July 21, 2017
Statement at the public hearings on the Nord Stream II Project
21.07.2017, Stralsund, Germany
On behalf of the Coalition Clean Baltic, an NGO network of 19 grass-root environmental NGOs around the Baltic Sea, including BUND – Friends of the Earth Germany, altogether representing over 850 thousand Baltic catchment residents, I would like to give couple of reflections on the proposed Nord Stream 2 Project EIA in transboundary context. As we represent environmentally-concerned citizens of both Parties of origin and affected parties of the proposed project, CCB is honoured to represent their voice.
As stated in the Guidance on the practical application of the Espoo Convention, in most cases the Convention is applied between neighbouring Parties. However it is also noted that the Convention does not only apply to transboundary impacts between neighbouring Parties but also to long range transboundary impacts. Activities that can make long-range impacts in transboundary context include activities with air pollutants or water pollutants, activities potentially affecting migrating species and activities with linkages to climate change.
And in this case it applies equally to all Parties of Origin, be it not only Russia and Germany, but also Finland Sweden and Denmark. As the primary cause of the impact is not a construction and maintenance, but the very fact of laying the pipeline across the Baltic Sea.
Saying that we would like to raise the attention to couple of such transboundary impacts and draw the attention of Germany as one of the Parties of origin on the need to address those impacts.
Not to dwell in detail on the climate change related impacts, we would like to reflect that a common position of Baltic environmental NGOs is that NS2 Project is in direct contradiction with EU Paris COP goals of reducing greenhouse gas emissions by 80-95% by 2050, by replacing fossil fuels with renewable energy sources. And we have already notified the European Commission of this fact.
However, we would like to touch upon critical nature values of the Baltic-wide importance that are threatened by the proposed project.
First, about migratory, vulnerable and endangered species.
One of the reasons for designating new Marine Protected Area in the Swedish EEZ, south of Gotland, was that the protection status of the Baltic harbour porpoise was determined as unacceptably poor. It was pointed to Sweden by the EC in the assessment of implementation of the Habitat’s Directive. It was also backed by the new knowledge that became available quite recently through the SAMBAH Project, providing a reliable and scientifically confident estimate that number of those small whales in the Baltic Sea is not more than 500 and each year we lose some of them due to human-induced mortality, e.g. fisheries. At this level the population of harbour porpoise is so critical that loosing even single animal that could breed and bring offspring is a huge loss. Therefore, the Swedish Government has put in place a protected area at Mid-Sea banks and develops a management plan to limit various human activities within its boundaries, including fisheries, shipping, deep sea mining or laying infrastructure. In that sense, adding yet another disturbing factor in the area that is crucial for mating, breeding and nursing of the harbour porpoise throughout almost the whole year is certainly a significant negative impact that has to be minimised, if not prevented. With this respect we are seriously concerned with the NS2 estimation of level of underwater noise produced and respective impacts it may cause while trenching and pipe-laying during the proposed project. With the knowledge we have, backed by science including HELCOM experts on underwater noise, we firmly require that should the project be permitted to commence, trenching and pipe-laying should be limited to the period from December to March. This consolidated NGOs position was also reflected at the public hearings in Sweden, where an option of shifting the route off the limits of the protected area was already lifted up.
The same goes without saying with regards to endangered ringed seal population in the Gulf of Finland that is already quite affected by similar human factors as harbour porpoise, and in addition – by climate change. The ammunition clearance and actual pipe-laying process in the vicinity of ringed seal haulouts and reproduction areas is a significant impact that cannot be neglected. So far, neither the ammunition issue nor the proposed routeing of the pipeline have been adequately responding to the associated environmental risks to ringed seals. This also became obvious and was highlighted at the public hearings in Estonia and Finland.
Secondly, about critical habitats of international importance
The proposed route that has been presented by the Nord Stream 2 AG as a part of Espoo EIA international consultations documentation is also a significant concern in terms of other common Baltic nature values. We would particularly like to point here to the landfall part in Russia, in the Gulf Finland. The route proposed by the company as the best from environmental point of view and hence included in the Espoo documents as the only suitable alternative is simply not based on the law. It suggests to cross Kurgalskiy Peninsula, the nature protected area of dual international importance that is designated as a wetland of international importance under Ramsar Convention and a Baltic MPA under Helsinki Convention. Irrespective that none of the Conventions prohibits such human activities to be performed in those areas, any changes to the protection status should be duly justified, while simple commercial interest of saving money for a shorter route could not be considered enough justification. Moreover, current legal status of this protected area in Russia simply prohibits any construction works within its limits, not even saying about wiping out massive land area with up to 80 m wide trench. Really worrisome is the fact that according to our knowledge the efforts are undertaken to change the limits of the protected area to allow such activities to be carried out.
