Marine litter strategy for Scotland: consultation analysis

5. Strategic Direction 3

Strategic Direction 3: Support the removal of marine litter from the marine and coastal environment.

Context

5.1 Significant action that supports the removal of marine litter from the marine and coastal environment is already underway from a wide variety of organisations. These range from small community groups to national NGOs. Some initiatives have been in existence for many years or decades and play a significant part in Scotland's work to tackle marine litter.

5.2 Planned actions within the refreshed Strategy will include, for example:

• An expansion of work to remove litter from rivers, thereby preventing this reaching the marine environment.

• Improving the efficacy of projects which remove litter from the sea and investigating the potential for an initiative to recycle the material collected.

Question 5: To what extent do you agree or disagree that the planned actions under each objective will contribute to the achievement of Strategic Direction 3?

5.3 Table B10 to Table B13 (Appendix B) provides the frequency tables to Question 5.

5.4 The vast majority of respondents (individuals and organisations) agreed (i.e. agreed or strongly agreed) that the planned actions under each of the following four objectives would contribute to the achievement of Strategic Direction 3:

• Reduce the cost of disposal of collected marine litter (84.4%).
• Increase the number of rivers in Scotland with co-ordinated projects to reduce litter levels, including removal (91.3%).
• Expansion of the Fishing for Litter project (89.7%).
• Installation of riverine litter removal technology in the River Clyde (84.5%).

Question 6: Do you consider there to be any omissions or gaps in the planned actions identified under Strategic Direction 3 in the Consultation Document that could help to contribute towards its achievement?

5.5 Views were relatively mixed - approximately one-third (38.0%) of respondents considered there to be omissions or gaps in the planned actions identified under Strategic Direction 3, Table B14. A similar proportion were unsure.

5.6 Organisations were more likely to report that there were omissions or gaps compared to individuals, in particular those with a focus on the issues of coastal development and conservation, communities, or environment and conservation.

Omissions or Gaps identified

5.7 The wider qualitative feedback has been grouped under each of the four objectives identified for Strategic Direction 3.

Reduce the cost of disposal of collected marine litter

5.8 The planned action under the objective of 'reduce the cost of disposal of collected marine litter' is to 'explore a mechanism to assist communities to reduce costs in disposing of large volumes of collected beach litter'. This attracted qualitative feedback from around half of respondents who considered there to be omissions or gaps.

5.9 The main groups of respondents who commented on this included organisations with a focus on the issues of coastal development and conservation, communities, or the environment and conservation, as well as from individual respondents.

