policy should be revised to HTL/HTL/MR and the and the road would be cheaper than to maintain the road and the banking in their present position. road will be left as it is. The statement that realigning the road will allow the saltmarsh to develop more naturally is, we suspect, driven by the need to achieve certain outcome measures, i.e. the acquisition of more

intertidal habitat. It appears however quite contradictory to seek to gain intertidal habitat whilst appearing to do

60 Lune Estuary – 11c 3 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? nothing to stem its loss in the same location, through lack of maintenance of training walls within the river. In the opinion of the community, realignment would seriously undermine the defences by reducing the width of the peninsula, thereby creating a narrow isthmus and increasing the likelihood of ‘breakthrough’, and the formation of a new channel north of the village, linking the river to the sea. In addition, as has been recognized, inundation of a historical landfill site could lead to the release of contaminants into the estuary. The proposal for managed realignment in this section is controversial and the impacts of such a policy need to be fully considered.

61 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_8 We wish to register our support for a 'Hold the line' policy. As residents of Sunderland Point we N Response noted. The SMP appraisal does place value on social / See comments below. believe that for the moment this is the correct policy. humanitarian considerations, but government funding for Individuals, defences is limited and is not expected to be sufficient to afford Sunderland Whilst it would appear that no value is placed on heritage social and humanitarian considerations we to defend everywhere in future. National funding for defences Point believe that is totally wrong and we believe that if taken to Court of Human Rights that they would be has for many years focussed on protection of people and strongly considered. property and locations, like Sunderland Point, where there are a limited number of properties for an extensive length of defence do not score well against other national high priority schemes. The draft SMP policy of no active intervention also allows for continued work on individual property defences and flood resilience subject to consent. PCR_31 (Questionnaire from consultation meeting) N Response noted . The SMP will contain a list of locations with important heritage value. There will also be a Individual, Not enough weight given to heritage (listed buildings). The importance allocated to heritage in the SMP has not been statement recognising that current national rules to Sunderland enough to substantially influence the policy choice for Sunderland I do not believe a new public road will ever be built to serve Sunderland Point. Far more cost effective set priorities and bid for funding do not favour Point and some other vulnerable locations along the coast. to maintain existing tidal road and restore and maintain the River Lune training wall. heritage value. In the event that government policy Community See comments on PU llc3.7 regarding the road, proposed to changes in future to make additional protection of Association Inexpensive means of slowing-down erosion should be studied as an intermediate option between 'HTL' change to remove reference to road and for the defence, revert such places more likely there should be an option of and 'NAI'. The SMP2 report does not take into account the acceleration in recent years of the rate of to HTL in first two epochs, followed by MR to tie in with the reviewing the chosen policies and actions. English erosion of the Point End at Sunderland. existing set back defence. Heritage should consider whether to include I feel the whole basis of SMP2 is contestable, because each sector of coastline has to be put in one Sunderland Village in studies to assess options for Following consideration of this and other responses received category or another (usually HTL or NAI). The choice is based on too-narrowly defined economic the future management of key heritage locations. during public consultation we recognise that it may be more criteria and is rather obviously influenced by foreseeable budgetary limitations, under the expectation appropriate to split this frontage into 4 smaller units, as the no Remove reference to realigning the road and change that public funds will sooner or later have to be made available to implement any decisions. active intervention policy may not be suitable along the whole PU11c 3.7 to HTL/HTL in 1 st 2 epochs . There should be a new category which might be ‘hold the line-in principle (HTLIP). This would frontage. Propose to split the PU into 4: recognise sectors of coastline for which there are cogent reasons for holding the line, but which were National funding for defences has for many years focussed on found not to meet the criteria Halcrow were instructed to work to. It should at least be strongly PU 11c 4.1 Sunderland Village NAI/NAI/NAI protection of people and property and locations, like Sunderland emphasised in SMP2 that such sectors of coastline exist. This would cost nothing, but would avoid Point, where there are a limited number of properties for an PU 11c 4.2 Sunderland Point MR/MR/MR sabotaging the efforts of private parties seeking to maintain threatened communities and heritage. extensive length of defence do not score well against other ‘Sabotaged’ because no planning authority or Natural England & Co will feel obliged to give serious PU 11c 4.3 Sunderland Point to the secondary national high priority schemes. The draft SMP policy of no active consideration to their propositions, even after a very expensive environmental impact study has been embankment NAI/NAI/NAI intervention is therefore considered to be appropriate for paid for. An NAI classification would amount, in practice, to allowing administrative obstacles to Sunderland village with the caveat that continued work on PU 11c 4.4 Secondary embankment to Potts Corner effectively prohibit any private initiative, even if funding was found for any engineering work. individual property defences and flood resilience should still be HTL/HTL/HTL The sector of particular concern to me (11c 4 – Sunderland Point to Potts Corner) has arguably been allowed subject to consent and privately funded defences remote

found not to meet the criteria for HTL to be renewed. If, after review, this arguable assessment were from the shoreline would also seem acceptable and appropriate to be maintained, the sector would be a prime candidate for ‘HTLIP’ status. subject to any necessary assessments and permissions. Due to the potential importance that Sunderland Point has on the Lune estuary as a whole, a more proactive policy would be

more appropriate to manage erosion and future integrity of Sunderland Point. We therefore propose to have a new PU for Sunderland Point with a policy of MR for all 3 epochs to manage erosion and allow intervention if required. In recognition of the defences already situated between the start of the secondary embankment and Potts Corner we propose to split the PU further to allow a hold the line policy to continue where there are defences and no active intervention south of the

62 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? defences. PCR_12 I've recently been made aware of your group and thought I'd check you were aware of the BAP Priority Response noted. This should be taken into account in the next No action proposed Species moth mentioned above present in good numbers on the saltmarsh between Sunderland Point more detailed level of study. Individual and Potts Corner. This is almost its sole surviving colony in England (the other one on the Wirral being threatened and very small). PCR_27 (Questionnaire from consultation meeting) N Since the previous SMP, capital schemes to hold the line have not See changes noted above been found to be viable. Individuals, Wish to see a change n policy to NAI from HTL Sunderland The draft SMP policy of no active intervention however, also Impact on seawall - the road to Sunderland - Decline of farming land due to erosion - breaching of the Point allows for continued work on individual property defences and seawall, damage to homes. Community flood resilience subject to consent. Association PCR_28 (Questionnaire from consultation meeting) N See above comments As above Individual All areas are a concern PCR_30 (Questionnaire from consultation meeting) N A follow up consultation meeting with Sunderland Point Community Association was held on 6 th January 2010. Individual, Insufficient rigour of analysis. Sunderland Yes, but we have invited you to come to a meeting to explain - the logic, the implications, and to give us Point the opportunity to fill in gaps in your analysis. Community Association PCR_32 (Questionnaire from consultation meeting) N The heritage importance of Sunderland Point has been Highlight potential –ve impact on conservation area highlighted by several respondents. While the conservation area and 16 (or 23?) listed buildings. In summary of Individual, NAI states there would be no impact on the historic environment. 'Completely wrong' All our and listed buildings are recognised in the objective appraisal in potential implications. Sunderland properties are listed buildings! Appendix G, the summary impact assessment in the main Point See also PCR_31 document needs to give more weight to the heritage impacts for this location. We therefore agree that the impacts on the historical environment should be highlighted and will update the summary sheet. Please note that the approach used in the summary indicated ‘no significant impacts’ because the national prioritisation of coastal defence projects has in the past focused only on Scheduled Monuments and Grade 1 or 2* listed buildings. We are not aware that any properties at Sunderland Point fall into these categories, but agree that potential loss of 16 grade 2 or 3 properties together ought to be registered as a significant impact. PCR_33 (Questionnaire from consultation meeting) N Following consultation, propose to split the PU and policies to Propose to split the PU into 4: allow for further monitoring, limited intervention to manage Individual, Sunderland Village to Potts Corner - prefer HTL as in SMP1 PU 11c 4.1 Sunderland Village NAI/NAI/NAI erosion and adaptation to increasing flood risk to properties. Sunderland PU 11c 4.2 Sunderland Point MR/MR/MR Point PU 11c 4.3 Sunderland Point to the secondary embankment NAI/NAI/NAI PU 11c 4.4 Secondary embankment to Potts Corner HTL/HTL/HTL

63 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_34 (Questionnaire from consultation meeting) N A follow up consultation meeting with Sunderland Point Community Association was held on 6 th January 2010. Individual, Concerned about the whole area of Sunderland Point Sunderland To discuss this further at a meeting where we can actually 'air' our views. This meeting was impossible Point to hear what was being said! Community Association PCR_35 (Questionnaire from consultation meeting) N Following consultation, propose to split the PU and policies to Propose to split the PU into 4: allow for further monitoring, limited intervention to manage Individual, Change the policy back to the first decision to HTL PU 11c 4.1 Sunderland Village NAI/NAI/NAI erosion and adaptation to increasing flood risk to properties. Sunderland The area of Sunderland Point, the erosion, the seawall and general maintenance. But the history and PU 11c 4.2 Sunderland Point MR/MR/MR Point visitor interest. Community PU 11c 4.3 Sunderland Point to the secondary Association We wish the people who make the decision to come and converse with the committee at Sunderland embankment NAI/NAI/NAI Point. PU 11c 4.4 Secondary embankment to Potts Corner PCR_36 (Questionnaire from consultation meeting) N Following consultation, propose to split the PU and policies to HTL/HTL/HTL allow for further monitoring, limited intervention to manage Individual, Change policy to NAI from HTL erosion and adaptation to increasing flood risk to properties. Sunderland Concerned with erosion of land at Sunderland Point and intertidal marsh erosion. Point Community Association PCR_37 (Questionnaire from consultation meeting) N There is already an acknowledged flood risk and some properties have implemented individual property defences or Individual, If no more sea defences are put in place we will be flooded. flood resilience. Sunderland Point Following consultation, propose to split the PU and policies to Community allow for further monitoring, limited intervention to manage Association erosion and adaptation to increasing flood risk to properties. PCR_38 Sunderland Point to Potts Corner should be HTL not NAI N Thank you for the helpful responses and points of detail which Propose to split the PU into 4: will be considered in finalising the SMP. Overton I object to the Shoreline Management Plan Review policy for unit 4:1, Sunderland Village to Potts PU 11c 4.1 Sunderland Village NAI/NAI/NAI Parish Council Corner which is NAI and ask that this be amended to HTL. The economic review uses national data sets for property values, PU 11c 4.2 Sunderland Point MR/MR/MR and is based on average prices for the type of property and The economic review on which the designation is based significantly underestimates the value of regional location, which is appropriate for use in national PU 11c 4.3 Sunderland Point to the secondary properties directly at risk from storm flooding and sea level rise and neglects the value of those which economic appraisals. As you have noted this gave a cash value of embankment NAI/NAI/NAI would become unsustainable as a result of the total loss of the waterfront properties. approximately £2.8 million for the 29 properties found to be at PU 11c 4.4 Secondary embankment to Potts Corner Also the review gives no indication that intangibles have been taken into consideration. Included in risk in the database. This indicates a value of about HTL/HTL/HTL these are that the village is a rare and virtually unspoiled example of an 18th Century waterfront, in a £95k/property. We have checked this against regional house conservation area with 16 listed buildings amongst a total of 38 dwellings. It is a popular recreation price data from the Land Registry, which indicates that at the See also PCR_31 regarding heritage value facility for visitors from a wide area. There is direct evidence that Sunderland Point draws more than time of the assessment, Q2 2009 the average house price in

50% of its visitors from outside the LA postal district (which is itself geographically extensive). The Lancaster region was approximately £115k, and terraced houses neighbouring policy unit PU 3:7 has a designation of HTL for the 0 - 20 year epoch moving to MR in approximately £67k, which is in line with our assessment but subsequent epochs. does not match your suggested approximate £300k per property. If the properties were valued as average detached This suggests a willingness to consider significant investment in sea defences and road re-alignment houses, (which we do not believe to be the case), at £223k, the which will be rendered much less viable economically if the line in PU 4:1 is not held. Logically PU 3:7 total would be £6.5 million. and PU 4:1 should be combined in a single unit as they are mutually dependant. We note your indication that there are actually 38 residential The value of the 29 properties at risk in PU 4:1 is grossly understated at £2,771,000, a more realistic properties that would be written off in the long term under a figure would be £8,776,000. With the loss of these the remaining 9 homes in the village would become

64 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? uneconomic to service resulting in a further loss of £3.936,000. Agricultural land is realistically valued in NAI policy. Based on average property values for the 38 the Review at £1,361,000 which suggests that the residential property valuation should be re-examined. properties, this gives a residential property value of £4.4 million. Under a baseline NAI economic evaluation infrastructure serving Other potential losses arise from damage to, or redundancy of, infrastructure. There is also a need to written off property cannot be included. The revised total cash add some weighting for the loss of intangibles. If all these considerations are given their true values the value of losses would therefore be £5.7 million. This would be cost benefit ratio will support a designation of HTL. equivalent to a discounted Present Value cost of £4 million if it is I propose therefore that policy units PU 3:7 and PU 4:1 be amalgamated as they are mutually dependant considered that write off would occur, on average, in year 10. and that HTL should be the Plan policy for the amalgamated units. Using the generic unit costs presented in Appendix H, we estimate that the cash costs of a HTL policy would need to include maintaining & improving when necessary 350m of seawall, 200m of revetment & 1350m of embankment. This would have a cash cost of about £10 million & PV cost estimate of about £3 million, including 60% Optimism Bias. This indicates that HTL could be economically viable as the BCR is >1 and would be increased by taking into account amenity and other intangibles. The above assessment also ignores the issue with the access road, which with nearly a meter of sea level rise will be cut off more often and for longer periods. Raising or relocating the road in the long term would add considerable costs. However, it has to be recognised that schemes achieving grant aid in the capital programme have needed to have BCRs greater than about 5 in recent years, and given the difficulty in seeking funding for this area since SMP1, it is considered appropriate that the policy remains no active intervention for Sunderland village. PCR_39 (Questionnaire from consultation meeting) N Response noted. Propose to split the PU into 4: Individual, Do not agree with changing policy from HTL to MR and eventually abandonment. See above responses re historical assets. PU 11c 4.1 Sunderland Village NAI/NAI/NAI Sunderland That the policy hasn't taken into account the social and historical importance of Sunderland Point. HTL Following consultation, propose to split the PU and policies to PU 11c 4.2 Sunderland Point MR/MR/MR Point policy would give residents a chance to raise money and 'look after' ourselves whereas MR would limit allow for further monitoring, limited intervention to manage Community PU 11c 4.3 Sunderland Point to the secondary funding available to protect our homes. erosion and adaptation to increasing flood risk to properties and Association embankment NAI/NAI/NAI heritage features. The old tip at Bowies field won't be protected therefore toxins will escape into the Lune causing PU 11c 4.4 Secondary embankment to Potts Corner pollution. Salt Ayr tip is being protected. The draft SMP policy was MR for the Cockersands Abbey HTL/HTL/HTL frontage, but is now proposed to change to HTL or MR in long The Chapter House at Cockersands is being protected even though it is uninhabited and receives few term. See also PCR_31 regarding heritage value visitors. Sunderland Point is an important historical place that thousands of people visit each year and the whole village is inhabited year round. PCR_40 (Questionnaire from consultation meeting) N See other related responses above. Individual, Inaccuracies in data used to make decisions Heritage sites such as Scheduled Monuments and Grade 1 & 2* Sunderland are given priority. How do you decide which heritage sites are of value? Sunderland Point is a conservation area. The Point presentation stated that sea defences may cause problems elsewhere - what happens if your area is the Following consultation, propose to split the PU and policies to Community elsewhere? allow for further monitoring, limited intervention to manage Association erosion and adaptation to increasing flood risk to properties and Is any protection offered to people or is the main concern for flora and fauna? heritage features.

65 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_41 (Questionnaire from consultation meeting) N A follow up consultation meeting with Sunderland Point Community Association was held on 6 th January 2010. PCR_42 Concerned with all our area of the coast. We need a meeting with ALL agencies concerned to put forward our views. Notes of meeting appended in Annex B7. Individuals, Sunderland Point Community Association PCR_106 I should like to voice my family's concern that the sea defences for Sunderland Point be maintained and Following review of this and similar responses, the proposal to Propose to split the PU into 4: improved. realign the road and allow the saltmarsh to develop more Individual, PU 11c 4.1 Sunderland Village NAI/NAI/NAI naturally has been dropped. My grandfather rented a holiday cottage on Sunderland Point from the early 1920s until 1958. We have PU 11c 4.2 Sunderland Point MR/MR/MR continued to visit the Point regularly and my parents have their memorial bench on the shore-line. See above responses and comments. Nothing beats the anticipation of embarking on the tidal road to the peace and beauty of the little PU 11c 4.3 Sunderland Point to the secondary hamlet. It must not be destroyed - and an alternative road must not be built!! embankment NAI/NAI/NAI Apart from allowing the destruction of a unique place, would not its disappearance affect erosion of PU 11c 4.4 Secondary embankment to Potts Corner other coastal areas? HTL/HTL/HTL I hope the Shoreline Management team will decide that Sunderland Point is worth conserving for many aesthetic, social and practical reasons. PCR_124 In particular Sunderland village / Potts corner - HTL should be retained. N Following consultation, propose to split the PU and policies to allow for further monitoring, limited intervention to manage Councillor, Sunderland Point is of strategic importance in protecting the Lune Estuary. Undervalues the heritage erosion and adaptation to increasing flood risk to properties and Lancaster City and socio-economic well being of the wider community. The Point is unique in many ways and an heritage features. Council extremely popular tourist attraction, not least Sambo's Grave. Prolific wildlife and natural habitats. The current HTL policy does not appear to be expensive, indeed it looks minimal. PCR_127 I am writing to protest at the plans to cease flood / sea defence works at the above location. As a Following consultation, propose to split the PU and policies to resident of Glasson Dock and also a yachtsman I am all too aware of the power of the sea. allow for further monitoring, limited intervention to manage Individual, erosion and adaptation to increasing flood risk to properties and Glasson Sunderland Point forms a vital 'finger' of defensive land breaking the momentum and power of the heritage features. incoming tide. I fear that if Sunderland Point is abandoned the surrounding coastline (to both the north and south) and particularly the estuary area, will then become exposed to the full power of the It is noted that there is uncertainty over the impact of erosion of incoming tide, and suffer avoidable flooding from the sea. the point on the wider estuary, and this helps justify limited intervention if required whilst further monitoring takes place. The areas that will be affected are well inhabited and include employment areas, which are particularly needed in an area where jobs are scarce. In addition a great deal of expense has recently been spent in an effort to protect the estuary as far north as Lancaster, and by allowing Sunderland Point to 'go' will cancel out much of this effort. I feel that the proposals are just considering Sunderland Point in isolation, and not fully considering the whole picture, and the vital role of Sunderland Point in slowing down the tide and reducing its destructive power. PCR_138 I am Leader of the Conservative Group on Lancaster City Council. I have been invited by the Response noted. Sunderland Point Community Association to read and comment on the Shoreline Management Plan Councillor, which is currently out for consultation. I cannot see any reason why Sunderland should not continue as Lancaster City a viable cultural, historical and residential proposition for the next 30/40 years at the very minimum at a Council cost which is practical, and therefore I ask that the Shoreline Management Plan should retain the Following consultation, propose to split the PU and policies to present designation of Hold The Line for both Overton Cattle Grid to Sunderland Village and allow for further monitoring, limited intervention to manage Sunderland Village to Potts Corner. erosion and adaptation to increasing flood risk to properties and I suppose the answer to the questions raised in the consultation partly depends on how much sea levels heritage features. will rise as a consequence of global warming / climate change, the melting of Greenland and Antarctic

