Environmental NGO (Coalition Clean Baltic and World Wide Fund for Nature) Statement for HELCOM Ministerial Meeting on the HELCOM Baltic Sea Action Plan, Krakow, 15 November 2007

CCB • November 15, 2007

ENVIRONMENTAL NGO (COALITION CLEAN BALTIC AND WORLD WIDE FUND FOR NATURE) STATEMENT FOR HELCOM MINISTERIAL MEETING ON THE 
HELCOM BALTIC SEA ACTION PLAN
KRAKOW, POLAND 
15 NOVEMBER 2007

On behalf of the environmental NGOs, Coalition Clean Baltic and WWF, who serve as observers to HELCOM, we appreciate the opportunity to share our position on the HELCOM Baltic Sea Action Plan (BSAP).  We welcomed HELCOM’s initiative to launch the BSAP process nearly two years ago.  The ambitions of the BSAP to deliver wide-scale and decisive actions necessary to achieve a good ecological status for the Baltic Sea was seen by CCB and WWF as fulfilling a critical need to achieve ecosystem based management in the Baltic Sea region.

Originally, the proposed text of the plan did indeed include many of the strong actions and tough decisions that so urgently needed.  Over time, however, the plan has been successively narrowed in scope and weakened due to political and economic disagreements between CPs and economic sectors like agriculture and fisheries – so much so that the plan you now seek to adopt is but a shadow of its former self. 
Instead, the BSAP is now high on rhetoric but missing many of the very ambitious actions and commitments which were the reason the BSAP was originally conceived.  In fact, the plan rarely steps beyond actions which have already been agreed on and negotiated in other fora.  This is important, but does little to demonstrate the added value of the BSAP and indeed HELCOM itself. As a result, the plan you are now set to endorse will unfortunately not reach its ambitious aims or objectives. 
Two of the biggest threats to the ecosystem of the Baltic Sea are eutrophication and the overfishing of cod.  The adopted HELCOM BSAP 
-   takes a positive first step towards addressing Eutrophication, e.g. with country-wise quotas for nutrient reduction, but this will not solve the total problem
-   unfortunately takes no actions to address the obvious risk for collapse of the Baltic cod stocks which could dramatically deteriorate the Baltic Sea ecosystem.  

Further, the plan is lacking:
-   Strong actions to shift CAP-subsidies in Baltic Sea into agri-environmental programmes which are needed to contribute to a substantial reduction of the nutrient run-off from agriculture. 
-   Strong actions to safeguard the Baltic Harbour Porpoise, which are at risk of collapse. 
-   Actions to address the threat of climate change, which is expected to significantly increase the effects of eutrophication on the Baltic Sea are absent.
-   Strong actions to stem the threat posed to the Baltic ecosystem by the introduction of alien species into the Baltic Sea via ships ballast water.
-   Strong actions to control nutrient run-off from agriculture, e.g. the designation of the whole Baltic catchment as a Nitrate Vulnerable Zone.

Additionally, since little attention has been given to how this plan will be implemented, coordinated, funded and evaluated - there is no clear understanding regarding how HELCOM and the CPs will even be able to manage and monitor this plan. Finally, even the few actions that have been identified are recommendatory and non-binding.  This means that there is no guarantee that contracting parties will even take these actions.  

We do appreciate, however, actions such as:
-   The country-wise nutrient reduction requirements which have been agreed by CPs.
-   The actions identified to ensure better environmental control for Industrial Animal Farms (Intensive rearing livestock farms) in Annex III of Helsinki Convention.
-   The establishment of a list of Hot Spots, identifying Industrial animal farms, not fulfilling IPPC directive
-   The active conservation of at least 10 threatened wild salmon river populations in Baltic Sea.

Overall, we are concerned with the very low ambitions for protection of the Baltic Sea environment from many Baltic Sea region countries and believe the true failure of this plan can be directly traced to the lack of political will and leadership on behalf of CPs.  Looking around the room – it is disheartening to see that this ‘Ministerial’ meeting does not even include Environmental Ministers from Denmark, Germany and Latvia, which may indicate the low importance of this process for these CPs.  
Furthermore, as the original intention of the BSAP was to take a holistic and integrated approach to tackling the many challenges in the region – it was a flawed intention from the start to only seek to include the agreement of environmental ministers.  In order to be successful, this plan requires strong support from the highest level of government of each CP, and commitment that the BSAP will be implemented in a coordinated and integrated way across ALL relevant ministries and departments.    
Clearly, your colleagues in the Ministries of Agriculture, Fisheries and Economy seem to have low ambitions for Baltic Sea Protection and would rather keep to business as usual.  Their influence has been quite evident during the negotiations and subsequent weakening of the text.  This is why it is so important that you strengthen your own expertise in these areas in order to achieve sustainable agriculture and fisheries for Baltic Sea protection.  

