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                    <text>Potential Climate Change Threats to underwater cultural heritage
Sirine Saad El-Dine Ghiye (Lebanese Archeologist, Diver)
Msc Student, Ulster University Ghiye-S@ulster.ac.uk / ghsirin@gmail.com
Abstract
Climate change is our greatest challenge. The paper is looking for the impact on underwater cultural heritage
(UCH), deep oceans, and coastal zone through literature reference and case studies. It will discuss the causes of
climate change, the results, with a focus on the sea surface temperature (SST) changes in the Mediterranean Basin
and the Pacific. SST will be calculated using Landsat 8 which is equipped by two bands of thermal infrared sensor
(TIRS). It is suitable for coastal zone monitoring due to its high resolution. The study depends on the use of
Landsat 7 which carried the Enhanced Thematic Mapper Plus (ETM+) sensor. Both images are interpreted and
analyzed on the QGIS to calculate the radiance and reflectance of each image to conclude the value of SST. The
paper will finish by presenting the cycle factors which threaten the UCH and summarize the relationship between
the change of climate and the UCH and how they help researchers understand climate in the past and the
adaptation by humans in past.
Keywords: climate change, SST, UCH, satellites imagery
List of Abbreviations
Carbone dioxide …. CO2
Normal Difference Vegetation Index …. NDVI
Operational Land Imager …. OLI
Sea surface temperature …. SST
Sea surface salinity …. SSS
Thermal Infrared Sensor …. TIRS
Thematic Mapper …. TM

U.S. Geological Survey …. USGS
Underwater cultural heritage …. UCH
List of figures
Figure 1. Lebanese land map
Figure 2. Chekka area with the cements factory’s location (Landsat 8, 2022)
Figure 3. Temperature during summer, Landsat 8, 2021, Temperature during summer, Landsat 7 1999
Figure 4. SST during the last 20 years ago during the winter

4
5
7
8

INTRODUCTION
The topic of this paper fits best within this Session “Major Threats to Underwater Cultural Heritage and
its environment,” because it will discuss the main disturbances and problems facing the maritime
archeological sites and underwater cultural heritage (UCH) due to climate change. This paper defines
the relation between climate and seas and oceans health, where the relationship is strong and
interdependent.
Climate can be defined into two levels: local climate, which is related to a specific area, city or country;
and global climate of Earth. The global climate is the connected system of sun, land and oceans, wind,
rain and snow, forests, deserts and savannas, and human activity (Lange 2020). All these local factors
are connected and responsible for the balance of ecosystems; any change in one ecosystem leads to
change in global climate. For example, global warming which is increasing of heat or energy in the
atmosphere of the Earth led to climate change (Rockman and Hritz 2019). Rising temperature of the
atmosphere led to melting of the ice in the poles which led to sea level change, this event was recognized
at the beginning of 19th century (Kennedy et al. 2002).
Anthropogenic factors are the main factor of climate change at a population of 7.8 billion people (World
Bank 2023). This is well defined and explained by the assessment reports of the Intergovernmental
1

�Panel on Climate Change which describe the influence of human activities that lead to warmer
atmosphere. Urbanization, development, and lots of industrial businesses accelerate the deterioration of
seas and oceans due to illegal infringement on the coast, increased illegal fishing, and toxic gas
emissions, all those led to change the main property of climate. One of results of climate change is the
increasing of the sea surface temperature, which led to change the chemical property of salt water
(Splading 2011). The paper presents the changes of sea surface temperature (SST) in Chekka, Lebanon
with satellites imagery on QGIS.

CASE STUDIES
The case studies under consideration are the following regions: the Mediterranean and the Pacific
basins. This paper detects the changes in sea surface temperature in the Mediterranean basin through
focusing in one example taking from Lebanon: Chekka area- North Lebanon (Figure 1). The aim of
taking this example is to prove how the human activity next to the sea, lead to change and increase in
the SST and land surface temperature in general. Chekka is a coastal area located in the Lebanese
northern provenance facing the Mediterranean Sea (Figure 2). Chekka provides two potential locations
for harbours, one to the north and one to the south of the headland of Chekka and its harbour is
mentioned when it was occupied by the Arwad’s fleet1 (Safadi 2014). The town was covered by olive
trees and salt marshes on the coast. These conditions of the town have been changed after the
construction of the first cement factory in the area dated back to 1931 CE followed by another company
after two decades. The coastline changed becoming heavily populated and many agricultural areas
vanished.
The main reason of this paper is to detect and monitor the changes of SST in the Chekka area as a
typical example for human activity effect on the seas and oceans health. The study is going to compare
the SST during summer and winter seasons during the last 20 years. This will be using satellites imagery
of Landsat program is the longest-running enterprise for acquisition of satellite imagery of Earth. It is
a joint NASA / USGS2 program and launched on 23 July 1972.
The study is also looking at the changes in SST of Pacific region and identifying the main reason for
these changes. The North Pacific has a temperature higher than the South, and that is because of the
ratio of land to sea areas is larger in the Northern Hemisphere and because Antarctica and the Southern
Ocean also influence water temperature (Cotter et. al. 2023). From the studying of those two regions,
the paper is identifying the results and consequences of changes in SST and the effect on the ocean, and
therefore to determine the effects on the maritime sites in seas and deep oceans. Radiance and
reflectance of images captured by the thematic sensor of Landsat are essential to calculate the value of
temperature. This will be explained in detail in the methodology.

1

It developed into a trading city in the Bronze Age, as did most of the Phoenician cities on this coast. It had a powerful
navy, and its ships are mentioned in the monuments of Egypt and Assyria (Safadi 2014).
2 The U.S. Geological Survey is the nation's largest water, earth, and biological science and civilian mapping agency (USGS
website)

2

�Med. Sea

Figure 1. Lebanese land map

3

�Med. Sea

Figure 2. Chekka area with the cements factory’s location (Landsat8 2022)

METHODOLOGY / RESOURCES
The use of remote sensing and geographic information system as the QGIS free and open source,
becomes a new technique used in studying many marine (Ramdani et al. 2021).
The paper studies the changes in SST through satellites imagery, calculate and measure the temperatures
on QGIS tools, in reason the detect the increasing of temperature during the last 20 years taking into
consideration the seasons: winter and summer. The study is based on literature and previous study on
the effect of climate change on the maritime sites, and how the maritime resource becomes a factor to
understand the climate change.
The algorithm created on ERDAS imagery 2014 for calculating the land surface temperature (LST), it’s
the same concept for SST (Advan and Jovanovska 2016). The layers used in the project are raster and
vector interpret and analyzed on QGIS version 3.6. The main coordinate system used is the WGS84
UTM zone 36N, ESPG: 32636.
The Landsat 8 which is working on infrared radiometer band 10 and 11 provides huge data covered the
Lebanese land. The sensors deployed on satellites imagery Landsat8 Operational Land Imager (OLI)
and the Thermal Infrared Sensor (TIRS) instruments allow to assess water parameter efficiently.
Through TIRS we can measure the land temperature in two thermal bands with a new technology that
applies quantum physics to detect heat. The process worked by measuring the amount of infrared light
emitted from the earth and the radiant temperature of water bodies (Bourouhou and Salmoun 2021).
Both sensors are covered the landmass with 30m of resolution (visible, NIR, SWIR); 100 meters
(thermal); and 15 meters (panchromatic). The primary features on Landsat 7 include a panchromatic
band with 15-meter spatial resolution, an onboard full aperture solar calibrator, five percent absolute
4

�radiometric calibration, and a thermal infrared channel with a four-fold improvement in spatial
resolution over Thematic Mapper (TM) (NASA, 2021).
Steps of calculating SST
1. Calculating the Top of Atmosphere radiance which is the raw images captured by sensor of
satellites, the radiance is the amount of radiation coming from the area, surface and cloud.
2. Calculating top of atmosphere reflectance which provides the ratio of radiation reflected to the
incident solar radiation on a given surface, and also from the cloud and atmospheric aerosols and
gases.
3. The brightness temperature is the measurement of radiance of the microwave radiation traveling
upward from the top of atmosphere to the satellites.
The process continues in progression to find the emissivity Ɛ of each pixel to convert the brightness
temperature into land surface temperature or in the other hand the sea surface temperature. The
emissivity is originated from the value of Normal Difference Vegetation Index NDVI which is provided
by the visible red and near infrared bands. The result returns the maximum and minimum values of
NDVI which are used in finding the proportion of vegetation in reason to rescale the NDVI between
values representing bare soil and total vegetation.
The operation is going to show the difference of temperature during the last 20 years with taking into
consideration the same seasons, where the result section interprets the analysis value through literature
resources of the impact of SST changes on UCH.

RESULTS
The results observed after calculating the SST through the Landsat images present an increasing of
temperature by almost 1 ºC during the last 20 years. Extracting results from maps shows the increasing
of temperature on the coastline near the cement factory, where the SST in the middle of sea become
more less. Figure 3 present clearly these changes, where the temperature on the coastline during summer
in 1999 was 24ºC -25 ºC, and it was almost 23 ºC far from the coast, but today the temperature on the
coastline in 28 ºC-29 ºC, and it’s almost 27 ºC far from the coast.
The results are also extracted from the SST map during the winter season for 2000 and 2021, where the
average temperature in Chekka area increased 2 ºC during the last 20 years (Figure 4).

5

�Figure 3. Summer temperature today (TOP, Landsat8 2021).
Summer temperature 20 years ago (BOTTOM Landsat7 1999)

6

�Figure 4. Winter SST today (left) and 20 years ago (right) (Landsat8 2021; Landsat7 1999).

This example describes the changes in SST due to the rising of toxic gases from the cement factories
next to the coastline. The main issue is to understand how the increasing of SST effect on the seas and
oceans health, thus on the maritime and coastal sites. There are an estimated three million shipwrecks
on the floors of the world’s oceans (Gregory et al. 2022), and more than 1000 coastal sites are under
threat and damage because of sea level rise (Reiman et al. 2018)
Increasing of CO2 in the atmosphere due to pollution and toxic gases, it leads to increase the
temperature of air, thus, to melt the ice of poles where this lead to rise the sea level. Research confirms
the rise of sea level by 1m by the end of 21st century, together with an increase in ocean surface
temperatures (i.e., water to a depth of approximately 100m) of between 0.2 and 0.5°C (Gregory et al.
2022). In summary, rising of sea level led to many unprecedented weather events which impact directly
on the coastal sites and erosion of coastline due to high tides. (Sesana et al. 2020). The effect of sealevel rise led to flooding and storms especially during the heavy rainfall, where the coastal sites become
underwater sites with time. The effect of sea level not only on culture heritage but also on the marine
boundary higher level will result in legal maritime boundaries become less well defined (Perez-Alvaro
2016).
In addition, the submerged sites will be affected by the sea level rise because adding more water led to
put the UCH under more depth, and more mass of water quantity on the shipwreck lying on the seabed
which may be more than they can withstand (Sesana et al. 2020). Furthermore, the most recent IPCC
report indicates not only an impact on surface ocean, temperatures but also on the deep ocean, with
increases of 0.6–2.0°C chemical reaction rates double for every 10°C increase in temperature (Kennedy
et al. 2002). This would reduce the amount of time a diver can remain underwater.
Increased CO2 in the atmosphere, which is absorbed by the oceans, leads to increase in the acidification
of seas and oceans where the PH of water decrease and influences the iron and steel of shipwrecks by
7

�increasing the rate of corrosion (Perez-Alvaro 2016; Wright 2016). With more evaporation and
precipitation and formation of sea ice lead all together to increase the salinity in water and change the
chemical and physical property of sea and ocean, that will create new bacteria and new organisms,
which affect and threaten the archeological features especially the shipworms, causing damage to
underwater wooden structures (Sesana et al. 2020).
This study shows the high impact of climate change and the relation with the UCH, which became a
main part of marine environment, the changes of sites help to understand the changes in climate.

CONCLUSION / DISCUSSION
We conclude that climate change will directly affect coastal and underwater sites, including the
deterioration of our UCH. The relation between climate change and maritime archeological sites is very
connected because shipwrecks become part of the marine environment such as artificial reefs.
Today, maritime archeology help researchers to understand the past climate and the human past
adaptation with climate change, where maritime and coastal sites illustrate the environmental changes.
Several projects provide the opportunity for maritime archaeology research on climate in the past and
then educate humanity to better understand the climate crisis. For example, several studies that focus
on the human-environment interaction such as migration in ancient periods, and human uses of aquatic
environment may inform what may happen in the future. It is important to involve cultural heritage in
climate action because heritage includes the identity of people that they want to pass to future
generations, and which may be at risk due to climate change.

8

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Bourouhou I., and Salmun F. Sea surface temperature estimation using remotely sensed imagery of Landsat 8 along the
coastline of Tangier - Ksar Sghir region, The International Conference on Innovation, Modern Applied Science &amp;
Environmental Studies (ICIES2020), Vol 234, 2021.
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https://www.britannica.com/place/Pacific-Ocean

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Gregory, Dawson, Elkin, Van Tilburg, Underwood, Richards, Viduka, Westley, Wright, Hollesen. Of time and tide: the
complex impacts of climate change on coastal and underwater cultural heritage, Journal of Antiquity 96, no. 390 (2022):
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Kennedy, Twilley, Kleypas, Cowan, Hare. Coastal and marine ecosystems and global climate change: potential effects on US
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Lange M. Climate Change in the Mediterranean: Environmental Impacts and Extreme Events, European Institute of the
Mediterranean, In: IEMED URLhttps://www.iemed.org/publication/climate-change-in-the-mediterranean-environmentalimpacts-and-extreme-events/. 2020.
Perez-Alvaro, E. Climate change and underwater culture heritage: Impacts and challenges, Journal of Culture Heritage 21,
(2016): 842-848.
Ramdani, Wirasatriya, Jalil. Monitoring the Sea Surface Temperature and Total Suspended Matter Based on Cloud Computing
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Region Eco-Development, IOP Conf. Ser.: Earth Environ. Sci. 750, 2021.
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due to sea-level rise, Journal of Nature Communications 9, no. 4161 2018. URLhttps://www.nature.com/articles/s41467-01806645-9
Reul, Grodsky, Arias, Boutin, Catany, Chapron, Amico, Dinnat, Donlon, Fore, Fournier, Guimbard, Hasson, Kolodziejczyk,
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radiometers: An overview of the first decade of observation (2010–2019), Journal of Remote sensing of Environment Vol.
242, no. 111769. 2020. URL https://www.sciencedirect.com/science/article/pii/S0034425720301395
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Southampton University 2014.
Sesana E., et al., Climate change impacts on cultural heritage: A literature review, Ed: Carter T, et all., Journal of Wiley
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Splading M. Perverse Sea change: underwater culture heritage in the ocean is facing chemical and physical changes, culture
heritage &amp; art review. 2011.

