Memorandum from Sea User Developer Group
1. SEA USER
DEVELOPER GROUP
The SUDG comprises a number of industries which
are committed to the sustainable development of the marine environment.
Areas of work include offshore renewable energy, cables and telecommunications,
aggregate extraction, ports, Crown Estate, marine recreation and
the oil industry. The aim of the Group is to enable sea users
and developers to formulate views on marine policy, including
the Marine Bill, with a view to taking the opportunity to achieve
constructive changes to UK sea use management. Members of the
group represent 3.4% of UK GDP and in addition to a commitment
to delivering sustainable development also have a high degree
of corporate responsibility. The Group is committed to working
constructively to promote the importance of sea use and development,
better regulation, effective environmental protection and the
proper use of science in decision making. The Group therefore
welcomes the Inquiry being carried out by the EAC, notes the scope
of the Inquiry and welcomes the ambition to ensure an effective
and coherent Marine Bill.
2. CONSULTATION
DOCUMENT AND
PROCESS
Overall, SUDG feels the Defra consultation is
disappointing, because it is dealing with early stage issues,
about what might be done, rather than asking for opinions on specific
proposals. It would have been useful for consultees to have been
provided with a schedule of all of the remaining stages of the
entire Marine Bill consultation process. The Group also makes
a number of other points:
1. The Consultation Paper is very extensive
and is largely impenetrable to small businesses, which make up
a large proportion of various marine industries. The nature of
some of these industries is also such that the additional costs,
associated with the outline proposals within the Consultation
Paper, would be a major burden. This is not adequately acknowledged
within the consultation.
2. SUDG welcomes the statements within the
"Underlying Principles" section (4.1), confirming that
sustainable development principles will be at the core of the
Bill. This is vital for future economic development of the UK,
with its heavy dependence on the marine sector industries. The
major challenge of delivering these principles within the Marine
Bill remains.
3. Whilst the Defra consultation document
outlines five main themes for a Marine Bill, the consultation
only addresses four of these. The omission is Fisheries which
is excluded on the basis of previous extensive reviews and consultation.
However, there are signs within the Defra consultation document
that Fisheries may not finally be included within the Marine Bill,
due to it being a devolved matter. Given the extensive damage
to the marine environment from Fisheries activity (see the Royal
Commission on Environmental Pollution report), it is absolutely
vital that control of Fisheries is robustly included within the
Bill, otherwise it will lack coherency.
4. A major disappointment for SUDG is that
the necessary integration of marine activities across a range
of government departments and agencies has yet to be addressed.
The ambitions within the Defra consultation document cannot be
realised without such integration. Similar comments apply to the
issues which are devolved. SUDG believes that what is required
is a UK-wide approach to management and protection of the marine
environment. Consequently, solution of the devolved issues is
another pre-requisite for a coherent solution.
5. SUDG welcomes the ambition for the Bill
to incorporate a marine ecosystem approach. However, much remains
to be done to understand the full implications of this approach.
6. With respect to the underlying principle
of sustainable development, the background work to the development
of the Bill has so far focused heavily on "marine ecological
objectives", ie rather narrow conservation issues. The socio-economic
aspects have received little attention (this is probably because
of the Defra origins of the Bill). Much wider engagement across
government is required to ensure that the underlying principles
are indeed delivered in a coherent and effective manner. This
is a major area for strengthening required for the proposed Bill.
In particular, substantive involvement by DTI and HM Treasury
is needed. Thus, in response to the EAC question "Does the
Consultation Paper give due consideration to the many varied and
competing demands placed on the marine environment . . . ?",
the answer has to be "No".
3. CONCLUSION
Overall, SUDG believes that any Marine Bill
requires much more background work across government and the devolved
administrations before "an effective and coherent Marine
Bill" could be presented to Parliament.
June 2006
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