Memorandum submitted by Surfers Against
Sewage
Surfers Against Sewage campaign for clean, safe
recreational waters, free from sewage effluents, toxic chemicals
and nuclear waste. Using a solution based argument of viable and
sustainable alternatives, SAS highlight the inherent flaws in
current practises, attitudes and legislation, challenging industry,
legislators and politicians to end their "pump and dump"
policies.
Surfers Against Sewage (SAS) welcome the opportunity
to submit written evidence to this Inquiry. Our submission will
focus on those issues with the potential to directly affect the
recreational water user.
The rich and diverse waters around our island
are under constant pressure from man. We are an island nation
with 10,000 miles of coastline, the sea is part of our heritage
and plays an important role in shaping our nation, both geographically
and socially.
The marine environment and all it yields is
too often viewed as a resource to be exploited. It is seen as
a dustbin for our waste, as a source of protein, a route for all
manner of vessels and a provider of energy.
SAS have welcomed the governments' acknowledgement
of the need to safeguard our seas, and acknowledge the positive
move in recent times to pull together all the aspects of our marine
environment and to develop a comprehensive, integrated management
strategy.
Quite clearly, managing our marine environment,
(acknowledging all the sectors who want a piece of that environment)
and ensuring that we do not damage it any further, is a mammoth
task, one which SAS doubt can be done without a single co-ordinating
body, with statutory powers.
1. LACK OF
A SINGLE
OVER-ARCHING
INSTITUTION
The Government have so far remained committed
to their decision not to introduce a Marine Act and thus a single
agency with overall responsibility for the marine environment.
SAS are concerned that despite the plentiful discussion of new
measures, new initiatives, designations and targets, the lack
of co-ordination that has blighted marine management until now,
will continue unless a single institution takes responsibility
for the entire package.
The elements contained within the documents
"Seas of Change" and "Safeguarding our Seas"
are all valid constituents in the package that should ultimately
deliver for the marine environment. Marine designations serve
a purpose, the precautionary principle should most certainly be
applied, extensive monitoring and research are a vital part of
the equation, as is stakeholder involvement. The polluter pays
principle should be adopted. There is no doubt that these are
all essential elements, but there is a danger, as with so much
government policy that the words will be there on paper, but there
will be nothing to show for them in reality.
2. A LACK OF
URGENCY
Protection of our marine environment is an urgent
matter, yet even following crises, such as the collapse of fish
stocks and devastating shipping accidents (in addition to ongoing
pollution hazards), the government fails to act with any real
sense of urgency. Public and stakeholder consultation is essential,
but using the information gathered, quickly and effectively is
equally important. It is here that government often fails.
3. STRATEGIC
ENVIRONMENTAL ASSESSMENTS
(a) The government have recognised that
in order to deliver their vision for our marine environment—"Clean,
healthy, safe, productive and biologically diverse oceans and
seas", it will be necessary to adopt an ecosystem based approach
to marine management. SAS are in agreement with this approach.
(b) Strategic Environmental Assessment is
a necessary tool for delivering this ecosystem based approach.
The purpose of SEA is to take a holistic approach, looking at
a particular area or a particular ecosystem and determining the
potential impacts that activities within that area could have
over time. Information is gathered so that decisions can be made,
strategies and policies can be developed and this is all done
on a far wider scale, taking into account more factors than Environmental
Impact Assessment (EIA).
SEA incorporates socio-economic and ecological/environmental
factors which facilitates the development of management measures
such as the designation of sensitive areas or no take zones, the
setting of limits on volumes of pollutants discharged or amounts
of a resource that can be exploited sustainably. SEA is also an
essential tool when making planning decisions. It ensures that
no one factor is viewed in isolation and reflects reality in that
it recognises that the actions of one sector will have implications
for another. SEA should encourage a balanced approach to policy,
planning and decision making in the marine environment, provided
it does not become sector biased.
(c) The advantage of SEA over EIA is that
with the broader scope of SEA it is possible to identify problems
earlier, which means it is possible to make far more extensive
changes to plans at the SEA stage than at EIA stage. This allows
for more flexibility.
