Select Committee on Environmental Audit Written Evidence


Memorandum from The Save Our Seabirds Charitable Trust

  The Save Our Seabirds Charitable Trust which aims, not only to rescue and support the rescue of injured seabirds, but to reduce the pollution which injures them, welcome belated signs of governmental abandonment of a piece-meal approach to marine problems, but has serious concerns about the content of a Marine Bill as set out in DEFRA's Consultation Document. They are listed below along with constructive proposals which are essential in legislation purporting to contribute to "Safeguarding Our Seas", (Mr Ben Bradshaw, Minister for Local Environment, Marine & Animal Welfare, paras. 10.4 & 10.6, pp.89, "Introduction"). 141 questions to respondents suggests uncertainty.

  Proposals to demarcate "closed areas" for shipping and fishing and protected coastal sites for birds are a nod in the direction of conservation and the Trust welcomes them. They are largely taken from the 2002 Bill brought by Mr John Randall MP on behalf of the RSPB: it failed because the RSPB's knowledge of birds was not matched by its knowledge of the sea. Since, however, some "closed sites" and protected coastal sites have already been established and are proving successful, legislation is unnecessary. All that is required is a swifter, adequately resourced and more energetic response from DEFRA but the financing proposed in the Document is derisory (Annex SC: table 3 p.248).

  The proposals for the Bill stress mechanisms to introduce licenses for use of the sea-bed. They are essential for the establishment of environmentally friendly wind, tidal and wave power. However, licensing has long been used to allow dredging companies to operate; again no need for a Bill as a precedent has already been set. The Trust agrees the need for enforcement, but it must be powerful enough to be effective.

  The government appears less concerned with urgently needed marine conservation measures than implementing EU Directives. Not surprisingly, Mr David Bench, Head of Marine Legislation Division, DEFRA, has informed the Trust that Section 7 of the Marine Bill Consultation Document, "Managing marine fisheries", has been dropped so avoiding consideration of the hostile criticisms of the EU common fisheries policy by the House of Commons Fisheries Committee and probably also by the 40 or so local Fisheries Committees listed among the 1100 "consultees". It is not possible to consider comprehensively the whole marine ecology and biodiversity of our coastal waters if the fisheries are omitted. The sea-bed, where fish lay their eggs and the fry hatch out, is home to other sea creatures notably sandeels, vital food for the disappearing cod and seabirds whose failure to breed in the last 2 summers, exposed by the RSPB, is due less to a rise in the sea's temperature than to a shortage of their natural food. Factory fishing above all by the Danes, sanctioned by the EU, led to the collapse of the sandeel fishery in the North Sea last July. The catastrophic slaughter of thousands of seabirds through major shipping disasters is not mentioned in the Document.

  DEFRA and Wildlife organisations pressing for a Marine Bill disregard the sea itself; ever moving it carries pollutants put in it which are deposited in the sea-bed in closed areas, sites of submarine scientific interest and anywhere else.

  There are glaring omissions in DEFRA's Consultation Document: no mention of the International Maritime Organisation and the MARPOL series of Conventions aiming to reduce marine pollution, nor of Lord Donaldson's Report on Pollution from Merchant Shipping Round UK Coasts: how effective have the resulting anti-pollution measures been? "Charting A New Course", the government's dismayed admission in 1998 that Britain needs a merchant marine, is ignored. The RMT and T&GW Union for ratings and port workers respectively were not consulted. The officers' union, NUMAST, was, but there is no word of its despairing call in 2000 for regulation of the shipping industry because poor maintenance was causing many wrecks. Most wrecks, not just the great tanker disasters, pollute as tanks rust and engine oil, used and unused, seeps into the sea. Many vessels still unlawfully discharge wastes including oil in order to cut "turn around time" spent in using port facilities.

  Shipping has always been global free enterprise. If the sea is to be protected from poisonous wastes it must be brought under the same voluntary tightly observed safety regulations as the much younger air transport industry. P&O NedLloyd's sale of container ports, notably Felixstowe, to Dubai Ports World, raises fear of more oil pollution as the Emirates alone have not signed the IMO MARPOL Conventions and there is heavy oil pollution in the Gulf.

  The Document refers to sewage pollution; the government has largely complied with EU Directives on providing Secondary Treatment which leaves millions of faecal bacteria in a 100 ml sample of water. But the EU leaves optional the highest Tertiary Treatment for population equivalents of 100,000 plus. Round the south east coast where our Trust operates, there are a number of them and will be more if government plans to increase housing go ahead. Tertiary treatment is being provided eg to protect oysters, but not directly to protect people immersing themselves in the sea in recreational pursuits. Coliforms, extraneous to the marine ecology are trapped on the sea-bed and churned up by rough seas according to the Environment Agency.

  A mere Marine Management Committee in DEFRA, which has shown so little awareness of the sea, is not adequate to deal with its vast complexity. A powerful government Department of the Sea is urgently needed to run licensing and establish the co-operation of marine professionals, not only the Chamber of Shipping and Institute of Chartered Shipbrokers, but the IMO, the ILO, and the three seafarers' trade unions, Lloyds and other shipping insurers, essential for improving the safety of shipping, as well as environmental interests and the excluded fisheries. The cost of regulation and enforcement would be reduced by giving responsibilities to existing organisations already involved—by restoring the Coastguard to full professional strength, providing resources to the Maritime & Coastguard Agency, especially the Counter-Pollution Branch, and the Royal Navy.

June 2006





 
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