MARINET Briefing Paper

The protection of the oceans requires both knowledge and political effort, it demands an informed public and the involvement of all spheres of civil society in working with and putting pressure on the institutions of government and the private sector” — Nelson Mandela 

MARINET campaigns against offshore aggregate dredging (mining the seabed for sand and gravel) because of the adverse impact that this exploitative operation has upon the coastal environment and the marine ecosystem. MARINET is particularly concerned about the threat to sea defences and coastal communities, to the fish spawning areas and marine life on the seabed which are both intimately connected to the health of commercial fish stocks and the livelihood of fishermen. Not least, MARINET is worried by the threat that aggregate dredging places upon sensitive coastal habitats such as salt marshes, sand dune systems, sand cliffs and inland habitats which are vulnerable to coastal erosion.

This briefing is aimed at informing campaigners about what is happening to our coastline and seabed due to offshore dredging, and how this practice impacts upon both the human and natural environment. It is by no means an exhaustive and complete review or a comprehensive guide, but will give some degree of insight into the complex issues. For those wishing for greater detail and fuller information reference sources to further reading are supplied.

We are urging everyone, MPs, MEPs, councillors, Friends of the Earth groups and conservation organisations, as well as fishermen and residents of coastal areas, and even people who visit the sea for their holidays or recreation, to take this issue on board as a matter of extreme importance. We are asking you to assist us in opposing this continuing and ever escalating strip mining of the seabed. We are also asking you to respond to the advertised applications for offshore sand and gravel mining that are published in the local press, and to object to these dredging applications using the evidence of damage presented here.

Footnote: MARINET consists of Friends of the Earth Local Groups, individual FOE members, members of Greenpeace, the Green Party. the North Sea Action Group, fishermen, coastal dwellers, environmentalists, ecologists, conservationists, bird watchers and many people concerned about the well being of the marine and coastal environment. MARINET’s objective is to help members run their own campaigns by providing facts, information and expertise, so filling the void on marine issues not covered by National FOE.

About our Seashore

Our beaches consist of sand and shingle, often backed by dunes and cliffs. These loose shoreline materials tend to be eroded (washed out to sea) by high onshore waves and undertow – caused by onshore winds – mainly during the winter months. (The eroding power of a wave is proportional to the square of the wave height). Normally this mobile sand and shingle, were it available, would be replaced by the opposite flow between the sea and the coast brought about by offshore winds during the months of summer. Such redeposition cannot result when the offshore material is removed by dredging. Furthermore, beaches absorb much of the sea’s energy by the oscillation of trillions of grains of sand and so act as a natural protector of the coastline and inland areas.

Offshore banks in particular take out much of the eroding energy of waves before they reach the coastline. If offshore sand and shingle are stripped, the resulting void naturally demands replacement of this dredged material by both the downtide drift and inshore to offshore movement of sand and shingle. Thus loss of offshore banks erodes the nearshore beaches and coastline, undermines sea walls, dunes and cliffs, and allowing the recapture of vital parts of our coastline by the sea with a consequent threat to all coastal dwellers. At this time of more frequent severe gales and rapidly rising sea levels due to melting icecaps and glaciers, along with the thermal expansion of the warming oceans and allied by the tectonic sinkage coupled with government reduction in sea defence funding, such damage constitutes an unacceptable threat.

About our seabed

Most of our seabed consists of a chalk, marl and rock base covered by variable depths of coarse sand and shingle. This sand and shingle is mobile and can be moved offshore and onshore by changing tidal and weather patterns, as described above. Marine life abounds in these areas, whilst the sand and shingle provides the essential physical habitat for a vast range of marine animals and plants, including fish which not only feed here but use these habitats to spawn and support their juveniles. This sand and shingle is the very material that is being excavated by the aggregate companies who sell it on for the manufacture of the concrete widely used in the construction of motorways, airports and buildings. Unfortunately, to strip the seabed of this cover of sand and gravel and its living content is equivalent to removing all the topsoil from a garden, leaving only a bare area denuded of life. Evidence gathered by marine divers and fishermen shows that even twelve years after this marine ‘strip mining’ the devastated areas often show little sign of life other than a presence of passing migratory fish. (1)

Offshore Marine Aggregate Dredging Companies

Eleven different companies are involved in offshore aggregate stripping. The first eight are represented by BMAPA, the British Marine Aggregate Producers Association, 156 Buckingham Palace Road, London SW1W 9TR, telephone 020-7730 8194, e-mail email hidden; JavaScript is required or web site www.bmapa.org

  • Britannia Aggregates Limited
  • British Dredging Limited
  • Hanson Aggregates Marine Limited
  • Kendall Bros (Portsmouth) Limited
  • Northwood (Fareham) Limited
  • Norwest Sand and Ballast Limited
  • RMC Marine Limited
  • United Marine Aggregates Limited
  • Westminster Gravels Limited
  • Volker Dredging Limited
  • Van Oord ACZ

They take their sand and gravel from a licensed area of 1,413 square km using dredgers of 2,000 to 8,000 tonnes capacity on a continuous basis. The dredgers operate on the same principle as a vacuum cleaner to suck up the sea floor and all the life in it. Once aboard the dredger the material is screened for suitability (i.e. the commercially viable grade of sand and gravel needed). Over half of the dredged material is rejected because it is silt or the wrong size. This waste is discharged overboard back into the sea. The rejected material suspends in the water then slowly drifts downtide back onto the seabed where it smothers and, consequently, further damages marine habitats and fish spawning areas.

The coarse cohesive sand and grit, coupled with the rooting systems of the marine bed flora, binds the seabed together. The fine sand and silt constituting up to 70% of that dredged and that dumped overboard, does not. It is highly mobile, and thus prevents the re-establishment of the rooting of the seabed plants. When dispersed and arriving on the beaches, serves to destabilise the previous cohesivity so permitting wave action to further erode the shoreline.

The screened sand (<5mm in size) and gravel (5mm to 40mm in size) is then brought ashore. 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 25km 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.

What the aggregate is used for

It is claimed that the United Kingdom market and its ever increasing road and housing building programme demands an astounding 5.5 metric tonnes of aggregate per inhabitant per year. Once this all came from inland quarries, but now over one-third is coming from the seabed. Up to now some forty seven per cent of marine dredged aggregate has been taken from off the East Anglian coastline. However, this major source of supply is now close to depletion because of over dredging, so the companies involved are now moving their main activities to the eastern English Channel, the south coast, around the Isle of Wight, and even as far as Wales.

Sand and gravel dredged off Norfolk was used to construct both Sizewell ‘A’ and ‘B’ Nuclear Power Stations. Much is used in the government’s road programme. 200,000 metric tonnes is needed for the construction of every mile of motorway. Housing, car parks and new offices also take their toll. The Netherlands is the prime non-UK customer. The huge runways, perimeter tracks and buildings of Schipol International Airport were constructed entirely from sand and gravel dredged off Norfolk, whilst even greater amounts were used to build up the Dutch Sea defences, a strategy that threatened East Anglians regard with incredulity. The Dutch restore their beaches with 9 million cubic metres of sand annually, compared with just 2 million in Britain.

The levels of seabed taken

The first recorded offshore dredging impact was when 382,000 cubic metres (660,000 tons) of sand and shingle were dredged offshore to the south Devon village of Hallsands between 1897 and 1902. It resulted in a rapid four metre lowering of the entire length of the beach, leading to the erosion of the cliffs; this followed by the complete destruction of the entire village itself within 18 years. The full and grim details are to be found at www.hallsands.org.uk and are given in the book ‘Hallsands – A Village Betrayed’ by Steve Malia, ISBN: 0 9536852 4 1 , published by Forest Publishing, price £4.99 from bookshops or available by sending a cheque for £6.99 (inc. P&P) payable to Steve Melia at 29 Heather Park, South Brent, Devon TQ10 9PU

The following photographs were taken by David Barrett of Norfolk during his visit to the stricken village in 2004, showing the remains and the boards telling the story.

 

Hallsands 1
Hallsands 2

Hallsands 3

The awareness that Offshore Aggregate Dredging is responsible for coastal erosion is not exactly new. The British Association for the Advancement of Science established a Committee in 1883 “for the purpose of inquiring into the rate of erosion of the Sea-Coasts of England and Wales, and the influence of the artificial abstraction of shingle and other materials in that action”, so demonstrating a strong indication of public and scientific concern even then. It reported in 1885 that shingle extraction was causing loss of land and property. Extensive land slide and shore retreat accompanying the 1897 North Sea storm surge increased public pressure for action to be taken.

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 then 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).

Analysis of the Royal Commission on Coastal Erosion Minutes of Evidence reveals the causes of coast erosion reported by engineers and geologists (those professional groups commonly advising the coast protection authorities) as ‘wave action and the removal of beach material for road-making and construction’. Although extraction in some locations directly affected beach-loss, the links with offshore extraction were poorly described. By the 1960s extraction of sand and gravel from beaches had been stopped but offshore extraction of aggregates increased. Although extraction from beaches for commercial reasons is not now allowed, in theory at least, in practice removal does occur when downdrift beaches are used as sources.