66 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? ice sheets and the extra volume that water occupies when its temperature is higher. I cannot envisage "protecting" somewhere when average sea levels, even at low tide, are above the level of the entrances to buildings. The Dutch may have drained their land in centuries past - but I don't see that as viable for a footprint of land like Sunderland Point. However, I'm not convinced that the effects of global warming on sea level will happen quickly or at all - and in the meantime, I think the tourism potential of Sunderland Point probably justifies continuing support for "holding the line" - though not for major expenditure to do so. It may sound hard, but I think that residents in low lying areas ultimately have to take the risk that comes from living there - and that asset values in such areas will and do reflect such risks. When the risk is high enough, the asset will have declined down to its salvage value! Spending public money has to have benefit to the community generally - and not just to the owners of properties at Sunderland Point! In this case, however, I think there is continuing benefit to the public generally at the present time - but the cost/benefit has to be taken into account, and if sea levels rise "beyond reason", there will eventually be a time when continuing expenditure to defend Sunderland point becomes unreasonable. That time has not yet arrived. PCR_144 I write in support of the comments made by Sunderland Point Community Association appraisal (see N Following consultation, propose to split the PU and policies to Propose to split the PU into 4: PCR_137) . I have worked with the city engineer at Lancaster Council trying to find a solution to the allow for further monitoring, limited intervention to manage Individual, PU 11c 4.1 Sunderland Village NAI/NAI/NAI coastal erosion and was chair of the EA flood resilience project. The project drew attention to ways erosion and adaptation to increasing flood risk to properties and Heysham that further work and study would be necessary. heritage features. PU 11c 4.2 Sunderland Point MR/MR/MR PU 11c 4.3 Sunderland Point to the secondary embankment NAI/NAI/NAI PU 11c 4.4 Secondary embankment to Potts Corner HTL/HTL/HTL PCR_17 At last week's meeting at Lancaster I mentioned a slight error in the Draft Plan relating to the Earlier drafts of the proposed policies discussed with Sub-divide PU 4.1 to the north of Sunderland Brows secondary embankment that runs from the Overton defence to a location mid-way between Sunderland stakeholders did split PU 4.1 at Sunderland Brows farm, see farm to take into account the differing residual life EA Point and Potts Corner - it intersects North of Sunderland Brows Farm at 341880 456780. appendix G, draft policies for discussion, but these were merged and the linkage to the Overton defence. following discussions with the CSG, which appears to have been I suggest that we will need to subdivide Policy Unit 4.1. On the Western shoreline of Sunderland Point, a misunderstanding or mistake. Following the points raised by South of where the secondary embankment intersects the shoreline, the existing defence is indeed poor the EA NW, we now propose to revert to splitting the PU into and the Plan is probably correct in the assessment of its residual life as 6 to 10 years. However, 4: between this location and Potts Corner (Carr Lane) the embankment was substantially improved as part of the Overton and Middleton Sea Defence scheme in the late 1990s and has rock armour or PU 4.1 Sunderland Village smaller rip-rap on its seaward face. This embankment is designed to reduce risk of floodwater reaching PU 4.2 Sunderland Point both Middleton and Overton. Were water to get onto Carr Lane, this road slopes down towards Middleton, so there is potential for over land flow. From Carr Lane North (or a point about 100m or PU 4.3 Sunderland Point to the secondary embankment so N of the road) the ground is higher, so I don't think there are formal raised defences here. I think PU 4.4 Secondary embankment to Potts Corner. there is some erosion protection, though probably in poor condition, along the frontage of the caravan site immediately North of Carr Lane. The draft SMP2 proposes no active intervention for all 3 epochs for the entire length described above. Maybe this should now be split into 3 lengths instead? These would be: 1. Sunderland Point to the secondary embankment 2. secondary embankment to Potts Corner (Carr Lane) 3. Potts Corner northwards I suggest the middle length should have 'hold the line' at least for 20 years, but more likely for all 3

67 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? epochs, given its importance to properties in Middleton and Overton. The other 2 lengths should probably have 'no active intervention' for all 3 epochs, as stated currently in the draft Plan. Length (1), i.e. the section from Sunderland Point to the secondary embankment, acts as a primary defence. Adopting the SMP policy of no active intervention will ultimately lead to the poor quality embankment overtopping more frequently and an increased risk of breach. This in turn will expose the secondary embankment to wave action, possibly within 20 years. To counter this, the secondary embankment would need the addition of rock armour and some analysis doing/checking regarding appropriate crest level. An action to investigate the need or otherwise for these works could be put against length (2) above in the Draft Action Plan. PCR_113 The Community of Sunderland village have reviewed the Draft SMP in great detail. They have promised 1) We have reviewed the items raised for consistency Propose to split the PU into 4: to submit their own detailed response to the consultation, but the following points are expected to be checks and consider that there is no conflict, as the EA NW PU 11c 4.1 Sunderland Village NAI/NAI/NAI raised. In discussions so far, the Sunderland Community have made a case for reviewing the proposed situations are very different at the quoted locations. A policy of No Active Intervention (NAI) in the first epoch. We don't appear to fully understand the viability study was undertaken for Roa Island in advance PU 11c 4.2 Sunderland Point MR/MR/MR implications of pursuing this policy and key points that need to be considered further are: of the SMP and this confirmed the viability of the HTL PU 11c 4.3 Sunderland Point to the secondary policy. There are many more houses there and an 1) Consistency between policy units. Residents highlighted that other factors aside from embankment NAI/NAI/NAI important lifeboat station, and the causeway to the economics have been used to promote a Hold the Line (HTL) policy in the 1st epoch. For island is not tidal. Askam is not at flood risk and erosion PU 11c 4.4 Secondary embankment to Potts Corner example, Roa Island (PU 11c 13.4) has a HtL policy in the 1st epoch to continue to manage risk risk could be managed very economically. There is no HTL/HTL/HTL to neighbouring saltmarsh, mud flats, navigation channel and lifeboat station. In addition, proposed HTL policy for boast moorings in the Askam-in-Furness (PU 11c 16.2) has a HtL policy to maintain the integrity of Askam as a Duddon. coastal settlement). Residents also pointed to "boat moorings" in the Duddon Estuary which

have a HtL draft policy. 2) The Heysham port is considered a key economic driver to the Bay and hinterland. The existing understanding of Ongoing communications between the Sunderland 2) What is the impact of Heysham Port on the point and the rest of the area, including the Lune coastal processes is summarised in Appendix C, Section Point Community with the Environment Agency, Estuary and Morecambe Bay? J and Section K. In terms of coastal processes the port Lancaster City Council and Natural England need to 3) How does the impact of the Lune training walls affect Sunderland Point? and adjacent defences forming the Heysham ‘headland’ continue, and will be added to the Action Plan. constrains the deepwater channel and helps prevent 4) It appears that Sunderland village are the only community in the North West to have NAI in variability and landward migration to both south and the first epoch "without warning". Can there be sufficient justification for this? north. There are indications of a limited northerly 5) There is concern that the policy decision is based on insufficient accurate heritage information. directed littoral transport, so the Heysham headland This mirrors a wider concern from English Heritage regarding the value placed on heritage would encourage accumulation of material to the south, features in the policy testing stage. giving some slight protection to the Sunderland Point to Hesham frontage and encouraging the growth of 6) There is concern that the policy decision is based on insufficient accurate environmental saltmarsh. information. 3) In general the Lune training walls have constrained 7) How does the strategic importance of the point and its impact on the left bank of the Lune channel movements and influenced accretion of the estuary (Thurnham) affect policy unit categorisation? estuary and stabilisation of saltmarsh. There is The above suggest that a HTL policy should be considered for the first epoch, unless the above matters uncertainty over the impacts of the deterioration of the can be satisfactorily answered. It is important that the Consultation Report reflects the ongoing training walls, but they are not considered to be coast communications between the Sunderland Point Community with the Environment Agency, Lancaster protection structures. City Council and Natural England. 4) Sunderland Point Community Association has been represented at stakeholder meetings throughout SMP2 development, so it is not ‘without warning’. Discussions with stakeholders and the CSG indicated that NAI with the defences was the approach currently being taken and the draft SMP policy was considered to be a continuation of this. NAI was also proposed for many other frontages, where this was considered to reflect

68 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? the present management practice. 5) As the SMP appraisal is objective led and not driven primarily by economics, heritage assets have not been monetised to derive benefits. See earlier comments about heritage assets. 6) Better and more detailed information would always be appreciated. However, monitoring and further studies will cost more and stakeholders and EA have indicated that as previous studies have failed to justify capital works they do not consider these to be worthwhile now. 7) There have been at least two studies to assess this, e.g. see Appendix G, page G-89, although the results are contradictory. The predicted rate of erosion also needs to be considered. While the Point is expected to erode up to 100m over the SMP it is not going to be “lost”, and a new channel around the back of the village is not expected unless there were a long term regression to NAI for all the defences in the Lune and surrounding area, which is not being proposed; so in a strategic sense the point would remain even under NAI for Sunderland Point. Following consultation, propose to split the PU and policies to allow for further monitoring, limited intervention to manage erosion and adaptation to increasing flood risk to properties and heritage features. There is an error in the Draft Plan relating to the secondary embankment that runs from the Overton See earlier comment. The draft policy unit 4.1 has been split into Propose to split the PU into 4: defence to a location mid-way between Sunderland Point and Potts Corner - it intersects North of 4 units. See also PCR_17 above. PU 11c 4.1 Sunderland Village NAI/NAI/NAI Sunderland Brows Farm at 341880 456780. PU 11c 4.2 Sunderland Point MR/MR/MR It is suggested that Policy Unit 4.1 should be sub-divided. On the Western shoreline of Sunderland Repeat of comment PCR_17 above. Point, South of where the secondary embankment intersects the shoreline, the existing defence is PU 11c 4.3 Sunderland Point to the secondary indeed poor and the Plan is probably correct in the assessment of its residual life as 6 to 10 years. embankment NAI/NAI/NAI However, between this location and Potts Corner (Carr Lane) the embankment was substantially PU 11c 4.4 Secondary embankment to Potts Corner improved as part of the Overton and Middleton Sea Defence scheme in the late 1990s and has rock HTL/HTL/HTL armour or smaller rip-rap on its seaward face. This embankment is designed to reduce risk of floodwater reaching both Middleton and Overton. Were water to get onto Carr Lane, this road slopes down towards Middleton, so there is potential for over land flow. From Carr Lane North (or a point about 100m or so N of the road) the ground is higher, so I don't think there are formal raised defences here. I think there is some erosion protection, though probably in poor condition, along the frontage of the caravan site immediately North of Carr Lane. The draft SMP2 proposes ‘No Active Intervention’ for all 3 epochs for the entire length described Repeat of comment PCR_17 above. above. Maybe this should now be split into 3 lengths instead? These would be: 1. Sunderland Point to the secondary embankment 2. secondary embankment to Potts Corner (Carr Lane)

69 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? 3. Potts Corner northwards I suggest the middle length should have 'hold the line' at least for 20 years, but more likely for all 3 epochs, given its importance to properties in Middleton and Overton. The other 2 lengths should probably have 'no active intervention' for all 3 epochs, as stated currently in the draft Plan. Length (1), i.e. the section from Sunderland Point to the secondary embankment, acts as a primary defence. Adopting the SMP policy of no active intervention will ultimately lead to the poor quality embankment overtopping more frequently and an increased risk of breach. This in turn will expose the secondary embankment to wave action, possibly within 20 years. To counter this, the secondary embankment would need the addition of rock armour and some analysis doing/checking regarding appropriate crest level. An action to investigate the need or otherwise for these works could be put against length (2) above in the Draft Action Plan. PCR_150 Specifically Sunderland Point but other areas are also still being discussed - further discussion required. N Response noted. Further public meetings were undertaken and the response date for ongoing discussions was extended. Engineering and Projects, Lancaster City Council PCR_156 I would ask you to retain the designation of Hold the Line for both areas - and for the wider Lune Response noted. Ongoing communications between the Sunderland Estuary. Point Community with the Environment Agency, Individual Consultation responses were accepted from Sunderland Lancaster City Council and Natural England need to Sunderland Point and Sunderland Village are considered as part of Policy Units (i.e. sub-sections) 11 c3 residents up to the end of March and as well as the local meeting continue, and will be added to the Action Plan. and 11 c4. One section (Overton Cattle Grid to Sunderland Village) covers the access road across the on 6 th January there was a further meeting in Morecambe on 16 th marsh, whilst the other (Sunderland Village to Potts Corner) looks at the future of both the village and February. Propose to split the PU into 4: the Point. Following consultation, propose to split the PU and policies to PU 11c 4.1 Sunderland Village NAI/NAI/NAI The consultation document considers two options for each: allow for further monitoring, limited intervention to manage PU 11c 4.2 Sunderland Point MR/MR/MR erosion and adaptation to increasing flood risk to properties and Cattle Grid - Sunderland Village heritage features. PU 11c 4.3 Sunderland Point to the secondary Scenario A - HTL HTL HTL embankment NAI/NAI/NAI MR at the Point will allow for limited intervention to be Scenario B - HTL MR HTL undertaken to reduce the rate of erosion and buy time whilst PU 11c 4.4 Secondary embankment to Potts Corner further studies and monitoring are undertaken. HTL/HTL/HTL The preferred choice in the proposal out for consultation is Scenario B: Investigate Managed Realignment (0-20 years); then Managed Realignment (20-50 years); then Hold The [new] Line (50 – See also PCR_31 regarding heritage value 100 years)

Sunderland Village - Potts Corner

Scenario A - HTL HTL HTL

Scenario B - NAI NAI NAI The preferred choice in the proposal out for consultation is Scenario B: No Active Intervention for all three time periods In effect, SMP2 proposes for Sunderland Point a policy of Managed Realignment and No Active Intervention i.e. that the Point is allowed to continue to erode. This would represent a radical change from the previous Shoreline Management Plan, SMP1 I believe these proposals to be wrong for reasons summarised below. a) that the consultants who have written the report – acknowledged as essentially a ‘desk top study’ - have failed to recognise the value and importance of Sunderland Point to the wider community

70 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? b) that the acknowledged need for further study means it would be wrong to change the present designation of Hold the Line, which allows for maintenance and improvement of existing defences. Key Concerns Protecting the Lune Estuary The report does not acknowledge the impact Sunderland Point has in protecting the Lower and Middle Lune Estuary. In effect, the Point acts as a breakwater or harbour wall and continued erosion of the Point will have a detrimental impact on defences further inland. In military terms, preserving the ‘fortification effect’ of the Point will prevent much greater damage further inland. This view is supported both by academic analysis and by the common sense views of those who have lived in, fished and farmed locally for up to 70 years. Sunderland Point is the key natural feature protecting the Lower and Middle Lune Estuary. A Limited Analysis The cost-benefit analysis does not take account of numerous areas of importance. I can provide further details but in summary, these include: The cultural and historic significance of Sunderland Point in Britain’s maritime history – it was at one time the third largest port in the country. The locality is a Conservation Area, most buildings are Grade II listed and the Point is home to Sambo’s grave, with its inscription from the 18th century recognising the common humanity of men of all colours. The recreational and amenity aspects of the Point – frequented by walkers, birdwatchers, photographers, artists, sailors, educational groups, wildfowlers, anglers and cyclists. The locality is a unique landscape which comprises salt marsh, beach, farmland, historic buildings, mud flats, and a tidal estuary – all within a mile and providing habitat for many birds on the RSPB’s Red and Amber Lists; for the rare Belted Beauty moth; for Lune salmon; and for diverse other flora and fauna. There is a question of equity of treatment. Some factors taken into account for other areas in SMP2 apply equally to Sunderland, but appear not to have been considered for this area. You will be aware that the local Sunderland Point Community Association also questions some of the costs in the analysis and would like to be involved in a more detailed debate if economic considerations are the key determinant of an area’s designation. The analysis to date has been limited and has not taken account of many important aspects of the area – economic, social/cultural, and environmental. Limited Consultation The invitation to attend a consultation event, a Coastal Change Workshop in early December, was received on November 16th with a consultation closing date of January 10th, subsequently extended to February 14th. Many residents, land-owners and others with an interest in the area from both sides of the Lune were not informed of the workshop. This over-full meeting was followed up, after a request from the Sunderland Point Community Association, by a workshop on January 6th focused on the Sunderland locality. The condensed process has given the wider community insufficient time to digest the many and detailed appendices, to fully understand the proposals, and to prepare support for the alternative ‘Scenario A - Hold the Line’. The workshops have also suggested much mitigating work is in development by DEFRA and other organisations, should the worst impacts of No Active Intervention and/or Managed Realignment be realised. However, there is no certainty that these will become adopted policy and the

71 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? impact/implications of SMP2 are thus unknown to those who live, work and visit the area. The consultation has been limited and has not made clear the implications of any changes to designation for Hold the Line. The Action Plan For the Lune Estuary (Policy Unit 11 c 3) and for Sunderland Village to Potts Corner (Policy Unit 11 c 4) the draft SMP2 document includes proposed action plans. I recognise the value of these and welcome them as an indication of future thinking. However for the Lune Estuary the first action is “Undertake a strategy study and consultation required to confirm the approach for delivering the SMP policies for the overall estuary” and for Sunderland Village to Potts Corner the first action is “Undertake/update more detailed study for Sunderland Village and the access road in Policy Unit 3.7. Include consultation and more detailed socio-economic evaluation of potential impacts and affordability of local or private defences and resilience or adaptation. Develop more specific approaches to deliver SMP Policies and inform future policy decisions at the next SMP” Insufficient analysis, consultation and clarity re. implications for these two Policy areas has been carried out and thus it would be wrong to change the designation from Hold the Line. Conclusion In summary, I recognise the work carried out to date in a desk top analysis of Sunderland Point and the work in developing the proposed action plan. However, a desk top study, by its nature, will often fail to appreciate what is actually happening on the ground. I believe the proposal to change the designation from Hold the Line to be wrong because: it undervalues the strategic importance of Sunderland Point in protecting the Lune Estuary; it undervalues many aspects of the heritage and socio-economic well- being of the wider community; the approach has focused on the impacts within individual Policy Units. It has failed to recognise that proposals for one Policy Unit have impacts on neighbouring Policy Units also, in this instance the broader Lune Estuary.

The designation of Hold the Line should therefore be maintained for both sub-sections 11 c 3 and 11 c 4. PCR_159 I am writing t o inform you that I am outraged at the No Active Intervention policy that is proposed for Response noted on historic environment in this and other See above changes Sunderland Point. I am in full support of the hold the line policy for both units being considered: from responses. Individual, the cattle grid to Sunderland point and Sunderland Village to Potts Corner. Overton See above comments on similar issues. Taking the comments I have lived in Overton all of my life and now run the local equestrian centre in Overton. We regularly into account we now propose to split 11c 4 split policy unit into use Sunderland Point as one of our riding routes as it is the only bridlepath in the area in which you can 4 sections: ride a circular route and not just ride up and down a track for 1/2 a mile to turn round and come the Sunderland Village – continue with no active intervention same way back. Both myself and my clients enjoy the uniqueness of Sunderland point and the wild life however, but also allow for continued work on individual that is attracted to this haven and also visiting Sambo's grave, I also always feel very proud telling my property defences and flood resilience subject to consent. clients the history of Sunderland Point and as I have always had friends living there as well it is a place very close to my heart. Sunderland Point – managed realignment to manage erosion risk If we lose Sunderland Point because of this policy it will be the biggest mistake ever made in this Sunderland Point to the secondary embankment – no active country as apart from it having implications on the river bank further up the Lune, it will decrease the intervention quality of life of many people and when we have 2 concrete block power stations and a 3rd about to be North of the secondary embankment to Potts Corner - the built it is very nice to be able to get to the coast without that looming in the background. policy is proposed to revert to HTL / HTL / HTL to reflect the On a personal level I would like to share a true story with you which will hopefully bring home just how importance of the defences here to Overton.

