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Hoylake Beach: Co-Leaders Write To Natural England

Cllrs Pat Cleary and Jo Bird outline detailed concerns regarding the future beach management plan for Hoylake

We write regarding the ongoing efforts to update the management plan for Hoylake Beach. In doing so we have taken advice from people with scientific expertise in the current condition and evolution of Hoylake Beach and a passionate interest in securing a future for the beach that maximises the long-term benefits for nature, the people of Hoylake and the wider community in Wirral and beyond.

At a meeting of Wirral Council’s Environment, Climate Emergency and Transport (ECET) committee on April 15th 2024, Wirral councillors voted by majority to press ahead with the maximum raking option for Hoylake beach.  As you will know, if enacted, this would mean an increase in the volume of windblown sand reaching the road in the RNLI corner of the beach and a reduction in protection from storm surges in front of the closest buildings to sea level along the whole sea front. The western slipway of the RNLI station already allows sand to leave the beach in south westerly winds, but a direct route from the outer beach is currently narrow due to the expansion of the green beach.  In November 2021, this part of the promenade was relatively sparsely vegetated and suffered disrupting sand problems after Storm Arwen. This is very likely to reoccur, costing the local authority significantly more in clean-up costs.  The estimated cost per year of clearing sand from Hoylake promenade was previously £46,000 a year. In addition, the direct costs of clearing vegetation under  are estimated by the council at circa £230,000.

That committee decision was taken despite feedback from Natural England that  would involve an unacceptable level of vegetation removal. Feedback from the recent public consultation was that about 2/3rds of those who engaged supported . The level of engagement was approximately half of that of the previous consultation in November 2022. Members of the ECET committee were not consulted about the public consultation and had no opportunity to comment on what should or should not be included.

At the meeting on April 15th Green Party councillors proposed an alternative to the two options presented for public consultation by the council. We believe this would have led to a better outcome for biodiversity as well as a larger, more attractive and more sustainable amenity beach area. This is explored in more detail below. 

We believe the critical factors to consider in developing a new beach management plan are:

  • Safe and secure conditions for the RNLI to carry out their operations
  • Easy access for all to amenity beach facilities
  • Preservation of plant species that are protected under national and international law
  • The uninterrupted evolution of sand dunes to assist the emergence of natural flood defences
  • The prevention of wind blown sand onto the promenade at Hoylake and the associated inconvenience to the public and costs of dealing with this for the local authority
  • The carbon benefits that arise from the natural evolution of the beach

These principles guided our alternative proposal to the ECET committee. We recommended replacing the cleared strips with managed flat “grass” tracks. In addition, we suggested exploring with Natural England the addition of an extended amenity beach seaward of the embryo dune ridge to any “artificial” area above the reach of the tide cleared to meet RNLI requirements close to the RNLI station. Fundamental to this proposal is access for all members of the public to the amenity beach area.

For its part the RNLI has stated:

  • That at present they are able to operate safely on the foreshore, though they are concerned that this may change in the future.
  • That they have avoided running training exercises on the Atlantic Salt Meadow because of public perception, not because there is an issue with recovering on the vegetation. 
  • They need a location to recover the main lifeboat during exceptional storm-assisted spring tides, when the Atlantic Salt Meadow is submerged, and subsequent return to the lifeboat station over a flat stable surface.
  • They have issues with windblown sand and encroaching vegetation on both the east and west slipways (not the beach itself).
  • That they do not want to be seen as shaping the final outcome as long as their long-term operational needs are met.

Our reason for proposing “grassed” RNLI recovery tracks are three-fold:

  • The recovery route, if reduced to bare sand, is parallel to the shore. This means that it is perfectly aligned to allow saltation to develop with the prevailing wind, blowing along the strip.  This will result in a progressive erosion and potential destabilisation of the Atlantic Salt Meadow. A similar effect already occurs in the much narrower footworn path close to the promenade wall and is causing issues on the west slip and a lip on the inner edge of the salt meadow. On top of this, in circumstances where there is a high tide and rough seas, there will be extensive erosion of the bare sand, leading to even greater erosion and potential damage to the habitat inland of the strip. Hence, we believe that bared sandy strips will fail in their primary aim to provide a flat and stable surface for the RNLI to work with, in addition to destabilising the surrounding habitat.
  • Shore Dock (Rumex rupestris) is listed on Annexes II(b) and IV(b) of the Habitats Directive and is protected under Schedule 5 of the Conservation of Habitats and Species Regulations 2010 and Schedule 8 of the Wildlife and Countryside Act 1981. At Hoylake, it exists between two contours in the area of the planned runways, one circa 15-20m out from the promenade and another along the sea wall, though there are many currently unidentifiable young dock rosettes between these lines. It currently occupies the only locations that meet its growing requirements at Hoylake, so translocating individual plants is not viable and it is not possible to site the proposed  track without affecting most if not all of the known extant plants between Kings Gap and the RNLI.
  • A ‘managed’ grassed track would be stable and potentially add to the biodiversity of the site.    A return route through the linear dune slack could be marked with occasional posts and highlighted as a footpath so it remains visible if flooded. For now, human footfall and occasional use by the RNLI tractor would maintain the path.  as the succession progresses, the vegetation could be cut. With correct timing this could be compatible with Shore Dock.  An accessible entrance to the high tide recovery site could be maintained by traversing the embryo dune ridge during exercises. Any local unevenness in the surface deemed to be an issue to the RNLI could be filled with loose sand or levelled slightly – there is already a wide and relatively flat plateau caused by Storm Arwen sand blow.  

The proposed amenity beach location is adjacent to the promenade and well above the Mean High Water Spring Mark, where it will require major and expensive interventions to remain completely unvegetated.   Above the reach of all but exceptional tides, the area that can be designated as amenity beach will not be any larger than that required for essential RNLI activities, due to the strict requirements to meet the test of overriding public interest in the Habitats Directive.  There has been no consideration of locating the amenity section of the beach along its current natural contour, seaward of the embryo dune line as initially suggested by Natural England in your advice of March 1st, 2020. There is also no consideration of setting up genuine access for all to one of the biggest sandy beaches in Europe. A softer option that works with the developing habitats and would potentially provide a much larger amenity beach area than . Beach management activity to remove/suppress an agreed area of new or existing Spartina and isolated Puccinellia clumps would have the effect of favouring vertical rather than horizontal dune ridge development which in turn would create more diverse habitat. It is our belief that removal/suppression of this pioneer habitat is both less likely to have a significant and damaging effect on the protected features of the SAC and easier to find appropriate mitigation for, than vegetation landward of the embryo dune line.

We ask that Natural England considers these alternative, less damaging solutions when refining the beach management plan for Hoylake. 

Specifically, we ask:

  • that Natural England take account of the points above in helping to shape a sustainable, cost-effective solution for the future management of Hoylake Beach
  • for feedback on whether our suggestions would be more compatible with protecting the conservation features of the statutory designated sites than the  proposal as agreed at the ECET committee on April 15th along with any additional points you would like to raise in response to this letter.

Thank you for taking the time to read our concerns. We look forward to hearing from you.

Cllr Pat Cleary & Cllr Jo Bird

Co-leaders, Green Party group on Wirral Council

Co-leader of Wirral Green Councillors, Pat Cleary with the Green Party Parliamentary Candidate for Wirral West, Gail Jenkinson on Hoylake Beach