mla-2025-00157
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| - | ==== %%**%%*Case Consultation Responses | + | ====== MLA/ |
| - | Environment Agency - Devon and Cornwall%%**%% | + | ===== Project description ===== |
| - | ==== *Consulted on 18 July 2025. Responded on 29 August 2025. ==== | + | **Project title**: Falmouth Docks Development |
| - | ***The consultee was asked for their comments on this case. They responded:** | + | **Project background** |
| - | | + | A&P Falmouth Ltd/FDEC is seeking approval to redevelop Falmouth Docks. The project aims to repair |
| - | ***Environment Agency position** | + | Redevelopment activities, to be consented through a full planning application with Cornwall Council (PA25/ |
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| + | * Demolishing the Northern Arm concrete structure below seabed level and removing the gang walkway and old timber piles west of it | ||
| + | * Constructing a suspended deck structure (Northern Wharf) within the existing 90 m gap between Queens Wharf and Northern Arm, extending functional wharf length with a deck level of +8.36 mCD | ||
| + | * Upgrading Queens Wharf structure and extending its suspended deck structure 50 m westward with a deck level of +8.4 mCD | ||
| + | * Installing a 290 m deck ('FLOW Deck') for FLOW device facilitation, | ||
| + | * Upgrading Duchy Wharf structure to support a FLOW device with a deck level of +8.24 mCD | ||
| + | * Potential strengthening works to Duchy and Country Wharf piles | ||
| + | * Demolishing on-site buildings and reconfiguring dock activities | ||
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| + | These improvements are crucial as the current infrastructure, | ||
| - | ***We have no objections to this proposal provided that conditions are included within any licence granted in respect | + | **Programme |
| - | * ***Implementation | + | The outline programme for the project is based on a worst-case programme scenario, developed to inform environmental assessments. ES Chapter 5, Section 5.2 provides more detail |
| + | However a detailed programme has not yet been produced and will be dependent on licences, funding and contractor methods/ | ||
| - | * ***Contaminated Land;** | + | The dock currently operates 24 hours per day, 7 days a week and it is anticipated that the majority of construction works would be undertaken on this basis, with the exception of demolition, piling and compaction which would not be undertaken at nighttime. |
| - | * ***Timing of piling work; and** | + | **Other information** |
| - | * ***Dredging method.** | + | Applicant details: A & P FALMOUTH LIMITED / THE DOCKS FALMOUTH / TR11 4NR// |
| + | Date application submitted: 31-MAR-2025// | ||
| + | Date application validated: 02-APR-2025// | ||
| + | Status: Submitted (In progress) | ||
| - | | + | View Application - [[https:// |
| - | | + | ===== Response Documents ===== |
| - | ***The development shall be carried out in accordance with:** | + | ===== Additional Documents ===== |
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| - | * ***the Flood Risk Assessment, produced by Ramboll (Document Reference: 15743-RAM-FD-SW-RP-EV-00015) on 17/11/2024 and** | + | ===== Representations ===== |
| - | * ***the ‘Proposed Site / Layout Plan’ document, produced by Ramboll (Document Reference: 15743-RAM-FD-SW-DR-CM-00003 REV S1-06) on 25/ | + | ==== Representation ==== |
| - | ***As stated within | + | I am writing to express my concern about application PA25/05579 (MLA/ |
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| + | I am concerned that the environmental assessment has not been conducted thoroughly, risking damage to the marine environment on which Falmouth depends | ||
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| + | Please confirm that you have received this email, and I hope that this will be followed up with environmentally responsible outcomes for Falmouth residents and visitors. | ||
| - | | + | Submitted on Fri 05 Sep 2025 10:31 |
| - | | + | ==== Representation ==== |
| - | ***Condition | + | I am writing to express my serious concern about the proposed dredging of Falmouth Harbour to accommodate larger cruise ships. While I understand the desire to encourage economic activity through cruise tourism, I believe this project carries significant risks for our environment, |
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| + | Falmouth is a unique and sensitive marine environment, | ||
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| + | Furthermore, | ||
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| + | Rather than prioritise short-time gains, I urge you to consider the long-term wellbeing of Falmouth’s people, environment, | ||
| + | Sustainable tourism, investment in local businesses, and protection of our natural heritage will serve the community far better than accommodating ever-larger cruise liners. | ||
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| + | I respectfully request that you reconsider the dredging proposal and instead explore alternative strategies that align with environmental protection, and the sustainable development of Falmouth. | ||
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| + | Thank you for your attention to this important matter. | ||
| - | ***No development approved by this planning permission shall take place until a remediation strategy that includes the following components to deal with the risks associated with contamination of the site shall each be submitted to and approved, in writing, by the local planning authority:** | + | Submitted on Fri 05 Sep 2025 10:29 |
| - | * ***A preliminary risk assessment which has identified: | + | ==== Representation ==== |
| - | * ***all previous uses** | + | I am writing to object to Marine Licence Application MLA/ |
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| + | Having reviewed the Environmental Statement and supporting documents, I have very serious concerns regarding both the adequacy of the assessments and the procedural integrity of the consultation. | ||
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| + | 1. Flawed Ecological Assessment | ||
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| + | 2. Contaminated Sediments | ||
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| + | 3. Noise and Air Quality | ||
| + | * The Noise & Vibration assessment underestimates the effects on both marine life and the local community. Dredging and construction are dismissed as “not significant” despite limited baseline monitoring and clear potential for disturbance. | ||
| + | * Air Quality assessment minimises the effect of increased shipping, construction emissions, and the continued lack of shore power for cruise liners. Cruise vessels are among the most polluting transport modes, and the claim of negligible impact is not supported by robust evidence. | ||
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| + | 4. Economic Justification | ||
| + | * The scheme is being justified partly on economic grounds, including cruise liner expansion. However, evidence shows cruise passengers contribute little to the local economy: many do not disembark, and those who do spend less than visitors arriving by other means. This does not outweigh the long-term ecological risks. | ||
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| + | 5. Procedural Irregularities | ||
| + | * The MMO’s own consultation letter to Cornwall Council explicitly stated that this project “does not fall within Annex I or Annex II of Directive 2011/92/EU or Schedule A1 or A2 of the Marine Works (EIA) Regulations 2007 and as such environmental impact assessment under the MWR is not required and no environmental statement has been supplied.” | ||
| + | * This is not a trivial error. It is a formal consultation document, and such wording risks having misled consultees, councillors, | ||
| + | * In these circumstances, | ||
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| + | Conclusion | ||
| + | The application is environmentally unsound, legally compromised, | ||
| + | * A revised Environmental Statement addresses the deficiencies outlined above; | ||
| + | * Proper compensation and Biodiversity Net Gain measures are included; and | ||
| + | * The consultation period is extended to remedy the procedural error and ensure meaningful participation. | ||
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| + | Without these steps, this licence should be refused. | ||
| - | * ***potential contaminants associated with those uses** | + | Submitted on Thu 04 Sep 2025 23:35 |
| - | * ***a conceptual model of the site indicating sources, pathways and receptors** | + | ==== NEMRG - Representation ==== |
| - | * ***potentially | + | The dredging proposed as part of this application is extreme and presents |
| + | - Very low environmental damage - replace berth pockets with floating structures taking advantage of the deep water harbour. | ||
| + | - Minimal environmental damage - create the berth pockets within cofferdams. | ||
| + | - Considerably reduced environmental damage - Adopt current international dredging best practises combined with the reuse or land disposal of dredged materials. | ||
| + | - Quantification of environmental damage - adopt current international dredging best practices. | ||
| + | Further details are provided in the attached document. | ||
| - | * ***A site investigation scheme, based on (1) to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site.** | + | [[https:// |
| - | * ***The results of the site investigation and the detailed risk assessment referred to in (2) and, based on these, an options appraisal and remediation strategy giving full details of the remediation measures required and how they are to be undertaken.** | + | ==== Falmouth Marine Conservation Representation ==== |
| - | * ***A verification plan providing details | + | We welcome the submission |
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| - | | + | ==== Representation ==== |
| - | ***Condition - Unsuspected Contamination** | + | I object to the Falmouth Docks proposal for the following reasons. |
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| + | Pollution | ||
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| + | Cruise ships are one of the most polluting ships, their diesel engines can produce more particulate emissions in a single day than thousands of London buses. They traditionally use heavy fuel oil which has a high carbon footprint that produces large amounts of CO2 and Sulfur oxides (SOx) and Nitrogen oxides (NOx). | ||
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| + | The exhaust fumes from these vessels if moored in Falmouth docks will not only fall on Falmouth but other small urban settlements within the Fal Esturary area. | ||
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| + | Whilst sailing in the Falmouth Bay near Gyllyngvase Beach I had to turn round after being engulfed in the black fumes coming from a large tanker as you sailed toward it, the residents of Falmouth cannot escape these pollutants. | ||
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| + | There is no need for any cruise ships to moor in Falmouth Harbour right next to residential and commercial properties spewing out more pollution in one day than all the vehicles in Falmouth in one day. | ||
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| + | If these cruise ships are to be allowed to moor in Falmouth Harbour they must have full shore power with engines off. | ||
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| + | Pollution form non native invasive species which may be attached to cruise ships or in their ballast or bilge tanks is more likely if more cruise ships are allowed to enter Falmouth waters. Nearly the whole of the south Cornish Coast is within an AONB and the Fal Estuary and surrounding area has several Sites of Special Scientific Interest (SSSI) which could be at risk from over development of Falmouth Harbour. The Fal Estuary is also a Special Area of Conservation. | ||
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| + | Pollution from the dredging of the harbour area, once any silt is disturbed by dredging small particulates can still escape. I understand from the Sediment and Containment Plume Modelling report that many toxic heavy metals are contained within the silt to be dredged. | ||
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| + | It is all well and good to say that any toxic dredge material will be taken away by lorry or barge to landfill or dumped out in the English Channel but we all know that you will not be able to capture all this silt as it escapes from the backhoe dredger while being lifted. | ||
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| + | I note that the semi contaminated material (called non contaminated by the report) will be taken out by barge and dumped in the disposal site shown in figure 6.38, where this is being dumped and allowed to plume is where a regular pod of dolphins are seen and feed along with seals, gannets, other sea birds and local fishermen. This cannot be right that this dredging is dumped in an area where there is a large concentration of sea life dependant on uncontaminated fish to feed. I have often sailed this area and regularly see the dolphins and gannets feeding. What is to prevent this semi contaminated dredge from washing up on the nearby coast where there are many public beaches. | ||