72 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? special this place is: The policy unit 11c 3.7, For the Cattle grid to Sunderland Village is now proposed as HTL / HTL / MR, and reference to realigning It was New Years Eve a couple of years ago and one of the locals was rather drunk and needed to be the road will be removed. taken home to Sunderland Point, being one of the few in the pub that doesn’t drink alcohol I was called upon to take him home in our 4x4, the tide was just covering the road, it was a clear night with a lot of moonlight and the water was very still and melancholy. We dropped our charge at his house and made our way back before the tide was much deeper on the road, as we drove off the gravel at Sunderland point our car headlights shone on 3 herons, 2 stood in the water and 1 just taking off for flight, with the lights, the mist and the sight of 3 herons I felt so lucky to have seen such a magical sight and it is something that really humbles me and I will never forget this for the rest of my life. It is so important that we save such places because once it’s gone there is no going back. From another angle our farm is on what was once marshland which was originally reclaimed when the sea defence went up, we have recently been doing building works and we have dug down and found seams of Golden Sand and what was a rocky beach, in a way it is sad that this coastline was lost due to reclamation, but please don’t let us lose the Sunderland Point from erosion as that cannot ever be gotten back. I hope you consider my comments in your decision. PCR_167 Lancaster Civic Society is concerned at the proposals for Sunderland Point under the Shoreline Responses regarding the heritage importance are noted and will Recognise the heritage value of Sunderland Point in Management Plan. be reflected in the revised summary document. the policy statement. See also PCR_31 regarding Lancaster heritage value Civic Society Sunderland Point is a Conservation Area with a number of Grade II listed buildings and an area which It should be noted that most of the frontage does not have has played an important part in the history of Lancaster. It is also much valued for its recreational existing effective defences, so it is not a practical proposition to Propose to split the PU into 4: amenities and has considerable tourist potential. “maintain the existing defences” over the 100 year period of the PU 11c 4.1 Sunderland Village NAI/NAI/NAI SMP which has to allow for the impacts of sea level rise. We very much hope that it will be possible to maintain the flood defences in this historic area. However, the policy of no active intervention will still allow local PU 11c 4.2 Sunderland Point MR/MR/MR defences, and limited intervention to help manage the onset of PU 11c 4.3 Sunderland Point to the secondary coastal change. embankment NAI/NAI/NAI PU 11c 4.4 Secondary embankment to Potts Corner HTL/HTL/HTL PCR_128 I enclose a document which was sent to me recently by a Community Association representing See PCR_137 interested parties from Sunderland Point. I wish to endorse their sentiments in every detail and ask you Lancaster City to pay particular attention to sections 3 and 4. Council and Morecambe See PCR_137 Town Council PCR_191 I have examined the SMP documentation and note that Policy units 11c3 and 11c4 are proposed for Thank you for the response. As you will be aware much of the For 11c 3.7, revise policy approach to remove policy change from the present HTL recommended in the original SMP. I apologise for making this existing coastline for these policy units does not have coast reference to the road and show HTL/HTL/MR, with Individual representation outside your consultation period but I have been overseas for several weeks. protection in place and the HTL policy set in the original SMP the MR setting back to the existing secondary around 10 years ago has not been implemented in practice. defence for Overton in the 3 rd epoch, subject to As you are aware I have worked on the Lune estuary and Morecambe Bay since 1983 and have further monitoring and investigations. therefore gained knowledge of shoreline evolution over the period. Having project-managed the Lune The project team notes the comments on uncertainties and estuary study (undertaken in part by Halcrow) on behalf of Lancaster CC I have also gained a thorough conflicting information. In response to this and other similar Propose to split the PU into 4: technical appreciation of the physical process regime. From the information available on your web site I responses on this frontage the PU has now been split into 4 PU 11c 4.1 Sunderland Village NAI/NAI/NAI have to advise you that in my opinion the evidence-base is inadequate and the data interpretation flawed units. The proposed SMP policy for Sunderland Point has been with regard to sufficient understanding of the Lune estuary and its shoreline evolution to justify policy revised to MR in all 3 epochs. PU 11c 4.2 Sunderland Point MR/MR/MR change. Bearing in mind also that the DEFRA guidance on sea level rise from 1990 to present is clearly

73 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? incorrect for the Irish sea and overestimates sea level rise by a factor of two it would appear premature For PU 3.7 the policy has been revised to HTL in short and PU 11c 4.3 Sunderland Point to the secondary to adopt policy change in this area at this time. medium term. embankment NAI/NAI/NAI Further studies and monitoring are recommended and once these are taken forward then I anticipate PU 11c 4.4 Secondary embankment to Potts Corner my reservations would be reduced although the recommended policies may change also. In the mean HTL/HTL/HTL time I have to challenge the policy recommendations made and request reinstatement of HTL policies

for the first two epochs until the evidence-base is robust enough to justify the raising of anxiety in the local community. I shall be pleased to discuss any matters arising at your convenience. PCR_137 Please find attached an appraisal detailing the concerns of the Sunderland Point Community with the The SMP appraisal is objective led and not driven primarily by Recognise the heritage value of Sunderland Point in SMP2 proposals for the two locations which affect them directly, i.e. Overton Cattle Grid to economics, heritage assets have not been monetised to derive the policy statement. Sunderland Sunderland Village (11c 3.7) and Sunderland Village to Potts Corner (11c 4). We believe that if the benefits. See earlier comments about heritage assets. Point For 11c 3.7, revise policy approach to remove proposals are implemented, they will have seriously damaging effects not just on Sunderland Point but Community In addition to a meeting at the Lancaster House Hotel there reference to the road and show HTL/HTL/MR, with also within the larger area of the lower and middle Lune Estuary. As Individuals and as a community Association were meetings with Sunderland residents at Overton on 6 th the MR setting back to the existing secondary association we are writing to express our concerns about the proposals because (a) we believe an January and Morecambe on 16 th February. In addition, defence for Overton in the 3 rd epoch, subject to insufficiently robust study has been carried out which appears to have essentially been a 'desk top consultation feedback from Sunderland residents were accepted further monitoring and investigations. exercise'; (b) we believe there has been insufficient time for a full and proper consultation and for an up to the end of March. explanation of the impact of the proposed changes; (c) we recognise the importance of carrying out Propose to split the PU into 4: further analysis, as is proposed in the action plan, and believe the present designation should remain Following consultation, propose to split the PU and policies to PU 11c 4.1 Sunderland Village NAI/NAI/NAI unchanged in advance of such analysis. We request that the SMP retain the present designation of HTL allow for further monitoring, limited intervention to manage for both locations Overton Cattle Grid to Sunderland Village and Sunderland Village to Potts Corner. erosion and adaptation to increasing flood risk to properties and PU 11c 4.2 Sunderland Point MR/MR/MR heritage features. PU 11c 4.3 Sunderland Point to the secondary embankment NAI/NAI/NAI PU 11c 4.4 Secondary embankment to Potts Corner HTL/HTL/HTL 1. Background Response noted The North West England and North Wales Shoreline Management Plan 2 (SMP2) is a strategic, non- statutory plan which provides a large-scale assessment of the risks associated with coastal processes

such as waves and tides. It has increasing relevance in the light of anticipated climate change. SMPs are an important part of the Government’s strategy for managing flooding and coastal erosion and it is placed at the top of the agenda by most authorities when considering their future budgeting priorities.

SMP2 considers three timelines: 0-20 years, 20-50 years and 50-100 years. It allocates to each sector of

the coast or policy unit one of four options: Advance the Line (ATL); Hold the Line (HTL); Managed Realignment (MR); No Active Intervention (NAI). It justifies its preferred option according to three criteria: Social, Environmental and Economic and assess the impacts of its choice under eight headings: Property and Population; Land Use, Infrastructure

and Material Assets; Amenity and Recreational Use; Historic Environment, Landscape, Character & Visual Amenity; Earth Heritage, Soils and Geology; Water; Biodiversity, Flora and Fauna. 2. Sunderland Point and Sunderland Village Sunderland Point and Sunderland Village are considered as part of Policy Units (i.e. sub-sections) 11 c3 and 11 c4. One section (Overton Cattle Grid to Sunderland Village) covers the causeway across the marsh, whilst the other (Sunderland Village to Potts Corner) looks at the future of both the village and the Point. The consultation document considers two options for each:

74 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Cattle Grid – Sunderland Village Scenario A - HTL HTL HTL Scenario B - HTL MR HTL The preferred choice in the proposal out for consultation is Scenario B: Investigate Managed Realignment (0-20 years); then Managed Realignment (20-50 years); then Hold the [new] Line (50-100 years). Sunderland Village – Potts Corner Scenario A - HTL HTL HTL Scenario B - NAI NAI NAI The preferred choice in the proposal out for consultation is Scenario B: No Active Intervention for all three time periods. These proposals represent a radical change from the previous Shoreline Management Plan, SMP1, and mean that effectively no attempts will be made to halt the erosion at Sunderland Point. The Sunderland Point Community Association is a newly created local forum allowing local residents a joint voice in responding to proposals. The Community Association consider these proposals to be wrong for reasons summarised below. The Association has already given its reasons verbally and in more detail to representatives of Lancaster City Council and the Environment Agency at Consultation meetings. They are currently being written up formally. As outline below, we believe a) that the consultants who have written the report – acknowledged as essentially a ‘desk top study’ – have failed to recognise the importance or value of Sunderland Point to the wider community b) that the process itself has not allowed sufficient time or opportunity for consultation and c) that the acknowledged need for further study means it would be wrong to change the present designation of Hold the Line, which allows for maintenance and improvement of existing defences. 3. Key Concerns Due to the uncertainty around the potential importance that Sunderland Point has on the Lune estuary as a whole, we agree 3.1 Protecting the Lune Estuary that a more proactive policy such as managed realignment would The report does not acknowledge the impact Sunderland Point has in protecting the Lower and Middle be more appropriate to manage erosion and future integrity of Lune Estuary. In effect, the Point acts as a breakwater or harbour wall and continued erosion of the Sunderland Point. We therefore propose to have a new PU for Point will have a detrimental impact on defences further inland. In military terms, preserving the Sunderland Point with a policy of MR for all 3 epochs to manage ‘fortification effect’ of the Point will prevent much greater damage further inland. This view is supported erosion and buy time whilst further studies and monitoring are both by academic analysis and by the common sense views of those who have lived in, fished and farmed undertaken. locally for up to 70 years.

Sunderland Point is the key natural feature protecting the Lower and Middle Lune Estuary. 3.2 A Limited Analysis See comment on PCR_38 The cost-benefit analysis, which is the principal criteria used to formulate the proposals, does not take account of numerous areas of importance. These include: • The cultural and historic significance of Sunderland Point in Britain’s maritime history – it was at one time the third largest port in the country.

75 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? • The locality is a Conservation Area, most buildings are Grade II listed and the Point is home to Samboo’s grave, with its inscription from the 18 th century recognising the common humanity of men of all colours • The recreational and amenity aspects of the Point – frequented by walkers, birdwatchers, photographers, artists, sailors, educational groups, wildfowlers, anglers and cyclists. • The locality is a unique landscape which comprises salt marsh, beach, farmland, historic buildings, mud flats, and a tidal estuary – all within a mile and providing habitat for many birds on the RSPB’s Red and Amber Lists; for the rare Belted Beauty moth; for Lune salmon; and for diverse other flora and fauna. • There is a question of equity of treatment. Many factors considered for other areas and which apply equally to Sunderland, appear not to have been taken into account. The Community Association also questions some of the costs in the analysis and would like to be involved in a more detailed debate if economic considerations are the key determinant of an area’s designation. The analysis to date has been limited and has not taken account of many important aspects of the area – economic, social/cultural, and environmental. 3.3 Limited Consultation Members of the Sunderland Point Community Association have been involved from an early stage and throughout the SMP2 The invitation to attend a consultation event, a Coastal Change Workshop in early December, was process as part of the ‘key stakeholder’ group. received on November 16 th with a consultation closing date of January 10 th , subsequently extended to February 14 th . Many residents, land-owners and others with an interest in the area from both sides of These members have been involved in a number of workshops the Lune were not informed of the workshop. This over-full meeting was followed up, after a request undertaken at key stages throughout the development of the from the Community Association, by a workshop on January 6 th focused on the Sunderland locality. The SMP2. condensed process has given the wider community insufficient time to digest the many and detailed In addition to the public meetings organised as part of the SMP2 appendices, to fully understand the proposals, and to prepare support for the alternative ‘Scenario A public consultation, discussions are ongoing between the – Hold the Line’ . Sunderland Point Community Association, the EA and Lancaster The workshops have also suggested much mitigating work is in development by Defra and other Council with regards to management at Sunderland Point village. organisations, should the worst impacts of No Active Intervention and/or Managed Realignment be realised. However, there is no certainty that these will become adopted policy and the impact/ implications of SMP2 are thus unknown to those who live, work and visit the area. The consultation has been limited and has not made fully clear the implications of any change to the present designation of ‘Hold the Line’. 3.4 The Action Plan 11c 3 .7 - We agree maintaining the existing alignment of the Update actions accordingly road in the short to medium term could be more cost effective, For the Lune Estuary (Policy Unit 11 c 3.7) and for Sunderland Village to Potts Corner (Policy Unit 11 but at the broad scale analysis for the SMP even this is not c4) the draft SMP2 document includes proposed action plans. We recognise the value of these and justified. However, realigning the embankment in the long term welcome them as an indication of future thinking. back to the existing cross-bank could potentially lead to creation However for the Lune Estuary the first action is of habitats required for environmental targets and therefore be a trigger to enabling a scheme that would allow adaptation. “Undertake a strategy study and consultation required to confirm the approach for delivering the SMP Removing the road from the marsh may be beneficial for the policies for the overall estuary” internationally designated sites in the future, but we agree the and for Sunderland Village to Potts Corner the first action is road is not part of the flood defence system and so will remove reference to it (see above responses and comments). Following “Undertake/update more detailed study for Sunderland Village and the access road in Policy Unit 11c3. review of responses the policy is now proposed to change to Include consultation and more detailed socio-economic evaluation of potential impacts and affordability of local HTL/ HTL/MR and consequently the action in the action plan will or private defences and resilience or adaptation. Develop more specific approaches to deliver SMP Policies and

76 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? inform future policy decisions at the next SMP” be revised to reflect this. Insufficient analysis or consultation has been carried out. There is a lack of clarity re. implications for these two Policy areas and thus it would be wrong to change the designation from Hold the Line. 4. Conclusion Taking the responses into account we now propose to split 11c Propose to split the PU into 4: 4 split policy unit into 4 sections: We recognise the work carried out to date in a desk top analysis of Sunderland Point and the work in PU 11c 4.1 Sunderland Village NAI/NAI/NAI developing the proposed action plan. However, a desk top study, by its nature, will often fail to Sunderland Village – continue with no active intervention PU 11c 4.2 Sunderland Point MR/MR/MR appreciate what is actually happening on the ground. however, but also allow for continued work on individual property defences and flood resilience subject to consent. PU 11c 4.3 Sunderland Point to the secondary We believe the proposal to change the designation from Hold the Line to be wrong because: embankment NAI/NAI/NAI Sunderland Point – managed realignment to manage erosion risk • It undervalues the strategic important of Sunderland Point in protecting the Lune Estuary; PU 11c 4.4 Secondary embankment to Potts Corner Sunderland Point to the secondary embankment – no active • It undervalues many aspects of the heritage and socio-economic well-being of the wider HTL/HTL/HTL intervention community; North of the secondary embankment to Potts Corner - the • There has been insufficient time for consultation and feedback; policy is proposed to revert to HTL / HTL / HTL to reflect the • The approach has focused on the impacts within individual Policy Units and has failed to importance of the defences here to Overton. recognise how proposals for one Policy Unit relate to and have impacts on neighbouring Policy The policy unit 11c 3.7, For the Cattle grid to Sunderland Village Units. is now proposed as HTL / HTL / MR, and reference to realigning The designation of Hold the Line should therefore be maintained for both sub-sections 11 the road will be removed. c3.7 and 11c4. PCR_209 You will have recently received a consultation response from the Sunderland Point Community See comment on PCR_137 Propose to split the PU into 4: Association ( See PCR_137 ). I write to support that response. The economic assessment is far too Individual PU 11c 4.1 Sunderland Village NAI/NAI/NAI narrowly based. Sunderland Point has an importance and value to the wider community because of its history - numerous visitors bear witness to that. The draft documents contain omissions, inaccuracies PU 11c 4.2 Sunderland Point MR/MR/MR and inconsistencies which lead to doubts about the validity of the recommendations. It is very important PU 11c 4.3 Sunderland Point to the secondary to the community of Sunderland Point to retain the (SMP1) designation of Hold the Line (HTL) and not embankment NAI/NAI/NAI to downgrade to No Active Intervention (NAI). I would ask the Coastal Group to look again at their proposals for this part of the coast. PU 11c 4.4 Secondary embankment to Potts Corner HTL/HTL/HTL PCR_217 You will have recently received a consultation response from the Sunderland Point Community See comment on PCR_137 Association. I write to support that response. The economic assessment is far too narrowly based. Individual Sunderland Point has an importance and value to the wider community because of its history - numerous visitors bear witness to that. The draft documents contain omissions, inaccuracies and inconsistencies which lead to doubts about the validity of the recommendations. It is very important to the community of Sunderland Point to retain the (SMP1) designation of Hold the Line (HTL) and not to downgrade to No Active Intervention (NAI). I would ask the Coastal Group to look again at their proposals for this part of the coast. PCR_218 I am writing with regards to the downgrading of the SMP for Sunderland Point from HTL to NAI. I See comment on PCR_137 believe that the main criteria used to make this decision is based purely on the economic which Individual immediately disadvantages small communities like Sunderland Point. It therefore disregards and Morcambe undervalues the history, its importance to wildlife and the number of visitors the village attracts each year. As one of these visitors I feel very strongly that the SMP policy for Sunderland Point remains as HTL. Thank you for taking the time to read this letter. PCR_219 I write to support the recent consultation response submitted by the Sunderland Point Community The SMP appraisal is objective led and not driven primarily by Association. I agree with the association's objections regarding the very limited economic assessment economics. Individual carried out by the Environment Agency. Sunderland Point is an important historical area and this is

77 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? evidenced by the numerous visitors who go there. See comment on PCR_137 The validity of the recommendations detailed within the draft documents is questionable given the number of errors, omissions and inaccuracies held within it. I strongly believe that it is imperative that Sunderland Point retain the (SMP1) designation of Hold the Line (HTL) and not to downgrade to No Active Intervention (NAI). I would be most grateful if the Coastal Group could review their proposals for this part of the coast. PCR_220 I am writing to voice my concern about the downgraded status of Sunderland Point to 'No Active See comment on PCR_137 Propose to split the PU into 4: Intervention'. I would urge you to support the community of Sunderland Point and return the status to Individual PU 11c 4.1 Sunderland Village NAI/NAI/NAI 'Hold the Line' and safeguard the future of this beautiful place. PU 11c 4.2 Sunderland Point MR/MR/MR PCR_221 I write to offer a view on the shoreline management proposals for Sunderland Point. This is a small and The consultation draft SMP proposed no active intervention for potentially vulnerable coastal settlement, that has a rich history behind it. I understand that there is a the estuary defences, but recommended that further work was PU 11c 4.3 Sunderland Point to the secondary Individual proposal for no active intervention. This is simply wrong for all sorts of reasons, not least of which is undertaken on local property defences and flood resilience, in embankment NAI/NAI/NAI the fact that the Sunderland Point Community Association has been very active in upgrading the existing support of, and continuation of, the work already done by the PU 11c 4.4 Secondary embankment to Potts Corner flood defences, with some council and Defra help, but with an awful lot of self help. For this community community association, the council and Defra. HTL/HTL/HTL to receive what is effectively a downgrading is a severe and totally unjustified setback. Such isolated Although there was a policy of HTL in SMP1, in practice the communities need support not intransigence from bureaucratic organisations. majority of the shoreline is undefended. The correct course of action is to support the Sunderland Point Community Association, and I believe Following review of these responses and many others received that the status should be changed back to "Hold the Line". I thought that maybe the brief of the for this frontage the project team now proposes to split the PU Environment Agency should be to protect the Environment, and support vulnerable coastal and policies to allow for further monitoring, limited intervention communities, such as Sunderland Point, but perhaps I am mistaken. Why will the Environment Agency to manage erosion and adaptation to increasing flood risk to not support the local community in their admirable efforts to cope with the very real threats posed to properties and heritage features. Sunderland Point by rising sea levels?

