Memorandum submitted by The Wildlife Trusts
1. INTRODUCTION
1.1 The Wildlife Trusts welcomes the opportunity
to comment on the Committee's inquiry into the marine environment.
1.2 The Wildlife Trusts are a unique partnership
of 47 local Wildlife Trusts covering the whole of the UK and the
Isle of Man and Alderney. The partnership campaigns for the protection
of wildlife and invests in the future by helping people of all
ages to gain a greater appreciation and understanding of nature.
Collectively The Wildlife Trusts have approximately 413,000 members
and manage almost 2,550 nature reserves, covering more than 80,000
hectares of land, ranging from inner city urban sites to the UK's
finest wildlife areas on the coast.
2. BACKGROUND
2.1 Central to the marine conservation work
of The Wildlife Trusts is a vision of healthy marine habitats
supporting a natural diversity of species. However, we also recognise
the social and economic value placed on marine resources and this
vision includes the sustainable management of these resources,
believing that balancing the needs of wildlife and people is essential
for the future of both.
2.2 The Wildlife Trusts believe that a radically
different approach to managing our marine environment is urgently
required. In June 2002 The Wildlife Trusts launched a report "Marine
Stewardship—meeting the challenge"[2].
This report suggests that the UK government should change its
current approach to one that is founded on the principles of managing
a whole ecosystem, sustainable development, and the precautionary
principle. This is the challenge of marine stewardship. Integrated
marine stewardship requires a radical overhaul of the present
fragmented, confusing and overlapping institutional and legislative
framework.
2.3 The Wildlife Trusts have called upon
the Government to set up a marine taskforce to develop this new
approach to managing the seas through a detailed marine plan.
A prerequisite for integrated marine stewardship is a revitalised
institutional framework and new legislation to ensure that such
stewardship is possible. The plan should also detail a toolkit
of devices that lead to healthy marine environment. The Wildlife
Trusts have set the UK Government five key challenges, these are:
1. A clear policy statement—a White
Paper—setting out the marine stewardship approach.
2. A package of legislation that sets out
the legislative and institutional framework required.
3. Reform of current institutional arrangements
to bring the management of marine resources under one Ministry
and/or agency at a UK and devolved level.
4. The development of a toolkit of approaches
to deliver integrated marine stewardship.
5. A monitoring framework and review process
to assess marine recovery and put in place necessary actions should
marine stewardship fail to meet the goal of a healthy marine environment
2.4 The Wildlife Trusts are convinced that
Britain's seas are suffering because of unsustainable management.
Last July we published a report called "Our Dying Seas?[3]
This report highlights the serious threats that are affecting
the seas around us, and the lack of any coherent planning or legislation
to tackle these threats. The Wildlife Trusts have produced "Our
Dying Seas?" to highlight the scale of the problem; to explain
what action The Wildlife Trusts have undertaken to try and improve
matters in specific areas; and to make concrete proposals of further
action that needs to be taken to improve matters.
2.5 The oceans of the world seem so limitless
that it would appear to be impossible for humans to inflict such
major damage that whole marine ecosystems are in peril. Yet that
is exactly what is happening, not least in the shallow, productive
seas that surround the UK. Every level of marine life is under
threat, from the charismatic bottlenose dolphin, harbour porpoise
and basking shark, to the critically endangered leatherback turtle,
and unique and precious sites on the seabed, where some of our
most attractive and diverse marine communities exist such as the
sunset coral and the pink seafan. Even popular staples of our
fish and chip culture are disappearing, with cod now following
mackerel into commercial extinction in the North Sea. Yet commercial
fishing for species like the sandeel continues, the crucial foundation
of the food chain that feeds a wide diversity of marine life from
commercial species to seabirds and dolphins. The continuation
of this practice could prevent the chance of any species recovery.
2.6 The protection of marine sites is also
inadequate, with some of our most "protected sites"
being damaged. Therefore, we must ensure that the practical mechanisms
are put in place to ensure the adequate protection of Marine Nature
Reserves or Coastal Special Areas of Conservation. And at the
shore, where the sea meets the land, the loss of habitat such
as salt marsh continues unabated, due to the insatiable demand
for land for development. This is before we even consider the
potential losses that are predicted as a result of global warming,
which will place further pressure on wildlife that rely on these
beleaguered intertidal zones.