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| + | Pollution to highly mobile species who can swim into the harbour area and I quote from the Marine plan and Policy Statement regarding disturbance to the highly mobile species: | ||
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| + | “The EcIA , HRA and chapter 9: Marine Ecology of the ES submitted to support this application detail activities which could lead to adverse physical disturbance or displacement impacts on highly mobile species, including fish, ornithology, | ||
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| + | The sediment and containment plume report summary 7.5, page 95, shows TBT the highly toxic biocide fails in all three zones when dredged. The conclusions at 8 page 97 are shocking that any of this material could be disturbed and released into a SSSI, AONB and conservation zone of the Fal Estuary. | ||
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| + | Noise Pollution | ||
| + | The Demolition and Construction Description states that construction of the site will continue 24hrs a day, this is considered acceptable by A&P because the port operates 24hrs a day ! This is not acceptable, the noise from construction is loud and the residents of Falmouth should be entitled to a respite from the noise this project is going to make. | ||
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| + | The report also states that there will be no demolition, piling and compaction work at night, but they have not defined their definition of night time hours, maybe they would like to do this. This port area is right next to the town of Falmouth and its close by residential properties. | ||
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| + | Will the FLOW activities also be 24hrs once that area is completed, again this is not acceptable being so close to residential properties in Falmouth, no consideration seems to have been given to them at all. | ||
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| + | Falmouth docks/port is an industrial and MOD port, but has recently tried to become a leisure port by accepting cruise ships. I do not understand how this very industrial port is trying to increase its industrial footprint and at the same time and in the same location become a cruise ship port. The two do not mix, a luxury cruise ship docking next to a FLOW site and a very noisy 24hr dry dock is hardly inviting. | ||
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| + | Also where will the two Royal Fleet Auxiliary bay fleet class boats birth when cruise ships are birthed. | ||
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| + | The dredging report alone is a cause for concern. | ||
| - | | + | Submitted on Thu 04 Sep 2025 21:25 |
| - | | + | ==== Representation ==== |
| - | | + | The attached document is my formal objection to the A & P proposal to turn Falmouth' |
| - | ***No piling works shall take place in the estuary during the core sensitive period 1st April to 31st August.** | + | [[https:// |
| - | | + | ==== Cornwall Wildlife Trust Representation ==== |
| - | ***Recommendation: | + | Summary of overall position |
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| + | We welcome the detailed Environmental Statement (ES) that has been submitted for the proposed extension | ||
| - | | + | [[https:// |
| - | | + | ==== Representation ==== |
| - | ***Reason: Backhoe | + | I am writing to express my horror at the proposal to dredge 850,000 tons of seabed sediment in Falmouth harbour and the bay. |
| + | I believe that too little investigation into the effect of seabed disturbance on the rare and precious maerl beds has been made. | ||
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| + | The docks produce highly toxic contaminants which will be disturbed by the dredging. This is right next to the Fal and Helford special area of conservation, | ||
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| + | Dumping thousands of tonnes of potentially toxic sediment just outside | ||
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| + | The purpose of the dredging | ||
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| + | I believe that the current Environmental Impact Assessments are weak and flawed. So little is known about this marine environment. Much more research should be done before any disturbance occurs. Habitats regulations 2017 states, "the developer must prove no adverse impact on the SAC". We must abide by the precautionary principal with respect to this decision. If this Environmental damage is done, it will be regretted for generations. | ||
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| + | I have lived by Falmouth Bay for nearly 40 years, I and thousands | ||
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| + | I register my strong objection to dredging | ||
| - | | + | Submitted on Wed 03 Sep 2025 18:33 |
| - | ***We have reviewed the Flood Risk Assessment, produced by Ramboll (Document Reference: 15743-RAM-FD-SW-RP-EV-00015) on 17/11/2024. We consider that it has adequately assessed the risks to the proposed development. We therefore consider that the proposed development will be acceptable in flooding terms provided that the minimum finished deck level for all new development shall be set no lower than 5.33m AOD and the development is built in accordance with the submitted ‘Proposed Site / Layout Plan’ document, produced by Ramboll (Document Reference: 15743-RAM-FD[1]SW-DR-CM-00003 REV S1-06) on 25/09/2023. We consider that the above condition will be sufficient to secure this mitigation.** | + | ==== Representation ==== |
| - | | + | I believe |
| + | It would be a tragedy to all sea habitats for miles. | ||
| + | if this was approved. | ||
| - | | + | Submitted on Wed 03 Sep 2025 18:26 |
| - | | + | ==== Representation ==== |
| - | ***We have reviewed | + | I do support |
| - | ***We therefore consider that permission should only be granted for the proposed development as submitted if the above conditions are included within any permission granted. Without these conditions, the proposed development | + | Submitted |
| - | | + | ==== Representation ==== |
| - | | + | Whilst of course anybody can understand |
| + | I implore you to conduct more studies to investigate | ||
| - | | + | Submitted |
| - | | + | ==== Representation ==== |
| - | ***The River Fal is designated | + | The MMO has incorrectly stated that this project does not fall within Annex I/II of Directive 2011/92/EU or Schedule A1/A2 of the Marine Works Regulations. In reality, capital dredging and port expansion of this scale clearly qualifies |
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| + | The best practice standards for surveying the site have not been met. This project will cause irreparable harm to our local marine life during | ||
| + | The modeling that has been done so far does not accurately depict | ||
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| + | It appears that assessment of harm to marine life from vibrations and acoustics has been omitted, as well as considerations of migratory | ||
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| + | It has come to my attention that the developer is using out-of-date maps to conduct ecological surveys. The HRA's conclusion of “no likely significant effect” on the Fal & Helford SAC was made on the basis of out-of-date reports and maps. This fails to meet the requirements of the Habitats Regulations 2017. | ||
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| + | It seems that precautionary principle has been ignored. Uncertainty | ||
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| + | On a personal level, many Falmouth residents already suffer from ill health resulting from excessive pollution (especially in the summer months) from cruise ships and A& | ||
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| + | An increase in cruise ships to our town would be awful. We already suffer from the increased air pollution from the ships as is, not to mention hoards of rude tourists who treat our streets and the people who live here abhorrently. We have to work shifts late into the night to accommodate their hospitality needs, | ||
| + | We need to ask ourselves: How can we expect the local population | ||
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| + | If a Falmouth devoid of culture and humanity is what you want, by all means green-light this ill-considered, | ||
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| + | Do a proper EIA and provide a transparency statement on where the profits from this project will be going. Anything less is criminal. | ||
| - | | + | Submitted on Wed 03 Sep 2025 10:45 |
| - | ***We have reviewed the WFD assessment and do not have any concerns; it covers everything we would expect to see. The waterbody is at Good Ecological Status, so the focus of the assessment needs to be on no deterioration and mitigating any risks for activities that may cause deterioration. We are satisfied that the assessment considers these adequately.** | + | ==== Representation ==== |
| - | | + | I object to this proposal |
| + | My reasons for this point of view are as follows: | ||
| + | Dredging | ||
| + | I am concerned that the size, and effects, of the sediment plume has been underplayed – relying on rising tide dredging and ignoring any effect of storm resuspension. | ||
| + | The Habitats Regulation are clear – the developer must prove there are no adverse impacts on Special Areas of Conservation – this is not the case with this application. The precautionary principle, where uncertainty exists, is legally required to apply: uncertainty clearly does exist here (insufficient baseline evidence, unproven need, a ‘do more’ approach). | ||
| + | In summary: my opinion is that this is an application to do the maximum development and has been crafted around strictly economic priorities. Whilst they should | ||
| - | | + | Submitted |
| - | | + | ==== Representation ==== |
| - | ***Safeguards need to be sought from the applicant | + | Dear Marine Licensing Team, |
| + | |||
| + | I write to formally object to marine licence application MLA/ | ||
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| + | 1. Incompatibility with Legislation and Environmental Protections | ||
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| + | 2. Environmental Impacts of Larger Cruise Ships | ||
| + | * The dredging appears primarily intended to allow “ultra-deep” cruise ships to dock, even though offshore wind infrastructure can be transported on shallower-draft vessels. | ||
| + | * Cruise ships disproportionately increase local air pollution, carbon emissions, sewage discharge, and turbidity (Commoy et al., 2005; Deidun & Vella, 2011; Carić & Mackelworth, | ||
| + | * These risks conflict with the Environmental Act 2021 and Climate Change Act 2008, which emphasise sustainable, | ||
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| + | 3. Insufficient Monitoring | ||
| + | * The Environmental Statement lacks a credible plan for monitoring re-suspended contaminants (e.g. copper, mercury, arsenic) from historic antifouling biocides known to cause significant environmental harm (de Campos et al., 2022). | ||
| + | * The modelling provided fails to consider storm-induced plumes or cumulative impacts on maerl, eelgrass, and native oyster habitats. | ||
| + | * No modern hydrographic surveys or independent monitoring regime are proposed, leaving | ||
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| + | I therefore request that the MMO: | ||
| + | 1. Reject the application unless a full Appropriate Assessment is conducted and made public. | ||
| + | 2. Require comprehensive, | ||
| + | 3. Mandate robust, independent monitoring, including real-time tracking | ||
| + | 4. Re-evaluate | ||
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| + | The Falmouth Bay and Fal Estuary’s rare and fragile ecosystems deserve the highest level of protection. I urge the MMO to refuse this licence in its current form. | ||
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| + | Thank you for your consideration in this matter | ||
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| + | Blake, C. and Maggs, C.A., 2003. Comparative growth rates and internal banding periodicity of maerl species (Corallinales, | ||
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| + | Carić, H. and Mackelworth, | ||
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| + | Commoy, J., Polytika, C.A., Nadel, R. and Bulkley, J.W., 2005. The environmental impact of cruise ships. In Impacts of global climate change (pp. 1-12). | ||
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| + | de Campos, B.G., Figueiredo, J., Perina, F., Abessa, D.M.D.S., Loureiro, S. and Martins, R., 2022. Occurrence, effects and environmental risk of antifouling biocides (EU PT21): are marine ecosystems threatened? | ||
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| + | Deidun, A. and Vella, P., 2011. Marine Ecological Impact Considerations for Cruise Liner Facility Development at Two Coastal Sites in the Maltese Islands. Journal of Coastal Research, (61), pp.114-122. | ||
| - | | + | Submitted on Mon 01 Sep 2025 13:58 |
| - | | + | ==== Representation ==== |
| - | ***The outline Construction Environment Management Plan (CEMP) seems a thorough document, but you may like to include | + | I object to this application on a number of grounds, there has been a flawed Ecological Impact Assessment (EcIA): Sensitive habitats like Maerl beds and seagrass are acknowledged, |