The first major seabed mining off the East Anglian coastline commenced in 1973 when just three million tonnes were taken. The extraction rate then rose each following year. By 1992 the annual removal rate had risen to 18 million tonnes. In 1996 26.1 million metric tonnes were taken, mostly captured offshore of Lincolnshire, Norfolk and Suffolk. As a result, since 1979 many beaches and dunes that had been accreting for the past one hundred years began to show serious losses increasing year by year. This loss of shoreline, the sea encroachment and beach stripping correlates powerfully with the distance, levels and timings of the dredging operations. (2)

In 2001 and again in 2002, 21.9 million metric tonnes of seabed was taken nationally, a slight reduction on 2000 when 23.05 million metric tonnes was removed. In the twelve years between 1989 and 2003 a total of 113,937,813 tonnes was taken offshore to Norfolk alone. However it must be recognised that more than three times the quantities listed were actually stripped from the seabed because the non-commercial large stones, fine material and silt, all surplus to requirement, are dumped back overboard and into the sea as waste.

Facts & Statistics relating to Marine Aggregate Dredging

(Source: Marine Sand and Gravel Information Service (MAGIS).

Regional Dredging Statistics from 1st January 1 2002 to 31st December 2002 showing the total tonnages taken from the seabed off each region of the UK.

Dredging Area Permitted (licensed) Removal Actual take in tonnes
Humber 4,650,000 3,023,227
East Anglia 12,575,000 9,011,323
Thames 3,700,000 1,647,795
South 11,175,000 5,756,644
South West 3,191,000 1,467,122
North West 1,384,999 482,270
Rivers and Misc n/a 545,302
TOTAL 36,675,999 21,933,683

Historic Extraction by Area Statistics showing the total tonnage extracted from the seabed from 1989-2002 denoted by the region where taken.

Extraction Area Total Removed
Humber 24,852,566
East Anglia 137,817,564
Thames 21,752,324
South Coast 75,069,066
South West Coast 30,336,752
North West Coast 4,841,101
Rivers and Misc 1,005,752
TOTAL 295,675,125

 

The Crown Estate is the landowner of the seabed from the low tide point to twelve miles offshore. They grant the licences and receive royalties 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.

The aggregate sells at £20-00 per metric tonne carrying 17.5% VAT (£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 so 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, with more than five times this sum going to the dredging companies coffers. A small fraction of this would be more than sufficient to protect our vulnerable coastline.

Presently there are 72 licences in force nationally for the dredging of just under 1,500 square kilometres of seabed, from which 14,742,316 metric tonnes of aggregate have yet to be removed. The majority of these licences are off the Lincolnshire and Norfolk coasts. (3). However, as most of the East Anglian seabed has now been stripped, attention is being focused on the eastern English Channel and south coast deposits plus those further to the west. Consequently the unique shingle beaches of Dungeness and their rare flora are now under threat as are the beautiful beaches of the Gower Peninsula of Wales. The vulnerable ecosystem of the English Channel and its scallop and sole stocks are also at risk.

The Losses Account 1: property, housing & tourism

Unlike those in Europe, people in the UK who lose their property or livelihood due to coastal erosion are not compensated, even when sea defences are denied them under ‘Managed Retreat’ alias ‘Coastal Realignment’. In theory, managed retreat has the potential to preserve and even create valuable wildlife habitat as well as building the beaches lost because of earlier dredging. The alternative is ‘coastal squeeze’, where coastal habitats are slowly lost between the rising sea and hard defences. However, managing a coastline for wildlife protection can have a negative impact on the villages and houses in which people live. Dredging and the impacts of climate change are causing real dilemmas about how far both wildlife and human habitats can be protected. Communities must be involved in decisions about how to manage their coastlines, and the effects of offshore dredging must become part of the analysis. Whilst ‘Managed Retreat’ would work well if the material released by erosion from the dunes, sand cliffs and shoreline were free to migrate naturally, thus helping rebuild depleted downtide areas and so take part in the offshore-onshore supply, this ideal cannot possibly come about when most of the freed sand and gravel is taken by offshore dredging.

Household insurance in high-risk coastal areas is denied, the risk being too great when charging even the very highest of premiums. Only the most highly valued properties qualify for protection by government funding. It has to be proved that the value of the property defended is at least twice the cost of the defence scheme itself. With concrete sea walls costing £10,000 per metre, i.e. ten million pounds a kilometre, central government states that such funding is in very short supply.

If a local authority wishes to provide the funding for vital sea defences, and in doing so exceeds its allotted expenditure budget, it is likely to find itself rate-capped. No value appears to be attributed to natural areas or to many wildlife sites and small groups of houses. As a result smaller villages, remote residences, SSSIs (Sites of Special Scientific Interest), salt marshes, sand cliffs, tern and seal colonies, coastal pathways, beach accesses and promenades, coastal farms and many of our most beautiful beaches and coastal areas are being written off. Those beaches that still remain are rapidly becoming foreshortened, denuded of sand, steeper and stonier, thus adversely damaging that part of the local economy which is dependent on holiday visitors and popular tourism.

At Hemsby North Marrams on Norfolk’s East Coast, where once there once were 98 bungalows, only five now remain. (Your author lost his bungalow there on 1st March 1988. It had stood there since 1930 on what was, prior to offshore dredging, an advancing beach and dune system). Hemsby once had a 150-metre sandy, gently sloping and safe beach. It is now reduced to a stony, three metre steepened beach at high tide.

Happisburgh on Norfolk’s north coast has lost its sea defences, coast road and thirty residences, along with its beach and lifeboat ramp. (4) Covehithe in Suffolk has lost its beach access, promenade and coastal defences. Felixstowe, Southwold and Aldeburgh have all lost much of their beaches. Both Trimingham and Overstrand in North Norfolk have lost their coast roads, and in Yorkshire both the farms and the road to Spurn Head were lost to the sea due to erosion following dredging off the Humber Estuary. Photographs of some of the damage caused along the East Anglian coastline may be seen on NSAG (North Sea Action Group) website http://members.aol.com/wwanglia/gowen1.htm under the item ‘Our Disappearing Coastline’. Further information on damage to the beaches of the Welsh Gower Peninsula due to marine aggregate dredging is on the Gower Save Our Sands web site www.gower-sos.com or by sending an e-mail to email hidden; JavaScript is required In Cornwall sand is being directly stripped from the beach.

The Losses Account 2: living & livelihood

Fishermen are losing their fishing grounds and hence their livelihood. What few longshore fishermen remain now have to go many miles further out to sea to avoid the dredgers, a very hazardous occupation for fishermen in small boats. Many fishermen are finding that what have been excellent fishing areas since living memory are now completely denuded of fish following dredging, and these areas have not even partially recovered after eight years. The coarse sand and gravel demanded by the dredgers are the very nursery areas where the fish spawn, consequently fish stocks are severely hit.

Richard Docwra, Chairman of the Caister Inshore Fishermen’s Association (5) has witnessed first hand the damage that results to fish stocks due from offshore dredging. Where once he caught plaice, sole, dab, and shrimp, he now catches nothing except for a few cod. “Since the area has been dredged all the original sea life has disappeared, and is still not even partially recovered after ten years” he says. A further problem is that the erosion of the foreshore results in steep vertical beach drops of over two metres. “At times I cannot even launch my boat for days at a time” he complains. Richard is now having to sell his boats and business.

David Bryant, shell fisherman of Lutton in Lincolnshire found that his catches were decimated following dredging of his prime fishing grounds in The Wash. He started a court case against the dredgers but the sheer cost forced him to abandon it. He had to travel a further fifty miles down the coast to make a living, spending far more in time and fuel costs than affordable; this eventually forcing him to abandon fishing.

Rodney and Graham Burns of the Aldeburgh Fishing Guild, who fished the Suffolk coast for over thirty years, found their means of earning becoming increasingly harder. They testified, “Before dredging commenced offshore to Orford Lighthouse seventeen years ago we had a prime fishing ground out there. Since then there’s been no fish there whatsoever. The whole area is now devastated. We cannot understand the government saying that they want to preserve fish stocks when at the same time they are allowing taking away the fishing grounds” they concluded. (6) Because of the loss of their fishing grounds, both have since had to give up fishing for a living.

Paul Lines, Secretary of the Great Yarmouth and District Fishermen’s Association, tells a similar story. “Whole areas of the seabed are wiped out where they dredge. Where once we had a good fishery seven to eight miles out from the Corton Sands to the back of Scroby, the entire area has been wiped out. We now have to go 15 miles out before we can start fishing, which is very hazardous for a thirty foot boat.”

