House of Commons Crown Estate Inquiry, input from MARINET

This is the MARINET submission, dated 11th March 2010, to the House of Commons Treasury Select Committee considering “the Management of the Crown Estate”. Our submission provides evidence on how the Crown Estate and the UK Government have managed, and often mismanaged, the seabed, its ecosystem and the related coastline in order to exploit the seabed, which is owned by the Crown Estate, for sand and gravel.

Date: 11th March 2010

FAO: Treasury Committee

Subject: Submission — New Inquiry on the Management of the Crown Estate.

Specific: Concern on Marine Estate Offshore Aggregate Dredging Licensing provision

(1) Preamble

(a) Marine Aggregate Dredging Concern

MARINET and the North Sea Action Group (NSAG) would wish to bring to the new Inquiry on the Management of the Crown Estate, the Marine Estate being the ‘owners’ of the seabed from the low tide point to twelve miles offshore, our concern is regarding Crown Estate ready provision of licences to dredging companies to extract aggregate from the sea bed, particularly those permitting further exploitation off the coastline of East Anglia.

The majority of the product, around fifty seven per cent, is landed in UK ports and supplies the construction industry. Some eight per cent of the product is placed back on the shoreline to refurbish popular holiday beaches damaged by erosion (usually caused by the dredging itself!) and thirty five per cent of the product is taken abroad to overseas ports such as Nieupoort, Amsterdam and Flushing. The reason for this export of UK sand and gravel is because Holland and most of coastal Europe do not allow the commercial exploitation of the offshore seabed for aggregate materials due to the damage this would cause to their marine environment, shoreline and fishing industry. Holland and Belgium do not allow dredging of sand and gravel deposits within 25 km of their shoreline or in coastal waters whose depth is less than 20 metres other than to maintain the shipping channels essential for port navigation. Maps present in our briefing show all UK dredging sites well within these limits.

This process, known as Offshore Aggregate Dredging or Marine Aggregate Dredging, is seen to be environmentally damaging to the fishing industry, the marine ecosystem and to the shoreline, hence the local economy. MARINET & NSAG hold that the cost of the ongoing damage created to the shoreline, tourist industry and business, the sea bed eco-system, to longshore fishing and the aesthetic value of our seaside, coupled with the impending loss of our sea defences and the threatened inundation of The Broads and seven Norfolk villages is considerably greater than the economic gain made by the dredging companies, the Crown Estate and the Treasury, created by the dredging industry.

We further hold that the Environmental Impact Assessments (EIAs) demanded in the past by DETR, DEFRA, EA and now MFA are not fit for purpose, being deficient in their content, lacking in meaningful evidence and partisan to the commercial profit and short-term economic gain aspect only.

(b) Aggregate Levels Landed and results

Statistics provided by The Crown Estate and the British Marine Aggregates Production Association (BMAPA) show that over the past ten years alone over 20 million metric tonnes (ca 12 million cubic metres) of seabed have been removed nationally, 8.8 million tonnes from off the Great Yarmouth area alone. In fact some three times this level was dredged, with one third, the cohesive sand, coarse stone and shingle suitable for concrete manufacture screened out (<5mm in size) and gravel (5mm to 40mm in size) is then retained for landing at the wharf, and with two thirds washed back overboard to the sea to smother additional prior living seabed downtide.

Over the period of cumulative intensive dredging the sea has deepened between 3 and 5 metres, up to 80 metres of beach and dune have been eroded by the natural replacement demand of the voids remaining following removal of the dredged material. Sea defences are threatened by underminement, over 100 coastal bungalows have been lost to the ocean and the sea has advanced inland by up to 120 metres this, being some eight times that accountable for by sea rise and land sink. (1)

A further point is that when dispersed and arriving on the beaches, this finer less cohesive material replacing the previous more stable beach sand and shingle serves to destabilise the previous cohesivity so permitting wave action to further erode the shoreline. The deepening of the sea further permits wave of greater crest height so more erosive to further denude the beaches.

It is the shingle, coarse sand and grit that forms the habitat for fish spawning, their feeding ground and refuge. It is also a main flora bed. Sadly, this is the very material targeted by the dredgers, as this is the basis of the best concrete. It is no coincidence that fish stocks have diminished massively since offshore aggregate dredging escalated to such a level as today.

Finally, the lowering of the sandbanks close to the dredging sites, once with marram dunes, seal colonies and nesting terns, have resulted in their demise, and are now below water on all but the very lowest tides. This has markedly reduced their original ability to break the high waves onshore,,so further increasing the erosive impact.

(c) Profits from Aggregates

This trade is highly remunerative, not only to the companies concerned but to the Treasury also, who apply VAT at 17.5% on each tonne sold. The aggregate sells at ca £20-00 per metric tonne (£23-50 including VAT) thus the government coffers benefit by £3-50 for each tonne sold. Over the thirteen-year period between 1989 and 2002 the Treasury benefited by £1,031,342,805-50p. £479,500,000 of this revenue arose from the sand and gravel taken offshore to Norfolk. Altogether in just thirteen years the total government treasury income amounted to £1,178,677,942. A small fraction of this would be more than sufficient to protect our vulnerable coastline.

The Crown Estate benefits from the levy on each tonne of aggregate extracted as the fee for the licence provided. They receive royalties of between 40p and 60p for each metric tonne taken. The Crown Estate netted over £10 million in the year 2001-2002 from national offshore dredging, over £4.5 million of this from East Anglian capture alone where consequently the greatest level of erosion and loss of fish stock has resulted. Between 1989 and 2002 The Crown Estate benefited by £147,334,686-50p nationally, with £68,908,782 of this total coming from East Anglia’s offshore contribution alone.

