Is nowhere safe from sand mining?: Guest post by Goodwin Sands SOS
Public concern about the prospect of mining the Goodwin Sands first reared its head in 2016, with the release of the Environmental Statement1 accompanying Dover Harbour Board’s licence application to extract 3.75M tonnes of sand to use as landfill for its port expansion.
This 1500 page-turner made light work of the potential damaging effects on marine mammals, benthic ecology, nature conservation, hydrodynamic processes, coastal processes, heritage and fishing, concluding that through ‘mitigation by design’ there would be ‘no significant adverse residual effects’ from the proposed activity. Reckoning this too good to be true, Goodwin Sands SOS was born.
As many will know, the Sands create the safe anchorage of The Downs whilst also posing a fatal hazard to shipping, often at the same time. The ferocity of the Great Storm in 1703 caused a reported 130 vessels sheltering in The Downs to drag their anchors and founder on the very sandbank they thought was protecting them. It was reported that 1,200 sailors drowned that night, including crews from the RN warships Restoration, Stirling Castle, Mary and Northumberland, which are all now listed as Protected Wrecks.
WWII brought further casualties to the Goodwins as 60 planes from Britain, Poland and Germany were reported missing over them during 1940 alone, with an associated loss of an estimated 80 aircrew.2
It was not surprising therefore that the Nautical Archaeological Society stated in its first submission to the Marine Management Organisation (MMO) ‘we cannot think of anywhere more inappropriate within UK waters in which to conduct marine aggregate dredging operations’.3 Their opinion apparently fell on deaf ears.
It soon transpired that Historic England and Natural England (NE) were far from living up to their claims to protect the nation’s heritage and environment. In fact, it is hard to see how they could have been more ineffective. The MMO repeats monotonously that its decisions are evidence-led, yet they do not seem to have the initiative to question the quality of the evidence they are fed.
The Goodwin Sands are a Marine Conservation Zone.4 The subtidal sand targeted for extraction is a protected habitat with the conservation objective of maintaining it in a favourable condition. Natural England advised the MMO that dredging would not hinder these objectives because the fauna would recover within 5 years.5 But it is the habitat that is protected here, not the fauna, and it is difficult to understand how removal of the sand will maintain it in a favourable condition.
Historic England are just as bad. Best practice for avoiding Underwater Cultural Heritage (shipwrecks and military remains) is by avoidance. Failing that, the fall back option is to impose Archaeological Exclusion Zones (AEZs) around ‘anomalies’ identified by pre-dredge geophysical surveys. The Thanet Offshore Wind Farm and National Grid’s IFA2 Connector projects have imposed AEZs ranging from 50m -150m, depending on the potential archaeological interest of the anomalies lying in the way.6,7
Historic England have accepted DHB’s proposal to impose mere 25m AEZs, which means that apart from being totally inadequate (the average wingspan of an intact bomber is 30m), avoiding the 50 or so anomalies located in the revised dredge zone will end up looking like a forest of fragile stalagmites.
All the anomalies in the surveyed area have been randomly classified by Wessex Archaeology as A2 ‘uncertain origin of possible archaeological interest’.8 One anomaly, analysed as a ‘sea floor disturbance’, has been identified by SOS divers as a plane crash site complete with unexploded bomb. Another area of ‘possible iron debris’ includes what could be either an iron water tank or an early steamship boiler. No matter, says the MMO, these assets are only in the buffer zone. They just don’t get it: none of the 50 anomalies remaining in the revised dredge have been identified and ‘ground truthed’ despite at least two sets of similarly analysed anomalies being revealed as irreplaceable heritage assets.
And here is the point. The MMO does not want to get it. The over riding impression is that this licence was going to be granted, whatever the objections raised. Sand mining brings revenue to the Government on two fronts; the MMO receives licence fees and The Crown Estate receives royalties. Through their ineffectual actions, Historic England and Natural England are complicit in this exploitation and it is a national disgrace.
The Goodwin Sands are an acknowledged sea defence for the chronically eroding East Kent foreshore. Millions of pounds of taxpayers’ money are spent every year on shoring up the beaches. Yet The Crown Estate’s own industry guidelines9 on assessing the sensitivity of offshore sandbanks to dredging appear to have been ignored completely.
We’ll leave you with this final thought - who regulates the Environmental Statements, the MMO and especially The Crown Estate? As far as we can tell, no one does. DHBs successful licence application has set a dangerous precedent with more likely to follow and it is easy to see that The Crown Estate, which has identified the South Goodwin sandbank as a valuable money-earner, will be only too pleased to oblige.
If being a Marine Conservation Zone, the final resting place for shipwrecks, sailors and WWII aircrew, and a vital natural sea defence, cannot protect the Goodwin Sands from being destroyed by sand mining, then nowhere is safe.
REFERENCES
Royal HaskoningDHV. MLA/2016/00227 Goodwin Sands Aggregate Dredging Environmental Statement March 2016
Dave Brocklehurst MBE. Curator, Kent Battle of Britain Museum. List of planes and aircrew missing over the Goodwin Sands May – November 1940 July 2016
Nautical Archaeology Society. Response to Marine Management Organisation August 2016
Defra, Goodwin Sands recommended Marine Conservation Zone June 2018
Marine Management Organisation. MLA/2016/00227 Environmental Impact Assessment Consent Decision and Decision Report July 2018
Vattenfall. Offshore Archaeology Archaeological Written Scheme of Investigation June 2018
TUV-SUD-PMSS IFA2 Variation Supporting Environmental Report with comments August 2018
Wessex Archaeology. Goodwin Sands Archaeological Review of Geophysical Data (2017) – Annex
British Marine Aggregate Producers Association & The Crown Estate. Marine Aggregate Dredging and the Coastline: a guidance note December 2013
The Goodwin Sands
About the Author/s:
Goodwin Sands SOS is a community campaign group, created in 2015 by concerned East Kent residents, to challenge Dover Harbour Board’s dredging licence application. You can reach them @ https://goodwinsandssos.org/