| + | In addition cumulative impacts have been ignored: | ||
| + | Pollution and contaminants: | ||
| + | Public consultation fairness: Because of the MMO’s error, the public and decision-makers may have wrongly assumed minimal impacts. The consultation period should | ||
| + | In addition, there have been no land based surveys to look for the impact that this development would have on bats, birds, invertebrates | ||
| + | Finally, I object on grounds of massively increased air pollution: Cruise liners keep engines running while in port, pumping out sulphur dioxide, nitrogen oxides, and particulates from heavy fuel oil , | ||
| - | | + | Submitted on Mon 01 Sep 2025 13:57 |
| - | | + | ==== Representation ==== |
| - | ***Waste hierarchy guidance** | + | Subject: Formal Objection to Application MLA/ |
| + | Dear Sir/ | ||
| + | We write to strongly object to the proposed dredging of Falmouth Harbour (MLA/ | ||
| + | |||
| + | 1. Massive Release of Contaminated Sediments | ||
| + | Reports warn that the plan entails removing 850,000 tonnes of toxic sludge from the harbour seabed, potentially spreading contamination across Falmouth Bay and beyond (Yahoo News UK). The sediments include legacy dockyard waste, heavy metals, hydrocarbons, | ||
| + | These risks contravening the Water Framework Directive (2000/ | ||
| + | |||
| + | 2. Scientific and Survey Deficiencies | ||
| + | | ||
| + | | ||
| + | | ||
| + | These deficiencies fall short of the Environmental Impact Assessment Regulations 2017, which mandate comprehensive and representative baseline surveys. | ||
| + | |||
| + | 3. Threats to Protected Habitats | ||
| + | | ||
| + | | ||
| + | * This undermines the Habitats Regulations 2017, which require an Appropriate Assessment and application of the precautionary principle in the face of uncertainty. | ||
| + | |||
| + | 4. Inadequate Assessment of Environmental Risk | ||
| + | * Sediment plume modelling is simplistic, ignoring storm-driven resuspension, | ||
| + | * Disturbance to marine mammals and seabirds has been dismissed without acoustic or disturbance modelling compliant with JNCC guidelines. | ||
| + | * No consideration of combined effects with other harbour and coastal activities, contrary to the Marine Policy Statement 2011 requirement for cumulative impact assessment. | ||
| + | |||
| + | 5. Air Pollution, Carbon Emissions, and Climate Impacts | ||
| + | * Dredging operations will generate significant CO₂, NOₓ, SOₓ, and particulate emissions, conflicting with the UK’s binding Climate Change Act 2008 (Net Zero target 2050). | ||
| + | * Re-suspension of organic-rich sediments will release “locked-in” blue carbon, undermining the UK’s climate adaptation and mitigation duties. | ||
| + | * Dust and fine particulate emissions risk exceeding safe thresholds established under the Air Quality Standards Regulations 2010 and WHO Air Quality Guidelines (2021 update). | ||
| + | |||
| + | 6. Public Health Concerns | ||
| + | * Legacy pollutants (arsenic, cadmium, mercury, hydrocarbons) risk bioaccumulation in fish and shellfish, threatening both public health and Cornwall’s seafood industry. | ||
| + | * Turbidity and contamination could compromise bathing water quality, potentially breaching obligations under the Bathing Water Regulations 2013 (derived from EU Bathing Water Directive 2006/ | ||
| + | * Local communities face exposure to airborne pollutants in contravention of the Public Health Act 1936 and Environmental Protection Act 1990. | ||
| + | |||
| + | 7. Socio-Economic and Cultural Impacts | ||
| + | * Falmouth Bay supports fishing, aquaculture, | ||
| + | * Damage to eelgrass and maerl beds undermines long-term ecosystem services, cultural heritage, and the Government’s “levelling up” commitments to coastal communities. | ||
| + | |||
| + | 8. Legal Non-Compliance | ||
| + | * The Habitats Regulations do not allow a “no likely significant effect” finding without robust evidence; speculative conclusions are unlawful. | ||
| + | * The EIA Regulations 2017 mandate assessment of air quality, socio-economic, | ||
| + | * The Marine Policy Statement 2011 requires precaution where evidence is lacking; this application disregards that statutory duty. | ||
| + | * The proposal also undermines obligations under the Environment Act 2021, which requires halting biodiversity decline and improving water quality. | ||
| + | |||
| + | Conclusion | ||
| + | Approving dredging under these conditions would be irresponsible, | ||
| - | | + | [[https:// |
| - | ***As much material as possible should be re-used | + | Submitted |
| - | | + | ==== Representation ==== |
| - | ***The applicant | + | Dear Marine Licensing Team, |
| + | |||
| + | I wish to lodge a formal objection to application MLA/ | ||
| + | |||
| + | 1. Inadequate Environmental Assessment | ||
| + | | ||
| + | | ||
| + | * Cumulative impacts with other pressures in the Fal Estuary are barely addressed. This is a major flaw given the multiple existing stressors on the system. | ||
| + | |||
| + | 2. Contaminated Sediment | ||
| + | * The project proposes | ||
| + | * These sediments are known to contain tributyltin (TBT) and heavy metals from historic dockyard activity. | ||
| + | * Mobilisation of these contaminants risks spreading pollution into oyster beds and designated shellfish waters, posing ecological, economic, and public health risks. | ||
| + | |||
| + | 3. Lack of Mitigation and Compensation | ||
| + | * Mitigation measures are vague and rely heavily | ||
| + | * No credible compensation or restoration plan is offered | ||
| + | * The scheme fails to demonstrate compliance with Cornwall Local Plan requirements for 10% biodiversity net gain. No marine or terrestrial BNG is calculated or provided. | ||
| + | |||
| + | 4. Procedural Concerns: The MMO Error | ||
| + | * The MMO’s own consultation letter | ||
| + | * This is not a trivial drafting slip. It is a formal consultation document, and its wording would have materially affected how councillors and members of the public understood the application. | ||
| + | * Many consultees may reasonably have assumed the project was minor in scope and did not require EIA. In fact, the opposite is true. | ||
| + | |||
| + | 5. Fairness of Consultation | ||
| + | * Because of this error, consultees have not had a fair opportunity to respond. | ||
| + | * The consultation period | ||
| + | |||
| + | Conclusion | ||
| + | The current application | ||
| + | | ||
| + | | ||
| - | | + | Submitted on Mon 01 Sep 2025 13:30 |
| - | | + | ==== Representation ==== |
| - | ***The law requires anyone dealing with waste to keep it safe and make sure it’s dealt with responsibly | + | I am writing to you in reference to the application MLA/ |
| + | |||
| + | There has been some extensive research about the negative impact of big cruise ships on our environment, | ||
| + | |||
| + | Several port cities around Europe have already started to crack down on cruise ships amid these mounting health and environmental concerns. They are leading the way towards a more responsible form of tourism and overall preservation of our valuable resources. | ||
| + | |||
| + | Although many cruise companies have started touting their green potential, very few are reducing their environmental footprint fast enough. | ||
| + | |||
| + | I have also been looking, more specifically, | ||
| + | |||
| + | Dredging docks can negatively impact the environment by disrupting habitats, increasing water turbidity, releasing pollutants, and altering seabed morphology. These impacts include the destruction of spawning grounds, coral reefs, | ||
| + | |||
| + | Seabed Changes: | ||
| + | The physical characteristics | ||
| + | |||
| + | Toxic pollutants: | ||
| + | The currently dormant toxic heavy metals being re-suspended in the process is alarming. | ||
| + | |||
| + | Contaminated Waste: | ||
| + | Sediments removed during dredging, especially from historically industrial areas, | ||
| + | |||
| + | Given the fact that the dredging will take place in an area adjacent to a Special Area of Conservation, | ||
| + | |||
| + | My research lead me to explore the legal aspect of the current MMO. I am surprised and deeply concerned by the recording of the project: | ||
| + | I came across Annex I/II of Directive 2011/92/EU and Schedule A1/A2 of the Marina Works (EIA) Regulations 2007. | ||
| + | According to the above, the current MMO appears to have been incorrectly recorded and this could have all kinds of undesired consequences, | ||
| + | |||
| + | Reference: | ||
| + | |||
| + | Under schedule A2, paragraph 8 of the 2007 Regulations, | ||
| + | Please note that the European Directive 2011/ | ||
| + | |||
| + | Under the current proposal, a huge amount of seabed material (850 tonnes) would be dredged and disposed of. All this activity would be taking place in proximity to a Special Area of Conservation. There is lack of information regarding the dumping of material 9km SE of the docks. | ||
| + | The aim of this development being to expand the functionality and activity of an existing commercial port. Such a project falls clearly under the Schedule A2 project category. | ||
| + | |||
| + | Should the MMO be proven to be incorrectly recorded, which it appears to be the case (i.e. as not Annex I/II and not as Schedule A1/A2), that could significantly be misleading, therefore impacting, above all, the legality of the EIA which is currently in process. | ||
| + | |||
| + | In the light of this, I am asking you, Ms Golightly, if your team could please: | ||
| + | |||
| + | 1. Clarify on what grounds the project was recorded as not fully falling under ‘Schedule A2’ category. | ||
| + | |||
| + | 2. If it is an inappropriate recording, can it be confirmed that the correct classification of Schedule 2 will be officially recognised as soon as possible? | ||
| + | |||
| + | 3. Ensure that the statutory E.I.A. will be processed accordingly due to the legal aspect of the above points which could undermine its validity. | ||
| + | |||
| + | Thank you in advance for your assistance. | ||
| - | ***In order to meet the applicant’s objectives for the waste hierarchy and obligations under the duty of care, it is important that waste is properly classified. Some waste (e.g. wood and wood based products) may be either a hazardous or non-hazardous waste dependent upon whether or not they have had preservative treatments.** | + | Submitted on Mon 01 Sep 2025 13:11 |
| - | | + | ==== Representation ==== |
| - | ***Informative | + | (Continued from Public Representation 19) |
| + | |||
| + | There is no version of this development that is environmentally beneficial. On the contrary, it risks wiping out Falmouth’s unique cultural heritage alongside its fragile ecosystems. | ||
| + | I would wholeheartedly support the FLOW contracts being prioritised and invested in, but not rolled in with this other detrimental works. As currently this FLOW part is being used as a clear greenwashing justification. It does not depend on this dredging, and in any case is more likely to be developed in the Northeast or Scotland, where the heavy industrial docks infrastructure already exists, and where they’ll mainly be deployed. | ||
| + | |||
| + | As one saying goes: “I’ve made you a cheese and asbestos sandwich—and you like cheese.” | ||
| + | |||
| + | |||
| + | The other major area of concern regarding the development is the failure to account for any marine elements in their legal obligation to deliver 10% BNG. | ||
| + | |||
| + | I am assuming this is outside of the remit of your assessment, but it is still worthwhile flagging up here as it shows another significant failure to follow an environmentally sensitive strategy. | ||
| + | |||
| + | For fact-checking on any of my assertions above, I refer you to Transport & Environment, | ||
| + | |||
| + | Or for verification, | ||
| - | ***We have reviewed the report entitled “Best Practicable Environmental Option (BPEO) Assessment”. Included within the report is an assessment to determine the BPEO for the management and disposal of waste and dredge arisings. One of the potential disposal options identified involves disposal | + | Submitted |
| - | | + | ==== Representation ==== |
| - | ***Yours sincerely** | + | Representing the organisation Ocean Rebellion as one of the co-founders. |
| + | Objection letter: | ||
| + | I object strongly to this development. | ||
| + | |||
| + | After speaking with many marine biology experts and oyster fishermen in the local area about their professional views on this application, | ||
| + | |||
| + | Their submitted dredging plan shows the additional 8 metre depth of dredge is to provide 2 large berths for the new super-sized deeper keeled cruise liners, as labelled on their own plans. | ||
| + | |||
| + | Here is my breakdown of their various failures to follow due process. | ||
| + | |||
| + | The Environmental Impact Assessment (EIA) is fundamentally flawed. I will not repeat all the specific issues, as they were clearly outlined in \[other\] objection letters, which I fully support. | ||
| + | |||
| + | However, even putting aside the weaknesses of the EIA, anyone with basic knowledge of how the sea works can see that the proposed dredging would be ecologically devastating. The dredge site lies directly off the dock quays, where, for decades—before any environmental controls existed—huge quantities of toxic waste were dumped. Many of these substances, now banned because of their extreme biocidal effects, remain in the seabed. These so-called “forever chemicals, | ||