(d) Licence Provision

For licence granting the DETR, later DEFRA, now the MFA, only take into account the information contained in EIAs (Environmental Impact Assessments) made for the dredgers licence applications by those selected, appointed and paid by the dredgers themselves. No other evidence is acknowledged and no second opinion is allowed. These EIAs intentionally do not research those issues that would provide meaningful evidence, nor do they follow up with post dredging research. It can take one or more years before the erosion results from a distant offshore dredging operation.

(e) Evidence of Impact

The MFA (and their predecessors) refuse to recognise any non-partisan independent research, and require no empirical research to qualify the computerized assumptions maintained to attempt to prove that offshore dredging is benign. Yet numerous independent scientific research projects show that erosion results from cumulative offshore aggregate dredging. The levels of resultant erosion of each area correlate quite powerfully with the levels dredged offshore, as does the lowering of the seabed when related to the cumulative active dredging areas. Thus, we have the situation that despite the overwhelming evidence of the damage created, not a single application for dredging off our eastern seaboard has ever been refused.

In addition to the many scientific papers from around the world on the erosion resulting from offshore sand and gravel dredging to be located by visiting our Marine Aggregate Dredging Campaign pages, others exist such as 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. Other important evidencing papers such as the ‘Sandpit Report’ (to be found by visiting http://sandpit.wldelft.nl/reportpage/reportpage.htm) show that the increased beach slope due to gravitational and tidal bourn sand flow to the pits left after dredging is responsible. Another additionally deals with the loss of beach sand cohesivity brought about by dredging to be seen under Evidence for the Anglian Offshore Dredging Association Confirming the Link Between Offshore Dredging and Erosion of the Adjacent Coastline. Our own correlation of cumulative dredging levels, timing and consequent loss of beach depth and tidal incursion is available at the conclusion of our comprehensive briefing on the overall impact of Marine Aggregate Dredging to be seen at Marinet Briefing Paper.

(f) History:

One hundred years ago, the British Government set up this Royal Commission on Coastal Erosion “…to reach some conclusion with regard to the amount of land which has been lost in recent years by the encroachment of the sea on the coasts of the United Kingdom…”. The Minutes of this appeared in 1908 and 1909, and the Final Report in 1911) expressed concern that removal of sand and gravel from beaches caused or accelerated coastal land loss.

There followed bitter arguments about the effects of extraction and how both the Government and the dredging contractors responded to land and property losses. The Government responded by setting up this Royal Commission on Coastal Erosion, following on the practice that Royal Commissions were established to inquire publicly about very important issues of national concern. This Royal Commission on Coastal Erosion that started work in 1907 presented its Final Report in 1911. It was required to inquire and report:

“a. As to the encroachment of the sea on various parts of the Coast of the United Kingdom and the damage which has been or is likely to be caused thereby; and what measures are desirable for the prevention of such damage”. It further considered what powers were needed for protection and if changes to the law were merited. The Royal Commission Final Report (1911 p.158) concluded:

“The removal of materials from many parts of the shores of the Kingdom and the dredging of material from below low water mark, have resulted in much erosion on neighbouring parts of the coast” and that “Removal of sediments from the shore should be illegal” (Para. 7(a) p.160).

It further recommended “systematic observations” of change below low water, deep water sediment travel and sandbanks movements for which “information at present is scanty and vague”. Little subsequent action was taken, nor has it to this day.

The Final Report (1911, Part II) said that on the basis of foreshore losses “the gradient of the foreshore must be becoming steeper.” (p.45). However, there was no recognition by the authorities of the implications. More recently, Taylor et al (2004) report that 61% of the coastline was steepening and 33% had flattened. This recognition, long before the onset of Global Warming, is critical to the debate about coastal changes, especially in the discussion of sand-mining impacts, as it indicates a progressive exposure of beaches to serious damage.

Despite the extensive damage to the English North Sea Coast in 1953, the Waverley Committee on Coastal Flooding (1954) failed to comment on this, but merely noted an increasing frequency of severe storms. However it stressed that research into the movements of beach material, offshore sand banks and related coastal problems was urgent (Summary of Recommendations Para. 114 -(3), p.28).

(g) Conclusion:

We are now in the grip of Global Warming induced sea rise, the governments ‘Managed Retreat’ policy no longer providing adequate protection of our coast and its infrastructure from the sea and under the auspices of the Shoreline Management Plan that has in effect written off large areas of our land to marine inundation. Further, with the Mediterranean tourist spots becoming too hot and too expensive for the ailing UK Pound exchange rate and the environmental and capital costs of flying, we need to retain our seaside and coastal resorts for the future. To permit the continuity of providing licences to an industry that is seen to further bring about such loss cannot be seen as aesthetically acceptable, morally and ethically viable nor economically sensible.

We ask that the Treasury Committee consider and ponder this serious situation and attempt to apply such measures as they feel fitting so as to maintain our precious shoreline and its attributes from plunder and the threatened loss of many low laying villages and areas of the best agricultural land in Britain, a vital necessity with world grain and food shortages on the horizon.

Yours Sincerely,

Pat Gowen
MARINET & NSAG

The HoC has published the report, including our contribution, as two volumes ISBN 978 0 215 55322 5 and ISBN 978 0 215 55320 1 on 22nd March ’10.

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