To make you a snapshot of the prospected impact, if such a development would be allowed, we would like to mention that the proposed landfall area in Russia is well known in the eastern part of the Gulf of Finland as the richest in terms of biodiversity with over 100 species of fauna and flora being redlisted as regional, national and Baltic-wide endangered and rare species. Habitats are represented by a mixture of pristine old-growth forests, bogs and dunes. In addition, it is an area that has been traditionally populated by indigenous Finno-Ugric people, being very much connected to nature and its values. Nature is a part of their traditional way of living, they are dependent on careful harvesting of nature resources. So, severe interference and impact that the NS2 Project would bring to the area is simply incomprehensible. It will be a devastating loss to natural, cultural, historic and social values that can hardly be avoided, minimised or compensated. It was pointed out in numerous inputs at the recent public hearings in Russia.
By the way the Russian national EIA process should be formally launched today, where we expect yet another round of discussions with the developer of the project. In that sense, the international attention to the issues we raised is highly relevant for the outcome of this whole process.
We believe that all Parties of Origin should realise the level of impacts that are not limited to adjacent areas only, but are of Baltic-wide importance, and that they bear full responsibility for those impacts by permitting the project in the way it is proposed now.
See full Statement in pdf here
February 28, 2017
Today, high-level representatives of the HELCOM Contracting Parties will meet in Helsinki to discuss how the Baltic Sea Region can contribute to the global goals on the conservation and sustainable use of the oceans, seas and marine resources by 2030. Actions related to eutrophication, marine litter and climate change will be given special focus in the discussions.
On behalf of environmentally concerned citizens of the Baltic Sea catchment, Coalition Clean Baltic would like to share some input to this work and bring to the attention of regional decision-makers the urgent needs to be addressed in order to reach the Sustainable Development Goals, (SDGs) and, even more importantly, to save the Baltic Sea from further deterioration.
Read the full statement here.
October 4, 2016
04 October 2016, Uppsala/Stockholm
Joint position of environmental NGOs on internal loading in the Baltic Sea
Environmental Ministers and High-Level representatives from HELCOM Contracting Parties at their meeting in Copenhagen in 2013, inter alia
- agreed to fully implement the 2007 Baltic Sea Action Plan by 2021 and to step up efforts for further strengthened implementation of the BSAP
- acknowledged that environmental deterioration such as oxygen depletion is increasingly affecting marine life by e.g. accelerating eutrophication through increasing the internal loading;
- supported development of environmentally sound approaches to remove the nutrients before they enter inland waters and the sea, and to address the internal loading, in coastal areas and semi-enclosed lagoons, as well as in the open sea;
The issue of internal loading was brought up to HELCOM’s agenda with the assumption that most of the reductions on land (both at point and diffuse sources) have been already achieved, e.g. through accomplishment of efficient sewage treatment and excess usage of fertilizer and manure in agriculture being gradually eliminated. Hence, according to the proponents, very limited, costly and constantly diminishing reductions can be achieved using conventional land-based approach, and thus interest on innovative sea-based measures that should be investigated and applied have gained traction.
NGOs strongly believe that the real reason for promoting alternative, sea-based solutions to the eutrophication problem might be tightly connected with observed poor implementation of BSAP MAI/CART commitments and lack of will to enforce stricter HELCOM requirements at national level in comparison to EU law, by some Contracting Parties/EU Member States. This recently became even more evident with several Contracting Parties questioning the MAI/CART scheme that was jointly agreed in 2007 and reviewed in 2013. Another possible reason could be the need to develop and implement ‘novel’ measures, not yet being used in current EU policies e.g. WFD or Nitrates Directive process, in order to be able to feed those into Programmes of Measures under the MSFD.
Meanwhile, cost-efficiency of already applied measures in terms of delivering good environmental status for the Baltic Sea with regards to eutrophication has been very poorly assessed – both at national or HELCOM level. So far only potential economic benefits stemming from implementation of the HELCOM BSAP measures have been evaluated. On the contrary the EU financial support mechanisms in many cases, e.g. in agriculture, cause continued high inputs of nutrients with minor consideration of environmental objectives for the marine environment.