| + | |||
| + | Disturbing this toxic sludge would be catastrophic for marine life. Despite some improvements in dredging technology, it is still impossible to remove this material delicately. It will not be contained in a sealed, non-polluting process. In reality, a massive dredger will churn up and spread tons of contaminated sediment throughout the surrounding waters, however carefully operated. | ||
| + | |||
| + | Nearly one million tons of this toxic sludge is then intended to be dumped offshore, in relatively shallow water. Once resuspended, | ||
| + | |||
| + | To make matters worse, this activity would take place immediately adjacent to a critical North Atlantic coral site, with the waste also deposited near other marine conservation zones of ecological importance. | ||
| + | |||
| + | The impacts extend beyond ecology. Commercial oyster beds will be threatened, putting at risk not just livelihoods but also our cultural heritage. By undermining the already fragile oyster fishery and the rare sailing tradition tied to it, this development amounts to both ecocide and cultural vandalism. If the oyster fishery collapses, it could spell the end of the Falmouth Oyster Festival, the Falmouth Working Boat sailing tradition, and the traditional boatbuilding heritage, of which Falmouth is global recognised —all of which are the backbone of Falmouth’s identity and tourism appeal. | ||
| + | |||
| + | In short: many species, traditions, and livelihoods face immense risk—while the only real beneficiary would be A& | ||
| + | |||
| + | Proponents claim that large cruise ships will bring economic benefits, but this is marketing spin, contradicted by fact. If cruise ships were truly so valuable, ports around the world would be clamouring for more. Instead, there is a growing global movement to limit or ban them due to the vast ecological and social damage they cause. Cruise tourists spend, on average, only about 20% of what other visitors contribute to local economies, and around half never leave the ship at all. Cruise companies deliberately encourage this, as money spent ashore reduces their own profits. | ||
| + | |||
| + | Moreover, the cruise liners Falmouth hopes to attract are utterly incompatible with a small town. Their arrival brings noise, congestion, and traffic disruption. Worse still, the air pollution from a single idling ship is equivalent to emissions from one million cars, releasing SOx and NOx at dangerous levels. These pollutants have immediate health impacts—raising asthma rates in children and contributing to long-term brain damage from toxic exposure. If these emissions came from a land-based source, the operators would be fined thousands of pounds per hour. | ||
| + | |||
| + | (Concluded on Public Representation 20) | ||
| - | | + | Submitted on Mon 01 Sep 2025 10:52 |
| - | | + | ==== Representation ==== |
| - | ***Direct dial 0208 474 6316** | + | Continued from PR 17: |
| + | |||
| + | OSPAR report 2018 | ||
| + | “Dredging activities have negative impacts on the marine environment Only limited information is available on the overall effects of dredging activities on species, habitats and ecosystem processes in the OSPAR Maritime Area. The removal of sediments, greater turbidity or enhanced erosion, due to dredging activities, can have adverse impacts on habitats such as estuaries, sandbanks, mud flats and salt marshes. Dredging activities influence the often diverse fauna and flora of these habitats, including threatened and or declining species or species that are of particular economic interest. Dredging activities may also lead to a re-suspension of sediments and associated harmful contaminants such as trace metals and there is a potential that these contaminants may be taken up in the food chain. Deposit of sediments on the seabed may bury benthos organisms and lead to changes in habitat and biological communities. Dredging activities also contribute to the cumulative impacts of human activities on the marine environment. | ||
| + | More efforts are needed to monitor and assess the effects on the marine ecosystems This assessment indicates that further efforts are needed to better understand the actual effects of dredging on the marine ecosystems of the OSPAR Maritime area. OSPAR should therefore consider options for monitoring and assessment of dredging activities that would allow a clearer analysis of the effects on species, habitats and ecosystems processes as well as an evaluation of the effectiveness of existing regulations, | ||
| + | https:// | ||
| + | |||
| + | Marine Pollution Bulletin 2018 | ||
| + | | ||
| + | | ||
| + | | ||
| + | “These impacts demonstrate that dredging in major UK ports is frequently associated with changes to both physical marine environments and the ecological dynamics of affected regions, and that careful monitoring and mitigation are necessary to reduce long-term ecological harm.” | ||
| + | https:// | ||
| + | |||
| + | This also relates to Marine Licence Application MLA/ | ||
| - | | + | Submitted on Mon 01 Sep 2025 10:50 |
| - | [[https:// | + | ==== Representation ==== |
| - | ==== *Natural England | + | I am writing to object to the application (MLA/ |
| + | a) in relation to support of high carbon industry; | ||
| + | b) in the absence of ecological reporting rigour and | ||
| + | c) due to high risk of ecological damage (As per historical and industry knowledge at UK ports) | ||
| + | |||
| + | |||
| + | a) High Carbon Industry has no place in a Climate Emergency | ||
| + | Cornwall Council and local councils have declared a climate emergency which precludes supporting carbon intensive activities which are known to be harmful to the environment – ie Cruise holidays and their associated emissions and carbon impact. | ||
| + | |||
| + | The CC Marine strategy specifically refers to promotion of low carbon marine enterprise, which the Cruise Ship industry evidently is not. | ||
| + | |||
| + | That said, improving harbour resources may have other benefits and those must be balanced with the risks of any development intervention as per Cornwall Council’s precautionary position on development. For example, their marine planning and recovery framework promotes evidence-based decision-making and encourages early action to protect habitats and species when there is uncertainty, aligning with the precautionary principle. | ||
| + | |||
| + | b) Ecology Report Rigour | ||
| + | |||
| + | Ramboll UK Ltd Ecology Reports | ||
| + | |||
| + | In the Ramboll UK Ltd ecology reports, the use of generic terms such as “unlikely” in relation to risk of events, with no indication what “unlikely” means, (does this mean once a week? Or once in 10 years| and with no context in relation to the impact of that risk is remarkable – all risk analysis must compare likelihood with consequences, | ||
| + | |||
| + | In addition, the report “Assumes” there will; be 11 additional cruise vessels and 12 additional cargo vessels visiting Falmouth Docks per year. Approximately an additional 15 hours/year during which animals could be disturbed from underwater noise associated with vessels. Additional boat movements will contribute intermittent noise which will not have a discernible effect on noise climate | ||
| + | |||
| + | Firstly, using assumptions to make critical decisions seems bizarre in this context – both in relation to ecological and economic impacts. | ||
| + | |||
| + | Secondly, the suggestion that each passing of a vessel will result in just 39 minutes of noise pollution is frankly ridiculous, particularly given that for cruise ships and other large vessels to enable continuous support of on board systems, it is necessary for their engines to remain running whilst in port. This highlights a lack of reporting rigour in relation to noise pollution. | ||
| + | |||
| + | c) Environmental Impact | ||
| + | Several organisations report the increasing awareness of environmental harm associated with disturbance of marine beds and development in marine areas (See below; CEFAS, the EA and OSPAR for example, in addition to scientific peer reviewed publications), | ||
| + | |||
| + | To my knowledge this has not been done as part of this development application, | ||
| + | |||
| + | The Environmental Agency: | ||
| + | “What is the impact on the environment? | ||
| + | Dredging and desilting can have serious and long lasting negative impacts on the environment. For example, it can damage or destroy fish spawning grounds and make river banks unstable. Silt can become suspended in the water, lowering oxygen levels, potentially releasing harmful chemicals that may be present. This, in turn, impacts on wildlife, and water quality downstream. The silt that has been removed from rivers can be difficult to dispose of, particularly where it is contaminated due to the historic industrial activity on the lower catchments of our rivers. | ||
| + | Before we undertake dredging and desilting activities we make sure the work will not have any negative impacts on the environment, | ||
| + | https:// | ||
| + | |||
| + | (continued in Public Representation 18) | ||
| - | ==== *Consulted | + | Submitted |
| - | ***The consultee was asked for their comments on this case. They responded: | + | ==== Representation ==== |
| - | ***Thank you for your consultation dated 18 July 2025. Please | + | Dear Marina Licensing Team, |
| + | |||
| + | There has been some extensive research about the negative impact of big cruise ships on our environment, | ||
| + | |||
| + | Several port cities around Europe have already started to crack down on cruise ships amid these mounting health and environmental concerns. They are leading the way towards a more responsible form of tourism and overall preservation of our valuable resources. | ||
| + | |||
| + | Although many cruise companies have started touting their green potential, very few are reducing their environmental footprint fast enough. The increase in the size of their ships is far from helping this issue. Carbon dioxide and sulphur emissions represent some of the alarming red flags. | ||
| + | |||
| + | I have also been looking, more specifically, | ||
| + | |||
| + | Dredging docks can negatively impact the environment by disrupting habitats, increasing water turbidity, releasing pollutants, and altering seabed morphology. These impacts include the destruction of spawning grounds, coral reefs, and seagrass beds, leading to reduced oxygen levels and stress on marine life. The sediment, often contaminated, | ||
| + | |||
| + | Seabed Changes: | ||
| + | The physical characteristics of the seabed, including topography and sediment particle size, are changed, potentially affecting the stability of the area and increasing erosion. | ||
| + | |||
| + | Toxic pollutants: | ||
| + | The currently dormant toxic heavy metals being re-suspended in the process is alarming. | ||
| + | |||
| + | Contaminated Waste: | ||
| + | Sediments removed during dredging, especially from historically industrial areas, can be heavily contaminated, | ||
| + | |||
| + | Given the fact that the dredging will take place in an area adjacent to a Special Area of Conservation, | ||
| + | |||
| + | My research lead me to explore the legal aspect of the current MMO. I am surprised and deeply concerned by the recording of the project: | ||
| + | I came across Annex I/II of Directive 2011/92/EU and Schedule A1/A2 of the Marina Works (EIA) Regulations 2007. | ||
| + | According to the above, the current MMO appears to have been incorrectly recorded and this could have all kinds of undesired consequences, | ||
| + | |||
| + | Reference: | ||
| + | |||
| + | Under schedule A2, paragraph 8 of the 2007 Regulations, | ||
| + | Please | ||
| + | |||
| + | Under the current proposal, a huge amount of seabed material (850 tonnes) would be dredged and disposed of. All this activity would be taking place in proximity to a Special Area of Conservation. There is lack of information regarding the dumping of material 9km SE of the docks. | ||
| + | The aim of this development being to expand the functionality and activity of an existing commercial port. Such a project falls clearly under the Schedule A2 project category. | ||
| + | |||
| + | Should the MMO be proven to be incorrectly recorded, which it appears to be the case (i.e. as not Annex I/II and not as Schedule A1/A2), that could significantly be misleading, therefore impacting, above all, the legality of the EIA which is currently in process. | ||
| + | |||
| + | In the light of this, I am asking you, Ms Golightly, if your team could please: | ||
| + | |||
| + | 1. Clarify on what grounds the project was recorded as not fully falling under ‘Schedule A2’ category. | ||
| + | |||
| + | 2. If it is an inappropriate recording, can it be confirmed that the correct classification of Schedule 2 will be officially recognised as soon as possible? | ||
| + | |||
| + | 3. Ensure that the statutory | ||
| + | |||
| + | Thank you in advance for your assistance. | ||
| - | ***The consultee included the following files with their response:** | + | Submitted on Sun 31 Aug 2025 19:55 |
| - | * %%**%%*[[https:// | + | ==== Representation ==== |
| - | ==== *Crown Estate - Marine Estates ==== | + | i am submitting this objection as a concerned member of the public who sees an environmentally damaging development taking place in the name of economic gain. we don't need more cruise ships. they are hugely damaging operations in themselves. |