2.7 The enormity of these problems demands
immediate action and commitment from national, regional (?), and
local Government to ensure effective protection of the marine
environment. The challenges of a dying sea are matched by the
challenge of sustaining those industries dependent on the marine
resource. The expanding marine sector is highly export-oriented
and is a major provider of jobs. However, the marine industries
are plagued by a confusing regulatory and consent system governed
by a wide range of government departments and other authorities.
Many industry leaders believe that unless the system becomes more
transparent and simpler to use, they will be forced to develop
in other EU waters.
2.8 Supporting a vibrant marine industrial
sector and ensuring thriving marine biodiversity is a challenge
that lies at the heart of sustainable development.
3. GOVERNMENT
ACTION TO
DATE
3.1 The crisis has long been acknowledged.
In 1992, the UK Government signed the OSPAR Convention on the
Protection of the Marine Environment of the North East Atlantic.
The Convention committed the UK to:
— Take all possible steps to prevent
and eliminate pollution and necessary measures to protect the
maritime area against the adverse effects of human activities
so as to safeguard health and to conserve marine ecosystems and,
when practicable, restore marine areas which have been adversely
affected.
3.2 This included the requirement to publish
Quality Status Reports (QSRs). When published in 2000, the QSRs
highlighted the damage being caused by anti-fouling treatments,
endocrine disrupters, radio-active substances, eutrophication,
oil spills and ballast water and that fact that most fish stocks
are now at the point of collapse.
3.3 The wide ranging array of regulatory
and policy initiatives over the last 30 years, developed in response
to specific events, new legal obligations, problems encountered
due to the lack of proper management or protection and to public
pressure, are clearly not enough. The lack of both a systematic
and co-ordinated approach and an overall vision for managing the
marine resource has brought our seas to the brink. Critical issues
include:
— The lack of a national vision or
statement—There is no single government statement on the
marine environment that either draws together the areas for which
DEFRA, DTLR, DTI, MOD and others are responsible nor addresses
better co-ordination of devolved and non-devolved matters.
— A poor strategic framework—Below
low water mark, there are no policy instruments to bring together
regulation over a wide range of activities within a common framework.
Management and consenting regimes for potentially damaging activities
are largely sectoral, and environmental considerations are predominantly
incidental to the main purposes and powers of the bodies that
operate them.
— A complex statutory structure—The
myriad of policies that govern the marine environment place varying
degrees of environmental responsibility on relevant bodies. Examples
include the Water Resources Act 1991, the Water Industry Act 1991,
the Transport and Works Act 1992, Merchant Shipping Acts and Offshore
Regulations and the Sea Fisheries (Wildlife Conservation) Act
1992.
4. THE MARINE
STEWARDSHIP REPORT
4.1 The Government acknowledges that
the present management of our seas is failing, and has committed
itself to significantly improving the situation. On 1 May 2002,
the UK Government published its first Marine Stewardship Report
(MSR). It describes how the government will enhance marine nature
conservation to conserve biodiversity as well as improving the
management of marine resources and developing scientific research
to help government make more informed policy decisions. In stating
that the report represents the first step, it acknowledges that
"much remains to be done to turn our vision into reality".
4.2 The Wildlife Trusts entirely agree with
these sentiments since the report is basically a review of the
present, clearly inadequate set of initiatives. The right words
are used but the report contains insufficient action, which will
improve and change the current unsustainable approach. Inaction
is justified through yet more evidence gathering of the marine
wildlife disaster we know is underway. Integrated management is
discussed and then effectively dismissed through 44 separate initiatives
to be undertaken over an 18-year period.
4.3 There is much to support in the report:
commitment to clean, healthy, safe, productive and biologically
diverse oceans and seas underpinned by six underlying principles—sustainable
development, integrated management, conservation of biological
diversity, robust science, the precautionary principle and stakeholder
involvement and integrated through an ecosystem-based approach
is exactly what is required. However, the seas need a clear process
and legislative timetable to put that commitment into place. The
report fails entirely to put in any new powers or actions at a
UK level.