Paul Lines explains that there is no food or habitat left for the fish in what were once prime fishing areas. He also tells how the silt produced by the dredging operation smothers other areas that once were productive fisheries. His constant complaints and continuing evidence of the damage are ignored. “They [the aggregate companies, The Crown Estate, DoE, DETR, DEFRA and the ODPM] [see footnote] do not take the findings of the fishermen into account” says Paul. “They tell us that we have no science to back up our findings and ignore us, despite the fact that we are the ones who see the evidence first hand.”(7)

Release of the fine sediment by the dredgers is known by shell fisherman like John Loose of Burnham and John and Geraldine Greene of Stiffkey to be one of the main causes of the serious loss of cockles, mussels, shrimp and other shellfish around the dredging areas of The Wash. Since dredging began stocks have been lowered annually. The Royal Society for the Protection of Birds (RSPB) are concerned by the loss of oystercatchers and other waders which have been reduced by over 70% in the past six years. The loss of shellfish, the birds’ food supply, is thought to be responsible for the decline, whilst the increasing incidence of toxic algae that bring about Paralytic Shellfish Poisoning (PSP) may be seen as another factor. PSP makes the shellfish unfit for human consumption, thus resulting in the closure of the shell fishery.

Footnote: The NRA, the National Rivers Authority, then the DoE, the Department of the Environment, followed by the DETR, the Department of the Environment, Transport and the Regions, once attended to all marine aggregate dredging matters. These duties were then passed to DEFRA, the Department of the Environment, Food and Rural Affairs. Licence applications are currently addressed by the ODPM, the Office of the Deputy Prime Minister.
Paul Joy, Chairman of Hastings Fishermen Protection Society, wrote in ‘Fishing News’ “Dredging was not only damaging the seabed, but the noise it generated interfered severely with the migration of sole and other species”. He added that the proposed plans to switch commercial dredging from the coast to the middle English Channel might look more attractive to Hastings fishermen as it would take dredging from the inshore fishing grounds but, in his opinion, the long term effects could ultimately cause more harm. (8)

John Wells Findings

Testifying at a meeting of MARINET and the Great Yarmouth Probus held at Great Yarmouth on 18th April 2007, John Wells, member of Coastwatch and a fishermen of the area, told how once the fishermen would go out accompanying the dredgers. The invitation resulted from the local fishermen’s complaints made at meetings with DEFRA, MAFF and the dredgers, where they expressed concern at dredging the herring spawning grounds and the huge numbers of fry (immature plaice, sole, dabs, etc.) that were being captured with the sand and gravel.

As the dredgers vehemently denied this, it was agreed that some of the fishermen should accompany the dredging operations so as to monitor and evidence that this did not occur in practice. But the precise opposite resulted, as they soon found on close inspection of the catch that the content of small fish in the take was enormous. When the fishermen presented this evidence, pointing out that if they had captured and landed such, they would undoubtedly receive a hefty fine, they were then debarred from the missions on grounds of the friction that resulted with BMAPA.

John Wells also testified how the Scroby sand bank had depleted seriously since 1973, with a half mile stretch suddenly lost that year and a further three quarters of a mile of the easterly end disappearing between 1974 and 1975. He pointed out that it was the firm opinion of both the fishermen and the offshore wind turbine operators that dredging to the immediate east had brought about instability of the turbine bases, as a 5 degree tilt of the masts of the northernmost four had resulted, bringing about damage to the turbine gears due to the eccentricity produced.

The Losses Account 3: the danger to life

In the great North Sea surge of 1953 307 people drowned and over 20,000 were left homeless in East Anglia when the dune sea defences failed. The responsibility fell heavily on the shoulders of the government of the time, which, despite numerous warnings, had failed to maintain them. Indeed, the worst hit areas were those considered to be amply protected by natural coastal dunes. These same dunes are now eroding rapidly, and this erosion has been greatly accelerated by offshore dredging. Moreover, the more severe storms due to global warming will be soon be occurring with a probability of once every ten years (with a future prediction of once in five years) whereas in the past it was stated as a probability of once every 50 years. All this is at a time when sea levels are rising fast and funding for sea defences is being reduced, yet aggregate extraction for private profit continues apace due to the exclusive demands of a market driven economy.

The Losses Account 4: the marine environment and its eco-system

Since large scale dredging commenced thirty five per cent of Norfolk’s salt marshes have disappeared. The unique Great Winterton Valley site of special scientific interest (SSSI) and European site) has in the past seven years lost 100 metres of sand dunes, its seal colony, its little tern colony and its beach and beach access to the sea. The famous Cley and Salthouse RAMSAR site is retreating rapidly since it lost most of its shingle bank which kept the sea at bay for over five hundred years. The ecology of the seabed has been severely damaged and its biomass is seriously depleted. Naturalist divers find that where once the seabed abounded in marine life and a stable ecosystem, it is now a marine desert and denuded of life. The natural sandy seabed habitat no longer exists, and dredging has left nothing but the bare chalk base in places (9)

The “Seas At Risk” Group, headed by Roger Lankester, fears that the deep holes made in the seabed may be causing an imbalance in the sea. For example, it is known that nutrients, originating from historic sewage discharges and now locked in the seabed, can be freed by deep bait digging by fishermen and, significantly, the impact of dredging could be producing this same effect on a far larger scale. Nutrient imbalance is known to be the main cause of algal blooms. Some of these algal blooms are toxic, thus bringing about shellfish bans and causing further damage to the marine environment and the fishing industry. Phaeocystis Pouchetti has increased ten fold in the past fifteen years. This is a non-toxic algae, but one which denudes the sea of oxygen and releases di-methyl-sulphide which oxidises in sunlight and the air to produce sulphurous and sulphuric acid, this contributing thirty per cent of the acid rain that falls on Europe. (10)
Please see www.scotland.gov.uk/Publications/2006/02/03095327/8 for further detailed information.

The Good News

It is customary to follow the bad news by the good news. Sadly, this is in short supply unless one is a shareholder in a marine aggregate company or a marine archaeologist. The stripping of our beaches and sand dunes has revealed several historical wrecks. For example, six metres below the authors Hemsby bungalow site a coaster that sank in 1799 with the loss of all thirteen hands suddenly reappeared in 2000 when the sands which covered it were lost due to offshore dredging. At Holme next the Sea in Northwest Norfolk a many thousand-year-old Neolithic site, in the form of inverted circular oak trees, was also exposed in 2000. Due to its structural similarity to Stonehenge it was immediately named “Seahenge”. More ominously, many accretion covered World War II bombs, shells and mines, plus wartime barbed wire fences and landing craft traps have now been exposed as a result of the erosion brought about by offshore dredging.

The ‘Justification’

Dredging licences are issued by the Crown Estate. Prior to 2001, licences followed a non-statutory procedure of obtaining a “Favourable Government View” from the DETR. Since then responsibility for the Government View procedure has passed to the Office of the Deputy Prime Minister (ODPM) which, in conjunction with DEFRA (the successor to the DETR), now requires an Environmental Impact Assessment (EIA) to be conducted. This requirement for an EIA, which is expected to become a statutory requirement soon now, is a clear improvement on the past. Sadly, the EIAs which have been inspected up to now have not been of the highest quality and, because they are paid for by the dredging companies themselves, there have arisen serious doubts about the objectivity of some of these EIAs.

H.R.Wallingford is a company which has authored EIAs and, in particular, the Coastal Impact Study within EIAs. The company was privatised in 1982 under the Thatcher government. Since then the company has become far less involved with independent, empirical research and has become instead more reliant on financially viable contracts for its income. Dr. Stephen Huntingdon, the company’s Operations Director, confirmed this in his evidence to the House of Commons Environment Committee (HoC Env Com) in 1992 when he stated that the company had “altered the balance between consultancy work and research, partly in order to maintain its income in a commercial environment”. The House of Commons Environment Committee noted that licence decisions were exclusively dependent on the company’s evidence and were unsupported by a second opinion. The Committee stated their concern by saying, “the conclusions reached by HR Wallingford are never scrutinised for second opinion”. This need for a second opinion was supported by MAFF and the NRA, but this up to now this has never come about.

MARINET’s EIA Study

Tim Deere-Jones, a marine environment and pollution consultant who was also MARINET’s founder chairman made a close study of the EIA’s produced for marine aggregate licence applications. (11) His main observations were:

  1. The EIAs operated to a basic framework (now codified in MMG1) and represented a welcome advance over previous methods of assessing and protecting the environment.
  2. Benthic biological research (study of marine life in and on the seabed) in UK waters was inadequate, and existing research (and EIAs) totally ignored the impact on meio and micro benthic fauna (creatures smaller than 5 hundredths of a millimetre e.g. bacteria and larvae) which are at the base of the food chain. Biological predictions were inherently unreliable because the baseline data was so weak. As regards the impact upon fish stocks and the environment in general, inspection showed that the methodology used in the surveys was inadequate, as was the assessment of the impact on the environment and the mitigation measures that were proposed. He noted that no conservation status has been attached to any UK benthic gravel sites, and that the post dredging impact on these sites was only measured over five days of dredging activity, when in fact the dredging took place over ten or twenty years periods. No consideration was given to the likelihood of the release of anaerobic or toxic materials as a result of disturbance and sand cover stripping that could give rise to anoxic conditions.
  3. Research into coastal impacts (e.g. erosion of the coastline) was inadequate and widely recognised to be an inexact science. He noted that the science itself is unduly reliant on the use of outdated principles, hypothetical and numerical models and upon computer simulations which are based on inadequate data. Thus the predictive ability of coastal impact studies is inherently weak. He found the studies in the EIAs of the impact of dredging on coastal erosion were very limited and under-researched, despite the fact that seabed sediment transport takes place at depths of over 100 metres, and he found that the EIAs used both limited and assumed data in computer based models whilst ignoring the actual findings made by local fishermen from their net movements. Furthermore, no long term effects, no cumulative effect and no wide ranging impact studies had taken place at those down-tide areas likely to be deprived of their beach nourishment as a result of offshore-inshore sand and gravel movement.
  4. Most EIAs contained a lack of information on viable alternative aggregate sources. He noted that the recycling of building waste can prove to be a good alternative aggregate material whilst the material from the dredging undertaken to keep ports open and navigable was wastefully dumped at sea instead of used as marine derived aggregate. None of these alternative sources were considered in the EIAs studied.
  5. T Deere Jones concluded (2000 B ) “the EIA process for marine aggregate extraction proposals is in disarray and is characterised by poor practice, inadequate historical baseline data, inadequate current empirical research at both site specific and national level, and a lack of will at the Government (DETR/Assembly/Crown Estate) level to oversee or impose the process.”
  6. No wave climate measurements took place over the long term period required to give data on the effect of dredging on wave heights and directions producing erosion, nor on major water (hence sediment) movement in conditions such as winter and storm periods.

