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

Memorandum by Wildlife and Countryside Link's Marine and Coastal Group (IT 80)



  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 developed—as 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 impacts.

  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 sea.


  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[2]. Ships' engines perform better with minimal sulphur content[3] 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.

Recommendation 1

    —  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 agencies.

Recommendation 2

    —  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".


  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 and infrastructure.

Recommendation 3

    —  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.

Recommendation 4

    —  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.


  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".


  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 Ships—Cleaner 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.

Recommendation 5

    —  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.


  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;

Recommendation 6

    —  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.

Recommendation 7

    —  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.

Recommendation 8

    —  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.


  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.

Recommendation 9

    —  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.


  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.

Recommendation 10

    —  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.


  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 Paints—Organotins such as Tributylin (TBT) have been shown to produce sub-lethal impacts—including reduced growth, deformities and reproductive failure—in 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.

Recommendation 11

    —  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 waters.

    Introductions of Alien Species—A 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.

Recommendation 12

    —  WCL believes that effective and appropriate measures—such as in transit ballast tank flushing—should 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.


  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.


  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 on land.

Recommendation 13

    —  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.

Recommendation 15

    —  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.


  WCL acknowledges the UK's role in discussions in the IMO and supports the setting of compulsory and minimum standard for shipowners insurance cover.

Recommendation 15

    —  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" principle.


  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 sites network.


  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 emissions.

    —  Improving efficiency.

    —  Standards for cleaner more efficient vehicles and fuels.

    —  Better enforcement

    —  Targets


  An integrated transport policy should seek to reduce transport derived environmental impacts across all sectors—it 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 Conservation

September 1998

2   International Chamber of Shipping, Shipping and the Environment-A Code of Practice, 1997. Back

3   Ibid. Back

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