DOC’s Response to EA Consultation

PLANNING FOR THE FUTURE
FOLKESTONE TO CLIFF END FLOOD AND EROSION MANAGEMENT STRATEGY

Overall, DOC strongly supports the principles enshrined in this document of Holding the Line and upgrading coastal defences where necessary to achieve a  1-in-200 year level across Romney Marsh.  DOC is also encouraged by the Environment Agency’s recent commitment to more meaningful consultation with local stakeholders, and its apparent willingness to draw more fully upon the considerable local expertise in the fields of sea defence and drainage on the Marsh.  DOC regards it as essential that this close consultation be maintained as more detailed proposals for each stretch of coastline are developed.

Subject to such consultation, DOC’s main concerns lie in the timescale proposed for the works, and the steps that will be taken to ensure the safety of the Marsh and the integrity of its coastal defences during the period until the works are completed.

1.  Strategy

The overall strategy outlined in Planning for the Future enshrines the concept of Holding The Line across Romney Marsh.  In order to achieve this it proposes the upgrading and  improvement of several stretches of coastal defence where this is felt to be necessary in order to preserve their integrity for at least the next 100 years.  DOC has consistently argued for a Hold The Line policy across the Marsh.  The fact that it is below sea level, its unique saucer shape and its delicate network of freshwater drainage ditches make any other policy, in our view, untenable if the future of the Marsh is to be secured.  We therefore strongly support the EA’s commitment to this policy, and to its effective implementation

2 .  Consultation

For several years after the initial announcement of a revised sea defence strategy for the stretch of coast line between East Suttons and Dungeness in June 2004, local stakeholders were effectively excluded from the process of strategic development.  This was unfortunate, both because they were the ones most directly affected by the proposals under discussion, and because essential local knowledge of tidal flows, shingle movement, drainage and many other factors that they could offer was not being utilised.  Indeed, one could argue that this approach had existed for some time and was a contributory factor to the problems that have plagued the 2004 Littlestone scheme, which is generally considered to have been based on a miscalculation in the scheme’s computer-led design of the directional flow of the shingle along the Greatstone and Littlestone shore lines which those with local knowledge and experience had consistently pointed out.

We are therefore very heartened by the significantly different approach to consultation that the Environment Agency has adopted over the past year.  A genuine attempt has been made to involve local stakeholders, ranging from District and Parish Councils, organisations such as the Drainage Board, through to individual stakeholders with an interest in the outcome.  The Liaison Group has been transformed into a real forum for debate about the future of sea defence on the Marsh, and local expertise is being tapped into.  The strategy document itself reflects a welcome willingness to enter into meaningful consultation with those whose lives are materially affected by the decisions that will be taken, and further detailed consultation is promised during the design stage of the proposals.

3.  Detailed Proposals

DOC regards it as essential that close and meaningful consultation by the EA with local stakeholders be maintained as the EA begin to draw up more detailed proposals for each stretch of coastline.  The devil will be in the detail – whether it be in the preservation of local amenity (i.e. the kite-surfing at Broomhill); or in the application of local knowledge to mitigate costly errors brought about by an approach that is based too narrowly on theoretical, computer-driven models; or in the design of major works like a rock revetment wall, seeking ways in which it can be made to enhance the landscape rather than compromise it.  Local stakeholders must be fully involved at all stages of the process, working with the EA to ensure a result of which both sides can be justly proud.  For this to work, a proper structure for this stage of consultation needs to be put in place that is both robust and practical, so that stakeholder input is meaningful and can be effectively integrated into the design process.

Although the proposals in the strategy document are still at the broad-brush stage, which can elicit only fairly general responses, we have outlined below DOC’s initial response to each of them below:

3.1  Cliff End to Rye Harbour Arm

We have no specific comment to make, other than that we support the approach outlined in principle

3.2  River Rother west and east banks and Rye Harbour Arm

As was made clear at the recent Liaison Group Meeting on 4 July, there are some concerns about the ‘realignments’ to the River Rother proposed in this section.  This will be the subject of further discussion within DOC, and may result in a separate submission from DOC to the EA prior to the design stage

3.3  Royal Military Canal
We have no specific comment to make.  We support the approach in principle

3.4  Camber Sands
We have no specific comment to make.  We support the approach in principle

3.5  Broomhill Sands
This section, which will be the first to be implemented under the current strategy, will set the pattern for successful consultation on detailed design proposals, and as such is of very great importance.  It also encompasses a significant number of issues –  sympathetic design of the revetment wall; the nature and extent of the amenity beach to be preserved at the western end; preservation of the beach as a whole; beach access; preservation of other amenities such as the kite-surfing at Broomhill.  We would suggest that the EA draw up proposals for a robust and practical consultation process for submission to DOC as soon as possible, so that an effective structure can be agreed in good time

3.6  Lydd Ranges
DOC is particularly concerned about the timescale currently proposed for the work on Lydd Ranges and those concerns are dealt with in the section entitled Timescale below.  DOC is also concerned that Natural England, who have consistently obstructed the progress of reasonable proposals for this section, may launch a rearguard action to sabotage the EA’s proposed strategy in the name of their very particular interpretation of environmental improvement.  We would welcome reassurance from the EA that, should this be the case, the EA will stand firm in defence of its strategy to preserve the long term safety and security of Romney Marsh.

