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
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
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: 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 c...

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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 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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