Consultation Report Relevant to Cell 11B Annex 2

Annex 2

Shoreline Management Plan Adoption

Annex 2- Consultation report relevant to Cell 11b Annex 2

North West & North Wales Coastal Group

North West England and North Wales Shoreline Management Plan SMP2

Appendix B Part 2 – Public Consultation Report

This document describes how we have consulted with the public about the Shoreline Management Plan 2, summarises the responses received during the consultation and gives the SMP2 team’s comments on these responses.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Contents Amendment Record

This report has been issued and amended as follows:

Issue Revision Description Date Approved by

Draft Public Consultation Report for client 1 0 10/05/2010 A Parsons comment

2 0 Final report for publication 11/06/10 A Parsons

Halcrow Group Limited Burderop Park, Swindon, Wiltshire SN4 0QD Tel +44 (0)1793 812479 Fax +44 (0)1793 812089 www.halcrow.com Halcrow Group Limited has prepared this report in accordance with the instructions of their client, the Environment Agency, for their sole and specific use. Any other persons who use any information contained herein do so at their own risk. © Halcrow Group Limited 2014 North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Table of Contents

1. INTRODUCTION – WHAT IS THIS DOCUMENT? ...... 1 2. HOW WE CONSULTED WITH THE PUBLIC AND DEALT WITH CONSULTATION RESPONSES ...... 2 2.1 Website ...... 2 2.4 Letters to all registered stakeholders ...... 4 2.5 What we did with the consultation responses ...... 4 3 GENERAL RESPONSES ...... 7 3.1 Responses giving support ...... 7 3.2 Climate change and Sea level rise ...... 8 3.3 Food Security ...... 9 3.4 Managed Realignment ...... 10 3.5 Private defences ...... 12 3.6 Compensation ...... 13 3.7 Consultation methods ...... 15 4 CONSULTATION STRATEGY AND RESPONSES RECEIVED: SUB-CELL 11A –GREAT ORME’S HEAD TO SOUTHPORT ...... 17 4.1 Consultation Strategy Sub-Cell 11a ...... 17 4.2 Public Events and Stakeholder Meetings ...... 19 4.3 Consultation Responses ...... 19 4.4 Area Specific Responses ...... 20 5 CONSULTATION STRATEGY AND RESPONSES RECEIVED: SUB-CELL 11B – SOUTHPORT TO ROSSALL POINT, FLEETWOOD ...... 28 5.1 Consultation Strategy Sub-Cell 11b...... 28 5.2 Public Events and Stakeholder Meetings ...... 29 5.3 Consultation Responses ...... 30 5.4 Area Specific Responses ...... 30 6 CONSULTATION STRATEGY AND RESPONSES RECEIVED: SUB-CELL 11C – ROSSALL POINT FLEETWOOD TO HODBARROW POINT ...... 33 6.1 Consultation Strategy Sub-Cell 11c ...... 33 6.2 Public Events and Stakeholder Meetings ...... 34 6.3 Consultation Responses ...... 35 6.4 Area Specific Responses ...... 35 7 CONSULTATION STRATEGY AND RESPONSES RECEIVED: SUB-CELL 11D – HODBARROW POINT TO ST BEES HEAD ...... 50 7.1 Consultation Strategy Sub-Cell 11d ...... 50 7.2 Public Events and Stakeholder Meetings ...... 52 7.3 Consultation Responses ...... 52 7.4 Area Specific Responses ...... 52 8 CONSULTATION STRATEGY AND RESPONSES RECEIVED: SUB-CELL 11E –ST BEES HEAD TO THE SCOTTISH BORDER ...... 58 8.1 Consultation Strategy Sub-Cell 11e ...... 58 8.2 Public Events and Stakeholder Meetings ...... 60 8.3 Consultation Responses ...... 60 8.4 Area Specific Responses ...... 60

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

SUPPORTING ANNEXES TO THE CONSULTATION REPORT

B4 Consultation Materials B5 Sub-Cell 11a Consultation Materials B6 Sub-Cell 11b Consultation Materials B7 Sub-Cell 11c Consultation Materials B8 Sub-cell 11d Consultation Materials B9 Sub-cell 11e Consultation Materials B10 Sub-Cell 11a Consultation Location Responses B11 Sub-cell 11b Consultation Location Responses B12 Sub-Cell 11c Consultation Location Responses B13 Sub-Cell 11d Consultation Location Responses B14 Sub-cell 11e Consultation Location Responses B15 SMP Document General Responses North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

1. Introduction – what is this document?

The North West England and North Wales Coastal Group and its members have consulted with stakeholders and the public throughout the development of the North West England and North Wales Shoreline Management Plan 2 (SMP2) see Appendix B Part 1 . Meetings have been held with stakeholder groups and elected members at key stages in the plans development and these are described in more detail in Appendix B Part 1 sections B1, B2 and B3 .

This Consultation Report describes how we have consulted with the public during the public consultation stage (October 2009-February 2010) to inform them about the draft Shoreline Management Plan 2 and to give them the opportunity to comment on the proposed policies. Section 2 describes what we have done and Sections 3 to 8 summarise the responses we received and how we are taking account of these in finalising the SMP2.

Public Consultation was originally planned to take place over a three month period, from the start of October 2009 until the 31st December 2009. However, due to technical problems with the Coastal Group website and the severe flooding which affected many people in Cumbria in November 2009, we extended the consultation until 14th February 2010.

Concern was expressed in some areas that stakeholders and the public would not have sufficient time to respond to the consultation, especially where there were contentious issues which would require further information and/or meetings to be held. To accommodate for this, certain areas where provisional responses with requests for extensions of time had been made were given until the 31st March 2010 to submit their final consultation responses.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

2. How we consulted with the public and dealt with consultation responses

The SMP2 team developed a strategy setting out how they would engage with the public about the SMP2 consultation.

The following methods of consultation were used during the SMP2 public consultation:

• Information on the North West England and North Wales Coastal Group Website (www.mycoastline.org );

• Consultation Response forms;

• Leaflets placed in town halls and other public buildings;

• Posters advertising events and to use at consultation events;

• Letters to extended stakeholder group, Parish Clerks and Elected Members;

• Press Releases distributed to local media;

• Elected Member Reports;

• Reports to Parish Councils;

• Links to the SMP2 and coastal group website on Local Authority Websites;

• Banners;

• Presentations;

• Radio and television coverage;

• Public evening meetings; and,

• Further targeted consultation in identified ‘hotspots’ tailored for each location taking into account the specific issues and stakeholders.

Details of consultation methods, materials used and meetings held for each area are included at the start of each of sections 4,5,6,7 and 8 .

2.1 Website

The North West England and North Wales Coastal Group website ( www.mycoastline.org) hosted information on the SMP2 consultation, consultation events, downloadable versions of the draft SMP2 consultation documents, the full consultation document and all appendices and maps. A consultation response form was also available to download or complete online. A copy of the consultation response form is provided below in Figure 1.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Figure 1: Example feedback form downloadable from website

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

2.2 Summary leaflets

A leaflet was produced by the SMP2 team to promote the SMP2 consultation. Five separate inserts were also produced and distributed with the leaflets; each containing information about Shoreline Management Planning in each specific area (know as sub-cells).

The general part of the leaflet contained information about the aims of the SMP2 and the key implications and challenges that these could bring to local communities and the environment.

Approximately 3500 copies of the leaflet were sent to Local Authorities and the Environment Agency to be distributed as appropriate. Leaflets were placed in Local Authority offices, Environment Agency offices, local libraries and Town Halls. A copy of the general and specific leaflet text is included in Annex B4.

2.3 Exhibition posters

A series of exhibition posters were produced by the SMP2 team. The posters showed what an SMP is and why it is needed, how the SMP2 has been developed, the 4 policy options available, maps showing where individual policy units, details of where further information can be found and how feedback can be given. Copies of these posters are included in Annex B4 .

An additional poster was produced for Local Authorities advertising the public consultation events a copy of which is included in Annex B4 .

2.4 Letters to all registered stakeholders

A letter which included a consultation response form was sent out to all people and/or organisations identified as having an interest in the SMP2 by Local Authority officers or who had registered an interest in the SMP2 over the course of its development. This letter gave information about the SMP2, raised awareness of the consultation and invited the reader to attend a consultation meeting. A copy of the stakeholder letter is provided in Annex B4.

2.5 What we did with the consultation responses

Written correspondence and consultation response forms were sent to Blackpool Council, the authority responsible for managing the SMP2. An email address was set up for emailed consultation responses and responses submitted through the Coastal Group website ([email protected]).

All consultation responses were collated and reviewed. People who responded received a standard reply from Blackpool Council, on behalf of the Coastal Group. This acknowledged their response and informed them that a formal response document would be produced after the end of the consultation. However, each response received was considered individually and if appropriate, a detailed reply was sent to the responder.

All responses received were recorded as detailed below:

• Upon receipt each response was given a unique reference number;

• Details of each response were entered into a Consultation Response Log (e.g. date, name, contact details, area of interest and comment);

• Each comment was considered individually and any actions required were noted; 4

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

• At the end of the consultation period the responses were reviewed and categorised according to theme and / or geographical location;

• The SMP2 Team held a two day workshop to discuss the response and agree an approach to dealing with them.

• The consultation report was reviewed by the PMB and CSG’s before finalising and making available to the public.

2.6 Where can I find my response?

Copies of all the SMP2 consultation responses can be found in Annexes B10 to B14. These annexes bring together responses under common themes or geographical location, by sub-cell. A comment and/or details of actions taken by the SMP2 Team is listed next to each consultation response. This is to make it clear how consultation responses have been taken into account.

Summarised versions of the consultation responses can be found in this document along with summarised versions of the SMP2 Team’s comments on these.

Section 3 details general responses to the SMP2, the principles behind it and the methods used to develop it. Sections 4 to 8 contain responses grouped geographically (based on the 5 sub cell areas). See Figure 2 below for the geographic location of the Sub-Cells.

Within each geographic summary there are sub-sections to describe:

• How we have engaged with the public to raise awareness of the SMP2 consultation;

• Details of Public Events and Stakeholder Meetings;

• An overall summary of consultation responses; and

• Summaries of area specific responses.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Figure 2: Map showing the location of Sub-Cells in North West England and North Wales

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

3 General Responses

Below are summaries of general responses and issues raised during public consultation and the SMP2 Team’s comments on the responses. These have been split into the following sub-sections.

• Responses giving support • Climate change and sea level rise • Food security • Managed realignment • Private defences • Compensation • Consultation methods

3.1 Responses giving support

Several responses were received expressing support for draft SMP2 policies and / or the draft SMP2 as a whole.

Examples of responses of support relating generally to the whole SMP area included:

“BASC acknowledges the visions outlined in the consultation document for North West England and North Wales Shoreline Management Plan SMP2. BASC believes this process complements existing government coastal initiatives which BASC and its members are actively involved in at national and local levels eg Marine Bill, Coastal Change Policy, Natural England and Environment Agency programmes.” British Association for Shooting and Conservation

“We are aware your SMP process has been out to consultation, a process we embrace and in which we welcome the chance to participate.” The Crown Estate

“With regard to marine activities in the NW, agree to the draft policies.” Royal Yachting Association

“Agree with draft policies for Morecambe Bay and the Kent Estuary” Morecambe Bay Wildfowlers Association

“Broadly agree with draft policies” Cumbria Local Access Forum

“Broadly speaking, we support the adoption of NAI or MR for those Policy Units where these are proposed as the Preferred Option” RSPB

“The National Trust has been involved in the consultation process around the preparation of the SMP2 and broadly supports the policy options and proposals which relate to the land in our care in the Merseyside coast.” National Trust

SMP2 Team Comments

The SMP2 Team would like to acknowledge and welcome the support given for the North West England and North Wales SMP2.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

3.2 Climate change and Sea level rise

A number of responses related to how climate change had been considered in SMP2 development. Other responses indicated people were sceptical about the existence of climate change.

Examples of responses relating to locations across the whole SMP2 area included:

“The main plan document may benefit from a clearer explanation of how climate change estimates have been and will be incorporated into the SMP2 process”.

“This outdated theory has now been thoroughly discredited by most leading scientists apart from the few who have invested their reputations in manipulating the research to try to prove the unprovable, sea levels have not risen and are not rising” .

“The sea levels have not risen by one single millimetre and the rivers running into the (Morecambe) Bay are less full than they have ever been.”

“Issues like climate change effect are not conclusive, in fact some parties now say it is not happening and could be in reverse”.

‘’I am sure that part of this process is promulgated by the theoretical potential for increased sea levels. This is a dubious and controversial area and, whilst it is not acceptable to do so, open to serious scientific challenge. Where is the evidence for this?’’

“Bearing in mind also that the DEFRA guidance on sea level rise from 1990 to present is clearly incorrect for the Irish sea and overestimates sea level rise by a factor of two it would appear premature to adopt policy change in this area at this time”.

SMP2 Team Comments

The global climate is constantly changing, but it is generally recognised that we are entering a period of accelerated climate change, particularly with respect to rising sea levels. The anticipated implications of climate change and sea level rise present a significant challenge to how the coast is managed in the future.

The sea level rise information in the SMP2 has been recommended by Defra and is shown in Table C4 of Appendix C. This information allows for 988mm of relative mean sea level rise between the years 1990 and 2115 in North West England. The Defra information gives average rates of relative sea level rise over 30 year time periods. The acceleration in rise is expected to increase exponentially in future. It is not surprising that evidence for measured sea level rise since 1990 does not yet match the mean rate expected for the first time period,

The United Kingdom Climate Projections 09 (UKCP09) are the most recent predictions on climate change and were released in June 2009. This information has not been used to develop the SMP2 as it was not available at the start of the SMP2 project. However, the SMP2 Action Plan will allow for this to be to be taken into

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

account in implementation and future updates. UKCP09 provides probabilistic projections of climate change. The UKCP09 information includes publications, key findings, information to help the reader and data. The UKCP09 information is available on-line at: http://ukclimateprojections.defra.gov.uk/ Coastal change projections will be updated nationally to consider these recent climate change projections after the SMP2s have been completed around the country.

3.3 Food Security

Concern has been raised that UK food security has not been thoroughly considered throughout the SMP2 process and that the decision to allow agricultural land to flood may result in future problems with food availability. Responses suggest that Government policy has recently changed, with farmers being urged to increase productive land and people being encouraged to grow food at home. Many responses suggest that the draft SMP2 policies go against this Government advice. Along the North West England and North Wales coastline, there has been significant reclamation of land for agricultural purposes. It is seen as unwise to consider abandoning this land at a time when the population is growing and there are concerns about the need to increase future British food production.

Responses mainly relate to Sub-Cell 11c and include:

“Resident feels that the food security policy has changed over the last 12 months with Hilary Benn advocating growing food at home. He thinks this should be taken into account in the SMP and give farmland more weight.”

“I am sure you are more than aware that over the course of the next 40 yrs the world's population is set to increase by some 50% to 9 billion people, most of who will live in Asia and are already net importers of food. 60% of these people will also live in cities and the last time I checked they don't produce much in the way of food there. Additionally we are currently loosing approx 3% of the world's farmland each yr to construction, deforestation and desertification and as they say they don't make it anymore, land that is. Combine all these factors and the world is going to starve within the next generation, certainly before it drowns. The thought of losing 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.”

“After the impact of the foot and mouth outbreak of 2001 surely the UK should be looking at being as near self sufficient in food production as it is possible. At least if we grow our own food in the UK we are in charge of the bio security of it. How long before the bio security of food becomes an issue for extremists and terrorists to exploit? With the population projected to grow to 70 million in the next twenty years surely we should be looking to reclaim land rather than letting it go to wetland. After World War 2 farmers were encouraged to produce food to feed the country and overcome the food rationing at that time. Grants were available for drainage projects and for farmers to improve their businesses now it appears that we should allow good fertile land revert to wetland and import food from places around the globe at what cost to the UK economy not to mention the Carbon footprint.”

“At a time when increasing world population is causing a massive increase in demand for food it is stupid to lose agricultural land; its retention is a much higher need than some amphibians or moths. Hundreds of years of effort have gone into the reclamation of farmland around our estuaries and thousands of pounds of both taxpayers and land owners money; to reverse this achievement now is crass stupidity;”

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

“It is also appropriate for us to highlight that a sustainable productive agricultural industry is a critical. Disappointingly this has often been undervalued here in the UK. However things are changing and it has been quite noticeable how quickly the issue of food security, even its availability has 'climbed' the political ladder in the last 12 months….The true value of agricultural land is its market price and this is not recognised or taken into full account in scheme appraisals. This view is once again, portrayed in the Shoreline Management Plan 2 - which disappointingly fails to acknowledge agriculture as a key policy driver in setting out future options for the relevant policy units” NFU Cymru

“Too often public organisations overlook the fact that agricultural land is a business asset which must be treated, now more than ever, as a precious commodity. With the publication of ‘Food 2030’ in January 2010, Defra have for the first time in almost 60 years formally recognised the value of the agricultural and horticultural industry’s primary products. Food security, it seems, has finally taken a step up within Defra’s estimation. The document sets out the steps the government feel will need to be taken to produce more food without unnecessary damage to natural resources, against the back drop of climate change whilst improving food safety. Given this back drop, the SMP must now recognise the role the North West has to play in the increased demand there will be for locally sourced food and energy.” NFU

SMP2 Team Comments

Government guidance on flood and erosion risk management decision making has placed an increased importance on consideration of farmland in recent years. The way that the national economic value of farm land is calculated has been changed to reflect the changes in agricultural subsidies.

Previously, the national economic value of farmland was considered by government to be 45% of the market value due to the subsidies artificially raising prices. This has now changed and the actual market value less £600/ha is used. Market values have also substantially increased in recent years. These increased values have been used in the SMP2 economic assessment. Land values used change for different agricultural land grades, but in the SMP2 area they are typically of the order of £13,000/ha.

The Defra “Food 2030” strategy was launched in January 2010. The SMP2 project started in October 2008 and as such, the “Food 2030” information was not used in the SMP2 development.

However, there is a proposed action in “Food 2030” to improve ways to value ecosystems through “ Applied research looking at how food production and consumption in the UK links to the value of ecosystem services principles for decision-making which help in considering whether to convert land or intensify food production in the UK based on a proper assessment of costs / benefits based on ecosystems services ”. In the final SMP2 Action Plan, we will recommend a further task to consider the implications of changing land use as a result of SMP2 policies.

3.4 Managed Realignment

Draft policies proposing managed realignment have resulted in mixed reactions. A number of responses have expressed support for managed realignment policies and have seen it as an opportunity to return to a more natural coast. This could help to address future climate change issues and loss of natural coastal habitat elsewhere. However, concern has also been raised about uncertainty process of managed realignment – how it would be implemented and where the new defence line may be. There are also concerns about the economic viability of managed realignment schemes, including the cost of removing existing defences and constructing

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

new defences further inland. Responses have questioned whether the schemes are simply being driven by the need to acquire more inter-tidal habitats rather than for the benefits to the local area. Both the RSPB and the NFU would prefer to see proactive managed realignment rather than a no active intervention policy.

Responses relate to locations across the whole SMP area and include:

“Coastal management polices such as No Active Intervention and Managed Realignment offer significant opportunities to allow natural processes to prevail and to address climate change impacts. RSPB is also supportive of using natural habitats such as dunes and saltmarsh, as natural flood defences. Opportunities for creation or better management of these habitats should be sought..” RSPB

“Where opportunities have been identified for managed realignment/ retreat these should be investigated further. It may be possible to feed actions into local wetland creation schemes which are currently being carried out in the Morecambe Bay area. It is accepted that managed realignment may only be possible in the longer term due to stakeholder pressures. However, it is important that potential sites are considered and publicised to stakeholders to make sure these options are possible and have support.” EA NW

“The NFU also accepts that managed realignment will play a part in achieving sustainable flood defence. Where realignment does take place, it needs to be planned and managed; not left to be determined by chance wherever the defences happen to fail.” NFU

“We would like to better understand the concept of 'managed realignment' and how this would be likely to be implemented in our area if the draft policy was approved. If more than one option is possible, we would like to know what these options are likely to be. Specifically, would this involve the actual removal of current defence walls?”

“No evidence to date has been presented regarding the necessity for more salt marsh on ecological grounds as marshland already exists, or has been created, in nearby areas such as Cockerham Marsh and Hesketh”

SMP2 Team Comments

Managed realignment is effectively moving the line of defence landward (or seaward) to control or limit coastal flood or erosion risk (such as building new defences further inland from the existing defences). Any increase of flood risk as a result of such movement will also be managed. This policy mainly applies to low-lying areas of land at risk of flooding, but can apply to cliffed areas, where taking managed action can slow or limit cliff erosion.

Managed realignment provides the opportunity to create a more natural coastline in a controlled way. It also helps to allow sediment movement and maintain beaches by providing space for natural landward roll-back of saltmarsh, beaches or dunes. It may also provide opportunities to create habitats for wildlife.

Theoretically, defences could be moved inland up to where the area at risk of coastal flooding ends (where the land begins to get higher). However, in reality defences are often not realigned that far (for example where there are settlements or infrastructure within the floodplain that need protecting). The SMP2 has identified where there are opportunities for managed realignment but does not state where the new line of defence would be. The SMP2 recommends that detailed studies are carried out before any realignment is implemented.

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These studies would need to consider the potential local and regional impacts of realigning defences, the risks and opportunities associated with any realignment and how the land is currently used. There will be a timetable detailing when further studies, including future managed realignment opportunities, will take place in the SMP2 Action Plan.

Following concerns raised by respondents including the Environment Agency, RSPB and NFU a number of policy units where a no active intervention policy was suggested in the consultation document have been changed to Managed Realignment to allow opportunities for habitat creation and active management of flood and coastal erosion risks where practicable.

3.5 Private defences

A number of responses were received about the decision to have a headline policy of No Active Intervention in cases where the defence can be maintained in the future with private funding. There are a number of areas where there are currently defences which were privately funded or funded by a combination of public and private sources. In these cases, further explanation was required to address landowner concerns.

Examples of responses received from locations across the whole SMP2 area include:

“the policy description needs to be clear i.e. that there is no economic case based upon a national economic assessment, but that there is landowner support for HTL.”

“Myself and our neighbours are quite happy to contribute to a private fund to ensure that the sea defences are maintained over the 100 year period.”

“As property owners, we have every right to protect our property and No Active Intervention directly contravenes that basic right.”

“The majority of this Policy Unit is in the ownership of private frontagers who have invested in the provision of the existing coastal defence. The headline policy of No Active Intervention in the long term conflicts with the detail of the policy which indicates that a Hold The Line policy subject to private investment would be allowed. The headline policy should reflect the policy for the majority of the frontage.”

SMP2 Team Comments

The SMP2 is a non-statutory document and provides information to help Local Authorities and others make planning decisions. While Local Authorities and the Environment Agency will use the SMP2 policies, these policies do not override statutory rights of landowners, or the Local Authorities or Environment Agency duties 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) and the Flood and Water Management Act (2010).

In North West England and North Wales, there are lengths of coastal defences that are privately owned and maintained. The SMP2 will help us to understand how and whether individual private defences affect the levels of risk elsewhere. In the future, private land and property owners will need to consider how they will deal with coastal change that affects their property. Since flood and coastal defence powers for Local Authorities

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and the Environment Agency is permissive, meaning that they do not have a duty to undertake works, but can do so if justified and affordable, the public do not have a general right to protection against coastal flooding or erosion.

It would be difficult to get National funding to defend a number of locations along the SMP2 coast as the cost of building and maintaining defences outweighs the value of the assets and land it would be defending.

Individuals and some private organisations have rights or powers to protect their own property, although permission is needed from Local Authorities and / or the Environment Agency before work other than routine maintenance can be carried out.

In situations, where small areas of private defence were not considered to have impact on erosion or flood risk elsewhere, the draft SMP2 policy was set as no active intervention. This decision was taken as such work would not receive national funding and therefore a hold the line policy could not be guaranteed. However, there was a caveat in the no active intervention policy stating that local/privately funded maintenance of existing defences would be allowed subject to consent.

Following consultation, the SMP2 team have decided that where private funding of defences is expected to continue, and private defences make up a majority of the Policy Unit, it is more appropriate to change the policy from a no active intervention policy to hold the line (subject to a private funding agreement).

There will not be details about how landowners can build or maintain their own coast defence in the SMP2. However, Defra’s position on maintaining uneconomic sea defences can be viewed at: http://www.defra.gov.uk/environment/flooding/documents/policy/guidance/seadefence.pdf

3.6 Compensation

Homeowners who live in areas where they consider the proposed SMP2 policy could reduce the value of properties or leave them vulnerable to flooding or erosion have voiced significant concerns. There are suggestions that policies may be in breach of Human Rights, and there have been questions regarding the rights to compensation and how this would be calculated.

Responses predominately relate to Sub-Cell 11c and include:

“In my opinion, although I stand to be corrected, I believe there could be issue under the Human Rights Act 1988….Article 8: the right to respect for private and family life.”

“If these public authorities do decide to approve the draft policy it may very well be that they will be in breach of the property owners human rights under Article 1 of the First Protocol of the Convention for the Protection of Human Rights and Fundamental Freedoms”

“No offers of compensation for loss of homes, farmland and businesses and destruction of same would affect the human rights of all landowners involved.”

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“If a change to a policy were to go ahead, then all of those affected by a loss of asset value (e.g., value of home, farm etc) will require immediate financial compensation. Twenty years ahead, if MR were to take place, then those directly affected by MR operations would require further compensation payments.”

“Your proposal did not include any compensation or financial support for the properties put at risk.”

“If you cannot do this (change the policy) then the very least is financial support in the form of market value of the properties and compensation for having to move. I recognise the current policy regarding permissive loss. However we moved here on the understanding of coastline protection as has been here for the last several 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 the meantime what do I do about my property? Please buy it off me, and compensate me for having to move.”

“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.”

“If the coastline was left to degrade, then this would have a detrimental effect on the value and selling potential of our property. No potential buyer would ever contemplate on purchasing a property that would ultimately fall into the sea.”

SMP2 Team Comments

The Environment Agency and Local Authorities can undertake flood risk management activities but do not have a legal duty to do so. In the UK there is not an automatic right to state funded flood protection and there is no right to compensation if there is a decision taken to stop maintaining defences.

The SMP2 is a non-statutory document and provides information to help Local Authorities and the Environment Agency make planning decisions on coastal defences. It does not provide solutions to issues such as compensation. The national cost of providing compensation to those who lose land or property to coastal flooding or erosion, whether as a result of SMP2 policies or not, could be high and government policy changes to allow for any payments of this kind would have to be properly evaluated against other demands on the public purse.

Money for building and maintaining public coastal flood and erosion defences comes mainly from central government. If compensation for owners of land and property lost to coastal flooding and erosion were introduced, decisions would have to be made regarding whether it should be provided at the expense of building defences elsewhere (if taken from the existing flood/erosion budget), or if it should be funded from a different area of the national budget (e.g. education, health, police, etc).

The Department for Environment, Food and Rural Affairs (Defra) and the Welsh Assembly Government (WAG) however, recognise that compensation could significantly help landowners. They are currently investigating the best ways to help people adapt to the changing coast. Defra recently held a public consultation on coastal adaptation and has announced funding for a number of pathfinder projects, which will

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report help to investigate and trial measures that can be taken by communities in areas where defences won’t be built.

Both Defra and WAG are developing and encouraging alternative approaches to managing coastal risks. In England up to £28 million of Defra's Comprehensive Spending Review settlement for 2008 – 2011 was made available to support adaptation measures. This was intended to focus on ways that we can reduce damage caused by floods and coastal erosion, through careful land use planning and building design, better information and community engagement to encourage sensible risk management by individuals or organisations, and measures to help communities adapt to increasing risk. Further information is available from: http://www.defra.gov.uk/environment/flooding/manage/index.htm

Current legislation does allow financial compensation for land purchase if this is required for the construction of coastal defences. In some cases this can extend to schemes involving the managed realignment of coastal flood defences. A guidance note on Defra’s position on land purchase, compensation and payment for alternative beneficial land use with managed realignment can be viewed at: http://www.defra.gov.uk/environment/flooding/policy/guidance/realign.htm

Where the SMP policy may result in increased risk to property and assets, whether due to coastal erosion or flooding, the effect on property owners should be managed through adaptation measures or relocation. Business and commercial enterprises will also need to establish the actions that they need to take to address coastal change in the future. This includes providers of services and utilities, which will need to plan for long- term change when upgrading or replacing existing facilities in the shorter term. They should also consider how they will relocate facilities that will be lost to erosion or flooding, and the potential need to provide for relocated communities. Other parties needing to consider mitigation measures will be the local highways authorities and bodies responsible for local amenities (including churches, golf clubs etc). The Coastal Group aims to work with these interest groups in the future, to ensure they are given appropriate advice and guidance.

3.7 Consultation methods

Some responses were received about how we have consulted with the public on the SMP2. Issues include the length of the consultation period, the availability to attend meetings at short notice and the locations of other meetings. In addition, some residents were not aware of the Plan’s existence in general and would have appreciated being kept informed and updated from an earlier stage.

Responses on consultation predominately relate to Sub-Cells 11c, d and e and include:

“We were also appalled to be told that you fully realised that the meeting had been called at short notice, but then to be further told that the deadline date for responses was Sunday 14 February (leaving just one working day after the meeting) was both ludicrous and thoughtless. We sincerely hope that your assurances that responses received after this date will still be considered, will hold true.”

“We will start by reiterating our disgust (expressed at the meeting) at the lack of publicity for this meeting – an all- important one for many of us.”

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

“We understand from speaking with some of our neighbours that you held a public consultation meeting last Thursday night 11 February 2010. We would like it to go on record that this meeting was not publicised in the local media, nor was it directly publicised to any of the local residents.”

“I was surprised to learn that you have developed such a plan and that I have not been informed or involved in such discussions.”

“Your consultation has been in name only, and has made no genuine attempt to involve the local communities”.

“I am rather concerned at the way the above "consultation" is being conducted. I can see that it will be OK from the point of view of experts and organisations, but for members of the public - whose views you say you want - it leaves a great deal to be desired.”

“In the spring and summer months, the area is visited by large numbers of people from outside the area, to say nothing about the many more who have holiday accommodation locally. Because of the timing of the consultation period, these people will not be offered the opportunity to take part in the consultation process.”

SMP2 Team Comments

The SMP2 team included key stakeholders, Elected Members and Parish Councillors whilst developing the draft SMP2. Due to the technical nature of choosing proposed policies, we decided to involve members of the public once the plan had been reasonably developed. We then went through the public consultation stage to let local people have their say on the proposed policies.

At the start of public consultation each Local Authority contacted the Parish Councils and local councillors in their area to inform them of public consultation and the public consultation events. It is understood that in some areas, this information did not reach all of the councillors or was not passed on to residents.

To advertise the consultation and make people aware of meetings, posters were put in Local Authority buildings and libraries, and advertised on Local Authority Websites and the Coastal Group website. Press releases were issued about the consultation and local events (from which much coverage was received).

In some contentious areas further meetings were held to try and address the concerns of residents.

Members of the public did not need to attend a public meeting to be able to comment on the document, as questions about or responses to the draft SMP2 could be emailed or sent to the SMP2 team.

Although the consultation was not during the summer season, we did receive a number of responses from outside the North West England and North Wales coastal area. Hosting the consultation on the Coastal Group's website helped to make the document available to people who were not local.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

4 Consultation Strategy and Responses received: Sub-Cell 11a – Great Orme’s Head to Southport

Figure 3: Map showing the location of Sub-Cell 11a, Great Orme’s Head (North Wales) to Southport.

4.1 Consultation Strategy Sub-Cell 11a In Sub-Cell 11a (between Great Orme’s Head in North Wales and Southport), we used the following ways to raise awareness of the SMP2 consultation.

Examples of consultation materials including stakeholder letters, press releases, press articles, cabinet reports, Coastal Forum Reports and meeting notes are included in Annex B5 .