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climate change, the results, with a focus on the sea surface temperature (SST) changes in the Mediterranean Basin&#13;
and the Pacific. SST will be calculated using Landsat 8 which is equipped by two bands of thermal infrared sensor&#13;
(TIRS). It is suitable for coastal zone monitoring due to its high resolution. The study depends on the use of&#13;
Landsat 7 which carried the Enhanced Thematic Mapper Plus (ETM+) sensor. Both images are interpreted and&#13;
analyzed on the QGIS to calculate the radiance and reflectance of each image to conclude the value of SST. The&#13;
paper will finish by presenting the cycle factors which threaten the UCH and summarize the relationship between&#13;
the change of climate and the UCH and how they help researchers understand climate in the past and the&#13;
adaptation by humans in past.</text>
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                <text> Ghiye, Sirine Saad El-Dine. 2023. “Potential Climate Change Threats to underwater cultural heritage.” Edited by Jennifer Craig, Jay Mok, T. Kurt Knoerl, Elena Perez-Alvaro, and Ole Varmer. In Proceedings of Fifth Asia Pacific Regional Conference on Underwater Cultural Heritage: Gwangju, The Republic of Korea, November 13-18 2023. The Museum of Underwater Archaeology. URL: https://apconf.omeka.net/exhibits/show/apconfproceedings/item/1960</text>
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                    <text>Impact Assessment of Current and Future Sea-Level Rises on Coastal and Underwater
Archaeological Sites in Indonesia
Ulung J. Wisha1,2, Wisnu A. Gemilang3, &amp; Nia N. H. Ridwan3
1

Department of Physics and Earth Sciences, University of the Ryukyus, Nishihara-Japan

2

Research Center for Oceanography, National Research and Innovation Agency (BRIN),
Jakarta-Indonesia
3

Research Institute for Coastal Resources and Vulnerability (RICRV), Ministry of Marine
Affairs and Fisheries, Padang-Indonesia

ABSTRACT
Despite the indirect impact of sea level rises on underwater archaeological sites, identifying future conditions is
imperative to support conservation planning to minimise the possible effects that may occur. This study aims to
identify the sea level trends in several important archaeological sites in Indonesia and estimate the future change
due to sea level rises. Altimetry satellite data were employed to determine the sea level anomaly (SLA) of three
chosen sites: Mandeh Bay, Banten Bay, and southern Tidore, where significant historical objects were recently
discovered. Hydrodynamic-based modelling was also used to estimate the water properties alteration in 2100 as
predicted by IPCC AR6, with a projection of about 0.68-0.70 meters (m) sea level increase. Under the sea level
rise scenario, the current magnitude will increase significantly by about 33-35per cent in 2100. It is followed by
an increase in sediment transport of 18 â€“ 37 per cent. As sedimentation is the primary issue in these three sites,
sea level rises will induce sufficiently high sedimentation on archaeological remains, and artefact shifting
position is also possible due to the more robust current regimes. Therefore, regular monitoring is an effort to
protect the archaeological remains. If possible, excavations are also recommended to conserve the underwater
cultural heritage (UCH) in Indonesia since it faces an upward sea level trend.
Keywords: UCH, shipwreck, artefacts, sea level trends, sea level projections

INTRODUCTION
Sea level rise has become a growing concern in recent years as it threatens coastal areas and poses a
significant threat to the preservation of underwater archaeological sites (Wetsley et al. 2023, 251-253).
Indonesia with its vast coastline and rich cultural history is no exception to this issue. The rising sea
level in Indonesia is gradually eroding coastal areas and threatening to submerge many ancient
underwater archaeological sites, which are essential for scientific research but also for the cultural
heritage of the country (Adhityatama and Yarista 2019, 55-56). Understanding the relationship
between sea level rise and underwater archaeological sites in Indonesia is crucial for preserving the
country's cultural heritage and preventing the loss of valuable historical information. Several
shipwrecks and underwater archaeological sites in Indonesia are threatened by sea level rise, including
those in the waters of Java and Sumatra. These sites would be a significant loss for scientific research
and destroy Indonesia's cultural heritage. Therefore, preserving these sites and preventing them from
being lost to the sea is essential.
Historical shipwrecks are diving sites and the object of research in Indonesia (Dillenia et al. 2021, 2-3;
Ridwan 2011, 5-6). To date, no studies assess the relationship of sea level trends with archaeological
remains in the coastal and terrestrial zones. Some examples of well-known archaeological remains that
may be threatened by sea level rise are: MV Boelongan Nederland, Gosong Nambi Shiwreck, and
Ceramic findings in Sungai Nyalo, situated in the West Sumatra, USS Houston and HMAS Perth in

1

�Banten Bay, and Tonguwai and Soasio archaeological sites in Tidore Island, North Moluccas Province.
This study will compare the status of sea level trends in these sites and their possible influence on the
UCH. Estimating the future state concerning sea level projection established by The
Intergovernmental Panel on Climate Change (IPCC) can be approached using hydrodynamic
modelling and statistical-based analysis. Therefore, this study describes the possible impact of sea
level rises on underwater archaeological remains in Indonesia. This study is expected to become a
basis for future decision-making regarding UCH preservation for local and central authorities.
CASE STUDIES
As mentioned earlier, this study will assess the possible impact of sea level rise on UCH in Indonesia.
Therefore, in this section, we want to introduce several essential sites threatened by sea level rise.
There are many significant archaeological sites in the West Sumatra Province. However, in this stage,
we will introduce the latest identified sites surrounding Mandeh Bay, namely MV Boelongan
Nederland and Gosong Nambi Shipwreck underwater sites and Sungai Nyalo terrestrial site. In 2017,
RICRV discovered plenty of artefacts in the terrestrial area of Mandeh Bay called Sunyai Nyalo
Village, close to the MV Boelongan Nederland shipwreck. Of 654 fragments were conserved,
consisting of ceramic pieces, green-glass bottles, and earthenware bottles with European, East Asian,
and Southeast Asian motifs (Figure 1a and b). This finding is an example of the incredible impact of
sea level rise since the upward trend of sea level induces significant erosion in the coastal area.
Therefore, these artefacts could be discovered at a one-meter depth. Thus, analysing sea level
anomalies in the West Sumatra region, particularly in the surrounding Mandeh Bay, is significant in
understanding its impact on shipwreck future conditions and the faith of undiscovered terrestrial
remains that may still exist in the West Sumatra Province.

Figure 1. The documentation of archaeological remains in the Indonesia waters; Sungai Nyalo artifact (a and b); Gosong
Nambi wreck (c and d); MV Boelongan Nederland (e and f); HMAS Perth (g and h); USS Houston (i and j); Artefact
findings in Tidore (k and l)

A shipwreck discovered by local fishers in 2015 and initially established in 2020 is the Gosong Nambi
wreck (Wisha et al. 2020, 63-65). Despite the lack of historical context for these remains, the
shipwreck is the centre of biodiversity since it is trapped within an atoll formation (Figure 1c and d).
Recently, locals reported that the position of this wreck is lowered due to the rubble avalanches
induced by extreme weather and tides. Therefore, since the remains are vulnerable, the long-term sea

2

�level rise could cause a more lowering position of this wreck and even be buried by rubble and
sediment.
On the other hand, MV Boelongan Nederland was a cargo ship built in the 1920s by the Dutch
shipping company Koninklijke Paketvaart-Maatschappij (KPM). The ship was used for transporting
goods and passengers in and around Indonesia and Southeast Asia. During WWII, the ship was taken
over by the Dutch and used to aid the war effort. However, in 1942, the Dutch scuttled the ship to
prevent it from falling into the hands of the advancing Japanese forces (Ridwan et al. 2015, 84-87).
The remains of MV Boelongan Nederland now lie in the waters off Mandeh Bay, West Sumatra,
Indonesia, and have become a popular recreation dive site. The shipwreck is also of historical
significance as it provides insights into the maritime history of Indonesia and the role played by
shipping companies like KPM in the region. This site is threatened by massive sedimentation, which
frequently hampers the diving activity due to the high sediment supply from the Mandeh Estuary right
in front of the shipwreck position (Figures 1e and f). The shipwreck lies at a depth of about 20 m, and
under the scenario of sea level rises, it is hypothesised that the sediment issue will get worse with
increasing sea levels.
The other case studies considered in this study are USS Houston and HMAS Perth shipwreck sites.
The USS Houston and HMAS Perth were two naval warships that were heavily damaged during the
battle and eventually sank during WWII in the Battle of Sunda Strait, which took place on 28 February
1942. Today, the USS Houston and HMAS Perth wrecks are popular dive sites in Indonesia and are
located near the island of Java. The wrecks are historically and culturally significant and essential for
scientific research and a reminder of the sacrifices made by those who fought in WWII. Efforts have
been made to preserve and protect the wrecks, including establishing a protected zone around the sites
and conducting ongoing monitoring and research to document changes in the condition of the wrecks
over time (Figure 1gâˆ’j) (Shaw 2017, 2-7).
Based on the recent documentation and field identification conducted by RICRV in 2018, HMAS
Perth is positioned at 19-34 m depth, while the USS Houston is at a depth of 16-30 m, both located in
the northern Panjang Island. The main problem in these sites is high sedimentation, with almost zero
visibility (Ridwan 2019, 1626-1627). Moreover, the shipwrecks are surrounded by mining and
industrial activities; they are located in the fishing zone; and are degraded by marine debris pollution
(Wisha et al. 2022a, 106009). Therefore, the increase in sea level could worsen the shipwreck
conditions in terms of greater sedimentation and degradation.
In east Indonesia Tidore Island, was the location to witness the first circumnavigation of the Earth by
Ferdinand Magellan and Juan Sebastian Elcano. There are many remains on Tidore Island as evidence
of Portuguese and Spanish colonialism over spice resources in this area. The most reachable sites are
Tongwai and Soasio, where many artefact fragments, such as cannon, ceramics, earthenware, and
metals, are scattered on the surrounding coral reef ecosystem, increasing the attractiveness of these
sites to recreation (Figure 1k and l) (Rahmawan et al. 2021, 173-174). Since it is directly connected to
the Pacific Ocean, the sea level rise may deteriorate the site conditions.
RESOURCES
To review the sea level trend in the study sites, we used the ~27-year sea level data (1992-2019) from
altimetry satellites, The Sea Level Explorer established by the University of Colorado Boulder, the
University of Hawaii Sea Level Center, and NASA Jet Propulsion Lab, (see
https://ccar.colorado.edu/altimetry/ ). The altimetry data were sourced from the Propulsion Labâ€™s
Physical Oceanography Distributed Active Archive Center (PODAAC). The sampled altimetry
coordinates (Table 1) are in Mandeh Bay, Banten Bay, and southern Tidore Island.
On the other hand, to estimate the possible future alteration due to sea level rises, we employed a sea
level projection data provided by the NASA Sea Level Projection Tool allowing users to visualize and

3

�download the sea level projection data from the IPCC 6th Assessment Report (AR6) (see
https://sealevel.nasa.gov/ipcc-ar6-sea-level-projection-tool). It is estimated that in 2100 CE the sea
level will increase by 0.68 m for Mandeh and Banten Bay and 0.70 m for Tidore Island.
The archaeological and environmental data were obtained from RICRV reports of field surveys in
Mandeh and Banten Bay in 2018 and in Tidore in 2019. The field survey consisted of diving activity
to the shipwreck sites, mini excavation, oceanographic parameters measurements, sediment sampling,
local social-economy, interviews, acoustic-based measurements, and many others.
Table 1. Coordinates of the sampled sea level data
Location
Mandeh Bay
Banten Bay
Southern Tidore Island

Longitude
100.2500oE
106.0833oE
127.4167oE

Latitude
1.2500oS
5.9167oS
0.5833oN

FRAMEWORK
The sea level anomaly (SLA) data was gained from yielded deviation between sea level at a specific
time and the mean sea level. Then, a future linear trend was used to calculate the sea level trend, the
annual amplitude, and the semi-annual amplitudes of each archaeological site.
As for estimating the future changes based on sea level projection, we employed a coupled model of
MIKE21 with flexible mesh to simulate the mutual interaction between waves and currents using a
dynamic coupling between the hydrodynamic and spectral wave models (Wisha et al. 2022b, 78). We
sampled the result from the coupled model developed according to site locations.
The sediment transport model is based on the hydrodynamic models previously simulated (Wisha et
al. 2022b, 78). The following equation defines the correlation between the wave energy flux
component and the sediment transport:
ð‘Šð‘’ð‘“ =

ðœŒð‘”
8

ð»ð‘2 ð¶ð‘ ð‘ ð‘–ð‘›ð›¼ð‘ ð‘ð‘œð‘ ð›¼ð‘

(1)

Where:
ð‘Šð‘’ð‘“ = Wave energy flux component along the coast at the time of wave breaking kilogram-meter per
second (ð‘˜ð‘”. ð‘š. ð‘  âˆ’1 )
ðœŒ = Specific gravity (seawater) kilogram per cubic meter (ð‘˜ð‘”. ð‘šâˆ’3 )
ð‘” = Gravity acceleration (9.81 meter per second squared(ð‘š. ð‘  âˆ’2 )
ð»ð‘ = Wave Height at the time of breaking (ð‘š)
ð¶ð‘ = Breaking wave celerity meters per second (ð‘š. ð‘  âˆ’1 )
ð›¼ð‘ = Breaking wave angle
A formula established by Triatmodjo (2012) was used to estimate the annum sediment transport. The
formula is defined as follows:
ð‘„ð‘  =

ð¾
ð‘Š
(ðœŒð‘  âˆ’ðœŒ)ð‘”(1âˆ’ð‘›) ð‘’ð‘“

(2)

Where:
ð‘„ð‘ 
= Sediment transport along the coast cubic meter per second (ð‘š3 . ð‘  âˆ’1 )
ð¾
= 0.39
ðœŒð‘ 
= Specific gravity (sand) (ð‘˜ð‘”. ð‘šâˆ’3 )
ð‘›
= Porosity (ð‘› â‰ˆ 0.4)

4

�RESULT
Sea Level Trend Over the Archaeological Sites in Indonesia
The altimetry data show upward trends of sea level over the sampled sites, at 0.39 centimetres per year
(cm/year), 0.40 cm/year, and 0.52 cm/year for Mandeh Bay, Banten Bay, and southern Tidore (Figure
2 and Table 2). Over 27 years of observed data (1992-2019), different patterns were observed in the
three parts of the Indonesian region. In Mandeh Bay, the sea level has increased since 2004 and
peaked in 2017 with an SLA magnitude of about 38 cm. Similar to Mandeh Bay, the SLA in Banten
Bay rose significantly in 2007, where the lowest sea level was observed in the next year, reaching -30
cm. The maximum sea level over 27 years was identified in 2018, reaching 26 cm.

Figure 2. Sea level trend over Indonesia region (a) derived from Altimetry data; (b) SLA in southern Tidore island;
(c) SLA in Mandeh Bay; (d) SLA in Banten Bay

In Tidore Island, the recorded sea level is arbitrarily erratic (Figure 2b). The sufficiently high sea level
trend in this area is due to the influence and circulation of the Pacific Ocean, where El-Nino Southern
Oscillation (ENSO) plays a significant role in shaping sea level (Moon et al. 2015, 8229). The lowest
sea level ever recorded was observed in 1998, reaching -28 cm, while the peak levels were observed
several times, such as in 2012 and 2018, reaching 25 cm. Overall, all those sampled archaeological
sites face an upward trend in sea level (Table 2), so future estimation of coastal dynamics due to sea
level rises is imperative.
Table 2. Sea level trend over 27 years of observation
Parameter

Mandeh Bay

Banten Bay

Southern Tidore Island

Trend (cm/year)
Annual Amplitude (cm)
Semi-Annual Amplitude (cm)

0.39
1.66
4.56

0.40
3.03
3.21

0.52
3.63
0.53

5

�The Possible Impact of Sea-Level Rises on Archaeological Remains
Sea level rises significantly impact shipwreck sites, particularly those located in coastal regions or
underwater. As sea levels rise it can lead to increased erosion, flooding, and sedimentation causing
damage to shipwrecks and their associated artefacts. Additionally, changes in ocean currents and
weather patterns can contribute to shipwreck deterioration.
One of the primary concerns with rising sea levels is the potential for loss of archaeological
information. As shipwrecks are exposed to increased water pressure and changing environmental
conditions, they can be subject to accelerated decay and destruction. This can result in losing valuable
historical and cultural information these sites contain. Moreover, sea level rise can make it difficult for
archaeologists and researchers to access shipwreck sites. As water levels increase, locating and
exploring these sites, particularly submerged ones, can become more challenging. This can limit the
ability of researchers to conduct surveys and excavations and potentially delay or prevent the recovery
of artefacts and other historical evidence.
Overall, sea level rise significantly threatens shipwrecks and their associated cultural heritage.
Archaeologists and policymakers must work together to mitigate the impact of rising sea levels and
ensure the preservation of these valuable historical resources for future generations.
Future Projection of SLR and its Influence on Coastal and Underwater Cultural Heritages
In 2100 CE the IPCC sea level projection, with a scenario of high gas emission (SSP3-7.0) is that it
will increase by ~0.68 m for Mandeh and Baten Bay, while in Tidore, the sea level is projected to
increase by ~0.70 m (Figure 3). From these values, we simulated a model predicting the changes in
water properties in the three sampled archaeological sites that have been validated using fieldmeasured data provided by RICRV. Overall, the increase in sea level contributes to higher
sedimentation (Figure 4).

Figure 3. Sea level projection estimated by IPCC AR6 in 2100 CE in Indonesia: Mandeh Bay (a); Banten Bay (b); and
Tidore Island (c)

In Banten Bay, the strongest current magnitude was approximately 0.66 m/s observed in August, and
the lowest was in April with a magnitude of 0.54 m/s. Under the sea level rise scenario, the current

6

�magnitude will increase by about 33.52 per cent ranging from 0.08 to 0.096 m/s (Figure 4a). A weaker
current profile was identified in Mandeh Bay, ranging from 0.042 to 0.059 m/s. With the estimated sea
level rise of 0.68 m in 2100, the current magnitude will increase by approximately 34.78 per cent,
reaching 0.079 m/s (Figure 4b). In Tidore, the current profile ranged from 0.047 to 0.062 m/s, and the
value will increase by about 35.73per cent in 2100 CE, ranging from 0.079 to 0.09 m/s (Figure 4c).
Similar to the current features, sediment transport will also increase under sea level rise.
Percentagewise, the increase in sediment transport in Banten Bay, Mandeh Bay and Tidore was
approximately 34.86, 18.54, and 37.07 per cent, respectively. Generally, the highest sediment transport
was observed during the southwest monsoon and vice versa for the northeast monsoon (Figure 4d-f).