| + | to dredge and destroy rare maerli beds for the construction of this facility is inexcusable and the stirring up of toxic sediment which will be prejudicial to marine life is not acceptable. | ||
| + | we need extensive National infrastructure in this country for our energy needs, day to day transport, improving water quality etc Not pointless Projects like this. | ||
| + | There are grounds to refuse this application due to a flawed MMO consultation and misleading of the public around the need for an EIA. Please refuse this application. | ||
| - | ==== *Consulted | + | Submitted |
| - | ***The consultee was asked for their comments on this case. They responded: | + | ==== Representation ==== |
| - | ***The Crown Estate is affected by the proposed works and landowner’s consent | + | Dear Marine Licensing Team, |
| + | |||
| + | I object to MLA/ | ||
| + | |||
| + | The dredging | ||
| + | |||
| + | Given these flaws, the assessments do not provide the robust scientific basis required | ||
| + | |||
| + | Yours faithfully, | ||
| + | Belle Benfield | ||
| - | | + | Submitted on Sat 30 Aug 2025 10:42 |
| - | | + | ==== Representation ==== |
| - | ==== *Duchy | + | Subject: Formal Objection to Application MLA/ |
| + | |||
| + | Dear Sir/ | ||
| + | |||
| + | I write to submit a formal objection to the above application for dredging works in Falmouth Harbour. The proposal, involving the removal | ||
| + | |||
| + | 1. Water Quality and Pollution Control | ||
| + | |||
| + | The Water Framework Directive 2000/60/EC (retained in UK law) prohibits deterioration of water bodies; dredging would release legacy dockyard waste, hydrocarbons, | ||
| + | |||
| + | Increased turbidity risks contravening the Bathing Water Regulations 2013, while dust and particulates may breach the Air Quality Standards Regulations 2010. | ||
| + | |||
| + | Emissions and nuisance effects engage duties under the Environmental Protection Act 1990. | ||
| + | |||
| + | 2. Biodiversity and Habitats | ||
| + | |||
| + | Adjacent eelgrass and maerl beds are protected under the Habitats Regulations 2017. An Appropriate Assessment is legally required; proceeding without one would be unlawful. | ||
| + | |||
| + | The proposal conflicts with the Environment Act 2021 (biodiversity duty) and Marine and Coastal Access Act 2009 (sustainable marine management). | ||
| + | |||
| + | 3. Environmental Assessment Deficiencies | ||
| + | |||
| + | The EIA Regulations 2017 require comprehensive surveys and cumulative impact assessments. Only five grab samples were taken; no seasonal or modern habitat surveys were undertaken. | ||
| + | |||
| + | Plume modelling ignores storm-driven resuspension and long-term turbidity. | ||
| + | |||
| + | The Marine Policy Statement 2011 requires precaution and cumulative assessment, both absent here. | ||
| + | |||
| + | 4. Climate Change and Carbon | ||
| + | |||
| + | Under the Climate Change Act 2008 (as amended 2019), the UK is legally bound to Net Zero by 2050. | ||
| + | |||
| + | Dredging will generate substantial CO₂, NOₓ, SOₓ emissions and release stored “blue carbon,” yet no assessment has been provided. | ||
| + | |||
| + | 5. Public Health and Food Safety | ||
| + | |||
| + | Toxic contaminants (arsenic, cadmium, mercury, hydrocarbons) risk bioaccumulating in fish and shellfish, contravening the Food Safety Act 1990 and fisheries legislation. | ||
| + | |||
| + | Airborne exposure risks are relevant under the Public Health Act 1936. | ||
| + | |||
| + | Conclusion | ||
| + | |||
| + | This application breaches multiple statutory obligations, | ||
| + | |||
| + | Water Framework Directive (2000/ | ||
| + | |||
| + | Habitats Regulations 2017 | ||
| + | |||
| + | Environment Act 2021 | ||
| + | |||
| + | EIA Regulations 2017 | ||
| + | |||
| + | Marine Policy Statement 2011 | ||
| + | |||
| + | Climate Change Act 2008 | ||
| + | |||
| + | Bathing Water Regulations 2013 | ||
| + | |||
| + | Air Quality Standards Regulations 2010 | ||
| + | |||
| + | Environmental Protection Act 1990 | ||
| + | |||
| + | Approval under such conditions would be unlawful, scientifically unsound, and environmentally catastrophic. | ||
| + | |||
| + | I therefore urge the MMO to refuse consent unless comprehensive ecological, hydrodynamic, | ||
| - | ==== *Consulted | + | Submitted |
| - | ***The consultee was asked for their comments on this case. They haven’t submitted a response yet.** | + | ==== Representation ==== |
| - | ==== *Historic England | + | My representation is that - |
| + | |||
| + | The proposal to dredge the harbour would appear to be serve the cruise industry and increase the profits | ||
| + | |||
| + | I see nothing to evidence that provision for Floating Offshore Wind (FLOW) related, which is welcome and of economic value to the local area, would require a deeper harbour. | ||
| + | |||
| + | Dredging the harbour to accommodate more and larger cruise ships would destroy areas of delicate seabed habitat which have taken years to develop and also damage those further away with suspended sediment. There are maerl beds within 100 to 200m of the dredging site. | ||
| + | |||
| + | Dumping 850,000 tonnes of sediment, highly toxified with heavy metals and oil, in Falmouth Bay will smother the seabed and damage marine life taking years to recover. I remember the Torrey Canyon. | ||
| + | |||
| + | It would appear that previous studies are out of date. | ||
| + | |||
| + | There has been no assessment of the impact on marine mammals. | ||
| + | |||
| + | The cost benefit to ports where cruise ships dock is questionable given that outings are arranged with tour companies to visit outside the area necessitating more vehicles on local roads with no benefit to town centre and local businesses. Passengers who fly to meet their ship will not have the capacity in their luggage to buy very much. | ||
| + | |||
| + | These ships are out of scale for Falmouth and views across the Carrick Roads are already marred by the floating tower blocks which currently call in. The smaller cruise ships which call in are more suitable and presumably do not need a deep channel. | ||
| + | |||
| + | There has been talk of installing a power supply ship to shore but how will the grid deal with powering what is essentially a large village moored in the harbour? Currently the ships power themselves sending pollution over the town. Our grandson’s asthma has hardly troubled him since they moved away from the hill above the docks. | ||
| + | |||
| + | Where does the sewage and waste go? | ||
| + | |||
| + | Where do they re vittle? | ||
| + | |||
| + | Given that some ships have desalination plants, where do they take on the extra water they need? | ||
| + | |||
| + | Increasing the traffic of cruise ships will destroy the very reason for them coming. I’ve seen ships blocking out the view across the lagoon in Venice. The authority has now restricted access only to smaller ships which do less general environmental damage. | ||
| - | ==== *Consulted | + | Submitted |
| - | ***The consultee was asked for their comments on this case. They responded: | + | ==== Representation ==== |
| - | ***Please find attached Historic England’s advice note** | + | Please find below a briefing regarding application MLA/ |
| + | Given the scale and location of this dredge adjacent to a Special Area of Conservation, | ||
| + | The full briefing is set out below for ease of reference: | ||
| + | |||
| + | FULL BRIEFING | ||
| + | I note that in relation to application MLA/ | ||
| + | This appears to be incorrect. Under Schedule A2, paragraph 8 of the 2007 Regulations, | ||
| + | The current proposal involves the capital dredging and disposal of approximately 850,000 tonnes of seabed material adjacent to a Special Area of Conservation, | ||
| + | If the MMO’s published documentation records the development as “not Annex I/II” or “not Schedule A1/A2,” that risks undermining both the transparency and legality of the current EIA process. It would also create a potential ground for procedural challenge, given that the MMO has nonetheless required an Environmental Statement. | ||
| + | |||
| + | I therefore ask the MMO to: | ||
| + | 1. Confirm on what basis the project was recorded as not falling under Schedule A2; | ||
| + | 2. Clarify whether the correct classification (Schedule A2) will be formally recognised; and | ||
| + | 3. Confirm that the statutory EIA process will be treated accordingly. | ||
| - | ***The consultee included the following files with their response:** | + | Submitted on Fri 29 Aug 2025 8:08 |
| - | * %%**%%*[[https:// | + | ==== Representation ==== |
| - | ==== *Inshore Fisheries | + | I am writing to formally object to the above marine licence application for the proposed capital dredging of approximately 850,000 tonnes of seabed at Falmouth Docks and subsequent disposal at sea. |
| + | |||
| + | Primary Concerns | ||
| + | |||
| + | 1. Incorrect Project Classification | ||
| + | |||
| + | I am deeply concerned that this project has been incorrectly categorized as not falling under Schedule A2 of the Marine Works (EIA) Regulations 2007. Given the scale of this dredging operation (850,000 tonnes) and its location adjacent to the Fal & Helford Special Area of Conservation, this should clearly be treated as a Schedule A2 development requiring a full Environmental Impact Assessment. This misclassification undermines the legal validity of the entire assessment process. | ||
| + | |||
| + | 2. Fundamentally Inadequate Environmental Impact Assessment | ||
| + | |||
| + | The Environmental Impact Assessment submitted is insufficient and contains serious flaws: | ||
| + | |||
| + | Insufficient Survey Data: Only five grab samples across the entire dredging zone is wholly inadequate for a project of this scale | ||
| + | |||
| + | Outdated Baseline Data: Reliance on 10-year-old habitat maps with no updated verification | ||
| + | |||
| + | Seasonal Bias: Surveys conducted only in November, missing critical peak biological activity periods | ||
| + | |||
| + | Lack of Modern Techniques: No high-resolution habitat mapping, drop-down camera surveys, side-scan sonar, or multibeam bathymetry | ||
| + | |||
| + | 3. Risk to Protected Habitats | ||
| + | |||
| + | The assessment fails to adequately address risks to protected habitats: | ||
| + | |||
| + | Maerl beds (North Atlantic coral) are recorded within 100-200 meters of the dredge site. These slow-growing, | ||
| + | |||
| + | Coarse sediments found in 2023 surveys are compatible with maerl and reef-forming species, yet no targeted investigations were conducted. | ||
| + | |||
| + | Sediment plume impacts on sensitive species appear to have been underestimated | ||
| + | |||
| + | 4. Legal Compliance | ||
| + | |||
| + | This application appears to breach Habitats Regulations 2017 (Insufficient evidence to prove no adverse impacts on SAC integrity), Marine Policy Statement (Precautionary Principle not applied despite clear uncertainty), | ||
| + | |||
| + | Legal Requirement for Precautionary Principle | ||
| + | |||
| + | Under UK law, where scientific evidence is uncertain or inadequate, the precautionary principle must apply. The development should not proceed until comprehensive, | ||
| + | |||
| + | Conclusion | ||
| + | |||
| + | Approving this dredging based on such inadequate assessment would set a dangerous precedent, potentially causing irreversible damage to protected marine ecosystems. The Fal & Helford SAC and surrounding marine environment deserve proper scientific assessment before any major intervention. | ||
| + | |||
| + | I urge you to uphold environmental protection standards and reject this application until a legally compliant, comprehensive assessment is completed. | ||
| - | ==== *Consulted | + | Submitted |
| - | ***The consultee was asked for their comments on this case. They responded: | + | ==== Representation ==== |
| - | ***Please find attached Cornwall IFCA’s response regarding MLA/2025/000157 | + | Keep Our Sea Chemical Free (KOSCF) is a local community group concerned with the health of our oceans. We have recently had experience of a company trying to embark on a project in St.Ives Bay on the basis of inadequate science and a lack of baseline data. This is totally unacceptable at a time when our oceans are under severe threat. It is important that communities are able to trust that bodies like the MMO will properly scrutinise any major projects in our Cornish waters and that the precautionary principal will be applied. |
| + | |||
| + | We have serious concerns about the proposed large scale dredging and dumping proposal for Falmouth Harbour. | ||
| + | |||
| + | 1. Misclasifcation: | ||
| + | |||
| + | 2. Inadequate Marine Environmental Impact Assessments: | ||
| + | |||
| + | 3. Justification: | ||
| + | |||
| + | https:// | ||
| - | ***The consultee included the following files with their response:** | + | Submitted on Thu 28 Aug 2025 16:28 |
| - | * %%**%%*[[https:// | + | ==== Representation ==== |
| - | ==== *Nat Federation | + | The MMO have stated that this project doesn’t fall under Annex 1/11 of the Environmental Impact Assessment Directive or Schedule A1/A2 of the marine works regulations, |
| + | |||
| + | 1. Inadequate Survey Effort, | ||
| + | Only five grab samples were taken across the entire dredging zone. | ||
| + | | ||
| + | * Surveys conducted only in November, missing peak biological activity seasons. | ||
| + | |||
| + | 2. Failure to Account for Sensitive Habitats | ||
| + | * Maerl beds, a protected and slow-growing habitat, have been recorded within 100–200 m of the dredge site. | ||
