text:
Steve Trowbridge
An itinerant Civil & Structural Engineer's view of what we build
Bridgwater Tidal Barrier
Tag: Bridgwater Tidal Barrier
Bridgwater Tidal Barrier EIA Scoping Opinion – a lack of knowledge, vision or a rubber stamp?
All large infrastructure projects require an assessment of its impact on the environment. The Bridgwater Tidal Barrier is no different and as one of the UK's first real climate change driven projects it is important that the long term impacts are understood not just the immediate aftermath of the construction process.
Screening and Scoping Opinions (Environmental Impact) Screening is the process of deciding which projects require an Environmental Impact Assessment (EIA). A scoping opinion only considers what information should be included in an EIA.
Infrastructure projects whether the BTB, the expansion of London's railways in the 1800s or the construction of the UK's motorways in the 70's have well established long term impacts on our environment as society adapts to the change the project imposes on the area. In Bridgwater's case the planned BTB removes 3 to 400Ha of potentially development land close to Bridgwater and its existing communication links (J23 of the M5). With the topographical constraints imposed by the M5, the railway and the River Parrett the other options for future development are few.
Bridgwater will in the 100 years of the BTB operation continue to expand and grow and a conservative assessment of the additional area of Bridgwater developed for housing and employment will be around 40% of Bridgwater's current footprint. Bridgwater's expansion has to go somewhere and it will impact on the environment beyond the immediate area of construction.
The water that will flood onto the the farmland with increasing frequency will be saline and will change the nature of the land destroying valuable freshwater habitat at Chilton Trinity and at Pawlett Ham's and the ability to grow food.
A warming climate will see the arrival of new species in particular the Asian Tiger Mosquito to existing open water and bringing the inter tidal habitat up to Dunball as proposed by the Parrett Estuary Flood Management Strategy to the edge of Bridgwater's habitable area threatening the health of people in North Bridgwater, Pawlett, Chilton Trinity and Puriton and the housing developments on King Drive. It is not unreasonable to consider that open water may well be considered in the same way as in other warm climates as being breeding grounds for mosquitoes and a source of the Zika virus and Denge Fever.
What the EIA opinion ignored.
The impact of pushing the economic development onto the Quantock Hills
The impact of building on the levels to the east of Bridgwater
The impact of seawater on the land.
Increasing the rate of salt ingress into the land due to retention of saline water in the borrow pits.
potential habitat creation for invasive species and the health threat they make to the local population.
The work done in in this document seems to irrationally imagine that
Bridgwater does not expand for the next 100 Years
Environmental changes will only be driven by sea level rise
The environmental impact is only in the immediate area of the scheme
There is a complete lack of appreciation of the what the BTB scheme entails and its impact on the environment. It studious ignores the wider impacts of this scheme and allows the development to move forward with little or no consideration of the impact. It offers no visibility to the public of what impacts may occur in the next 100 years. EIA are by nature speculative and in the case of the BTB scheme the applicants should provide a wider and more comprehensive assessment.
The EIA is simply inadequate and as a consequence make the work done incomplete and questionable in its efficacy. It is a continuation of the lack of vision and understanding of this project, a project that is key to the long term future of Sedgemoor and Bridgwater.
Bridgwater Tidal Barrier; EA submits Planning Application via Transport and Works Act
The Environment Agency has recently submitted its application to build the Bridgwater Tidal Barrier through the Transport and Works Act (TWA). Its rather like a planning application to Sedgemoor District Council but in this case its to the Secretary of State.
The EA TWA submission repeatedly sets out 10 objectives for this scheme and this article examines whether the Barrier we are being sold does what the EA and SDC say is on the tin.
DOES THE BRIDGWATER TIDAL BARRIER MEET ITS OBJECTIVES?
The scheme consists of two elements designed to keep the sea out of Bridgwater town centre for the next 100 years. Dunball and Bristol Road have to take their chances if there is a breach where as Chilton Trinity gets a second level of protection.
Ultimately the EA plan is to hand over the existing downstream fresh water habitat to the sea creating an inter-tidal habitat. The effect will be to bring the coast from the Steart Peninsula up to Dunball converting the existing farmland to mudflats and salt marsh.
The BTB consists of two elements.
7 miles of improved river banks that will be maintained for 20 years after the construction of the BTB after which that maintenance will cease and the frequency of the saltwater inundation on the land will be allowed with increasing frequency and the freshwater habitat poisoned.
2. A large reinforced concrete structure with two lift gates located in unconventionally inland and exposed to salt water with a large tidal range that causes one of the most corrosive mechanisms for this type of structure.
The EA / SDC / SRA Objectives
These objectives are presented with no basis as to how they were arrived, what the pass fail criteria is and the implications of not meeting the objectives.
Reduce tidal flood risk to the highest number of properties and commercial businesses in Bridgwater and the surrounding are
Reduce tidal flood risk to critical infrastructure and utilities in Bridgwater and the surrounding area
Deliver a scheme that can be adapted for the future effects of climate change.
Align the project with the strategy set out in the PEFRMS (see also Section 2.2).
Align the project with the recommendations set out in the 'Protecting Bridgwater and the Somerset Levels & Moors from Tidal Flooding, Flood Risk Management Review' (Black & Veatch, 2014) (see also Section 2.2).
Ensure the design and operation of the scheme aligns with Local Plan policy for development and does not restrict the future development of Bridgwater and the surrounding area.
Minimise the impact on environmental receptors during the construction and operation of the scheme. Deliver mitigation as required to protect those receptors that may be affected, whilst maximising positive environmental outcomes.
Minimise health, safety and welfare risks associated with the construction, and operation of the scheme.
Identify funding and partnership opportunities and outline any additional work to gain financial contributions.
Develop a sustainable scheme that minimises future operation and maintenance.
Objective No 3; Deliver a scheme that can be adapted for the future effects of climate change
It is not stated what those effects of climate change are believed to be, the reader is therefore wrongly invited to presume that the only effect will be rising sea level whilst ignoring other potential changes to the environment and what provisions for adaption have been included in the design as the statement implies.
To illustrate that the EA has not met its own objective I have the following observations.
In order to support this statement, there would need to be a set of assumptions and the concept as to how it might be achieved.in order to judge whether the statement was correct, and the objective met . No such statement exists in the submission.
The stated position of the EA/ SDC/ SRA is no pre-investment for a future scheme; there is no plan B or provision in terms of reserving space for the construction of a new barrier behind or in front of the proposed one.
The TWA submission implies that the structure would be useful beyond its design life of 100 years and quotes a 1:1,000 return period as being available for flood defense. The BTB is a reinforced concrete structure and in the saline (seawater) environment of the River Parrett such structures do not do well and it is likely that structure would need to be replaced rather than adapted.
The indicated clearance between the barrier gates when lifted and the underside of the access bridge shows no provision for taller gates needed to accommodate rising sea level beyond the design basis.
The planned abandonment of the downstream River Parrett riverbanks some 20 years after the barrier structure is completed means that the secondary flood defenses ultimately become the primary flood defence and the future shoreline close to Bridgwater. Much of these banks particularly adjacent to the A38 are founded on the near liquid clay that underlay the Somerset Levels. Nearby Cannington Bends with similar ground conditions continues to settle and the submission notes the need for it to be made up every 30 years or so. It is worth noting that the trial embankment test results do not form part of the supporting documentation. Higher banks will increase the risk of settlement or a breach occurring and triggering an event that the scheme is meant to stop.
There is nothing within the TWA submission to support the statement that the objective has been considered, addressed or met.
Objective 7; Ensure the design and operation of the scheme aligns with Local Plan policy for development and does not restrict the future development of Bridgwater and the surrounding area.
Bridgwater if it maintains its present level of growth in housing and employment will need to increase its footprint by 40% during the design life of the BTB. Much of the allocated land in the present Local Plan approved in 2019 is already under development with only the new Gravity Development at Puriton providing substantial employment land. The only other low quality land available for housing and employment , around 1400 acres strategically close to Junction 23 will be used by the BTB as an operational flood plain to take seawater when barrier is in operation.
There is no statement explaining what Objective 7 actually means or how the objective is achieved.
Specifically this proposal
Denies the Bridgwater the economic benefit associated with developing land adjacent to a motorway junction (J23).
Denies Bridgwater the opportunity to build some 5000 houses and supporting employment centers
Forces future housing development to the south west of Bridgwater that will continue to increase the demand on on the A39.
Increases the separation between residential and employment centres with housing moving to the south and employment to the north ans as consequence increasing the amount of commuting and demand on the road system that ultimately restricts economic development.
the SDC 2050 transport strategy shows the Northern Bridgwater Bypass crossing the operational flood plain created by this scheme. Roads creates economic development and the Transport Strategy and BTB appear to have conflicting objective for the land to north of Chilton Trinity.
The location of the Tidal Barrier ignores the expansion of Bridgwater over the next 100 years showing no consideration for the planned expansion of the town. There is nothing in the BTB submission to indicate what considerations have made. The EA/SDC decision not to commission an Economic Impact Assessment means that statement cannot be substantiated and explains the lack of a coherent position on objective 7. The Objective is clearly not met.
EA blocks early Bridgwater Bypass Route
In October 2019 the EA produced a plan to block off the only remaining early route for a Bridgwater Bypass. Despite being close to the A38 and having no village (Chilton Trinity) to consider material the EA has decided to dig another borrow pit rather than use locally excavated clays, material that is always available as part of local construction works primarily house building. That pit located in the only remaining place is where an early Bridgwater Bypass can go and the river is at its narrowest.
