Memorandum by Wildlife and Countryside
Link's Marine and Coastal Group (IT 80)
MARINE ASPECTS OF THE GOVERNMENT'S WHITE
PAPER ON INTEGRATED TRANSPORT
Wildlife and Countryside Link is the liaison
body for the voluntary organisations in the UK concerned with
conservation and protection of wildlife and the countryside. WCL's
members collectively represent 5.5 million supporters in the UK.
WCL's Marine and Coastal Group has for some time focused on transport
issues in the marine environment. It responded to the consultation
paper on Integrated Transport policy and now welcomes the opportunity
to respond specifically to the marine elements of the White Paper.
Transportation is an essential element of modern
society but one which can result in significant negative impacts
upon the environment, both directly and indirectly. The Government's
White Paper on Integrated Transport is a welcome attempt to rationalise
and improve on the UK's existing transport network and to reduce
the sector's impact on the environment.
Clearly transport related problems in the terrestrial
environment are pressing and it is the nature of government and
voters alike to view the world in an anthropocentric fashion which
naturally affects the way in which policy is developedas
a result the marine environment, supporting relatively few humans,
can often become marginalised in government policy. Wildlife and
Countryside Link (WCL) believes an integrated policy should recognise
both global and local environmental impacts and address issues
relating to biodiversity, animal welfare, conservation of habitat
and human health. It should concern itself with impacts that are
both high profile and those that are less so. The environmental
impacts of transport in the marine environment, though less tangible
to the person in the street, are nevertheless significant.
WCL welcomes the general shift towards a more
environmentally sensitive transport system as evidenced in the
White Paper and supports Government's wishes to facilitate shipping
as an efficient means of transport with relatively low environmental
A comparison of the environmental impacts of
shipping as compared with road transport in terms of CO2
emissions per tonne/per mile casts a favourable light on maritime
transport. A further examination of current capacity within the
shipping industry shows room for expansion without the need for
large scale expansion of the supporting infrastructure. The shifting
of freight from roads onto shipping therefore may be a positive
solution to many land based transport problems.
However, it is the view of WCL that substantial
progress on maritime policy and practice is needed if this redistribution
of load is to result in a net gain for the environment rather
than merely a displacement of burden. Our concerns about increased
use of ships go further than just climate change/emissions issues
and include: continued use of TBT, introduction of alien species
in ballast water and illegal discharges of oil and rubbish at
2. SUSTAINABLE SHIPPING
Emissions from shipping are very different to
those from road vehicles. Per tonne-kilometre levels of nitrogen
oxides and carbon monoxide and hydrocarbons are lower in shipping,
however, SO2 emissions per tonne-kilometre (the chief
cause of acid rain) have been shown to be more than double.
Ships' engines perform better with minimal sulphur content
and so it is in industry's and the environment's interests to
address this problem. Unless this is done it is misleading to
describe any fuel powered shipping as an "environmentally
friendly" means of carrying trade.
WCL urges the Government to invest
in work within the IMO with the aim of reducing the global cap
for sulphur content in shipping fuel which is at most equal to
the current world average and to require the oil industry to supply
cleaner fuel for shipping. WCL also calls for North Sea States
to introduce measures to require vessels operating solely or largely
within the North Sea and westward extension area to burn fuel
of no more than 1.5 per cent total sulphur content.
It is our understanding that DETR's Shipping
Working Group, whose recommendations the paper refers to, does
not include representation from the environmental or nature conservation
WCL would wish to see the sound environmental
management of shipping as one of the policy's major aims and would
like reassurance that input from experts in the field of pollution,
and other environmental fields, has been and will be sought by
the Shipping Working Group to inform its discussions on how best
to maximise "environmental benefit from shipping".
3. INTEGRATED PORTS
WCL welcomes the government's policy on the
integration of ports particularly the emphasis placed on the need
for development to be contained within the existing land areas
WCL would like to stress that in
considering new developments decision makers should fully implement
their environmental duties and honour those commitments the UK
has made to international nature conservation agreements, such
as the Convention on Biological Diversity and the EU Habitats
and Birds Directives. Ports are "relevant authorities"
under the Species and Habitats Regulations and should therefore
be involved in the development of SAC management plans.
WCL notes that currently no national policy
exists for port development and that as a result there is at times
excess port capacity within various specialised areas of the sector
such as semi and dry bulk traffic. At the same time there is evidence
to suggest that areas which are currently expanding such as "load
on-load off" and "roll on-roll off" may soon be
short of capacity.