The Marine Stewardship Challenge
The Marine Stewardship Report should be able
to answer these questions:
1. How will the Government establish a marine
management system that has biodiversity conservation at the heart
of sustainable management of the marine resource?
2. How will the Government develop an integrated
strategy that delivers sustainable development?
3. How can the Government monitor the state
of the seas to check its policies are working?
4. How will the Government adequately implement
European Union (EU) requirements for strategic environmental assessment,
environmental impact assessment and deliver its obligations under
the Habitats and Birds Directives and fulfil recent commitments
made at OSPAR and at the North Sea Conference?
5. A NEW APPROACH
5.1 Integrated marine stewardship—a
new approach
5.1.1 The Wildlife Trusts have set out to
government a new approach that we believe can answer the Marine
Stewardship Challenge. It is an approach based on sustainable
development and the precautionary principle; an approach that
provides for long-term stewardship based on caring and understanding;
an approach that integrates all concerns—biodiversity, fishing,
industry—into an ecosystem-centred framework. The principles
upon which integrated marine stewardship is based are set out
below.
Principles for marine stewardship
Sustainable development—Development that
meets the needs of the present without compromising the ability
of future generations to meet their own needs (Brundtland Report,
1987).[4]
In a marine context, this would ensure that economic development
is framed in ways that both protects the marine environment and
is socially beneficial to the people who live, work and visit
our seas and coasts.
Integrated management—A strategically
co-ordinated approach to managing marine resources.
The precautionary principle—The precautionary
principle recognises the limitations of knowledge. To be alert
to—and humble about—the potential gaps in knowledge
that are included in our decision-making process is fundamental.
Where knowledge levels are simply not good enough to predict environmental
impact, the precautionary principle confers an approach that minimises
risk.
An ecosystem-centred approach—This approach
is based on considering impacts of all activities across the whole
marine ecosystem. It recognises that a healthy marine environment
provides a range of `free' environmental goods and services to
society.
Restoration of the seas—The approach seeks
to put the marine environment onto a recovery path that restores
the seas to a healthy state.
This diagram sets out how Government might deliver
Marine Stewardship
Annex 1 sets out a more detailed view on how the
Marine Stewardship Challenge could be delivered.
5.2.1 Integrated marine stewardship requires
all UK marine regulators, stakeholders and users to take responsibility
for the marine environment. An overhaul of the present confused
and overlapping arrangements is essential. Developing a coherent
institutional framework requires Cabinet Minister responsibility,
the creation of a separate marine department or agency or consolidation
of marine responsibilities into an existing department/agency.
5.2.2 Environmental responsibilities for
coastal waters are presently devolved. Given that marine ecosystems
operate as whole entities that transcend legal and geographical
boundaries, it is essential that devolved arrangements include
careful co-ordination to avoid duplication and confusion. This
approach has already been taken by DEFRA through the Review of
Marine Nature Conservation's Regional Sea Pilot which has ensured
the project boundary is based on regional sea rather than country
boundaries.
5.3 Primary legislation
5.3.1 Integrated marine stewardship requires
primary legislation. The Wildlife Trusts marine stewardship challenge
called on the Government to publish a White Paper that sets out
the Government's vision of integrated marine policy and management.
In order to implement this vision there will be a requirement
for a package of new legislation, including a Marine Act and/or
devolved Acts.
Lessons from abroad
An integrated approach to marine policy is not
a new idea. Other parts of the world have successfully developed
this approach. [5]
Australia—In 1996, Australia initiated
its Oceans Policy—a response to some 34 reviews (since 1989)
arguing for the pressing need for integrated marine policy and
that Australian seas under its jurisdiction be well managed and
protected. Launched in 1998, the policy is coordinated by a new
National Oceans Office and has had a good reception, although
concerns still exist over the protection/exploitation balance.
Nevertheless, this process is fundamentally guided by the ecosystem
approach—a prerequisite for managing the vastness of the
Australian tropical to Antarctic Ocean.