SEA can be used to identify potential areas
for projects or activities to take place and EIA can then be carried
out at sites which are not only suitable, but where it is known
that there will be the least possible impact on the marine environment
and society.
By taking into account all inter-relating factors,
SEA encourages the identification of potential synergistic and
cumulative impacts.
— It is essential that SEA is applied
not only to plans and projects but also to policies. This is the
only way to close the circle and to acknowledge the full impact
an activity or a product will have through its entire life cycle
on both the environment and society.
— It is vital for SEA to be applied
to all activities that have the potential to impact significantly
on the marine environment.
— SEA (at a programme/policy level)
should be used in conjunction with EIA (at a individual project
level).
The Wildlife Trusts and WWF have well established
views on the use of SEA, SAS support their position.
4. DESIGNATION
OF MARINE
ENVIRONMENTAL HIGH
RISK AREAS
(a) This concept was introduced in the Donaldson
report, "Safer Ships, Cleaner Seas" published in 1994.
The report was the product of an Inquiry following a catastrophic
oil spill, the Braer. It is hardly remarkable that such an event
prompted an Inquiry. What is remarkable however is that nearly
10 years on, the majority of the recommendations in this report—including
MEHRA designations, have not been implemented. Despite a government
consultation in 1999 and the promise of a further one early in
2003, we have seen no movement in this area. Meanwhile shipping
accidents continue to pose a threat, as incompetent crews, manning
inadequately maintained vessels are given free reign to travel
around our coastline.
(b) It is vital that the designation of
a MEHRA is accompanied by a suite of management measures such
as mandatory pilotage, areas to be avoided, traffic separation
schemes etc. A MEHRA must not simply become a designation marked
on a navigational chart in the hope that vessels will pay closer
attention when in the area. It must be a meaningful designation
with the potential to deliver real benefits, this means there
must be penalties if the specified management measures attached
to a MEHRA are ignored.
(c) It is essential that stakeholders including
NGO's are consulted on the proposed location of MEHRA's as well
as the management and mitigation measures to be introduced.
5. THE UK'S
NATIONAL CONTINGENCY
PLAN IN
CASE OF
A MARINE
INCIDENT
(a) The UK is an island nation, yet when
the RMS Mulheim, on its way from Cork to Lubeck, ran aground with
its cargo of car waste near Lands End, Cornwall, we were forced
to wait for salvage equipment to arrive from Ireland and Holland.
In the days it took for the right equipment to arrive, the vessel
became open to the sea and her cargo of toxic plastic car waste
washed into the ocean.
The cargo hatch doors had been opened in order
to start retrieving the car waste before the correct equipment
had arrived. Opening the cargo hatches weakened the vessel, making
removal from the rocks impossible.
If specialist salvage equipment had been available
in the UK, it is possible that the vessel would not have lost
her cargo and that she would no longer be stranded on the rocks
of Gamper Bay.
(b) There are 300,000 major ship movements
around the UK coastline each year. We still only have four emergency
tugs for the whole of the UK.
(c) An emergency contingency plan is an
essential part of successful marine management. You can have all
the necessary precautionary measures in place, but if an accident
does happen in spite of this, a realistic contingency plan that
is based on a current and accurate assessment of risk to the marine
environment, will be all there is stopping an accident turning
into a catastrophe.
6. THE POLLUTER
PAYS PRINCIPLE
(a) The Polluter Pays Principle is an essential
part of the ecosystem based approach to marine management.
Whether it be a water company failing to operate
a sewage treatment works correctly, a ship spilling oil or a factory
illegally discharging chemical waste, we still fail to ensure
that the polluter pays a fine that is proportional to the size
of their environmental crime.
Magistrates rarely fine up to maximum amounts
allowed and that appears to relate both to pollution offences
with their source on land and those occurring at sea. According
to the Advisory Committee on the Protection of the Sea in 2002
there were less than three prosecutions from over 400 illegal
spills.
(b) Identification of special areas requiring
protection—such as SPA's and SAC's is one of a number of
management tools, but until the polluter finds it more inconvenient
to pollute than not to, individuals and organisations of all sizes
will continue to abuse what is a slack system.
12 September 2003
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