Beachy Head to Selsey Bill Shoreline Management Plan. Appendix A: SMP Development

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2 Contents A.1 Introduction... 3 A.2 Project Information... 5 A.2.1 SMP Background... 5 A.2.2 Client Steering Group (Csg)... 5 A.2.3 Consultant... 5 A.2.4 SMP Study Boundaries... 6 A.2.5 SMP Programme... 6 A.3 Stage 1: Scope SMP... 8 A.3.1 Stakeholder Engagement Strategy (Task 1.3)... 8 A.3.2 Data Collection (Task 1.4)... 8 A.4 Stage 2: Assessments To Support Policy Development... 9 A.4.1 Baseline Understanding Of Coastal Behaviour And Dynamics (Task 2.1)... 9 A.4.2 Baseline Scenarios (Task 2.2)... 9 A.4.3 Definition Of Features, Benefits And Issues (Task 2.3) A.4.4 Definition Of Objectives (Task 2.4) A.4.5 Identify Flood And Erosion Risks (Task 2.5) A.4.6 Assessment Of Objectives (Task 2.6) A.5 Stage 3: Policy Development A.5.1 Development Of Policy Scenarios (Task 3.1) A.5.2 Policy Scenario Assessment (Task 3.2) A.5.3 Identification Of A Preferred Scenario (Task 3.3) A.5.4 Confirm Preferred Scenario (Task 3.4) A.5.5 Draft SMP Document Preparation (Task 3.5) A.6 Stage 4: Public Examination A.6.1 Gain Approval In Principal (Task 4.1) A.6.2 Confirm Consultation Strategy (Task 4.2) A.7 Stages 5 And 6: Finalise And Disseminate Plan... 18

3 A.1 Introduction This Appendix provides a full explanation of the Shoreline Management Plan (SMP) process adopted and a description of the policy decision-making process and outlines the chronology of the SMP development. Task Numbers are referred to, which relate to the Tasks outlined in the 2004 Procedural Guidance (Defra, 2004). It also provides a route map for the supporting information used in the SMP development and included in appendices, these are as follows: B: Stakeholder Engagement Stakeholders have had an important role in shaping the plan. All communications from the stakeholder process are provided here, together with information arising from the consultation process. C: Baseline Process Understanding Includes baseline process report, defence assessment, NAI and WPM assessments and summarises data used in assessments. It also includes the assessment of breaching through the Medmerry Barrier. D: Thematic Studies This report identifies and evaluates the environmental features (human, natural, historical and landscape) in terms of their significance and how these need to be accommodated by the SMP. E: Issues & Objective Evaluation Provides information on the issues and objectives identified as part of the Plan development, including an appraisal of their importance. F: Initial Policy Appraisal & Scenario Definition The impacts of a range of policy scenarios upon shoreline evolution have been evaluated, which has formed a key part of determining the acceptable sustainable policies and their combination into scenarios for testing. G: Preferred Policy Scenario Testing A summary of the assessment and appraisal of the preferred policies, via (i) assessment of shoreline interactions and response against preferred policy; and (ii) assessment and achievement of the objectives against the baseline scenario (No Active Intervention) and the preferred policies. The assessments are based on the findings of Appendices E and F. H: Economic Appraisal and This report provides a high-level assessment of the economic Page 3 of 18

4 Sensitivity Testing justification of each preferred policy, which is reported in terms of justified, not justified and marginal. I: Metadatabase and Bibliographic Database All supporting information used to develop the SMP is referenced for future examination and retrieval. References are listed in the respective appendix document. Page 4 of 18

