This report presents the independent analysis of responses to the Consultation on a refreshed Marine Litter Strategy for Scotland. The consultation ran from 29 December 2021 to 22 March 2022.
The Scottish Government has made a commitment to refreshing the 2014 Strategy, and Marine Scotland, with and through the Marine Litter Strategy Steering Group, has been engaging with key stakeholders and partners over the last three years to take stock of the original Strategy and to identify objectives and actions to help inform and shape a refreshed Marine Litter Strategy and Action Plan which is currently in draft form.
The public consultation
The purpose of this public consultation was therefore not to repeat the earlier engagement process progressed by the Marine Litter Strategy Steering Group. Rather, it sought feedback on the draft refreshed Strategy and on the range of actions that have been identified as priorities to guide the work of Marine Scotland and partners up to 2027.
A total of 220 responses were received to the consultation and a vast majority were submitted by individuals (75.5%). The remainder were from organisations spanning a diverse range of remits and interests, including: coastal development and conservation; communities; environment and conservation; industry; and other.
The consultation attracted campaign responses, primarily from individual respondents, and these expressed support for a ban on wet wipes containing plastic and support for Extended Producer Responsibility (EPR) schemes. The following is not meant to be an exhaustive list of points raised through the consultation, rather the executive summary presents some key themes. The main report contains the more detailed analysis and a response from Marine Scotland regarding how they will respond to the comments.
Given the cross-cutting nature of the Strategic Directions, some themes were raised throughout the consultation questions. For example, terrestrial litter is mentioned throughout.
Strategic Direction 1: Improve public and business attitudes and behaviours around marine and coastal litter, in co-ordination with the National Litter and Flytipping Strategy.
The vast majority of respondents (individuals and organisations) agreed (i.e. either agreed or strongly agreed) that the planned actions under each of the four objectives would contribute to the achievement of Strategic Direction 1:
- Encourage positive behaviour and deter littering and flytipping (85.5%).
- Improve waste management in the fishing and aquaculture sector, by establishing systems to support the collection and recycling of gear (86.9%).
- Improve waste management for collected marine litter (87.4%).
- Reduce sewage related debris (SRD) through a behavioural change campaign (84.6%).
More than half of respondents considered there to be omissions or gaps in the planned actions identified under Strategic Direction 1 (57.4%).
The main points raised in relation to the objective to 'encourage positive behaviour and deter littering and flytipping' were: greater enforcement of existing regulations; incentivising responsible waste disposal; and EPR schemes. There were also a few comments that called for more technological solutions, such as tagging and tracking of litter, and more effective public awareness campaigns.
In relation to the objective to 'improve waste management in the fishing and aquaculture sector', the most common points raised were support for actions that would encourage the fishing and aquaculture sectors to do more in this area, and support for actions which aim to make it easier to recycle gear.
The objective to 'improve waste management for collected marine litter' attracted few comments with most commentary concentrated on stopping litter at source. The main feedback also highlighted the challenge of limited facilities in Scotland for the recycling or disposal of end-of-life fishing gear.
Comments regarding the objective to 'reduce SRD through a behavioural change campaign' were divided, with many organisation respondents supportive of the planned public awareness campaign, whilst individuals were more skeptical. Many individuals felt that wet wipes containing plastic and/or other single use plastics should be banned or reformulated rather than relying on public awareness raising. Industry respondents (e.g. companies involved in the manufacture of wet wipes and related industries) raised a number of objections to any ban or reformulation of wet wipes containing plastic, and put forward a case that a switch to biodegradable wipes would not be a solution, including that a distinction should be made between domestic and professional use wet wipes.
Strategic Direction 2: Reduce marine and coastal based sources of litter, with a focus on the most problematic sources, in co-ordination with land sourced litter being reduced by the National Litter and Flytipping Strategy.
The vast majority of respondents (individuals and organisations) were in broad agreement that the planned actions under each of the following three objectives would contribute to the achievement of Strategic Direction 2:
- Reduce plastic pellet loss into the marine environment (89.1%).
- Improve the ability of the fishing industry to retrieve lost fishing gear from the sea (82.0%).
- Reduce sources of SRD (86.4%).
Just over half of respondents considered there to be omissions or gaps in the planned actions identified under Strategic Direction 2 (52.6%).
In terms of the actions related to the objective to 'reduce plastic pellet loss into the marine environment', the main points raised centred on: a need for fines/penalties; support for improved monitoring of plastic pellet loss; and support for the adoption of the British Standards Institution (BSI) Publicly Available Specification (PAS) standard as part of a supply chain approach.