Canada—Similar legislation is used by
Canada, integrating policy, long term regional economic development,
sustainability and the delivery of an ecosystem approach.[6]
6. THE MARINE
STEWARDSHIP TOOLKIT
6.1 Assessment tools
The Wildlife Trusts believe that at the heart
of delivery of the Marine Stewardship Challenge there is the need
for integrated planning and management. We believe two assessment
tools are of particular use in developing integrated stewardship
plans: Strategic Environmental Assessment and Environmental Impact
Assessment.
6.1.1 Strategic environmental assessment
Strategic environmental assessment (SEA) has
to be transposed into UK legislation by 2004 under the EU SEA
Directive (2001/42/EC). The DTI has already undertaken to use
this methodology to license future UK continental shelf oil and
gas exploration. SEA ensures a formalised, systematic and comprehensive
approach to evaluating the environmental impacts of policies,
plans or programmes to be used for publicly accountable decision-making.
The assessments provide a mechanism for ecosystem-scale consideration
that may not always be possible through individual project assessment.
SEA should:
— Encourage consideration of environmental
and social objectives at all levels.
— Facilitate consultation between various
Government bodies and stakeholders and enhance public involvement
in the evaluation of environmental and social aspects.
— Encourage consideration of alternatives
that are either not obvious or not practical at the project environmental
impact assessment (EIA) stage.
— Render some individual project EIAs
redundant or less extensive in scope, if the impacts of a plan
or new programme are fully assessed at the SEA stage.
— Allow effective analysis of cumulative
effects and facilitate consideration of combined impacts, which
may be overlooked or outside the scope of individual project EIAs.
— Provide opportunities for identifying
areas where there may be beneficial cross-over between the needs
of different users of the marine environment (eg combining wind
farms and fishery no-take zones).
Perhaps most importantly, SEA should determine
appropriate and inappropriate sites for projects and facilitate
spatial planning decisions. For further information on SEA see
Annex 2.
Making SEAs work
Currently, SEAs have been applied in isolation
by different sectors. This approach is ineffective, as it cannot
resolve inter-sector conflict. Applying SEAs in a more holistic
manner aligns the approach with both the Common Fisheries Policy
and the OSPAR Convention and significantly addresses the marine
stewardship challenge. For example, the present UK oil and gas
sector-specific SEAs are deficient because they fail to take account
of potential conflict with other sectors: such as fishing, aggregate
extraction and offshore power generation. By only assessing product
and project impact, rather than policy impacts (eg a low carbon
economy), they do not deliver an ecosystem-centred approach.
6.1.2 Environmental Impact Assessment
Environmental Impact Assessments (EIAs) enable
a systematic examination of the environmental consequences of
a project in advance of the development predicting negative impacts
and developing mitigation proposals. Reviews have shown that present
EIA practice is poor[7],
in part because of the
— lack of detailed guidance;
— poor scrutiny systems by authorising
Government departments;
— inadequate historical baseline data
and, inadequate current empirical research;
— lack of will at Government level
to oversee and improve the process.
There are also limitations inherent in the EIA
process in that it:
— reacts to development proposals,
so cannot steer development away from environmentally sensitive
areas;
— has a limited ability to address
alternative developments or mitigation measures;
— does not adequately consider cumulative
impacts resulting from a number of developments being undertaken
in a given sea area, and
— does not adequately consider in-combination
impacts resulting from the interactions of a number of different
activities (eg aggregate extraction and fishing) being undertaken
in a given sea area.
6.1.3 EIA conclusion
EIA is a powerful assessment tool and an essential
part of the "ecosystems approach" toolkit. However,
EIA guidance and practice for UK marine industries needs to be
reviewed and improved in order that EIA fulfils its proper function.
Moreover, its inherent limitations are such that EIA is only an
effective tool when applied in combination with SEA, in order
to provide a strategic overview and context for individual developments.
6.2 Spatial planning
Once the resource has been assessed, the threats
identified, and the risks have been calculated, spatial planning
decisions can begin to be made. Spatial planning is about the
appropriate location of all maritime activities including the
provision of a representative network of Marine Protected Areas,
including Special Areas of Conservation, Special Protection Areas,
a network of national sites, fishery no take zones, permanent
or temporary areas of no exploitation and shipping designations
such as Marine Environmental High Risk Areas. A planning body
or agency needs to be established to ensure that there is a transparent,
integrated and strategic approach to the decision—making
process that involves all stakeholders. Spatial planning should
be carried out at a regional sea level (eg the Irish Sea).
