Marine Scotland’s Marine Litter Strategy 2022 Consultation – Plastic@Bay Response

Marine Scotland is updating their Marine Litter Strategy, and it is now out for consultation. The last Marine Litter Strategy was published in 2014. Plastic@Bay have been fighting ocean plastic pollution in NW Scotland since 2017. We have witnessed indescribable damages linked to plastic pollution. We have faced this problem without support from the authorities, who do not recognise that the coast of NW Scotland is one of the most polluted coasts in Europe (probably in the world). To tackle this problem, we have introduced novel methods of monitoring of plastic pollution, conduct our own research on the pollution dynamic and remove vast quantities of pollution (within limit of our capacities). We found that within the tons and tons of plastic washing up locally, the large majority was associated with the marine industry: fishing, aquaculture and shipping. This fact is observed all along the coastline and on the Islands by other groups, and rural communities, from Tiree to Shetlands. We have started recycling fishing ropes and nets, and designing community recycling workshop and facilities to give some real solution to rural coastal areas most affected (and ignored). After studying the Marine Litter Strategy 2022 carefully, we have concluded the objectives and actions underpinning the strategy are not sufficient to help these communities.

If you want to get involved we have written a set of questions to ask your MSPs that would elevate the debate and gear us towards efficient solutions. You can find them at the end of this document.

Response

Strategic Direction 1 – Improve public and business attitudes and behaviours around marine and coastal litter, in co-ordination with the national litter and fly-tipping strategy. Action will include:
* A review of enforcement of the terrestrial littering and fly-tipping regulations.
* The development of a waste management system to improve recycling routes for end of life fishing gear.

Marine Scotland must implement the ‘Extended Producer Responsibility’ on Fishing Gear, making manufacturers pay for collection and recycling.

Under the EU Single Use Plastic Directive, Extended Producer Responsibility obliges producers to cover the costs of gathering up the waste plastic items that are discarded in the public collection system. If Scotland intends to align with this Directive, it must hold manufacturers of plastic fishing gear accountable in the same way. Manufacturers should cover the cost of collection and recycling of end-of-life fishing gear (ELFG) at ports, and the costs of removing old fishing gear and associated plastic from the beaches and seabed of Scotland. 

By 2025, the EU Single Use Plastic Directive requires a minimum collection of 50% of ELFG and the recycling of 15%. There is no indication in the actions or deliverables of Objective 2, that Marine Scotland is considering recycling of ELFG. There is one company in the EU, based in Denmark, that recycles polyolefin ropes and nets; the kind used by most Scottish fishermen, fish farms and the shipping industry. To ship plastic abroad from Scotland to Denmark is prohibitive both in cost and environmental footprint. In 2016, KIMO was unsuccessful in implementing such a scheme in Scotland. Has the Scottish Government considered incentivising recycling of polyolefin ropes and nets here? They would make a valuable employer. 


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 fly-tipping strategy. Action will include:
* Considering a range of policy options to reduce sources of sewage-related debris.
* Contributing to the development of an international plastic pellet certification scheme.

Marine Scotland have failed to recognise net cuttings and waste from aquaculture and shipping as a major source of ocean plastic pollution.

Cuttings of nets and ropes, generated at sea and in ports, are a major source of ocean plastic pollution. This has not been addressed in the Strategy. Surveys carried out in NW Scotland (mostly Durness) over a six month period (May 2021 to Oct 2021), show that net and rope cuttings between 5 > 50 cm account for 30% of ocean plastic pollution by weight (Figure 1). A survey of pollution removed between November 2021 and February 2022 showed similar results; Total 801.5 kg, rope and net 429.7 (53%), fish farm feeder pipes 225 kg (28%). Additionally, in 2017, we surveyed just 3 metres of Scouriemore, a deeply polluted cove on the NW coast and counted 10,471 rope cuttings (Figure 2). KIMO International has also identified rope and net cutting as a major source of ocean plastic in the North Sea, in a recent report.

Figure 1. Statistics of monitoring 79 beach cleans made in the Durness area from the 07-05-21 to the 21-10-21. Ocean plastic is categorised by type (hard plastic, foam, ropes and nets, and MOD (Ministry of defence) flares) and size (meso (0.5 – 5 cm), macro (5 – 50 cm) and mega (over 50 cm)).

Figure 2. Clockwise from top left: Beach cleaners at Coigach, Western Ross. Net Cutting becoming part of the soil matrix, Scouriemore, Scourie. A collection of net cutting for recycling, Plastic Lab, Durness, Sutherland. Another picture documenting how net Cutting becoming part of the soil matrix, Scouriemore, Suthreland. Usually collection from a winter beach clean at Balnakeil Beach, Dunress, Sutherland. Collection of net cutting collected near Scourie, Sutherland.