Ports need good transport links with markets
and can also be used to influence how those links are made. The
provision of multimodal terminals can encourage a shift from road
to rail or from long haul shipping to short sea shipping and coastal
shipping. Intermodal transhipment can also be reduced with greater
use of existing inland waterway networks.
WCL therefore calls on the Government
to develop a national port policy, which must take into account
the UK's international conservation commitments and consider local
environmental and community issues, and to give guidance on port
capacity needs and additional planning guidance to PPG20.
4. MARINE SAFETY
WCL welcomes the integration of enforcement
agencies to create the new Marine and Coastguard Agency (MCA)
and also welcomes the extension of the agencies responsibilities
to include "responding to incidents at sea and on the coast
that involve danger to the environment".
5. RISK ANALYSIS
Evidence has indicated that shipping can produce
significant impacts upon sensitive marine and coastal ecosystems.
These are particularly obvious in the case of major accidents,
such as the Sea Empress, but normal shipping activity can
also produce negative effects. Following the Braer oil
spill, Lord Donaldson recommended in his report Safer ShipsCleaner
Seas that Marine Environmental High Risk Areas (MEHRAs) be
established. These are marine areas that are identified as being
particularly sensitive to pollution or other shipping-related
activity. WCL believes that these are areas which are deserving
of special shipping control measures, in order to reduce the risk
of environmental impacts. Such measures might include: routeing
systems; exclusions areas; and surveillance and reporting arrangements.
In order for MEHRAs to be established,
there is an urgent need for a comprehensive and systematic evaluation
of shipping risk to be undertaken around the UK coast and in UK
territorial waters. This should establish, on an area by area
basis, both the potential level of threat presented by shipping
activity, and measures that should be introduced to control or
eliminate such risk. WCL would like to receive confirmation of
whether the new Agency will be tasked with this operation, when
the designation of MEHRA's will take place and whether it will
then be the Agency's responsibility to develop, promote and enforce
the protection of such areas.
6. LOSS OF
WCL welcomes the fact that the MCA will pay
particular attention to vessels carrying hazardous or polluting
cargoes. Wreck exploration to establish causes of accidents is
also welcome, however;
WCL calls on the Government to continue
to work with the International Maritime Organisation (IMO) towards
an international convention on wreck removal and the development
of contingency plans for the salvage of lost cargo from the seabed.
Furthermore, WCL encourages the Government
to work with North Sea States and within the IMO to require that
transponders be fitted to packaged hazardous cargoes, in order
to aid identification of their location if lost.
WCL also urges the Government to
work within the IMO to ensure that MARPOL regulations to phase
out single hull tankers in favour of safer double hull constructed
vessels achieve their aim as rapidly as possible.
7. EUROPEAN ACTION
The European transport policy affects the UK,
for example the increase in lorry weight on UK roads within 150km
of a port will have an affect. Also the continuing development
of the Trans European Network and how shipping is built into it
could have a significant impact on how we approach integrated
transport in this country.
WCL urges the government to take
a leading role in Europe in relation to marine transport issues
and to continue in its support of the EU Green Paper on ports
and the objective to increase efficiency and improve infrastructure
by integrating ports into the multi-modal TENs, as the UK is likely
to be one of the countries most affected and also able to offer
expertise on the subject.
8. COMMISSION FOR
The establishment of the CfIT is a positive
measure that we hope will lead to the development of an increasingly
sophisticated and efficient transport network in the UK.
WCL urges that although not expressly
mentioned in the list of items that the Commission will be approached
for advice on, and despite the fact that no targets have been
set in the white paper for marine transport, the Commission will
nevertheless be called upon to develop a thorough understanding
of marine transport issues and take into account environmental
concerns when offering independent advice. WCL also hopes that
the Commission will be urged to consult with the Environmental
and Conservation Agencies and with experts in the NGO community.
9. CLEANER, MORE
In the same way that it is now accepted that
cars have an impact on the environment it must be acknowledged
that all shipping impacts on the environment. Aside from the problem
of fuel emissions discussed earlier, shipping can also generate
other impacts which can have a devastating direct impact on ecosystems:
Organotin Pollution from Anti-Fouling PaintsOrganotins
such as Tributylin (TBT) have been shown to produce sub-lethal
impactsincluding reduced growth, deformities and reproductive
failurein non-target species, even at extremely low concentrations.