What this borrow pit means is that nothing can happen until EDF finish with the Park and Ride at Dunball. This pit will see the taxpayer pay for a longer more expensive bridge and wait longer for traffic relief.
Bearing in mind that this borrow pit could be anywhere and is not actually needed as alternative supplies of suitable fill are always available the only logical reason for this location appears to be to ensure that SDC's flagship Gravity development does not have any immediate competition. If that is not the case SDC councilors need to be explaining why economic opportunities are being blocked on their watch, why we are not building sustainably and not building in the most economical way.
Despite Sedgemoor District Council declaring a climate change emergency (Bill Revans instigation) the Bridgwater Tidal Barrier scheme continues to ignore any attempt to make this scheme sustainable and reduce cost.
Where is the scrutiny of this scheme by councilors?
Where is the sustainability?
What could be a better plan than to dig a very big hole where you might need to build a road?
annotated extract of SDC drawing showing bypass route and borrow pit
Original SDC/EA drawing showing pits to be dug.
SDC 2050 Transport Strategy map
Irresponsibile or Incompetent? Local councillors role in the Bridgwater Tidal Barrier
An old boss of mine says unintended consequences is merely the failure to adequately consider the implications of the decision being made.
The location of the Bridgwater Tidal Barrier (BTB) is probably the most significant decision Sedgemoor District Council has made in many years. Rarely can such an important decision have been made with so little debate. If it's in the wrong place we and the following generations live with the consequences for the next 200 years or so. No one is giving us another one if its wrong.
On the 26th July 2017 a full Sedgemoor District Council meeting agreed the location of the Bridgwater Tidal Barrier. This decision according to the minutes was apparently waived through without discussion. That the EA and SDC gave a superfical 3 page briefing document with so few key facts indicates just how confident EA and SDC officers felt able too simply ignore the longer term collateral environmental and economic impacts of this scheme. It is a clear indication of the low esteem our councilors are held in. Councillors lack of oversight of this scheme does indicate the officers probably wernt wrong. Silent oversight committees seems to have presided over continued and unsatisfactorily explained cost rises. The cost almost doubled in the the six months after the decision was made. Barely a word was said.
Abandoning 1,400 acres of valuable land next to a motorway junction capable of supporting £1B of future investment (jobs) whilst unnecessarily forcing future housing onto the Quantocks foothills extending Bridgwater to absorb Cannington, Spaxton and North Petherton.
This decision will be seen as one of the most irresponsible and reproachable acts by councillors of any local authority at any time. SDC knowingly made a decision to convert the Parrett Estuary into an Intertidal Habitat and behind the the secondary flood defence create more areas of habitat suitable for freshwater mosquitios such as the Zika and Denge carrying Asian Tiger Mosquito to take up residence.
Limiting economic expansion, building on the Quantocks, poisoning the fresh water ecology of Chilton Trinity and Pawlett Hamsand and creating a future health hazard is hardly what we people voted councillors into office for.
If they did know why did they do it?
If they didnt know why not?
Why is this case?
The BTB design uses farmland downstream of the barrier to allow incoming saltwater to spill over riverbanks onto the farmland. It destroys the economic value of around 2.400 acres of land either to continue as low-grade farmland or 1,400 Acres of that total to the south of the Parrett providing land for nearly a £1B of economic development accessible from J23. Would any town throw such an economic legacy away with so little concern? Bridgwater has. The longtime environmental Impact of this scheme is equally as bad; the land being flooded will ultimately become saltmarsh and a large part of the local Quantock foothills unnecessarily developed
The December 2018 public consultation asked for feedback on three basic points
The details of the proposals for both the barrier and the downstream flood defences.
How you think the proposals may affect you, your land or your business.
What additional improvements you would like to see delivered as priorities, in addition to the barrier and the downstream flood defences, subject to funding.
Large civil engineering projects influence long-term economic development as we have seen with development taking place around our motorway junctions; the proposed Bridgwater Tidal Barrier (BTB) will influence Bridgwater's future development in a similar way for at least the next 200 years. The Bridgwater Vision published in 2015 and referred to in the presentation identified land for future development most of which is either now approved or starting to be built out under the local plan. Bridgwater is already reaching the limit of land that can be easily accessed from the town and the M5.
Assuming Bridgwater continues to develop economically at even half its present rate, during the design life of the BTB, an additional 25,000 houses will be built and together with land for employment and Bridgwater's footprint will grow by around 40%.
Under the present BTB scheme low quality farmland directly beside Junction 23 that could have provided space for at least £1B of economic development, housing and jobs will be lost to the town. Alternative land over the next 100 years will need to be found and that will invariably mean development moving on to high quality agricultural to the south and west of Bridgwater. We will build on the land that feeds us whilst living ever farther from planned and established centres of employment to the north and north east of Bridgwater (Horsey). Building at Horsey will require a new bridge over the King Sedgemoor Drain; money that could be used to cross the Parrett and bring forward a much needed northern bypass.
The reader should take cognisance that the two options studies done for this scheme, the first included highly improbable options such as the Bridgwater Bay power lagoon and outside the influence of the authors. The second option study looked at the same solution at a limited number of locations and would always arrive at the narrowest part of the riveras the prefered solution. It was a superficial study and lacking rigour and at the time of this note the final information used by an SDC sub group remains unpublished despite an FoI request to Sedgemoor District Council remaining outstanding.
Other options and locations to protect Bridgwater and the downstream villages were available but not considered.
The Bridgwater Tidal Barrier is a 7mile long inland tidal surge flood defence scheme with a 100 year design life based on sea level rising around 800mm during this period. Similar to the current Thames Barrier it consists of a two elements.
Riverbanks profiled to preferentially spill seawater, during extreme tidal surge conditions, onto farmland at Chilton Trinity and Pawlett Hams.
A small double vertical floodgate barrier located in the industrial and employment Express Park area of Bridgwater and approximately 1 mile from the town centre.
The replacement Thames Barrier will be sited more conventionally at the mouth of the Thames; Combwich is Bridgwater's equivalent location.
The riverbanks are expected settle and need reconstructing every 35 years
The height to which the riverbanks can be raised is limited by the poor ground conditions.
Although needed no provision of any kind for a replacement is considered.
Contaminates around 2400 acres of farmland with salt water
Constrains economic development to the northwest of the town.
Significant loss of existing freshwater habitat in line with managed realignment policy 7d39 of the Shoreline Management Plan to create an intertidal habitat.
EA DIAGRAM SHOWING SALTWATER FLOWING ONTO FARM LAND
The closure of the barrier at low tide creates a separation of the two types of water that use the River Parrett. Upstream freshwater from the Parrett and its tributaries such as the Tone; Yeo and Cam will be impounded behind the closed gates. Downstream the freshwater will finish emptying into the Severn and the then the empty river filled with seawater on the incoming tide.
All flooding shown downstream of the Bridgwater Tidal Barrier will therefore deposit salt water onto the land. This is saltwater and the impact should not be confused with the 2014 event.
The land in question at Chilton Trinity has not been flooded with salt water in this way within living memory. Pawlett Hams was briefly flooded in the early 80's and flooded Pawlett from the north where no flood defences are planned.
What is clear is that considerable ambiguity remains in the proposal. Many issues are simply ignored or the messages contradictory. The following summary and notes provides some comments that should be addressed.
It is disappointing that such an important scheme appears to have been given so little strategic thought whilst the barrier appearance and immediate landscaping seems to have received considerable if unsuccessful attention.
Clearly the priorities of the design and client team are not those of the ratepayers who do not need a solution where the medicine kills the patient which is what we appear to have.
River Banks
One consistent underlying theme is that once the barrier is built the land to the north and south, Chilton Trinity and Pawlett Hams, will ultimately become intertidal habitat in line with existing published policies.
The key supporting facts are
The cost estimate that does not include for future riverbank reconstruction
Planned flooding of agricultural land with saltwater.
The claim made "Bridgwater and the surrounding area will be better protected against a severe flood by building the barrier and improving the downstream flood defences. These works will also maintain the current standard of defence to agricultural land".is misleading to landowners indicating that farming will simply carry on as normal. With the frequency of saltwater flooding increasing the land will not support the type of grass needed for agricultural. Areas of Norfolk are still recovering from single sea water incursion 65 years ago.
Borrow Pits
No location for the pits was given, which side of the secondary flood defence. It would not be unreasonable to assume between the river bank and the secondary flood defence. A rough estimate would indicate that the scheme will need around 100,000m3 to 150,000m3 of clay creating a large open area (7-8Ha) of stagnant water that will through our now warmer summers become more saline as they will operate as a large evaporation pond. That mechanism does not allow the wildlife enhance described to occur.
Locations were shown to stakeholders but not the public
A number of claims are made regarding the lack of environmental impact that this scheme has on the ecology however changing the habitat from freshwater to saline will fundamentally change the area in line with the published strategy of changing the land to an intertidal habitat.
2,400 acres of fresh water habitat is destroyed through repeated seawater flooding.
Cost or Intention
An estimate of £94M is given in the EA presentation. Through a FoI request (03 April 2018) The EA provided an estimated whole life cost closer to £160M. That estimate assumed £12.4M Net Present Value or £55M cash cost over 100 years including for maintaining and rebuilding the riverbanks that is around 4x the value of the land. Economically this statement on maintenance costs makes funding the future bank rising impossible. If the circa £100m estimate is correct this would cover the gate maintenance and not the riverbanks.