PCR_222 I am writing in regard to the SMP2 and in particular to the section Sunderland Village to Potts Corner. I Response noted. It is not correct to say that purely financial understand that the preferred choice in regard to this section is NAI rather than HTL. In opting for NAI grounds are used. Individual I feel that this is based on a lack of recognition of the historic nature of the Point, the considerable Sunderland Following review of these comments and many others received number of houses that have Listed Building status and the fact that many people come here for Point for this frontage the project team now proposes to split the PU recreation - to walk, paint, take photographs, watch the great variety of bird life or just enjoy the and policies to allow for further monitoring, limited intervention uniqueness of the location. It is high on the list of the places of interest advertised by the Lancaster to manage erosion and adaptation to increasing flood risk to Tourist Information department. properties and heritage features. It would appear that you are basing your judgement in regard to Sunderland Point solely on Financial

grounds, and in so doing prejudicing any efforts to raise funds from other sources, or indeed to obtain permission from other regulatory bodies to carry out any flood protection measures. It is for these reasons that I therefore request that your preferred choice in respect of the coastline from Sunderland Point to Potts corner be raised from NAI to HTL even if a proviso is included such as 'subject to funds being available'. PCR_225 My wife and I have been Sunderland Point residents for over 26 years though we have known the place Following review of these responses and many others received Propose to split the PU into 4: since childhood and my family connections with the village go back to the 18th Century. You will for this frontage the project team now proposes to split the PU Individual PU 11c 4.1 Sunderland Village NAI/NAI/NAI therefore appreciate our concern over the SMP for the Morecambe Bay area and in particular how it and policies to allow for further monitoring, limited intervention Sunderland affects our village. to manage erosion and adaptation to increasing flood risk to PU 11c 4.2 Sunderland Point MR/MR/MR Point properties and heritage features. The village in its unique setting and its historical association with the growth of Lancaster during the PU 11c 4.3 Sunderland Point to the secondary 18th C, continues to attract visitors from all over. In addition we have regular visits from artists, bird embankment NAI/NAI/NAI watchers, photographers and parties organised by schools, societies and the tourist office. PU 11c 4.4 Secondary embankment to Potts Corner As I understand it is adopt a 'laissez-faire' attitude as regards existing sea defences is very short-sighted HTL/HTL/HTL

78 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? and would lead to the loss of valuable agricultural land when we are being encouraged to be self- sufficient in food production. I enclose a copy of my brother-in-law’s history of the village of which over 8,000 copies have been sold (all locally). This is just another indication of what we have and we should hold onto! PCR_226 You will have recently received a consultation response from the Sunderland Point Community Response noted. It is not correct to say that purely financial Association. I write to support that response. The economic assessment is far too narrowly based. grounds are used. Individual Sunderland Point has an importance and value to the wider community because of its history - Following review of these comments and many others received numerous visitors bear witness to that. The draft documents contain omissions, inaccuracies and for this frontage, the project team now proposes to split the PU inconsistencies which lead to doubts about the validity of the recommendations. It is very important to and policies to allow for further monitoring, limited intervention the community of Sunderland Point to retain the (SMP1) designation of Hold the Line (HTL) and not to to manage erosion and adaptation to increasing flood risk to downgrade to No Active Intervention (NAI). I would ask the Coastal Group to look again at their properties and heritage features. proposals for this part of the coast.

PCR_227 There has been a community at Sunderland Village for several centuries with records of storms dating Thank you for the response and additional information provided. back to the early 1700s with their erosive effect on Sunderland Point. Recent investigations into the Sunderland coastal and estuarial physical processes affecting the area date from the early 1990s, when the National Point Rivers Authority (now Environment Agency) reviewed their tidal defences between Overton and Community Middleton. This study concluded that the defence line should be re-positioned to landward of Association Sunderland Village thereby reducing costs. The realigned tidal defence was completed in the mid 1990s and the residents of Sunderland Village were naturally concerned over the future of their sea wall (now to seaward of the realigned tidal defence) and the exposure of the village to inundation by the sea.

Between 1995 and 2005 there were several significant studies commissioned by Lancaster City Council,

to investigate the erosion of Sunderland Point and options for flood alleviation of the village. Within this period there have been two major plans prepared addressing shoreline management at Sunderland The assessment presented in Appendix C, page C-457 refers to Village: the unlikely baseline scenario of a No Active Intervention Policy for all of the defences in and around the Lune estuary. This

approach is not what has been proposed in the draft SMP2. If all _ Morecambe Bay Shoreline Management Plan (1999) defences in the Lune were to be abandoned then tidal flows in the Lune would significantly increase due to the additional tidal _ Lower Lune Flood Risk Management Strategy (2005) flooded area inland and in combination with long term sea level rise there could be potential for a new or additional channel to form. Both of these plans recommended ‘hold-the-line’ regarding the village frontage. The project team notes the comments on uncertainties and In 2006 the Government issued guidance for the preparation of the next round of shoreline conflicting information. In response to this and other similar management plans (SMP2) due for completion in 2010. The SMP2 draft document for the Lune Estuary responses on this frontage the PU has now been split into 4 and Morecambe Bay is now in the public consultation phase. units. SMP2 differs radically from earlier plans by proposing a ‘No Active Intervention’ policy, which is a Sunderland Village – continue with no active intervention complete reversal of the earlier proposals, and which over the 100 year period that the plan attempts however, but also allow for continued work on individual to cover, could lead to the total breakdown of the defences and the potential formation of a new property defences and flood resilience subject to consent. channel north of Sunderland Point linking the Lune Channel with the sea. (Appendix C - Baseline Process Understanding Page C-457) Sunderland Point – managed realignment to manage erosion risk Due to these changes, the viability of properties in Sunderland village is likely to be compromised and Sunderland Point to the secondary embankment – no active more drastic adaptation or abandonment may be required. (Appendix G – Policy Scenario Testing Page intervention G-90) North of the secondary embankment to Potts Corner - the The community of Sunderland Point expresses its serious concerns over this proposal and would policy is proposed to revert to HTL / HTL / HTL to reflect the welcome an explanation as to what has prompted such a dramatic change in the policy which has been

79 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? in force until now. They consider that the SMP2 document does not appreciate the importance of importance of the defences here to Overton. Sunderland Point, either geographically or socially. Key Concerns - Protection of the Lune Estuary. The Baseline Process understanding predicts that with no active intervention, the mouth of the estuary The baseline assessment in Appendix C recognises the will widen as Sunderland Point continues to erode, allowing increased wave energy to enter into the importance of the “scars” at the mouth of the outer estuary, estuary during storm conditions and high water levels. (This prediction is in direct contradiction of the which control wave energy entering the estuary more than the JBA Consulting Technical Note 2008 which states that the extent of the promontory itself has little point itself. It also notes that with sea level rise the influence of influence on wave conditions within the estuary.) As it moves up-river, the wave energy might be the scars will reduce, effectively widening the mouth. expected to be attenuated by the presence of areas of marsh. It has incorrectly been assumed that The assessment predicts that with failure of the training walls the these areas of marsh are stable, whereas in reality, they are undergoing rapid erosion, particularly in the channel in the outer estuary will start to meander, and that this area of the Point itself and at Overton, Colloway and Aldcliffe. could result in erosion on the meanders of up to 10m/year. The main factor that has contributed to the historical change of the low water channel and saltmarsh However as the estuary is flood dominated, the eroded material and mudflat habitats within the Lune Estuary is believed to be the construction of the various channel is expected to be largely distributed in the estuary rather than training walls. Decline of the training walls is now failing to retain the main channel against its natural lost out into the Bay. Due to the redistribution of material in the path at some locations (Halcrow, 2002b) and is responsible for meander bend extension and erosion of estuary the overall volume is expected to remain relatively the saltmarsh edge at Overton and Aldcliffe. stable. Due to the meandering this does not mean that specific areas will be stable. It is also predicted that as sea levels rise, flooding of low- lying land will increase. Inundation will become more frequent and north of Sunderland village, eventual extensive flooding may result in the formation of a new channel linking the Lune Channel to the sea.

Inundation of large areas would result in the estuary significantly increasing in size as the shoreline

realigns. This would move the estuary away from its current dynamic stability which would result in an increase in the tidal prism and deepening of the main channel. (SMP2 Appendix C - Pages C-455 to 457.) Again this relate to the baseline assessment of no active As a result of these changes, it would be reasonable to expect that there will be an increased risk of intervention for the whole estuary and do not represent the flooding especially under storm surge conditions at Glasson, Conder Green, Aldcliffe and further assessment of the proposed policies put forward, which allow for upstream as far as Lancaster itself, with associated damage to property and infrastructure. In particular, HTL policies at Glasson, and in the inner estuary. the potential losses to businesses around Glasson and the damage to the sewage treatment works at

Stodday could be significant. Whilst the stated objective is to continue to protect infrastructure, the preferred policy appears to be completely at odds with it. The long term viability of the properties at Sunderland Point was questioned under both Scenario A & B, so there are limited long The works outlined in Scenario A (SMP2 Appendix G - Policy Scenario Testing - Page G-88) are the term benefits as under HTL the village would become effectively obvious countermeasure to these risks, and it is impossible to understand why ‘hold the line’ has not ringed by defences and cut off unless the road were relocated. been adopted as the preferred policy . Key Concerns - Economic justification The Overview to the Draft Recommendations states “Comparison of the value of the assets at flood See earlier comment on PCR_38 above. and erosion risk in Sunderland Village to the cost of the defending the frontage, has shown that there is not sufficient justification to secure national funding for long term flood risk management.” This statement illustrates the differing views as to the assets at risk. Just as the estuary should be viewed as an entity rather than a collection of separate units, so also should the assets within the estuary be considered collectively. By looking at the assets at risk in Sunderland Village in isolation from those in neighbouring policy units, the benefit-cost ratio (BCR) becomes completely skewed. If the baseline scenario is to be believed, then the values of property and infrastructure at risk elsewhere in the estuary must also be included in the comparison. The stated value of the assets in Sunderland Village is also open to question and the method applied to calculate the BCR requires more detailed explanation. The figure of £2,771,000 (SMP2 Appendix H –

80 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Economic Appraisal and Sensitivity Testing – Annex 1- Page 1-5) is clearly not the present market value of the 29 properties deemed to be at risk. Whilst it is accepted that some form of national guideline has been applied in the calculations, this ceases to be relevant when there is the possibility that total abandonment may be required. It is understood that real costings were prepared for the works outlined in Scenario A, referred to above, although it is appreciated that these may not be current. However, with appropriate adjustments for inflation etc, they would provide a more reliable basis for comparison than the average figures quoted and used in the cost-benefit analysis. (SMP2 Appendix H – Economic Appraisal and Sensitivity Testing – Annex 2 - Page 2-2) Impact Assessment - Historic Environment See above comments on historic environment. We agree that Revise summary assessment for historic this should be given more weight in the summary tables. Note environment. Sunderland Point was the original Port of Lancaster, having been founded in 1680. that Overton parish Council response mentions 16 listed See also PCR_31 regarding heritage value In the mid 18th century it had become the third largest port in the country. At this important time, it buildings. conducted the bulk of the west coast transatlantic trade and also traded with Africa, Europe and the

Baltic. As a result it has a unique place in the nation’s maritime history.

Within the village of Sunderland there are 26 listed structures, all of which are part of the original fabric of the port. Both the village and the surrounding area, which includes Sambo’s Grave, are a designated conservation area. Sunderland Point is also part of an historic fishery which has been in operation since it was granted to Hugh Garth in 1180. The community at Sunderland Point acknowledge that the predicted changes outlined in this document are unlikely to occur within their lifetime. Whilst it is impossible to place an economic value upon such a heritage, they consider that there is an overriding obligation upon today’s generation to preserve it for future generations. Hence abandonment should not be an option. Impact Assessment – Social Many of the social, recreational and nature conservation values Propose to split the PU into 4: would not be lost under NAI with the defences, but could be Not only is Sunderland Point home to 38 families, it is also an attraction to countless visitors PU 11c 4.1 Sunderland Village NAI/NAI/NAI preserved or even enhanced under the revised policies throughout the year, amongst whom are many school parties for whom Sunderland Point and Samboo’s recommended for this frontage. PU 11c 4.2 Sunderland Point MR/MR/MR Grave provide a tangible link with the past. PU 11c 4.3 Sunderland Point to the secondary Its isolation and tranquillity attract people from around the country. Many are artists and embankment NAI/NAI/NAI photographers, but the location is also popular with birdwatchers, sailors, and walkers. Being a destination at one end of the River Lune Millennium Park, it is particularly popular amongst cyclists. PU 11c 4.4 Secondary embankment to Potts Corner HTL/HTL/HTL Sunderland Point also provides a safe anchorage for local fishermen who set out from here to fish in the River Lune and in Morecambe Bay. It therefore plays an important part in the life of many people, other than those who live here, from both the local area and from further afield. Impact Assessment – Ecology General responses received from nature conservation bodies would favour policies of NAI or MR rather than HTL. Morecambe Bay and the River Lune Estuary are recognized as internationally important ecological areas and are designated Ramsar sites, Special Sites of Scientific Interest, (SSSI) Special Protection Areas, (SPA) and Special Areas of Conservation. (SAC) Sunderland Point is habitat to the rare species of the Belted Beauty moth (Lycia zonaria brittanica) whilst the River Lune Estuary is bounded by large areas of saltmarsh which provides habitat for significant numbers of waterbirds, many of which appear on the RSPB Red and Amber lists. Many other species of flora and fauna are to be observed at Sunderland Point. These include bats,(Pipistrellus

81 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? pipistrellus) eels,(Anguilla anguilla) sea holly, (Eryngium maritimum) and the black poplar. ( Populus nigra ssp. Betulifolia) The NAI policy is in direct contravention of the statutory obligations to protect and enhance habitat and species Impact Assessment – Water The River Lune has a history of flooding from both fluvial and tidal flood events. Significant tidal storm events in 1907, 1927 and 1977 caused widespread flooding to residential property, industrial units,

roads and agricultural land. More recently, lesser events in 1983, 1990, 1995 and 1997 have also caused flooding. The combination of high tides associated with gale force winds and / or heavy rainfall increase the likelihood of flooding. As noted above, that scenario has not been recommended as The scenario outlined in SMP2 Appendix C - Baseline Process Understanding Page C-457 will seriously proposed policy, it is simply the baseline by which benefits of increase the risk to landfill sites and the Lancaster waste water treatment works, with the potential other options can be assessed. The landfill sites and the WWTW release of contaminants into the estuary. ( There is no mention of the latter within the SMP2 document sites in policy unit 3.4 had a proposed HTL policy in the yet its current flood risk assessment is 1 in 75 or less, i.e. 1.3% chance each year. ) consultation document and this is still the case. Impact Assessment – Economic In the short to medium term, within Sunderland Village, the downgrading to NAI will have a negative effect on property values and insurance premiums

Should the above long-term scenario be allowed to develop, the new defences constructed in the This is based on an incorrect interpretation of the policies, as the middle and lower Lune estuary would likely be rendered useless. The losses associated with an extreme SMP recommends HTL at these locations weather event will be multiplied considerably and losses will not just be confined to Sunderland Village and surrounding agricultural land. We express our deep concerns about the reliability and the interpretation of the information used to construct the SMP2 Draft Document.

Following the publication of the Lower Lune Flood Risk Management Strategy in 2005, the Environment We note that there are conflicting reports on the influence of Agency commissioned a wave modelling study, the JBA Consulting Technical Note (SMP2 Appendix G the Point on wave conditions. In response to the concerns Page G-89) raised we intend to revise the policy to Managed Realignment for This study concluded that: ‘Sunderland Point exerts little influence on the wave climate of the Lune Sunderland Point, which will allow for limited work to slow the Estuary in its position in 1848; it’s present position or in it’s likely future position.’ rate of erosion whilst further monitoring of the impacts takes place. Having taken professional advice, we are informed that this study, which is used to justify the proposal to adopt Scenario B, contains serious errors (Appendix 1) and its fitness-for-purpose is therefore of doubtful value.

We are also advised that the figures given for predicted sea level rise in the Irish Sea are incorrect and

that the evidence-base is inadequate. The actual seal level changes measured over the last ten years or Coupled with the failure to recognise important impacts of policy change, the omission of key so should not be confused with the allowances that the infrastructure at risk from flooding, the incorrect assumptions about the stability of salt marsh within government guidance says we have to plan for. the lower and middle estuary, and the failure to relate the effects of policy changes in one location upon adjacent locations, any proposal to change the present ‘hold the line’ status without further study must See comment above regarding stability of the estuary as a whole. be questioned. In summary: The community of Sunderland Village are opposed to the proposal to adopt a ‘No Active In relation to this and other responses received, it is now Propose to split the PU into 4: Intervention’ policy. They feel that the data being used to arrive at this conclusion is incomplete, and proposed that the plan is revised to allow for limited PU 11c 4.1 Sunderland Village NAI/NAI/NAI that the consequences of adopting such a policy have been underestimated. They request that the intervention to reduce the rate of erosion whilst further proposal should be reconsidered in view of the important impacts brought to light. monitoring data is gathered at Sunderland Point. The headline PU 11c 4.2 Sunderland Point MR/MR/MR

82 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? policy for this will be most appropriately described as managed PU 11c 4.3 Sunderland Point to the secondary realignment. embankment NAI/NAI/NAI PU 11c 4.4 Secondary embankment to Potts Corner HTL/HTL/HTL PCR_228 However, with regard to the plan itself, I find little evidence of any consideration of how planned action The physical linkages between frontages have been considered in Propose to split the PU into 4: / inaction for one sub-cell may impact on an adjacent cell. In particular, I refer to the Sub-Cell 11c 2, 3, the baseline process assessments which are presented in Lancaster Port PU 11c 4.1 Sunderland Village NAI/NAI/NAI and 4, and the effect on other parts of the Lune Estuary should Sunderland Point be unprotected and appendix C. Commission allowed to wash away. The erosion of Sunderland Point would not just affect the residents and PU 11c 4.2 Sunderland Point MR/MR/MR There have been conflicting previous reports on the impacts of properties there. Sunderland Point acts as a natural sea defence for the estuary, particularly for Bazil erosion of the point. Within the context of the appraisal period PU 11c 4.3 Sunderland Point to the secondary Point and Overton, but also for Glasson Dock. Changes to the line of the navigable channel brought of the SMP the point will change but will not be lost. However, embankment NAI/NAI/NAI about by further erosion at Sunderland Point could affect the viability of Glasson Dock as a Port, and in relation to this and other responses received, it is now the subsequent loss of commercial activity, jobs and leisure activity (leisure passage along could not PU 11c 4.4 Secondary embankment to Potts Corner proposed that the plan is revised to allow for limited provide sufficient income to pay for keeping the port open to service the marina in the canal basin for HTL/HTL/HTL intervention to reduce the rate of erosion whilst further instance, therefore leading to further job losses). monitoring data is gathered at Sunderland Point. The headline Such changes at the estuary would also ultimately lead to the exposure of the Lancaster Waste Water policy for this will be most appropriately described as managed Treatment Works at Stodday to direct wave action and consequent erosion. I would therefore urge realignment. reconsideration of the proposed defence strategy for Sunderland Point. PCR_229 I am writing with regards to the plans to let Sunderland Point (Morecambe) fall into the sea. The shoreline management plan has to consider the impacts of Propose to split the PU into 4: climate change and work to the allowances for sea level rise that Individual I feel it essential that the coastal protection for Sunderland Point should remain 'hold the line' for PU 11c 4.1 Sunderland Village NAI/NAI/NAI the government has set. With almost a metre of mean sea level several reasons: I have looked at the draft consultation report (11c4) and think that some of the rise to allow for over the period of the plan, and the anticipation PU 11c 4.2 Sunderland Point MR/MR/MR justification for the decision is completely incorrect. For example, it suggests that there would be no that sea level rise will accelerate significantly after 50 years, impact on 'recreational assets' should 'no active intervention' be adopted. As a resident here (not a PU 11c 4.3 Sunderland Point to the secondary coastal change is going to be inevitable. If a long term policy of property owner), I see many many people enjoying Sunderland Point throughout the year. We have embankment NAI/NAI/NAI hold the line were adopted then substantial defences would be hundreds of visitors who take part in the following recreational activities: photography, birdwatching, required to build walls around the village. Representatives from PU 11c 4.4 Secondary embankment to Potts Corner cycling, walking, horseriding, running, sailing, canoeing, jetskiing, picnicing, beachcombing.... If the residents association attending stakeholder events have HTL/HTL/HTL Sunderland Point was allowed to crumble away, a beautiful, natural 'recreational asset' would be lost. It agreed that Sunderland Point is unlikely to be sustainable in the is used by young and old alike to get fresh air, exercise and spend time together; all desperately long term, beyond 50 years, if predictions for sea level rise turn necessary in today's busy, modern society. out to be correct. I am also a school teacher who is planning to bring 150 children from Morecambe over several days to It may be a helpful educational exercise to explain to the children study Sunderland Point as part of our topic on 'Treasure' - the focus being, that it is one of our 'local about the impacts of global climate change on vulnerable treasures' - it is very difficult to understand and explain to children that we don't actually care about this locations like Sunderland Point. beautiful treasure enough to preserve it.

