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Cllr Alex Rennie Leader of Havant Borough Council Public Service Plaza Civic Centre Road, Havant Hampshire, PO9 2AX Alex.Rennie@havant.gov.uk
Dear Alex,
Our ref: PO2023/12389/MK
8 September 2023
Thank you for your letter of 22 June about coastal assets in the vicinity of Langstone Mill Pond and Chichester Harbour I apologise for the delay in responding. Please also accept this as a response to your letter of the same date to Lord Parkinson of Whitley Bay.
I know the Environment Agency (EA) is aware of the deterioration of the structures you describe, and the challenges associated with management of the coastline within the harbour.
I am very aware of the terrible consequences flooding and coastal erosion can have for people, businesses and the environment. Climate change is happening now, and we expect to see an increase in extreme weather, flooding and coastal erosion. That is why our Flood and Coastal Erosion Risk Management Policy Statement and Strategy provides a long-term vision of how we will better protect and prepare homes and businesses from flooding and coastal change and create climate resilient places.
This Government is acting to drive down flood risk from every angle and announced in March 2020 that the amount invested in flood and coastal erosion schemes would be doubled in England to £5.2 billion between 2021 and 2027, providing around 2,000 flood defences to better protect hundreds of thousands of properties across England.
Our £5.2 billion programme includes defences for the coast where it is sustainable and affordable to defend the coastline. In areas where it is not, other approaches such as managed realignment or transition will be needed. For this reason, in addition to the £5.2 billion investment, the Government is investing £200 million in the Flood and Coastal Innovation Programme. As part of this £200 million, Ministers have allocated £36 million over six years to develop a ‘Coastal Transition Accelerator Programme’ to trial opportunities, in a small number of coastal areas at significant risk of coastal erosion, to transition and adapt to a changing climate/coastline.
As I am sure you will appreciate, local authorities are best placed to understand their coastline and to develop the most appropriate approaches to managing risk through Shoreline Management Plans (SMPs) and their local planning policies. By 2026, Defra has committed to review policy on these plans (in our Policy Statement) to ensure SMPs remain fit for the future, and are transparent, continuously reviewed and enable local authorities to make robust decisions for their areas. The EA is therefore supportive of considering the potential roll back of the footpath as part of an appropriate adaptation plan. Although the objectives and scope of the proposed Chichester Harbour Environment and Investment Adaptation Plan have not yet been developed, the EA anticipates that this could be the appropriate mechanism for taking all the necessary factors into consideration.
I would encourage you to continue discussing your plans for adaptation and realignment as well as the contingency plans for the wall through this mechanism and the SMP action plan, in conjunction with the EA and your coastal partnership.
I understand some of this work is already happening in the harbour, as the EA is working alongside its partners as members of the Chichester Harbour Protection and Restoration of Nature. This group’s focus is to protect, enhance and restore habitats and help create a harbour more resilient to climate change. The EA continues to be supportive of a strategic assessment of this coastline, by working with stakeholders to identify where it may not be affordable and/or appropriate to continue holding the existing defence line, in places where climate adaptation and environmental outcomes can be realised.
With regard to the Mill Pond and heritage protection, I have been informed by Heritage England that there are a number of Grade II listed buildings in the area, however, the mill pond itself is not designated and there are no scheduled monuments.
Development of the proposed Chichester Harbour Environment and Investment Adaptation Plan should be expected to include express consideration of the historic environment, including reviewing heritage data, engaging with civil society, and seeking heritage advice from local authorities and Historic England. The mill is nationally designated as a Listed Building – Grade II. Historic England is working closely with the EA and Natural England on how heritage contributes to the resilience and vitality of coastal communities when addressing shoreline change and marine habitat restoration, including better accounting for culture and heritage in and alongside Natural Capital. As the Government’s advisor on the historic environment, Historic England is keen to engage with the EA, Natural England and local authorities to secure thriving coastal places for people and for nature and I would encourage you to continue doing so.
The EA welcomes your proposal to bring partners together in developing an agreed contingency plan and is committed to finding a sustainable solution going forwards. I understand that the EA’s Area Director for Solent and South Downs, Simon Moody, has kindly agreed to meet you and the other organisations involved to discuss this further.
Thank you once again for taking the time to contact me about this important issue.
