Project title: Falmouth Docks Development

Project background

A&P Falmouth Ltd/FDEC is seeking approval to redevelop Falmouth Docks. The project aims to repair the aging dock infrastructure, enhancing berth capacity for alongside docking to support current business and future needs, including cruise and cargo capacity, and floating offshore wind (FLOW) market support. Existing layout drawing: 15743-RAM-FD-SW-DR-CM-00001.

Redevelopment activities, to be consented through a full planning application with Cornwall Council (PA25/01598) and this marine licence application with the MMO, include:

• Pocket dredging berth areas for underkeel clearance for larger cruise vessels (up to Excellence class) and FLOW renewable energy devices, achieving depths of -10.5 m CD
• Removing foul ground within former Kings and Empire Wharves regions
• Surface skim the seabed on the site's eastern side (to achieve depths of -5.5 mCD)
• Demolishing timber piles and infrastructure at Western Wharf
• Constructing a new suspended deck structure at Western Wharf with a deck level of +8.36 mCD
• 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, with a deck level of +8.36 mCD
• 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

These improvements are crucial as the current infrastructure, particularly in the Western Wharf area, is unsafe for operational use, and the central causeway risks failure without development. More information in the ES

Programme of works

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 of the anticipated timescales associated with the demolition and construction stage. For all decks the general programming assumes the following broad activities: enabling and strengthening works, demolition, dredging, construction of new infrastructure, and finishing works. Works are anticipated to take a duration of approximately 42 months if wharfs are built in parallel. It is possible that the demolition and construction stage could occur over a longer duration if wharfs are constructed sequentially. In addition, wharfs could potentially be constructed in any order, and it is requested that the sequencing of demolition and construction is read as indicative. However a detailed programme has not yet been produced and will be dependent on licences, funding and contractor methods/availability. Parts of the proposed development may need to be taken forward in a different order according to business needs and funding arrangements.

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.

Other information

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 - MLA_2025_00157-APPLICATION-FORM.pdf

I am writing to express my concern about application PA25/05579 (MLA/2025/00157) for Falmouth Docks capital dredge.

I am concerned that the environmental assessment has not been conducted thoroughly, risking damage to the marine environment on which Falmouth depends for tourism and quality of life.

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

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, community and long-term sustainability.

Falmouth is a unique and sensitive marine environment, home to diverse ecosystems that could be severely impacted by dredging. Disturbance of seabed sediments risks releasing pollutants, degrading water quality, and harming vital habitats for marine life. These changes would not only damage biodiversity but also undermine the health of our fishing grounds and the natural beauty that makes Falmouth such a special place.

Furthermore, the expansion of capacity for very large cruise vessels raises broader concerns about the social and environmental costs of mass tourism. Cruise ships contribute disproportionately to carbon emissions and marine pollution, while offering limited local economic benefits, as much of the revenue flows back to international operators rather than staying in the community. Increased visitor numbers could also place unsustainable pressure on local infrastructure, housing and services.

Rather than prioritise short-time gains, I urge you to consider the long-term wellbeing of Falmouth’s people, environment, and economy. Sustainable tourism, investment in local businesses, and protection of our natural heritage will serve the community far better than accommodating ever-larger cruise liners.

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.

Thank you for your attention to this important matter.

Submitted on Fri 05 Sep 2025 10:29

I am writing to object to Marine Licence Application MLA/2025/00157 (Falmouth Docks redevelopment and capital dredge).

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.

1. Flawed Ecological Assessment

• The Environmental Impact Assessment acknowledges the presence of maerl beds and seagrass within and near the dredge footprint. Both are UK Priority Habitats, slow-growing, and irreplaceable once lost. The loss or smothering of these habitats is understated as “minor” or “not significant.”
• Survey coverage was limited in season and spatial extent. Data gaps are acknowledged but dismissed, with impacts downplayed rather than properly quantified.
• Cumulative and indirect impacts (e.g., sediment plume dispersal, interactions with existing pressures in the Fal and Helford SAC) are given cursory treatment despite being critical.
• There is no credible compensation strategy. Monitoring is not mitigation, and there is no plan to offset losses or deliver the 10% Biodiversity Net Gain required under the Cornwall Local Plan.

2. Contaminated Sediments

• The dredge involves disturbing ~850,000 tonnes of seabed material contaminated with tributyltin (TBT), copper, and heavy metals from historic dockyard activity.
• Mobilisation of these pollutants threatens nearby oyster fisheries, shellfish waters, and marine food chains. Dilution and disposal at sea are not a substitute for safe containment.

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.

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.

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, and members of the public into believing the scheme was of minimal impact. In fact, it is plainly a Schedule A2 project.
• In these circumstances, the consultation period should be extended. To continue without extension undermines fairness, transparency, and legality.

Conclusion The application is environmentally unsound, legally compromised, and non-compliant with planning policy. The MMO should not grant this licence unless and until:

• 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.

Without these steps, this licence should be refused.

Submitted on Thu 04 Sep 2025 23:35

The dredging proposed as part of this application is extreme and presents unacceptable known and unknown risks to the marine environment, as such this representation suggests 4 approaches which would significantly reduce the risks entailed while allowing the economic aims of the application to be achieved.

1. Very low environmental damage - replace berth pockets with floating structures taking advantage of the deep water harbour.
2. Minimal environmental damage - create the berth pockets within cofferdams.
3. Considerably reduced environmental damage - Adopt current international dredging best practises combined with the reuse or land disposal of dredged materials.
4. Quantification of environmental damage - adopt current international dredging best practices.

Further details are provided in the attached document.

250904NEMRG-MLA_2025_00157-Representation.pdf

We welcome the submission of the Environmental Statement (ES) for the proposed Falmouth Docks extension and appreciates the opportunity to comment. Falmouth Marine Conservation are concerned about aspects of the impact assessment, the adequacy of proposed mitigation, and the scope of planned monitoring. As such, we are submitting a Holding Objection. If the additional information requested is provided and our concerns are fully addressed, we may be in a position to withdraw this objection. Please refer to our full response for detailed comments.