5 A.2 Project Information A.2.1 SMP BACKGROUND This SMP is an update of the Beachy Head to Selsey Bill SMP produced by Halcrow in 1996.The SMP was developed and produced on behalf of the South Downs Coastal Group (SDCG) in accordance with the latest Procedural Guidance (PG) for the production of SMPs (Defra, 2004), and as one of the first second-generation SMPs to be produced, formed part of the testing of the PG. The SMP was developed over the period April 2003 to December A.2.2 CLIENT STEERING GROUP (CSG) At the start of the SMP process the Client Steering Group (CSG) was defined, some of whom were selected from the SDCG on the basis that together they provide a fair representation of the geographic area and interest, i.e. environment. The CSG included: Arun District Council Worthing District Council Brighton and Hove City Council West Sussex County Council Environment Agency English Nature Defra It was agreed that Arun District Council would be the Lead Authority and, as such, were responsible for the financial management of the project, including grant aid submission, and overall project administration. The CSG had overall responsibility for the delivery of the SMP and were involved throughout the life cycle of the SMP. As well as initiating the development process and defining the scope and extent of the SMP, they were responsible for managing the development of the SMP through guidance and review of the work undertaken. The CSG will also oversee implementation of the SMP, with regular meetings continuing following completion of the SMP. A.2.3 CONSULTANT Halcrow Group Ltd were commissioned to produce the SMP on behalf of the SDCG. Key team members included: Miss Rachel Fowler Mrs Alison Atkinson Mr Adam Hosking Ms Emma Fisher Mr Stuart Hedgecot Dr Richard Westaway Project Director Project Manager Senior Coastal Scientist Coastal Scientist Principal Environmental Scientist GIS Analyst Page 5 of 18

6 A.2.4 SMP STUDY BOUNDARIES This SMP relates to sediment sub-cell 4d as defined in HR Wallingford (1994) and the first SMP covered the area from Beachy Head to Selsey Bill. Moving the western boundary of the SMP to include both Braklesham Bay to take account of the potential flood risks that may occur at Medmerry was considered. An alternative option was to move the boundary east towards Aldwick to exclude Pagham Habour and Selsey Bill. However, as the overriding factors in an SMP are coastal processes and shoreline interaction, by not including Selsey Bill in this SMP would detract from the importance influence that the headland and harbour have on coastal processes in the adjacent areas. Thus, it was considered that the existing boundaries that extend from the drift divide at Selsey Bill and the drift divide at Beachy Head should remain, but an independent study of the possible flood risks and linkages between Medmerry and Pagham would be completed to inform the SMP (Appendix C). There are several rivers and estuaries within the area covered by the Beachy Head to Selsey Bill SMP. Since there have not been any Catchment Flood Management Plans (CFMPs) produced for this area, there are no pre-defined inland boundaries to which the rivers and estuaries should be considered within the SMP. To address this, estuaries were considered up to their tidal limit or the limit of coastal policy influence, which generally coincided with the point where the rivers cross with the A27 main road along this particular frontage. A.2.5 SMP PROGRAMME The Figure below illustrates the timetable of activities carried out as part of the SMP development. Highlighted in red are the activities that involved stakeholder engagement (further details are included in Appendix B). Page 6 of 18

7 Stage 1: Scope SMP CSG meeting to decide SMP approach (Apr 2003) Stakeholder engagement documents issued (May 2003) Stakeholder feedback analysed and information collated (July 2003) Initial Key Stakeholder Group Meeting (Sept 2003) Stage 2: Assessment to support policy Baseline understanding of coastal behaviour and dynamics (Aug/ Sept 2003) Baseline scenarios (Sept 2003) Theme review (Oct 2003) Development of issues table and objectives (Aug - Oct 2003) Stakeholder feedback incorporated (Sept - Oct 2003) Issue of draft issues table to KSG (Sept - Nov 2003) Objectives ranked and revised table issued to KSG (Nov-Dec 2003) Stage 3: Policy development KSG workshop to develop policy ideas (Nov 2003) Testing of policies defined at KSG workshop against processes and objectives (Dec 2003 Jan 2004) KSG workshop to steer preferred policy (Mar 2004) Review of scenario testing to select preferred policies (Mar May 2004) Economic analysis and sensitivity testing (Apr May 2004) Members meeting to agree draft preferred policies (May 2004) SMP document and appendices produced (June Sept 2004) Stage 4: Public examination CSG meeting to confirm consultation strategy (May 2004) Public Consultation (Dec 2004 Apr 2005) Stage 5: Finalise SMP Review output from consultation (May to Aug 2005) Revise SMP (Sept 2005 Mar 2006) Develop Action Plan (Sept Mar 2006) Finalise SMP (April May 2006) Stage 6: SMP dissemination Publicise SMP Implement SMP Page 7 of 18

