Further objection to MMO licensing further dredging off Great Yarmouth – 15th Nov 2013

Rather an elongated communication, but felt to be necessary to spell out the details so as to fully cover our concerns and to contain sections that could be used by others objecting to this latest application.


Further objection to MMO1 Further objection to MMO2

Friday 15th November 2013

Dear Monika Van Wyk,

I write as founder chairman of MARINET, also as an individual who has already lost a coastal property to the sea at Hemsby without compensation due to dune and beach erosion and is about to lose another, probably this coming Winter, as the coastline disappears further.

I wish object to application MLA/2013/00417 requesting the issue of a licence for Volker Dredging to take a further 22.5 million metric tonnes (circa 14 million cubic metres) of marine aggregate from 18 kilometres off the Great Yarmouth coastline over the next 15 years, on the same grounds and with similar reasons supplied to the MMO when opposing applications MLA/2013/00119, MLA/201300306 & MLA/201300338. (see http://www.marinet.org.uk/campaign-article/objections-to-dredging-licence-renewal-offshore-to-great-yarmouth )

Were all these licences permitted it would take a total of over 108 million tonnes or 68 million cubic metres from these four sites combined, which just has to be seen as quite unsustainable.

Such intense cumulative deepening of the seabed increases the beach and shoreline slope, amplifying the sand cover run-off, so allowing the sea to reach the protective dune base to undermine and bringing about its loss. The deeper offshore sea also amplifies the wave height to further damage and export the beach sand and dune. Two storms this year, when the offshore seabed has been disturbed, resulted in a loss of 4 metres of sand depth and fifteen metres of dune face along much of the stretch of our East Anglian coastline from Happisburgh to Felixstowe, so threatening loss of amenity, wildlife, tourist facilities and the imminent loss of many coastal dwellings and businesses

These happenings that correlate the level and timing of dredging and shoreline erosion have not been noted in evidence supplied by Environmental Statements (EAs) which rely upon models that appear as being made from old wave studies made in 2004 at distant Felixstowe. There has been much change in the seabed since then, undoubtedly brought about by the dredging itself. No empirical long term post-dredging studies appear to have been applied since that time nine years ago.

MARINET met the representatives of EMU, who were acting on behalf of AODA, the Anglian Offshore Dredging Association to explore our rational reasons and needs for a scoping report and the institution of a more realistic study for EAs.

These reasons were that:

    1. We require a scientific study examining, on a historical basis, the correlation between dredging levels and timings in the offshore area and beach coastal erosion measurements, with empirically based erosion measurement for both before dredging commenced and since dredging commenced. We believe that all the scientific evidence for this particular study exists, and it simply requires commissioning as part of the Environmental Assessment (EA). If no such correlation is exists then and only then will the dredging companies have evidence to support their claim that no link between dredging and shoreline erosion exists, and they can be absolved.


    1. We require a scientific study of whether there is any measurable transfer of sand from the beaches where erosion is occurring to the offshore dredging sites. Such a study is simply and easily performed by means of tracer material placed on the adjacent beaches, and its movement monitored and recorded over a period of seven years following offshore dredging. This technique involves pre-existing established scientific practices, and has already been undertaken successfully elsewhere (Fylde coast, Lancashire). The dredging companies claim that there is no movement of material from the beaches to the dredging sites, so this study would confirm if the dredging companies or are correct in there presumption or are others who have found this.


    1. The EA must review the assumptions built into the computer modelling which informs the REA with regard to the offshore wave regime. The offshore wave regime and the height of waves arriving on the beaches is a key factor in coastal erosion. If the seabed is deepened by removal of the offshore seabed, the wave regime can be intensified and cause increased coastal erosion. This possibility/ probability of such needs to be verified. More importantly still, the existing wave regime model hitherto (originally formulated in connection with the licence application for adjacent Area 401/2 and applied to all other application sites) is now many years old, and takes no account of the dramatic changes that have occurred to the seabed since it was originally calculated. Furthermore, our own studies of the original Area 401/2 wave regime model has identified that there were significant flaws in the data used to calculate the model (land-based meteorological data was used rather than offshore meteorological data which is a valid procedure, provided it is adjusted to allow for the increased wind speeds that occur offshore and that the data is contemporaneous – however the wave model did not state that the wind speeds had been adjusted to allow for the “offshore weighting” and the land-based data was not contemporaneous but several years old). Therefore, there is a clear need for the REA made in 2010 to revisit the question of the offshore wave model. It simply is not acceptable that future licence applications are made on the basis of an out-of-date wave model, and a wave model too that suffers from serious suspicions as to its scientific integrity in its original conception. If the aggregate companies wish to convince as to their commitment to science, then a new wave model would be serious evidence of that commitment.


  1. Scroby Sands, which lies some distance offshore from Great Yarmouth offers protection from high waves by acting as a breaker. It used to be a significant offshore sandbank always lying permanently above the high tide level, and measuring 1 mile in length and one-quarter mile in width. It had sand dunes, resident terns and seals, and was a significant physical and ecological feature. Periodically storms would erode the exact dimensions, sometimes submerging the whole sandbank, but over time the original feature and its dimensions were always re-established. However, following the commencement of offshore dredging in the 1960s the erosion that followed one such particularly severe storm was not followed by re-instatement of the sandbank permanently above high tide level, and this significant ecological feature has never returned. At the present time, there is strong circumstantial evidence that offshore dredging, which removes sand from the surrounding area, is to blame. This evidence needs to be very carefully examined from a scientific perspective and correlated against wave regime predictions and measurements (an updated version, see item 3 above). If the REA were to do this, it would gain substantial credibility and acceptability. Without such a study of Scroby Sands, the belief will always be that the REA has been afraid of the truth and ran away from it.

