Joint NGO position on Baltic Sea internal loading
CCB • October 4, 2016
Baltic environmental NGOs, represented by Coalition Clean Baltic network consisting of 18 grass-root organizations from 11 countries in the Baltic Sea catchment and the WWF Baltic Ecoregion Programme forwarded for consideration of HELCOM Contracting Parties a joint statement regarding the issue of internal load in the Baltic Sea.
Some of the Contracting Parties state that most of the nutrient source reductions on land have already been achieved, for example through efficient sewage treatment and elimination of excess usage of fertilizer and manure in agriculture. Therefore, those countries consider further land-based reductions to have limited effects at high costs, instead arguing for innovative sea-based measures.
The environmental NGO signatories to this joint statement 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. Actually, the 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 and HELCOM level, and the EU financial support mechanisms often cause continued high inputs of nutrients with minor consideration of environmental objectives for the marine environment.
This view is strongly backed 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.
Our main points on this matter are as follows:
- 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.
- 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, so there is no sense and need to change the path and turn to sea-based measures.
- Although positive effects of reduced land-based input could be seen in some coastal areas, there is still a need for further improvement, especially addressing diffuse runoff and losses from agriculture.
- Proposed sea-based measures to address internal loading have not proven to be (a) effective, (b) cost-efficient, (c) polluter-specific and (d) harmless at a larger scale and in a longer-term perspective.
- Very few end-of-pipe solutions have appeared to be more efficient than source reduction measures, hence the latter should be further promoted and supported.
- External nutrient reduction before entering the sea is the only truly effective long-term strategy to combat eutrophication.
About CCB Coalition Clean Baltic – CCB is a politically independent network, uniting 28 environmental non-profit organizations, as well as partners and experts from 11 countries surrounding the Baltic Sea. The main goal of CCB is to promote the protection and improvement of the environment and natural resources of the Baltic Sea region by encouraging new and constructive approaches and engaging people to become part of the solution instead of part of the problem. CCB Secretariat is based in Uppsala, Sweden. Background The HELCOM Baltic Sea Action Plan (BSAP) from 2021 includes a commitment to develop a regional action plan for habitat and biotope restoration by 2026. This plan is expected to: Define qualitative and quantitative restoration targets Establish a prioritized list of restoration actions Provide an implementation toolbox of best practices and methods The scope of the HELCOM action plan focuses exclusively on benthic habitats and biotopes , with particular emphasis on active restoration measures . Adoption of the plan is foreseen at the HELCOM Ministerial Meeting in November 2026. Coalition Clean Baltic (CCB) recognizes the importance of the HELCOM process but also the need to strengthen ambition, improve implementation guidance, consider a source-to-sea approach, and ensure long term ecological effectiveness . Therefore, a CCB Shadow Restoration Implementation Plan will complement and critically assess the HELCOM Restoration Action Plan. The purpose of the CCB Shadow Restoration Implementation Plan is to: Provide a science-based and practice-oriented complement to the HELCOM Restoration Action Plan Identify gaps, weaknesses, and missing elements in the HELCOM Restoration Action Plan Propose concrete, implementable actions, under a source-to-sea approach, to ensure effective restoration outcomes Strengthen alignment with the BSAP objectives and broader regional and EU policies Your Role You will compile the CCB Shadow Restoration Implementation Plan with aims to: 1. Assess the proposed HELCOM restoration measures , particularly their expected ecological impact by Reviewing proposed HELCOM actions for benthic habitats Evaluating whether actions are sufficient to achieve good environmental status Identifing missing measures, insufficient ambition, or unclear guidance 2. Define recommendations on how restoration should be implemented in practice including Required scale, intensity, and geographic coverage of actions Feasibility and effectiveness of active restoration methods 3. Propose additional actions and priorities , especially where the scope of the HELCOM action plan is insufficient, such as Integration of a source-to-sea approach for better ecological coherence Passive restoration measures Including actions on riverine systems (barrier removal, flow restoration) and coastal ecosystems (dunes, wetlands, lagoons) Incorporating important fish habitats and spawning/nursery areas, as well as ecosystem connectivity 4. Align HELCOM restoration efforts with other relevant policy frameworks , including the Baltic Sea Action Plan, Marine Action Plan, EU Biodiversity Strategy, Nature Restoration Regulation, Marine Strategy Framework Directive, Maritime Spatial Planning Directive, Water Framework Directive and Common Fisheries Policy. This is a Joint efforts with WWF Baltic Sea Programme The organisations, CCB and WWF Baltic Sea Program, will produce two separate documents with separate logos and will be presented at a joint side-event at the HELCOM Ministerial Meeting in November 2026. Actions for the Consultant/Expert & products to deliver The final document of the shadow restoration implementation plan Conduct interviews with all WA Leaders and MOs of CCB working on restoration to gather concrete input Share at the end all notes of the research and transcripts of interviews with MOs Bi-weekly call of consultant + CCB to check-in on progress, problems and next steps Publications/Sources CCB Restoration Guidelines https://irp.cdn-website.com/53007095/files/uploaded/CCB+Restoration+Guidelines_Update+October+2025.pdf CCB BSAP Shadow Plan: https://www.ccb.se/publication/Shadow%20Plan Profile A college degree, preferably in marine science, political science, environmental studies, social sciences, or a comparable field Experience in political campaigning, strategic communication, or advocacy, ideally in environmental, climate, nature, or marine conservation, preferably with an NGO Knowledge about relevant political settings and frameworks in the Baltic Sea (HELCOM, BSAP, MSFD, NRRL, ...) Experience in collaborating with coalitions, initiatives and civil society actors Initiative, independence and reliability working fully remotely Excellent written and spoken English are required Contract Terms Contract Type: can be structured as a consulting contract or a fixed-term employment (for candidates based in Sweden). We are open to discuss what works best depending on your situation. Time: From 15 June until 15 Oct 2026, at 50-75% work pace. Location: Remote position. Application Process: Should you be interested in applying for this position please send your CV (max. 2 pages) together with a personal letter (max. 1 page) before 9 June 2026 to: secretariat@ccb.se *** Being an international organization, CCB’s work is carried out in English. Applications submitted in any other language will not be considered. Incomplete applications (e.g. lacking either CV or personal letter) will be also not considered. We will be reviewing applications as they come in and encourage early applications. Only shortlisted candidates will be contacted. *** For inquiries , contact CCB Biodiversity Officer: andrea.cervantes@ccb.se Equal Opportunities CCB is an equal opportunity employer. In the application and hiring process, CCB will not discriminate against any individual based on race, colour, sex, language, religion, national or social origin, property, disability, age, family status, sexual orientation and gender identity, economic and social situation.