Coastal Group website

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

A list of local consultation events and the full draft SMP2 consultation document, including appendices and maps were included on and downloadable from the North West England and North Wales Coastal Group website ( http://www.mycoastline.org ). A consultation response form was also available to download or complete on online.

Press Notices / Press Briefings

A press release was issued by Denbighshire County Council (DCC) in November 2009 on behalf of Denbighshire County Council, Conwy County Borough Council and Flintshire County Council. A feature on the public consultation was also included on the Denbighshire County Council website.

Wirral Metropolitan Borough Council issued press releases on 7th December 2010, about the public consultation, and providing information about the public meeting on 10th December 2010. Articles were included in the Wirral Globe on 7th December 2009 and the Wirral News on 9th December 2009.

A press release was issued by Sefton Council on the 4th December 2009 to advertise the SMP2 consultation. In addition a video was available to view online on the council’s website: www.sefton.gov.uk/

Stakeholder Letters

Wirral Council sent letters to coastal golf clubs including Heswall, Caldy, Leasowe, Royal Liverpool and Wallasey Golf Clubs). Letters were also sent to residents at Heswall, informing them of the SMP2.

A letter to residents informing them of the SMP2 and draft policies went out with the SMP2 leaflet to public buildings and libraries along the Sefton frontage.

Cabinet Reports

A Wirral Council report was presented to the ‘Streetscene and Transport Services’ Cabinet in September 2009 regarding the SMP2 public consultation.

A Sefton Council Executive Report about the SMP2 consultation was presented to the Southport Area Committee on the 28th October 2009, the Formby Area Committee on the 29th October 2009, and the Crosby Area Committee on the 4th November 2009. The SMP2 was also taken to the following area committees:

• Formby Parish Council on the 6th October 2009

• Hightown Parish Council on the 16th November 2009

Coastal Forum Reports

A Coastal Forum report was produced and meetings with the Wirral Coastal Area Forums were held throughout October 2009, informing them of the background to the SMP2 and the consultation process.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Informal discussions regarding the SMP2 consultation were also undertaken with professional partners through the Sefton Coast Partnership.

Draft SMP2 Documents

The draft SMP2 documents and leaflets were made available for the public to view at the following locations.

• Conwy: all Council Offices and Public Libraries;

• Denbighshire: Council offices in Rhyl, Prestatyn, Denbigh and Ruthin; Public Libraries in Rhyl, Prestatyn and Rhuddlan; Town Council offices in Rhyl, Prestatyn and Rhuddlan;

• Flintshire: Mold County Hall, Flint Council Offices, and Public Libraries at Mold, Holywell, Bagillt, Flint, Connah’s Quay, Queensferry, Mancot, Broughton, Saltney, Buckley as well as Mobile Libraries;

• Wirral: Public Libraries, Eastham, Irby, Heswall, Hoylake, Leasowe, Moreton, Seacombe, Wallasey, Wallasey Village and West Kirby; at Birkenhead, Bromborough, Wallasey Town Hall and Cheshire Lines Building;

• Sefton: Public Libraries.

Copies were also provided for all County Councillors, local MPs and Assembly Members, and Councillors at Rhyl and Prestatyn Town Councils.

4.2 Public Events and Stakeholder Meetings

Two public meetings / workshops were held in December 2009 to publicise the SMP2 consultation and allow stakeholders and members of the public to come and ask questions/find out more information about the SMP2 and the draft policies. Public events were held at the following locations:

• North Wales, 7th December 2009 at Kinmel Manor, Abergele

• Wirral, 10th December 2009 at Kings Gap Court Hotel, Hoylake

In addition, a separate meeting was set up to discuss the draft policies relating to Caldy Golf Club and the West Kirby frontage. The meeting was held at Caldy Golf Club on 14th January 2010.

The notes from the three meetings are included in Annex B5.

4.3 Consultation Responses

Responses were received from over 60 residents, businesses, Parish Councils and other organisations. Responses were received in a variety of forms:

• letters;

• consultation response forms (hand written and electronic); and

• e-mails. 19

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

A summary of issues raised during public consultation relating to specific policy areas are included in the following sections. Annex B10 includes all SMP2 public consultation responses. A comment and/or action taken by the SMP2 team is also included for each response.

4.4 Area Specific Responses

4.4.1 Great Orme to Little Orme - 11a1

There was overall support from consultees for the draft policies along this coastline. The aim is to allow the currently undefended cliffs of Great Orme and Little Orme to continue changing naturally with no active intervention, whilst reducing risk to Llandudno by maintaining the present defences with a hold the line policy. The main responses and queries received are summarised below:

• Consultees agreed with and supported the preferred policies.

• However, there were concerns raised by the Environment Agency (EA) Wales that the short term policies were not ambitious enough in terms of managed realignment. They felt that managed realignment is often a sustainable short term option and as such should be considered for locations on the whole of the north Wales coast.

SMP2 Team Comments

It has been identified that there are no opportunities for managed realignment in this area, due to limited realignment space available, location of infrastructure (such as roads and railway), properties along the coast and the large area of Llandudno which is at flood risk.

No changes to the draft policies have been made following public consultation.

4.4.2 Little Orme to Clwyd Estuary - 11a2

There was mixed support from consultees for the draft policies along this coastline. The long term plan is to continue managing flood and erosion risks to this currently developed shoreline which includes the main road and rail links to the region with a hold the line policy. The main responses and queries received are summarised below:

• Concerns were raised by EA Wales and the RSPB that the short term policies were not ambitious enough in terms of managed realignment. They felt that managed realignment is often a sustainable short term option and as such should be considered for the locations on whole of the north Wales coast.

• There was concern over how the existing defences limit movement of shingle around the coast and the effect this would have on designated sites and breeding bird colonies.

SMP2 Team Comments

Managed realignment was considered at a number of locations along this area of coast. However, this was rejected due to the need to construct longer lengths of defence, limited realignment space available due to the road, railway, levels of the land and the limited potential to create habitats in the longer term as sea levels rise. Following the public consultation the SMP2 team have reviewed some initial work by EA Wales to identify possible sites for managed realignment along the North Wales coast. The results of this review show that no

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report locations have been identified for managed realignment in the long term along this area of coast. The team do however recognise that short term managed realignment or habitat creation opportunities could be considered and could contribute towards Biodiversity Action Plan (BAP) targets. This could happen in conjunction with a hold the line policy along parts of the coast and this is now reflected in the SMP2 Action Plan.

The SMP2 team recognise that some of the defences along the North Wales coast can block sediment movement along the coast, which in turn could potentially have adverse effects on designated sites and wildlife. Therefore in the SMP2 Action Plan we have recommended that there should be a sediment movement and beach management study along the North Wales coast to develop a strategic approach. We also recommend looking into managing and modifying coastal structures to help prevent loss of beaches and intertidal areas.

No changes to the draft policies have been made following public consultation.

4.4.3 Clwyd Estuary - 11a3

Public feedback was supportive for the draft policies within the Clywd Estuary. The draft plan is to continue managing risk to the settlements along the coast, which include Kinmel Bay, Towyn, Rhyl and Prestatyn, whilst investigating opportunities for managed realignment elsewhere within the estuary. The main responses and queries received are summarised below:

• Managed realignment policies were welcomed, however concerns were raised by EA Wales that the short term policies were not ambitious enough in terms of managed realignment. They felt that managed realignment is often a sustainable short term option and as such should be considered for locations on the whole of the north Wales coast.

• It was considered that action should be taken to stop building on the flood plain to reduce risk to properties. However, another consultee raised concern regarding the opportunities for managed realignment, and its impact on the Local Development Plans and Unitary Development Plans.

SMP2 Team Comments

Following the public consultation the SMP2 team have reviewed some initial work by EA Wales to identify possible sites for managed realignment along the North Wales coast. The results of this review show that there are some locations within the Clwyd Estuary that may be suitable for managed realignment. However, the SMP2 team decided that it was not appropriate to propose managed realignment until a suitable plan for delivering this realignment has been developed and all the potential options have been sent to stakeholders for their views. This delivery plan is currently in development in the form of the Environment Agency’s Tidal Clwyd Flood Risk Management Strategy and the next stage of consultation will start later this year. This is to allow public consultation on any proposed realignment. The team recognise that after this, there may be opportunities for managed realignment sooner and the policy description will reflect this.

The SMP2 team have worked closely with Local Authority planning departments to identify large-scale developments in the area, which either have planning permission or have submitted a planning application. A development in Rhyl was identified - opportunities for managed realignment identified in the SMP2 will not impact on this development.

No changes to the draft policies have been made following public consultation.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

4.4.4 Clwyd Estuary to Point of Ayr - 11a4

There was general support for the draft policies in this area, which includes Rhyl and Prestatyn. The plan is to continue managing flood and erosion risk to the developed areas of the coastline through hold the line policies. The proposed policy for the dune system at the Point of Ayr is for managed realignment, allowing the dunes to behave naturally. This policy will allow limited maintenance of the dune system to help it continue to act as a natural defence. The main responses and queries received are summarised below:

• It was felt that natural dune change should be allowed to continue, including the natural roll-back of dunes. This was particularly noted at the western end of the dune system where there are rock/stone defences. It was suggested that further development should be prevented in this area to allow this roll-back.

• There was concern about the proposal to use dredged sand from the Dee estuary for beach replenishment as the aim was to keep this sand within the estuary. However, sand may be available from dredging the channels in the Port of Mostyn.

• It was noted that the future of Prestatyn Town is reliant on the future of tidal defences in the town.

SMP2 Team Comments

Managed realignment was considered at a number of locations along this area of coast. However, this was rejected due to the need to construct longer lengths of defence, limited realignment space available due to the road, railway, levels of the land and the limited potential to create habitats in the longer term as sea levels rise. Managed realignment is however, recommended as the draft policy at the Point of Ayr. This would occur through managing dunes and beaches. It is believed that the dunes will naturally roll-back and action will need to be taken to allow space for this natural roll-back, together with maintenance of the dune system to help it continue to act as a natural defence.

Following the public consultation the SMP2 team have reviewed potentially feasible sites for creating habitat through a managed realignment policy along the North Wales coast as identified by EA Wales. The results of this review show that there are no locations along this section (apart from the Point of Ayr) that are suitable for managed realignment.

No changes to the draft policies have been made following public consultation.

4.4.5 Dee Estuary - 11a 5

There were mixed views regarding the draft policies within the Dee Estuary. The majority of responses were about the eastern side of the Dee Estuary. The main aims of the SMP2 are to continue to protect assets where appropriate, whilst allowing the estuary to change naturally where possible. The main responses and queries received are summarised below:

• A potential managed realignment scheme has been put forward between Mostyn to Flint Marsh.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

• Concerns were raised by EA Wales that the short term policies were not ambitious enough in terms of managed realignment. They felt that managed realignment is often a sustainable short term option and as such should be considered for locations on the whole of the north Wales coast.

• Concern was raised about former waste disposal sites close to the estuary which may cause pollution or may need expensive work to improve the area under a no active intervention policy. Respondents were concerned that the draft SMP2 failed to identify that some sites are already threatened by flooding or erosion now and not just at risk from future sea level rise.

• There was concern that a no active intervention policy in the medium and long term at Caldy Golf club would result in the club incurring substantial losses on past investment and reduced future income and could have effects on the environment. Concern was also raised that this could have knock on effects for Dee Sailing Club as pollutants could be released from landfill and such a policy could have implications on maintaining slipways etc.

• Concern was raised regarding the rights of residents and landowners to protect their property and the potential property blight effects of the draft long term policies of no active intervention (PU11a 5.7 Thurstaton Slipway to Croft Drive, Caldy & 5.8 Croft Drive Caldy to West Kirby Marine Lake). Respondents felt strongly that the plan should reflect their wish to continue defending their property with private funding. It was felt that there was reasonable expectation that existing private maintenance of defences would continue to protect property and businesses, and that no active intervention was therefore not a suitable long term policy

• There was concern about the proposed hold the line policy at Hilbre Island, where there are no man made defences and some parts of the shoreline are eroding.

SMP2 Team Comments

The long term vision for the Dee is to continue to protect assets where necessary but where possible to allow space for natural, long term change in the estuary. The draft SMP2 identified a number of areas with potential opportunities for managed realignment within the estuary which broadly match the areas identified by EA Wales. However, the team decided that it was not appropriate to propose managed realignment as the headline policy in the short term until a suitable plan for delivering this realignment has been developed and all the potential options have been sent to stakeholders for their views. Work on establishing this delivery plan is currently underway in the form of the Environment Agency’s Tidal Dee Flood Risk Management Strategy and the next stage of consultation will be started later this year. The team supports this work and recognises that there may be opportunities for managed realignment sooner and therefore the policy description will reflect this.

The existence of landfill sites and their potential risks to the estuary was recognised by the draft SMP2 and an estuary wide study has been recommended in the Action Plan. This will investigate ongoing and future risks to management of the estuary. Responses received on specific areas where contamination is a real risk now, will be directly passed on to the EA Wales Tidal Dee Flood Risk Management Strategy team for consideration.

Following review of consultation responses and further information submitted during the public consultation, the medium and long term no active intervention policy at Caldy Golf Club has been revised. Evidence put forward by Caldy Golf Club indicates that they will continue to fund maintenance of the defences in front of the golf club. Consequently the hold the line policy will be extended to the short, medium and long term subject to a private funding agreement being in place.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Similarly, the draft policies for the area between Croft Drive, Caldy and West Kirby Marine Lake have been revised after the consultation responses were reviewed. Responses indicated that about 40% of the defences are privately owned and evidence has been submitted to confirm that property owners will continue to contribute to the cost of these defences being maintained. As such, the hold the line policy in the short and medium term has been extended to the long term, subject to a private funding agreement being in place.

The draft hold the line policy at Hilbre Island is recommended due to the flood protection that the island provides to the mainland, the way that it controls the way that the estuary works and its amenity value. The Local Authority advised that a no active intervention policy would not be appropriate due to health and safety issues on the island.

The following revisions to the draft policies have been made as a result of the consultation:

11a 5.7 - Thurstaton Slipway to Croft Drive, Caldy - changed to Hold The Line (0-20 years), Hold The Line (20 to 50 years), Hold The Line (50 to 100 years) subject to a private funding contributions agreement.

11a 5.8 - Croft Drive Caldy to West Kirby Marine Lake – changed to Hold The Line (0-20 years), Hold The Line (20 to 50 years), Hold The Line (50 to 100 years) subject to a private funding contributions agreement in the long term.

4.4.6 North Wirral - 11a6

There was general support for the draft policies along the North Wirral coast. The main aim in this area is to continue managing flood and erosion risk to property and infrastructure (such as roads and amenities), whilst acknowledging the need to look at more sustainable ways to provide this protection in the future. The main responses and queries are summarised below:

• A number of responses related to the need to ensure that the North Wirral coast is continually monitored.

• Concern was raised about of the cost of realigning defences compared to maintaining defences in their current position and the associated cost of removing contaminated material to allow for any potential realignment.

• Wirral Council have suggested renaming some of the policy unit areas along the frontage for clarity.

SMP2 Team Comments

The Cell 11 Regional Monitoring Strategy (CERMS) is an ongoing project throughout North West England and North Wales and carries out a variety of monitoring activities. There are number of actions in the Action Plan which will help to inform a coastal defence strategy for Wirral.

There may be opportunities to create a more natural dune system in some areas along this coast in the long term. There may also be difficulty getting funding to rebuild defences in their current position when they fail. Therefore we have recommended investigating options for managing defences and looking at any potential contamination, the results of which will inform the long term policy. These investigations would be part of a strategy study following on from the SMP2 which will confirm how this area of coast will be managed in the

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report future by looking at coastal risks; financial implications of actions and social and environmental benefits of options. The results of this will help to guide the long term approach in this area.

No changes to the draft policies have been made following public consultation, however, the names of some policy units have been revised based on Wirral Council’s recommendations.

4.4.7 Mersey Estuary - 11a7

Consultees generally supported the draft policies in the Mersey Estuary where the long term plan is to manage flood and erosion risk to property and infrastructure in the narrows and the southern shore, and allow parts of the upper estuary to change more naturally. Managed realignment at strategic locations will potentially reduce flood risk upstream and create habitat for wildlife. The main responses received are summarised below:

• It was queried whether managed realignment is the best policy in the Upper Estuary. The EA have questioned whether the cost of realigning defences can be justified (even given the potential environmental benefits of realignment).

• The Runcorn Bridge to Pickerings Pasture policy unit boundary has been questioned, due to the need for the Terrace Road area of Widnes to have a hold the line policy.

• Concern was raised about the no active intervention policy to the south and east of Garston due to of the potential effects that this would have on Liverpool City and its infrastructure, including potential future expansion and development plans.

• There are some areas where there are landfill sites, but it is not clear who is responsible for managing these sites or what the plan suggests as the most sustainable way forward in such cases.

SMP2 Team Comments

It is important for the SMP2 to identify potential sites to create new habitat to help offset for the potential loss of internationally designated habitat elsewhere, due to the impacts of hold the line policies and predicted sea level rise. It is likely that identified sites would secure funding however this would need to be linked into the EA’s regional Habitat Creation Programme.

The Runcorn Bridge to Pickerings Pasture policy unit ends at Runcorn Bridge because this is a natural hard point in the estuary. However, the team would agree that locally the hold the line policy should include the Terrace Road area and any potential managed realignment would therefore be east of this location.

The no active intervention policy south and east of Garston is with the same as current shoreline management practice along this frontage. The eroding cliffs near the airport are within the Site of Special Scientific Interest, and the no active intervention policy allows for a naturally functioning coast. Defra guidance states that the SMP2 has to consider existing assets (which can include sites with approved planning permission) when deciding on policies, but should not suggest policies in anticipation of future development. Any future expansion and development of Liverpool Airport which would need flood or erosion protection must have full environmental assessments and any new defences would need to be part-funded by the developer. Speke Hall is a National Trust property and as indicated in their response, the National Trust has been involved in the consultation process and supports the draft policies for this location.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

The SMP2 acknowledges that there are a number of landfill sites within the Mersey estuary and that there needs to be further detailed studies to look at long term options for these.

No changes to the draft policies have been made following public consultation, however, the boundary of PU 11a 7.7 has been revised to include Terrace Road.

4.4.8 Seaforth to River Alt - 11a8

There was general support for the draft policies for this area. The plan suggests managing erosion risk to property and infrastructure where appropriate whilst allowing natural processes to continue as far as possible. The main responses received are summarised below:

• The description “allow natural process to continue” sounds like no active intervention, yet the headline policy is managed realignment.

• It was queried whether a hold the line in policy unit 8.3 Hightown to mouth of the River Alt (east bank) is affordable in the long term.

SMP2 Team Comments

In order to encourage the dunes to be stable and to grow in this area, it is necessary to manage the structures in the River Alt that keep channels away from the dunes. The managed realignment policy will therefore allow natural processes to continue on land but will allow these structures to be maintained.

Although the draft policy between Hightown to mouth of the River Alt (east bank) is hold the line, this is likely to mainly involve managing the dunes which act as a natural defence and therefore the associated costs of holding the line are limited. This approach is consistent with many other areas in a similar situation.

No changes to the draft policies have been made following public consultation

4.4.9 Formby Dunes - 11a9

Public feedback was supportive for the draft policies along this shoreline. A managed realignment policy for the Formby dune system will encourage natural change but allow action to be taken to protect the dunes where/if necessary. The main responses received are summarised below:

• Sefton Council carry out coastal monitoring in this area and both Sefton Council and the National Trust in Formby actively manage the dunes. Concerns have been raised about the description of managed realignment which reads 'minimal intervention'. It is thought that this should be substituted with the word 'active' in the light of the research and work being routinely undertaken.

• While there are some negative implications predicted with a managed realignment policy, on balance the implications are mainly positive. The draft policies and draft Action Plan are supported by Sefton Council.

• The National Trust noted that they are working with partners to produce a coastal adaptation strategy which will set out how coastal change is dealt with and how all parties can maintain the benefits gained from this stretch of coast.

SMP2 Team Comments

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

The SMP team recognise that a number of parties are working actively with Sefton Council to manage the Formby Dune System. However, to be consistent with other policy areas we need to use the words “limited” or “minimal” to describe how action will be carried out under a managed realignment policy. However “limited intervention” is more appropriate in this case and therefore the policy description will be changed.

The SMP2 team welcome the support for the draft policy. Development of future land use plans is fully supported by the SMP2 Action Plan.

No changes to the draft policies have been made following public consultation.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

5 Consultation Strategy and Responses received: Sub-Cell 11b – Southport to Rossall Point, Fleetwood

Figure 4: Map showing the location of Sub-Cell 11b, Southport to Rossall Point, Fleetwood.

5.1 Consultation Strategy Sub-Cell 11b

In Sub-Cell 11b (between Southport and Rossall Point, Fleetwood), we used the following ways to raise awareness of the SMP2 consultation.

Examples of consultation materials including press releases, cabinet reports and meeting notes are included in Annex B6 .

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Website

Press Notices / Press Briefings

A press release was issued by Blackpool, Fylde and Wyre Councils on 11th December 2009.

Press coverage

An article on the SMP2 consultation was published in the Lancashire Evening Post on 18th December 2009.

Cabinet Reports

A Cabinet Report informing councillors about the start of the SMP2 consultation process was presented at a Wyre Borough Council Cabinet Meeting that was held on 7th Sept 2009.

Blackpool Council informed the relevant Portfolio holder of the start of the consultation process through the regular ‘Members Information Bulletin’.

Coastal Forums

Meetings were held with Cleveleys, Poulton and Fleetwood Forums and Wyre Flood Forum.

Draft SMP2 Documents

Copies of the draft SMP2 documents were displayed in all public libraries in Wyre Borough Council between December 2009 and February 2010. They were also displayed in all council buildings which included the Civic Centre, Cleveleys Site Offices and Marine Hall from December 2010. The full Consultation documents were also available on the Wyre Borough Council website.

The full consultation documents were also available at Blackpool Town Hall and Westgate House between December 2009 and February 2010.

5.2 Public Events and Stakeholder Meetings

Three public meetings / workshops were held between November 2009 and February 2010 to publicise the SMP consultation and allow stakeholders and members of the public to come and ask questions/find out more information about the SMP and the draft policies. Public events were held at the following locations:

• West Lancashire, 23rd November 2009 at West Lancashire Investment Centre (meeting notes are included in Annex B6)

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

• Blackpool, 15 th December 2009 at the Savoy Hotel, Blackpool (meeting notes are included in Annex B6)

• Pilling Parish Council, 10 th February 2010 at the Pilling Memorial Hall

5.3 Consultation Responses

Responses were received from over 10 residents, businesses, Parish Councils and other organisations. Responses were received in a variety of forms:

• letters;

• consultation response forms (hand written and electronic); and

• e-mails.

Summaries of issues raised about specific areas during the consultation are included in the following sections. Annex B11 includes all SMP2 public consultation responses. A comment and/or action taken by the SMP2 team is also included for each response.

5.4 Area Specific Responses

5.4.1 Ribble Estuary - 11b1

There was general support for the draft policies within the Ribble estuary, where the aim is to continue managing risks to Southport and Lytham by maintaining the natural estuary system. Within the Ribble and Douglas estuaries, the aim is to establish a balance between the cost of protecting homes and land and maintaining the natural environment. This may include looking at opportunities for managed realignment where possible. The main responses and queries received are summarised below:

• Support has been expressed for managed realignment in both the Ribble and Douglas estuaries. However, it is felt that where managed realignment is proposed in the long term bringing this policy forward should be considered.

• A no active intervention policy should cover the whole of the area from Naze Point to Warton Bank (policy unit 11b 1.14), as managed realignment at Poolstream (Bush Farm Creek in the SMP2) may no longer be necessary. • Concern was raised about the apparent lack of sand dune management at St Annes.

• Concern was raised about how the loss of the training walls in the Ribble will affect the way the coast works.

SMP2 Team Comments

A large number of managed realignment opportunities have been identified in the SMP2 in the Ribble. Carrying out many realignment schemes together could have significant implications on the way the estuary works and therefore we have recommended staggering any realignment over a period of time.

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In some locations managed realignment is the draft policy for the medium term, while in others studies are recommended to take place in the medium term to look at further opportunities to set back defences in the long term and implement where practicable.

The SMP2 action plan recommends that an estuary wide study is undertaken to investigate various managed realignment opportunities in the long term and develop plans to implement where practicable to create a more sustainable defence alignment. The SMP2 team propose to add consideration of the impacts of deterioration of the training walls on coastal processes to the proposed study. In addition there are a number of linked studies being undertaken to support the SMP2, including a sediment study which will further consider the implications of large scale managed realignment in the Ribble, and help inform future management of the estuary.

Following discussion with EA NW the SMP2 team is satisfied that proposing localised managed realignment at Bush Farm Creek is no longer appropriate and consequently the policy has been revised to indicate no active intervention for the full policy unit PU 11b 1.14 Naze Point to Warton Bank.

The draft SMP2 policy of hold the line for the St Annes frontage describes implementation as maintaining the existing defences to an adequate standard where present as well as maintaining the dunes as a natural defence through dune management. Details regarding these management activities are beyond the scope of the SMP2. However, Fylde BC, during the course of the SMP, has produced and adopted a local Sand Dune Management Action Plan http://www.fylde.gov.uk/environment/conservation/sand-dunes/dunes/ .

The following revisions to the draft policies have been made as a result of the consultation:

PU 11b 1.14 Naze Point to Warton Bank - change to No Active Intervention (0-20 years), No Active Intervention (20-50 years), No Active Intervention (50-100 years) for the whole frontage.

5.4.2 St Annes to Rossall Point - 11b2

There was support for the draft policies for this frontage where the main aim is to continue managing risk to property and infrastructure through providing defences on existing lines, with some improvements where required. This will be achieved by hold the line throughout with managed realignment in the short term between St Annes and Blackpool to allow the dunes to function naturally whilst considering options for a secondary defence. The main comment received related to:

• Concern regarding the potential loss of the beach in the future under rising sea levels and implications this would have on tourism and recreation.

SMP2 Team Comments

The SMP2 has recognised that it is likely to become increasingly difficult to retain beaches along the frontage as sea levels rise in the future. In order to help address this, the SMP2 has recommended the need to develop a long term beach management strategy along the Blackpool frontage to deal with the long term trend of beach erosion. This concurs with Blackpool Council’s response which acknowledge support for future management options to sustain the beach, including the development of a long term beach management strategy.

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No changes to the draft policies have been made following public consultation.

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6 Consultation Strategy and Responses received: Sub-Cell 11c – Rossall Point Fleetwood to Hodbarrow Point

Figure 5: Map showing the location of Sub-Cell 11c, Rossall Point, Fleetwood to Hodbarrow Point.

6.1 Consultation Strategy Sub-Cell 11c

In Sub-Cell 11c (between Rossall Point, Fleetwood and Hodbarrow Point near Millom), we used the following ways to raise awareness of the SMP2 consultation.

Examples of consultation materials including stakeholder letters, press releases cabinet reports and meeting notes are included in Annex B7 .

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Website

Press Notices / Press Briefings

A number of consultation meetings were advertised on the Lancaster City Council website and in an advertisement in the Lancaster Guardian Public Notices section on 12th February 2010.

Examples of consultation materials including press releases for consultation meetings are included in Annex B7.

Cabinet Reports

A Cabinet Report informing councillors about the start of the SMP2 consultation process was presented at a Wyre Borough Council Cabinet Meeting that was held on 7th Sept 2009.

A report was presented to the Lancaster City Council Cabinet on 9 th October 2009 to provide an update on the development of the SMP2 and the plans for the consultation.

A report was presented the South Lakeland District Council Community Services Overview and Scrutiny Committee on 18 th January 2010, explaining the importance of the SMP2 and outlining the proposed draft policies.

A Copeland Borough Council (CBC) Executive report was presented to the members on 22 September 2009 regarding the SMP2 public consultation.

6.2 Public Events and Stakeholder Meetings

Three public meetings / workshops were held between December 2009 and January 2010 to publicise the SMP consultation and allow stakeholders and members of the public to come and ask questions and find out more information about the SMP and the draft policies. Public events were held at the following locations:

• Lancaster, 8th December 2009 at Lancaster House Hotel, Lancaster (Notes from the meeting are included in Annex B7)

• Barrow, 14th December 2009 at Forum Twenty Eight, Barrow (Notes from the meeting are included in Annex B7)

• Kendal, 25th January 2010 at South Lakeland District Council Town Hall, Kendal

Further meetings requested by residents at Sunderland Point and Thurnham, were held as follows:

• Sunderland Point, 6th January 2010 at Overton Memorial Hall

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• Ben Wallace MP, 22 nd January 2010, Great Eccleston

• Geraldine Smith MP , 5 th February 2010, Morecambe

• Thurnham Village Institute, 12 th January 2010

• Thurnham, Glasson Village Hall, 5 th February 2010

• Thurnham, Glasson Village Hall, 8 th March 2010

• Regional Flood Defence Committee site visit, 26 th March 2010

Following extension of the consultation period, further meetings were held:

• Overton, Sunderland Point and Heysham, 16th February 2010 at Morecambe Town Hall, Morecambe

• Carnforth, Bolton-le-Sands, Hest Bank and Silverdale, 17th February 2010 at Carnforth Railway Station, Carnforth

6.3 Consultation Responses

Responses were received from over 120 residents, businesses, Parish Councils and other organisations. Responses were received in a variety of forms:

• letters;

• consultation response forms (hand written and electronic); and

• e-mails.

A summary of issues raised about specific areas during the consultation relating are included in the following sections. Annex B12 includes all SMP2 public consultation responses. A comment and/or action taken by the SMP2 team is also included for each response.

6.4 Area Specific Responses

6.4.1 Fleetwood and Wyre Estuary - 11c1

There were a small number of responses received for the Fleetwood and Wyre Estuary frontage. Here the long term plan is to continue providing protection to the outer reaches of the estuary, through hold the line, to protect the large areas of flood risk and development. Although this will constrain natural development of the outer estuary, there is a plan to allow the upper reaches to function more naturally and opportunities for managed realignment will be pursued. The main responses and queries received are summarised below:

• A number of consultees (RSPB, EA NW, Wyre BC) raised the potential for managed realignment in sections of policy unit 1.5 (Stanah to Cartford Bridge and Cartford Bridge to Shard Bridge). The consultation draft SMP2 policy of hold the line then no active intervention is considered to take a passive approach to seeking these opportunities. A long term policy of managed realignment would also enable promotion of habitat creation.

• The issue of the recent Cumbria floods was raised, and the question asked whether the existing coast protection system would have worked if similar problems affected the Wyre coastline. It was also

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suggested that the Environment Agency should be preventing further housing development on flood plains.

SMP2 Team Comments

During the policy assessment stage the SMP2 team assessed both managed realignment and no active intervention in policy unit 11c 1.5 Stanah to Cartford Bridge and Cartford Bridge to Shard Bridge. Under both policies the shoreline is expected to evolve in a very similar manner, however, under no active intervention unless individual landowners took on maintenance, existing defences would be allowed to fail and the unprotected areas would be progressively inundated up to naturally higher ground. This scenario was considered more viable due to the topography of the chosen areas and the general lack of assets at risk which means there is likely to be no economic justification for further defences.

However, the SMP2 team recognise that under a managed realignment policy the shoreline would also be allowed to realign back to high land but in a more proactive, managed way, which could be more conducive for habitat creation purposes. We therefore propose to revise the draft policy to managed realignment, which will allow flexibility in the approach to managing change. The stated approach for the first epoch allows for earlier implementation and will recognise potential for Biodiversity Action Plan habitat creation.