Falmouth Docks MMO licence FMC.pdf

I object to the Falmouth Docks proposal for the following reasons.

Pollution

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).

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.

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.

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.

If these cruise ships are to be allowed to moor in Falmouth Harbour they must have full shore power with engines off.

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.

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.

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.

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.

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:

“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, and marine mammals.”

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.

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.

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.

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.

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.

Also where will the two Royal Fleet Auxiliary bay fleet class boats birth when cruise ships are birthed.

The dredging report alone is a cause for concern.

Submitted on Thu 04 Sep 2025 21:25

The attached document is my formal objection to the A & P proposal to turn Falmouth's waters into an environmental toxic desert, to enable unwanted excessively large and highly polluting cruise ships to berth, on the pretext of facilitating green energy provision.

MMO Falmouth Object.pdf

Summary of overall position

We welcome the detailed Environmental Statement (ES) that has been submitted for the proposed extension to Falmouth docks. However, Cornwall Wildlife Trust still has concerns around several aspects of the application in terms of assessment of impacts, the extent and type of mitigation proposed, and the amount of monitoring planned. Consequently, this response takes the form of a Holding Objection. If the additional information we request is made available and fully addresses our concerns, we may be in a position to withdraw this holding objection. Please see our full response as submitted for detailed comments.

Falmouth Docks MMO licence CWT response FINAL.docx

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.

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, and is bound to have a negative impact on this precious marine environment. In addition to maerl beds, there are areas of seagrass which are so important in removing carbon, these are our marine rainforests.

Dumping thousands of tonnes of potentially toxic sediment just outside the SAC will have unknown but likely severe consequences on this protected area. Independent in depth and proportionate surveys and risk assessments must be completed prior to any of these activities.

The purpose of the dredging is to enable larger cruise ships and vessels into the harbour, further increasing pollution in this highly environmentally sensitive area. Increased associated emissions, traffic, sewage and infrastructure will be detrimental to Falmouth and its inhabitants.

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.

I have lived by Falmouth Bay for nearly 40 years, I and thousands of others love this special place.

I register my strong objection to dredging and dumping in the harbour and bay. It risks irreversible environmental damage to protected marine habitats for short term economic gain.

Submitted on Wed 03 Sep 2025 18:33

I believe that the amount of dredging to be undertaken will have a very detrimental effect on the ecology of the surrounding area, removal of the sediments from the docks with all their pollutants contained within each dredge will only cause these sediments to be dispersed to the surrounding area. It would be a tragedy to all sea habitats for miles. if this was approved.

Submitted on Wed 03 Sep 2025 18:26

I do support the work related to the development of offshore wind but object to the drive to enable larger and more cruise ships to visit and the associated dredging. We are in a climate emergency and we need to be restoring marine ecosystems, which when healthy can play a huge role in carbon storage, rather than further destroying them. I do understand that the needs of the local economy are important, but research is clear that large cruise ships are environmentally detrimental in all sorts of ways, and some cities are now deliberately limiting their visits as a result of this. As others have said, visitors from cruise ships spend less onshore than other visitors, and I would urge that our marine environment be given the protection it deserves, especially given that healthy and diverse marine ecosystems can themselves play a key role in helping mitigate the disastrous impact of climate change.

Submitted on Wed 03 Sep 2025 17:55

Whilst of course anybody can understand the importance of job creation for this massive operation, surely the incredibly fragile state of Falmouth Bay seabed cannot be ignored. The proposed dredging would stir up toxic sediments in an area of marine habitats. I implore you to conduct more studies to investigate and consider the implications to these fragile habitats.

Submitted on Wed 03 Sep 2025 12:49

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 as a Schedule A2 project, requiring full EIA scrutiny. This misclassification undermines the legality and transparency of the licensing process. The MMO must formally acknowledge the project’s correct categorisation and ensure that the EIA process fully complies with statutory requirements.

The best practice standards for surveying the site have not been met. This project will cause irreparable harm to our local marine life during a time of unprecedented threat to biodiversity. For example, within a few meters of the proposed development site there are protected maerl beds. Growing only 1mm per year, this project would devastate them permanently as they won't be able to recover once buried, even if by “only” a few mm. The modeling that has been done so far does not accurately depict the breadth and scale of sediment shifts that will result from this project.

It appears that assessment of harm to marine life from vibrations and acoustics has been omitted, as well as considerations of migratory and nesting factors for turtles, dolphins, seals, fish, and more.

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.

It seems that precautionary principle has been ignored. Uncertainty is high with so little solid data, and as such UK marine policy requires that we ere on the side of caution and not proceed with this plan in its current form.

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&P's activities. Asthma cases are on the rise. Many have had to leave our beautiful town already due to air and noise pollution. I suffer from sound sensitivity due to the docks' exemption from usual quiet hours, which interacts with my autism in a debilitating way. I know I am not the only one affected by this.

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, for minimum wage and no tips, all while being unable to afford to live in the town we work because it is taken over by holiday lets. We need to ask ourselves: How can we expect the local population to accommodate such an influx in tourism when we don't have our own basic needs met? Our wages are shit, our homes are filled with mold (resulting in medical conditions popping up in a youthful generation at a rate never before seen), our bosses don't care if we live or die, and the Council doesn't care if we are all made homeless. Rendering this town even more inhospitable to locals is going to leave it without a local population to sustain the economy. Everyone will move to Bristol or Plymouth, as many already have. Falmouth will turn into even more of a ghost town in the winter than it already is, with local businesses and developers forced to source hospitality workers from outside the county for seasonal work. Just look at Cape Cod in Massachusetts: Almost no local culture, only rich tourists and underpaid workers brought in from abroad to work the high season while living in dorms.

