The link to the Consultation is here:
My response:
In general it is difficult to disagree with the aspirations outlined in the section entitled Planned New Actions up to 2027. My concern is that the timescales identified are simply too long. There are some issues that can, I suggest, be easily dealt with now, without waiting for the results of monitoring and, no doubt, further consultations on specific aspects.
I annex for reference the text of the response I received to my FOI request FO190551 in June 2019. The first section shows that instead of things starting in 2022 and ending with ideas by 2027 the governmental ambition was to have plans in place by 2016 and to have things under control by 2020. The last twenty years have seen a massive increase in all types of pollution and the environment cannot wait any longer.
This response is confined to three specific types of marine waste, (a) large, easily identifiable items, such as pieces of fishing equipment, net, creels, bottom gear and components of fish farm cages and supporting equipment, (b) microplastics, specifically from aquaculture and (c) items which by their nature cannot be identified, such as sections of plastic rope and twine.
Large Items
From coastal excursions over the years I can confirm that our remote island beaches are littered with large fish farm components. I annex a photograph taken on Luing a few years ago as an illustration. In August 2019 I saw, on the shore at the Westmost end of Ulva, a section of pipe about twenty metres long, utterly impossible to remove without mechanical help and/or a suitable vessel. As we all know, such items once beached become the responsibility of the local landowner to remove, a completely unjustifiable burden when the source is invariably one of the hugely profitable foreign companies who are allowed into our coastal waters.
The very obvious solution to this is for there to be a requirement that all such items have an identifier attached, perhaps in the nature of a barcode, so that the cost of removal can be met by the polluter. The industry itself accepts this in respect of the retail products in our supermarkets. The requirement would not require to wait for legislation, as, for example, it could easily be made a condition of planning consent or a SEPA CAR licence.
Microplastics
These are the most insidious of all, as we are constantly and credibly informed by the media that they are everywhere. The use of plastic feeding pipes started only quite recently. Fish farm workers were still seen feeding fish manually from sacks of pellets in the early years of saveseilsound, when we were gathering evidence for our campaign.
We are all, the Scottish public, Marine Scotland and SEPA included, being treated with extreme cynicism by the aquaculture industry, who know that the standard process adopted to replace workers on site inevitably puts microplastic into the water column, not to speak of the salmon they are rearing. This practice is entirely deliberate and in principle no different from the fly tipping, which your report rightly treats very seriously. Fish farm companies should be told to stop forthwith under threat of prosecution.
Other waste
For centuries the fishing industry has dumped waste deliberately, in the form for example of small offcuts of rope or accidentally when fishing gear has been lost, but until very recently that materials were more or less biodegradable. This has only become a pressing issue in the recent past, when it has migrated totally to the use of plastics. Particularly insidious is the practice of using cheap inferior quality plastic line for such purposes as temporary ties. I can affirm that in a short walk along the shore here one will see dozens of such scraps.
The most obvious solution to this is to ban the use of plastics as much as possible, just as land based industries are being encouraged or forced to do. I appreciate that this will require further consultation and eventually, legislation. It will no doubt be met with the standard response that our “indigenous” fishermen know best, despite their choice of materials being anything but.
Conclusion
In relation to two of these categories of waste Marine Scotland can and should act now. Please do so!
Annex:
SEPA FOI dated 18 June 2019 ref: F0190551 - Information regarding the dumping of plastics and microplastics on our West coast.
Question 1 Many of our coastal inlets and skerries are becoming littered with debris from fish farms, for example discarded black plastic feeding tubes and fish cage components, some as large as 80 metres in length, image of an example from Mull annexed. Does SEPA have any responsibility for pollution of this sort, as opposed to pollution from microplastics, which I assume are central to your functions?
Under the terms of Regulation 9 of the EIRs, SEPA has a duty to provide advice and assistance. We advise the larger items of waste referred to fall to the local authority to regulate, as part of planning applications process, the applicant would be required to submit a waste/litter minimisation and management plan to ensure the safe disposal of waste material and debris associated with the operation of the development.
In relation to fish farms the introduction of the technical standard for Scottish finfish aquaculture will have helped to reduce the amount of equipment that is lost to sea. Though primarily designed to prevent escapes of finfish due to technical failure, the secondary effect is that there is also a reduction in the loss of equipment during storm events. This is due to the Standard covering the design, construction, materials, manufacture, installation, maintenance and size of equipment; taking into account the site specific environmental conditions e.g. wave height, wind and current speeds.
However, once lost from a site it is often difficult to attribute an item to a particular site or company, and the item would essentially become ‘marine litter’. Marine litter is one of the descriptors of ‘good environmental status’ (GES) under the Marine Strategy Framework Directive (MSFD), which requires all member states to have put in place a programme of measures by 2016 to ensure that ‘properties and quantities of marine litter do not cause harm to the coastal and marine environment’ by 2020. Concerns such as marine litter have become more broadly recognised and will be addressed through the operational response to the MSFD. Marine Scotland has published a Marine Litter Strategy as part of its overall approach to marine planning and management which provides guidance on managing the adverse impacts of marine litter. In supporting the Scottish Government’s commitment to achieve GES as part of the MSFD, regional marine plans should raise awareness of the problems associated with marine litter and encourage marine users and developers to dispose of litter in ways which do not harm the marine environment.
Though not directly within our remit, SEPA does have a direct involvement in ensuring that these wastes are stored, transported and disposed of appropriately.
SEPA will on occasions refer cases where marine litter from fish farms has become apparent to companies operating in the vicinity of the litter and this frequently results in the waste being uplifted from the shore and properly disposed. We may also advise the Crown Estate or Local Authority of such incidents.
Regarding micro-plastics, these are now known to be present everywhere in the water environment where water comes into contact with plastic. We currently do not regulate the discharge of micro-plastics however, we recognise the concerns around micro-plastics, and we are in discussions at UK and EU level to develop our understanding of any impact, and how they can be most appropriately regulated.
Question 2 In recent years, in order to reduce their labour force, fish farms have replaced the feeding of stock manually with systems involved the pumping of fish pellets through plastic tubes similar to the one in the annexed image. Doing this necessarily abrades the insides of the tubes and creates microfibres, which enter the marine environment either directly or after being consumed by the salmon in the cages. The companies concerned know that this happens, monitor the thickness of the tube walls and replace them when they are too thin. Research in Norway has recently suggested that in their industry this causes about 325 tonnes of microplastic waste to enter the water column each year, see
If we assume that the Norwegian industry is about 5 times the size of the Scottish one it would appear that perhaps 65 tonnes is entering our environment. Is SEPA aware of this source of pollution? And If so, what action is SEPA taking? As referred to in response to question 1 we currently do not regulate the discharge of micro-plastics however, we recognise the concerns around micro-plastics, and we are in discussions at UK and EU level to develop our understanding of any impact, and how they can be most appropriately regulated.