The aquaculture and shipping industries are significant sources of plastic pollution and must not be overlooked. The latest gear inventory report by Defra, shows that aquaculture in Scotland produces 4,000 tonnes of plastic waste annually. Fish and shellfish farms  are also major consumers of plastic nets, ropes and associated gear (buoys, feeder pipes, drum barrels, mussel pegs, oyster bags, etc. Figure 3). These items comprise a substantial proportion of the ocean plastic pollution we survey and clean from the NW coast. 

Figure 3. Clockwise from top left: 800 meter fish-farm pipes Duart Beg, Scourie, Sutherland (June 2019). Float from fish farm, Whiten Head Grey Seal Colony, Sutherland (Oct 2017). Fish-farm pipe, East Faraid Head, Durness, Sutherland (10th Dec 2019). 80 meters fish-farm pipes cut up to clean off Balnakeil Beach (Nov 2021). Large fish farm float, Balnakeil Beach, Durness, Sutherland (Jan 2021). Oyster bags, Balnakeil Beach, Durness, Sutherland (23rd April 2021). Collection of mussel pegs from cleans around Durness, Sutherland, picture taken March 2020. Fish-farm pipe on Orkney (April 2019). Fish-farm pipes, Oldshoremore, Kinlochbervie, Sutherland (14th Feb 2022). Fish-farm pipe, East Faraid Head, Durness, Sutherland (28th Dec 2019). Fish-farm pipe and float, East Faraid Head, Durness, Sutherland (22nd Feb 2021). Fish-farm pipe, Balnakeil Beach, Durness, Sutherland (Oct 2019). Fish-farm pipe, Balnakeil Beach, Durness, Sutherland (Feb 2020).

Strategic Direction 3 – Support the removal of marine litter from the marine and coastal environment. Action will include:
* An expansion of work to remove litter from rivers, thereby preventing this reaching the marine environment.
* Improving the efficacy of projects which remove litter from the sea, and investigating the potential for an initiative to recycle the material collected.

Marine Scotland have failed to include beach cleaning in their, Strategic Direction to ‘Support the removal of marine litter from the marine and coastal environment.’

The major gap in the consultation is the omission of beach cleaning. 

  • Omitting beach cleaning from the objectives shows that Marine Scotland has no idea of the volumes of plastic washing ashore on the coast of Scotland (Note 1). 
  • Marine Scotland is relying on the goodwill of volunteers to remediate ocean plastic pollution generated on land and at sea by very profitable industries. Professional surveying and cleaning by trained personnel is required to fully grasp the intensity of the pollution (Note 2). 
  • Beaches are a major sink for ocean plastic pollution. In the West Highland and Islands over 50% of plastic pollution is generated at sea. This plastic typically floats and will not be picked up by trawl nets (Note 3). Marine Scotland needs to start supporting major beach cleaning operations in the most polluted areas. This would complement the prevention of pollution entering the ocean via the Clyde, and expanding the KIMO program ‘Fishing for Litter’.

Note 1: Quantification of ocean plastic pollution washing ashore in Scotland.

Plastic@Bay offers a research portal where beach cleaners and groups can enter location, date and quantity of marine litter after a clean.

GroupQuantity
(Kg)
Location
Turning the Plastic Tide 45763East Grampian Coastal Partnership, Aberdeenshire
Caithness Beach Cleans36245Thurso Area, Caithness
Ocean Gives 20067Isle of Tiree
Plastic@Bay9890Durness, Kinlochbervie and Scourie, Sutherland
Pringle’ family4080Scourie, Ullapool and Stoer, Sutherland and Wester Ross
Pentland Canoe Club1000Loch Eriboll, Sutherland
Table 1. Total pollution cleaned from beaches in Scotland (116,145 kgs) recorded on Plastic@Bay Research portal between 2018 to 2021. 

If you further examine the most monitored beaches; Dunnet, Sandside, Thurso and Scrabster, Caithness (Caithness Beach Cleans) and Balnakeil Beach, Sutherland (Figure 4), it is clear that the pollution rate (kg/day right corner Figure 5) is either increasing or stable. On the worst hit beaches, such as Dunnet beach, the average pollution rate is 11 kg/day, which equates to 4,000 kg annually. 

These results show that the actions proposed by Marine Scotland in their Marine Litter Strategy 2014 have had no effect on ocean plastic pollution levels in these areas; on the contrary, all the pollution rates are increasing. 

The quantities given here do not account for the plastic stored in coastal sediments which could increase these pollution volumes 5 to 10 fold.