The baseline broad scale assessment of heritage assets for the I also found the point that 'no active intervention' would have 'no significant impacts on the historic SMP appraisal focussed on scheduled monuments, and Grade 1 Update impact assessment to recognise the environment' to be unfounded and ridiculous! Sunderland Point has a massive part in local history, listed buildings. We do however recognise that a cluster of important heritage features of Sunderland Point. having been a thriving port, it also played a large part in the local connections to the 'Slave Trade'. It Grade 2 properties is important and so will update the impact has also been a popular holiday resort in the past. We have 'Sambo's Grave' and the 'Cotton Tree'. To assessments accordingly. let it all disappear under the sea would be a tragedy. Following review of these responses and many others received Finally, from a very personal point of view, Sunderland Point is where I grew up and I am currently for this frontage the project team now proposes to split the PU bringing up my own children here, because it is a magical, wonderful, natural place. I would find it into 4 units. incredibly sad if my grandchildren/great grandchildren could not see where they came from, and if they and countless other children in the future didn't have the opportunity to enjoy and experience the Sunderland Village – continue with no active intervention splendour of Sunderland Point as we have had the privilege to do. I hope this goes in some way to urge however, but also allow for continued work on individual to let Sunderland Point remain 'Hold the Line'. property defences and flood resilience subject to consent. Sunderland Point – managed realignment to manage erosion risk

83 Sunderland Village to Potts Corner – 11c 4 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Sunderland Point to the secondary embankment – no active intervention North of the secondary embankment to Potts Corner - the policy is proposed to revert to HTL / HTL / HTL to reflect the importance of the defences here to Overton. PCR_145 I am very disturbed at the current proposal within the latest Shoreline Management Plan for Sunderland Response noted. Update impact assessment to recognise the Point and the Lune Estuary area to lose its current Hold The Line status. important heritage features of Sunderland Point. MP As noted in other responses regarding Sunderland Point, the (Morecambe & Even now, the high tides are threatening the residents of First and Second Terraces and the lands of HTL policy set in the previous SMP1 has not been affordable or Propose to split the PU into 4: Lunesdale) farmers at Sunderland Point. The village is an historic heritage site. The first cotton was landed in deliverable in practice. This has resulted in residents and the PU 11c 4.1 Sunderland Village NAI/NAI/NAI England here. The port at Sunderland Point was the forerunner of that at Lancaster and provided the community association working with the local authority and earliest shoots of the Cotton trade that has had such a vast impact on Lancashire, the North West and Defra to implement local property resilience measures rather PU 11c 4.2 Sunderland Point MR/MR/MR the history of England. To this day, visitors come to see the remains of the historic village, to than constructing large scale defences. The draft SMP2 allowed PU 11c 4.3 Sunderland Point to the secondary appreciate the peace and quiet of the Terraces and the farmland behind leading to “Sambo’s Grave”. It for this approach to continue as long as sustainable, which was embankment NAI/NAI/NAI is also a popular area for sailing and for bird watching of the waders on the river and the Bay. anticipated as being the next 20 to 50 years. PU 11c 4.4 Secondary embankment to Potts Corner I also have grave doubts about the future of the river Lune and the estuary if there is no retention of Following consultation, propose to split the PU and policies to HTL/HTL/HTL the Hold The Line policy of the original SMP. allow for further monitoring, limited intervention to manage erosion and adaptation to increasing flood risk to properties. This would threaten the riparian agricultural lands along the river and the estuary. No doubt, it would also affect the viability of the port at Glasson on the other side of the river from Sunderland Point. These issues relate to the homes and employment of those who live here as well as the leisure and heritage aspects of the area. I would be most grateful if you would consider these points when deliberating upon the Shore Line Management Plan for the Sunderland Point area with a view to offering protection to the villagers through a Hold The Line policy for the next two epochs. PCR_231 Has major concerns that the effect of the policy has not been adequately researched and consequently Response noted. Due to the uncertainty with implications of Update impact assessment to recognise the Councillor for not fully understood. erosion, the need for further studies and the strong concerns important heritage features of Sunderland Point. Lancaster City about potential loss of heritage, the proposed policy is now We have two expert reports giving different interpretation of consequences. History of Bay including Propose to split the PU into 4: Council proposed to change to Managed Realignment at Sunderland recent engineering operations can have unexpected consequences. Loss of portions of Sunderland Point Point, which will allow for limited intervention to reduce the rate PU 11c 4.1 Sunderland Village NAI/NAI/NAI can have potentially serious consequences for adjoining coastline. of erosion at the point. PU 11c 4.2 Sunderland Point MR/MR/MR PU 11c 4.3 Sunderland Point to the secondary embankment NAI/NAI/NAI PU 11c 4.4 Secondary embankment to Potts Corner HTL/HTL/HTL

84 Potts Corner to Heysham – 11c 5 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_150 Specifically Sunderland Point but other areas are also still being discussed – (Heysham) further N Further public consultation events took place in Lancaster City No changes proposed. discussion required. Council area subsequently to receipt of this response. Engineering and Projects, Lancaster City Council

Heysham to Hest Bank – 11c 6

No response received

85 Hest Bank to Heald Brow – 11c 7 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_75 11c 7.5 RSPB River Keer to Heald Brow - Statements in the current document broadly reflect our earlier submission. The draft SMP proposes NAI for the private embankment Revise short term policy approach description and frontage, but also indicates that more local investigations action plan. However, it should also be noted that current protection for the Leighton Moss SPA (freshwater) is should be undertaken into management options including provided by a private embankment, seaward of the railway line. This arguably leaves the Leighton Moss issues related to Coatstones landfill site. Propose to amend SPA vulnerable. Furthermore, as suggested in our earlier submission, MR to the railway line could text in policy description and action plan to also include create additional habitat in this location. A relatively small amount of work would be required to consideration of possible habitat creation adjacent to the enhance the railway line as the new primary defence for the Leighton Moss SPA – toe defences to the railway. existing embankment, and a short stretch of new defence where there is an underpass under the railway. Statements in the current document about long-term options for MR into Leighton Moss, subject to compensatory freshwater habitat being secured elsewhere, reflect our earlier submission. In light of all the above, we would therefore suggest that the Preferred Policies for the Leighton frontage within this Unit over the 3 time periods, should be MR, HTL and then finally MR. PCR_71 11c 7.4 N Thank you for the response. Individual, 11c 7.5 The maps of the flood plain area presented with the SMP2 No further action required. Silverdale indicate the coastal flood plain area that is already at risk Two Councillors attended the consultation meeting on 8th December 2009, here follows their Parish Council of flooding under an extreme tidal surge. The observations/comments. Far more people turned up than expected, and many were unhappy with approximate 1m of sea level rise that we need to allow proposals from the Environment Agency, although much of that was about the fait accompli position for in SMP2 will mean that the risk of flooding and depth and process rather than the actual plans. of potential flood waters would significantly increase over In planning the Shoreline Management Plan the Environment Agency take three stances; No Active the period of the plan. Intervention, Hold the Line, and Managed Realignment. With regard to the 3 points of detail: The area of coastline from Bolton-Le-Sands caravan park through Heald Brow to Ashmeadow in 1. While the general policy for River Keer to Heald Arnside is designated 'No Active Intervention'. In other words there will not be any work carried out Brow, policy unit 7.5 is No Active Intervention, the to existing flood defences. A good stretch of this involves the railway embankment, which the SMP does make allowance to carry out works if Environmental Agency shrugs off as being the responsibility of Network Rail. The other end of the Bay, the railway is at risk, or the SPA freshwater from the Arnside viaduct onwards is 'Hold the Line', where flood defences will be maintained. There are designations are threatened or there are proposals to realign the defences just east of Arnside Station which could allow tidal flooding. management changes at Leighton Moss relative to Maps presented indicate that the flood plain area [if sea levels rise 1mtr] would mean that: tidal incursion. The shoreline management plan policy of no active intervention does not include 1. Leighton Moss would be lost, and obviously the road under the Crag. The River Keer would the defences to the River Keer itself, which are effectively cut off from Millhead/Warton/Silverdale. mentioned in the Action Plan for further 2. The inrush of water over land east of the railway at Arnside would cut the road to Sandside consideration by the EA (River Keer at Mill Head and also the one to Storth; the railway being lost. This means the only way out of Arnside Improvements). would be via Silverdale, and the only exits from Silverdale would be the Yealand Road past 2. The land east of Arnside is presently defended, but Leighton Moss or the Gaitbarrows road past Challan Hall. the flood risk area shows the impact of a potential 3. If the proposal to make the embankment at Arnside a tidal flood area was executed, then that extreme surge tide. The medium and long term road would be out of action on a regular basis. In addition, a general flooding of Leighton Moss policy proposed includes for management of this would obviously be detrimental to wildlife. risk, and proposals for potential managed realignment would need to take account of risks to the roads and railway. 3. See above points, and comments on responses from RSPB, PCR_75 above. Note that both natural England and RSPB who have responsibility for Leighton Moss reserve have been involved in

86 Hest Bank to Heald Brow – 11c 7 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? developing the plan and have indicated that long term change at sites like this may be inevitable. While there would need to be mitigation for losses of freshwater habitat, there is potential for different wildlife opportunities as a brackish or saline tidally influenced marsh. PCR_150 Warton, Carnforth, Bolton-le-Sands and Hest Bank Lack of local buy-in - further discussions required N Two further public consultation events took place No changes proposed subsequently to receipt of this response. Engineering and Projects, Lancaster City Council PCR_213 Concern was highlighted that the area around Morecambe Lodge is not protected and therefore The linked flood risk between the shoreline south of flooding could arise at this point pushing the water across the fields and creating a problem to the rear Morecambe Lodge (PU7.1) & North east of Red bank Farm Bolton-le- Revise Action Plan items 11c 7 – 2.1 & 2.2 to ensure of the properties on The Shore. These properties are currently protected from the sea to the front by (PU7.3) is acknowledged in the flood maps used in the SMP Sands Parish that the linked flood cell is considered strategically. way of a sea defence embankment. Cllr Craddock therefore asked for consideration to be given to and both these frontages have HTL policy, with allowance for Council some form of rock armour to stop this event happening and thereby safeguarding the sea defence potential MR in the medium term if practical. The area around already in place. Morecambe Lodge itself is PU7.2, is considered to be slightly raised ground and so not at risk of flooding according to the Environment Agency’s flood risk mapping. We propose to revise the Action Plan, which currently recommends separate studies for the two frontages to ensure that the inter-linked flood risks are considered together.

87 Heald Brow to Humphrey Head – 11c 8 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_150 Warton, Carnforth, Bolton-le-Sands and Hest Bank Lack of local buy-in - further discussions required N Two further public consultation events took place No changes proposed subsequently to receipt of this response. Engineering and Projects, Lancaster City Council

88 Kent Estuary – 11c 9 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_135 We live at Waterside Fold/Heversham/LA7 7EZ. If I have understood the draft plans correctly our Direct comment sent as below: No changes proposed property would be lost in the proposed re-alignment. Could someone from your department please Individual Thank you for contacting us. In the draft Shoreline contact me to clarify the position & implications. Management Plan it is proposed that in the longer time scales there is potential for Managed Realignment in the policy unit. However the Shoreline Management Plan does not assume or suggest any potential alignment. It is proposed in the action plan that there are studies undertaken in the short term to investigate realignment opportunities and these would consider which lengths within the policy unit could be realigned and to what extent. I hope this helps clarify things for you. If you would like further information or would like to respond on the draft plans please respond to this email address. PCR_101 As you know my wife and I were particularly concerned that the consultation map for the Kent N The lines shown on the maps do not give an indication of Amend PU map Estuary (Sub-Cell 11c; Area: 9; Map: 1) indicates managed realignment of the sea defences, currently where we would expect the shoreline to be in the time Individual, protecting our home, further inland so that our home would effectively be lost to the tides in the periods shown but are rather separated out to allow different Meathop estuary. We were relieved to be told by both the lady from Halcrow and Andy Shore from the policies for different time periods to be shown visually. Environment Agency that the indicated realignment around our home was in fact an error on the map At the meeting it was pointed out that the lines go to the rear and would be corrected prior to formal adoption of the Plan. of your property and this is a mistake as they are meant to In the meantime however we would like to register formal objection to the proposal as it stands, follow the coastline as it is now. This will be rectified when pending correction of the map. Presumably SLDC will inform all interested parties / stake holders on changes are made following consultation. our behalf? The policy proposed in the draft SMP for the policy units Hollins Well Road north to Levens Bridge (east bank) & Levens Bridge to Kent Viaduct (west bank) is for Hold the Line for up to the first 20 years, during which studies would take place to confirm longer term policy and develop the approach to medium to longer term managed realignment. The SMP does not assume or suggest any potential alignment and consideration would be given to existing properties when developing the approach. It is proposed in the action plan that there are studies undertaken in the short term to investigate realignment opportunities and these would consider which lengths within the policy unit could be realigned and to what extent. PCR_89 Too much mention of habitats, too little mention of food production. At a time when increasing world N In the past, reclamation of land around the north west coast No changes proposed population is causing a massive increase in demand for food it is stupid to lose agricultural land; its has been assisted by accretion of sediment and stable or Individual, retention is a much higher need than some amphibians or moths. slightly falling sea levels relative to land levels. Due to the Witherslack expected impacts of climate change we now have to plan for Hundreds of years of effort have gone into the reclamation of farmland around our estuaries and rising sea levels, which will make coastal defences much more thousands of pounds of both taxpayers and land owners money; to reverse this achievement now is expensive in future and expenditure on defences is already crass stupidity; my recommendation is 'not a yard, not and inch'. Indeed there is a strong case for stretched. continuing reclamation of some of the existing marshland; the coastline in the NW is accreting, as is clear to see in many areas such as Morecambe Bay. The cost of re-aligning the existing defences will be Comments about the scale of agricultural land loss and future more than continuing to maintain them. food security and prioritisation of defences are proposed to be considered as a broader scale issue across the whole SMP at regional or national level in the Action Plan.

89 Kent Estuary – 11c 9 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_210 One of our councillors recently attended the exhibition and studied the plans - he then reported back Response noted. The draft SMP does allow for maintaining No changes proposed to the Parish Council who now wish to make the following comment:- the defences for up to 20 years. However, in the longer term Witherslack, it may not be affordable or justified to continue to maintain all Meathop and The Parish Council of Witherslack, Meathop and Ulpha feel strongly that all existing sea defences are of the existing defences and alternative approaches need to be Ulpha Parish maintained. considered, particularly in the light of the sea level rise Council allowances that we have to plan for. The Action Plan allows for further studies to investigate the most appropriate approach, including further more detailed consultation in future. PCR_77 DON’T UNDERSTAND THE SMP – WHAT DOES IT MEAN? WHAT WILL YOU DO ABOUT The Environment Agency and Local Authorities have No changes proposed HOMES YOU ARE INTENDING TO BLIGHT? permissive powers to undertake flood risk management Individual, activities but do not have a duty to do so. Unfortunately there Witherslack That you have not visited properties that could be affected – knew nothing about all the NGOs and is no right to flood protection or continuation of management GOs who are generating lots of activity - only found out by accident! of existing flood defences, and provided adequate notice is None of it is written in a way that can be understood clearly by someone not active in the given, no right to compensation in relation to withdrawal from environmental arena. maintenance of defences. However, a claim for compensation may arise, for example if the existing defence were to be Do you have anyone who has been elected by the communities to sit within the consultation group deliberately breached or dismantled and this was to expose and can consider the impact on existing settlements and community and service infrastructure? properties to increased risk of flooding. Need to know what you plan on doing about people who live in these areas and their properties – are The draft plan development has included consultation with we to be sacrificed and when? elected members and this has included arranging elected Are we to be : members forums to provide briefings and to listen to views. compulsory purchased or; The SMP is a broad scale plan covering many miles of coast. The approach to implementation of the revised policies for just evicted or; managing the coast is to be further developed through further left to drown? consultation and investigations at a more local level.

90 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_4 11c 10.2 PCR_185 As owners of the Lakeland Leisure Park we have taken a keen interest in the development of the SMP for Morecambe Bay. This has included investment in a comprehensive study to inform the consultants Bourne preparing the plan. This study has been copied to Halcrow and the principal regulatory bodies (EA, Leisure Council and Natural England), some six months ago in time for its consideration as Limited part of plan development.

Following the commencement of public consultation over the draft plan posted on your web site in

October ’09 the Company referred the posted documentation to its technical advisers for comment.

A first observation is that the documentation is not ‘stakeholder-friendly’ in that it is necessary for a specific frontage interest to hunt through ten appendices to compile the evidence base for the preferred policy decision. The absence of cross-referencing for a specific frontage interest may result (Extracts of letter comment to PCR_185 dated 28th See below in stakeholders only viewing the main document whose summary format can perforce lose important January 2010 below) evidential and/or contradictory detail. This is likely to be most relevant to individual property owners who are unlikely to have access to their own specialist advisers. We have now received the initial appraisal of the SMP documentation as presented for public The project has been in development since early in 2008 and consultation on the web-site (mycoastline.org) and the appraisal gives rise to considerable concern the baseline reports (Appendices C, D and E) were put over the justification for the preferred policy recommended for the Humphrey Head to Cark together before the Lakeland Leisure Park report was received, shoreline frontage. The concerns derive from – so unfortunately the report was not referenced in these documents. However, please be assured that the Lakeland • Inaccurate baseline data presented for the frontage; Leisure Park report has been reviewed and information used and referenced where appropriate during the policy appraisal stage of the SMP (e.g. Appendix G pg Section G2.3 page G-108. If you could further specify the inaccuracies in the baseline data we will be happy to amend and update in the final SMP2 document. • Inconsistencies in the application of assumptions made over effects of climate change generally in the If you can please specify the inconsistencies we can make Bay; appropriate revisions when finalising SMP2 document if required. • Contradictions between appendicised policy conclusions and the preferred policies presented in the As above, please give specific details in your further response so main report; that we can ensure these are amended.

• Confusion over the application of SMP policy to private frontages; The SMP2 covers the whole frontage and takes into account both private and publically owned defences and natural features. Responsibility for delivery of activities to manage defences on the ground is beyond the level of detail possible in such a high level plan. However, we welcome your comments on activities that could be included in the SMP Action Plan for this frontage. • Absence of evidence that the extensive data contained in the Company’s shoreline management We appreciate your help in providing us with information to aid strategy report has been used in the development of preferred policy; the SMP2 assessments. Unfortunately our initial assessments in the baseline reports (Appendices C, D and E) were put together before the Lakeland Leisure Park report was received and therefore your report was not referenced in those appendices. However, as noted above, please be assured that the report has been reviewed and information used and

91 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? referenced where appropriate during the policy appraisal stage of the SMP. The report provides a large amount of data about Morecambe Bay coastal processes as a whole. The report also provide a useful assessment of the do-nothing and hold the line scenarios for the Lakeland Leisure Park frontage, however MR and ATL have been discounted without assessment, and the strategic management of the linked adjacent defences is not included. • Absence of a commentary for planners alongside preferred policy regarding private frontages Section 4.2 of the main SMP2 document discusses broad scale thereby limiting guidance available from the SMP. actions for spatial planning and item 8 in the policy unit action plans allows for addition of local actions related to spatial planning. If you have specific suggestions for additions please include in your further response. We can then discuss this point with the project management board. In order to assist the detailing and further appraisal of these concerns we request clarification of the Government policy states that where a landowner wishes to following – maintain their own defences without public assistance then consent from the local planning authorities will usually be (i) the right of the Company as owner of the Caravan Park to maintain its coastal defences within the required. It would be unreasonable to withhold that consent existing footprint to provide present levels of protection to its property for all three epochs; unless the proposed works would give rise to clear and demonstrable disbenefits or adverse impacts on the environment or on the wider community. Any decision to withhold consent must be justifiable and the landowner must have the right to challenge the decision. Where defences are adjacent to a European designated site, as in this case, continued maintenance of that defence will also require Natural England consent. Consents are generally time-limited, so it is not possible to state whether present levels of protection will be permitted over a 100 year period. (ii) the legal basis for compensatory costs arising from long term HTL policy for this frontage; In carrying out Flood and Coastal Risk Management (FCRM) functions, the operating authority is required by the EC Habitats Directive (92/43/EEC) and European Union Birds Directive (79/409/EEC) and their implementation in the UK under that Conservation (Natural Habitats & c.) Regulations 1994, under Regulation 48(1) (“Habitats Regulations”), to create wildlife habitats to replace those lost through coastal squeeze or construction of flood defences. Where defences are owned and maintained by third parties, any compensatory requirements will need to be discussed with the EA. The Agency manages Regional Habitat Creation Programmes which deliver the compensatory habitat required for the approval of SMPs. It is likely that a contribution towards costs will be sought from the defence owner / maintainer. (iii) the location of the assumed shoreline setback position referred to in the plan documentation; The SMP2 draft policy for Humphrey Head to Cowpren Point is to ‘hold the line’ for 0-20 years followed by ‘managed