3.7  Dungeness Power Stations and Denge Marsh Sewer
Our comments are contained in the section entitled In the Short Term below

3.8  Dungeness Power Stations to Greatstone
We have serious concerns about the future of the Dungeness Borrow Pit, which are dealt with in the section entitled In the Short Term below

3.9  Greatstone to Romney Sands
We support the plan to improve these defences and to protect the dunes.  However, DOC has strong opinions on the efficacy or otherwise of the 2004 Littlestone scheme which affects both this and the neighbouring section.  Rather than detail them here, we propose to submit a separate paper on this subject from Tony Hills, who has studied it at length and who is already in discussion with representatives of the EA, the RNLI and the relevant local councils

3.10  Littlestone to St Mary’s
See above

3.11  St Mary’s Bay
We have no specific comment to make.  We support the approach in principle

3.12  High Knocke to Dymchurch
We have no specific comment to make.  We support the approach in principle

3.13  Hythe Ranges
Our comments are covered in the section entitled Timescale below

3.14  Hythe to Folkestone Harbour
We have no specific comment to make.  We support the approach in principle

4 . Timescale

DOC’s immediate concern is the timescale proposed for the works, in particular that for the Lydd Ranges.  The integrity of the Romney Marsh sea defences is only as strong as its weakest point.  And given the saucer shape of the Marsh, a significant breach at any point poses a material threat to the whole.  The current state of parts of the Lydd Ranges’ sea defence is assessed as a 1-in-5 year level, and yet work on this stretch is not envisaged to start until around 2015, with a finishing date of 2020.  You don’t need to be a mathematician to see the problem.

We understand that the MOD do not wish both their vital ranges at Lydd and Hythe to be out of action at the same time.  We also understand the need for a timely start on the improvement to the sea defences at Hythe, given the housing density at risk in that location.  However, we would urge the Environment Agency very strongly to consider extending the work on the Broomhill/Jury’s Gap section, planned for 2010 – 2012, so that it includes the strengthening of the Green Wall and the groyne enhancement as far as Midrips in the Lydd Ranges.  This will take care of the part of the Lydd Ranges frontage that is most at risk, enabling the works to move in a timely fashion to Hythe Ranges, and returning once that is completed to finish off the longer but less urgent section of Lydd Ranges from Midrips to the Denge Marsh Sewer.

5 .  In the Short Term

DOC also has serious concerns about the defence of the Romney Marsh coastline in the period until completion of the works envisaged in the EA’s strategy document, given that work is not scheduled to begin until 2010 and will not be completed until 2020, even assuming there are no problems with planning permission, design or finance.

Our concern is sharpened by the opposition of Natural England to the continued use of the Dungeness Borrow Pit, which has long been the source of recycled shingle to maintain the sea defences both of the Dungeness Power Stations and the sections of Marsh coastline currently most at risk of breach in an extreme weather event.  As a result of this opposition, the EA’s 2006 planning application for use of the Borrow Pit in the short to medium term has stalled within Kent County Council, and appears to be in an administrative limbo.  Not only is this necessitating the use of shingle from other sources, with massive cost implications and, in the case of onshore shingle extraction, a considerable adverse environmental impact on the Marsh.  But also the aggregation of shingle which is no longer being recycled, along with shingle being moved south along the shoreline from Littlestone, is beginning to cause serious practical problems which urgently need to be addressed.

DOC understands only too well the apparently unlimited power of Natural England within an area designated a Special Area of Conservation.  However, we refuse to accept that an unelected quango, however wide its remit, can be allowed to impose arbitrary and highly contentious views on environmental ‘improvement’ without any possibility of their basis being challenged.  There are a number of possible solutions to the current impasse, and DOC would welcome the opportunity to discuss them constructively with the EA.  We would also ask that a full and detailed briefing on the EA’s plans to preserve the integrity of the Romney Marsh sea defences in the short to medium term be made available to DOC within the next month.

DOC (Defend Our Coast Association)
1st August 2008