Figure 4. Statistics on beaches cleaned more than 20 times from data entered by beach clean groups in the Plastic@Bay Research Portal.
Figure 5. Weight Accumulation graphs, accumulative weight versus time with average pollution rates kg/day (right) of the eight most cleaned beaches recorded on Plastic@Bay Research Portal [6].

Note 2: Employing trained staff to monitor and clean, works!

When funding has been available, Plastic@Bay have intermittently employed a Coastal Ranger to clean and monitor plastic pollution around Durness, Kinlochbervie and Scourie, NW Highlands. During these times the quantity of plastic we can remove doubles or triples. In our experience, employing someone to clean, monitor and survey is the most effective way to clean the coastline. This method drastically increases the quantities of plastic being removed and it increases the efficiency of cleaning, thus allowing more coastline to be covered than by just relying on volunteers. 

Another excellent example is Turning the Plastic Tide, an initiative by East Grampian Coastal Partnership, whereby Crawford Paris was employed as a Beach Litter Officer, to monitor the coast and organise volunteer-based beach cleans. They have removed 45 tonnes of plastic since Aug 2018. 

Note 3: Beaches are a sink for ocean plastic pollution.

In rural coastal areas of Scotland, such as the Highlands and Islands, with low populations and no major river systems, over 50% of the pollution washing ashore is generated at sea by fishing, aquaculture and shipping. It does not mostly come from the land via rivers, as suggested by Marine Scotland in this Strategy and in their 2020 report (See Comments on Strategic Direction 4). To suggest otherwise illustrates a lack of understanding of the dynamics of plastic pollution in the ocean, and that Marine Scotland is not properly monitoring the most polluted areas of Scotland. 

Within the KIMO’s Fishing for Litter Scheme the major proportion of plastic collected via trawls is denser than water, such as nylon fishing gear. However, the majority of plastic pollution washing ashore floats (Polypropylene_PP and Polyethylene_PE). PP & PE ropes and nets are the most common type of gear used by Scottish fishermen and fish farms, along with PE fishboxes, oil drums and fish farm feeding pipes, this is what make up the vast proportion of the plastic washing ashore in the Highlands and Islands.


Strategic Direction 4 – Improve monitoring at a Scottish scale and develop measures for strategy evaluation. Action will include:
* Contributing to the development of an agreed methodology for inter-tidal microplastic monitoring.
* Improving the quality of the data being obtained from litter removal projects.

The approaches will not expose the extent of the pollution in Scotland

Plastic@Bay surveys of ocean plastic pollution cleaned from beaches in NW Highlands show that between 50 to 90% of what we remove by weight (Figure 1), is from fishing (Figure 2) and aquaculture (Figure 3)

Numerous newspapers have reported the devastating effect that plastic pollution from these industries is having on beaches around Scotland and its islands. Some examples are listed below:

  • Beattie, K. (2022, Jan 5th). Shetland seal’s escape from ‘floating death traps’ of netting. The Press and Journal.
  • MacLeod, M. (2021, Oct 28th). ‘Fish farm waste is a ‘complete disregard for the environment’. Stornoway Gazette 
  • Eden, T. (2021, July 29th). Kilted up Prince Charles dons a kilt as he meets volunteer beach cleaners on the first day of Scotland visit. The Scottish Sun.
  • Merritt, M. (2021, June 19th). Artist tries to turn the tide on plastic in Tiree. The Times.
  • Edwards, R. (2019, Oct 10th). Outrage over loch polluted by plastic waste from fish farm companies. The Ferret.
  • Merritt, M. (2019, July 10th). Shock at 20 tonnes of plastic littering Scottish beach. The Herald.
  • Enoch, N. (2018, April 13th) So much for unspoilt beauty: Hiker reveals shocking haul of rubbish he catalogued as he walked 1,000 miles around the coast of Scottish islands. Mail Online.

“I’d like to tackle him [the Prince of Wales] about fishing because 99% of what we pick up is fishing related – nets, creels etc – in case he can use his influence.”

Dorcas Sinclair of Caithness Beach Cleans

We welcome the expansion of monitoring areas to include ‘an open east coast beach’, in order to more accurately assess ocean plastic pollution in Scottish waters, but monitoring needs to be expanded nationwide and all year round. 

We notice vast variations between the summer, when most surveys used by Marine Scotland are made, and the winter, which lacks data. On Balnakeil Beach (Figure 6) about 1000 kg of plastic is deposited in 4 months of winter, with ‘only’ 500 kg during the rest of the year. This pattern has been observed for 5 years.

Figure 6. Seasonal pollution Balnakeil Bay from may 2017 to December 2021. Note the increase in pollution during the winter.

