On 15 February 2021, the New Seafront Promenade Project from Griells to the Pletera, near l'Estartit, in Pals Bay, within the municipal term of Torroella de Montgrí, in BOE-B-2021-7096 drawn up by the company DOPEC, by means of the construction of a new a raised walkway on pillars, running parallel to the coastline which will cross very fragile and threatened dune habitats of great environmental interest.
The Association Save Pals Beach, along with other organisations and private individuals, opposes the construction of this new promenade on account of its high environmental impact, its lack of necessity—since the two areas are already connected by the beach and two further inland paths outside the dunes—and certain economic, legal and ethical considerations.
This article is a summary of the various objections that have been submitted to address it and to highlight the impact it will have on the natural environment, the dune system and its vegetation, which is much needed in the face of rising sea levels and storms, increasingly frequent in Pals Beach Bay.
A Natural Allegation
The project explicitly states in its project objective section the following description:
«The main objective of the project is to carry out the construction of a seafront promenade to link the Griells and La Pletera residential developments, together with the renaturalisation of the Maritime Public Domain (D.P.M.T.) areas currently occupied by the El Molino campsite. The aim is to improve accessibility, tackle encroachments on the DPMT, prioritise pedestrians and bathers, enhance beach services, achieve maximum integration with the natural environment, conserve the beach and promote sustainability.»
The project says: «At present, there is no footpath linking the Griells promenade with the Pletera area, forcing users to walk along the beach outside the fencing of the El Molino campsite, which in turn causes damage to the dune system..» But at present Griells and La Pletera are connected by three routes: first, the sandy beach itself, which is currently little frequented; the Avenue of the Medes Islands, which links Griells and La Pletera directly overland; and, further inland, the Fonda road. A simple adaptation of one of these existing roads that are located away from the beach and the dunes, With a space reserved exclusively for pedestrians, it would make it completely unnecessary to have to build a new promenade over the dunes to be preserved.
one Memory, p. 1.
Dune systems are particularly important for halting sea encroachment and beach erosion in a context of rising sea levels and intense storms..
The primary objective of the multiple protection measures in this area of Pals Bay is to prevent the degradation and disappearance of the dunes and their flora and fauna, a habitat that is currently very exceptional on the peninsular coastline and in the Mediterranean basin, with a High degree of rarity and high degree of threat. To achieve this, effective measures must be adopted to prevent trampling and overcrowding by people and domestic animals, an objective that is clearly at odds with the construction of this new promenade, which is intended to cross the dune habitat.
The project does not include any measures to promote the accretion and stabilisation of the dunes, and the effective delineation of the existing dune systems and the elements intended to delineate them are insufficient to prevent access, which is often promoted by the administration itself. [2, 3] or nearby private businesses, such as the «El Molino» campsite [4].
Specifically, this area is to be delineated with a rope held by a row of cross-posts, which is insufficient to prevent domestic animals that frequent the space without a lead from gaining access, putting endangered species such as the Stachys maritima or the Kentish plover, which uses these dunes to nest at the beginning of summer.
two – «Users of the Griells dog beach in Estartit are calling for more space.». Diari de Girona, 25.8.2019. View PDF.
three «Catalan beaches where you can take your dog without any problems». Nació Digital, 3 September 2020.
4 – The campsite's website does not mention that pets are allowed; however, there are various references on other websites where this information does appear: «Pets allowed» or in this otherCamping Caravaning El Molino is the campsite closest to La Griells beach. It accepts animals on camping pitches. Animals are allowed in bungalows and accommodation.
Natural values
The site where the new seafront promenade is to be built has the highest level of environmental protection: the Natura 2000 Network (N2000), within the Plan of Areas of Natural Interest (PEIN), and the Montgrí Natural Park, the Medes Islands and the Lower Ter (PNMMBT). The Law 15/2010 of the Parliament of Catalonia, approving the creation of the Natural Park [5] requires the approval of a Master Plan for Uses and Management (PRUG) within one year, after the entry into force of the Special Plan for the Protection of the Natural Environment and Landscape (PEPMNP), which was to be approved within a maximum of two years, approval which, after more than ten years, has still not been granted, despite the mandatory requirement laid down by the Law itself. It is these instruments that should establish what kinds of activities may be carried out in the Natural Park and plan the management and uses of the different zones. In the absence of this PRUG and PEPMNP, the provisions relating to the PEIN and XN 2000 apply.
5 – Published in Official Gazette of the Government of the Valencian Community 5642. 3.6.2010.