WWF and the Wildlife Trusts Study of ES

The World Wildlife Fund (WWF) and the Wildlife Trusts published a similar study by Dr. Miles Hoskin and David Marshall in 2003. (12) The authors reviewed five Environmental Statements (ES) written in support of licence applications made between 1999-2000. They expressed and noted concern on several matters regarding the general approach to science and scientific writing in the ESs. These included:

  • A heavy reliance on existing environmental data not obtained for the purpose for which they were being used, resulting in a less reliable assessment of likely impacts than data which is sampled for that purpose.
  • Scientific methods were rarely summarised in sufficient detail to fully provide a clear understanding of what was done, or to judge its relevance and reliability.
  • The language used gave the impression that assessments made were infallible truths rather than fallible predictions. (In reality, the actual impacts of aggregate extraction can only be known once it is underway).
  • Many statements of fact were made without reference to the original source of supporting information.
  • The logic underpinning conclusions about likely impacts was often highly questionable.
  • All EIAs required certain aspects of work to be done by specialist consultants that were sub-contracted for that purpose.

The ES did not present the sub-contractor’s report in full, only a summary. However, it was not clear whether these summaries were written or approved by the specialist contractor. With regard to the main areas of study in the ES which Hoskin and Marshall reviewed, they concluded “The best aspects were the descriptions of the proposed activity, physical description of the extraction area and predictions of interactions with other uses of the sea.” (e.g. shipping, underwater cables, archaeological sites, etc).

The poorest aspects of the ES were those relating to ecology and fisheries. “There is an acute need for improved guidance on several aspects of the assessment process and for greater communication between the consultants, government and other stakeholders regarding the quality of ES documents.” Yet a further excellent independent study by Susan Gubbay was published by the WWF and the Wildlife Trusts in 2003. (13) Virtually identical conclusions to those of Hoskin and Marshall were reached.

The Eurosion report, available online at the Eurosion website www.eurosion.org reads “Dredging of river and seabed for navigational purposes or construction purposes removes an important amount of sediments. This creates a sediment starvation which is in certain circumstances compensated by (re)activating erosion processes along the shore areas. This has proved to be the case in a significant number of cases including Cove do Vapor (Portugal), the Western Scheldt Estuary (Netherlands and Belgium), Donegal (Ireland), Cavado (Portugal), and North Norfolk (UK).”

The question put to a key member of the Eurosion team by Norman Lamb MP was “Does offshore dredging cause coastal erosion?” The answer was an unequivocal “Yes ! Of course !”. Chapter 1.5.4. ‘Erosion’ (page 45), the final Eurosion document (which is intended to be the state of the art document to which all EU member Governments and Municipal Authorities refer) under the header ‘Sand Mining and Dredging’ states: “Whereas beach nourishments may have a positive effect on coastal erosion, sediment extraction for sand mining locally attributes to erosion of the foreshore of the coast and may lead to erosion of the beach and dune system on the longer term. Local deepening of the sea-floor can alter wave patterns and cause gradients in sediment transports, resulting in local erosion.”

The North Carolina Public Radio broadcast by the American Corps of Engineers stated that their research and empirical data continued to demonstrate that offshore dredging creates environmental damage to coastal ecosystems as well as leading to increased erosion.

The dredging of inlets and offshore shoals for sand fill increases onshore erosion according to the EU’s 2004 “Guide to Coastal Erosion Management”. It further states this causes sediment starvation and hydraulic changes inducing even more erosion. A 2000 research abstract for the Minerals Management Service (USA) states “When a shoal is flattened [by dredging], the degree of wave energy concentration is likely to be reduced, resulting in greater wave energies hitting the coastal area. This may result in increased coastal erosion or unwanted, detrimental changes in longshore or nearshore current patterns. Significant coastal impacts could also be expected during storm events in that increased wave energies which might have been somewhat dissipated by the presence of the shoal would now impact the coastal area with greater forces.”

Thus speak the experts, but not the apologists for the dredging companies, nor our Environment Agency, nor our governments ministers, who in the face of known findings continue to claim that there is no evidence that marine sand and gravel extraction causes erosion, and place the blame for it exclusively on earlier defence provision and upon the increase in storm severity and sea rise brought about by Global Warming.

The irony of the situation is that those who oppose offshore dredging on grounds of realistic evidence and actual findings are charged by the authorities of having ‘no scientific basis’ to their arguments, when the reality is that it is the deficient EIAs and the resulting UK claims that lack a trustworthy scientific basis!

The most recent United Marine Dredging Application

In September 2002 a new application by UMD (United Marine Dredging, a sister company of United Marine Aggregates) appeared asking for a new licence to dredge a further 7.5 million tonnes of sand over 15 years from Area 254, known as the Cross Sands, situated 10km offshore to Great Yarmouth. (14) It was approved. This area has already been dredged twice in the past fifteen years, yet new aggregate has appeared, a process said to be impossible by the authorities who claim that such deposits are not mobile. Of course, the fresh sand could only have come from the eroding shoreline as the north to south sedimentary drift has virtually ceased now due to dredger capture off the northerly Yorkshire and Lincolnshire coast and The Wash. This supply previously came across The Wash to the north and eastern Norfolk and Suffolk coast. The cost of a copy of the EIA for Area 254, produced by EMU, UMD’s consultants (with the same address as UMD) was £80-00. Upon reading a borrowed copy it became immediately obvious that many incorrect assumptions about the impact on fish, shellfish and the marine benthos in general had been made. ‘Low impacts’ were claimed upon benthic macro faunal diversity, abundance and biomass. ‘Low impacts’ were also claimed with regard to silt smothering, benthic invertebrate species spawning, and the adverse effects on plankton through light loss due to suspended silt.

As well as claiming a ‘low impact’ due to the effects of aggregate and silt overspill on shellfish and bottom dwelling fish, it was also asserted that there would be ‘low impact’ with regard to the loss of prey and key fish. Similar claims were made with regard to the sonic effects upon migratory fish and shellfish routes, the spawning of fish and juvenile fish, and the effect of the noise and disturbance upon sea-bird populations, on breeding and feeding marine mammals and basking sharks and on designated nature conservation areas and species of conservation importance. These were all given either a zero or a low significance status and, as such, it was claimed that they required no monitoring, no investigation and no mitigation. Only one issue was admitted to be of moderate significance. This was the impact of the dredging operation on the herring spawning ground. Yet, despite the impact being listed as being of moderate significance no mitigation or monitoring was recommended, other than liaison with DEFRA and CEFAS. Furthermore, because the EIA assumed there to be a lack of precision regarding the location of the herring spawning beds, it was suggested that the impact could not be determined. The authors obviously had not consulted with the local fishermen who know the exact location of the spawning grounds and who know that these exist in the areas of coarse sand and grit, the very material demanded by the dredgers.

With regard to the physical impact on the coastline (i.e. the erosion of beaches, sand cliffs and dunes and the draw-down of sand from beaches into the dredged areas, the possibility of stonier beaches and steeper beach slopes, and the possibility of increased wave height due to the removal or lowering of offshore sandbanks). United Marine Dredging’s EIA suggested the following inadequate impact assessments and their negative response to them:

Area of Concern Predicted Significance claimed Monitoring/Action Required
Increase in turbidity Low None required
Mobility of sediment Low Some localised monitoring only
Change to seabed sediment Low Some localised monitoring only
Beach draw-down (erosion) Low to none None required
Impact on offshore sandbanks None None required
Increase in coastal wave height Low None required
Changes to tidal currents Low None required
Disruption of sediment supply to dependent coastline Low to none None required
Impact on water quality None None required

 

Thus it can clearly be seen by the denial of predicted impacts as recorded above that the well-documented evidence of damage, as well as the long expressed concerns of local inhabitants and fishermen, have been totally ignored. There is still no recommendation of research into the long-term impact, thus reinforcing the “Catch 22” situation whereby if there is no research then there is no official evidence, and if there is no official evidence then there is no need for any research.