If a Falmouth devoid of culture and humanity is what you want, by all means green-light this ill-considered, green-washed project. It'll make the executives at A&P richer, and probably a few councillors that they have in their pockets too, and that's all that really matters, isn't it?

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

I object to this proposal and mainly because I do not feel it has placed sufficient priority on the environment. The ‘do less’ scenario is only cursorily outlined in section 2.6.4; it is given scant consideration and dismissed before it has been explored. In fact, this should be the essence of an environmental approach: what can we do without disturbing and damaging the environment? The truth is that the FLOW infrastructure could be accommodated with far less intrusion; the docks could be repaired and reinforced, as outlined, without the scale of dredging (850,000 tonnes) proposed. My reasons for this point of view are as follows: Dredging is hugely disruptive to marine habitats – the Marine Environmental Impact Assessments are inadequate and flawed. Maerl and other cold water reef forming species are slow growing and sensitive to fine sediment – both settling on them and from light blocking turbidity. Maerl beds were found within 200m of the dredge site, yet the EIA uses 10year old maps with no updates or verification. My concern is that the Marine EIA seems to set out to ignore the possibility of sensitive habitats in the area – the survey used only 5 grab samples across the entire dredging zone. The survey did not use advanced techniques, such as high-resolution habitat mapping, and were conducted at a calendar time of low biological activity. 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 have weight it does not seem sensible, given the environmental impacts, that the ‘do less’ approach has not been set out more clearly. This drives us to polarised positions: I can only oppose this application and ask that a more nuanced approach be taken.

Submitted on Wed 03 Sep 2025 9:27

Dear Marine Licensing Team,

I write to formally object to marine licence application MLA/2025/00157, submitted by A & P Falmouth Ltd, concerning dredging, disposal of dredged material, and associated works at Falmouth Docks and Falmouth Bay based on the following three primary issues:

1. Incompatibility with Legislation and Environmental Protections

• The project is subject to the Marine and Coastal Access Act 2009 and the Marine Works (EIA) Regulations 2007 (as amended), yet the current assessments are inadequate.
• The site lies adjacent to the Fal & Helford SAC, which contains highly sensitive habitats such as maerl beds, growing only ~1 mm per year and exceptionally vulnerable to smothering (Blake & Maggs, 2003).
• Legal obligations require an up-to-date Appropriate Assessment. Reliance on outdated mapping and only five seabed samples, over a decade old, does not satisfy this duty.

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, 2014).
• These risks conflict with the Environmental Act 2021 and Climate Change Act 2008, which emphasise sustainable, low-impact development.

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 the MMO without robust evidence of likely harm and the public not fully informed.

I therefore request that the MMO: 1. Reject the application unless a full Appropriate Assessment is conducted and made public. 2. Require comprehensive, up-to-date surveys (sonar, video, and sediment sampling) across the site, particularly near maerl and eelgrass habitats. 3. Mandate robust, independent monitoring, including real-time tracking of plumes, contaminants, and ecosystem health. 4. Re-evaluate the need for ultra-deep dredging in light of less damaging alternatives.

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.

Thank you for your consideration in this matter

Blake, C. and Maggs, C.A., 2003. Comparative growth rates and internal banding periodicity of maerl species (Corallinales, Rhodophyta) from northern Europe. Phycologia, 42(6), pp.606-612.

Carić, H. and Mackelworth, P., 2014. Cruise tourism environmental impacts–The perspective from the Adriatic Sea. Ocean & coastal management, 102, pp.350-363.

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).

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?. Critical Reviews in Environmental Science and Technology, 52(18), pp.3179-3210.

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

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, however their loss is downplayed as “minor,” which is misleading given they are both irreplaceable and protected. In addition cumulative impacts have been ignored: The EcIA barely considers cumulative effects with other pressures in the Fal Estuary and Falmouth Bay (shipping, past dredging, pollution). The MMO should assess this under EIA Regulations. Pollution and contaminants: The sediment that could be removed contains TBT and heavy metals from historic dockyard activity. Mobilising 850,000 tonnes of contaminated sediment poses a significant risk to the SAC and to oyster fisheries., this has not been properly assessed, neither have the impacts of noise, underwater noise from dredging and increased vessel traffic is dismissed as “low,” with no robust evidence. MMO must require a precautionary assessment for marine mammals and fish. Public consultation fairness: Because of the MMO’s error, the public and decision-makers may have wrongly assumed minimal impacts. The consultation period should be extended to allow informed responses. In addition, there have been no land based surveys to look for the impact that this development would have on bats, birds, invertebrates and other land based creatures. 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 ,equivalent to thousands of additional car journeys. Falmouth has no shore power to reduce this. Southampton , which is a port that has a large numbers of visiting cruise ships, has a chronic problem with air quality directly linked to this issue. Children, elderly people, and those with asthma are especially at risk from rising air pollution. Even small increases in particulates worsen breathing and heart problems.

Submitted on Mon 01 Sep 2025 13:57

Subject: Formal Objection to Application MLA/2025/00157 – Environmental, Legal, and Public Health Risks Dear Sir/Madam, We write to strongly object to the proposed dredging of Falmouth Harbour (MLA/2025/00157) on the following critical grounds:

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, and residuals from the Wheal Jane mine spill—pollutants that pose serious ecological and human health hazards when disturbed. These risks contravening the Water Framework Directive (2000/60/EC) (transposed into UK law), which requires that water bodies achieve and maintain “good ecological and chemical status.”

2. Scientific and Survey Deficiencies

• Only five grab samples were taken across the dredge zone—grossly insufficient to assess ecologically sensitive areas.
• No modern habitat mapping using sonar, drone, or camera surveys, and no verification of nearby maerl or eelgrass beds.
• Absence of seasonal surveys—data collected only in November misses peak biological activity, spawning, and migration periods.

