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South Downs Shoreline Management Plan – 1st Review

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					                                                                    APPENDIX 1
           South Downs Shoreline Management Plan – 1st Review

                         Public Consultation Response Report


Introduction

The South Downs Shoreline Management Plan [SMP] review is one of the first three
SMPs to be reviewed and as such is being used as a pilot to develop, test and validate
new Department for Environment, Food and Rural Affairs [Defra] Procedural Guidance
for the development of SMPs.

One of the mainstays of the new guidance is the need for meaningful consultation. This is
now undertaken throughout the Review process and takes the following form:


                                       Inception -
                                  call for information


                                In-study consultation -
                                methodology dependent
                                   upon Model used



                                 Public examination /
                                consultation / feedback
                                       feedback

                              Adoption (by Client authority)
                                 & Defra Approval


                                 Dissemination & use


Purpose of this report

This report outlines the various stages of the SMP consultation process. The main
purpose of it, however, is to catalogue the responses to the Public examination /
consultation / feedback process and to suggest what changes are required to the Plan
before it should be put before the Client Authority Committees for adoption, prior to
submission to Defra.

Background to Consultation

Various consultation models have been put forward in the Interim Procedural Guidance.
The South Downs Coastal Group [SDCG] review has adopted Consultation Model #2 for
the main consultation process. The choice was made by the Client Group and was based
largely upon experience gained in the production of the 1st SMP. Please refer to the main
                   SMP report and to Defra‟s Procedural Guidance for more detailed information on the
                   models available and methodology involved in each.

                   In essence, Model #2 involved a call for information from „Stakeholders‟ at the
                   commencement of the Review; some 175 Stakeholders were identified, being drawn
                   from:

                              the previous SMP,
                              Coastal Defence Strategies [CDSs] within the study area and
                              lists held by SDCG member officers.

                   A Key Stakeholders‟ Forum was also set-up. The Forum consisted of approximately 40
                   persons or bodies representing either statutory consultees or those with a regional interest
                   or perspective on the issues. The intention was that the Forum would be a two-way
                   conduit for information flow and would ultimately help to guide the direction of
                   acceptable “preferred policy” decisions.

                   The Forum met three times during the review process; in essence, chronologically, to
                   identify issues and objectives, to discuss and establish the ranking of them and to agree
                   the proposed policies as far as practicable.

                   An integral part of the consultation process was the Public examination of the proposed
                   policies. The process is detailed below.

                   The Public Consultation Process

                   The Public Consultation was for a period of 3 months, from 10 January to 8 April 2005.
                   During this time the main draft document was available for inspection at SDCG Member
                   offices and main libraries across the area.

                   The South Downs website had a link to the main document, available for reading on-line;
                   most of the member authority had links to the site (www.ssdcg.org.uk) on their corporate
                   websites. The appendices were too big to put on the web and so a CD was made freely
                   available via a link on the site – approximately 85 copies of the CD have been issued to
                   date.

                   The CD contained the appendices generated by the consultant (Halcrow) as well as a
                   digital version of the main document. The opportunity was also taken to include the
                   various other material available e.g. the PowerPoint® presentation and the posters used at
                   the Public exhibitions.

                   Arun DC, on behalf of SDCG member authorities, issued a press release prior to the
                   consultation period; this highlighted the need for the review, listed the offices where the
                   document could be viewed and gave the venues of the exhibitions, together with the web
                   address and how comments could be made.

                   A series of 5 exhibitions, in areas of change in policy was organised. The venues are
                   given below together with then numbers attending in brackets:

                              Selsey (37 attendees),
                              Pagham (86),

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                              Climping (57),
                              Peacehaven (41) and
                              Seaford (50).

                   These exhibitions were held in the middle of February - roughly half way through the 3
                   month consultation period. The exhibitions were open 2:30 - 7:30pm and had a rolling
                   presentation (PowerPoint), poster displays, policy unit information displayed and staff on
                   hand to answer questions. Other related information (e.g. the FutureCoast air photo
                   video) was also available.

                   A full colour A3 (folded) Summary Leaflet, giving a textual explanation of the policies
                   coming forward, was also produced and made freely available.

                   To ensure that the maximum practicable press exposure for the exhibitions was gained, a
                   Notice was inserted in a number of local newspapers across the region for the two weeks
                   prior to the exhibitions (this included the West Sussex Gazette. Chichester Observer,
                   Bognor Regis Observer, Littlehampton Gazette, Worthing Herald, Adur Gazette. Sussex
                   Express) The fact that the exhibitions were being held was also picked up upon by local
                   radio.

