Marine litter strategy for Scotland: consultation analysis

6. Strategic Direction 4

Strategic Direction 4: Improve monitoring at a Scottish scale and develop measures for Strategy evaluation.

Context

6.1 It is widely recognised that the current evidence base for the levels of marine and coastal litter is limited, and the Strategy seeks to build on existing data capture and management measures so that we can help deliver appropriate and reliable data. This could help provide information on the types, quantities and distribution of marine litter, to provide an insight into the associated problems and threats, and to increase public awareness of the condition of the coastline.

6.2 The UK Marine Strategy is being implemented in a co-ordinated way across the UK Administrations. The UK Marine Strategy Part Two sets out proposals for UK monitoring programmes to monitor progress towards Good Environmental Status (GES), which will be reflected in the Marine Litter Strategy. Data collected for GES monitoring will facilitate reporting on whether the Marine Litter Strategy's aims and objectives are being met.

6.3 Planned actions for the Marine Litter Strategy for Scotland include, for example:

• Contributing to the development of an agreed methodology for inter-tidal microplastic monitoring.
• Improving the quality of the data being obtained from litter removal projects.

Question 7: To what extent do you agree or disagree that the planned actions under each objective will contribute to the achievement of Strategic Direction 4?

6.4 Table B15 to Table B19 (Appendix B) provides the frequency tables to Question 7.

6.5 The vast majority of respondents (individuals and organisations) agreed (i.e. agreed or strongly agreed) that the planned actions under each of the five objectives would contribute to the achievement of Strategic Direction 4:

• Use of Fishing for Litter initiative data to evaluate industry engagement (85.9%).
• Accurate assessments of marine plastics in Scottish waters (86.0%).
• Development of an agreed methodology for inter-tidal microplastic monitoring (82.9%).
• Social science evaluation of the Marine Litter Strategy (81.4%).
• An understanding of Scottish island beach litter (89.7%).

Question 8: Do you consider there to be any omissions or gaps in the planned actions identified under Strategic Direction 4 in the Consultation Document that could help to contribute towards its achievement?

6.6 Views were mixed. Around one-third each answered "yes", "no", or "don't know" to the question on whether there were any omissions or gaps in the planned actions identified under Strategic Direction 4, Table B20.

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

Omissions or Gaps Identified

6.8 The wider qualitative feedback has been grouped under each of the five objectives identified for Strategic Direction 4.

Use of Fishing for Litter initiative data to evaluate industry engagement

6.9 Around one-fifth of those respondents who considered there to be omissions or gaps in the planned actions identified under Strategic Direction 4 commented further on the objective regarding the 'use of Fishing for Litter initiative data to evaluate industry engagement'.

6.10 Many highlighted that debris and waste from the fishing industry accounted for a significant proportion of marine litter in Scotland citing both academic and anecdotal evidence (e.g. twine and ropes washed ashore).

6.11 For example, the voluntary organisation Plastic@Bay referred to a Marine Scotland study which reported that "fishing gear accounts for just 6% by abundance but 41% of the total weight of plastic found in beach surveys in North-East Scotland".

6.12 Several respondents emphasised the importance of weighing and sourcing to provide a more accurate assessment of marine litter.

6.13 The fact that the Fishing for Litter initiative addresses industrial marine litter at source underpinned much of the support for the planned actions to increase engagement with new and participating harbours and to improve the quality of data collection.

6.14 A wider point, raised by a few respondents, was that sufficient infrastructure, such as weigh bridges, would be required at harbours across Scotland to facilitate greater industry engagement. Further, capacity constraints within the fishing industry was also raised as a potential issue/challenge in terms of data collection.

6.15 The following quotes help to further illustrate some of the points outlined above:

"Provision of facilities to recycle marine litter is key. At present we understand that very little marine litter, and marine plastics in particular, is recycled with most going to landfill. This is due to a lack of dedicated facilities set up to recycle litter in Scotland. Provision of facilities in Scotland able to reprocess and repurpose recyclables would be positive."

