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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. External nutrient reduction before entering the sea is the only truly effective long-term strategy to combat eutrophication.

In memoriam of Petro Hrytsyshyn

By CCB • August 20, 2026
It is with great sadness that the Coalition Clean Baltic shares the news of the passing of Petro Hrytsyshyn, a long-standing colleague, environmentalist and true friend of the CCB family. The hospitality and warmth with which he embraced each and every one of us in Lviv will always be an example of genuine and close relation and lasting, professional friendship. For many years, Petro was Director of the Western Centre of the Ukrainian Branch of the International Centre for Scientific Culture – World Laboratory, one of CCB’s oldest member organisations in Ukraine. But it is the role he played in our family of environmental NGOs in the Baltic Sea Region that we will remember him for. Petro was one of the people who helped build, connect and sustain the international environmental community of which CCB is a part. For decades, he worked across borders and disciplines, bringing together scientific knowledge, environmental organisations, local communities and international partners around a shared belief that environmental challenges can be met through cooperation, practical solutions and persistence. Within CCB, Petro was a familiar and valued presence at conferences, seminars and joint activities over many years, representing Ukraine and the Western Centre while also contributing his own knowledge and experience to the wider Baltic Sea community. He hosted numerous CCB activities in Lviv and shared his expertise on the issues closest to him: water protection, sustainable sanitation, ecological safety and sustainable agriculture. He also represented the Western Centre in international environmental processes, contributing to discussions on environmental protection, water management and sustainable development. What made Petro's contribution especially important was that he understood environmental protection not only as a matter of policy or science, but as something that had to work in practice, on the ground. His work on ecological sanitation and wastewater management, for example, sought practical ways of reducing pollution and protecting water resources in rural areas of Ukraine. He continued this work into recent years. In 2023, Petro was among the experts contributing to CCB's analysis of the Greatest Water Management Challenges in the Baltic Sea Region, bringing the Ukrainian perspective into a broader regional assessment. More recently, he contributed to the Green Recovery Plan for the Ukrainian part of the Vistula River Basin, including the Western Bug and Syan sub-basins – work that reflected the qualities of his whole career: international cooperation, practical environmental knowledge and a commitment to the future of Ukraine's rivers and communities. For those of us who worked with him, however, his legacy is not only projects, publications and meetings. In a network such as CCB, people are the foundation of cooperation, and Petro was one of those people who kept the connections alive through changing political circumstances, new environmental challenges and difficult times that Ukraine faces as a result of Russia’s unprecedented war of aggression. He represented a generation of environmental professionals and civil society activists who understood that lasting environmental progress depends on solidarity, openness and the willingness to work together across borders. His long commitment to cooperation between Ukrainian and European environmental organisations was an important part of that legacy. CCB is grateful for the many years of cooperation with Petro, for his knowledge and commitment, for his hospitality and friendship, and for the bridges he helped build between people and organisations working for a healthier environment. Our thoughts are with his family, friends, colleagues and all those who had the privilege of knowing and working with him. Petro Hrytsyshyn 1951–2026 May the memory of Petro Mykhaylovych remain with all of us who continue the work to which he devoted so much of his life.

CCB's submission on the European Ocean Act

By CCB • July 14, 2026
We support the Ocean Act objectives for improving coherence, coordination and effectiveness of EU ocean governance. However, we emphasize that the Act must deliver truly ecosystem-based management and that reaching Good Environmental Status (GES), as defined in the Marine Strategy Framework Directive (MSFD), should be established as a cornerstone of the Act.