                   Elected Members of Lewes DC were concerned that all those affected by the proposed
                   policies should know and should be directly informed. Accordingly, those elected
                   members undertook a „letterbox drop‟ to all the potentially „at risk‟ properties in their
                   area - this included the summary leaflet mentioned above.

                   Following the exhibitions, Brighton & Hove City Council had the display material that
                   was prepared for the exhibitions (11No A2 posters) on static display in Rottingdean
                   Library and Brighton & Hove Town Halls – the material was displayed for a week at
                   each location.

                   A 'consultation comment form' (blank attached as Appendix A) was prepared and 51 of
                   these have been returned. Just over 30 individual letters and e-mails, which tended to be
                   more pointed and specific in nature than the forms, have been received.

                   Various Councils ran pieces in their corporate 'customers' newsletters and talks to other
                   groups (e.g. Littlehampton Civic Society) have been given.

                   Whilst Parish Councils were represented on the Stakeholders‟ Forum by representatives
                   of the Sussex Association of Local Councils, a copy of the summary leaflet, with an
                   explanatory covering letter, was sent to all Parish Councils along the whole frontage.

                   An elected members' day was staged at The Barn, Worthing to inform members about the
                   process and the policies coming forward. There were three sessions (all the same) during
                   the day and about 30 members attended in total.

                   The 'event' was held on 13 April 2005 (i.e. after the end of the consultation period) and it
                   was used to inform members about the comments received. All the MEPs for the region
                   were invited this event but none attended. MPs were unfortunately fully engaged on the
                   hustings prior to the General Election.



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                   Consultation Responses

                   The responses can be divided into two categories: those which were made on the pro-
                   forma response sheet (either at the exhibitions or posted in subsequently) and those which
                   have been lodged by letter or e-mail. The former were typically generic in content and are
                   summarized below; the latter were more detailed and referring to specific, if sometimes
                   parochial, matters or sites. These are included on a spreadsheet included at Appendix B.
                   The spreadsheet also includes entries from the pro-forma responses where specific
                   comment, requiring consideration of a change to the Plan, was made.

                   The pro-forma was set out in two parts. The first was attempting to gather some basic
                   information regarding the respondent i.e. demographics and awareness of the SMP
                   process. The second was in the form of „free space‟ which was intended to move away
                   from the usual „tick box‟ questionnaire which is sometimes perceived as „loaded‟
                   questions.

                   Demographics / awareness

                              Of the 51 only 9 were unaware of the Environment Agency Flood Maps – most of
                               these were from Seaford
                              17 were unaware of the previous SMP
                              the majority of the respondents were only recently aware that the Review was
                               being undertaken
                              most found out about the consultation through press advertisement / feature but a
                               significant number became aware by „word of mouth‟
                              74% said the exhibition information was easy to understand; of those that did not
                               find it easy, one did not care for the „jargon‟ and another thought the information
                               not detailed enough
                              only 2 found the venue and/or opening times unsuitable

                   Comment themes (from pro-formas)

                              many parochial issues – local management issues not within the policy setting
                               scope of the SMP (concerns to be passed to the relevant authorities) – e.g. surfing
                               at Seaford
                              many „logical‟ or „sensible‟ responses in regard to proposed policies for specific
                               areas
                              general welcome of the consultation process
                              the Environment Agency‟s Cuckmere proposals featured heavily – this is
                               considered to be outside the scope of the SMP, as the document specifically does
                               not set policy for the Cuckmere so as not to prejudice the ongoing applications /
                               enquiry / investigations (again, these comments to be passed to EA)
                              gaps in the defences along the cliffed frontage east of Brighton
                              several were aware of the cliff recession east of Brighton and were glad that this
                               had been realized and some element of forward planning were being undertaken.

                   Members of the South Downs Coastal Group had the opportunity to comment upon the
                   Consultation Draft before it went on public release; they have also supplied comments
                   during and subsequent to the Public Consultation Period, as matters came to their

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                   attention. These comments may require the Plan to be amended and are included in the
                   appended spreadsheet.