The Cumbria problems in 2009 were related to very heavy rainfall, resulting in very exceptional river flows, whereas the SMP2 is concerned with coastal flooding and erosion. The most recent major coastal floods affecting Fleetwood and surrounding area were on November 11, 1977, when over 5,000 properties and 7,900 acres of agricultural land were flooded. The floods were unexpected as there was no flood warning system in place at the time. Since that time there have been many improvements to the coastal defences, but the 1977 floods here and the 1990 foods at Towyn in North Wales serve as a reminder that although we can reduce the risk of frequent flooding with defences and are now able to provide warnings, it is not possible to prevent all flooding. The SMP2 has not considered in detail the standard of protection provided by the existing defences, as this is dealt with at the more detailed strategy level, but there will always be a chance that they could be overtopped under very exceptional tidal surge events.

The following revision to the draft policies has been made as a result of the consultation:

11c 1.5 Stanah to Cartford Bridge and Cartford Bridge to Shard Bridge - change to Hold The Line (0-20 years), Managed Realignment (20-50 years), Managed Realignment (50-100 years).

6.4.2 Knott End to Glasson Dock - 11c2

Significant numbers of responses were received for this frontage stretching from Knott End to Glasson Dock. The consultation draft SMP2 proposed policies were for hold the line at the western end of the frontage to manage risk to property and infrastructure, but to investigate opportunities for managed realignment in the medium and long term east of Fluke Hall. The main responses and queries received related to the proposed managed realignment in policy units 2.3 and 2.4 and are summarised below:

• There are significant concerns regarding the proposed seawall realignment which, although the actual location was not specified, may increase risks to or lead to loss of residential properties. Consultees feel that this would blight property and leave them worthless, as well as potentially leading to flooding. Residents are unclear about possible compensation or financial support to those affected. Some consultees also stated that there was no suggestion that there would be a change in policy when they bought their properties, nor was planning permission withheld. Some quoted existing agreements

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between property owners and the local council or Environment Agency that defence provision would continue.

• There were further significant concerns relating to the impact of realignment on businesses, specifically farmland and caravan parks, and the knock-on effects on the local economy should these be lost. Concerns were also raised regarding the risk to Cockersands Abbey Scheduled Monument.

• Questions were asked regarding the realignment including the likely extent / location of new defences and timescales of flooding resulting from such a scheme, the possibility of privately funded defences, the likely implementation of managed realignment, whether there was economic justification for realignment and how the habitat created as a result of realignment would be managed.

• Concern was raised about future British food security, and how potential loss of large areas of farmland following realignment fits with recent government policy regarding the importance of UK food production in future.

• There was significant concern regarding the consultation process and how it was undertaken with consultees feeling that they had not been well informed. There was suggestion that the process was deliberately flawed to prevent local residents being involved. One consultee thought that there should be bi-annual consultation in the future to keep residents informed.

• A number of consultees raised the issue of human rights, feeling that the proposed realignment would breach the human rights of residents involved.

• A number of requests were made for release of reports from previous studies of the area commissioned by the Environment Agency prior to the SMP2. Subsequently further responses and questions were received on those specific studies.

• The ongoing issue of sedimentation in the outfall channels at Piling on land drainage was raised at several meetings with a request that it is considered in the action plan.

SMP2 Team Comments

The SMP2 team acknowledges the strong feelings of concern raised by many respondents. During the consultation period meetings have been undertaken with the public, with Cockerham Parish Council and with the Cockersands Forum residents group at which local concerns have been raised and the issues discussed regarding the difficulty of justifying long term affordability of the maintenance and improvements to the defences that would be required to hold the line that most respondents would prefer.

The Environment Agency and Local Authorities have permissive powers to undertake flood risk management activities but do not 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.

Under a policy of managed realignment properties located behind new defences would benefit from improved flood defences. There would also be the opportunity to protect local or individual properties from erosion, for example the Scheduled Monument at Cockerham Abbey, which is on slightly raised ground. The draft SMP2 did not propose any specific alignment options for a new defence, but it is considered that a large proportion of the property at risk would be defended if an alignment similar to that considered in previous studies were to be adopted. Land use for the area between the existing defences and new defence line would need to be

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report planned in consideration of the risks and consultation with land and property owners, but it is likely that large areas could be used for grazing and there would be habitat creation opportunities. The draft SMP2 proposed that more detailed studies were required to determine the approach to management of this frontage and this is still the case.

The SMP is a non-statutory document and does not over-ride rights, duties and powers provided through legislation, so does not contravene human rights.

In recognition of the additional information submitted and strong concerns raised over the draft policies during consultation, the SMP team consider that there remains a need to consider alternative options for managing the existing defences into the medium term, whether or not the primary defence is realigned. The headline SMP2 policy is therefore now proposed to change to “ Hold the Line OR Managed Realignment ” in both the 2nd and 3rd epochs in PU 2.4. In PU 2.3 the 2nd epoch policy will change to “ Hold the Line OR Managed Realignment ” for consistency, but remain as HTL in the 3 rd epoch as there is not considered to be opportunity for phased MR in PU2.3 in the same way that there is in PU2.4.

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. The EA NW has indicated commitment to organising regular future consultation meetings with the Cockersands Forum.

The action plan will be updated to include an action for the EA to consult with Natural England over dealing with the issue of sediment accretion blocking the outfall channels at a strategic level.

The following revision to the draft policies has been made as a result of the consultation:

11c 2.3 Fluke Hall to Cocker Bridge – change to Hold The Line (0-20 years), Hold The Line or Managed Realignment (20-50 years), Hold The Line (50-100 years)

11c 2.4 Cocker Bridge to Glasson Dock – change to Hold The Line (0-20 years), Hold The Line or Managed Realignment (20-50 years), Hold The Line or Managed Realignment (50-100 years)

6.4.3 Lune Estuary - 11c3

There were a number of concerns received regarding the draft policies for policy unit 3.7 Overton Cattle Grid to Sunderland Village. The draft plan is to continue to manage flood and erosion risk to property and infrastructure in the estuary, but to cease defence of small areas where there is no development. The main responses received are summarised below:

• Concern has been raised regarding the draft managed realignment policy in policy unit 3.7 – Overton Cattle Grid to Sunderland Village. It was suggested that the proposed realignment of the Sunderland Village access road was inconsistent with the policy for Sunderland Village itself.

• The residents of Sunderland Village have always lived their lives around the fact that access to the village is cut off most days over high tide, and they accept that access will be restricted for slightly longer periods in the future. However, being cut off by the tide is one of the essential characteristics of life at Sunderland Point.

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• There was suggestion that the evidence base for policy change within the Lune Estuary is inadequate and the data interpretation is flawed.

SMP2 Team Comments

The consultation draft managed realignment policy 11c 3.7 Overton Cattle Grid to Sunderland village was recommended to allow for future re-alignment of the road and the defence together. However, there is no clear source of funding for realigning the road and concerns expressed during consultation have indicated a desire for the road to remain where it is. Following review of concerns raised and consideration of information put forward during the consultation process the SMP2 team agree that maintaining the existing defence alignment in the short to medium term could be more cost effective, but at the broad scale analysis for the SMP even this is not justified over the long term. In the long term, realigning the embankment to the existing secondary defence could potentially lead to creation of habitats required for BAP targets and therefore be a trigger to enabling a scheme that would allow adaptation. Removing the road from the marsh may be beneficial for the internationally designated sites. The SMP2 team have therefore revised the draft policy for Overton Cattle Grid to Sunderland Village HTL / HTL / MR where the defences could be realigned to the existing set back defence protecting Overton in the long term, subject to future studies.

The draft SMP2 documents recognised that there is uncertainty in the physical processes within the Lune estuary and the SMP2 team is aware that there are conflicting views on the impact of erosion at Sunderland Point on the overall coastal risks in the estuary. The SMP2 team also acknowledge that sea level rise may not yet be being realised, but the allowances that we have to plan for show increasing rates in the future. The draft SMP2 action plan for the estuary already includes a number of studies which are recommended to inform future policy and management of the estuary. However, we propose to add the need to monitor and consider in more detail the impacts of the training walls on both flood risk and evolution of the designated habitats, including an action to determine responsibility for these structures.

The following revisions to the draft policies have been made as a result of the public consultation:

11c 3.7 Overton Cattle Grid to Sunderland village - change to Hold The Line (0-20 years), Hold The Line (20-50 years), Managed Realignment (50-100 years)

6.4.4 Sunderland Village to Potts Corner - 11c4

Many responses were received during consultation for this shoreline where the proposed draft preferred policy is for no active intervention throughout the SMP2 period due to a lack of economic justification for funding defence improvements, and the benefits to the natural environment that would result. The main responses and queries received are summarised below:

• There was significant concern regarding the policy for no active intervention.

• Consultees were concerned about loss of property in the long term, and loss of property value and insurance in the short term. There were also concerns regarding loss of farmland and the loss of intertidal marsh habitats, and impact on the historic environment.

• Some consultees felt that a policy of no active intervention would breach human rights of the residents of Sunderland Village.

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• Impact on recreation and tourism was raised, with consultees concerned that the policy would affect the large numbers of visitors to Sunderland Point and Village.

• Further concerns were raised regarding the potential impact on the wider environment, if Sunderland Point was abandoned and its sheltering effect was lost through erosion. There was suggestion that the evidence base for policy change within the Lune Estuary is inadequate and the data interpretation is flawed.

• One consultee suggested that the policy unit should be sub-divided due to the presence of a secondary embankment which ran from the Overton defence to midway between Sunderland Point and Potts Corner.

• Several responses were received indicating that the heritage values of the many listed buildings had not been considered properly in the draft SMP2.

• The preparation of the SMP2 was questioned, with consultees feeling that there was an insufficient rigour of analysis. One consultee stated that the whole SMP2 process was flawed due to the categorisation of each unit into one of four policies, and the need to use too-narrowly defined economic criteria.

• It was suggested that there were inconsistencies in policies, with Sunderland Village being no active intervention, but other similar areas having proposed policies of hold the line, in the first epoch or throughout. Places mentioned included Roa Island and Askam-in-Furness.

• The consultation process was criticised with consultees feeling that there was insufficient time to respond and to properly study the vast amount of information.

SMP2 Team Comments

The previous SMP proposed a policy of Hold the Line, but capital schemes to implement that policy have not been found to be viable for public funding over the last ten years. However, this has resulted in residents and the community association working with the local authority with support from Defra grants under a pilot scheme to implement local property resilience measures rather than constructing large scale defences. The draft SMP2 proposed policy of No Active Intervention for the coastal defences allows for a continuation of existing practices as long as sustainable, which was anticipated as being the next 20 to 50 years, and so is not a major change in approach to present shoreline management practice.

The SMP2 is a non-statutory document and does not over-ride rights, duties and powers provided through legislation, so does not contravene human rights.

It is agreed that in the medium and long term road access to Sunderland village will become progressively more restricted due to sea level rise, which will reduce access for tourism but there has been strong opposition from consultees to the suggestion in the draft SMP2 to re-route the road away from the marsh (see PU 3.7).

The SMP2 team note that there is uncertainty over the impact of erosion at the point on the wider Lune estuary and there have been conflicting studies on the impact. It is now proposed to split the Policy unit to allow for a managed realignment policy at the point which would allow for limited intervention to reduce the rate of erosion whilst further monitoring is undertaken.

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The secondary embankment protecting Overton and Middleton has been discussed with EA NW and it was agreed that Policy Unit 4.1 needs to be further split to the north of Sunderland Brows Farm, where this embankment joins the coast. This will be in accordance with preliminary drafts of the proposed policies discussed with stakeholders and reported in Appendix G.

The heritage importance of Sunderland Point has been highlighted by several respondents. While the conservation area and listed buildings are recognised in the objective appraisal in Appendix G, the SMP2 team agree that the summary impact assessment in the main SMP2 document needs to give more weight to the heritage impacts for this location.

The SMP2 has been prepared in accordance with national guidelines. The more detailed analysis called for needs to be part of more local studies. At SMP level the appraisal is objective led and not driven primarily by economics. The review of SMP1 has to take into account existing practice and the results of studies since SMP1. Although there are only four generic policies, the SMP2 is able to suggest how the approach to policy might be undertaken which can be very different by location.

The SMP2 team has reviewed the items raised for consistency checks and consider that there is no conflict, as the situations are very different at the quoted locations. A viability study was undertaken for Roa Island in advance of the SMP2 and this confirmed the viability of the HTL policy. There are many more houses there and an important lifeboat station and the causeway to Roa Island is not tidal. Askam is not at flood risk and erosion risk could be managed very economically.

Following requests, further public meetings were undertaken and the response date for ongoing discussions was extended to 31 st March 2010.

The following revisions to the draft policies have been made as a result of the consultation:

11c 4.1 Sunderland Village – (New policy unit) No Active Intervention (0-20 years), No Active Intervention (20-50 years), No Active Intervention (50-100 years) (continue individual property / community defences and property adaptation) 11c 4.2 Sunderland Point – (New policy Unit) Managed Realignment (0-20 years), Managed Realignment (20-50 years), Managed Realignment (50-100 years) 11c 4.3 Sunderland Point to Secondary Embankment - (New policy unit) No Active Intervention (0-20 years), No Active Intervention (20-50 years), No Active Intervention (50-100 years) 11c 4.4 Secondary Embankment to Potts Corner - (New policy unit) Hold The Line (0-20 years), Hold The Line (20-50 years), Hold The Line (50-100 years)

6.4.5 Potts Corner to Heysham - 11c5

Just one comment was received regarding policy area 11c5 where the draft SMP2 policy is to continue to provide protection to the power station and port of Heysham, through hold the line, but with a policy of no active intervention to the south where defences were not expected to be economically justified and natural evolution of the coastline would be allowed. The comment received is summarised below:

• Concern was raised that further discussion was needed with stakeholders along this frontage.

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SMP2 Team Comments

Following receipt of this response, further public consultation events took place in the Lancaster City Council area subsequently to receipt of this response (see Section 6.2 for details).

No changes to the draft policies have been made following public consultation.

6.4.6 Heysham to Hest Bank - 11c6

This coastline includes the town of Morecambe where the draft policy is to continue to hold the line to manage flood and erosion risk to property and infrastructure. The policy for Lower Heysham in the south is for no active intervention.

No responses were received for this area.

SMP2 Team Comments

No changes to the draft policies have been made following public consultation

6.4.7 Hest Bank to Heald Brow - 11c7

A limited number of responses were received for this stretch of coastline. The draft plan is to undertake managed realignment in combination with no active intervention where there is higher land, whilst managing coastal risks. Policies to the north may be subject to change depending on the future of the railway and future management at Leighton Moss. The main responses and queries received are summarised below:

• RSPB would prefer to see managed realignment in the short term, hold the line in the medium term and managed realignment in the long term policy in unit 7.5 (River Keer to Heald Brow). This would enable protection of Leighton Moss SPA, ensure protection of the railway line and enable habitat creation.

• There was concern regarding the potential loss of the railway and roads at the northern end of the frontage and that general flooding of Leighton Moss would be detrimental to wildlife.

• It was suggested that flooding around Morecambe Lodge could affect the rear of properties on The Shore, which are currently protected from the front. It was requested that further defence be added.

SMP2 Team Comments

The draft SMP2 policy for PU 11c 7.5 River Keer to Heald Brow was no active intervention for all three epochs for the private embankment frontage, but also indicates that more local investigations should be undertaken into future management options including issues related to Coatstones landfill site. Policy implementation also includes the need to monitor coastal risks to railway, and to only carry out works if the railway is at risk, or the SPA freshwater designations are threatened or management changes at Leighton Moss relative to tidal incursion. Both Natural England and RSPB who have responsibility for Leighton Moss reserve have been involved in 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.

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The SMP2 team reviewed the responses and decided to amend the policy description and action plan to also include consideration of possible habitat creation adjacent to the railway. However, the SPM2 team agrees that the policy for 11c 7.5 should remain as no active intervention. Further studies should then be available to inform policy choice in the next review of the SMP.

The linked flood risk between the shoreline south of Morecambe Lodge (PU7.1) & North east of Red Bank Farm (PU7.3) is acknowledged in the flood maps used in the SMP and both these frontages have a hold the line policy, with allowance for potential managed realignment in the medium term if practical. The area around Morecambe Lodge itself (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. The SMP2 team 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.

No changes to the draft policies have been made following public consultation

6.4.8 Heald Brow to Humphrey Head - 11c8

Just one comment was received regarding policy area 11c8 where the draft plan is to continue to manage risk to property and infrastructure through hold the line along much of the coastline, but enable natural coastline evolution through no active intervention in undeveloped areas to the east of Arnside. The comment received is summarised below:

• Concern was raised that further discussion was needed with stakeholders along this frontage.

SMP2 Team Comments

Following receipt of this response, two further public consultation events took place along this frontage (see Section 6.2 for details).

No changes to the draft policies have been made following public consultation.

6.4.9 Kent Estuary - 11c9

There were a number of responses received for the Kent Estuary, where the draft long term plan is to return the estuary to a more natural state and create additional habitat where possible, whilst considering impact on estuary flows and economic losses resulting from loss of agricultural land. The responses received are summarised below:

• Concern was raised in relation to managed realignment within the Kent estuary, with regards to property and agricultural land loss and maintaining defences that are already there.

SMP2 Team Comments

In the past reclamation of land around the North West coast has been assisted by accretion of sediment and stable or slightly falling sea levels relative to land levels. Due to the expected impacts of climate change we now have to plan for rising sea levels, which will make coastal defences much more expensive in future and expenditure on defences is already stretched. The draft SMP does allow for maintaining the defences for up to

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20 years for the whole of the estuary. However, in the longer term it may not be affordable or justifiable to continue to maintain all of the existing defences and alternative approaches need to be considered, particularly in the light of the sea level rise allowances that we have to plan for.

In the draft SMP2 opportunities for managed realignment have been identified in the medium and long term for the Kent estuary. However the SMP2 does not assume or suggest any potential alignment for managed realignment. The draft SMP2 policy is for hold the line for up to the first 20 years, during which time studies would take place to confirm longer term policy and develop the approach to medium to longer term managed realignment. It is proposed in the action plan that these studies are undertaken in the short term to consider realignment opportunities within the estuary as well as which lengths within the policy unit could be realigned and to what extent.

The SMP2 team propose that responses received about the scale of agricultural land loss and future food security and prioritisation of defences are to be considered as a broader scale issue across the whole SMP at a regional or national level in the Action Plan.

No changes to the draft policies have been made following public consultation.

6.4.10 Humphrey Head to Cark - 11c10

Two responses were received relating to the shoreline between Humphrey Head and Cark where the consultation draft preferred plan was to set back from the present shoreline, whilst continuing to manage risk to the railway and other assets including agricultural land where economically justifiable. The realignment would be undertaken in a phased and controlled manner to ensure risk to people and property continues to be managed. The responses received are summarised below:

• One consultee had concern relating to the justification of the policies, with specific concerns regarding inaccurate baseline data, incorrect application of assumptions regarding effects of climate change; contradictions between policy conclusions in the appendices and preferred policies; and confusion of the application of SMP policy to private frontages. Clarification was requested regarding the right of the landowner to provide private defences over all 3 epochs, and whether there was any compensation available if this was not the case.

• There was concern over the proposed loss of a large area of valuable agricultural land. It was felt that the uncertainty which the policies imply would lead to a loss of investment in the land.

SMP2 Team Comments

A direct response was provided to the consultee, a commercial organisation and landowner that has recently invested substantially in defence improvements. Further correspondence requesting a meeting was then received. The correspondence is documented in Annex B12.

The SMP2 team notes that the consultation draft policy allowed for Hold the Line in the short term, followed by phased Managed Realignment over the medium and long term. This would take into account the economics of maintaining the defences on their existing alignment and allow a long term return to a more natural coast and avoiding adverse impacts on the internationally designated sites. Following review of the consultation responses, the SMP2 team has changed the medium term policy to recognise that the caravan park section of the frontage has substantially new defences and that there is a commitment to private funding to maintain

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report these for at least the short and medium term to protect the caravan park. The policy will therefore remain as Hold the Line for the short term, followed by a revised medium term policy of Managed Realignment and local Hold the Line subject to private funding. The long term policy will remain as Managed Realignment.

The alignment of any new defences would need to be agreed before the phased medium and long term realignment, but land and properties behind the new defence line would benefit from improved protection. The SMP2 team notes that the national guidance is clear that SMP2 analyses and proposed policies must be based on existing assets at risk and not allow for or encourage future development in coastal risk areas.

The following revisions to the draft policies have been made as a result of the consultation:

11c 10.2 Humphrey Head to Cowpren Point change to - Hold the Line (0-20 years), Managed realignment and local Hold the Line (subject to private funding agreement) (20-50 years), Managed realignment (50-100 years)

6.4.11 Outer Leven Estuary - 11c11

Only one comment was received regarding the Outer Leven Estuary, where the aim is to manage risk to the railway and agricultural land where economically justifiable, but to generally allow the shoreline to set back from the present alignment and respond to coastal change through policies of no active intervention and managed realignment along much of the frontage. The comment received is summarised below:

• Concerns have been raised regarding the policies potentially impacting flood risk management for the area around Canal Foot, Ulverston. At extreme high tides it is thought that properties would flood and much of the East Ulverston Ward would flood if defences to the north of the Leven viaduct (in 11c 12) were breached.

SMP2 Team Comments

The draft SMP2 allows for managing the flood risk to Canal Foot and surrounding area by consideration of flood risks from the Conishead frontage and subject to further studies creating a set back embankment in future.

At Canal Foot itself the proposed SMP allows for a Hold the Line policy which can manage risks to the flood pathway to the wider area along the canal, and this will allow the local authority and the Environment Agency to take action to manage the risks if necessary and justified.

The potential for flood risk from north of the viaduct is recognised in the SMP2 policy maps. The proposed policy in 11c 12.3 was Hold the Line followed by Managed realignment and then No Active Intervention in the long term, which would allow for consideration of the risks at the next stage of studies and a set back defence to be constructed in future if necessary.

No changes to the draft policies have been made following public consultation.

6.4.12 Leven Estuary - 11c12

There were only a few responses received regarding the Leven Estuary. The preferred plan is to manage risk to property and infrastructure where economically justifiable, with realignment of flood defences elsewhere.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

This would lead to loss of or reduction in quality of areas of agricultural land but allow expansion of saltmarsh. The main responses and queries received are summarised below:

• There were concerns regarding the dangers of flooding inland due to breaching or realignment of defences near Barrow End Rocks, as happened in 2002. This could not only affect isolated properties but also local infrastructure as far away as the Ulverston Canal.

• There was support for a return to a more natural area adjacent to the valuable RAMSAR site of Morecambe Bay, but concerns regarding the flood risks, implications for drainage and impacts on the access roads crossing the mosses.

SMP2 Team Comments

The flood risks are recognised in the SMP2 policy maps and do need to be taken into account in the development of the next stage of studies. The proposed draft policies allow for Hold the Line for up to 20 years whilst further investigation and monitoring are considered, as allowed for in the draft Action Plan, prior to implementing Managed Realignment to set back the defences, at which time a new set-back defence could be constructed if necessary.

No changes to the draft policies have been made following public consultation.

6.4.13 Bardsea to Piel Island - 11c13

Limited responses were received for this frontage which stretches from Bardsea to Piel Island. The draft plan is to allow natural coastal evolution where possible, although local defences would be permitted where there are assets at risk. To the south the policy is dependent on economic justification for the defence of the coast road so that it can remain at its current position. The main responses and queries received are summarised below:

• Questions were raised regarding clarity of the policies of no active intervention with private funding of defences permitted.

• Concern was raised regarding coastal erosion and its impacts on the area, including parts of the A5087 Coast Road and sites of historical and environmental importance.

• Concerns were raised about the consistency of treatment of Scheduled Monuments and the importance of Piel Castle.

SMP2 Team Comments

Where no active intervention is the draft policy (PU 13.1 Bardsea to Newbiggin) this means that there is very unlikely to be public investment in coastal defences along the length of the frontage. However, the policy statement also acknowledges that there are localised defences along the frontage at present and that maintenance of these may continue to be permitted subject to consent. In addition, depending on the level of risk and the technical, environmental and economic acceptability there may be a case for local authority or Environment Agency funded localised defences. The SMP team therefore propose to include in the Action Plan an action to develop an adaptation strategy to facilitate future local flood or erosion risk protection or resilience work to isolated properties along the frontage.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

The draft SMP Policy for the frontage which includes the A5087 Coast Road (PU 13.2 Newbiggin to Rampside) allows for hold the line, followed by possible realignment of the road in appropriate locations by the Highway Authority if economically justified in the future.

The draft policy statement for Piel Island proposes a general no active intervention policy for the island, with the proviso that localised defences, eg at Piel Castle would be permitted, subject to consent. The no active intervention policy allows for the natural sections of coast to remain as such to maintain the character of the island. Although localised defences may be permitted at Piel Castle, they are not likely to have a wider impact. The draft action plan already includes an action to consider in more detail the impacts of the SMP2 policy on Piel Castle.

However, the SMP2 team also now propose to add in the need to include for consideration of appropriate recording or mitigation for impacts on the historical environment under no active intervention policies on Piel Island and other frontages to the north in the policy statement area.

No changes to the draft policies have been made following public consultation

6.4.14 Walney Island - 11c14

There were a variety of responses received regarding Walney Island. The draft plan is to allow natural coastal evolution along much of the coast, while defending key locations including the narrowest part of the island, adjacent to the landfill site. Overall, this will help make the defended sections more sustainable and be compatible with the designated sites to the south and north of the island. A policy of hold the line applies to the landward side of the Island where economically and environmentally justifiable. The main responses and queries received are summarised below:

• The proposed policy of managed realignment has been questioned along the West Shore Park frontage as it appears that the beach is recovering, which suggests that material is by-passing the groyne. There is a need for short term intervention at this frontage for up to 15 years to manage risks while allowing for relocation of properties and facilities.

• Consultees suggested that Walney Island should be protected, due to its important role protecting Barrow-in-Furness and to protect local residents, including those living in houses that have just been built.

SMP2 Team Comments

The draft SMP2 policy of managed realignment at West Shore Park was recommended to help address the issue of sediment entrapment by the groyne to the south of the frontage, while also managing risk to West Shore Park itself now and into the future. The responses have now been taken into consideration by the SMP2 team and the policy statement will be updated to reflect the need for short term intervention to manage risks while the approach to relocation of properties and facilities is developed.

The SMP2 recognises the strategic importance of Walney Island and its role in providing protection to Barrow and the adjacent mainland. However, as the island is not expected to breach through erosion even well beyond the 100 year timescale of the SMP, and the fact that expenditure on flood defences is subject to national

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report prioritisation, it is unlikely to be affordable or environmentally acceptable to defend the whole island in the future.

No changes to the draft policies have been made following public consultation

6.4.15 Walney Channel (Mainland) - 11c15

Only one comment was received relating to the Walney Channel, where the preferred plan is to manage risk to property, industry and infrastructure within Barrow-in-Furness through a policy of hold the line. However, where there is little risk, the policy will be no active intervention. The comment received related to a typographic error in the policy statements.

SMP2 Team Comments

No changes to the draft policies have been made following public consultation

6.4.16 Duddon Estuary - 11c16

A number of responses were received regarding this frontage. The long term draft plan is to allow the shoreline to return to a more natural coastline by realigning or withdrawing from defences where appropriate. Risk to property and infrastructure would continue to be managed where economically and environmentally viable. The main responses and queries received are summarised below:

• One consultee felt that there are a number of places where a policy of managed realignment with tidal exchange would be more appropriate and allow proactive habitat creation (Policy units 16.3, 16.4, 16.6 and 16.12).

• There were concerns regarding the risk to the railway and farmland within policy unit 16.8 (inner Duddon Estuary). It is considered that with minimal maintenance the existing embankment could last for at least 50 years and therefore hold the line should be adopted for at least the short and medium term.

• The location of the sub-cell 11c to 11d boundary, which the draft SMP located at Haverigg was questioned as it had been expected to be at nearby Hodbarrow Point.

SMP2 Team Comments

The SMP2 team agree that a headline policy of managed realignment would be a more proactive option, however, there is likely to be limited justification for flood and coastal defence expenditure to do so. Therefore, the SP2 team has decided to acknowledged in the policy statement for the Duddon, that there may be potential opportunities for regulated tidal exchange and intertidal habitat creation landward of railway in a number of locations.

In relation to PU 16.8 the SMP2 team has reviewed the consultation responses and now propose to change the policy to hold the line in the short term, pending further consultation and investigation of managed realignment opportunities. The comments about marsh management and the existing condition of the defence have been noted and will be taken into account during the next stage of studies. Importantly, realignment or withdrawal from maintenance of defences would not necessarily apply to the whole policy unit 16.8 frontage

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report and the detail of the approach to delivery of the policy will be developed during more local consultation and further studies.

Location of the boundary between the sub-cells had been based on the boundaries report developed before the present study started but there was confusion in the report. Following discussion amongst the SMP2 team the boundary will now move to Hodbarrow Point.

The following revisions to the draft policies have been made as a result of the consultation:

PU 11c 16.8 Duddon Estuary (Both banks upstream of Viaduct and the right bank south to Green Rd Station) - change to Hold The Line (0-20 years), Managed Realignment (20-50 years), Managed Realignment (50-100 years)

Revise sub-cell boundary to Hodbarrow Point , which means that PU 16.2, Hodbarrow Nature Reserve & Lagoon will be the First unit in the 11d area.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

7 Consultation Strategy and Responses received: Sub-Cell 11d – Hodbarrow Point to St Bees Head

Figure 6: Map showing the location of Sub-Cell 11d, Hodbarrow Point to St Bees Head.

7.1 Consultation Strategy Sub-Cell 11d

In Sub-Cell 11c (between Hodbarrow Point near Millom and St Bees Head), we used the following ways to raise awareness of the SMP2 consultation.

Examples of consultation materials including stakeholder letters, cabinet reports and meeting notes are included in Annex B8 .

Website

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Stakeholder Letters

Copeland Borough Council sent letters to a number of residents in targeted locations, including Millom Marshes, Selker to Eskmeals, Braystones, Nethertown and Coulderton Beach informing them of the SMP2 consultation.

Cabinet Reports

A Copeland Borough Council (CBC) Executive report was presented to the members on 22 September 2009 regarding the SMP2 public consultation.

Draft SMP2 Documents

Copies of the main Draft SMP2 Document were made available for viewing from October 2009, in the following locations:

• Members Room CBC,

• Spatial Planning CBC,

• Development Control CBC,

• Millom CBC Office

• Whitehaven CBC Offices (this copy included SMP2 Appendices)

• Egremont Town Hall

Copies of the SMP2 were also available at the following libraries:

• Millom Library,

• Cleator Moor Library,

• Frizington Library,

• Gosforth Library,

• Whitehaven Library,

• Kells Library,

• Mirehouse Library,

• Hensingham Library,

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

• Egremont Library,

• Thornhill Library,

• Seascale Library,

• St Bees Library

• Distington Library.

Examples of consultation materials including stakeholder letters are included in Annex B8.

7.2 Public Events and Stakeholder Meetings

A public meeting was held at The Beacon, Whitehaven on 16 th December 2009 which was open to stakeholders and the Public from Sub Cells 11d and 11e. However due to the Cumbria floods in November 2009 the meeting was not well publicised and travelling to the venue from the North was disrupted. Notes from the meeting are included in Annex B8.

A SMP2 workshop event was held at Muncaster Castle, Muncaster on 11th February 2010. Letters were sent to Councillors, parish clerks and residents inviting them to attend, although it was also requested that they forward the invitation on to others as the event was free to all. A copy of this letter and notes from the meeting are included in Annex B8.

7.3 Consultation Responses

Responses were received from over 20 residents, businesses, Parish Councils and other organisations. Responses were received in a variety of forms:

• letters;

• consultation response forms (hand written and electronic); and

• e-mails.

Summaries of issues raised about specific areas during the consultation are included in the following sections. Annex B13 includes all SMP2 public consultation responses received. A comment and/or action taken by the SMP2 team is also included for each response.

