Memorandum submitted by Gillian Mills
(DMB 03)
I would like to put forward that the consideration
of the wider implications of what seemed, a few lines in the 2006
Consultation has now spawned many far reaching consequences.
1. A path at cliff height now exists in
many areas, because the impact is on mainly the landowners and
farmers, but importantly gives a level of safety being a separate
distance from the shore and sea or estuary.
2. The wording "spreading room",
seems to be jargon for what? Car Parks, Picnic Areas, Camp Sites?
All these require correct 21st century sewage provision, pipes
out to sea are not acceptable anywhere.
3. Clear designation and avoidance of paths,
where they would be considered on any shore line, designated or
proposed for shellfish aquaculture, either by expansion of Several
or Regulated Orders. There are reed beds and bogs, again where
safety and damage would be of equal impact.
4. We have a large back log, of Several
and Regulated Orders between DEFRA legal and the Crown Estates,
both in renewals and new orders like the request for Morecambe
Bay. Even on a safety issue we are not seeing movement, and we
have seen none since 2005. These orders would have to be caught
up, to return or retain rights for these fisheries, before Coastal
Access Provisions.
5. If every shellfish business however small
requires a licence, they have already been caught as the only
industry, where PAYE employees are part of The Gangmasters Authority,
careful mapping and thought should be given to these businesses,
together with National Parks and Bird Habitats.
6. The coastal erosion and sea defences
should have had a section in the Marine Bill given their importance,
you cannot allow areas to disappear if a coastal path is policy.
Or checking and rerouting would become a weekly imperative on
some coast sections.
7. Coasts at sea level in current working
use, should not be considered playgrounds for cyclists, horses
or dogs, they are dangerous and rescue times will not stretch
in all cases. In the case of shellfisheries, animals should be
excluded given the extensive testing regimes associated with the
aquaculture industry.
Gillian Mills
Chairman, Mollusc Committee of the Shellfish Association
of Great Britain
May 2008
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