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Llanelli Sand and Dredging Ltd has applied for an aggregate Production Licence Area 476 Nobel Banks for a period of 15 years with extraction of 300,000 tonnes a year (total 4.5 million tonnes). The Government is required to undertake consultations with interested parties. Your response should set out any concerns that you might have about the proposals, suggest mitigation measures that might be included as conditions in a favourable Government view, should one be given by the Assembly. Details of where to send your letters are below. Please write by 4th December 2002 The area is located to the southwest of the Gower Peninsular, off shore of Carmarthen Bay This is not the Helwick Bank which is just off Port Eynon Point but the effects of Dredging could have a knock on effect here. Llanelli Sand and Dredging Company commissioned Coastal Impact study to back up their application. We have put together 6 points with reference to their application which we wish the Assembly to take on board. Comments on Environmental Statement and Coastal Impact study Area 476 (Dredging on Nobel Banks) 1. .No dredging licence should be granted for more that 5 years 2. There are a number of mistakes in the Costal Impact Study (CIS). Should the Assembly base their decisions on a report that is inaccurate? 3. No new evidence is used in this report, and previous concerns raised on the adequacy of the Helwick EIA and CIS have not been addressed. 4. Llanelli Sand and Dredging licence application is seeking an increase in removal from the Bristol Channel equal to 25% of the current dredging total (table 2.2), without any evidence that such an increase is necessary. Moreover, the provision in Para 2.4 "to roll forward any unused tonnage" suggests that the company does not think that there is a need for 300,000 tonnes per year and that the licence bid is speculative. The Licence should be based on historical sales figures for the local area, no stockpile or sales out of area should be included in the figures. 5. Dredging should stop at Helwick Bank immediately, and a 10 mile ban off the Gower coast. 6. If the dredging application for the extraction of sand from the Noble bank is approved the proper monitoring of coastline must continue and information gathered annually reviewed. Gower Save Our Sands encourages you use the above information and write to: Brian Cleator |