Help us protect the Goodwin Sands from destruction by dredging

by Goodwin Sands SOS

Help us protect the Goodwin Sands from destruction by dredging

by Goodwin Sands SOS
Goodwin Sands SOS
Case Owner
The Goodwin Sands should be a preserved and protected Marine Conservation Zone and remain the undisturbed graveyard of ships, aircraft and their crews. They should not be dredged for landfill.
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Goodwin Sands SOS
Case Owner
The Goodwin Sands should be a preserved and protected Marine Conservation Zone and remain the undisturbed graveyard of ships, aircraft and their crews. They should not be dredged for landfill.
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Latest: June 6, 2019

GOODWIN SANDS SOS - JUDICIAL REVIEW DECISION DEFERRED

Thank you to everyone who has donated to our campaign and for the last minute effort in getting us past our £20,000 target during Court lunch recess yesterday!

Our QC.gave a very clear and con...

Read more

Who we are  Goodwin Sands SOS is a community campaign group, created in 2015 by concerned East Kent residents, to challenge Dover Harbour Board’s dredging licence application. The Marine Management Organisation has now granted a licence to dredge 3 million tonnes of sand from the Goodwin Sands to use as landfill for the Dover Western Docks Revival.

The Goodwins, as they are known locally, are a 10-mile long sandbank lying three miles off the East Kent coast and stretching between Sandwich and St Margaret’s Bay. They are recommended for designation as a Marine Conservation Zone (rMCZ) full of vulnerable ecosystems and are the UK’s most important underwater archaeological area as well as the largest maritime graveyard in UK waters, possibly in the world.

Map showing location of Goodwin Sands, boundary of recommended Marine Conservation Zone (purple), proposed dredging zone (red) and larger 'study area' (yellow)

Why we need funds now  Following more than 2 years of campaigning the Marine Management Organisation (MMO) granted Dover Harbour Board a dredging licence in July 2018.  We now need to raise funds to challenge this decision in the High Court.  This is the only way we can achieve the conservation objectives of the Goodwin Sands recommended Marine Conservation Zone and protect our Underwater Cultural Heritage, (shipwrecks and military aircraft crash sites) including the graves of sailors and WWII aircrew.  

"To me, the idea that a company can dredge the area and use the aggregate for its development, without respect for nature or heritage, is shocking" – Lewis Pugh, UN Patron of the Oceans

Our lawyers have told us that the MMO's decision was unlawful because it did not deal with Dover Harbour Board's application properly, ensuring the protection of the marine environment and maritime archaeology.  

We now need to raise £8000 to lodge the case and a further £30,000 to cover further Court and legal costs.

Please help us to protect this unique and vulnerable marine environment!  

Background information  Feared by mariners for centuries, the Goodwins hold the remains of over 2,000 shipwrecks and some say 50,000 souls have met their watery grave there. They were known as the ‘ship swallower’ for a very good reason!

In respect of the historic maritime environment it would be difficult, if not impossible, to contemplate a more inappropriate locality in English waters in which to conduct dredging operations.” – Nautical Archaeology Society

The skies above the Goodwins saw fierce aerial combat during the Battle of Britain in 1940. The remains of nearly 60 Spitfires, Hurricanes, Junkers and Dorniers and many of their aircrew lie scattered across the area in locations that remain unknown to this day.  The sands represent the final resting places of brave young men from Britain, the Commonwealth, America, Poland and Germany and their graves should be left undisturbed.

“The Goodwin Sands are archaeologically extraordinary for three reasons: they have perhaps the highest density of wrecks in the UK, these wrecks have the reputation of being abnormally well preserved and the sands contain one of the highest densities of designated marine heritage assets in the UK” – Wessex Archaeology (archaeological contractor to Dover Harbour Board)

In August 2018, a local diver discovered the remains of what appears to be a WWII bomber lying on a part of the seabed that had been surveyed, not once but twice, by Dover Harbour Board’s contractors. Neither survey identified this as the possible final resting place of aircrew but merely listed it as a ‘seafloor disturbance’. What else have these surveys missed?



The Goodwin Sands have been included in the latest round of Marine Conservation Zone designations but the dredging licence was granted just one week after the end of the MCZ public consultation period.

"A Marine Conservation Zone should not be subjected to activities from which it has to recover " – Kent Wildlife Trust 

The Goodwins are also an important and traditional fishing ground for the local Ramsgate fleet, provide haul-out sites for a colony of 500 seals and are a natural sea defence for the vulnerable East Kent foreshore. The Downs, a natural anchorage created by the sands, has sheltered fleets of ships for centuries and continues to do so to this day.