5.10 The main points raised include:

• It was noted across consultation responses that there could be stronger reference to "beach cleaning", the "volumes of plastic washing ashore on the coast of Scotland" and "the massive amount of work undertaken by local individuals, community groups and NGOs".
• Aligned to the point above, it was proposed by an organisation respondent that beach cleaning could be considered "as a stand-alone objective within this Strategic Direction". Wider feedback from respondents suggested that Marine Scotland could consider "supporting major beach cleaning operations in the most polluted areas" or "target efforts in areas not covered by volunteer schemes, or those too inaccessible to be cleaned without specialist support". Consultation responses highlighted that more work or action was needed to "aid removal on remote and rural mainland beaches" as "many face barriers to marine litter removal due to the amount of litter and the logistics of removing it from the beach and transporting it to a waste facility". Such activity was also said to "create a disproportionate cost" in these communities.
• Litter picks in Scottish towns and cities ("urban beach cleans"), were said to play an important role in helping prevent litter from reaching the sea in the first place. Further, beach cleaning operations in the most polluted areas could also help "complement the prevention of pollution entering the ocean via the river project in the Clyde and joining the KIMO 'Fishing for Litter' scheme". In cities where communal rubbish bins are in use on the street, it was felt that these should be secure and emptied frequently to prevent wind blowing rubbish onto the streets.
• The significant reliance on the "goodwill of volunteers to remediate ocean plastic pollution generated on land and at sea" was commonly highlighted in consultation responses. A suggestion was that "professional surveying and cleaning by trained personnel is required to fully grasp the intensity of the pollution", and that it was important to not rely on volunteer efforts alone.
• The planned action's key deliverable i.e. to provide 'information to assist relevant parties (e.g. community groups, NGOs) to dispose of large volumes of beach litter without prohibitive financial costs' also drew feedback from respondents, namely that on its own the objective of reducing the cost of disposal of collected marine litter could be difficult to achieve. The main points raised were that:
  • The deliverable appeared to focus on the provision of information only and did not provide any wider "commitment of human resources (paid staff)" to support overall achievement of the objective. This could result in increased "reliance on local volunteers".
  • There should be "no cost" to volunteers, etc associated with disposing of beach litter.
  • Actions perceived missing under this objective included those that could support a more "coordinated approach" involving all relevant parties, and "investment in marine litter clearance" by the Scottish Government.
• Further, there was a request for actions that provide increased funding/ support to enable "local authorities to make collection and recycling much more accessible" and convenient. For example, by providing more skips free of charge for beach cleaning purposes at marina, port and beach locations, more recycling bins, larger litter bins, and marine litter safe disposal areas. Here, it was noted that the "level of support across local authorities differs greatly" and that "voluntary groups in many areas are expected to fund their own skips - £500 each". Additional financial support for local authorities was considered necessary "otherwise people are discouraged from picking up items from their local beaches, etc". Implementing measures to ensure marine (and all) waste/litter was managed responsibly and dealt with sustainably to avoid beach litter going to landfill (e.g. recycle, reuse and repurpose) were considered vitally important. Another viewpoint expressed was that the provision of skips could be "collected and paid for jointly" by relevant industries and fishing grants".

5.11 The following quotes reflect the points raised:

"We know from the communities and community-groups who conduct beach litter picks that local authorities are struggling to facilitate and pay for the removal and disposal of fishing gear found on beaches. Many of the groups that we work with are having to deal with it themselves; in some cases, this is deterring groups from litter picking on beaches, as the waste that they collect will not be picked up. We do not believe that the action to 'explore a mechanism' and the related deliverable of 'information to assist relevant parties' goes far enough in terms of contributing to the achievement of the objective. Volunteers, often as part of community groups or NGOs, are vital players in the remediation and clean-up of marine litter, and the disposal of the litter they collect should never cost them money. Therefore, there is scope for the cost of this to be met via a comprehensive EPR scheme".

Keep Scotland Beautiful

"Work with councils to make it clear and obvious what is to be done with large amounts of litter collected by volunteers, including litter that might be brought to shore in remote areas, such there is little difficulty and no cost for those volunteers".

Individual

"The polluter should pay……properly involve themselves in clearing up beach…. Communities should not have to pay a single penny to clear up litter on their beaches - nor should they have to do the work themselves".

Individual

"A particular challenge…. on marine litter, is on understanding who is responsible for the collection and disposal of litter on the coast and foreshore…..most of this falls to the Local Authority but there is ambiguity around the extent of their responsibility and for which types of litter and in which locations. Clarity on this would be useful so that people know who is responsible and who to contact. Likewise, the establishment of for example a recognised hotline that community groups/members of the public etc can contact on litter issues would be useful. Local Authorities would benefit from increased resources to ensure they are able to pick up litter that is collected both by individuals or community groups. Marine litter is often found in remote locations which are difficult to reach and/or difficult to arrange collection. It would be useful for the Strategy to put mechanisms in place able to address these issues. As a starting point, it would be useful to undertake an assessment of facilities available, opportunities for transportation to a central facility or hub and the need for short-term storage of marine litter".

Crown Estate Scotland

"….employing someone to clean, monitor and survey is the most effective way to clean the coastline. This method drastically increases the quantities of plastic being removed and it increases the efficiency of cleaning, thus allowing more coastline to be covered than by just relying on volunteers".