6.3 Management tools
Once spatial planning decisions have been made
on the types of activities that should be permitted and appropriate
locations identified, a set of management tools must be applied.
These tools can be divided into two main groups: spatial controls
(requiring appropriate legislation to control activities in each
sea area) and level controls (setting out, for example, consent
conditions, limits on extraction, volume/concentration of polluting
discharge, limits on fishing, quantity of aggregate extraction).
6.4 Enforcement measures
Such control requires enforcement. Current enforcement
is carried out by a plethora of organisations and Government departments,
including the Ministry of Defence. All use their own working platforms
but patrol the same areas. In a number of circumstances these
services have joined forces to tackle certain issues such as drug
smuggling. In order to be cost effective and to avoid duplication,
law enforcement in the UK's marine environment needs to be rationalised.
However, it is important to remember that by including the full
range of stakeholders and users in the development of strategies,
plans and controls there will be greater "buy-in" and
a reduced need for enforcement.
Lessons from abroad
Australia—The proposed Australian Coast
Guard will operate as Australia's maritime police force. Its officers
will have the full range of law enforcement powers charged with
the detection, surveillance and law enforcement response to human
smuggling, drug smuggling, illegal fishing, search and rescue
operations, maritime safety and environmental protection.
The USA—The United States Coast Guard
has four strategic goals: Maritime Safety, Maritime Mobility,
National Defence and the Protection of the Nation's Natural Resource.
In their strategic plan 1999, the Commandant stated that its goal
for the nation's natural resource is to help the nation recover
and maintain healthy populations of maritime protected species
stating the Coastguard will eliminate environmental damage and
natural resource degradation associated with all maritime activities.
6.5 Recovery tools
Given inadequate management, and resultant over-exploitation
and damage, recovery tools are needed to restore habitats and
wildlife populations (including rebuilding fish stocks). An example
is provided by the Scoble Point project, which aims to re-create
a rocky seabed habitat in the Salcombe-Kingsbridge Estuary which
was smothered in dredge spoil some 14 years again. Granite blocks
have been carefully sunk to provide a substrate for recolonisation.
6.6 Regulation
Integrated marine stewardship also requires
an appropriate regulatory framework delivered through new primary
legislation, consolidating legislation to harmonise and fill gaps,
amending legislation where it is currently out of date; and repealing
and replacing legislation where it is no longer necessary or appropriate.
A Marine Act or Acts could also provide the framework for legislative
reform to address marine environmental management.
6.7 Research
The assessment and planning process will highlight
future research needs. Existing marine and coastal research programmes
of all UK research councils should place a priority on funding
practical research that helps to achieve the aims of this Marine
Stewardship Challenge. Action must be taken swiftly because of
the delays between providing funding for research and the availability
of results.
7. SUMMARY
The Wildlife Trusts believe that the UK, as
a maritime nation, can no longer sustain its current use and approach
towards the management of the marine environment. It is not meeting
its international obligations, nor is it meeting the demands of
its people and coastal communities.
We must adopt a new approach, based on sustainable
development and the precautionary principle. We must provide for
the long-term stewardship of our marine environment through an
integrated approach to the management of all our concerns whether
fishing, the extractive industries or our marine biodiversity.
We must rise to marine stewardship challenge.
Joan Edwards
The Wildlife Trusts
11 September 2003
Annex 1
1. Set Vision
1.1 Long term—eg clean and healthy
seas
1.2 Short term—action required
2. Set general principles
2.1 Precautionary
2.2 Polluter pays
2.3 User pays
3. Set general approach
3.1 Integrated
3.2 Transparent
3.3 Flexible
3.4 Pragmatic
3.5 Holistic
3.6 Strategic
4. Develop Toolkit
4.1 Assessment tools
4.1.1 SEA (non sectoral)
4.1.2 EIA
4.2 Delivery tools
4.2.1 Spatial planning (should involve mapping
and decision making about what activities take place and where,
cost benefit analysis will be a valuable tool)