The expected need to rebuild the riverbanks twice in the 100-year design life is not mentioned in the presentation and the assumption must be that the intention will not become reality and would conflict with clauses 1.10.1 and 1.10.2 of SDC's Parrett Estuary Flood Risk Management Strategy
The whole life cost of the scheme is either
£100M with one set of the riverbank improvements at the time the barrier is constructed.
£160M with three sets of the riverbank improvements including the time the barrier is constructed and subsequently at 35-year intervals after that. That must be the budget.
Did nobody ask why?
Collateral Impact
This scheme is presented at completion in 2024 and looks only at immediate local impacts. Construction will have immediate and long term wider negative consequences for Bridgwater none of which have been raised or addressed despite written assurances that that would not be the case.
Loss of 1400 acres of key land suitable for £1B of economic investment for housing and industry that is directly accessible to Junction 23.
Creation of a working flood plain over which a potential bypass might need to be constructed.
Increasing separation of housing from employment by forcing development elsewhere.
Loss of economic food production on prime agricultural land
The loss of in existing land values of around £12m and potential bankruptcies where the land is used to secure business loans.
Environment Impacts
Destroys 2400 acres of fresh water habitat through deliberate seawater flooding initially during extreme tidal events but ultimately becoming within the normal tidal range.
Forces development to take place on high quality agricultural land to the south and west of Bridgwater.
Forces apart residential and employment areas with a consequent long term cost to the economy and the environment.
Places increased demand on the A38, A39 and Kings Drive as industrial development is forced east to Horsey and to the approved BAE industrial site.
Barrier Superstructure
The barrier superstructure is 2 to 2.5 times higher than it needs to be and lacks any shape that reflects its functionality. It achieves the rare combination of being both pretentious and mediocre. With a structural volume that must be four times what could be reasonably required to support its function it is bloated, unnecessarily expensive and will be difficult and expensive to maintain. Overhanging shapes require specialist access equipment for maintenance. Everything on the structure seems designed to cost more than is necessary. Its appearance seems to owe more to Mr Blobby and the Teletubbies than the Falkirk Wheel, it doesnt do anything like the Falkirk Wheel so hardly a tourist attraction.
The very large ovoid bridge structure will be particular difficult to maintain, it will be almost impossible for safe inspection of the lower quadrants to be made or worked upon. The form of the structure indicates little attention appears to have been taken with regard to the Construction, Design and Management 2015 regulations with regard to the safe operation and maintenance
The poor design of this structure extends to the gates, rather than protect the gates from the salt loaded wind driven rain, the site is classed as a marine environment, rain will be spilled from the ovoid bridge onto the gates increasing maintenance and reducing the life of the gates.
As a piece of architecture and a piece of engineering this structure almost certainly fails on cost, function, operator safety and buildability.
Storage Buildings are provided when the EA has a depot nearby at Bradney.
Did no one ask why we need additional buildings at the barrier site?
Presumably they would also attract rates?
The lack of sustainability in this project is very concerning;
The decision to excavate burrow pits to reduce construction traffic seems highly questionable. "Where possible, we will excavate material locally from 'borrow pits'. This will minimise the need to bring in material to build the new downstream flood banks and reduce construction traffic."
The EA was more than happy to bring excavated material from its Cannington flood project to Chilton Trinity yet the more sustainable option of building the banks over a longer period using spoil from building sites is not considered. It's not as if the defences need to be at their final levels until the last planned rebuilding of the banks 35 years before then end of the design life. This work could be done on an opportunistic basis over the next 50 years or so in a sustainable cost effective method by local contractors.
The continuing reference to 2055 that is key date in the shoreline management plan indicates thatany future raising of the river banks is unlikely to occure.
This process would also assist in maintaining accesses and local resources able to respond to urgent requirements such as a breach in the river bank.
Finally just to prove the point the EA/SDC presented on page 7 of the stakeholder presentation three images of unrelated events to support its postition.
West Quay collapse, an old wall collapsed when it got too much water behind it; we see thse failures alongside our roads all the time but we dont try and link them to climate change or a tidal barrier.
The 2014 flood was a pluvial (rain) event and the Bridgwater Tidal Barrier is not designed to mitigate a repeating event. There is clue in the word Tidal. Unfortunately many people in Bridgwater and the surrounding area believe that it is part of a pluvial flood defence scheme.
one was applicable
WEST QUAY & 2014 ARE NOT TIDAL EVENTS
Perhaps an SDC, Town or county councillor reading this might decide to ask some serious questions about this project, one can only hope.
Flood protection, wildlife & environment is always a one sided view.
The impact of wildlife organisations on locally managed flood projects is a concern. They seem to be free to make unsubstantiated statements whilst pursuing their objectives with little public visibility, criticism or professional oversight and it is a growing problem. It is a situation becoming increasingly familiar and yet another example of our growing democratic deficit where minorities impose their ambitions on the majority. The Somerset Levels, the Parrett Estuary and Bridgwater's need for a flood defence from the sea has brought many of these parties with their own agenda to one location each focusing on what they consider to be important. Bridgwater seems to be well down the list of importance despite the planned construction of the Bridgwater Tidal Barrier. The purpose of this article is to provide an explanation as to how this is happening.
Bridgwater currently builds around 500 houses a year and if that rate continues at even half that rate for the next 100 years we could expect to see the number of houses in Bridgwater rise by 25,000 taking another 700Ha (1,700 acres) of land for housing and a further 300Ha needed for employment. This 1,000Ha's will see Bridgwater's existing footprint grow by at least 50%, The 25,000 houses and associated economic development will generate perhaps 300,000m3 of clays and soil waste.
With flat and level land needed for employment land at the old BAE site and at Horsey offer the only other viable employment options to Bridgwater and they are to the northwest. New housing will be forced onto good quality farmland south along the A38 swallowing up North Petherton and eventually meeting Taunton coming the other way and to the west developing the land between Bridgwater and Cannington. Bridgwater will consume its high value agricultural land on the hills as it, like the rest of the country, continues to build our outdated ideas of housing.
Bridgwater will therefore become an even more difficult place to live and work as the gap between residential development and employment continue to grow. Every day a large part of Bridgwater's population will get up and drive along the A38 and A39 to get to work. Bridgwater will not even start considering a bypass until 2040.
Apart from the normal lack of imagination by planners and developer's Sedgemoor's (Bridgwater) greatest problem now appears to be the wildlife and flood pressure groups that seem to take an extreme view in the pursuit of what they consider to be in their interest. They show little tolerance or understanding that people also live on the Levels and in Bridgwater and ignor the EU directives that accept people must come first. The true impact of their objectives is concealed and never addressed.
These organisations also seem immune from any need to consider facts in their statements whilst criticising property developers for the smallest omission. The irony that is they now ape those same commercial organisations in assembling land and changing its use without considering its long term impact on the wider local population and it should be lost on no one.
Some typical examples
Steart Peninsula
The local economic benefits alluded to as part of the original Steart Peninsula planning application remain unproven and therefore represent little tangible benefit to the local population yet quoted as fact by The Severn Vision statements.
The Severn Vision
This plan will expand the existing saltmarsh by 833% around the Severn Estuary and in Bridgwater's case large areas of agricultural land removed from food production and converted from a freshwater environment to a saltwater one (intertidal habitat). To date two phases have been completed; The Steart Peninsula and the RSPB reserve (funnded by Bristol Ports) both of which remove economic activity and destroy an existing habitat to create another. A process little different from modern housing development. Whilst an argument might be made on the basis of geography for these two areas to be returned to the sea no such argument exists for the destruction of Pawlett Hams and Chilton Trinity including areas of the SSI.
This is a process promoted by the following organisations
Wildlife and Wetlands
The Wildlife Trusts
Campaign for Rural England (CPRE)
Severn Rivers Trust
With regard to Bridgwater it makes claims regarding carbon savings whilst ignoring the collateral effect of moving Bridgwater's housing developments onto higher quality agricultural land and increasing commuting distances. Also ignored is the loss of food production on 5,000 acres of land and the transfer of that food production overseas. It is particularly misleading in its statements with regard to Bridgwater providing no supporting evidence as to the negative benefit that it has considered in any balanced and holistic way. It is completely one sided yet already two key elements have been delivered, Steart Peninsula and RSPB reserve. The Bridgwater Tidal Barrier will deliver the southern land at Chilton Trinity and Pawlett Hams .
The Environment Agency and Sedgemoor District Council's Dec 2018 public consultation made a claim with regard to the lack of any environmental impact of this scheme. The EA and SDC have not considered environmental impacts beyond the immediate area of the scheme despite this scheme imposing restrictions on economic development forcing residential development to the south and west of Bridgwater and employment to the northwest of the town.
It is worth noting that HPC looked at issues far beyond the immediate area of the power plant when it did its enviromental impact assessment.
This statement above cannot be true as
Seawater is shown overtopping the river banks onto the existing farmland, the fact that it is seawater is misleading.
The farmland at Chilton Trinity and Pawlett Hams will be poisoned for agriculture through the introduction of saltwater
The existing wildlife that requires a freshwater environment will be destroyed.
The location of the borrow pits, which side of the secondary flood defence, was not shown. The plan to excavate 100,000m3 of material will create a lake of nearly 13 acres that will act as a reservoir for saltwater.
1,400 acres of high quality farmland suitable will be unnecessarily developed invariable towards North Petherton and Cannington as this scheme will convert 1,400 acres of low quality farmland that could have been used to saltmarsh.
100 years of lost food production on 2400 acres of farmland.
