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MARINET's Comments on UK Licence Applications

Here are some examples of MARINET responses to applications for a government view for dredging applications. These may be used as models for individual returns of objection by members, who may add their own local concern(s) of the threats imposed to their own areas, if the application for a favourable government view were not rejected.

Area 202/436 - Cross Sands, 7 km east of Gt. Yarmouth

HAML (Hanson) has applied to the ODPM for an licence to dredge for a further 5 years this already dredged area because the licence earlier given expired on January 1st 2006. Without consultation with any of the the stakeholders, HAML were given permission to continue to dredge for a further six month period whilst the application is dealt with.

The ODPM has apparently ruled that the usual Press Notices were not to be published, although it was stated on the letter from MES (Marine Ecological Surveys Ltd) "In accordance with paragraph 2 (c) of the Interim Government View Procedures HAML are required to undertake consultations with interested parties as per the attached list. To this end, comments on the ES update are sought from consultees on the proposed extension. Comments should be submitted to Marine Ecological Surveys at the address below no later than Monday 6th March 2006"

Both MARINET and the North Sea Action Group were omitted from the list of consultees. However, upon contact with MES Ltd, we have been supplied with copies of the Environmental Statement Update which addresses the relicencing application for a further 5 years.

The resulting objections to the extension by Pat Gowen and Stephen Eades follow.

Letter of objection sent by Pat Gowen to Marine Ecological Surveys - dated 22nd February 2006

Reply from MES to Pat Gowen's submission above of the 22nd February - dated 19th April 2006, 4 pages

Email from Pat Gowen to MES as reply to the above letter from MES of the 19th April 2006 - dated 7th April 2006 - 3 pages

Reply from MES to the above letter from Pat Gowen - dated 3rd May 2006, 1 page

Letter of objection sent by Stephen Eades to Marine Ecological Surveys - dated 28th February 2006

Response from Marine Ecological Surveys to the above submission from Stephen Eades - dated 19th April 2006, 3 pages

Response from H.R. Wallingford to the above submissions from Stephen Eades and Pat Gowen - dated 7th April 2006, 6 pages.

Letter of objection sent by Stephen Eades to Marine Ecological Surveys - dated 20th April 2006

Response from MES to the above letter - dated 27th April 2006

Letter to the Office of the Deputy Prime Minister sent by Stephen Eades regarding all the correspondence to MES - dated 10th May 2006

Response from the Dept. for Communities and Local Government (formally ODPM) to the above letter - dated 30th June 2006

DCLG decision document to the licencee, Hanson Aggregates Marine Limited - dated 30th June 2006

Letter sent to the DCLG (formally ODPM) concerning issues arising from the decision to re-new the licence for Area 202 - dated 7th August 2006

Reply from DCLG to the above letter concerning licence renewal of Area 202 - dated 29th September 2006

 10th October 2006   Letter sent to the DCLG (formally ODPM) in reply to the above letter.

 8th January 2007   Letter sent to the DCLG

 6th March 2007   Reply from DCLG - Only the last paragraph of this letter is relevant to Area 202 & 436

 3rd April 2007   Letter sent to the DCLG

 10th April 2007   Supplementary letter to DCLG

 11th July 2007   Letter from MFA (formerly DCLG) which replies to the letters of 3rd and 10th April 2007.

 28th August 2007   One of two letters sent to the MFA which reply to letter of 11th July 2007 from MFA.

 28th August 2007   One of two letters sent to the MFA which reply to letter of 11th July 2007 from MFA.

 30th October 2007   Letter from MARINET to D.Spooner, MFA requesting a reply to our letter of 28th August 2007 to the MFA.

 4th December 2007   Letter from the MFA which replies to our letters of 28th August and 30th October 2007.

 16th December 2007   Letter from MARINET to the CEO, MFA which replies to the MFA's letter of 4th December 2007.

Areas 401 & 402 - off Gt. Yarmouth

Areas 401 and 402 form the far part of a massive dredging site stretching 12 miles from Winterton-on-Sea in north Norfolk to Corton in north Suffolk, between three and thirteen miles offshore, as seen on the following map.