Though the use of TBT paints is banned in the UK on vessels under
25m in length, it is still used on many large commercial vessels.
While a global ban on organotins in anti-fouling paints is likely,
it will be some years before it takes effect. Any increase in
shipping could therefore result in an increase in TBT levels in
coastal waters and estuary/port sediments.
WCL therefore calls for the UK government
to take a strong lead to encourage North Sea/European States to
introduce a total ban on the use of organotin-based anti-fouling
paints for vessels operating solely or largely within European
Introductions of Alien SpeciesA
number of non-native marine species have been introduced to European
waters as a result of shipping activity. Such species have the
potential to disrupt native marine communities, alter ecosystems
and become serious pests.
WCL believes that effective and appropriate
measuressuch as in transit ballast tank flushingshould
be introduced so that alien species are not transmitted by long
distance or coastal shipping. WCL urges the Government to take
a strong lead within IMO to agree global regulations on the introduction
of alien species and to work within the OSPAR convention framework
on the potential for transfers within the NE Atlantic.
WCL believes that a paper on integrated transport
systems that advocates increases in marine transportation, should
acknowledge the potential deleterious impacts of shipping on the
marine environment and plan for their mitigation.
10. EMERGENCY TOWING
WCL welcomes the provision of increased ETV
cover and fully endorses the plan to impose a levy on ships to
pay for additional ETV cover and hopes that this measure will
be similarly endorsed by the Shipping Working Group in their soon
to be published report.
11. DISCHARGE OF
WCL welcomes the proposal to ensure greater
integration of shipping and port operations in planning the provision
of adequate reception facilities for ship's waste. WCL recognises
that there is little point in preventing pollution at sea, if
this then results in unacceptable treatment and disposal of wastes
In order to ensure that such facilities
are utilised by vessels, it would be desirable for charges for
such facilities to be incorporated in general port fees. Additional
charges might be levied, however, for specialist waste reception
and treatment such as oil and noxious chemical washings. It is
imperative that any waste that is received by ports be dealt with
by the most environmentally acceptable methods.
Even with the provision of adequate port facilities,
removing the excuse is only partially addressing the problem.
Illegal activity, for example the discharge of oily wastes from
either cargo or bilge tanks, may still increase.
In order to combat this, WCL urges
the Government to: continue to work with North Sea states to improve
the monitoring and enforcement relating to the legal and illegal
discharges of chemical and oily wastes; and, to investigate and
progress the development of a publicly accessible system of reporting
of emissions and transfers of chemicals and other ship's wastes.
Unless these policies are fully implemented
it is likely that an increase in shipping activity will result
in an increase in both the legally and illegally sanctioned discharge
of waste products to the marine environment.
12. MARINE CLEAN-UP
WCL acknowledges the UK's role in discussions
in the IMO and supports the setting of compulsory and minimum
standard for shipowners insurance cover.
WCL urges the government to address
the issue of compensation for the environmental damage as well
for costs of clean-up operations and losses, caused by marine
pollution by fully implementing "the polluter pays"
WCL supports the Government's plans for improved
Environmental Appraisal and urges that it be rigorously applied
in the marine and coastal environment, although some WCL members
have reservations with regard to the application of the environmental
capital approach. We are pleased that the proposal takes into
account the UK's Biodiversity Action Plan obligations and hope
that these will continue to be interpreted in their widest sense
especially with regard to target species such as the harbour porpoise
which currently lack the protection provided by the designated
WCL considers the lack of any mention of marine
transport and the marine and coastal environment in the following
key areas of the paper to be a failing and incongruous with the
principle of integration.
Comparison of per-tonne kilometer
Standards for cleaner more efficient
vehicles and fuels.
An integrated transport policy should seek to
reduce transport derived environmental impacts across all sectorsit
is not acceptable to resolve one environmental problem only to
create another. In considering this, WCL believe that an integrated
transport policy should: set out a clear strategy and targets
for the mitigation of existing levels of environmental damage
as a result of shipping activity, incorporating and providing
for any predicted growth in the sector.
This statement is supported by the following members
of Wildlife and Countryside Link:
Marine Conservation Society
The Shark Trust
Whale and Dolphin Conservation Society
Wildfowl and Wetlands Trust
The Wildlife Trusts
WWF-UK (World Wide Fund for Nature)
Young Peoples Trust for the Environment and Nature
2 International Chamber of Shipping, Shipping and the
Environment-A Code of Practice, 1997. Back