7.4 Area Specific Responses

7.4.1 Haverigg to Selker - 11d1

There was mixed support for the draft policies in this area. The draft plan between Haverigg and Selker is to allow natural coastal evolution through no active intervention as much as possible. However, property and infrastructure at Haverigg will continue to be protected by maintaining and improving the existing defences, and maintenance of existing private defences would continue to be permitted at Hartrees Hill, Silecroft subject to consent. The main responses and queries received are summarised below:

• The location of the sub-cell 11c to 11d boundary, which the draft SMP located at Haverigg was questioned as it had been expected to be at nearby Hodbarrow Point.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

• Concern has been raised that implications of the potential nuclear new build, new wind farm proposals and potential expansion of the prison at Haverigg all need to be considered.

• Consultees at Hartrees Hill have expressed concern that under a no active intervention policy they will be unable to maintain or construct private defences to maintain access to the beach and to prevent breach of the natural bank.

SMP2 Team Comments

In accordance with national guidance the SMP2 is only able to consider planning schemes and future development where planning permission is already in place. Therefore, potential schemes such as the wind farm and prison expansion at Haverigg and nuclear new build proposals at Kirkstanton have not been included in the plan as no planning consent is in place. These developments would need to go through project specific environmental impact assessments. It is however acknowledged in the policy statement that the policies along this frontage would be subject to revision in the future dependant upon the promotion of power station developments.

Policy choice is based on risk and at present the dune system at Haverigg is accreting and according to the EA flood risk maps, the prison is at low risk from flooding from the open coast frontage. As the future behaviour and evolution of the dune system is uncertain, the action plan for this area has included an action to ‘Undertake beach, dune and coastal defence asset monitoring in conjunction with Cell 11 Regional Monitoring Strategy to inform strategy and future SMP reviews’. It is also acknowledged that the EA flood maps used in the SMP2 appear to underestimate flood risks landward of dune systems in some cases and therefore there is another action to ‘Continue with improvements to flood risk maps and inundation modelling’ in this area.

Following review of consultation responses by the SMP2 team including consistency checks against revisions made to policies in similar locations where the future intention is to continue to allow privately fund defences along the frontage, the no active intervention policy at Hartrees Hill has been revised. To allow private landowners to continue to maintain their defences, subject to consent, the policy unit will be extended to include the potential flood risk area to the north and the policy will change to hold the line for the short, medium and long term subject to private funding agreements.

The following revisions to the draft policies have been made as a result of the consultation:

Revise sub-cell boundary to Hodbarrow Point, which means that PU 16.2, Hodbarrow Nature Reserve & Lagoon will become the first unit in the 11d area and the other unit numbers change in 11d 1.

Original unit 11d 1.3 – Silecroft (Hartrees Hill) now extends further north to include the flood risk area and the policies have changed to Hold The Line (0-20 years), Hold The Line (20-50 years), Hold The Line (50-100 years) subject to private funding agreements.

7.4.2 Selker to Eskmeals - 11d2

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

There were significant concerns raised by consultees regarding the Selker to Eskmeals coast where the draft plan was to return to a naturally functioning system without defences or interventions, through a policy of no active intervention throughout. The main responses and queries received are summarised below:

• There were concerns about loss of property at Eskmeals, and the impacts of this on residents. One consultee suggested that as payers of council tax, they could reasonably expect that the local council would protect their property and well-being.

• However, the issue of greater concern to the majority of consultees was the potential loss or realignment of the Eskmeals road. There were a number of issues relating to this:

o Concern was raised regarding erosion of the road which provides access to local properties, Bootle and the MoD range.

o Reesponses assumed that any realignment of the road would be over working farmland and therefore there would be significant impacts on this local business. Many consultees felt that defending the road on its current alignment would be a more appropriate solution than rerouting.

o Impact on the important MoD facilities if the road access was lost, and indirect impact on the local economy. The contributions that the MoD make to Cumbrian economy were quoted.

o There were concerns regarding the timing involved with a plan for road realignment which would requiring planning, agreement, consultation etc. It was felt that the existing road could be lost before the new road was constructed, causing major problems and that short term protection was therefore essential.

• There were also concerns regarding the potential loss of habitat at Eskmeal dunes.

• A number of consultees felt that the consultation had been poorly executed, with a lack of publicity, short time-scale for responses following the Muncaster meeting and the meeting presenter was unable to respond adequately to detailed questions asked, particularly with regard to compensation and funding of relocations.

• MOD indicated that the consultation draft policy of No Active Intervention is not acceptable to them in 11d 2.2 at the area fronting Eskmeals Firing Range. They considered that although there are not any formal defences in this area at present, maintenance of defences for the Range must be permissible for the future because any loss of real estate would be detrimental to the operation of the range and there are hard assets that cannot be simply ‘rolled back’.

SMP2 Team Comments

The draft SMP2 policy for 11d 2.1, which included Stubb Place, was based on previous local studies that had already indicated that in the long term re-aligning the road would be economically preferred in the long term over building coastal defences for the road in its present location. The draft Action Plan therefore proposed that the Highway Authority and the MoD should consider the justification for and appropriate timing for relocation of the road at Stubb Place. However, following review of concerns raised the SMP2 team acknowledges that the proposed further investigations into the practicality of relocating the road will take time and that short term actions will be required to keep the road open in the mean time. The SMP2 team therefore now propose a revised policy of Managed Realignment at Stubb Place, which will allow short term measures to be undertaken to keep the road operational while a longer term solution is developed, which may or may not involve re-routing the road.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

The consultation meeting at Muncaster was arranged at short notice shortly before the end of the consultation period following requests and responses indicating that the proposed additional Silloth meeting was too far away and the potential attendees had not been informed of or able to attend the Barrow meeting in December. Answering detailed questions about allocation of funding for schemes between the coast protection authority, the highway authority and the MoD are beyond the scope of the SMP2 studies and need to be considered formally between the responsible bodies. Defra is presently funding several coastal adaptation pathfinder projects that do include relocation of properties, but it is not certain where national funding may be available in future.

The SMP2 team note the concern raised by the MoD and that although there are no formal defences, beach management activities are apparently undertaken occasionally at Eskmeals Range. As there are no hard defences and the range is integral with and adjacent to the internationally protected habitats of the Drigg Coast and Eskmeals dune system, introduction of new hard defences would require full environmental impact assessment and Habitats Regulations Approval for consent. Although such consents may be able to go through under a case for over riding public interest, if there is considered to be an adverse impact there would be a requirement for compensation under the European Habitats Directive through additional equivalent habitat creation elsewhere. The SMP2 team therefore consider that most appropriate policy, in line with current practice and the existing policy under SMP1, would be Managed Realignment. This would allow present practices to be continued where necessary but would also allow for future testing of options to “roll back” hard assets or replace further inland when they reach the end of their residual lives in the medium or long term. It would also allow for future installation of localised hard defences at essential locations if necessary.

The following revisions to the draft policies have been made as a result of the consultation:

11d 2.2 : move boundary with 11d 2.1 to south of Stubb Place and change whole frontage to Managed Realignment (0-20 years), Managed Realignment (20-50 years), Managed Realignment (50-100 years)

7.4.3 Ravenglass Estuary Complex - 11d3

There was little support for the draft policies in the Ravenglass estuary area. The draft plan is to allow the estuaries to evolve naturally without further intervention. However, risk to Ravenglass itself and the Cumbrian coast railway will continue to be managed. The main responses and queries received are summarised below:

• There were a number of responses regarding how the roads around the estuary already flood regularly at peak tides and need defending or raising now, particularly the main A595 near Muncaster Bridge. Issues were also raised about blockage of drainage and the need for maintenance of defences.

• There were concerns regarding possible abandonment of properties due to flooding and inaccessibility, and whether there was compensation available for relocation of residents.

• There were responses about the consistency of treatment of Scheduled Monuments such as Ravenglass Roman Fort.

SMP2 Team Comments

The no active intervention policy would allow natural evolution of the shoreline and provide space for rollback of saltmarsh as sea levels rise. Continuation of natural processes is beneficial to the international and national designated sites that include the estuaries around Ravenglass. In addition, the SMP2 broad level economic 55

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report assessment for this section indicates that there is unlikely to be sufficient economic justification for new defences other than at Ravenglass. The Roman Fort site has been and still is suffering erosion seaward of the railway and the draft SMP2 Action Plan proposed that the site was considered in more detail to determine if protection or mitigation such as recording should be undertaken.

Although the SMP2 has noted the need for raising the road at Muncaster Bridge the SMP2 only deals with coastal flood and erosion defence management and therefore management of the roads lies with the Highways Authority.

The local authorities and the Environment Agency have powers to undertake flood risk management if they can justify and afford to do so but do not have a legal duty to do so. As there is no right to publicly funded coastal defence there is no provision for compensation from central or local government funds to offset any loss due to flooding or erosion suffered by property and landowners. However, the government is presently undertaking some pilot projects developing coastal adaptation approaches and it is possible that there may be changes in policy in future to promote adaptation or relocation where it is not sustainable or affordable to defend.

No changes to the draft policies have been made following public consultation

7.4.4 Drigg Point to Seascale - 11d4

There were no responses received on the draft policies for this stretch of coastline where the plan is to allow a policy of naturally functioning coastline through no active intervention throughout.

SMP2 Team Comments

No changes to the draft policies have been made following public consultation

7.4.5 Seascale to St Bees - 11d5

There were some concerns raised over the draft policies for the coastline from Seascale to St Bees where the draft plan is to continue to manage risk along the coast from Seascale to Sellafield, whilst promoting a naturally functioning coastline elsewhere whilst monitoring and managing risk to the railway. The main responses received are summarised below:

• The proposed lack of protection for the properties located on the beach at Braystones was of significant concern, including the impact on residents, the effect on the railway since the properties were thought to provide protection to the railway line and the visual impact of abandoning properties and defences in the longer term

SMP2 Team Comments

The draft SMP2 recognises that protecting properties on the shingle bank seaward of the railway is not likely to be sustainable in the long term due to sea level rise. The government is presently undertaking some pilot projects developing coastal adaptation approaches and it is possible that there may be changes in policy in future to promote adaptation and relocation where it is not sustainable or affordable to defend.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

The draft SMP2 allows for monitoring risk to the railway and taking action to extend defences to the embankment if it becomes necessary in future.

The SMP2 team has considered the responses received and the comments made at the meetings. An additional item will be added to the SMP2 Action Plan to develop an adaptation strategy, consider provision of EA flood warnings, clarify responsibility for maintaining emergency access and allow for ongoing liaison with the residents association. In order to facilitate these additional actions and to allow for ongoing local beach management by residents the short term policy will be revised to Managed Realignment.

The following revisions to the draft policies have been made as a result of the consultation:

11d 5.5: Braystones, Nethertown and Coulderton - change to Managed Realignment (0-20 years), No Active Intervention (20-50 years), No Active Intervention (50-100 years)

7.4.6 St Bees - 11d6

There were no responses received on the draft policies for this stretch of coast where the plan is for no active intervention along the undefended cliffs to the south, to allow them to continue eroding naturally, and long term realignment of the St Bees shoreline to enable a beach to be sustained whilst realigning defences to continue to manage risk. In the short and medium term, existing defences would be maintained.

SMP2 Team Comments

No changes to the draft policies have been made following public consultation

7.4.7 St Bees Head - 11d7

There was support to allow the coastline to continue functioning naturally through no active intervention at St Bees Head.

SMP2 Team Comments

No changes to the draft policies have been made following public consultation

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

8 Consultation Strategy and Responses received: Sub-Cell 11e – St Bees Head to the Scottish Border

Figure 7: Map showing the location of Sub-Cell 11e, St Bees Head to the Scottish Border.

8.1 Consultation Strategy Sub-Cell 11e

In Sub-Cell 11e (between St Bees Head and the Scottish Border), we used the following ways to raise awareness of the SMP2 consultation.

Examples of consultation materials including press releases, cabinet reports and meeting minutes are included in Annex B9 .

Website

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Press Notices / News Releases

Allerdale Borough Council issued a news release on 13 th January 2010.

Cabinet Reports

A Copeland Council Executive report was presented to the members on 22 September 2009 regarding the SMP2 public consultation.

Draft SMP2 Documents

Copies of the main Draft SMP2 Document were made available for viewing from October 2009, in the following locations:

• Members Room Copeland Borough Council (CBC)

• Spatial Planning CBC,

• Development Control CBC,

• Millom CBC Office

• Whitehaven CBC Offices (this copy included SMP2 Appendices)

• Egremont Town Hall

Copies of the SMP2 were also available at the following libraries:

• Millom Library,

• Cleator Moor Library,

• Frizington Library,

• Gosforth Library,

• Whitehaven Library,

• Kells Library,

• Mirehouse Library,

• Hensingham Library,

• Egremont Library,

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

• Thornhill Library,

• Seascale Library,

• St Bees Library

• Distington Library.

8.2 Public Events and Stakeholder Meetings

A public meeting was held at The Beacon, Whitehaven on 16th December 2009 which was open to stakeholders and the Public from Sub Cells 11d and 11e. However due to the Cumbria floods in November 2009 the meeting was not well publicised and travelling to the venue from the North was disrupted. Notes from the meeting are included in Annex B9.

A public event was held on 26th January 2010 at the Solway Resource Centre in Silloth. The programme began with a presentation by Halcrow before leading into a question and answer session, followed by an opportunity to browse exhibition material and ask individual questions of project team members. Letters were sent to parish clerks advertising this event. A copy is included in Annex B9.

8.3 Consultation Responses

Responses were received from over 10 residents, businesses, Parish Councils and other organisations. Responses were received in a variety of forms:

• letters;

• consultation response forms (hand written and electronic); and

• e-mails.

Summaries of issues raised about specific areas during public consultation relating to policy are included in the following sections. Annex B14 includes all SMP2 public consultation responses. A comment and/or action taken by the SMP2 team is also included for each comment.

8.4 Area Specific Responses

8.4.1 St Bees Head to Whitehaven - 11e1

There was support to allow a naturally functioning coastline through no active intervention along this stretch of coastline between St Bees Head and Whitehaven.

SMP2 Team Comments

No changes to the draft policies have been made following public consultation

8.4.2 Whitehaven to Workington - 11e2

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

The draft plan is to continue managing flood and erosion risk to the key regional centres of Whitehaven and Workington, and to continue to protect the railway. Where possible, the coastline will be allowed to evolve naturally. The one response received is summarised below:

• Concern was raised regarding the rapid erosion at Parton. There is concern that tidal water would flood through the tunnel under the railway to flood properties and that the railway embankment is at serious risk of tidal erosion.

SMP2 Team Comments

The draft policy of hold the line will allow for continued future management of risks to assets in the village of Parton as well as the railway. However, the responsibility of maintaining the railway defences lies with Network Rail and any concerns raised will be passed on.

No changes to the draft policies have been made following public consultation

8.4.3 Workington to Maryport - 11e3

A limited number of responses were received for this stretch of coastline, where the draft plan is to continue managing risk to the key towns of Workington and Maryport whilst allowing the coast to evolve naturally where possible. The main responses and queries received are summarised below:

• It was queried why there is no inclusion of a County Wildlife Site.

• One consultee raised the issue of the coastline south of the SSSI at Maryport and suggested potential options for management along this frontage and commented on the removal of shingle accumulations south of the harbour entrance at Maryport.

• A consultee who is a significant landowner in the area expressed surprise that the plan had been developed and asked to be included in further consultation.

SMP2 Team Comments

As the SMP2 is a high level document, and covers a large area of coast (between North Wales and the Scottish border) the SMP2 team decided to only include environmental areas designated for their international and national conservation importance. County Wildlife Sites will however need to be taken into consideration during development of more local scale coastal defence strategy plans and schemes.

The draft policies have been proposed to seek the best approach to managing the flooding and erosion risks. The removal of shingle from the beach, if undertaken on a large scale or over a long period of time could increase coastal flood or erosion risks elsewhere. With regards to the hold the line policy between Siddick and Risehow it is not anticipated that the suggested large groynes would be required, however, the detail of how to ‘hold the line’ will be considered as part of strategy plans and schemes.

No changes to the draft policies have been made following public consultation.

8.4.4 Maryport to Dubmill Point - 11e4

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Consultees were concerned with the draft policies in this area. The draft plan is to manage flood and erosion risks to Maryport and Allonby, while allowing the coast to evolve naturally in other locations. The main responses and queries received are summarised below:

• There were a number of concerns regarding the policy of no active intervention in policy unit 4.3 (Maryport Golf Course to Allonby). It was felt that this coastline should be protected due to risk to the road and to the proposed site of a cycleway which would be part of the National Cycle network. The gabions at the Saltpans were thought to be a successful coast protection measure.

• One consultee wished to inform the team of the ongoing proposal for a project to enlarge the water impoundment area of Maryport Harbour, which could potentially lead to the realignment of the River Ellen to the north of the harbour, and an improvement to sediment supply along this coastline.

SMP2 Team Comments

The draft policy for policy unit 11e 4.3 Maryport Golf Course to Allonby is no active intervention. The SMP2 team has reviewed the consultation responses and the proposed policy has now been revised to managed realignment for the short, medium and long term. A hold the line policy was not considered viable due to the need to allow the coast to evolve naturally. Hold the line would also be unlikely to be affordable from national budgets due to the relatively small number of assets at risk of erosion. Managed realignment, however, will allow for the risks to heritage assets, the road and other properties to be managed appropriately through minor short term works, such as the previous use of gabion baskets and adaptation measures.

As part of the SMP2 development the team has taken into account existing development and approved proposals for development that has been approved through planning. However, as this proposal to develop Maryport harbour is in its infancy it has not been considered in the SMP2. If following project specific environmental impact assessment these proposals develop and obtain planning approvals they will be picked up in the next review of the SMP when the current policy of hold the line may need to be revised.

The following revisions to the draft policies have been made as a result of the consultation:

11e 4.3 – Maryport Golf Course to Allonby - changed to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

8.4.5 Dubmill Point to Silloth - 11e5

Limited responses were received for the coastline between Dubmill Point and Silloth, where the draft plan is to maintain the naturally functioning system and preserve the environmental status of the area through no active intervention. The main responses and queries received are summarised below:

• There was concern regarding the change from the SMP1 policy of hold the line to no active intervention, and the impacts on the coastline, local infrastructure and heritage features.

• Another consultee felt that designated habitats and isolated properties at Mawbray should be protected.

SMP2 Team Comments

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

The SMP1 policy of hold the line was only considered to be acceptable as long as no ‘hard defences’ were used due to the importance of Silloth Dunes and Mawbray Banks, which are environmentally designated as Sites of Special Scientific Interest. Assessments as part of draft SMP2 development looked at both hold the line and no active intervention in this location. With hold the line there was concern that hard defences would have an adverse impact on the environmental sites, and under Government Guidance the policy is not likely to be economically justified. It is understood that much of the coastline at present is naturally functioning and relatively stable (although we understand there has been some attempts to stabilise the dunes) and therefore no active intervention was found to be a favourable option. It is recognised that there are assets at risk around Beckfoot including the road and therefore the action plan recommends monitoring of risk to the village and to investigate the case for local flood defences / individual property defences or resilience measures in the medium term or when risk increases.

Due to the small number assets at risk and the need to allow the coast to function naturally, it is unlikely that public money would be available for large scale defence schemes. However, following review of of the consultation responses and additional information received, the SMP2 team now proposed to change the policy to managed realignment for the short, medium and long term. This will allow responsible bodies to manage the dune system for nature conservation, take action to manage risks while relocating the coastal road; and record, relocate or protect historic environment features in the World Heritage Site as necessary where required.

The following revisions to the draft policies have been made as a result of the consultation:

11e 5.1 Dubmill Point to Silloth - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

8.4.6 Silloth to the Grune - 11e6

Only two responses were received on the draft policies from Silloth to The Grune. Here the draft plan is to manage flood and erosion risk to Silloth and its amenities, whilst allowing the coastline to function naturally along the Grune through no active intervention. The responses are summarised below:

• It was queried whether the hold the line policy included replacing the wooden groynes at Dubmill Point, and it was also suggested that the breakwater at Silloth Pier should be replaced in order to provide protection to Grune Point.

• One consultee felt that the lack of protection for the Grune was inappropriate, on the basis that it acts as a natural breakwater by dissipating wave energy and providing protection to Cardurnock and Anthorn.

SMP2 Team Comments

The SMP2 is a high level plan which identifies policies to manage coastal risks but does not go into the detail of how the policies will be implemented in local solutions. The SMP2 action plan has recommended that a local coastal risk management Strategy and coastal process study should be undertaken which should confirm the policies for Silloth to Moricambe Bay (including the Grune), and address the issues of interruption of shoreline sediment transport and investigate future defence options for the frontage.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

The SMP2 team have reviewed the responses and consider that they will be best addressed in the further study already recommended, which will consider the most appropriate approach to deliver the SMP2 Policy. The SMP2 team also recommends that monitoring of coastal change should continue to provide new data to inform future SMP reviews.

No changes to the draft policies have been made following public consultation.

8.4.7 Moricambe Bay - 11e7

The draft plan is to allow natural coastal evolution where possible. However, draft policies of hold the line and managed realignment will be implemented to manage the risk to the majority of property and built assets. The responses and queries received are summarised below:

• It was felt that there are areas with a policy of no active intervention, where managed realignment could be implemented as a more proactive policy.

SMP2 Team Comments

The SMP2 team considered managed realignment at a number of locations in this area during the development of the SMP2. However, in some locations this policy was not considered suitable due to limited economic justification and little short term need for habitat creation. Given that there are already some additional set- back defences in a number of locations, no active intervention would allow saltmarsh to roll back naturally with sea level rise, while still providing some protection landward.

The SMP2 team has reviewed the responses and further information put forward during consultation and the draft policy is now proposed to change to Managed Realignment in a number of locations in Moricambe Bay. This will allow organisations, local land owners and responsible bodies to put in place measures to proactively adapt to future coastal changes. It will also allow opportunities for future habitat creation to be included within the Environment Agency’s Regional Habitat creation Programme where appropriate.

The following revisions to the draft policies have been made as a result of the consultation:

PU 11e 7.3 Wath Farm to Saltcoates including Waver to Brownrigg - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

PU 11e 7.4 Newton Marsh - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

PU 11e 7.5 Newton Marsh to Anthorn including Wampool to NTL - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

PU 11e 7.7 Anthorn to Cardurnock - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

8.4.8 Cardurnock to the Scottish Border - 11e8

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

The draft plan in this area will allow the shoreline to remain or become largely natural in form, allowing a sustainable and naturally functioning coast in the future. However, draft policies of hold the line and managed realignment allowed for managing the risk to property and infrastructure where appropriate. The main responses and queries received are summarised below:

• It was felt that there are areas with a draft policy of no active intervention, where managed realignment could be implemented as a more proactive policy.

• Managed realignment in this [and similar locations] is likely to be in combination with other units that are likely to lose similar habitats, so the SMP needs to consider the needs in combination with these other units.

• There were responses about the consistency of treatment of Scheduled Monuments and the importance of managing risk to the assets of the World Heritage Site.

SMP2 Team Comments

The SMP2 team considered managed realignment at a number of locations in this area during development of the SMP2, however, in some locations this policy was not considered suitable due to limited economic justification and little short term need for habitat creation. For consistency, in these locations the draft policy was for no active intervention for the short, medium and long term, while also allowing maintenance of existing localised private defences. Managed realignment was however, proposed between Demesne Farm and the Metal Bridge (Esk) and between the Metal Bridge (Esk) and the River Sark.

Following review of responses and further information put forward during consultation the SMP2 team now propose to extend the managed realignment policy to include the other areas where the draft policy was no active intervention. This will allow organisations, local land owners and responsible bodies to proactively adapt to future coastal changes and manage risks to the World Heritage Site Features. It will also allow opportunities for habitat creation to be included within the Regional Habitat creation Programme if required in the future.

The following revisions to the draft policies have been made as a result of the consultation:

PU 11e 8.1 Cardurnock to Bowness-on-Solway - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

PU 11e 8.2 Bowness-on-Solway - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

PU 11e 8.3 Bowness-on-Solway to Drumburgh - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

PU 11e 8.4 Drumburgh to Dykesfield - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

PU 11e 8.5 Dykesfield to Kingsmoor (Eden Normal Tidal Limit) - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

PU 11e 8.6 Kingsmoor (Eden Normal Tidal Limit) to Rockliffe - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

PU 11e 8.8 Rockliffe to Demesne Farm - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

PU 11e 8.9 Demesne Farm to Metal Bridge (Esk) - change to Managed Realignment (0-20 years), Managed Realignment (20-50 years) and Managed Realignment (50-100 years).

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

ANNEX B4

General SMP2 Consultation materials

Event Posters

SMP Leaflet

SMP Banners

Stakeholder Letter

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Event Posters

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

SMP Leaflet

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report SMP Banners

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report Stakeholder Letter

OUR REF

YOUR REF

ENQUIRIES TO: MRS F CRAYSTON Email: [email protected]

th 16 November 2009

Dear Sir/Madam,

Invitation to workshop about how to manage the changing coast in your area

Our coastline is changing. It always has and it always will. Waves, tides, wind and storms move sand and sediment around the coast and in and out of estuaries, changing the way that the shoreline looks, works and protects our homes and towns. Climate change and increased use of the coast for homes, recreation and industry will speed up these changes and it is important that we take action now to prepare for the future. To help us to deal with our

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report changing coast and the effects of climate change we need a long term plan to set out how our shoreline is looked after.

Shoreline Management Plans (SMP) identify the best way to manage our coast over a long period of time, taking into consideration the social, environmental and economic effects of different ways of protecting communities and land against coastal flooding and erosion.

SMPs provide evidence and guidance for Local Authorities, the Environment Agency and other organisations to help them plan the best way to look after their coast and consider risks from the coast whilst planning development.

We are currently in the process of creating a new SMP for North West England and North Wales and we need your help to make sure that the information we’ve used and the suggestions we’ve made are correct and appropriate. You can find the draft SMP2 at www.mycoastline.org or in your local town hall.

We will be holding a series of short, informal workshops to give you the opportunity to find out more about shoreline management planning in your area and have your say. Details of venues, dates and times are listed below:

th Monday 7 December, Kinmel Manor Hotel, Abergele, 19:00-20:30

th Tuesday 8 December, Lancaster House Hotel, Ellel, 19:00-20:30

th Thursday 10 December, Kings Gap Court Hotel, Hoylake, 19:00-20:30

th Monday 14 December, Forum Twenty Eight, Barrow, 19:00-20:30

th Tuesday 15 December, Savoy Hotel, Blackpool, 19:00-20:30

th Wednesday 16 December, The Beacon, Whitehaven, 19:00-20:30

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report If you would like to attend one of the meetings please reply to this letter either by sending an email to [email protected] or write to North West England and North Wales Coastal Group, c/o Fiona Crayston, Blackpool Council, Westgate House, Squires Gate Lane, Blackpool, FY4 2TS stating your name, organisation (if appropriate) and which meeting you wish to attend.

We want to make sure that as many peoples views as possible are represented at the workshop – please feel free to forward this email/pass on these details to anybody who you think might be interested but please be sure to ask them to register by contacting Fiona (as above).

Many thanks and we hope to see you there,

North West England and North Wales Coastal Group.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

ANNEX B6 – Sub-Cell 11b

Consultation materials & Meeting notes

Press Releases

Committee / Cabinet Reports

Meeting Notes:

• West Lancashire 23 rd November 2009

• Blackpool 15 th December 2009

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Press Releases

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Cabinet / Committee Report

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Meeting Notes

West Lancashire Shoreline Management Plan (SMP) Consultation Event 23 rd November 2009 Notes

Present: Trevor Dunn, West Lancashire Council Graham Lymbery, Sefton Council Fiona Crayston, Blackpool Council Paul Hatch, West Lancashire Council Richard Shearer, Environment Agency West Lancashire Elected Members and Parish Councillors

GL gave a brief presentation and then there was a round table discussion about the proposed policies.

It was felt that accretion is occurring along the West Lancashire Coastline since the dredging at Southport was stopped.

Policy Unit 1.3 The consensus around the room was that HTL was the correct policy for this length. However MR in the longer term may not be necessary as the shoreline will be accreting.

There were discussions about the scour on Hesketh Outmarsh that seems to be very quick at the controlled breach points, and it was questioned whether this should have an effect on the SMP policy. Also how are the processes in this area going to change with the loss of the training walls in the Ribble.

Policy Unit 1.4 No issues

GL thanked all for coming.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Blackpool Shoreline Management Plan (SMP) Consultation Event 15 th December 2009, Savoy Hotel, Blackpool Notes

Present: Andy Parsons, Halcrow Fiona Crayston, Blackpool Council Jo Marriner, Environment Agency Carl Green, Wyre Council Lee Swift, Environment Agency Andy Shore, Environment Agency Stakeholders including Elected Members, Civic Trusts and landowners, members of public

CG welcomed all and introduced the evening

The members of the project team introduced themselves

AP gave a presentation and then asked for general questions.

Would the new Cleveleys scheme be able to withstand a 1 in 1000 event like the Cumbria floods? CG stated that it has been designed to a 1 in 200 event in 50years time so up to a 1 in 500 event there would be overtopping but it would give quite good protection. It is worth noting that the Cumbria event was a 1 in 1000 event but could happen again.

ATL is rare but it has already been done in Wyre and Blackpool. What impact assessment has been done for those? AP said that at each level in of coastal planning there is an environmental assessment which has much more detail in the studies at scheme level than is contained in the assessments in the SMP.

Is the SMP going to help people who are at risk of flooding and have difficulty getting insurance. CG stated that if a property has 1 in 75 year protection they should be able to get insurance. Schemes now give greater protection than that so it should help but really the insurance companies take it as a business decision. AP added that the SMP doesn’t look at the standard of protection, that will start to be looked at in the strategies and probably wouldn’t be finalised until a scheme is designed.

To what extent is fluvial flooding looked at in the SMP? AP stated that the fluvial flooding is covered in a Catchment Flood Management Plan which is taken into account in the SMP as it was written before it.

CG split the group into tables of geographical areas where a representative from the project team was available to answer more specific questions.

North West England and North Wales SMP2 Appendix B Part 2 – Public Consultation Report

Blackpool Shoreline Management Plan (SMP) Consultation Event Specific Comments Raised

This is a summary report of the specific questions and points that attendees raised whilst in the individual breakout sessions at this meeting. If you feel that your question or point has not been noted, please contact Fiona Crayston at [email protected] . All relevant comments will be considered as part of the SMP review.

Royal Yachting Association Expressed concern at the situation at Fleetwood Marina. Also concerned that RYA had not been invited directly but had to seek information. Letters were sent to RYA at a National and NW region level (Graham Knox) and all letters were sent with a line in that they should be passed on to anyone with an interest.

Wyre Estuary Concern from some in the area about the recent sedimentation trend and wanted to link this to recent schemes on the open coast. It was explained it was unlikely to be due to the new schemes and is likely to be part of a longer term trend of sediment transport which is shown in CETaSS.

There were discussions around planning permission being granted on the flood plain with a proposed housing estate south of Fleetwood.

The erosion rates for Glasson Docks were queried as it is thought they may be underestimated in the SMP.

There was concern about the inspection and maintenance of the sea walls at Fleetwood.

There is an ongoing beach management study and it was questioned when the results were going to be released. There were also questions about the coastal monitoring and it was explained that the data will be available on the Channel Coast Observatory website in the future.

Blackpool-River Wyre The embankment at Pilling seems to be stated as an earth embankment but there is actually rock armour along it as well.

The dykes need to be dredged as the gates in the seawall prevent sediment being washed out and the build up leads to drainage problems. Could this be looked at in the action plan?

It was felt that a Fylde Coast Beach Management plan should be looked at in the Action Plan given the sediment linkages along the frontage.

North West & North Wales Coastal Group

North West England and North Wales Shoreline Management Plan SMP2

Annex B11

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

Ribble Estuary ––– 11b 1 Response Response SMP2 Team Comments Proposed Action from?

