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More dark clouds over the Port of Dover’s Goodwin Sands dredging project
[Image:  thePipeLine]


A spokesperson for the Marine Management Organisation has confirmed to thePipeLine that the controversial application by the Port of Dover to dredge 2.5 million cubic metres of sand and gravel from the south west Goodwin Sands is to go out to a further forty two day public consultation.  The news comes just a day after the Port of Dover appeared to accuse the locally based SOS Save Our Sands campaign group of being responsible for potentially delaying the £120 million Dover Western Docks Revival  project, to modernise and extend the cross channel port’s Western Docks which was due for completion by 2019.  However, critics of the dredging application point out that, while the SOS group has undertaken an increasingly vociferous campaign questioning a number of the ecological and heritage aspects of the scheme as set out in the Port of Dover’s application for a Marine Licence to permit the dredging, numerous independent bodies as well as Government agencies, including Historic England, have expressed reservations about the proposal, to the extent that a fresh consultation became inevitable.

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On Wednesday 28 September the online news website Kent Live carried a story which flagged up a possible delay to the port extension and which then named the Save Our Sands group opposing the scheme.  The story then stated,

“The port claims the application process for the project has been “extended” due to the opposition and could lead to delays.”

Kent Live then quoted a Port of Dover spokesman who said,

“We have previously set out an initial timetable for delivery, but a number of variables are outside our control.”

However, public relations experts and the Save Our Sands campaigners see the report, which only quoted the Port of Dover spokesman, as a pre-emptive strike aimed at deflecting the blame for the project becoming bogged down onto the campaigners rather than onto the Port of Dover itself, and onto the consultants who prepared the controversial Environmental Impact Assessment [EIA] in support of the application, Royal Haskoning DHV.  It is pointed out, that it is the critical responses from agencies, including Historic England, and the independent expert opinions which seem to have caused the MMO to ask the Port of Dover for additional information requiring further consultation.  Those responses are all based on perceived flaws and omissions in the data provided by Royal Haskoning’s EIA.
Particular concerns have been raised with regard to the potential impact on vulnerable fish species and marine mammals.  In its submission to the initial consultation the highly respected Marine Conservation Society concluded,

“In conclusion MCS believes that the likely impact on the potential Goodwin Sands Marine Conservation Zone designated features are such this application should not be consented. Were this to go ahead, the  seabed of the MCZ, its biodiversity, the seals depended on it and the fish spawning and nursery grounds of the area will be adversely affected.”

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A number of archaeological bodies are also concerned that the EIA also underplays the potential number of sites and significance of any maritime cultural heritage which might be identified within the proposed dredging area.  The Nautical Archaeology Society concluded its initial submission by stating,

 ‘…it would be difficult, if not impossible, to contemplate a more inappropriate locality in English waters in which to conduct dredging operations’.

Summarising its initial response Historic England was also clear in its opposition to the proposal as submitted telling the MMO,

“We must advise you that we are not satisfied by the information presented in this Marine Licence application, as referenced above, and we must recommend that you do not grant consent for this development as presently submitted.”
However, the most emotive opposition to the dredging scheme has come about because of the potential for disturbing the remains of missing service personnel, particularly  aircrew shot down over the Straits of Dover during the Battle of Britain.  One of the missing, Pilot Officer Keith Gillman came from Dover himself, and represents an iconic image of the Battle of Britain thanks to his photograph appearing in the front cover of Picture Post magazine, just days after his death.

It is now understood that, while the Port of Dover told thePipeLine that the Ministry of Defence had been “included” in the process“since the beginning”, the Ministry of Defence Joint Casualty and Compassionate Center [JCCC] which ensures that the terms of the Protection of Military Remains Act 1986 preventing unlicensed interference with crashed military aircraft and designated military shipwrecks are observed, had not been consulted directly until recently.

However, following pressure from the campaigners and other concerned bodies, this appears to have changed and the Port of Dover is now in dialogue with JCCC, while the Air Historical Branch and Royal Navy historians are understood to be checking their records to assess the extent of any potential issue with military remains and which nations might have missing personnel whose maritime military graves could be damaged by the dredging.

A spokesperson for JCCC told thePipeLine,

“We have made the Dover Harbour Board aware of the provisions of the [Protection of Military Remains] Act.  

We are doing all we can to highlight the Act and the implications if it is not adhered to.”

The spokesperson also pointed out that a licence to excavate/remove an aircraft or wreck would not be granted, if it was suspected that either explosive ordnance, or human remains, were present. This stipulation could have major implications for the project because it would mean that every potential aircraft site would have to be identified in advance, assessed and avoided by the setting up of an exclusion zone, or a breach of the Act could take place.  Either case could add to the length and cost of the project.

Welcoming the new consultation, a spokesperson for the Save Our Sands campaign told thePipeLine that in the group’s view, far from their campaign being responsible for any delay,

“… these delays have been caused by themselves alone.   The Environmental Impact Assessment compiled by Royal Haskoning DHV left too many important questions unanswered.”

The campaign spokesperson added,

“Goodwin Sands SOS would like to reiterate that it is not against the port regeneration scheme itself.  There are viable alternatives to dredging the Goodwin Sands and Dover Harbour Board would do well to start considering them, if they have not done so already.”

thePipeLine e-mailed the Port of Dover and asked it to comment on the suggestion by the SOS Save Our Sands campaign that the delay in processing the MMO licence is actually down to the flaws in the ecological and archaeological sections of the EIA provided by Royal Haskoning, and the failure of Port of Dover and its consultants, to contact the MoD Joint Casualty and Compassionate Center to discuss the issue of missing military personnel whose remains might be found in the proposed dredging area, and not to the SOS campaign as suggested in the story published by Kent Live.

A spokesperson for the Port of Dover replied,

The Marine Licence Application was submitted to the Marine Management Organisation (MMO) in mid-May with the completed Environmental Statement and supporting environmental impact studies.

 “Following the statutory 42-day consultation period which began in June, the MMO requested further information and the Port of Dover has responded to this. The MMO have now given notice for a further 42-day period in order to inspect the additional information.

“We welcome this extended process to ensure the MMO can fully evaluate the application and welcome the opportunity for the public to gain a clearer understanding of what we are proposing.”

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thePipeLine is an independent news publication that investigates the place that heritage, politics, and money meet.

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