Our understanding is strongly supported by the findings of the recent EU Court of Auditors’ report “Combating eutrophication in the Baltic Sea: further and more effective action needed” (2016), echoed by the EU Council Conclusions on the ECA’s Report, which reflected the following:
- within 2007-2013 the EU contribution to waste water collection and treatment projects in the BSR was 4.6 billion euro from ERDF/CF, while rural development measures, including water protection measures amounted to 9.9 billion euro from EAFRD.
- Member States’ plans for achieving HELCOM nutrient reduction targets are lacking ambition as they do not go beyond statutory EU requirements, that do not suite the Baltic-specific needs; those plans are often delayed and vary in level of enforcement, as well as based on insufficient information and lack progress monitoring; moreover HELCOM requirements on sewage treatment and agro-environment measures are not in full incorporated into national legislation in most of the Contracting Parties.
- None of the Baltic EU MS have reached good ecological status of their surface and ground waters by 2015, as originally set under the WFD and hence reaching in time Good Environmental Status under the EU MSFD is also very questionable, again partly due to lacking coordination with the objectives and activities of the existing regional sea conventions (HELCOM)
On February 12, 2015 the seminar “Sea-based measures to reduce the effects of eutrophication” was arranged by Sweden’s Ministry of Environment, Baltic Sea Centre and Swedish Agency for Marine and Water Management with the aim to review nine pilot projects and in light of these, to discuss opportunities and challenges associated with sea-based measures to reduce internal loading. During the seminar it was pointed out by many participants that the Baltic Sea ecosystem is fragile and there is a lack of knowledge about how the flora and fauna will react to these types of substantial human manipulations. Also the risks and uncertainties increase for the ecosystem when the measures applied go from small scale at the coastal level to large scale on the open seas. However, the concluding panel agreed that some offshore activities in the future might be complementary to current land-based measures to speed up the recovery of the Baltic Sea.
Putting it candidly, the internal nutrient load in the Baltic Sea means a recirculation of “old sins”, hence it is a consequence and not a cause of eutrophication. Despite pilot attempts, scientific knowledge is still lacking and vast uncertainty remains about the effectiveness of measures to reduce the internal load, especially for large-scale Baltic Sea wide application. Furthermore, the total costs of the proposed measures have not been calculated, neither any estimates of effectiveness and environmental consequences of proposed measures on the open Baltic Sea ecosystem have been produced. As currently the anoxic “dead” bottom zones extend to several national EEZs and cover an area comparable to twice the size of Denmark, the question remains who should pay for the needed EIA and investments for technical solutions addressing open sea eutrophication.
Despite no formal discussion has been held on internal load within HELCOM since the seminar, HELCOM HOD 50-2016 requested to include issues on internal load into the agenda of PRESSURE 5-2016.
Based on the above and to express the joint Baltic environmental NGOs position on the discussion, we would like to draw the attention to several important points on this issue to reflect upon:
- Internal load is not a cause of eutrophication, but it is a consequence of numerous years of mismanagement of nutrient inputs from the Baltic Sea catchment. According to the Baltic Eye’s policy brief “The internal phosphorus load – recycles old sins” (October 2016), the accumulated load of nutrients in the catchment is about 20 times higher than estimated load bound in bottom sediments. Hence, nutrient sources in the catchment will still need to be addressed as being the root cause of phosphorus accumulation on the sea floor.
- There is no evidence that the Contracting Parties have taken and implemented all relevant measures to reduce eutrophication, as agreed in HELCOM BSAP – especially from land-based sources (stricter sewage treatment and fertiliser application, nutrient recycling, etc.) and as agreed in Article 6 and Annex III of the Helsinki Convention (1992).
- Although positive effects of reduced land-based input could be seen in some coastal areas, there is still a need for further improvement. Measures for continued reduced supply and a more resource-efficient use of nitrogen and phosphorus have effect and are of great importance and should be a priority, not least in order to reduce eutrophication in lakes, rivers and coastal waters in the Baltic Sea Region, in meeting the WFD and MSFD requirements.
- Proposed sea-based measures to address internal loading have not proven to be (a) effective, (b) cost-efficient, (c) polluter-specific and (d) harmless in application at a larger scale and in longer-term perspective, hence violating two fundamental principles of the Helsinki Convention, namely precautionary and polluter-pays principle.
- Very few end-of-pipe solutions have appeared to be more efficient than source reduction measures. Without curbing nutrient pollution sources we will not be able to cease eutrophication cause (point and diffuse inputs) and hence tackle the consequences at sea (anoxic bottoms, internal loading).