Agree to to Agree draft Policies? PCR_3 11b 1.3 Crossens Pumping Station to Hesketh Out Marsh West (Hundred End Gutter) Y Support for draft policy is ack nowledged. Add new item to draft Action Plan for PU 1.3 North Meols Banks Marsh, seawall with The SMP recommends that studies are undertaken in the medium Parish Council reserva term to investigate Managed Realignment opportunities in the long At present, because of EA's assessment of Banks as a high flood risk area with main cause of flooding tions term and implement where practicable. The suggestion of improving inundation through the sea wall, Banks is suffering from both planning and insurance blight. It would the old sea wall as a secondary defence, funding permitting, could be appear that holding the line would maintain this situation, which we cannot allow to continue as the taken forward in the short term epoch and would not compromise residents of the village want to be able to regenerate the village to ensure 'sustainability'. I think it longer term proposed policy. A new item will be added to the draft imperative that the comments made by myself at the meeting be investigated so that the flood risk action plan. assessment can be reviewed and changed to lift the blight. I was discussing the meeting with a parish council colleague and he suggested another option, funding permitting, and that is to rebuild the older There is an action already recommended in the draft action plan seawall as a second line of defence. (Action 11.1) to continue with improvements to flood risk maps and inundation modelling to provide improved flood warning service. PCR_75 11b 1.3 Crossens to Hesketh Outmarsh West Due to the large number of MR opportunities in the Ribble identified No action required in the draft SMP, multiple MR undertaken at the same time may have RSPB - We are unclear why MR is not proposed earlier than the 50-100 years period, especially as HTL significant implications on estuary processes and therefore we have would only protect agriculture land. We would recommend bringing this Preferred Policy forward. recommended a staggered MR approach throughout the estuary. In 11b 1.6 Hesketh Outmarsh East to White Bridge, Rufford some locations MR is the draft policy for the medium term, while in others studies are recommended to take place in the medium term - We are unclear why MR is not proposed earlier than the 50-100 years period, especially as HTL to look at further MR opportunities in the long term. would only protect agriculture land. We would recommend bringing this Preferred Policy forward. Draft Action Plan item 11b 1.1 proposes an estuary wide study to 11b 1.7 White Bridge, Rufford, to Old Railway Embkmt, Much Hoole Marsh (River further investigate and consult on plans for managed realignment.. Douglas right bank) There are also a number of linked studies being undertaken to - We are unclear why MR is not proposed earlier than the 50-100 years period, especially as HTL support the SMP, including a sediment study which will consider the would only protect agriculture land. We would recommend bringing this Preferred Policy forward. implications of large scale MR in the Ribble. 11b 1.8 Old Railway Embankment, Much Hoole Marsh House to Hu tton Marsh (Pilots Cottage) - We are unclear why MR is not proposed earlier than the 50-100 years period, especially as HTL would only protect agriculture land. We would recommend bringing this Preferred Policy forward. 11b 1.13 Freckleton Marsh (Wes t end of sewage works) to Naze Point - We are unclear why MR is not proposed earlier than the 50-100 years period, especially as HTL would only protect agriculture land. We would recommend bringing this Preferred Policy forward. PCR_113 11b 1.12 MR was not considered appropriate for most of this frontage due to Revise mapping not to include creek at Lea the significant area of development in the flood zone along eastern marsh. EA NW This policy unit seems too large to adequately identify managed re-alignment options. The policy of part of the frontage, and the risk of contamination due to the Hold the Line for all three epochs may restrict opportunities to promote wider re-alignment in the Add text to short term policy approach for 11b historic and authorised landfill sites located west of Lea Marsh. vicinity of Lea. Possible options are to split the policy unit or to place further emphasis on localised 1.2: “Investigate small Managed Realignment / opportunities for managed realignment at Lea Marsh It was noted in the Environmental “justification” column of the draft habitat creation opportunity at Lea Marsh and policy statement that there may be localised opportunities for short implement if practicable.” to medium term MR adjacent to the creek at Lea Marsh an action to investigate / progress this was recommended in the draft Action Plan. This can however be further emphasised by additional text to the short term policy & the mapping can be revised not to include the creek.

Ribble Estuary ––– 11b 1 Response Response SMP2 Team Comments Proposed Action from?

Agree to to Agree draft Policies? 11b 1.13 The consultation draft policy does already allow for potential No action required implementation in the second epoch as it says “Manage flood risk by The policy is for managed re-alignment in the third epoch. There may be an economic argument for maintaining existing defences to an adequate standard. Undertake this to be brought forward to the second epoch. This would also promote the potential for Newton studies to investigate Managed Realignment opportunities in the long Marsh as a site for habitat creation, but we accept that stakeholder engagement would be required if term and implement where practicable.” the draft policy is to be changed The SMP action plan recommends that an estuary wide study is undertaken to investigate various Managed Realignment opportunities in the long term and develop plans to implement where practicable to create a more sustainable defence alignment. Include coastal processes and habitats study; stakeholder consultation, more detailed economic appraisal; investigation of options for adapting paths and rights of way to coastal change. 11b 1.14 Following response and follow up discussion with EA NW the policy Revise to the same NAI poli cy for the whole PU has been revised to indicate no active intervention for the full policy It could be argued that the policy here should be no active intervention for the full policy unit. The map unit. allows for re-alignment at Poolstream (Bush Farm Creek in the SMP) but this policy may not be necessary at the time of publication of the plan. Further discussion required. PCR_13 11b 1.19, 1.20, 1.21 Y Support for draft policy is acknowledged. Individual, What work / when to reinforce the dunes & access to the beach areas of St Annes? There are cuttings Local management activities are beyond the scope of the SMP. Lytham St in the defences now to allow this access e.g. bottom of Highbury Rd, St Annes where dunes have been However, we included two actions in the consultation draft Action

Annes flattened to access beach sport shop. Why are these access(es) allowed without flood gates or other Plan to help address these issues: water flow controls? • Revise flood maps to take account of potential for breach of Clear & signed access points through dunes and similar protection to beach? Make these points into the dunes. weatherproof footpaths with duck boards where required so they are likely to be used. • Develop dune management plan to define actions necessary Add “including management of flood risks from Check by manned patrol at times of high tide / storm that floodgates or similar controls are closed (HM to maintain conservation features of dunes whilst providing cuttings and / or access routes through the Coastguard?) natural coastal defence. dunes” to draft action plan item 2.13 Propose to add need to manage flood risk related to access cuttings through dunes. PCR_65 Concerned about land drainage, agricultural land protection. Y Support for draft policy is acknowledged. Adding text to action 1.1 to include ‘Assess needs for intervention to manage land drainage Individual, Facilities for the drainage of inland water into the sea must be made available and maintained. Major in areas where saltmarsh accretion causes Tarleton outfalls are vitally important for land water to discharge from areas behind the embankments. The issue with siltation of outfall channels has been raised in other problems at outfalls’ (as already included in If adequate outfalls are not provided, flooding to the land side of embankments will become a real areas. While it would appear efficient to agree a strategic approach other policy areas throughout the SMP) possibility and a greater threat than inundation by the sea. to managing the issue on the designated sites with Natural England and other stakeholders, this needs to be addressed through an The continued silting of the Ribble Estuary may prejudice the efficiency of land drainage gullies on the Action Plan item from the SMP. seaward side and a programme of regular inspection, maintenance and dredging of these channels needs to be in place. The importance of providing and ensuring the integrity of the outfall drainage channels for the protection of property, including Grade 1 agricultural land, must override any ecological or environmental factors. There can be no compromise on this due to the importance of protecting property and prime agricultural land. PCR_70 11b 1.16, 1.17, 1.18, 1.19, 1.20, 1.21 Y Support for draft policy is acknowledged. No action required Friends of the The shore defence seawall is breaking up. One reason is that trees (e.g. Sycamore) are now growing Fylde BC is, jointly with Blackpool Council, developing a coastal there. The prom railings and slope is old and has not been kept in repair and maintained. The footpath strategy that will consider the long term management of the

Ribble Estuary ––– 11b 1 Response Response SMP2 Team Comments Proposed Action from?

Agree to to Agree draft Policies? Estuary is breaking up quite badly and one area in front of Fairhaven Sand Dunes is sinking. defences. The need to maintain the defences was noted in the draft SMP Action Plan, PCR_79 11b 1.19, 1.20, 1.21 Management activities are beyond the scope of the SMP. However, No action required the draft action plan already included an action to help address this Individual, St Concerned by the lack of management of sand dunes. issue: Anne’s • Develop dune management plan to define actions necessary to maintain conservation features of dunes whilst providing natural coastal defence. PCR_139 11b 1.9 Y Support for draft policy is acknowledged. EA NW, to note the need for more detailed consultation with PDWA. Preston and Preston and District Wildfowlers Association (PDWA) have been in existence since 1953. We have Include the Preston and District Wildfowlers Association as a District 110 full members plus a small number of junior members and around 20 “waiting list” members mainly stakeholder in future strategy / schemes and continue the discussions Wildfowlers from the local area. The Association is affiliated to the British Association for Shooting and regarding Hutton marsh, PU11b 1:9. Association Conservation (BASC), which is a national organisation representing sporting shooting and conservation of wildlife/habitats with over 130,000 members. PDWA own the sporting rights on the tidal saltmarsh known as Longton and Hutton Marshes. PDWA also have 81 years remaining of a lease of the sporting rights on the reclaimed land referred to at Location (Policy Unit) 1.9. We understand from the consultation that this land has been identified for possible managed re-alignment within 0-20 years. PDWA have managed part of this reclaimed land as a non-shooting wildfowl sanctuary area since the land was reclaimed. The area managed has a high conservation status and regularly holds significant numbers of both breeding and wintering wildfowl. In winter months there are often well over a thousand wildfowl present. PDWA also manage the adjacent area of previously reclaimed saltmarsh (to the North East) as a non- shooting wildfowl sanctuary area. As stated above we also own and exercise the sporting rights on the saltmarsh on the other two sides of the reclaimed land. Our wildfowling activities are strictly controlled by both legislation and the rules of the association. Our activities are also covered by a Consent from Natural England as the area concerned is within the SSSI. PDWA therefore already successfully manage and control the conservation and habitat of part of the area designated for re-alignment, and on the salt marsh on three of its four sides. We recognise the environmental (and flood prevention) benefits of returning this area to tidal influence and improving its current unfavourable status. PDWA are actively looking to become more involved in land management and habitat improvement projects (particularly development of new wetland areas), for the benefit of the local community, our members and nature conservation. PDWA are therefore willing (and wish to) be involved in any managed re-alignment of this area of land and to help with its future management. We would be happy to, for example, take on Higher Level Stewardship agreements with Natural England as part of our commitment to manage this area effectively. Natural England officially recognises the value of properly managed wildfowling to conservation. PDWA asks that the North West England and North Wales Shoreline Management Plan SMP2 consultation recognises the long standing and culturally important activity of wildfowling and the sensitive nature of the habitats over which wildfowlers shoot and that we have the opportunity to be directly involved with this exciting re-alignment project.

Ribble Estuary ––– 11b 1 Response Response SMP2 Team Comments Proposed Action from?

Agree to to Agree draft Policies? PCR_174 With reference to Appendix J6 1.2 Sub Cell 11b section H (Hutton Marsh), it is stated that private Response noted Update Appendi x J text accordingly upgrading of sea defences has caused some parts of the SPA to be in unfavourable condition and that it Natural should be brought back under tidal influence. It may be necessary to refer to the timing of the upgraded England work and the designation, to ensure that any work to bring the area under tidal influence is carried out in line with the conservation objectives of the site. PCR_171 iii) The draft recommendations for Sub –cell 11.b1 and the predicted implications of the draft policies Y No action required being adopted in this location are noted. Sefton MBC While there are some predicted negative implications, on balance the implications are broadly positive. The draft recommendations and draft Action Plan are supported. PCR_205 I have been approached by my constituent, Mr Bob Foster of the above address. My constituent would Respon se letter has been sent, directly to MP, indicating that: No action required like to know why Croston in West Lancashire has not been included in the North West England and David Borrow The area at Croston, which Mr Bob Foster queries, is slightly inland North Wales Shoreline Management Plan. MP of the River Douglas and therefore is not specifically mentioned in I would be grateful for your comments on the question my constituent has asked. I look forward to the SMP. However, the area is covered by Policy Unit 11b 1.7 and hearing from you soon. the flood risk to Croston has been considered as part of the evaluation of policies for that unit. PCR_214 The draft SMP on the River Douglas or inland. REMADE (Lancashire County Council) has [proposed Details of the proposed new bridge and scope of design are beyond EA NW to pass comment to Area team. the] disused Southport to Preston Railway Bridge as a new crossing, could this gate be locked to stop the scope of the SMP. The response will be passed on to EA NW, Individual fast flow tides, with a footway on top of the gates. who would be consulted as land / defence owner / manager. Hesketh Bank

St Annes to Rossall Point ––– 11b 2 Response Response SMP2 Team Comments Proposed Action from?

Agree to to Agree draft Policies? PCR_26 Interested in sedimentation and the effects on birds with increased number of residents and tourists Y Support for draft policy is acknowledged. No action required attracted to the seawall. Blackpool & Fylde College PCR_175 Con cerns: Main Document: Page 24: ‘While the preferred policy for many of these areas is to hold the Response noted. No action required

St Annes to Rossall Point ––– 11b 2 Response Response SMP2 Team Comments Proposed Action from?

Agree to to Agree draft Policies? Blackpool line in the long term, there may be a detrimental impact on tourism through loss of beaches at places The SMP has recognised that it is likely to become increasingly Council such as along the North Wales Coast and at Blackpool, where it will become increasingly technically technically difficult to retain beaches with sea level rise in the (Planning) difficult to retain beaches as sea level rise causes coastal squeezes pressures’. – The Blackpool Local future. Therefore the SMP has recommended the need to develop Development Framework (LDF) places great emphasis on the coast and beach as a recreational, a long term beach management strategy along the Blackpool environmental and economic asset, and any loss of beach would have a detrimental effect on the resort. frontage to deal with the long term trend in beach erosion in As part of the LDF, the Blackpool Core Strategy emphasises the vital role the coast will play in the order to maintain the beach as a valuable asset. sustainable growth and regeneration of Blackpool. To ensure the beach remains a valuable asset, we would support future management options to sustain the beach, including the development of a long term beach management strategy. Main Document: Page 27: ‘promote use of the SMP2 recommendations in spatial planning of land use’ – Reference to the SMP2 will be included in the Blackpool Preferred Option Core Strategy.

North West & North Wales Coastal Group

North West England and North Wales Shoreline Management Plan SMP2

Annex B15

General and Draft Document Responses and Comments

1 General Response

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? PCR_1 I am seeking to confirm the status of the SMP2 reports and appendices? The main report is The consultation is considering the draft SMP 2 including all appendices. Update stakeholder lists in Appendix B noted for consultation, some of the appendices are noted for review. Will the consultation Individual Stakeholder lists are given in Appendix B, these will be updated further in the consider revisions to all documents, or just focus on the Policy Actions Plans? final document. The webpage only lists the local authorities and statutory organisations involved in the SMP2 process. I assume other local organisations were also involved, is there a list of these? PCR_9 Just how much notice and how much publicity has been given to t he meeting at King's Gap Public Consultation took place between the start of October 2009 and the 14 th No action required Hotel, Hoylake, Wirral which is taking place even as I type? February 2010. Documents were available to view on the coastal group website Individual, and in libraries. There were a number of stakeholder meetings in December West Kirby I am most certainly interested but have only just picked up news of this on the web sites of a) and these were advertised on the website and in the local press. A balance has The Liverpool Echo and b) The Wirral News both of which date from Wednesday 9th so not to be struck between amounts of notice given as it was considered best not to much time to notice it and arrange to attend! advertise too far in advance. As well as the notices you saw, the meeting was also advertised on local radio. However, the events were primarily to raise awareness and publicise the consultation and it was not necessary to attend the events to participate in the consultation.

PCR_5 The coast is changing. It always has and it always will. TRUE Climate change is predicted to The key focus for the SMP2 is not climate change, it is planning for managing No action required bring about a rise in sea levels, stormier seas and more frequent rainfall, all of which will affect existing coastal flood and erosion risks now and into the long term, taking Individual the way and the rate that our coast is changing. SAYS WHO? THIS OUTDATED THEORY account of current knowledge. HAS NOW BEEN THOROUGHLY DISCREDITED BY MOST LEADING SCIENTISTS APART The global climate is constantly changing, but it is generally recognised that we FROM THE FEW WHO HAVE INVESTED THEIR REPUTATIONS IN MANIPULATING THE are entering a period of change, particularly with respect to rising sea levels, RESEARCH TO TRY TO PROVE THE UNPROVABLE. SEA LEVELS HAVE NOT RISEN AND and the anticipated implications of climate change and sea level rise present a ARE NOT RISING. THE IDEA IS UTTER TWADDLE WITH NO BASIS IN FACT The North significant challenge to future coastal management. The guidance we have to West England and North Wales Coastal Group was set up to bring together experts from work to requires us to consider future sea level rise allowances, and those organisations across the region to look at economic, social and environmental issues and considered in the SMP2 are given in Table C4 of Appendix C. This indicates an suggest the best possible solutions for managing this change in a sustainable way. LEAVE WELL allowance of 988mm of relative mean sea level rise over the 1990 to 2115 ALONE AND SPEND THE TAXPAYERS MONEY ON OTHER, MORE IMPORTANT period in North West England. The Defra allowances give average rates of THINGS. relative sea level rise for 30 year epochs. The allowances increase exponentially between epochs so it is not surprising that evidence for measured sea level rise since 1990 does not yet match the mean rate expected in the first epoch.

PCR_10 I am rather concerned at the way the above "consultation" is being conducted. I can see that it The SMP2 is a technical document. However, leaflets explaining the SMP were No action required will be OK from the point of view of experts and organisations, but for members of the public distributed in libraries and town halls and also at the stakeholder workshops. Individual, - whose views you say you want - it leaves a great deal to be desired. Firstly, the only notice of th West Kirby Public Consultation took place between the start of October 2009 and the 14 the workshop at Kings Gap was a small paragraph on an inside page of the local freesheets a February 2010. Documents were available to view on the coastal group website day or so before the meeting. Many people (myself included) will not have spotted it in time. and in libraries. There were a number of stakeholder meetings in December Secondly, the appendices setting out summaries of what is currently proposed do not open and these were advertised on the website and in the local press. A balance has properly in that they are corrupted and in an extra wide format. Thirdly, most of what is to be struck between amounts of notice given as it was considered best not to written is (perhaps understandably) in rather technical language which many members of the advertise too far in advance. As well as the notices you saw, the meeting was public may find difficult. I feel that if you genuinely want input from the public you should hold a also advertised on local radio. However, the events were primarily to raise well advertised public meeting based around a summary document designed specifically for the awareness and publicise the consultation and it was not necessary to attend the layman. events to participate in the consultation. PCR_113 We know through recent experience that a significa nt review period is required between The Project Management Board is taking this into account and regularly Review programme completion of draft documents and the scheduled publication date. This should be factored reviewing the programme. EA into the schedule for SMP2 adoption and sign-off.

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? There needs to be a clear mechanism to feed back high -level policy and guidance issues to SMP te am to ensure that this is included in the high level action plan. Inclusion for Action Plan Defra / EA National Quality Review Group. We propose that this is done through a generic action in the Action Plan. Linked to the above item, we would like to see a generic action for all partners to contribute Noted Coastal group to devel op a lessons to a ‘lessons learned’ report, to be completed after sign-off. This will help steer future learned report revisions of Defra guidance and provide a useful starting point for officers involved in SMP3! It should address all elements of the project including procurement, project management and consultation. PCR_25 With regard to marine activities in the NW, agree to the draft policies. Y The SMP2 team would like to acknowledge and welcome the support given for No action required the North West England and North Wales SMP2. Royal Yachting Association (RYA) PCR_60 Agree with draft policies for Morecambe Bay and the Kent Estuary Y No action required Morecambe Bay Wildfowlers Association PCR_62 Unfortunately, as you will see below, curators in the NW a re deeply dissatisfied with the SMP2 (Comment sent 23rd Nov 2009) process. There are some very significant methodological issues that need addressing in order English Thank you for taking the time to collate the views of the historic environment to enable people to understand the reasoning behind the preferred policies and to have Heritage & curators. Like you, we are disappointed that the curators in the NW are finding confidence that the judgements have been made in a knowledgeable and thorough way. Local HERs themselves dissatisfied with the SMP2 process. It is certainly not the case that any information that they have provided has been purposefully ignored. They have had the opportunity to provide material, and comment on its inclusion, at Further correspondence: each stage in the process so far. Yes, the consultation documents may well have changed since the comments were made but Please note that the stage we are at now is the most critical stage of the SMP2 obviously the process takes quite a long time. I think some more general difficulties are (1) that development. We need their views and detailed comments on the draft policies people are unclear about responding to a policy that may mean that sites of World Heritage for their specific frontages, and the draft action plan that has been developed to Site status do not necessarily warrant protection and (2) that curators are already extremely manage residual risks. If the curators (or anyone else) consider that different pressed and have ever increasing workloads. I think many people were under the impression policies should be selected, or that policy unit boundaries need to be revised, that your work would include contracting your own historic environment advisor to provide now is the time to tell us. Now is also the time to suggest additional actions to the level of input that is needed. Perhaps this is something that should be considered in future be included in the SMP action plans. SMP rounds. Review NAI policies with potential for Further response: Following detailed review of responses at the end of significant historic environment consultation a number of draft policies are now proposed to change from NAI impacts. to MR, particularly those in the World Heritage site in the Solway. This will allow for further assessment of risks to historical assets and limited intervention to manage risks related to coastal change if justified.

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? 1. Absence of historic environment information The information provided was initially used as a basis for Appendix D, the SEA Environmental Baseline Report. This was originally known as the "Theme As you know the historic environment curators in the NW have tried to engage as fully as review", and the earlier version of this report was circulated many months ago possible with the SMP2 process and to this end have provided you and your team with much and we updated and revised it following comments from stakeholders, including information on significant historic environment assets along the NW coast and have engaged in additional historic environment information that was added at the time. the various rounds of consultation. Responses from curators strongly suggest that people feel Following establishment of the baseline information of features near the coast, the information they had previously supplied has not been taken into account. The inclusion of the next stage of the project looked at coastal erosion and flooding risks that historic environment assets in the tables is extremely uneven. It appears that not all nationally could affect the features. There are several reasons why historic environment and internationally important archaeological sites have been registered despite the fact that features may not be mentioned in the policy tables in the main document: curators made full sets of information available to you. How can people have confidence in the firstly, the tables are a summary of the information in the larger tables in the process when only some historic environment assets appear to have been included in the Issues and objectives tables, appendix E and the SEA appendix I. Secondly, assessment? generally only features where there is a risk of loss due to coastal erosion or coastal flooding over the 100 year period under the NAI scenario appear in these tables. There are many HE features that are near the coast that are not at significant risk and so not mentioned in the policy statements. For example in Appendix G, section 3: Objectives assessment for Whitehaven to Workington (pg 376): We have identified that under NAI there would be potential loss or damage to Old Quay and Old Quay Lighthouse Scheduled Monument (SM) at Whitehaven due to tidal flooding. However, there is likely to be no flood and erosion risk to Parton Fort Scheduled Monument or part of the Hadrian’s Wall World Heritage Site at Parton. Under the 3 policy scenarios tested the Old Quay and Old Quay lighthouse (SM) at Whitehaven would be protected from tidal flooding. We have therefore not mentioned the Parton Fort SM as there is no risk to this under the 3 policy scenarios tested or under NAI.

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? 2. Opaque methodology The methodology is described at some length in the SMP appendices. I am not sure how we can best explain the approach to HE curators other than referring There are significant concerns about the methodology that has been adopted and the them to the documentation, including the SMP Defra SMP guidance and English Review proposed policies in World judgements that have been made. There is a lack of transparency about the methodology and Heritage’s own SMP guidance. If some of them have not seen English Heritage’s Heritage Sites and where appropriate process. Curators do not understand what account has been taken of historic environment guidance, which was launched in parallel with Defra’s SMP guidance we should revise NAI policies to MR to allow assets in arriving at the preferred policies. For example, it is unclear why, if historic make them aware and this may help them to understand the approach and responsible bodies to manage the risks environment assets are to be included as a consideration in SMP, that coastline with sites of what they should expect. related to coastal change through World Heritage Status should have a preferred policy of No Active Intervention. As has been recording, adaptation and limited explained in previous rounds of the SMP exercise, World Heritage status is the highest Turning to your comment on World Heritage sites, the two designated areas intervention where appropriate. possible international designation for HE assets. If WH sites do not qualify for proactive near that Cell 11 coast that I am aware of are the Liverpool Maritime management, what are the chances for sites of national or local importance and what is the Mercantile City area, and the area around Hadrian’s wall. For the former, point of engaging in a consultation with the historic environment sector? proposed SMP policy is to HTL for all three epochs. The Hadrian’s wall site covers a large area of the southern shore of the Solway. The site includes a Trying to balance disparate factors is obviously extremely challenging. Curators feel that, while variety of different shorelines and some of the designated area is saltmarsh, the tables lists social, environmental and economic justifications, considerably more weight seaward of the high water shoreline. Although the channels are mobile and it is appears to have been given to natural environment than historic environment factors. For a high energy environment, the shoreline of the Solway is not predicted to be example, there are areas like ‘Dubmill Point to Silloth’, where the entire environmental section at significant erosion risk. There are however, significant flood risks. relates only to the SSSI site (and advocates allowing natural processes to continue) without mentioning scheduled sites and a Roman cemetery. Undertaking no management is described I agree that the Dubmill Point to Silloth (11e 5-1) SEA impacts table, which as necessary to conserve the environmental status of the area – clearly this does not conserve states “No known impacts on the historic environment” should be more the historic environment! There needs to be an explicit statement of how the various factors specific and mention the assets of the WHS. The proposed policy in all 3 and interests are being taking into account and balanced against each other. The whole epochs is NAI, which is believed to reflect current practice. As you say, the methodology for balancing costs and benefits used to put forward the tables is unclear. whole of the coast is within the Hadrian’s Wall WHS, although the specific scheduled monuments are understood to be set back from the shoreline and

not at erosion risk over the SMP period.

Beckfoot Roman Fort built as part of the northern frontier defences, along the west coast is included in Appendix D (Annex D5, pg 19). Where it is noted that: ‘visible as a slight raised platform, its unscheduled associated cemetery is

the subject of ongoing coastal erosion. It is part of the Hadrian’s Wall World Heritage site and at risk of further erosion’. The cemetery is not designated as part of the SM and therefore has not been included in the objectives assessment. The objectives assessments also does not

mention Beckfoot Fort as it is not considered to be at risk under NAI or the policies tested, which is supported by the NWRCZA: ‘Little of the fort at Bibra/Beckfoot (NY 08964884; SAM CU255; NMR 9087; HER 625C) survives

as surface expression but internal details are still clearly visible on aerial photographs and have been mapped (Fig. 9.11), along with the extensive vicus (NMR9087; HER 626 C) which survives to the north and south of the fort, as

part of the Hadrian’s Wall NMP. The site is situated on a low-lying sloping ground with the highest point on the western edge which overlooks a low till sea cliff. The site is not considered to be at risk of erosion in the near future

however (M. Collins, pers. comm.).’

In the NWRCZA:‘Beckfoot Cremation cemetery (NY 08654850; HER 591 C) is located 400m south of the Roman fort, adjacent to the location of Milefortlet 15. The site has been known about for over a hundred years and was revealed

by coastal erosion. The first excavation revealed a funeral pyre in 1948 (Hogg 1949). Continuing erosion has produced further finds of pottery, wood and metalwork. Whilst the HER states that erosion and shifting dunes have

obliterated the site recent geophysical survey and trial trenching suggests otherwise, with finds of coins and other material. British Archaeology magazine for September-October 2009 records that as recently as June 2009 a complete

pottery vessel containing cremated human bone was found on the foreshore. Coastal erosion in this location has been recorded at over 0.3m a year by English Heritage and milefortlet 15 (mentioned above), may have already been 5 completely eroded.

