Draft Scottish Marine Litter Strategy: Analysis of Consultation Responses

This report presents the analysis of responses to the Scottish Government’s ‘Consultation on a Draft Scottish Marine Litter Strategy'. The consultation closed on 27 September 2013.


Question 2 - 4 Vision

Q2. Do you agree with this vision?

Q3. Does the draft vision have the right level of ambition?

Figure 2 - Distribution of responses to Question 2

Figure 2 - Distribution of responses to Question 2

Questions 2 and 3 were answered by 24 people. Of those that responded, 50% were broadly content with the draft vision and level of ambition, although a number of respondents suggested additional text which could be incorporated to strengthen the vision.

Half of respondents to these questions felt that the vision was too vague in its ambition, and some respondents offered an alternative form of wording for the vision.

Two respondents felt that the Vision was not measurable and baselines should, therefore, be established.

Five respondents indicated that the Vision should go further than the targets set for Good Environmental Status. In particular, two respondents suggested that the Vision might include a target of an overall reduction of litter which may not be visible, and requested that this be investigated as part of the review process.

Overall, six respondents sought clarity on the definition of the term 'significant risk' in the vision. Respondents felt that it was not clear how progress against this target could be measured. One respondent suggested that 'significant risk' should be replaced with 'harm'.

There were a number of suggestions to changes to the Vision from small numbers of respondents:

  • The addition of words 'coastal', 'litter' and 'redesign' to read "By 2020 marine and coastal litter … and redesign, reduce, reuse, recycle and recover waste and litter resources".
  • A further two respondents felt that the Vision should explicitly include coastal as well as marine litter.
  • One respondent felt that the focus on waste should be broadened to include wider and related issue of behavioural change.
  • Two respondents suggested that there should be a reference to existing legislation and the role of enforcement in reducing litter.
  • Two respondents suggested that the Strategy should build on current work to manage marine litter removal by supporting volunteer groups, beach managing authorities and by ensuring enforcement policies are consistent.
  • One respondent thought that the Vision should include a reference the key Strategic Directions and also sources of litter.
  • One respondent suggested an alternative "By 2020 marine litter in Scotland is significantly reduced so that the integrity and function of marine ecosystems is not compromised and there is no significant risk to communities and human health. This is …".
  • One respondent suggested that the establishment of recycling plants would fulfil the vision of recovering waste resources.
  • One respondent suggested that the word 'act' should be replaced with 'manage waste'.

One respondent suggested that the Vision could be strengthened by including text which emphasises the treating of waste as a resource.

While a few respondents expressed a view that tackling litter at source is key, others expressed concern that the focus of the Strategy was on prevention of litter at source and thought that the vision should also seek to include a target of an overall reduction of litter, particularly for those items of litter which may not be visible, such as microplastics. In addition, one respondent made reference to abandoned fishing and industrial materials in the marine environment and suggested that free recycling schemes should be established to target these types of litter.

A few respondents highlighted the importance of linking the Strategy to the Litter Strategy in addressing litter from land based sources.

Q4. Do you think implementation to achieve Good Environmental Status under Descriptor 10 will be sufficient or do you think additional action in Scotland is necessary?

Question 4 was answered by 22 respondents. This question has two parts. There was a mix of responses with 45% (one individual; and nine organisations with a mix of Environmental and Local Groups, Local Authority organisations and Others, including the third sector) expressing a view that action in Scotland should go further than current Good Environmental Status targets for Descriptor 10:

Two respondents stated that there needs to be action to address the non-visible litter items in the marine environment, including the coastline.

Three respondents highlighted that there is an opportunity to set percentage targets, specifically in relation to OSPAR's [2] ecological quality objective where the baseline is known.

One respondent felt that additional action should be taken if there was to be a noticeable effect on marine litter levels and costs associated with tackling litter.

One respondent suggested that additional action required should include the promotion of regular beach cleans and marine litter surveys, as well as preventative measures.

One respondent felt that while a lack of data was an issue, that more ambitious targets should be set but acknowledged that this would likely require additional resources.

One respondent highlighted that there should be additional action because of the importance of the marine environment on industry and tourism.

Of those respondents that felt the strategy, combined with implementation under Descriptor 10 would be largely sufficient, a range of comments were received:

One respondent suggested that there may be benefit in undertaking a review of all current marine litter initiatives to gain an understanding of any resource gaps.

One respondent stated that a pragmatic approach would be to aim to meet Good Environmental Status targets rather than unrealistic goal setting beyond these targets.

Three responses highlighted the need for a standardised method of monitoring to be developed and implemented, with one highlighting that this was required to enable the development of longer term targets. Two of those respondents suggested that consideration could be given to the development of effective litter indicators such as categories/types of litter. Further to this point, one respondent expressed a view that in the absence of a baseline it was difficult to ascertain whether additional action or targets would be required.

One respondent stated that while action under Good Environmental Status will be sufficient now, there may be changes required as research develops. It was also suggested that the findings of the Marine Strategy Framework Directive Task Group 10 report (2010) should be considered. A further respondent highlighted the need for the Good Environmental Status targets to be robust and supported by an adequate programme of measures.

One respondent highlighted the key issues as being source control measures, linkage with the National Litter Strategy and ensuring that measures apply consistently to all sectors.

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