Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence

Memorandum by the Royal Society for the Protection of Birds (FUS 6)

1.1 Terms of reference

  1. This submission addresses two specific points of the inquiry's terms of reference: the contribution shipping can make to the objectives of the Transport White Paper, particularly the potential for shipping to reduce the environmental impact of freight transport and what action is required from Government to assist in the development of sustainable short sea shipping.

  2. The Society has a strong track record in the field of shipping, transport issues. We provided detailed responses to Lord Donaldson's inquiry into the Braer incident[1] and have developed wider transport policy (Vital Spark: RSPB's policy on energy and biodiversity[2] and Breaking Point: RSPB's policy on transport and biodiversity)[3]. Subsequently, RSPB has focused attention on the future development of the ports industry in Great Britain[4] and have fed the results of a detailed economic analysis into our responses to Government consultations on Trust Ports[5] and integrated transport,[6] and the European Commission's Green Paper on sea ports and maritime infrastructure.[7] The RSPB is now looking at the role of shipping in the context of progressing a more integrated approach to transport and the environmental costs and benefits this may involve.

1.2 The importance of coastal areas

  3. There are 163 estuaries around the coast of the UK, covering an area of 581,240ha.[8] This represents about 28 per cent of the total estuarine area of the NW Europe.[9] Each winter approximately 1.7 million waders and 650,000 wildfowl descend on our estuaries to feed, rest and shelter.[10] This represents approximately 40 per cent of all waders and 4 per cent of all wildfowl wintering in NW Europe.[11] The hard coast is also of global importance for seabirds with between 2.0-2.5 million auks and up to three million pairs of other species breeding in the British Isles.[12]

  4. At least 42 estuaries qualify for designation as Special Protection under the EU Birds Directive[13] on numbers alone. Other sites qualify in their own right because they have internationally important numbers of particular species. Whilst there are currently no SPAs designated at sea for feeding, roosting and moulting seabirds, at least 20 areas have been identified in the North Sea, English Channel and Kattegat as being of international importance for seabirds.[14] However, there have been substantial losses of habitat in the past. On just 18 estuaries, at least 89,000ha have been claimed (25 per cent loss of the total British resource).[15] Estuaries are continuing to undergo massive habitats loss—the Stour has lost 44 per cent of its saltmarsh between 1973 and 1988.[16] Probably the most serious current threat is the loss of habitat due to sea level rise. It is estimated that at least 10,000ha of intertidal habitats will be lost in England alone in the next 20 years due to sea level rise.[17]

  5. The coast is not just important for birds. It is the gateway for trade in and out of the UK. Over 558 million tonnes of freight traffic passed through UK ports in 1997, an overall increase of 1 per cent on the previous year.[18] It is perhaps inevitable that two such important interests on the coast have tended to collide more often than not in estuaries. At least 77 ports in the UK operate within or have jurisdiction over 44 internationally important bird sites.[19]

  6. Today, ports continue to develop and expand. Recent developments leading to the loss of estuarine habitats include Felixstowe Docks, Sheerness Docks and Mostyn Docks with further losses possible at Southampton. Recent major dredging programmes have been/are being carried out at Southampton and Felixstowe. The presence of oiled seabirds on beaches demonstrates the continued chronic oil pollution of the marine environment due to illegal discharges.


3.1 Comparing Environmental Impacts

  7. The environmental impacts of shipping must be considered in the context of wider transport impacts. However, there is little information on the environmental impacts of different modes of transport to facilitate a direct comparison. Many impacts are either not quantified or transport mode specific. For example, it has been estimated that up to 47,000 badgers, 3,000-5,000 barn owls and between 20-40 per cent of amphibian breeding populations are killed on roads each year.[20] Other impacts are indirect. For example, it takes 120,000 tonnes of aggregates to build one kilometre of motorway.[21] Aggregate extraction has significant impacts on a number of important habitats such as lowland wet grasslands and heathland.

  8. Whilst the construction of transport facilities such as roads is obviously destructive, it is often the routine use of constructed facilities that is more damaging in the long term. For example, noise can harm flora and fauna with many species of bird avoiding areas close to roads for nesting.[22] However, a far more insidious impact are the greenhouse gas emissions that lead to climate change and acid rain. These emissions appear to provide the only currently available environmental data for comparison between modes of transport.

  Recommendation 1: Government must give greater consideration to the relative environmental costs and benefits of different forms of transport and to reflect this in integrated transport policy.