HIC Priority
In this regard, the impact that the overcrowding of users on this seafront promenade will have on the … has not been adequately quantified.’Priority Community Interest Habitat (PCIH), under the ZEC or LIC code (ZEPA code: ES5120016). This contravenes Article 6 of the Habitats Directive, subsequently developed for better interpretation [6].
six «Management of Natura 2000 sites – provisions of Article 6 of Directive 92/43/EEC on habitats (2019/C 33/01)». Official Journal of the European Union C 33 of 25 January 2019.
The project does not consider the species that we currently find in space, included in the’Annex II of the Habitats Directive, the Catalogue of threatened flora of Catalonia, nor the Wild Species under special protection and the Catalogue of threatened species which will be affected during the execution of the works and, after these, during their operation, nor what the representativeness, presence and behaviour of these species are at the different times of the year. This does not allow the infrastructure design to be adapted, endangering existing fauna and flora, and does not permit adequate planning to reduce the impact on the biota.
No environmental or botanical professional has been hired to verify, plan and oversee operations concerning the site's biota..
Alien species
The project provides for the removal of allochthonous species, adopting a much stricter level of compliance than that set out by the PEIN objectives for this purpose, which restrict it to Invasive Alien Species. Of the three species that the project defines as allochthonous, only one is included in the Spanish Catalogue of Invasive Exotic Species: the American cane (Arundo donax Law 1753).
Although the project provides for hiring site supervision staff and technicians such as surveyors, engineers and architects, No environmental or botanical professional has been hired to supervise the works and prevent them from negatively affecting the protected biota of the site..
On the other hand, the project also does not address the objective of the PEIN (ES5120016 El Montgrí-Les Medes-El Baix Ter, Directorate-General for Territorial Policies [DGPT], Department of Territory and Sustainability) for habitat 2210 Moving dunes of the coastal cordon, which with sand (Ammophila arenaria) they set, among others, the following objectives:
Minimisation of erosion risk.
Location of recreational areas away from the habitat.
Protection of the dune ridge by means of signage or perimeter fencing.
The project does not achieve these objectives during the execution of the works, nor throughout its useful life and the commissioning of the new infrastructure.
The project's layout, which includes walkways, boardwalks, and stairs over the dune cordon, will increase over-visitation of the habitat to be protected, with the arrival of cyclists, runners, pedestrians, domestic animals, as well as other sports and leisure uses, which contradicts the previous objectives of the DGTP.
Coastal regression
The new promenade is located within the shoreline zone, which is affected by flooding and coastal storms. This stretch has suffered a progressive regression of the low-water line between 1946 and 2020. This situation has been particularly damaging for the Griells development, which has already been the subject of several interventions using public funds to repair the defence structures (groynes). [7, 8, 9].
The extension of the breakwater and the placement of the walkway represent an increase in the length affected by storms, which would lead to an increase in reconstruction tasks on an almost annual basis.
This rock revetment has been repaired on several occasions, and with the construction of this promenade further works will need to be carried out periodically, such as reconstructions and extensions of the existing revetment, repairs to the new promenade walkway and sand transvases, which entails an increase in maintenance costs. When dredging and sand replenishment works are required, there is a high risk of affecting the Partially protected seagrass meadows of Cymodocea nodosa Asch. and [10] Posidonia oceanica (L.) Delile [11], located in the infralittoral zone just off the promenade, which may lead to negative changes for species that use the seagrass meadows as shelter and nursery, and indirectly affect fish stocks. The meadows of Posidonia They are the best natural barrier that mitigates the severity of storms, which will become increasingly frequent and violent on Pals Beach as the planet warms.
seven – «They have finished the work to rebuild the Griells Promenade.». El Punt Avui+, 13.1.2016.
Eight – «Emergency work to repair the Griells promenade in the Estartit». Ministry for the Ecological Transition.
nine – «Temporary groyne on the Griells Promenade in Estartit». Diari de Girona, 3 April 2013. (View PDF).
10 – B. Hereu, C. Linares, D. Díaz, J. L. Riera, A. Rodríguez, L. Navarro, E. Aspillaga, M. Canals, D. Amblàs, «Mapping of Cymodocea nodosa meadows in the Gulf of Pals», 2012. University of Barcelona, Girona Department, «la Caixa» Social Work.».
11 – J. Romero, M. Pérez, T. Alcoverro «The Posidonia oceanica seagrass of the Medes Islands: more than thirty years of study».
