The Government consultation for the Marine Strategy Framework Directive (MSFD) is now open, which will help identify specific new measures to help tackle the marine litter crisis. A United Nations Environment Programme (UNEP) report estimates that 8 million individual items of litter enter the marine environment every day. We don’t believe that the measures currently suggested by the Government go far enough, and would like to see the Government seize this unprecedented opportunity to introduce much more ambitious targets and initiatives to reverse the growing volume and impact of litter on the UK coastline. Almost all of the measures proposed by the Government have already been in place for several decades and have so far failed to prevent the rising tide of marine litter, which has more than doubled in the last twenty years to 2,309 litter items per km of beach surveyed in the MCS Beach Watch 2013 survey.

We have officially submitted the Marine Litter Report to Defra’s Marine Strategy Framework Directive team, urging more radical action and a variety of sustainable, achievable and targeted measures to reduce marine litter. We have also submitted an official consultation response highlighting the inadequacies of the Government’s current approach. We are now encouraging all our supporters – every surfer, recreational water user, environmentalist, member and beach lover – to take this opportunity to participate in the consultation, joining us in calling for stronger action and leadership to reduce UK beach litter by 50% by 2020.

The consultation doesn’t solely focus on marine litter however our responses focus solely on this issue and possible measures (the consultation in fact addresses measures for 11 environmental descriptors outlined in the MSFD, some of which we’ll address separately, such as water quality). The consultation closes on 24th April.  We have provided example responses for you to copy, edit and paste as guidance.

Marine Strategy Framework Directive – Marine Litter Consultation

Please see the instructions and sample answers below and submit your response to the consultation below:

The first page of the consultation asks for your name, email address and organisation.  If you are responding as an individual please insert “recreational water user”.

Q1) Are the proposed measures for the Descriptor sufficient to meet the requirements of the directive, bearing in mind the current limitations in our knowledge base?

Select NO for D10 Marine Litter

Copy and paste the following text in the box provided for explanations:

In reference to the marine litter descriptor, firstly, I would like to register my disappointment at the inadequate targets set by the UK Government to address the problem of marine litter. Given the current level of marine litter and the rate at which marine litter continues to rise on UK beaches, I don’t believe that striving to reduce the amounts of litter on our beaches from 2014 litter levels by 2020 will sufficiently protect the marine environment, marine life and recreational water users. I support Surfers Against Sewage’s (SAS) calls to reduce levels of UK beach litter by 50% by 2020.

Furthermore, I believe that the proposed measures to address the dramatic rise in marine litter are also insufficient. Almost all of the proposed measures are existing measures that have already been in place for many years, during which time marine litter levels have more than doubled from 1,100 litter items per km of beach surveyed to 2,300 litter items per km of beach surveyed (Marine Conservation Society Beachwatch survey 2013). The proposed measures include the Environmental Protection Act 1990, the Urban Waste Water Treatment Directive 1991, the Clean Neighbourhoods and Environment Act 2005 and the revised Waste Framework Directive 2008.

There are only three new confirmed measures currently not in use – the OSPAR Regional Action Plan, Marine Plans and the single-use carrier bag regulations in England. 1) The OSPAR Regional Action Plan also focuses mainly on measures already in place. 2) The Government is currently unable to explain how Marine Plans can reduce levels of beach litter. 3) The current version of the single-use carrier bag charge for England allows exemptions for SME that employ less than 250 people, including franchises. Many beach businesses would qualify for this exemption and be allowed to continue to provide free single-use bags. The single-use bag charge also contains exemptions for paper and biodegradable bags. Paper bags are used by fast food outlets such as KFC and McDonalds and these bags consistently feature highly in litter surveys. Both these exemptions threaten to significantly undermine the effectiveness of this measure.

It seems clear that more effective measures are needed to properly address the consistent increase of marine litter. Surfers Against Sewage’s 2014 Marine Litter Report details realistic, achievable, targeted and proven actions and measures across all sections of society to better tackle marine litter. Suggested measures are based on the evidence that Surfers Against Sewage and its supporters have collected through years of experience tackling marine litter at grassroots coastal activities including community beach cleans.

Even more alarmingly, Surfers Against Sewage also predicts that current suggested measures identified in the Marine Strategy Framework Directive will fail to even keep the levels of marine litter on the UK’s beaches at the record high levels recorded in 2014.

Q2) Are there any additional existing or planned measures for this descriptor we have not identified that might also contribute to the achievement of the relevant environmental targets and achievement or maintenance of GES?