3.2 Atmospheric emissions of different modes of transport

  9. All forms of transport that use fossil fuels emit greenhouse gases and usually acid rain precursors. In Europe, transport (all forms) contributes 69 per cent of CO emissions, 58 per cent of atmospheric NOx and 1 per cent of Ox emissions.[23] Whilst it is clear that road transport contributes by far the greatest amount to atmospheric pollution, shipping contributes the next greatest in terms of gross pollution (table 1).

A comparison of atmospheric emissions in the UK between different modes of transport (taken from the Royal Commission on Environmental Pollution's 18th Report, 1994)

1,000 tonnesRoadRail Air1Shipping2

Carbon monoxide6,029 121119
Nitrogen oxides1,398 3214130
Volatile organic compounds949 8414
Sulphur dioxide623 360

1 Estimate does not include emissions from aircraft except those below 300 feet during take off and landing.
2 Estimate does not include emissions from ships outside coastal waters (i.e., beyond 12nm).

  10. However, in comparison to other modes of transport, ships can move large volumes of freight relatively efficiently (table 2). Only freight transport by pipeline is more efficient. When contributions to atmospheric pollution take account of this, shipping is one of the cleanest forms of transporting large amounts of freight in terms of atmospheric emissions. However, this does not mean it is a clean form of transport. Shipping still makes a significant contribution to certain atmospheric pollutants such as sulphur dioxide. In addition, there are a number of other environmental impacts which are difficult to compare with other modes of transport, such as TBT pollution and the introduction of alien species in ballast water.
A comparison of atmospheric emissions between different modes of transport taking account of energy consumption (taken from the Royal Commission on Environmental Pollution's 18th Report, 1994)

RailWater RoadPipeAir

Specific primary energy consumption
6774232,890 16815,839
Specific total emissions
(g/ CO2
41.030.0207.0 10.01,206.0
0.2 5.5

  11. With this in mind, the RSPB will support the greater use of shipping where it leads to a transfer of freight from other more damaging forms of transport if the environmental implications of increased shipping use are addressed. These impacts are considered below in section 4.

  Recommendation 2: Government should actively support the greater use of shipping when it leads to a transfer of freight from other more damaging forms of transport, where the environmental benefits clearly outweigh the environmental costs of doing so.


4.1 Port development

4.1.1 Land claim

  12. Conflicts in interests between wildlife conservation and shipping commonly arises because ships require ports and ports usually require substantial areas of land for berths and handling facilities. Often, this leads to permanent loss of intertidal land of high conservation interest. Recent and ongoing major land claim activities include Felixstowe Docks and Sheerness Docks and Mostyn Docks with proposals at Southampton Docks.

  13. A key impact of land claim is that estuarine processes are altered. Any interference with these processes may have a significant effect on estuarine geomorphology.[24] It may also reduce the ability of the estuary to absorb wave energy. This can result in increased tidal energy reaching parts of the estuary not previously adjusted to this, leading to the erosion of intertidal areas upstream of the land claim.

  Recommendation 3: Where environmentally damaging port or shipping related developments are proposed, Government must be sure that no less damaging alternatives exist, that the development is clearly in the public interest and that full compensation for the damage is made.

4.1.2 Dredging

  14. Ships usually require channels to be dredged in order for them to access port facilities. It is estimated that some 30 million tonnes of sediment were dredged by ports in 1993.[25] At the same time, some estuaries are undergoing massive habitats loss—the Stour has lost 44 per cent of its saltmarsh between 1973 and 1988.[26] There is concern that the continued removal of sediment from such estuaries is making the matter worse.[27] Changes in estuarine length and/or depth due to dredging can result in major changes to the tidal properties. This may lead to loss of intertidal and subtidal habitat and increases in flood risks due to increased wave and tidal amplitudes.[28]

  Recommendation 4: Government should ensure that all port related dredging activities are kept to the minimum necessary to secure safe navigation and that where possible, the material dredged is disposed of in the most environmentally beneficial way.

4.2 Pollution

  15. Marine transport accounts for around 12 per cent of the contaminants entering the world's oceans.[29] However, the precise contribution of individual contaminants by the shipping industry is unclear. For example, there appears to be few estimates of the contribution emissions to the air make to contamination of water. The best estimates are for oil pollution.

4.2.1 TBT

  16. The relative efficiency in energy terms of shipping is maintained in part by the use of hull coatings such as the organo-tin compound tributyl-tin (TBT) to prevent the growth of fouling organisms such as barnacles. TBT has been described as one of the most toxic chemical ever to be deliberately introduced into natural waters.[30] In areas of heavy shipping such as the English Channel where there are some 420,000 ship movements annually,[31] dog whelk populations have been eliminated from busy coastal areas. The estimated cost in economic terms of the impact of TBT on the Arachon Bay oyster fishery (France) is $147US million.[32]

  17. The recent IMO ban on the use of organotin compounds in anti-fouling paint is a welcome development.[33] However, it will be another decade before organotins finally stop entering the marine environment from ships since the presence of organotins on ships' hulls will not be banned until 2008.

