Memorandum from Trinity House
This Memorandum contains the response of Trinity
House to the invitation by the Environmental Audit Committee to
organisations to seek their views on the Committee's inquiry into
the new Marine Bill. In particular this Memorandum contains Trinity
House's response to the questions prompted by the Consultation
Paper published by DEFRA and in particular "whether due consideration
is given to the many varied and often competing demands placed
on the environment and, if so, how the Bill may be strengthened
to rectify the omission". Trinity House welcomes the opportunity
to assist the Committee in its Inquiry.
TRINITY HOUSE
Trinity House is one of three General Lighthouse
Authorities (GLAs) within the British Isles providing marine aids
to navigation. Trinity House has responsibility for England, Wales
and the Channel Islands. Trinity House is a corporation established
by Royal Charter, although its powers as a GLA are principally
derived from the Merchant Shipping Act 1995, as amended.
Trinity House's primary role is to deliver a
reliable, efficient and cost-effective aids to navigation service
for the benefit and safety of all mariners. This includes the
superintendence and management of all lighthouses, buoys and beacons
within its area and covers the inspection and audit of all local
aids to navigation, of which there are currently some 10,000. Additionally,
our statutory responsibility for superintendence and management
encompasses advising Government and determining the marking requirements
that operators of offshore structures, renewable energy developments
and aquaculture sites must establish in the interests of the safety
of navigation. This growth area is coupled with an increase in
decommissioned offshore oil and gas installations, which, where
left in position, often remain a hazard to navigation and need
to be marked by the relevant operator with suitable aids to navigation.
Trinity House also has powers under the Merchant
Shipping Act to mark, destroy, remove or raise wrecks that pose
a navigational hazard and which lie outside areas controlled by
harbour or conservancy authorities.
Trinity House, as a marine organisation, is
keen to ensure the protection of the marine environment and is
certified to the ISO 14001:2004 Standard (Environmental Management
Systems).
Does the consultation paper give due consideration
to the many varied and often competing demands placed on the marine
environment?
Trinity House agrees with broad objectives of
marine spatial planning laid out in paragraph 8.33 of the Consultation
Document. The objectives there mentioned recognise the need to
achieve a balance between the competing economic, social, cultural
and environmental needs in the marine environment and to create
a more efficient use of the marine space available to "strike
a better more considered balance, between inevitably competing
pressures".
In this regard Trinity House believes that the
Bill should recognise that as an island nation there should be
a balance between the importance of safety of marine navigation
and the protection of the environment. A single marine casualty
could undermine major environmental gains achieved over many years
(for example incidents such as the Torrey Canyon, Braer and
Sea Empress). Safety of navigation should therefore be a key
concern in marine spatial planning and in the Bill generally.
By way of illustration Trinity House considers
that existing established economically important shipping routes
should be safeguarded so that their use is not interfered with
or restricted by proposed development. In particular detailed
analysis of the impact on shipping routes must be considered when
the location for new marine development (such as an offshore windfarm
or new port facility) is considered.
In considering the impact on shipping routes
regard must also be had to the future, including the effects that
the development may have on established routes. For example, sediment
transfer due to the location of an offshore windfarm may eventually
cause a major diversion of a current well used route.
Another material concern is that marine spatial
planning should apply equally to all UK waters in order for it
to be effective. In particular a co-ordinated approach amongst
devolved administrations responsible for their own respective
areas must be achieved. For example certain areas of the Irish
Sea could be covered by waters under the control of England, Wales
and Scotland, Northern Ireland, the Republic of Ireland and the
Isle of Man. Furthermore, regional plans, if taken forward under
the Bill must adopt a coherent approach where they intersect between
one region and its neighbour, in particular at jurisdictional
boundaries.
From the particular perspective of Trinity House
as a GLA under the Merchant Shipping Act 1995, we are anxious
to ensure that we are consulted at the earliest possible opportunity
about the navigational marking and the implications for the mariner
of all proposed marine developments in our area of responsibility.
To this end Trinity House believes that it is essential that we
are consulted at the marine spatial planning stage, or earlier,
when development is first considered.
Finally, we are concerned to ensure that our
statutory responsibilities for, and ability to carry out, the
provision and maintenance of aids to navigation, including the
marking and dispersal of wrecks, should be undertaken expeditiously
for the safety of all classes of mariner and the marine environment.
If we were unable to respond quickly to a wreck or similar navigational
hazard, the potential for serious damage to the environment could
be very significant. We are anxious that the Bill should make
proper provision in this regard.
June 2006
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