|Writer's flood risk alert on proposed Spurn visitor centre|
AUTHOR Dr Jan Crowther has been at the forefront of the opposition to the Yorkshire Wildlife Trust’s proposal to build a visitor centre within the proposed Triangle Field location. Her objections are recorded on Facebook, on her website http://www.wilgilsland.co.uk/ and in her comprehensive submission (reproduced in full below) to East Riding council planning department.
My background: I have been associated with Kilnsea since 1985 (caravan on Sandy Beaches). I have lived in Kilnsea since 2001. I have written a history of Spurn and Kilnsea (The People along the Sand: Spurn and Kilnsea, a history 1800-2000, published 2007). I am the Chair of the Spurn, Kilnsea and Easington Area Local Studies Group – Skeals (though I am not necessarily representing its views here). I was for many years clerk to Easington Parish Council, and have also been an Easington Councillor. I therefore write with some knowledge of the area, both personally and professionally. I would like to make an objection based upon the reasons that the previous application was refused, i.e. Flooding Risk and Visual Impact. I could make many more as a keen birdwatcher and lepidopterist but will confine myself to those points, since they are the ones chosen by the Planning Committee.
I object to this application as I did to the previous one.
The YWT admit that none of the sites are suitable, due to flood risk. My solution – do not build new. Re-use existing buildings. They dismiss Southfield Farm by saying that it is in Flood Zone 3a and subject to flooding, though it was not flooded in 2013 (nor 1953, nor 1978, nor 1987, nor 1995/6).
Throughout their Flood Risk Strategy they refer a number of times to the local community. They never acknowledge that the local community has expressed almost total opposition to the building of a visitor centre on Triangle Field. According to their submission the YWT apparently expect the help and co-operation of a community which has shown itself to be largely in opposition to them. Examples below:
On p. 3 of The Flood Risk Assessment document I read this aspiration ‘YWT to work with ERYC, EA and the local community at Kilnsea in on-going monitoring and managing the level of flood (and erosion) risk’. Have they talked to Easington Parish Council about this? NO. This reappears later as a recommendation. Have they done any liaison work with the local community on this matter? NO.
They refer on p. 10. to two embankments in the village of Kilnsea, one built in 2007 and one in 2015 and say it is the responsibility of the local community to maintain them. Have they asked the Parish Council if they are taking on this responsibility? NO. The community has no such responsibility.
P 31 quote from a document saying that ‘For the exception test to be passed, it must be demonstrated that: The development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment’. Can they demonstrate this? NO.
On p. 62 they say ‘the level of risk to the development will change over time and it is essential that all parties that may be affected by the change monitor how that risk will change. YWT should formally work with public and private partners (ERYC, EA and the local community at Kilnsea etc.) to monitor the future level of flood (and erosion) risk by specifically by reference to: The condition of existing flood defences; and Erosion of the North Sea coastline’. Has Easington Parish Council been approached to find out if it will accept such a role? NO.
I ask our Ward Councillors to confer with Easington Parish Council and ascertain how much responsibility they are prepared to shoulder on behalf of their rate-payers. The precept is tiny; Easington is only a very small parish. Its residents have never asked, nor expected, the Parish Council to take on such responsibity, and I think we may legitimately ask why a body like the Yorkshire Wildlife Trust should expect to build a Visitor Centre on a flood plain of this nature and then expect a small council and its residents to help them to protect it from the inevitable floods.
Visual Impact and some background
Councillors may be asked to look at a virtual reality video made for the YWT, which purports to demonstrate how this large two-storey building would ‘nestle’ into the landscape. It is entirely false. One can show anything with virtual reality and this video is misleading beyond belief. And I am sure they will note that it does not even show how this building would look from the Canal, where it would be a dominant feature in a natural landscape.
Some relevant background. In 1988 the Spurn and Kilnsea area, from Long Bank south, was designated a Heritage Coast, to general acclaim. The Spun Heritage Coast Project, an alliance between the Countryside Commission, the Nature Conservancy Council, Humberside County Council, Holderness Borough Council, Easington Parish Council and the Yorkshire Wildlife Trust was set up. Many excellent projects took place, including the creation of Canal Scrape and car park, tree- and hedge- planting, new hides and walks, and the creation of the Blue Bell Visitor Centre in a former pub with a free car park at the rear. None of these projects did anything to destroy habitat, rather they enhanced the area. Some of the hedges soon died, or failed to flourish, because establishing new vegetation in the area around the Canal and Clubley’s Field is very difficult if not impossible (I can supply photos). But the co-operation between all those bodies and Spurn Bird Observatory was a huge success and the whole community worked together.