  18. However, a number of points are worth bearing in mind. First, in order to maintain some of the advantages of energy efficient shipping transport, alternatives need to be found. The IMO has called on States to develop procedures for evaluating new anti-fouling systems and to consider the impacts on environment and society, including commercial interests. However, there is little information on the impact of alternatives and there is a danger that some, such as Irgarol 1051 and Thiram would be just as environmentally damaging.[34] However, a recent seminar concluded that the replacement of hazardous technologies with less hazardous ones should only be seen as an interim measure.[35] Their use should be subject to a complete assessment of ecological risks, the strictest regulation and monitoring in order to contribute to the further development of non-hazardous technologies.

  19. Second, even though it has been shown that coastal mollusc populations can recover quite quickly after the cessation of TBT use.[36] TBT and its degradation products (monobutyltin and dibutyltin) are persistent and can remain in marine sediments for some considerable time. In addition, there is growing evidence that these contaminants are bio-accumulated in the tissues of marine mammals.[37] A survey between 1992 and 1996 found high concentrations of TBT in dolphins, whales and in the liver, kidney and brain tissues of southern sea otters found dead along the coast of California.[38]

  Recommendation 5: Government should as a matter of urgency fund research into finding environmentally safe alternatives to harmful anti-fouling paints.

  Recommendation 6: Government should contribute to and support IMO measures to ban the use of TBT in anti-fouling paints by the year 2003 and develop measures in the UK to ensure that after this date, there is no further use of TBT.

  Recommendation 7: Government should initiate a programme to monitor the levels of TBT in the marine environment in order to identify whether further measures are necessary to ensure TBT in the marine environment declines to benign levels.

4.2.2 Oil pollution

  20. It is estimated that approximately 24 per cent (568,000 tonnes) of all the oil entering the marine environment from all sources each year, comes from shipping.[39] Of this, operational discharges of oil from shipping accounts for around 80 per cent, much of it illegal. It is estimated that between 15,000-60,000 tonnes of oil are illegally discharged into the North Sea annually, mainly between the Strait of Dover and the German Bight.[40]

  21. Under the MARPOL Convention, contracting parties are required to ensure provision of reception facilities for ships' waste which are adequate to meet the needs of ships using them without causing undue delay. In the UK, this responsibility has been given to harbour authorities and terminal operators. If facilities in UK ports are both adequate in capacity, and easy to use, the result will not only be less pollution in port, but also less pollution in the open sea. Recent legislation, the Merchant Shipping and Maritime Security Act 1997,[41] contains enabling powers for the Secretary of State to require ports to prepare and implement waste management plans. However, a report for the Marine Safety Agency identified that ports could do much more to talk to their users and establish their needs.[42]

  22. Research carried out on behalf of the new Marine and Coastguard Agency which was recently presented to the IMO has pioneered the use of synthetic DNA to identify the source of oil residues and bunkers.[43] The work used synthetic DNA to "tag" oil so that it was ship specific and not liable to mistaken identity. This approach would have benefits both for the environment and the ship operator. It would allow more effective prosecutions of illegal discharges of oil into the sea and also help protect ships from wrongful prosecution.

  Recommendation 8: Government should continue to strive to ensure that adequate, effective and easy to use port reception facilities are available for all forms of ship waste.

  Recommendation 9: Government should support research which would help to reduce illegal discharges of oil into the sea and increase effective enforcement of existing regulations. Where effective measures are developed, Government should promote these to the IMO.

4.2.3 Air pollution

  23. Shipping carries some 80 per cent of the volume of goods traded globally.[44] It produces lower emissions of atmospheric pollutants per tonne of goods moved than any other major mode of transport. However, per tonne fuel consumed, ships engines are amongst the world's highest polluting combustion sources not least due to the nature of the fuel they use. Emissions of sulphur and nitrogen oxides by shipping are extensive. Globally, ships account for 4 per cent of the sulphur oxide (SOx) emissions, 7 per cent of the nitrogen oxides (NOx) and 1.4 per cent of the carbon dioxide (CO2) emissions.[45]