Figure 4. Monthly average of current magnitude in the surrounding site; Banten Bay (a); Mandeh Bay (b); Tidore
Island (c); and the estimated sediment transport sediment in the Banten Bay (d); Mandeh Bay (e); and Tidore Island
(f). The negative values denote the left-ward transport, and the positive values denote the right-ward transport.

Overall, the sea level rise potentially changes the water properties of the three sampled archaeological
sites. The increase in current velocity relates to the potency of coastal erosion and sedimentation.
Since sedimentation is the most crucial issue in these sites, the sea level rise will significantly impact
the archaeological remains by inducing higher suspended sediment and sedimentation. In some cases,
aside from making the remains more submerged, the shifting in the position of the shipwreck and
artefacts due to the robust current profile is possible. Therefore, regular monitoring is required to
protect the remains from the impact of sea level rise. However, archaeological excavation is also
recommended if possible.

ACKNOWLEDGMENTS
We would like to thank Research Institute for Coastal Resources and Vulnerability (RICRV) for the basis data provided.
Gratitude is also given to University Colorado Boulder for providing the sea level data and to those who have helped in the
completion of this study.

7

�BIBLIOGRAPHY
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and future threatsâ€. The Journal of Island and Coastal Archaeology 18, no. 2 (2023): 251-283.
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(2019): 55â€“71.
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Heriati, A. &amp; Adhityatama, S. â€œStudy of the Historic Shipwreck Sites Area Development for Marine Ecotourism in
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Shaw, L. â€œGuardians of Sunda Strait: remembering HMAS Perth and USS Houston.â€ Signals, no.119(2017): 2-7.
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8

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                <text>Wisha, Ulung J., Wisnu A. Gemilang, and Nia N. H. Ridwan. 2023. “Impact Assessment of Current and Future Sea-Level Rises on Coastal and Underwater Archaeological Sites in Indonesia.” Edited by Jennifer Craig, Jay Mok, T. Kurt Knoerl, and Elena Perez-Alvaro. In Proceedings of Fifth Asia Pacific Regional Conference on Underwater Cultural Heritage: Gwangju, The Republic of Korea, November 13-18 2023. The Museum of Underwater Archaeology. URL: https://apconf.omeka.net/exhibits/show/apconfproceedings/item/1907 </text>
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                    <text>The Duty to Protect Our Ocean Heritage from Potentially Polluting Wrecks
Ole Varmer (The Ocean Foundation)
Mariano Aznar (ICUCH, University Jaume I)
ABSTRACT
The importance of conserving our ocean heritage is well recognised and was codified in international law in the
1972 World Heritage Convention. The 1982 Law of the Sea Convention (LOSC) recognises a duty to protect
‘objects of an archaeological or historical nature’ but is devoid of details for implementation. The 2001
UNESCO Convention on the Protection of Underwater Cultural Heritage provides sorely needed details in the
various maritime zones in accordance with the LOSC and well accepted international standards of archaeology
and conservation. This paper summarises the relevant international law to help address the major threats to UCH
from Potentially Polluting Wrecks (PPWs).
Keywords: Underwater Cultural Heritage; Natural Heritage, Law of the Sea; 2001 Convention
List of abbreviations
Continental Shelf (CS)
Exclusive Economic Zone (EEZ)
International Union for the Conservation of Nature (IUCN)
Law of the Sea Convention (LOSC)
1979 Convention on Long-Range Transboundary Air Pollution (LRTAP)
Potentially Polluting Wrecks (PPWs)
Underwater Cultural Heritage (UCH)
United Nations Educational, Scientific and Cultural Organization (UNESCO)

INTRODUCTION
The topic of this paper fits best within Session 13 Major Threats to Underwater Cultural Heritage
(UCH) because it summarises the relevant international law and provides the context and legal
foundation for the development of measures to address the threats and conserve our ocean heritage as
discussed in other papers in this session. The paper starts with an overview of the international law
relevant to these threats and the measures to address them. This will also provide examples addressing
the major threats to UCH, the resources available to tackle these threats under the law, the framework
or approach to address these threats, and the result that we seek: a moratorium on activities that are
major threats to UCH until the ocean science has been conducted to ensure that these activities are
truly sustainable developments. In the context of the UN Decade of Ocean Science for Sustainable
Development that means if it is not safe for life, property, the marine environment, and UCH, then it
is not sustainable development.
The case studies under consideration in this session include major threats to UCH from Potentially
Polluting Wrecks (PPWs), fishing, mining, energy development, climate change and the related threat
from sea level rise. This paper looks at the legal duty to protect our ocean heritage from the threats
presented by PPWs, however, the duty is relevant to all the threats particularly those involving
activities that directly affect UCH, such as salvage, and those that may indirectly affect UCH, such as
fishing and mining.

CASE STUDIES
The case under consideration is the law related to the threat to our ocean heritage (natural and
cultural) from PPWs. According to the International Union for the Conservation of Nature (IUCN),
‘marine pollution from sunken vessels is predicted to reach its highest level this decade, with over
8,500 shipwrecks at risk of leaking approximately 6 billion gallons of oil’ (IUCN 2023). The vast
1

�majority of PPWs are from World War I and II (WWI and WWII). They contain hazardous materials
including chemicals, unexploded ordinances, and an estimated six billion gallons of heavy fuel oil.
‘This is 545 times more oil than the Exxon Valdez leak in 1989 and 30 times that of the Deepwater
Horizon spill in 2010, both of which had severe and long-lasting environmental consequences’ (IUCN
2023).
There are several legal questions that may arise under international and domestic law in addressing
the threats presented by a sunken vessel that is a potential threat to the marine environment. This
paper briefly summarises those international laws and discusses the legal issues and context that are
of particular interest in not only addressing the threats to the marine environment but also in the
preservation and conservation of PPWs which may be objects of an archaeological or historical nature
under the 1982 UN Law of the Sea Convention (LOSC) if not UCH under the 2001 UNESCO
Convention on the Protection of Underwater Cultural Heritage (henceforth 2001 Convention). As
many PPWs are sunken state craft, there are also issues of ownership, sovereign immunity, and the
fact that many sites are also wartime graves. This paper is not intended to be a comprehensive
analysis and a case-by-case basis analysis will be necessary and will often include the flag State,
coastal State, and other States with an interest in the ship, cargo, or personnel.

RESOURCES
The resources needed to address the threats from PPWs are surveys to identify their location,
document heritage information and environmental assessments on how to sustainably develop and
manage to conserve the heritage and livelihood dependent upon a healthy ocean. There are some legal
resources relevant to address the threats from PPWs including the 1982 LOSC, and the duties to
protect the marine environment and objects of an archaeological and historical nature. This will be
followed by discussion of the 2001 Convention that was developed to address the very brief and
vague LOSC articles 149 and 303 but in a manner consistent with the balance of interests of coastal
States and flag States. The evolution of the international duty to protect and conserve our ocean
heritage can be traced to the Stockholm Declaration and the 1972 World Heritage Convention—
where the wisdom of integrating the conservation of both natural and cultural heritage became
international law.
The international law to protect marine life can be traced to agreements trying to address the over
exploitation that arose from technological advances in the industrial revolution as discussed by
Charlotte Jarvis’ paper on bottom trawling in the same session and volume as this paper. The
environmental movement that followed WWII sparked the development of laws to address the threats
to our natural and cultural heritage for present and future generations. For example, the 1946
Convention for the Regulation of Whaling to conserve these overexploited creatures and the founding
of the International Union for the Conservation of Nature and Natural Resources (IUCN) in 1948.
1972 Stockholm Declaration
The United Nations Conference on the Human Environment met in Stockholm, Sweden and resulted
in the Stockholm Declaration. It codified the customary practice of nations in balancing of
development and protecting the environment so that it may be inherited by future generations in a
healthy state (heritage). It contains principles that document and delineate the duty to protect and to
cooperate for that purpose under customary international law, including that we bear ‘a solemn
responsibility to protect and improve the environment for present and future generations’ (Principle
1). A ‘special responsibility to safeguard and wisely manage the heritage of wildlife and its habitat,
which are now gravely imperilled by a combination of adverse factors. Nature conservation, including
wildlife, must therefore receive importance in planning for economic development’ (Principle 4).
‘States should adopt an integrated and coordinated approach to their development planning to ensure
that development is compatible with the need to protect and improve environment for the benefit of
their population (Principle 13)’. ‘In exercising the sovereign right to exploit their own resources, there
2

�is the responsibility to ensure that activities within their jurisdiction or control do not cause damage to
the environment of other States or of areas beyond the limits of national jurisdiction’ (Principle 21).
While there is no express reference to cultural heritage, the duty to protect the environment should be
interpreted to include cultural heritage as well as natural. This view is also supported using ‘integrated
and coordinated approach’ to development planning in Principle 4. This is reinforced by the
integration of natural and cultural resources to be conserved in UNESCO’s 1972 World Heritage
Convention.
1972 World Heritage Convention: Integrating the conservation of natural and cultural heritage
While the focus in Stockholm was on the environment and sustainable development; at UNESCO
headquarters in Paris the focus was an agreement to protect natural and cultural heritage. With 193
State parties, it remains one of the most widely accepted treaties. While it started with recognising
terrestrial sites and traditional cultural structures, it has evolved to recognise heritage in the marine
environment beyond the territorial sea into the EEZ/CS. For example, the Papahānaumokuākea
Marine National Monument in Hawai’i was inscribed on the World Heritage ‘mixed list’ for its
‘outstanding universal value’ as both a natural and cultural heritage site. Of note, is that some of the
natural heritage, like coral, were also recognised as cultural heritage of the native Hawaiian people
and some of their practices were recognised as intangible cultural heritage. This move seaward
continues as there are now calls for recognition of heritage in the high seas (UNESCO 2016),
including wreck sites such as Titanic. The challenges involve ensuring consistency with the LOSC,
more specifically, implementing the duty to protect and cooperate through reliance of flag State
jurisdiction, and Port State jurisdiction for enforcement of activities directed at cultural heritage under
the high seas. The legal context for all activities in the ocean starts with the international legal
framework of the LOSC including potentially polluting wrecks.
The 1982 Law of the Sea Convention (the legal framework for activities at sea)
The LOSC is well recognised as a codification and progressive development of the law of the sea.
It provides the legal framework for the use and protection of the marine environment, including
natural and cultural heritage resources. It balances the flag State rights of navigation, fishing and other
uses with the coastal State jurisdiction and authority in various maritime zones including a 12 nm
territorial sea, a 24 nm contiguous zone, a 200 nm EEZ, the continental shelf, the high seas and Area
beyond national jurisdiction.
Under Article 303(1), applicable to archaeological and historical objects found in any part of the sea,
recalls the general obligation whereby ‘States have the duty to protect objects of an archaeological
and historical nature found at sea and shall cooperate for this purpose.’ Specifically, regarding the
Area, under Article 149, ‘[a]ll objects of an archaeological and historical nature found in the Area
shall be preserved or disposed of for the benefit of mankind, particular regard being paid to the
preferential rights of the State or country of origin, or the State of cultural origin, or the State of
historical and archaeological origin.’ While it is not always clear which nations have preferential
rights, it would include the flag States of the sunken ship and nation from which the cargo came.
While it is expressly limited to the Area, the consideration of preferential rights provides some
guidance for cooperation on UCH found in other maritime zones, particularly the portion of the
continental shelf beyond the 24-mile limit of coastal State jurisdiction under Article 303(2). The
LOSC is now recognised as customary international law, and it may therefore be argued that its duty
to cooperate to protect objects of an archaeological or historical nature should also be recognised as
customary international law, as evidence by the practice of nations including non-parties like the
USA. While there is little guidance or detail on how to fulfil the duty to protect under this Article,
other Articles and laws are helpful in guiding parties as they fulfil the duty to protect including the
duty to protect natural heritage and the marine environment to which it is inextricably linked.
Under Articles 192 and 194 there is the general obligation of States to protect and preserve the marine
environment. This general principle may be applied both to wrecks that become artificial reefs,
3

�deserving protection as part of the marine environment, and to wrecks that are potentially (or actually)
endangering this environment because of their deteriorating structure or polluting cargo still aboard.
Specifically, Art. 194(3)(b) deals with the measures to be taken by States, including those designed to
fully minimise ‘pollution from vessels, in particular measures for preventing accidents and dealing
with emergencies, ensuring the safety of operations at sea, preventing intentional and unintentional
discharges, and regulating the design, construction, equipment, operation, and manning of vessels’
(Aznar 2015). Note how this duty to protect the marine environment is like the very general duty to
protect cultural heritage under Articles 303 and 149. Thus, the obligation under Part XII may provide
guidance on how to implement the duties under Articles 303 and 149, as the 2001 Convention does.
The LOSC does not explicitly address the issue of the protection of maritime graves in international
waters (Aznar 2015).
The 1992 Rio Declaration
Ten years after the LOSC and twenty years after the Stockholm conference, the United Nations
convened another Conference on Environment and Development in Rio de Janeiro, Brazil. This 1992
Rio Conference resulted in the Rio Declaration on Environment and Development, including Agenda
21, which provides that there is a duty to protect the marine environment and to cooperate for that
purpose—expressly flowing from the 1982 LOSC. Chapter 17.1 highlights how the LOSC ‘sets forth
rights and obligations of States and provides the international basis upon which to pursue the
protection and sustainable development of the marine and coastal environment and its resources.’ It
then identifies approaches to implement this duty and specifically calls for integrated management
and a precautionary approach in the sustainable development and protection of the marine
environment.
Precautionary approach
A precautionary approach to addressing threats to the environment can be traced back to domestic
German law in the 1970s. It was first used in an international agreement in the 1980 regarding the
Conservation of Antarctic Marine Living Resources. However, it was the Rio Declaration that is
received wide international recognition.
‘In order to protect the environment, the precautionary approach shall be widely
applied by States according to their capabilities. Where there are threats of serious or
irreversible damage, lack of full scientific certainty shall be not used as a reason for
postponing cost-effective measures to prevent environmental degradation’
Principle 15, Rio Declaration.
It has been incorporated into several international treaties including: 1992 Convention on Biological
Diversity, the 1992 United Nations Framework Convention on Climate Change, the 1995 WTO
Agreement on the Application of Sanitary and Phytosanitary Measures, the 1995 Fish Stocks
Agreement, the 1996 Protocol to the 1972 London Convention on the Dumping of Wastes and Other
Matter, the 1997 Protocol to the International Convention for the Prevention of Pollution From Ships,
the 1998 Agreement on the International Dolphin Conservation Program, the 1998 Long-Range
Transboundary Air Pollution (LRTAP) Persistent Organic Pollutants Protocol, the 1998 LRTAP
Heavy Metals Protocol, the 1999 LRTAP Acidification Protocol, the 2000 Convention on the
Conservation and Management of Highly Migratory Fish Stocks in the Western and Central Pacific
Ocean, the 2001 International Convention on the Control of Harmful Anti-Fouling Systems, and the
2001 Agreement on the Conservation of Albatrosses. It should be applied to PPWs particularly those
that are historic or UCH. The precautionary approach is particularly appropriate in the management of
PPWs because they are ticking time bombs and if historic, are also time capsules of our heritage. If
so, the 2001 Convention is particularly relevant.

4

�2001 Convention
To address the threat of looting and unwanted salvage, and the details sorely needed to implement the
LOSC, UNESCO convened a meeting to negotiate an agreement to protect UCH. Consensus was
reached quickly on a clear definition of UCH, and a ban against the law of finds and salvage. There
was also consensus on four principles: 1) to protect and preserve UCH; 2) the preferred first policy
option of in situ preservation, and adherence to the Annex Rules when a party decides not to preserve
in situ and recovery is in the public interest ; 3) no ‘commercial exploitation’ of UCH; and 4)
cooperation among States to protect UCH, particularly for training, education, and outreach.
Consensus was not reached on the regime for cooperation in the protection of UCH in the EEZ/CS as
some delegations had concerns about ‘creeping jurisdiction’ of coastal States and the treatment of
foreign sunken craft within the territorial sea (Dromgoole 2013). That many PPWs are historic
heritage resources calls for a precautionary approach. The fact that most PPWs are wrecks from the
World Wars and are thus maritime graves also calls for a precautionary approach through a temporary
moratorium against salvage (Varmer 1999). ‘This precaution is even stronger when there are human
remains in the sunken wreck, which, according to Article 2(9) of the 2001 Convention, must be given
proper respect’ (Aznar 2018).

