The British Sub Aqua Club is the Governing Body for the sport of Sub Aqua Diving and Snorkelling in the United Kingdom. As the governing body we do feel that part of our role is to support the protection of our underwater cultural heritage (UCH) whenever we feel it may be threatened.

The dredging proposals for the Goodwin Sands concern us. We recognise that surveys have been done to ensure that no obvious material culture is threatened with catastrophic removal. However, we are mindful that some UCH may well not show up on the surveys currently undertaken. There is also the need to remember that there may well be material down there that we do not know how to see. Absence of evidence is not evidence of absence.

We note with interest the comments concerning overburden and sand movement. Covering and uncovering of UCH in this area is unpredictable at the very least, as anyone who has dived the wrecks in this area will testify. We are also conscious of the wide range of archaeological material that may well be unseen at present. Because the Goodwin Sands has a reputation for being a ship-killer earned over many centuries some currently invisible and fragile material may be extant but not visible with current survey methods.

In the survey reports we have read there seemed to be an emphasis on aircraft and metal remains-but as yet we are unconvinced that the ability to locate much more ephemeral remains has been addressed either in the proposal or the survey methodology.

As the National Governing Body we are fully aware of the responsibility for ensuring that our national heritage is properly protected so that future generations will have the benefit.  We know that other areas can produce material of the equivalent quality and quantity, and we would urge you to pursue those alternative sites, which have a reduced threat to potential archaeological remains in the Goodwin sands.

Jane Maddocks MA
Wrecks and Underwater Cultural Heritage Adviser to the British Sub Aqua Club
August 2017