Robin Burn |
It
is now 10 years since the demolition of former Grillo zinc oxide
production factory adjacent to Burry Port Harbour. The
former Grillo Site was sold and demolished in 2007 and the site has
lain dormant since then and debris remains on the site. The site has , in its time been various metal working establishments finally up until its generation a site for Zinc Oxide manufacturing.
The
site is contaminated with a cocktail of toxic metal, organic and
inorganic compounds all with risk to public health.
Carmarthenshire
County Council were aware, that, by allowing planning for housing
development on that site, would trigger a call in by the Environment
Agency, revoking Article 14 and Section 106 agreements.
In
a Planning Committee on January 18 th 2011, the planning committee
were advised by senior officers of Carmarthenshire County Council
“that, as the Committee was minded to approve planning
application S/18723, subject to the conditions detailed within the
Report/Addendum of the Head of Planning and/or reported at the
meeting, the Head of Planning be granted plenary powers to deal with
any outstanding matters once the Article 14 Notice is withdrawn, or
the application is called-in for determination, inclusive of the
Appropriate Assessment being signed off by CCW within a reasonable
time period from forwarding the same, in accordance with the
provisions of Regulation 43(1) of the Conservation of Habitats &
Species Regulations 2010 and inclusive also of a Section 106
Agreement”
In
other words Carmarthenshire County Council accepted the fact that
this development was on a Classified C2 floodplain.
In
correspondence from the Environment Agency Wales, responsibility for
monitoring the site and its associated ground water, is the
developer. Camarthenshire County Council has been made aware of
actions to be taken including post remedial monitoring of
groundwater. The Environment Agency understands that ground water
beneath the site is in continuity with open water within Burry Port
Harbour.
The
Environment Agency Wales would continue to act as an adviser to the
Local Authority for matters that could impact on ground or surface
waters when requested.
In
respect of the future development of the site, the site is proposed
for residential purposes and some community asset, given the present
economic restrictions and uncertain waste disposal system quality,
should a change of use of the site be considered to one of emphasis
on social and cultural asset?
The
Llanelli Star has published articles based on the views of a number
of elected Councillors of Pembrey and Burry Port Town Council.
These
views, in favour of developing the Harbour Area to the proposed
planning applications and that failure to do so would be detrimental
to the future prosperity of Burry Port. The views vociferously
expounded appear to be based on the principle that the proposed
development area has never flooded and that the flood maps have now
been changed to show, that the development areas are not on a flood
plain.
Unfortunately
this view, only supports a part of the facts surrounding the flood
risks for these sites, and does not support the real facts as
expounded by both Natural Resources Wales and Watermans
.
Both organisations have submitted their assessments of flood risk to
Carmarthenshire County Council and can be accessed from the County’s
Planning Applications sites, currently on line.
Firstly
Natural Resources Wales, in their document, whilst they advise, that
their Flood Map Information, updated shows the site to be flood free,
they acknowledge, that Site 6 lies partially within the current C2
Zone as defined by the Development Advice Maps (DAM) referred to
under Technical Advice Note (TAN)15 Development and Flood Risk (July
2004).
They
qualify this statement by advising that their information does not
take into consideration climate change allowances or blockages at
structures through which flood water passes.
They
go on to say” In accordance with TAN 15 the proposed development of
up to 134 residential properties would be considered as highly
vulnerable and should not be permitted within zone C2. However, if
your authority are minded to consider the application it should be
shown through the submission of an appropriate flood consequences
assessment (FCA) that the consequences of flooding can be acceptably
be managed over the lifetime of the development.
The
NRW document makes reference to a Flood Consequences Assessment
“Redevelopment of Burry Port-Sites 5&6 Flood Consequences
Assessment Final. July 2014 Referenced 16025/FCA02A prepared by
Waterman Transport and Development Ltd”
and
submitted to the Authority forming part of the Planning Application
documentation.
The
document discusses Tidal Flood Risk and comments that the principle
risk of flooding at the site is potential tidal flooding in the
future. The principle cause is the effect of Climate Change in terms
of tidal flood risk.
TAN
15 states that provision must be made for future changes in flood
risk, specifically as a result of Climate Change. In this case flood
risk must be considered over the anticipated lifetime of each
development.
It
is proposed to develop sites 5&6 for residential use; therefore a
lifetime of development of 100 years has been assumed giving an
assessment year of 2114, and as the Department for Environment Food
and Rural Affairs (DEFRA) has produced guidance regarding sea level
rises for 2114, sea level rise is 14.5 mm/year.
