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CRAG ISSUES - Ainsdale Dune Restoration

FACTS AGAINST ENGLISH NATURE'S AINSDALE DUNE RESTORATION

Dune restoration is basically flawed, as it seeks to increase the habitat for dune loving specie, at the expense of specie that live in the woods or shade. Trees are an important social, recreational and amenity asset, and ameliorate the local climate at Formby. They add variety and character to the landscape, as well as providing walkers with shelter from wind, rain and sun (Cancer). Only the most mobile can move through a dune environment.

It is inconceivable that English Nature (EN) could ignore the unanimous resolution from Sefton Councilors, dated 4/3/04, which restricts management of the frontal woods to option 2 (B) as outlined in the consultation process. That is, "Restricted to the positive management for woodland for woodland wildlife as in the main area of the pinewoods".

However, if EN wants to continue dune restoration, the most damaging result is the loss of red squirrel (RS) habitat. EN's phases 1 & 2, plus their anticipated program for phases 3 & 4, will remove 75 ha of trees and scrub (PI CMACS 2000) - that is the habitat of 75 RS (1 RS per ha in frontal woods C Shuttleworth 1997). Note: This loss of RS habitat, plus its impact in numbers, is confirmed (P83 CMACS 2000). This loss of RS habitat is compounded by the recommended removal of trees in the rear woodlands for age profiling. This removes 3 ha per year for 20 years = 60 ha, plus loss due to firebreaks of say 15 ha = total loss of75 ha. That is the loss of habitat for 150 RS (2 RS per ha in rear woods). The total loss of 225 RS is surely unacceptable for protected specie.

Little or no compensatory planting is being carried out by EN, as there isn't the space in the 'safe haven' area (Between railway line & sea), and planting Eastwards would encourage infiltration of grey squirrels. However, replacement trees would be of no immediate benefit, as they would need 15-20 yrs to be cone bearing for RS food.

The red squirrel (RS) project for Newborough has recently sought advice from the University of Wales, Bangor (UWB) genetics unit ref. 'The minimum squirrel population that would be required for a genetically robust population'. The advice was about 500 and ideally they should have about 1 ha of habitat per RS. This conflicts with Gurnell et al. (1996) who suggested that 200 RS would be viable in the long term. As there is only 302.6 ha of woodland and scrub along the Sefton Coast (CMACS 2000), it is beginning to become obvious why Formby's RS population is struggling to survive. A larger habitat (and population), through cancellation of dune restoration, would increase their chances of surviving the ravages of parapox virus and grey squirrel infiltration.

As the UK has 54,500 ha of sand dunes (www.ukban.org), the benefits of producing a further 37 ha are hard to see (especially costed per ha!). There is an extraordinary plan, on this site, to "create Atlantic dune woodland on five carefully selected sites". Formby's woodland (and also Newborough Forest) should be prime candidates to meet the characteristics of Atlantic dune woodland (EU code 2180), if further Scots pine and other appropriate species, are planted during thinning. We seem to have a scenario, where EN (and CCW) will destroy forests in one area and then create 5 wooded dunes by planting on pristine dune habitat. A masterstroke of conservation practice!

There is also the local proportionality to consider. The Sefton Coast dune system covers 1222 ha (p4 CMACS 2000), of which 302.6 ha is trees and scrub. Adding 37 ha of dunes = extra 3%, but this involves removing 12.2% of forest. With 920 ha of dunes, EN have little grounds for demanding the felling of any trees, particularly as the North West has the lowest level of tree cover of any English region (p102 CMACS 2000). The top priority should be preserving this scarce forest resource.

The Habitat Directive does not give EN the authority to carry out dune restoration; its aim is to conserve biodiversity and conserve or (Not and) restore habitat where necessary. The Directive concerns the conservation of all habitats and when referring to 'predictable events', they mean principally anthropogenic (man's influences) - For example, road building, farming, building works, drainage etc - The Habitat Directive, requires EN to mitigate any predictable process, such as above, which would be detrimental to the habitat's conservation status.

Moreover, EN must not seek to counter natural processes such as erosion or the natural colonization of dunes by dune plants which tend to stabilize and fix mobile dunes; the so-called 'subject to natural change, to maintain' reference. The reference to 'maintenance implies restoration' does not apply where the changes are due to natural processes. The 'preventative measures' refer to countering anthropogenic impacts not natural ones.