  24. One of the main environmental impacts of sulphur and nitrogen oxides emissions is the creation of acid rain which destroys forests and lake fauna particularly in northern latitude countries. Research has calculated that the cheapest way of reducing acid rain in Europe is to reduce emissions from sea. If technical measures are applied solely to land-based emission sources, to achieve a 50 per cent reduction in those areas of Europe where critical loads for acidification were exceeded in 1990, would cost seven billion ecu by the year 2010.[46] However, if the maximum sulphur content for shipping fuel was set at 1.5 per cent in the Baltic and North Sea, this cost is greatly reduced—for every one ecu spent on reducing sea-based emissions, 13 ecu would be saved on land. Despite the added costs to shipping, there would also be benefits since ships engines perform better with minimal sulphur content.[47]

  25. There are no technical difficulties to reducing sulphur and nitrogen oxide emissions from shipping.[48] For sulphur, the simplest solution is to reduce the sulphur content in bunker fuels. The average sulphur content of today's fuels is around 3 per cent and should as a first step be set as the global limit on fuel sulphur content. In more sensitive areas such as the North Sea and Baltic Sea, a stricter limit of 0.5 per cent should be set for ships operating solely or largely within these areas. For nitrogen oxides, engine running temperatures should be kept low since it is at higher temperatures that most nitrogen oxides are formed. In addition, selective catalytic reduction (SCR) can reduce nitrogen oxides in exhaust gases by as much as 95 per cent.[49] A reduction in ship speeds could help to reduce CO2 emissions although this has to be balanced by increased transit times.[50]

  26. The IMO is set to take action on air pollution from ships. A programme is being developed to monitor the average sulphur content of residual fuels as a contribution towards implementing a MARPOL annex on preventing air pollution from ships. This annex would set limits on sulphur oxide and nitrogen oxide emissions from ships exhausts and prohibit deliberate emissions of ozone-depleting substances.[51]

  Recommendation 10: Government should actively support current and future IMO programmes to reduce atmospheric pollution from ships particularly through increased use of cleaner fuels.

4.3 Ballast water

  27. Some 10 billion tonnes of ballast water is handled annually[52] in order to improve ship stability. At any one time this ballast water may be transporting more than 3,000 species of plant and animal around the globe.[53] The effect of introducing alien species can range from negligible to quite profound. All over the world, there are examples of serious economic and ecological effects of the introduction of alien species. For example, the introduction in the 1980s of the Zebra mussel Dreissena polymorpha from Europe into the Great Lakes requires the cleaning of water intakes, sluices and irrigation ditches at a cost of $5,000 US million dollars by the year 2000.[54]

  28. There is also growing concern about the hazards posed to human health by the transport in ballast water of bacteria (e.g., strains of cholera) and other pathogens, as well as the risks connected with toxic algae. For example, in 1991 and 1992, ballast water transported from Latin America to ports of the US Gulf of Mexico contained a strain of cholera bacteria which posed a serious risk to human health due to the contamination of seafood such as oysters and fish.[55] With the development of genetically modified organisms (GMOs), and faster ships in service increasing the survival rate of organisms carried in ballast tanks, these concerns are likely only to increase.

  29. Guidance from the IMO regarding reduction in alien species invasion risk includes not taking ballast water onboard in areas: where sewage outfalls or harmful organisms are known to be present; close to dredging operations; where tidal stream is known to be turbid or flushing is poor. The IMO also recommends that ballast water should be exchanged in the open ocean to increase the salinity of the ballast tanks to levels above which any freshwater species could survive. Whilst this does reduce the number of species able to survive to propogate in a new area, studies have shown that this may only be 67 per cent effective.[56] Other methods of trying to control the number of species carried on ballast tanks include filtration, biocides, thermal treatment, ultraviolet treatment, acoustics, deoxygenation and anti-fouling coatings.

  30. The IMO is now moving to tighten up legal instruments for the management of ballast water and is likely to submit a draft legal instrument for the June/July session to be put before the conference in 2001 or 2002. Measures could include powers for port states to turn away ships which fail to show a ballast water management plan and mandatory ballast management plans for port states that deem it unnecessary to adopt international standards.[57]

  Recommendation 11: Government must ensure that IMO guidelines on the taking on-board of ballast water are strictly adhered to.

  Recommendation 12: Government should facilitate research into methods of ensuring that ballast water does not pose a risk to the environment, human health or economic interests due to the introduction of alien species.