Despite the weaknesses of this plan, the original intention of the BSAP remains valid – the Baltic Sea still needs urgent and concerted action to protect and restore it to ‘good ecological status’.   We therefore urge each of you to seek the support of your Prime Ministers/Presidents and take responsibility for:
1.   Implementing the BSAP but acknowledge that the implementation of the plan will not be enough to reach the goals and objectives of the BSAP and to therefore:
2.   Take responsibility for its weaknesses and failures by developing a process to address the still urgent need to take dramatic and integrated action to save the Baltic Sea – ensuring that this action is taken at the highest level of each CP (where Agriculture and Fisheries sectors must take their full responsibility)– ideally in the form of a summit meeting in order to secure the health of the Baltic and therefore the continued economic success and quality of life of  our region.
The Baltic Sea, and indeed the people around the Baltic Sea region, deserves more than declarations. Only real action and accountable leadership can achieve this – we therefore acknowledge you, Baltic Ministers of Environment and EC DG Env, as our most important partners to save the Baltic Sea environment and urge you to act and learn from the failings of this process. Thank you for your attention!  

By CCB March 30, 2026
Brussels, 30 March 2026 - Today, Fisheries Ministers from EU Member States meet with the European Commission for the AGRIFISH Council. On this occasion, Oceana, BLOOM, ClientEarth, Coalition Clean Baltic (CCB), Environmental Justice Foundation (EJF), Seas At Risk and WWF EU, handed a symbolic ''Pandora’s Box'' to the EU Commissioner Costas Kadis, sending a clear message as the European Commission prepares its 2026 evaluation of the Common Fisheries Policy (CFP). The box represents the risks of revising EU’s main fishery policy framework: once opened, competing demands from Member States, industry, small-scale fishers, and coastal communities could quickly spiral into division, regulatory delays and uncertainties. This would put at risk the hard-won progress made in restoring Europe’s fish populations and improving the profitability of the fishing sector. NGOs urge decision makers to build on the progress made to date and to prioritise the full and timely implementation of the existing rules. Reopening the CFP and its related provisions would undermine ocean health and the long-term future of Europe’s fishing communities. '' Europe's fisheries policy is facing a credibility test. The law is already there. The tools to rebuild our seas already exist. What's missing is the political will to deliver. Overfishing should have ended by 2020 at the latest. Reopening the CFP would signal that missed deadlines carry no consequences, erode trust, revert the progress made, and put the future of our fisheries and coastal communities at stake ’’, said the NGO coalition. *** Oceana: Vera Coelho, Executive Director and Vice President in Europe BLOOM: Claire Nouvian, Founder and General Director ClientEarth: John Condon, Lead of Marine Ecosystems Coalition Clean Baltic (CCB): Ida Carlén, Co-Chair Environmental Justice Foundation: Steve Trent, CEO/Founder Seas At Risk: Dr Monica Verbeek, Executive Director WWF EU: Ester Asin, Director
By CCB March 10, 2026
Uppsala, March 2026 - CCB has closely worked with the implementation of the EU Marine Strategy Framework Directive (MSFD) ever since its adoption and welcomed the opportunity to give feedback to this crucial directive for marine biodiversity and ocean health through the EU Call of Evidence . Evaluations conducted by the EU Commission previously found many positive effects for EU marine waters stemming from the directive, but also that the directive has some shortcomings. CCB however, maintains that the largest obstacle to fully implementing the directive and achieving Good Environmental Status (GES) is the lack of political will among Member States to do so. This forthcoming revision must therefore result in a framework directive that is more easily enforceable, measurable and implementable, accompanied by sufficient funding to carry out the measures. Furthermore, in order to achieve GES as fast as possible other key pieces of EU legislation must also support reaching it and focus on achieving the goals of the MSFD in their objectives. Seeing that European seas generally are in poor condition and under mounting pressure from human activities and that in the Baltic Sea the situation is especially dire there is an urgent need for truly ecosystem-based management of our seas and for reaching GES. The revised MSFD can help us achieve this, but only if it includes the points outlined below and the directive is fully and swiftly implemented: *** [Short version]*** Operationalise the overarching GES goal: EU sea areas were supposed to reach GES already in 2020, but due to low political ambition, sadly did not do so. Member States should therefore strive to reach GES as fast as possible now. Setting a new overall deadline for when to reach GES is not the answer on how to achieve this goal most efficiently, instead tools that address pressures and measure progress and ensure actual, timely implementation of ambitious measures must be included in the revised directive in order to operationalise achieving the overall GES goal. CCB therefore recommends making the existing and forthcoming threshold values for the