FRAMEWORK
The legal duties to protect our ocean heritage under international law, and the goals of the UN Decade
of Ocean Science for Sustainable Development, show that the best way to address the threats from
PPWs is a precautionary approach including a moratorium against activities that may trigger these
ticking time bombs until the proper science and assessments are done to make sure such activities are
truly sustainable. A temporary moratorium could be, and limited to, activities directed at PPWs such
as salvage and certain indirect activities that could result in irreparable harm and destruction to UCH
and marine life such as bottom trawling, or Deep Seabed Mining until after surveys have been
conducted to ensure that no PPWs are in planned exploitation areas, proper Environmental Impact
Assessments have been conducted, and significant natural and cultural heritage are Marine Protected
Areas.

RESULTS
The IUCN has called for the development of international standards to determine the best practices
for addressing this threat including the classification of PPWs according to potential environmental,
social, and economic impacts (IUCN 2023). If this precautionary approach is respected, and the
standards are developed and followed, the results would be a healthier ocean which is so important for
those lives and livelihoods dependent upon a healthy ocean. The duties for protection would be
addressed, and the economic development would clearly be sustainable.

5

�Acknowledgements Thank you to Mark Spalding, The Ocean Foundation, and Louise Sanger, Lloyd’s Register Foundation
Heritage, and Education Centre, for their support of this paper and the Threats to Our Ocean Heritage project. Thank you to,
Charlotte Jarvis, Michael Brennan, Jim Delgado, and Ben Ferrari for their help developing the ideas that are reflected here.

Bibliography
(Aznar 2015) Aznar, M. J.” Sensitive Wrecks, Protecting Them and Protecting from Them.” Revue Belge de Droit
International 1-2. Bruxelles: Éditions Bruyant, 2015.
(Aznar 2018) Aznar, Mariano, “In Situ Preservation of Underwater Cultural Heritage as an International Legal Principle.”
Journal of Maritime Archaeology 13, no. 1 (2018): 67-81. DOI: 10.1007/s11457-018-9192-4, Available at SSRN:
https://ssrn.com/abstract=3164159
(2001 Convention) UNESCO Convention on the Protection of Underwater Cultural Heritage, Adopted 2 November 2001,
entered into force 2 January 2009 (2562 UNTS 1)
(Dromgoole 2013) Dromgoole, S. “Reflections on the Position of the Major Maritime Powers with Respect to the UNESCO
Convention on the Protection of the Underwater Cultural Heritage 2001.”, Marine Policy 38, (2013): 116-123.
(IUCN2023) IUCN Issues Brief, Marine Po;;utopm From Sunken Vessels (2023) see https://www.iucn.org/resources/issuesbrief/marine-pollution-sunken-vessels#:~:text=There%20are%20an%20estimated%203,as%20'potentially
%20polluting%20wrecks'. see also https://majorprojects.org.au/ppw/
(IUCN 2020) IUCN Resolution on Sunken Vessels WCC-2020-Res-026-EN
International cooperation on marine pollution from sunken vessels
(LOSC) Law of the Sea Convention, Adopted 10 December 1982, entered into force 16 November 1994 (1833 UNTS 397)
(NOAA 2013) National Oceanic and Atmospheric Administration. 2013. Risk Assessment for Potentially Polluting
Wrecks in U.S. Waters.
Stockholm Declaration of the United Nations Conference on the Human Environment, Report of the United Nations
Conference on the Human Environment, U.N. Doc. A/ CONF.48/14/Rev.1 (1973), p. 3; U.N. Doc. A/CONF.48/14 (1972),
pp. 2-65. and Corr. 1 available at http://www.un-documents.net/unchedec.htm
(UNESCO 2016) Freestone, D. Laffoley, D., Douvere, F. and Badman, T., World Heritage in the High Seas: An Idea
Whose Time Has Come, See also World Heritage Centre World Heritage Marine Program at:
http://whc.unesco.org/en/marine-programme.Hampi+World+Heritage+Site+KarnatakaHampi
(Varmer 1999) Varmer, Ole. “The Case Against the ‘Salvage’ of the Cultural Heritage.” Journal of Maritime Law, and
Commerce 30, no. 2 (1999): 279-302.

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                <text>The Duty to Protect Our Ocean Heritage from Potentially Polluting Wrecks </text>
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                <text>Varmer, Ole. 2023. “The Duty to Protect Our Ocean Heritage from Potentially Polluting Wrecks (PPWs).” Edited by Jennifer Craig, Jay Mok, T. Kurt Knoerl, and Elena Perez-Alvaro. In Proceedings of Fifth Asia Pacific Regional Conference on Underwater Cultural Heritage: Gwangju, The Republic of Korea, November 13-18 2023. The Museum of Underwater Archaeology. URL: https://apconf.omeka.net/exhibits/show/apconfproceedings/item/1906 </text>
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                    <text>Decommissioning Offshore Structures:
A Threat or an Underwater Cultural Heritage Opportunity

Dr Elena Perez-Alvaro¹ and Dr James Delgado²
¹Professor Master in Cultural and Natural Heritage UNIR, España
ICOMOS International Committee on the Underwater Cultural Heritage
²Senior Vice President SEARCH, Inc., United States of America
ABSTRACT
This article focuses on the possibility of recycling, removing, and leaving on-site offshore structures, such as
wind turbines and oil platforms. It also looks at the environmental consequences of these structures recycling
mostly carried out in southern Asian countries with limited work and environmental regulations. The
construction of some of these offshore structures does not provide ‘end-of-life’ considerations, so, if left in situ
they will become underwater cultural heritage in the future. This article will look at the benefits of a
collaboration between offshore and maritime industries and underwater cultural heritage practitioners. It will
also highlight the importance of including as underwater cultural heritage less “attractive” sites which may not
be as popular, but can still be of importance. If forgotten, we may lose a significant part of humanity’s history.

List of tables
Table 1. SWOT analysis: Strengths/Opportunities/Weaknesses/Threats (created by authors).

INTRODUCTION
The topic of this paper fits best within the session on Major Threats to Underwater Cultural Heritage
at the Fifth Asia-Pacific Regional Conference on Underwater Cultural Heritage because the
actions that are being taken now in relation to the decommissioning of offshore structures will
have a potential impact on the future scope of and management of underwater cultural heritage.
The decommissioning of offshore structures is still in a legal vacuum, and, if left untouched on
the ocean, they will become underwater cultural heritage in the future. New offshore energy
and developments in the oceans are a growing but still completely unexplored industry. Oil and
gas platforms have been developed for longer, but it is in the current and future decades when they
will stop working. A new issue for ocean users is that offshore oil, gas reserves and wind farms
trigger one of the largest decommissioning operations undertaken in the marine environment (Ross
1978). When offshore structures reach the end of their productive life, they are
decommissioned and then dismantled, recycled, or disposed of. However, construction of these
elements does not provide ‘end of life’ considerations. Over the next several decades, more than
7,500 oil and gas platforms in the waters of 53 countries will become obsolete (Fowler et al.
2018), including platforms that sit on the seabed, floating production systems, and other offshore
storage and loading units (Simpson 1998).
Their decommissioning will cause many issues because, due to their size and weight, the removal of
platforms is a complex engineering process that will require some of the heaviest lifting
operations ever attempted at sea. This dismantling, recycling, or preservation in situ of those
platforms will have an impact on the underwater cultural heritage because, for the first time,
underwater cultural heritage experts can anticipate what is going to become – or not become –
submerged heritage in the future. In addition, the removal of these structures of which many have
become habitats may have a detrimental impact on the local natural environment.

1

�Underwater cultural heritage can and does include sites or resources that reflect threats to the
environment. This takes place on land with sites associated with extractive mining, as well as
industrial sites where past processing or manufacturing have left a legacy that is both archaeological
and detrimental to the ecosystem and/or human health. However, this negative aspect does not
diminish the potential significance of the site(s) nor their potential to yield pertinent archaeological
evidence. For example, the oil boom in the United States started with the commercial success of the
Drake Well drilled in 1859 in Pennsylvania along the banks of Oil Creek, it was designated a National
Historic Landmark in 1966 and subsequently listed on the National Register of Historic Places (Drake
Well Museum, n.d.). The query here is - if we should preserve sites that only speak to what we
see as positive aspects, or if we should embrace the preservation and study of sites that speak to
all aspects of the human experience and the consequences of human activities? This paper argues
that underwater cultural heritage practitioners and the new energy industry can mutually benefit from
sharing knowledge and working together.
Underwater cultural heritage, like that on land, reflects all aspects of human behaviour. A Panamanian
historical and archaeological site, the American-built submersible Sub Marine Explorer, represents
mid-nineteenth century over-fishing and despoliation of Panama’s oyster beds (Delgado 2012). There
is a strong potential for extensive archaeological remains from the centuries-long Middle Passage of
the transatlantic African slave trade (Turner et al. 2020) as well as individual shipwrecks (Delgado et
al. 2022). Other pertinent examples include historic and archaeological sites related to gold dredging,
sites associated with the global wars of the twentieth century, and perhaps the most pertinent, the
World Heritage Site at Bikini Atoll, which include nuclear test structures, sunken ships, craters, and
radioactive isotopes (Brown 2013).

CASE STUDY
According to Offshore Wind, there are 162 offshore wind arms at the moment. There are also 2,011
offshore oil rigs. In recent years, the first few offshore wind projects are now dismantled (Smith and
Lamont 2017), but the decommissioning projects are small relative to current installations. In fact,
most of these decommissioning projects were demonstration or research projects. However, according
to IHS Markit (2016), 2,000 offshore projects will be decommissioned between 2021 and 2014. Due
to the novelty of the situation, the impacts of decommissioning practices on structures related to oil
and gas development from the oceans are unknown.
This article will look at how the decommissioning of these offshore structures will have an impact on
how underwater cultural heritage is currently understood. The resources for this work include the
2001 UNESCO Convention on the Protection of the Underwater Cultural Heritage (hereinafter 2001
UNESCO Convention) and practice of nations.

RESOURCES
The 2001 UNESCO Convention defines underwater cultural heritage as
[…] all traces of human existence having a cultural, historical, or archaeological
character which have been partially or totally under water, periodically or continuously,
for at least 100 years.
It should be noted that pipelines and cables placed on the seabed are explicitly excluded from the
definition of underwater cultural heritage. In addition, “[i]nstallations other than pipelines and cables,
placed on the seabed and still in use, shall not be considered as underwater cultural heritage.”
However, when those installations, such as platforms, are no longer in use then they may become
2

�underwater cultural heritage if they are also of an archaeological or historical interest and have been
under water for more than 100 years.
However, not all countries have ratified the 2001 UNESCO Convention, and not all national
legislations require a time limit (as in the case of 100 years under water) for an offshore structure to
become of importance. Some countries, such as France, Croatia, and Estonia, do not have a temporal
limit in their definition of underwater cultural heritage, and submerged remains are protected based on
historical interest. In Greece, ‘cultural’ objects are protected 50 years after their sinking. Furthermore,
it is a wise practice to assess the potential of sites that are more recent as being significant and worthy
of recognition, study, and preservation. In the United States of America (USA), for instance, like
Greece the 50-year rule is applied, exceptions are made for events that occurred and which have
attained recognition of significance; World War II sites were granted this designation by the USA in
the 1980s, less than fifty years after the start and end of that war.
It is beyond the scope of this paper to get entangled with the definition of underwater cultural
heritage, which has been broadly debated in the literature (see bibliography). However, this
demonstrates that offshore structures that function for some years now can become underwater
cultural heritage according to much legislation, and in 100 years, they will be under the umbrella of
the 2001 UNESCO Convention. In fact, existing platforms and wind turbines have a constructionoperation-decommission cycle of 20 to 30 years (Smyth et al. 2015). However, the regulation of the
disposal of offshore installations is not a clear nor regulated legal process (Forte 1998), so many
decisions are on a case-by-case basis. Until now, none of these decisions have taken into
consideration the possibility for these structures to become underwater cultural heritage for the future
benefit of humankind.
There are a number of sites that are highly significant because they represent industries or activities
that reflect environmental despoilation and damage such as whaling ships, for example, which can be
found as floating ships, shipwrecks, and shore-based sites. Such is the case with South Georgia Island
(USA), the British Columbia (Canada) coast, and the various sites in Australia and in Chile’s portion
of the Estrecho de Magallanes. There are also early sites associated with the extractive petroleum
industry listed in the United States National Register of Historic Places, the Canadian National
Historic Sites, and deemed significant in Saudi Arabia and other countries (Symons et al. 2014).

FRAMEWORK
There are three main approaches when decommissioning offshore structures:
1. Dismantling and recycling: Globally, over 40 platforms each year reach the end of their useful
life, which equates to around 40,000 tonnes of potentially recyclable materials (Choi et al.
2016). However, the most profitable shipbreaking methods are also the most dangerous to
both worker safety and the environment (Choi et al. 2016), since many of the structures have
been constructed with materials that are now known to be both toxic and highly pollutant. The
materials that are recycled usually employ some dangerous methods. For instance beaching,
which are carried out in southern Asian countries with a lack of enforced environmental
legislation and welfare working regulations. The practice of beaching these platforms means
to ground them in order for them to be scrapped. Although in some countries of the world
there are strict regulations for platforms to be dismantled and recycled, in other countries,
such as Bangladesh, India and Pakistan, there are facilities where the safety and well-being of
the workers and the environmental impacts are ignored (Choi et al. 2016). In 2022, at least 10
workers lost their lives when breaking apart platforms on a particular coast of Bangladesh
(NGO Shipwrecking Platform, n.d.). Some of the accidents were on platforms owned by wellknown companies. There are fatal consequences of recycling these structures: necessary
diving activities that can result in injury or fatalities or helicopter trips necessary for the
3

�workforce and supervisory staff. It is necessary to take into consideration that in shallower
waters, platforms typically weigh around 5,000 tonnes, although some deep-water steel
platforms weigh over 200,000 tonnes when in-service and around 40,000 tonnes when
stripped to its skeletal frame. The scrap resulting from this recycling process is often
auctioned off to scrap dealers or sold to cash buyers (NGO Shipwreck Platform, n.d.).
2. Leaving them totally intact: There are two main reasons to leave the platforms untouched
after decommissioned or sinking them to the bottom of the oceans. The first reason is
economical. It has been estimated that the global cost of removal of platforms is US$210
billion (IHS Markit 2016). However, there is also an environmental reason. After some years,
underwater remains become, in most cases, artificial reefs, housing thousands of fish species.
The disturbance of these ecosystems and the impacts of removing these can have a negative
impact on the marine environment. Some researchers (Fowler 2018) have looked at the
environmental impacts of the decommissioning practices and the removal of offshore wind
turbines. The authors consider that complete removal of the structures have a negative impact
on biodiversity, provision of reef habitat and protection from bottom trawling because of the
reopening of areas of fishing. In addition, as explained, there are some chemical-contaminated
sections of the structures, and bringing them to shore can also be a controversial issue. In fact,
dealing with hazards are one of the main issues that arises when offshore structures are left in
the oceans, including the release of toxic, flammable, or explosive materials, or failure
consequences that can result in environmental disasters (Baker 1998). The reality is that, in
100 years, the platform will become underwater cultural heritage according to the 2001
UNESCO Convention.
3. For some authors, partial removal options are better options, which still means these
structures will become underwater cultural heritage in the future and be under the umbrella of
the 2001 UNESCO Convention. It is argued that just some of the most toxic parts of the
structures could be dismantled or those parts that can imply a navigation hazard. As discuss
below, over 500 energy platforms previously installed on the USA Outer Continental Shelf
have been partially removed and made into artificial reefs in the Gulf of Mexico in
coordination with USA coastal states and other stakeholders including fisherman.
According to Jordan and Bennie (1998), one of the most important controversies over the
decommissioning of offshore structures is the relationship between the public and private interest. In
the case of the Brent Spar, a North Sea oil storage operated by Shell UK, the company shared that
deep sea sinking was the safest option for disposal from an environmental and safety point of view.
However, Greenpeace occupied the platform for more than three weeks and provoked a media scandal
that damaged Shell’s reputation, arguing that sinking the platform was just to cut costs and not for
scientific reasons. Finally, Shell decided to reuse much of the main structure of the platform for a new
harbour facility (Jordan and Bennie 1998).
The legislation at the moment requires complete removal of offshore installations, but it allows
exceptions that fulfil technical criteria (Forte 1998). Although the main objective of this paper is not
to evaluate the best option for the decommissioning of offshore structures, it is pertinent to value the
impact that leaving these structures under water would have to the construction of a new kind of
underwater cultural heritage. Table 1 shows a SWOT analysis in order to understand the strengths,
opportunities, weaknesses, and threats of leaving these structures as underwater cultural heritage.

