Draft Scottish Marine Litter Strategy: Analysis of Consultation Responses

Question 10 - 13 Strategic Direction 2

• Strategic Direction 2: Reduction of land-sourced marine litter entering the marine environment, in parallel to the National Litter Strategy

Q10. What are your views on the possible actions?

Q11. Which do you believe is the most important possible action in helping to deliver the Marine Litter Strategy?

Q12. Can one or more of these possible actions be delivered under existing activities or do you think more action is needed under the Marine Litter Strategy?

Q13. Do you think any of the existing actions need to be improved?

For the purposes of analysis, Questions 10 - 13 will be considered together based on the comments received to the consultation.

89 respondents commented on Strategic Direction 2. There was particular concern amongst 67 (75%) individuals who submitted a standard response and specifically expressed a view that the existing actions outlined in the consultation document under Strategic Direction 2 should be listed under 'Possible' actions. The existing actions referred to were as follows:

• Co-ordination with Zero Waste Scotland activity.
• Improve enforcement of ship waste management plans and inspections of Garbage Record Books under the Merchant Shipping (Prevention of Pollution by Garbage and Sewage) Regulations 2008.
• Incorporation of waste management systems into the design of new vessels.
• Extend existing Port Waste Reception Facilities to include fishing vessels.
• No-special-fee reception facilities and compulsory discharging of marine litter in port for all vessels including fishing boats.
• Research into recycling and reuse facilities for fishing nets at ports.
• An anonymous system to report vessels illegally dumping waste at sea.
• Incorporation of environmental responsibilities into the education and training of ship owners, ship operators, crews, port users, fishermen and recreational boat users.
• Plastics industry code of conduct for the safe handling, packaging and transportation, by sea of plastic pellets.

This view was reinforced by comments from a further 10 respondents (1 private individual and a mixture of organisations) who felt that many of the existing actions may not currently be happening to the level required or sufficiently enforced, or were in the very early stages of implementation. One of those respondents specifically requested that actions 2-9 be listed under the possible actions list, and considered for implementation.

Additional comments provided are summarised below:

• One respondent expressed a view that they did not believe the existing actions were being implemented sufficiently to achieve Strategic Direction 2, or the wider vision.
• Two respondents suggested that many of the existing actions are not currently happening.
• Two respondents suggested that the actions identified are not at an advanced stage.
• One respondent commented that there has been little or no positive action implemented on the ground.
• Two respondents suggested that the existing actions need to be strengthened, with more detail, to lead to a measurable reduction in marine litter.
• One respondent commented that these actions may not be happening at all ports across Scotland. It was suggested that a new action could be to assess the existing actions to identify how they are working; and what the geographic spread is of them.

In general comments about Strategic Direction 2, four responses felt that Strategic Direction should make provision for both land and sea based sources of marine litter, and stipulate land and marine sourced litter in its description. One respondent suggested that it may be appropriate to develop a 2-tiered Strategic Direction which addresses the issue of land sourced and sea sourced litter.

Two respondents requested more detail regarding specific actions which should be taken forward as part of the National Litter Strategy, and have a direct benefit on the incidence and amount of marine litter.

15 respondents commented on Question 11. 8 (53%) of respondents commented that both possible actions outlined in the consultation document were of equal importance. One response suggested that both actions would contribute equally to achieving the outcomes of the Marine Strategy Framework Directive.

Six respondents thought that the Fishing for Litter initiative should continue to be encouraged, and its expansion explored. It was suggested that it could contribute to education programmes, with one respondent suggesting that thought should be given as to how and by what means the message is delivered. It was also highlighted that the success of the initiative depends on the availability of facilities for the disposal of collected waste. One respondent thought that that there should be more public recognition of work already achieved through the initiative to reduce litter.

Six respondents indicated that incorporating marine litter into regional plans was an important measure. Two of those responses highlighted that there would be a need to identify how performance will be measured and reported. A further respondent highlighted that regional planning must include a duty to reduce marine litter. Another respondent commented that it should not add an additional layer to existing legislation. Two respondents highlighted that the National Marine Plan should set the framework for how marine litter reduction can be incorporated into regional marine plans.

One respondent commented specifically on Question 12 and indicated that the possible actions could be delivered under any existing schemes. However, it was suggested that some of the existing actions need to incorporate specific activities to address land sourced marine litter.

In responding to Question 13, two respondents felt that better enforcement was required to fully realise the actions. One respondent felt that the actions were ambitious given the international nature of shipping and its regulation. Three respondents suggested that existing actions could be improved by imposing deadlines. It was also highlighted that many of the actions rely on decisions made at the EU or international level and Scotland should look to implement best practice at the earliest opportunity.

A range of views were expressed and suggestions provided on other possible actions as follows:

• One respondent suggested that it may be appropriate to amend the associated actions for Marine Scotland, and the responsible sections of Scottish and UK government, to focus on contributing to national and international efforts to change vessel and training requirements. It was also suggested that action could be taken to review the requirements of the UK regulations on International food waste.
• One respondent suggested that consideration could also be given to looking at the opportunities for marine litter clean ups at sea in post-storm conditions.
• Two respondents expressed a view that where possible, duty bodies should identify and support opportunities for recycling and reuse of coastal and maritime sources of litter.
• One respondent commented that marine users such as fishing vessels, shellfish farms and other smaller commercial enterprises should be encouraged to have waste management plans. The respondent also highlighted an area of concern for marine operators on the issue of who is responsible for regulation of marine litter.
• Four respondents commented that the issue of Sewage Related Debris should be incorporated into the list of actions. Two of those respondents suggested the reintroduction of a public education campaign on this issue.
• One respondent suggested the development of a mariner course for those in the shipping, fishing and recreational sectors.
• One respondent suggested that co-operation with Scottish Water should be included as a potential action.
• One respondent suggested that mechanisms should be explored to ensure the return/recovery of prevalent items of marine litter e.g. fishing nets.
• One respondent suggested that a scheme to report inappropriate waste disposal could be extended to land based businesses.