Breakwater extension
The expansion of the breakwater and the siting of the new footbridge represent an increase in infrastructure within the area affected by storms, which in turn entails additional maintenance and reconstruction work and higher costs to repair the damage caused by these storms, almost on an annual basis., contradicting the PNMMBT Declaration Act Expanding a work that will have to be constantly repaired also goes against the economic sustainability of this infrastructure. This will increase the impacts on the natural space, not only during its initial execution, but in every episode of repair and reconstruction. This will be the case until the inevitable decision of its definitive dismantling, at the end of its useful life.
Lifespan
The project estimates an infrastructure lifespan of 25 years. This is due to the impact of wave action from maritime storms, within the route planned for the works. This has been occurring annually for the last 5 years.
The released energy during the storms due to the impact of waves on the foundation piles and the coastal line recession, estimated at -0.92 m/year for this stretch of the Pals beach., There is no assessment in this project of what this impact will be over the infrastructure's service life. Nor is there any assessment of the impact on the stability of the foundation pillars, which will be buried in sedimentary soils. These soils are mostly composed of medium and fine-grained sands. Furthermore, no provision is made for the cost of repairing this damage. This cost is more than predictable, according to the reports included in the study, as the current upper limit of the new construction is situated twenty metres from the current limit [13].
Thirteen – Orthophotograph from the June 2018 flight, Id. Sheet: 314-94, ICGC. (View PDF).
Cost
There is no forecast of what the annual maintenance cost of this infrastructure will be, nor the cost of its operation. predictable dismantling, and whether this is reversible. The dune/beach dynamics occurring today in this section during the process of dune accretion or regression have not been adequately described. The role played by the floodable part of the backdune, or how economic activities carried out on private property within the maritime-terrestrial foreshore, classified as «old salt marshes,» affect it, or the factors favouring the deflation of the dune front are not evaluated. Therefore, you cannot design a dune preservation scheme unless you study the causes that negatively affect the dune dynamics of this stretch.
On the other hand, according to Chapter 4 of the Manual published by the General Directorate of Coastal Affairs [14], urbanisation processes such as this are a clear impact that has led to the definitive disappearance of our dune systems.
fourteen «Handbook for the Restoration of Coastal Dunes». Chapter VI, General Directorate of Coasts.
Of the areas to be preserved under the project, approximately 431 TP3T of the surface will be covered by walkways, with the consequent impact on the planned vegetation development, which requires solar irradiation and rainfall.
It is quite likely that these structures that are planned to be installed affecting the direction of the flows and the intensity of the wind, at the level near the dune surface and which cause a destabilisation of the wind dynamics of the dunes intended to be conserved.
In a recent doctoral thesis, the dune conservation status of Pals Beach at Griells is assessed, with the area rated as having a high density but tending towards disappearance, despite its recent recovery [15]. It is positive that the project provides for cross-access from the shoreline to the wave-wash zone via defined steps or walkways and by means of fencing to restrict access to degraded dunes, which will as a foreseeable result lead to an improvement in the emergence and development of dune morphologies.
15 – Carla Garcia Lozano, «The dune systems of the Catalan coast: historical evolution, current status and restoration potential.»2019, Doctoral thesis – CC BY-NC-ND 4.0.
Beach hardening
However, the project involves the installation of an opaque surface over the areas where the promenade is planned to be built. This is planned to be constructed with a cover of 1,415.18 m².2. Furthermore, 196 m2 of the crosswalks, over a total of 3,750 m2 dune preservation area.
In other words, of the spaces to be preserved in the project, the 43% surface will be covered by new walkways, with the consequent impact on the development of dune vegetation that requires solar radiation and rainfall, essential for fixing the dunes.
Similarly, the structures planned for installation will substantially affect the direction of flows and the intensity of the wind on the dune surface and will cause a lack of…’contribution of new sediments and destabilisation of the wind dynamics of the dunes that are intended to be preserved.
Best alternative
All in all, the best alternative to the new seafront promenade. is not to build it over the protected dune habitats, avoiding a new elevated walkway with a route parallel to the coastline., but rather to improve the two existing paths further inside Avinguda de les Medes and Carretera Fonda, which currently link Les Griells and La Pletera, with a segregated space exclusively for pedestrians.
Furthermore, visitor flows should be channelled perpendicularly to the riverbank and coastline, with marking that effectively limits trampling of the dune ridges by users and their pets, and the slope planned for the new ramp in the northern sector should be removed.
Lighting
No public lighting facilities are planned for the project.
In principle, this decision could seem entirely coherent with the stated intention of affecting the environment as little as possible. This would save on consumption and maintenance and even make this route more attractive at night.