Select YES for D10 Marine Litter

Copy and paste the following text in the box provided for explanations:

In reference to the marine litter descriptor, Surfers Against Sewage’s Marine Litter Report offers a framework of existing practical and achievable measures to help achieve significant reductions in beach litter during the MSFD timeframe. This report can be downloaded here – http://www.sas.org.uk/wp-content/uploads/SAS-Marine-Litter-Report-Med.pdf. Surfers Against Sewage’s measures work towards:

• Stopping marine litter at source – preventing it entering the environment in the first place.
• Creating a circular economy through extended producer responsibility and greater corporate accountability.
• Amend current and creating new legislation to protect the coastal environment from marine litter.
• Dramatically up-scaling marine litter education and volunteering opportunities amongst coastal communities and the general public.

Surfers Against Sewage Measures:

Using Existing Legislation

• Balloon & Lantern Releases: Surfers Against Sewage is calling for intentional releases of balloons to be classified as littering and that outdoor releases be made illegal under existing legislation such as the Environmental Protection Act 1990 or the Clean Neighbourhoods and Environment Act 2005. Surfers Against Sewage is urging local authorities to ban balloon releases and for the UK to recognise this significant source of litter that pollutes our marine and coastal environment, harming wildlife, which requires a complete ban on outdoor releases for effective prevention.
• Beach Littering: Surfers Against Sewage is calling for Parish Councils to better use their powers of enforcement to tackle marine litter. Cuts to unitary, county and district local authorities mean there are fewer local Enforcement Officers to administer fixed penalty notices to people who drop litter. However, under the Clean Neighborhoods’ Act 2005, employees of Parish Councils and other authorised persons can issue fixed penalties for littering offences. Surfers Against Sewage urges Parish Councils to exercise these powers more forcefully, particularly at local beaches blighted by littering. This measure will also raise awareness that littering is an offence and deter would be offenders.
• Surfers Against Sewage will also support individual members of the public in the use of Litter Abatement Orders. Under the Environmental Protection Act (EPA), individuals can complain to the landowners about persistently littered beaches. If no action is taken to get the area cleaned, they can seek a Litter Abatement Order through the Magistrates’ Court.

Business

Surfers Against Sewage current campaigns including Return to Offender and Unidentified Floating Objects engage manufacturers and retailers with the impacts the packaging from their products, and in some cases their products, are having on the marine and beach environment. Surfers Against Sewage is calling on businesses to:

• Develop active and improved product stewardship strategies (Extended Producer Responsibility) to better protect the marine and wider environment from their products and associated packaging.
• Support school education programmes & wider behavioural change campaigns to transform how the public buys, uses and consumes products.
• Reduce the amount of unnecessary packaging used.  Support and facilitate re-use and recycling, particularly at beach and coastal locations.
• Support grass roots marine conservation initiatives and beach clean activities.
• Develop environmental impact icons and messaging to encourage recycling & better disposal.
• See http://www.sas.org.uk/campaign/return-to-offender/ for more details. These campaigns have recently resulted in several power stations preventing several tens of thousands of Taprogge Balls escaping into the marine environment annually. See http://www.sas.org.uk/campaign/ufos/ for more details.

Individuals & Communities

• Surfers Against Sewage is calling for individuals, communities and businesses to support and participate in activities to protect the coastline from marine litter including beach cleans and education events.
• In 2014 SAS mobilised 10,000 community volunteers across 335 community beach cleans and spoke to 4,000 pupils at education events. In 2015, SAS aims to mobilise between 10,000 – 12,000 community volunteers across community beach cleans. The charity’s vision is to build its grassroots volunteering capacity to engage, train and mobilise a network of up to 25,000 community beach clean volunteers by 2020. As part of this target, by 2020, Surfers Against Sewage aims to deliver 1,000 beaches cleans and implement 5,000 beach litter surveys annually as part of SAS’s on-going marine litter campaign commitments.
• More information – http://www.sas.org.uk/campaign/beach-cleans/

Education

• Surfers Against Sewage’s Seas For Life schools education programme includes extensive information on marine litter and available solutions. It also addresses the concept of citizenship and how students can have a positive impact on the marine environment to contribute to safeguarding fisheries, oceans, waves, beaches and other coastal assets. This programme reaches thousands of students annually and will continue to provide a strong educational opportunity on the issue moving forward.
• More information – http://www.sas.org.uk/campaign/education-materials/

Behavioural Change

Surfers Against Sewage’s Think Before You Flush initiative raises public awareness about the problem sanitary products (known in the business as Sewage Related Debris or SRD) cause in the sewerage system and marine environment if they are flushed down the toilet. In 2014 SRD was thought to be responsible for 253,000 blockages in the UK’s sewer system leading to clean up costs in excess of £80 million. The campaign also raises the awareness of the environmental impacts of plastics used in sanitary products and calls for a complete ban on plastic components that consistently pollute the marine environment such as cotton bud sticks and micro-beads.