The site is obviously of enormous importance, particularly given that little is known of the cemeteries associated with the Roman frontier defences and, given the years of erosion, which may have seen over 30m of land lost to the

sea, the site is seen as a priority for further work. The SMP 2 draft policy for this section of coastline is NAI so the erosion of the site will continue

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? 3. Inconsistency and specific objections Where your colleagues notice specific inconsistencies and omissions, please can they let us know so that the documents can be corrected? Several curators noted that the treatment of scheduled monuments and historic environment assets generally is inconsistent. For example, there is no mention at all of the scheduled Ravenglass Roman fort is mentioned in the draft policy statement for 11d 3 monument of Ravenglass Roman fort (Glannaventa), or that part of it is seaward of the railway summary SEA table, and Action Plan, where a study is recommended. The site line, and subject to threat of erosion. In relation to Piel Castle, the ‘built environment’ lists is in policy unit 3.1 and is shown on the policy mapping. This is an area where “ferry slipway and public house” but not the castle. The “Do Nothing” option suggests “beach we were uncertain where to put the PU boundary, as the site could losses likely on SE corner of Island”, without mentioning of the likely damage to the alternatively be included with the Ravenglass frontage PU 3.2, where we have monument. The section 11e 4, 3 advocates letting the defences put in place to defend the recommended a draft HTL policy. According to the draft RCZA report from Medieval saltpans at Allonby saltpans (inaccurately described as Roman) decay and then ARS the site seaward of the railway has been subject to erosion and this is why removing them. These defences are thought to have worked well, and were put in place with we recommended a study, which should consider the risks and viability of the full consent of the interested parties. Curators oppose the presumption of their removal provision of protection and confirm the policy for the next SMP review. and it is suggested that this be reconsidered and the defences maintained and renewed. The draft policy statement for Piel Island proposes a general no active intervention policy for the island, with the proviso that localised defences, e.g. at Piel Castle 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. Section 11e4:3 I suspect you quote is from a pre-consultation draft, because the policy approach in the latest version, as on the website since the start of October, specifically allows for local limited intervention at the heritage assets in the short term (0 to 20 years) and for this to continue over the medium and long term if is sustainable to do so. 4. Presentation We are very disappointed that you consider the layout of the tables unhelp ful. The format was discussed and agreed with the PMB and we believe that most The layout of the tables gives an unhelpful impression, with the advocated management people thought that it was an improvement on the approach used in other proposal being given first with the characteristics of the coast second. It would be preferable SMP2s. This was because it gives a simple explanation of policy and potential to identify the factors that need to feed into the policies first and use these as a basis for management approach, a summary of justification, implications to the SEA identifying the preferred management. receptors, and a draft list of actions that need to be undertaken to help put the proposed policies into practice. PCR_86 Broadly agree with draft policies Y The SMP2 team would like to acknowledge and welcome the support given for Make reference to the Marine and the North West England and North Wales SMP2. Coastal Access Act in the main Cumbria Local Complete lack of reference to Marine & Coastal Access Act introducing access along entire document. Access Forum coastline. (CLA) PCR_100 We are aware your SMP process has been out to consultation, a process we embrace and in The SMP2 team would like to acknowledge and wel come the support given for Add to high level action plan the need which we welcome the chance to participate. Whilst we do not have any specific comments the North West England and North Wales SMP2 and the helpful clarification of to have early discussions with the The Crown we have prepared the enclosed briefing note which we would be grateful if you would take the Crown Estate’s position in the briefing note. Crown Estate for any proposed Estate into account when collating information and making decisions on policy and forward to anyone managed realignment sites.

that might be connected with the decision making process. PCR_114 BASC are grateful for the opportunity to respond to this consultation and look forward to The SMP2 team would like to acknowledge and welcome the support given for No action required working with the North West England and North Wales Coastal Group as the process moves the North West England and North Wales SMP2. British

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? Association for forward. Shooting and BASC was founded in 1908 as the Wildfowlers Association of Great Britain and Ireland and is Conservation the UK’s largest shooting association. BASC is constituted as an Industrial and Provident (BASC) Society and has a membership in excess of 130,000. BASC is the representative body for sporting shooting in the UK and the largest fieldsports organisation . It aims to promote and protect sporting shooting and the well being of the countryside throughout the UK and overseas. It actively promotes good firearms licensing practice, training, education, scientific research and practical habitat conservation. BASC believes that all who shoot should conduct themselves according to the highest standards of safety, sportsmanship and courtesy, with full respect for their quarry and a practical interest in wildlife conservation. BASC’s expertise in shooting matters is widely recognised and it is routinely consulted by a variety of government departments and agencies (including the Home Office, Defra, LANTRA & The Health and Safety Commission) and other statutory and non-statutory bodies. BASC represents approximately 165 affiliated wildfowling clubs in the UK with a total membership of around 15,000 individuals. Wildfowling clubs manage more than a quarter of a million acres of land (104,000 hectares) in the UK, 90% of which is designated as Sites of Special Scientific Interest (SSSI). In England, Wales and Northern Ireland BASC affiliated wildfowling clubs lease some 700km of foreshore from the Crown Estate. Increasingly, wildfowling clubs are buying farmland that had previously been drained to allow farming. These areas are now being returned to wetland for the benefit of wildlife and quarry species. This complements Environment Agency managed realignment schemes and flood risk management. Wildfowling is the pursuit of quarry species of ducks, geese and waders with a smoothbore gun, principally on estuaries and coastal marshes, but also on large wetlands further inland. Wildfowling is usually a solitary activity and in England and Wales takes place from 1st September to 20th February on the foreshore and ending 31st January inland. Wildfowling is a recreational benefit for local communities and wildfowling clubs provide a focus for wardening of land, monitoring of wildfowl and habitat protection and improvement. The Birds Directive (1979) fully recognises the legitimacy of hunting of wild birds as a form of sustainable use. Wildfowling is an activity that provides significant social, cultural, economic and environmental benefits in the UK. Management of the wildfowl resource by local communities is integral to the management of wildlife on our coasts and an important aspect of our coastal heritage. Land managed for wildfowling often plays an important role in local flood management risk strategies and wildfowling clubs are well placed to deliver continued benefits to such strategies, especially in the management of land involved in managed realignment projects. Wildfowling clubs manage land involved in Environmental Stewardship and Higher Level Stewardship schemes. BASC encourages more clubs and members to participate in such projects. We recommend greater empowerment of local communities in the management of land as a long-term strategic benefit to flood risk management. As stated, many clubs undertake conservation work on the land on which they shoot, actively participating in Environmental Stewardship schemes for example, and undertake regular litter removal and clean-up work on the coast. Natural England (NE), which is the statutory conservation agency for England, recognises the value of shooting to conservation. BASC recognises the importance of the coastal environment and the need to balance different user needs. The North West England and North Wales Shoreline Management Plan SMP2 consultation should recognise the long standing and culturally important activity of wildfowling and the sensitive nature of the habitats over which wildfowlers shoot. In 2004, an estimated 2.6 million work days were undertaken on habitat and wildlife management as a result of sporting shooting in the UK. This is the equivalent of 12,000 Full

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? Time Equivalent jobs. As a result of sporting shooting, £250 million was spent on conservation activities and that shooters themselves contributed 2.7 million work days, the equivalent of 12,000 full time jobs. £8 million alone was spent on tree planting. The total value of sporting shooting to the UK economy in the same year was £1.6 billion. (Source 2006. PACEC. Economic and Environmental Impact of Sporting Shooting in the UK. Available online at www.shootingfacts.co.uk ) , Given this level of involvement, we hope that developing policy will recognise the important contribution shooting makes to the environment, and that the activities of those involved will not be inadvertently restricted. BASC acknowledges the visions outlined in the consultation document for North West England and North Wales Shoreline Management Plan SMP2. BASC believes this process complements existing government coastal initiatives which BASC and its members are actively involved in at national and local levels e.g. Marine Bill, Coastal Change Policy, Natural England and Environment Agency programmes. PCR_118 I have been a fisherman in Morecambe Bay for most of my 55 years and can trace the same job The key focus for the SMP2 is not climate change, it is planning for managing No action required back through my family for 200 years at least. existing coastal flood and erosion risks now and into the long term, taking Individual, account of current knowledge. Flookburgh This is a fact. Within Morecambe Bay the movement of the channels can represent a more The sea levels have not risen by one single millimetre and the rivers running into the Bay are significant short and medium term challenge to coastal defence management less full than they have ever been. and flood defence than sea level rise. We need to plan to manage our coastal Erosion will continue as it has for millions of years but nothing is going to happen in the next defences irrespective of sea level rise. hundred that warrants your wasting tax payer’s money so get off the case. The global climate is constantly changing, but it is generally recognised that we are entering a period of change, particularly with respect to rising sea levels, and the anticipated implications of climate change and sea level rise present a significant challenge to long term coastal management.

PCR_149 NFU Cymru represents a significant number of farms in the shoreline management plan area running from Great Orme to the Dee Estuary. NFU Cymru We note the support given by NFU Cymru to Hold the Line policies. As an organisation representing farmers, NFU Cymru's number one priority is to prevent flood

damage to agricultural land farm buildings and farmhouses.

We could not accept a situation whereby there is an automatic presumption that agricultural land can be sacrificed to protect new (and existing) urban developments.

NFU Cymru believes that the importance of local participation in flood management issues The weight that is given to farmland in flood and erosion risk management Add further consideration of policies in should not be understated. Indeed, local stakeholders and individuals affected by published appraisals has increased very significantly over the last few years. The approach relation to food security and the policies and possible schemes should occupy a prominent position in any decision-making to assessing the national economic value of farm land has changed to reflect the importance of agricultural land to the process. Local knowledge of past history and landscape is too often ignored and the changes in agricultural subsidies. Previously, the approach was to take the SMP2 action plan. experience of local people is a valuable source of information that should be encouraged and economic value as 45% of market value. This has now changed to market value indeed relied upon. So whilst we welcome a commitment to consult with ourselves this must less £600/ha. Market values have also substantially increased and these land extend to our local network and show a real commitment to taking into account those views. value increases have been included in the SMP economic assessment, which uses land values varying by agricultural land classification, but typically of the It is also appropriate for us to highlight that a sustainable productive agricultural industry is order of £13,000/ha. critical. Disappointingly this has often been undervalued here in the UK. However things are changing and it has been quite noticeable how quickly the issue of food security, even its We agree that the importance of food security has changed recently, and there availability has 'climbed' the political ladder in the last 12 months. have been a number of comments received reflecting the importance of agricultural land. Clearly as our population increases and our diet evolves together with changes in climatic conditions coupled with other factors, we here in the UK will become increasingly dependent on our agricultural land, not only for our own ability to produce food but for energy resources

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? also. NFU Cymru policies and priorities In the final version of the SMP2, we will propose a high level action plan task for further consideration of the implications of land use change related to SMP2 We firstly outline some general points of principle that NFU Cymru regard as being central to policies. This could be taken forward with the Environment Agency’s any shoreline management plan. developing Regional Habitat Creation Programmes or at national level. - Our number one priority is to prevent flood damage to agricultural land.

To this end, we firmly believe that existing defence structures should be maintained, which is

often a cheaper option than new capital investment schemes - a fact that is often overlooked.

That increased spending will be required to maintain current flood defences and the Government and its agencies must acknowledge, not just the requirement for further resources, but also their responsibility to mitigate the negative effects of flooding and protect

both industry and the public.

- There must not be an automatic presumption that agricultural land can be sacrificed to protect new urban developments. If flood storage areas are sought, or flood mitigation actions are to be reduced then full and proper consultation must be conducted and full and proper

compensation must be paid through good discussion and agreement.

Strategies should recognise the importance of agricultural land. Agriculture is a commercial interest but for some reason it is not afforded the same consideration as, for example, industrial and commercial concerns - these are usually within built up areas and are therefore

reasonably well protected. Agricultural land, often purchased through a mortgage, is a capital asset of a business. Those outside of agriculture seem unwilling to accept or simply fail to grasp that agricultural land has an economic as well as environmental value, and its future affects

individuals, families and livelihoods.

The true value of agricultural land is its market price and this is not recognised or taken into full account in scheme appraisals. This view is once again, portrayed in the Shoreline Management Plan 2 - which disappointingly fails to acknowledge agriculture as a key policy

driver in setting out future options for the relevant policy units. This must be corrected.

- Clearly, it is absolutely vital that the SMP acknowledges the true cost to the UK economy of annual flooding of agricultural land. This is even more important as global commodity prices rise and food security and even food availability become a concern. It should be accepted that

generally there is a gross underestimate of the true annual costs of flooding to agriculture which we contend is far in excess of current DEFRA and WAG estimations. - Landowners are being asked to contribute to mitigating the effects of flooding on society by accepting floodwaters onto their land to protect people and habitats. Full and proper

compensation must be paid in return for this service to society. Land is a farmer's investment in his business and in his and his family's future and any compensation must therefore properly reflect the actual value of the farmland.

Agriculture

- Flooding of farmland is often viewed as a minor problem for those unaffected but we would

like to highlight that in the main standing water is not 'good' for productive farmland, it will lead to ongoing crop losses and long term damage to the soil. It is also a common misconception that farmers insure their crops and will therefore be making insurance claims to offset their losses. This is not the case as most insurance companies will

not insure standing crops. This of course could be the reason behind the lack of data on actual economic losses arising from the flooding of agricultural land. Questions then arise as to whether land will be eligible for the Single Farm Payment, whether it will conform to requirements of Good Agricultural and Environmental Condition under the

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? cross compliance element of Common Agricultural Policy. Coastal defence budgets should be increased. Maintenance of existing sea walls tends to be Much of the north Wales coast is low lying and susceptible to tidal flood risk. neglected at the expense of capital projects. There should be a continuing commitment to Due to the inter-connected flood risk the over-arching SMP2 draft policy for existing defences which can be maintained for relatively modest funds. north Wales is to hold the line. There are limited areas of proposed managed realignment in the Clwyd and Dee that will be considered further in coastal Conclusion defence strategies. A sustainable productive agricultural industry is a critical asset for the UK and will become

increasingly so. The 2010 Oxford Farming Conference has heightened this view as Government realise that food security is a major issue at present and has openly stated that farmers will have to produce more from the land that we have in the UK. Therefore, increasing flood activity on land which is highly productive goes against Government policy. As usual, agricultural appears to have been dismissed as unimportant. We would argue that there needs to be an estimate of the acreage at risk in each policy unit and what is produced of this acreage. We do, however, hope that the Hold the Line approach allows for existing defences to be maintained, repaired and improved over time to allow the agricultural land at risk in this Plan to remain as productive land as food and energy demands increase. Farming may be prepared in the light of consultation to be part of a solution but not the solution PCR_190 The NFU in the North West welcomes the opportunity to comment on the draft North West Response noted, also see response to PCR_149 above. and North Wales Shoreline Management Plan (SMP). We represent 6,500 Farmers and NFU Growers and see our role in this process as critical to its success. In addition it is of the utmost importance that farmers and growers are also directly involved as it is they who will almost certainly see their day to day business affected by any changes to the current Add further consideration of policies

management of the shoreline along our coast. The economic, social and environmental proposing land use change in relation contribution made by this land based sector must receive serious consideration when deciding to food security and the importance of on long term strategies and policy for coastal management. agricultural land to the SMP2 action plan. There are similar issues of concern for our members wherever their businesses are located

along the coast from Great Orme’s Head to the Scottish Border. For this reason we feel it’s appropriate to respond generally to the document.

General comments

The NFU and its members view the Shoreline Management Planning process with a great deal of interest. During this consultation process it is clear that confusion has arisen, amongst the

membership, in relation to the role that the SMP will play in management of coastal processes over the next century. We understand that this is a high level, strategic document that will set This is correct, thank you for assistance in this process. the policy direction as opposed to outlining specific projects at locations along the North West

coast. We will endeavour to make this clear to members in continued communication following the conclusion of this consultation.

On that note however it is crucial that when projects are being considered within the next phase of planning that the membership are the first port of call when projects are being Noted. We will make the coastal group aware of the importance of early developed. Too often public organisations overlook the fact that agricultural land is a business involvement of NFU to represent farmers and landowners. asset which must be treated, now more than ever, as a precious commodity. Farm businesses will move to protect that asset, if it comes under threat.

However we welcome the forward look that the long term nature of the SMP affords. This

should allow adequate time to adapt and mitigate to the effects of the changing climate as well We note that in England, the Defra “Food 2030” strategy launched in January as the impact which natural coastal processes have. 2010 and so was not available to be taken into account when developing the With the publication of ‘Food 2030’ in January 2010, Defra have for the first time in almost 60 SMP2 consultation draft documents ready for the start of the consultation years formally recognised the value of the agricultural and horticultural industry’s primary period which commenced in October 2009. There is a proposed action in 10

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? products. “Food 2030” to improve methods for valuing e cosystems through “ Applied research looking at how food production and consumption in the UK links to the value Food security, it seems, has finally taken a step up within Defra’s estimation. The document of ecosystem services principles for decision-making which help in considering whether sets out the steps the government feel will need to be taken to produce more food without to convert land or intensify food production in the UK based on a proper assessment unnecessary damage to natural resources, against the back drop of climate change whilst of costs / benefits based on ecosystems services ”. We will propose in the final improving food safety. version of the SMP2, a high level action plan task for further consideration of Given this back drop, the SMP must now recognise the role the North West has to play in the the implications of land use change related to SMP2 policies. This could be increased demand there will be for locally sourced food and energy. British agriculture is well taken forward with the Environment Agency’s developing Regional Habitat placed to deliver both these requirements. Creation Programmes or at national level.

In order to allow the industry to respond to this challenge we suggest that the objective which suggests the minimisation of coastal flood and erosion risk to agricultural land and horticultural

activity is amended to read; Response noted. However, the SMP objectives were set, following consultation Action for coastal group to consider o To maintain the productive capacity and biodiversity benefits of farmland and the countryside with stakeholders in 2008. As we have developed and consulted on the draft this in strategies in future – or produce At present the strategy fails to adequately recognise the importance of agricultural land. There plan it is difficult to change objectives now. However, this could be taken into guidance for strategies? is an automatic assumption amongst national and some local stakeholders that a defence on an account in setting objectives in the more detailed strategies that will follow on undeveloped stretch of coast could be realigned or in the worst case scenario abandoned, with from the SMP2, and in revisions to the plan at SMP3. the resulting creation of new wildlife habitat because ‘there is nothing there worth protecting’. This is not correct as land values are used in flood and coastal erosion risk Agriculture is a commercial interest but is not afforded the same consideration as, for example, management planning at all levels – i.e. SMP / Strategy / Scheme. However, it is industrial commercial concerns which are usually in suburban areas and therefore reasonably true to say that the capital / write off value /ha will generally be less for well protected. agricultural land than urban, and this reflects the potential for prioritisation of Agricultural land, often purchased through a mortgage, is a capital asset. There seems a general future taxpayers funding for defences. unwillingness to recognise that agricultural land has an economic as well as environmental

value, and that its future use affects businesses and livelihoods.

The use of flood or coastal plain in order to alleviate flooding in rural areas, in cooperation

with land owners, may offer an effective way to utilise the capacity of land to accommodate

excess water. If it is to be proposed that landowners contribute to mitigating the effects of Response noted. There are many examples of such compensation for flood flooding by accepting floodwaters onto their land to protect people and habitats, adequate storage areas. financial compensation must be payable in return for this service to society. This land is a

farmer’s investment for the future and any compensation must therefore reflect the capital value of the farmland.

The NFU accept that in the current economic climate in the UK there is little prospect of

improvements to some sea walls, but are keen to see a range of engineering and non- engineering measures used in concert to manage flood and coastal erosion risk. There should We suggest that NFU take this up at a national policy level, as prioritisation of be a continued commitment to existing defences which can be maintained for relatively modest funding cannot be dealt with in this consultation. sums. Maintenance is currently being pitted against investment in capital projects as a result of

government policy; this seems at odds with the priorities outlined within ‘Food 2030’. The imbalance needs to be considered urgently.

The NFU also accepts that managed realignment will play a part in achieving sustainable flood Response noted. Following this and other comments from other stakeholders a defence. Where realignment does take place, it needs to be planned and managed; not left to number of proposed policies have been revised from NAI to MR to allow for a be determined by chance wherever the defences happen to fail. more proactive approach to be undertaken by responsible bodies.

So in summary the key issues of concern to farmers and land managers are as follows; o Sufficient flexibility from the SMP is required to allow individual land managers to manage The SMP is non-statutory and does not over-ride rights, powers or duties in their land and business assets irrespective of over arching policies legislation. Action for RHCP managers to consult o There must be a mechanism which facilitates long term, meaningful cooperation between The Environment Agency is developing Regional Habitat Creation Programmes with NFU in order to develop local land managers and the agencies to find local solutions to local issues and so we suggest that the proposed mechanism should be developed through solutions. that programme. o Meaningful and genuine consultation is critical where, for example, realignment projects are being considered

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies?

PCR_191 Thank you for the acknowledgement. It reads as if the sta keholder engagement henceforth is Comments sent by Blackpool: to comprise your decision reported on the web - hardly in accordance with conflict resolution Individual The response I gave is a standard response and, as you point out, is to acknowledge guidelines as issued by DEFRA. Where there is controversial policy change proposed in the receipt of comments. It states that the consultation report will be written and put on Plan I would expect the CSG to set-up a meeting with relevant representatives including the the website as I believe for some of the comments received this is all that will be Plan consultants to attempt to address the concerns conveyed. The impression to be gained by needed. However as you point out consultation is two way and in many areas this is stakeholders at present is one of 'Big Brother' rules. I should be grateful for your reassurance already going on with local meetings and responses to initial comments. that this is not the case and on how the CSG intends to deal with objections to policy proposals from the 'Little Guy' in accordance with Government guidelines on conflict This is in addition to the wider public meetings that were held in December and resolution. January. We are holding some internal meetings next week to discuss how the comments received to date need to be dealt with and how they will effect the plan. I fully expect that actions coming out of those meetings will include holding specific meetings or giving specific responses to the majority. I have stayed away from putting this in the standard response as it will inevitably be different at different places. PCR_228 I attended a meeting in Morecambe Town Hall recently, regarding the above plan, after having Public Consultation was originally programmed to take place over a three read about it, by chance, in the local press. As we received no official notification at the start of month period, from the start of October 2009 until the 31st December 2009. Lancaster Port the consultation, or for any of the subsequent stakeholder meetings, we have not been given However, issues with uploading the draft SMP2 documents onto the Coastal Commission the opportunity to study and comment on the plan. On further investigation, I discover that Group website and delay in production of leaflets resulted in a decision by the the Lancaster Port Commission, a Competent Harbour Authority who are landowners in the Project Management Board (PMB) to extend the consultation period by a Lune Estuary, and whose harbour area extends along the coast from Knott End to Lancaster couple of weeks to the 10th January 2010. and from Lancaster to Sunderland Point, was not included on the list of invited stakeholders An unforeseen fluvial flood event in Workington in December 2009 meant that for the original consultation, and indeed have still not received any communication on the the consultation event arranged to take place in Whitehaven the same week matter. I find this perplexing, especially as you consulted my predecessor during your original had to be postponed. To accommodate this, the PMB agreed to extend the information gathering stage for the plan. I was led to believe at the meeting that the public consultation period by a further month, until the 14th February 2010. consultation period has been extended until the end of March. Is this indeed the case, as I understand that there were several other prominent omissions from the original consultee list? Concern was expressed at a number of consultation events held in January Perhaps it could call into question the validity of the plan as a whole if it is evident that the 2010 that stakeholders would not have sufficient time to respond to the required consultation process has not been performed competently and comprehensively? consultation, especially where there were contentious issues which would require further information and / or meetings to be held. A request for a further extension to the consultation period was discussed by the PMB and as a result stakeholders in ‘contentious’ areas were given until the 31st March 2010 to finalise their responses. PCR_75 Climate change, coastal squeeze, Natura 2000 sites and the Habitats Regulations. The support of the RSPB as member of the environmental sub -group of the SMP2 Project Management Board in assisting in development of the SMP2 is RSPB The RSPB supports management of the coastline that allows natural processes to function acknowledged. wherever possible. We believe this will be especially important in light of the latest climate change predictions, and their associated impacts on sea level rise and coastal squeeze. The UKCP09 projections were not available at the start of the project in 2008 and so the assessments have been based on the Defra 2006 guidance. It is Coastal management polices such as No Active Intervention and Managed Realignment offer noted that the guidance used, which makes allowances of almost a metre of sea significant opportunities to allow natural processes to prevail and to address climate change Coastal Group Action to Consider level rise over the 100 years, is almost twice the 50% probability (i.e. most impacts. RSPB is also supportive of using natural habitats such as dunes and saltmarsh, as implications of UKCP09 on the SMP2 likely) projection increases from UKCP09 of less than 0.5m over 100 years. natural flood defences. Opportunities for creation or better management of these habitats policies. should be sought. Support acknowledged. Following detailed review of responses at the end of consultation a number of draft policies are now proposed to change from NAI Much of the NW England and North Wales coast is important for wildlife, including to MR. This will allow for further assessment of risks to historical assets and internationally important populations of waterfowl such as pintail, oystercatcher and knot. In limited intervention to manage risks related to coastal change if justified. recognition of this importance, large sections of this coastline are designated under the EU Birds and Habitats Directives as either Special Protection Areas (SPA) or Special Areas of Conservation (SAC). These sites make up the Natura 2000 network, and the UK government

is committed to ensuring that the integrity of this network of sites is maintained.

Coastal squeeze and resulting habitat loss pose a real threat to these sites, and the SMP 12

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? process therefore provides an opportunity to identify coastal management solutions that can We propose to add high level items to the SMP2 action plan to take these create new habitat to maintain the coherence of the Natura 2000 network – this would need items forward, although in terms of mitigation or avoidance rather than Add action to high level action plan. to be accompanied by studies into the rate of loss of Natura 2000 sites and habitats, and be “Compensation”. linked to both BAP habitat targets and compensation requirements within the Regional Habitat

Creation Plan.

With regards the Regional Habitat Creation Plan, and compensation requirements relating to the SMP2, we believe that the various Action Planning tables, e.g. Tables 3 and 4 (pages 29-31), Actions for spatial planning and Further Actions, and those relating to the Preferred Policies

within each Unit, must identify the need for an action to identify habitat compensation opportunities. New coastal management proposals could also constitute a threat to Natura 2000 sites, and

therefore need careful consideration. Provision for this is provided under the Habitats The draft Appropriate Assessment recommended that the more detailed Regulations, which require the competent authority to undertake an Appropriate Assessment strategies and schemes will require more detailed HRA, and this is already of any plan or project that is likely to affect a Natura 2000 site. included in the action plans. Consultation -

The RSPB recognises the need for consultation with all stakeholders, and especially with

landowners and communities who will be faced with changes to the management of their coastline. Early and open dialogue will be necessary, with clear strategies in place to help these landowners and communities adapt to the changes that they face.

We remain concerned therefore, that in the first time period being considered by the SMP2

(0-20years), an apparent default policy of Hold the Line (HTL) is being suggested, even where future policies are likely to recommend No Active Intervention (NAI), or Managed Realignment (MR). This appears to us to conceal the likelihood of future NAI or MR options

being pursued in these areas. It misses the opportunity to use this current SMP review as the

start of the consultation process on the NAI or MR options. It will therefore fail to set in place

from the outset the right framework for the consideration of the more progressive options MR is recommended in this location in the draft plan in the medium and long No action required that will be necessary in the future – for example, Policy Unit 7.4, Runcorn to Arpley, we term. We have acknowledged that MR could be possible earlier and have believe there are several safe opportunities for MR with no need to wait until the 20-50 year therefore added that where practicable implement Managed Realignment within time period. the first epoch . Furthermore, delaying a policy such as NAI on uneconomic defences would run contrary to

Defra and the EA’s stated policy on such defences (http://www.environment- agency.gov.uk/static/documents/Leisure/maintenance_1830292.pdf) – where, once notice has been served, a delay of around 2 years might be expected, not 20 years.

Where the HTL default has been set in the first time period, the text accompanying each

Policy Unit does make it clear that during this period early consideration and investigation into NAI or MR will be made – we understand that this may mean opportunities to pursue these policies come forward sooner than the second time period (20-50yrs). The Action Plan for

each Policy Unit reflects the need to undertake these investigations, which we welcome.

While we are still concerned by the adoption of this default, and we would argue against this for the reasons outlined above, we welcome the inclusion of the explanatory text (about consideration of future NAI or MR policies). We believe this is crucial, to ensure the likelihood

of these options being pursued is not concealed from communities and stakeholders. Response noted and support for policies acknowledged. We understand that Broadly speaking, we support the adoption of NAI or MR for those Policy Units where these policies can and will change as new information becomes available, the more are proposed as the Preferred Option. detailed strategies will use a more accurate time plan than the 3 epochs used in the SMP2. At SMP3 the more detailed work from strategies can be used to refine timing of proposed changes to approach. PCR_113 Where opportunities have been identified for managed realignment/ retreat these should be Response noted Update the draft SMP2 documentation investigated further. It may be possible to feed actions into local wetland creation schemes to make stronger links to the EA’s 13

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? EA NW which are currently being carried out in the Morecambe Bay area Th e SMP team propose to update the draft SMP2 documentation to make Regional Habitat Creation Programme. stronger links to the EA’s Regional Habitat Creation Programme. It is accepted that managed realignment may only be possible in the longer term due to stakeholder pressures. However, it is important that potential sites are considered and publicised to stakeholders to make sure these options are possible and have support. When further studies and assessments are made for MR the Area Biodiversity teams would welcome the chance to comment on these in terms of potential habitat creation and biodiversity benefits. The Area Biodiversity teams would like to view any Appropriate Assessments for Habitats Regulations carried out for any sites along Morecambe Bay SPA, SAC, RAMSAR (This is one of the purposes of establishing the SMP2 Environmental Sub-Group). PCR_194 1. T he document fails to adequately link the SMP with the CFMPs which have already been The CFMPs were reviewed and have been taken into account. However, We produced could explain better how SMPs & CFMPs link up in general terms in the main Explain CFMP / SMP links better in the CCW SMP report. main document 2. The issue of maintenance of the beaches in relation to the hold the line option chosen for The consultation draft SMP2 proposed a study of sediment transport and beach most of the open coastline is not adequately addressed. The beaches are the first line of management for the north Wales coast. We can make this firmer by turning it Revise action plan item to show defence and also of key recreation importance and the raison d’etre for the coastal into an action to develop a beach management strategy for North Wales. commitment to developing a strategy communities. However sea level rise will cause their increased erosion and loss and will also for beach management rob some of the areas nearer the Dee estuary of their natural sediment supply. The SMP as a key strategic document should be providing clear advice as to how this should be addressed at a strategic level. 3. The sustainability of the hold the line option adopted over the longer term should be more Similar comments have been made by EA Wales, and we propose to include Revise items in high level action plan. clearly addressed particularly as the Welsh Assembly Government has a statutory remit in this stronger commitment to the “New Approaches” strategy and tackling risk by area. We have concerns that holding the line in the longer term, even if the same level of warnings, resilience and development control. protection is given, will be associated with increased consequences of flooding and this is not adequately defined and addressed. General

1. As the document is extremely large it is not surprising that there are many spelling errors Correct mistakes and spelling errors and missing words in sentences within the documents. Welsh place names seem to be We will correct the specific mistakes identified. throughout. frequently spelt differently i.e. Rhyll/Rhyl; Foryd/Forydd. There are also factual errors in some sections for instance Traeth Pensarn SSSI has been identified yet in Appendix G 4.1 (G406) it states that there are no conservation designations present. Additionally some described features are still in the wrong policy unit. PCR_194 In our opinion there needs to be recognition that certain factors need to be given higher Yes in Response noted. In response to points from the EA’s national review team we weighting than others because of the importance attached to them. Consequently areas part to have proposed to highlight the important factors or potential showstoppers. CCW recognised as of being more than national importance need to be given greater weighting than policies those of more local interest. Additionally certain features are readily recreatable if necessary elsewhere and should not be given as higher weighting therefore - these include golf courses and cyclepath/footpaths. Alternative cyclepaths/footpaths can be designed into new coastal defence schemes so the argument for their retention in situ is not a strong one. Whilst we accept that there would be reluctance to move them it is not essential that they should be retained in situ if other factors such as flooding of homes and risk to people are threatened. It would have been better to have considered the evaluation in a hierarchical fashion taking account of their identified importance.

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? The information presented should have been more up to date -it seems strange that The data collection and assessments of defences for the SMP took place at the No changes proposed. information on existing flood banks around the Dee and Clwyd estuaries has not been used as start of the project in 2008 and used the best available information at the time. these will have been assessed by EAW for the Dee and Clwyd estuaries as part of their flood The Dee and Clwyd strategies have started much more recently. risk management strategies. Using Google Earth for assessment seems strange and in our opinion undermines the credibility of the document therefore. Our previous comments on landscape appear to have been heeded but whether this transpires No action proposed. into action on the ground remains to be seen. There are several examples of fairly poor This needs to be taken up with at strategy / scheme stage. practice around the estuary/open coast particularly where Network Rail have undertaken work such as between Greenfield and Llanerchymor when consideration of the aesthetics of their construction and implications for users of the coastal path appear to have been ignored- you cannot see the sea anymore unless you climb on the boulders. PCR_170 The Shoreline Management Plan should be integrated with the Tidal Dee Flood Risk As previously noted the Strategy programme is developing behind the SMP, Management Strategy being prepared by Environment Agency Wales. taking account of the SMP findings. It is not possible for the information to flow Cheshire the other way as the strategy is not yet complete and it is not possible to re- West and The table setting out actions and responsibilities in section 4.2 refers in part 2) to the Regional work the SMP at this stage. Chester Economic Strategy. This is now being combined with the Regional Spatial Strategy and Council Regional Housing Strategy to form RS2010. It should refer in 3) to the need for local authority planning officers to be involved in the process and not just informed. The responsibility should Update Table 4.2 to reflect responses. Updated Table 4.2 to reflect also be with local authority planning officers. 4) refers to the need to submit SMP2 to planning comments. committees. As it is not just a development management issue it should also be taken to Local Development Framework Panels and other similar panels / committees. SMP2 should be fully incorporated into and taken account of in the LDF, not just used as reference material or an annex. PCR_199 The National Trust is an independent charity founded in 1895, with a statutory purpose and Y The SMP2 team would like to acknowledge and welcome the support given for obligation to 'permanently protect places of natural beauty or historic interest for the benefit the North West England and North Wales SMP2. National Trust of the nation'. We have over 100 years' experience of managing land and buildings and take a

long term view of environmental management - a key element of a genuinely sustainable approach - because by statute we are 'here to stay'. The Trust is the largest conservation body in the UK. We are responsible for the protection of some of the most beautiful, important and environmentally sensitive places in England, Wales and N Ireland. This includes nearly 250,000 ha of land, including over 700 miles of coastline, and 250 historic buildings. Much of this property has unique legal protection, called 'inalienability', meaning it cannot ever be sold or mortgaged against the Trust's wishes without the permission of Parliament. In 2005 the Trust published 'Shifting Shores, living with a changing coastline' which set out our approach to managing coastlines. This document draws on the National Trust's experience as Britain's largest coastal landowner. The coast is one of our most dynamic environments. Sea level rise and climate change are forecast to increase the scale and pace of coastal change. To help us plan for the future, we commissioned research to assess how our coastline is likely to change over the next 100 years. The results suggest that many of our important sites are at risk from coastal erosion and flooding. We face some difficult choices in managing this change, but we want to make well informed decisions that stand the test of time. Learning from our experience our policy now favours adaptation, giving ourselves time and space to change with the coast and work with the forces of nature. The National Trust has been involved in the consultation process around the preparation of the SMP2 and broadly supports the policy options and proposals which relate to the land in our care in the Merseyside coast. PCR_227 Whist we acknowledge that more opportunities for public consultation were a rranged and that

Response Response Agree to SMP2 Team Comments Proposed Acti on from? draft Policies? Sunderland the consultation period has been extended, we are still of the opinion that there has been Although the consultation was not during the summer season, we did receive a Point inadequate consultation allowed for response to this important document. In the spring and number of responses from outside the North West England and North Wales Community summer months, the area is visited by large numbers of people from outside the area, to say coastal area. Hosting the consultation on the Coastal Group's website helped Association nothing about the many more who have holiday accommodation locally. Because of the timing to make the document available to people who were not local. of the consultation period, these people will not be offered the opportunity to take part in the

consultation process. In addition, there have been notable exceptions to the list of invited stakeholders. The SMP2 team is discussing with Lancaster City Council about arranging a meeting with the community association in order to go through the proposed As there is a proposal for controversial policy change, we ask that the Coastal Study Group, in changes at Sunderland Point accordance with the conflict resolution guidelines issued by DEFRA, will now arrange a meeting between the plan consultants and representatives from the Sunderland Point Community Association, in an attempt to address their concerns.

