Extract of correspondence between NRW and the Maritime Unit, Gwynedd Council re: Proposed works to the Crib Groyne at the harbour entrance -
A Brief from the Maritime Unit for PMBHA Members
"We have been in further communication with NRW with regard to the repair of the Crib Groyne and the Marine License Public Consultation period has ended.
We have tendered the work for the Crib Groyne and are intending to appoint the successful contractor within the next few weeks with hopefully commencing the work before the end of September 2019.
I have copied below further questions from NRW. The purpose being just to keep you informed of progress and to provide a broader view of the areas that we need to address by Cyngor Gwynedd in order to meet with the requirements of NRW.
We will respond to the request for further information as soon as possible but of course this can delay matters further and possibly incur additional costs.
The reference to ‘sand’ in item number 1 relates to the placing of sand on rocky foreshore areas to replace any habitat loss as a result of increasing the footprint of the Crib Groyne. As we are all aware the sand will disappear from such rocky foreshores very quickly and possibly be re deposited nearby. My initial interpretation of the ‘sand’ was as a replacement for ‘rock’ on the Crib Groyne which of course, thankfully, was not a requirement.
We await a response from our technical advisors which is expected later today."
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"There are concerns with regards to the direct permanent loss of the Large shallow inlet and bay feature as the proposal involves the placement of rock armour and the resulting loss of 320m2 of Large shallow inlet and bay SAC feature.
The conservation Objectives for the Pen Llŷn a’r Sarnau Special Area of Conservation state that to achieve favourable conservation status all features, subject to natural processes, need to be fulfilled and maintained in the long-term. If these objectives are not met restoration measures will be needed to achieve favourable conservation status.
The Bay is currently considered to be of high habitat quality, therefore this development as currently submitted would incur a permanent loss of high quality habitat and should therefore be considered as significant and in need of assessment in terms of adverse effect. We therefore need to consider whether the following measures would be sufficient to avoid an adverse effect:
1. Subfeature replacement (rock for sand) and whether that would be considered to maintain the overall extent and distribution of the feature
2. How effective the rock armour would be in acting as a rocky outcrop when it is freshly quarried rock (albeit local rock), and whether it could be considered to be a replacement SAC habitat.
Please provide justification for the effectiveness of these options to avoid adverse effect on the integrity of the SAC.
Changes in hydrodynamics (Reef feature)
When discussing the impact of potential changes in hydrodynamics on the SAC reef feature as a result of the proposal, the Technical Note (CEUK, 2019) which you submitted concludes that the proposals would not alter the pattern of flow or behaviour. However, there is no assessment provided of the location of reef SAC feature and any indirect effects to allow assessment. We would expect to see a map of the feature and the new design of groyne with potential pathways considered. Please provide this
Please provide an indication of when this information could be provided."