Crown Estate Scotland

"Volunteers are not professional scientists and surveyors. They will generally participate in monitoring pollution during the summer months, when it is pleasant. The most populated areas will have the most volunteers and thus will be most surveyed."

Plastic@Bay

"We need weigh bridges or suitable machines which can accurately weigh what is coming in, unless the collecting venues have these facilities; weighing area at every port ~ could beach cleaners have similar skips for fishing gear retrieved from the beach? Some of our ropes washed up are massive, cannot be moved or weighed by hand."

OceanGives

"More checks required on the quantities of waste put ashore…and assessed if the quantity is accurate according to the time at sea and the number of crew members."

Individual

Accurate assessments of marine plastics in Scottish waters

6.16 Almost one-third of those respondents who considered there to be omissions or gaps in the planned actions identified under Strategic Direction 4 commented further on the objective relating to 'accurate assessments of marine plastics in Scottish waters'.

6.17 The main points raised can be summarised as follows:

• The action to expand OSPAR monitoring beaches to include an open coast northeast beach was in the main welcomed given the "significant difference between islands and mainland areas in terms of the type and volume of marine litter."
• As stated above in relation to the Fishing for Litter objective, several respondents reinforced the importance of weighing and identifying the source of marine litter to provide an accurate assessment of marine plastics in Scottish waters.
• On beaches with large volumes of marine litter, volunteer capacity was highlighted as a potential barrier to providing accurate assessments. For example, it was reported that rural and remote areas (e.g. island communities) were disproportionately impacted by a lack of volunteer capacity given they are generally less populated than other areas.
• A general point raised regarding accurate assessments of marine plastics were the limitations posed by seasonal and geographical variations in data collection. For example, it was highlighted that wind strength and tide direction can impact on the accuracy of assessments as marine litter can be moved and deposited elsewhere between assessments. Therefore, the conditions "highlight the "pot luck" element of infrequent measurements not tied to specific wind/tide conditions". It is important to note that this challenge is not unique to OSPAR and applies across all methodologies.

6.18 The following quotes help to further illustrate some of the points outlined above:

"In addition to expanding OSPAR monitoring beaches to include a northeast beach, there are many sources of data which could be utilised to inform a general picture of marine litter around Scotland. For example, we at Think About Plastic-Arran (TAP) have detailed data, which has been collected using the scientific methodology used by Marine Conservation Society, for 12 beaches around the coast of the island which covers 2018, 2019, 2020, 2021. The data has been analysed to provide information about the type and quantity of coastal litter collected at specific sites around each coastline of the island and has also been amalgamated to provide an overall picture for the island. (All 12 beaches have different litter profiles). The data is also used to monitor the effectiveness of strategies employed by TAP e.g. business accreditation which has reduced the amount of plastic used by Arran businesses."

Think About Plastic - Arran (TAP)

"Many rural areas do not have the manpower numbers found in or near a city. Coves difficult to access, beaches miles from roads. It requires far more work than on the mainland densely populated areas… It is essential Island data collection is financially supported by employment of beach clean coordinators. It takes a huge amount of time to carry out beach cleans and surveys in areas where the amount of rubbish is extensive and populations limited."

OceanGives

"We welcome the expansion of monitoring areas to include 'an open east coast beach', in order to more accurately assess ocean plastic pollution in Scottish waters."

Plastic@Bay

Development of an agreed methodology for inter-tidal microplastic monitoring

6.19 Approximately one-fifth of respondents who considered there to be omissions or gaps in the planned actions identified under Strategic Direction 4 commented further on the objective regarding the 'development of an agreed methodology for inter-tidal microplastic monitoring'.

6.20 Much of the feedback referred to monitoring of marine litter in general terms rather than specific reference to inter-tidal microplastics.

6.21 Where there was specific reference to inter-tidal microplastics, feedback from several respondents supported a harmonised approach to the development of an agreed methodology as set out in the action plan. It was noted that such an approach could avoid duplication of effort and encourage consistency and comparison of data.