The Think Before You Flush initiatives aims to:

• Create Think Before You Flush communities to help engage the public, raise awareness of the issue and impacts, and encourage responsible bathroom behavior to protect the sewerage infrastructure, sewage system capacity and the marine environment from sewage & plastic pollution.
• Ensure manufacturers of sanitary products remove plastics to prevent sewage system blockages and plastic beach litter. We are also calling on them to better educate their customers on responsible disposal of sanitary products and, in the case of sanitary wipes, to ensure that they never advise of disposal in the loo.
• Support a complete ban on micro-beads and other unnecessary plastic elements in cosmetic products.
• See http://www.sas.org.uk/campaign/think-before-you-flush/ for more details.

Q3) Are there any new measures that are needed? If so please provide details and evidence to show how they would contribute towards the achievement or maintenance of GES or the environmental targets as set out in the Marine Strategy Part One.

Select YES for D10 Marine Litter

Copy and paste the following text in the box provided for explanations:

In relation to the marine litter descriptor, Surfers Against Sewage published their Marine Litter Report, 2014 -2020 vision in 2014. The report can be downloaded at http://www.sas.org.uk/wp-content/uploads/SAS-Marine-Litter-Report-Med.pdf. The report features many suggested measures aimed at tackling marine litter, which I support, including:

• A UK wide container deposit scheme. The Beachwatch survey (2013) identifies 76 plastic drinks bottles per km of UK beach surveyed. The plastic bottle is consistently in the top 10 litter items in the Beachwatch survey. A container deposit scheme could address the impacts of this litter item, providing frameworks to ensure these items are reused and prevented from becoming waste, littering our towns, countryside and coastlines. Irn Bru have had a bottle return scheme in place since 1875. The scheme currently distributes approximately 30 million bottles annually. Container deposit schemes have been effective in reducing single-use bottle litter across Europe with Sweden, Denmark, Germany and Finland all operating successful schemes. For example, in Germany alone between 1-2 billion single-use containers have been removed from circulation since the container deposit scheme was introduced.

• A mandatory requirement for all caps and bottle tops to be attached to the bottle. Caps and bottle tops are the 2^nd most common item identified in the Beachwatch survey (2013). The stay tab was introduced in the 1980s and successfully addressed the issue of ring pull litter from beverage cans. A similar solution needs to be implemented for plastic bottles.

• Smoking bans or appropriately managed smoking zones for beaches suffering from chronic cigarette butt litter. The cigarette butt is the most littered item in the world with 4.5 trillion butts dropped annually. Surfers Against Sewage is calling for local authorities to create specific beach smoking zones with effective and well-managed cigarette butt bins, litter control measures & public information to minimise cigarette waste washed onto the beach from the local area. In exceptional circumstances at the most chronically affected beaches localised smoking bans may be the only solution to tackling this source of beach and marine pollution. Surfers Against Sewage also calls for more public information about the impacts of cigarette butt waste, the correct disposal of cigarette butt waste and for smokers to be supported on this journey with adequate and well-positioned ‘coastal ashtrays’, smoking zones and with a wider distribution of portable ashtrays at coastal locations. Surfers Against Sewage will continue to develop and distribute ‘No Butts on the Beach’ information, education materials, stickers and butt bins at outside events wherever possible. Plage Lumiere in the South of France is the first non-smoking beach in Europe. The smoking ban operates on a defined section of the beach but increase awareness and improved disposal practices by smokers outside the smoking ban area have been observed. There are also smoking bans in place on beaches in Italy and USA.

• The Operation Clean Sweep protocol, adopted by the British Plastics Federation in response to a Surfers Against Sewage campaign strives to minimise or eliminate plastic pellet loss from manufacturers, to safeguard the marine and wider environments. Small plastic particles are the most common litter item on our shorelines. I support SAS’s calls for the Operation Clean Sweep protocol to become a mandatory requirement at all factories using plastic pellets, reducing the numbers of small plastic particles entering the marine environment.