                   Detailed responses

                   These are set out in the spreadsheet at Appendix B but there are a number of themes that
                   appear:

                              supportive comments form English Nature and West Sussex County Council
                              misunderstanding of the ethos of shoreline management planning; some e.g.
                               Pagham, were concerned that whilst one Policy Unit may be designated „Hold the
                               Line‟ this could be affected by a „Managed Realignment‟ policy in a neighbouring
                               unit. Whereas in practice the effect on the whole coastline is considered for any
                               particular proposal
                              there is an issue around a legal agreement with respect to the furtherance of
                               proposing policy in one particular Unit. This is to be resolved outside the scope of
                               the Review

                   Suggested amendments to the Plan

                   The comments have been considered by the Project Team and instructions issued to
                   Halcrow to undertake various edits. None of the comments are „showstoppeers‟, similarly
                   none of the changes will result in a change of policy.

                   There are a number of textual changes and the addition of more detailed plans has been
                   instructed.

                   The final draft of the Plan will include an Action Plan, which will set out the steps for the
                   implementation of the policies and the next stages in the coastal management process e.g.
                   which Coastal Defence Strategies are to be prepared / reviewed and when.


                   Recommendations

                              Instruct Halcrow to carry out the amendments noted above, and continue the
                               preparation of the Action Plan
                              Circulate the final report to members of the South Downs Coastal Group for final
                               comment / release
                              Gather support for the Plan from relevant bodies e.g. English Nature letter of
                               „comfort‟ with the proposals
                              All SDCG Operating Authorities to formally adopt the Plan and
                              Submit to Defra for adoption / approval.
                              Disseminate the adopted Plan as widely as appropriate and
                              Incorporate the policies for specific Policy Units into coastal defence management
                               and the Planning processes (e.g. Local Development Framework) of the South
                               Downs frontage.




                   Prepared by: R. Spencer – SMP Project Manager (Arun District Council), August 2005
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                                                                                                              APPENDIX A

South Downs                         SHORELINE MANAGEMENT PLAN                                       1st Review

Comments Form

This form is provided to allow you to make comments and to help the Group address
any concerns that you may have. Alternatively, you may respond in writing or by
e-mail to the Project Manager. (please see overleaf)
The form is in two parts – this page is intended to provide the Group with some
information about you and how you heard about the Plan & Consultation. The reverse
side is provided to allow you to make specific comments on the proposed Plan.

You do not need to complete all or any of these questions on this page. Any
information you do give (excluding personal details) will be collated into a
Response Summary and presented to the various Committees that will
consider the adoption of the proposed Plan. The Response Summary will
become part of the SMP documentation (for transparency and audit
purposes).

Name
Address

                                                                                Postcode………………………
Telephone ……………………….                                              e-mail
Age (please circle age group)                                     under 16    16-25   26-45      46-65 over 65
Interests with the coast

Are you aware of the Environment              YES              NO
Agency‟s Flood Risk maps?
If yes is your property outside or
                                   Outside in Zone 2 in Zone 3 Don‟t know
inside the Flood Zone(s)?
Are you aware of the existing                 YES              NO
Shoreline Management Plan? (1997)
When did you become aware that
the SMP was being reviewed?
How did you hear about this Public Word of mouth       Press Advert   Press feature
Consultation?                      Poster   Leaflet in Library   Other……………..
Was the information provided in                                   YES        NO (if no, why)………………………..
the Exhibition easy to understand?                                                          continue overleaf if necessary
Were the venue and the opening                                    YES        NO (if no, why)………………………..
times suitable for this Exhibition?                                                         continue overleaf if necessary
                                                                              Please continue overleaf

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Please use this side to make any comments you have – either about the proposed Plan in general,
the proposals for specific sections of coastline (Policy Units) or the Consultation process.

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                        please continue on separate sheet if required

May we contact you regarding the comments you have made?                   YES   NO

I understand that my personal information will be kept private and used for the purposes of the
Shoreline Management Plan only and that any other information given and the comments made will be
collated and presented in summary form to the various Committees considering the adoption of the
proposed Plan. I also understand that all responses (with personal information removed) will become
part of the SMP documentation (for transparency and audit purposes)


Signed ……………………………………………………                                                  Date ……….…….……….….

Please hand completed forms to a member of staff at the exhibition or post it to “SMP Project
Manager, Arun District Council, Arun Civic Centre, Maltravers Road, LITTLEHAMPTON,
West Sussex. BN17 5LF” or e-mail your comments to coastal.defence@arun.gov.uk
                              ALL COMMENTS TO BE RECEIVED BY 9 APRIL 2005


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