However, the problem is that this promenade will form the final part of a pedestrian route, which begins at El Molinet and ends at La Pletera. In addition to a recreational function, it will have to assume a structuring role and a transit point to reach the houses of La Pletera. This is the only qualified way to get there on foot that is safe and suitable for everyone.
In any case, an attempt should be made to make a minimum of lighting compatible with respect for the environment and the minimisation of light pollution, for example: low beacons, motion detectors, limited operating hours, etc. The security that lighting would provide would minimise the widespread use of vehicles.
Access
Many people reach Griells Beach via Tulipa Street. At present the only authorised route is down the metal staircase that leads from the promenade a few metres north of the end of that street. It is a rather inconvenient access for many people and, moreover, has at times become impracticable when the sea leaves the beach with only a minimal stretch of sand.
There used to be, just before the end of Tulipa Street, a rather dilapidated downhill path running parallel to the seafront, heading south, which led directly to the widest part of the beach in front of Camping El Molino. It was very handy.
In the project, it is foreseen that the first descent ramp from the promenade to the beach will be quite a bit further south than the end of the street, meaning that people arriving from the street who want or need good access will be forced to walk a relatively long stretch of the promenade towards La Pletera.
This issue is especially problematic for people with reduced mobility. These individuals will often arrive in vehicles which they will park in the designated disabled bays, or they will get out of cars at the end of Tulip Street.
Camping access
The project includes four designated access points from the campsite to the beach. These are 4 gates in the fence from which campers can ascend to the promenade via a staircase. From this point, they can descend to the beach with other people via the ramps provided.
Besides, it is not considered very coherent that the project foresees and pays for 4 doors with their staircases when there is currently only one. Without staircases, we think the connection between these doors and the promenade should be made with total continuity, so that campers cannot escape the official routes, go under the viaduct, and cross the dunes directly.
They would save themselves having to go up the promenade and walk along a section of it to the nearest ramp. This possibility would be almost certain when the campers loaded the various artefacts that are often used on the beach. We believe that these four routes should be channelled without any possible escapes.
Green zone at the El Molino campsite
We would not want to miss the opportunity to highlight the possibility that the construction of the promenade, by the Department of Coasts, could have been used so that, simultaneously, the green area that has been planned for years next to the promenade, and even part of which it encroaches upon, could have been obtained and implemented by the Town Council.
Although El Molino campsite has been there for over 50 years, the urban planning of Torroella has also placed it in a position of non-compliance for many years. This non-compliance will one day have to be faced by the Town Hall and, obviously, could have been addressed with much more weight at the time of the promenade's construction.
Precisely, if the promenade project is analysed, it is concluded that it would achieve its full meaning and integration if, on both sides of the elevated walkway, there were natural spaces to preserve.
However, unfortunately, this is not the case. On its inner side, instead of the advertised green area, there is the campsite, with its fence. Before that, there is a strange strip of land into which the project is forced to fit a series of staircases that, obviously, would not be there without the campsite.
It can be concluded that, in this case, the preservation of a non-compliant campsite requires the provision of temporary amenities that will one day have to be dismantled.
With the construction of the new promenade, the campsite's expectations would be effectively extended and improved. A new fence is being erected, four gates installed in line with a new internal layout, access stairs built and even dunes put in place to protect it from the sea. We will have camping in the green area for another 50 years.
NEW DELIMITATION OF THE MARITIME-TERRESTRIAL ZONE
Although four alternatives were established in the impact study of this project, three of them follow the same fixed route over the dunes. It is advisable to rethink public works with genuinely alternative proposals.. For example, they should not consist solely of varying the materials used to configure a catwalk with the same layout.
Outside the strict scope of this project, we urge the administrations to carry out appropriate studies for a review of urban planning and public works, which will lead to a more rational use of urban development.
This means that a review of the coastline and the maritime-terrestrial zone should be taken into account. This should be more adapted to the rise in sea level and storms. Also, what works should not be permitted within this area, due to their environmentally ephemeral and economically unsustainable nature.
The works should be more oriented towards the public interest. With a long-term vision of adapting to global warming and the reduction in sediment input. because of the multiple weirs that impede the flow of the Ter River. These retain the sediments that nourish the beaches; and because of changes in land use in the catchment area that are slowing down erosive processes.
This article is a summary of the submissions presented to the Griells Promenade Project at La Pletera, published on 15 February 2021 in BOE-B-2021-7096, drafted for the company DOPEC.
Header photograph: John J. Vidal
Article creation date: 12/6/2021.
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