APPENDIX 36
Letter to the Chairman
from the Chairman, Norfolk Branch, Country Landowners Association
(F59)
Following your visit to the north Norfolk coast
earlier this month, perhaps I might make some observations on
Project Assessment Guidance Notes, with particular relevance
to Happisburgh and Salthouse. I wrote to Elliot Morley in similar
terms on 1 May.
One of the distinctive features of PAGN is the
discounting formula whereby an annual rate of 6 per cent has (since
1989), been applied and which produces multipliers of (for example)
7.36 for a 10-year period, 9.71 for 15 years, 11.47 for 20 years,
12.78 for 25 years, 13.76 for 30 years, 15.76 for 50 years, 16.62
for 100 years, 16.67 for 200 years, and so on.
One of the more perverse results of this form
of analysis is that it makes the short-term solution appear more
attractive than long-term planning. The more imminent the risk,
the greater the present value of the scheme whereas beyond a certain
point the future becomes of minimal interest.
This often impedes common-sense solutions. Happisburgh
church is some 100 metres from the cliff top (taken from the churchyard,
and clearly the building needs that as support), but as the Minister
indicated to me, PAGN would not understand the need for a defence
scheme until the distance was reduced to about half. (An additional
problem is that when the existing obsolete timber revetment becomes
unsafe, it will have to be demolished and one could expect a rate
of loss of some 6 metres a year, based on the position near the
lighthouse.)
So much for the more general points, but there
are other ways in which the valuation procedures work against
a scheme:
1. In effect PAGN applies salami tactics
to small communities. Each house is valued separately as it drops
into the sea. In a large conurbation, or in an area of countryside
with only isolated dwellings, this may not be unfair, but the
problem for a village like Happisburgh is that PAGN does not put
any value on its survival as a community at all.
2. In practice, it is not at all clear that
historic buildings are correctly valued or whether the owners
are consulted. They should go in at the cost of reconstruction
using traditional materials and methods. Happisburgh Church is
listed Grade I and has recently had substantial grant aid from
English Heritage. I enclose for your information a copy of an
independent valuation done in 1996 and putting it at £5.5
million (a value on which the architect to Westminister Abbey
was, I understand, consulted). But nearby is an outstanding arts-and-crafts
house, currently a retirement home, built by Detmar Blow, listed
Grade II*,and stated in the Buildings of England (1997)
to be his "first important work and perhaps his best".
Thereare then 16 buildings listed Grade II in the village and
parish, including more of Blow's work, and thelighthouse of 1791.
3. Environmental assets are notoriously
difficult to value, and District Councils have particular trouble
when it comes to commissioning sophisticated studies from University
departments which even the Environment Agency is often reluctant
to afford. This in practice means that they are usually ignored.
The position is scarcely in practice mitigated by allowing environmental
points under the prioritising test which was introduced last year,
in circumstances of even fewer funds, for those schemes which
had gone through the PAGN process.
4. Into this situation, the Habitats Directive
has now injected further considerations. I am not clear whether
the government has yet come to a view on the extent of its obligation
to replace sites covered by Natura 2000 and lost to the sea. I
certainly think that their status should count heavily in favour
of a protecting scheme for the purposes of PAGN. At Salthouse
one has the situation that part only of the site would be protected.
In that case, that part should be valued in such a way as to assist
the scheme. However, it would not follow that the unprotected
part of the site would be a cost of the scheme for the purposes
of PAGN (even if HMG were under an obligation to replace it if
lost), because its loss would be due, not to the scheme, but to
tidal forces. I should stress that I make the point from a position
of great sympathy with RSPB in its desire to maintain as much
as possible at Cley/Salthouse and Minsmere.
5. Contingent benefits, like environmental
and heritage assets, tend to be excluded because of valuation
problems. The dangers of the erosion at Happisburgh outflanking
the reef scheme at Sea Palling are self-evident, but have not
yet been effectively absorbed by the PAGN process so as to justify
defence works.
7 June 1998
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