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
and have developed wider transport policy (Vital Spark: RSPB's
policy on energy and biodiversity
and Breaking Point: RSPB's policy on transport and biodiversity).
Subsequently, RSPB has focused attention on the future development
of the ports industry in Great Britain
and have fed the results of a detailed economic analysis into
our responses to Government consultations on Trust Ports
and integrated transport,
and the European Commission's Green Paper on sea ports and maritime
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.
This represents about 28 per cent of the total estuarine area
of the NW Europe.
Each winter approximately 1.7 million waders and 650,000 wildfowl
descend on our estuaries to feed, rest and shelter.
This represents approximately 40 per cent of all waders and 4
per cent of all wildfowl wintering in NW Europe.
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.
4. At least 42 estuaries qualify for designation
as Special Protection under the EU Birds Directive
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.
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).
Estuaries are continuing to undergo massive habitats lossthe
Stour has lost 44 per cent of its saltmarsh between 1973 and 1988.
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.
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.
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.
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.
Other impacts are indirect. For example, it takes 120,000 tonnes
of aggregates to build one kilometre of motorway.
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.
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
3.2 Atmospheric emissions of different modes of
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
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)
|Volatile organic compounds||949
|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
|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)
|Specific primary energy consumption
|Specific total emissions|
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. ENVIRONMENTAL IMPLICATIONS
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.
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.
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.
At the same time, some estuaries are undergoing massive habitats
lossthe Stour has lost 44 per cent of its saltmarsh between
1973 and 1988. There
is concern that the continued removal of sediment from such estuaries
is making the matter worse.
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.
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
15. Marine transport accounts for around 12 per cent of the
contaminants entering the world's oceans.
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.
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. In areas
of heavy shipping such as the English Channel where there are
some 420,000 ship movements annually,
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.
17. The recent IMO ban on the use of organotin compounds
in anti-fouling paint is a welcome development.
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
a recent seminar concluded that the replacement of hazardous technologies
with less hazardous ones should only be seen as an interim measure.
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. 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.
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.
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.
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.
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,
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.
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.
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
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
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.
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.
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 reducedfor 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.
25. There are no technical difficulties to reducing sulphur
and nitrogen oxide emissions from shipping.
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. A reduction
in ship speeds could help to reduce CO2 emissions although
this has to be balanced by increased transit times.
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
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
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.
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.
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.
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.
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
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.
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.
5. A PLACE FOR
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 TransportBetter for Everyone.
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).
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 happenenvironmental 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
(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
(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
6. DEVELOPING A
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.
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
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.
7. MARINE ENVIRONMENT
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. 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
(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
(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
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
Briggs B and Harley D 1994 Vital Spark: RSPB's policy on energy
and biodiversity. RSPB, Sandy. Back
Briggs B, Bina O and Harley D 1995 Breaking Point: The RSPB's
policy on transport and biodiversity. Published RSPB, Sandy. Back
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
Huggett D J 1997 Review of Trust Ports: A response to DETR's consultation
paper from the RSPB. Published RSPB, September 1997. Back
Briggs B 1997 Developing an integrated transport policy: the RSPB's
contribution. Published RSPB, November 1997. Back
Green Paper on Sea Ports and Maritime Infrastructure (COM(97)678
Final): Detailed comments from the RSPB, February 1998. Back
JNCC 1993 Review group on JNCC marine and coastal projects. Published
JNCC, Peterborough. Back
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
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,
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
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
Council Directive of 2 April 1979 on the conservation of wild
birds (79/409/EEC). Back
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
See Davidson et al 1991 ibid. Back
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
Pye K and French P W 1992 Targets for coastal habitat creation.
EN Research Report No. 35. Back
DETR Press Release Eighth consecutive rise in port traffic;
30 September, 1998. Back
Talbot L 1992 UK Ports and the IBA network. Unpublished RSPB report,
Royal Commission on Environmental Pollution, 18th Report: Transport
and the Environment. Published October 1994, CM2674. Back
Royal Commission on Environmental Pollution, ibid. Back
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
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
Pethick J 1995 Geomorphological impact of navigation dredging,
Southampton Water. Unpublished draft report for RSPB, December
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
See Burd 1992 ibid. Back
IECS 1993 Coastal processes & conservation-the Stour-Orwell
estuary. EN Report. Back
See Pethick 1995 ibid. Back
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,
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
OSPAR 1993 North Sea Quality Status Report 1993. North Sea Task
Force, ICES, Oslo and Paris Commissions, London 1993. 132 pp. Back
Johnson P et al 1998 Report on the World's Oceans. Publ.
Greenpeace Research Labs, May 1998. Back
IMO calls for ban on toxic paints from 2003, Lloyd's List, 7 November
Ship owners urge caution as toxic paint comes under fire, Lloyd's
List, 3 November 1998. Back
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
See Stewart and de Mora 1990 ibid. Back
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
Action call on anti-fouling paints, Lloyd's List, 2 November 1998. Back
International Chamber of Shipping 1997 Shipping and the Environment:
A Code of Practice. Publ. International Chamber of Shipping, London,
24 pp. Back
OSPAR 1993, ibid. Back
Anon 1997 Merchant Shipping and Maritime Security Act 1997.
Chapter 28. HMSO (London). ISBN 0-10-542897-3. Back
WRc. 1995 The Quality of Provision of MARPOL facilities at
UK ports: a WRc report to the MSA. CO3804. Back
UK plans use of "DNA" to identify oil spills. Lloyd's
List, 12 November 1998. Back
International Chamber of Shipping 1997 ibid. Back
Mathiesen TC 1994 The Human Element in Environmental Protection.
Marine Pollution Bulletin 29 (6-12): 375-377. Back
Amann et al 1996 Cost-effective control of acidification
and ground-level ozone. Second interim report to the European
Commission, DXXi, December 1996. Back
International Chamber of Shipping 1997 Shipping and the environment:
a code of practice. Back
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
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
IMO prepares to act over air pollution. Lloyd's List, 5 November
Lloyd's List 5 November 1998, ibid. Back
Early progress in IMO on crating ballast water rules. Lloyd's
List, 17 November 1998. Back
CSBO/MB/CETS/CSBO 1996 Stemming the Tide; Controlling Introductions
of Non-indigenous Species by Ships' Ballast Water National Academy
of Sciences, USA. Back
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
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
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
Early progress in IMO on creating ballast water rules. Lloyd's
List, 17 November 1998. Back
A New Deal for Transport-Better for Everyone, Publ. DETR,
20 July 1998. Back
Royal Commission on Environmental Pollution's 18th Report, 1994. Back
Hilling D 1993 waterways for a single Europe. In: Dock and Harbour
Year Book, 1993. Back
Inland Waterways Association 1994 Waterborne transport-lifeline
for British industry. Publ. by Inland Shipping Group of the IWA,
March 1994. Back
See RSPB's submission to Lord Donaldson's Inquiry into Pollution
from Merchant Shipping, February 1993. Back