92 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? realignment’ for 20-50 years and 50-100 years. At this high level, the plan has considered the current understanding of coastal processes and recommends that phased managed realignment (MR) should be investigated for policy unit 10.2 Humphrey Head to Cowpren Point. Theoretically the maximum extent of any realignment is limited by the extent of the coastal floodplain. However, in reality there are a number of other constraints which mean the actual extent of any realignment is likely to be less than this. The draft SMP2 does not give a proposed alignment as this would need to be investigated in greater detail. Similarly phasing, which may depend on condition and viability of the various existing defences within the whole policy unit would need more detailed investigation than possible at SMP level. The draft Action Plan proposes further studies and discussions with landowners and communities to develop a strategic approach for the policy unit. The Consultation draft Action Plan proposed that the studies are led by the EA, but this would be subject to agreement and partnership approaches will be encouraged. These studies would need to consider potential impacts at a local and regional scale taking into account current land use and risks and opportunities. Details relating to groundwater and saline intrusion will also need to be taken into consideration. The proposed studies will investigate the suitability of managed realignment and investigate options for the timing, location and nature of works along the overall frontage. Of course, local stakeholders will be formally consulted throughout this process and their views will be considered. (iv) the reasons why a HRA is required for ‘With present management’ The draft Action Plan proposes, at item 12.3 to ‘Undertake a HRA for the managed realignment strategy’. Plans or projects that may potentially impact on internationally designated Conservation sites require these assessments, which need to be agreed by NE and inform the Appropriate Assessment by the Competent Authority the Local Planning Authority or EA. The Habitats Regulations require an ‘Appropriate Assessment’ where structures serving a Flood and Coastal Erosion Risk management function are likely to have a significant effect on an International Conservation site(s). This is the case where ‘present management’ is to continue management of a coastal protection structure, where this structure is likely to have a significant effect on an International Conservation site(s), such as a loss of saltmarsh area and / or deterioration of the marsh. Although ongoing management of existing defences may be within the same footprint, potential impacts of coastal squeeze upon the intertidal area needs to be investigated. Natural England will be able to provide further information on

93 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? this matter should this be required. (v) the principal driver for EA policy implementation along the frontage is economic. Government Policy is to take a risk-based approach to managing coastal change and flood risk. It is not possible, or sustainable, to defend everywhere. The EA and LAs have permissive powers to manage flood and coastal risks to communities and assets where it is technically feasible, environmentally sustainable and economically viable. Investment in coastal defences is subject to national prioritisation against outcome measures specified by government. In general, opportunities for managed realignment are investigated where there is potential for multiple benefits – such as reduced maintenance costs and habitat creation. This can provide a more sustainable coastal defence approach for the future. At the present time the Company does not agree that the evidence presented supports a preferred The proposed policy for the Humphrey Head to Cowpren policy of managed realignment for the second epoch (20-50 years). Bearing in mind that investments Point policy frontage includes both private (the Lakeland are often made for returns over a 20 year+ period it is important for the Company to receive due Leisure Park frontage) and public or other property owners’ recognition in the SMP that its defences are designed to cope, albeit through adaptation, with forecast defences. The draft SMP2 policies as given in the consultation shoreline exposure changes over the next 50 years. The appendices supporting the plan document documents for this frontage are: present evidence to support this position. The Company is not satisfied with the policy of managed 0-20 yrs HTL realignment after 50 years but is prepared to accept such a policy at this stage for confirmation through monitoring with commitment to plan review at least every 10 years. However, the medium Manage flood risk by maintaining existing defences to an term preferred policy of managed realignment is not acceptable as presented. adequate standard. Investigate opportunities for phased managed realignment to address flood risk when defences become uneconomic to maintain in their current alignment and implement where practicable. 20-50 yrs MR Implement opportunities for phased realignment when defences become uneconomical and establish a more natural and sustainable defence alignment. 50-100 yrs MR Phased realignment of remaining defences towards a more natural and sustainable defence alignment. A managed realignment policy for a frontage does not necessarily mean that the whole frontage would be aligned, or indeed any of the frontage realigned, as implementation of a MR policy would depend on the results of investigations / studies and consultation undertaken in the short term. The mention of phasing is intended to acknowledge that the Lakeland Leisure Park embankments have recently been raised and strengthened with consideration of 50 years of future sea level rise. Your defences are therefore likely to remain well into the medium term while other sections of this frontage could be realigned in earlier stages. However, the sustainability of holding your defence line in this advanced position against increasing

94 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? sea levels and an increasingly stormy climate does need to be considered in the long term, and you also recognise this in your letter. Additional Responses received 23 February 2010: Responses extracted from notes of meeting with Bourne Leisure on 17 th March 2010 Thank you for your response of the 28th January 2010, as you are aware our reply has been delayed due to annual leave however here are our responses. The format of the reply is in accordance with There would need to be consent from Natural England and the the draft SMP 2 Document and your letter. Environment Agency under the Habitats Regulations and CROW act respectively. However these consents would be 1. Regarding the clarification of points of detail - given to Holker Estates as they own the land which the (i) 'planning consent will usually be required for maintenance'. There is no requirement for planning defences are on. consent for works of maintenance as far as we are aware. It would be appreciated if you could Under the CROW act there is an option to have ‘agreed confirm the precise position with due reference to relevant legislation and regulation. maintenance’ which would not require consent each time to undertake once they are agreed. (ii) As we understand the position there is no obligation on a private frontager to make contribution - The EA can either just pay compensatory costs or they can ask please can you provide additional clarification. private landowners to contribute when they benefit from a defence. However there is no obligation for the landowner to make a contribution. The European compensatory habitat would apply to a private frontage the same as any other frontage (iii) If there is no setback line then how was the economic appraisal carried out? The information There was an assumed line for calculations which assumed that provided on consideration of setback infers that the regulatory Authorities will tell private frontagers the west bank would be realigned to higher ground and would what policy will be for their frontage. This is not correct - the regulatory Authorities need to tie into the Caravan Park defences (roughly following the old accommodate the private frontager's policy in their Action Plan where this policy is HTL. footpath). The economic assessment is included for the preferred policy as it provides guidance for the operating authorities. It does not prevent private works if the relevant consents are obtained. When the emergency works were taking place there were discussions about rolling back the caravan site. There is also the question of ownership as Holker Estates own the land that the defences are on and also the caravan park is vulnerable to flooding from behind. The policies apply to the operating authorities and private individuals are not bound by them providing they can get the necessary consents. (iv) Could you please provide confirmation that such work on the HRA will not fetter the private BL’s consultant clarified the issue at meeting: The draft policy frontager's rights to maintain their coastal defences. statement does not mention that the private frontage is going to be held for 50years even though this information is in the Strategy produced by Bourne Leisure and was supplied to the project team. This could be misleading to Local Authority Planners . The SLDC planners have stated that the area is in Flood Zone 3 and the SMP policy would not be the main driver against planning permission. (v) The maintenance of Lakeland shoreline frontage will reduce costs for EA maintenance of the We are being challenged by the national Quality Review Group

95 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? continuous flood defence system between Cark and Humphrey Head - this is not acknowledged in about the affordability of Hold the Line in the future epochs for the SMP documentation. the draft plan. Bourne Leisure would still be able to defend their caravan site even if the EA retire the line, it would just mean more investment. 2. Regarding 'other concerns' - We have made general observations on items (i) and (ii) which are then followed by specific concerns on the SMP documentation as presented on the web site. (i) There is no evidence that Halcrow have been asked to consider the potential of different policy responses from private frontages. This may not be important where only public frontages apply or where the policy is hold-the-line but becomes a key issue for frontages such as Lakeland. Indeed, Lakeland may be a unique instance of a private commercial frontage in the north-west with the resources to hold-the-line but confronted with a policy of setback in SMP-2 for the 20-50 and 50-100 year epochs. (ii) The policy of managed realignment is justified on an economic basis for the EA without any acknowledgement of the option for Bourne Leisure (BL) to hold-the-line and the implications for the EA defences to either side. If recent arrangements for division of cost were to be repeated in the future then it may well be that the economic case for EA is to hold-the-line for the 20-50 year epoch. The present documentation does not make it clear regarding the dependency of policy on forecast sea level rise and how this is to be specifically checked through monitoring with a feedback to timing of policy changes. The distinct possibility of Morecambe Bay keeping pace with sea level rise by increased sedimentation is not mentioned in the policy documents and yet this is an acknowledged scientific outcome possibility. (iii) Main SMP document - consultation Draft. Page 22 - 'The long-term vision for Cartmel Peninsular is to set back defences, while maintaining protection, where economically justifiable, to the railway and agricultural land and to allow additional saltmarsh development/habitat creation.' No mention of Lakeland in this section but if the Lakeland frontage is hold-the-line then the exposure of EA defences to either side will be significantly different. Whilst this sort of detail would be rightly taken forward into future studies the acknowledgement of the situation should be made clear in the SMP. Page 25 - 'The key areas of management change are...... Cartmel Peninsular....where the long term technical sustainability and economic viability of a hold-the-line policy is questionable. These management policy changes are based on comprehensive consideration of multiple factors including scientific fact and best technical knowledge.' We require to see this 'comprehensive consideration' in the full and examine how it deals with BL strategy as set down in the report. Page 30 - 'Business and commercial enterprises will need to establish the measures they need to take to address the changes that will take place in the future.' BL has done precisely this but has received no acknowledgement for providing detailed assessment of shoreline exposure risk and coastal defence strategy to assist in the development of SMP-2. (iv) Policy Draft Recommendations. 10.2 - Although hold-the-line is cited for 0-20 years the wording would allow a managed realignment within this period. The potential of outflanking and integrity of the public highway are the issues for BL if the EA pursue managed realignment earlier.

96 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? - Predicted implications forecast the possible loss of the caravan park in 20-50 years due to managed realignment. What is the basis of this assertion which contradicts the design standard of the recently completed coastal defences - standards conveyed to Halcrow in the strategy report? - The draft Action Plan includes studies for managed realignment within 10.2 when' existing defences become uneconomic to maintain in their current alignment '. If BL hold-the-line and provide the materials as previously the economics continue to make sense for the public purse in the 20-50 year epoch. In addition a BL hold-the-line will extend the life of the Scheduled Monument in Cark airfield. There is then little evidence of public/private sector cooperation opportunities being considered. (v) Appendix 'C'. Appendix C East Plain embankment residual life of coastal defences is less than 10 years and Low Marsh NP stated that this appendix is a baseline that was written embankment is 6-10 years. There is no reference to the recent work and no reference to the before the project team received the Bourne Leisure Strategy Halcrow to update all documents to state that strategy report. It is our opinion this assessment was carried out using out-of-date references and so does not take account of it. All subsequent documents have Appendix C is a baseline and has not been with no site visit. taken account of the Strategy. updated. Baseline Understanding - large scale - concludes the Bay is accreting at the present time and there has PB stated that there should be a statement in the plan and to date been a net fall in sea level relative to land level. - local scale - (Cartmel peninsular) -'sediment policy statements that says that the baseline has not been linkages to adjacent frontages will be negligible'. No recognition of recent work is recorded in the updated as the residual life of the defences has changed. area history. The appreciation of low water channel behaviour associated with the Leven estuary is Halcrow to update all documents to state that Appendix C is a too simplistic and fails to recognise recently-recorded behaviour included in the strategy report baseline and has not been updated. produced for BL.

With Present Management (WPM) - All OK for the three epochs provided the Bay accretes in pace with sea level rise and the Leven low water channel does not meander into the defences. It needs to be remembered that the recent construction work renders the Lakeland defences resistant to a similar channel meander event to that occurring in 2006. No Active Intervention (NAI) - Available data declared does not include the strategy report but otherwise as for WPM. Predicted Change with WPM - Provided the Bay accretes in pace with sea level rise and low water channels do not meander against defences then some increased overtopping predicted in storms. This would suggest that since water depths remain the same and the waves in storm activity are depth-limited that raising of defences would become an economic option compared to MR. Predicted Change with NAI - Earth embankments predicted to fail within 20 years this suggests there are 'no defences' in the second and third epoch. It would therefore appear that the Lakeland Leisure Park does not exist for the purposes of this section of the report because the present defences will remain beyond 20 years (vi) Appendix 'F'. Appendix F Policy Development - two scenarios are presented for testing - HTL / HTL / HTL and HTL / MR / MR PB said that Appendix F states that the defences will be - but the comment is interesting -'Current embankment around Cartmel Peninsular is likely to maintained into the second epoch so why is the policy HTL?

provide protection well into the medium term. Potential for MR when current defences expire for NP stated that it depended on when the realignment had been environmental and technical reasons.' (See actions relating to further comments assumed to go ahead. It is stated that there should be phased below) Justification of Policies to test - this includes - 'The caravan park and airfield has a largely newly realignment so the defences would need to be maintained until constructed revetment around the seaward extent. HTL locally is likely to be economically justified all realignment complete. for at least the medium term (i.e.20-50 years). MR to be tested in the longer term.' Halcrow to confirm what timings were assumed for the This is the first acknowledgement of the recent work and provides a conclusion that is not then realignment. carried forward.

97 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? (vii) Appendix 'E'. Assessment of issues and Objectives - the relevant objective is - 'To minimise coastal flood and erosion risk to....tourism assets and activities.' The specified features covered by this objective include caravan parks and these are also recorded as a key consideration. (viii) Appendix 'G'. Policy Scenario Testing - The two scenarios (A and B) tested are -HTL / HTL / HTL and HTL / MR / MR respectively. The strategy report is acknowledged here with sustainability questioned in the long term (i.e. 50-100 years). The sustainability of Lakeland Leisure Park is only discussed under the long term - there is no mention under the medium term for scenario 'A'. Under Scenario 'B' sea level rise is assumed to have an impact but no mention of qualifying previous assumptions that the Bay accretes in pace with sea level rise. 'Managed realignment may become a feasible scenario' - So nothing is defined here. There is a call for monitoring and studies in the short term to assess sustainability in the medium and long term; it is considered therefore more acceptable that the results should be obtained of these studies before changing policy? In the medium term scenario 'B' only talks about a strategy to be developed for relocation of the Leisure Park for implementation in the long term so the SMP is advocating here HTL for Lakeland even though MR is the declared policy for the whole frontage.

In the long term Scenario 'B' infers that a setback line is formulated now - we require to obtain this information. The costs of MR are acknowledged but again sea level rise is used as a justification without reference to the qualification that accretion in the Bay keeps pace. Scenario-testing - provides an assessment for medium and long term MR in scenario 'B' of relocating the caravan park - there is no recognition of associated costs compared with HTL. Preferred Policy - For the medium term the wording is - 'MR - seek opportunities for the phased realignment of uneconomical defences towards a more natural and sustainable defence alignment.' It would be appreciated if the meaning of this form of words be clarified and stated. (ix) Appendix 'H'. The rationale for the economics is not provided and does not appear to include adequate costs for medium term MR. There is also mention again here of 'HTL likely to result in costs for compensatory habitat' – please could this be explained. The calculated B/C ratio of 1.91 does not appear to be realistic. (x) Appendix 'I'. Strategic Environmental Assessment - this identifies the need for a Habitats Regulation Assessment (HRA). (xi) Appendix 'J'. Confirmation of HRA requirement and NE preference for MR in the first epoch rather than HTL. The evidence does not support this.

(xii) Key Issues we require (i) explanation of residual life of existing coastal defences set at less than 10 years with no apparent

98 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? recognition of recent work – details of which were provided in the strategy report. ii) justification of preferred policy set against a background of - - present accretion in the Bay - historic lowering of sea level relative to land - assumption of accretion in pace with sea level rise (subject to monitoring to confirm). - assumption of low water channel location away from the shoreline. (iii) justification of 'no defences' along the whole policy unit with NAI for the medium term (20-50 yrs) with the armourstone profile now in place and with the assumptions and present situation summarised in (ii) above. (iv) rationalisation of the preferred policy with Appendix 'F' statements of HTL at least through the medium term. (v) explanation of increased exposure for medium and long term set against the assumptions in (ii) above. (vi) explanation of medium term strategy development for relocation of the Leisure Park in policy scenario testing but whole frontage to be MR in medium term for preferred policy. (vii) request for the assumed setback shoreline location. This is a large document and the review so far gives cause for concern over the data base used; the consistency of the rationale and the loss of important information by way of summary. In its present form the SMP-2 does not appear to reflect accurately the supporting documentation and also appears to rely on inadequate information for key assertions. I hope the above is clear, but as can be seen there are a number of issues that remain unanswered. It is considered that there is a need for a direct around the table dialogue with all interested parties on frontages like Lakeland that are affected by proposed policy change. It is our opinion that a meeting should be convened to seek resolution of the issues rather than rely on correspondence. Further response 18 th March 2010 Actions & Responses from meeting sent to Bourne Leisure on 6/04/10 are given below: Further to our meeting at Lakeland Leisure Park yesterday the 17th March 2010, I provide below my record of the actions arising from the meeting. I have sent this email to all the representatives of the 1) SLDC to check with planning department about SMP 2 Client Steering Group who attended the meeting with the exception of Nick Petit of Halcrow whether there is a requirement to gain planning for whom I do not have an email address. I have also forwarded the email to all those named on your consent to undertake maintenance works to sea confirmation email. defences. 1. Actions on Blackpool BC (Fiona Crayston). The response that has been received from SLDC Planning Department is below. (i) Clarification on the planning requirement for the maintenance of private coastal defences. It depends on what the maintenance involves. If it is straightforward maintenance/repair no planning permission will be required. If the work involves additional defences, i.e. increasing the height, width or placing defences elsewhere, permission may be required depending on the extent. For example, an increase in the height by perhaps 10-30cm would not require permission a significant increase would.

99 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? (ii) Provision of the details and rationale applied to the economic assessment. 2) Halcrow to supply more detailed information on the costings of an assumed set back line, including potential timings. The economic assessment for Humphrey Head to Cark is based on the following figures and assumptions: The economic assessment is broad scale and so timings of costs or benefits are assumed to occur at the mid-point of either the short, medium or long term epochs. No Active Intervention Losses – baseline assessment based on National Property database gives assets in risk area a current capital value of £27.7 million. Assuming write-off in middle of medium term gives Present Value (PV) discounted value of NAI damages as £8.5 million. Preferred Policy (Managed Re-alignment): – Maintenance costs have been included for the full frontage. – No major work is allowed for on the caravan park revetment, which has a residual life of 50 years, reflecting Bourne Leisure’s strategy. - 3.7km of new (retired) earth embankment are constructed throughout the unit, in the middle of second epoch, to ensure a continuation of flood defence along a retired line. The overall cost of the policy is £2.9 million (discounted Present Value) including for maintenance over the medium and long term. – At the end of the 2nd epoch, it is assumed that the caravan park defences will fail, and the site will have to be then be lost; no costs are allowed for in the SMP in relation to this. – Total benefits of the policy, which include the continued protection of the caravan park for the first and second epochs (until year 50), and the ongoing protection of assets behind the retreated line of defence, are estimated to be £5.6 million (Appendix H, pH-48). – The overall Benefit Cost Ratio of the Managed Re-alignment policy is therefore 1.91 Whilst it is recognised that Bourne Leisure are committed to defence of the caravan site for at least the next 50 years (i.e for the first 2 SMP epochs), the method of economic analysis used by the SMP considers all funding, rather than differentiating between public and private. Therefore, the cost of any works to the BL defences must be included in the analysis. (iii) Technical, economic and environmental rationale for the recommended MR policy in the second 3) Halcrow to give a clear concise argument for MR in epoch for the Cark to Humphrey Head policy unit. the second epoch drawing on the documentation and Defra guidance Historically Morecambe Bay has experienced import of sediment and little or even negative relative sea level rise, which

100 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? has facilitated significant past land claim around the bay and in estuaries, although in some areas, such as the Cartmel peninsula this has not always been successful (Appendix C, p C-507 & C- 515). It is acknowledged that Morecambe Bay is a sediment sink and has further capacity for infilling (Appendix C, p C-15 & C- 30). Although there is recognised uncertainty, the considered view is that presently accretion within Morecambe Bay has been keeping pace with or out-pacing historical sea level rise. The Bay is acknowledged to be a strong sediment sink and the coastal processes review, (Appendix C-30) suggests that provided sufficient sediment is available, overall stability of the Bay is expected to be maintained in future. The regional Defra 2006 sea level rise allowances that the SMP has to consider are given in Table C4. Over the short and the medium term (ie next 50 years), the relative mean sea level change allowances require us to consider increases to mean sea level above 1990 levels of 123mm by the end of the first epoch, and 348mm by end of medium term and 923mm by the end of the SMP 100 year appraisal. As there are expected to be variations across the region, and Morecambe Bay has historically seen relative sea level fall, there is uncertainty of when sea level rise will begin to impact the Bay. It has been assumed, Appendix C, p C-507 that impacts in terms of shoreline response will not be seen until into the medium term. However, in relation to flood risk it should also be noted that locally in estuaries and bays there may be amplification of tidal range that may mean that high tide levels and surge tides could be subject to larger increases than the regional allowances. The residual flood risks to assets behind defences will therefore increase significantly in the long term so it is appropriate to consider planning for adaptation where it is feasible, rather than assuming long term protection will be provided and increasing the assets at risk in the flood plain through development when it could be directed elsewhere. With regard to the stability of the Bay, the need to allow for the accelerated sea level rise of 13mm/year after 2085 is so significantly different to contemporary conditions that there is large uncertainty that sediment supply to the bay can keep pace.