— Areas for certain activities
4.2.2 Regulatory controls
4.2.3 Economic controls
4.3 Enforcement
4.4 Recovery tools
4.5 Focused research
4.5.1 Demonstration projects
4.5.2 Best practice
5. Strategy for implementation
5.1 Marine Act and nested marine legislation
5.2 Dedicated regulatory authority?
5.3 Budget
5.4 Monitoring
6. Institutional change—The development
of a common stewardship approach
6.1 Full stakeholder participation
6.2 Partnership
6.3 More public and sector awareness
6.4 More openness
6.5 Common data sets
Annex 2
STRATEGIC ENVIRONMENTAL
ASSESSMENT
Strategic Environmental Assessment is a formalised,
systematic and comprehensive process of evaluating the environmental
impacts of policies, plans or programmes and their alternatives.
SEA involves the preparation of a written report on the findings
of the evaluation, and the utilisation of findings in publicly
accountable decision-making. Put more simply, SEA is a process
that assesses the impacts of activities undertaken on a area-wide,
regional, national or even international scale as opposed to just
examining the impacts that may be associated with an individual
project, as would be the case with a project Environmental Impact
Assessment (EIA).
SEA potentially achieves the following:
— Encourages consideration of environmental
and social objectives at all levels, including those of policy
development, plans/programmes and specific project objectives;
— Facilitates consultation between
various government bodies and stakeholders and enhances public
involvement in the evaluation of environmental and social aspects
of policies, plans and projects;
— Encourages consideration of alternatives
that are either not obvious or not practical at the project EIA
stage;
— May render some individual project
EIAs redundant or less extensive in scope, if the impacts of a
plan or new programme are fully assessed at the SEA stage;
— Allows effective analysis of cumulative
effects and facilitates consideration of in-combination impacts,
which are likely to be overlooked or outwith the scope of individual
project EIAs; and
— Provide opportunities for identifying
areas where there may be beneficial cross-over between the needs
of different users of the marine environment (eg combining wind
farms and fishery no-take zones).
Perhaps most importantly of all, by facilitating
special planning decisions, SEA can determine areas that are inappropriate
or appropriate for development.
Whilst the primary concerns of SEA is examining
environmental impacts, it need not be limited to environmental
considerations. SEA can also be used to assess the implications
of a policy programme or plan for social or economic structures.
For example SEA might be used to take account of the potential
impacts of proposed actions on socio-economic factors including:
— Population demographic and distribution;
— Cultural values and assets;
— Overall quality of life;
EIA versus SEA
Due to its later emergence as an assessment
tool, SEA tends to be viewed as an extension of EIA. Rather, SEA
should be seen as a prerequisite to EIA, providing the essential
context and overview. Together, these tools can be used to produce
a comprehensive system of environmental assessment. By applying
SEA at an early stage, many of the shortfalls found within EIAs
are addressed, as is indicated in the table below:
Summary of the scope of SEA and EIA
| SEA | EIA
|
| Strategic | Specific |
| Applied to policies, plans and projects |
Applied to individual projects |
| Area/region basis | Site basis
|
| Can consider cumulative and in-combination effects
| Difficult to consider cumulative and in-combination effects
|
| Greater degree of flexibility | Constrained to specific projects
|
| |
The SEA Directive
In 2001, the EC Directive on Environmental Assessment of
Certain Plans and Programmes (2001/42/EC, known as the SEA Directive)
became law within the European Union. European member states are
currently working to transpose the Directive into national law
by 2004. The purpose of the Directive is to ensure that: "environmental
consequences of certain plans and programmes are assessed during
preparation and before adoption".[8]
SEA and the UK offshore oil and gas sector
Over recent years it has become increasingly apparent that
SEA can be used as a valuable tool to address the environmental
impacts resulting from the offshore oil and gas industry. Much
of the impetus for applying SEA to offshore oil and gas has come
at an international level. For example, in 1997 the International
Offshore Oil and Gas Experts Meeting in the Netherlands recognised
that:
"Prior assessment is important and baseline
assessments/studies valuable in predicting impacts. Some parties
do not consider environmental impact assessment to be sufficient
to determine impacts and believe that strategic environmental
assessment is necessary to accommodate cumulative impacts"[9].