8 A.3 Stage 1: Scope SMP A.3.1 STAKEHOLDER ENGAGEMENT STRATEGY (TASK 1.3) A three-level approach was adopted: Level 1: the Client Steering Group (see above) Level 2: A Key Stakeholder Steering Group (KSG) Level 3: additional stakeholders. The aim of the Key Stakeholder Group (KSG), referred to in the 2004 SMP Procedural Guidance, was to act as a focal point for discussion and consultation through development of the SMP. Members of the KSG were involved in a series of workshops throughout the SMP development. Appendix B provides further details of all KSG meetings and stakeholder engagement exercises. Membership of both the KSG and additional stakeholder group was determined through discussion with the CSG and through utilising the first SMP and existing strategy studies. A full list is provided in Appendix B. Although Elected Members were not formally involved during the SMP development they were consulted at the start of Stage 4. Further details are provided in Appendix B. A.3.2 DATA COLLECTION (TASK 1.4) Data was collected via a number of sources including stakeholders, literature search and a websearch. Key resources were: The first generation SMP (Halcrow, 1997) Futurecoast (Halcrow, 2002) Existing strategy studies completed since the first generation SMP. Solent Coastal Habitat Management Plan (Posford Duvivier, 2003) English Nature Research Report 565 (English Nature, 2004) Nature Conservation Designation information from the English Nature website ( MAGIC website ( Data provided by English Heritage Environment Agency s Indicative Flood Management data All the data and information gathered and used within the SMP development is referenced and provided on the Metadata CD, which accompanies Volume 2 of the SMP document. Page 8 of 18

9 A.4 Stage 2: Assessments to Support Policy Development A.4.1 BASELINE UNDERSTANDING OF COASTAL BEHAVIOUR AND DYNAMICS (TASK 2.1) A Assessment of coastal processes and evolution A qualitative approach was taken for the assessment of coastal behaviour and understanding, incorporating existing information at various temporal and spatial scales. Numerical analysis was not undertaken as a sufficient level of detail had already been derived through the various strategy plans that exist along this frontage. Thus, this review includes statements on interactions, shoreline movement and predictions of shoreline evolution at various scales and is reported in Appendix C. A review of this report was undertaken by the CSG. A Assessment of coastal defences It was intended that the National Flood and Coastal Defence Database (NFCDD) would be used in the assessment of coastal defences. This data was not available; therefore information on condition grades of defences was obtained from the eight operating authorities and the Environment Agency. A as well as the existing CPSE and SPS data. An assessment of residual life under a no active intervention policy was undertaken using the condition data together with National Assessment of Defence Needs and Costs for flood and coastal erosion management (NADNAC) condition deterioration curves, using the table below (from the Defra 2004 Procedural Guidance, Volume 3) as a guide. The report is included in Appendix C. A review of this report was undertaken by the CSG. Defence Description Estimate of residual life (years) under NAI policy Existing Defence Condition Grade: Grade 1 Grade 2 Grade 3 Grade 4 Grade 5 Seawall (concrete/ masonry) 25 to to to 15 5 to 7 0 Revetment (concrete/ rock) 25 to to to 15 5 to 7 0 Timber groynes and other timber structures (e.g. breastwork/ revetments) 15 to to 20 8 to 12 2 to 7 0 Gabion 10 to 25 6 to 10 4 to 7 1 to 3 0 Note: Grade 5 is not used in the CPSE, but is included here as a measure of failure. This information was used in the No Active Intervention assessment (Task 2.2) as a first approximation of when defences will fail. A.4.2 BASELINE SCENARIOS (TASK 2.2) In order to analyse the shoreline interactions and response to various management policies two baseline scenarios were developed: No Active Intervention (NAI), which assumes that defences are no longer maintained and will fail over time, and With Present Management (WPM), which assumes that all defences are maintained to provide a similar level of protection to that provided at present. Page 9 of 18

