Both KCC and TDC said
that health hazards of sewage discharge at Foreness are not a material
consideration when passing Southem Water's plan to extend the works. The Government
Office of the South Easthas since written to FEA confirming its
belief that health hazards are indeed a material consideration for the
foregoing authorities!
The plan for the
Foreness sewage works' extension breaches over 40 articles in the Parliamentary
Planning Guidelines(PPGs) and in the Local Plan (TDC).
The Southern Water Communications Director, Tom James, said that the
articles carry no legal authority. Both he and KCC also say "nobody
takes any notice of PPGs".The Public Inquiry Inspectorate
(Portobello Public Inquiry) recently directed that Southern Water should
work in compliance with PPGs.
If the Foreness sewage
works extension plan goes ahead, millions of gallons of crude
(non-disinfected) storm sewage carrying countless faecally derived virulent
microbes (bacteria & viruses) at each discharge will still be spread
over the foreshore during periods of intense rainfalls each year. There are
five CSOs (combined crude sewage rainwater outfalls) discharging directly
onto bathing beaches along the coastline (Westgate to Foreness). Discharge
of storm sewage will not be affected by the proposed extension to the
Foreness sewage works. The Marine Conservation Societyrecommends
that CSO discharges be limited to a one-in-twenty year storm event (http://www.mcsuk.org).
Long Nose Spit is a
Site of Special Scientific Interest(SSSI), EU Marine Special
Area for Conservation (SAC) and Ramsar Site (SPA for Sea Birds).
Foreness Point cliff top has a legacy of open space land for which there
will be permanent loss and damage.
DEFRA still has not
advised the Environmental Agency of its decision on the FEA appeal against
Southern Water's license application to discharge sewage onto the Foreness
foreshore from the planned works extension. The water company has yet to
submit the vital sewage dispersion data requested a year ago by the
Environment Agency.
In 2001, Margate beach
failed to reach the bacteriological test safety standard set out in the EC
Bathing Water Directive (1976). This means it will not qualify for the Seaside
Award(Tidy Britain Group) and will be reported as 'very poor'in the Good Beach Guide2002 publication. Test failures
followed on from crude storm sewage discharges at Foreness (FEA Report
available on request). The outdated EC Bathing Water Directive 1976, held up
in revision since 1992, to introduce much stricter safety standards, is on
cue for publication and enactment in June 2002.
In order to carry out
sewage CSO discharges DEFRA have confirmed that Southern Water need
permission of the private owners of the foreshore. This it does do not have
and apparently has not yet sought permission.
Southern Water wishes
to purchase 10-acres of Foreness Point clifftop open space land. The land
had been left in the will of the previous owner to Thanet residents for
their recreational use.
Foreness Point will be
unable to accommodate the massive stormwater/sewage holding tanks and
chemical scrubbing units that will become a requirement in the foreseeable
future (probably by 2010).
Southern Water would
have an option to turn-off the proposed UV-irradiation disinfection
equipment during winter months (Oct. 1st - May 15th). Discharged bacteria
and viruses can survive and over winter in sand, sediment and in shellfish.
DEFRA write that the
prodigious amount of sanitary detritus regularly washed up onto beaches and
promenades west of Margate ("Tampon Bay") does not constitute a
problem. This is nonsense and the Nuisance Lawsare
disregarded.
Foul alien sediments
recently found around the CSO dual pipelines at Long Nose Spit (Foreness
Point) are under scientific investigation as to composition and origin.
The Environment Agency
adopts double standards, classing our region as estuarinefor
nitrate pollution, but wrongly as open-seafor sewage
discharge (see Admiralty charts). This has serious implications for
compliance to the EC Water Quality Directive 2002 (deals with limits on
chemical pollutants) which applies to rivers but probably not yet to
estuaries. Whereas rivers flow in one direction, tidal estuaries are subject
to regular upstream and downstream flows, and a body of water passes slowly
through it to the sea. Thus sewage wastes in an estuary have a long
'residence' time.
The Secretary of State
for the Environment, Michael Meacher MP, has said the discharge problem at
Foreness sewage works is not environmental. In contrast, English Nature
record that the biodiversity of the region is on a knife edge. For example,
the Turnstone (migratory bird from Canada) in 2001 stopped breeding along
the Thanet coastline. Also, for the first time no juvenile fish were found
in the Thanet coastal waters (Margate Fisherman's Association).
Plans for sewage
works' progress up through tiers of Planning Authorities (TDC.KCC,
Environment Agency) without a public health risk assessment being made. This
is in breach of the Human Rights Act2000 and the EC
Charter of Fundamental Human Rights2001.