  31. Even if the environmental implications of increased shipping are reduced, there are a number of issues which must be addressed if shipping is to make a greater contribution to integrated transport. A significant contribution to this debate, was the publication of A New Deal for Transport—Better for Everyone.[58] Unfortunately, the White Paper went into comparatively little detail on sea and inland waterway transport. Whilst a series of "daughter" papers are to be produced, as the preceding sections demonstrate, there are a wide range of wildlife-related issues which need to be addressed. Having said this, there was much in what the White paper did say about ports, shipping and inland waterways which is welcome. The challenge is now to turn these welcome words into positive action.

5.1 Sustainable shipping

  32. RSPB welcomes Government's desire to facilitate shipping as an efficient and environmentally friendly means of transport. We also welcome moves to improve regulatory control of shipping using UK posts since this should help to address concerns about increasing ship use. However, as the preceding sections indicate, these concerns go further than just the climate change/CO2/SOx/NOx issues and include: continued use of TBT, introduction of alien species in ballast water and illegal discharges of oil at sea.

  Recommendation 13: In order to achieve the objective of sustainable shipping, the forthcoming integrated transport "daughter" papers which relate to ports and shipping must address the wide range of environmental issues which are a consequence of existing port use and shipping activities.

5.2 Coastal and inland shipping

  33. RSPB welcomes increased support for coastal shipping in that this should make a significant contribution to moving freight off roads. However, the Society is disappointed that Government feels only 3.5 per cent of the UK road freight traffic might transfer to coastal shipping. A comparison of freight transport by water in a selection of "developed" countries indicates that whilst GB transports up to 28 per cent of freight by water, other countries such as the USA, Japan and the Netherlands transport more (35 per cent, 45 per cent and 58 per cent respectively)[59]. In addition, in terms of increases in water use between 1981 and 1991, GB only managed a 5 per cent increase compared to a 12 per cent increase in the Netherlands and a 16 per cent increase in Japan. We believe that there might be considerably more potential in this area but it will require greater Government intervention in this transport sector.

  34. The Society supports in principle, the greater use of inland waterways and hope that Government will encourage investment in the development and introduction of new shipping technology such as split-ship and low profile coaster designs. However, any greater use of inland waterways must take full account of the potential environmental impacts, and in particular the likely significant impacts of reopening old waterways, both to freight and recreational traffic. With this concern in mind, we welcome the production of revised planning guidance on increasing more freight to be carried by water and encourage it to consider not only the impacts of inland ships themselves but also the intermodal terminals, inland ports, etc., which would be needed.

  35. However, if inland and coastal shipping is to make a significant contribution to integrated transport, Government must intervene in the transport market to give it a helping hand. The development of short sea shipping (coastal and inland shipping) is considered further in section 5.

  Recommendation 14: Government must more actively promote and facilitate the development of short sea shipping (coastal and inland shipping) as part of an integrated approach to freight transport, where there are clear environmental benefits.

5.3 Integrating ports

  36. Considering that the UK has not had a ports policy for a number of years, the White Paper represents a significant step forward and is welcomed as such. There are a number of points in particular which the RSPB welcomes:

    (a)  enhancing environmental and operational performance by encouraging multi-modal access to markets;

    (b)  making the best use of existing infrastructure rather than further expansion of facilities;

    (c)  promoting best environmental standards in design and operation of ports;

    (d)  possible financial support from the Strategic rail authority for improving rail connections to ports; and

    (e)  support for the EU Green Paper on ports and the objective to increase efficiency and improve infrastructure by integrating ports into the multi-modal TENs.

  37. What will be important now is to develop ways in which these policies can be carried forward in order that they make a significant contribution to reducing the impact of ports and shipping on the environment whilst at the same time increasing their role in reduction the impacts of other modes.

  Recommendation 15: The ports integrated transport "daughter" paper must develop a framework which actively carry forward the broad principles relating to ports outlined in the Integrated Transport White Paper.

5.4 Making it happen—environmental appraisal

  38. There are a number of very significant statements in the Integrated Transport White Paper which RSPB welcomes and we will measure Government's performance in implementing integrated transport policies against these. In particular:

    (a)  the clear statement that it is important to consider alternatives to new construction including better use of existing infrastructure;

    (b)  the principle that a damaging scheme should not go ahead unless it is clear that the net benefits in terms of the other objectives (including environmental benefits) clearly override the environmental disbenefits, that there is no other better option and that all reasonable steps to mitigate the impact have been taken;

    (c)  the criteria against which proposals must be assessed including: how important is the area; how serious is the likely impact; are there alternatives; if no alternatives, is mitigation or compensation feasible.

  39. However, we are concerned about Government's qualified support for the concept of environmental capital (especially critical natural capital) and the intention to incorporate it into the assessment and appraisal of new infrastructure. RSPB believes that the concept is seriously flawed, and those developing the concept have consistently failed to demonstrate that it has any benefit whatsoever for conservation of the environment.

