18/5/00 NO CLEAR RESPONCE RECIEVED

Mr C Morgan
Planning Division
Welsh Office Cathays Park
CARDIFF CF 1 3NQ

Dear Mr Morgan

9 December 1997

LLANELLI SAND DREDGING LTD - GOVERNMENT VIEW, HELWICK BANK

I am now in a position 'to respond formally to your letter of 26 September following a meeting of the full Committee on 5 December.
The Committee noted the conclusions of the consultants for the Bristol Channel Marine Aggregates Resources and Constraints Research Project (Newsletter No. 3). Here they recognised that there are gaps in environmental data including on demersal fish using the banks, and general data in the northern part of the Outer Bristol Channel, and an inadequate understanding to enable the prediction of potential longer term dredging impacts. The filling of such data gaps will require more research.
The Committee considered the Consultancy report it commissioned on the Cribb Environxnental Assessment appended to the application. It noted that the impartial report by the Consultant agreed entirely with the Committee's previous viewpoint, that the Assessment was inadequate for a number of reasons.
I enclose a copy of my report to Committee, and a copy of the Consultants report on the Gibb Environmental Assessment.
In conclusion, the Committee agreed to all of the recommendations listed on page 4, notably that a precautionary approach should be taken, and the application should be limited to the current rate of extraction (100,000 tonnes per year) for a maximum of five years, and renewal beyond this point should be conditional.
I trust that you will address the views expressed within the enclosed documentation before deciding whether to give a positive view.

Yours sincerely

P J Coates Director
Enc.

cc: The Crown Estate, Marine Estates, 16 Carlton House Terrace, London, SWlY SAH
MAFF Environmental Protection Division, Nobel House, 17 Smith Square, London SWlP 3JR

ITEM 11 (a),

Application bv Llanelli Sand Dredgins Ltd to take Aggregate from Helwick Bank.

Llanelli Sand Dredging Ltd has held a licence to take sand from the Helwick Bank from February 1993 to February 1997, allowing up to 400,000 tonnes over 4 years at a maximum rate of 100,000 tonnes per year. An extension was allowed of up to 50,000 tonnes between February 1997 and July 1997, and a second extension of up to 50,000 tonnes until January 1998. Arising from an undertake of quota in the initial 4 years of the licence, even with the two extensions, the total limit of 400,000 will not be exceeded.

2.1 On the 24 May 1996 Crown Estate Commissioners (Marine Estate) commenced informal consultations on a proposal to extend aggregate dredging on the Helwick Bank and double the rate of annual extraction to 200,000 tonnes per year. Two reports were enclosed: "A Study on the Impacts on the Coastline" by H R Wallingford (Ex3371); and "An Environxnental Assessment of Proposed Dredging on the Helwick Bank" by Gibb (Wales) May 1996.

2.2 In 1992 Gibb (Wales) produced an Environmental Statement which accompanied the original application. The report attempted to address the environmental impact of the proposal, particularly as it related to bottom living marine life (benthos), fish and other predators. The Committee raised concerns which were not covered in the original draft. The final report re-iterated the Committee's concerns but did not address them! Nevertheless, on the basis of both the application and the supporting information, Welsh Office gave a positive formal Government view in 1993.

2.3 At the informal application stage of the current application (May 1996), ofEcers and Dr S Shackley offered critical comment on the revised Environmental Assessment by Gibb, and sent this ta Crown Estate in July 1996. Gibb had attempted to undertake some fisheries and environmental survey work, but this had been extremely unprofessional in approach, and the assessors appeared to have lacked even basic survey experience. We concluded that the benthic survey could be considered, at best, to be a one off, qualitative survey, when it was clearly intended to be all encompassing and quantitative. The fisheries survey was marred by the operators inability to handle the equipment, and again was a one off Further survey techniques also needed to be deployed. Additionally, critical questions were left unanswered on the abundance, distribution and behaviour of sandeels in relation to the specific habitat, and an assessment of the overall importance of the bank to the general fisheries area (including sandeels).

2.4 On the 26 September 1997, Welsh Office planning department have undertaken a formal consultation with regard to the formulation of a full Govemment view in response to an application from Llanelli Sand Dredging Ltd to obtain a new licence to dredge for 200,000 tonnes per year over a 10 year period (2 million tonnes in total). 3. Cribb Environmental Statement was a report by H R Wallingford (Ex 3546 August 1997)'Study of Impacts on the Coastline.' Also a report by Gibb "Environmental Statement for Proposed Dredging on the Helwick Bank", dated August 1997.

3.1 Although some minor amendments to the text on the original draft of May 1996 were apparent, the report did not appear to call upon further primary survey work, and the omissions highlighfed in the original draft were still apparent! It is difficult to draw any other conclusion than the Consultants, and Crown Estate Commission have paid lip ser~%ace to the comments provided by Committee's~ representatives.

3.2 Accordingly Dr E I S Rees, an indepensde:~.t marine scientist based at the Marine Science Laboratories, Bangor, has been co~~missioned to provide an impartial and critical examination of the report. This report is appended.

