Bacton Response to SMP

25 May 2005

From: Coastal Concern Bacton

(A group of residents concerned by the implications of the Shoreline Management Plan)

Dear Norman Lamb,

Re: Letter from Elliot Morley 31 March 2005

(214224,214567,214576 and 214510)

Mr. Morley has requested that the contents of his letter be relayed to your constituents. We, therefore, felt it appropriate, as a group, to reply to Mr. Morley's letter. We have arranged our comment under the same headings as provided by Mr. Morley.

The demand for defences and priority scoring

To exaggerate the argument of the opposition to a point of absurdity is an old but hardly reasonable debating strategy and we know of no person who has asked for Britain to be surrounded by concrete. We trust that our politicians will listen to our reasoned arguments concerning sea defences because we consider the proposed policy to be wrong both for coastal residents and the Nation as a whole. Working with coastal processes sounds a nice romantic idea to justify areas of no active intervention until one realises that it means sacrificing peoples' homes to the sea.

The present pressure for better coastal defences, we submit, is a function primarily of decades of neglect by successive governments. The pressure for better flood defence inland, arises primarily from the foolhardy opening up of planning consent to build on flood plane areas. The present problem can be seen as primarily a consequence of short-sighted policy in the past, rather than global warming. Inevitably, at some point, the cost of these prior short term policies becomes all too apparent.

Now, there is a competition between coastal and inland flood defences for what has become an inadequate annual budget (even though it has been increased).

The coastal community feels aggrieved that it has been treated differently from inland areas which have received much greater sympathy and a disproportionate share of the budget.

Why is it that we do not hear of Floodplain Management Plans or of the evacuation of any inland homes because it is too expensive to provide flood defence, whereas we do hear of peoples homes being sacrificed to the sea with the owners being financially ruined? Why should certain unfortunate individuals on the coast pay the price of past policy whilst the inland flood plane property developers have already made large profits for which the National community now has to pay the price with flood defences?

The prioritisation of schemes, despite having an improved formula, still presents major problems. The main problem is the all or nothing outcome. Once approved, there seems to be no proportionate ceiling put on the budget. Thereby, a large budget is given to provide luxury sea defences for Southwold when nothing is given to assist the equally worthy but smaller community at Happisburgh. We know of no individual who thinks this is either fair, reasonable or proportionate but rather it is seen as cruel and divisive.

The priority scheme also allowed an unnecessarily expensive scheme to provide inappropriate island defences at Gorleston. Fortunately, the local residents seem to have been listened too and a much cheaper but adequate scheme approved.

The priority scoring system by failing to take account of longer term expenses is not able to spend relatively small amounts now in order to save much larger sums being spent in the future. As it takes no account of longer term expenses it is inappropriate to apply such an approach to long term planning.

These examples, show how the prioritisation formula has the potential to be both unfair and disproportionate with consequent wastage of public money.

Additionally, because island defences give very good defence to some parts of the coast they surely mitigates against the aim of working with, rather than against coastal processes. In the case of the installation at Eccles and Sea Palling there appears to be greater erosion at either end of the system with sea water now entering the Norfolk Broads despite this very costly defence. Some will say this is a clear case of wastage of public funds, especially as local people had warned of this likely scenario but were ignored.

Sustainability must surely be another term for cost effective as we could, no doubt, not only maintain the present coast but reclaim land if there was sufficient economic advantage in doing so. Indeed, as the Shoreline Management Plans are attempting to look forward up to 100years it seems likely that during that period it would be advantageous to reclaim shallow areas of sea for a variety of purposes such as wave, wind or tidal power, fish or shellfish farming, leisure areas and marinas and airports or ports.

Not sustainable, therefore, can only be seen as another term for not cost effective in the long term. This would depend on several assumptions:

1. That funding continues to be provided largely as at present - whereas, over 100years it could well be more in the hands of Europe or local coastal taxes.
2. That the coastal erosion continues on present trends - but this is a large assumption dependent, as it is, on so many variable factors.
3. That engineering practices remain largely unchanged - which seems most unlikely. In the time scales considered, Civil Engineering may well be largely undertaken by robotic means. Already there is a composite concrete being developed that is many times stronger and more durable than reinforced concrete and that does not require the expensive process of steel re-enforcement. Such a material could revolutionise current engineering practice in the near future. Another relevant technology is wave power. Surely well within 100years we could see viable wave power with the additional benefit of calming inshore waters.

There is, we maintain, a good likelihood of considerable sustainability of the present shoreline into the future and the main obstacle to sustainability, at present, is a lack of determination. There needs to be some constructive thinking about alternative methods of funding.

What is required is not further revision of a formula, with blind loyalty to it, but the application of human intelligence with multidisciplinary advice to the complex problems involved. Too great a reliance on just engineering advice is likely to distort the planning procedure and sometimes sell the most expensive installation to the public purse.

Shoreline Management Plans

Whilst it seems reasonable to have a strategic plan for coastal defence the present remit has led to an inflexible plan which fails to take full account of long term cost, is insensitive to any future developments and is based upon long term predictions of very doubtful reliability or validity. It has been wise to have a trial run and we need to learn lessons from it, as the Plan is clearly inadequate.