  Recommendation 16: Government should formalise the criteria against which the suitability of new port related developments should be measured by revising the relevant planning policy guidance notes and environmental assessment regulations.

  Recommendation 17: Government should drop its qualified support for the Critical Natural Capital concept as it is seriously flawed.


  40. Short sea shipping could have a significant part to in an integrated transport strategy, providing a viable alternative to road freight transport. However, this is unlikely to happen unless a more "level playing field" is created. This will involve a number of facets including carbon taxes on fuel, reform of the freight grant facility and for the true costs of road transport to be reflected in freight haulage costs.

  41. Increased short sea shipping and a reduction in environmental impacts might be facilitated with the more formal development of a "hub port" system within Europe. In particular, the concentration of deep water facilities at just a few locations could reduce the number of sites where there is pressure to expand and thus reduce the environmental impact. In addition, it might ensure that ports unable to cater for the larger ships, retain an active role through servicing feeder ships. This might help to retain port related employment in areas which otherwise would have lost it.

  42. Greater use of hub ports will increase transhipment of cargoes which may have significant cost implications. However, it can be argued that these costs result in part from the current emphasis on roads. If transport policy was to move away from the road bias, then the economics of transhipment might change.

  43. One potential way of offsetting the costs of transhipment from hub ports might be to avoid intermodal transhipment costs at the destination port (e.g., between ship and lorry) and for the ship to continue on to the heart of the market by inland waterways.[60] An increase in inland shipping in particular would require the development of combined transport freight terminals. It would also require innovative development of new vessels since the UK's inland waterways greatly restrict the size of barge which can be used. The spilt ship design, low profile coasters, barge carrying/towing systems, integrated tug-barge systems could all help deliver direct shipments.[61]

  Recommendation 18: The integrated transport "daughter" papers which relate to ports and shipping should give full attention to the potential for short sea (coastal and inland) shipping and the ways in which this potential can be met.


  44. A feature of short sea shipping is that it involves the movement of goods by ship often in coastal waters. As already commented in this submission, many of these areas are of extremely high importance for wildlife (see section 2). After the inquiry into the Braer incident, Lord Donaldson recommended that marine environment high risk areas should be established so that ships can avoid such sensitive areas. This recommendation has still not been implemented. If short sea and coastal shipping is to increase as part of an integrated approach to freight transport, then measures to establish effective MEHRAs must be implemented.

  45. In doing this, it will be vital not to put shipping at risk from exposed seas. For this reason, it may not always be possible to route ships away from sensitive areas. In these areas, other measures such as traffic separation schemes and provision of tug escorts should be introduced. RSPB has previously recommended that ship routing measures are undertaken in a number of marine areas.[62] Measures for these areas are as urgent as ever.

  Recommendation 19: Government as a matter of utmost urgency should develop a network of Marine Environment High Risk Areas and introduce measures to ensure minimal risk to the marine habitats and species within these areas. The first tranche of MEHRAs should include:

    (a)  In general: shipping lanes should be established 20km offshore of the Scottish and English North Sea coasts, preferably as part of a mandatory scheme.

    (b)  Rathlin Island: the areas around Rathlin Island should be made an area to be avoided.

    (c)  The Minches: the proposals to establish an area to be avoided around the Minches should include compulsory pilotage if the area to be avoided is not made mandatory.

    (d)  Moray Firth: routes taken by oil tankers, and the location of moored vessels in the Moray Firth must be reviewed and appropriate steps taken to avoid risk of collision.

    (e)  The North East Coast: areas to be avoided by certain classes of ships should be established in the immediate area (a radius out to 10km offshore) of the Farne Islands, Coquet Island and the hugh seabird colony at Bempton Cliffs, Flamborough Head.

    (f)  Isles of Scilly: an area to be avoided for certain classes of vessels should be established around the Isles of Scilly to ensure oil tankers do not approach hazardous shallows.

    (g)  Milford Haven: a formal traffic pattern must be developed in the approaches to Milford Haven to safeguard important wildlife habitats.

