POINTS FOR OBJECTION TO THE DREDGING

• The Goodwin Sands is a collective war grave (maritime military grave).
• Kent Battle of Britain Museum confirms that at least 60 planes and 70 pilots from Britain, Germany and Poland crashed into the Goodwin Sands area during the Battle of Britain 1940.

• The locations of these crash sites are unknown. The shifting dynamic nature of the sands means that remains will have spread widely over the year.

• Military air crash sites should be automatically protected under the Protection of Military Remains Act 1986. It is an offence to tamper with, damage, move or unearth any such remains without a licence from the MOD.

• Wessex Archaeology has identified 6 anomalies within the proposed dredge zone and a further 8 along the western boundary. Their identity is unknown. They could well be disarticulated remains of World War II aircraft, with remains of crewmembers inside.

• The MOD requires DHB to research the location of any military air crash site and the fate of the crew. A dredging licence will not be issued if human remains are likely to be found on the site. DHB have not yet done this.

• One of the pilots whose remains lie in the Goodwin Sands is Pilot Officer Keith Gillman from Dover. He was killed, aged 19, and became an iconic poster boy at the instigation of Sir Winston Churchill.

• Annexe to the UNESCO Convention and the Valletta Treaty: the UK Government abides by these two agreements, which state that funds should be set aside for the recovery, restoration and preservation of architectural heritage discovered during explorations. No such fund has been included in any assessment provided by DHB.

• Alternative aggregate sources: landfill is available from other commercial marine aggregate sites located in the Outer Thames Estuary and East English Channel. DHB refuses to look seriously at these or the use of reclaimed and recycled materials.

• Availability of enough aggregate: DHB says alternative sites cannot provide the quantity required in the available timescale. They need 1.3 million tonnes of aggregate per year, which is 1/13 of the total annual UK output. Is this project too ambitious for the resources available?

• Perceived conflict of interest: Royal Haskoning DHV manages the marine aggregate branch of The Crown Estate, who owns the seabed. RHDHV compiled the Environmental Assessment. DHB therefore employed a company whose best interests lie in concluding there will be no residual impacts from the dredging.

• CO2 emissions: DHB says reduced CO2 emissions are a good reason to dredge the Goodwins. However, increased lorry and cargo ship traffic in the new port will increase CO2 emissions dramatically and these will be ongoing.

• Seals: Natural England recommends avoiding dredging during sensitive times of year (June through August). The proposed dredging schedule for 2018 is May to August and for 2019, May to July. DHB have offered to increase the buffer zone around the seals’ haul out sites but this will not protect the seals during their sensitive breeding and moulting seasons.

• Marine Conservation Zone: Kent Wildlife Trust has submitted the whole of the Goodwin Sands as marine conservation zone number 17 for designation by DEFRA in 2017/18. If DHB are granted a dredging license before this, the recommended conservation zone will not be protected.

• Granting a licence now will open the doors to other companies seeking sand for construction as a precedence will have been set.