These deficiencies fall short of the Environmental Impact Assessment Regulations 2017, which mandate comprehensive and representative baseline surveys.

3. Threats to Protected Habitats

• Maerl beds, a critically slow-growing habitat and a Special Area of Conservation (SAC) feature, lie within 100–200 m of the proposed dredging zone, yet remain unsurveyed.
• Eelgrass beds, important for carbon storage (“blue carbon”) and as nurseries for commercial fish species, risk irreversible smothering.
• 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, long-term turbidity, and cumulative impacts.
• 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 2006/7/EC).
• 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, recreation, and tourism—all dependent on clean water and healthy ecosystems. Contamination or even the perception of pollution could devastate these sectors.
• 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, and ecological impacts—all inadequately addressed.
• 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, unlawful, and environmentally catastrophic. I urge the MMO to refuse consen

MMO MLA_2025_00157.docx

Submitted on Mon 01 Sep 2025 13:36

Dear Marine Licensing Team,

I wish to lodge a formal objection to application MLA/2025/00157 (Falmouth Docks redevelopment and dredging). My concerns fall under several headings:

1. Inadequate Environmental Assessment

• Sensitive habitats such as maerl beds and seagrass are acknowledged yet dismissed as of “minor significance.” These are irreplaceable, priority habitats under UK conservation law.
• The surveys underpinning the EcIA are limited in season and scope. Significant data gaps are acknowledged, yet conclusions proceed as though the evidence base were sound.
• 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 to disturb and move approximately 850,000 tonnes of seabed material.
• 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 on “monitoring” rather than prevention.
• No credible compensation or restoration plan is offered for the loss of seagrass or maerl, despite their protected and slow-growing nature.
• 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 to Cornwall Council explicitly stated that the 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 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 should therefore be extended to allow people to engage on the basis of correct information. To proceed otherwise risks undermining the integrity of the process.

Conclusion The current application is environmentally unsound, procedurally compromised, and non-compliant with local policy. I therefore urge the MMO to:

• Refuse this application outright, or
• Require a revised Environmental Statement addressing the shortcomings above, alongside an extension of the consultation period.

Submitted on Mon 01 Sep 2025 13:30

I am writing to you in reference to the application MLA/2025/00157 (Falmouth Docks capital dredge).

There has been some extensive research about the negative impact of big cruise ships on our environment, our health and wellbeing.

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, at the dredging aspect of the development plan. Even if all precautionary measures were to be taken, which is potentially not the case, this process could be catastrophic for the local habitats and wildlife, even with some work of ‘reparation’.

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, is then difficult to dispose of, and can cause long-lasting erosion and habitat instability.

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, making them difficult and expensive to dispose of safely.

Given the fact that the dredging will take place in an area adjacent to a Special Area of Conservation, a holistic view of the plan is extremely important.

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, including on the legal side of things.

Reference:

Under schedule A2, paragraph 8 of the 2007 Regulations, “construction of harbours and port installations, including fishing harbours (projects not included in Schedule A1)”, is listed as being an Annex II/Schedule A2 activity. Please note that the European Directive 2011/92/EU,Annex II, 10 (e) also refers to appropriately equivalent wording.

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.

Submitted on Mon 01 Sep 2025 13:11

(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, Europe’s leading NGO on land-based and oceanic transport emissions, whose data and analysis underpin many of these points.

Or for verification, please contact any of the specialist marine biologists at Exeter university, or the Blue Marine Foundation.

Submitted on Mon 01 Sep 2025 12:28

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, a clear pattern has emerged. Once again, Falmouth Docks appear to be attempting to ride roughshod over environmental legislation, causing serious harm to the marine environment in pursuit of short-term profits.

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,” along with other toxic biocides, persist in a deep sludge of poisonous mud.

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, it will drift, smother, poison, and kill marine life indiscriminately—not only at the time of dumping but for years to come. Storms will repeatedly churn it up, driving it into sensitive habitats, including coral and oyster beds, particularly during easterly surges. None of this long-term risk is accounted for in the EIA.

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&P.

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

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, including the application of BEP. OSPAR Contracting Parties are encouraged to develop appropriate dredging strategies, in particular with regard to MPAs and other sensitive areas. However, before developing additional OSPAR measures to exercise specific control on the effects of dredging operations on marine species and habitats, existing regulations, including EU legislation, should first be fully implemented and evaluated.” https://qsr2010.ospar.org/media/assessments/p00366 Dredging.pdf

Marine Pollution Bulletin 2018

• Acoustic pollution from dredging disrupts communication and behavior in marine fauna.
• Altered hydrography and sediment composition change ecosystem processes, affecting spawning grounds and feeding patterns.
• Increased risk of invasive non-native species through altered substrates and water chemistry.

“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://www.sciencedirect.com/science/article/abs/pii/S0025326X18304545

This also relates to Marine Licence Application MLA/2025/00157

Submitted on Mon 01 Sep 2025 10:50

I am writing to object to the application (MLA/2025/00157 Application) to develop the docks at Falmouth – specifically 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 and noise pollution assessment

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, without which there is no meaning. An event may be “unlikely” yet the consequences of this “unlikely” event may be catastrophic – resulting in a much more significant risk profile – the ecological report does not identify the level of risk.

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), and the critical need for full Environmental Impact Assessments to be conducted.

To my knowledge this has not been done as part of this development application, and is essential to give the public any confidence that this application process has followed due diligence.

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, water quality or flood risk elsewhere in the catchment. We also design and undertake the work in a way that improves the river habitat or if that is not possible, minimise any impact as far as we can.” https://environmentagency.blog.gov.uk/2021/12/23/floods-and-dredging/

(continued in Public Representation 18)

Submitted on Sun 31 Aug 2025 21:52

Dear Marina Licensing Team,

There has been some extensive research about the negative impact of big cruise ships on our environment, our health and wellbeing.