November 1998

1   RSPB submission to Lord Donaldson's Inquiry into Pollution from Merchant Shipping, February 1993; Supplementary Submission to Lord Donaldson's Inquiry Addressing the Problems of Chronic Pollution from Shipping, April 1993. Back

2   Briggs B and Harley D 1994 Vital Spark: RSPB's policy on energy and biodiversity. RSPB, Sandy. Back

3   Briggs B, Bina O and Harley D 1995 Breaking Point: The RSPB's policy on transport and biodiversity. Published RSPB, Sandy. Back

4   Huggett D J 1997 Ports and Nature Conservation-supply and demand in the GB ports industry. RSPB Report in conjunction with MDS Transmodal, May 1997. Back

5   Huggett D J 1997 Review of Trust Ports: A response to DETR's consultation paper from the RSPB. Published RSPB, September 1997. Back

6   Briggs B 1997 Developing an integrated transport policy: the RSPB's contribution. Published RSPB, November 1997. Back

7   Green Paper on Sea Ports and Maritime Infrastructure (COM(97)678 Final): Detailed comments from the RSPB, February 1998. Back

8   JNCC 1993 Review group on JNCC marine and coastal projects. Published JNCC, Peterborough. Back

9   Davidson N C, Laffoley D, Doody J P, Way L S, Gordon J, Key R, Drake C M, Pienkowski M W, Mitchell R Duff K L 1991 Nature conservation and estuaries in Great Britain. NCC, Peterborough. Back

10   Cranswick P A, Waters R J, Evans J and Pollitt M S 1995 The Wetland Bird Survey 1993-94; Wildfowl and Wader counts. BTO/WWT/RSPB/JNCC, Slimbridge. Back

11   Smit C and Piersma T 1989 Numbers, midwinter distribution and migration of wader populations using the East Atlantic Flyway. In: IWRB Special Publication No. 9. Back

12   Lloyd C, Tasker M L and Partridge K 1991. The status of seabirds in Britain and Ireland. Published for the NCC and Seabird Group by T and A D Poyser. Back

13   Council Directive of 2 April 1979 on the conservation of wild birds (79/409/EEC). Back

14   Skov H, Durinck J, Leopold M F and Tasker M L 1995 Important Bird Areas for seabirds in the North Sea including the Channel and the Kattegat. Published BirdLife International, 1995. Back

15   See Davidson et al 1991 ibid. Back

16   Burd F 1992 Erosion and vegetation change on the saltmarshes of Essex and North Kent between 1973 and 1988. NCC Research and Survey Report No. 42. Back

17   Pye K and French P W 1992 Targets for coastal habitat creation. EN Research Report No. 35. Back

18   DETR Press Release Eighth consecutive rise in port traffic; 30 September, 1998. Back

19   Talbot L 1992 UK Ports and the IBA network. Unpublished RSPB report, Sandy. Back

20   Royal Commission on Environmental Pollution, 18th Report: Transport and the Environment. Published October 1994, CM2674. Back

21   Royal Commission on Environmental Pollution, ibidBack

22   E.g., Keller V E 1991 The effect of disturbance from roads on the distribution of feeding sites of geese wintering in NE Scotland. Ardea 79: 229-232; Reijnen R, Foppen R & Veenbaas G 1997 Disturbance by traffic of breeding birds: evaluation of the effect and considerations in planning and managing road corridors. Biodiversity and Conservation 6(4): 567-581. Back

23   Wilkins T 1997 A comparison of Short Sea Shipping with Road and Rail Freight Transport across Europe. A review of the potential cost, environmental and safety benefits of short sea shipping. MSc Thesis. Back

24   Pethick J 1995 Geomorphological impact of navigation dredging, Southampton Water. Unpublished draft report for RSPB, December 1995. Back

25   MAFF 1994 Monitoring and surveillance of non-radioactive contaminants in the aquatic environment and activities regulating the disposal of wastes at sea, 1993. Aquatic Environment Monitoring report No. 44, MAFF Directorate of Fisheries Research, Lowestoft. Back

26   See Burd 1992 ibid. Back

27   IECS 1993 Coastal processes & conservation-the Stour-Orwell estuary. EN Report. Back

28   See Pethick 1995 ibidBack

29   GESAMP 1990 The State of the Marine Environment. IMO/FAO/UNESCO/WMO/IAEA/UN/UNEP Joint Group of Experts on the Scientific Aspects of Marine Pollution. UNEP Regional Seas Reports and Studies No. 115, Published UNEP, Nairobi. Back

30   Stewart C and de Mora S J 1990 A Review of the Degradation of Tri(n-Butyl)tin in the Marine Environment. Environmental Technology 11: 565-570. Back

31   OSPAR 1993 North Sea Quality Status Report 1993. North Sea Task Force, ICES, Oslo and Paris Commissions, London 1993. 132 pp. Back