4

�Table 1. SWOT analysis: Strengths/Opportunities/Weaknesses/Threats (created by authors).

STRENGTHS
Cultural heritage for the future of mankind
Low economical cost
Avoid occupational safety of dismantling
Avoid noise of dismantling

OPPORTUNITIES
Environmental aspects such as fish reefs
Learn from the future
Public and private initiatives such as diving
Future uses

WEAKNESSES
Non-natural bodies in the oceans
Uncertainty in public acceptance
Changed visual landscape impact
Possible overlap with other ocean actors

THREATS
How many? Some? All of them?
Maintenance issues
Oil and gas spills
Safety navigation hazards

For instance, the Gulf of Mexico is an example of possible preservation as a maritime landscape
whose 20th century underwater cultural heritage includes not only oil tankers wrecks, but the evolving
landscape of oil wells that are progressively shifted from shallow to deep water, as well as the
technology and changes in offshore oil well rigs. Such a maritime landscape would also include the
extensive deep-sea infrastructure of not only wells but pipelines, and the onshore infrastructure such
as the Houston Ship Channel and refineries (BOEM 2021). Ironically, perhaps, the provision under
federal laws in the USA to assess the potential impacts to cultural resources has led to an extensive
and well documented range of underwater cultural heritage in the Gulf as a result of compliance with
those laws and regulations.

RESULTS
Offshore structures are products of modern civilizations; additionally, harbours and caravels were
developments of past civilizations. Today, we aim to preserve the tangible remains of those past
developments, and, as we preserve lighthouses and Viking longships, future civilizations may want to
protect offshore structures as proof of progress and blossom of energy construction in the 21st century.
The research approach of this paper is focused on calling for a collaborative partnership between the
new energy industry and underwater cultural heritage experts. It is one of the first opportunities in
history where underwater cultural heritage practitioners can foresee what is going to become
underwater cultural heritage in the future. It is a unique opportunity to decide how important this
heritage will become for humanity and to establish a dialogue with these companies on aspects such
as preservation of metal under water, oil spills control or the dichotomy between cultural and natural
tangible remains in the oceans, all of which underwater cultural heritage practitioners have experience
with (Perez-Alvaro 2019).
Popularity of beautiful underwater cultural heritage sites does not always equate significance, and
some of the offshore infrastructures addressed in this article may also need to be considered,
recognized, designated as heritage, and preserved. It is also important to highlight the benefits of the
construction and dismantling of these offshore structures to underwater cultural heritage because prior
to any offshore construction, research must reveal that no underwater archaeological sites are located
in the planned location and new archaeological sites can be discovered. However, there is still a lot to
do regarding policies and procedures in offshore energy extraction. The archaeological education for

5

�energy farm construction companies and workers is essential to respecting underwater cultural
heritage.
Clarification of best practices in the development sectors of the oceans will need to emerge in the next
years, and underwater cultural heritage managers should be part of the conversations not only for the
opportunity to share their knowledge on underwater remains but also to decide which structures can
become underwater cultural heritage due to any particular characteristics that can benefit both the
knowledge of humankind and the environment. This will also provide a new way to deal with
heritage: it will offer the opportunity to decide in the present what we want to remember about this
century that is worth preserving for the future.

Acknowledgements
This research has been supported by the Honor Frost Foundation through the British Academy/Leverhulme Research Grants
Scheme. The authors would like to thank Ole Varmer and Chris Underwood for their valuable comments on this article.

6

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                <text>Perez-Alvaro, Elena  and James Delgado. 2023. “Decommissioning Offshore Structures: A Threat or an Underwater Cultural Heritage Opportunity.” Edited by Jennifer Craig, Jay Mok, T. Kurt Knoerl and Ole Varmer. In Proceedings of Fifth Asia Pacific Regional Conference on Underwater Cultural Heritage: Gwangju, The Republic of Korea, November 13-18 2023. The Museum of Underwater Archaeology. URL: https://apconf.omeka.net/exhibits/show/apconfproceedings/item/1905</text>
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                    <text>Bottom Trawling and the Damage to Underwater Cultural Heritage: An Overview of
the Destruction and Possible Steps Forward
Charlotte Jarvis (The Ocean Foundation, Threats to Our Ocean Heritage Project Leader)
ABSTRACT
Trawling has long been regarded as a damaging practice and marine ecologists have lobbied for restrictions. The
damage to Underwater Cultural Heritage (UCH), however, has received less attention, though it is just as
consequential. This paper looks at UCH damage case studies and the impacts of heritage loss and then suggests
steps forward. The case studies in the paper will include the damage to UCH across the ocean and in the
Mediterranean and Black seas. Shipwrecks are as much part of the marine landscape, and thus of importance to
ecologists, as they are to the cultural, historical landscape. Yet nothing has been done to seriously limit trawling
and protect the underwater cultural landscape and archaeological impacts and data are missing from biological
reports on the process. No underwater policies based on cultural preservation have been formulated to manage
offshore fishing. There is a preferred policy for in situ preservation in the 2001 UNESCO Convention on the
Protection of Underwater Cultural Heritage and some practical measures for site managers to address the
threats from bottom trawling but if in situ preservation is to be supported, more needs to be done. Moorings can
be added and shipwrecks, if left in place, can become artificial reefs and places for more artisanal, sustainable
hook-and-line fishing. However, what is needed most is for states and international fishing organisations to ban
bottom trawling at and around identified UCH sites, as has been done for some seamounts.
This work is part of the Threats to Our Ocean Heritage project, a UN Decade for Ocean Science approved
Action discussing this issue of Trawling, Deep Seabed Mining, and Potentially Polluting Wrecks. The expected
results include ocean literacy that increases awareness of the issue to a wider range of stakeholders including
international organisations, states, and institutions with the authority to effectuate change.
Keywords: Underwater Cultural Heritage; Bottom Trawling; Maritime Archaeology

List of abbreviations
Exclusive Economic Zone (EEZ)
National Research Council (NRC)
Nautical Miles (nm)
Remotely Operated Vehicle (ROV)
Underwater Cultural Heritage (UCH)
United Nations Educational, Scientific and Cultural Organization (UNESCO)
List of figures
Figure 1: A beam trawler and an otter trawler.
Figure 2: A diver examining fishing debris on a shipwreck.
Figure 3: The intensity of trawling around the globe, focused in coastal regions in tonnes per
kilometres squared.
Figure 4: Evidence of fishermen respecting prohibited zones in Southwest Turkey.

INTRODUCTION
Trawling has been recognised as a catastrophically damaging practice with lasting
negative consequences on seabed ecology and marine life. Less well known though are the
dramatic effects trawling has also had on maritime archaeology sites. Although legislation limiting
trawling may help biological communities rebound, the archaeological material lost can never be
recovered. Restrictions must be passed as soon as possible to prevent further material and heritage
destruction.

1

�Bottom, or beam, trawling refers to the practice of pulling a net behind a boat to catch fish. Trawling
grew from a need to keep up with declining fish stocks and developed further with technological
changes and increased demands, though fishermen constantly complained about the problems in
overfishing it created. All three trawling revolutions—invention, mechanisation, and later deep-water
expansion—have been met with controversy and pushback from the public and conservationists alike
(Roberts 2008, 133). Yet nothing has been done to seriously limit the practice and protect the
submerged cultural landscape. Crucially, archaeological impacts and data are also missing from
biological reports and published articles on the practice.
Trawling developed from the practice of fishing with a net, but that older style was more controlled.
Fishermen knew what they were going to pull up each time and rarely had surprises. With bottom
trawling, nets are weighted to keep them low along the sea floor and a large beam on deck spread the
nets wide to increase catch. This practice of dragging nets along the bottom of the sea, according to
historian Jeffery Bolster (2012), redefined the fisherman’s relationship with the fish and it became an
exploitative relationship. The practice has enabled humans to both exploit the sea and destroy their
own history at the same time.
There is no doubt that trawling has decimated fish stocks globally and brought hardship on fishing
communities. Today’s boats must work an estimated 17 times harder than in the past because there
are literally fewer fish in the sea (Roberts 2012, 44). With one pass by a trawler, boulders can be
displaced, large epifaunal invertebrates removed and damaged, and sediment re-suspended (Freese et
al. 1999, 119). Structural components of fish habitats are removed, and biodiversity is lost. The
effects have been likened to clear cutting a forest, or strip mining.
This paper serves as a call for action to address the threats to our ocean heritage from the long history
of the destructive activities of bottom trawling. Calum Roberts (2012, 6) writes that the ‘impacts [of
trawling] are discussed in isolation and different meetings and by different people who never quite see
the picture’. He is referring to different people within the marine scientific fields such as those
focused on fishery sciences or pollution. His point holds true, though, with a group of people many do
not consider to be ocean heritage professionals: maritime archaeologists or underwater cultural
heritage professionals.
Although efforts to illustrate sustainability in seafood, such as the Marine Stewardship Council stamp,
may attempt to show safe fishing practices, one can never be sure of the wider harm being done,
especially to UCH. Some conservationists, including Roberts (2008, 348), argue that trawling should
be limited to locations where it does not harm the ecological landscape. Maritime archaeologists and
marine ecologists need to communicate and work together to lobby for moratoria on trawling.
Shipwrecks are as much part of the marine landscape, and thus of importance to ecologists, as they
are to the cultural and historical landscape.

History of Trawling
First Revolution
As far back as 1376, the English parliament was already worried about the destructive nature of
trawling to fish populations and habitats, noting that trawling ‘runs so heavily and hardly over the
ground when fishing that it destroys the flowers of the land’ and takes so many fish ‘to the great
damage of the commons and the destruction of the fisheries’ (Petition by the Commons to King
Edward III, 1376 seen in Bolster 2012, 235). Trawling in Europe continued sporadically through the
medieval and early modern periods until the early nineteenth century when the industrial revolution
pushed trawling technology further.

2

�Second Revolution
By 1840, fishermen, using sail power, were already noticing depleted stocks, so changes developed
out of a necessity to compensate for a declining catch. Enter steam-powered vessels, which could
gather four times more fish per catch than a sailing vessel (Bolster 2012, 237). These vessels were not
limited by weather and had the strength to power nets with chain reinforcements on the seafloor. This,
by the end of the nineteenth century, enabled the transition to the otter trawl, where two ‘doors’ are
used to open the nets easily, accommodating larger nets (NRC 2002, 14).

Figure 1: A beam trawl (top) and otter trawl (bottom). (Source: Ecomare, licensed under
the Creative Commons Attribution-Share Alike 4.0 International)

Third Revolution
Arguably the most detrimental technological advance came after World War II. Factory-sized,
freezer-equipped trawlers appeared and changed fishing practices. These vessels had stern ramps to
accommodate larger nets and brought quick-freeze facilities, storage, and fishmeal processing
machines onboard. Trawling spread to the deep sea, spearheaded by the Soviet Union but quickly
growing into a global industry. The 1950s and 1960s saw the rise of echo sounders and access to areas
beyond the reach of shallow trawls. But these new fishing grounds often had rough seafloors that
shredded the nets. In response, an innovation was born that significantly increased the destructive
power of the trawls. ‘Rockhopper gears’, up to one metre in diametre and weighing hundreds of kilos,
are massive steel rubber rollers and chains attached to trawl nets, enabling them to grate flat over the
seafloor, destroying everything in their path (Atkinson 2012, 16)
3

�Commercial fishermen now had the technology to send their boats out for longer, fish further away,
and fish faster with larger nets (NRC 2002, 12). Eastern European nations took this to a new level,
creating ‘floating towns built for the sole purpose of processing marine life into food’ (Roberts 2008,
189). Biologically productive deep seamounts became the new targets and using sonar, vessels could
trawl through a large group of fish taking in 50 to 60 tons in a few minutes (Roberts 2008, 291).
Today, trawling has grown to previously unimaginable rates. The nets used cut paths through the
seafloor at least 100 metres wide and four stories tall, pulling in fish at staggering and unsustainable
rates. Many nets are made of synthetic materials which do not break easily when snagged, allowing
for higher powered vessels (Brennan 2016, 158). These nets also make up the largest portion of
marine debris and plastic pollution in the ocean. With improved gear and electronics, vessels can map
the seafloor, fish very close to bottom features, drag nets over rougher seafloor than before (Dorsey
1998, 2), and decimate fish populations and UCH sites across the ocean. This destruction of natural
heritage has been well documented and there are some promising studies in UCH damage from
trawling that will be explored next.

Figure 2: A diver examines debris left from fishing gear in the Stellwagen Bank Marine Sanctuary, a nationally
protected area in the United States that allows trawling and fishing within its borders. Almost all wrecks in this
protected area have been impacted by trawling (Marx 2010) (Image source: National Oceanic and Atmospheric
Administration, https://stellwagen.noaa.gov/protect/shipwrecks.html).

4

�CASE STUDIES
Coastal Trawling and the Continental Shelf
Coastal seas are some of the most ecologically productive areas with delicate plants and marine life
and complex ecological systems. A 2021 report found that trawling is the most intense in the
territorial (12 nautical miles (nm) offshore) seas of coastal states (Steadman et al. 2021, 5; Pauly,
Zeller, and Palomares 2020) and is illustrated in figure 3.

Figure 3: The intensity of trawling around the globe, focused in coastal regions in tonnes per kilometre squared
(Source: Pauly, Zeller, Palomares 2020, printed under Creative Commons Attribution Non-Commercial 4.0
International License).

Coastal trawling is also particularly destructive to UCH, since it is where most known wrecks are
located (Atkinson 2012, 11). For example, of the more than 100 shipwrecks in Turkish waters, 16
were observed within trawling boundaries in the Aegean Sea to quantify damage. Researchers found
these wrecks with trawl scars running across the site (Brennan et al. 2012). Off the coast of Northern
Italy, the Mercure wreck was discovered after historic material was found in a trawl net, and further
research showed that trawling nets had spread the vessel and is artefacts across an area of 100 meters
(Atkinson 2012, 53).
Many wrecks in the Asia Pacific region lie in areas of heavy trawling activity and the wreck timbers
have already been damaged. For example, Sten Sjostrand identified 15th- and 16th-century wrecks off
the coast of Malaysia, and both were damaged by the time he returned even though the 15th-century
wreck once stood 1.8 metres off the seabed (Atkinson 2012, 49). Three kilometres west of Ko Si
Chang, Thailand, the Chang I wreck was found when trawl nets stuck to it during a survey in 1981,
and archaeological survey markers were left behind. By the time archaeologists revisited the site in
1983, the markers were missing, likely sheared off by trawl gear (Green et al. 1986, 108). Off the
coast of New South Wales, Australia, many wrecks have been impacted by scallop dredgers including
the City of Launceston, Euralba, Eleutheria, the Isis, and the Lady Darling (Atkinson 2012, 53).