Wider points expressed support more broadly for reducing the overall production and use of plastic, microplastics and single use plastic items, alongside research into more environmentally friendly alternatives and materials.
In response to the objective to 'improve the ability of the fishing industry to retrieve lost fishing gear from the sea', several points were raised. As above, consideration of fines/penalties was an issue that was raised here too, and across the consultation. Preventative measures to tackle the issue of lost fishing gear was considered important. There was acknowledgement that progress would be heavily reliant on the ability and willingness of the fishing community to spend time and resources on retrieval and that there were various challenges and external factors at play. Here, various suggestions were proposed to encourage retrieval, including a deposit return scheme, a payment for fishing gear returned for recycling, and a scrappage incentive, to name a few examples.
The actions that support the objective to 'reduce sources of SRD' attracted most feedback within Strategic Direction 2. There was broad support for actions that promoted long-lasting behaviour change and improved product labelling for correct disposal, alongside actions that encouraged better control of pollution incidents and sewage overflow discharges from sewage treatment plants to prevent wet wipes that are not designed or marketed as flushable ending up in the environment.
Two main viewpoints were expressed regarding the proposal for a mandatory standard and a blanket ban regarding the manufacture and sale of wet wipes containing plastic:
- Individuals and most sub-categories of organisation respondents (i.e. all except industry), felt that the action could be more strongly worded/phrased and that the proposed timeframe was not considered urgent or quick enough. Further, there was feedback that expressed support for a wider ban on plastic in other single use items (e.g. tampon applicators, etc), and for manufacturers to be mandated to move to environmentally friendly alternatives within a reasonable timescale.
- Industry (e.g. companies involved in the manufacture of wet wipes and related industries), while supportive of minimising pollution from wet wipes that are inappropriately disposed of, highlighted wider complexities that would need to be considered. For example, the diversity of wet wipes on the market (e.g. domestic versus professional use). Here, it was suggested that any future legislation should make a distinction between wet wipes as is the case in the European Union (EU) Single Use Plastics Directive (2019/904), in particular given the role that professional wet wipes play in effective prevention and control strategies. It was noted that non-flushable wet wipes, which represent most wet wipes in the marketplace, are not designed to be flushable and disposing of them down the toilet would not be appropriate for a variety of reasons and should be disposed in an appropriate bin. Further work/time was felt to be needed for industry to develop satisfactory alternatives that were effective and not prohibitively expensive e.g. for products used for infection prevention.
Strategic Direction 3: Support the removal of marine litter from the marine and coastal environment.
The vast majority of respondents (individuals and organisations) agreed that the planned actions under each of the following four objectives would contribute to the achievement of Strategic Direction 3:
- Reduce the cost of disposal of collected marine litter (84.4%).
- Increase the number of rivers in Scotland with co-ordinated projects to reduce litter levels, including removal (91.3%).
- Expansion of the Fishing for Litter project (89.7%).
- Installation of riverine litter removal technology in the River Clyde (84.5%).
Views were relatively mixed - approximately one-third of respondents considered there to be omissions or gaps in the planned actions identified under Strategic Direction 3 (38.0%). A similar proportion were unsure.
In terms of planned actions to support the objective to 'reduce the cost of disposal of collected marine litter', much of the commentary focussed on beach cleaning. Here, it was felt that the Strategy's narrative on beach cleaning could be stronger (e.g. scale of the problem, heavy reliance on volunteers) with some noting that it could be considered as a standalone objective. It was noted that paid staff would be needed over and above volunteers, with greater attention also given to supporting beach cleaning operations in the most polluted areas, those areas not covered by volunteer schemes and/or those areas deemed inaccessible to be cleaned without specialist support. Further, increased funding/support could help local authorities make collection and recycling more accessible.
For the objective to 'increase the number of rivers in Scotland with co-ordinated projects to reduce litter levels, including removal', projects such as those run by Keep Scotland Beautiful were welcomed and considered important. However, actions to support the continuation, scaling up and extension of such projects would require additional funding to ensure a long-term focus. The importance of preventing marine litter at source and tackling the problem upstream was also emphasised. The important co-ordination role of Non-Governmental Organisations (NGOs) was also highlighted in terms of their ability to access their pool/bank of volunteers to help conduct much of this work.
Mixed views were provided on the two actions related to the 'expansion of the Fishing for Litter project' objective. On the one hand, the action to 'promote the Fishing for Litter scheme within the fishing industry and to ports, harbours and fishers not currently participating' was welcomed, supported and considered a good approach. An alternative view questioned whether the project had been able to demonstrate success/impact based on funding to date while another respondent felt that the action sought to appease an industry that has caused much of the damage in the first place.
