Imagine if a building contractor, digging foundations for a luxury holiday resort, trucked the excavated earth to a neighbouring nature reserve and dumped it. Now imagine if they had to repeat that process annually, and were licenced to do so by Natural England. It would be a national scandal. There would be petitions and parliamentary debates over the issue, and who – even among the most venal of right-wing politicians – would dare to defend it?
Well, that is roughly analogous to what is being done off the coast of Sussex, except that as yet, it has met with scarcely a ripple of controversy.
Earlier this year the Marine Management Organisation, the statutory body regulating marine activities around England and Wales, granted the renewal of a 10-year licence to Premier Marinas, the company that leases and operates Brighton Marina, to annually dump up to 100,000 tonnes of sediment dredged from the marina at a disposal site near Rottingdean – within the Beachy Head West Marine Conservation Zone.
Sussex Wildlife Trust (SWT) is now seeking a judicial review of this decision, arguing that this ongoing dumping of sediment adversely impacts the habitat and species features that the protected area designation is supposed to safeguard.
Dumping sediment is damaging the habitat
Beachy Head West was designated a Marine Conservation Zone (MCZ) in 2013 because of numerous features of conservation interest within the area, including chalk reef habitat, blue mussel beds, and the presence of native oysters, which would once have formed colonial reefs continuous across much of the North Sea and English Channel before populations were decimated by industrial trawling and dredging. The short-snouted seahorse, one of two seahorse species native to British waters and fairly rare, also inhabits the reserve.
SWT argues that these and other notable features are put at risk by the dumping of sediment, and that monitoring commissioned by Premier Marinas has failed to take account of the majority of the MCZ designation features, instead doing only the bare minimum that was legally required.
For instance, the impact of the Rottingdean sediment dumping on oysters hasn’t been monitored, because the presence of oysters in the area consists only of scattered individuals or small groups, rather than large reef-forming aggregations. This is despite the fact that, as sessile filter feeding animals, oysters are known to be vulnerable to smothering by sediment.
It seems like quite the catch-22 for preventing the recovery of oyster reefs – monitoring of activities likely to have adverse impacts on oyster numbers isn’t required, precisely because oyster population densities are not currently high enough to merit consideration.
While motile species like the short-snouted seahorse are less vulnerable to sediment smothering, these were also deemed unnecessary for monitoring, despite being among the MCZ features and a relatively rare flagship species for the area. In the case of this species (and seahorses in general) we still have limited knowledge about their populations or ecology.
It’s plausible though that such sediment dumping could have indirect effects on them, such as by impacting the structure of benthic vegetation in which they live, or by affecting the abundance of their small invertebrate prey.
What, you may therefore ask, is the point of such Marine Protected Areas, if such activities can be greenlit with such little regulation? Good question.
Higher costs should not be a barrier to considering alternatives
Of course, Premier Marinas argues that this dredging and disposal is necessary to keep the marina navigable for boat traffic, and that the disposal site at Rottingdean is nearby and therefore reduces the distance (and cost) of shipping the dredged sediment compared to potential alternative sites. But as SWT points out, those alternatives do exist, and while they may have certain technical or economic drawbacks compared to the Rottingdean site, disposal sites at Shoreham or Newhaven are outside of any protected area designations.
The Shoreham site may be problematic, because the eastward direction of longshore drift would result in sediment dumped there washing straight back towards Brighton. But the Newhaven site, a short distance out from Newhaven Harbour, sits eastward of the marina, sandwiched in between the two discreet areas that make up the MCZ.
Given the choice of two alternatives, it should arguably not even be up for consideration to annually dump 100,000t of sediment in the middle of a MCZ, simply to maintain a pristine space for the affluent to keep their pleasure yachts. If it would be more costly to use the Newhaven or Shoreham sites, higher fees could be charged for berthing and boatyard services – I’m sure the average boat owner could afford to pay a bit more – or cut costs elsewhere.
More thorough monitoring is required
At least until more thorough monitoring has taken place, ideally including an experimental moratorium on dumping at Rottingdean, then it seems difficult to justify the renewal of the licence – particularly in the current context of frustration among marine conservationists and environmental groups at just how ineffectual our Marine Protected Areas are. Even regardless of measured impacts, this dumping is emblematic of a reckless ‘out of sight, out of mind’ attitude towards the marine environment.
With the government committed to an increasingly unlikely target to protect 30 per cent of land and sea by 2030, this needs to change drastically. If Marine Protected Areas are to contribute meaningfully to this target, they must at a minimum be protected from commercial fishing, pollution from sewage or industry, and from being used as casual dumping grounds for large quantities of sediment.
This licence should be revoked.
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