Scapa flaw

By Siałababamak (Own work) [CC-BY-SA-3.0 ( or GFDL (], via Wikimedia Commons
By Siałababamak (Own work) [CC-BY-SA-3.0 ( or GFDL (], via Wikimedia Commons
This is a great letter from a former colleague of mine, Steve Sankey, to the SNP Scottish Minister for the Environment and Climate Change, Paul Wheelhouse. It’s about a change in policy by Orkney Islands Council on ballast water management.

Yawn? How dull? Not at all – quite interesting because it is very important! Here’s what another EPA says about it – the USA EPA. Here’s an article closer to home with attractive pictures.  And here’s the European Maritime Safety Agency’s views too.  Even something called the UK government says the right things about it.

Being careless with ballast is a daft thing to be – that seems to be the consensus.

The Scottish Environment Protection Agency has advised that the change of policy does not protect the environment of Scapa Flow.

Scottish Natural Heritage has advised that the proposed change will not ensure the protection of the Loch of Stenness SAC.

No-one could say that they haven’t been warned!  Great letter Steve!


Mr Paul Wheelhouse MSP
Minister for Environment & Climate Change
St Andrew’s House
Regent Road
Edinburgh EH1 3DG

27 May 2014


I write, following my letter to you of 19 November 2013, to seek urgent clarification of the status of the Scottish Government’s review of Orkney Islands Council (OIC) recent implementation of their ballast water management policy (December 2103). You advised me by letter on 18 December 2013 that “Scottish Ministers are currently considering further for their own interests.

You have already indicated to me by letter that SEPA has already advised OIC that the proposed policy change does not offer acceptable protection to Scapa Flow. You also have a duty under the European Union’s Habitats Directive (92/42/EC) to ensure that there is adequate protection for the Loch of Stenness Special Area of Conservation. As you will be aware SNH has already advised OIC that they cannot guarantee the integrity of this site under the proposed policy change.

OIC has now published its final post adoption report of the Strategic Environmental Appraisal (April 2014) and, moreover, is now proceeding to apply for an Oil Transfer Licence from the Secretary of State for Transport. They are proceeding regardless of the above advice from the statutory advisors.

In view of this development I would ask that you give me an urgent progress report on your review of OIC’s ballast water management policy. I have recent correspondence (6 May 2014) from Mr Paul Speight of the European Commission DG Environment office which states that “it would appear unusual to have the advice of both of these statutory nature bodies ignored given their expertise…” I agree with his analysis, and would therefore be grateful for your views.

Yours sincerely
Steve Sankey
South Ronaldsay

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2 Replies to “Scapa flaw”

  1. It has long been known that alien invasive species can be introduced into marine ecosystems via ships' ballast water with sometimes devastating impact on the receiving water body. Wisdom would therefore dictate that we should be very cautious indeed about any policy change that might increase the likelihood of this happening.

    The above post does not make it quite clear exactly what is being proposed by Orkney Islands Council - more information on this can be found at

  2. Why not write to both SNH and SEPA to ask why they are not using their full range powers to stop this?

    I would guess they have had a quiet word from the minister telling them that their involvement would not be in their own interest.


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