100,000m3 of clay will be unnecessarily excavated from the land being protected whilst during the same period 300,000m3 will be produced as waste through normal housing and industrial construction activities. (the secondary flood defences do not need to be completed to the full height during intial construction
Denying economic development in the north-west will increase commuting efforts in the local community generating avoidable C02; the scheme ensures the increased separation of employment areas from housing.
The claims regarding this scheme are questionable at best and the lack of information misleading at worse. The extract from the EA/SDC public display indicates a plan to create a stepping-stones for species that are not identified.
The CPRE's support for The Severn Vision that results in the wholesale destruction of a large area of our existing productive landscape and the equivalent of 10 500 acre farms is not what we imagined their core mission to be that says
"We campaign for a beautiful and living countryside. We work to protect, promote and enhance our towns and countryside to make them better places to live, work and enjoy, and to ensure the countryside is protected for now and future generations."
How allowing saltwater (seawater) onto productive farmland that has taken 500 years to remove the salt from seems a strange way of protecting our countryside.
Somerset's Wild Trust (SWT)
Another supporter of The Severn Vision.
Somerset's Wild Trust's website says
Since the 2013-14 flooding events, the dominant narrative in the floodplains has focussed on hard engineering schemes and dredging to reduce flood risk, overlooking flood risk reduction techniques that work with nature and provide a range of benefits to society. A future is developing where more public money will be spent on fossil fuel intensive dredging and pumping, to further drain the peat soils of the Levels, thus releasing more carbon and exacerbating climate change. As peat is drained, it shrinks, lowering land height and making the area ever more vulnerable to extreme weather. Well-informed debate on the future of Somerset's low-lying areas in the face of rising sea level is limited, so a further vital part of our work on the Levels is to communicate a more optimistic narrative which gives nature its proper value.
This statement ignores that the Somerset Level's is an artificial environment that needs regular maintenance and seems to conflate the need to dredge Somerset's rivers and the need to get pluvial flows from the upper Parrett catchment areas to the sea bypassing the levels storage with an idea that somehow this process is designed to shrink the peat. "A future is developing where more public money will be spent on fossil fuel intensive dredging and pumping, to further drain the peat soils of the Levels, thus releasing more carbon and exacerbating climate change" is a particularly spurious and misleading statement. It sounds like people are secretly pumping water off the levels as some sort of conspiracy.
Anyone with any knowledge of the Levels would know that retaining water levels is just as important to the Levels as draining them. No one is going to drain the peat. Well informed debate requires informed knowledge and that is clearly not the case with this statement by the SWT.
FLAG Flooding on the Levels Action Group
FLAG reflects its single issue origins seemingly taking its position on Somerset's farming industry geographically from the lands relationship to Moorland and what is best for Moorland.
A post (Nov 2018) supporting Somerset' s farming industry on the Levels was made by FLAG making Brexit the largest threat to farmers in anticipation of a nonexistent trade deal with the US; no doubt the cause of the 2014 flood and global warming will in time also be subscribed to Brexit.
FLAG's postion downstream of Moorland at Chilton Trinity and Pawlett Hams is quite different. Flag is altogther less compasionate regarding the farmers there having their land flooded with saltwater to alleviate upstream flooding. Concern is simply dismissed by a statement worthy of Marie Antoinette "let them raise salt beef or lamb". It completely ignores that the Bridgwater Tidal Barrier has already destroyed land values for 2,400 acres of land and food production we might have gained. Reverse nimbyism seems to apply; as long the flooding is on someone else's land FLAG appears to be happy whilst refuses even the smallest tacit support for or willingness to consider alternatives tht might have a better outcome for the wider community.
Whilst our wildlife organisations may have started with good intentions what is clear is that many people associated with these organisations simply don't understand the mechanisms of the Somerset Levels, the impact of what they propose (The Severn Vision) and in most cases don't care if it doesn't suit their agenda. They fail to consider that ultimately the economy pays for everything and destroying local economies will ultimately call into question the viability of protecting our environment; the ratepayer maintains the roads used to get to our wildlife sites and will pay or make a significant financial contribution to the cost to the current planned defences and the their subsequent replacements. A case of shooting the goose that lays the Golden Egg of in this case chasing away industry and people.
It is clear that many organisations support the existing proposals to turn the Parrett Estuary into a saltmarsh. The decision by SDC and the EA not to commission an economic impact assessment has allowed those organisations and the Environment Agency to create the worst possible long term economic future as there is no assessment mechanism other than the government investment rules to measure the value of this scheme. Allowing the undermining Somerset's agricultural industry, wasteful development and not working towards an integrated low energy society is not what we should be doing.
Bridgwater Tidal Barrier Final Public Consultation
Ahead of the forthcoming last public consultation on the Bridgwater Tidal Barrier (BTB) the rate and tax payers might consider asking what becomes of Bridgwater after the BTB reaches the end of its design life?
The answer is simple.
if there is no barrier capable of keeping the rising sea out there will be no house insurance, no mortgages and Bridgwater the town will not be a viable place to live.
Our present proposed EA flood defence scheme is based on retreating as far back from the sea as we can, it deliberately puts our backs to the wall On one side of the barrier we will ultimately have the inter tidal habitat (the sea) and on the other our housing and industry.
No space is being provided behind the proposed barrier to create another bigger one. As a consequence there will be nowhere to go with a replacement that does not have a huge and unnecessary price tag. There is an irony that land at Chilton Trinity returned to the sea under the present scheme and the planned managed realignment in 2055 will be inadvertently reclaimed under a downstream replacement barrier albeit land now poisoned with salt.
With sea level rise continuing for hundreds of years past the design life of the BTB one would expect that as responsible people we would give some consideration to what happens next. Unfortunately, like so many things in need of fixing and investment we seem content to kick the problem into future refusing even to consider how we might make some provision to help those that follow us.
Many years an Arup engineer called Poul Beckmann wrote the opening sentence of a document with the line "Human nature is that we put off until tomorrow what we should do today". Never has that been more true today than in Somerset. Somerset's failure to develop a realistic, affordable and sustainable long-term strategy is unforgivable. It really is time for some of the promises made by our political leadership on this issue to be delivered and people stop making excuses why things cannot be done. Simply working our way through the Somerset 20 years plan and saying the future is not our business is irresponsible and unacceptable.
The SRA was asked "What is the SRA and its partners working assumption for the replacement of the existing scheme and barrier?
The written answer received from the SRA answer is in blue
From day one, the tidal barrier will be designed in such a way that it will still provide a 1 in 1,000-year standard of protection in 2125. The design includes an allowance for climate change up to 2125.
Climate change does not stop in 2125!!!!
1:1,000 sounds good but its just the margin on the starting point and degrades over time. The Dutch use 1;10,000 and maintain it as the level of protection.
The downstream defences will be designed in such a way that they will still provide a 1 in 200-year standard of protection in 2055, with allowance for further adaption for climate change over time.
2055 is important because this is the date from which managed realignment is implemented under Policy 7d39 of the Shoreline Management Plan.
EA explaining the scheme in 2017
It is to be expected that any piece of infrastructure would need updating after 100 years. We cannot decide now how future generations may wish to live or what their priorities for infrastructure will need to be. This is why, for example, there are plans for the Thames Barrier to be re-built in future decades but decisions on exactly where and what will be required are deliberately being left for later.
Building the barrier in the town as planned does not give those in the future choices but leaves them no choice to but to go downstream and use land we have previously given back to the sea and to abandon the £100M investment the present scheme will have cost.
The response attempts to conflate the need to replace the 1970's Thames Barrier as a reason not to make provision today for a replacement in Somerset. if you know you have to replace something why would you not plan for the replacement? Its an excuse.
We should be learning the lessons of the past rather than making a virtue of repeating the failures that the SRA reply implies.
The Thames Barrier Myth
The continual portrayal Thames Barrier shown on TV as an iconic single barrier solution is misleading; the barrier is actually part of the Thames Estuary flood defence system comprising not one but eight individual tidal barriers that all shut together. Five of the eight barriers are closer to Bridgwater's situation than the "Thames Barrier". They are however where they should be at the mouth of the rivers they defend not 5 miles upstream as with Bridgwater's Tidal Barrier.
Thames Estuary Flood Defence
Using the Thames Barrier as an excuse for not planning a replacement in Somerset is particularly disingenuous for a number of reasons.
Nearly 60 years ago when the Thames Barrier was designed climate change was not understood as it is now. There was little provision for sea level rise just the post Ice Age tilt of the south of England to consider.
The Thames Barrier is upstream of what were active docks that had navigation rights in the Thames Estuary.
In Somerset we have a topography in the form of the Polden Hills, Pawlett Hill and Stockland Bristol that we can link and use to our advantage. London does not have such a luxury.
All the Thames Barrier replacement options move the replacement barrier downstream perhaps as far as Tilbury. (July 2016 update)
The most frequent use of the Thames Barrier is now the management of fluvial flood water rather than tidal surge. Something Bridgwater is not designed to do.
Sedgemoor District Council is able to reserve space for a bridge over the Parrett south of Dunball should its not be doing the same for a replacement barrier?
The collective response is No ; there is no plan.
The SRA, EA and SDC were conformed as having contributed to the response
Bridgwater Tidal Barrier; the Questions the public need to Ask
Once the question "how will the proposed Bridgwater Tidal Barrier be replaced?" the present scheme simply looks out of date and poor value for money.
The Bridgwater Tidal Barrier is repeating the same mistake as was made with the Thames Barrier system setting it as far upstream as possible. Because of the selected location a replacement would like the Thames Barrier have to go downstream towards Combwich. Confused? We should be.
When you go to public consultation some questions worth asking;
How will the proposed Bridgwater Tidal Barrier be replaced?"
