Correspondence with Anne McIntosh

MARINET wrote to Anne McIntosh, who has been Shadow Minister for Environment, Food and Rural Affairs since 8th September 2009, to express our concern of the ongoing impasse regarding continuing Offshore Aggregate Dredging. She in turn wrote to Huw Irranca Davies who is the existing Parliamentary Under-Secretary of State in DEFRA.
The Ministers reply to her consisted of the usual output as regards dredging as seen earlier on our website, so a follow-up was sent to Anne McIntosh to cover our response to the content, some quotes and points of which our members might find useful when dealing with the matter.

Dear Anne McIntosh,

My abject apologies for not having come back to you earlier regarding my expressed concern on the issues of continued offshore aggregate dredging, sea defences and the impact of the governments ‘Managed Retreat’ a.k.a. ‘Making Room for Water’ policies. I have been very busy surveying our coastline for damage over the summer months, and only now am beginning to catch up with the accumulated backlog of correspondence.

I am afraid that this is a rather voluminous reply, that you may initially prefer to place into the hands of your Research Assistant, but a necessary one so as to fully explain the contradiction of the claims made by the Minister of the Environment.

Following your retailing of the reply that you received from Huw Irranca-Davies, the implication that I read into it in your letter to John was that you were satisfied with the present regulations governing the exploitation of our seabed for sand and gravel.

You quoted (from the Ministers letter):

“All applicants for dredging licences are required to undertake a Coastal Impact Study to assess if there would be any effect on the adjacent coastline, e.g. by the drawdowndraw down The process by which tides and wave motion remove (draw down) material from a beach and pull it out to sea. A sandy beach experiencing draw down is thus denuded of its sand. The process can be natural (i.e. winter storms) or can be artificially caused (e.g. aggregate dredging, whereby the dredging of sand and gravel offshore causes sand to be drawn down from the beach in order to replace the material which has been dredged). of beaches into the dredged areas or by changing wave conditions as a result of lowering sandbanks. The MFA takes a precautionary approach and consent will not be given if there is a likelihood that the proposed operations will exacerbate coastal erosion. The Marine Minerals Dredging Regulations came into force 1st.May 2007 as a statutory process of the control of mineral extraction in British marine waters. In the majority of cases an Environmental Agency,along with other stakeholders,is always given the opportunity to comment. We consider whether the methods of controlling offshore dredging now in place provide the necessary environmental safeguards.”

My comments:

The CIA’s mainly consist of computer modelling of theorised assumptions that are not backed by empirical research, and are designed to attempt to prove that the erosion experienced is not due to offshore aggregate dredging. Any good scientist knows that to help prove a held theory that experiments need to be instituted to attempt to disprove it, then to see if it still stands up. To prove the point of the flow of our shoreline to the voids in the offshore seabed it is only needed to conduct a simple survey of shoreline to offshore sand movement, but this has consistently been refused of grounds of the cost involved, they taking the attitude that ‘it doesn’t happen so why should we waste money in proving that we already know’.

My objections, along with many others, to the granting further and continuing licences to extract aggregate from the offshore seabed comment always supplies comprehensive scientific evidence on the damage created, But these are always totally ignored. (See MARINET’s Comments on UK Licence Applications).

It is true to state that all applications for dredging licences are required to undertake a Coastal Impact Study. But these studies are carried out by organisations selected by, appointed by and paid for by the dredging companies themselves. and no evidence from the many other independent scientific studies conclusively proving that such dredging causes coastal erosion are considered. (See studies from around the world on the erosion resulting from offshore sand and gravel dredging by visiting our Marine Aggregate Dredging pages).

No second opinion is permitted. Those performing the EIAs (Environmental Impact Assessments) for the dredgers do not bite the hands that feeds them, and of course for commercial reasons would not be selected if they did. It’s the old story of ‘he who pays the piper plays the tune’.

The fact that five metres of seabed depth has been lost, much of Scroby gone, that the Scroby wind farm cable encased and buried three metres into the sea bed finished up two metres above it, that huge areas of our once extensive Norfolk and Suffolk beaches are now under the sea, that our main dune defences have been demolished, that our beaches stripped of their sand are now sloping far more steeply so allowing gravitational run off to the dredged chasms and that consequently the sea now reaches the toes of our sea defences and soft sand cliffs to further undermine them, this all since the commencement of industrial scale offshore dredging is not recognised when further licences to dredge are granted. And despite all the evidence of this supplied to those who so generously provide the licences, not a single application has ever been refused. This might be due to the fact that royalties to the Crown Estate and by VAT applied to the product has resulted in over £1.4 billion to the Treasury in the past fourteen years from that aggregate dredged off Great Yarmouth alone. What the dredging companies have profited by is not revealed.