The frontal woods protect the rear woods from salt and sand blast - Particularly in the area of fast eroding coast - Note: "The removal of a small patch of pinewood at the seaward end of Fisherman's Path in 1989 (Sturgess 1989) has had the effect of causing sandblasting, burn, die back and death of the pines immediately behind. This has been due to the removal of shelter, exposure of pines to the desiccating effects of winds off the sea and the burning effects of salt in sea-spray" (p82 CMACS 2000). Atkin's note that the "movement of sand in the restored area "is limited" (6.12 Atkins 2004), but this is to be expected, as this area is protected by old/high dunes and not subject to coastal erosion.

Removing the frontal woods is irreversible, as once they have gone we can't put them back again. The mature woods at the rear, at wider spacing, have no resistance to salt and sand and are easily overwhelmed. These trees were planted by the Blundell and Formby estates, to protect the area and railway line from wind blown sand. This arose after such serious sand storms, that the village center around St Luke's church was forced to move to Chapel Lane. There are too many houses, at risk, around St Luke's church.

Dune restoration ignores the precautionary principle. With predictions of rising temperatures and rising sea levels, together with more fierce storms creating rising wave height, we can't risk EN's experimental schemes destabilizing the coast. It is vital that we maintain all the tree and scrub on our coastal sand dunes, to help build up the sand, as an insurance against flooding, as the area behind Formby and Ainsdale is below sea level.

Dune restoration is unsustainable in destroying existing trees & scrub, and putting in its place a habitat that has to be maintained by sheep. This is not only costly, but extremely unsightly, due to fence post and wire. It doesn't increase bio-diversity; we need all the sea buckthorn and lodgepole pine, as both resist salt winds and give food to red squirrels.

The proposal to remove a continuous width of 475m of woodland and scrub is overkill. It assumes the coast will erode 250m over the next 50 years, providing for an excessive 225m of continuous dune habitat. But, should the coast erode less than 250m, it will have resulted in further unnecessary and wasteful destruction of frontal trees and scrub.

Atkin's EIA report refers to the frontal woods impeding natural coastal defense processes. There is no evidence of this, as it points out. The rate of erosion is determined by tide height, wave energy and replacement level of sand - nothing to do with trees.

Removal of trees goes against many of Sefton Council's policies, including CPZ2, CPZ7, CPZ8, ER6, GBC5 and CS3. It should be stated, there has been an unsatisfactory theme throughout all aspects of the public consultation on dune restoration at the above site.

Initially, the public had no access to the meetings discussing the 'Life Project', which included dune restoration, even though any grants to the project were dependent on full involvement with the public. The meetings with Atkins for the EIA, allowed the public to list the concerns/objections to dune restoration that Atkins had to take into account, but their report never responded, in detail, to every objection they received. When the Area Committee arranged a meeting,

The presentation by English Nature (EN) was so long that only a few people were allowed to put one question, with generally an unsatisfactory response from the panel of' experts'. EN's idea of consultation is to make their proposals public, end of discussion. It took two women to point out that EN wasn't listening. Every one of these meetings was extremely frustrating for the participants, as EN did their best to suppress a full debate with no face to face discussion with an expert. Failure to achieve this end has resulted in the issues continuing to fester, which is in nobody's interest.

As an illustration, I did my own summary of the Negative/Positive results arising from dune restoration (Letter to Atkins 2/2/04, copy available from myself). I found that option B had the least negatives and most positives. It was also the lowest cost and sustainable option - even Atkins shows it as virtually neutral in impacts! - Why then didn't Atkins propose option B? Well, of course, we know that EN paid Atkins to do the report, and EN wanted option C or D to be recommended. It is this distortion of the facts for its own end, by a Government department - paid for with our money - which is so sickening and damaging to the integrity of our democratic traditions. If my facts are wrong, it is surely in Atkin's or EN's interest to have made a detailed rebuttal to every point raised?

Neither of above has satisfactorily answered people's objections. If necessary, Sefton Coast Watch, with 5,000 signatures against dune restoration, will have to ask that the Arhus Convention be applied to obtain justice - that is the individual's right to participate in public decision making on matters relevant to the environment, the right to access to a court and the right to information on the environment - and /or asking for a Strategic Environmental Assessment (SEA).

The losses from dune restoration exceed the gains, without taking cost into account.

Alan C Hollway AIWSc 9/11/2004

CRAG ISSUES - Ainsdale Dune Restoration

Enclosed for interest and to show we are still around. This letter has been prepared to send to the Forestry Commission, should English Nature apply for a felling license. It does appear that the most effective way to fight English Nature is to get the local council to vote against their plans. It is also necessary to read the Habitat Directive thoroughly, so you can fight EN on their own ground - Alan Hollway - Tel. 01704 876155