As a result, the erroneous assumptions that characterise and underlie many marine aggregate EIAs continue to hold sway and believed by the authorities in government, so aggregate dredging continues to be permitted. Another apposite metaphor (this time of British rather than American origin) which summarises the situation is that of Horatio Nelson who placed a telescope to his blind eye to declare “I see no ships.” Indeed, he did not. However those who really looked could clearly see the threat.

Indeed, not even the precautionary principle has been heeded, let alone the very obvious evidence produced by independent studies of past dredging operations. The fundamental concern is that the United Marine Dredging EIA makes a number of entirely unfounded assumptions in place of researched facts. The report lacks investigative evidence, is grossly incomplete and thus cannot be seen to be an unbiased and independent document. The criticisms made by Tim Deere-Jones, Susan Gubbay, Miles Hoskins and David Marshall in their studies of previous EIAs for WWF-UK and The Wildlife Trusts are, most regrettably, amply illustrated by this dredging application and its EIA.

Is Further Research vital – or just recognition of that already accomplished?

Top world Coastal Geomorphologist Professor John Pethick, recognising that sources of sand which supply the shoreline come from offshore banks, has similar concerns to those of MARINET. He says “We must not dredge these banks, otherwise it will increase the erosion, the very reverse of what is required!” (15)

Internationally renowned Coastal Geomorphologist Professor Constantine Goudas is highly concerned of the threat given by Offshore Aggregate Dredging and fully supports the cessation of this (mal)practice. He, like many other independent experts, completely supports MARINET in its opposing stance.

Dr. Martin George of the Broads Authority Advisory Committee, 1990 – 1994 environmental adviser to the National River’s Authority Anglian Regional Flood Defence Committee was very concerned on the adverse impact of offshore dredging taking place off the Norfolk coastline. He proposed research to investigate the issue, but was fobbed off by the NRA who claimed they were unable to afford the cost as it was far too expensive. He recognises that the dramatic increase of coastal erosion over the past twenty years cannot be ascribed solely to Climatic Change, and has come to the view that offshore dredging is a contributor.

Alan Brampton of the recently privatised hydraulics consulting company H.R. Wallingford points out that the seabed “naturally accumulates sand and fills out the bumps and hollows with material from the coast”. He freely admits that he is engaged in “an inexact science” and that “sediment transport is very difficult to model”. Yet it is such modelling, uniquely provided by his company and financed by the dredging companies, that is used to support further dredging! Moreover, Wallingford’s Brampton has so far done all the work on modelling of the impact of dredging proposals nationally.

In 1992 the House of Commons Environment Committee report on Coastal Planning and Protection complained, “We were concerned to find that the whole area of the impact of marine aggregate extraction on the coastal zone is under-researched and based on premises years out of date.”

Tony Murray, head of Marine Estates Offshore of The Crown Estate, once expressed the hope that the assumptions made by the modelling for each specific dredging area would ensure that no major damage was done. Now he admits that these studies undertaken for each individual dredging proposal may not be enough. “There is concern about a cumulative effect of lots of dredging licences. We have research looking into that.” He said. It was widely recognised that to be of value it had to do more than merely review the old Wallingford data which appeared to have been the limits of work so far.

Where once the NRA claimed that dredging had no effect upon erosion, the Environment Agency is now slowly beginning to recognise the facts of the situation. Once in public meetings their spokesmen stated “research has shown that there should be no effect”. They later modified this to “there could be some effect”. Now they say “there could well be impact, but we don’t really know, as no research has been done”. (16) But the NRA aided funding of a research project by Hull University to investigate the full effects of the problem.

The study in question is the ‘SNSSTS’, the ‘Southern North Sea Sediment Transport Study’. This research, recommended and advised by the Halcrow report is now available on the Internet. This is important reading, and gives good insight into sediment movement, although still limited in the full understanding of the escalated sand and shingle movement that occurs under winter surge conditions. It further raises almost as many questions it answers on sediment movement and removal. Thus, it is still incomplete and may not provide the conclusive evidence in time to save our rapidly decaying coastline.

In 1996 Sir William Halcrow and Partners (Burderop Park, Swindon, Wiltshire SN4 0QD, telephone 01793-812479, telex 44844 Halwil G, fax 01793-812089) produced their ‘Sheringham to Lowestoft Shoreline Consultation Plan, Sediment Sub-cell 3B. It showed grave concern about flooding of the 6,000 low-lying hectares in Norfolk behind the sea defences. In respect of the eroding dunes, it stated a real threat exists. “Were the present defences to be removed, the backing dunes are no longer substantial enough to provide a natural defence and would not ‘roll back with’ but would be vulnerable to breaching, and thus leave the whole area open to inundation.”

Under “Further Studies and Data Requirements. 3.1.2. Offshore Banks” it stated: “The sandbanks which lie offshore of the Norfolk and Suffolk coast are known to be of significance to shoreline development. However, whilst bank development is believed to be understood, their direct implications for specific shoreline locations are not well known and the impact of changes to these banks is not sufficiently understood. It is therefore considered essential to future shoreline management that research into the onshore-offshore interaction is carried out… whilst it is known that sediment exchange occurs between the shoreline and the offshore areas, it is not clear how, and importantly where material is transported offshore. This requires a detailed examination of nearshore processes and sediment movements.” Para. 3.1.3 reads: “…a reappraisal of the transport processes and the sediment budget is warranted. This is extremely important to strategic development and should be undertaken prior to further review of the strategy.”

Quotations from MPs and MEPs

Tony Wright MP (Lab.Great Yarmouth) like former Lowestoft MP David Porter (Con) raised the subject in the House of Commons, but neither could get a positive response from the Minister. Both MPs want to ban the export of aggregate. Locally, forty-seven per cent of that dredged offshore to his constituency is exported to The Netherlands. Tony Wright said, “We have seen severe coastal erosion. I believe that some of this is due to the dredging of aggregates. If we can cease export, which constitutes one third of the total taken, it will save some of the seabed” he said. He is continuing to push the Minister on this matter. (17)

Former Environment Minister John Gummer MP (Con. Suffolk Coastal) in respect of the continuing offshore aggregate dredging said “I’m concerned about the fishing, but much more worried about its effect upon the way the tides work and how it effects our coastline. I’ve got 74 miles of coastline, all of it exposed to the growing storms and the higher sea levels that come from global warming. To make it worse would be devastating! I feel that there’s some urgent work to be done.” (18)

Dr. Caroline Lucas MEP (Green, South East) says, “It seems to me that as this activity is damaging the coastline to such a great extent exports should be stopped straight away. The other issue is how much of this need for aggregate can come from recycling. We need legislation to mandate this.” (19)

In fact, 36 million tonnes of construction waste ends up in UK landfill sites each year, three times more waste than the nation’s 21 million households put together. Further, it is escalating. It is estimated that less than 10% of the UK’s construction waste is recycled, in marked contrast to Germany and The Netherlands, both of which re-use or recycle 80% of their construction waste. In Denmark it exceeds 90%. In most cases such can be directly used as base aggregate, filler, etc. or can be modified to use for concrete, so dramatically reducing that exploited unnecessarily from our seabed.

Damion Green MP, previous Conservative Shadow Spokesman on the Environment said “The government should be setting out very clear guidelines saying that if long term environmental damage is being caused by an activity then it should be in the power of local authorities to stop this happening. I think there is enough evidence that inevitably, if you continuously dredge in one area then you are going to get long term damage. We should apply a precautionary principle that if we think there is a danger of long-term damage that would be permanent then we should stop doing it. Clearly, this is an area where you would get cumulative problems. We should use much more recycled material in roads and use more renewable energy.” (20)

Christopher Beazley MEP (Con. Eastern Region) stated “The research” (for the granting of licences) “is still insufficient, and because there is therefore no evidence they” (the government) “assume that they can go ahead and grant permission. There is an economic clash between real interests and the treasury” (21)

Norman Lamb (Lib-Dem, North Norfolk) wrote “I have been concerned about the impact of dredging on coastal erosion for a number of years. I am also unhappy about the fact that the Crown Estate will not disclose how much income they receive for individual dredging consents. This seems to me to be an issue of public interest. I would like to see more research into the impact of dredging. I am very concerned about the potential impact of dredging off the coast. When I asked for the total sum paid in licence fees to the Crown Estates in respect of each site and was told that this was commercially confidential I realised that there was a potential conflict of interest, hidden from public view. There was a financial interest in granting licences but no one knows what it is. Surely this information must be in the public domain? Whilst I am not in a position to judge the extent of the threat it is clear that everything you do to the seabed has a knock on effect. In the meantime, the precautionary principle should apply” (22)

Recognising the semantics within previous government assertions that “there was no evidence to suggest a link between offshore aggregate dredging and coastal erosion” had not satisfactorily explained whether dredging had contributed to coastal erosion, Norman Lamb asked a further Parliamentary Question of Elliot Morley on 8th January 2004. The reply again was “There was no evidence that offshore dredging had any effect on coastal erosion”. Note the semantic wording chosen by the Minister, “was” and not “is”.