- External nutrient reduction before entering the sea is the only truly effective long-term strategy to combat eutrophication. Therefore, we call upon the Governments of the Contracting Parties to follow their commitments under the HELCOM BSAP and demonstrate it with real actions, i.a. finally endorsing Country Allocated Reduction Targets by all the Contracting Parties and implementing nutrient reduction measures stipulated by the Helsinki Convention (1992) and its Annexes.
May 12, 2016
CCB has joined a group of NGOs (Greenpeace, Oceana, WWF, Swedish and Danish Societies for Nature conservation, Swedish and Danish Anglers Associations, Living Sea and Fisheries Secretariat) and written an open letter to the ministers in Denmark and Sweden asking them to uphold the existing closed areas in the Kattegatt. The area has been closed to fishing since 2009 and may represent on of the few productive fishing areas in EU that has not been trawled at all the past 7 years.
The joint NGO position is that the area must be made a permanent closed area not only to protect fish reproduction and weak fish stocks but also because of natural values existing in the area. Following the closure in 2009, the recovery of the bottom in the area is remarkable and to protect the area permanently suits well with EU and Member states ambitions under Marine Strategy Framework Directive (MSFD) implementation. In fact the opposite, to not protect it, is hard to argue for or even consider due to the uniqueness of such a trawl free area. Opening up the area for active fishing and especially towed gear such as trawls is going from an clearly improved or even good environmental status (GES) towards not meeting the GES objective. That is a breach of the objectives of not only MSFD but also Common Fisheries Policy (CFP).
The full letter can be read here (in Swedish): Brev Kattegatt final svenska
Scientific statement: the area closed for fishing since 2009 has had clear positive effects and should stay in place. Read (in Swedish) http://www.gp.se/nyheter/v%C3%A4stsverige/stoppet-gav-effekt-torskbest%C3%A5ndet-v%C3%A4xer-1.115701
Swedish Scientific evaluation of the area (in English): http://www.slu.se/Documents/externwebben/akvatiska-resurser/publikationer/PM-Rapporter/Summary_Evaluation_of_Closed_Areas_in_Kattegat.pdf
STECF evaluation of the effects of the closed area (in English):https://stecf.jrc.ec.europa.eu/c/document_library/get_file?p_l_id=53314&folderId=133326&name=DLFE-12704.pdf
December 11, 2015
CCB made already in 2014 a joint statement, underlining the important steps needed for a sustainable aquaculture sector in the Baltic Sea catchment. This statement has now been updated with a clearer stance on what we as an NGO group can support and that we do not consider open cage farms in the Baltic an option at all. Furthermore, in light of several pilot projects and research studies on compensatory measures, we do not consider such compensatory measures acceptable as arguments for allowing further development of open cage systems since they are neither economically viable nor actually compensate in a sufficient way. CCB considers closed re-circulatory land-based system (RAS) as best available technology (BAT) and that any and all public money to support a growth in the sector should only be used for BAT. Other land based systems such as ponds etc with species not requiring feed input or that does not produce nutrient run off can also be considered. This statement has also been translated into Polish and Lithuanian.
Read the statement here: CCB Sustainable Aquaculture update 2015 final
December 1, 2015
These are CCB proposals for action for the conservation of the Baltic Sea harbour porpoise population. These actions are necessary for all EU Member States to fulfill the demands on monitoring programs and programs of measures under the MSFD, and to meet the requirements of the Habitat Directive and the HELCOM BSAP.
Read the statement here: CCB_statement_on_porpoise_to_fulfill_MSFD_and_HELCOM_2015
November 19, 2015
With reference to the Terms of Reference of the HELCOM STATE & CONSERVATION Group, Coalition Clean Baltic submitted the following two information documents to the third Meeting of the Group:
- (7J-4) Proposal for actions to save European eel in the Baltic Sea
- (7J-5) Physical loss and damage to the sea floor marine sediment extraction in the Baltic Sea
Read statement here: 4-19 Pending issues from State and Conservation 3-2015_CCB
November 19, 2015
A crucial part of the coherent implementation of the BSAP and the EU MSFD is the commitment to fund the needed measures to reach the GES targets. CCB is becoming concerned that several CPs being also EU MS have argued at different occasions, including the IG PoM and EU MSCG, that funding is a major problem for implementing the MSFD PoMs. For a number of reasons CCB considers these claims unjustified.
Read statement here: 4-17 Funding the EU MSFD Programs of Measures_CCB
November 11, 2015
European Eel (Anguilla anguilla) is listed as critically endangered (one step away from extinct in the wild). The EU in 2007 jointly decided on a management plan for the recovery of the eel stock. The Member States are required to take measures to secure that 40% of adult eels reach the sea for migration to spawning grounds. It is the Member States own responsibility to take relevant measures, and the Commission reviewed the measures so far.
