Draft Scottish Marine Litter Strategy: Analysis of Consultation Responses

Question 14 - 17 Strategic Direction 3

• Strategic Direction 3: Contribute to a low carbon economy by treated 'waste as a resource' and seizing the economic and environmental opportunities associated with the zero waste plan

Q14. What are your views on the possible actions?

Q15. Which do you believe is the most important possible action in helping to deliver the Marine Litter Strategy?

Q16. 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?

Q17. Do you think any of the existing actions need to be improved?

For the purposes of analysis, Questions 14 - 17 will be considered together based on the comments received to the consultation.

88 respondents provided comments on Strategic Direction 3. There was particular concern amongst 66 (75%) individuals who submitted a standard response and specifically expressed a view that two of the existing actions outlined in the consultation document under Strategic Direction 3 should be listed under 'Possible' actions. The existing actions referred to were as follows:

• Encourage port and harbour reception facilities to drive separate collection.
• Deliver a project to establish free fishing net disposal at a network of fishing ports across Scotland, to include the infrastructure to recover and recycle the nets and other plastics recovered from fishing operations.

10 further respondents (one private individual and a mixture of organisations) expressed a similar view, and there was a general perception that it was unclear which existing actions outlined under Strategic Direction 3 were currently underway, and in which locations across Scotland. Five of those respondents specifically requested that the two existing actions highlighted be added to the possible actions list, and implemented. Additional comments provided are summarised below:

• Two respondents highlighted that the establishment of a free scheme for disposal of fishing nets at fishing ports would require to be adequately resourced.
• One respondent commented that if both actions, highlighted above, are indeed taking place they should be improved by enforcement, appropriate infrastructure and encouraging business and industry to develop a market for recycled materials.
• Four respondents suggested that an additional action of enforcement be added to the list of possible actions. It was also suggested that a review be undertaken on a perceived lack of enforcement of existing activities.
• One respondent highlighted that they would like to see many of the existing actions at a more advance stage.
• One respondent expressed a view that some of the existing actions are not at a stage where they can be considered a success or not, and efforts must be made to implement them and review their effectiveness.
• One respondent made commented that the actions need timescales as it is not clear if they have been implemented already, and also suggested changes to the wording of both actions - 'To provide' or 'To make available' should replace 'Encourage' under action point 2; and action point 3 should include 'beach cleans'.

18 respondents offered substantive comments on the possible actions outlined in the consultation document. The majority were broadly supportive of both possible actions, however, the points that were noted in the responses included clarity on deliverables; actions to enforce and incentivise recycling; and engagement with industry and local authority waste plans. Five respondents stressed the need to ensure a joined up approach, and the importance of ensuring links with the Zero Waste Plan, regional marine plans and co-ordination with delivery bodies, including Zero Waste Scotland, Local Authorities, The Crown Estate and private landowners.

One respondent made a general comment that Strategic Direction 3 should be more specifically linked to land and marine based sources of litter and clarified to further explain how the actions would impact on the problem of marine litter.

In response to Question 14, 12 (67%) respondents indicated that both possible actions outlined in the consultation document are significant and will enable recycling and reuse of materials. One respondent commented that while both actions had merit, they can only be implemented fully if there are end-user manufacturers, and it is important to link to efforts to engage industry.

One respondent indicated that investing in technologies that facilitate recovery and monitoring was the most important possible action and highlighted that this would require new actions.

One respondent expressed a view that the recycle and reward pilot is the most important action, however, also believed that possible actions should be investigated to generate financial assistance for clean technologies.

One respondent mentioned that a consistent approach to waste collection for recycling would be beneficial, and thought that the Strategy should encourage more research into recycling schemes, particularly those being carried out in other countries.

One respondent stated that they would support a Recycle and Reward pilot if such an initiative would not place additional financial burdens on Local Authorities. Further to this, one respondent highlighted that this pilot would need further consideration and engagement with local authorities, as it may have a negative impact on local waste services.

In response to Question 15, one respondent stated that seeking opportunities to incentivise recycling and correct disposal was the most important potential action. One respondent stated that investment in new technologies and environmental monitoring is essential, and four respondents commented that Marine Scotland must take responsibility for the monitoring of industry and enforcement of legislation. One respondent commented that the action looking to incentivise correct disposal is likely to have more impact on the amount of marine litter generated locally.

In response to Question 16, one respondent commented that additional work was required on 'producing waste as a resource', and on schemes to recover and recycle fishing nets.

In addition, respondents offered suggestions for improvement; or issues that they felt should be addressed:

• One respondent suggested that the redesign of products should be included alongside looking for opportunities to incentivise recycling.
• Two respondents suggested that targets should be considered to ensure that existing actions are delivered.
• Two respondents suggested that there is a need for investment into research and development of recycling routes, and end markets have to be identified.
• One respondent mentioned marine sector requirements linked to other areas of environmental legislation, in particular reference was made to the Waste (Scotland) Regulations 2012.
• One respondent suggested that more advice is needed for beach clean volunteers regarding what marine litter can appropriately be recycled.
• One respondent emphasised the importance of addressing waste at source, and the need for consumer awareness of the negative impacts of incorrect disposal of non-biodegradable waste on networks that serve Waste Water Treatment Works.
• One respondent highlighted that a lot of marine based litter, which is recovered, is not suitable for recycling.
• One respondent suggested that additional measures should be considered to encourage manufacturers to use the types of materials that would facilitate recycling and make correct disposal easier for consumers.