5

�It is not just shipwrecks being destroyed, though. Rising sea levels have put many prehistoric
landscapes under coastal waters today. Among the sites worst affected by trawlers is Doggerland, a
30,000-square-kilometre area inhabited during the Mesolithic period (8,000 years ago), which is now
under the waters of the North Sea. Hundreds of stone tools have been dragged up over the centuries as
it has been bulldozed by trawlers (Atkinson 2012, 68). This area is a valuable example of a site that is
both a paleo seascape as well as a site of past human inhabitation.
Also in the North Sea, near Brown Bank, Dutch fishermen found items dating to 7200-6000 BC and
near Colijnsplaat, Netherlands, when Roman alter stones were dragged up. Even a Neanderthal skull
fragment has been found in this area. Off the coast of England, a Saxon period longshore post was
visible at low tide, with trawl damage obvious. There are many examples of this in North America
too. As a result of deglaciation and isostatic uplift, many sites of the First Americans are now covered
by water. Fishermen off the coast of New England have reported findings of tools from the Middle
Archaic period and off Virginia a mastodon skull and a stone biface were discovered (Atkinson 2012,
55, 56, 64, 66).
Submersible surveys have also discovered shipwrecks that have already been damaged by trawlers on
the Continental Shelves (12nm to 200nm from the coast and &gt;200 m deep). In the Bulgarian Black
Sea, trawling methods reach down about 100 m on the shelf (limit of trawling depth here) to catch sea
snails, clams, and other benthic species and have been a significant practice for decades, unregulated
by the government (Prahov et al. 2021, 748 and 749). Since 2010, surveys have been conducted to
monitor the damage to wrecks, but no adequate prevention measures have been taken (Prahov 2021,
749).
The issue of heritage destruction by trawling is also important to the Asia-Pacific Region because
traditionally, trawling studies with UCH have focused on European and North American waters, even
though roughly 50 per cent (over the last decade of available data) of all bottom trawled fish come
from the continental shelf/EEZs of Asian nations or the foreign fleets of Asian countries (Steadman et
al. 2021, 5).
Deep Sea Trawling and The High Seas
As technology improved and moved further out to the seamounts in the deep sea, more UCH sites
must be protected from trawling. The deep-water sites are further from anthropocentric damage and
valuable resources due to their in-accessibility. Remotely Operated Vehicle (ROV) technology has
allowed previously impossible deep-sea (more than 200 m deep) exploration and has revealed
beautiful, complex habitats. Stunning corals and rich communities are now visible, yet most already
showed trawl scars and broken fishing gear. Today’s trawls can reach depths of 2000 m and
everywhere scientists look they see evidence of trawling destruction and no evidence of recovery
(Victorero et al 2018, 2).
There is also evidence of trawl damage on deep-water wrecks off the coast of Turkey along its
Mediterranean, Aegean, and Black Sea shores (Brennan et al 2016). Michael Brennan’s (et al 2012,
55) work in studying wrecks in Aegean Turkish waters below diving depth, showcases the damage
trawling can do and the high stakes of what is being lost. The studied sites range in depth from 82410 m deep and cover centuries of history (Brennan et al 2012, 64). In the Black Sea, Ereğli E, one of
the oldest deep-water wrecks yet discovered, could have been one of the most significant wrecks ever
found in the area, but by the time it was found in 2011, it had already been nearly destroyed by
trawling (Brennan et al 2016, 84).
In the Pacific, though New Zealand is the only main participant of deep-water trawling over
seamounts in the high seas of the South Pacific, there are a handful of active vessels in the North and
the existing and potential future damage done must be discussed (Thomas 2022). There are hundreds
of years of history preserved on the Pacific seafloor and immeasurable quantities of intangible cultural
heritage that need to be protected.
6

�FRAMEWORK
The case studies and research show how bottom trawling is not only a threat to our natural heritage
but are clearly a major threat to UCH. The stories of our societies and our ancestors are wrapped in
intangible connection with the ocean and captured on the seafloor as artefacts, shipwrecks, and
remains of those lost or buried at sea. Marine global heritage has largely been based on natural
heritage. However, UCH is also ocean heritage and must be respected in the same way.
Cultural heritage and natural heritage are intertwined when it comes to the ocean. UCH can support
ecological marine biodiversity and helps boost sea connectivity. Natali Pearson and Benjamin
Thompson (2023, 3) argue that it is beneficial for sites with high UCH and high natural heritage to cooccur and be used strategically together. Over time, shipwrecks come into equilibrium with the
marine environment around them and become part of the benthic topography (Brennan 2016, 172).
Trawling rapidly destroys this equilibrium, which often has been balanced for centuries (Brennan et
al. 2013, 99). Shipwrecks often function as artificial reefs providing habitats, shelter, and adding hard
materials to an otherwise soft seafloor. Michael Brennan’s (2016, 172 ; Krumholz and Brennan 2015)
research on the Knidos shipwrecks along the Aegean coast of Turkey indicates that lightly trawled
ancient wrecks with structures on the seafloor still exhibit more fish population and biomass than
heavily trawled wreck sites with little or no structure remaining. Through this process of ‘spill over’,
protected shipwrecks can help increase the strength of surrounding fish stocks. Shipwrecks can be as
indispensable to the seafloor ecology as a natural coral reef or seamount. Thus, shipwrecks should not
be viewed solely in a cultural significance context; they are part of the natural ocean landscape as well
as our cultural history.

RESULTS
The results of this paper are a suggestion of steps forward. Underwater policies formulated to manage
offshore fishing based on cultural preservation are lacking. Some trawling restrictions were placed
after backlash in the 1990s when ecologists and fisheries experts, well aware of the dangers of
trawling, lobbied for more restrictions. This research and advocacy for regulation are a good start.
There is a preferred policy for in situ preservation by archaeologists and historians codified in the
2001 UNESCO Convention on the Protection of Underwater Cultural Heritage but some practical
measures for site managers to address the threats from bottom trawling are needed. If in situ
preservation is to be supported, moorings should be added for shipwrecks that are destinations for
ecocultural tourism. As artificial reefs they may be appropriate places for more artisanal, sustainable
hook-and-line fishing. However, what is needed most is for states and international fishing
organisations to ban bottom trawling at and around identified UCH sites, as has already been done
for some seamounts. Most importantly, trawling damage should not be allowed as a justification
for salvage.
The author recognises that these results cannot be achieved without the voice and support of the
fishing community. Wrecks, however, also present problems to fishermen. When nets snag, gear is
lost or ruined and can be costly to replace. Shipwrecks can also endanger the lives of those onboard
vessels. In Britain from 1976 to 2005 around 16 vessels capsized after gear was snagged on
obstructions and many lives were lost (Atkinson 2012, 3). Although some shipwreck sites have only
been found because of fishermen’s reports, there is no requirement for fishermen to do so.
Collaboration and partnership between archaeologist and fisherman is needed and archaeologists must
understand the context fishermen operate in to communicate effectively (Brennan et al. 2012, 62; see
Figure 4).

7

�Figure 4: Evidence of fishermen respecting prohibited zones in Southwest Turkey: dark grey area shows a zone
where trawling is prohibited, dots show visible trawl scars on the seabed (Source: Brennan et al. 2012, 62 reprinted
with permission).

What we do with trawling can pave the way for other important ocean exploitation. Climate change
will continue to threaten our oceans (for example, sea-level-rise sinking previously terrestrial sites)
and we know ecologically why it is important to protect the ocean. While there are many unknowns in
deep sea biodiversity and ecosystem services, what we do know clearly points to vast and far-reaching
damage. In other words, we know enough from existing trawling damage that tells us we should stop
similar practices, like seabed mining. We cannot predict undiscovered historical significance.
Trawling is a clear and present threat not only to fish populations and habitats, but also to submerged
cultural landscapes. There should not be a choice between humans and the natural world. Restrictions
such as the options above, must be passed as soon as possible to prevent further material and heritage
destruction.

Acknowledgements Thank you to The Ocean Foundation, The Lloyd’s Register Foundation Heritage and Education Centre,
ICOMOS-ICUCH, and Ocean Decade Heritage Network for their support of this paper and the Threats to Our Ocean
Heritage project. Thank you to Mark Spalding, Ole Varmer, Alexandra Refosco, Michael Brennan, Jim Delgado, Louise
Sanger, and Ben Ferrari for their help developing the ideas that are reflected here. Thank you to Claire Zak and Sheri
Kapahnke for hosting a session and a dynamic discussion on Coastal UCH sites at the EAA meeting in 2022 that sparked the
idea to pursue this research.

8

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                <text>Bottom Trawling and the Damage to Underwater Cultural Heritage: An Overview of the Destruction and Possible Steps Forward </text>
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                <text>Trawling has long been regarded as a damaging practice and marine ecologists have lobbied for restrictions. The&#13;
damage to Underwater Cultural Heritage (UCH), however, has received less attention, though it is just as&#13;
consequential. This paper looks at UCH damage case studies and the impacts of heritage loss and then suggests&#13;
steps forward. The case studies in the paper will include the damage to UCH across the ocean and in the&#13;
Mediterranean and Black seas. Shipwrecks are as much part of the marine landscape, and thus of importance to&#13;
ecologists, as they are to the cultural, historical landscape. Yet nothing has been done to seriously limit trawling&#13;
and protect the underwater cultural landscape and archaeological impacts and data are missing from biological&#13;
reports on the process. No underwater policies based on cultural preservation have been formulated to manage&#13;
offshore fishing. There is a preferred policy for in situ preservation in the 2001 UNESCO Convention on the&#13;
Protection of Underwater Cultural Heritage and some practical measures for site managers to address the&#13;
threats from bottom trawling but if in situ preservation is to be supported, more needs to be done. Moorings can&#13;
be added and shipwrecks, if left in place, can become artificial reefs and places for more artisanal, sustainable&#13;
hook-and-line fishing. However, what is needed most is for states and international fishing organisations to ban&#13;
bottom trawling at and around identified UCH sites, as has been done for some seamounts.&#13;
This work is part of the Threats to Our Ocean Heritage project, a UN Decade for Ocean Science approved&#13;
Action discussing this issue of Trawling, Deep Seabed Mining, and Potentially Polluting Wrecks. The expected&#13;
results include ocean literacy that increases awareness of the issue to a wider range of stakeholders including&#13;
international organizations, states, and institutions with the authority to effectuate change.</text>
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                <text>Jarvis, Charlotte . 2023. “Bottom Trawling and the Damage to Underwater Cultural Heritage: An Overview of the Destruction and Possible Steps Forward.” Edited by Jennifer Craig, Jay Mok, T. Kurt Knoerl, and Ole Varmer. In Proceedings of Fifth Asia Pacific Regional Conference on Underwater Cultural Heritage: Gwangju, The Republic of Korea, November 13-18 2023. The Museum of Underwater Archaeology. URL: https://apconf.omeka.net/exhibits/show/apconfproceedings/item/1904 </text>
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                    <text>Underwater Cultural Heritage and Fishing Communities: safeguarding heritage and
safeguarding fishermen

Ben Ferrari (Lloyd’s Register Foundation Heritage Education Centre, Senior Advisor)
Antony Firth (Historic England, Head of Marine Heritage Strategy)
David Gregory (National Museum of Denmark, Senior Researcher and Honorary Professor)
Louise Sanger (Lloyd’s Register Foundation Heritage Education Centre, Head of Research,
Interpretation &amp; Engagement)

ABSTRACT
This paper proposes that development of a fit-for purpose management to protect underwater cultural heritage
from negative impacts caused by fishing gear requires three elements; evidence-based characterisation of
impacts; understanding of the pressures and constraints acting upon fishing communities; commitment to
engagement with fishermen and industry associations. A new study is introduced, ENDURE, that will help to
characterise and quantify damage caused by fishing gear to archaeological material as part of a broader study of
site formation and preservation in situ. The work of Lloyd’s Registry Foundation on fishing safety is presented
as a contribution to the design of appropriate management regimes – it is emphasised that fishing is already
inherently dangerous and that dislocation from traditional fishing grounds caused by exclusion or limitation of
fishing in certain areas can exacerbate occupation safety challenges; the work of Historic England in is described
as a case study of liaison with fishermen to safeguard heritage and the need for broad. The need for commitment
to a broad programme of engagement with fishermen, industry associations and responsible agencies is
illustrated. The paper concludes that the vital role of fishing in maintaining the stability of coastal communities
must be recognised while seeking arrangements that minimise risk to heritage on the seabed.
Key Words: Impact , Preservation in situ, Safety, Engagement
Abbreviations
ALDFG - Abandoned, Lost and Discarded Fishing Gear
CFP - Common Fisheries Policy
DEFRA - the Department for Environment, Food and Rural Affairs
FIPAD - Fishing Industry Protocol for Archaeological Discoveries
FMP – Fisheries Management Plans
HAZ - Heritage Action Zone / High Street Action Zone
HE - Historic England
HPMA – Highly Protected Marine Area
IFCA - Inshore Fisheries and Conservation Authority
LRF Lloyd’s Register Foundation
MPA – Marine Protected Area
MMO - Marine Management Organisation (MMO)
UCH – Underwater cultural heritage
UKMA – UK Marine Area

1

�INTRODUCTION
This paper addresses three areas of endeavour central to managing the impact of fishing activity on
Underwater Cultural Heritage (UCH). There are more than three million shipwrecks estimated
worldwide according to UNESCO (Croome 1999, 49-52). The UNESCO 2001 Convention on the
Protection of Underwater Cultural Heritage encourages in-situ preservation and states that wrecks
older than 100 years count as a cultural heritage site. This encompasses many metal shipwrecks,
including World War 1 casualties and gives rise to significant conflicts of interest (Firth 2018, 8-9).
They are habitats for marine life, enhancing biodiversity and biomass (Bałazy et al. 2019, 1-2). They
can also pose environmental pollution threats, especially if they contain hazardous substances such as
oil, chemicals, or munitions (Ndungu et al. 2017; Szafrańska et al. 2021). Marine spatial planning
issues often arise as wrecks interfere with the ever-increasing offshore sub-sea engineering efforts,
such as the installation of cables, pipelines, or wind farms (Papageorgiou 2018, 195-196). Shipwrecks
are also treated as geohazards and obstacles to marine engineering, posing risks to navigation or safety
through unexploded ordnance. The impact of fishing activity must therefore be considered in the
context of a complex marine management and stewardship environment.
The first section deals with the need for evidence-based characterisation of the impact of fishing that is
integrated into wider consideration of site formation dynamics. A major European Research Council
research programme, ENDURE, is introduced. Based at the National Museum of Denmark, ENDURE
aims to disentangle natural and anthropogenic decay processes and determine their cumulative effects
on UCH. The aim is to validate the efficacy of in situ preservation.1 The following sections develop
the proposition that the application of such foundational work on new management regimes will be
compromised in the absence of full appreciation of the pressures operating on the fishing industry and
without concerted effort committed to close engagement with fishermen. Not all fishing activity poses
an equal threat to UCH, and it is critical that an understanding of material differences in impact shapes
management solutions. The second section introduces the work of Lloyd’s Register Foundation (LRF)
- shaping a future for the fishing industry that is safe for all fishers working in a sustainable ocean
economy. Today’s fisheries are part of a highly stressed marine system, and the human cost of fishing
is appallingly high. LRF’s work will help inform proposals for protection of UCH that avoid
exacerbating occupational safety challenges. The third section presents work undertaken by Historic
England (HE) to engage with fishermen to mitigate damage to UCH and develop fit-for-purpose
management regimes. It emphasises the need for broad engagement with agencies as well as industry
bodies and communities.

CASE STUDIES
Out of sight but not out of mind - Sustainable preservation of underwater archaeological sites
Given the scale of the heritage management challenge – a wide range of site types in complex,
dynamic environments - a desk-based approach for assessment of the most significant site formation
processes is urgently needed. Rapidly progressing marine remote sensing techniques allow effective
non-intrusive detection, characterisation, and monitoring of underwater sites (Plets et al. 2011, 87-88;
Westley et al. 2019, 3629-3632). The remote characterisation and monitoring of change at individual
sites (Quinn &amp; Boland 2010, 2938-2940; Brennan et al. 2016, 82-84) includes environmental factors
to understand physical formation processes in control of site preservation (Smyth &amp; Quinn 2014, 221223; Fernández-Montblanc et al. 2016, 240-242; Quinn &amp; Smyth 2018, 1429-1432; Geraga et al.
2020, 1210-1215; Majcher et al. 2021, 1-4).
Gregory and Manders (2015, 7-10) formed a baseline process-based approach to control, assess and
achieve in-situ preservation, and one of its central points is the assessment of the most significant
chemical, biological and physical threats to the site. Understanding the formation of underwater sites
also enables more accurate archaeological interpretation. Assessing environmental factors can not only
1

Project ENDURE https://www.endureerc.com.
2

�lead to better understanding of events that caused the sinking of the vessel but it also helps to predict
pathways of future deterioration. This enhances understanding of potential pollution and fishing
hazards and address UCH management needs.
In ongoing work (Gregory et al, forthcoming) baseline post-depositional site formation processes for
more than 500 shipwreck sites located in the North and Baltic Seas are being examined. Multi-beam
bathymetry data supplied by the marine survey company (JD-Contractor A/S) are integrated with
multiple environmental and anthropogenic influenced data layers sourced from open-data portals. The
sites were manually classified using a revised form of Muckelroy’s (1977) approach and subsequently,
statistical correlation analysis was used to determine the most significant variables. Fishing activity
was assessed through inclusion of variables representing fishing efforts. EMODnet (2023)2 provides a
variety of quantified fishing activities in the Baltic and North Seas. Only the fishing methods entailing
direct contact of the fishing gear with the seabed were relevant. Bottom seiner, beam and otter trawler
fishing data were downloaded from the EMODnet portal, representing fishing intensities averaged
across three years. However, caution is required as there is on-going research into the footprint and
actual impact of fishing on seabed habitats (McConnaughey et al. 2020, 325-30). Although the study
presents a simplified, preliminary approach it serves as a big-data-driven attempt to assess the
predominant basin-scale post-depositional site formation factors acting at UCH sites. Water depth,
bottom fishing intensity and oceanographic variables like salinity have significant influence as well as
the expected correlation between the age of a wreck site (sinking date) and its current preservation
state. These aspects are being further developed in the ENDURE project addressing the following key
knowledge gaps: 1) the efficacy and long term sustainability of ‘in-situ preservation’; 2) what to
preserve and why; 3) a comprehensive understanding of decay processes (including their rates) and
how and in what circumstances these can be mitigated for; 4) the invisible and inaccessible nature of
these sites and how such a large resource can be effectively monitored; 5) the increasingly dynamic
and changing nature of the marine environment due to both natural and anthropogenic drivers; and 6)
the lack of integration of UCH management with other disciplines and end users of the marine
environment.