28 May 2026 - Baltic Sea herring stocks and the herring fisheries have in recent years become a central point of contention in Baltic Sea fisheries policy. Member States' approaches to the International Council for the Exploration of the Sea (ICES) recommendations for herring quotas have varied, and the public debate around herring is polarised. At the same time, dialogue between groups of fishers and other stakeholders in different countries has been limited, and not all actors have had a clear picture of each other's perspectives and needs. Within the framework of the Fisheries for the Future project, funded by Ålandsbanken’s Baltic Sea Project, Finnish and Swedish fishers, environmental organisations and researchers gathered last autumn to discuss the status of herring stocks and fishing in the Baltic Sea. Participants gained a better understanding of differences between countries and areas regarding stock status, fisheries management and research. The organisations that took part in the workshop all agree on the need for joint dialogue and wish for the cooperation to continue. “ The project combines research and practical understanding of the herring situation in the Baltic Sea. That makes the initiative particularly important, as the lessons learned can contribute to better decisions and more accurate measures going forward ," notes Crista Hietala, Head of Marketing and Communications at Ålandsbanken and the Baltic Sea Project. During the workshop, a shared understanding emerged of the complexity of the issue, where fishing is one factor but not the only cause of the state of the stocks. The need for a holistic approach was emphasised, in which environmental changes and factors affecting fisheries regulation are considered alongside fishing itself. " Herring stocks are affected by a range of interacting factors – from water quality and salinity to changes in food webs and climate change. At the same time, knowledge about how these factors interact remains limited, which contributes to increased uncertainty in management ," says Aimi Hamberg, Marine Policy Officer at Coalition Clean Baltic. More stable quotas increase predictability The predictability and economic sustainability of fishing can be improved by reducing annual variations in fishing quotas. Multi-annual and more stable quotas would facilitate the planning of fishing operations and better secure the herring's central role in the Baltic Sea ecosystem. The fishing and environmental organisations that participated in the workshop propose that EU member states ask the International Council for the Exploration of the Sea (ICES) to investigate how the quota system can be developed in a more stable and long-term direction, while at the same time ensuring the recovery of sustainable herring stocks. More knowledge about herring spawning areas Workshop participants emphasise that a significantly better knowledge base is needed about herring spawning and nursery areas than what we have today. Updated information on the most important reproduction areas for herring is central to marine spatial planning, for example when siting offshore wind power and other uses of sea areas. Towards ecosystem-based stock assessments During the workshop, it was recommended that herring stock assessments should be based on an ecosystem perspective. ” We believe that stock assessments and advice on fishing quotas need to take greater account of changes in central ecosystem factors, such as predation by seals and cormorants. It is important to expand data collection in order to achieve this ," say representatives of Vi Svenska Fiskare (We Swedish Fishers). As a first step, workshop participants recommend that Finland and Sweden initiate a joint regional project in the Gulf of Bothnia, which can later be extended to other parts of the Baltic Sea. Management areas should be reviewed – dialogue on protected areas needs to continue The workshop highlighted the need to review the division of management areas in the Baltic Sea. Participants propose that the Bothnian Sea and the Bothnian Bay be separated as distinct regulatory areas. This is motivated by genetic differences between the stocks and the fish's migration patterns. In addition, participants consider it important to continue the dialogue on possible protected areas in the Bothnian Sea. Such areas could be introduced as time-limited pilot trials, whose effects are evaluated scientifically. The dialogue on protected areas in the Bothnian Sea has continued between the organisations at a meeting held in February. *** Related documents Read the press release in Swedish and in Finnish . Main outcomes of the workshop in Swedish and Finnish. *** Further information The Fisheries for the Future workshop was a collaborative project between the environmental organisation Coalition Clean Baltic (CCB) and WWF Finland, with funding from Ålandsbanken’s Baltic Sea Project. Among the represented fishing organisations were Suomen Ammattikalastajaliitto/Finlands Yrkesfiskarförbund (Finnish Professional Fishers' Association), Österbottens Fiskarförbund (Ostrobothnia Fishers' Association), Vi Svenska Fiskare (We Swedish Fishers), Kustfiskarna Bottenhavet (Bothnian Sea Coastal Fishers), Ålands fiskare (Åland Fishers) and Sportfiskarna (the Swedish Anglers' Association). Fisheries management was represented by the Government of Åland and the County Administrative Board of Stockholm. In addition, experts from the Natural Resources Institute Finland, the University of Turku and the Swedish University of Agricultural Sciences participated.