The main points raised on the two actions relating to the 'installation of riverine litter removal technology in the River Clyde' objective can be summarised as follows: could the technology be implemented in other river catchments, etc; and there was agreement that the boom installed would need to be appropriately monitored and maintained to ensure no unintended consequences – and followed up with effective community engagement.
Strategic Direction 4: Improve monitoring at a Scottish scale and develop measures for Strategy evaluation.
The vast majority of respondents (individuals and organisations) agreed that the planned actions under each of the five objectives would contribute to the achievement of Strategic Direction 4:
- Use of Fishing for Litter initiative data to evaluate industry engagement (85.9%).
- Accurate assessments of marine plastics in Scottish waters (86.0%).
- Development of an agreed methodology for inter-tidal microplastic monitoring (82.9%).
- Social science evaluation of the Marine Litter Strategy (81.4%).
- An understanding of Scottish island beach litter (89.7%).
Views were mixed on whether there were omissions or gaps in the planned actions under Strategic Direction 4. Around one-third each answered "yes", "no", or "don't know" to the question.
The objective 'use of Fishing for Litter initiative data to evaluate industry engagement' was underpinned by support for the planned actions: to 'increase engagement in both new and participating harbours', and to 'improve the quality of data collection'. This was often expressed in the context of fishing debris and waste accounting for a significant proportion of marine litter in Scotland. To facilitate greater industry engagement, a few respondents highlighted the importance of ensuring sufficient infrastructure (e.g. weigh bridges) was available at harbours across Scotland.
To fulfil the objective to provide 'accurate assessments of marine plastics in Scottish waters', the planned action to 'expand OSPAR monitoring beaches to include an open coast northeast beach' was welcomed by most respondents. More generally, it was considered important to focus on weighing and identifying the source of marine litter. Barriers to accurate assessments were, however, reported as seasonal and geographical variations in data collection and volunteer capacity.
In taking forward the 'development of an agreed methodology for inter-tidal microplastic monitoring' objective, feedback from several respondents supported a harmonised approach as set out in the action plan. It was also considered that there would be value in learning from existing methodologies adopted elsewhere (e.g. internationally).
Few comments were provided on the objective regarding a 'social science evaluation of the Marine Litter Strategy'. A point raised was that this may be "too subjective" to gather reliable data. It should be noted that the social science evaluation, by its very nature, is to gauge how individual people value the natural environment – it is not meant to be a substitute for scientific monitoring.
Most respondents welcomed and understood the rationale for including a specific objective that focussed on developing a greater 'understanding of Scottish island beach litter'. Here, there was recognition that marine litter is a significant issue in island communities, and that such communities face a particular set of challenges (e.g. smaller populations, less capacity/resource, logistics, and costs, etc).
Strategic Direction 5: Maintain and strengthen stakeholder co-ordination in Scotland, the UK, regionally, and globally.
The vast majority of respondents (individuals and organisations) agreed that the planned actions under each of the four objectives would contribute to the achievement of Strategic Direction 5:
- Expand communications and understanding of Marine Litter Strategy work with delivery partners (89.0%).
- Build on and strengthen working relationships with wider UK (83.2%).
- Increase engagement with OSPAR through: participation in and implementation of the Regional Action Plan for Marine Litter; and taking a lead role with relevant actions (80.8%).
- Strengthen co-ordination across the British-Irish Council region (83.4%).
A relatively high proportion of respondents overall (and individuals in particular) were unsure whether there were any omissions or gaps in the planned actions identified under Strategic Direction 5 (39.8%). Just over one-quarter (27.6%) said there were omissions or gaps.
The main comments under the objective to 'expand communications and understanding of Marine Litter Strategy work with delivery partners' were primarily from organisations with a focus on communities who noted that community groups were a valuable resource (e.g. litter picking activities, providing intelligence through surveying and monitoring activities, advocates for national campaigns and driving change in their local communities). As such, community groups and volunteers were viewed as an integral part of helping to deliver the Strategy and it was felt that this could be more fully reflected within the document. The importance of regular and ongoing community engagement and involvement was also considered vital.
In relation to 'building on and strengthening working relationships with the wider UK', the most common comments were to stress the transnational nature of marine litter and that collaboration with other jurisdictions was vital, and that having differing standards across the UK (e.g. for wet wipes) could have detrimental impacts on manufacturers and consumers.
There were few comments on the objective to 'increase engagement with OSPAR', beyond a few which welcomed the planned increased engagement. Similarly, 'co-ordination across the British-Irish Council region' was also considered essential.
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