TThe survey method using OSPAR methodology, run by volunteers, does not accurately record the impact of some industrial plastic pollution in Scotland. We believe this is a major omission that skews perception of the most important sources of marine plastics:

  1. This method surveys the abundance of beach litter, i.e. the number of individual items. However there is a major difference in size between industrial-scale plastic fragments and mismanaged waste pollution. In consequence, numerous small items could hide the major pollution in volume. The danger of plastics comes mainly from their fragmentation potential – the bigger the initial size of the piece of plastic, the higher the risk. We consider that both the source and the size of plastic fragments (measured by their weight) are critical to understand plastic pollution. This is why many groups are now considering measuring the weight of the debris in their research. This has been highlighted in a Marine Scotland study (Smith and Turrell 2021), where fishing gear accounts for just 6% by abundance but 41% of the total weight of plastic found in beach surveys in North-East Scotland. Similar results are found by Plastic@Bay in NW Scotland and by the Ocean Cleanup in the Great Pacific Garbage patch.
  2. Volunteers are not professional scientists and surveyors. They will generally participate in monitoring pollution during the summer months, when it is pleasant. The most populated areas will have the most volunteers and thus will be most surveyed. This explains the asymmetry in the pollution maps provided by Marine Scotland, that contain nearly no datapoints from the West Coast and Hebrides.
  3. Pollution is site specific and will be influenced by local human activities, past and present. To be able to evaluate and solve a local pollution issue, the monitoring method should be adaptive. There is an urgent need to go beyond the 25-year old OSPAR methodology, developed in a situation where plastic was not such an ocean pollution emergency.

If you have made it the end, congratulations and thank you for your interest. We are passionate about fighting plastic pollution. If you have any comments on our consultation we would be happy to hear them. This is a working document, and will be saved and sent to Marine Scotland before the 22nd March 2022.


Questions you could suggest to your MSP to ask the government

Question 1

There is a report about to be released by DEFRA and Future Resources for the whole of the UK on quantifying the amount of plastic fishing gear in use and in the environment. Unfortunately it is not yet publicly available, according to some of Plastic@Bay calculations these may account to a million tons + of plastic to manage each year. Yet we have no British solution scaled to the problem. When will we be ready?

Question2

In the marine litter strategy, some of the main consumers of the plastics found on the shoreline in vast quantities by Plastic@Bay CIC surveys are not mentioned as a potential source, i.e. the aquaculture and shipping industries. How can a pollution plan function if the main industries involved are not considered ? 

Question3

Marine Scotland published in 2020 that 90% the pollution is from land sources in Scotland without mentioning the source of this statement. However, in some of the most polluted areas of the Scottish coast, i.e. the north-west and islands, there is no big river system or any potential land source for the industrial-scale plastic pollution that we observe. In contrast we and other groups monitor the dominance of plastic generated at sea. When will these areas and industrial impacts be considered a priority?

Question4

Plastic fishing equipment is going under the Extended Producer Responsibility  that will soon be implemented in the EU. Scotland wants to follow these guidelines. Are the Scottish manufacturers aware of this? Are manufacturers prepared to cope with the expenses and duty they will have?  A consequent part of the gear used in Scotland is manufactured in Asia, how do we deal with it?

Question5

Fishing and fish farming gear is highly technical and plastic has totally replaced natural fibres in these industries. Is the government ready to explore solutions to re-establish natural fibre production in Scotland both by allowing agricultural production of fibres, encouraging Scottish net manufacturers to get out of the “all plastic” and attract leading-edge industries to develop alternatives to plastic for the benefit of the marine industries and our environment?

Question6

People come to us to describe that since the 60s plastic has been washing up in our area. Three generations have been witnessing a constant and exponential increase of pollution. So much that now the soil itself is locally only plastic, some beaches having more than a metre of plastic accumulated. The danger for the local population of chemical intoxication is real (especially carcinogenic), the reports of animal entanglement are frequent but the most startling is the total lack of action to make the situation better. We understand that depopulated areas are not politically interesting as they cast so little votes but it is still your country and your ocean, what are you waiting for? 


Marine Scotland’s Marine Litter Strategy (full text)

A-Marine-Litter-Strategy-for-Scotland-marine-litter-strategy-scotland-consultation

One Reply to “Marine Scotland’s Marine Litter Strategy 2022 Consultation – Plastic@Bay Response”

  1. I live in Inver on Inver Bay which is just off the Dornoch Firth but I beachcomb all round the peninsula and on Dornoch beach. I have found the same range of plastic debris as yourselves, most of it fishing industry debris. We have quite a lot of lobster fishing here (a lot of rocky shoreline on the south side of the peninsula) and I find lots of cut offs about 5cm curved sections of thin rope. Also find lots of knots cut off thicker ropes. In the summer Portmahomack is a holiday centre and I find more plastic bottles in the summer but not that many.

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