6.22 To this end, the UK and Ireland Spill Association made specific reference to existing and developing methodologies which may be useful. This included: Centre for Environment, Fisheries and Aquaculture Science who are working on a methodology for sediment microplastic monitoring; Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection who have published guidelines for the monitoring and assessment of plastic litter in the ocean; and a study of laboratory methods for the analysis of microplastics in the marine environment published by National Oceanic and Atmospheric Administration which includes "recommendations for quantifying synthetic particles in water and sediments [that are] internationally adopted as the current standards."

6.23 Keep Scotland Beautiful also supported a harmonised approach to developing an agreed methodology and suggested that there may be value in "linking terrestrial and marine litter perception surveys and methodologies in order that a joined-up picture can be generated."

6.24 The following quotes help to further illustrate some of the points outlined above:

"With an agreed methodology, such as the protocol of the Marine Conservation Society, and engagement with RYA Scotland, it should be possible to use recreational boaters to collect information from remote anchorages."

Royal Yachting Association Scotland

"There is a lot of effort going on internationally and nationally. Do not waste resource by duplicating effort… If a different method is used pleased ensure it is internationally understood and share the outcome and learnings as we are all learning to navigate our way through this relatively new challenge."

UK and Ireland Spill Association

"The survey method using OSPAR methodology…. does not accurately record the impact of some industrial plastic pollution in Scotland. We believe this is a major omission that skews perception of the most important sources of marine plastics: This method surveys the abundance of beach litter, i.e. the number of individual items. However there is a major difference in size between industrial-scale plastic fragments and mismanaged waste pollution. In consequence, numerous small items could hide the major pollution in volume. The danger of plastics comes mainly from their fragmentation potential - the bigger the initial size of the piece of plastic, the higher the risk. We consider that both the source and the size of plastic fragments (measured by their weight) are critical to understand plastic pollution. This is why many groups are now considering measuring the weight of the debris in their research."

Plastic@Bay

"Seems little point monitoring microplastics whilst there are huge amounts of visible plastic littering the shore. Ultimately this will be a source of microplastics for hundreds of years. Better to clear and monitor the larger plastic items."

Individual

"Pollution is site specific and will be influenced by local human activities, past and present. To be able to evaluate and solve a local pollution issue, the monitoring method should be adaptive."

Community of Arran Seabed Trust

"Data is an important tool in tackling the issues related to litter and littering, therefore a common monitoring system (such as the Litter Monitoring System) that enables a better understanding of the litter on land and beaches that could end up in the sea should be encouraged for clarity and consistency. The LEAMS data gathering methodology enables indicator data to be collected, and is aligned to the Code of Practice on Litter and Refuse (Scotland) 2018 'CoPLaR'. CoPLaR, and therefore LEAMS provide a system of zoning to monitor and understand litter pathways. These tools could be particularly useful with regard to marine litter if applied more consistently by duty bodies."

Keep Scotland Beautiful

"Supporting fishermen and fishing communities to play an active part in the process of designing methods, monitoring and assessing plastic and micro-plastic debris found in intertidal zones would help to bring communities and legislators together. Would there be possible job opportunities?"

Individual

Social science evaluation of the Marine Litter Strategy

6.25 Ten percent of respondents who considered there to be omissions or gaps in the planned actions identified under Strategic Direction 4 commented further on the objective regarding a 'social science evaluation of the Marine Litter Strategy'.

6.26 A point raised was that a public attitudes survey may be too subjective to gather reliable data on which to base an evaluation of the Strategy. It should be noted that the social science evaluation, by its very nature, is to gauge how individual people value the natural environment – it is not meant to be a substitute for scientific monitoring. Therefore, it was considered important to make the distinction between perceptions and reality of the scale of the marine litter problem, as well as the extent to which attitudes translate into action.

6.27 Another point raised was that careful consideration would be required to gather a representative sample - "visitors are particularly important participants in the marine litter scenario".