Up to now, no compensation or reimbursement for the resultant environmental, shoreline, housing, business or infrastructure losses due to dredging have been provided. The proceeds so far have been all profit. But just imagine the compensation claims that may now arise if the cause were openly admitted!

It thus has to be assumed that all the aggregate released to sea by ‘Managed Retreat’ could be just a means of providing more sand and gravel for further exploitation. The dredging companies stated two years ago that they were moving their activities to the south coast as all available deposits had been exhausted off East Anglia. But eighteen months ago they applied for and were granted, by John Prescott, without any press notice appearing as demanded and without any Environmental Impact study, an immediate go-ahead to recommence aggregate removal. So where did all this new material suddenly appear from if not from our coastline? The north to south sedimentary drift supply has virtually disappeared since similar dredging took place of Holderness in The Wash. It obviously must have been eroded from our coastline.

Unfortunately for our coastline, the dredging industry and its associated coastal engineering consultants hold sway. The results are accelerating erosion and profits for these groups, the government bodies too. In many ways, we are losing our coastlines to greed, not erosion, and as demonstrated in our current economic crisis, greed is not easily tamed.

History shows that the erosion of our Eastern Seaboard Coastline has been ongoing in history since the icecaps melted, first leaving Tundra, then dense oak forest, then the English River and lots of salt marsh, this eventually expanding to form the German Ocean and now the even larger North Sea. But this although this development shows a smoothed mean average of shoreline loss over the past many centuries, it has not been a linear one way progression. Like Boy George’s Karma Chameleon, it comes and goes.

The land rose for a while, then sunk again, then rose again, leaving us with our Norfolk Broads when the peat was dug out. But the coastline from Happisburgh right down to Great Yarmouth was accreting beyond the first 50 years of the last century, in fact until two years following the commencement of intensive offshore aggregate dredging. The Great Winterton Valley and its extension toward Sea Palling and down to California is proof of this. The western side of this valley was once the dune front to the sea, as evidenced by the position of the old Winterton Lighthouse on the original cliff top. There then built up a series of dunes in front of this, leaving the lighthouse and the valley behind far them as they proceeded east. The sudden major losses in the past, e.g. Dunwich, Ness, Shipden, etc. were brought about by unique massive storms and surges, not the slow erosion rate.

In 1938 (my first memory) we had four extensive and accreting dune banks between the valley and the beach between Caister and Winterton Ness. These began to disappear soon after mass offshore aggregate dredging commenced around 1975, the rate of loss escalating year by year, eventually to leave less than half of the only remaining dune now fronting the valley. This, devoid any assistive defences, will probably disappear within the next five to eight years. Happisburgh has experienced a slow yet steady degree of erosion for well over a century, but only since commercial scale offshore sand mining commenced has it increased by a factor of between ten to fifteen times the original mean rate. The severe draw downdraw down The process by which tides and wave motion remove (draw down) material from a beach and pull it out to sea. A sandy beach experiencing draw down is thus denuded of its sand. The process can be natural (i.e. winter storms) or can be artificially caused (e.g. aggregate dredging, whereby the dredging of sand and gravel offshore causes sand to be drawn down from the beach in order to replace the material which has been dredged). lowering of the beach due to offshore sand exploitation has not only brought the sea to the soft cliff base, but has assisted in scouring out the original effective groyne defences so further diminishing beach height. Thus each high tide now reaches the soft sand cliff base to undermine and collapse it, the aggregate released now being taken offshore to fill the voids created in the seabed by the dredging.

A study of our coastline from aerial photographs taken by the Luftwaffe commencing in 1940 show the extensive dunes as they were then, as do early beach photographs taken by holidaymakers from 1932 on. Our afflicted beaches, once accreting prior to intensive offshore dredging, are now very foreshortened and much steeper due to sand run off, this due the recapture replacement demand created by the removal of between three to five metres of seabed offshore, added to by the far larger eroding waves that accompany deeper water. Both of these results are exclusively due to dredging.

It is not so much that the sea is rising but that the beaches are being lowered. And even if the dredging ceased today, we would continue to experience further erosion for at least the next ten years as the beach and seabed attempt to re-establish a natural equilibrium contour as there is a lag factor built in. (Please refer to my graph correlating beach sand stripping and tideline incursion to the times and levels of aggregate dredging at the end of my full briefing on the topic in our Marine Briefing Paper.)