What becomes of Bridgwater after sea level rise exceeds the design basis of the Bridgwater Tidal Barrier?
Why is there no long-term plan or vision for what comes next?
Why is the ratepayer required to provide money to raise river banks money protecting land at Chilton Trinity when the planned sea water flooding will make it of no economic value?
Why is not improving fluvial flow in the river system part of the scheme?
Why did the cost of the scheme almost double after the location was decided on?
Sustainable Flood Defence
The UK has a serious problem with leadership and sustainable construction where flood defence is concerned. There is a profound lack of critical thinking in the delivery of future UK flood defences and an unwillingness by agencies to get their hands dirty at a local level. As a consequence government continues to fail regarding sustainability and value for money; taxpayer funded agencies seem unable or unwilling to work together. It is a situation compounded by wildlife and environmental organisations who have seen an opportunity to gain control of and modify land in much the same way that monasteries such as Glastonbury once did.
Flood defence schemes are invariably seen in terms of a definable project that can be closed rather than the first step of a sustainable long term solution. The protected community needs to live with and manage these schemes for 100's of years after they are built. Our thinking on delivery is just too short and too expensive when it is a 300 year or so problem and especially when the initial solution only has a 100 year design life; it makes little sense. There is an obvious gap. That gap means that today's options should at least consider what happens next. Should we really be adopting a solution today requiring the construction of a replacement barrier tomorrow rather than a scheme today that has provision or a plan for extending it already built in? Our current scheme takes planned obsolescence to a new level.
We should not be closing out future options for the generations that follow and we should follow our own rules for sustainable development
"Sustainable development is development that meets the needs of the present, without compromising the ability of future generations to meet their own needs."
Delivery of the Bridgwater Tidal Barrier continues to be an exemplar of non-sustainable thinking. Part of the scheme requires the river banks between the tidal barrier and the village of Combwich to be maintained. The EA's plan to do this work as part of the barrier construction contract. Material is to be dug from the adjacent protected fields and where a future Northern Bridgwater Bypass might be routed. Sedgemoor District Council (SDC) have protected in the Local Plan a potential crossing point on the River Parrett just south of the A38 roundabout at Dunball.
Clearly excavating Chilton Trinity's fields and creating a series of salt water pits that creates an ideal future breeding ground for salt marsh breeding mosquito's is not what people have considered the consequence to be. It is far from impossible that in a generation Chilton Trinity and Combwich may ultimately become uninhabitable because of this excavation process rather than from the increased flood risk. Managing mosquito borne diseases may well become the larger challenge in low lying areas as our climate warms up. It is difficult to see how the EA could contemplate the creation of such a situation.
With whole life costs of the Bridgwater Tidal Barrier reaching £100M for a barrier, secondary banks and the raised river banks; banks that need continual raising means we need to consider modification of the delivery model to get the costs of this project under control.
That whole life cost also ignores the 100 year economic impact, both locally and nationally, of losing 1000's of acres of productive agricultural land notwithstanding the questionable morality of a food importing country choosing to export more of its food production offshore.
If we are going to build the solution we have we need better and more economic delivery solutions than is currently proposed. We can then at least ameliorate the present situation with a better delivery system.
Brexit allows the modification of the EU water and waste directives that have now been written into UK law. We can now change the way in which we manage waste for the better.
Every year Sedgemoor will build 5-600 houses and the excavation of foundations and drains for each of these houses will create around 15-20m3 of waste material (clay) suitable for re use as bank raising fill material. Sedgemoor's planned housing developments will create around 9,000m3 per year that currently must be paid for to be disposed of. Housing developers could supply all the material needed to raise the banks. That is sustainable construction.
Over the 100 years life of the barrier there could be as much as 900,000 m3 of material we need to find a home for; material that could be used to build up the banks and preserve the land we have at Chilton Trinity for future generations. Even if the volume is only 10% of the possible amount its probably enough to avoid digging up land at Chilton Trinity.
Under present EA proposals the EA is going to pay landowners for material that other organisations with similar material must pay to dispose of. We are meant to be reducing this sort of activity not making the situation worse.
We simply don't need to get all the work in place in 2024; we need just enough to maintain the flood defence need and then use local resources to progressively deliver the longer-term solution with a local benefit to the economy. This work could be collectively done by local contractors under the supervision of either the EA or the Drainage Board. There is simply no engineering need for the EA to wantonly and unnecessarily destroy our landscape when cheaper and more sustainable alternatives are available.
NB there is only an intent to continue to raise the river banks
To put this into perspective that recycled material would
build a bank 5m high bank from the Bridgwater Tidal Barrier to Combwich.
raise the banks and build the secondary flood defences up to match climate change.
raise the banks, build the secondary flood defence and start building new defences north from Pawlett Hill towards Highbridge.
5m high and nearly 5 miles long, 100 years of digging house foundations
Sea level rise is not expected to slow for at least 300 years making both the barrier redundant as the river banks can only be raised perhaps another metre before they overload the poor ground conditions of the Parrett Estuary. Ultimately the long term plan for Chilton Trinity and Pawlett Hams's will be realised.
The continued conditioning of the population by the EA to passively accept surrender to the sea as the first option for non-London areas of the UK is disingenuous and defeatist and never mind its land we need to grow food on.
At £100M the present solution for the Bridgwater Tidal barrier is clearly neither sustainable or affordable. A situation that needs to be laid at the door of the Government, Somerset Rivers Authority and specifically the EA and Sedgemoor District Council (SDC) who provide joint project oversight. We need
Sustainability in what we do is placed at the centre of our plans
An independent inquiry into how flood defence is being delivered in Somerset.
A peer review of the BTB project into how it has arrived where it has.
Build the Bridgwater Tidal Barrier at Combwich
The option of building the Bridgwater Tidal Barrier at Combwich was always affordable and as we now see the full whole life cost of the present scheme being made public its clear the best location was never considered.
Why Combwich?
Combwich would be a conventional location for a tidal barrier as its near the mouth of the River Parrett. Combwich is a unique site that would offer Somerset a long term solution to protecting the southern Levels as a barrier and associated embankment would close the narrow gap between Stockland Bristol and the Polden Hills via Pawlett Hill. The location also offers an appreciable increase in the fluvial conveyance capacity of the existing River Parrett catchment river system.
COMBWICH & BRIDGWATER TIDAL BARRIER LOCATIONS
Original image is courtesy of the British Geological Society.
The yellow colour in the above image is the soft clay deposited around 11,000 years ago. The existing river banks will see the new flood defences from Combwich up to the site of the proposed Bridgwater Tidal Barrier built on this soft material that is up to 20m deep. Defences that due to settlement will need to be built back up every 30-35 years defending land that will have been flooded with saltwater.
The argument is that it's the cheapest solution where it is in Bridgwater.
People continue to believe the width of the river and the length of the barrier structure is the only driving cost of the scheme. Whilst size does matter it is not all that matters. Like most schemes that start without a clear direction the final cost proves to be significantly more expensive than expected and the Bridgwater Tidal Barrier is no exception. The EA project team didn't understand its costs just its objective. They are not the same and nor are they aligned with securing Somerset's long term future.
Most people are aware that present scheme originated from a 2009 scheme that was little more than a knee jerk reaction to climate change and the long-standing need for a control system in the river. What we have seen is that inexperience in project delivery saw the early focus on one element of the scheme rather than the scheme as a whole. Effort was exclusively focused on the barrier, the type of gate and location within a short length of the River Parrett and it clouded objective thinking about an holistic scheme. It was so bad that the EA team doing the barrier were unaware of the test bank being done by the EA and Team Van Oord; there was simply no joined up thinking.
Nobody at that time or since has been willing to stand back and take a cold hard look at what was needed when the Cameron Government's political promise of post 2014 flood money removed critical thinking from the delivery process.
The simple fact is that every activity has a cost and the choice the client and the designer has is where you spend the money today and tomorrow. A simple comparison of where our money will be spent is produced below. You can spend money on lawyers and land agreements for secondary flood defences or spend the money on a better barrier. Paper does not keep the sea out.
Combwich offers a number of advantages that offset the barriers extra length and the constraints of the present location in Bridgwater. These advantages include the use of precast concrete construction, the availability of space for construction, no need for an expensive diversion channel and the long periods when the river is empty make considerable cost savings.
The key savings are given below.
Where the barrier money goes
a barrier structure could also support a future bypass.
Barrier and replacement Dunball Wharf at Combwich
The good thing about the River Parrett and there are very few is that its possible to work on the river bed without the need for a coffer dam. If you have the space and you're in the infrequently used navigation channel of the Parrett you move and do things in the water during high tide and then drive down the bank onto a prepared river bed. and work during low tide.
Bridgwater Tidal Barrier Cost; an unacceptable defence
The January 2018 news that the estimated cost of the Bridgwater Tidal Barrier (BTB) had reached £100M caused the BBC last week to interview stakeholders at the EA, Sedgemoor and Bridgwater Town Council. Anyone who heard the interviews and knows anything of the history of this project will be as equally concerned as Bridgwater's Town Council. The risk regarding withdrawal of funding is real; Government will not accept being led on and neither should the ratepayer which is becoming the real story of the Bridgwater Tidal Barrier.
EA and SDC interviews.
The EA chose somewhat disingenuously to blame the hike in price on the Government making a perfectly normal and responsible demand regarding cost information. Information not previously provided to the SDC ratepayer. It was clear during the public consultations (the boards are still available on the SDC website) that the selection method (river width) was flawed in ignoring the cost of the downstream works and the associated maintenance costs that went with them. Cost confusion about this project has been a problem ever since work started on developing options and presenting the options to the public. Previous written responses raised this issue in March 2016 and nothing was done to clarify the situation in subsequent public consultations.
