Marinet changes its policy on comments to the MMO about marine aggregate licence applications
Marinet has informed the Marine Management Organisation (MMO), 26th September 2014, that it will no longer be submitting detailed comments to the MMO about marine aggregate licence applications because the MMO has consistently failed to respond in any meaningful form to the comments that Marinet has submitted. Consequently, Marinet has concluded that the MMO is just rubber stamping the licensing process.
Marinet has set out this change in policy for the MMO in its submission on licence applications for Areas 296 and 494. Marinet has informed the MMO that it has now developed a standardised reply which records its view as to why marine aggregate licences are injurious and should, as a general rule, not be granted.
It is Marinet’s view that it is pointless expending its own valuable and limited resources on a regulatory consultative process which only functions in name, but not in practice. Marinet can scarcely recall a single occasion when the MMO has responded to Marinet regarding the commentary it has submitted. There is no point in a consultative process, Marinet believes, unless a genuine dialogue exists. The MMO appears wholly uninterested in such a dialogue.
Marinet will continue to submit responses to marine licence applications because Marinet believes it is essential that the evidence concerning the injurious nature of the licence is registered on each occasion. If it were to not respond, Marinet fears that such an absence of comment might be construed as consent — a version of reality that is totally at odd with its belief and the facts. Hence Marinet’s decision to maintain its response, albeit in a standardised form for the reasons stated.
Marinet notes: the Marine and Coastal Access Act 2009 was hailed at the time by government as providing a re-invigoration of the licensing process. Marinet observes that reality has demonstrated that this “promise” by government has proved to be very hollow, and perhaps as equally hollow as the delivery that other key feature of the 2009 Act — marine conservation zones, and the protection of our seas and their marine habitats and species.