I am in no doubt whatsoever that the vast majority of the escalated rate of erosion is due to offshore dredging, to which I and independent coastal geomorphologists also attribute the loss of the previous-to-dredging sedimental drift. With the loss of defences and the release of material from the undermined tall cliffs at Overstrand, Happisburgh, etc. we should have had far more sand to feed the beaches, not less.

We are not dealing with a ‘natural’ situation. Both sea rise and dredging are man made. Only the 1.8 — 2.0mm land sink of East Anglia and Kent is natural. The mechanism bringing about the loss of sedimental drift is highly likely to be the intensive dredging in The Wash and off Holderness and beyond, the voids so created then filling with the sand and shingle that would otherwise continue its mobile north to south path. Research to prove this has been accomplished, but is denied by those with vested interests in ongoing sand mining. Requests to have such a sand mobility study built into the Environmental Impact Assessments have been denied in the UK on the grounds that ” … it doesn’t happen, so would be waste of time and money to pursue” (!) Yet it is very easily accomplished by labelling of the beach sand and then investigating that found in both the troughs and in the landed aggregate.

Such research to investigate offshore dredging causing beach draw down was carried out by Blackpool Council during 2007 who became very worried when they lost 2″ (yes — 2 inches!) of sand from their holiday beach. And where did they find it? In the aggregate landed by the dredgers of course! This test employed fluorescent tiny glass balls and radioactive tracer labelled beach sand and then tracking them to destination. Such a test has intentionally not been demanded by DEFRA /MFA/EA or performed by those employed by the dredging companies for EIA provision as it would conclusively prove that erosion was due to dredging, and to reveal that would certainly not be in their financial interest.

Another important point is to understand that ice cap and glacier melt plus thermal expansion of the sea is by far not the greatest threat. It would take a pretty big surge to overtop the sea walls where we have them. We currently have a yearly sea-level rise of 3.2mm added to by 2mm of East Anglian sinkage annually. That’s an equivalent of rise of 5.2mm per year. Thus one would have expected an effective sea rise of (3.2 + 2) x 35 = 182mm, i.e. 18.2cm over the thirty-five years since 1972 when East Coast dredging began in earnest. Perhaps a mite more due to degraded weather, more powerful northerly winds, etc.

On an average 1 in 20 mean beach slope this would have produced a thirty-five year sea advance of the mean high tide mark of 18.2cm x 20 = 3.64 metres, perhaps allowing that little more for the worsening climatic conditions of global warming. In fact the mean rate of approach has been between three and sixteen times this, dependent upon the particular spot metered. So it’s not so much the glacial and icecap melt causing the rapidly escalating erosion. That’s quite bad enough. It is the draw down of our beaches now allowing the sea to reach and destroy the natural dune defences and threatening to undermine our sea walls, and that’s brought about by intense and cumulative Offshore Aggregate Dredging.

The only ‘natural’ cause is land sink. Both Global Warming and Offshore sand mining are far greater factors, and both are entirely man created.

For full details please visit our MARINET website to read the main briefing under Marine Aggregate Dredging to be found in our Marine Briefing Paperl and my article on Coastal Defences to be seen by going to Why Canute Failed. That on the fallacy of current practice of beach recharge is also well worth a read.

Your study of the items on our website will provide the fully comprehensive detail on all of these points. In addition to those many already present we have placed yet another scientific research paper evidencing the shoreline erosion brought about by ongoing dredging detailed in the study report “Processes of selective grain transport and the formation of placers on beaches” by: Paul D. Komar, College of Oceanography, Oregon State University Corvallis, Oregon 97331 USA. and Chi Wang, Sandong College of Oenology, Quindao, the Peoples Republic of China).

Where previous papers such as the ‘Sandpit Report’ (to be found by visiting and the many other scientific papers have mainly shown that the increased beach slope due to gravitational and tidal born sand flow to the pits left after dredging is responsible, this one additionally deals with the loss of beach sand cohesivity brought about by dredging.

You can see it on our website under Evidence for the Anglian Offshore Dredging Association Confirming the Link Between Offshore Dredging and Erosion of the Adjacent Coastline. But I expect that along with all the rest of the authentic evidence, this too will be ignored in favour of partisan ‘evidence’ in favour of continuing the exploitation.

I trust and hope that this comprehensive reply will assist your awareness that all is not as it would at first appear on the surface over this exploitation of sand and gravel from our East Anglian (and other) offshore seabed(s) and that it will arm you with a sufficiency of evidence so as to further pursue the matter.

With best wishes and regards,

Yours Sincerely,
Pat Gowen

MARINET (the Marine Environmental Information Network) and the NSAG (North Sea Action Group)

Tel: (01603) 402554

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