Southern Water said
that the plan for Foreness works extension is the best scheme available. It
is not, better schemes exist (e.g. inclusion of storm water
holding tanks to allow for later disinfection treatment before discharge,
installation of a Membrane BioReactor).
The TDC Policy
Committee said that even if they believe the FEA to be right on certain
issues, they stand by information supplied them by the Environment Agency
and by the East Kent Health Authority .
TDC has stated that it
is their policy not to sell the land at Foreness to Southern Water.
Therefore a Compulsory Purchase Order (CPO) will likely be made by the water
company.
The telemetric system
at Foreness for recording the frequency of storm sewage pipeline discharges
has been out of action for many years.
Diffuser ports at the
end of the Long Sea Outfall pipeline (LSO) at Long Nose Spit have been
broken for at least 8 years.
The proposed
excavation chamber in the Foreness clifftop to house the new works comes
within only 4 metres of the eroding cliff face. Excavation will produce
cliff vibrations, a noise a nuisance and a respiratory system health hazard
(e.g. asthma) from airborne chalk dust.
The unit for removal
of noxious gas (hydrogen sulphide) generated at the proposed new works has
not been commissioned by Southern Water so its efficacy cannot be evaluated.
Insouciant regard has
been given to the dangers and nuisance of heavy vehicles (a few thousand
movements) to and from the to be widened Friends Gap (opposite primary
school) during both cliff chamber excavation and construction of the
proposed sewage works.
The Foreness Point
site is unsuitable for further industrial development now and for the
foreseeable future. Southern Water stated that the preferred site was
Weatherlees. The development would treble the size of the present blockhouse
and spoil the view.
The North East Kent
European marine sites Management Scheme (publication 2000) gives scant
regard to sewage pollution and to bathers' health and safety , and none to
the water pollution carried in from outside of the region (the North Sea is
highly polluted).
There is no routine
monitoring at our designated bathing beaches for pathogenic viruses (from
sewage discharges) or for pollution bye.g.man-made chemicals
(endocrine disruptors) that cause feminisation and sterility of marine male
organisms.
Responsible
organisations and authorities are tardy in dealing with solving the limited
area bacterial contamination problem of Margate main sands arising from
Tivoli Brooks.
The CSO pipelines at
Long Nose Spit are in decay and their casing is underscored in places.
The discharge of crude
sewage at Long Nose Spit will increase if the proposed works extension goes
ahead since the plan is to transfer extra sewage from Broadstairs to
Foreness through a to be installed pipeline.
A pipeline
installation is planned, with air vents, from Foreness to Weatherlees (to
run along e.g.Princess Margaret Avenue) for transfer of foul
smelling sewage sludge.
The Environment
Agency has written to TDC stating that figures presented in the FEA report
on putative analysis of storm sewage discharge frequency at Foreness are
incorrect. But the figures are those of the Meteorological Office and
Environment Agency themselves! And they are correct!
Scottish Power plc has
owned Southern Water Services Ltd since 1997 and has put the company up for
sale.
The wet chalk
cliffs in Thanet are rare in the UK and Europe and are the habit for unique
species of algae, and also they are of geological interest. The Marine
Conservation Society calls for further biodiversity studies on the effects
of bioaccumulation of chemical pollutants from discharges. Meantime the
Precautionary Principle should be applied.
Due to a recent alert
that sewage effluent derived human enteroviruses persist by adsorbtion to
marine sediments, and accumulate in shellfish, the FEA have asked TDC to
consider banning shellfishing on the foreshore and/or to post warning
notices. TDC now have the matter under consideration .
To date we find no
evidence that KCC or TDC hold leases to the privately owned local foreshore.
There are virtually no beaches in Thanet, it is foreshore.
Does Southern Water
need to apply to the Crown Estate Commission for a license to e.g.
discharge extra sewage to be transferred from Broadstairs through the
long pipeline outfall (LSO) at Long Nose Spit?
Does KCC/TDC have
a Coastal Zone Management (CZM) plan and/or an overall Shoreline Management
Plan for pollution in accord with the Planning & Policy Guidelines for
the Coast (PPG 22) and with the House of Commons 1992 Environment Select
Committee assessment?
The FEA have
called-on the Secretary of State for the Environment (DEFRA) for a Public
Inquiry on building the extension to the Foreness sewage works. No response
has been received. The European Convention on Human Rights (ECHR Strasburg)
does require judicial decisions to be made by independent bodies. The EU has
its own court in Luxembourg. The FEA are investigating its options for
taking its appeal to these bodies should the Discharge Consent application
be licensed.