February 2005 Update

Marine Aggregate Extraction Licence Area 401/2 ( A&B )

Renewal Request Public Notice Eastern Daily Press Friday 11th February 2005.

Hanson Aggregate Marine Ltd are making an application for the renewal of the existing licence for a further 15 years. The proceedure is as illustrated below (which is taken from the Environmental Statement supporting the application).

ApplicationWhereby the Applicant applies for a Government View
from the Office for the Deputy Prime Minister.
ConsultationFollowing completion of the Environmental Statement and
Coastal Impact Study, the application is put to consultation
and advertised in local papers and the Fishing News.
ConfirmationA supplement to the ES, summarising the process thus far,
is prepared and sent to the ODPM together with
confirmation that the Applicant wishes to proceed.
AssessmentDEFRA and ODPM discuss the Application and either
makes a decision or initiate further discussion.
and Decision
Issue of the Government View.

As can be seen from the box headed Assessment DEFRA and the Office of the Deputy Prime Minister share responsibility for the granting of dredging licences.

The Coastal Impact Study supplied by the applicant supporting this application was carried out by HR Wallingford Ltd.

I have to hand two company searches carried out on that company at different times. These searches show that of the 18 members of the Board of Directors 2 are listed as in “Government Service” and 4 are listed as “Civil Servant”. One of those Civil Servant Directors is Reginald George Purnell who is the Chief Engineer of DEFRA. He of course is responsible for the Coast Defences around the UK.

I understand that HR Wallingford are also used as consultants by Central Government in the decision making process of granting dredging licences.

Whilst I make no allegation, inference or judgement of HR Wallingford, its Directors or Employees I firmly believe that this situation could be open to conjecture. If this were the case surely the wider Public Interest would be jeopardised no matter how honourable the Company, its Directors or Employees, which I do not question here nor do I question their integrity. However I do feel that impartiality and objectiveness could be seen by some as casualties in this application.

Therefore I would call for this Coastal Impact Study to be withdrawn from the support of the application for licence extension and by extrapolation the licence extension application itself should be withdrawn or refuted.

Notwithstanding all of the foregoing I also have to hand the complete non technical summary of the Environmental Statement which forms part of the application. Of immediate attention and concern to me was paragraph 5 “Need For The Dredging Licence”:


    A review of supply and demand issues for marine aggregate in the South East
    and London has concluded that landings of marine dredged sand and gravel in
    the South East will need to be maintained, in the long term, at least at the
    current rate of between 10 and 11 million tonnes per annum. In addition to
    maintaining this supply rate, the importance of guaranteeing sufficient
    resources for beach replenishment projects and exports should also be
    considered. During 2000, approximately 7 million tonnes was dredged from
    the coast around the South East and East Anglia, and discharged directly to
    beaches or to wharves in northern Europe.

    In order to meet the expected demands, the construction industry must be
    assured that sufficient supplies of specific mineral types are available upon
    request. It is not the case that the granting of the Area 401/2 licence renewal
    will lead to a material increase in extraction rates – this is a straightforward
    continuation of existing dredging patterns, that will ensure the effective
    maximisation of a proven resource in this area and also allow blending of the
    remaining resources in Area 401/2 with resources from future licence areas.
    The need arises because there must be sufficient capacity in the supply chain to
    respond to changes in demand.

    The resource under consideration in the Area 401/2 licence will provide for the
    continuation of a suitable resource for building materials to meet future
    construction requirements in London and South-East England.

I would very much like to draw attention to the European Union state of the art document dealing with coastal issues the Eurosion Study, www.eurosion.org to which all member States and Municipal Authorities can and should refer when addressing coastal matters and indeed Shoreline Management Plans.

Particularly I would refer to page 45 of the Eurosion Report, paragraph 1.4.5 “Erosion”, under the sub heading “General description” can be found:

    The east coast of the United Kingdom is less exposed to waves and 
    therefore the tide plays a relatively important role, especially in 
    the estuaries in the southern part of the North Sea.

    The main causes of erosion are:

    * Sea Level rise for estuaries
    * Gradients in longshore sediment transport for sedimentary coasts
    * Storm  surges for cliff coasts and dune coasts

Later on page 47 under the sub heading “Erosion due to human interference in the coastal zone” can be found a paragraph entitled “Sand mining and dredging” which contains the following:

    Whereas beach nourishments may have a positive effect on coastal erosion, 
    sediment extraction locally attributes to erosion of the foreshore of the 
    coast and may lead erosion of the beach and dune system on the longer term.

    Local deepening of the seafloor can alter wave patterns and cause gradients 
    in sediment transports, resulting in local erosion.

In the entire main body of the Kelling to Lowestoft Ness Shoreline Management Plan there is but one minor reference to offshore dredging:

    Whether or not there are links between offshore dredging and coastal erosion is uncertain.

That, it seems to me, is in direct conflict with the Eurosion Study which is much more certain of the consequences of offshore dredging and its effect on coastal process. Throughout the SMP there is reference to the desire to return to “a more natural coastline” and “natural process”. Quite simply natural process can never take place along the east coast whilst offshore dredging continues in the Humber and East Coast dredging areas.

The SMP also identifies a sediment budget shortfall along the Norfolk coast, depending on which expert you choose to believe, of between 300,000 and 450,000 cubic metres annually leading to beach losses and steepening which in turn leads to erosion of the cliffs and land. Why then do we allow between 10 and 12 million cubic metres, or tonnes, to be removed from the system by offshore dredging off this coast every year?

It seems we, the coastal communities along the east coast, are being forced to sacrifice our coastline, our homes, our businesses and our heritage all without consideration or compensation to ensure supplies of aggregate for London the South East and for export to the Continent where offshore dredging for marine aggregate is banned because it causes coastal erosion.

In short we, the coastal communities along the east coast and elsewhere are being discriminated against in pursuance of profit and gain for others.

Whilst Central Government allows this to continue it is, in my view, in contempt of Article 14 of the Bill of Human Rights.

From dredging activity off the east coast the Government receives app. £52,000,000 in Royalty and tax income annually. Yet they will neither replace sea defences or compensate those who lose property or land. Clearly the Government is not in favour of social justice and every member of it should hang their head in shame, the responsibility is theirs jointly or severally.

The licence extension application noted above MUST be rejected and a moratorium placed on all Marine Aggregate Dredging activity in British Waters.

Please, please, please would every right thinking individual write to the address shown in the Public Notice and condemn this current licence application also write to your MP requesting him/her to raise the dredging/coast defence problem in Parliament.

Malcolm Kerby (26 February 2005)