Seals 'haul-out' to rest on the Goodwin Sands (courtesy Julian Sims)

Dover Harbour Board submitted their licence application in May 2016 with the intention of commencing dredging in September of the same year. However, the high level of objections from conservationists including Kent Wildlife Trust, Zoological Society of London, Marine Conservation Society, marine archaeologists including the Nautical Archaeology Society, Joint Nautical Archaeology Policy Committee and Historic England and over a thousand members of the public, resulted in an unprecedented three public consultations.

A total of 315 possible archaeological sites (anomalies) were located in the dredge and buffer zones during the second geophysical survey in 2017 but none have been visually identified. Any one of these could be another military aircraft crash site or the remains of an ancient shipwreck. 

Graphic showing the locations of the 315 anomalies found in the study area


"The fight against the dredging of the Goodwin Sands, an important environmental site and the site of numerous World War 2 graves, is a project close to all our hearts and one worth fighting for" –Sir Tim Smit and Edward Smit, Charlestown Shipwreck Museum and the Eden Project


Our Case   Under the Marine & Coastal Access Act 2009, activities that disturb MCZs are allowed; however, they involve a rigorous two stage assessment. In this particular licence application the MMO only carried out the first stage, which we do not consider good enough.  In the second stage, the developer has to prove that public benefit outweighs any potential damage to the environment and furthermore that this damage can be offset.   In this case, It also requires consideration of alternative dredging sites.  None of this was done.  

As yet, there is no defined purpose for the reclaimed land.  Regarding alternative aggregate sources, there are plenty of commercial dredging sites in the Outer Thames Estuary easily accessible from Dover.

We consider the MMO acted unlawfully in relation to our Underwater Cultural Heritage.  They did not finalise the details of how any heritage assets discovered during the dredge would be dealt with, before they granted the licence.  The MMO also failed to comply with the UK's adoption of the Annex to the UNESCO Convention 2001 for the Protection of Underwater Cultural Heritage, the UK Marine Policy Statement and ignored their obligations under the Protection of Military Remains Act 1986.

The surface of the Goodwin Sands when uncovered at low tide

"In respecting the wilderness of the Goodwin Sands, we respect ourselves" – William Horwood, Author

We really hope that those of you who have already supported us will continue to do so.   We ask you to broadcast this important message far and wide to ensure we reach our target.

Please help us protect this unique and vulnerable marine environment now!

Thank you.






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Update 15

Goodwin Sands SOS

June 6, 2019

GOODWIN SANDS SOS - JUDICIAL REVIEW DECISION DEFERRED

Thank you to everyone who has donated to our campaign and for the last minute effort in getting us past our £20,000 target during Court lunch recess yesterday!

Our QC.gave a very clear and concise account of our challenge yesterday and the MMO's barrister responded with a rather confusing and meandering reply. 

The Judge asked probing questions of both sides and quickly appeared to grasp the legal issue at stake, namely that the MMO had not considered the direct impact of the removal of sand on the resultant lowering of the level of the seabed. 

The Judge is deferring his decision as the submissions took all day.  

The result of this JR obviously has huge ramifications on the success of the Government's Marine Conservation Zone project.  If a developer is allowed to remove a protected habitat because it is the cheapest option, it makes a complete mockery of the whole protection programme.


Update 14

Goodwin Sands SOS

May 31, 2019

GOODWIN SANDS MARINE CONSERVATION ZONE

DEFRA announced today that Goodwin Sands has been included in the third and final tranche of Marine Conservation Zones.

This is fantastic news for the Sands in general and a very positive step forward for the campaign, coming as it is just a few days before the Judicial Review at the High Court on 5th June.

Unfortunately, it does not mean that the proposed dredging will not go ahead but it should mean that the Judge will be extra cautious before making a decision about quashing the licence.  

So we have everything to gain from the Judicial Review next week.  If you are in the area of The Strand do pop in and join us!


Update 13

Goodwin Sands SOS

May 28, 2019

One week until our Judicial Review

Many thanks must go to all our wonderful backers who have donated towards this important cause - every contribution from £5 to £1000 has been very welcome.  However, we are not quite done yet!  

With one week to go until our Judicial Review we need to raise just over £3,000 to reach our CJ target of £20,000.  

Be in no doubt that if the proposed dredging is allowed to go ahead, it will set a very dangerous precedent for subsequent applications.

So, please encourage others to help us by donating to the cause. Our lawyers and Counsel are doing all they can to ensure we protect this unique environment for ourselves and future generations.  Let's make sure they receive the remuneration they deserve.

Thank you.

Joanna and Fiona 

Update 12

Goodwin Sands SOS

May 15, 2019

Three weeks to go until the Judicial Review!