The well known poor ground conditions of the Parrett Estuary were again blamed. Ground conditions have become a convenient hook to hang cost increases on. If the costs associated with ground conditions are being continually underestimated at such a late date there is clearly a management issue that needs to be fixed.
SDC again conflated Cameron's "never again "statement made in 2014 with the Bridgwater Tidal Barrier. People will continue to imagine that the Bridgwater Tidal Barrier will somehow mitigate a 2014 flood when that isn't the case.
Readers can listen to the program on BBC iPlayer for a few weeks. Move the bar along to hear the EA at 40min and SDC is around 140min
The defence of the cost is indefensible.
The reality is that neither the EA's technical management team, those responsible for providing senior project management/Governance (EA/SDC) or the councillors providing oversight have the necessary experience for a project like this. (£29M was beyond their reach and £100M is farther still and requires experienced management). The BTB was always going to get away from under them as it clearly has.
As a contributor to the EFRA Future Flood Prevention report in 2016 I highlighted the issues that are deeply embedded in this project. Entitled Managing local UK infrastructure; the Client Deficit. it highlighted the lack of an independent adviser to stakeholders as a continuing problem with UK locally managed infrastructure projects, it is a situation repeated elsewhere and in Somerset the SRA is a particularly good example of people being responsible for delivering projects that they are not experienced or qualified to do and not being provided with the support they need. The KSD expansion project seems to be struggling in a similar way to the BTB. Googling ones mobile phone is not a valid substitute for experience nor is having laid a patio in earlier years.
We all now understand that the Bridgwater Tidal Barrier solution (location) was driven solely by the promoted idea that "river width" somehow equated directly to project cost; getting the barrier as far upstream (narrowest point) was the cheapest option for the EA. it was always a flawed strategy and the cost we are now seeing is the result of that approach. It is the result of not doing work that should have been done during the options study. The initial cost of the downstream raising of the river banks and the cost associated with the intent to continue to do so does not appear to have been fully considered in the original location decision.
Unfortunately, valuable and costly time was spent on what sort of gate we should have had rather than looking at the overall solution and there was no challenge to the 2009 B&V spread of locations. Long term costs and the EA's rather ambiguous position regarding the long term raising of the river banks were conveniently ignored in the 2016 public consultations. Consultations that completely ignored the principles set out in Government guidelines on public consultations.
This situation was compounded by the obvious client project inexperience shown in the rush to engineering studies before an outline plan was agreed that always results in the cost escalation we are seeing. The sudden arrival of the secondary flood defences is something that should have been highlighted in the option studies, it may not have been needed at sites farther downstream and was not shown in the early public consultations. After 30 years of managing the design process on much larger projects than the BTB starting a project without a real plan is always a trap waiting for the unwary. Sadly, as a result of the BTB execution strategy what we now have is less normal project delivery and more an episode of Grand Designs. At least the consultants should avoid any blame.
What was striking in last week's radio interview was the lack of any new arguments after all the work that has apparently been done to support the scheme in its present form. What is equally impressive is that both the EA and SDC imagine that Bridgwater will not want to grow beyond the line of the barrier over the next 100 years or that a critical piece of infrastructure should be located so close to the town. Shouldn't someone have asked how big will Bridgwater be in 100 years? The whole BTB project appears to have now deteriorated to the justification of an original poor decision. It is most disappointing.
The information the ratepayer has seen to date raises questions of transparency or competency neither of which seems to have been achieved or available to any degree.
Ratepayers should not be paying for all the people involved in the BTB project and the broader Somerset Flooding issues to be learning on the job which seems to be the case.
Its well past the time that the Bridgwater Tidal Barrier including its location is independently reviewed before it is presented to the ratepayer one last time. Its time we considered moving the Bridgwater Tidal Barrier downstream to Combwich.
The questions of
transparency with regard to cost and economic impact.
management team competency
oversight competency and relevant experience
the approved barrier location
what happens at the end of the 100 year design life; Bridgwater Tidal Barrier 2?
clearly needs to be looked at as the information previously provided to the public and one assumes our councillors did not reach the standards we should expect and was wrong.
Projects do not suddenly almost double in price in 15 months without good reason. The defence of the cost increase presented in the interviews was as unacceptable as the scheme itself has now become.
Bridgwater Tidal Barrier cost reaches £100M
Sedgemoor District Council and the Environment Agency recently reported at the Somerset Rivers Authority (SRA) meeting in January a 50% increase in the cost of the Bridgwater Tidal Barrier. The reported cost appears to have increased from £70M in October 2017 to £100M in January 2018 (five months) and yet it went through without comment .
The cost escalation of a scheme that does nothing to address the 2014 fluvial flood is eye watering and yet, according to the minutes, no action is taken to explain why this escalation had occurred and what action was being done to mitigate it. The mere acceptance by our elected members is not acceptable if the delivery of our infrastructure is to be managed locally rather than through central government.
Bridgwater Tidal Barrier Cost History
March 2014 the cost of barrier was reported at £26M
September 2016 The EA gave the public figures during a public consultation various options with costs; site 5 the selected site was costed at £45M – £60M.
October 2017 the BBC reported on the cost of the scheme to be in the order of £70M "Bridgwater tidal barrier costs 'could go up by £10m"
January 2018 indicates the cost is now around £100M as noted below from the published SRA draft minutes.
In a period of around 15 months from September 2016 to January 2018 the cost of the Bridgwater Tidal Barrier scheme rose by around £50M or 100% and not one word of concern is expressed or recorded in the public domain. This cost is now nearly 4x the original cost estimate in 2014.
Bridgwater Tidal Barrier is now a £100M scheme where
the financial investment makes no contribution to mitigating a repeating 2014 fluvial flood,
repeated saltwater flooding onto farm land from the River Parrett is seen as being an acceptable regime despite poisoning farmland and wildlife.
there is no plan in place beyond the barriers 100 year design life
brings saltwater onto our agricultural land
Looking at the numbers the only thing that can be concluded is that the cost estimates presented to the public and to councils for the purpose of decision making were widely inaccurate or inconsistent either of which is unacceptable for investment decisions; especially decisions that affect the long term future of Bridgwater and Somerset Levels beyond.
The selection decision of the current site (Site 5) was chosen purely on the basis of the width of the river and must now be called into question. It would appear that the cost of the other downstream elements of the scheme must be causing this cost escalation. A cost and concern that were dismissed at the time of the consultation.
the EA wants to dig up the very land its meant to be protecting to win the soil for flood defences.
No project should be seeing this amount of budgetary increase without challenge. Cost escalation on this scale is unacceptable and unnecessary. There is clearly a continuing problem regarding a lack of oversight both technically and financially in this project.
What should be done?
The extra £50M buys a much better scheme than the one Bridgwater is getting. £100M would allow
the barrier to be located as is normal practice as close to the mouth of the river as possible which in this case is Combwich. Combwich was never looked on the basis of cost, clearly that is an argument that can no longer be supported.
elimination of most of the downstream river works that the EA's tests indicate will need to happen every 35 years or so.
increased fluvial capacity in the River Parrett and the King Sedgmoor Drain potentially benefiting communities beyond Sedgemoor
a solution that can be economically extended beyond the 100 year design life currently offered.
£100M is £1M a year for next 100 years on scheme that will be rendered redundant once the river banks can no longer be raised to combat sea level rise; the scheme in present form is throwing money away
The public expect that those on scrutiny committees to use there position to bring transparency and accountability to the process of public expenditure. Such bringing to account appears to be sadly lacking together with visibility of any independent engineering review that a project of £100M warrants. The project is growing in value and the oversight is not growing with it.
Unfortunately what we see happening is the management of infrastructure projects by people, primarily councillors and officers who are unqualified to do so. The SRA is a prime example of an organisation primarily engaged in the commissioning of engineering activities with no engineers in lead roles. The Bridgwater Tidal Barrier has become a Grand Designs episode of Civil Engineering
A Public Inquiry into the management of the Bridgwater Tidal Barrier scheme should be convened that should look at
Location (including the examination of Combwich)
Competency and experience of councillors and officials to manage civil engineering works such as the Bridgwater Tidal Barrier and other SRA projects.,
Bridgwater will only get half a barrier despite Funding not Ringfenced
Sedgemoor 2050 Transport Investment Strategy- what climate emergency?
UK Construction; the coming change is not what people imagine


Are you ready for SUPERFIGHT presented by GoDaddy?
TONIGHT — night live from Philadelphia's 2300 Arena — Major League Wrestling presents a live beIN SPORTS network broadcast featuring two world championship title fights.
The live card from the 2300 arena has a bell time of 7:30 p.m. The live beIN broadcast begins at 8 p.m. ET on beIN SPORTS.
You can see a full list of matches for Saturday's card here. The card is an MLW FUSION TV taping, as well, so bring your signs!
VERY limited tickets are available digitally at www.MLWgo.com and may be purchased at the 2300 Arena box office while available. Be advised: this card is tracking to sell out. MLW encourages purchasing tickets while available.
Major League Wrestling shows are interactive. Fans get to not only experience major league action in the ring but have the opportunity to meet some of their favorites before bell time.
Additionally, there is a private VIP Meet and Greet for $80 ringside ticket holders (SOLD OUT) which includes early entry (6 p.m.). This meet and greet has extended meet and greet privileges.
The world of MLW never stops. See you at the historic 2300 Arena for SUPERFIGHT presented by GoDaddy!