Could this be due to the fact that despite copious levels of independent evidence detailing serious damage supplied to Elliot Morley’s Department over the past ten years the only ‘research’ the government has ever acknowledged is that supplied in Environmental Impact Assessments made by partisan private companies selectively hired, appointed by and paid for by the eight dredging companies themselves? These have continuously failed to address and investigate the long term cumulative damage done to our beaches, sand cliffs, coastal housing and fishing industry by the lucrative seabed mining, the results of which are already clearly apparent. It would appear that the findings of non-aligned research need recognition rather than that more research is needed, otherwise an excuse for postponement of cessation of dredging is created.

Henry Bellingham (Con) North West Norfolk, in an interview with the author stated “Where there is almost certainly some public support for some dredging where there is an immediate local benefit, for example recharging sea defences or building local infrastructure, there is no support whatsoever for the dredging of a local national resource simply for that resource to be exported abroad” (23)

Official Myopia

The North Sea Action Group, along with the Norfolk County Council, the Parish Councils of Mundesley, Sea Palling and Waxham and many more have long asked that commercial offshore dredging be suspended unless it can be proved that the operation does not contribute to beach erosion.

Despite objections by a broad range opinion and organisations (including the North Sea Action Group, Norwich and Broadland Friends of the Earth, along with the Councils of Great Yarmouth, Waveney and North Norfolk, many Parish Councils, hundreds of East Anglian fishermen, environmentalists, coastal dwellers and other concerned individuals to each and every published dredging licence application, along with formal protests to the Crown Estate, the National Rivers Authority, DoE, DETR, DEFRA and the Minister of the Environment, the reality is that offshore commercial dredging for sand and gravel has continued. In fact, every single licence application but one sought has so far been approved.

Government Responses – and the lack of them

Despite the overwhelming evidence of the loss of fish and shellfish stocks, the destruction of marine habitats and the obvious seriously escalating erosion along so much of the East Anglian coastline, all of which clearly correlates with the offshore extraction of sand and gravel, the response from Tony Baldry, Junior Environment Minister to questions raised in the House of Commons, was “We have no evidence to indicate that sand and gravel extraction is damaging natural sea defences and increasing the vulnerability of coastal areas to flooding”. This statement demonstrated either deliberate evasion of responsibility, or serious myopia, because copious amounts of evidence and practical findings have been submitted to the Ministry for study.

In a 13th September 1996 letter, in response to this author’s evidence and concern, the Department of the Environment wrote: “I must emphasise that all applications for dredging are rigorously examined against the government’s policies to achieve sustainable development and ensure the protection of the coastline and fish stocks. We consider that this examination of dredging proposals is adequate and, whilst research into the protection of both the coastline and fish stocks is ongoing, there is no case for a unilateral cessation of all dredging until further research has taken place”.

But the ‘rigorous examination’ claimed is only concerned with the erosive effect produced by enhanced wave action on that part of the coastline immediately opposite to the area exploited. The “examination” takes no account of the joint effect to down drift areas, nor any account of changed marine channelling, nor of the sum effect of cumulative dredging operations collectively, nor of the destabilisation of the seabed once denuded of plant life and coarse sediment. As previously stated, the damage to the eco-system and fishing has never been fully or properly researched in Britain. If one does not seek the evidence, one can neither see it nor discover it. This may well be the intention. Thus, it appears that enshrined financial interests are paramount, the environment is compromised and, especially, that the precautionary approach is totally absent from the governments consideration and concern. Short-term profits are in vogue, and long term damage and economic loss appear to remain ignored as a result of the Government’s singular concern for money.

Tides of Change?

In late March 2001, possibly as a result of escalating protest, the DETR announced at last that they had begun consultation on new guidance rules covering the extraction of minerals from the seabed. Their draft guidance made proposals for a new policy framework for sustainable development of marine mineral resources in English territorial waters. The DETR said they intended to provide the dredging industry with “sufficient access to suitable long term resources to meet its varied markets, while ensuring that the extraction of the mineral does not have an unacceptable impact on the marine or coastal environments, or on other legitimate uses of the sea”. Whilst these two contradictory objectives can clearly be seen as mutually exclusive, it was to be hoped that some degree of compromise might be possible.

The Current Government’s Marine Policy.

Recently the Government (DEFRA) and English Nature have published important policy statements. In the case of DEFRA, this is titled ‘Safeguarding Our Seas’ (Product Code PB 6187, obtainable from DEFRA Publications by telephoning 08459-556000). It required the dredgers to be tracked by GPS monitoring. Prior to this at least one dredging company was observed by members of the National Rivers Authority Anglian Regional Flood Defence Committee to be engaged in dredging much closer to the Norfolk shoreline than its licence permitted, undoubtedly the cause of the sudden and very rapid escalation of the erosion experienced.

The DEFRA policy statement argued that management should follow an “ecosystem-based approach” and that government and coastal/marine authorities should align their actions to achieve “integrated coastal zone management”. In the case of English Nature, their policy statement is titled ‘State of Nature: Maritime – getting on an even keel’ (ISBN 1 85716 6474, obtainable from English Nature Publications, tel. 01733-455000).

English Nature state “From the evidence we have studied we conclude that, despite the efforts made so far to protect it, the state of marine and coastal biodiversity is not good enough. Much coastal habitat has been lost, and the seabed has in most places been highly modified, and so less capable of supporting a rich biodiversity. The marine ecosystem is showing signs of significant stress and low resilience to continuing pressure. All this adds up to an alarm call for those who use and manage our coasts and seas and care about the future”.

The Fishermen’s bodies say that they want all mineral extraction to take place under licensing conditions which are as tightly controlled as those for inland aggregate extraction, whilst MARINET and the North Sea Action Group want to see all offshore dredging terminated unless it can be evidenced that no damage to the marine ecosystem or the coastline will result from the practice. As an interim measure, our organisations wish to see the export of the aggregate ceased and the increased use of building waste, tarmac scrapings, kaolin spoil, crushed glass, etc.

The Government’s guidance proposals suggest that their objective for a “sustainable” marine aggregate industry can be met by the careful location of new dredging areas, and by considering new licence applications in the light of an environmental impact assessment which assesses the impact on both the coast and the marine environment. Further, the guidance suggests exerting control through legally enforceable attachments to any permission given and by requiring operators to monitor the environmental impact both during and on completion of the dredging operation. Copies of the consultation document are available free of cost from Alan Clayton of the DETR by ‘phoning him on 020-7944 3872, by sending an e-mail to him at www.planning.detr.gov.uk/conindex.htm or by sending him a fax message asking for the document to 020-7944 3859.

The first of two central government planning documents ‘Minerals Planning Guidance Note 6’ (MPG6) was published in 1994. It stated that dredging for marine minerals may cause disturbance to fisheries and the marine environment, particularly in areas of special sensitivity. It stated that “proposals to dredge must therefore have full regard to the impact on the marine environment, sea fisheries and the potential effects upon the coastline. There is a presumption against extraction unless the environmental and coastal impact issues are satisfactorily resolved”. (24) However, MPG6 has now largely been superseded by more recent guidance specifically on marine aggregate extraction with Marine Mineral Guidance Note 1 (MMG1) published in 2002. The original ‘presumption against extraction’ has been restated as “The government wishes to see the continued use of marine dredged sand and gravel to the extent that this remains consistent with the principles of sustainable development.” (25) But MMG1 fails to define “the principles of sustainable development” only continuing to say “To achieve this, the dredging industry requires sufficient access to suitable long-term resources to meet its varied and fluctuating markets and to provide it with sufficient confidence to invest in new ships and wharves” so ensuring that the marine dredging industry will continue on a long term economic basis by investing even further in the process. From the Government’s perspective, the definition of sustainability appears to be the preservation of employment, profitable business and the continued right to plunder marine sand and gravel, and decidedly not the environmental definition of sustainability, i.e. the protection of marine and coastal biodiversity and its physical habitats. However, MMG1 does add, “At the same time, it is important that dredging activities do not significantly harm the environment or fisheries or unacceptably affect other legitimate uses of the sea.” It begs their definition of the words ‘significantly’ and ‘legitimate’. MMG1 suggests that the potential danger of significant harm to the marine environment and fisheries is best identified by new proposals and the renewal of expiring licences to undergo a non-statutory licensing procedure known as obtaining a favourable ‘Government View’. This is based upon the provisions of MMG1 and operated at the present time by the Office of the Deputy Prime Minister (ODPM). It requires (in Section 11) that the total area of seabed authorised for minerals dredging be kept at a minimum and (in Section 14) that a precautionary approach is required of the Government in its consideration of new dredging applications and that (in Section 16) an Environmental Impact Assessment (EIA) accompanies every application. The governments MMG1 document proposes that in future the Environmental Impact Assessment produced to cover the application for a licence to dredge the seabed must cover and address number of specific investigations as follows:-

  • a description of the proposed activity
  • a description of the physical nature of the seabed
  • a description of the biological status of the proposed dredging area
  • a description of other users of the area (e.g. fishing, waste disposal, submarine cables, etc)
  • an assessment of the physical effects of dredging
  • an assessment of the biological effects of dredging
  • an assessment of the effect on other users of the sea
  • an assessment of cumulative impacts
  • a programme of measures designed to address significant adverse effects from dredging, and
  • a programme of environmental monitoring to detect significant adverse biological and physical impacts.