2 Responses Relating to Mapping

Response Response SMP2 Team Comments Proposed Action from? PCR_113 The term ‘Indicative Floodplain / Map’ is so metimes referred to when describing the flood outline. In most locations we are trying to describe the area at potential coastal This is now known as the ‘Flood Map’ and should be described as such throughout the SMP2. We are flood risk. The assessments were based on the mapping that has been Amend references to “Indicative EA able to provide updated maps if required. referenced, so without re-working many documents it would be difficult Floodplain / Map”. to switch the map layers. We will change references to ‘Indicative Floodplain / Map’ and refer to either the ‘Flood Map’ or ‘coastal floodplain’ as appropriate.

3 Responses Relating to Documentation

4.1 Main SMP Report Response Response SMP2 Team Comments Proposed Action from? PCR_4 Document is not stakeholder friendly, with no cross -referencing. The SMP team has decided that additional text explaining the contents of and interaction of appendices needs to be added to the main SMP2. Add text to main SMP2 document Bourne explaining appendices better. Leisure Limited PCR_113 Action Plan general comments EA to review action plan and EA When all policy scenarios action plans are collated, there are in excess of 800 draft actions in the Further discussions on the requirements for the final version of the propose specific amendments for consultation draft. Although a good starting point, there is a significant amount of work required from all Action Plan have been undertaken within the project team, but definitive agreement by the Project partners to reconcile these actions into a form which is more easily managed, implemented, reported and guidance is awaited. Management Board. placed into the Medium Term Planning framework. For example, does the draft Action Plan recommend strategies in the right areas? The National Quality Review Group has stressed that the Action Plan should be affordable and achievable. To this end, the Environment Agency would welcome the opportunity for continued involvement in action plan development, in particular during consideration of action prioritisation, timescales and funding. The large number of actions for completion by 2015 is unrealistic and needs consideration. We have already started this process internally, and we would like to discuss further with partners before the SMP2 is published. The action owner needs consideration during future discussions. To date, the action owners have not been consulted. To be realistic, all owners need to be fully engaged in the process, to accept responsibility for the action and to confirm that sufficient resources are available to complete the action within the stated deadline. An important point raised by the Regional Flood Defence Committee relates to development control. The action to ‘ensure flood and erosion risks are accounted for in planning decisions to aim to reduce the need to manage flood risk in future’ is allocated to the EA alone. Planning Authorities should take the lead when making decision so they should be the lead for this action. Consistency. For example, the actions relating to improving flood warning vary. Non for St Bees to Whitehaven; Whitehaven must need warnings. Further consultation with EA Flood Incident Management teams is needed during the development of the Action Plan. Unless EA is satisfied that models for some locations do not need improving then all actions should be like those for Walney Island i.e.: "Continue with improvements to flood risk maps and inundation modelling to provide improved flood warning service." There may be merit for a generic action to acknowledge the potential impact of future government policy decisions upon SMP2 policy. For example, to keep abreast of outcome of forthcoming National Policy Statement on Nuclear Sites and to monitor proposals for tidal barrages at estuary sites in Cell 11. PCR_115 General comment - who signs up to the SMP Actions and in large, multifunctional organisations like the This was discussed by the Project Management Board and it has been Action Plan ite ms to be reworded to EA, do we need individual sections/departments to sign up? For example, there are items in the Action agreed that All actions in the Action Plan must formulated so that they be deliverable by the Coastal Group EW Wales Plans that we may want to include in the FRM Strategy action plan eg Ref 1.3 in 11a 4 Beach recharge plan can be delivered by Coastal Group Members. This means that it is the members. currently sitting with EAW as lead but may be more appropriate for LA to lead on, as a coastal erosion Local Authority and Environment Agency members that must sign up. issue (strategy is FRM only). PCR_113 There are a number of policy units with a headline policy for medium to long term managed realignment. Under current funding rules the economic case for MR may not always be clear. However, the ‘intent of EA The SMP team agree with this because the headline policy of managed management’ and potential for MR should be introduced to coastal communities at the plan level – the EA to propose / agree specific realignment does not necessarily imply an expectation of public funding. economic arguments may strengthen over time (due to climate change, compensatory habitat changes to explanatory text about This policy covers a large number of potential delivery options, which requirements and government policy in relation to habitat creation). This ‘intent of management’ aim of intent of management. includes adaptation responses to changing risks, rather than constructing SMP2 policy could be emphasised further in the main plan document. large scale defences.

Response Response SMP2 Team Comments Proposed Action from? There remains some doubt about the role of estuarine authorities in the SMP2 process. Unlike Maritime Actions to consider the need to change the location of the Schedule IV Add item to generic action plan for authorities, estuarine authorities are not required to formally adopt the SMP2, despite having significant boundary in some estuaries, such as the Mersey, were already included the coastal group to clarify the future lengths of frontage which are subject to SMP2 policy. This is further complicated by their position which in the draft SMP2. role and status of the estuarine is upstream of the Schedule IV boundary. This prevents those authorities from claiming Grant in Aid authorities needs before the next A generic action can be added to the action plan for the coastal group to under the Coast Protection Act. The future role and status of the estuarine authorities needs to be SMP review. consider the role of estuarine authorities. considered before the next SMP review and this should be reflected by a generic action in the SMP2 action plan. The main plan document may benefit from a clearer explanation of how climate change estimates have As coastal flooding represents a much greater risk than erosion across Add action plan item to review the been, and will be, incorporated into the SMP2 process. In practice, it is intended that the National this SMP2 area, it is suggested that a high level action plan item should be SMP2 policies in the light of new EA Coastal Erosion Mapping project will ‘UKCP09 proof’’ the SMP2s through the publication of a SMP / added. guidance on use of UKCP09 NCERM comparison report between SMP2 adoption and final sign-off. An alternative is to include scenarios in flood and coastal consideration of the comparison report as a generic action in the SMP2 Action Plan. erosion. PCR_98 1.1 Sub -cell description bullet points (pg. 2) - Is the split between sub -cell 11c and d Haverigg or Location of the boundary between the sub -cells ha d been based on the Amend boundary, and revise policy Hodbarrow Point? boundaries report developed before the present study started, but there units, mapping and other Barrow BC was confusion in the report. Following discussion amongst the SMP team documentation to match. the boundary will now move to Hodbarrow Point. 1.5 How has the work been managed? (pg. 8) & throughout - The coastal group should be referred to as The draft SMP used the Coastal Group name in use at the time. Coastal group to confirm if change North West England & North Wales Coastal Group (i.e. England added) required. 2.2 Baseline Environment (pg. 11) final bullet point - Refers to population bullet point ‘below’ – should be Specific item to be corrected. Correct typo. ‘above’. 2.3 SEA Objectives (pg. 12) 1s t bullet point - Acronym BAP is used with no expansion. BAP is explained in the glossary, but all acronyms should be expanded at Check all acronyms expanded at first first use, or refer to the glossary. use or directly reference the glossary. 2.8 WfD (pg . 16) 2nd para. - Uses technical terms with no explanation, i.e. ‘hydrological regimes’ and Technical terms should be included in glossary and reference m ade to Check technical terms such as those ‘water body morphology’. the glossary where necessary. mentioned are included in glossary and cross-referenced. The final sentence of the paragraph repeats the point in the first sentence. 3.1 Summary of the Plan (pg. 17) 1st para. - Redundant term ‘balanced sustainability’ i.e. Is there such a SMP team to review text. Review specific text. thing as ‘unbalanced sustainability’? (maybe me being pedantic). 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 more specific Modify / improve text regarding groyne at Earnse Point – have the conclusions of the ABPmer Appropriate Assessment report for West generic action. Earnse Point / Westshore Park. Shore Park been taken into account? PCR_69 Main SMP 2 document - The map on page 37 is wrongly annotated. Sub section 11e and suffixes are The errors in annotation will be co rrected. Revise map on page 37, including labelled sub section 11d and suffixes. improving background to more Individual suitable mapping. Such lack of attention to detail makes one wonder how many more errors exist in the document. PCR_121 Page 3 Section 1.2 Action suggested changes. Wirral Council Suggest a change in orientation of Table 1 to reflect hierarchy of SMP / Strategy / Scheme. Text refers to Agree – specific changes to be made. them “sitting at the top” – would be beneficial to represent this graphically via the table structure (for clarity) Also; the role of the SMP within Local Authorities – informing planning decisions via their Local Development Frameworks – should be highlighted (accept it is identified as such later in the doc). Page 13 Section 2.5 Action suggested changes. Appraisal of policy scenarios against objectives should indicate whether this was done objectively or Agree – specific changes to be made. whether a ranking was given to objectives. Page 16 Section 2.8 Para 2 Action suggested changes. Typo – influences should read influenced Agree – specific changes to be made.

Response Response SMP2 Team Comments Proposed Action from? Page 18 Para 2 Agree and will update text to mention towns requested. Note that Amend text in main SMP doc. Wallasey embankment provides flood risk management function for the Birkenhead not protected by north Wirral coastline. Towns of Leasowe, Wallasey and New Brighton are large area that links through to the Mersey. protected but not mentioned. Page 23 Section 3.2 Update text for PMB review. Under the heading Property, Land Use and Recreation Objectives the text describes that where economically viable preferred policy is to maintain existing defences into the long term. It may be Responses noted. Revised text to be drafted and circulated to project worthwhile giving an indication of various funding streams for future maintenance (public / private etc) and management board for consideration. also indicating that maintaining private defences is permissible even where it is not considered to be economically viable and where it is not environmentally damaging. Page 27 Section 4.1 Last para. Action suggested change. The sentence beginning “In many areas of the SMP2….” Has text missing from the end – possibly the Agree – specific change to be made. words “is required”. PCR_175 concerns: Page 24: ‘While the preferred policy for many of these areas is to hold t he line in the long term, there may be a detrimental impact on tourism through loss of beaches at places such as along the North Ensure the importance of the Blackpool Responses noted. The importance of the beach was emphasised in the Wales Coast and at Blackpool, where it will become increasingly technically difficult to retain beaches as amenity value of the beach is Council draft SMP2 and an action plan item identified the need to develop a long sea level rise causes coastal squeezes pressures’. – The Blackpool Local Development Framework (LDF) mentioned in the Appendix H and in (Planning) term beach management strategy. The important economic value of the places great emphasis on the coast and beach as a recreational, environmental and economic asset, and the action to develop a long term amenity beach may need to be better highlighted. any loss of beach would have a detrimental effect on the resort. As part of the LDF, the Blackpool Core beach management strategy. Strategy emphasises the vital role the coast will play in the sustainable growth and regeneration of Blackpool. To ensure the beach remains a valuable asset, we would support future management options to sustain the beach, including the development of a long term beach management strategy. Page 27: ‘promote use of the SMP2 recommendations in spatial planning of land use’ – Reference to the SMP2 will be included in the Blackpool Preferred Option Core Strategy.

4.2 Appendix A Response Response SMP2 Team Comments Proposed Action from? PCR_115 - Tables should have titles and need to indicate chairs/leads where appropriate. Specific items to be reviewed and amended as appropriate. Review & amend text. EA Wales - Section A2 – there is a subparagraph numbering issue. Specific items to be reviewed and amended as appropriat e. Review & amend text. A2.1 2nd para reword This SMP, SMP2 was developed and produced in accordance with… Specific items to be reviewed and amended as appropriate. Review & amend text. A2.2 2nd para reword This group includes the 5 sub cell leads as r epresentatives for all the other district Specific items to be reviewed and amended as appropriate. Review & amend text. authorities as well as SEA statutory consultees… After A2.4 add comms subgroup here? Specific items to be reviewed and amended as app ropriate. Review & amend text. A2.4 reword (SMP study Boundaries) 2nd para The study recommends that 5 separate SMP2s should be Specific items to be reviewed and amended as appropriate. Review & amend text. produced for Cell 11 but with some minor modifications to the boundaries from SMP1. A3 flow chart reword Stage 4 needs to be amended to reflect new public consultation dates. Stages 5 and Specific items to b e reviewed and amended as appropriate. Review & amend text. 6 will need to be populated with relevant info once public consultation has been completed. A4.1 4th para reword Initially membership for both the EMF and SF was drafted from the SMP1 list. These Specific items to be reviewed a nd amended as appropriate. Review & amend text. were then verified and updated by the PMG and CSG members. A5.1 (b) add Defence data has been double -checked by operating authorities in the CSG. Specific items to be reviewed and amended as appropriate. Review & amend text. A5.2 1st para clarify WPM – does thi s mean same SOP (ie. an increase in flood defence heights over time SMPs do not specifically consider Standard of Protection, so With Review & amend text if necessary. to keep up with climate change) or maintenance of existing structures (so SOP will drop over time)? Present Management refers to generally taking the same approach as in the recent past. This would normally include considering improvements when necessary due to changes in risk, but not specifically climate change. A5.3 1st para 2nd sentence reword Therefore the first stage is to identify… relationships between these Specific items to be reviewed and amended as appropriate. Review & amend text. features and how coastal management can alter coastal processes and impacts on the environment. 2nd para reword The SEA Environmental Baseline Report (Theme Review)… Specific items to be reviewed and amended as appropriate. Review & amend text. A5.4 1st para reword The definition of issues and objectives is a key activity of the…..they inform the Specific items to be reviewed and amended as appropriate. Review & amend text. development of policy options and secondly, they help…. A6.1 2nd para reword The first stage of the SMP2 assessment was therefore to determine the main Specific items to be reviewed and amended as appropriate. Review & amend text. factors influencing policy decisions along the coast i.e. key policy drivers. A key policy driver can be defined….

4.3 Appendix B Response Response SMP2 Team Comments Proposed Action from? PCR_115 I think either a list of members (PMG and CSG at least) or examples of members should be provided Lists of members of the different stakeholder groups could be added to Add lists of s takeholder group members for the different stakeholder groups. the Appendix quite easily. to Appendix B EA Wales Further details of the events could be provided – issues, attendance, outcomes, what was expected of We are happy to expand on further details of each meeting upfront in Amend appendix accordingly them etc. the text, for example purpose of the meeting and outcomes etc. The minutes from each, including attendance lists are already included in the supporting annexes to this appendix. PCR_98 App B2.1 Table of meeting dates EMF/SF3 meeting - The meeting for su b-cell 11c was held in Waterside Thank you for highlighting these errors. The Appendix will be revised Amend appendix accordingly House on 19/6/09 not Lancaster Hotel and the sub-cell 11d & e meeting was combined. accordingly. Barrow BC Ditto for next page.

4.4 Appendix C Response Response SMP2 Team Comments Proposed Action from? PCR_115 Baseline processes statements for each policy unit (page 43 onwards) – really like this, its well laid out and Thanks. None clear. Not sure if we need to go into so much detail at the beginning of the report telling the reader the EA Wales headings considered – just do it! PCR_113 Appendix C4 - Mersey Estuary (p. C -200) Correct specific item. EA The embankment around Norton Marsh is listed as “unknown” in origin. This is an Environment Agency Noted, but probably not included in the NFCDD data at the time of the defence and should be listed in the NFCDD data already available to the project. defence assessment. PCR_98 App C (pg. C602 - 603) 3 boxes in the table - Loca tion should be Walney Island Middle Hill Lane (not Noted. Correct specific item. Middle Hall). Barrow BC As above (pg. 604) 2 boxes in table - Location is Walney Island Walk Haw Scar not Walk Hill Scar. Noted. Correct specific item. (pg. c617) 4th para. And fina l para. - Walk Haw Scar (not Walk Hill) and Mill Scar (not Mill Hall Scar). Noted. Correct specific item. Same page final para. - Mill Scar (not Mill Hall Scar). Noted. Correct specific item. (pg. C619) 2nd para. - Mill Scar (not Mill Hall Scar). Noted. Correct specific item.

4.5 Appendix D Response Response SMP2 Team Comments Proposed Action from? PCR_115 Good logical layout. Thanks. None EA Wales Like the way the tables indicate what coastal section the character area sits in. PCR_98 App D (pg. D49) - South Vickerstown is in twice. Specific items to be reviewed and amended as appropriate. Review & amend text. Barrow BC PCR_194 The map showing international designations is out of date - the Dee Estuary is now SAC and the At the post consultation meeting with CCW & NE it was confirmed by No action proposed. revisions to the SPA and Ramsar Site are now confirmed. All the Dee Estuary sites encompass at least CCW that the plan should be based on the information available at the CCW three separately notified SSSIs in England and Wales (SAC includes 3; SPA 4 and the Ramsar Site 5). time of assessment, and where there have been changes during the SMP2 review it is not necessary to consider them. The Liverpool Bay pSPA is now out to consultation

Certain Welsh SSSI now appear to be missing from the tables whilst sites in England are all identified. Shotton Lagoons and Reedbeds SSSI is not now mentioned although identified previously and Gronant Dunes and Talacre Warren SSSI is not specifically identified in policy unit 4. Parts of this SSSI in Review list and amend / add missing sites. Amend specific items identified. Denbighshire are also designated as LNR. PCR_212 Appendix D, Table 6.9, pg D -66 lists the relevant national, regional and sub -regional pl anning policies for the plan area, referring to both the English and Welsh planning context. However when considering CCW Agree. Welsh policies to be inserted. Amend specific items identified. Appendix I, Table 8.2, pg 39, this only quotes English policy. The equivalent Welsh policies need inserting. We look forward to seeing the final version of this document and working closely with you and the NW & N Wales Coastal Group on the implementation of this SMP. If you require clarification on any of Response noted. these points do not hesitate to contact me.

4.6 Appendix E Response Response SMP2 Team Comments Proposed Action from? PCR_98 App E (pg. E132) Golf Clubs row - The defences at Earnse were not constructed to protect the golf This may be true, but was not apparent from the flood risk maps used in Check specific text and revise as course. The land falls away from the cliffs at the shoreline towards a housing estate which lies on the development of the SMP2. We have flagged elsewhere the need for appropriate. Barrow BC considerably lower land. Protection of this estate was the primary reason for the replacement of the ongoing improvements to flood risk mapping, particularly where it defences (with the acknowledged benefit to the golf course at the same time). The defences also assumes that natural high ground, promenades or dunes cannot breach. provide a degree of protection to West Shore Park as the natural recession line with no defences would be some way back into the park at the present time. PCR_194 SMP objective E 1.1.3 Table 1 E -3 Additional categories of site need to be mentioned including wildlife Any non -statutory wildlife sites designated by local authorities were Revise table and update SEA. sites/non-statutory sites of nature conservation importance and if RSPB nature reserves are mentioned picked up and included in the planning policy summary sheets which CCW then all nature reserves managed by wildlife trusts and groups need to be identified. Both the were included as an annex to the theme review. These sheets were Merseyside Ringing Group and Deeside Naturalist’s Society (DNS) have reserves at the head of the Dee summaries of the primary planning policy documents (eg. local plans, Estuary for instance. Part of the DNS’s current reserve consists of a series of pools bunded by a bank to minerals and waste planning docs etc) which each LA has produced. retain water adjacent to the river channel. This is filled by ingress of waters over a tidal period and can There were a couple of reasons why we identified them in this way be overtopped on the biggest tides but is vulnerable to breaching rather than in the main nature conservation chapter: • as locally designated, non-statutory wildlife sites are identified and designated as part of local planning policy, we felt that it would be best to make reference to them in the planning policy summary sheets; • such wildlife sites are arguably the lowest level wildlife site designation and so while we thought it important that they were identified in the theme review, we felt that they wouldn’t/shouldn’t/couldn’t have a bearing on shoreline management policies on an SMP-wide scale and hence we didn’t therefore make mention of them in the main nature conservation chapter. It could be argued that LNRs & RSPB reserves would fall into the same category; however, they were included in the nature conservation chapter. We will however, revisit this table, ensuring that we are consistent in our approach to identifying all statutory and non-statutory local sites of nature conservation interest.

4.7 Appendix F Response Response SMP2 Team Comments Proposed Action from? PCR_115 Section F1 1st para reword the appendix outlines the key steps undertaken to identify policies… Specific items to be reviewed and amended as appropriate. Review & amend text. EA Wales Section 2nd para reword ... the assessment of policy scenarios; a string of policies together rather than Specific items to be reviewed and amended as appropriate. Revie w & amend text. considering a series of locations in isolation. Section F4 add definition of Key Policy Drivers (KPD) so acronym makes sense in subsequent tables. Specific items to be reviewed and amended as appropriate. Review & amend text.

4.8 Appendix G Response Response SMP2 Team Comments Pro posed Action from? PCR_115 Section G1 2nd para reword the development of the policy scenarios to test here have been previously Specific items to be reviewed and amended as appropriate. Review & amend text. described in Appendix F. So within this Appendix… EA Wales PCR_113 We appreciate the large amount of work conducted to test the various policy scenarios along the coast. Specific items can be reviewed and amended as appropriate. However, Consistency review on policy It is important that this objective analysis is applied, and seen to be applied, consistently across the SMP although stakeholders have questioned consistency there are good statement wording across whole EA area. The choice of headline policy and associated descriptions must be consistent across the full SMP2 reasons for there to be different descriptions due to differing situations SMP. Review & amend text as area. As the project team is aware, this consistency has been questioned by some stakeholders and will with regard to coastal risk. The parts of Appendix G that document necessary. need to be addressed in the Consultation Report. policies discussed with stakeholders cannot be modified where it is a record of what was done.

4.9 Appendix H Response Response SMP2 Team Comments Propose d Action from? PCR_115 Document provides good summary but: No action proposed. EA Wales - Has the economic appraisal (column “Broad-scale SMP review”) only been conducted for the preferred Yes, see response to PCR_113 below. Any additional requirement policy? Do we know for example if MR Epochs 1-2-3 is cheaper/more expensive than HTL 1, MR 2&3? would require further work. - The sums are completed for the 100 -yr period but can we have a break down on broad -scale spend To develop additional tables giving policy unit level expenditure would No action proposed. profile i.e. frontages where HLT is proposed for Epochs 1-2-3, roughly which year between 0 and 100 is require significant additional work. the bulk of the investment required? At Policy Unit but also Wales/sub-cell scale. - Can we (PMG) have a copy of the economic appraisal spreadsheets used for the analysis? Detailed “PAG 3” type spreadsheets have not been used, so are not PMG to indicate specific requirements and Halcrow to available. Much of the information used and results are summarised in provide. appendix H. However, if there is specific further information required by PMG we can provide. - Can we have a summary table showing total levels of anticipated investment required to deliver SMP2 These can be provided. Add summary tables to Appendix H. policies in Wales/England and by sub-cell? - Have WAG looked at this appendix and provided comments – prior to adoption, can they give the All documents have been available for review. WAG comments have LA & EAW to discuss with WAG prior to adoption. Welsh LAs and EAW reassurance that the money need to deliver the SMP2 policies in Wales is/will be been received through the QRG response. there or realistic? PCR_113 Appendix H – Economic Analysis pre sents the high -level economic analysis (B/C) for the preferred policy, The national SMP guidance only requires us to broadly check the No changes proposed. but not for other policy scenarios considered. This should be included for transparency. Alternatively, it economic viability of the preferred policy: EA should be made clear that this information is available on request should stakeholders require further 'The socio-economic status of the preferred policies should be information. appraised. Best available information should be used (e.g. existing coast defence strategies), however by using appropriate broad scale costs for defences and output from MDSF, new assessments for policies can be made (see Appendix C). The socio-economic assessment should address whether or not each policy is clearly economically viable; clearly not economically viable; or of marginal viability. We have not, therefore, looked at the economics for all options, and so do not have this information to make available. However, we could do something as additional work, but national guidance does not require this.

4.10 Appendix I Comments Response SMP2 Team Comments Proposed Action from? PCR_212 We welcome the opportunity to comment on the NW England and N Wales SMP2 SEA Report. Noted None CCW Our comments in respect of this SEA are made in the context of our role as a consultant body under the Environmental assessment of Plans and Programmes (Wales) Regulations 2004 and as advisors to the

Welsh Assembly Government on matters pertaining to the natural heritage of Wales and its coastal waters. These comments should also be read in conjunction with our separate responses to the Shoreline Plan Comments will be addressed in conjunction. Read all comments together. itself, sent by email on 17 Feb 2010, and our response to the Habitats Regulation Assessment component The mitigation measures are identified in Annex 1 to the SEA. However, of this consultation contained in our letter dated 21 Jan 2010. We recognise that there has been an greater detail will be provided on the identified mitigation measures actively dialogue involving CCW and Natural England officers during the development of this document. (while ensuring that where possible, mitigation is identified for all In Appendix I, Table 8.1, the mitigation measures are expresses in fairly vague terms. As this plan could receptors where adverse impacts are identified) in the tables in Annex 1. have significant adverse environmental effect on key nature conservation areas, this issue needs further Information on mitigation will be brought forward into the relevant

attention. tables in the SEA. Stronger statements will be made in the SEA ER, particularly where it is essential that mitigation measures are Further explanation required. It is unclear from reading Appendix I, Table 8.2, whether the SEA is recommending that the SMP or other implemented to ensure that the impacts of the plan are environmentally plans should resolve the issues which have been identified. We will make stronger links to the Regional acceptable. Mitigation relating to the provision of replacement, Habitat Creation Programme (RHCP). alternative or compensatory habitat cannot be confirmed until the conclusions of the Appropriate Assessment (i.e. the impacts of the

policies on the European sites) have been agreed with Natural England

and CCW. The Environment Agency has recently clarified that mitigation required by the SMP will be delivered through the developing Regional

Habitat Creation Programmes (RCHP). We agree that this information We will make this clearer and ensure that we In Section 1.8.4 ‘Monitoring’ it is unclear how the key identified monitoring activities will monitor the is essential to the viability of the Plan and the text will be updated consult on the monitoring plan. effective implementation of the SMP. We therefore look forward to commenting on the monitoring action accordingly upon finalisation of the Appropriate Assessment. plan as it develops. Further detail will be provided on monitoring activities to ensure effective implementation of the SEA. Further clarity will be provided on the issues and recommendations described in Table 8.2.

SEA Summary of Secondary, Cumulative and Synergistic Issues – This is a way of identifying potential issues which could arise through the implementation of proposed policy, rather than proposing how they will be resolved. Maybe make it clearer that issues will be resolved at a lower strategy/scheme level. This needs to be clarified and monitoring plan will need to be consulted on.

4.11 Appendix J Comments Responses SMP2 Team Comments Proposed Action from? PCR_113 Appendix J - Appropriate Assessment is hard to read on some computers due to its large file size and lack There could be some changes made to reduce the file size and improve Consider benefits of splitting the documen t into sub - of a clear index or discernible structure. Area staff have suggested that it is either split into smaller sections ease of navigation. cells, or reporting differently to make easier to read EA or re-written to be more concise. & reduce file sizes.

PCR_75 Matrix Tables for each sub -cell. We will ensure that latest available conservation RSPB Conservation Objectives – we note that these tables do not use the latest version - those included are the We requested the latest versions from NE during the development of objectives are used. old-style objectives that predate the JNCC Common Standards Monitoring Guidance. This should be the doc and have used what we received from them, in addition to web

corrected. based sources where there were gaps.

J1.4 Page 5: This is not considered to be a result of SMP implementation. Where

This sets out 5 bullet points on the application of the AA process, and which polices require AA. there is a change in policy from the original SMP to the new SMP, this is None Areas for which the proposed policy is NAI and there is a naturally occurring defence are identified as not a result of SMP implementation and the impacts have been identified and requiring AA (bullet point 1) – likewise those where the policy is NAI but there are no natural defences adequately assessed. This approach has been discussed and agreed with providing the previous policy was NAI as there will be no change (bullet point 3). NE and CCW. We have raised concerns about this position in our earlier submissions. The continuation or adoption of an NAI policy does not necessarily mean there won't be an adverse affect - a policy of NAI against naturally As no adverse effect is currently concluded, compensation will only be high ground can still result in a coastal squeeze effect from sea level rise. If modelling carried out for the Further discussion required with RSPB needed if through review with NE and CCW an adverse impact was purposes of the SMP were to show that sea level rise would result in coastal squeeze against natural defences, then this places an Article 6(2) duty on the EA and Defra. identified and the need for IROPI and therefore compensation was required. We believe that the SMP should provide two outputs: 1) Identification of Article 6(3) compensation requirements from policies that go through the AA process We could do more to outline potential generic impacts, but it’s not the job of the SMP to resolve issues such as this when nothing is actively None 2) Where there is a policy of NAI against a natural defence, the SMP process could be used to identify being proposed to change from what is currently occurring. We don’t coastal squeeze losses as a result of sea level rise and therefore identify Article 6(2) habitat creation needs. have sufficient info at SMP level to fully identify habitat losses and gains and any calculation would be estimates and info from RHCP will be Further discussion required with NE/CCW Article 6(2) responsibilities ultimately sit with Defra, and as the SMP2 will require Secretary of State sign-off, required to do this. these must be addressed. J2.1 It was decided through consultation with NE/CCW that this would be Further discussion required with RSPB to see is we the approach. In consideration of “close proximity” reference needs to can further explain the reasons for this approach The scoping matrix rules out likely significant effects from policy units that do not contain International sites, be made to the linkages identified in the baseline coastal process or are not adjacent or in close proximity to them. This fails to consider the wider coastal squeeze impacts assessments. We will provide further clarification on this. We will Revisit scoping for final version of plan. on the system as a whole from HTL policies in these cells. (see J4.1 too). We are not convinced that all the review the draft assessments when updating for the final plan. policy units that could result in coastal squeeze impacts as a whole have been identified.

Policy Units which do not contain, are not in close proximity or may be affected by proposed policies we deemed not to require HRA

Comments Responses SMP2 Team Comments Proposed Action from? J4.3 Further discussion required States that SMPs are high level policies and therefore difficult to determine exact effects that any proposal We need to discuss this further with statutory consultees as to the level would have on the integrity of International Site and so, considered at this stage, it cannot state any definite of detail we can go into adverse affects arsing from SMP policies and that the detailed LSE and AA appendices will only be completed

at scheme or project level. Whilst we agree that AA at individual scheme level is crucial, effort must be made to ascertain as much detail as possible at this strategic level. Where AA at the scheme level is required the SMP must commit to this, which it does (see page 4, J1.4). However, we are concerned that a default

assessment of no adverse affect is being applied to the strategy level (see page 26). mitigation?