The recent introduction of the SEA Directive has had a considerable
positive effect within the UK. Although the requirements of the
Directive do not have to be implemented until 2004, the Department
of Trade and Industry (DTI) has taken a policy decision that SEA
will be undertaken prior to future wide-scale licensing of the
UK Continental Shelf (UKCS) for oil and gas exploration and production.
To date SEA has been undertaken for two areas of the UKCS. SEA1
covers the area to the north and east of the Shetlands—known
as the white area and formerly subject to a territorial dispute
by the UK and the Faeroe Islands; SEA2 covers the "mature"
areas of the North Sea already subjected to extensive offshore
oil and gas activity.
Limitations of the current UK approach to SEA
Welcome and progressive as the current SEA process is, by
itself it is unlikely to comprehensively address the major threats
currently faced by the UK's marine environment. This is for reasons
including:
— The current SEA programme is sector specific,
focusing upon the environmental impacts resulting from the further
expansion of the oil and gas industry. While oil and gas exploitation
can potentially produce major impacts upon the marine environment,
so do a number of other activities such as fishing, aggregate
extraction and the development of offshore renewable power generation;
and
— At present the Government is applying the SEA
process to plans and programmes but not to policies, as a result
of the current scope of the SEA Directive. Consequently, no consideration
is being given to the indirect impacts that the use of the products
resulting from further oil and gas development might have upon
the marine environment. For example, the production and burning
of, potentially, millions of tonnes of fossil fuel will contribute
to further climate change that in turn will influence the oceanography
and ecology of the UK's marine environment.
The Wildlife Trusts believe that in order to combat these
shortcomings SEA should:
— Be extended to all activities likely to have a
significant impact upon the marine environment; and
— Form a key assessment tool within an integrated,
coordinated and strategic management regime for the UK's marine
environment, which has the ecosystem approach at its core. Such
a management regime should be brought about through the bringing
into force of an Oceans or Marine Act for the UK.
Overall conclusions
— EIA and SEA are powerful assessment tools and
are both essential items in the "ecosystems approach"
toolkit.
— EIA guidance and practice for the UK marine industries
needs to be reviewed and improved in order that EIA fulfils its
proper function.
— The use of SEA should be expanded to cover all
uses of the marine environment—in addition to oil and gas
exploitation—that may have a significant environmental and/or
social impact.
— SEA should form a key assessment tool within an
integrated and strategic system of marine management, which is
based on the ecosystem approach and brought into effect through
a UK Oceans or Marine Act.
Lisa Browning and Joan Edwards
The Wildlife Trusts
August 2003
2
The Wildlife Trusts. Marine Stewardship-Meeting the Challenge.
Joan Edwards. July 2002. Back
3
"Our Dying Seas?" The Wildlife Trusts. Colin Speedie
and Joan Edwards. July 2002. Back
4
Our Common Future (the Brundtland Report)-Report of the 1987 World
Commission on Environment and Development. Oxford University Press.1987.
ISBN 0-19-282080-X. Back
5
The Wildlife Trusts and WWF. Time for a different approach for
the marine environment. Marine Update 45. June 2001. Joan Edwards
and Sian Pullen. Back
6
The Wildlife Trusts and WWF Marine Update 47. Lessons from abroad.
Malcom Mc Garvin. Back
7
The Wildlife Trusts and WWF Joint Marine Programme has reviewed
EIA applications by comparing environmental statements of a random
selection of projects against the Commission's DGXI's environmental
checklist. Results were poor. A review of environmental statements
produced for offshore oil and gas developments. Mick Green (2000)
Environmental Impact Assessment in the Marine Environment. A report
to the Joint Marine Programme of the Wildlife Trusts and WWF.
Marine aggregate extraction. A review of selected Environmental
Statements. Report to the Joint Marine Programme of The Wildlife
Trusts and WWF-UK. Dr Miles Hoskin and David Marshall, MER (2003). Back
8
SEA Directive, 2001/42/EC. Back
9
Cabinet Office, Code of practice on written consultation, November
2000. Back
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