BMAPA announced two years ago that aggregate dredging would cease offshore to Great Yarmouth because of commercial exhaustion of stocks and concern of the environmental impact, and that dredging operations would move to the south coast. But it came as no surprise this year that an application for a Government View was placed by Hanson Aggregates Marine Ltd. to renew the licence to further dredge from Area 401/2 offshore to Great Yarmouth. The company has long dredged for sand and shingle off the Great Yarmouth coast, but the licence is set to expire on March 31 2006.

MARINET and the North Sea Action Group (NSAG), the East Anglian forerunner of MARINET, opposed the application as soon as it was launched, initially sending the following letter to Marine Environmental Surveys, the company selected and funded by Hanson to represent them.

Letters of objection concerning Areas 401 and 402

 5th & 25th March 2005  Letters of objection sent by Pat Gowen

 24th March 2005   Initial letter of objection sent by Stephen Eades to the consultants, Emu.

 29th July 2005   Response from consultants Emu Ltd. Copies of the Technical Notes referred to in this letter may be obtained by applying direct to the consultant, Emu Ltd, at the address given on their letterhead. If you experience difficulty, please contact MARINET.

 22nd August 2005   Second letter of objection sent in reply to the consultant's response above.

 17th August 2005   Letter of objection sent by Mike King to the consultants, Emu.

 14th February 2006   Letter of objection sent by Mike King to ODPM.

 18th February 2006   Letter of objection sent by Stephen Eades to ODPM.

 22nd February 2006   Letter of objection sent by Pat Gowen to ODPM.

 21st December 2006.   Response from DCLG, concerning application for a Government View - Area 401/2 & marine mineral dredging regulations.

 8th January 2007   Reply to above letter sent by Stephen Eades to DCLG.

 6th March 2007   Reply from DCLG
Appended to the above letter are the following two 'Temporary Government View Extensions on Licence 401/2'

 31st March 2006   Temporary Government View Extension on Licence 401/2

 21st December 2006   Temporary Government View Extension on Licence 401/2

 2nd April 2007   Letter from Stephen Eades to DCLG

 11th April 2007   DCLG Decision Document granting a new dredging licence for Area 401/2

 12th June 2007   Letter from Mike King (Yarmouth FOE) to DCLG, objecting to the continued offshore dredging in Area 401/2

 26th July 2007   Letter from MFA (previously DCLG)to Mike King, in reply to the above letter

 3rd July 2007   Letter from MFA (formerly DCLG) which replies to our letter of 2nd April 2007

 7th July 2007   Letter from Stephen Eades to MFA in reply to their letter dated 3rd July 2007, in which we raise with the MFA issues of concern about the efficacy of the DCLG decision document of 11th April 2007

 7th July 2007   Supplementary letter from Stephen Eades to MFA, concerning the DCLG decision document of 11th April 2007

 26th July 2007   Letter from MFA which replies to a letter dated 7th July from Stephen Eades.

 7th August 2007   Letter from MFA which replies to a letter dated 7th July from Stephen Eades.

 28th August 2007   Letter from Stephen Eades to MFA which replies to the letters of 26th July and 7 August 2007 from the MFA.

 30th October 2007   Letter from MARINET to D. Spooner, MFA requesting reply to our letter of 28th August 2007 to the MFA.

 16th November 2007   Letter from the MFA which replies to our letters of 28th August and 30th October 2007.

 16th December 2007   Letter from MARINET to the Chief Executive Officer, MFA which replies to the MFA's letter of 16th November 2007.

Area 430 - East of Southwold, Suffolk

Area 430, East of Southwold, is located some 15 miles (24 kms) off the Suffolk coast. The current licence was issued jointly to United Marine Dredging Ltd and CEMEX UK Marine Ltd in July 1997 until November 2007, permitting the extraction of 6 million tonnes between the two companies, giving an annual maximum of 300,000 tonnes per company. The maximum take from the seabed in any one year is 1.2 million tonnes.

The new licence to be held jointly by the two companies is for the removal of a maximum of 9 million tonnes over a 15 year period. There will be an annual average extraction rate of 600,000 tonnes between the two companies, with the maximum annual take being 1.2 million tonnes. The consultants employed by the companies to prepare the Environmental Statement accompanying the licence application are Metoc plc, Exchange House, Station Road, Liphook, Hampshire GU30 7DW.