Further, the points of issue raised in our MARINET meeting with EMU (the AODA consultants) that jointly established the vital need of meaningful tests and realistic Environmental Impact Assessments to be employed before a licence to dredge was issued have finally been shunned by the dredgers. After over a year of awaiting a response, hopefully an agreement, AODA finally indicated that they would continue as before without implementing or taking into consideration any of the vital needs, or positively answering any of our questions. Our points and questions put to AODA through EMU included the following:

    1. How is it that only the partisan claims of those selected by, appointed by and paid by the dredging companies themselves are considered when a dredging licence is sought, whilst the copious reports from non-aligned international expert bodies evidencing and recognising the erosive impact remain ignored.(see Scientific Studies Of Dredging Induced Erosion at http://www.marinet.org.uk/campaigns/scientific-studies)


    1. Why is no second opinion permitted when considering granting licences for offshore aggregate dredging when the view of the body selected by the dredging company conflicts with wider and well established independent findings?


    1. Why do the Environmental Impact Assessments continue to employ data based upon computerised outputs made using inputs of models created from speculative and assumed data rather than actual empirical findings? Why have these modelled claims been made without even testing them against meaningful and realistic empirical findings?


    1. Why have BMAPA and AODA consistently refused to carry out a sand-tracking study of material transported from the eroding coastlines to the dredging site voids in order to reveal the actual mobility and transport of the original shoreline material?


    1. Why are Aggregate Extraction Licences (EIA) issued without any attempt to evaluate the movement of offshore sand which feeds the coastal dune system? (Recent examples are EIAs issued for Area 457 Liverpool Bay and Areas 401/2 and 202/436 off Great Yarmouth. Such omissions of data obviously reduce ability to anticipate the effect extraction will have on the neighbouring coast, and therefore fail to protect the coast from erosion. Currently the EIAs do not track the sand lost from our shoreline, do not employ topical current data and neither do they perform practical empirical research. They only rely upon assumed data. We asked that they recognise the powerful correlation between dredging and erosion, but this point was declined to be considered by AODA).


    1. Why did Suffolk Coastal District Council, Halcrow, The Environment Agency, DEFRA, The Crown Estate, AODA and BMAPA combined still maintain that massive dredging operations are not responsible for coastal erosion when there exists not a shred of evidence to support that claim?


    1. Why have no significant and meaningful post-dredging impact studies been carried out following dredging, particularly cumulative mass dredging of multiple associate areas of the offshore seabed?


    1. On what basis do DEFRA (now MLA?) and the dredging companies ignore the copious independent international evidence that offshore aggregate dredging is responsible for coastal erosion? Even on the most simplistic basis is it not blatantly obvious that digging extensive pits offshore will promote gravitational tidal assisted sand movement from higher level areas, e.g. coastal deposits, and so steepen the shore profile, and therefore lead to beach 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). and coastal erosion?


    1. Why is there no attempt to look for, and to sponsor, significant empirical research that would show up the causal connection between dredging and coastal erosion?


    1. Is it not now generally accepted that Halcrow’s 1992 predictions for the sea approach over the Norfolk coastline covering 60 years, i.e. up to 2052, were underestimated by a factor of twelve, the forecast lines of approach given having already been crossed within 5 years? Is it not that this error was the consequence of Halcrow’s failure to take into account the effect of aggregate dredging off the coast? When the impact of dredging is taken into account, do not the actual coastal loss figures closely agree with this and so become fully explainable?


    1. Why do the Dutch use aggregate dredged off our coast, but ban dredging at similar depths and distances from off their own? Is it not because they evaluate and understand the damage to sea life and coastal erosion caused?


    1. Why is it that dredging off our coastline continues and additional dredging sites are being sought offshore to Norfolk and the Humber when BMAPA announced four years ago that the deposits on the East Coast were exhausted and that these areas would be abandoned in favour of the South Coast and Channel sites? Is it not apparent that these ‘new findings’ off Great Yarmouth (and Southwold) have been deposited by migration of material from the beaches, dunes, soft sand cliffs and protective sandbanks of the East Anglian and Humber coastlines?


    1. What influence on coastal shoreline stability do you feel is contributed by the loss of beach and seabed cohesivity due to the decreasing ratio of the coarse granular sand removed and that of non-cohesive ‘soft sand’ waste dumped overboard in dredging operations?


    1. Have BMAPA and the dredging companies considered the implementation of the Dutch idea of sub-seabed suction extraction so less destroying the surface faunafauna The animals characteristic of a region, period, or special environment and flora in order to assist stability and retain the existing eco-system?


  1. In the absence of government reimbursement of losses brought about by those losing their housing, businesses, income and amenity, and the loss of much original funding of coastal defences, have BMAPA considered overwriting these losses with a fund built from the considerable profits of their companies?

MARINET asserts that if all these questions were satisfactorily answered, then, and only then, would the dredgers be able to make their case and establish their claim that the considerable escalation of erosion has not been brought about by their activities.

One further point we wish for the MMO to note is that, in the case of dispute, a second opinion from a non-partisan party, financially unlinked, should be permitted as well.

In the light of past findings and existing evidence of the erosive impact of dredging induced erosion, we would ask that the MMO as a new body take notice this time and consequently refuse these proposals.

My apologies for a lengthy treatise, but it is considered necessary that this issue of the impact of marine aggregate dredging is brought to your attention for proper and thorough consideration.

Pat Gowen
17 Heath Crescent

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