10 These assessments were completed at three pre-defined timescales (epochs): 0-20; and years. It was not appropriate at this stage to define Policy Units; therefore the coast was divided initially according to the defence characteristics with their associated performance and residual life expectancies. For the two scenarios, predictions of future shoreline change and erosion/ flooding risk were developed from the baseline understanding of coastal behaviour and dynamics (Task 2.1) together with additional data on historical shoreline change, from analysis of EA beach profiles and historical Ordnance Survey maps, and the Environment Agency s Indicative Flood Map data. Further details of the information used are provided in Appendix I. The two baseline scenario reports are included in Appendix C. Maps showing the predicted shoreline response under these two scenarios have been produced and are also included in Appendix C. These maps and conclusions from the analyses were presented to the KSG workshop held on 27th November 2003 (see Appendix B). A.4.3 DEFINITION OF FEATURES, BENEFITS AND ISSUES (TASK 2.3) A Theme review A review of the characteristics of the coast was undertaken to identify key features along the coast and define why these features are important to stakeholders. This review evaluated existing data and data collected from stakeholder inputs (see Appendix B for more details) and was supplemented by: a familiarisation visit to whole coastline, concentrating on sensitive areas review of first round SMP review of other relevant documents discussions with local authority officers data provided by English Nature, English Heritage, East and West Sussex County Archaeologists. All data sources used in the review are supplied on the Metadata CD. The full report is included in Appendix D and includes information on the following themes: landscape and nature conservation historic environment current and future land use. A Issues table As part of the Defra 2004 Procedural Guidance testing, a table identifying feature and benefits had already been developed for this SMP, but this table was revised using the information gathered for the above review. This Issues Table clearly sets out for each location: the feature issues associated with the feature Page 10 of 18

11 why the feature is important, i.e. the benefit/s provided who the beneficiaries are whether it affects policy selection A KSG workshop was held in September 2003 to discuss and review the issues. As a result of feedback received, minor edits/ additions were made. A.4.4 DEFINITION OF OBJECTIVES (TASK 2.4) Having identified the features, issues and benefits associated with each coastal location, the next step was to define objectives for these locations. In the process of doing this, it was found that a number of generic objectives could be developed to ensure consistency within the issues table. These are outlined below: Type Residential properties Commercial properties Heritage SSSI (geology) SSSI (habitats) Generic Objective Prevent loss of residential properties due to erosion Prevent damage to /loss of residential properties due to flooding Prevent loss of commercial properties due to erosion Prevent damage to /loss of commercial properties due to flooding Prevent loss of [heritage site name] due to erosion Prevent damage to/loss of heritage site/s due to flooding Continued erosion of cliffs to maintain exposures (under Defra High Level Target 4) Maintain existing [possible add type] habitats (under Defra High Level Target 4) Nature designations Maintain existing [possible add type] habitats National Trails/ Public footpaths Maintain trail or footpath Golf Course Prevent loss of golf course due to erosion AONB Maintain landscape quality Infrastructure (services) Maintain services to properties Infrastructure (roads) Beach Maintain existing access Maintain [major] communication link between communities [name as appropriate] Maintain communication links within [town] Maintain a beach [possibly add type e.g. sandy/ wide etc.] suitable for recreational purposes Car parking Maintain car park facilities Access Maintain access to beach/sea RNLI/ IRB Lifeguard Station Farmland Maintain access to beach/sea Maintain Lifeboat Station [in the town] Prevent loss of farmland due to erosion Prevent damage to/ loss of farmland due to flooding Page 11 of 18

12 The development of this Extended Issues Table involved a review by both the CSG and the KSG. The table was provided to the KSG in September 2003, prior to the KSG workshop and members were asked to: review the features identified check that all relevant issues had been included check that the benefits identified were correct and all beneficiaries were included check that the objectives were a good representation of the requirements of the beneficiaries. The report sent out to stakeholders is included in Appendix B. Feedback from the stakeholders was minimal, but the comments received were incorporated into the extended issues table. Involving stakeholders at this stage was key to ensuring that prior to policy appraisal all issues had been understood and incorporated into the process and in the promotion of buy in to the decision process. A.4.5 IDENTIFY FLOOD AND EROSION RISKS (TASK 2.5) In order to understand whether the features identified within the Issues Table were actually at risk, results from the No Active Intervention assessment were used to look at flood and erosion risks under such a scenario. This information fed into the assessment of objectives (Task 2.6). A.4.6 ASSESSMENT OF OBJECTIVES (TASK 2.6) In order to prioritise or rank the objectives generated as part of Task 2.5, the objectives were assessed using a number of questions: At what scales (spatial/temporal) is the benefit important? What is the importance of the benefit, i.e. the impact if this feature/ benefit were lost tomorrow? Is there enough of the benefit? Can the benefit be substituted? (This followed guidance laid out in the Defra 2004 Procedural Guidance Volume 2). Using the answers to the above four questions, the objectives were then ranked. Through testing of the Defra 2004 Procedural Guidance it was recognised that it is neither possible nor appropriate to compare different types of features, e.g. environment site with housing, therefore a comparative ranking was generated specific to each theme. The following themes were used: Natural environment (E) Housing (H) Commercial and agricultural property (C) Infrastructure (roads, pipelines, etc.) (F) Recreation (R) Page 12 of 18

