13 June 2014
N2B hears that there are people who believe that we are being unfair to the Shoreline Management Plan (SMP), that we have used inflammatory language, even that we lack respect for the democratic process by which it was produced.
Rule four in the campaigners’ handbook is that they, the authorities, can say what they like when they like, change their story as often as they like and not suffer for it in any way. On the other hand if you, the campaigner, get a single fact wrong then your campaign is mortally wounded.
So, as the accusations have been levelled, N2B feels that it needs to set out the facts underpinning its argument. Facts so factual that even Mr Gradgrind would approve of them.
First the two major errors in the SMP:
- The SMP says that the sea defences were placed there by private initiative. Not true – N2B has a copy of a photograph that proves that the county council installed them and the county council has admitted so in response to a Freedom of Information request.
- In appendix H the SMP says that from Beesands South to Start Point: SMP policy is economically viable as there are few assets at risk (note that the existence of Hallsands is not even admitted here). Not true – there is a village called Hallsands on this stretch of coast and in it, immediately behind the sea defences, are residential properties worth, at a conservative estimate, £3m. These were built a few years before the SMP was published and it is disgraceful that they have been written out of the SMP. To the £3m you can add a further substantial amount attributable to established properties that would become inaccessible if the sea defences and therefore the road were to be eroded.
If the SMP is so wrong about Hallsands what faith can we have in the rest of it?
Now to address the ‘consultation’ process:
- N2B has failed to identify any residents who heard of the development of the SMP , still less its potential implications;
- N2B has an e-mail from a planning officer who deals with applications for our village in which he says he was unaware of the SMP until a few months ago. Are lay persons expected to be more aware of planning matters than planners?
- Even if residents had known of the ‘consultation’ process and, not knowing that the ‘non-statutory’ document would be treated as chapter and verse at a later date, chosen not to take part they still had the right to expect that those who drew up the plan would exercise due diligence;
- Even if residents had known of the process and (N2B is guessing here) the publication of a draft plan for comment:
a) The SMP is an opaque, multi-sectioned document that is extremely difficult for a lay citizen to follow, let alone understand*;
b) It is not the responsibility of the lay citizen to ensure the accuracy of abstruse technical documents produced by highly-paid experts; and
c) Now that N2B knows of the plan and its implications it has taken an unreasonable amount of effort to establish the facts. It is extremely unlikely that such information would have been revealed in time for correction of the draft plan.
*Here is just one example of opacity: As this review is not a full economic assessment, a formal benefit-cost assessment using benefit-cost ratios (BCR) has not been undertaken. However a benefit-cost ratio (BCR) has been included to help clarify and review the ‘robustness’ of the preferred plan. What does this mean in English?
In the light of the above N2B considers that it has been remarkably restrained in the language that it has used to describe the SMP and the alleged consultation process.