 24th April 2006   Metoc plc letter - seeking MARINET's views on the Scoping Document for the Environmental Statement

 24th May 2006   MARINET letter to Metoc

 9th January 2007   Metoc plc letter - in response to MARINET's views on the ES Scoping Document

 20th January 2007   MARINET letter to Metoc

 14th March 2007   Metoc plc letter - replying to MARINET's queries about the Scoping Report for the ES

 2nd April 2007   MARINET letter to Metoc

Area 457 - Liverpool Bay

Westminster Gravels Limited applied in 2002 under the Government View procedure for a licence to extract a maximum of 18 million tonnes of marine sand and gravel over a 15 year period, based on a maximum extraction of 1.2 million tonnes per annum. The site, known as Area 457, Liverpool Bay, is located approximately 25kms off the north west coast of England, 28 kms from the coast of north Wales, and covers an area of approximately 65 square kilomtres. Permission, with an accompanying licence to extract 1.2 million tonnes per annum for 15 years, has now been granted on 19th March 2008. MARINET has objected to the granting of this licence, and has asked for its revocation by the licensing agency (Marine and Fisheries Agency), see below.

 30th October 2002   MARINET letter to the applicant's consultant Environmental Resources Management (ERM).

 15th November 2002   MARINET letter to the applicant's consultant Environmental Resources Management (ERM).

 22nd December 2002   MARINET letter to the applicant's consultant Environmental Resources Management (ERM).

 5th November 2002   MARINET letter to ODPM.

 24th July 2003   Letter from ERM the applicant's consultant.

 1st March 2004   MARINET letter to ODPM in response to the enquiry by the ODPM as to whether MARINET has any comments on licence application by Westminster Gravels Ltd to extract 1.2 million tonnes of marine aggregate per annum from Area 457.

 7th December 2007   Letter from MFA concerning Area 457

accompanied by

 7th December 2007   Letter from MFA to Westminster Gravels Ltd in respect of a draft decision document by the MFA on their licence application.

also accompanied by

 Undated   Draft decision document and Schedule of Conditions undated and recorded as "draft", issued by the MFA to Westminster Gravels Ltd in respect of Area 475.

 16th December 2007   Letter from MARINET to the Chief Executive Officer, MFA, in respect of the MFA's letter and their draft decision.

 19th May 2008   Decision letter granting a licence from MFA, accompanied by a Schedule of Conditions. (be aware that this is a large document of 1.6MB)

 7th June 2008   Letter from Stephen Eades to the MFA, challenging the granting of a licence to dredge area 457.

Areas 458 & 464 - Eastern English Channel Licences

As the licences on the East Coast become worked out and reach "commercial exhaustion", the marine aggregate industry will need new areas to exploit if it is to stay in business. The area the industry would prefer to move into lies midway between England and France in the eastern English Channel.

The eastern English Channel contains extensive deposits of sand and gravel. It is also supports a rich and diverse marine ecosystem and a strong commercial fishery.

If the marine aggregate industry were to begin to exploit the aggregate deposits in the eastern English Channel, it is anticipated that there would be a dozen or more dredging sites yielding (dependent on the licences granted) between 8.5 and 17 million tonnes per annum. By contrast, the current total yield from all the marine aggregate extraction sites in the UK is between 22 and 23 million tonnes per annum (mtpa), and the East Coast licences have provided approximately 47% of aggregate taken from the sea in the past decade.

So far, the UK Government has granted a licence in April 2005 for Area 461 (Median Deep) which lies 25 miles off the East Sussex coast and further, in May 2006, has granted a set of additional licences in the adjacent eastern English Channel sites - Area 473 (Greenwich Light East), Area 474 (Eastern English Channel North) and Area 475 (Eastern English Channel South).

The licence for Area 461 runs for 15 years with permission to extract 2 million tonnes in the first year, 2.5 million tonnes per annum (mtpa) until year 5 of the licence, and 5 mtpa thereafter. In the case of Areas 473, 474 and 475 the licences also run for 15 years [see details below] with permission to extract 121 million tonnes over this 15 year period from all three sites combined.