At a first glance this Government View procedure appears to be a strong instrument capable of protecting the marine environment, especially as the Crown Estate can only issue a licence if the dredging company has, via its EIA, succeeded in obtaining a favourable Government View. Further, ODPM has proposed that the Government View procedure should in 2003 be superseded by a statutory system that will include provisions for a Public Inquiry if necessary.

Undoubtedly as a result of the demands of MMG1, there is now evidence that the assessment of new applications appears to be far better. For example, a far more responsible document was published by Entec UK Limited in their June 2003 Environmental Impact Assessment Scoping Report on the Application to the Crown Estate by UMD/Van Oord to dredge 7.5 million tonnes of sand and gravel over the next fifteen years from an area located in The Wash off the east Lincolnshire and north Norfolk coastline, where many highly sensitive habitats including RAMSAR sites, SPAs, SSSIs, NNRs, LNRs, AoSPs and SCAs are located.

Entec UK Ltd recognised virtually all of the effects likely to occur as a result of dredging, including sediment plumes drifting long distances, sediment deposition, the impact on fish migration, the results of cumulative dredging, displacement of fish stocks, destruction of marine habitat and spawning grounds. It also gave the impact on the north Norfolk coast, the effect on wave climate, sediment transport, tidal pathways and damage to the coast due to changes in currents as well as the lowering of offshore banks. The EIA Scoping Report included the impact on the precious nature conservation sites, on marine ecology, on species and their habitats as well as seabirds and seals. In fact, Entec’s EIA addresses everything except alternative sources of aggregate. It would be most surprising therefore if this application is approved !

The Shortcomings

The Environmental Impact Assessments (EIAs) now proposed by the ODPM are intended for all new licence applications for offshore dredging areas. But EIAs are not demanded for those areas already licensed but yet to be dredged (they constitute an area of seabed even greater than those currently being exploited), nor are they demanded for those areas now being dredged, neither those areas already dredged. Research on these long dredged sites could clearly provide the evidence to demonstrate the long-term cause and effect of aggregate dredging, but such research is not even contemplated at the present time. Sadly the Government, despite the early warnings and findings (remember the amazing BSE saga?), ignores the writing on the wall, and requires absolute and irrefutable proof of damage before it will consider realistic intervention in any money making venture. All this despite the fact that, even in monetarist terms, the long term losses to our fishing industry, environment, coastal holiday businesses and housing exceed by many times even those vast profits being made by the few.

Even if offshore dredging were to cease today, the natural demand to replace seabed material by the depleted dredged-out areas will persist. These areas, dependent on the distance offshore and the amount removed will continue to reclaim their losses from our shoreline for at least seven years or more before a sediment balance is re-established. It is already too late for many coastal areas and fishing grounds. As the Prince of Wales said in his address to the North Sea Conference: “Whilst the investigation is ongoing, the patient may die.” Unfortunately, the official verdict and its findings, along with the required action, may come far too late to prevent further and ever more serious environmental damage, as well as loss of life and livelihood.

Summary

Whilst we rightfully blame over fishing for the decline in our fish stocks and global warming for the rise in sea temperature and level, increasing storm frequency and severity, and hence the serious threat to our coastal areas, these must be added to by the more direct threat of the damage brought about by stripping of our offshore sand and gravel. The drift of sediment and the onshore-offshore balance of our beaches, dunes and sand cliffs is being seriously impacted by this continuing and escalating exploitation. At the same time as the government claims to wish to preserve fish stocks, the marine habitat and the feeding and spawning areas for fish are being progressively and systematically damaged by continuing and escalating offshore aggregate dredging. For this damaging practice to continue at a time when sea levels are rising, CO2 capping targets are being reduced, sea defence funding cut, all resulting in vital areas of our shoreline being consigned to the sea without compensation or reimbursement to the losers, is an unacceptable, unreasonable and unequitable situation that needs immediate addressing.

What you can do

Unless we can mount a well-supported and effective campaign, it is considered unlikely that any realistic cessation or curtailment of such highly profitable and damaging exploitation will come about, as powerful vested interests exist throughout all stages of the operation. It is not that the damage is unknown or cannot be foreseen, but that the decision to continue to dredge our seabed is based upon pure profit to the few at the expense and detriment of the many. The assurances peddled of ‘no damage’ are based upon pure presumption and not on the facts as evidenced.

If you wish to see beaches and living seas for the next generation, and if you wish to see continuity of sustainable coastal fishing as well as to continue to enjoy our rich and diverse wildlife and beautiful coastline, write, e-mail, fax or telephone your constituency MP expressing your concern at the damage and danger being brought about by the continuity of offshore aggregate dredging. Ask that as a minimum he/she joins other coastal MPs to try to stop the export of our shoreline and that, in the long term, your MP supports full abandonment of the damaging exploitation of sand and shingle from our seabed. Ask that he/she will place a parliamentary question based on your evidence and concern, and that he/she will ask of DEFRA and ODPM what progress has been made toward terminating the damaging practice of offshore aggregate dredging.

Send your letter to your MP at the House of Commons, London SW1A 1AA. If you don’t know who your MP is, use the website www.locata.co.uk/commons or telephone the House of Commons on 020-7219 3000. Write also to your area MEP asking for their support for an end to this practice and if he/she will align with the many Green MEPs in the European Parliament who are trying so hard to protect our environment. Watch out for local Press Notices indicating applications for further dredging areas and send your objection, using some of the evidence and arguments provided in this Briefing Paper, and send it to the return address supplied within the Press Notice.

When marine issues, flooding, erosion, fish stocks and beaches are topical and in the news, as they surely will be as increasing and escalating damage results, write a letter for publication to the press and use the radio and TV ‘phone-in’ programmes to make people aware of what is going on hidden beneath the waves, because that impact will surely affect their future and that of their children and grandchildren.

You are welcome to join MARINET. FOE Local Groups are entitled to full membership whilst non-FOE groups and individuals are entitled to affiliate membership. Membership is free at the present time, although a donation to funds would always be most welcome.

References

  1. Verbal evidence to author given by Great Yarmouth naturalist & diver Percy Trett Jr. and colleagues.
  2. See graph on the last page correlating offshore dredging tonnage removal, beach depth loss and sea encroachment along a 10km stretch of coast between Winterton and Caister-on-Sea between 1971 and 1997.
  3. Figures produced by BMAPA, British Marine Aggregate Production Association.
  4. For detail and pictures see Happisburgh Save our Shoreline web site www.happisburgh.org.uk
  5. Richard Docwra of the Caister Inshore Fishermen’s Association is on e-mail at email hidden; JavaScript is required
  6. Interview on BBC TV’s ‘East at Westminster’ programme.
  7. Interviews on BBC TV’s ‘East at Westminster’ and BBC-1 TV’s ‘Countryfile’ programmes.
  8. ‘Fishing News’ 15th November 2002.
  9. Report by Percy Trett Junior, Gt Yarmouth diver, writer and naturalist. See also pre and post dredging of seabed photographs on http://members.aol.com/ruraleye/gowen4a.htm
  10. ‘Tommorrow’s World’, BBC-1 TV, 1999.
  11. The Biological Impacts & Effects on the Coast of Marine Aggregate Extraction in UK Waters (2000 A) and ‘A Review of Selected Environmental Assessments & Environmental Statements produced for Marine Aggregate Extraction Proposals for Dredging Areas 372/1, 372/2, 446/447, 452 and 454 by Tim Deere-Jones. (Commissioned by the UK Wildlife Trusts and WWF UK) (2000 B).
  12. Marine Aggregate Extraction — A review of selected environmental statements, 2003, a report to the Joint Marine Programme of the Wildlife Trusts and WWF-UK by Dr. Miles Hoskin and David Marshall, available from Lisa Browning, Marine Conservation Officer of the Wildlife Trusts in south east, e-mail email hidden; JavaScript is required
  13. ‘Marine aggregate extraction and biodiversity — Information, issues and gaps in understanding’ by Susan Gubbay, also available from Lisa Browning, Marine Conservation Officer of the Wildlife Trusts in the south east, e-mail email hidden; JavaScript is required
  14. UMD/Van Oord ACZ Application for a Licence to Dredge Marine Aggregate in Area 481 (Inner Dowsing) Environmental Impact Assessment – Scoping Report. Entec UK Limited.
  15. As (5) in dealing with attempting dredging the Sizewell Bank that protects the nuclear power plants.
  16. Verbal replies to questions posed by the author at meetings held on coastal erosion and the impact of offshore dredging at Skegness, Lowestoft, Winterton-on-Sea, the North Sea Flood Conference, etc.
  17. As (6)
  18. Interview on BBC-1 TV’s ‘Countryfile’ programme.
  19. All as (6)
  20. All as (6)
  21. All as (6)
  22. Letter to author 9th October 2003.
  23. Interview with author 18th October 2002.
  24. Mineral Planning Guidance Note 6, ODPM, 1994.
  25. Marine Minerals Guidance Note 1. ODPM 2002.
V13.2b 04/01/2004. Written for MARINET and Friends of the Earth by Patrick J.A.Gowen JP MIST, Chairman of MARINET & Head of the North Sea Action Group, 17 Heath Crescent, Hellesdon , Norwich, Norfolk NR6 6XD. Tel/fax/answerphone 01603-402554. Mobile ‘phone 07767-041443 E-mail email hidden; JavaScript is required
Note 1:   This briefing will be updated by separate releases as new pertinent information becomes available.
Note 2:   The following photographs and much of this treatise is based on findings made on the shores and seas of the East Coast as it was here that the first major offshore aggregate dredging operations took place, where the greatest amount of sand and gravel has been taken over the longest period and consequently where the greatest level of damage has resulted. There is no reason to believe other than that similar impacts will also result in the other areas now being contemplated for marine aggregate dredging. Even if the requirements of MMG1 are strictly enforced legally they will not apply to those areas already being dredged, nor those already licensed for future dredging. Hopefully those concerned for these areas and for coastal areas where new applications for dredging will arise can benefit from these findings and take precautionary measures before damage to the shoreline and marine environment results.
“The protection of the oceans requires both knowledge and political effort, it demands an informed public and the involvement of all spheres of civil society in working with and putting pressure on the institutions of government and the private sector” – Nelson Mandela

The Visible Results of Offshore Aggregate Dredging

seabed 1
The seabed offshore to Great Yarmouth prior to dredging operations showing the sand and fine gravel cover replete with shellfish, starfish, sea plants, etc. Such provides a refuge, a spawning bed, a feeding ground and a habitat for fish and larger marine creatures whilst at the same time the roots and binders of the resident population stabilises the sand deposit preventing its migration.

 

 

seabed 2
The same area following dredging, showing it denuded of sand and shingle cover and all life, leaving only the largest stones exposed on the bare chalk base. What sand and shingle remains is now left destabilised allowing strong tides to sweep it away. Evidence shows that the area has not nearly recovered its biodiversity even after 20 years.

 

 

 

Hemsby Beach
The demise of some of the 98 bungalows at Hemsby North Marrams on the eastern Norfolk coast, which lost three lines of coastal bungalows and three major dune systems in the twenty years following the commencement of large scale cumulative offshore aggregate dredging. The bungalows had stood since the early ninteen-thirties on a previously acreting dune and beach and dunes system.

 

Weybourne BeachWeybourne on the North Norfolk coast, showing the loss of its sea defences and the ever steepening and stonier beach resulting as it lost its sand due to offshore reinstatement demand from the dredged offshore areas and the loss of sediment supply from the north.

 

 

 

 

 

 

 

Wreck of Coaster

The wreck of a coaster that sank with the loss of all fourteen hands in 1799. Its presence was previously unknown as it was buried seven metres under the author’s bungalow, covered for almost two hundred years by a once accreting dune system. But following ten years of a huge increase in offshore aggregate dredging 115 metres of dune were undermined and seven metres of sand was stripped from the beach. Only five coastal bungalows now remain of an original ninety eight that stood for over sixty years at Hemsby North Marrams.

Happisburgh
Happisburgh on the north east Norfolk coast, where thirty bungalows have been lost to the sea. The ‘chimney’ is an old well once over 300 metres inland, scoured out of the cliff as the sea encroached. Happisburgh has lost a further twenty metres since this photograph was taken. The cliff edge is now up to the wall of the hotel seen at the top left of the picture. The road has disappeared completely.

Time lapse photographs taken of Winterton-on-Sea dunes from the same spot.

Time lapse 1
Winterton Dunes in north east Norfolk, showing the extensive dune system in 1953. The seven ton 2 x 2 x 3 metre concrete blocks formed a World War II defensive line erected in 1939 to make things difficult for any attempted invasion. As can be seen by the far horizon they stood some 100 metres from the shoreline edge on a gradually accreting dune and beach system until soon after intensive offshore dredging commenced some twenty years later.

Time lapse 2
Winterton-on-Sea dunes taken from the same spot in July 2002, showing the WW-II ‘tank trap’ defences still with rich marram grass around them, but with the blocks now only ten metres from the dune edge.

 

 

Time lapse 3

A further photograph of Winterton-on-Sea dunes taken from the same spot just two months later in September 2002, now showing the huge blocks scattered on the lowered beach ten metres below. As more sand was stripped from the beach it markedly lowered, allowing the sea to come right up to the dune base, so eroding the banks and bringing about the collapse of the prior natural defences. A further 20 metres of dune have been lost since then. Winterton has been denied coastal defences.

 

Sea Palling
North east Norfolk’s Sea Palling beach, once a 150 metre sandy beach and dune system, stripped down to the marl and clay with not a grain of sand left until restoration. This was accomplished by installing offshore bunds of Norwegian rock to break the waves and by pumping on many thousands of tonnes of sand dredged offshore. Although effective for Sea Palling it was not without consequences to downtide Waxham and Winterton that due to the arrest of sand supply have demonstrated severe erosion ever since.

 

dredger
A dredger in operation three miles offshore to Great Yarmouth, Norfolk. The non-commercial silt can be seen being discharged back to the sea from the vessel’s port side. This pollutes the sea for a considerable distance downtide, eventually settling on the seabed to smother other adjacent living areas.

 

 

Winterton-on-Sea
An aerial view of Winterton-on-Sea taken in 2003, showing the erosion of the beach, sand cliff and dunes. Ten years ago the beach extended to the lower left hand corner of the picture. Since then continuing erosion has taken a further twenty metres, resulting in the loss of the Coastwatch Lookout seen as the white tower. The edge is now up to the beach-side café seen just beyond.

 

Heacham
Heacham in north-west Norfolk, once extensive and entirely sandy beach, showing its capture by huge cuts lowering the beach and eroding the protective bank. The coastal bungalows behind this are now threatened. Note that whilst the sand has been lost, much of the stonier shingle remains.

 

Licensed dredging areas and sites around the UK

map1map2

 

Above Left   sites currently being dredged around the United Kingdom in red.
Above Right   licensed areas indexed (from The Crown Estate).
Below   the huge dredging area offshore to Great Yarmouth, Norfolk

map3
The above maps are acknowledged to BMAPA and to The Crown Estate. They can be seen in greater detail by going to their web sites, www.bmapa.org and www.thecrownestate.co.uk/42_dredge_areas_and_statistics where further information may be found.

Correlations of Offshore Dredging levels with Coastal Losses.

 

graph

The graph shows the delayed correlation between the accumulated levels taken by offshore aggregate dredging as Extraction in millions of metric tonnes up to 1994 -purple-, the sea incursion by the mean of the tidal reach in metres as Tide Mark -blue- and the mean beach sand depth level stripped as Sand Loss up to 1997 -yellow- also in metres.

 

 

 

 

The survey took place over a 10Km shoreline between North Winterton-on-Sea and California, Norfolk, between 1972 and 1997, with the data taken four times per year in January, April, July and October. Over the period of the study the total offshore aggregate removed rose from close on zero up to 260 million metric tonnes, with the majority coming from the site mapped on the previous page.

Over the period of the study the mean tidemark encroached 115 metres whilst six metres of sand was stripped from the beach, producing underminement leading to the loss of three of the previously stable dune hills that had supported coastal bungalows. Prior to the commencement of offshore aggregate dredging these beaches were accreting, as indeed they had been for the previous eighty years. The build up ceased within two years and the loss of sand and shoreline became noticeable some three years after East Anglian offshore dredging commenced between Winterton-on-Sea and Corton in Suffolk, increasing year by year after this. Severe erosion then followed along the Suffolk coastline, later in Essex also.

Whilst sea rise due to thermal expansion, melting icecaps and glaciers, added to by escalating, stronger and more frequent northerly gales due to Global Warming, these added to by East Anglian sinkage, have all significantly contributed to the loss of coastline and beach sand, the marked correlation shown powerfully links the main shoreline loss to the retarded natural recapture of coastal sand deposits by the dredged out offshore areas. The increase of erosive wave energy due to the loss of offshore wave breaking potential is a further aggravating factor when sand and gravel are taken from areas immediately opposite the vulnerable coastline.

Finale

If we continue to allow the exploitation of our offshore sand and gravel, particularly at this time of sea rise and worsening climate, now that funding for coastal defence has been reduced and reimbursement for loss refused, we shall soon be faced by a huge loss of our coastline, its productivity, its villages and many inland communities reliant upon marine protection. We shall also see the final demise of our longshore fishing industry and its associate businesses. Your pressure to curb the exploitation is essential for a sustainable coastal and offshore future.

First written by Pat Gowen 04/01/05
Updated 16th December 2007 to V.13.4

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