The current situation. It could hardly be more different. Firstly, the YWT independently had conversations with E.ON well before anyone local knew that it intended to set up a two-million-pound Community Fund. The community (including Easington Parish Council) was simply informed some time later that the YWT had been given £900,000 to construct a visitor centre on a small meadow in Kilnsea. I was a councillor when two representatives from E.ON came to talk to the Parish Council and apologise to locals for the disruptions caused by the building of the wind turbines offshore. They were very surprised to be told that we knew nothing about this scheme. Since then, despite the YWT constantly reiterating that they have liaised with the community and taken its views into account I can confirm that no changes have been made to the plans. Despite 351 written objections, petitions against signed by about 90% of households, and the recent application being refused 9/0 by the East Riding of Yorkshire Planning Committee, the YWT has re-submitted. Or is this a new application? It looks the same to me. Note that most objections relate to the LOCATION. Note that the supports almost never mentioned the location.
Confusion between Kilnsea and Spurn. The Yorkshire Wildlife Trust bought Spurn in 1960, which is the peninsula from Spurn gate south. Spurn Nature Reserve has always been regarded as that area of land. However there seems to be some confusion about what constitutes ‘the reserve’, certainly in some of the documents I have read. For example this from The Design and Access Statement – ‘The building allows staff to always be available in the centre of the reserve with all equipment for conservation and safety to be readily available’. How can a building in Kilnsea outside Spurn Gate be in the centre of the reserve? Am I, as a resident of Kilnsea, now living inside a nature reserve? If the YWT now regard Kilnsea as their own reserve I think they should at the least involve its population in its plans!
The visual impact. The Visual Impact Document states that changes have been made as a result of consultation. The main objections from people throughout the process have been on the chosen site. No change whatever has been made to that. The ‘new’ document has been written by Rootstock, in actual fact by Harry Watkins, who was employed by the YWT as Spurn Heritage Officer, and was responsible for the application from the outset. This is not a neutral assessment.
Regarding the detailed analysis of visual impact in the document I will confine myself to only a few, though I could go through it line by line and refute the conclusions there.
P. 23 - ‘the creation of the new visitor centre is a large scale intervention in an area of medium sensitivity’. ‘after a five year period the fast-growing species selected will screen the access ramp and courtyard …. The intervention can be judged to have a major-moderate positive significance’. My comments – when the Spurn Heritage Coast Project planted this area in the late 1980s/early 1990s many of the trees and hedges died and those that remain are stunted. Why would plants grow better now? Rather worse I would say as erosion means the coast is nearer.
p. 25 ‘As a consequence of the consultation with statutory stakeholders and Easington and Kilnsea residents, changes have been made to the wider landscape and habitat designs to fulfil the fourth purpose of the Heritage Coast, to “take account of the needs of agriculture, forestry and fishing and the economic and social needs of the small communities on these coasts”. What on earth does this mean?
p. 26 regarding traffic to Kilnsea – ‘Given that the area was able to accommodate approximately 70,000 visitors p.a. historically, the predicted visitor numbers are unlikely to cause significant impacts’. My comment – is the writer unaware that these visitors (figures from 1970s) went straight down the Spurn peninsula which is what they had come to visit?
p. 26 ‘the creation of the sea wall and the associated railing (Figure 5) has … reduced the impact of the wide open skies in this location’. My comment – WHAT?
My final comments on this document – the YWT describe the Visual Impact Document as ‘impartial’. I think it needs to be re-emphasised that the writer is Harry Watkins, who was the person responsible for the original application when working for YWT and who has now been appointed in another capacity/company (Rootstock) to comment upon that same application. It is hard to see how this can be an impartial observation. Had the YWT been confident of their position - that no adverse impact would arise from the Visitor Centre's construction and location - they would no doubt have sought the views of a truly independent observer unconnected with the YWT.
Finally, as I did to the previous application I strongly object to this planning application because building in this area of serious flood risk has never been allowed. Please note the decisions made regarding these applications in Kilnsea - 15/02530/PLF, 15/00999/PLF, 13/03869/EIASCR, 13/03517/PLF, 13/02188/PLF, 10/04850/PLF, 10/00785/STPLFE, 09/01552/CLE, 08/00107/PLF, 05/08284/PLF |, 04/06743/OUT. If this application were allowed it would encourage the re-submission of applications you have previously, and rightly, refused in such a sensitive area.
I trust that having looked closely at this re-submission, taking into account that it is virtually identical to the one refused in July, and noting the objections to it from all over the country, you will also refuse it.