The trial in this area has shown the inherent weakness of relying primarily on a single disciplinary approach i.e. civil engineering. A statistician would attempt to determine the extent of reliability in the predictions made and give us a recognition of the severe limitations on our ability to predict beyond a decade, at most. None of us would be happy about making decisions now on predictions from 10years ago, let alone 20,50 or 100years ago.

Also, we are far from convinced that sacrificing a proportion of coastline where there is no active intervention, will result in greater long term stability. Such a policy remains experimental and could well be a very costly experiment with much human suffering being the only sure outcome.

The costing and economic evaluations are to say the least over simplistic and could be improved by input from a range of relevant experts. Surely we should not make large scale and largely irreversible decisions, involving considerable sacrifice, on the basis of incomplete and unreliable evidence.

Taking an example, lets try to imagine what the situation would be in Bacton in 20years time when it is planned to cease maintenance of the sea wall. of course, we could imagine many entirely different situations.

Imagining just one possibility:

The sea wall was treated 5years ago, as a result of a European grant for all North Sea defences, with a compost material giving an expected life span of over 100years with little further maintenance. The predicted loss of beach material had not transpired because recent longer summers and shorter winters had reversed that trend. Currently, the inshore area was calmed by a combined wind and wave power installation and there was competition between the Cromer crab shellfish farming consortium and the local sailing clubs for further development of the marine environment. Onshore, the community had grown into a small town with the ever increasing international demand for coastal residence (as most people no longer needed to reside near a place of work) and property prices had soared. The possibility of abandoning this area to the sea would now be illegal without complete compensation and would be seen as irrelevant and unthinkable.

Common sense tells us that the best scientific predictions over such long periods as considered in the Shoreline Management Plans amount to little more than guesswork.

Any of the following might affect estimates of cost effectiveness:

Firstly factors affecting weather patterns or climate:

1. A major volcanic eruption or a series of large eruptions.
2. A submarine earthquake in the fault line off Norway or a major eruption in the Canaries causing tsunamis.
3. Major alterations of sea currents, especially any failure of the Gulf Stream.
4. Increased cloud cover.
5. Increased or decreased global dimming.
6. Changes in the rate of human activity e.g. as the result of global pandemics.
7. Changes in the concentration of atmospheric methane as a result, perhaps, of changes in diet away from meat or increased exploitation of methane from disused mines. Decomposition of marine methane hydrates following increasing sea temperatures.
8. Fossil fuels becoming increasingly expensive compared to other sources of power. Or other changes affecting the rate of production of carbon dioxide.
9. Longer or shorter summers in Northern Europe.

Secondly, Factors affecting the cost - benefit analysis:

1. Improved building materials.
2. Improved civil engineering methods.
3. Less or greater erosion than expected.
4. Changes to land use and residency.
5. Demand for land, particularly coastal land, with consequent changes of property values.
6. The continued advancement of leisure use and tourist value in coastal areas.
7. Changes in the use of inshore sea areas.
8. Advances in communication technology and political unity, making it easier for people to chose to live where they like and giving them more free time with greater resources to spend on sports and leisure.
9. Other technological changes such as robotics or wave and wind power.
10. Changes in the relative prices of building materials, staffing and other associated costs.

We insist that the protection of our National territory with all the heritage that it contains must be given a higher priority and value than appears to be the case at the moment. Furthermore proper ongoing maintenance of our existing defences with enhancement of them as necessary remains the best long term policy as it will be most cost effective in the long term.

Assistance to individuals and communities.

We do not accept that the community needs to adapt to a changing coastline when it is the individuals who happen to be living in the wrong place who have to take the full force of this with no National support.

We expect that the coastline be managed to protect our vital interests without callous sacrifice of the few for the sake of saving a very insignificant amount for the many. The scientific evidence contained in the SMP has poor face validity and little indication of reliability. It provides an inadequate basis on which to disregard principles of social justice.

The fact that the Government provides coastal defences under permissive powers is insufficient grounds for not providing compensation, because social justice should be paramount, and the Government can legislate, as necessary, to make compensation possible.

In any case we do not see the need to develop an inflexible plan that stretches over such a long time scale with so many uncertainties. We would rather see a flexible approach that allowed frequent review of policy as events unfold.

Aggregate dredging

A cautionary principle should be applied to aggregate dredging, as longer term effects of this are uncertain. It could be that negative effects on coastal erosion are difficult to quantify because of the large natural variation that hides these effects in the short term. It may be that effects are minimal until a threshold of volume extracted from a certain area is reached. Alternatively, effects could be cumulative, adding to a large effect over time, but insignificant on an annual basis. A further possibility is that effects are delayed in time. Such effects may not be revealed in short term studies and there would be suspicion of bias in any studies by the dredging companies themselves.

Human Rights Act

The impact of the Human Rights Act in the context of loss of property to the sea cannot be fully appraised until it has been tested in the courts.

Yours sincerely: