Concern grows over aggregate dredging violating Goodwin Sands war graves

The online History site, PipeLine, reports 17th September 2016: As Battle of Britain Day on 15th September passes, marking another year further away from the iconic 1940 air battle, thePipeLine highlights concerns that the Port of Dover’s proposals for a major dredging project on the Goodwin Sands, could place the final resting place of missing RAF and Luftwaffe aircrew at risk.

Seventy six years on from the titanic air battles of the summer and autumn of 1940, a new Battle of Britain is raging over the Dover Straits.  However, this time the targets are not the ports, airfields, factories and homes of southern England, but the plans of Dover Harbour Board to dredge sand and gravel needed for the extension of Dover Western Docks, from the south west corner of the environmentally and historically sensitive Goodwin Sands, just four kilometres off the Kent coast.

Archaeologists, historians and campaigners fear that this time the casualties and collateral damage caused by the dredging could include the last resting place of as many as seventy Battle of Britain aircrew from the Royal Air Force and the German Luftwaffe, not to mention an unknown number of other airmen and military personnel reported missing in action in the area during World Wars One and Two.

Pilot Officer Keith Gillman [Image: Public Domain]

Pilot Officer Keith Gillman
[Image: Public Domain]

Still more concerning to many, especially local campaigners in Dover and Deal, is that one of the missing airmen whose maritime military grave might be threatened by the Port of Dover’s dredgers, is Pilot Officer Keith Gillman of 32 Squadron, who was actually born in Dover on 16th December 1920.

Pilot Officer Gillman was reported missing over the English Channel off Dover on 25th August 1940 when a mere eight aircraft from his squadron intercepted a German raid which included an estimated thirty six Me 109 fighters.  After his death Keith Gillman, who was aged just nineteen, became an unnamed icon representing all the RAF pilots who flew in the battle.

Now, campaigners against the dredging on the Goodwin Sands fear that the remains of Pilot Officer Gillman and dozens of other airmen and sailors will be put at risk by the Port of Dover’s operation.  Fears which have been enhanced by the fact that the Port of Dover’s own Environmental Impact Assessment [EIA] of the project classed the potential for the dredging operations encountering maritime and aviation archaeology at the Goodwin Sands dredge site as “high”.

This includes the potential for encountering the remains of military craft and aircraft covered by the Protection of Military Remains Act, which prevents the unauthorised excavation or recovery of all military ships and aircraft lost after 1914 and the remains of any service personnel lost with them.  This means that, while there is no such thing as a “war grave” at sea, the remains of service personnel lost at sea do have legal protection from unauthorised disturbance.  A concept which the UK Ministry of Defence defines as a “maritime military grave.”

Given the fears of the opponents of the project thePipeLine asked the Port of Dover if it was concerned at the possibility of disturbing the remains of military personnel, potentially including those of Dover’s own Battle of Britain hero, Pilot Officer Gillman?  A spokesperson for the Port of Dover replied,
“The Ministry of Defence are a statutory consultee and as such have been included in the Marine Licence Application process since the beginning.

“Experts have surveyed the dredge areas and identified exclusion zones for known archaeological sites. Should in the unlikely event of anything currently unknown be discovered it will immediately trigger the recognised industry protocol of mapping, recording and establishing an exclusion zone. The process for managing this is openly set out within the Environment Statement and was further explained in detail at the open meeting held back in July.

“The Port of Dover takes seriously its responsibilities and continues to work with the relevant statutory bodies to ensure that in the event of the licence being granted best practice procedures are employed throughout the proposed dredge periods.”

However, independent experts are not convinced that such a watching brief is adequate defence against accidental damage in such an archaeologically sensitive area.

Indeed, the experts at the Nautical Archaeology Society noted in its submission to the Marine Management Organisation, opposing the licence application, that: “The Impact report acknowledges the high potential for discovery of military aircraft remains, but fails to acknowledge the high potential for discovery of intact, as opposed to disarticulated remains of aircraft.”

It is perhaps with all this in mind that the Nautical Archaeology Society experts concluded their submission by stating: “In respect of the historic maritime environment it would be difficult, if not impossible, to contemplate a more inappropriate locality in English waters in which to conduct dredging operations.”

The lead role in this regard is actually taken by the Ministry of Defence’s Joint Casualty and Compassionate Centre (JCCC).

While the detailed guidance issued by the JCCC to those considering seeking a licence for the recovery of a wrecked aircraft makes allowance for aircraft parts trawled, or otherwise recovered accidentally, the guidance states explicitly that: “If it is known or suspected that there might be human remains at the site, a licence will not be issued.”

Indeed, if discovered such a site would become immediately a ‘Protected Place’ under the Protection of Military Remains Act 1986, meaning that the dredging would have to halt immediately and an exclusion zone around the position of the wreck would have to be established.

Such is the potential for sensitive sites of all types in the proposed dredge site that in a worst case scenario for the Port of Dover, the dredgers could be faced an inefficient slalom between exclusion zones, while always facing the risk of encountering further material requiring the imposition of yet another exclusion zone.

In the longer term experts consulted by thePipeLine suggest that a series of exclusion zones creating fresh banks, channels and pedestals of sand in an area of sandbanks where the seabed is already highly mobile, could destabilise the area and threaten the survival of the very archaeology and maritime military graves, the exclusion zones are designed to protect.

It was also pointed out that there is no detailed modelling of this type of scenario in the EIA submission.

Source: PipeLine, 17th September 2016. For the full details of Pipeline’s report, see


Marinet observes: The fact that sand moves in a clockwise circulatory motion around the Goodwin Sands makes it distinctly likely that dredging in any specific location, and its subsequent infill by sand from elsewhere in the Goodwin Sands, will cause crashed aircraft to be exposed and damaged in areas of the Goodwin Sands not exposed to the actual dredging. All of these sites are war graves, their exposure and location are unpredictable, and hence the Protection of Military Remains Act 1986 essentially mandates a refusal of this licence application.

Not only is refusal on the above grounds clear-cut, so also is the EIA Regulations requirement that alternative sources of sand need to be evaluated. The Port of Dover’s EIA did not evaluate whether the other licensed aggregate dredging sites in the English Channel and Thames Estuary could supply its needs — grounds for refusal of the application for this reason alone — and the EIA did not properly evaluate the availability of “manufactured sand” recovered from the crushing of waste rocks in nearby quarries, see Marinet publication The Need to Dredge — Fact or Fiction?

Please do share this

  • Facebook
  • Twitter
  • Delicious
  • StumbleUpon
  • Add to favorites
  • email hidden; JavaScript is required
  • RSS