REBECCA POW MPFrom: CEO Chichester Harbour Conservancy
Ref: CEO/CHC/28/23
Cllr A. Rennie Leader of the Council Havant Borough Council [Delivered by email]Dear Cllr Rennie, Langstone Sea Wall, Langstone Mill Pond to Wade Lane
Reference: Cllr Rennie note to CEO CHC on subject dated 22 Jun 23.
1. Thank you for your kind note and sight of those sent to Lord Parkinson and to Rebecca Pow MP
2. Thank you too for outlining your new initiative for the harbour.1 As you have identified, the harbour faces multiple challenges which have led to its declining condition. Chichester Harbour Conservancy (CHC) is aware of these and have in-place a Ministerially endorsed, rolling 5-year Management Plan which identifies, in detail, all the points to which you refer (and others) with proposed actions. Importantly, the 5-year Plan was written by CHC on behalf of, and adopted by, Hampshire County Council, West Sussex County Council, Chichester District Council, and Havant Borough Council.2 The Plan endorses the concept of rollback for footpaths.3
3. A key cause of harbour degradation4 is coastal squeeze, where rising seas levels are constrained by hard sea defences to the detriment of natural habitats. This reduces the intertidal zone and increases mean depth which compromises saltmarsh growing conditions. This occurs because the natural release of sediment from higher land is prevented. Thus, hard sea defences (such as sea walls) are detrimental to the ecology of the harbour, whereas working with nature and adapting through managed roll-back (or re-alignment)5 is good.
4. In the Reference, you rightly note that coastal defence works can cause avoidable harm to the harbour and cite an example where the Planning Inspectorate (PINS) found in favour of Natural England by refusing consent for repair where there is no risk to homes and property. In my opinion this was the right and responsible decision, enabling work to commence on re-
1 TheChichesterHarbourEnvironmentandInvestmentAdaptionPlan.
2 HavantBoroughCouncilendorsedthisplanon8Apr2019.
3 ChichesterHarbourManagementPlan(2019-24),Action1.14,page25.
4 Accordingtothe2021NaturalEnglandreportintothestateofChichesterHarbour,58%ofsaltmarshhabitat areahasbeenlostsince1946,withtheequivalentofmorethan3footballcontinuingtobelosteachyear.
5 Allowingtheseatobreachharddefences,wherepossible,tocreatenewnaturalseadefencesofsaltmarsh.
Chichester Harbour Conservancy
The Harbour Office, Itchenor, Chichester, West Sussex PO20 7AW
01243 512301
info@conservancy.co.uk
www.conservancy.co.uk
routing the footpath within a more sustainable landscape, enabling nature to thrive and providing places that people can enjoy.
5. The Marine and Coastal Access Act of 20096 is the legal basis from which the King Charles III England Coast Path is being established. Subsection 55B considers the Route Subject to Erosion, and 55C Alternative Routes. Furthermore, Natural England’s ‘Coastal Access –Approved Scheme’ document7 from 2013 explains the statutory framework, the implementation of this new National Trail, and that roll-back is how the path will adapt to coastal erosion. This applies not just around Chichester Harbour, but nationally and seeks to ensure people still have access to the coast despite inevitable coastal change.
6. I fully accept that Langstone is a difficult challenge and that local people have a strong affection for the Mill Pond and the walk to Wade Lane. However, the current arrangements are not sustainable in the face of rising sea levels. The Mill Pond is now subject to overtopping from the harbour, meaning that it is already a brackish environment. These overtopping events will become more frequent with sea level rise I also recognise local concerns about the wildlife that use the Mill Pond. However, I would reassure you that these species will adapt to natural coastal change, as coastal species have done for millennia There may also be an option to create a new habitat locally (see para 10).
7. It is unfortunate that the case at Langstone appears to pitch two different conservation sites (the harbour and Mill Pond) against each other, though there is an unequivocal and substantial difference in their respective importance. The harbour holds SSSI status8, is an AONB9 , a Special Area of Conservation, and a Special Protection Area. It is also a designated Ramsar Site10. The Mill Pond sits within the AONB and is a Site of Importance for Nature Conservation (SINC); a county-level assessment. The former is of international and national importance, whereas the latter is not However difficult to relay, this distinction matters. As such, the priority for conservation is clear. It is the harbour.