Plastic@Bay

"It is not just the cost of disposal of collected marine litter that is the problem but also the convenience of the process. Some recreational boaters have cleaned beaches in remote areas but sometimes all that can be done is to pile plastic above the high-water mark. There are regrettably few places where the amount of beach litter can be considered small, but disposing of even small amounts of litter can pose problems…..Collecting marine litter provides the start of a awareness journey for many, with beach cleans being central to organisations taking action, or being seen to take action, on environmental issues".

Royal Yachting Association (RYA) Scotland

"Work inland, both on rivers and in strips of land adjacent to the coast, is important in reducing marine litter. Beach cleans are the final opportunity to stop litter, often generated inland, from entering the sea. However, beach cleans, indicate a failure of systems elsewhere and a need to direct policy at sources of marine litter rather than the end product".

Think About Plastic - Arran

5.12 Within its response, the Marine Conservation Society noted its support for the actions but recommended "a cost benefit analysis was done on these projects" (i.e. the action to 'explore a mechanism to assist communities to reduce costs in disposing of large volumes of collected beach litter' and the action to 'expand the Keep Scotland Beautiful Upstream Battle project or equivalent riverine project' – see below) "to ensure effort and funds are deployed for the highest environmental gain" and to "assess impact for future investment".

Increase the number of rivers in Scotland with co-ordinated projects to reduce litter levels, including removal

5.13 The planned action of 'expansion of the Keep Scotland Beautiful Upstream Battle project or equivalent riverine project' that sits under the objective to 'increase the number of rivers in Scotland with co-ordinated projects to reduce litter levels, including removal', attracted the following commentary.

5.14 The range of points raised centres on the following:

• Keep Scotland Beautiful noted that the continuation, scaling up and extension of such projects were important in terms of "preventing marine litter by stopping those items littered in the terrestrial environment from reaching the sea".
• Wider comments further highlighted the importance of preventing marine litter at source and tackling the problem upstream. Such comments noted the role and volume of land-based litter ending up in the sea, and the need for further action to "address litter reduction in rivers and estuaries", "reduce contamination from land and raw sewage", "direct policy at sources of marine litter" or a wider suggestion that "remote river monitoring schemes could be set up".
• Here, there was also feedback from other organisations involved in the Keep Scotland Beautiful Upstream Battle project. For example, Friends of Dumbarton Foreshore emphasised the growing issue of "unpickable micro and nanoplastics" on the shore, and that they expected to see "ever greater volumes of plastic waste… until production is stemmed".
• The UK and Ireland Spill Association highlighted the important "co-ordination" role of NGOs (Rivers Trust and their Scottish equivalents) in assisting with delivery of the objective to increase the number of rivers in Scotland with co-ordinated projects to reduce litter levels, including removal. The Association noted that such organisations could "access their volunteer banks to conduct much of this work. It would help their effort if they were able to display signs e.g. Volunteers from XXX charity help you to enjoy this beach/river/lake by collecting litter from it. It improves your enjoyment of it but protects our wildlife. Take your litter home. Want to help visit www.xxxxcharity.org".

5.15 A couple of comments related specifically to the key deliverable identified in the Consultation Document, namely that 'three of Scotland's main rivers to be involved in litter projects that include removal and responsible disposal of waste'. Here, the feedback from two individual respondents is presented below.

"A national Strategy is required to address litter reduction in rivers and estuaries. Why have only three rivers been included in the plans? Whilst I understand that some pilot schemes need to be tested for success…. I would urge that this pilot stage be set out as such with a timeframe and date for all rives and estuaries in Scotland to then be operationalised and included in the overall Strategy".

Individual

"Many of the above actions could/should extend to other river catchments".

Individual

Expansion of the Fishing for Litter project

5.16 Mixed views were provided on the two actions related to the 'expansion of the Fishing for Litter project' objective.

