The Environment Agency tell us they “Follow the principles on consultation set out in the guidance provided by government.” That means they should:
- Give enough information to ensure that those consulted understand the issues and can give informed responses”
- Include validated impact assessments of the costs and benefits of the options being considered”
- Take consultation responses in to account when taking policy forward”
- Use… collaborative approaches”
- Consult about policies or implementation plans when the development of the policies or plans is at a formative stage. Do not ask questions about issues on which you already have a final view.”
- Government Consultation Principles -2018
Has this happened? Let’s see.
In July 2015 the Environment Agency held drop ins and conducted a survey. 54 responses were received and out of the options presented, a flood storage reservoir was favoured, involving:
- the construction of an earth embankment dam …. a reservoir …., adjacent to the Coggeshall Football Club car park. An earth embankment …. across the natural valley of the Blackwater at this point.
This survey opened the consultation process. That a 54 people favoured some form of reservoir does not justify the approach that has subsequently been taken. On the day of this event the EA met with Blackwater Aggregates.
In November 2016, 2 months after the Environment Agency published an update which made no mention of Blackwater Aggregates, the Environment Agency and Blackwater Aggregates met with Essex County Council for pre-application planning advice. The scheme - described in detail in the application - is the scheme now being pursued.
In April 2017 representatives of the Environment Agency gave a presentation to Coggeshall Parish Council. They gave an overview of the Government’s flood alleviation programme, noting that cost benefit analysis had ruled out grants for Coggeshall and encouraging the clerk to collect money from those affected by flooding . No mention was made of the scheme being developed with Blackwater Aggregates.
In June 2018 an article in “Current” magazine (an in-house EA publication) praised the collaboration with Blackwater Aggregates :
- The regular open communication across the team allowed work to be targeted, ensured the team remained engaged, allowed quick decisions and ultimately ensured the project was delivered ahead of programme with significant cost efficiencies.
- the project team successfully met the very tight timescale with over 50% cost saving and satisfied the end client and stakeholders.
We, the real “stakeholders”, were in the dark, we had to wait another 3 months before we were made aware of the partnership between Blackwater Aggregates and the Environment Agency and 5 months before we were made aware of the quarry.
The May 2019 drop-in took place after it became clear that the flood alleviation scheme was first and foremost a quarry. In July around 200 Coggeshall residents attended a meeting called by the Parish Council. Representatives of the Environment Agency addressed the meeting. The 354 respondents to the Environment Agency’s online survey - including many who are affected by flooding - overwhelmingly rejected the scheme.
The October 2019 Update blamed this rejection on “factually incorrect information” in a leaflet published by CRAQ. Two of the examples cited were not mentioned in the leaflet and the third was based on information in the Environment Agency’s own environmental scoping document. The community’s rejection was not attributed to the news that flood relief would be preceded by 20 years of quarrying progressing over 155ha of much loved green space.
In October 2019, in response to the overwhelming rejection of the scheme, the Environment Agency promised to “make improvements to the availability of information relating to the detailed design of the scheme”.
In April 2020, there was no “ongoing process.” The Drop-in events were cancelled because of the coronavirus pandemic. Apart from cosmetic changes our responses had not been taken into account "when taking policy forward.” Instead, the Environment Agency declared that their scheme was final. While the rest of the world was on hold, the Environment Agency intended to press ahead with the planning application.
In 2023 in response to one of these FoI requests we received the hydrologists’ reports drawn up for the Environment Agency which confirmed that the proposed £34m scheme would only reduce the risk of flooding from the Blackwater. Dealing with the greater threat from surface water and Robin’s Brook would have to wait until the Blackwater scheme was completed - 20 years!
We, the “stakeholders” have not benefited from “open communication”. The information we have been given about mineral extraction in the valley, the use of quarrying in the construction of the scheme, the number of properties at risk, the number of properties that will benefit remains unclear. What is clear is that this scheme would bring 20 years of quarrying to an open, green space which will, disrupt wildlife, destroy the landscape setting of our historic village and blight the lives of those living nearby. In return for this we get a flood alleviation scheme that fails to alleviate flooding.
In March 2024 in the midst of consultation about revisions to the Essex Minerals Local Plan the EA and BA held a drop-in event. Far from offering a further opportunity for consultation the event confirmed that our responses and contributions have been dismissed and the collaboration with Blackwater Aggregates continues .
