FLAWED EIA COULD MEAN PORT OF DOVER WRITES BLANK CHEQUE FOR GOODWIN SANDS WRECKS

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Dark-Clouds-over-Dover-Harb
Dark clouds gather over the Port of Dover’s plan to dredge the famous and sensitive Goodwin Sands
[thePipeLine]

Thanks to today’s unveiling of Henry VIII’s flagship Mary Rose in Portsmouth we now know the exact cost of conserving and displaying a nationally important wooden shipwreck.  It is an eye watering £35 million pounds plus.  Thanks to last weeks award of cash from the Libor fund to the maritime archaeology charity MAST to allow work on the wreck of HMS Invincible in the Solent, we also know the current going rate for an archaeological project on a vulnerable historic wreck which falls short of full recovery.  That comes in at a cool £2 million [and that is not counting the money spent on the site already].  Yet the Port of Dover seems prepared to risk an unknown number of HMS Invincibles and even a Mary Rose or two, not to mention a public relations car crash, just to save itself some cash and the company claims, some nautical miles on its carbon footprint, as it seeks a licence from the Marine Management Organisation to dredge sand and gravel from the Goodwin Sands, six miles north east of the ferry port of Dover on the coast of East Kent.

The Port of Dover plan is to use a suction dredger to remove three million cubic yards (2.5 million cubic metres) of sand and gravel from the south west corner of the Goodwin sands, from within an area covering 4.5 square miles which has been recommended for designation as a Marine Conservation Zone [MCZ].  The material, which will be extracted over a six year period starting as soon as the late Autumn of 2016, will then be transported the six miles to Dover’s Western Docks, where the Port of Dover plan to relocate their cargo operations and construct a new marina for private boats.  It is claimed the works will free up space to extend the Ferry Port at Dover Eastern Docks and that the entire project will also create some 600 jobs in what is an area of high unemployment.  However, the scheme is facing a growing backlash from heritage and environmental groups in Kent, and increasingly from further afield, amid criticisms that the Environmental Impact Assessment [EIA] submitted by the Port of Dover was deeply flawed, prejudging that the Goodwins were the only practical site for obtaining sand and gravel for the project and thus failing to properly consider alternative, less historically and ecologically sensitive sites.  This is a criticism which opponents of the scheme argue certainly applies to the assessment of the risks to the known and suspected maritime and aviation archaeology of the Goodwins undertaken by the Port of Dover’s archaeological consultants Wessex Archaeology.

The archaeological element of the Environmental Impact Assessment submitted by the Port of Dover’s consultants Royal Haskonning DHV, was assessed by Wessex Archaeology, in consultation with Historic England, and it suggests a series of mitigation measures for any discoveries of archaeological importance.  The claim is that if these measures are adopted there will be;

• No direct impacts on known wreck sites;

• Minor impacts on unknown wreck sites – but offset by mitigations; and

• No impact on heritage assets along the coast.

However, independent experts in Maritime Archaeology consulted by thePipeLine suggest that the whole plan is actually high risk, with the potential for, on the one hand, costly delays to the project brought about by the discovery of shipwrecks or crashed aircraft, and, on the other hand, the potential irreparable loss of those same wrecks and even of maritime military graves which are supposedly kept safe under the terms of the Protection of Military Remains Act if the system breaks down and important sites are located accidentally.

The crux of the problem is that while there are an estimated 800 known wrecks on and in the Goodwin Sands there are an unknown number of other wrecks which could date back as far as the first seafarers who ventured onto the waters of the Straits of Dover.  As a simple measure of the potential of the area for finds of early shipping, it can be pointed out that not only has there been the famous find of the Dover Bronze Age boat, the discovery of bronze artifacts off Langdon cliffs, immediately north of the Port of Dover, confirms the presence of Bronze Age seafarers.  Moving forward to the 20th century the German U-boat U12 is also missing in the area, with her entire crew of twenty seven officers and men.  There have also been four known sea battles in the area from the Battle of Sandwich in August 1217 to the Second World War.  While the weather has also played its part in wrecking vessels on the Goodwin’s, for example, as well as the Great Storm of 1703, in October 1624, there occurred: “a wonderful great storm, through which many ships perished, especially in the Downs,”  The Downs being the sheltered anchorage between the Goodwin Sands and the port of Deal.

It is this which leads the EIA to conclude;

“…the potential for the presence of previously unrecorded wrecks on Goodwin Sands is very high.”

The critics say that the risks to those wrecks from the Port of Dover dredgers is equally high.