5.17 On the one hand, the action to 'promote the Fishing for Litter scheme within the fishing industry and to ports, harbours and fishers not currently participating' was welcomed and supported. Here there was feedback that considered the project to be a "good approach". Continuing to work in partnership with the commercial fishing industry was also considered vital.

5.18 There was wider feedback that highlighted the importance of the action being extended to include participation of "small fishing boats" and "all boats landing into Scottish ports".

5.19 The following quotes reflect the points raised.

"…the scheme does need expansion - and more funding - to be made available and easy to use in every dedicated fish landing port. It also needs more regular attention - to make sure that collection skips are always available and emptied, and that waste bags are available to fishing crews. As well as this, consideration should be given to a legal impetus to oblige all boats landing into Scottish ports to participate in the scheme. No vessels should be coming ashore to land fish, and not also be landing rubbish bags from the duration of their fishing trip".

Shetlands Fisherman's Association

"We would support the expansion to the Fishing for Litter project to increase recycling levels of gear and easy access to collection and recycling points. However, the cost of this must be borne through a comprehensive EPR Scheme".

Marine Conservation Society

"… an urgent need to see this scheme rolled out across the islands and west coast…. Although the role of communities is mentioned…. given the fundamental role that communities play in the removal of marine litter from the marine and coastal environment….actions to support this role would significantly strengthen the Strategy and its outcomes".

Individual

"The more boats that are Fishing for Litter the better – I think that forming solid relationships to train and support 'fisherman-scientists' could lead to the development of a group of mediators who could communicate more effectively between the 'government scientists' and people with lived experiences of working in the industry. The Fishing for Litter project could be the start of the process of training willing fishermen".

Individual

5.20 On the other hand, a couple of respondents (an individual, and a coastal development and conservation organisation) queried more activity aimed at encouraging those not currently participating to become involved in the Fishing for Litter scheme. This feedback was typically framed in the following terms:

• The scheme has been in place for many years and given the scale of marine litter problem (e.g. washed up on beaches, etc) it was difficult to conclude that the scheme had been successful.
• Disagreement was expressed that funding is proposed to continue to be awarded to the Fishing for Litter scheme "to appease the very industry that has caused the damage in the first place".

Installation of riverine litter removal technology in the River Clyde

5.21 The main points raised on the two actions relating to the 'installation of riverine litter removal technology in the River Clyde' objective can be summarised as follows:

• Some posed questions on the planned focus of use of riverine litter removal technology in the River Clyde only. Points raised included that it could be installed in "other rivers", known "hotspots" across the country, and/or that measures may need to be taken to clear up the banks and floor of its tributaries/other river catchments/include litter sinks in the rivers Kelvin, Cart, Forth and Clyde Canal, etc to achieve "significant impact".
• There was agreement with the action plan that the boom installed would need to be appropriately monitored and maintained – and followed up with effective community engagement.
• The technologies to remove waste in conjunction with the boom and the boom itself would need to be closely monitored to ensure no unintended consequences, for example, on wildlife and environment in the river.

Wider Points

5.22 Similar to wider points provided under other Strategic Directions, there were a variety of other comments that highlighted more general points that cut across the refreshed Strategy and Action Plan as a whole:

• The important role of education and awareness raising, including ongoing community and public engagement and involvement.
• Disappointment was expressed that the bottle and can return scheme in Scotland was delayed – it was reported that this could have had an "immediate and significant impact on the amount of plastic and glass bottles being littered and finding their way into the sea".
• Pollution from pharmaceuticals in rivers was identified as an increasing problem, "with UK rivers now identified as some of the most polluted by pharmaceuticals in Europe". KIMO UK suggested that implementation of measures to address this could be included under Strategic Direction 3 and/or Strategic Direction 4 – "starting with monitoring and a background report to assess the extent of the issue".
• Actions to share and promote research into the removal of micro plastics in the marine environment could be considered.
• That there could be further consideration of the use of incentives and/or fines/penalties and/or actions to restrict the production of plastic.