13 Heritage (G) Landscape (L). Both the objectives assessment and ranking data was input to the Issues Table. This revised table was reviewed by both the CSG and KSG. The full table is included in Appendix E. This ranking was not intended as a mechanism to prioritise decisions, but to help fully understand the issues that had been raised and aid in policy selection and development. However, it was agreed by the CSG that it was too subjective and did not add value to the policy appraisal; therefore the ranking was not taken any further after this stage. Page 13 of 18

14 A.5 Stage 3: Policy Development A.5.1 DEVELOPMENT OF POLICY SCENARIOS (TASK 3.1) The focus of the KSG workshop on the 27 November 2003 (see Appendix B for further details) was to involve stakeholders in the identification of key policy drivers along the frontage, through bringing together an understanding of the issues and the risks, and developing an appreciation of each other s viewpoints. The two baseline scenarios (Task 2.2), associated flood and erosion risk assessment (Task 2.5) and the full Issues Table were presented to the group. The KSG was first divided into four groups of individuals with broadly similar interests or disciplines and each group was asked to provide a practical vision for the SMP coastline over each of the three epochs, taking account of the information on defined issues and risks. The KSG was then divided into different groups of individuals, split by geographical area. Each group was asked to consider the different viewpoints highlighted from the morning session and seek a level of agreement on what should be the key drivers and/ or policy options that were needed to underpin scenario testing for specific sections of coast. The conclusions of each group were fed back to the rest of the KSG, highlighting areas of agreement and conflict. From this exercise and further discussion with the CSG, it was possible to identify policy scenarios, i.e. a combination of policy options for each of the three epochs, using the key drivers and meeting a balance of objectives identified. Pre-defined policy options comprise: o Hold the Line (HTL), o Managed Realignment, o No Active Intervention (NAI), o Advance the Line As an outcome of the KSF an initial screening of the appropriateness of each generic policy for each pre-defined feature was undertaken. The screening process looked at combinations of the key policy drivers and objectives to define which policy options should be appraised in greater detail over the three epochs (2025, 2055 and 2105). Where no key policy driver was identified, an initial brief review of all generic policy options was undertaken, considering not only the defined objectives, but also technical feasibility and likely economic justification. This led to the selection of appropriate policies to be tested against all the objectives in greater detail. The reasons why any particular policy was not considered in greater detail was also stated for each feature (Appendix F). Two key policy drivers, Beachy Head and Selsey Bill, were identified at this stage. A.5.2 POLICY SCENARIO ASSESSMENT (TASK 3.2) A Assessment of shoreline interactions and response To develop the preferred policy scenario for the whole SMP coastline, the initial screening process described above was taken a stage further and each policy identified for individual features was assessed in terms of future shoreline response. The first stage was to state assumptions made regarding the broad implementation of such policies at each location: this is necessary in order to assess response of adjacent shorelines. This was then reviewed by the CSG. Then an assessment of Page 14 of 18