 

4.3 “Impacts which results in damage or destruction of the heritage assets themselves, or their relationship with their wider environment and context, are permanent. Once destroyed a heritage asset cannot recover.”  Port of Dover Goodwin Sands EIA


Having admitted that there is only one chance to get the methodology right and that once destroyed there is no way to undo the damage, the EIA document then goes on to suggest that pre-disturbance surveys and a watching brief are sufficient insurance to prevent the loss of any significant archaeology.

However, our experts disagree,  pointing out that the entire project runs the risk that the first indication of a wreck of potentially national importance, for example a Roman vessel of the Classis Britannica Channel Fleet of which no examples are known,  could be the broken pieces falling into the dredger hopper.  By then any damage will be done.  This would be bad enough if it related simply to archaeology.  The accidental destruction of an aircraft or vessel which the public would see as a war grave would be a public relations disaster for the Port of Dover, especially as the company has been warned specifically that there is a high likelihood of such a discovery, particularly relating to RAF and Luftwaffe aircraft shot down during the Battle of Britain which raged in part over the Straits of Dover between July and October 1940.

It is also pointed out that, should a discovery be made which requires excavation, conservation and ultimately display, this would impose an immediate and potentially hugely expensive open-ended requirement for conservation, curation and storage which could cause problems in a maritime archaeology sector which is already operating at near full capacity.  Here it is pointed out that the nationally important, incredibly well preserved wreck of the third rate ship of the line HMS Stirling Castle, cast up on the Goodwin Sands on the night of 27 November 1703 in the Great Storm, is still awaiting full excavation, and that the Goodwin  Sands could contain an unknown number of other vessels, each as well preserved and as important in its way as Stirling Castle.

Neither is the imposition of an exclusion zone around any wreck site, with the aim of preserving the site in situ a foolproof solution.   In a highly mobile marine environment, such as a sand bank, this has the potential to, at best, create a column, or series of columns of sand, each containing a wreck and each liable to erosion, merely postponing the day when an expensive programme of archaeology and conservation is required.  At worst the entire seabed around the wreck is destabilised and immediate rescue excavation is required.

Our experts conclude that as the Port of Dover’s application admits, there is a very high risk of the dredging operations uncovering and permanently damaging, or even destroying nationally important maritime archaeology which the mitigation measures proposed could not prevent. Given that near racing certainly, they argue that the Marine Management Organisation should exercise the precautionary principle and the application for a marine licence should therefore be refused.

Reinforcing this view are the stipulations of the Annex to the UNESCO Convention on the Protection of the Underwater Cultural Heritage which governs UK policy towards historic wrecks, but which receives strangely little notice in the Goodwin Sands EIA.

For example Rule 1 requires preservation in situ of underwater archaeology as the first resort; while Rule 4  states that;

“If excavation or recovery is necessary for the purpose of scientific studies or for the ultimate protection of the underwater cultural heritage, the methods and techniques used must be as non-destructive as possible and contribute to the preservation of the remains.”

It is questionable if the suction pipe and hopper of a dredger fulfills that criteria.

There is one later rule which should also give the Marine Management Organisation, and the Port of Dover, pause for thought.

Rule 17 states that;

“Except in cases of emergency to protect underwater cultural heritage, an adequate funding base shall be assured in advance of any activity, sufficient to complete all stages of the project design, including conservation, documentation and curation of recovered artefacts, and report preparation and dissemination. “

That is tantamount to requiring the Port of Dover to write a blank cheque for the maritime archaeology of the project and commit to a potential conservation period of thirty or more years.

And remember what those costs might be;   One HMS Invincible £2 million, add a Mary Rose and it is £35 million and counting…

 

 

However, critics of the Port of Dover proposal point out that it is important to treat the historic and natural environment as one entity.  Protect one and the other is also protected.  In this regard the objections to the proposed dredging do not just come from archaeologists and some of the criticisms suggest the potential  damage to the sensitive ecology of the Goodwin Sands could be equally beyond mitigation and beyond price.

 

“The current assessment of alternatives appears to be based purely on distance from Dover and is built on a pre-judgment assumption…”

 

Seals-Goodwins-Web

Seals are among the marine creatures threatened by the proposed dredging of the Goodwin sands by the Port of Dover
[thePipeLine]

Both Grey and Common Seals use the Goodwin sands as a haul out site where they mate and rest, while there are many less obvious aspects of the maritime ecosystem which could also be adversely effected by the dredging proposal.  Bryony Chapman, from the Kent Wildlife Trust [KWT], told the BBC;

“It’s bound to have an impact on the sediment habitats there and the important mussel beds and ross worm reefs which provide the basis for the food chain.