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, at the dredging aspect of the development plan. Even if all precautionary measures were to be taken, which is potentially not the case, this process could be catastrophic for the local habitats and wildlife, even with some work of ‘reparation’.

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, is then difficult to dispose of, and can cause long-lasting erosion and habitat instability.

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, making them difficult and expensive to dispose of safely.

Given the fact that the dredging will take place in an area adjacent to a Special Area of Conservation, a holistic view of the plan is extremely important.

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, including on the legal side of things.

Reference:

Under schedule A2, paragraph 8 of the 2007 Regulations, “construction of harbours and port installations, including fishing harbours (projects not included in Schedule A1)”, is listed as being an Annex II/Schedule A2 activity. Please note that the European Directive 2011/92/EU,Annex II, 10 (e) also refers to appropriately equivalent wording.

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.

Submitted on Sun 31 Aug 2025 19:55

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.

Submitted on Sun 31 Aug 2025 3:32

Dear Marine Licensing Team,

I object to MLA/2025/00157 because the Environmental Impact Assessments provided are inadequate and underestimate the real risks of this project. Surveys of benthic habitats were too limited in scope and failed to reflect seasonal variation, leading to an under-recording of sensitive habitats such as maerl beds. Maerl is recognised as an irreplaceable habitat, and once smothered by sediment it cannot recover.

The dredging of 850,000 tonnes of contaminated sediment also poses a serious threat of resuspending TBT and heavy metals from historic antifouling paints. The Fal estuary is predominantly flood tide, meaning contaminants will be driven upriver, directly affecting shellfish beds and the oyster fishery. This is not properly modelled in the EIA.

Given these flaws, the assessments do not provide the robust scientific basis required for such a major licence. I urge the MMO to refuse consent or at minimum require a full reassessment of the ecological risks.

Yours faithfully, Belle Benfield

Submitted on Sat 30 Aug 2025 10:42

Subject: Formal Objection to Application MLA/2025/00157 – Proposed Dredging of Falmouth Harbour

Dear Sir/Madam,

I write to submit a formal objection to the above application for dredging works in Falmouth Harbour. The proposal, involving the removal of approximately 850,000 tonnes of contaminated sediments, presents grave legal, environmental, and public health risks.

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, heavy metals, and Wheal Jane mine residues into the water column.

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, including:

Water Framework Directive (2000/60/EC)

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, carbon, air quality, and public health assessments are undertaken, and a full Appropriate Assessment completed in line with the Habitats Regulations.

Submitted on Fri 29 Aug 2025 16:44

My representation is that -

The proposal to dredge the harbour would appear to be serve the cruise industry and increase the profits of the port.

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.

Submitted on Fri 29 Aug 2025 13:17

Please find below a briefing regarding application MLA/2025/00157 (Falmouth Docks capital dredge). I am concerned that the project has been incorrectly recorded as not falling under Annex I/II of Directive 2011/92/EU or Schedule A1/A2 of the Marine Works (EIA) Regulations 2007. Given the scale and location of this dredge adjacent to a Special Area of Conservation, this classification appears inconsistent with the Regulations and risks undermining the validity of the current EIA process. I therefore request urgent clarification from the MMO on this point. The full briefing is set out below for ease of reference:

FULL BRIEFING I note that in relation to application MLA/2025/00157, the MMO has indicated that the proposed Falmouth Docks capital dredge “does not fall within Annex I or Annex II of Directive 2011/92/EU or Schedule A1 or A2 of the Marine Works (Environmental Impact Assessment) Regulations 2007 (as amended).” This appears to be incorrect. Under Schedule A2, paragraph 8 of the 2007 Regulations, “construction of harbours and port installations, including fishing harbours (projects not included in Schedule A1)” is explicitly listed as an Annex II/Schedule A2 activity. The European Directive (2011/92/EU, Annex II, 10(e)) includes equivalent wording. The current proposal involves the capital dredging and disposal of approximately 850,000 tonnes of seabed material adjacent to a Special Area of Conservation, in order to expand the functionality of an existing commercial port. On its face, this is plainly a Schedule A2 project. 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.

Submitted on Fri 29 Aug 2025 8:08

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, protected habitats could be irreversibly damaged.

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), and EIA Regulations (Robust baseline evidence is lacking)

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, up-to-date surveys and studies are completed using modern methodologies.

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.

Submitted on Thu 28 Aug 2025 17:25

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: The project has been incorrectly recorded as not falling under Annex I/II of Directive 2011/92/EU or Schedule A1/A2 of the Marine Works (EIA) Regulations 2007. Given the scale of this dredge and its location beside a Special Area of Conservation, the project must be treated as a Schedule A2 Harbour construction and dredging for port expansion are Schedule A2 projects. That means they require full Environmental Impact Assessment.

2. Inadequate Marine Environmental Impact Assessments: The proposed dredging and dumping of 850,000 tonnes of material that contains highly toxic contaminants from the docks is potentially extremely damaging to local ecosystems. There are sensitive habitats close to this site and no proper current mapping. The impact on marine mammals and other wildlife could be disastrous. Much better evidence is required.

3. Justification: Whilst supporting renewables, KOSCF would like to see evidence that FLOW related infrastructure requires 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. We totally oppose the facilitation of large cruise ships - cruise ships have a negative impact on local communities and are highly polluting and unsustainable as a transport method. There are many harbours around the world trying to mitigate the impact of cruise ships or even banning them. Jobs are always used as an excuse for large projects like this - but it is important to recognise the jobs that flow from a healthy ocean. Equally, the health of our marine ecosystem is priceless.

https://keepourseachemicalfree.com

Submitted on Thu 28 Aug 2025 16:28

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, so you don’t believe the application requires a full environmental impact assessment. This is simply wrong. By law, harbour construction and dredging for port expansion are Schedule A2 projects. That means they require full Environmental Impact Assessment. Given the scale of this dredge and its location beside a Special Area of Conservation, the project must be treated as a Schedule A2 development. By recording it otherwise, MMO undermines the legal process and risks rendering the whole assessment unsound. This is a procedural flaw that you must address otherwise the whole project is illegal. I am objecting on these grounds -

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, fine sediment settling into maerl interstices, and light-blocking turbidity—all potentially lethal to sensitive species.