The SMP assessment of estuary response indicates that the estuaries of Morecambe Bay will be expected to accrete, and be fed from the Bay. While there is uncertainty in theories on estuary “Rollover” (Appendix C, pC-4), landward movement in estuaries to keep pace with the tidal frame could result in erosion of outer areas of estuaries to compensate for accretion towards the upper estuary.

101 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? It is understood that the defences at the Bourne Leisure site were upgraded in response to channel movements, rather than general erosion. The meandering of the channels and the associated highly dynamic intertidal banks are a recognised major factor in the shoreline behaviour, due to the potential for different areas to becoming susceptible to significant changes in exposure to the waves and currents (Appendix C, page C-16 & C-515). The movements of the Leven channel have compromised defences on this frontage before (C515) and so even though the Bourne Leisure site defences have a 50 year residual life it is appropriate to consider and plan for managed realignment in the medium to long term. As discussed above there are uncertainties surrounding future trends, allowances and predictions for sea level rise, general accretion in the Bay and local exposure to wave action and erosion from channel movement. As a high level policy document, the SMP must take a conservative approach, in order to derive a sustainable policy for the future managers of the coastline, and avoid unsustainable burdens on future generations. Therefore SLR must be assumed to outpace accretion in the long term, as a conservative estimate or scenario. This being the case, it is envisaged that rising sea levels will erode the saltmarsh margins in the area, exacerbated by increasing movement of the various local channels, and so increase the vulnerability of the embankments. A retreat of the defence line is therefore suggested, in order to reduce the risk of a breach and subsequent inundation of the flood plain behind. The defences surrounding the Bourne Leisure site need to be considered in the context of the risk of sea flooding from the adjacent frontages to the west and east (see map of extreme flood risk area in draft SMP Policy Statement). Although more sheltered, these adjacent defences are not so recently upgraded and were considered in the draft SMP to have residual lives less than those of Bourne Leisure and failure of these defences would compromise the site. The timing of proposed managed realignment will most appropriately be based on monitoring the condition of the existing defences and new, set back defences would not be constructed until near the end of the residual life. The draft SMP policy statement recognised that the policy unit has a number of defence elements with differing residual lives, so proposed a phased approach, (see draft Policy statement). This would allow for the Bourne Leisure defences to be retained over the 50 year local strategy developed for the site. In accordance with this approach, if accretion keeps pace with SLR and the Leven Channel does not cause erosion of the

102 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? saltmarsh that protects the defences to the west of the Bourne Leisure headland, then these defences may not become uneconomic to maintain and the need for Managed Re- alignment in the medium term will be avoided. In the long term epoch, beyond the Bourne Leisure local strategy the draft SMP assumed that the defences would become uneconomic to maintain and so the remainder would be realigned. (iv) Proposed form of words to be included in the Plan policy document (and Action plan as 4) Halcrow to look at wording in the plan to state that appropriate) to acknowledge the Lakeland coastal defences and shoreline management strategy over the baseline defence assessment is a baseline and when

the next fifty years. Such wording to include acknowledgement of the revised baseline for the it was undertaken. Also to make it clear the new frontage as a consequence of works carried out during plan development. information has been supplied in some instances. Should consider rewording all documents to make it

clearer that there is the expectation of the defences fronting Bourne Leisure's site will be maintained for at least 50years.

To be done when appendices revised, at a later date – No

action required for response

5) Halcrow to look at rewording the policy statement and plan to acknowledge that there is a private funding source for the defences and that the design life of the

defences is 50 years. Draft revised policy statement wording was forwarded The Policy Statement has been revised in draft to recognise to Bourne Leisure on 6/04/10. BL’s intention to continue to defend the caravan site, which comprises part of the Humphrey Head to Cark frontage, for the next 50 years, with private funding. 2. Actions on Bourne Leisure Ltd. (i) To await the information in item 1. above and to respond as quickly as possible on matters arising to minimise delays to the SMP 2 completion. I trust you are in agreement with these details, however I believe that these were the four action points to come out of the meeting. Further response 21st April 2010 Further comments for consultation report below. We are in receipt of your Notes of the meeting held at Lakeland Leisure Park on 17th March 2010, together with your consultation responses issued on the 6th and 8th April 2010. We have also received the proposed updated draft policy statement. You will find below our detailed Consultant’s response to the recent replies issued on the 6th and 8th April 2010. (a) The SLDC planning department response clarifies the position on maintenance. Noted. (b) Economic Assessment – Does the National Data Base include any value for the Caravan Park and, As described in the appendix, rateable values are used, in a No action required. if so, is this included in the £27.7 million? Any such valuation would need to be removed with the generic way, to derive valuations for commercial properties. caravan park now assumed to have a residual life of 50 years minimum. The meeting notes have the Although the site is included we would not expect high retired line tieing into the Caravan Park defences. Does the £2.9 million include for a new length of accuracy - this would normally only be provided at more embankment across the landward boundary of the Caravan Park or further inland? Does the detailed study stages such as strategies or scheme appraisals economic assessment account for the increased protection afforded by the Caravan Park defences to which use local valuations based on discussions with property

103 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? the EA embankments either side thereby deferring the timing of any re-alignment? The economic owners. As the assessment allows for phased MR, and the site assessment includes for the full cost of maintenance of the Caravan Park defences so it is important defences will be maintained for 50 years it should not be for this benefit from the defences to be included also removed from the appraisal. The outline economic appraisal simply assumed sufficient length of new defence to completely defend across the area behind the caravan park. The SMP2 does not fully take account of the potential increased protection and extended life of the Environment Agency defences by the sheltering from the Bourne Leisure defences. This is too detailed for the SMP level assessment. The SMP2 policy is not specific on timing of the realignment and actual phasing would be subject to monitoring and economics. (c) MR rationale for second epoch – The DEFRA sea level rise advice in October 2006 states annual Responses noted, however the project team was required to rates of sea level rise – for the north-west these rates are:– base the assessments on the 2006 guidance.

1990 – 2025 : 2.5 mm/yr We also note that the July 2009 UKCP09 climate change

scenarios for UK provide for the first time probabilistic 2025 – 2055 : 7.0 mm/yr assessments of sea level rise. However, the EA is undertaking a Add an Action Plan item to the main SMP to consider 2055 – 2085 : 10.0 mm/yr project to consider the implementation of the new scenarios in the impacts of the emerging post UKCP09 climate flood and coastal risk management projects. An item will be change FCRM guidance on the SMP policies and 2085 – 2115 : 13.0 mm/yr added to the Action Plan to consider the impacts of the new residual risks. In 2008 the Journal of Geophysics published a paper from the UK’s leading expert on sea level rise climate change guidance on the SMP2 policies when it is

(P.L.Woodworth) – the paper presented comprehensive evidence that sea level rise for the UK over available. the twentieth century was 1.4 (+/-0.2 mm) mm/yr. Also in 2008 Woodworth co-authored a

publication for the American Geophysical Union that examined sea level rise acceleration over the

last 300 years – this concluded that the underlying trend remained at around 0.01 mm2/yr over the last two hundred years. Simple extrapolation of this trend (included in the paper) gives a sea level

rise of 340 mm by 2090 (rather than 2060 as assumed in the plan).

So the questions are:–

Why is the recent science on the rate and acceleration of sea level rise ignored in SMP 2? The

guidelines from DEFRA (October 2006) should of course be observed as requested by Government but not without qualification or challenge using quality evidence available now for over two years. Response noted. With the medium and long-term policies for the Humphrey Head to Cowpren Point frontage The Defra allowances are just that – allowances to be taken predicated entirely on sea level rise why is the policy to be changed at this time when the evidence into account by policy makers when setting coastal defence base is shown to be flawed? The sea level rise of 2.5 mm/yr from 1990 has not occurred- the policy and in the design of capital schemes. The 2006 increased acceleration of sea level rise has not occurred. The timing of sea level rise changes forecast allowances are based on the precautionary principal and are by DEFRA is now at least 20 years late and maybe 30 years. The scientific evidence will of course be subject to revision, which can be taken into account in future No change proposed. constantly updated but surely the present factual evidence overwhelmingly supports a medium term SMP reviews and strategies. The allowances increase policy of HTL subject of course to regular review from monitoring data. Such an approach provides a exponentially between epochs so it is not surprising if evidence sustainable policy without premature anxiety for local communities. The policy change from HTL to for measured sea level rise since 1990 does not yet match the MR could reasonably be tied to sea level rise evidence so that as soon as the acceleration increases mean allowance in the first epoch. As noted in earlier responses the next plan review would consider policy change. After all there is a twenty year ‘breathing space’ the implementation of SMP policy will need to reflect defence following acceleration increase according to forecast. condition and changing risks so actual timings of changes will be Morecambe Bay has over 100 square miles of intertidal sand and is formally classified as an estuary. subject to more detailed consideration. No change proposed. The supply of sediment to the Leven and Kent estuary approaches is therefore assured for the period The SMP2 team have earlier responded, noting that channel of the plan. Local erosion of these smaller estuary approaches will remain that associated with migration has previously been an issue in this policy area.

104 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? channel migration rather than anything more severe. The SMP2 is a broad scale plan and takes a simplistic approach through using 3 epochs. Strategies and schemes are able to Whilst the long-term epoch is a major present concern to the Caravan Park the assumption that the consider timings more accurately. It is agreed that a 50 year defences will fail in 50 years is a severe interpretation of the evidence available. From the sea level assumption could be a severe interpretation, but it should be No change proposed. rise issues raised above the allowance already incorporated into the defence design projects forward viewed as a long term plan that will be updated at to provide satisfactory service levels of defence to beyond 2090 assuming maintenance is carried out. approximately 10 year intervals. The SMP 2 is required to consider a 100 year future time horizon so the assumption that sea level

rise will outpace accretion needs to be set in that timeframe. This is not supported by the factual

evidence adduced above. The avoidance of unsustainable burdens on future generations is a worthy objective which is best served by identifying potential risks and linking policy to factual evidence rather than prematurely raising alarm amongst coastal communities.

(d) The revised policy statement continues with MR in the second epoch but this is not correct. As The draft revised policy statement, forwarded on 6/4/10 Halcrow make clear in the meeting notes it will be necessary to complete the revised line indicated as follows:

embankment before policy change so the policy change should be HTL subject to change to MR when Humphrey Head to Cowpren Point 11c 10.2: the revised line is completed. If the economics provide a case for MR by the middle of the second Add statement “Localised HTL should be allowed for epoch then the implementation of policy change is unlikely till towards the end of the epoch – HTL is 0 – 20 years: private defences, subject to landowner agreement and then more representative of the proposed policy in the second epoch. appropriate consents” to 1 st epoch as below. Hold the Line – Manage flood risk by maintaining existing Also if accretion keeps pace with sea level rise over the second epoch, as expected, then raising the defences to an adequate standard. Investigate opportunities existing banks is known to be the cheapest option – a study is not needed to prove this known fact. for phased Managed Realignment to address flood risk Revised text for proposed final policy statement: Again this argues against MR in the second epoch. when defences become uneconomic to maintain in their current alignment. Humphrey Head to Cowpren Point 11c From a planning point of view (notwithstanding Flood Zone 3 issues) the SMP 2 should provide 10.2: guidance on development timescales. If HTL is the likely policy in the second epoch then 20-50 years: developments of up to 50 years life should be stated as OK from coastal defence point of view. 0 – 20 years: Managed Realignment – Subject to study findings, Otherwise the SMP 2 is effectively ‘blighting’ the area behind the existing defence line. It is therefore monitoring of the defences and shoreline evolution, Hold the Line – Manage flood risk by proposed from the evidence available that the policy statement be changed for the second epoch to implement opportunities for phased realignment when maintaining existing defences to an adequate be HTL with the same wording as for the first epoch with the additional paragraph on private defences become uneconomical and establish a more standard. Investigate opportunities for phased defences to appear in all three epochs. natural and sustainable defence alignment. Managed Realignment to address flood risk when defences become uneconomic to maintain in their Localised HTL should be allowed for private defences, current alignment. subject to landowner agreement and appropriate consents Localised HTL should be allowed for private 50-100 years defences, as long as this has no adverse affects Managed Realignment – Phased realignment of remaining on coastal processes or internationally designated defences towards a more natural and sustainable defence habitat and subject to a private funding alignment. agreement, landowner agreement, and appropriate consents. Localised HTL should be allowed for private defences, subject to landowner agreement and appropriate consents. 20-50 years: Following further discussions within the project team, review of Managed Realignment and Local Hold the consultation responses and proposed changes in other The Line (subject to private funding contentious policy areas, the SMP2 team has sought advice from agreement ) – Subject to, study findings, the National Quality Review Group, who ensure all SMP2s monitoring of the defences and shoreline meet Defra guidelines and are consistent. The SMP2 team has evolution. Implement opportunities for phased subsequently agreed to change the policy headline in the second realignment when defences become uneconomical epoch for Policy Unit 11c 10.2 (Humphrey Head to Cowpren and establish a more natural and sustainable Point) to recognise that the caravan park section of the defence alignment. frontage has substantially new defences and that there is a Localised HTL should be allowed for private commitment to private funding to maintain these for at least

105 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? the short and medium term to protect the caravan park. The defences, as long as this has no adverse affects policy for the second epoch will now be ‘Managed Realignment on coastal processes or internationally designated with Local Hold the Line’. This can only be applied in special habitat and subject to a private funding cases where there is a reasonable expectation that the private agreement, landowner agreement, and landowner will continue to provide funding for the local appropriate consents. defences. The detailed wording within the policy statement will 50-100 years reflect that this is subject to private funding and subject to gaining necessary consents. This is standard procedure for all Managed Realignment – Phased realignment private frontages with a policy to ‘Hold the Line’. Following the of remaining defences towards a more natural precautionary principle it would be unreasonable of the SMP2 and sustainable defence alignment. not to highlight that MR may occur in the second epoch along Localised HTL should be allowed for private the adjacent Environment Agency maintained frontages. Until defences, as long as this has no adverse affects further studies are conducted there is significant uncertainty on coastal processes or internationally designated over the actual timing, extent and viability of future realignment. habitat and subject to a private funding The long term SMP2 policy will remain as Managed Realignment agreement, landowner agreement, and with the previously revised approach statement. appropriate consents. It will be important for Bourne Leisure to continue dialogue with the local planning authority and the Environment Agency regarding flood incident management procedures and to consider how the inter-dependency on adjacent defences in the flood cell is dealt with in the future. Although we consider it is already implicit in all HTL policies that private defences to HTL are allowed, we agree that we can add the additional paragraph to the 1 st epoch as well. In accordance with response above, the three policy epochs should not be seen as definitive timings for change. 3. Action Plan The SMP2 team notes that the national guidance is clear that No changes proposed. SMP2 analyses and proposed policies must be based on existing It is highly unlikely that the funding will be available for the studies recommended for this policy unit assets at risk and not allow for or encourage future over the next five years. This makes the argument for policy to be based on the factual evidence to development in coastal risk areas. The SMP is a non-statutory be even more important. If the studies are deferred, as is likely, to the end of the first epoch then document and while policies for coastal defence authorities are there will be significant economic impact on developments affected by the policy change from HTL to set within SMPs they do not override Statutory rights or duties MR. under land use planning legislation, the Habitats Regulations or flood and coastal defence legislation such as the Coast Protection Act (1949), the Land Drainage Act (1991), the Flood and Water Management Act (2010) etc. In summary, the proposed changes to the SMP 2 following our meeting do not go far enough. The Response noted. policy of MR for the second epoch is not supported by the available factual evidence or the Following review of the consultation responses, and noting the See above arguments adduced by Halcrow. A policy of HTL for the second epoch would recognise the factual commitment that Bourne Leisure has made for future defences, evidence more thoroughly. The policy commentary would alert the local community to the potential the proposed revised SMP policy in the second epoch has been risks and thereby fulfil the objective of sustainable policy. Monitoring would identify when policy changed to managed realignment with local Hold the Line, change needed to be considered and thus the local community would become more engaged in the subject to private funding agreement. process. This approach identifies the risks but links the policy change to factual evidence rather than unrealised forecast – it therefore takes an adaptable approach and avoids premature blight and It will be important for Bourne Leisure to continue dialogue anxiety. with the local planning authority and the Environment Agency regarding flood incident management procedures and to As you are aware Bourne Leisure have invested, in partnership with the Environment Agency, consider how the inter-dependency on adjacent defences in the

106 Humphrey Head to Cark – 11c 10 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? considerable sums of money both in the physical defences at Lakeland and a comprehensive study flood cell is dealt with in the future. based on recent detailed information. A monitoring system has been set up as detailed in the Strategy Plan which will continue to gather information in the short and long term. We do not believe the present proposed changes reflect the current and future situation at Lakeland. Bourne Leisure through Haven Family Holidays has 35 Holiday Parks around the mostly on a shoreline location. In addition Warner Holidays and Butlins also have coastal sites around the UK. The Company through our consultants have been involved in numerous SMP2 consultations. In the majority of cases the proposed SMP2 policy reflects the actual situation that will occur, this we understand is the Environment Agency policy. Lakeland is an important site to the Company as can be shown by the commitment made over the last four years in particular. It is our future policy to develop this site and continue to support The EA in the Hold the Line Policy. PCR_211 Concerned by the loss of a large area of valuable agricultural land. Response about the scale of agricultural land loss and future Forward comments to EA food security and prioritisation of defences are proposed to be Cartmel and The uncertainty which this policy implies will undoubtedly mean that there will be a lack of considered as a broader scale issue across the whole SMP at a Grange West investment in a large area of valuable agricultural land in this locality. Local farmers in this area felt regional or national level in the Action Plan. & Lower that the policies of the environment agency in failing to clear the dykes and cuts regularly is already Allithwaite leading to the value of land falling. They have particularly commented on the way only the centre of The issues raised with regard to the Environment Agency’s Parish Council one dyke was cleared with the debris being piled up inside the dyke effectively blocking the land management of the land drainage system and local consultation drains and the fact the main cut is now only cleared once a year and that in the autumn. The result that has taken place is too detailed for the broad scale SMP, so has been loss of summer crops as fields are waterlogged and the inability of animals to be kept will be passed onto the EA by the SMP team. outside in winter. If farmers are to be expected to take over the maintenance of these drains then they will need some certainty about the future of the land. Recently Lower Allithwaite Parish Council and myself as District Councillor were involved in a consultation on the proposed Coastal Management Strategy. I enclose a copy of the submission made to the coastal group. You will see that most of the concerns of the local farmers whose land may be under threat were not particularly about the coastal defences but the Environment Agency's current policies on clearing cuts and drains. I would be grateful if you could explain the consultation that took place with farmers before alterations to the drainage schemes was implemented and any reviews you may have made about the possible impacts of the changes of practice which you have implemented.

107 Outer Leven estuary – 11c 11 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_203 11c 12.3 – 11c 11.5 See also comments on response on 11c 12.3 below. No changes proposed. Councillor, My concerns are based around cell 11 and especially the area at Canal Foot, . The The draft SMP allows for managing the flood risk to the Canal South Lakes ideas suggested are HTL + MR and already these are deemed as inadequate by residents on the Foot area by consideration of flood risks from the Conishead District shoreline. The SLDC flood protection officer is helping to undertake some project work that frontage and subject to further studies creating a set back Council will help. a) the houses on the front at Bay House / canal Foot area. At extreme high tide the embankment in future. water (in certain conditions) will undermine and pass underneath the road surface and flood At Canal Foot itself, there is as you say a potential flood properties (swamp would be a better word). b) The whole of East Ulverston Ward would pathway along the canal. The proposed SMP allows for a HTL become flooded if defences were breaches at the north - Greenodd Sands area plus ingress policy here and this will allow the local authority and the from area near Conishead. All residents have extreme concerns with the concept of NAI at environment Agency to take action to manage the risks if the Conishead area - this particular following surface water flooding which affected 102 houses necessary and justified. in Nov 2009 - 50 resident households now in temporary accommodation and others suffering greatly. The residents also are very concerned over the huge body of water in and future issues which may affect how this 'reservoir' plays its part in keeping houses dry.