32   Johnson P et al 1998 Report on the World's Oceans. Publ. Greenpeace Research Labs, May 1998. Back

33   IMO calls for ban on toxic paints from 2003, Lloyd's List, 7 November 1998. Back

34   Ship owners urge caution as toxic paint comes under fire, Lloyd's List, 3 November 1998. Back

35   Boats against the Current: stopping the use of hazardous anti-fouling technologies. Seas at Risk/Friends of the Earth International Seminar, 15 May, Amsterdam. Back

36   See Stewart and de Mora 1990 ibid. Back

37   Kannan K, Senthilkumar K, Loganathan B G, Takahashi S, Odell, D K and Tanabe S 1997 Elevated Accumulation of Tributyltin and its Breakdown Products in Bottlenose Dolphins Tursiops truncatus) Found Stranded along the US Atlantic and Gulf Coasts. Environmental Science and Technology 31 (1): 296-301; Tanabe S, Prudente M, Mizuno T, Hasegawa J, Iwata H and Miyazaki N 1998 Butyltin Contamination in Marine Mammals from North Pacific and Asian Coastal Waters. Environmental Science and Technology 32 (2): 193-198. Back

38   Action call on anti-fouling paints, Lloyd's List, 2 November 1998. Back

39   International Chamber of Shipping 1997 Shipping and the Environment: A Code of Practice. Publ. International Chamber of Shipping, London, 24 pp. Back

40   OSPAR 1993, ibid. Back

41   Anon 1997 Merchant Shipping and Maritime Security Act 1997. Chapter 28. HMSO (London). ISBN 0-10-542897-3. Back

42   WRc. 1995 The Quality of Provision of MARPOL facilities at UK ports: a WRc report to the MSA. CO3804. Back

43   UK plans use of "DNA" to identify oil spills. Lloyd's List, 12 November 1998. Back

44   International Chamber of Shipping 1997 ibid. Back

45   Mathiesen TC 1994 The Human Element in Environmental Protection. Marine Pollution Bulletin 29 (6-12): 375-377. Back

46   Amann et al 1996 Cost-effective control of acidification and ground-level ozone. Second interim report to the European Commission, DXXi, December 1996. Back

47   International Chamber of Shipping 1997 Shipping and the environment: a code of practice. Back

48   See Oftedal et al 1996 Air pollution from sea vessels: the need for potential reductions. Publ. European Federation for Transport and the Environment, T and Report 96/9. Back

49   See Cleaner shipping-a cheap way to reduce a acidification in Europe. Publ. by The Swedish NGO Secretariat on Acid Rain, The European Federation for Transport and the Environment and the European Environmental Bureau, August 1997. Back

50   IMO prepares to act over air pollution. Lloyd's List, 5 November 1998. Back

51   Lloyd's List 5 November 1998, ibidBack

52   Early progress in IMO on crating ballast water rules. Lloyd's List, 17 November 1998. Back

53   CSBO/MB/CETS/CSBO 1996 Stemming the Tide; Controlling Introductions of Non-indigenous Species by Ships' Ballast Water National Academy of Sciences, USA. Back

54   Eno NC, Clark R A and Sanderson W G 1997 Non-native marine species in British waters: a review and directory, JNCC, Peterborough; Morton B 1996 The aquatic nuisance species problem: A global perspective and review. In: Zebra mussels and aquatic nuisance species; pp. 1-54 edited by D'Itri F M Suchanek T M 1994 Temperate coastal marine communities: Biodiversity and threats; American Zoology vol. 34: 100-114. Back

55   McCarthy S A and Khambarty F M 1994 International dissemination of epidemic Vibrio cholerae by cargo ship ballast and other non-potable waters; Applied and Environmental Microbiology vol. 60 (7): 2597-2601. Back

56   Locke A, Reid D M, Sprules W G, Carlton J T and van Leeuwen H C 1991 Effectiveness of mid-ocean exchange in controlling freshwater and coastal zooplankton in ballast water; Canadian Technical Report of Fisheries and Aquatic Sciences 1822. Back

57   Early progress in IMO on creating ballast water rules. Lloyd's List, 17 November 1998. Back

58   A New Deal for Transport-Better for Everyone, Publ. DETR, 20 July 1998. Back

59   Royal Commission on Environmental Pollution's 18th Report, 1994. Back

60   Hilling D 1993 waterways for a single Europe. In: Dock and Harbour Year Book, 1993. Back

61   Inland Waterways Association 1994 Waterborne transport-lifeline for British industry. Publ. by Inland Shipping Group of the IWA, March 1994. Back

62   See RSPB's submission to Lord Donaldson's Inquiry into Pollution from Merchant Shipping, February 1993. Back

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