8. An assessment of the damaged harbour wall at Langstone indicates that though unsightly, use of the foot path will not be impacted in the immediate future 11 Consequently, I see no justification for temporary works and am thus unable to support such action. To do this would likely be taken by those seeking an unsustainable like-for-like repair as confirmation that their view is correct and proper. Reversing this opinion and establishing a responsible and enduring solution will then be considerably more difficult and will add to the economic cost and environmental impact. It will also likely be perceived as setting a precedent for other hard defences in poor condition in the harbour where similar roll-back action will be necessary. Failure to secure responsible decisions here will contribute further to Chichester Harbour’s current trajectory of decline.
9. I will, of course, seek to engage closely with the broad thrust of the Chichester Harbour Environment and Investment Adaptation Plan. However, I see one of its stated aims of
6 https://www.legislation.gov.uk/ukpga/2009/23/part/9
7 https://publications.naturalengland.org.uk/publication/5327964912746496
8 SiteofSpecialScientificInterest–AveryhighlyprotectednationaldesignationofhabitatintheUK.
9 AreaofOutstandingNaturalBeauty–AveryhighlyprotectednationaldesignationofhabitatintheUK.
10 Ramsar–Aninternationallyrecognisedwetlanddesignation.
11 CoastalPartnersestimateaworst-casescenariooferosionat10cmperyear,forthestretchofdamagedsea wall.Itislikelytobelessthanthisbecausethefootpathisfinishedwithhardstanding.HampshireCounty Councilhavenointentiontoclosethefootpath,despitetheseawalldamage.
seeking to, “reduce impacts from maintaining coastal defences,” as incompatible with responsible and ecologically sound coastal management for the reasons I have outlined in this note.
10. To the west of Mill Pond is a site called Langstone Meadows. As part of the Chichester Harbour Environment and Investment Adaptation Plan, it might be worth assessing whether this site is suitable for an enhanced habitat creation project, to ecologically develop this current green space and enrich its local community value for the next generation of residents. Whilst just a suggestion at this stage, this could be an impressive legacy, if feasible.
11. Established by its own Act of Parliament in 1971, Chichester Harbour Conservancy is the principal guardian for Chichester Harbour Area of Outstanding Natural Beauty (AONB) and the Amenity Area. As such, the Conservancy and its partners are committed to finding the best solutions for the harbour that both conserve and enhance the environment in an adaptive way and allow people to continue to access and enjoy this special place. The Conservancy looks forward to working with all partners to deliver the right outcome for the environment, current residents and critically, those yet to come.
12 I have copied this note to Lord Parkinson, the Rt Hon Gillian Keegan MP, Rebecca Pow MP, Alan Mak MP, Cllr Humby, Caroline Douglas, Simon Moody, and Allison Potts.
Yours sincerely,
<Signed on Original>
Matt Briers CBE Chief Executive OfficerChichester Harbour Conservancy
The Harbour Office, Itchenor, Chichester, West Sussex PO20 7AW
01243 512301
info@conservancy.co.uk
www.conservancy.co.uk
Cllr Alex Rennie Leader of Havant Borough CouncilHavant Borough Council
Public Service Plaza
Havant
PO9 2AX
Our ref: SM/KD
Your ref:
Date: 7 July 2023
Dear Alex
Thank you for your letter dated 22 June 2023 concerning coastal assets in the vicinity of Langstone Mill Pond and in Chichester Harbour more widely.
I am aware of the deterioration of the structures you describe, and the challenges associated with management of the coastline within the harbour.
The National Flood and Coastal Erosion Risk Management Strategy sets out clear long-term ambitions for climate resilient places, creating a nation ready for, and resilient to, flooding and coastal change We want to help risk management authorities, communities and individuals understand and prepare for this change. To achieve this, we will need to work with nature This means in some cases naturebased solutions will be used to enhance flood and coastal resilience, which result in multiple benefits including contributing to nature recovery by creating and restoring habitats that store and sequest carbon, improving water quality and boosting biodiversity.
Some of this work is already happening in the harbour, as we are working alongside our partners as members of the Chichester Harbour Protection and Restoration of Nature (CHaPRoN) This group’s focus is to protect, enhance and restore habitats and help create a harbour more resilient to climate change
We are supportive of a strategic assessment of this coastline, by working with stakeholders to identify where it may not be affordable and/or appropriate to continue holding the existing defence line, in places where climate adaptation and environmental outcomes can be realised.