6.28 The following quote helps to further illustrate some of the views provided:

"Attitudes often differ from actions, and it is extremely difficult to elicit reliable evidence to support actions following through from attitudes. Visitors are particularly important participants in the marine litter scenario, and it would be important to ensure they are represented in the sample surveyed. Our own data collection indicates that much litter is generated 'accidently' and some comes from elsewhere, carried on tides, so whilst attitudes are important, they are only a small part of the picture… In the case of Arran, much marine litter collects in inaccessible and seldom visited places and therefore out of the eyes of many members of the public. Their attitude may be different if they had a clear picture of the issues."

Think About Plastic - Arran (TAP)

Understanding Scottish island beach litter

6.29 Over one-third of respondents who considered there to be omissions or gaps in the planned actions identified under Strategic Direction 4 commented further on the objective of 'understanding Scottish island beach litter'.

6.30 The main points raised can be summarised as follows:

• Most respondents welcomed the objective and plans actions to better understand Scottish island beach litter. There was recognition of the different challenges faced in Scottish island communities regarding beach litter compared to other areas. However, others questioned why the objective and actions only related to the Scottish islands. For example, it was noted that other rural areas in the mainland face some similar challenges e.g. Dumfries & Galloway was explicitly mentioned. Opportunities for knowledge sharing and lessons learned from the monitoring data was therefore considered important.
• Marine litter is said to be an enormous challenge for island communities. Given that they are less populated than other areas (e.g. more difficult to attract/retain volunteers), wider feedback highlighted a need for additional financial support to tackle the issue of marine litter in island communities. It was suggested that the creation of jobs and other opportunities (e.g. development officers, beach clean coordinators/rangers, studentships, etc) could help ease the burden of limited volunteer capacity particularly where physical collection of data in island communities is "difficult" and "time consuming".
• A few respondents questioned the need for a pilot study when the problem of beach litter in island areas is well established, and that urgent action was now required.
• Albeit each point was raised singly by a respondent, potential gaps highlighted a need to ensure monitoring covered inhabited and uninhabited islands, and litter sinks in estuaries and sea lochs.

6.31 The following quotes help to further illustrate some of the points outlined above:

"The Marine Conservation Society welcomes the focus on marine litter on Scottish Islands and would welcome support to add another OSPAR monitoring beach to a Scottish island location.

With many beaches across Argyll and Bute, Highlands and Islands, Aberdeenshire and Dumfries and Galloway reporting high levels of beach litter, any monitoring support for beaches with high levels of marine litter on Scottish Islands should also be shared with beach cleaners on mainland Scotland facing similar levels of litter."

Marine Conservation Society

"The inclusion of the objective to understand Scottish island beach litter and the associated actions are very welcome. The SIF Marine Litter Working Group had discussions with Marine Scotland which, highlighting a lack of island data, was followed up with a proposal for…a three-year funded study into island marine litter data… the pilot study mentioned within the actions is therefore all the more pressing. Data informs actions and further development and therefore given the urgency of the need to tackle marine litter in the islands…we would strongly support a change in timescale to 'short', and ideally within the year ahead."

Small Isles Community Council

"I see why Scottish island beach litter is singled out, but surely some of the NW coast remote, rural mainland beaches should be included."

Individual

"Understanding the sources of Marine Litter is important on all Scotland's shores, not just the islands, so a wider study is essential."

Scottish Fishermen's Federation

Wider Points

6.32 Many of the wider points raised under Strategic Direction 4 reinforced support for prioritising effective enforcement and legislation rather than data monitoring. To this end, a view expressed was that action should not wait for data to be collected particularly when the scale of the challenge regarding marine litter was well established. Some expressed frustration at the perceived lack of action undertaken to date.

6.33 In addition to monitoring activity, increased education and awareness of the sources of marine was again highlighted as an important tool to help address the issue.

6.34 The following quotes reflect the broad nature of comments:

"Evaluations and data collection should directly feed into strengthening legislation to stop this, especially stopping poor practice and banning of materials (where possible) that contribute to these problems."

Individual

"Assessing and evaluating is a waste of taxpayers' money. We know it there, there is plenty evidence and data from all around UK and the world. The effort should be in stopping it, not just looking at it, counting/ weighing it and wasting more time writing it up. Just act, the evidence is there on every beach/ river/ shoreline walk that anyone makes."

Individual