text:
S. Meyers
M. Zeidel
K. Das
H. Janowitz
G. Apodaca
Assessing quality of life.
The Mount Sinai journal of medicine, New York
Disruption of bladder epithelium barrier function after spinal cord injury.
G. Apodaca, Susanna Kiss, W. Ruiz, S. Meyers, M. Zeidel, L. Birder
American journal of physiology. Renal physiology
Neural-epithelial interactions are hypothesized to play an important role in bladder function. We determined whether spinal cord injury (SCI) altered several indicators of urinary bladder epithelium… Expand
Treatment of Clostridium difficile infection.
Role of membrane proteins in permeability barrier function: uroplakin ablation elevates urothelial permeability.
P. Hu, S. Meyers, +4 authors T. Sun
Although water, small nonelectrolytes, and gases are freely permeable through most biological membranes, apical membranes of certain barrier epithelia exhibit extremely low permeabilities to these… Expand
Qualitative and quantitative differences and patterns of variability in disfluencies emitted by preschool stutterers and nonstutterers during dyadic conversations
Abstract Disfluencies produced by 24 young stuttering and nonstuttering boys (4 to 5 years old) interacting in three dyadic sessions were analyzed. Each child interacted with his own mother, an… Expand
Lessons learned from the "It Takes a Valley" program: recruitng and retaining future teachers to serve high-needs schools
A. Strage, S. Meyers, J. Norris
Olsalazine sodium in the treatment of ulcerative colitis among patients intolerant of sulfasalazine. A prospective, randomized, placebo-controlled, double-blind, dose-ranging clinical trial.
S. Meyers, D. Sachar, D. Present, H. Janowitz
Sixty-six outpatients with active ulcerative colitis who were intolerant of sulfasalazine were treated in a double-blind randomized trial. They received placebo or olsalazine sodium in daily doses of… Expand
Colchicine therapy of the renal amyloidosis of ulcerative colitis.
S. Meyers, H. Janowitz, +4 authors S. Dickman
Two patients with severe proteinuria, due to renal amyloidosis complicating chronic ulcerative colitis, improved remarkably with colchicine therapy. One patient with an initial daily urine protein… Expand
Fecal alpha 1-antitrypsin measurement: an indicator of Crohn's disease activity.
S. Meyers, A. Wolke, S. Field, E. Feuer, J. W. Johnson, H. Janowitz
Random fecal alpha 1-antitrypsin levels were determined in 34 patients, 24 with Crohn's disease, and 10 "controls" having diarrheal illnesses not associated with intestinal protein loss, in an effort… Expand
Prediction of child abuse in an ambulatory setting.
N. Rosenberg, S. Meyers, N. Shackleton
Medicine, Psychology
A prospective random study was performed on 476 patients, up to 2 years of age, by full-time registered nurses in the emergency room. The parent (caretaker) and child were assessed in an effort to… Expand

redpajama_set_name: RedPajamaCommonCrawl


Fair's Nursery, located at 9340 Fair Way, has been in Maple Grove for more than 50 years. Starting out as a vegetable market at the corner of 93rd Avenue N. and Jefferson Highway, Fair's has evolved into a full-service garden center, greenhouse and floral/gift shop.
Bud Fair established the business in the early 1950's. He sold it to his son Mike Fair in the 1970's, who sold it to the present owners Mark Hasse and Phil Phenow in 2000. "We strive to maintain the professionalism and customer service that is Fair's," Phenow said.
Fair's continues to sell just about everything people need to enhance their outdoor living spaces. The garden center provides annuals, perennials, water plants, lawn care products, sod, bulk rock and mulch. Fair's Nursery has a variety of trees and shrubs, many grown at its tree farm in Monticello and delivered to the store.
Additionally, Fair's has a commercial-landscape department run by Mark Hasse, co-owner.
Fair's Nursery, Garden Center and Floral is open year round, with slightly shorter hours in the winter months. Summer hours are 8 a.m. to 8 p.m., Monday through Friday; 8 a.m. to 5 p.m., Saturday and 10 a.m. to 5 p.m., Sunday. For more information, call 763-425-4212.


This is the total opposite of my experiences in Poland.
I have been to Warsaw and Krakow and everywhere I was given the choice to decline DCC.
From taxis to shops and restaurants, even ATMs (avoided Euronet). Only in some smaller shops the merchants were confused about the DCC prompt but that could be resolved quickly.
With contactless? Contactless seems to be the issue here.
Just say you spoke to them but didn't speak the language well enough to resolve it with them, or that they weren't knowledgeable about how to refund it.
not least as it is often printed on the receipt that the card holder consented to DCC.
Just say that it was consented to after they took the card machine? Revolut is clever enough to know that this kind of thing happens.
Don't Gibraltar use some weird currency that is pegged at GBP level?
Gibraltar uses GBP, the same as the UK. But their banknotes are different (as in Scotland, Northern Ireland, Jersey, Guernsey and the Isle of Man). Gibraltar's banknotes are represented in the wholesale banknote trading markets as GIP, but Gibraltar's currency is GBP. GBP and GIP are not pegged, but the same currency, just different physical representations of it. Some ATMs in Gibraltar offer a choice of GBP and GIP, and some banks in the UK accept deposits of GIP, particularly if they have a branch in Gibraltar.
So basically this means, never return the pin pad before the transaction is completed and it starts printing the slip. This is the only possibility to avoid the merchant interfering with the transaction and answering the DCC prompts.
Next day while browsing the Revolut app I saw I had a GBP transaction. I looked at the card slip and yes, there was a notice of DCC.
You get a push notification when you pay something. You should see it right away if something strange happens.
I learned my lesson! Just after this incident, I enabled push notifications.
Until Revolut finally implement an option to block GBP, would it not be possible to get around the problem of these unscrupulous waiters if having entered your PIN, you keep hold of the terminal after the message appears instructing you to return it, press the green button again if necessary, and then you can make sure that you select EUR for any DCC option that appears before handing the terminal back?
would it not be possible to get around the problem of these unscrupulous waiters if having entered your PIN, you keep hold of the terminal after the message appears instructing you to return it, press the green button again if necessary, and then you can make sure that you select EUR for any DCC option that appears before handing the terminal back?
Not always. In some cases, as reported above in Poland, the amount is converted to GBP without any option having been selected to do so during the transaction process, either by the card holder or by the merchant.
On a recent trip to Madrid (where DCC is rife) I found contactless the easiest way of avoiding DCC. Most contactless terminals offer DCC after tapping the card, but it was easy to just hit the (red couloured) EUR icon on the display. For larger transactions over €30 I just used Apple Pay, linked to a 0% commission Visa card. Interestingly the incidence of DCC prompts was less using Apple Pay.
The benefit of contactless over entering the PIN is that it gives the merchant less opportunity to intervene in the transaction as the DCC prompt is almost immediate after the card or iPhone is tapped on the terminal and it just a case of quickly pressing the EUR key.
The one time I did use the PIN was on a transaction for €100, and this is what happened. I entered the PIN to approve the €100 shown on the display, the terminal then both displayed and printed the DCC "offer" at which point the merchant went to hit F4 - GBP, I quickly blocked his hand by putting my hand over the terminal and said in Spanish that I did not want to pay in GBP. He then got irate and said he would get more bank charges if it went through in EUR. I said this was nonsense and that the currency of Spain is not GBP. The merchant then demanded €2 in cash to allow the transaction to go through in EUR. As my hand was nearer the F1 key than his, I quickly hit F1 and the transaction finally went through in EUR. Sure he was pissed off, but so was I, big time. These people know full well that DCC is a money making scam.
That is outrageous! Thanks @MattW93 for sharing your story and well done for handling it so well. I'm delighted to hear that you stood your ground against a disingenuous merchant who understood DCC very well and tried to force it upon you.
Having this issue also in Brazil with the only merchant that works, Celo.
I've just got back from three weeks in Brazil and I didn't have any problems with DCC. It was rarely offered, and on the occasions that it was, there was no problem selecting BRL. Can you please explain what happened?
I think it is generally not allowed to block certain conversions and / or DCC after the transaction is authorized. The Seller has an "guarantee" that the payment goes through. If you could cancel it somehow after authorization no one would accept cards anymore, because of the high risk.
Isn't it illegal to charge for card transactions within the EEA? I know it is in the UK but I thought this was EU Directive material, meaning it should be enforced in Spain too.
@Recchan, you're absolutely correct. The legislation is Article 62(2) of the Directive (EU) 2015/2366 on payment services in the internal market (PSD2). Directives are not law, and are enacted into each member state's national law, for example in the United Kingdom under Regulation 6A(1) of the Consumer Rights (Payment Surcharges) Regulations 2012. The legislation took effect from 13th January 2018.
I think it is generally not allowed to block certain conversions and / or DCC after the transaction is authorized. The Seller has an "guarantee" that the payment goes through.
Isn't an authorisation valid only for the specified amount? Otherwise a merchant could request an authorisation for €0.10 and then charge €10,000.
Before anyone gives the example of TfL, which requests an authorisation for £0.10 at the beginning of the journey and subsequently charges a lot more at the end of the day, I believe that in this case, TfL's authorisation is just to check that the card is valid, not that it is capable of being charged the total amount that might accrue by the end of the day.
I'm not sure. In the USA you get an amount charged but a few days later you get another charge with an higher amount because the tip (base bill plus tip) gets handled differently. Not sure if that is related, though.
Didn't another user here wrote something like "I authorized an amount in currency x in the pos terminal but later I saw that I got charged in currency y."?