RESOURCES
The world’s most dangerous industry
The damage caused to UCH by trawling activity cannot be ignored by responsible Government
agencies and Lloyd’s Register Foundation3 (LRF) is committed to supporting the safe and effective
management of UCH. However, attempts to develop better management regimes for UCH located on
or near fishing grounds will be compromised without a high-level of awareness of challenges faced by
the fishing community. Accordingly, LRF Heritage Education Centre has launched the Learning from
the Past4 programme to help generate insights that contribute to fisher safety. It will also help
archaeologists and historians to communicate with fishermen and policy makers to limit harm to both
the natural and historic marine environments.
Illegal fishing, climate change, weak governance, poverty, and reduced fish stocks all contribute to
make fishing one of the world’s most dangerous professions. Recent work by the FISH Safety
Foundation indicates that over 100,000 fishing-related fatalities occur annually with the majority in the
developing world.5 Negative health effects on industry participants in general and fatalities greatly

2

https://emodnet.ec.europa.eu/en/fishing-intensity-data-set-extended-additional-sea-regions
https://www.lrfoundation.org.uk/en/
4
https://hec.lrfoundation.org.uk/get-involved/introducing-learning-from-the-past-236
5
https://www.the-human-cost-of-fishing.org/
3

3

�exceed those in the wider shipping sector.6 In Bangladesh, over 1,350 fishermen die at sea every year,
often in boats without the most basic safety equipment.7
LRF has launched several initiatives, such as FishSafe2025, to help assure fisher safety through
training and awareness.8 The highly influential Insight Report on Safety in the Fishing Industry
(Attwood 2018) stressed the need to improve safety in ways that are appropriate for local
communities. The Foundation has also supported development of new safety technology—for example
SeaWise®, a tablet-sized device that monitors the stability of smaller fishing vessels.9 These outputs
contain many insights that may be valuable in designing new UCH management regimes—especially
in inshore waters.
Marine Protected Areas (MPAs) and latterly, Highly Protected Marine Areas (HPMAs), will be a key
tool in both marine nature and heritage conservation but displacement of fishers from familiar
grounds, whether through creation of MPAs or other processes, can carry a cost that must be
recognised and addressed in planning stages. The LRF funded film Two Kinds of Water10 tells the
story of fishers in Africa’s most vulnerable fishing communities. Displaced from their traditional
fishing grounds into stormier waters, fishers are forced to venture further and stay at sea longer in
poorly adapted vessels. Larger, mechanised fishing vessels now compete with artisanal fishers for fish
and pose a safety threat to their more fragile, smaller craft. Fishing communities also face disruption
around the UK. Fishers have been moved from traditional shore facilities due to redevelopment. The
UK Government plans for new, HPMAs,11 may also deny fishers access to traditional inshore grounds.
UK sea fisheries associations have warned of a looming displacement crisis with lasting harm to
coastal communities.12
The UK Government has consulted extensively on proposed HPMAs and eventually refused two of
the proposed designations. The needs of fishing communities were prominent in the published
rationale for rejection.13 For Lindisfarne, reasons included residents’ concerns about losing their
heritage, community, and cultural identity through losing fishing and their health and safety concerns,
including mental health. The Inner Silver Pit South designation was refused on the basis that the
relatively high costs to fishermen would not be offset by the potential benefits from its designation as
a HPMA.

FRAMEWORK
Protecting England’s Maritime Heritage and fishing community engagement
Fishing in English waters, using both mobile and static gear, involves a variety of complex
interactions with UCH. Fishing has given rise to important heritage both underwater and along our
coastlines, but fishing can also cause damage to UCH. Fishing is often a source of information about
UCH – in the form of new discoveries – even where those discoveries are a consequence of fishing
impacts.

6

https://www.spglobal.com/marketintelligence/en/mi/research-analysis/seafarer-fatalities-shows-shipping-mustdo-more.html
7
https://www.fishsafety.org
8
https://www.lrfoundation.org.uk/en/impact-stories/saving-lives-of-the-worlds-poorest-fishermen/
9
https://www.lrfoundation.org.uk/en/impact-stories/hook-marine
10
https://www.lrfoundation.org.uk/en/news/keeping-fishers-safe-at-sea/
11
https://www.gov.uk/government/publications/highly-protected-marine-areas-hpmas-review-2019
12
https://www.nffo.org.uk/spatial-squeeze-report-parliamentary-launch/
13
https://www.gov.uk/government/publications/highly-protected-marine-areas/highly-protected-marine-areashpmas#an-overview-of-the-pilot-hpma-selection-process
4

�Historic England (HE) is the government’s advisor on the historic environment in England, including
in the UK Marine Area (UKMA) off England14, encompassing the territorial sea to 12 nautical miles
(nm), and the UK Continental Shelf and Exclusive Economic Zone to median lines with neighbouring
countries or to the boundary of national jurisdiction (200 nm) in the southwest. HE’s capacity to
designate sites under heritage legislation is limited to the territorial sea but HE advises government on
a range of other powers relating to resource use, the environment and fishing that apply to the full
extent of national jurisdiction. For fisheries management, another key boundary lies at six nm, which
is the outer limit of areas administered by Inshore Fisheries and Conservation Authorities (IFCAs).
Beyond six nm, fisheries management is subject to the Common Fisheries Policy (CFP) of the
European Union (EU). Since the UK left the EU, fisheries off England beyond six nm are now
administered by the Marine Management Organisation (MMO), one of the family of public bodies
sponsored by the Department for Environment, Food and Rural Affairs (Defra).
HE, including through its precursor English Heritage, has been engaging with fisheries for many
years. It commissioned a wide-ranging examination of fishing and the historic environment that
encompassed the contribution of fishing to the historic environment as well as direct and indirect
interactions, both positive and negative (Firth et al. 2013). The report spurred further investigations
and continues to provide evidence to support advice to government.
In the 1990s, ‘fishermen’s fasteners’ were included among the core data recorded in the national
inventory, now known as the National Marine Heritage Record. Fasteners are places where fishermen
have noted snags to their gear which, in several cases, proved to be historic wrecks. Whilst fasteners
indicate potential UCH, their actual character is unknown. This and several other ambiguities
prompted a project led by Sussex IFCA to better understand fasteners and their heritage implications,
including testing whether the survey methods used by IFCAs for fisheries and habitat mapping could
also be used to examine fasteners. The project, which included dialogue and joint fieldwork with
fishermen, confirmed the continued importance of fishermen’s fasteners as a source of information
(Firth &amp; Dapling 2020). The project also flagged the safety issues presented by cultural heritage to
fishing insofar as some fishing vessels, and fishermen’s lives,15 have been lost from snagging
obstructions and other historic material such as ordnance.16
The potential for IFCAs to use habitat survey methods to examine UCH was further explored in a
project led by Isles of Scilly IFCA with the University of Plymouth (Firth et al. 2020). In 2012-13,
HE funded a pilot project to encourage fishermen to report their discoveries of UCH through a Fishing
Industry Protocol for Archaeological Discoveries (FIPAD) (Davidson 2013). FIPAD was further
developed with the support of the National Lottery Heritage Fund and Sussex IFCA in 2016-18.17
Notwithstanding these positive instances of collaboration, fishing is still a cause of impacts to UCH,
including to highly significant historic wrecks designated under heritage legislation. Several instances
of documented damage are currently being investigated as heritage crimes and in other instances,
fieldwork has been commissioned to remove Abandoned, Lost and Discarded Fishing Gear (ALDFG)
that is obscuring designated sites and presenting a hazard to licensed divers. Whilst damage is a
criminal offence, fishing as an activity is not restricted on these sites. Consequently, and in addition to
pursuing criminal damage, HE efforts are twofold: working with the fishing sector to discourage the
use of potentially damaging methods in the vicinity of important sites; whilst also exploring the use of
fisheries management measures to formally restrict fishing. New fisheries legislation, the Fisheries Act
2020, was introduced to accompany the UK leaving the EU and encompasses ‘features of
archaeological or historic interest’ within the scope of the marine and aquatic environment that can be
conserved, enhanced, and restored through financial assistance, regulations, or conditions on sea
fishing licences. It was confirmed by the Minister in Parliament that regulations for conservation
14

Cultural heritage and fisheries in the UK are both devolved matters: distinct arrangements apply in England,
Scotland, Wales, and Northern Ireland.
15
https://www.gov.uk/maib-reports/capsize-and-sinking-of-beam-trawler-noordster-off-beachy-head-englandwith-loss-of-3-lives.
16
https://www.gov.uk/government/news/galwad-y-mor-report-published.
17
https://fipad.org/
5

�purposes may be used to amend or introduce legislation to protect features of archaeological or
historic interest individually or collectively.18
Exclusion of fishing activity from limited areas around specific heritage sites is a residual option if the
risk of impact cannot be reduced through other means, but it is not the starting point. As noted earlier,
fishing is a valued part of our heritage, contributing to the character and sense of place of coastal
communities, including people who work in them or visit. Often, UCH is itself the heritage of fishing
generally but also of the fishermen themselves: numerous fishing vessels lie wrecked in English
waters, not least from the First and Second World Wars when fishing vessels and fishing crews served
in the hazardous role of minesweeping. HE has supported the contribution of fishing heritage to
regeneration of coastal communities through Heritage Action Zones (HAZs) and High Street Action
Zones (HAZs). Examples of this include the ‘Kasbah’ at the heart of Grimsby’s historic fishing
industry,19 and the Whapload Road area of North Lowestoft (Bristow 2019). HE is carrying out a
thematic assessment of heritage relating to steam fishing, encompassing heritage assets on land and at
sea.
HE continues to explore how heritage contributes to the sustainability of fishing, reducing impacts to
UCH but potentially contributing to the wider sustainability of our continued use and enjoyment of our
seas. HE is supporting and co-supervising a new PhD starting in October 2023 on using cultural
heritage proactively to help manage UK marine fisheries in conjunction with Heriot Watt University
and the University of Exeter as part of the Centre for Doctoral Training in in Sustainable Management
of UK Marine Resources (CDT SuMMeR). The research will examine how the legacy of cultural
heritage embedded in the practice of small-scale fishing – traditional ecological knowledge, maritime
landscapes, historic landing places, traditional vessels, and all their associated skills and material
culture – can be used to drive greater sustainability within fisheries management.
Historic England continues to engage with Defra and the MMO on major changes to fisheries
management introduced by the Fisheries Act 2020. The new Joint Fisheries Statement (JFS)20 – which
sets out the overall direction of fisheries management across the UK –acknowledges that the seafood
sector is an important part of the economy of coastal communities and has a rich cultural heritage from
which many of those communities draw a sense of place and identity. There is work to do, however,
on detailing how this rich cultural heritage is to be conserved and enhanced through the JFS. Historic
England is engaged on the practical implications of the Fisheries Management Plans (FMPs) that
support the JFS through binding obligations and identified measures for dealing with individual fish
stocks, types of fishing and geographic areas. The introduction and implementation of FMPs provides
a key opportunity to flag the impacts of specific fisheries and how they can be reduced, but also the
positive contribution that heritage can make to the long-term sustainability of fishing and coastal
communities.

CONCLUSION
Unhelpfully, some commercial salvage companies have used the threat of trawl damage to justify the
commercial salvage and sale of valuable materials from historic wreck sites—a line of argument that
must be refuted through evidence led approach to the actual nature and scale of impacts created by
different types of fishing gear in different locations. Fishing is also an inherently hazardous
occupation and the fact fishing communities represent intangible cultural heritage values is
increasingly recognised in consultations21 and programmes supporting the regional socio-economic
18

https://hansard.parliament.uk/Commons/2020-09-15/debates/a7b42ae4-819e-45c7-a0d6fc32b494aacf/FisheriesBill(Lords)(FifthSitting)#contribution-FCA4B1FA-E107-4602-B34C-E9AF6F80A30F
19
https://historicengland.org.uk/services-skills/heritage-action-zones/greater-grimsby/
20
https://www.gov.uk/government/publications/joint-fisheries-statement-jfs
21
https://www.theheritagealliance.org.uk/wp-content/uploads/2020/10/Heritage-in-the-Marine-Environmentpaper.pdf
6

�role of fisheries.22 Heritage agencies have worked successfully with fishing communities to explore
collaborative management approaches. Indeed, examples exist of fishing communities recruited and
trained specifically to assist with monitoring and conservation of UCH. 23 However, much more effort
is needed to develop ways to balance the needs of fishers with preservation of nature and heritage.
Lloyd’s Register Foundation will continue to support such efforts.

Bibliography
Attwood, D. Insight report on safety in the fishing industry: a global safety challenge [online] Lloyd’s Register Foundation.
Available at: https://www.lrfoundation.org.uk/en/publications (2018)
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Firth, A., and Dapling, T. “Fishing for heritage: A project to better understand ‘fishermen’s fasteners’ off the coast of
Sussex”. Historic Environment Research 15 (2020): 38–45. https://historicengland.org.uk/imagesbooks/publications/historic-england-research-15/he-research-15/
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Ecological Surveys Ltd, 2013. https://historicengland.org.uk/research/results/reports/6951/FishingandtheHistoricEnvironment
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8

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                <text>Ferrari, Ben, Antony Firth, David Gregory, and Louise Sanger. 2023. “Underwater Cultural Heritage and Fishing Communities: safeguarding heritage and safeguarding fishermen.” Edited by Jennifer Craig, Jay Mok, T. Kurt Knoerl, Charlotte Jarvis, and Ole Varmer. In Proceedings of Fifth Asia Pacific Regional Conference on Underwater Cultural Heritage: Gwangju, The Republic of Korea, November 13-18 2023. The Museum of Underwater Archaeology. URL: https://apconf.omeka.net/exhibits/show/apconfproceedings/item/1903 </text>
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                    <text>Assessing Potentially Polluting Wrecks in US Waters
Michael L. Brennan (SEARCH, Inc., Deep Water Sector Leader)

ABSTRACT
The topic of this abstract fits within this session on threats to underwater cultural heritage (UCH) because of the
environmental risk posed by shipwrecks with petroleum cargoes. While many shipwrecks from the World Wars
are important parts of our cultural heritage, they also pose a significant threat to the marine and coastal
environment as the steel hulls containing their cargoes continue to corrode. A vital limiting factor in addressing
such pollution risks is that many of these wrecks lie in deep water and have yet to be located. Surveys to find
these wrecks, followed by assessment and management are required to prevent or minimize the adverse impacts
to our ocean heritage. Recent work using satellite detection of oil slicks has assisted in locating certain oil tanker
shipwrecks in deep water.

KEYWORDS Potentially Polluting Wrecks, World War II, oil spills, shipwrecks

INTRODUCTION
This paper studies the wrecks identified by the United States National Oceanic and Atmospheric
Administration (NOAA) as “Potentially Polluting Wrecks” (PPW), which are those that pose the
greatest risk of leaking or spilling their petroleum cargoes or bunker fuel and causing an
environmental hazard (NOAA 2013a). This fits within this session, “Major Threats to Underwater
Cultural Heritage” because most are considered historic under the US National Historic Preservation
Act (NHPA). More than half of the wrecks identified as PPWs are merchant ships from World War II,
which is a significant theme of national importance reflected in the programs for recognizing and
encouraging the historic preservation efforts in the United States. The risk of threats to conservation
of our heritage also refers to both natural and cultural resources under the World Heritage
Convention. Historic and archaeologically significant shipwreck sites that are also potentially
polluting therefore pose a risk to natural ocean heritage while being cultural sites also at risk
themselves of collapsing. In these instances, when a wreck suffers a loss of structural integrity due to
corrosion in the marine environment, the result is not only a loss of archaeological integrity as a
historic site, but as a catastrophic pollution event as the cargo that had been retained in the hull is
released. Under U.S. law, removing oil to prevent potential release from historic wrecks needs to
consider and attempt to avoid or mitigate any loss of the historic property.