15 future shoreline response was undertaken, with changes reported by each epoch (as undertaken for the two baseline scenarios). Predictions were made of both the rate of change and type of change along the coast; the two baseline scenarios proved extremely useful in developing the assessments. Maps were produced identifying future areas of flood or erosion risk for each scenario and for each of the three epochs (Appendix C). Reports detailing these assessments are included in Appendix C. A Assessment of achievement of objectives For each policy the achievement of objectives was assessed using the Issues and Objectives Table developed as part of Stage 2. At this stage a qualitative review rather that quantification of losses was undertaken. This Issues and Objectives Table is included in Appendix E. A.5.3 IDENTIFICATION OF A PREFERRED SCENARIO (TASK 3.3) Results of the policy scenario testing were presented to the KSG at a workshop in March The proposed policy was presented, together with the maps of potential flood and erosion risk. The stakeholders were asked to identify any areas where they disagreed with the proposed policy and wished to discuss further. The KSG was then divided into different groups of individuals, split by geographical area. Each group was asked to discuss the potential disagreements in order to steer the policy for that specific coastal stretch. Feedback from the meeting, together with the conclusions from Task 3.2, were used to modify the policy scenarios in order to develop a Preferred Scenario for each location, i.e. a scenario that best achieved the defined shoreline management objectives in a sustainable manner. Only minor changes were made, although it was recognised that east of Brighton there were still some considerable concerns regarding the impact of policy change and that the SMP should identify the need for measures to be in place to deal with loss of land and property. It was also agreed that, at this time, it would be inappropriate to set a single long-term policy for Cuckmere Haven, as further studies to look into potential impacts of a change in policy were necessary. Where changes were made to the policy scenario, Task 3.2 was repeated. Once the preferred policy scenarios had been defined, Policy Units were identified. These are simply frontages for which a discrete shoreline management policy applies. The preferred policy scenarios were reviewed by the CSG and agreed in principle so that Task 3.4 could be completed prior to review by Elected Members (Task 4.1). A.5.4 CONFIRM PREFERRED SCENARIO (TASK 3.4) A Economic assessment Once the preferred policy scenarios had been agreed by the CSG, more detailed economic analysis was carried out. Although economic considerations had been taken into account in the development of the scenarios, up to this stage no quantification had been undertaken. It should be noted that this assessment was not to establish the economic justification for a scheme, simply to make a broad assessment of the economic robustness of the preferred policies, i.e. whether the policy was: Page 15 of 18

16 clearly economically viable clearly not economically viable of marginal viability (and therefore in need of more detailed assessment at a later date, e.g. as part of a strategic plan). Losses and benefits were calculated only on the basis of residential and commercial property values. Other assets such as utilities, highways etc., were valued or included and intangible benefits such as recreation, or amenity or environment were not included. This is in accordance with the 2004 Procedural Guidance (Defra, 2004). Appendix H includes further details on the analysis undertaken. A.5.5 DRAFT SMP DOCUMENT PREPARATION (TASK 3.5) A draft version of the SMP was produced in accordance with the Procedural Guidance, for review by the CSG. Page 16 of 18

17 A.6 Stage 4: Public Examination A.6.1 GAIN APPROVAL IN PRINCIPAL (TASK 4.1) Prior to a final version of the SMP being produced, the preferred policy scenarios were presented to an Elected Member s group in April The policies and their justification were presented to the group for further discussion (details are provided in Appendix B). Concerns were raised at the meeting regarding the public acceptance of the proposed policies, which will result in loss of properties and infrastructure over the 100 year period, without any mitigation measures being in place. Internal meetings were held by the various local authorities with their Members. Agreement was eventually reached for the public consultation process to proceed, but with the proviso that any SMP documents for consultation should make it clear that the SMP represents the best policy that can be achieved within the current government guidance and policies. It was agreed that the SMP documents should also make it clear that there is a need for management strategies to be introduced to deal with the consequences of implementing the proposed policies. Additional comments regarding the document contents and presentation were also taken on board. A.6.2 CONFIRM CONSULTATION STRATEGY (TASK 4.2) A strategy for the public consultation exercise was agreed through discussion with the CSG. The following was agreed by the group: The most appropriate method of dissemination is through manned public exhibitions The exhibitions should be held in the areas that are most affected The local press should be used as much as possible both for educational purposes and advertisements There is a need for a leaflet explaining the background and principles of the SMP There may be a need for additional meetings to be held for certain stakeholder groups. Further details are included in Appendix B. Page 17 of 18

18 A.7 Stages 5 and 6: Finalise and Disseminate Plan These stages will be carried out following consultation and will involve the following tasks: Stage 5: Finalise Plan Stage 6: Plan Dissemination REVISIONS TO DRAFT SMP (TASK 5.1) DEVELOP ACTION PLAN (TASK 5.2) FINALISE SMP (TASK 5.3) PUBLICISE SMP (TASK 6.1) IMPLEMENT PLAN (TASK 6.2) Following public consultation comments were reviewed and modifications made as agreed with the CSG. An Action Plan to implement the SMP was developed in accordance with the latest Procedural Guidance (PG) for the production of SMPs (Defra, 2004). The SMP was finalised and reviewed by the CSG ready for dissemination. The CSG was responsible for making the SMP accessible and for publicising its completion. This was carried out under supervision of the CSG, in accordance with the Action Plan (Task 5.2). Page 18 of 18