It is nearly three years since we embarked upon our journey to save the Goodwin Sands. We were motivated by a genuine respect for the lives of brave aircrew who lie there and by the consideration of the thousands of mariners who graves are buried beneath the waves.   We love the wildness and savagery of this unique environment and understand the significance of the Sands as a local flood-defence; moreover we wanted to save them for future generations.

During this time we have come an extraordinarily long way.  We always insisted we would seek a Judicial Review if the dredging licence was granted and here we are with just three weeks to go!   

Buxtons solicitors and Counsel from Brick Court Chambers have done a truly fantastic job; they have put together a well-argued case against the Marine Management Organisation’s assessment on the impact of dredging the Goodwin Sands.  

We must continue to support them by fund raising as much as possible as they deserve every penny we can get   So, if you haven’t donated yet, (or if you have and would like to give more!), please dig as deep as you can and contribute to our appeal today.  

Finally, please don't forget to forward this email to any of your friends, family and colleagues who you think might support us.

Thank you very much!

Regards, Joanna and Fiona

Update 11

Goodwin Sands SOS

April 25, 2019

MoD dive team to be on standby for any dredging discoveries

The Ministry of Defence has confirmed that it will have a dive team on standby to investigate any discoveries unearthed by the dredging of the Goodwin Sands, should it go ahead later this year.

This is despite the MoD saying it couldn't object outright to the proposed dredging, on account of the lack of evidence that military aircraft crash sites exist within the proposed dredge zone.  

Even the discovery of an apparent WWII bomber near the dredge zone did not convince the MoD that many more such sites exist or that any one of the unidentified anomalies (potential heritage assets) could be part of a shipwreck of military aircraft crash site.

This is just another of the many frustrations we have encountered with the Government's statutory advisors and highlights why we must ensure that the Judicial Review halts this dredging application once and for all.

The American Department of POW /MIA Accounting Agency (DPAA) has confirmed it will be undertaking a joint dive venture with 3H Consulting Ltd, who have been a tremendous support to the campaign, during this summer.  

The purpose of the dive venture is to identify the bomber found in August 2018 (of which the MoD states it has no record) and to try and locate some of the other US bombers lost over the Goodwin Sands during WWII.  Any remains of lost US aircrew found during the dive will be repatriated under the terms of Project Recover.  

The American Government appears to have far more respect for its war dead than does the UK Government, despite the impressive and numerous ceremonies that take place annually around the UK on Remembrance Sunday.


Update 10

Goodwin Sands SOS

March 28, 2019

We've got a court date!

The date for the Judicial Review (JR) has now been set for Wednesday June 5th 2019 at the High Court in London.  

The main purpose of the JR is, of course, to prevent the rapacious sand mining of the Goodwin Sands.  However, it is also an opportunity to closely scrutinise the current marine licensing process and its effectiveness in protecting our maritime environment and underwater cultural heritage (shipwrecks and crashed military aircraft).

Fundraising is now in full swing so please do share this link with your friends, post it on your Facebook page and twitter feed and if you are feeling really generous, please do pledge again.

Thank you for your continued support; together we can do it!



Update 9

Goodwin Sands SOS

March 19, 2019

Judicial Review granted!

We are delighted to announce that the claim for a Judicial Review of the MMO's decision to allow the dredging of the Goodwin Sands has been granted in the High Court.  The full hearing will take place in June this year.

The MMO's costs have been capped at £10,000, considerably less than they have already spent responding in to our claim.

Lawyers Richard Buxton Ltd are being very generous in their approach towards fees; however they still require us to raise at least £35K for costs going forwards.

So please, continue to dig. in your pockets as deeply as you can. Considering what is at stake, we are sure you will agree that £35K is a small price to pay.

The case is being seen as of national importance about the robustness of the marine licensing process in protecting our marine environment and underwater cultural heritage and the extent to which the Government's environmental regulators are prepared to stand up to the economic Blue Growth Agenda.

Thank you for your continued support and please share this link with anyone you think would like to help us.

Update 8

Goodwin Sands SOS

Feb. 21, 2019

Sir Tim Smit KBE speaks out against rapacious mining

It has been brought to our attention that the link posted yesterday of Sir Tim Smit KBE speaking out against the rapacious. mining of the Goodwin Sands did not work.

Please accept our apologies and hope you enjoy listening to him here:

Sir Tim Smit KBE speaks out


Update 7

Goodwin Sands SOS

Feb. 20, 2019

Video recording by Sir Tim Smit KBE

Sir Tim Smit KBE of the Eden Project International and Charlestown Shipwreck Museum has spoken out against the rapacious mining of the Goodwin Sands.  You can listen to his recording here:

Sir Tim Smit KBE speaks out against the rapacious mining of the Goodwin Sands

We hope you will share this recording with your friends and colleagues and encourage them to donate to our fund raising appeal.  