108 Leven Estuary – 11c 12 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_123 In the consultation document this area is considered for MR in the 20-50 yr period, followed by NAI N Response noted. The flood risk is recognised in the SMP policy Revise approach to PU 12.3 to allow for consideration in the 50-100 yr period. Whilst on a personal basis, I would welcome a return to a more natural area maps and does need to be taken into account in the of need for a set back defence. Add item to Action Councillor, adjacent to the valuable RAMSAR site of Morecambe Bay, never the less, as the South Lakeland development of the next stage of studies. The proposed draft Plan to consider flood risks to lower Ulverston and South Lakeland District Councillor for the Mid Furness Ward, I must point out to you the dangers inherent in this policies for this area allow for Hold the Line for up to 20 years need for a set back defence in longer term. District policy. whilst further investigation and monitoring are considered. The Council approach to implementation of policies would be developed In 2002, under conditions of a surge tide and east/south east winds, these defences were breached through studies and more localised consultation as allowed for around the Barrow End Rocks area. Although I was not present at the time to witness this, I have in the Action Plan. been informed that the ingress of water from this breach travelled southwards until it reached Next Ness i.e. not far off Ulverston Canal. I have been informed by those with local knowledge, that, historically, this combination of sea and weather conditions has occurred on a 1/50 yr basis. If the defences in this area are not maintained on a long term basis, then I believe that at some time in the future, there may be a risk of a much greater flood than that which occurred in 2002. You have identified potential impact on isolated properties in the document, but I would like to remind you also of the following: There are 4 roads crossing the mosses to the south. These roads are already showing damage due to previous flooding and poor management of drainage schemes. As well as providing access to some 50 houses and agricultural land, these roads are the access roads to the coast and to the Leven viaduct, and as such, some of the 4 must be retained in a good condition. A flood of greater proportions is likely to reach the canal area of Ulverston. This area is being flagged up in the Local Development Framework for future development. I have spoken to the owners of Plumpton cottage farm, Mr William Case, and his father-in-law, Mr John Phizaklea, of whom would be able to provide you with more details of the area and likely impact of changes to the sea defences. The document states a need for investigation into the impact of the policy for this section on the rest of the estuary and the adjacent bay. This is highly complex area which I believe is still not fully understood, in spite of a number of surveys over the years. I hope that the NW England and N Wales coastal group will carry out those investigations before arriving at a firm conclusion as to the future management of this section of the sea defences. PCR_143 11c 12.3 N Response noted. The flood risk is recognised in the SMP policy Revise approach to PU 12.3 to allow for consideration maps and does need to be taken into account in the of need for a set back defence. Add item to Action Individual, Lack of attention to tidal flooding from overwhelming of defences barrow end rocks. development of the next stage of studies. Plan to consider flood risks to lower Ulverston and Ulverston Damage to defences alone will impact as far as the canal. need for a set back defence in longer term.

PCR_203 11c 12.3 Response noted. The flood risk is recognised in the SMP policy Revise approach to PU 12.3 to allow for consideration maps and does need to be taken into account in the of need for a set back defence. Add item to Action Councillor, My concerns are based around cell 11 and especially the area at Canal Foot, Ulverston. The ideas development of the next stage of studies. Plan to consider flood risks to lower Ulverston and South Lakes suggested are HTL + MR and already these are deemed as inadequate by residents on the shoreline. need for a set back defence in longer term. District The SLDC flood protection officer is helping to undertake some project work that will help. a) the Council houses on the front at Bay House / canal Foot area. At extreme high tide the water (in certain conditions) will undermine and pass underneath the road surface and flood properties (swamp would be a better word). b) The whole of East Ulverston Ward would become flooded if defences were breaches at the north - Greenodd Sands area plus ingress from area near Conishead. All residents have extreme concerns with the concept of NAI at the Conishead area - this particular following surface water flooding which affected 102 houses in Nov 2009 - 50 resident households now in temporary accommodation and others suffering greatly. The residents also are very concerned over the huge body of water in Ulverston Canal and future

109 Leven Estuary – 11c 12 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? issues which may affect how this 'reservoir' plays its part in keeping houses dry.

110 Bardsea to Piel Island – 11c 13 Response Response Agree to SMP2 Team Comments Proposed Action from? draft Policies? PCR_98 Draft action plan 11c13 item 2.2 - The Roa Island Study is being reviewed currently Response noted Action plan updated to reflect this. Barrow BC Draft action plan 11c13 item 10 adaptation/resilience - Refers to item 13.1 which doesn’t exist Response noted Correct reference to tem 12.2 PCR_91 I note that no active intervention is proposed for sub cell 11c location 13 (Bardsea to Piel) except that Details of changes to defences are beyond the scope of Forward comments to SLDC for response local protection may be permitted subject to consent. work for SMP team and therefore will be passed to the Individual Local Council representative. A site specific feasibility My residential property lies on the coast at Baycliff and is currently "protected" by a gabion stone wall. study may be needed to assess the effects of any Could you tell me what form of additional or replacement protection would be acceptable? defences on the adjoining coastline. A feasibility study

I also note that in some other sub cells where no active intervention is proposed, there is also the could also be used to assess whether localised defences commitment to "providing" (as opposed to "permitting") localised property defences. could be of sufficient priority to justify national or local funding. However, where NAI is the proposed policy this This implies that such protection would be provided by the EA at no cost to the property owner whereas means that there is very unlikely to be public investment additional protection that would be merely "permitted" would presumably be at the owner's expense. in coastal defences, so this should not be the case. Can you please explain why there is a difference?

There are six properties fronting the beach in this location which are currently protected by gabion walls With regard to whether localised defences are that will probably require upgrading by epoch 2. Is this not a sufficient level of residential development at 'permitted' or 'provided' under a No Active Intervention risk to justify the "provision" of local protection rather than merely consenting to it? Scenario, we are unsure where in the plan this is written. We would be grateful if you could let us know as this is Check wording of other policy units. likely to be a mistake. In some areas the plan may suggest that No Active Intervention provides increased protection to adjacent lengths of coast due to sediment supply but there should not be any other references.

Depending on the level of risk and the technical, Revise Action Plan item. environmental and economic acceptability there may be a case for local authority or environment agency funded localised defences. Propose to add revise item for PU13.1 in action plan to include considering the feasibility of erosion protection. PCR_147 As part of the public consultation on the Shoreline Management Plan, Parish Council have Response noted. reviewed the policies for the areas 11c.PU13:1 and 11c.PU13:2, which cover the length of the parish’s Aldingham We propose to revise the Action Plan item 12.2 to Revise Action Plan item. coastal boundary. I have outlined the observations of the Council below. Parish Council include for consideration of appropriate recording or 11c.PU13:1 – there is some concern that sites of historical or environmental importance within this mitigation for impacts on the historical environment policy unit may be irreversibly damaged or destroyed if no attempts to protect them are made. These under no active intervention. include: a) St Cuthberts Church and graveyard, Aldingham which dates back to 1144 AD, though the site may be older. The site stands right on the shore and is currently protected by a large sea wall. b) Aldingham Motte is a 11th century earthwork which was once the administrative centre of Furness; it is one of the oldest structure in the area. The motte and adjacent earthworks stand on the top of a hill which has already seen considerable erosion in recent years. c) Sea Wood, an ancient deciduous woodland managed by the Woodland Trust. d) Beanwell at Baycliff, a natural freshwater stream which provided water for the area until the early 20th century. 11c.PU13:2 – parts of the A5087 Coast Road are already dangerously close to the shoreline and it is Response noted. The draft SMP Policy for this frontage No changes proposed. only through the efforts of this Council that damage to this important route has been prevented in the allows for Hold the Line, followed by possible past. realignment of the road in appropriate locations by the Highway Authority if economically justified. A breach which reached within 600mm of the road was halted by an expensive rock-armour infill, but

111 Bardsea to Piel Island – 11c 13 Response Response Agree to SMP2 Team Comments Proposed Action from? draft Policies? there is evidence that the defence is already being shifted. It is the opinion of the Council that back-filling these defences with concrete or using metal gabions would be a simple but effective way to prevent further deterioration, saving more costly repairs in the future. During public consultation for our Parish Plan, coastal erosion came out as one of the most important topics and more than 2/3 of the respondents to our questionnaire said that they were ‘quite concerned’ or ‘very concerned’ about the issue. Almost 60% of the households in the parish returned a questionnaire, so this represents a significant number of residents. We hope that their views will be taken into consideration. The Parish Council looks forward to hearing the final outcomes of your consultation. PCR_62 Several curators noted that the treatment of scheduled monuments and historic environment assets The draft policy statement for Piel Island proposes a Revise action generally is inconsistent. In relation to Piel Castle, the ‘built environment’ lists “ferry slipway and public general no active intervention policy for the island, with English house” but not the castle. The “Do Nothing” option suggests “beach losses likely on SE corner of Island”, the proviso that localised defences, e.g. at Piel Castle Heritage without mentioning of the likely damage to the monument would be permitted, subject to consent. The environmental justification summary given is “Natural sections of coast should remain as such to maintain the character of the island. Defences at Piel Castle would have minimal wider impact.” Under economic justification summary there is a note that “limited defences for the Scheduled Monument may be viable, not valued at this stage”. Also, an item has been included in the action plan to consider in more detail the impacts of the SMP policy on Piel Castle. Your advice on the appropriateness of the proposed action plan item, including responsibility is welcomed – presently shown at EA, but may be more appropriate to be EH as owner of the property? Piel Castle reference relates to SMP1.

112 – 11c 14 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_98 11c 14.5 Will amend spellings / place references. Correct place names. Barrow BC Walney Island 11c14 draft recommendations 14.5 - Under justification it refers to managing risk to communities at Biggar and Tummer Hill – this should be Biggar Bank and Biggar Village (here and also in various references in the Appendices Tummer Hill is misspelt as Trummer Hill` 11c 14.7 Draft policy - West Shore Park is 3 words Noted, will correct place name. Update policy statement to reflect need for short term intervention to facilitate medium term relocation of Surveys of the beach in front of West Shore Park show signs of possible recovery of the beach properties. indicating that material may now be bypassing the groyne, therefore, ‘feasibility’ of breaching the Response noted. groyne is not the only issue to be explored and may not be necessary in any case As above draft action plan item 2.3 - As above – not certain that breach would be necessary. BBC Response noted. Update Action Plan to reflect limited intervention. policy is to protect the frontage in the short term (up to 15 years) to allow time for relocation of properties at risk Sub-cell 11c (pg. 21) 2nd para. And elsewhere in the document - Final sentence refers to modifying the The text about modifying the groyne will be changed to a Modify / improve text regarding Earnse Point / groyne at Earnse Point – have the conclusions of the ABPmer Appropriate Assessment report for more specific generic action. Westshore Park. West Shore Park been taken into account? PCR_20 The effects of failure to address concerns of residents and the effects on the Cumbrian infrastructure The SMP2 action plan allows for progression of the South No changes proposed and its repercussions re. energy coast. Walney Flood Alleviation scheme and limited intervention to Individual, manage risks at West Shore park. Friends of I feel that ALL agencies need to address the concerns of residents within their local environment. The Walney; issue re flooding on Walney has been ongoing for 20 years with no visible progress. Barrow Trades Council PCR_21 Do not agree with policies. The coastline should be held, Walney Island is only 1 mile wide. N Response noted. Expenditure on flood defences is subject to Policy statement updated to reflect response from national prioritisation and unfortunately it is unlikely to be BBC. Councillor, Concerned about Land in front of West Shore Park. affordable or environmentally acceptable to defend Barrow Walney Island coast line which protects Barrow-in-Furness. everywhere in future. The SMP does recognise the strategic Borough importance of the island in protection of Barrow and the Council Yes I feel that coastal protection should be placed in this area as soon as possible to protect the shipyard etc, and the island is not expected to breach through residents in the area before it’s too late. erosion even well beyond the 100 year timescale of the SMP. See response from Barrow BC above. The council indicates commitment to interim measures to protect the shoreline in the short term to allow for relocation of properties at West Shore Park. PCR_22 11c 14.2; (Questionnaires from meeting, but no further details No changes proposed provided) PCR_24 Concerned about policies. Individuals, Walney Island PCR_23 11c 14.7 Y (Questionnaires from meeting, but no further details No changes proposed provided) Individual, Walney Island PCR_64 A number of houses that have just been built need to be protected. Y Response noted. No changes proposed Individual, One important danger is not having a way of making a daily measurement of tidal interest, to the The regional monitoring programme will be making coastal Hare Hill, general public because ideas from visitors could have an effect on similar tidal systems. The weather is monitoring data available to all parties via a website.

113 Walney Island – 11c 14 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Walney an interest that stands alone in its prolification to everyone. PCR_120 I have been aware of problems relating to coastal erosion and the resultant flooding on Walney Island Response noted. The SMP2 does recognise the importance of Amend Policy statement to reflect adaptation for nearly twenty years. Firstly through a work colleague and County Councillor. Since then I have Walney in protecting the shipyard, port and the town on the measures. Individual been involved with a community group and one major issue ahs been the erosion at Earsne Bay mainland. While the erosion rates predicted near Earnse Bay adjacent to West Shore Residential Park on Walney. It is apparent from attending community, would impact on West Shore Park, there is no risk of the neighbourhood forum meetings and the recent meeting re shoreline management that those residents island breaching at this location over the period of the plan. affected feel disillusioned by a lack of consideration by the Quango's such as DEFRA and English The Council is undertaking limited intervention to slow the Nature etc. rate of erosion and facilitate adaptation. Walney island is vital to the prosperity of Barrow in Furness, it acts as a breakwater to the shipyard and port facilities and also provides vital protection to the low lying areas of Salthouse and Marsh street, many of these areas are at present due for regeneration which could be put at risk by failure to deal with coastal erosion on Walney.

114 Walney Channel (Mainland) – 11c 15 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_98 Walney Channel 11c15 Predicted implications 0-20 years - The landscape character and visual amenity Response noted Revise assessment to amend format to neutral column shows ‘no designated landscapes within scenario area’ as negative – should be neutral Barrow BC

115 Duddon Estuary – 11c 16 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? PCR_75 11c 16.3 Askam to Dunnerholme Agreed, MR would be a more proactive option, no limited No change proposed justification for flood and coastal defence expenditure to do so. RSPB - MR with tidal exchange would be a more proactive policy.

We do however note that tidal exchange is referenced in this section. 11c 16.4 Dunnerholme to Sand Side The flood risk zone in this area includes properties in / near Revise “justification” text to reference social benefits Soutergate in addition to the railway, whereas in PU16.3 the in protecting Soutergate. - We remain unclear why HTL is proposed for this section, which is very similar to 16.3. railway is set further from the coast and no properties in the Tidal exchange under a MR policy would therefore seem appropriate. flood risk zone. 11c 16.6 Herdhouse Moss Response noted. No change proposed - MR with tidal exchange would be a more proactive policy. We do however note that tidal exchange is referenced in this section. 11c 16.12 Hodbarrow Nature Reserve & Lagoon Response noted. The need for compensatory habitat was noted Revise Action Plan item to link to RHCP in the draft plan. The revised action plan will link consideration - Statements in the current document broadly reflect our earlier submission, with regards impacts on of alternative habitat creation to the Environment Agency’s this part of the Duddon Estuary SPA. developing regional habitat creation plan. Before MR could be considered, alternative freshwater habitat would need to be secured. PCR_163 11c 16.8 Thank you for the helpful response. Individual, Background: live and farm at Low Shaw Farm, which is located principally between the flood In relation to this and other responses received, we propose to Revise short term policy in 16.8 to HTL whilst further Millom embankment and the nearby railway line. change the policy to HTL in the short term, epoch 1 pending consultation and investigations are progressed. further consultation and investigation of MR opportunities. Type of Flood defence: Raised grassed embankment. The responses about marsh management and the existing Flood Embankment The current embankment protects the farmland, house condition of the defence are noted and will need to be taken Relevance: and buildings and the railway line. Without the embankment the sea would inundate a into account during the next stage of studies. Note that in substantial part of the farm. The embankment provides safe grazing for Marsh going sheep during practice realignment or withdraw from maintenance of defences

high tides. The Marsh is designated a site of Special Scientific Interest with grazing forming an would not necessarily apply to the whole frontage and the detail important part of the Marsh Management. The ability to safely graze the marsh would be severely of the approach to delivery of the policy will be developed in restricted without the farmland providing safe sheep grazing during periods of high tides. If the more local consultation and studies.

existing sea defences were allowed to be breached the nearby railway line would be in danger of

being washed away. We will add consideration of risk to the railway to the Action Action Ref 2.2 should be expanded to consider the risk to the railway line from Green Road Station Revise Action ref 2.2 to include railway plan. to the Viaduct. Flood defence The existing embankment is in generally good condition Condition: with minimal annual maintenance and no signs of erosion. Future Management: The existing structure is fit for purpose for the foreseeable future, and with minimal maintenance should provide many years of flood defence. Hence a ‘Hold The Line’ policy should be adopted for at least the period 0-20 years and 20-50 years Summary: Study work for PU 16.8 must include the risk to the railway. The existing embankment will provide adequate flood protection for the foreseeable future with minimum maintenance so a ‘Hold The Line’ policy should be adopted. PCR_188 11c 16.8 16.8 – following responses during the consultation period the headline policy for the short term will be revised to HTL, whilst Millom 11c 16.9 Revise short term policy in 16.8 to HTL whilst further consultation and investigations into the practicality of

116 Duddon Estuary – 11c 16 Response Response SMP2 Team Comments Proposed Action from? Agreeto draft Policies? Without Duddon Bridge to Millom implementing the medium term policy of managed realignment is consultation and investigations are progressed. Parish Council investigated. We understood from information given at the meeting held at Muncaster Castle on Thursday 11th February 2010 that the coastal defence priorities have changed since the building of the present

embankment as recently as the 1960’s. Previously the priority was to defend agricultural land, 16.9 – Response noted. However, the draft policy was to however, precedence is now given to protecting housing and other buildings. Thus a full study and continue to hold the line in the short term whilst further review of coastal defences is being undertaken with a view to drastically reducing active intervention. consultation and investigations with regard to the practicalities No changes proposed The council’s observations are: of withdrawing from the front line are progressed. The further

studies and investigations will inform the medium / long term As the meeting was held only on 11th February it is hoped that these representations will be taken policies, which may need to be revised subsequently. In into account and not regarded as late submissions. particular, the option of Managed Realignment is subject to

The land adjacent to the present embankment is low-lying and there are no natural features which further consideration of the wider implication on the estuary. could form the basis of a new line of defence before the railway embankment itself. It would Further modelling of coastal processes in the estuary has been therefore be necessary to build a new embankment to the seaward side of the railway track. The underway during the consultation and is expected to report

cost of such new protection is likely to be very much more than maintaining the existing earth works. later this year.

The council is very disappointed with the principal aims of the policy for defending the coast which now seems to be to let things take their course and accept the consequences. The responses regarding the proposed Kirksanton site are It is very noticeable that the laissez-faire attitude identified in the above clause is very different from noted. The environmental impact studies for that site are considerations of coastal defence planning which are relevant to the proposed new nuclear power expected to include consideration of the wider impacts of any

station at Kirksanton where very considerable coastal fortifications will be necessary if adequate proposed long term coastal defences and short term protection for the site is to be ensured. Representatives of the council have attended several nuclear construction impacts. It is anticipated that the local council, power station consultation meetings and it is understood that the nuclear building project cannot parish council and the Environment Agency and others all be

proceed unless stringent safety measures are complied with in order to safeguard the site from consulted on the Environmental Statement when produced and coastal erosion and flooding. will need to comment on implications on wider scale coastal processes at that time. The SMP team suggests that the coastal The policy of protecting some parts of the coast at the expense of other parts is misguided and as a processes review for the SMP and reports on ongoing more consequence in the long-term there will be damaging effects on the whole coast including those areas detailed studies for the Duddon should be taken into which are meant to be protected. consideration when responding.

In conclusion the council is of the opinion that the object of safeguarding the railways, roads and property in sections 11c PU16.8 and 11c PU16.9 cannot be achieved without safeguarding other parts of the coast due to the inter-relationships of the coastal system. We consider, therefore, that all the

existing defences along these section ought be maintained.

PCR_98 Is the split between sub-cell 11c and d Haverigg or Hodbarrow Point? Draft boundary is incorrect due to confusion in boundary Change boundary to Hodbarrow Point document. Barrow BC

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