3.3 Dr Rees states in a letter that adequate advice was not obtained from experienced benthic ecologists, either before undertaking the sampling, or in writing up the results, and the data in the report appears so flawed that it can make little or no contribution to the biodiversity aspects of the broader strategy. He also suggests that in any long term dredging strategy if it was decided to conserve the ecology of any linear bank, then the Helwick Bank may be a good candidate. Finally, he recommends that the application should be held over until a proper aggregate dredging strategy has been prepared for the whole Bristol Channel, and that this larger study provides a proper review of the related ecological and fishery aspects.

4. Study of Impacts on the Shoreline (HR EX 3546)

4.1 The report discusses the sand reserve, the history and effect of past abstraction, the currents and sand transport modelling, sediment transport pathways, changes in the volume of the bank, effects of waves on the coastline, etc.

4.2 The Director's summary of the main conclusions are:
· That the bank is stable in time, although redistribution of sediment occurs across the bank, for example, due to storm (wave) events.
· That there is no evidence that previous dredging (193,444 tonnes between 1993-95) has reduced the,size of the bank. Notably, since the bank has not changed in size, natural transport processes must have compensated for the volume extracted.
· That there is no evidence that reducing the size of the bank would reduce the sand on local beaches, although sand loss on these beaches could theoretically affect the bank. Wave action may be increased however.
· That the source of sand for the bank comes from the surrounding sea bed, particularly from the south and east, and not the beaches, and that it moves in a clockwise circular way around the bank system.

4.3 If the bank has not decreased in size since dredging started, due to sediment transport onto the bank to replace that moved, the question is begged, would the bank have increased in size had there been no dredging? If the answer is "no" because the bank is a stable structure, perhaps dredging activity could take sand that would be otherwise lying locally on the sea bed close to the bank, or perhaps lost from the system within the general westerly movement of sand out of the Bristol Channel, and as identified by the global Welsh Office study? 5. Discussion 5.1 Clearly the study of the biodiversity aspects associated with the application has not been furthered by the work undertaken. There remains many questions that need to be addressed.

5.2 In late 1989 / 90 the Committee suggested to Crown Estates :
i) That they pay for all studies relating to the initial exploitation of aggregate from any bank system from the pool of revenues received from aggregate landing levies. We argued that the current system where the initial applicant pays for the survey would result in the production of inferior environmental assessments. I believe the current case is an example of this failing.
ii) That a full Environmental Impact Assessment for all initial applications was essential, and that it must be afforded the ca:ne priority as the Coastal Defence Study (which Crown Estates has made mandatory).

5.3 The Wallingioru reports appear to be comprehensive. The consultants indicate that beach erosion is unlikely to become a problem; but they refuse to be fully committal because of the from inshore areas which could adversely impact fisheries; and:
i) To object to proposals to renew aggregate dredging licences on both the Nash and Helwick Banks, at least until the Welsh Office (Bristol Channel Marine Aggregates) study has been completed, and any implications that may arise had been taken into consideration.
ii) To draw the attention of the developers to the perceived shortcomings in their environmental impact assessments as they relate to the survey of fish and other marine life. In particular, in relation to the Helwick assessment, to suggest that a new firm be chosen which has a greater expertise in marine environmental research.

Recommendations

To recognise the requirements of the aggregate industry for sand derived from marine source and the Conclusions of the H R Wallingford study, that the Helwick bank is stable despite recent aggregate extraction.
To acknowledge the continued lack of understanding of the importance of linear sandbanks as marine habitat, and in particular the fish stocks which depend upon that habitat.
In consideration, it is recommended:

i) That Welsh Office refizse the current application by Llanelli Sand Dredging Ltd in favour of renewal of their licence at the current rate of 100,000 tonnes only per year, and for a maximum of 5 years only, and subject to conditions.

ii) To once again draw the attention of Welsh Office and Crown Estate to the definciencies of the Gibb (Wales) study whicl~ in regard to the fisheries and marine ecological aspects, is superficial and wholly inadequate.

iii) That as a condition of the authorisation, that a full and thorough Environmental Impact Assessment be undertaken, by specialist consultants, and that they be provided with adequate resources.

iv) That the above survey be paid for by Crown Estate Commission and/or Government, and not the initial applicant.

v) That no further increase in extraction be allowed, either by Llanelli Sand Dredging Ltd or other companies (eg. displaced from the Nash) until the results of the study are known.

vi) That existing licence applications on the Nash Bank be reviewed, and in any event, they are not renewed upon their expiry in circa 2000, pending a similar review to that undertaken on the Helwick.

vii) That the Bristol Channel Marine Aggregates Study be extended, to include primary research into the ecological issues raised.

viii)That the Government should encourage a new impetus directed towards the recycling of existing materials, the use of alternatives and the incentive to, and the development of, technology to extract aggregates lying in deepwater water offshore. It is acknowledged that the'fisheries factor' may become relatively more important than is presently the case in inshore waters if deepwater resources are extracted, and this needs fizrther assessment.

The Director considers that the above may represent a practical approach to the perceived environmental problems of aggregate dredging within South Wales, which is a very large, essential, and highly valuable industry.

Background papers:

1. Map: Dredging area on Helwick
2. Report by Dr. E I S Rees.

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