Enjoy!

Update 6

Goodwin Sands SOS

Feb. 7, 2019

Mining the Goodwin Sands

We have been talking about dredging but according to Sir Tim Smit of the Eden Project and the Charlestown Shipwreck Museum in Cornwall, we should actually be talking about mining - mining in an area containing the second highest density of shipwrecks in UK waters (Co Durham is the first), mining a habitat designated for protection within a proposed Marine Conservation Zone and mining an offshore sandbank that serves as a vital natural sea defence.

We have been given a date for a verbal Permission hearing at the High Court in late February.  However, it will be rescheduled for early March due to Counsel commitments - which gives us even more time for fund raising!

At the Permission hearing, we will have the opportunity to put across our case for a Judicial Review to the Judge in person.  Since the environment cannot defend itself in court, we hope to convince him / her on its behalf that we have s strong case and that this fight is not just about the Goodwin Sands but about the appalling state of the current marine licensing process in general.

We are currently negotiating favourable fees with our lawyers but inevitably we still need funds to continue this legal fight.  So please continue to share this email with anyone you think will support us.  Thank you very much!

Update 5

Goodwin Sands SOS

Nov. 25, 2018

Just £1,000 more needed to pay initial legal fees!

We only need another £1,000 to pay the lawyer's bill for lodging our claim for a Judicial Review with the High Court.  So please do all you can to help us achieve this as soon as possible!

The deadline for the Marine Management Organisation to lodge a response to our claim was last Friday 23rd November.  We haven't yet heard whether they did this or not.  If they didn't, it shows a distinct lack of interest on their part but unfortunately it doesn't mean that we have won.  

Last week we publicly launched the new charity, Goodwin Sands Conservation Trust, which will eventually succeed SOS and will work towards raising public awareness of the importance and significance of the sands, both as part our heritage and marine environment and as a natural sea defence.

So please keep watching this space and share the page with anyone you know who might like to support us.  Thank you!

Update 4

Goodwin Sands SOS

Nov. 7, 2018

The next step!

A copy of our Court papers were sent to the Marine Management Organisation (MMO) and Dover Harbour Board, as an interested party, last week.  


The MMO has 21 days to respond and their counter claim will also be lodged at the High Court.  A decision will then be made on the next step i.e. whether or not we are granted leave for a Judicial Review. This decision could be made either before Christmas or early in the New Year.


In the meantime we are continuing our fund raising and would love to reach £11,000 by 11am on 11th November in respect of all those Airmen whose graves lie in the Goodwin Sands and who gave their lives so bravely and willingly so that we could be free.



Update 3

Goodwin Sands SOS

Oct. 25, 2018

Judicial Review papers lodged!

The papers seeking a claim for a Judicial Review have been lodged today with the High Court of Justice.  We feel a real sense of achievement, despite having hoped this step wouldn’t be necessary.  

We cannot thank enough those donors who have made this possible.  You know who you are and it just shows the level of concern surrounding the proposed dredging.  

We expect to hear within about 6 weeks whether we will be awarded a JR and we are already planning ahead. 

In anticipation of a positive response from the High Court, our fund raising must continue to ensure we have funds to continue ‘the good fight’.  

Thank you all for your incredible support - we really couldn’t have done this without you.  Please continue to share this link as far and wide as you can.  

Onwards and upwards! 

Joanna and Fiona 

Update 2

Goodwin Sands SOS

Oct. 18, 2018

MMO's response to our Pre Action Protocol letter

We have now received a response to our Pre Action Protocol letter.from the MMO 

As anticipated, it is full of bluster and denial.  We expected nothing less.  

Richard Buxton has therefore instructed Counsel from Brick Court Chambers in London to formally prepare the papers to lodge a claim for a Judicial Review.  This will be submitted by Friday 26th October.

Richard has worked successfully with Brick Court Chambers on a number of environmental and marine archaeology cases, so are confident that the best legal expertise is being made available to us.

Thank you for your interest in our case and do please share this webpage with anyone else you know who may support us.

Joanna and Fiona 


Update 1

Goodwin Sands SOS

Oct. 15, 2018

Waiting for the Marine Management Organisation's response to our PAP letter

The Marine Management Organisation have intimated that we should receive their response to our Pre Action Protocol letter by Wednesday 17th October.

We are waiting 'with baited breath' to hear what they have to say but are not expecting them to revoke the dredging licence at this stage.

We are therefore preparing a barrister to formally submit a claim to seek a Judicial Review, which we have to do by Thursday 25th October.

So keep watching this space, the next ten days could be exciting!

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