Maybe it also depends on the kind of authorization. Chip and PIN, contactless or magnetic.
I saw a nice advise for avoiding DCC - try to use contactless. If you do that, you usually see the terminal an can select the currency yourself. At least that's what I heard so far.


Ready to Jump up and rejoice before our Lord? If upbeat and uplifting Praise and Worship is more your style, this is the service for you! Join us Sunday Morning's at 9:00 AM for our Contemporary Service and sing songs like Matt Maher's "All the people say Amen", Chris Tomlin's "Set Free", Hillsong United's "I Surrender" and Michael W. Smith, "New Hallelujah" & "Mighty to Save". Come sing along with Worship Leader, Matt Bierner and the Praise Team! We're saving you a seat!
Choir Director, Allene Cadwallader leads the choir every Sunday morning during this service. Our Worship Service follows the rich tradition of Christian worship with focus on prayers and scriptural reading. We rejoice before our Lord as the choir lifts our spirits and leads the church in worship with traditional songs straight out of the Methodist Hymnal. Praise the Lord while singing songs like "Sweet, Sweet Spirit", "Crown Him with Many Crowns", and "Onward Christian Soldiers". Come on down and join us this week. We'll be here waiting.
Our Bell Choir appears for Special Performances throughout the year. The beautiful tones of the Bells leaves your heart warm and opened to receive the blessings of Jesus Christ.
Our praise team will get you up out of your seat and fill you with the Holy Spirit!
This is a time when children ages 7-18 can come together to learn how to read music and sing in a loving group atmosphere.
Our children are our legacy. They're constantly reaching for the future and are most likely to live up to what you believe of them. Believe in your children like God believes in YOU! Show our children the way, the truth and the light! Children are the living message we send to a time we will not see. Let THIS generation be the ones to carry on our God and share the truth with others like no one has before!
Our youth at First UMC Belen are a vital part of Summer Vacation Bible School and Sunday Children's Church. They assist the elementary age children with things like Arts and Crafts, Games, and music as our youth leaders.
Special events are held throughout the year. We have gone on summer camping trips,, skiing, Summerfest, Youth Retreats and so much more! We've gone on special Mission trips where we share the Word of God and ourselves in the service. Some of our past trips have been to inner city Los Angeles, Puerto Rico, El Paso and to the Navajo Nation!
To help defray the cost of our camps and Missions Trips, We hold fund raisers throughout the year. We do car washes, yard sales, pancake breakfasts and more! We'll announce our next fundraiser soon!


text:
Gravity Payments CEO Dan Price of Seattle cuts his salary to boost company's minimum wage to $70K
While a campaign is underway in B.C. to raise the minimum wage to 15 dollars, a Seattle company is going to pay its employees at least $70,000 a year.
Gravity Payments CEO will make $930,000 less per year
All Points West · CBC News · Posted: Apr 15, 2015 9:50 PM PT | Last Updated: April 16, 2015
Dan Price, CEO of Gravity Payments, announced Monday he will be cutting his $1 million yearly salary to increase his company's minimum wage to $70,000 a year. (Gravity Payments)
Dan Price, the CEO of Gravity Payments, made the announcement on Monday that he will help finance the new minimum wage by cutting his own remuneration from $1 million a year, down to the $70,000 mark.
'Fight for $15' protests focus agenda on low-wage jobs
Canada's minimum-wage workers deserve more money, more respect
B.C. minimum wage to be tied to the province's Consumer Price Index
Price says his goal isn't to make money, but to make a difference.
"I really do view everything I do as a responsibility and seeing growing inequality and how it is harder to just make ends meet and live the normal American dream," said Price. "Things are getting more expensive, especially in a city like Seattle and the wages aren't keeping up."
Price had been planning the change over the past few weeks, but wanted to surprise everyone at the end of the quarter.
"I could see the faces of everyone. Jaws were dropping, people were hugging, high fiving. There was a standing round of applause for him," said Maria Harley, VP of operations at Gravity Payments.
Harley says employees told her how much their new salary would change their lives.
"I've heard things from, 'I can finally afford to move out of my parent's home,' 'I can finally afford to have a baby', we have some people that are parents and really want a good education for their children and feel like they can finally afford that."
Before the announcement, the lowest salary at the company hovered around $34,000 per year.
Harley says raising the company's minimum wage is also going to be good for business.
"We're optimistic about the return on investment. We've already got thousands upon thousands of inquiries of people saying we want to support your business, we want to do business with you," said Harley.
Since the company made the announcement, it has received over 5000 resumes in just one day.
Harley thinks the benefits of increasing compensation outweighs the costs, but every business is different.
"It's definitely a risk and it's one you just have to take a leap on when you are ready."
When is a minimum wage not a minimum wage?


Pirate Isle Slots is a stunning animated 3D slot. It has an amazing array of symbols that you will no doubt enjoy in this Pirate theme-based slot. It has become one of the more popular online slots for US players, and you'll read why in a minute.
Pirate Isle Slots is a progressive slot. It has more bonus features that you can imagine. Included in this slot game are an Extra Bet Button and an Auto Play button. We do recommend you read the pay table as there are countless symbols, payouts, special features, and rules of the game.
One of the features of this slot game is that you need to collect different colored keys that will lead the pirates to treasure. When you collect these keys, they will be placed at the top right corner of the slot game.
The Skeleton Key is wild and substitutes for all other symbols except the two scatter symbols to form winning combinations. During the regular game the Skeleton Key will be grouped on reel 3. The payout is doubled when these keys appear. The other special keys are color coded. When they appear with the Skeleton Key, they will pay out from 1200 coins to 2000 coins, respectively. When all five keys are collected, the free spins round will commence. There are two scatter symbols: The Galleon and the Treasure Chest. These scatters, when appearing in a winning combination, will pay out handsomely. If you get 5 Galleon symbols, you will win 200xs your bet; get 5 Treasure Chests and you will win 150xs your bet. The Treasure Chest symbol will lead you to the Free Spins Round.
Here you can win up to 300 free spins! You will be taken to a second screen where you will be asked to select 5 locations on the map that may contain a Chest, a Map, or a Ghost. Finding a treasure chest will award you another pick. If the lock on the treasure chest matches the Treasure Chest key color, your win is tripled. If you find the map, you will be awarded another round of picks. Up to five rounds can be won. If you find a Pirate Ghost, the feature will end and you will be awarded 100 free spins. If all the treasure keys are active, however, the number of free spins awarded is tripled. The Skeleton Key will appear grouped on reels 2, 3, and 4 during the free spins round. If you get three or more treasure chests, 15 additional free spins will be awarded.
This stunning video of two ships fighting each other at sea is incredible. When you get three or more Galleons, this feature will be triggered. Three ships will be involved: the Pirate ship, the Spanish Treasure Ship, and the Enemy Galleon Ship. You will be taken to a second screen where you will get a chance to fire the cannon until you defeat your opponent ship or five of your opponents have been faced. If you defeat the Spanish Ship, you will continue on to a new level. At the bottom of this screen you will find a scale that ranges from zero to ten. This is called the prize ladder. It starts with three and ends at jackpot. An extra bet of 5xs the bet per line can be played for this feature. Each time you defeat a ship, the multiplier number on the scale will move up.
This is one of the more popular slot games online. The features are amazing, and the interactive showcase is phenomenal. Don't forget, too, that you can win up to 300 free spins playing this game. Join us as we play Pirate Isle Slots at SlotoCash Flash Casino.


On Sept. 2, HHS released a final rule on re-enrollment and annual eligibility redeterminations for health insurance exchanges, simultaneously releasing guidance for issuers on discontinuation and renewal notices.
The rule and guidance were finalized largely as proposed, with a few modifications. The rule finalizes the proposal to give issuers broad flexibility to re-enroll consumers in their plans, including qualified health plans (QHPs), for 2015, without requiring them to re-select a plan or re-determine their eligibility. While issuers will be required to inform consumers about annual premium changes, if consumers take no action, they will generally remain in the same QHP and receive the same 2014 subsidy, as long as the consumer grants the exchange access to their tax return information. The final rule did make one notable change, stating that if a QHP is no longer offered on the exchange, an issuer can no longer automatically re-enroll a consumer in a plan outside the exchange.
HHS estimates that 95 percent of HealthCare.gov enrollees, approximately 5.1 million individuals, will be auto-reenrolled, helping ensure that consumers have continuous care. In addition, the redetermination process helps health plans retain their current books of business. However, an Avalere analysis suggests that many of the plans with high enrollment in 2014 will increase their premiums in 2015. As such, consumers who do not proactively re-select a plan could experience avoidable premium increase if their premiums are significantly higher than they were in 2014. Moreover, consumers who were previously enrolled in a second-lowest-cost silver plan in 2014, the "benchmark" plan, could be automatically re-enrolled in that plan for 2015, even if it is no longer the benchmark. Subsidized exchange enrollees who are re-enrolled in a more expensive plan must pay the difference-dollar for dollar-between the benchmark plan premium and their selection.
With open enrollment about two months away, the exchanges and QHP issuers are preparing to notify enrollees about the open enrollment period, whether their plans are being renewed or discontinued, and any expected coverage changes in 2015. For coverage on the individual exchange, issuers must send written notice of renewal before the first day of the next annual open enrollment period (Nov. 15, 2014). For grandfathered coverage in the individual market, and grandfathered and non-grandfathered coverage in the small group market, issuers must provide each plan sponsor or individual, as applicable, written notice of renewal at least 60 calendar days before the date of the renewal of the coverage.