| + | * The developer relies on 10-year-old maps and no updated mapping or verification has been done. | ||
| + | * Coarse sediments found in 2023 are compatible with maerl and other reef-forming species, yet no targeted investigations were conducted. | ||
| + | |||
| + | 3. Sediment Plume Risks Underplayed | ||
| + | * Modelling suggests only “a few millimetres” of deposition, but fails to account for storm resuspension, | ||
| + | |||
| + | 4. Marine Mammal Impacts Neglected | ||
| + | * The EIA dismisses risk to cetaceans and seals, relying on observers and general “good practice.” | ||
| + | * No acoustic modelling or seasonal exclusion zones are proposed—Assessment falls short of JNCC standards. | ||
| + | |||
| + | 5. Habitats Regulations Assessment (HRA) Legally Weak | ||
| + | * The HRA’s “no likely significant effect” conclusion is based on outdated data and unverified assumptions. | ||
| + | * Cumulative and in-combination impacts with other regional projects are not assessed. | ||
| + | * No contingency strategy exists if protected habitats are discovered during works. | ||
| + | |||
| + | ⸻ | ||
| + | |||
| + | Legal Compliance Issues: | ||
| + | |||
| + | This application risks breaching several legal and policy frameworks: | ||
| + | * Habitats Regulations 2017 — Developer must prove no adverse impacts on SAC (Special areas of conservation) integrity; current evidence is insufficient. | ||
| + | * Marine Policy Statement — Requires the precautionary principle where uncertainty exists, which is clearly the case. | ||
| + | * EIA Regulations — Demand robust baseline evidence; the current baseline is far from sufficient. | ||
| + | |||
| + | To be honest you should be ashamed of yourselves for misclassifying this project and clearly this is either negligence or has been done deliberately. | ||
| + | |||
| + | This dredge, (ignore the greenwash of the Flow system) will enable much larger cruise ships to dock and this appears to be the real reason why the project is going ahead. This is unacceptable when we are in climate and ecological emergency. A healthy marine ecosystem is vital to Falmouth’s long-term environmental, | ||
| - | ==== *Consulted | + | Submitted |
| - | ***The consultee was asked for their comments on this case. They haven’t submitted a response yet.** | + | ==== Representation ==== |
| - | ==== *MMO Coastal Offices & MCT - South West Marine | + | I am writing with reference to the above application. Please note that the reference above only works if you remove the MLA/ prefix. That is confusing and it makes it likely that some people will think the site isn't working. The local press have been citing the above reference and telling people to go on to your site. They are likely to have just copied and pasted the ref number, and been told by the site that no such reference exists. This happened to me. As there will be a fair amount of confusion around this, could the consultation therefore be extended? |
| + | |||
| + | In relation to the above application, | ||
| + | |||
| + | MMO does not consider the application is one that appears to be part of a project which falls within either Annex I or Annex II to European Directive 2011/92/EU or a Schedule A1 or A2 project of the MWR and as such environmental impact assessment under the MWR is not required and no environmental statement has been supplied. | ||
| + | |||
| + | Does that mean the MMO doesn' | ||
| + | |||
| + | Other concerns I have are over the lack of information about the dumping of the non-hazardous waste off the coast. The proposed site is relatively close to a protected | ||
| + | |||
| + | Furthermore, | ||
| + | |||
| + | Given the above, I think the MMO do need to look at this application carefully. | ||
| + | |||
| + | Yours sincerely, | ||
| - | ==== *Consulted | + | Submitted |
| - | ***The consultee was asked for their comments on this case. They didn’t have any comments.** | + | ==== Representation ==== |
| - | ==== *MMO Coastal Offices & MCT - Conservation Team ==== | + | I wish to object this application. Rare maerl beds (North Atlantic coral) are recorded nearby, but the Environmental Impact Assessments are based on outdated maps, just five seabed samples (which ought to have been seasonal), and no modern habitat surveys. |
| + | |||
| + | Under UK law, when evidence is uncertain, the precautionary principle must apply and the development should not be allowed to go ahead until more in depth surveys and studies have been carried out. | ||
| + | |||
| + | What’s Being Proposed | ||
| + | | ||
| + | * Disposal of dredged material at sea. | ||
| + | * Justification: | ||
| + | |||
| + | Flaws in the Marine Environmental Impact Assessments | ||
| + | |||
| + | 1. Inadequate Survey Effort | ||
| + | * Only five grab samples were taken across the entire dredging zone. | ||
| + | * No high-resolution habitat mapping—no drop-down camera surveys, side-scan sonar, or multibeam bathymetry. | ||
| + | * Surveys conducted only in November, missing peak biological activity seasons. | ||
| + | |||
| + | 2. Failure to Account for Sensitive Habitats | ||
| + | * Maerl beds, a protected and slow-growing habitat, have been recorded within 100–200 m of the dredge site. | ||
| + | * The developer relies on 10-year-old maps and no updated mapping or verification has been done. | ||
| + | * Coarse sediments found in 2023 are compatible with maerl and other reef-forming species, yet no targeted investigations were conducted. | ||
| + | |||
| + | 3. Sediment Plume Risks Underplayed | ||
| + | * Modelling suggests only “a few millimetres” of deposition, but fails to account for storm resuspension, | ||
| + | |||
| + | 4. Marine Mammal Impacts Neglected | ||
| + | * The EIA dismisses risk to cetaceans and seals, relying on observers and general “good practice.” | ||
| + | * No acoustic modelling or seasonal exclusion zones are proposed—Assessment falls short of JNCC standards. | ||
| + | |||
| + | 5. Habitats Regulations Assessment (HRA) Legally Weak | ||
| + | * The HRA’s “no likely significant effect” conclusion is based on outdated data and unverified assumptions. | ||
| + | * Cumulative and in-combination impacts with other regional projects are not assessed. | ||
| + | * No contingency strategy exists if protected habitats are discovered during works. | ||
| + | |||
| + | Approving this dredging would set a dangerous precedent, risking irreversible damage to protected marine habitats in favor of short-term economic gains. A healthy marine ecosystem is vital to Falmouth’s long-term environmental, | ||
| + | |||
| + | Please insure that there is : | ||
| + | * Proper, modern benthic and maerl mapping using camera and sonar surveys. | ||
| + | * Seasonal ecological surveys and independent plume modelling. | ||
| + | |||
| + | |||
| + | The developers say that these works will allow Falmouth to support floating offshore wind (FLOW) deployment in the Celtic Sea (a big UK government priority), that it will create “green jobs” in renewables supply chains and be positioned as a transition away from traditional/ | ||
| + | But this dredge would also enable much larger cruise ships to dock. That’s not “green infrastructure” — it means more air pollution, sewage discharge, and carbon emissions locally. | ||
| + | Additionally there’s no hard evidence provided that FLOW-related infrastructure needs a deeper harbour. Offshore wind components (turbines, blades, floating substructures) can and are transported on vessels with shallower drafts than the ultra-deep cruise liners the dredge is designed to accommodate. | ||
| + | |||
| + | They are using FLOW as a “green wash” to push through dredging that primarily serves the cruise industry. | ||
| + | |||
| + | Also, the EIAs don’t show any positive environmental outcome from the dredge. The “benefits” are economic and industrial, not ecological. | ||
| + | |||
| + | The ocean is an integral part of our onshore forests too. Fish that spawn in our rivers depend on a healthy marine environment once they reach the sea, just as our rainforests and waterways rely on a healthy Fish and Marine life population returning. It all forms part of the same interconnected ecosystem. | ||
| + | |||
| + | We are in a biodiversity and climate emergency and we need to act appropriately and not put short term economic gain above long term environmental impacts. | ||
| - | ==== *Consulted | + | Submitted |
| - | ***The consultee was asked for their comments on this case. They responded: | + | ==== Representation ==== |
| - | ***Dear Yvonne,** | + | Having lived for over 30 years in Valencia, Spain, I have seen the damage caused by cruise ships (and excess tourism generally) to the local economy and environment. They spew large numbers of people on shore for a short space of time who spend little in the local area. Local shops close and multinationals like McDonalds open to provide the usual fare found at tourist sites throughout the world. The visual impact of seeing a huge cruise ship in Cornish waters is 100% negative. The entire project seems to be designed to serve the cruise industry, where is the evidence that FLOW-related infrastructure requires a deeper harbour? |
| + | The Marine Environmental Impact Assessments are inadequate. The surveys only took place in November... missing peak biological activity seasons. | ||
| + | There are maerl beds within 100 to 200m of the dredging site, but there has been no updated mapping or verification, | ||
| + | Proper benthic and maerl mapping and seasonal ecological surveys must be done. | ||
| + | There has been no assessment of the impact on marine mammals. | ||
| - | | + | Submitted on Thu 28 Aug 2025 8:37 |
| - | | + | ==== Representation ==== |
| - | ***Kind regards,** | + | As a fisherman who has worked at sea in the Falmouth Bay area for 45 years I am deeply concerned with the proposal to DUMP dredged waste from Falmouth docks into Falmouth Bay. The sediment will be highly TOXIC and to DUMP into the sea surely goes 100% against what the MMO supposedly stands for. Protecting our oceans and the marine environment. |
| + | I can remember when mud from the TRURO river was dumped at sea southeast of FALMOUTH that was a designated dumping ground some 20 years ago. The ground became barren of life for a long period as I believe the seabed was suffocated by what had been dumped on it. | ||
| + | If you add toxicity into the equation I think this proposal will have a very detrimental impact on Falmouth Bay for years to come. | ||
| + | I would like to see any documentation of any surveys made public covering the impact your proposal might have. | ||
| + | Dumping at sea is surely returning to the dark ages which, an archaic practice which most seafarers don't participate in so how can the MMO justify its approval of such a scheme. | ||
| - | | + | Submitted on Wed 27 Aug 2025 22:08 |
| - | ***The consultee included the following files with their response:** | + | ==== Seal Research Trust Representation ==== |
| - | * %%**%%*[[https:// | + | SRT has substantial concerns about this application, |
| + | |||
| + | SRT's main focus is the impacts on seals and other marine wildlife however to protect seals as the ecosystem in the Fal needs to be vibrant and biodiverse. As a result we would like to raise concerns about a number of points in this application as follows. | ||
| + | |||
| + | There seems to have been little consideration of the likely impacts on marine mammals of dredging the seabed that contains contaminants which will be mobilised with the sediment. Seals are benthic feeders, consuming more sand eels and dragonets than any other species, and therefore seals along with other marine species will be impacted by any disruption to the seabed. Mobilised contaminants from an industrial harbour will likely have toxic effects on multiple marine species. Mobilised sediments will reduce light penetration, | ||
| + | |||
| + | Prior to any permissions they need high resolution habitat mapping within and beyond the dredging area, especially in relation the SAC, as impacts outside of the SAC will be felt within it as they are connected. This is essential to identify habitats and species in order to assess impacts and plan mitigation. There is reference to samples being taken but these seem very small in number and were taken over a single time period, which is wholly inadequate. Any baseline needs to cover different seasons for at least three years in order to produce any reliable information. Maps provided as part of the project need to be current, relevant and detailed. Sediment plumes will inevitably result from dredging and will always be uneven within a marine habitat, with some areas being heavily impacted and others less so. | ||
| + | |||
| + | We are current working with Celtic Sea Power FLOW on passive audio visual recording kit for cetaceans and seals. This has already been trialled in the Fal and could be deployed within and beyond the dredging area to assess marine mammal densities to help plan mitigation to reduce impacts on these species. The dredging activity is likely to produce a lot of noise, which may rebound within the enclosed geography of the estuary. Noise impacts on marine mammals are substantial and could have a potential increase in cetacean strandings, particularly common dolphins which are well known to become disoriented in this area and become stranded due to unfamiliarity with enclosed tidal areas. This is a well known hotspot for this occurrence, which has to be responded to by rescue organisations, | ||