descriptors and their criteria legally binding and part of the main directive. Improving regional coordination and implementation: To improve the coherence, coordination and effectiveness of MSFD implementation, assessment of GES, monitoring and the national PoMs the role of the Regional Seas Conventions (RSCs) must be clarified. CCB would welcome collating all the national PoMs into one regional PoM for the Baltic Sea, which should be aligned with, in addition to reaching the goals of the MSFD, with achieving the goals of the Baltic Sea Action Plan (BSAP). Land-sea interface: For the Baltic Sea to achieve GES it is key that land-based pressures, primarily nutrient runoff from agriculture causing severe eutrophication, is also addressed and that implementation of the MSFD goes hand in hand with the implementation of the Water Framework Directive (WFD). The goals of the MSFD and achieving GES should also be included when implementing and shaping the Common Agricultural Policy (CAP), as well as any synergies with implementing the EU Zero Pollution Action Plan which are also important to identify and utilise. The Baltic Sea also has a too high prevalence and level of other pollutants and hazardous substances affecting marine life. Fisheries and aquaculture: As one of the main pressure factors on the marine environment in general, as well as in the Baltic Sea, fisheries and aquaculture and the effects they have on the marine ecosystem and its biodiversity must be addressed in order to achieve GES. This is especially crucial when considering the MSFD descriptor for Biodiversity (D1), Fish and Shellfish (D3), Food webs (D4) and the one for Seabed integrity (D6). Climate change: Climate change is also affecting the Baltic Sea faster than other marine regions and must be factored in when managing the sea area and its resources to ensure EBM and the full implementation of the MSFD and achieving GES. The effects of the climate crisis should be accounted for when setting pressure reduction targets and threshold values for the descriptors and their criteria, in a way that when an effect cannot be measured nor predicted the precautionary principle must be used. Revising Art. 14 of the MSFD: Article 14 in the MSFD outlines the acceptable exceptions when reaching GES is not possible. The article needs to be revised in the forthcoming revision, since it contains too many and too broad in scope possibilities for exemptions (e.g. in Art. 14(4)), which jeopardise the implementation and fulfilment of the directive as a whole. A possible way of modifying it would be to introduce an obligation for Member States to demonstrate that they have taken all measures within their control nationally and that they have tried to address the problem and advance solving it on a regional level through cooperating with other Member States, before they can apply for a possible exemption. Make the Programme of Measures contain ambitious & concrete measures: One of the cornerstones of the MSFD is the national PoMs that are published every six years and are precluded by an assessment of GES in national waters and a monitoring programme. Unfortunately, the current approach to PoMs where Member States freely can choose measures has led to an overall too low level of ambition in the PoMs, and to large differences within regions and between neighboring countries in terms of which measures are included. In order to fully implement the directive and to achieve GES it is of paramount importance that the national PoMs have a high level of ambition and contain concrete, implementable measures and that there is regional coordination. Easing the reporting burden: One of the results from the evaluation of the MSFD was that the current reporting burden is considered to be too high and a possible way to address this is to align the reporting obligations of the MSFD to more reassemble those of the WFD, that has a more simplified 6-year cycle compared to the MSFD. The implementation cycle however should not be revised or at least not in a way that delays reaching GES. Improve coherence with other legislation: To ensure that the revised MSFD is fully implemented it is essential that coherence with other relevant legislation is improved. The MSPD (foundation for the forthcoming Ocean Act) is also currently being revised and to reach the goals for both the directives achieving GES needs to be a cornerstone of the Ocean Act. This is the only way to deliver truly ecosystem-based management of our seas, and the revision of both directives should therefore be coordinated and focused on achieving GES. CCB looks forward to continuing to provide input to the revision process of the MSFD as well as working with the implementation of the MSFD, especially in the Baltic Sea. CCB expects that the revision will result in a more enforceable directive that leads to the fast implementation of ambitious measures to improve the state of the Baltic and European Sea areas and to the achievement of GES. The full text of the submission is available here . *** Links to supplemental documents supporting our positions: CCB’s submission to the Call for Evidence for the Ocean Act Guiding Recommendations for Source-to-Sea Restoration in Riverine, Coastal, and Marine Ecosystems (Coalition Clean Baltic, 2025) Position Paper on Marine Protected Areas (Coalition Clean Baltic 2024) Don’t sink the Common Fisheries Policy – fulfil its potential (joint NGO Briefing 2025) Blue Manifesto (joint NGO paper)