Areas 458 and 464 in the eastern English Channel are presently undergoing an application for a dredging licence under the Government View procedure. The submissions by MARINET to the Government and the company (United Marine Dredging Ltd) in respect of the public consultation on this licence application are provided below, as is the response of the company to MARINET's initial submission.

Initial letter of objection on behalf of MARINET sent by Stephen Eades dated 22nd July 2004.

Response from consultants UMA, dated 9th March 2005. 3 pages.

Second letter of objection sent in reply to the consultant's response above - dated 24th September 2005.

East English Channel : Regional Monitoring Programme.

Introduction:

In accordance with the licence conditions issued by the Government in 2006 for the new aggregate dredging sites in the Eastern English Channel (Areas 473, 474 and 475 : see below), the East Channel Association (ECA) has announced its 5 year Monitoring Blueprint for these sites. The ECA is the trade Association of the dredging companies involved with these licences.

Given the great biodiversity of marine life in the Eastern English Channel and the fact that the aggregate dredging sites incorporate or lie adjacent to a marine habitat protected by the United Nations Convention on Biodiversity ("sub-littoral, sands and gravels" see: www.ukbap.org.uk/UKPlans.aspx?ID=44 ) along with the importance of the Eastern English Channel for the herring and scallop fishing stocks, the UK Government has required the ECA (dredging companies) to devise a comprehensive monitoring programme over the first 5 years of the licences to ensure that no significant adverse impact occurs. If adverse impacts were to be detected, then it is possible that the licences would need to be altered or even revoked.

On 22nd August 2006 the ECA invited interested persons and organisations (e.g. fishing representatives, environmental organisations, government agencies and departments) to a meeting of the East Channel Environmental Network (ECEN). This meeting of the ECEN, which the ECA proposes to convene on an annual basis, explained the purpose and design of the East Channel Regional Monitoring programme.

MARINET attended this meeting and greatly welcomes this East Channel Regional Monitoring programme which is both essential and an important step forward. Such regional monitoring programmes do not currently occur for aggregate dredging elsewhere in the UK.

However, in MARINET's view, the East Channel Regional Monitoring programme currently has a number of serious flaws in its design. We have explained these flaws, along with proposed remedies, in a letter dated 4th September 2006 to the ECA. This letter is reproduced below.

 4th September 2006   Letter to East Channel Association from Stephen Eades

 28th September 2006   Response from East Channel Association

 31st October 2006   Further letter to East Channel Association from Stephen Eades

 5th February 2007   Reply from the East Channel Association

The East Channel Association has commenced its 5 Year Monitoring Programme, and its member companies has received recently from the Government to commence dredging in Areas 473 West, 474 East and Areas 464/458, and these join Areas 461, 475, 473 East and 474 Central where aggregate extraction licences have already been granted. Additionally, the aggregate companies are currently seeking permission to dredge in Areas 478 and 477. For a detailed map of the location of these Areas see: www.eastchannel.info/map01.htm

The East Channel Association has published the results from the first year of its 5 year Monitoring Programme on its website, see: www.eastchannel.info/library01.htm At the same address the East Channel Association have also published their January 2003 Regional Environmental Assessment which provides a strategic overview of the resources, physical and biological, in the Eastern Channel; and, the ECA has also published at the same website address the Monitoring Blueprint which serves as the basic design model for the 5 Year Monitoring Programme.

The East Channel Association has established an East Channel Environmental Network (ECEN), composed of stakeholders and others with an interest in the Eastern Channel, and the ECA reports annually to the ECEN on the progress of its Monitoring Programme. In 2006 the ECA reported on the Monitoring Blueprint - see MARINET's queries listed in the correspondence above. On 17th July 2007 the ECA has reported to the ECEN on the results of its first year of monitoring. See below for MARINET's list of questions for the attention of the ECA at the July 17th meeting:

 7th July 2007   MARINET's questions to the East Channel Association's meeting of the East Channel Environmental Network

Area 472 - Culver Sand, inner Bristol Channel

Area 472 lies on the English side of the median line between England and Wales in the Bristol Channel. This aggregate dredging application is located on a south-westerly sandbank which is part of Culver Sand, a possible Special Area of Conservation under the EU Habitats Directive. The extraction area covers 3.8 square kilometres, involves the extraction of up to 1 million tonnes per annum for 15 years, and the marine aggregate companies are Cemex UK Marine Ltd, Hanson Aggregates Marine Ltd and United Marine Dredging Ltd. Permission, with and accompanying licence, has been granted on 8th May 2008 by the Marine and Fisheries Agency.