• The Think Before You Flush initiative calls for a ban on plastics in sanitary products that become sanitary related debris (SRD) and the removal of microplastics from shower gels, facial scrubs, toothpastes and all other products that enter the sewerage system. SRD makes up 4.3% of all marine litter in the Beachwatch survey (2013). Items like cotton bud sticks and tampon applicators are flushed down the toilet and escape into the environment after a failure in the sewerage network.

• Introducing more Environmental Protection Labeling: Surfers Against Sewage is calling for labeling on plastic packaging to include additional environmental warnings. New, impactful icons should be introduced to simply convey the environmental danger of plastic packaging, to mirror current, successful health & safety icons related to household chemicals and anti-smoking labeling.

• Fishing Waste: Surfers Against Sewage is calling for the fishing industry and government to develop better monitoring and regulation to eliminate equipment that is unfit for purpose, with particular focus on nets and tagging of equipment. Approximately 14% of UK beach litter comes from the fishing industry (Marine Conservation Society Beach Watch Survey).
• Surfers Against Sewage will undertake monitoring & reporting of marine litter as part of their ongoing and expanding community beach clean operations up to 2020, feeding in collected data to the Marine Strategy Framework Directive. Marine litter will be categorised, documented and reported on annually as part of SAS’s annual report and membership communications. This citizenship science project relies on volunteers to record their observations at UK beaches. Information regarding levels of litter on UK beaches is spars. Our additional monitoring will help SAS and regulators make better-informed decisions about future measures and actions to tackle the marine litter crisis.
• Please see the SAS Marine litter Report (http://www.sas.org.uk/wp-content/uploads/SAS-Marine-Litter-Report-Med.pdf ) and the SAS website (www.sas.org.uk ) for further details on all of these proposed measures.

Q4) Are there any measures proposed that you think are not justified or that will not contribute towards the achievement or maintenance of GES or the environmental targets set out in the Marine Strategy Part one?

Select YES

Copy and paste the following text in the box provided for explanations:

• In reference to the marine litter descriptor, whilst I accept the current measures could be used to address marine litter I’m concerned they have proven ineffective at tackling levels of marine litter over a prolonged period. The measures that are planned, but not yet implemented, are insufficient to make the impact needed to meet Good Environmental Status.

Q5) Do you agree with the justification for the use of exemptions under Article 14?

Select NO

Copy and paste the following text in the box provided for explanations:

I would accept exemptions are justified under certain circumstances. However, I have concerns about how Article 14 might be implemented inappropriately.

Whilst marine litter is undoubtedly a cross-border issue, the OSPAR UNEP ‘Marine Litter Preventing a Sea of Plastic’ report (2009) states that 80% of marine litter originates from land-based sources. Identifying the source of marine litter from items found on the beach is often incredibly difficult. Article 14 should only be implemented if the litter items can be accurately and positively identified as entering the environment from outside the UK’s territorial waters.

It is also important to recognise events such as shipping accidents, poorly managed landfill sites and other similar incidents can result in significant marine litter impacts but should not be exempt under the Article 14 as natural causes or force majeure. Proactive management actions can ensure these incidents are significantly reduced. For example, prioritising adequate resources during ship container loading and securing in ports, avoiding travelling in extreme weather conditions wherever possible or investing in appropriate coastal defenses around litter collection sites.

I also believe measures must not be exempt due to disproportionate costs, as these costs need to be met by the producer of the waste, for the good of the nation. For example, the beverage industry could argue that a container deposit scheme would be prohibitively expensive to implement and the current excessive use of single-use bottles is the most cost efficient method of beverage distribution. However, this ignores the depletion of natural capital for the nation and the excessive costs spent on coastal clean ups met by local authorities that are often struggling to provide vital services to communities.

 Q6) Are there any significant human activity-related pressures that are not addressed by the proposed measures?

Select YES

Copy and paste the following text in the box provided for explanations:

In relation to the marine litter descriptor, whilst the consultation suggests measures that could, in theory, be used to address the major marine litter inputs, in practice these measures have proven completely inadequate at preventing levels of marine litter more than doubling in the last 20 years. This clearly supports the need for additional measures to address the majority of human activity-related pressures. I would ask that the UK Government adopt the measures proposed in the SAS Marine Litter Report (2014).