CASE STUDIES
A handful of significant shipwrecks have undergone site assessment and pollution risk mitigation
through oil removal operations in the last few decades, but have typically been responsive to oil leaks
rather than proactive. The wrecks that still retain their bunker fuel and petroleum cargoes will leak
them into the ocean, and it is a matter of when rather than if. A major factor, therefore, is how much
cargo or fuel remains, which is determined by the amount of damage to the hull, what level of
structural integrity remains, the rate of corrosion, and how the wreck is situated on the seabed.
Several case studies speak to these efforts, here I discuss three: SS Jacob Luckenbach, USS
Mississinewa, and SS Bloody Marsh. Remediations of polluting wrecks have typically been conducted
as reactionary spill response rather than proactive remediation of retained petroleum cargos. However,
the approaches and methodologies employed on these early remediations have assisted in developing
our understanding of removal efforts and how to assess sites. The lessons learned from these

1

�remediations have informed later work and guided the various studies that have begun to standardize
approaches to pollution mitigation from shipwreck sites.
SS Jacob Luckenbach
In 1953, the 164-m C-3 freighter SS Jacob Luckenbach collided with its sister ship in the fog offshore
San Francisco when departing for Korea with full bunkers. All crew members were rescued as the
vessel sank to a depth of 53 meters (m) in less than 30 minutes. A series of mystery oil spills were
observed in the 1990s, and possibly going back as far back as the 1980s, and a group consisting of the
US Coast Guard, California’s Office of Spill Prevention and Response together with NOAA’s Office
of National Marine Sanctuaries (ONMS) searched for the source of these spills in 2001 (Symons and
Parker-Hall 2003). NOAA’s involvement as a trustee for ocean resources included the ONMS
because the wreck lies within the Greater Farallones National Marine Sanctuary protecting significant
natural and cultural resources. Leading up to this, thousands of oiled birds had washed up along
California beaches (Michel et al. 2005). Samples of the oil were chemically fingerprinted to the
bunker fuel carried on Jacob Luckenbach. A salvage operation was undertaken in May 2002 to
determine the amount of oil remaining on the wreck and remove as much as possible. Many of the
fuel tanks were found to have badly corroded piping and vents, which caused the oil to leak into cargo
tanks; the assessment identified numerous spaces on the wreck that were estimated to contain 540 tons
of heavy fuel oil (Michel et al. 2005). After 123 days on site, the operation removed 350 tons of oil
from the wreck.
The pollution remediation of the Luckenbach wreck was the first major one performed by the United
States. Its location in a sanctuary further complicated the effort due to environmental impact concerns
and mitigation. Approximately 85,000 gallons of oil were removed leaving an estimated 29,000
gallons of the oil within the wreck likely in small overhead spaces within the structure. The project
was also viewed as a restoration action that addressed the immediate threats to the marine life and
environment (Symons and Parker-Hall 2003).
USS Mississinewa
USS Mississinewa (AO-59) was a 553-ft T3-S2-A1 type auxiliary oiler launched in the spring of
1944. The oiler carried a cargo of 146,000 barrels of aviation fuel and Navy Special fuel oil (Gilbert et
al. 2003). While at anchor at Ulithi in the Federated States of Micronesia in November, the tanker was
struck by a kaiten, a Japanese human-piloted torpedo, which caused a large explosion that sprayed
fuel across the ship that set it ablaze. The aviation fuel caused a second explosion, followed by a final
one when the flames reached the ammunition magazine. The ship capsized and sank, extinguishing
most of the fires. Sixty-three sailors died in the attack. It was the first known successful use of a
kaiten (Mair 2008).
A team of adventure divers located the wreck in 2001 in the Ulithi lagoon at a depth of 38 m. Soon
after, a typhoon hit and caused the surrounding beaches to be “fouled by heavy oil leaking from the
vessel” (Gilbert et al. 2003, 175). The oil continued to leak for months causing the Governor of Yap
State to declare a state of emergency. U.S. Navy divers patched leaks in 2001, and then conducted a
more extensive oil removal operation in 2003. The bow of the tanker had been blown off during the
attack and lies at 90 degrees on its port side while the rest of the wreck is fully capsized on the seabed,
which presented the removal team access to the cargo tanks (Naval Sea Systems Command 2003).
Approximately 6,000 tons of oil was removed from the wreck and pumped onto a barge. Oil remains
on the site, but is only residual oil in the piping, likely less than 50 tons (Michel et al. 2005). The
removal operation was more straightforward than at the Luckenbach wreck due to the inverted
position of the wreck and the warmer waters, which made moving the heavy fuel oil easier and better
visibility for divers.
A similar oil removal operation was conducted by the U.S. Navy on the wreck of the German heavy
cruiser, Prinz Eugen in 2018. The vessel had been a target ship at Bikini for Operation Crossroads

2

�following its capture by the US at the end of the war. After the nuclear tests, the ship was towed to
Kwajalein Atoll, where it capsized and sank in shallow water against the reef. The removal operations
recovered nearly 230,000 gallons of oil from the wreck, which had been leaking into the waters of the
atoll (Naval Sea Systems Command 2019).
SS Bloody Marsh
Recent ocean exploration efforts located the wreck of SS Bloody Marsh in deep water off the coast of
South Carolina in 2021. The T2-SE-A1 tanker was sunk with two torpedoes by U-66 on its maiden
voyage from Texas to New York with a cargo of more than 100,000 barrels of heavy fuel oil (NOAA
2013b). After an initial attempt to find with wreck by NOAA ship Okeanos Explorer in 2019, we
were provided satellite data from colleagues in the UK who had found a series of oil slicks in the area
of the tanker’s reported sinking that had been repeating since the 1990s. A second mission with
Okeanos conducted additional multibeam mapping in the area and located a target, which when dived
on with the ship’s ROVs, was identified as the wreck of Bloody Marsh. The stern and area of the
engine room was severely damaged from the first torpedo strike, and the forward 100-feet or so of the
tanker were missing and this bow section is ostensibly somewhere nearby. The main part of the wreck
is the completely inverted hull, identified through its welded joinery and overall dimensions. The
welded seams and hull plates are fairly intact in this main section, and the leaking oil is likely
stemming from ruptured tanks near the areas of torpedo damage rather than corroding plate seams.
The wreck, however, due to its intact and inverted state, is expected to likely contains a large amount
of the oil cargo it carried.

RESOURCES
The resources available to conduct pollution risk assessments of potentially hazardous shipwrecks
typically start with desktop and historical research, followed by site inspection and then remediation,
when warranted. However, often, remediations are reactive rather than proactive and sometimes must
start with patching leaks and move to direct remediation and oil removal, as was the case with
Mississinewa. Studies like the RULET work, NOAA’s PPW study, and the International Oil Spill
Conference work by Michel and colleagues have done much to lay the groundwork for standardized
approaches to stepped assessments and informed remediations. Estimates of 20,000 PPWs convinced
Congress to appropriate $1 million for NOAA to identify and prioritize the most ecologically and
economically significant PPWs in U.S. waters for inclusion into USCG regional and area contingency
plans resulting in NOAA’s 2013 PPW study.
NOAA’s PPW study began with an assessment of nearly 20,000 historic era shipwrecks that had the
potential to pollute that lay within the territorial waters of the US Exclusive Economic Zone (EEZ).
Through systematic assessment and detailed historical research, as well as assessing available
archaeological data, the list was ultimately reduced to 87 shipwrecks that had the greatest potential to
pollute. However, fewer than half of the 87 wrecks identified as highest priority in the PPW study
have been found, in a large part because they were sunk away from the coast and lie in deep water.
While desktop assessments of historical accounts of petroleum cargoes and the sinking events are
essential, those only go so far. Locating and assessing the shipwreck sites themselves is imperative,
especially now that wrecks from World War II are now passing their 80th year in the marine
environment undergoing corrosion. Expanded efforts for targeted ocean exploration to find potentially
polluting wrecks is necessary to understand the scope of the pollution threat posed by these wrecks.
Since its 2013 study of PPWs, NOAA’s ONMS Maritime Heritage Program, and Ocean Exploration
assessed two of the 87 wrecks: MV Fernstream, wrecked in 1952, lies in shallow waters inside San
Francisco Bay, and SS Coast Trader, a World War 2 (1942) combat loss in the Straits of Juan de
Fuca, between the state of Washington and Canada’s Province of British Columbia. These
assessments determined that all the oil had been released when Fernstream sank, and approximately
half of the oil had been released when Coast Trader sank, but that the other half remained in the

3

�intact, and essentially non-corroded forward hull of the wreck. Bloody Marsh was the third such
assessment, this time undertaken by NOAA Ocean Exploration collaborating with the author. While
the wreck of Bloody Marsh was thankfully relatively intact and indicative of a stable hull, we also
learned that the hull was inverted and containing a substantial percentage of its cargo. It is not a
matter of if that will spill out, but when, and at what rate, either slow leaks or catastrophic.

FRAMEWORK
The research questions regarding addressing pollution concerns from shipwrecks include standardized
steps to be taken among stakeholders to best mitigate their pollution risks. While there is no consensus
on a single comprehensive approach for pollution remediation between nations who have dealt with
the issue, approach typically taken is incident specific and requires evaluation of the wreck,
environmental conditions, risk reduction, and potential for catastrophic pollutant release (Landquist et
al. 2013, 91; Etkin et al. 2009). The determination of a shipwreck as potentially polluting does not,
however, negate its significance as a historic site. While the pollution risk from wrecks can pose a
threat to ocean heritage, the potential hazard also poses a risk to the archaeological integrity of the
historic sites. NOAA’s Remediation of Underwater Legacy Environmental Threats (RULET) project
was designed to assist “in prioritizing potential threats to ecological and socio-economic resources
while at the same time assessing the historical and cultural significance of these nonrenewable
cultural resources” for shipwrecks in US waters (NOAA 2013a, 1). As a US agency, NOAA is
required to comply with federal laws that protect natural and cultural resources. Therefore, the
RULET work not only assessed which shipwrecks in U.S. waters might pose a risk of polluting, but
also whether they met the standard for listing on the National Register of Historic Places.
To narrow down the list of shipwrecks in US waters that could pose a pollution threat, the RULET
study used a series of risk factors to assess the potential structural integrity of those identified wrecks
and the oil remaining on board, and oceanographic factors that might influence removal operations.
These include the amount oil on board, if the wreck had been demolished as a risk to navigation, if a
large amount of oil was lost during the sinking, and the nature of the sinking event (NOAA 2013a,
ES-3). Responses included a variety of options from leaving shipwrecks alone and responding to leaks
or spills as they arose, to full oil removal and salvage. Intermediate options include background
research for wreck-specific response plans, site monitoring, and in situ assessments through remote
sensing and ROV documentation (NOAA 2013a, 74).
Factors affecting response options include the type and volume of oil on board, water depth and
visibility, location relative to shore, and other site factors like the wreck orientation. The study also
addresses the potential impact of remediation on shipwrecks’ historical integrity: “this vessel is of
historic significance and will require appropriate actions under the NHPA and the Sunken Military
Craft Act (SMCA) prior to any actions that could impact the integrity of the vessel” (NOAA 2013b,
6). Such assessments are important in protecting shipwrecks that are historically significant and war
graves. However, for many of the shipwrecks in the NOAA PPW study, they have yet to be located,
so the response options are high level and all encompassing.
The U.S. Coast Guard, which would lead, coordinate, and often contract for the remediation of
polluting wrecks, is required under Section 106 of the NHPA to consider adverse effects to the PPWs
that are also historic properties (Symons et al. 2014, 2024). In an emergency response situation, there
is often insufficient time to adequately comply with the NHPA, to determine if a wreck warranted
mitigation because it was listed in or was eligible for the National Register of Historic Places
(NRHP). What was needed was a proactive approach that streamlined the process. Thus, the
responsible federal agencies entered into the NHPA Section 106 Programmatic Agreement (PA) to
ensure that historic properties are considered in their planning for and conduct of the emergency
response under the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

4

�Following the larger contextual study, NOAA’s Maritime Heritage Program evaluated three
representative shipwrecks with a high pollution potential to determine which characteristics and
historical associations would be eligible for the NRHP, meet the definition of a historic property, and
would then be subject to Section 106 consultation should the Coast Guard move forward with
assessment and pollutant recovery activities (Symons et al. 2014, 2025). The three wrecks nominated
as tests were the WWII combat losses of SS Lancing, SS Empire Gem, and SS Coimbra. All three
were pollution risks and lie off the coast of North Carolina and New York. The results include how
they were accepted and listed in the NRHP.

RESULTS
The expected results of this combination of historical research and on-site assessments and
remediations is a greater understanding of how to efficiently and effectively mitigate pollution risks
from sunken oil tankers and other potentially polluting wrecks. Modern technology has allowed for
better access to sites in deep water and will continue to improve the process. However, not only are
there more potentially polluting wrecks that have yet to be found and assessed, there are actively
leaking wrecks in US waters and elsewhere.
Satellite detection of oil slicks, such as that which led us to the wreck of Bloody Marsh, has located
repeating slicks over areas of deep water that have yet to be explored, but likely point to the locations
of other PPW sites. However, the cost is high of bringing vessels and deep-water survey equipment to
those remote areas offshore. Additional dedicated funds and resources need to be brought to bear to
address these polluting sites. Some of these documented repeating slicks are off the eastern seaboard
of the United States along the path of the Gulf Stream and, were a catastrophic release to occur, could
oil a large area of the east coast shoreline (NOAA 2013a, 2013b).
Expanded ocean exploration, targeted efforts to find and assess potentially polluting wreck sites, and
the implementation of new technologies, such as satellite detection of oil slicks, is imperative to
addressing this problem and mitigating the environmental hazard these wrecks pose.

ACKNOWLEDGEMENTS
I’d like to thank The Ocean Foundation, Lloyd’s Register Foundation, Ole Varmer, Mark Spalding, James Delgado, and
Charlotte Jarvis for their support and assistance in preparing this manuscript.

5

�BIBLIOGRAPHY
Etkin, D.S., van Rooij, H., McCay French, D., Risk assessment modeling approach for the prioritization of oil removal
operations from sunken wrecks. Effects of Oil on Wildlife. Estonia: Tallin, 2009
Gilbert, Trevor, Sefanaia Nawadra, Andy Tafileichig, Leonard Yinug, 2003. Response to an Oil Spill from a Sunken WWII
Oil Tanker in Yap State, Micronesia. International Oil Spill Conference Proceedings 1, (2003): 175-182.
Landquist, H., I.-M. Hassellöv, L. Rosén, J.F. Lindgren, I. Dahllöf,. Evaluating the needs of risk assessment methods of
potentially polluting shipwrecks. Journal of Environmental Management 119 (2013): 85-92.
Mair, Michael. “Oil, Fire, and Fate: The Sinking of the USS Mississinewa AO-59.” WWII by Japan’s Secret Weapon.
Platteville, WI: SMJ Publishing, 2008.
Michel, Jacqueline, Trevor Gilbert, Jon Waldron, Charles Blocksidge, Dagmar Schmidt Etkin, Robert Urban. Potentially
Polluting Wrecks in Marine Waters, 2005 International Oil Spill Conference, IOSC 2005.
NHPA Section 106 Programmatic Agreement (PA) to ensure that historic properties are taken into account in their planning
for and conduct of the emergency response under the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP) (2002, signed 1997) https://www.nrt.org/sites/2/files/Programmatic_Agreement_on_Protection_of.pdf
Naval Sea Systems Command, U.S. Navy Salvage Report, USS Mississinewa Oil Removal Operations. Naval Sea Systems
Command, S0300-B6-RPT-010, 0910-LP-102-8809, 2003.
Naval Sea Systems Command, U.S. Navy Salvage Report, Ex-USS Prinz Eugen Oil Removal Operations. Naval Sea
Systems Command, S1740-AK-RPT-010, 0910-LP-118-8301, 2019.
NOAA. Risk Assessment for Potentially Polluting Wrecks in U.S. Waters. 2013a
&lt;https://nmssanctuaries.blob.core.windows.net/sanctuariesprod/media/archive/protect/ppw/pdfs/2013_potentiallypollutingwrecks.pdf&gt;. Accessed 6 April 2022
NOAA. Screening Level Risk Assessment Package: Bloody Marsh. 2013b
&lt;https://nmssanctuaries.blob.core.windows.net/sanctuaries-prod/media/archive/protect/ppw/pdfs/bloody_marsh.pdf&gt;.
Accessed 6 April 2022.
Symons, Lisa, and Heather A. Parker-Hall. “The SS Jacob Luckenbach: Integration of NOAA Trust Issues into the
Response.” International Oil Spill Conference Proceedings 2003 1 (2003): 649-653.
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Resource Consultation and Compliance for Pollution Assessment and Recovery Activities on Shipwrecks. International Oil
Spill Conference Proceedings 2014 1 (2014): 2024–2036.

6

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                <text>Brennan, Michael L.. 2023. “Assessing Potentially Polluting Wrecks in US Waters.” Edited by Jennifer Craig, Jay Mok, T. Kurt Knoerl, and Ole Varmer. In Proceedings of Fifth Asia Pacific Regional Conference on Underwater Cultural Heritage: Gwangju, The Republic of Korea, November 13-18 2023. The Museum of Underwater Archaeology. URL: https://apconf.omeka.net/exhibits/show/apconfproceedings/item/1902 </text>
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