 29th October 2007   MARINET submission in respect of the marine aggregate licence application

 8th May 2008   Decision letter of the Marine and Fisheries Agency

Areas 473, 474 & 475 - Eastern English Channel

The UK Government (Department for Communities and Local Government, formerly ODPM) has announced approval on 15th May 2006 for aggregate dredging licences in three areas located in the Eastern English Channel.

These areas are Area 473, known as Greenwich Light East; Area 474, known as Eastern English Channel (North); and Area 475, known as Eastern English Channel (South).

These three areas in the Eastern English Channel now join Area 461, known as Median Deep, as licensed dredging sites. Area 461 was licensed 1st April 2005.

The location of these specific sites can be viewed on Map 1.

The location of all the proposed aggregate dredging sites in the Eastern English Channel can be viewed on Map 2.

Licence applications have also been submitted for Areas 458 and 464, known as West Bassurelle, but no determination of these licence applications has currently been made. See this page for further details about Areas 458 and 464.

Further information about all these dredging sites in the Eastern English Channel is also available from the East Channel Association which is run by the dredging companies - see www.eastchannel.info to view the non-technical summary of the Regional Environmental Assessment (REA) conducted by these companies.

The UK Government has decided to issue aggregate dredging licences for Areas 473, 474 and 475 on the following terms:

• The licences shall exist for 15 years, subject to reviews at year 5 and year 10.
• The total amount of aggregate (sand and gravel) which may be extracted during the 15 year period is 121 million tonnes from all three sites combined.
• Not more than 4 million tonnes per annum may be extracted from all three sites combined during the first 3 years.
• Not more than 4.5 million tonnes per annum may be extracted from all three sites combined during the next two years, and the total for the first 5 years shall not exceed 21 million tonnes combined.
• During the next 10 years the extraction limit will be decided at the relevant time (i.e. following the 5 and 10 year reviews), but shall not exceed 10 million tonnes per annum.
• There will be an annual programme of environmental monitoring for the first 5 years, and then a Substantive Review of the licences in year 5 which, if necessary, can result in a new Environmental Impact Assessment being undertaken.

MARINET has not been involved in the Consultation Process (Government View procedure) for these specific licence applications as these application pre-date MARINET's work in this area. However, other organisations have been involved. The decision document issued by the UK Government for Areas 473,474 and 475 states that the Joint Nature Conservation Committee (English Nature) is satisfied that dredging may proceed providing that it is subject to precautionary monitoring and mitigation measures which JNCC has recommended. Under these conditions, JNCC believes that habitat which might be potentially designated as a candidate for Special Area of Conservation is unlikely to be significantly affected. JNCC has been concerned by the impact of screening (the discharge of unwanted material from the dredgers which can smother life on the seabed), but has agreed that limited screening should occur in Areas 474 West and 473 East for the purpose of assessing screening impacts. The Maritime and Coastguard Agency is satisfied about measures to ensure the safety of shipping in the Channel, and DEFRA is satisfied that the sole fishery will not be adversely affected, and that scallop populations should be safe provided their populations are recorded at the commencement of dredging and monitored annually.

In response to these potential concerns, the UK Government has made it a condition of the licences that monitoring of the environmental impact is undertaken annually both at and around the dredging sites for the first 5 years, and that the licences will be subject to a Substantive Review in year 5.

MARINET will follow this monitoring closely. MARINET remains concerned that the impact on marine life and the marine ecosystem in these areas may be greater than anticipated, and MARINET notes that a specific habitat of conservation importance, known as sub-littoral sands and gravels (i.e. marine ecosystems associated with sand and gravel habitats on the seabed) which are identified as being of conservation importance by the UN Convention on Biodiversity have not received specific mention or protection in the UK Government's decision document for Areas 473, 474 and 475 - see www.ukbap.org.uk/UKPlans.aspx?ID=44