27 June 1997

Dear Chris
Dredging on Helwick Bank
Thank you for your consultation of 6 June on the request for a further extension of Llanelli Sand Dredging Ltd's existing licence.
We do not fully understand the figures given in your letter. If the to date amount is 280,000 tonnes, does this mean that no extraction has taken place between 1 February and 'to date'? This would be the implication if a further 50,000 tonnes is likely to be extracted by 31 July!
On this basis, we would have some significant reservation about extending the licence because it would appear that the demand is not there and the estimate of amount to be extracted is a considerable overestimate. Thus it would be very difficult to suggest, if an extension were required, what it should be.
We have no evidence that an extension is required. However, if there really is a need, we would consider an extension of a year so that the maximum that could be removed would be the original 400,000 tonnes. We are concerned that if sand is extracted from the Helwick Bank, that it is steadily extracted and excessively large amounts are not removed in a short period. Such extraction could well cause instability in the erosion/accretion cycle with knock-on effects to the sediment transport in the pSAC nearby. We therefore suggest that a condition be added to cover rate of extraction, for example that no more than 20,000 tonnes may be extracted in a three month period.
This would enable the EA on the new study to be produced and ' a careful assessment of it made before a decision is made on the new application. We do not wish to see haste in making this decision because a new deadline is imminent. I hope you find these comments helpful.

Yours sincerely

Dr Tony Prater (Deputy Wales Officer)

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