Read statement here: 7J-4 Proposal for actions to save European eel in the Baltic Sea
November 2, 2015
HELCOM’s Initial Holistic Assessment of Ecosystem Health of the Baltic Sea (BSEP122) considers dredging and marine sediment extraction as pressures, which can have large impacts on local marine environments. Such impacts include smothering of benthic organisms, abrasion of the sea bottom, as well as increased siltation and resuspension of contaminated bottom sediments caused by dredging/extraction activities. Scientific studies, underwater observations and hydrographic surveys have shown that impacted bottom sites can take decades to recover, if at all do so.
Read statement here: 7J-5 Physical loss and damage to the sea floor marine sediment extraction in the Baltic Sea
October 23, 2015
The Coalition Clean Baltic would like to raise the attention of HELCOM STATE & CONSERVATION Group experts and call for urgent HELCOM’s action regarding the alarming situation being reported around Kurgalskiy State (Regional) Nature Reserve, located in Leningrad Oblast of the Russian Federation.
Read statement here: 3N-4Cover CCB letter on Kurgalskiy
October 20, 2015
Comments on final draft of the BAT reference document for the Intensive Rearing of Poultry or Pigs (IRPP BREF). Proposal for some rewording in the BAT conclusions 30 to 34.
September 18, 2015
Open letter addressing Russian authorities and HELCOM with regards to an alarming situation around Kurgalskiy Nature Reserve at the coastline of the Gulf of Finland.
The letter addresses the situation, which mainly concerns conflicts between nature protection goals, large infrastructure projects and urban planning of the coastal area in the vicinity of the Kurgalskiy State Nature Reserve. The situation requires urgent action to prevent damage to natural amenities of this Protected Area and save it as the only MPA within Russian part of the Baltic Sea that covers both land and sea area.
Read the letter here. Note: the letter is both in English and Russian.
August 19, 2015
CCB together with 28 environmental organizations has sent this letter to the EU Commission demanding that all eel fishing in Europe should stop and that other needed action to halt the human induced eel mortality until the stock has recovered must be put in place. Read the letter here
April 17, 2015
A group of NGOs collaborating on implementation of the CFP and supporting a new management plan for the Baltic Sea Fisheries that meets the ambition of the new CFP. This statement was sent to MEPs in EP prior to the vote in April 2015 on the Baltic Multiannual Plan file (2014/0285(COD) in plenary. The statement shows support of the agreed report from the PECH fisheries expert Committee and urges MEPs to make sure the plan matches the CFP.
NGO Priorities on the Baltic MAP for EP Plenary
April 1, 2015
A statement letter to the EU Fisheries Ministers from Coalition Clean Baltic, BirdLife Europe and Central Asia, Client Earth, Oceana, Seas at Risk, The Fisheries Secretariat, The Pew Charitable Trusts, and WWF Poland.
Read the letter
March 26, 2015
This is a statement with recommendations from a joint group of NGOs directly addressing the Baltic MAP proposal report and amendments given to the PECH Committe in EP, March 2015. 20150326 NGO priorities Baltic MAP_final
February 28, 2015
NGO considerations for BALTFISH members on the Multiannual plan for the main Baltic Fisheries.
Read the briefing here
January 22, 2015
This is a joint statement on key priorities to address in creation of the new multiannual fisheries management plan for the sprat, herring and cod stocks in the Baltic Sea. It is a joint statement including CCB, Birdlife, Oceana, WWF, FISH and FANC and it has been shared with Member States and European Parliament members as well as internally in NGOs. Read the statement here: Jan2015 Joint NGO Priorities on the Baltic Sea Multiannual Plan_FINAL
August 1, 2014
A joint NGO position paper by Coalition Clean Baltic (CCB), Seas At Risk (SAR), BirdLife Europe, World Wide Fund for Nature (WWF), The Fisheries Secretariat (FISH), Marine Conservation Society (MCS), European Bureau for Conservation and Development (EBCD), Swedish Society for Nature Conservation, North Sea Foundation, Friends of the Earth, Germany (BUND), ENT Foundation.
February 28, 2014
CCB, Fishereis Secretariat, Oceana, FANC and WWF made a joint response to a draft discard plan presented by the BALTFISH group. The original text and the NGO statement is available here:
Joint NGO statement
BALTFISH original proposal