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, economic, and cultural value and to the health of our region and our planet. The MMO should be properly protecting it and upholding the laws which require a full EIA.

Submitted on Thu 28 Aug 2025 15:40

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, I am a local councillor in Falmouth, although am writing this in my personal capacity as the council was consulted on this prior to the 1 May elections. I am concerned by the statement on page one of the consultation document:

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't consider this development needs an environmental statement? I would have thought the development is covered by Schedule I Section 14 Trading ports; Schedule II 59 Construction of intermodal transhipment facilities and of intermodal terminals (Falmouth receives goods either by ship or lorry, e.g. bottles for recycling and building materials, before the goods continue on by lorry or ship) and 63 Construction of harbours and port installations of Directive 2011/92/EU. That being the case, an Environmental Impact Assessment is very much needed.

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 Marine area (within (2KM) and there doesn't seem to be a survey of the site, or information about how the dredged material will be distributed. In addition, while the numbers of protected bird species making their homes in the area may be low and they may be used to current dock activity, it doesn't mean they won't be fatally affected by the redevelopment and the proposed change of uses at the port. The precautionary principle should be followed here, especially as bird numbers are so low.

Furthermore, the dredging document A&P have provided seems to suggest that while precautions will be made to avoid contamination of the surrounding area, there won't be any monitoring. See attached screenshot of p 44 Falmouth Docks Development: Outline Construction Environmental Management Plan

Given the above, I think the MMO do need to look at this application carefully.

Yours sincerely,

Submitted on Thu 28 Aug 2025 11:10

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

• Capital dredging of approximately 850,000 tonnes of seabed.
• Disposal of dredged material at sea.
• Justification: deepen port for large vessels, including cruise liners and floating offshore wind (FLOW) infrastructure.

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, fine sediment settling into maerl interstices, and light-blocking turbidity—all potentially lethal to sensitive species.

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, economic, and cultural value.

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/heavy industry. 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.

Submitted on Thu 28 Aug 2025 10:12

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, so the assessment is based on 10 year old maps. 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

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

SRT has substantial concerns about this application, which seems inadequate to the extent that we would apply the precautionary principle and object to 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, which will impact sensitive and rare species including maerl, not just during the dredging process but when sediments are remobilised during storm events, which are becoming more frequent and severe due to climate change. This project needs to learn from previous examples with unintended consequences, such as the mass crustacean die off associated with similar activities in the Teesmouth area.

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, and therefore we are concerned that these incidents may increase due to the additional noise.

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.

Consulted on 18 July 2025. Responded on 29 August 2025.

The consultee was asked for their comments on this case. They responded:

Thank you for consulting us on the above marine licence application.

Environment Agency position

We have no objections to this proposal provided that conditions are included within any licence granted in respect of:

- Implementation of Flood Risk Assessment (FRA);

- Contaminated Land;

- Timing of piling work; and

- Dredging method.

The suggested wording for these conditions is set out below, together with advice on flood and coastal risk management, contaminated land, biodiversity, fisheries, water framework directive (WFD), pollution prevention and waste management.

Condition - Implementation of submitted FRA and 'Proposed Site / Layout Plan'

The development shall be carried out in accordance with:

- the Flood Risk Assessment, produced by Ramboll (Document Reference: 15743-RAM-FD-SW-RP-EV-00015) on 17/11/2024 and

- the 'Proposed Site / Layout Plan' document, produced by Ramboll (Document Reference: 15743-RAM-FD-SW-DR-CM-00003 REV S1-06) on 25/09/2023.

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.

The mitigation measures shall be fully implemented prior to first use and subsequently retained and maintained thereafter throughout the lifetime of the development.

Reason: To reduce the risk of flooding to the development and future users over the lifetime of the development.

Condition - Site Investigation and Remediation

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:

- A preliminary risk assessment which has identified:

- all previous uses

- potential contaminants associated with those uses

- a conceptual model of the site indicating sources, pathways and receptors

- potentially unacceptable risks arising from contamination at the site.

- 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.

- 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.

- 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.

Any changes to these components require the express written consent of the local planning authority. The scheme shall be implemented as approved.

Reasons: To ensure that the development does not contribute to, and is not put at unacceptable risk from, or adversely affected by, unacceptable levels of water pollution from previously unidentified contamination sources at the development site. This is in line with paragraph 187 of the National Planning Policy Framework.

Condition - Unsuspected Contamination

If, during development, contamination not previously identified is found to be present at the site then no further development (unless otherwise agreed in writing with the local planning authority) shall be carried out until the developer has submitted a remediation strategy to the local planning authority detailing how this unsuspected contamination shall be dealt with and obtained written approval from the local planning authority. The remediation strategy shall be implemented as approved.

Reasons: To ensure that the development does not contribute to, and is not put at unacceptable risk from, or adversely affected by, unacceptable levels of water pollution from previously unidentified contamination sources at the development site. This is in line with paragraph 187 of the National Planning Policy Framework.

Condition - Timing of piling work

No piling works shall take place in the estuary during the core sensitive period 1st April to 31st August.

Reason: To protect Atlantic salmon, European eels and Sea trout during the core sensitive period. Atlantic salmon are listed as species of Principle Importance under Section 41 of the Natural Environments and Rural Communities (NERC) Act 2006. They are protected under the Conservation of Habitats and Species Regulation (2017) as amended.

