Coastal SSSI series review implementation: scoping study of evidence requirements to support notification of managed realignment sites

Project Description

Many estuaries and coastal sites are also classified as Special Protection Areas (SPAs) and designated as Special Areas of Conservation (SACs) under EU Designations. In England, all formal European sites (as opposed to those identified through policy measures only) must be first notified as SSSI. This is an important distinction as UK Government policy also includes potential SPAs, possible/proposed SACs, listed or proposed Ramsar sites and sites that form compensatory measures on statutory European sites. However, in the Designation Strategy, Natural England clearly states that it will ‘ensure that existing sites are notified for the right features including the designated features of overlapping Natura 2000 and Ramsar sites’.

This is further influenced by the growing number of managed realignment sites established around the coast as compensation measures as part of the Habitats Regulations Assessment process (HRA). These have arisen following a decision by competent authorities that adverse effects on the integrity of existing European sites cannot be avoided, that alternative solutions do not exist and that imperative reasons of overriding public interest apply.

It is implicit in the legislation and guidance that the habitats created must be of suitable quality to secure the coherence of the European site network. Furthermore, Government policy in England (para 118, NPPF, 2012) requires that any compensatory ‘land or water must itself be protected as if it were fully classified SPA or fully designated SAC. The logic of this is that it is highly likely that the Secretary of State will need to classify or designate the site as an SPA or SAC’ (Tyldesley & Chapman, 2013). It follows that many, if not all these sites, will be heavily monitored and supported by abundant data.

In contrast, unmanaged breaches of seawalls and beaches/dunes/shingle banks can, by their nature, be unexpected. Although rare, and likely to be restricted to seawalls where Shoreline Management Plans have recommended that existing walls will not be maintained, ecological data will probably be lacking. Different protocols may well be required to support the notification of these sites.

Both types create further issues for the existing criteria. For example, the size of the site is typically pre-determined and naturalness, typicalness, fragility and rarity can be difficult to assess in rapidly changing habitats. There is no scenario of ‘choosing the best examples’ and so the straightforward application of the criteria set out in Bainbridge et al. (2013) may not be possible.

It is clear, therefore, that any evaluation of the possible notification of managed realignment sites must meet several expectations. It follows that the process and criteria adopted should be robust, evidence-based and open to public scrutiny.