The
FCA concludes that the site remains dry in the majority of the
scenarios modelled, however the site is at risk of flooding during a
0.1% plus climate change annual probability tidal event and an
extreme 0.5% annual probability tidal event plus climate change and
with tidal levels at the upper extent of the confidence interval. The
FCA therefore proposes mitigation in the form of raising ground
elevations to 7.1 meters AOD to address flood risk. We accept that
the proposed mitigation works effectively to create a plateau that
remains flood free for all scenarios considered within the FCA.
The
proposed mitigation increases flood risk on the B4311 to the west of
the site and significant flood risk on the adjacent former Grillo
site requiring mitigation by a similar raising of ground elevations
to 7.1m AOD
To
counteract the lack of suitable waste management facilities by Welsh
Water, it should be made incumbent on the developer to incorporate
all the current waste disposable systems that are environmentally
sustainable and friendly into the plans for the build.
Site
remediation continues to be priority, as no attempt has been made
since demolition to clean up the site. This is now becoming a
critical issue.
Remediation
costs will be extensive, perhaps under current economic conditions
beyond the means of any developer. The solution in this case is
European funding backed by Welsh Government.
This
solution would clear the ground for Community assets for cultural
community and recreation to meet conditions of a Local Development
Plan as well as creating employment opportunities for the local
community. The site stands on a designated flood plain, the
development called in by the Environment Agency on behalf of the
Welsh Government to restrict the building of houses.
A
buy back from the developer and clean up funded by Europe is a
logical solution to a problem considered to be an ongoing one.
This
was written in 2017, and the recent announcement that the site has
been acquired by Carmarthenshire County Council is welcomed.
In
communications on the 23rd of December with the Leader of
the Council
Emlyn
Dole , People First leader Sian Caiach questioned the validity of
purchasing the site and pointing out that the authority would then take responsibility for the safety and site monitoring.
Councillor
Dole was reminded that, site investigations would be required, for
public safety, and the new calculations on likely sea level rise,
much more than at the time of outline planning, means that this area
may not be suitable for development at all. In his reply he says:
The Council has agreed terms to purchase the former Grillo site to promote its development to support the Council’s regeneration aspirations for Burry port and delivery of the Burry port Masterplan. The purchase terms are commercially confidential and I am afraid, therefore, that I cannot divulge the purchase price.
I can, however, confirm that the price agreed, subject to contract, takes into account remediation costs in terms of resolving any site contamination issues. The price agreed is supported by independent valuation advice. I can also confirm that on completion of the proposed purchase, the current owner, Castletown Estates Ltd, will have no further involvement with the development of this site.
Yours sincerely,
Cllr. Emlyn Dole
Leader of the Council
So the site has not yet been finally purchased and the whole matter is far from decided.
This
has now created an ideal opportunity for public consultation to
decide the future use of this harbour side piece of real estate.
It
has been widely acknowledged for many years that an expansionist
policy for house building was a preferred use of development land at
the cost of degradation of the fishery in the Inlet and Estuary.
The
opportunity has now been given to the authority to choose a different
route as to the use of utilisation to the benefit of local residents.
There
is no argument to the cleaning up of this derelict area to enhance
the appeal of the Harbour .
Development
has always been linked to a dwelling build programme, however the
last attempt to enhance the frontage of the harbour with a mixed
development of retail and dwelling was a failure, with a complete
lack of interest by potential developers.
Innovative
thinking is now must, local residents have to be consulted.
Robin
Burn I Eng FIMMM
January
2019.
You would think that the council would have stopped planning development of contaminated flood plain sites next to the sea after the Delta Lakes fiasco?
ReplyDeleteHI Robin what is the latest re the redevelopment of the Harbours since it has fallen into private hands, I hear there are issues with that company not living up to its promises as well?
ReplyDeleteHi Gaynor,
ReplyDeleteThere are two issues that affect the harbour, firstly the harbour fabric, the walls and the approach to the lighthouse have had little or no repair since the major conversion to the marina. The second is the assault by the tides on viability of the marina and moorings. The inlet and approach to the harbour is influenced by accretion, which is unstoppable, and due to the fact that the sand in the inlet is of a fine quality the harbour contained is filling up with sand and again is unstoppable. Dredging is a regular requirement and is expensive to maintain the viability of the moorings. I am led to believe that dredging is on the list of things to do this year and the harbour infrastructure has been surveyed for required maintainance.I wonder whether or not that if the organisation were aware of the problems before the sale.
Hope this helps
Robin
Awesome post.
ReplyDeletesite