Recommendation: All percussive piling shall have a soft start up before full percussive piling takes place to ensure fauna, in particular fish, are able to move away before full percussive piling takes place.

Condition - Dredging method

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 on European eel. Any subsequent variations must be agreed in writing by the Environment Agency and the MMO.

Reason: Backhoe dredging is accepted as being low impact to eel at all life stages unlike other dredging methods. European eels are protected under the Eel (England and Wales) Regulations 2009, therefore certain types of dredging require an exemption notice under the Eel Regs which may require screening at inlets and outflows of pumps and or suitable mitigation.

Advice - Flood and Coastal Risk Management

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.

The Coastal Processes and Sediment Regime Report produced by Ramboll has confirmed that “The model predicts no maximum or minimum water level change greater than 1 mm, indicating no effect on habitat function or flood risk linked to the effect of the proposed development on tidal water levels”. Additionally, flood modelling indicates that the change in significant wave heights for the 1-year return period conditions at mean high water spring have a footprint that is broadly limited to the permitter of the development proposal. No change in wave height is indicated along the coastline or over intertidal areas. As such, we are satisfied that the proposal will not result in increased flood risk for surrounding areas.

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.

Advice - Contaminated Land

We have reviewed the Contaminated Land Desk Study prepared by Ramboll UK Limited (“Ramboll”) dated January 2025. The report identifies a moderate risk to controlled waters and other supplies and concerns. We suggest that intrusive ground investigation and risk assessment is carried out to confirm the level and severity of contamination across the site.

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 on this site poses an unacceptable risk to the environment and we would wish to object to the application.

Advice - Biodiversity

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 and mitigated the loss of habitat from the dredging activity within the Fal & Helford SAC.

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.

Advice - Fisheries

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.

Advice - Water Framework Directive (WFD)

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.

The main concerns highlighted by the assessment are mobilisation of sediments and contaminants, and impacts on protected sites in the area and fish. With regard to fish, in Table 4-2b on page 31 where it states “Both have the potential to be present but the Fal is not a particularly important river for either species*.” We take this opportunity to highlight that 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). Nevertheless, we consider that the conditions that we requested above should help prevent disturbance to any fish migrating up the Carrick Roads.

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).

Advice - Pollution prevention

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.

Such safeguards should cover the use of plant and machinery, oils/chemicals and materials; the use and routing of heavy plant and vehicles; the location and form of work and storage areas and compounds and the control and removal of spoil and wastes.

The Environment Agency can provide pollution prevention guidance: pmho1107bnkg-e-e.pdf. Further guidance is available at: Pollution prevention for businesses - GOV.UK

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.

Advice - Waste management

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:

Waste hierarchy guidance

Use of waste on-site

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) ©) for the use of, 'uncontaminated soil and other naturally occurring material excavated in the course of construction activities, etc…' in order for the material not to be considered as waste. Meeting these criteria will mean waste permitting requirements do not apply.

Where the applicant cannot meet the criteria, they will be required to obtain the appropriate waste permit or exemption from us.

The applicant is advised to contact our National Permitting Service on 03708 506 506 for further advice and to discuss the issues likely to be raised. Should a permit be required, they should be aware that there is no guarantee that it will be granted.

Movement of waste off-site

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.

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

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.

Proper classification of the waste both ensures compliance and enables the correct onward handling and treatment to be applied. In the case of treated wood, it may require high temperature incineration in a directive compliant facility. More information on this can be found here: Classify different types of waste: your legal responsibilities - GOV.UK

Informative - Environmental Permitting

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 on land. This option, if chosen, may require an Environmental Permit under the Environmental Permitting (England and Wales) Regulations 2016. On this basis therefore the applicant is advised to contact our National Permitting Service for further advice: Get advice before you apply for an environmental permit - GOV.UK

Please contact us again if you require any further advice.

Yours sincerely

SARAH SQUIRE

Sustainable Places - Planning Advisor

Direct dial 0208 474 6316

Direct e-mail SPDC@environment-agency.gov.uk

[Show full response](https://marinelicensing.marinemanagement.org.uk/mmofox5/fox/live/#)

Consulted on 18 July 2025. Responded on 8 September 2025.

The consultee was asked for their comments on this case. They responded:

Thank you for your consultation dated 18 July 2025. Please find attached Natural England's formal statutory response.

The consultee included the following files with their response:

The consultee was asked for their comments on this case. They responded:

The Crown Estate is affected by the proposed works and landowner's consent is required. The applicant is asked to liaise with our Managing Agent for the area: Michael Bapty of Carter Jonas on 01489 667840, mike.bapty@carterjonas.co.uk regarding landowner's consent for the proposed activity.

And

The Crown Estate is affected by the proposed disposal activity and landowner's consent is required. The applicant is requested to liaise with Mark Wrigley on 0207 851 5062, mark.wrigley@thecrownestate.co.uk regarding landowner's consent for the proposed disposal activity.

Consulted on 18 July 2025.

The consultee was asked for their comments on this case. They haven't submitted a response yet.

Consulted on 18 July 2025. Responded on 14 August 2025.

The consultee was asked for their comments on this case. They responded:

Please find attached Historic England's advice note

The consultee included the following files with their response:

Consulted on 18 July 2025. Responded on 19 September 2025.

The consultee was asked for their comments on this case. They responded:

Please find attached Cornwall IFCA's response regarding MLA/2025/000157 - Falmouth Docks Development.

The consultee included the following files with their response:

Consulted on 18 July 2025.

The consultee was asked for their comments on this case. They haven't submitted a response yet.

Consulted on 18 July 2025. Responded on 29 August 2025.

The consultee was asked for their comments on this case. They didn't have any comments.

Consulted on 18 July 2025. Responded on 1 September 2025.

The consultee was asked for their comments on this case. They responded:

Dear Yvonne,

Please see the attached advice regarding protected species.