| + | |||
| + | A thorough investigation needs to be done of the cumulative and in combination impacts resulting from other development projects within the Fal. Surely this is essential before any decision can be made. | ||
| + | |||
| + | There needs to be continuous ongoing monitoring of the habitats and species in the estuary to enable dredging to be discontinued once unexpected impacts have been observed. | ||
| + | |||
| + | Overall it seems the development application has not done due diligence in terms of thorough investigation of the likely impacts of such a huge project to the complex, unique and sensitive marine ecosystem of the Fal, upon which a substantial tourist industry depends with huge economic losses as a result. A priority is being given here enabling economic benefit for a niche industry/cruise liners. Much better evidence is required to justify dredging for the FLOW industry. | ||
| - | ==== *Trinity House - Trinity House ==== | ||
| - | ==== *Consulted on 18 July 2025. Responded on 3 September 2025. ==== | + | ===== Case Consultation Responses ===== |
| - | ***The consultee was asked for their comments on this case. They responded: | + | ==== Environment Agency - Devon and Cornwall ==== |
| - | | + | Consulted on 18 July 2025. Responded on 29 August 2025. |
| - | | + | The consultee was asked for their comments on this case. They responded: |
| - | ***Consent is to be sought from Trinity House by Falmouth Dock and Engineering Company | + | Thank you for consulting us on the above marine licence application. |
| - | ***We will require the existing sets of 2 fixed vertical red lights to be relocated - one set to the end of the extension of Queen’s wharf and one set to the corner of the Northern and new Western wharfs.** | + | Environment Agency position |
| - | ***Many thanks.** | + | We have no objections to this proposal provided that conditions are included within any licence granted in respect of: |
| - | ***Kind regards,** | + | - Implementation of Flood Risk Assessment (FRA); |
| - | ***C. Bransby** | + | - Contaminated Land; |
| - | ==== *Maritime and Coastguard Agency | + | - Timing of piling work; and |
| - | ==== *Consulted on 18 July 2025. Responded on 28 August 2025. ==== | + | - Dredging method. |
| - | ***The consultee was asked for their comments | + | The suggested wording |
| - | ***Dear Yvonne,** | + | Condition - Implementation of submitted FRA and ' |
| - | ***Thank you for the opportunity to comment on the Marine Licence application for Falmouth Docks Development. The UK Technical Services Navigation team of the Maritime and Coastguard Agency has reviewed the documents received and would like to comment as follows:** | + | |
| - | ***We note that the works fall within the jurisdiction of a Statutory Harbour Authority | + | - the Flood Risk Assessment, produced by Ramboll |
| - | ***The MCA confirms we have no objections to a licence being granted on this occasion. This is on the understanding that all maritime safety legislation is adhered to, and that the following risk mitigation measures take place: ** | + | - the ' |
| - | ***Conditions: | + | As stated within the above Flood Risk Assessment the minimum finished deck level for all new development shall be set no lower than 5.33m AOD. |
| - | ***None** | + | The mitigation measures shall be fully implemented prior to first use and subsequently retained and maintained thereafter throughout the lifetime of the development. |
| - | | + | |
| - | ***Advisories: | + | Condition - Site Investigation and Remediation |
| - | * ***Bunding and/or storage facilities must be installed | + | No development approved by this planning permission shall take place until a remediation strategy that includes the following components |
| - | * ***The site is within port limits and the applicant is the SHA and is the responsible local navigation authority. They should follow the Potential Future Controls in the NRA.** | + | - A preliminary risk assessment which has identified: |
| - | * ***Consider adopting the Ports & Facilities Marine Safety Code (PMSC), which sets out a national standard for every aspect of port marine safety. The Code is not mandatory, however it is endorsed by the UK Government, devolved administrations, | + | - all previous uses |
| - | ***The MCA has considered the relevant Marine Plan as part of its assessment of this application. ** | + | - potential contaminants associated with those uses |
| - | ***If you have any questions on this response, please let us know.** | + | - a conceptual model of the site indicating sources, pathways and receptors |
| - | ***Kind regards** | + | - potentially unacceptable risks arising from contamination at the site. |
| - | ***UK Technical Services Navigation** | + | - A site investigation scheme, based on (1) to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site. |
| - | [[https:// | + | - The results of the site investigation and the detailed risk assessment referred to in (2) and, based on these, an options appraisal and remediation strategy giving full details of the remediation measures required and how they are to be undertaken. |
| - | ==== *Royal Yachting Association | + | - A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in the remediation strategy in (3) are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action. |
| - | ==== *Consulted on 18 July 2025. Responded on 8 September 2025. ==== | + | Any changes to these components require the express written consent of the local planning authority. The scheme shall be implemented as approved. |
| - | ***The consultee was asked for their comments on this case. They responded:** | + | |
| - | ***The RYA would like local clubs and recognised training centres to be kept informed of scheduled works to minimise impact on their activity. Location and contact details can be found at find.rya.org.uk** | + | Condition - Unsuspected Contamination |
| - | ==== *Royal Society for the Protection of Birds - South East ==== | + | If, during development, |
| - | ==== *Consulted on 18 July 2025. ==== | + | |
| - | ***The consultee was asked for their comments on this case. They haven’t submitted a response yet.** | + | |
| - | ==== *Royal Society for the Protection of Birds - Dorset, Solent (Hampshire/ | + | No piling works shall take place in the estuary during the core sensitive period 1st April to 31st August. |
| - | ==== *Consulted on 18 July 2025. ==== | + | |
| - | ***The consultee was asked for their comments on this case. They haven’t submitted | + | |
| - | ==== *Centre for Environment, | + | |
| - | ==== *Consulted | + | Any dredging activities shall be undertaken using a back-hoe dredger in order to minimise the sediments suspended in the water column and reduce impacts |
| - | ***The consultee was asked for their comments on this case. They didn’t have any comments.** | + | |
| - | ***The consultee included the following files with their response:** | + | |
| - | * %%**%%*[[https:// | + | We have reviewed the Flood Risk Assessment, produced by Ramboll (Document Reference: 15743-RAM-FD-SW-RP-EV-00015) on 17/11/2024. We consider that it has adequately assessed the risks to the proposed development. We therefore consider that the proposed development will be acceptable in flooding terms provided that the minimum finished deck level for all new development shall be set no lower than 5.33m AOD and the development is built in accordance with the submitted ' |
| - | * %%**%%*[[https:// | + | |
| - | ==== *Centre for Environment, | + | |
| - | ==== *Consulted on 18 August 2025. Responded on 22 August 2025. ==== | + | The proposed development is situated within Area 11, Policy Development Zone 5, Policy Unit 11.10 of the Shoreline Management Plan, which has a management intent of 'Hold the Line' (Local Activity Only). We consider that this development conforms with the area policy for the Shoreline Management Plan, and therefore raise no concerns to this development from a coastal erosion risk management perspective. |
| - | ***The consultee was asked for their comments on this case. They responded: | + | |
| - | ***Please find coastal processes advice attached here.** | + | We have reviewed the Contaminated Land Desk Study prepared by Ramboll UK Limited (" |
| - | ***The consultee | + | We therefore consider that permission should only be granted for the proposed development as submitted if the above conditions are included |
| - | * %%**%%*[[https:// | + | |
| - | ==== *Centre for Environment, Fisheries | + | Given that the proposal lies within the Fal & Helford SAC, Natural England (NE) will take the lead on biodiversity issues. We have no objections to the application provided that NE are satisfied that the HRA has adequately assessed |
| - | ==== *Consulted | + | The BNG report states that the current calculated change is -46.96% and it is not possible for the proposed development to achieve this on-site. We note that options for offsite biodiversity offsetting are being sought in consultation with Cornwall Council. These should be agreed prior to the development commencing. |
| - | ***The consultee was asked for their comments on this case. They haven’t submitted a response yet.** | + | |
| - | ==== *Centre | + | The River Fal is designated as a recovering salmon river (meaning a population is starting to re-establish after a period of absence) and a principal sea trout river (meaning there is a rod catch \50 individuals a year). The proposed development lies within the Atlantic Salmon and European Eel migratory route for the River Fal so it is important that the activities associated with the proposed development do not adversely impact on fish migration. The proposed development will therefore only be acceptable if the conditions outlined above are included, requiring works to be programmed to avoid sensitive times for migratory fish and to be undertaken using appropriate methods. Without these conditions we would object to the proposal because it cannot be guaranteed that the development will not result in significant harm to migratory fish. |
| - | ==== *Consulted on 21 July 2025. Responded on 11 August 2025. ==== | + | |
| - | ***The consultee was asked for their comments | + | We have reviewed the WFD assessment and do not have any concerns; it covers everything we would expect to see. The waterbody is at Good Ecological Status, so the focus of the assessment needs to be on no deterioration and mitigating any risks for activities that may cause deterioration. We are satisfied that the assessment considers these adequately. |
| - | ***Hi Yvonne** | + | The main concerns highlighted by the assessment are mobilisation of sediments and contaminants, |
| - | ***Please find enclosed my benthic ecology advice to this request.** | + | For the potential impacts on habitats and protected sites, Natural England will take the lead as the proposed development lies wholly within the Fal & Helford Special Area of Conservation (SAC). |
| - | ***All the best** | + | Advice - Pollution prevention |
| - | ***Stef** | + | Safeguards need to be sought from the applicant to minimise detrimental effects to the water environment and the risks of pollution during the construction phase. |
| - | ***The consultee included | + | Such safeguards should cover the use of plant and machinery, oils/ |
| - | * %%**%%*[[https:// | + | The Environment Agency can provide pollution prevention guidance: pmho1107bnkg-e-e.pdf. Further guidance is available at: Pollution prevention for businesses |
| - | ==== *Cornwall Coastal Partnership - Coastal Partnership ==== | + | The outline Construction Environment Management Plan (CEMP) seems a thorough document, but you may like to include a condition which requires the CEMP to be reviewed and signed off prior to any work commencing. |
| - | ==== *Consulted on 23 July 2025. ==== | + | |
| - | ***The consultee was asked for their comments on this case. They haven’t submitted | + | The developer must apply the waste hierarchy as a priority order of prevention, re-use, recycling before considering other recovery or disposal options. Government guidance on the waste hierarchy in England can be found here: |
| - | Document Consultation Responses | + | Waste hierarchy guidance |
| - | ==== *EA (Devon and Cornwall) ==== | + | Use of waste on-site |
| - | ==== %%**%%*Piling Restrictions ==== | + | As much material as possible should be re-used on site. If materials that are potentially waste are to be used on-site, the applicant will need to ensure they can comply with the exclusion from the Waste Framework Directive (WFD) (article 2(1) (c)) for the use of, ' |
| - | Consulted on 15 July 2026. Responded on 13 August 2026.%%**%% | + | Where the applicant cannot meet the criteria, they will be required to obtain the appropriate waste permit or exemption from us. |
| - | ***The consultee was asked for their comments | + | The applicant is advised to contact our National Permitting Service |
| - | * %%**%%*[[https:// | + | Movement of waste off-site |
| - | * %%**%%*[[https:// | + | |
| - | ***They responded: | + | The Environmental Protection (Duty of Care) Regulations 1991 for dealing with waste materials are applicable to any off-site movements of wastes. The code of practice applies to you if you produce, carry, keep, dispose of, treat, import or have control of waste in England or Wales. |
| - | ***Please enter your comments | + | The law requires anyone dealing with waste to keep it safe and make sure it's dealt with responsibly and only given to businesses authorised to take it. The code of practice can be found here: Waste duty of care: code of practice (accessible version) - GOV.UK |
| - | ***The consultee included | + | In order to meet the applicant' |
| - | * %%**%%*[[https:// | + | |
| - | ==== *NE (12 - Devon, Cornwall and Isles of Scilly) ==== | + | |
| - | ==== %%**%%*Falmouth SAC AA Addendum April 2026 ==== | + | We have reviewed the report entitled "Best Practicable Environmental Option (BPEO) Assessment" |
| - | Consulted on 28 April 2026. Responded on 20 May 2026.%%**%% | + | |
| - | ***The consultee was asked for their comments on [[https:// | + | |
| - | | + | ==== Natural England - 12 - Devon, Cornwall and Isles of Scilly ==== |
| - | | + | Consulted on 18 July 2025. Responded on 8 September 2025. |
| - | | + | The consultee was asked for their comments on this case. They responded: |
| - | ***Kate** | + | Thank you for your consultation dated 18 July 2025. Please find attached Natural England' |
| - | ***The consultee included the following files with their response:** | + | The consultee included the following files with their response:[[https:// |
| - | * %%**%%*[[https:// | + | ==== Crown Estate |
| - | ==== *CEFAS (SEAL) | + | ==== |
| - | ==== *Consulted | + | The consultee was asked for their comments |
| - | ***The consultee was asked for their comments on [[https:// | + | The Crown Estate is affected by the proposed works and landowner' |
| - | ==== *Shellfish Advice ==== | + | And |
| - | ==== *Consulted on 9 April 2026. Responded | + | The Crown Estate is affected by the proposed disposal activity and landowner' |
| - | ***The consultee was asked for their comments on [[https:// | + | ==== Duchy of Cornwall |
| - | | + | Consulted on 18 July 2025. |
| - | | + | The consultee was asked for their comments on this case. They haven' |
| - | | + | ==== Historic England - Dorset/ |
| - | | + | Consulted on 18 July 2025. Responded on 14 August 2025. |
| - | ***The consultee | + | The consultee |
| - | * %%**%%*[[https:// | + | |
| - | ==== *CEFAS (SEAL) ==== | + | The consultee included the following files with their response: |
| + | |||
| + | [[https:// | ||
| - | ==== *Consulted on 14 November 2025. Responded on 8 December 2025. ==== | + | ==== Inshore Fisheries and Conservation Authorities - Cornwall |
| - | ***The consultee was asked for their comments | + | Consulted |
| - | * %%**%%*[[https:// | + | The consultee was asked for their comments on this case. They responded: |
| - | * %%**%%*[[https:// | + | |
| - | * %%**%%*[[https:// | + | |
| - | * %%**%%*[[https:// | + | |
| - | ***They responded: | + | |
| - | | + | The consultee included the following files with their response: |
| + | |||
| + | [[https:// | ||
| - | ***The consultee included the following files with their response:** | + | ==== Nat Federation of Fishermen' |
| - | * %%**%%*[[https:// | + | Consulted on 18 July 2025. |
| - | ==== *NE (12 - Devon, Cornwall and Isles of Scilly) ==== | + | The consultee was asked for their comments on this case. They haven' |
| - | ==== *Consulted on 17 October 2025. Responded on 26 November 2025. ==== | + | ==== MMO Coastal Offices & MCT - South West Marine Area ==== |
| - | ***The consultee was asked for their comments | + | Consulted |
| - | * %%**%%*[[https:// | + | The consultee was asked for their comments on this case. They didn't have any comments. |
| - | * %%**%%*[[https:// | + | |
| - | * %%**%%*[[https:// | + | |
| - | ***They responded: | + | ==== MMO Coastal Offices & MCT - Conservation Team ==== |
| - | | + | Consulted on 18 July 2025. Responded on 1 September 2025. |
| - | ***The response from Natural England | + | The consultee |
| - | ***Kind regards,** | + | Dear Yvonne, |
| - | ***Esther Hughes** | + | Please see the attached advice regarding protected species. |
| - | ***Marine | + | Please note I have not commented on the identified |
| - | ***Devon Cornwall and Isles of Scilly Area Team** | + | Kind regards, |
| - | ***Natural England** | + | Hope |
| - | ==== *CEFAS (SEAL) ==== | + | The consultee included the following files with their response: |
| + | |||
| + | [[https:// | ||
| - | ==== *Consulted on 28 August 2025. Responded on 3 October 2025. ==== | + | ==== Trinity House - Trinity House ==== |
| - | ***The consultee was asked for their comments | + | Consulted |
| - | ==== *Shellfish Advice ==== | + | The consultee was asked for their comments on this case. They responded: |
| - | ==== *Consulted on 28 August 2025. Responded on 2 October 2025. ==== | + | Good afternoon Yvonne, |
| - | ***The consultee was asked for their comments on [[https:// | + | |
| - | ***Good afternoon, | + | Consent is to be sought from Trinity House by Falmouth Dock and Engineering Company for any changes to aids to navigation. |
| - | ***Please see the attached advice in relation | + | We will require |
| - | ***Kind regards** | + | Many thanks. |
| - | ***Bella Voak** | + | Kind regards, |
| - | ***The consultee included the following files with their response:** | + | C. Bransby |
| - | * %%**%%*[[https:// | + | ==== Maritime and Coastguard Agency |
| + | Consulted on 18 July 2025. Responded on 28 August 2025. | ||
| + | |||
| + | The consultee was asked for their comments on this case. They responded: | ||
| + | |||
| + | Dear Yvonne, | ||
| + | |||
| + | Thank you for the opportunity to comment on the Marine Licence application for Falmouth Docks Development. The UK Technical Services Navigation team of the Maritime and Coastguard Agency has reviewed the documents received and would like to comment as follows: | ||
| + | |||
| + | We note that the works fall within the jurisdiction of a Statutory Harbour Authority (SHA) Falmouth Docks and Engineering Company and therefore they are responsible for the safety of navigation within their waters. | ||
| + | |||
| + | The MCA confirms we have no objections to a licence being granted on this occasion. This is on the understanding that all maritime safety legislation is adhered to, and that the following risk mitigation measures take place: | ||
| + | |||
| + | | ||
| + | |||
| + | None | ||
| + | |||
| + | In addition, the following advice should be provided to the applicant to facilitate the proposed works: | ||
| + | |||
| + | | ||
| + | |||
| + | - Bunding and/or storage facilities must be installed to contain and prevent the release of fuel, oils, and chemicals associated with plant, refuelling and construction equipment, into the marine environment. | ||
| + | |||
| + | - The site is within port limits and the applicant is the SHA and is the responsible local navigation authority. They should follow the Potential Future Controls in the NRA. | ||
| + | |||
| + | - Consider adopting the Ports & Facilities Marine Safety Code (PMSC), which sets out a national standard for every aspect of port marine safety. The Code is not mandatory, however it is endorsed by the UK Government, devolved administrations, | ||
| + | |||
| + | The MCA has considered the relevant Marine Plan as part of its assessment of this application. | ||
| + | |||
| + | If you have any questions on this response, please let us know. | ||
| + | |||
| + | Kind regards | ||
| + | |||
| + | UK Technical Services Navigation | ||
| + | |||
| + | |||
| + | ==== Royal Yachting Association - Royal Yachting Association ==== | ||
| + | |||
| + | Consulted on 18 July 2025. Responded on 8 September 2025. | ||
| + | |||
| + | The consultee was asked for their comments on this case. They responded: | ||
| + | |||
| + | The RYA would like local clubs and recognised training centres to be kept informed of scheduled works to minimise impact on their activity. Location and contact details can be found at find.rya.org.uk | ||
| + | |||
| + | ==== Royal Society for the Protection of Birds - South East ==== | ||
| + | |||
| + | Consulted on 18 July 2025. | ||
| + | |||
| + | The consultee was asked for their comments on this case. They haven' | ||
| + | |||
| + | ==== Royal Society for the Protection of Birds - Dorset, Solent (Hampshire/ | ||
| + | |||
| + | Consulted on 18 July 2025. | ||
| + | |||
| + | The consultee was asked for their comments on this case. They haven' | ||
| + | |||
| + | ==== Centre for Environment, | ||
| + | |||
| + | Consulted on 21 July 2025. Responded on 26 August 2025. | ||
| + | |||
| + | The consultee was asked for their comments on this case. They didn't have any comments. | ||
| + | |||
| + | The consultee included the following files with their response: | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | ==== Centre for Environment, | ||
| + | |||
| + | Consulted on 18 August 2025. Responded on 22 August 2025. | ||
| + | |||
| + | The consultee was asked for their comments on this case. They responded: | ||
| + | |||
| + | | ||
| + | |||
| + | The consultee included the following files with their response: | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | ==== Centre for Environment, | ||
| + | |||
| + | Consulted on 15 August 2025. | ||
| + | |||
| + | The consultee was asked for their comments on this case. They haven' | ||
| + | |||
| + | ==== Centre for Environment, | ||
| + | |||
| + | Consulted on 21 July 2025. Responded on 11 August 2025. | ||
| + | |||
| + | The consultee was asked for their comments on this case. They responded: | ||
| + | |||
| + | Hi Yvonne | ||
| + | |||
| + | | ||
| + | |||
| + | All the best | ||
| + | |||
| + | Stef | ||
| + | |||
| + | The consultee included the following files with their response: | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | ==== Cornwall Coastal Partnership - Coastal Partnership ==== | ||
| + | |||
| + | Consulted on 23 July 2025. | ||
| + | |||
| + | The consultee was asked for their comments on this case. They haven' | ||
| + | |||
| + | ===== Document Consultation Responses ===== | ||
| + | |||
| + | ==== EA (Devon and Cornwall) ==== | ||
| + | |||
| + | ==== Piling Restrictions | ||
| + | Consulted on 15 July 2026. Responded on 13 August 2026. | ||
| + | |||
| + | The consultee was asked for their comments on these documents: | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | [[[[https:// | ||
| + | |||
| + | They responded: | ||
| + | |||
| + | | ||
| + | |||
| + | The consultee included the following files with their response: | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | ==== NE (12 - Devon, Cornwall and Isles of Scilly) ==== | ||
| + | |||
| + | ==== Falmouth SAC AA Addendum April 2026 ==== | ||
| + | Consulted on 28 April 2026. Responded on 20 May 2026. | ||
| + | |||
| + | The consultee was asked for their comments on [[https:// | ||
| + | |||
| + | Dear Yvonne, | ||
| + | |||
| + | Apologies for the delay in responding. Please find Natural England' | ||
| + | |||
| + | Kind regards, | ||
| + | |||
| + | Kate | ||
| + | |||
| + | The consultee included the following files with their response: | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | ==== CEFAS (SEAL) ==== | ||
| + | |||
| + | Consulted on 9 April 2026. Responded on 1 May 2026. | ||
| + | |||
| + | The consultee was asked for their comments on [[https:// | ||
| + | |||
| + | ==== Shellfish Advice ==== | ||
| + | |||
| + | Consulted on 9 April 2026. Responded on 27 April 2026. | ||
| + | |||
| + | The consultee was asked for their comments on [[https:// | ||
| + | |||
| + | Good morning, | ||
| + | |||
| + | | ||
| + | |||
| + | Kind regards | ||
| + | |||
| + | Bella Voak (shellfish advisor) | ||
| + | |||
| + | The consultee included the following files with their response: | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | ==== CEFAS (SEAL) ==== | ||
| + | |||
| + | Consulted on 14 November 2025. Responded on 8 December 2025. | ||
| + | |||
| + | The consultee was asked for their comments on these documents: | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | They responded: | ||
| + | |||
| + | Please find my comments attached. | ||
| + | |||
| + | The consultee included the following files with their response: [[https:// | ||
| + | |||
| + | ==== NE (12 - Devon, Cornwall and Isles of Scilly) ==== | ||
| + | |||
| + | Consulted on 17 October 2025. Responded on 26 November 2025. | ||
| + | |||
| + | The consultee was asked for their comments on these documents: | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | [[https:// | ||
| + | |||
| + | They responded: | ||
| + | |||
| + | Dear Yvonne, | ||
| + | |||
| + | The response from Natural England was submitted via email on 20th November 2025. Please let me know if you require any further information. | ||
| + | |||
| + | Kind regards, | ||
| + | |||
| + | | ||
| + | |||
| + | | ||
| + | |||
| + | Devon Cornwall and Isles of Scilly Area Team | ||
| + | |||
| + | | ||
| + | |||
| + | |||
| + | ==== CEFAS (SEAL) ==== | ||
| + | |||
| + | Consulted on 28 August 2025. Responded on 3 October 2025. | ||
| + | |||
| + | The consultee was asked for their comments on [[https:// | ||
| + | |||
| + | ==== Shellfish Advice ==== | ||
| + | |||
| + | Consulted on 28 August 2025. Responded on 2 October 2025. | ||
| + | |||
| + | The consultee was asked for their comments on [[https:// | ||
| + | |||
| + | Good afternoon, | ||
| + | |||
| + | | ||
| + | |||
| + | Kind regards | ||
| + | |||
| + | Bella Voak | ||
| + | |||
| + | The consultee included the following files with their response: | ||
| + | [[https:// | ||
| + | |||
| + | |||
| + | ===== Sediment Sampling ===== | ||
| + | |||
| + | {{url> | ||
| + | |||
| + | |||
| + | ===== Other Pages That Link To This Page ===== | ||
| + | |||
| + | {{backlinks> | ||
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