External Affairs / Policy / Consultations Consultations
Marine Bill
Marine Bill Consultation Team
Defra – Marine Legislative Division
Area 2E, 3-8 Whitehall Place
London, SW1A 2HH
20th June 2006
Dear Sirs
On behalf of the Institute for Outdoor Learning I make the following responses to the above-proposed Bill.
The Institute for Outdoor Learning is a registered charity that was formed five years ago as the result of the convergence of six outdoor organizations. The Institute provides opportunities for professional development, networking and sharing good practice, represents the views of our members and the wider interests of outdoor learning through development of partnerships with other organisations.
We represent probably the broadest spectrum across the industry of any existing organization. Our members include employers and employees involved in walking, mountaineering, personal development, outdoor activities, field studies, outdoor therapy, watersports and outdoor education and recreation.
Our members are present in outdoor and field study centres, educational establishments, including schools, or may be lone providers. They work for charities, local authorities commercial enterprises or themselves either in a full time or voluntary capacity. We are the largest Outdoor Organisation of our kind.
IOL supports the aim of improving marine nature conservation and the vision of a marine environment that is clean and healthy and the modernisation and streamlining of the present legal processes. We are well aware of the potential conflicts between usage of the sea by people and the nature conservation objectives. We are in a position to help with the education of current and future stakeholders.
The Bill contains limited analysis on the implications for outdoor education and recreational activities that take place in the Marine environment. However, if this should change as the Bill develops then we would urge the Bill team to consult further with us.
You should be aware that a number of field study centres teach the practical aspects of national examinations, particularly in biology, ecology and geography where trawling and sampling are carried out. Invariably most species are returned to the sea.
Section 7 Managing marine fisheries
We have no comments but are uncertain of the meaning in clause 6.26 lines 2/3;
--management of this activity should take proper account of all the many different types of fishing activity, as well as other, non-fishing marine based activities. We take it that this does not apply to education or recreation water sports?
Section 8 Planning in the Marine Area
We welcome the opportunity to streamline the licensing process and replace the many permits and permissions from different authorities that at present exist for any work below the high water springs line. We welcome the suggestion that there will be consultation and stakeholder engagement in drawing up any future plans.
We respond affirmatively to questions 1 & 2.
Section 9 Licensing marine activities
Question 32:
We would support the proposal that licensing marine activities which are subject to regulation should be efficient for users, reduce burdens on business and better ensure the sustainable development of the marine area. We note clause 9.2 that the simplification will only apply to existing legislation. We accept that this and other statements within the Marine Bill, confirm that there is no intention to legislate recreational watersports users in any way.
Question 35:
We have no proposals as most of this section covers work, such as by electricity undertakings, which are of no concern to the Institute.
Section 10 Improving marine nature conservation
Question 69:
We do not consider that unlicensed activities currently threaten the conservation of marine ecosystems and biodiversity.
We note section 10.93 ‘concern for intensive use of recreational craft in sensitive sites’.
There is a huge variety of recreational craft with differing impacts so we would ask to be informed upon what research this statement is based on. We would favour more comprehensive monitoring and ongoing research. Perhaps some of this could be done in partnership with the Royal Yachting Association, the major National Governing Body.
In taking an ecosystem approach the Bill should include ‘humans’ as part of the ecosystem since we suspect a strong correlation between recreationally attractive and conservation rich sites. We think that this should be recognised in this section of the Bill as well as being addressed under spatial planning.
Question 73
Any improvements in terms of simplification of current designations of sites would be welcomed with clear guidance given on key activities that could pose threats to the sites in question. Information about current sensitive sites is often hard to access so one of the key ways the Government could prevent marine nature conservation offences is by more effective promulgation of information locally via various stakeholder groups, HM Coastguard, Harbour Authorities and National Governing Bodies for sport with clear maps or charts being available on line.
You will also be aware of the benefits of the RYA and BMF’s scheme, ‘The Green Blue’ which aims to provide practical advice and information to not only recreational users of the sea but also to marine businesses.
Section 11 A new Marine Management Organisation
It would appear sensible that one agency deals with all the functions outlined in the Marine Bill. However, the Government would have to ensure that work is not duplicated and that if functions are transferred with their staff from other departments then the consequent saving would be applied to the cost of the MMO.
We believe that such an organisation could function more efficiently if it took on the nature conservation role. (clause 11.62)
Yours faithfully
Steve Lenartowicz
Chairman Institute for Outdoor Learning