Please note I have not commented on the identified Marine Protected Areas, as none of these are listed for any current or proposed MMO management.

Kind regards,

Hope

The consultee included the following files with their response:

Consulted on 18 July 2025. Responded on 3 September 2025.

The consultee was asked for their comments on this case. They responded:

Good afternoon Yvonne,

Trinity House has no objections to this application.

Consent is to be sought from Trinity House by Falmouth Dock and Engineering Company for any changes to aids to navigation.

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.

Many thanks.

Kind regards,

C. Bransby

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: 

Conditions: 

None

 In addition, the following advice should be provided to the applicant to facilitate the proposed works:

Advisories:

- 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, and representatives from across the marine industry sector. It is applicable to both Statutory Harbour Authorities (SHA) and non-SHAs including marinas, terminals, marine berths, and jetties. The Department for Transport also publishes the PMSC Guide to Good Practice, which provides useful information and detailed guidance on the safe management of these facilities and is intended to supplement the Code. This can be found here: Ports and marine facilities safety code - GOV.UK

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

[Show full response](https://marinelicensing.marinemanagement.org.uk/mmofox5/fox/live/#)

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

Consulted on 18 July 2025.

The consultee was asked for their comments on this case. They haven't submitted a response yet.

Consulted on 18 July 2025.

The consultee was asked for their comments on this case. They haven't submitted a response yet.

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:

Consulted on 18 August 2025. Responded on 22 August 2025.

The consultee was asked for their comments on this case. They responded:

Please find coastal processes advice attached here.

The consultee included the following files with their response:

Consulted on 15 August 2025.

The consultee was asked for their comments on this case. They haven't submitted a response yet.

Consulted on 21 July 2025. Responded on 11 August 2025.

The consultee was asked for their comments on this case. They responded:

Hi Yvonne

Please find enclosed my benthic ecology advice to this request.

All the best

Stef

The consultee included the following files with their response:

Consulted on 23 July 2025.

The consultee was asked for their comments on this case. They haven't submitted a response yet.

Consulted on 15 July 2026. Responded on 13 August 2026.

The consultee was asked for their comments on these documents:

They responded:

Please enter your comments here.

The consultee included the following files with their response:

Consulted on 28 April 2026. Responded on 20 May 2026.

The consultee was asked for their comments on [Falmouth SAC AA Addendum April 2026.pdf](https://marinelicensing.marinemanagement.org.uk/mmofox5/download/action/3ql5tlf91ih4fjpi2knn3pmr13sa6k9ue7t9icmq7c133f8ermqb5qgh7ct16bqbvto7knhtffvh169j7b1hquegr0iph19op3ev/action-download-file/fyG8ll_o4vuPPDKc/file) . They responded:

Dear Yvonne,

Apologies for the delay in responding. Please find Natural England's advice letter attached.

Kind regards,

Kate

The consultee included the following files with their response:

Consulted on 9 April 2026. Responded on 1 May 2026.

The consultee was asked for their comments on [ES Vol1 Ch10 Commercial Fisheries and Shellfisheries 02.pdf](https://marinelicensing.marinemanagement.org.uk/mmofox5/download/action/3ql5tlf91ih4fjpi2knn3pmr13sa6k9ue7t9icmq7c133f8ermqb5qgh7ct16bqbvto7knhtffvh169j7b1hquegr0iph19op3ev/action-download-file/fyG8w6_o4vuPPDKc/file) . They haven't submitted a response yet.

Consulted on 9 April 2026. Responded on 27 April 2026.

The consultee was asked for their comments on [ES Vol1 Ch10 Commercial Fisheries and Shellfisheries 02.pdf](https://marinelicensing.marinemanagement.org.uk/mmofox5/download/action/3ql5tlf91ih4fjpi2knn3pmr13sa6k9ue7t9icmq7c133f8ermqb5qgh7ct16bqbvto7knhtffvh169j7b1hquegr0iph19op3ev/action-download-file/fyG8w6_o4vuPPDKc/file) . They responded:

Good morning,

Please see the attached advice in relation to shellfisheries.

Kind regards

Bella Voak (shellfish advisor)

The consultee included the following files with their response:

Consulted on 14 November 2025. Responded on 8 December 2025.

The consultee was asked for their comments on these documents:

They responded:

Please find my comments attached.

The consultee included the following files with their response:

Consulted on 17 October 2025. Responded on 26 November 2025.

The consultee was asked for their comments on these documents:

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,

Esther Hughes

Marine Higher Officer

Devon Cornwall and Isles of Scilly Area Team

Natural England

Consulted on 28 August 2025. Responded on 3 October 2025.

The consultee was asked for their comments on [ES Vol1 Ch10 Commercial Fisheries and Shellfisheries 02.pdf](https://marinelicensing.marinemanagement.org.uk/mmofox5/download/action/3ql5tlf91ih4fjpi2knn3pmr13sa6k9ue7t9icmq7c133f8ermqb5qgh7ct16bqbvto7knhtffvh169j7b1hquegr0iph19op3ev/action-download-file/fyGjdW_o4vuPPDKc/file) . They didn't have any comments.

Consulted on 28 August 2025. Responded on 2 October 2025.

The consultee was asked for their comments on [ES Vol1 Ch10 Commercial Fisheries and Shellfisheries 02.pdf](https://marinelicensing.marinemanagement.org.uk/mmofox5/download/action/3ql5tlf91ih4fjpi2knn3pmr13sa6k9ue7t9icmq7c133f8ermqb5qgh7ct16bqbvto7knhtffvh169j7b1hquegr0iph19op3ev/action-download-file/fyGjdW_o4vuPPDKc/file) . They responded:

Good afternoon,

Please see the attached advice in relation to shellfish.

Kind regards

Bella Voak

The consultee included the following files with their response: