MARINET responds to attack from Marine Aggregate Industry

The pot calls the kettle black!

On 1st June 2004 the Maritime Journal published on their website ‘Aggregates industry hits back at ‘misleading’ Marinet claims’ The article incorporated a series of misleading and untruthful claims made by Martin Drury, Chairman of BMAPA, the British Marine Aggregates Producers Association. It was to have been found and read by going to the Maritime Journal website www.maritimejournal.com . However, possibly due to reaction and perhaps for fears of litigation, the statement appears to have been since removed from the Maritime Journal website. It is nevertheless reproduced by us in full below.

MARINET did not publish this affront by BMAPA on our website at the time as negotiations were still on the way with BMAPA, AODA (the Anglian Offshore Dredging Association) and their marine environment consultants, EMU, to have a dialogue and to hold a meeting in order to discuss the shortcomings of the dredging process, the licensing methodology, the limitations of the Environmental Impact Statements, and the need for meaningful pre and post dredging scientific tests to be taken into consideration and to be put into practice before licences were issued. The purpose of which being to properly determine in full any seabed and shoreline damage resulting from the cumulative and large scale dredging, both ongoing and planned.

Accordingly, MARINET felt that a prejudicial stand-off, thereby preventing ongoing negotiations, could evolve if the debate descended into a slanging match involving the trading of insults as distinct from a sane, factually based constructive discussion based on known scientific findings, which hopefully would lead to an amicably settled agreement.

Thus, following a long exchange of correspondence over the course of eighteen months, a three hour meeting to discuss fully the areas of contention was finally agreed, and took place on 9th September 2010 between AODA’s marine environment consultants (EMU) and their project managers, Justina Southworth and Kim Bridge, with Pat Gowen and Mike King representing MARINET.

It turned out to be a most valuable discussion, addressing all our points of issue and contention with two experts who revealed themselves to be highly qualified to fully understand and appreciate the issues at stake. It was fully transcribed by them and is available from MARINET as a 1.37 Mb PDF file quoting ‘AODA/EMU PC Workshop Report’. The document was duly sent on to AODA for their consideration, and hopefully their enactment.

Sadly, despite numerous further requests made to EMU and AODA, no reply came to the points and questions posed by MARINET at that productive meeting held with EMU on behalf of AODA/BMAPA, even after over a year of waiting although all of the issues having been being promptly supplied in full to the dredging companies by their negotiators (J. Southworth and K. Bridge) following the meeting. When, after much chasing, AODA/BMAPA’s response finally evolved, it failed to take aboard MARINET’s concerns, questions and suggestions, so indicating that no change of policy was likely to be forthcoming.

In the light of the failure of AODA/BMAPA to accept the concern of MARINET and their failure to agree to a meaningful and responsible dialogue on the subject of conducting the scientific tests necessary to conclusively prove or disprove the damaging impacts of their offshore aggregate dredging, along with an evaluation of the degree of sand migration from the shoreline which is linked to the issue of the consequent erosion of the coastline which has resulted since the onset of cumulative commercial scale offshore aggregate dredging, it now appears appropriate to reproduce in full the article printed in The Maritime Journal which contains the accusations by Martin Drury (BMAPA) along with our response and our reaction to these unjust allegations.

The Maritime Journal article stated as follows (verbatim):

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“The British Marine Aggregate Producers Association (BMAPA) has hit back at what it calls ‘inaccurate and irresponsible claims’ made by environmental pressure group Marinet over the industry’s impact on the environment. BMAPA rejects many of Martinet’s (sic) claims about aggregates dredging and its effects on coastlines.

Martin Drury, chairman of BMAPA accused Marinet of ignoring the facts in a bid to bolster their campaign. Marinet launched a campaign calling for a reassessment of aggregate dredging at an event at the House of Lords on 12 May 2004.

‘If Marinet expect a meaningful debate with the industry on the issues they must base their arguments on fact and not fiction. So far they have ignored all the scientific evidence and made a number of damaging claims that are inaccurate and irresponsible, ‘ said Mr Drury. “We have never denied that marine dredging makes an impact but we strive to minimise our impacts and work closely with all stakeholders. Marinet completely ignores scientific evidence that would instantly settle the concerns of any reasonable organisation. If Government regulators were not happy with our performance then licences could be refused or revoked”

According to BMAPA, the aggregates industry believes that Marinet is:

1. Ignoring research that suggests coastal erosion is caused by the actions of the sea and tides aided by extreme weather conditions (Southern North Sea Sediment Transport Study, 2002).
2. Making misleading statements about the Eurosion study, stating that it suggested dredging off Norfolk contributes to coastal erosion. Norfolk was never even considered by the study.
3. Claiming that the marine aggregates industry is rapidly expanding when production levels have been stable for 15 years.
4. Claiming dredging is banned in France, Belgium and Holland, when, for example, Dutch production is twice that of the UK.
5. That dredging has a significant impact on fishing when less than a tenth of one per cent of the UK continental shelf is dredged — leaving 99.9 per cent of the seabed undisturbed.
6. Suggesting more recycling could replace marine aggregates, when UK recycling levels at 65 million tonnes per annum, are three times higher than the European average.

Mr Drury concluded: ‘The industry works in partnership with many environmental organisations, so it is a shame that Marinet is choosing to campaign based upon misconceptions and confrontation. We can only hope for a more positive and constructive relationship with them in the future.’

BMAPA claims that there is ‘no evidence of any coastal impact due to dredging ‘ and says ‘coastal erosion and coastal change, driven by waves and currents, is a natural phenomenon that affects both beaches and cliffs. The industry’s objective is to ensure that marine aggregate extraction does not affect these coastal processes ‘ said BMAPA. ‘Although dredging occurs varying distances offshore (often 8km or more) and commonly in water at least 20m deep, the industry still carries out detailed studies. As a further safety mechanism, monitoring of the seabed and adjacent coast in sensitive areas is also undertaken while dredging is carried out. BMAPA also rejects claims that dredging is responsible for a decline in commercial fisheries, or that it damages long-term biodiversitybiodiversity Biological diversity in an environment as indicated by numbers of different species of plants and animals..

Contrary to assertions that dredging is not a sustainable practice, BMAPA says the reality is that subject to continuing research and consideration of local environmental impacts, there are sufficient marine aggregate resources on the seabed for at least a further 50 years at present levels of extraction.

BMAPA says the use of recycled materials in aggregates markets has more than doubled over the last 15 years and now accounts for nearly 25 per cent of British total aggregate demand — which is three times higher than the European average”

End of Maritime Journal article.

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MARINET’s response:

Martin Drury accuses MARINET of “inaccurate and irresponsible claims” when in truth our concerns are based entirely on actual findings and upon recorded scientific evidence made by a number of reputable independent bodies, in addition to our own findings. But we get from BMAPA’s Chairman the statement: “BMAPA rejects many of Martinet’s claims about aggregates dredging and its effects on coastlines” despite the fact that evidence simply does not exist to support their contrary claims.

Martin Drury accuses Marinet of “ignoring the facts” when arguably the fault really lies with himself for doing precisely what he accuses Marinet of. What he should really be doing is addressing the facts which Marinet has presented which prove the damaging effects of marine aggregate dredging, rather than attacking us. Such an allegation only generates heat, not light. He is critical that “Marinet launched a campaign calling for a reassessment of aggregate dredging at an event at the House of Lords on 12th May” when he should actually welcome this were there any substance or evidence behind his claims of non-damage.

He states that MARINET “must base their arguments on fact and not fiction. So far they have ignored all the scientific evidence and made a number of damaging claims that are inaccurate and irresponsible“. This statement is simply untrue. MARINET does use factual evidence, which is neither inaccurate nor irresponsible, and the verification of this can be established by simply visiting our website. We only wish that he and BMAPA would do likewise.

Martin Drury goes on to say “If Government regulators were not happy with our performance then licences could be refused or revoked”. Our response is that indeed they could be, but no applications have ever been rejected yet, despite MARINET’s strongly evidence-based objections.

The reality is that the government is an interested party in granting licences, as both the Treasury and as the Crown Estate obtain considerable revenue by their provision. As a consequence, the regulator — which is meant to be independent of government, but actually derives a substantial part of its budget from government — pays heed only to the Environmental Impact Assessments (EIA) produced by the environmental consultants who are selected by, appointed by and paid by the dredgers themselves. The regulator does not permit any second opinion from independent environmental consultants with an independent brief. Thus the regulator only receives EIA evidence from the supporting consultants which are paid for by the applicants. There is thus no independent evidence base in the EIA element of the licensing process, and as a result it is therefore hardly surprising that evidence from other parties opposing and non-supportive of a dredging licence is ignored.

Let us now turn to Martin Drury’s accusations one by one, in the order given.

1. In response to the claim “Ignoring research that suggests coastal erosion is caused by the actions of the sea and tides aided by extreme weather conditions (Southern North Sea Sediment Transport Study, 2002)” we would recommend that BMAPA study the numerous independent scientific papers by the numerous astute independent bodies that have fully evidenced the erosive impact of offshore aggregate dredging upon the shoreline. Examples of these can be found under studies from around the world on the erosion resulting from offshore sand and gravel dredging on our website. Whilst tidal and climatic factors certainly have their impact, research and correlation have clearly shown that offshore dredging contributes a major erosive impact. We also note that lowering the seabed due to dredging can result in the drawing down of sand from adjacent beaches thus steepening the profile of beaches, and when a beach’s profile (gradient) is steepened the erosive force of the sea and tides during extreme weather conditions is increased. Thus marine aggregate dredging can actually intensify the impact of coastal erosion under these weather conditions. The evidence for this is well documented in the scientific studies which we have referenced above.
2. In response to “Making misleading statements about the Eurosion study, stating that it suggested dredging off Norfolk contributes to coastal erosion. Norfolk was never even considered by the study” MARINET would suggest to Mr. Drury and BMAPA that the original Eurosion study report — prior to the censoring out all the evidence that related to the erosive impact of dredging off Norfolk — is actually read in full and studied again. The evidence can be seen under at North Norfolk Dredging Induced Erosion in Eurosion Report — 4th December 2005 where, with photographs of the damage sustained. it specifically states, verbatim under ‘2.2.2. Human structures and activities have exacerbated coastal erosion’ in the text which follows:
   “To a lesser extent, coastal erosion is also exacerbated by human activities which are implemented in some cases hundreds of kilometres away from their zone of impact. This has proved to be particularly the case for:(ii) Aggregate extraction. Dredging of river and seabed for navigational purposes (i.e. deepening navigation channels) or constructional purposes (e.g. sand and gravel mining) removes an important amount of sediments. This creates a sediment starvation which is in certain circumstances compensated by (re)activation 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) (our emphasis). In some cases, dredging activities, by modifying the water depth in the near-shore area, induce wave refraction which in turn modify the long-shore and cross-shore sediment transport patterns”.Uncovered by Maike of Coastal Essex FoE (email hidden; JavaScript is required) another Eurosion Paper on Essex Estuarial Erosion (this quite distinct from the 29th October 2005 EUROSION Report in which the powers that be attempted to delete that content showing the North Norfolk Coast erosion being due to Offshore Aggregate Dredging) can be seen by visiting http://copranet.projects.eucc-d.de/files/000163_EUROSION_Essex_estuaries.pdf. This paper relates to the serious ongoing estuarial coastal loss of Essex, which, with other causes, shows that offshore dredging is implicated in the loss of sediment supply, hence the resultant erosion.And yet another paper from the Eurosion Project, contracted by the European Commission to a consortium led by the Dutch National Institute for Coastal and Marine Management (RIKZ) for the period 2002-2004 is given under ‘Living with Coastal Erosion — EUROSION Policy — Recommendations December 2003’As well as the Eurosion Project contracted by the European Commission to a consortium led by the Dutch National Institute for Coastal and Marine Management (RIKZ) for the period 2002-2004, there are many more papers evidencing erosion resulting from offshore dredging to be found in our Marine Aggregate Dredging Campaign page from around the world on the erosion resulting from offshore sand and gravel dredging.
3. In response to Martin Drury’s content “Claiming that the marine aggregates industry is rapidly expanding when production levels have been stable for 15 years”we would point out that by continuing to extract, year after year, a similar annual take, the total amount of aggregate removed from the seabed constantly grows, meaning an ever greater removal of aggregate and a further lowering of the seabed each year, with the recognised cumulative erosive result. The following table from The Crown Estate and BMAPA fully evidences this fact:REVIEW OF UK MARINE AGGREGATE EXTRACTION ACTIVITIES from The Crown Estate and BMAPA showing historic patterns of marine aggregate extraction removal in metric tonnes for 2000 — 2005, excluding beach replenishment and fill contracts.
   

   EXTRACTION AREA			YEAR
   	2000	2001	2002	2003	2004	2005	TOTAL
   HUMBER	3,122,080	2,933,623	2,710,881	2,928,366	3,031,699	3,392,015	18,118,664
   E COAST	9,129,635	9,636,697	9,011,323	8,611,199	8,538,073	7,881,670	52,808,597
   THAMES	854,483	909,141	1,291,103	838,185	758,257	696,012	5,347,181
   S COAST	5,613,538	5,628,008	5,399,080	5,658,262	5,148,959	5,389,346	32,837,193
   SW COAST	1,602,394	1,549,431	1,467,122	1,515,241	1,633,383	1,591,610	9,359,181
   NW COAST	316,090	421,068	482,270	470,962	558,398	611,983	2,860,771
   RIVERS & MISC	46,120	73,047	78,597	85,153	99,079	124,506	506,502
   YEARLY TOTAL	20,684,340-	21,151,015-	20,440,376-	20,107,368-	19,767,848-	19,687,142-	121,838,089

   In 2006 the total dredged was 24.3 million tonnes of which 13.4 million was landed at wharves in England and Wales for processing and use as construction aggregate; 6.7 million was landed at wharves on Continental Europe for construction aggregate whilst 4.2 million was used for beach replenishment and contract fill.

   Note 1 With the huge demand for aggregate for projects such as new roads and the Olympic Stadium, the building programme and the possible Thames Estuary Airport, an even far greater supply may be called for.

   Note 2 Beach recharge — the practice whereby beaches that have been stripped of their sand are “recharged” with sand pumped onshore from offshore dredging sites — not only increases the above extraction figures should the practice be included in the calculation of these figures, but the practice of beach recharge is also likely to be necessary only because adjacent offshore dredging has produced the draw-downdraw down The process by which tides and wave motion remove (draw down) material from a beach and pull it out to sea. A sandy beach experiencing draw down is thus denuded of its sand. The process can be natural (i.e. winter storms) or can be artificially caused (e.g. aggregate dredging, whereby the dredging of sand and gravel offshore causes sand to be drawn down from the beach in order to replace the material which has been dredged). and loss of sand from these beaches in the first place. Scientific evidence to prove this assertion is hard to establish, but it is worth noting that “beach recharge” only occurs on beaches which are adjacent to offshore dredging areas, and not elsewhere. For further details see our article on beach recharge.

4. In response to “Claiming dredging is banned in France, Belgium and Holland, when, for example, Dutch production is twice that of the UK” we would point out that the Dutch only dredge in waters whose depth is greater than 20 metres and therefore this aggregate extraction occurs at a far greater distance offshore than occurs in the UK. In addition, the Dutch company Van Oord has licences to dredge off Great Yarmouth aggregate that is exported from the UK to continental Europe, but this does not occur in Dutch production where it is solely for their own domestic use and that what is taken is for shoreline replacement and dyke building. In The Netherlands dredging of harbours to permit navigation is carried out, and for their shortfall of building aggregate the Dutch rely upon that exported from the UK. First hand evidence of the position and restrictions on offshore dredging in Holland is given on our MARINET video film in interviews with the Dutch MPs, by the Harbour Master and others who testify to the situation.
   The clear fact which Mr. Drury and BMAPA ignore is that contrary to practice in the UK, the Netherlands do not dredge aggregate within 25km of their shoreline in coastal waters whose depth is less than 20 metres, other than to maintain navigation in the port shipping channels.
   The reality is that The Netherlands use our sand and shingle taken from along the coastline of the UK at distances far closer than 25km and at lesser depth in order to make up their “aggregate deficit” in terms of their overall national need for aggregate, with thirty five per cent of the sand and gravel that is dredged from off Great Yarmouth being exported and taken to overseas ports such as Nieupoort, Amsterdam, Flushing, and on from there. (For more detail please refer to our Marinet Briefing Paper)
5. In response to the claim “That dredging has a significant impact on fishing when less than a tenth of one per cent of the UK continental shelf is dredged — leaving 99.9 per cent of the seabed undisturbed” is statistically quite true but this is a quantitative, not a qualitative, comment which compares the area(s) dredged with the entirety of the seabed. From a qualitative perspective (those areas most important from both an ecological and shoreline protective standpoint) those areas dredged for aggregate are the very coarse sand and gravel beds where the fish shelter, feed and spawn, and most of this key habitat for fish is specifically targeted because this is the very granular, coarse, stable and cohesive material that makes the best concrete that sells at the best price. Thus the damage resulting to the most vital living seabed in terms of fish ecology and stability is considerable, and the statistical argument advanced by BMAPA wholly conceals this fact. In very simple terms, the non-dredged areas (the 99.9%) are of less importance to both fish and the aggregate companies because the sand and gravel is less suited to spawning needs of the fish, and the “product” in aggregate usability terms is inferior.
6. In response to BMAPA’s point that we propose that “Suggesting more recycling could replace marine aggregates, when UK recycling levels at 65 million tonnes per annum, are three times higher than the European average” — we observe that this statement is probably and hopefully true. However, one has to ask if this recommendation for increased sourcing of aggregate by means of recycling and re-use is really shared by BMAPA as they benefit from dredging the seabed for material. and one suspects that an increase in recycled aggregate would not benefit their bottom line.As for Mr. Drury concluding: “The industry works in partnership with many environmental organisations, so it is a shame that Marinet is choosing to campaign based upon misconceptions and confrontation. We can only hope for a more positive and constructive relationship with them in the future” we have to observe that we have tried, tirelessly, to have ‘a more positive and constructive relationship with them in the future’. The true facts are that MARINET waited for over a year for them to respond to the points made in our consultation with their agents EMU, but the end result of this appears that BMAPA/AODA intend to continue with ‘business as usual’ by declining to have their chosen consultants carry out meaningful and informative studies that would prove the issue one way or the other.

We have listed the fifteen points of requirement where actual scientific evidence is required from BMAPA/AODA in order to justify their continued dredging off the coast of East Anglia — our evidence and case provided to them is listed on our website under Dredging Licence deadlines extended — and yet never, at any time, has BMAPA/AODA responded to the need to provide this scientific evidence. Rather, they simply proceed, and steadfastly ignore our documented argument concerning the need for a genuinely justified scientific basis to their activity.

We rest our case.

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