Marine Management Organisation faces legal challenge over dredging licence
A campaign group has sent a pre-action protocol letter against the Marine Management Organisation (MMO) over its grant of a licence for the dredging of the Goodwin Sands in Kent.
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.
In July this year the MMO granted a licence to the Dover Harbour Board to dredge three million tonnes of sand to use as landfill for the Dover Western Docks Revival.
The Goodwin Sands SOS campaign group, which has raised £4,909 towards its initial target of £8,000 to launch the claim, has instructed law firm Richard Buxton to act on the claim.
It said on its Crowd Justice page: “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.”
It added that the sand bank was “the UK’s most important underwater archaeological area as well as the largest maritime graveyard in UK waters, possibly in the world”.
Its legal team have argued 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.
Goodwin Sands SOS added: “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.”
An MMO spokesperson said: "The Marine Management Organisation received a Judicial Review Pre-action Protocol letter on 25 September 2018 in response to its decision to issue a marine licence to Dover Harbour Board for dredging in the Goodwin Sands.
“The MMO is currently in the process of preparing responses to each of the grounds in the Pre-action Protocol letter and is unable to provide further comment at this time.”
