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
|