The ‘Chichester Harbour Environment and Investment Adaptation Plan’ referred to within your letter has been submitted to the Environment Agency to be considered for Flood and Coastal Erosion Risk Management Grant in Aid (GiA) funding It has secured £35,000 of GiA funding in 2023/24 and we look forward to receiving the necessary application for approval from Coastal Partners to access this funding The Plan requires an estimated £600,000 of funding in subsequent years, but this will be subject to national prioritisation against other eligible projects. We will be able to confirm whether it has successfully secured funding for 2024/25 later this financial year.
Any short-term remedial work to the deteriorated assets may require a Flood Risk Activity Permit (FRAP) from the Environment Agency under the Environmental Permitting (England and Wales) Regulations 2016. Work undertaken without a necessary permit would constitute unlawful activity. Due to the nature conservation designations in this location, we are required to consult with Natural England as part of the application process. It would therefore be prudent to discuss any proposals with Natural England to determine the likely outcome of such a permit application whilst we await the conclusion of the strategic work.
I welcome your proposal to bring partners together In developing an agreed contingency plan we are committed to find a sustainable solution going forwards, so I’d be happy to meet with you and the other involved organisations to discuss this further
Yours sincerely
Simon Moody Area Director Solent & South DownsEnvironment Agency
Guildbourne House, Chatsworth Road, Worthing, West Sussex, BN11 1LD
www.gov.uk/environment-agency Tel 020 302 57123
Alex Rennie Havant Borough Council By email only Dear Mr RennieLangstone sea wall, Langstone Mill Pond to Wade Lane
Thank you for your letter of 22 June 2023 regarding the current situation at Langstone Sea wall, Langstone Mill Pond to Wade Lane, Allison has asked me to respond on her behalf as the Natural England Manager with oversight of this area of work.
We recognise the importance of this issue for the local community and look forward to finding a solution which maintains access whilst also recovering and protecting the important and fragile habitats of Chichester Harbour.
You’ll be aware that in February 2021, Natural England published its Condition Review of the Chichester Harbour intertidal, subtidal and bird features of the designated sites (Bardsley et al., 2020). Overall, the main intertidal habitat interest features were assessed as being in unfavourable declining condition, largely due to the continued loss of the extent of saltmarsh and the poor quality of saltmarsh and mudflat habitat. The review shows that the Chichester Harbour Site of Special Scientific Interest (SSSI) is failing due to extensive coastal defences with most having the Shoreline Management Plan policy of ‘hold the line’
One of the main recommendations from the review was to remove barriers to coastal change caused by inappropriate or unsustainable coastal management, which are causing saltmarsh erosion. This loss occurs as saltmarsh has limited capacity to ‘roll back’ in response to rising sea levels (brought about by climate change) due to the presence of fixed sea defences such as the Langstone sea wall.
Where these defences are protecting homes and businesses from the risk of flooding, compensation for the loss of saltmarsh is dealt with through the Environment Agency’s Habitat Compensation and Restoration Programme (HCRP).
We believe that where those sea defences are protecting areas where there is no direct risk to property, we should instead look to explore opportunities for allowing roll-back to occur and to contribute to the recovery and protection of sensitive habitats whilst maintaining access to the coast for people
Our view is that the current rates of erosion to this part of the sea wall and footpath do not necessitate
costly and potentially environmentally damaging repairs either in the short term (such as the placement of sandbags etc) or in the longer term (re-building the seawall) We believe it would be much better to work collectively to agree a longer-term solution such as roll-back of the footpath and realignment of the seawall.
We very much support the proposal to develop in partnership a Chichester Harbour Environment and Investment Adaptation Plan which delivers the ambitious objectives that you have outlined. The need for this Strategy is recognised by all partners and has in many ways partly being addressed through the HCRP and the national Flood and Coastal Erosion Risk Management programmes lead by the Environment Agency.
Thank you for your suggestion to meet with yourself and colleagues from the Environment Agency to discuss things in more detail, we look forward to this opportunity.
Yours Sincerely
Graham Horton Manager Thames Solent team