For example, it is stated that a HTL policy may result in coastal squeeze, potential 'preventative measures' (i.e. mitigation) such as beach recharge are identified, and it is then stated that other preventative measures relate to the requirement to ensure any potential effects on integrity of site features are fully considered - Further studies and assessment at strategy/scheme level will be used to i.e. assess later at the strategy level. It then goes on to conclude that the strategy will have to demonstrate identify adequate mitigation. At SMP level the approaches to policies no adverse affect of the HTL policy and it is considered that such preventative measures as further have been targeted to avoid adverse impacts, e.g. by proposing Make this clearer, rather than the further studies etc assessment (which in itself cannot be considered a preventative measure) mean that it can be concluded that preventative measures, indicating that adverse impacts can be avoided. are the mitigation – they will be used to develop the no adverse affects on integrity are anticipated at this stage. Where is the evidence that further studies and mitigation beach recharge are adequate mitigation? J5.1 In combination effects - page 18. Do another review of relevant plans and policies and This clearly states that only plans or projects that have the same affects as the SMP (i.e. coastal squeeze) We can look at other kinds of development plans, such as those that include those not only associated with activities that have been considered, and that any other plans or projects that have differing effects would be more have been suggested will have similar effects. Consult with statutory appropriately considered at the proposal stage. We would strongly disagree with this - the purpose of the in consultees for their input and knowledge of other combination assessment is to assess the effects of all plans and projects on the interest features of the sites plans and policies they may have in question, not just those with 'the same type of effect'. There will be a whole host of other plans and projects that have the potential to interact with the SMP in terms of effects on interest features, eg offshore renewables, dredging, plans or projects resulting in direct habitat loss, etc etc. All plans or projects and their effects that it is possible to identify at this stage, must be considered.

Comments Responses SMP2 Team Comments Proposed Action from? PCR_99 Thank you for giving the Countryside Council for Wales the opportunity to comment on the HRA Noted None proposals for the North West England and North Wales Shoreline Management Plan 2 (SMP2). Our CCW comments are made in the context of our role as a consultant body under the Conservation (Natural Habitats &c) Regulations 1994 and as advisers to the Welsh Assembly Government on the natural heritage of Wales and its coastal waters. CCW welcomes and supports the efforts made by the Environment Agency, Noted The NW Coastal Group and your consultants, in respect of this HRA process and looks forward to working None closely with you on the implementation of the Shoreline Management Plan in the future. Our general comments follow below and detailed comments are contained in annex 1 attached.

Please note that our comments are limited to those sites which lie wholly or partly within Wales and do not Noted None cover those sites which lie entirely within England. However, they should be read in conjunction with comments from Natural England as the issues raised may be relevant to the assessment as a whole. These comments should also be read in conjunction with our separate responses on the SEA and on the Plan itself. We could change the report title to reflect that it This could be changed and the additional information incorporated covers the HRA, not just AA and additional We note that this report is described as the “appropriate assessment” rather than a Habitats Regulations information will be incorporated Appraisal (HRA). The Appropriate assessment only forms part of the HRA along with the “screening” and

“test for likely significant effects”. We appreciate that these elements have been completed and consulted

on separately but, for completeness, these initial stages of the assessment should also be included in this

report. We could go through the report and identify where at all possible any We understand and appreciate that this HRA has concentrated on the impacts of the proposed SMP2 Identify potential adverse effects at high level and potential adverse effects could be identified. Incorporate the 3 pre- policies on the European and international sites identified rather than project level impacts that may occur detail approach more comprehensively requisites that should be met before adopting the approach. as a result of implementing those polices. We also appreciate that the level of detail that can be considered as part of a plan level assessment is not the same as would be the case for a project level appraisal. We should make firmer recommendations that more detailed HRA is Add these recommendations and firm up on policy However, we must emphasise that this assessment must still address the potential adverse effects as far as is undertaken for strategies/schemes and policy implementation is only implementation practicable before deferring assessment down to the project level. It should also show that the three undertaken following the satisfaction of these proposals prerequisites for deferment are met before adopting this approach; these are that it is not possible for the

plan to determine the effects at this level, that the lower tier plan or project is subject to HRA through

legislation or policy and that the Plan is capable of being amended subject to the findings of the more

detailed assessment. We welcome, therefore, the firm recommendation that there will be a need to carry

out more detailed, project level, HRAs on the coastal flood risk strategies and scheme proposals and specific

SMP2 policies will only be implemented subsequent to the findings of those assessments. There appears to be some confusion in the Report over the difference between mitigation measures and We agree the terminology is incorrectly used in places, and the Review the document to ensure that these terms compensation measures. Mitigation and avoidance measures will prevent any likely significant effects from assessment should generally have said referred to avoidance or are correctly used manifesting themselves as adverse effects, thus enabling site integrity to be maintained (as defined by the mitigation. We will ensure mitigation/compensation terminology is Sites’ conservation objectives). Compensation implies that an adverse effect will occur and site integrity will correctly used be compromised (for example, the loss of inter-tidal habitat as result of coastal squeeze and its replacement

outside the site boundary). Mitigation should be considered as part of the appropriate assessment process and included with the outcomes and recommendations. Compensation forms part of the consideration for any case for Imperative Reasons of Over-riding Public Interest (IROPI) which is put forward and must not be

considered as part of the appropriate assessment. There are numerous points within this Assessment where “compensation” is referred to and the implication is that features within the sites are likely to be

compromised by the implementation of a certain policy (subject to more detailed assessment) and that

alternative habitat will need to be created.

This may be simply confusion of terminology and the references to “compensation” actually should read “mitigation”, but this needs to be clarified as a matter of some urgency. Need to go through the assessment and address consultees comments where valid and consult with them to determine whether the Further liaison and discussion with CCW/NE is Given these concerns, CCW feel that the assessment needs further clarification before we can fully concur conclusions are correct required to find out whether determinations are with an assessment of “no adverse effects”. These particularly relate to issues of mitigation and correct and can be agreed upon compensation outlined above, but there are also a number of potential effects in combination with other plans, policies and programmes that need to be further considered or, if already considered, then a more Further discussion as part of a meeting/workshop comprehensive rationale for their exclusion included. required We need to work with consultees to clarify points raised It may be possible to resolve many of the points raised by clarifying the methodology or text but as it currently stands we feel that this HRA appropriate assessment is not completely consistent with other Noted & we will revise Section J1.2 as appropriate. Amend competent authority as appropriate SMP2s being developed and contains some significant discrepancies that may leave it open to challenge. We

have copied this letter to Peter Jones at the Welsh Assembly Government (WAG) because of our 32 understanding that WAG is the competent authority for this plan in Wales.

Comments Responses SMP2 Team Comments Proposed Action from? Please note, these comments are limited to those sites which lie wholly or partly within Wales and do not Noted None cover the sites which lie entirely within England. However, they should be read in conjunction with

comments from Natural England as the issues raised may be relevant to the assessment as a whole. These comments should also be read in conjunction with our separate responses on the SEA and on the Plan itself.

J1.2 background It should be noted that while the Environment Agency may act as the lead competent authority for the Noted Ensure that this is made clear within this section SMP2 process for plans that are “cross border” between England and Wales, the Welsh Assembly Government are the Competent Authority with respect to those elements of the SMP2 that lie within Wales at the current time. J1.3 Requirement for Appropriate Assessment The text will be amended to reflect this While it is not incorrect to refer to the appropriate assessment of the plan under the Habitats Regulations Noted or specifically to Regulation 48, you should note that the appropriate assessment is just one element of the overall Habitats Regulation Assessment (HRA). The full assessment, as noted in the text, includes a screening stage (identification of sites and test for likely significant effect) which may or may not lead to the need for an appropriate assessment of the plan and there may be additional stages depending on the outcome of the appropriate assessment. Regulation 85 (as amended) relates specifically to land use plans and may be of more relevance in this context. We note and support the rationale for progressing the Plan to the appropriate assessment stage. J1.4 Appropriate Assessment Procedure We will look at this in further detail We note the decision to screen out policy units which do not have a material boundary with an Agreed international or European site. While we understand the argument in relation to the requirement for

specific projects and schemes to undergo further HRA assessments and that potential effects from actions carried out in such policy units are less likely to have direct effects on spatially distant sites, it is important to remember that the policy applied to any particular cell can have cumulative, indirect and in combination

effects some of which could impact on sites a considerable distance away. For example, an “advance the line” policy could affect flow patterns or sediment processes across a much wider coastal process unit than the individual policy unit. It is the function of a high tier plan such as the SMP2 to at least identify the

potential for such effects to occur and ensure that any later decisions based on project level assessments are fully informed and not unreasonably constrained by the policy proposals set down within the SMP2. We will provide further information regarding how We note the additional clarification given in section J4.2 that efforts were made to ensure that policy units Further explanation of this is required. This requires cross-referencing the units are discreet and how they have been were also “discreet spatial units” and that “impacts [within the unit] would be largely confined to that policy to the coastal processes assessments in Appendix C, the policy scenario divided in that way unit” but we feel that further clarification is required of the meaning of “largely” and “adjacent” in the development in Appendix G and the use of Policy Areas.

context of the potential impacts of these excluded policy units on the identified sites. As it currently stands,

we are uncertain if this is sufficiently robust to provide a “generic” screening but it may be acceptable if individual policy units were evaluated in this way if only in to confirm the lack of potential cumulative and indirect effects.

They should also be considered for the potential impacts “in combination” with other plans, policies and Discuss this further with consultees This need further discussion programmes and the SMP2 itself should contain suitable policies to deal with this level of uncertainty.

We also note that policy units where “no active intervention” (NAI) is being proposed, and this was the Maybe we could incorporate a clause that where case previously, have been screened out in line with Commission rulings relating to Flood Management Agreed areas had been identified as compensatory areas Plans. While we do not necessarily disagree with this, providing the NAI policy is being consistently applied where NAI was proposed, the Policy could be across the three epochs, but there may be wider implications that should be considered by the assessment, changed in order to protect these areas? such as the potential for such areas to be used as mitigation or even compensation should there be a case made for Imperative Reasons of Over-riding Public Interest (IROPI) in relation to other policy units.

J2.1

See comments on J1.4 in relation to screening out specific policy units. Noted Further clarification will be added into this section too.

Comments Responses SMP2 Team Comments Proposed Action from? J2.3 Noted None We welcome the consideration of avoidance and mitigation measures within this assessment. J2.4 Noted Fo llowing discussions with NE and CCW and based on the agreements we come to, we will need to be The Regulations clearly set out the process for making a case for IROPI if the Plan authors feel that a policy clearer about the case for IROPI, if at all needed must be implemented, regardless of the adverse effects that may occur on the site(s). The first element of this process is to confirm there are no alternatives to the proposals followed by a number of other steps which may differ depending on whether a priority habitat or species is present, and often involve a lengthy process to identify the availability of adequate compensation measures. Finally, it should be noted that the ultimate decision on whether there is a case for IROPI does not lie with the competent authorities but with Westminster or the Assembly and ultimately the Commission. The complexity of this process should not be underestimated and this Assessment should make this clear. J2.5 Noted None We welcome the additional studies (CETaSS) being carried out to inform lower tier assessments of projects and schemes. J4.1

J4.2 See comments on J1.4 in relation to screening out specific policy units. Noted Add further clarification J4.3 We will see if these conditions can be met to clarify We note your conclusion that there is insufficient information, at this stage, to determine whether the Noted. In a similar way to the SMP assessment being undertaken now, the approach NEW and NW SMP2 will have adverse effects on the international and European sites identified and, EA policy is for strategies to also go through HRA. therefore, the intention to defer detailed assessment to the project and scheme level. This is not an ideal situation, as the guidance is clear that where it can not be ascertained that a plan will not have an adverse effect on site integrity then that plan must not progress to adoption. However, it may be an acceptable approach providing certain conditions can be met. Firstly, it must be clear that this appraisal can not reasonably assess the effects of the SMP2 on the identified sites in a meaningful way. Secondly, the assessment of the lower tier plans/projects (the detailed scheme HRAs) must be able to change the nature, scale and/or location of the proposals so that adverse effects can be avoided. These assessments, therefore, must not be constrained by location specific policies in the SMP2. Finally, the assessment of the lower-tier plan or project must be either legally required or will be carried out as a matter of policy. It is clear that some of the proposed policies for certain cells clearly have the potential to have adverse effects and, and given the nature of the SMP2 process, strong caveats must be included in the Plan to ensure that projects will not be constrained in how much they can alter the policy at the detailed scheme design/implementation stage. See comments below for discussion of specific policy units. J5.1 We should look at these strategic policy documents We welcome the comprehensive list of plans and projects that have been considered in this element of the Noted to see how they could potentially act in combination assessment. However, we are disappointed that a number of significant strategic policy documents relevant with the SMP to North East Wales do not appear to have been considered, such as the National and Regional Transport Plans, NE Regional Waste strategies, Wales Spatial Plan and detailed NE Wales Spatial Plan Areas and the relevant Environment Agency strategic documents such as Catchment Flood-risk Management Strategies (CFMPs) and the Dee River Basin Management Plan, though we note that the CFMPs have been included in the discussion in section J6.3.

Comments Responses SMP2 Team Comments Proposed Action from? J6.1.1 Sub Cell 11a (a) Llandudno We need to further discuss this with consultees We note that “coastal squeeze” has been identified as a potential impact leading to adverse effects on a Noted number of sub-tidal and inter-tidal features in the Menai Strait and Conway Bay SAC. We also note that the terrestrial features of the Great Ormes Head SAC are unlikely to be adversely affected by the policy proposals. While CCW would potentially welcome the use of soft engineering options as alternatives to hard coastal defences in certain areas of this policy cell, these may also have their own impacts on the site features and would require more detailed appraisal before being carried out and, therefore, their use as a potential mitigation measure needs to be qualified. Also, while we welcome and support the clear recommendation that more detailed strategic and project level HRA will be required to “explore the practicality and feasibility of this policy option”, it should be noted that this is not a mitigation or avoidance measure but a requirement of the process due to the level of uncertainty in the assessment. We do welcome the acceptance that the more detailed strategy will need to demonstrate no adverse effect before this policy can be implemented, but have some reservations over the ability of the preventative measures identified to effectively prevent the impacts of coastal squeeze should they be identified as a result of the more detailed assessments. Therefore, we feel the conclusion of “no adverse effects” may be a little premature. J6.1.1 Sub Cell 11a (b) Point of Ayr to Mostyn, south of Mostyn Dock We need to further discuss this with consultees We note that “coastal squeeze” has been identified as a potential impact leading to adverse effects on a Noted number of sub-tidal and inter-tidal habitats and bird features of the Dee Estuary SPA, Dee Estuary Ramsar Site and Dee Estuary SAC (please note that all these sites are now fully designated or classified). We also note that there are no adverse effects identified for the two lamprey species features. While CCW welcomes and supports the clear recommendation that more detailed strategic and project level HRA will be required to “explore the practicality and feasibility of this policy option”, it should be noted that this is not a mitigation or avoidance measure but a requirement of the process due to the level of uncertainty in the assessment. We also welcome the acceptance that the more detailed strategy will need to demonstrate no adverse effect before this policy can be implemented, and support the recommendation to develop a long term monitoring programme and Estuary wide habitat creation plan. However, we have some reservations over the ability of the preventative measures identified to effectively prevent the impacts of coastal squeeze should they be identified as a result of the more detailed assessments, particularly as the assessment itself identifies the likely need for new habitat creation. Therefore, despite the positive sedimentation environment of the Dee Estuary, we feel the conclusion of “no adverse effects” may still be a little premature.

Comments Responses SMP2 Team Comments Proposed Action from? J6.1.1 Sub Cell 11a (c) Mostyn t o Flint Marsh We need to further discuss this with consultees CCW understand that this policy unit has different policy option proposals for the three epochs with Noted managed retreat proposed for the medium and long term. We note that “coastal squeeze” has been identified as a potential impact leading to adverse effects on a number of sub-tidal and inter-tidal habitats and bird features of the Dee Estuary SPA, Dee Estuary Ramsar Site and Dee Estuary SAC (please note that all these sites are now fully designated or classified). We also note that there are no adverse effects identified for the two lamprey species features. While CCW welcomes and supports the clear recommendation that more detailed strategic and project level HRA will be required to “explore the practicality and feasibility of this policy option”, it should be noted that this is not a mitigation or avoidance measure but a requirement of the process due to the level of uncertainty in the assessment. We also welcome the acceptance that the more detailed strategy will need to demonstrate no adverse effect before this policy can be implemented, and the potential to use the managed retreat option as a potential mechanism to provide compensatory habitat both within this unit and from within the wider estuary. We note that there may also be a number of issues with this option in terms of contaminated land and these should be fully assessed at the strategic and project levels. However, we have some reservations over the ability of the preventative measures identified to effectively mitigate the impacts of coastal squeeze should they be identified as a result of the more detailed assessments, particularly as the assessment itself identifies the likely need for new compensatory habitat creation. Therefore, despite the positive sedimentation environment of the Dee Estuary, we feel the conclusion of “no adverse effects” may still be a little premature. J6.1.1 Sub Cell 11a (d) Flint Marsh to Chester Weir to Sealand Rifle Range (inner Dee Estuary, both bank s) We need to further discuss this with consultees CCW appreciate that this policy unit has a higher degree of uncertainty associated with than some of the Noted others but note that while managed retreat is being considered as a potential option in the medium to long term time period, the recommended policy for the three epochs is hold the line. We note that “coastal squeeze” has been identified as a potential impact leading to adverse effects on a number of sub-tidal and inter-tidal habitats and bird features of the Dee Estuary SPA, Dee Estuary Ramsar Site (please note that these sites are now fully designated or classified), Dee Estuary SAC and river Dee and Bala Lake SAC. We also note that there are no adverse effects identified for the two lamprey or Atlantic salmon species features or River habitat feature. We would welcome further study into the potential for habitat creation in this cell if managed retreat is proposed in future. While CCW welcomes and supports the clear recommendation that more detailed strategic and project level HRA will be required to “explore the practicality and feasibility of this policy option”, it should be noted that this is not a mitigation or avoidance measure but a requirement of the process due to the level of uncertainty in the assessment. We also welcome the acceptance that the more detailed strategy will need to demonstrate no adverse effect before this policy can be implemented, and the potential to use the managed retreat option as a potential mechanism to provide compensatory habitat both within this unit and from within the wider estuary. We note that there may also be a number of issues with this option in terms of contaminated land and implications for the navigable channel of the Dee and these will need to be fully assessed at the strategic and project levels. However, we have some reservations over the ability of the preventative measures identified to effectively mitigate the impacts of coastal squeeze should they be identified as a result of the more detailed assessments. It is possible that if a managed retreat option is adopted then mitigation could be carried out as outlined, but if a hold the line policy is maintained for the three epochs then the assessment itself identifies that new compensatory habitat creation will need to be considered. Therefore, despite the positive sedimentation environment of the Dee Estuary, we feel the conclusion of “no adverse effects” may still be a little premature.

Comments Responses SMP2 Team Comments Proposed Action from? J6.1.1 Sub Cell 11a policy units e – l. We need to further discuss this with consultees and These policy units do not lie within Wales but have the potential to impact on cross-border sites (the Dee Noted the requirement for IROPI if conclusion needs to be Estuary SAC, SPA and Ramsar and/or Liverpool bay pSPA). Any mitigation measures proposed as a result of changed these policy proposals must take into account the impact on the sites as a whole and we welcome the recommendation made to develop and implement a holistic strategy for the Dee Estuary and the wider sub cell. As outlined above, while we welcome and support the intention to carry out additional strategic and policy level HRAs and to make the detailed implementation of the policy dependent on the outcomes of these assessments, this should not be regarded as mitigation. In addition, if loss of habitats does occur as a result of the policy proposals and this can not be mitigated or avoided then the alternatives proposed, in terms of replacement habitat creation, would be compensation (ie adverse effects have not been avoided) and would need to be considered as part of any case for IROPI that may be put forward. As the assessment currently stands, with the exception of those units where a NAI option is proposed, we think it is premature to conclude that there will be no adverse effects as a result of these policy options. Table 4 sub cell 11a – Summary of “in combination” impacts on international sites. This table will be re-named We are somewhat confused by this table which appears to summarise the cumulative effects of the It is cumulative effects between sites, rather than in combination with proposed SMP2 policies on the designated sites and possible mitigation and compensation measures rather other plans and programmes than an assessment of any effects in combination with other plans and programmes and projects. We assume that this is a mislabelling of the table and therefore refer to our comments above in relation to the cumulative effects identified. J6.3 In combination Further explanation and clarification can be added See also our comments on section J5.1. We note that the only plan identified with the potential for “in Noted combination” effects with the NWE and NW SMP2 is the River Dee CFMP. We do not fully understand the

arguments made as to why the SMP2 policies will not lead to in combination effects with the CFMP policies. While we appreciate that the SMP2 is concerned with coastal flooding and the CFMP with fluvial flooding, there is a considerable crossover when considering effects, particularly where the tidal sections of rivers are

concerned, and this is acknowledged in the narrative itself. There is clear potential for policies and proposals within the CFMP to have “in combination” effects with the SMP2 on the integrity of the European and international sites identified. For example, maintaining or enhancing fluvial defences might only lead to

minimal losses of the habitats identified in J6.1 but when combined with losses due to coastal squeeze resulting from similar policies within the SMP2 then an overall adverse effect could manifest itself. This can be changed if deemed necessary through We appreciate that the report identifies this uncertainty and recommends further study is required to We will need to address this in discussion with NE/CCW consultation ascertain what the consequences might be, but we would welcome further clarification on the conclusion

that no policies have the potential to lead to an “in combination” effect, particularly given the report then

goes on to state that; “there is the potential for some of the proposals of the NWE&NW SMP2 to have in combination effects with the River Dee CFMP” in the next paragraph.

We also are somewhat surprised that, given the number of significant infrastructure elements that run along We can look further into plans and policies Noted the North Wales coast and Dee Estuary, and identified in this SMP2, that none of the relevant regional policy documents, strategic plans or local development documents have been included, or if included, have been found to have no potential “in combination” effects. We would have anticipated that the regional transport plans and proposals relating to coastal development and ports would have at least some potential effects in combination with the NWE&NW SMP2 and it may be useful to clarify why this was found not to be not the case.

Comments Responses SMP2 Team Comments Proposed Action from? J7.1 Summary This needs further discussion with NE and CCW We note that the final paragraph of the summary only mentions that appropriate mitigation and /or Noted improvements leads to an overall conclusion of no adverse effects. This is not consistent with the rest of the

report. As stated in our comments above, it is possible that mitigation (and avoidance) measures may enable any adverse effects identified to be avoided. However, this HRA identifies both high levels of uncertainty and the likely requirement to compensate for impacts on features that will be lost as result of coastal squeeze

caused by the implementation of the policies. It is accepted that in many cases uncertainty is such that the high tier plan can not ascertain whether there will be an adverse effect and that, given certain provisos, the assessment can be deferred to lower tier assessments.

We note that this argument is used extensively in this report and welcome and support the clear We need to make the implications clear if the plan Noted recommendations for strategy and project level assessments to be carried out and policies to be proceeds in this way

implemented only when the findings of such assessments are known. This is not mitigation, however, but an

acknowledgement that the assessment has not been able to ascertain “no adverse effects”. It is possible for

the plan to proceed in this situation but it must do so with a clear understanding of the implications of

deferring the assessment. Review the document to ensure that these terms There also appear to be some confusion over the difference between mitigation measures and Need to ensure mitigation/compensation terminology is correctly used are correctly used compensation measures. Mitigation and avoidance measures will prevent any likely significant effects from

manifesting themselves as adverse effects, thus enabling site integrity to be maintained (as defined by the sites’ conservation objectives). Compensation implies that an adverse effect will occur and site integrity will be compromised (for example the loss of inter-tidal habitat as result of coastal squeeze and it’s replacement outside the site boundary). Mitigation should be considered as part of the appropriate assessment process and included with the outcomes and recommendations. Compensation must not be considered as part of the assessment and should only be considered once the case for IROPI has been made (Regulation 53 or Regulation 85C of the amended Regulations). There are numerous points within this Assessment where “compensation” is referred to and the implication is that features within the sites are likely to be compromised by the implementation of a certain policy (subject to more detailed assessment) and that alternative habitat will need to be created This may be simply be confusion of terminology and all references to “compensation” actually mean to refer to “mitigation” but this should be clarified as a matter of urgency as it currently leaves this assessment, and therefore the SMP2 itself open to challenge. J7.2 Conclusion Identify potential adverse effects at high level and See comments above. We understand and appreciate that this HRA has concentrated on the impacts of the We could go through the report and identify where at all possible any detail approach more comprehensively proposed SMP2 policies on the European and international sites identified rather than project level impacts potential adverse effects could be identified. Incorporate the 3 pre- that may occur as a result of implementing those polices. We also appreciate that the level of detail that can requisites that should be met before adopting the approach. be considered as part of a plan level assessment is not the same as would be the case for a project level

appraisal. However, we must emphasise that this assessment must still address the potential adverse effects as far as is practicable before deferring assessment down to the project level. It should also show that the three conditions for deferment are met before adopting this approach; these are that it is not possible for the plan to determine the effects at this level, that the lower tier plan or project is subject to HRA through legislation or policy and that the Plan is capable of being amended subject to the findings of the more detailed assessment. We welcome, therefore, the firm recommendation that there will be a need to carry out more detailed, project level, HRAs on specific development proposals and specific policies will only be implemented subsequent to the findings of those assessments. We do, however, feel that the assessment needs further clarification before we can fully concur with an assessment of no adverse effects. These particularly relate to issues of mitigation and compensation but there are also a number of effects in combination with other plans, policies and programmes that need to be further considered or, if already considered, then a more comprehensive rationale for their exclusion included. It may be possible to resolve many of the points raised by clarifying the methodology or text but as it currently stands we feel that this HRA appropriate assessment is not completely consistent with other SMP2s being developed and contains some significant discrepancies that may leave it open to challenge.

Comments Responses SMP2 Team Comments Proposed Action from? PCR_174 North West England and North Wales Shoreline Management Plan 2 (SMP2) – Consultation on Habitats Noted None Regulations Assessment (HRA) ‘Appropriate Assessment’ Natural England Thank you for giving Natural England the opportunity to comment on the HRA proposal for the North Noted None West England North Wales Shoreline Management Plan (SMP2). Our comments are made in the context of

our role as a Competent Authority under Regulation 48 of the Habitats Regulations 1994. Please note that our comments should be read in conjunction with those from the Countryside Council for Noted None Wales as the issues raised may be relevant to the assessment for the whole of Cell 11.

We note that there is a need in the report to clarify the difference between ‘mitigation’ and ‘compensation’, Need to ensure mitigation/compensation terminology is correctly used Review the document to ensure that these terms both in terms of their definitions and their relative roles in the process of managing impacts on a site. are correctly used Noted The EC Guidance Paper on Article 6 (4) identifies Mitigation measures as ‘Those that aim to minimise or

even cancel, the negative impacts on a site that are likely to arise as a result of the implementation of the

plan or project’. Mitigation should be considered part of the Appropriate Assessment process and included

with the outcomes and recommendations. Compensatory measures are independent of the plan or project

(including any mitigation measures). They are intended to offset the negative impacts of the plan or project

so that the overall ecological coherence of the natures 2000 network is maintained.

Compensation should only be implemented in the event the proposed plan or project for the site must be None Noted undertaken for imperative reasons for overriding public interest; in spite of a negative assessment of the implications for the site. None Compensatory measures are independent of the plan or project (including any mitigation measures). They Noted are intended to offset the negative impacts of the plan or project so that the overall ecological coherence of

the natures 2000 network is maintained. Noted Compensation should only be implemented in the event the proposed plan or project for the site must be None

undertaken for imperative reasons for overriding public interest; in spite of a negative assessment of the

implications for the site.

With reference to J6 1.2 Sub Cell 11b section H (Hutton Marsh), it is stated that private upgrading of sea None Noted defences has caused some parts of the SPA to be in unfavourable condition and that it should be brought back under tidal influence. It may be necessary to refer to the timing of the upgraded work and the designation, to ensure that any work to bring the area under tidal influence is carried out in line with the

conservation objectives of the site. Noted It can be included Natural England feel that due to its proximity to the coast, the Duddon Mosses SAC should be considered for inclusion in the Appropriate Assessment process. It is noted that on several occasions in the Strategic Environmental Assessment document that the impacts of the proposed polices are currently uncertain. Clarification of how these impacts are being identified, an

indication of their severity and a proposed timetable of impact and associated management would be beneficial. Natural England would also like to have clarified how these factors have been integrated into the Habitats Regulations Assessment.

Regarding the Water Framework Directive assessment, Natural England acknowledge that the majority of Noted Management Areas in North West England and North Wales SMP2 area bodies will not see deterioration in Ecological Status or Potential of the water bodies and therefore there will not fail the WFD Environmental Objectives. Further to this, areas where the preferred policy options have the potential to fail in meeting the

WFD policies, justification for policy selection, the necessity for monitoring, and mitigation measures have been identified. Natural England would like to take the opportunity to reinforce the need for any flood risk strategy to account for coastal processes, continued monitoring, and sign up to mitigation measures suggested within the SMP2 process.

4.12 Appendix K Comments Responses SMP2 Team Comments Proposed Action from? PCR_115 In general, the assessment is good, covering everything as set out in the guidance. Noted. EA Wales The glossary section at the front is very useful. I think a section needs to be included about other Environmental Designations, relating them to the WFD as Noted. Consider adding a section in to the appendix in the guidance - 'Where there are sites protected under other EU legislation (such as the Birds or Habitats Directive), the Directive aims for compliance with any relevant standards or objectives for these sites. Therefore where a site which is water dependant in some way is protected via designation under another EU Directive and the Good Ecological Status/Potential targets set under the Directive would be insufficient to meet the objectives of the other relevant environmental Directives, the more stringent targets would apply.' Is this a retrospective assessment (apologies for my ignorance) - if it is I think this needs to be explained. It Yes this assessment has essentially been retrospective . Add in words to say what stage the WFD was may be useful to state when, during the SMP process, it was started. undertaken I like the way the rivers have been included (ever if they weren't assessed), it was good to provide details of Noted. the methodology for this thinking. It may be useful to have more maps showin g the location of other waterbodies - there is only one showing Noted. Consider revising maps and the need for additional the Coastal and Transitional waterbodies - I think the colour coding of these waterbodies needs to be maps translated to the Assessment Tables (or vice versa) as it is slightly confusing as to what they correspond to in the Tables. A Groundwater location map would be useful. The management units that fail the WFD should be highlighted more in the tables, maybe just colour in the Noted. Consider making changes to the table column where it fails (with the 'x' in) in red to highlight it. A map would be good to show the management units that fail, to show this in a more pictorial way. Noted. Consider revisions to the appendix PCR_75 We welcome the inclusion of the WFD objectives assessment, however we are concerned that the Response is noted. Clarify monitoring actions and revie w mitigation mitigation measures proposed appear to be restricted to those in the River Basin Management Plans. proposals when taking into account all consultation RSPB Monitoring in itself cannot be considered to be a mitigation measure as in itself it makes no provision for responses. what happens if this monitoring shows deterioration is occurring. Article 4.7 of the Water Framework Directive (2000/60/EC) states that environmentally better options must be examined before proposals that

could cause waterbody deterioration can be brought forward. The key consideration in the choice of environmentally better options in this instance is the potential impacts on Natura 2000 sites and clearer links must be made between the Appropriate Assessment of this plan for the requirements of the habitats

directive and the WFD assessment. It must be made clearer which environmentally better options have Improve links between the AA and WFD when been considered and how the conclusions from the WFD report have been taken into account in the main finalising the appendices and main report. SMP document.

We note in the Discussion and Conclusions section that several Units are identified where the SMP2 may

impact on WFD objectives for the waterbodies concerned.

For Units 11c 2.3/2.4, 11c 7.1/7.3 and 11a 7.4/7.6, we have made comments supporting the proposed preferred policies. Clearly, this support would be subject to the comments made above in relation to Support has been noted. Natura 2000 sites and WFD objectives at these locations.

4.13 Appendix L

Response Response SMP2 Team Comments Proposed Action from? PCR_115 L2: Would this be more useful as a metadata table – so we know the dates of the datasets (which would The data collection phase of the SMP2 took place in 2008 and we No action required. be useful for future studies)? suggest that by the time further studies take place some of the data will EA Wales have been superseded. So we are not sure further work to develop this would be worthwhile.