We are also really worried about the amount of sediment being removed and what impact that could have on coastline and important conservation areas on the coast.”

Ms Chapman also told the Guardian;

“It’s still recovering from that previous dredging and we wouldn’t want it taken right back again.”

However, the Port of Dover takes a more utilitarian view of the Goodwin Sands seeing the Sands as a resource to be exploited, as Alan Breck, the Project Manager of the Port of Dover Revival Project told the BBC;

“Goodwin Sands contains an important aggregate resource and has been dredged previously for fill aggregate for infrastructure projects at the Port of Dover and Port of Ramsgate.”

The Port of Dover also claim that the amount of material to be removed represents just 0.22% of the total volume of sand and gravel present, but in its strongly argued written response to the Marine Management Organisation the Kent Wildlife Trust disputes this stating;

“The dredging would remove 2.5 million m3 of MCZ feature. As the majority of the application area is subtidal sand, this equates to approximately 4.4% by area of the subtidal sand feature within the rMCZ. 1 (and 1.4% of the whole rMCZ). We understand that the volume proposed to be dredged equates to 0.22% of the volume of the whole of the Goodwin Sands complex, however we cannot find any reference to the percentage volume of the subtidal sand feature within the rMCZ. The percentage volume of the subtidal sand that would be removed must be far higher than 0.22% given that other habitats are present within the rMCZ and that the Goodwin Sands extends beyond the boundaries of the rMCZ. “

The KWT add that in its view the Environmental Impact Assessment, undertaken by consultancy Royal Haskoning DHV, is flawed because it is too “light touch” and fails to properly consider alternative sources for the required sand and gravel;

“We would expect an Environmental Impact Assessment (EIA) to consider the environmental impacts of such a scheme, and give equal weight to this environmental impact against economic considerations. This information should provide the evidence for a well-balanced argument and an objective view to be drawn. However, we do not feel that this has been at all well represented in this Environmental Statement and that economic considerations are overshadowing consideration of the biodiversity value of the area, and the strategic importance of this site in the MPA network. The current assessment of alternatives appears to be based purely on distance from Dover and is built on a pre-judgment assumption that the environmental impact on the rMCZ is no greater than in other licenced areas”

Of course, however many Environmental Impact Assessments [EIA’s] are undertaken, and the Port of Dover’s submission extends to five volumes and hundreds of pages,  all natural resources are finite and campaigners are asking is this an exploitation too far, especially when the Goodwin Sands are so close to becoming  a Marine Conservation Zone.

 

“…this is a dangerous and appalling project,”

As the officers at the Marine Management Organisation sit down to assess the application from the Port of Dover there are signs that the organisation is aware of the highly controversial nature of the proposal to the extent that the organisation told the Kent Wildlife Trust in a letter that, although not yet designated;

 “the MMO will take into consideration the impacts of the proposed activity on the features of the rMCZ, in line with existing licensing procedures”

In other words, they would consider the application as if Defra had confirmed the designation, which is expected in Tranche 3 of MCZ designations due next year, 2017.  However, in its response to the MMO the Kent Wildlife Trust argues that the case was so sensitive and would set such a precedent for the industrial exploitation of Marine Conservation Zones, that the decision should be called in by the Secretary of State.

So far none of the organisations in the archaeological sector have been quite as outspoken as the Kent Wildlife Trust, but that is changing with the controversy surrounding the Port of Dover’s plan becoming increasingly public and the critics increasingly vocal, attracting national attention.

At the time of writing a petition opposing the dredging proposal on the campaign site 38 Degrees has reached over 8500 signatures and thePipeLine understands that the influential umbrella group for UK Maritime Archaeology, the Joint Nautical Archaeology Policy Committee is also likely to lodge an objection.

If it does it will be in good company.  Alongside those eight and a half thousand objectors and the many critical submissions to the MMO consultation which ends today, 20 July 2016, Actors Mark Rylance and Miriam Margolyes, both of whom have connections with the Dover area, have publicly opposed the proposal, with Ms Margolyes telling the MMO;

“I’ve always believed in the Harbour Board until now and have defended the docks and the people who try to earn their living here in the depressed south-east. But this is a dangerous and appalling project, which will threaten the whole coastline. You have become destroyers of what makes this area so wonderful.”