Mr C Morgan
Planning Officer
E.2 National Assembly for Wales
Cathays Park CARDIFF
CF 10 3NQ
17 May 2000
Dear Mr Morgan
AGGREGATE DREDGING
RE: GOVERNMENT VIEW (NASH BANK)i 17/9/99
RE· REOUEST FOR EXTENDED TERMS (HELWICK
BANK)i 19/11/99
I have had recent cause to revisit the above
in the preparation of reports. I would request a response from NAW officials;
taking advice from external consultants as necessary, on aspects we have
previously raised. But now raised in more detail. You will recall that
I am a member of the Welsh Office `Bristol Channel Marine Aggregates Steering
Group' and therefore have seen many relevant reports.
A. Local drawdown of sand
1. Firstly there is a need to obtain definitive figures of the size (volume)
of both Nash and Helwick banks, using standardised and accepted technique,
and for this to be undertaken on a regular (e.g. at least annual) basis.
Consultant's reports show various figures particularly for the Helwick.
There is a need to standardise measurement to different heights - Chart
Datum. e.g. To -15m, -20m, -35m.
2. There seems to be value in stipulating the figures for the amount of
sand historically removed by dredging in relation to the total volume
of each bank. Whilst we have taken a quick look at the figures (enclosed),
Consultants could do so more accurately. Figures for future projected
removal could also be looked at in the same way.
3. Consultants are all of the same view that the Helwick Bank has not
yet decreased in size over the years. The situation on the Nash is less
certain, but indications are that any change could be seasonal or annual,
but that even though the bank shape broadly changes the overall volume
has not yet significantly decreased.
4. Therefore, (and the Consultants all seem to agree) there exists a feed
of sand to each bank from the surrounding area, the nature of which is
bank specific.
5. My main question to experts is this:
Can they give absolute assurances that there is no danger of drawdown
of local beaches (especially Porthcawl and Port Eynon/Oxwich/Mewslade
specifically)? Over what wider area may the effects of local drawdown
(agreed A.4 above) be extended?
6. It seems clear to many that the area surrounding the Nash has a thinner
layer of surface sand than hitherto. Models which seem to explain the
general mair.tenance of bank volume despite significant sand dredging
removal seem to concur with tha view.
Hydraulics Research in their Auaust i9g`/ (E~:3~46) report omthe Helwick
(Para 8 Sec 4.3) also make an ambiguous statem~~3.~ re Port Eynon beach
and the eastern Helwick. which suggests to me that there may be v :Aider
implications of local drawdown as the banks, in a dynamic hy~rographical
sitaation, seek to maintain volume in the face of sand extraction.
Please could you establish a view from Consultants and receive their assurances
in writing before any further extensions to dredging are given by the
Assembly. .
B. Larger scale sand movement
l. Various consultants indicate a large scale, long term residual movement
of sand from east to west in order to form the mid charlnel large sand
wave structure so referred.
2. If this process continued then this bank structure would move ever
seaward. It apparently does not and is stable. Accordingly there must
exist some form of balancing west to east movement.
3. ABP Research Consultants have sought to address this through sediment
particle movement analysis studies off Govan Head via fluorescerit labelling.
Please note that in our view this study did not address storm movements
originally intended and covers only "summer storms south westerly
force 5 or 6". What of storm force 10 winds?
I believe that large storm events have the capacity to remove large volumes
of sediment and to great depths (witness the Milford Haven dump site studies).
To what extent can the Consultants quantify this movement and indicate
the extent this would balance out any residual longer term gross westerly
movements of sand so referred at B.1 above? C. Within our understanding
(or lack of understanding) of the quantification of the physical processes
involved in A and B above, to what extent can various Consultants give
a categorical assurance that:1. The changes being experienced to sand
levels on beaches as far afield as Porthcawl and Tenby are not a result
of aggregate dredging?
2. There is no relationship between the historically large quantities
of sand removed by dredging on the Nash and Gower beaches/Helwick Bank?
I can recall no longer term tracer studies based, for example, on the
Nash. However, other studies e.g. on the movement of sands dumped on the
Swansea Bay dumpsite do show significant movement in storm conditions
albeit inward to Swansea Bay and not laterally.
D. Ecological aspects
You will recall that my Committee's previous submissions have centred
upon the potential impacts of dredging on ecological aspects.
We still maintain the stance that detrimental changes have taken place
on the Nash and we would not wish to see transfer of dredging effort to
the Helwick.
Committee has previously commented and critically appraised the Environmental
impact statement/assessment work on the Helwick. Indeed it commissioned
an independent report on that work.
Please be aware that we have not received an adequate response (even a
response) to these concerns and our independent experts submission of
December 1997 appears to have been ignored.
Before I am personally labelled as `anti' all dredging aspects, please
be aware that it is my personal view that the changes we are experiencing
on local beaches are part of a longer term natural sequence, independent
of dredging, and in due course sands will return. However, that is only
my personal view, and I am not an oceanographer / coastal geologist which
is why I raise the above questions of such experts.
The biological/ecological aspects do remain a serious concern of mine,
and are areas in which I have some experience.
I trust that you will, in due c`.:urse, be able to respond in full to
this letter, and provide the necessary reassurances.
FISH
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