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Position statement on the EC Communication Towards a strategy to protect and conserve the marine environment (COM (2002) 539 final) May 2003 INTRODUCTION WWF welcomes the Commission Communication Towards a strategy to protect and conserve the marine environment (COM (2002) 539 final) and believes that such a Communication, which summarises the present situation with regard to development and implementation of policies to control threats and sets environmental, operational and institutional objectives, is long overdue. The Communication represents the first step towards the building of a thematic strategy for the protection of the marine environment. The loss of degradation of biodiversity resulting from overexploitation of fisheries, changes in structure, loss of habitat, contamination by dangerous substances and nutrients are of such severity that it is essential this work is progressed with the greatest possible speed, and that the necessary resources are made available for development and implementation of the Strategy. WWF broadly welcomes the objectives and believes that ensuring these are implemented across Europe’s seas will be of great value. We do, however, consider that the current Communication could have been more progressive. For example, the commitments given by North Sea Environment Ministers at the Fifth North Sea Conference (5NSC) in Bergen 2002 and the Commitments given by all EU Member States at the World Summit on Sustainable Development (WSSD) are not reflected in the Communication. It will be important to ensure in the future that objectives are set which “push the boundaries” in terms of the management and protection of Europe’s seas. A brief reference is made to the impact of counter productive subsidies, which encourage overfishing or other activities, but no attention is paid to the “footprint” that EU Member States have on developing parts of the world and the high seas. WWF believes this should be addressed in the Strategy. WWF strongly advocates the importance of stakeholder engagement throughout the process and welcome the opportunity for stakeholder involvement. WWF is an environmental stakeholder, with representation across EU countries and accession countries, with direct experience that can contribute to the process. WWF advocates the elaboration of all objectives and action with timelines. WWF welcomes the principle of a Consultative Body as outlined at the Stakeholder Conference in Denmark, December 2002. AN ECOSYSTEM-BASED APPROACH TO THE MANAGEMENT OF THE MARINE ENVIRONMENT WWF considers the application of the ecosystem approach, incorporating the precautionary principle, as fundamental to achieve the sustainable use of the seas, and in seeking truly comprehensive and integrated governance. WWF endorses, therefore, the outcome from the Stakeholder Conference in Denmark, December 2002, that recognises an ecosystem approach as being core to the success of the Strategy, and the need to develop EU Guidelines on and ecosystem approach. WWF identifies the following six points as critical for the development and implementation of an ecosystem approach: The setting of a vision and environmental goals with stakeholder engagement Developing an integrated marine policy Assessing the resource and status of the resource (including the use of biodiversity, socioeconomic and risk assessments, and threats analysis) Establishing a spatial planning system, incorporating mapping activities and a decision making process to identify what activities can take place where Identification of delivery tools, such as consents, permits and economic tools Developing a strategy for delivery incorporating a legislative framework to delivering an ecosystem approach In taking forward the EU Marine Strategy WWF advocates: Delivery of an ecosystem approach: - A vision for the seas of Europe and reflecting our “footprint” outside European seas - An integrated marine policy to assist management on a regional basis - Inclusion of a mechanism for strategic assessment, some of which could be developed by the Strategic Environmental Assessment (SEA) Directive (2001/42/EC), and applied to the full range of activities both in protected areas and the wider marine environment on a regional or sub-regional basis - A framework for spatial planning at a sub-regional level e.g. Southern North Sea or Adriatic Sea to deliver both protection and management of Europe’s seas - Delivery tools for the management of the resource through EU guidance and regulations - An overall strategy, set against a regulatory backdrop, to show how the above can be delivered, including fiscal measures, research, enforcement, monitoring and evaluation, and involving extensive stakeholder consultation and participation Delivery of an integrated framework between Europe and relevant regional and international bodies. WWF proposes the inclusion of an overarching action to complement the overall objective set out in the Strategy, incorporating the development of an integrated marine policy in coastal and offshore waters. CROSS CUTTING EU ISSUES Agriculture and EU Water Policy (including Water Framework Directive 2000/60 (WFD)): WWF highlights eutrophication and use of agricultural pesticides as an example illustrating the cross cutting nature of the Strategy and the need to work closely on agriculture and freshwater issues to ensure the sustainable use and management of the marine environment: The need to tackle the input of nutrients into the environment at source, for example by reducing nitrate application to agricultural land by aligning the aims of the Common Agricultural Policy (CAP) with the Nitrates Directive (91/676) and the WFD at the earliest opportunity via reform of the CAP. The improvement of water quality through management of river catchment, estuarine and coastal areas through the WFD, the Nitrates Directive, and via Article 7 of Directive 76/464 on the pollution caused by certain dangerous substances discharged into the aquatic environment of the Community. To reduce and eliminate nutrient impacts to ecosystems and wildlife including Natura 2000 sites. The harmonisation of decision-making taken under CAP, WFD, the Nitrates Directive and the Urban Waste Water Directive (91/271) to tackle eutrophication and the release of harmful pesticides into the aquatic environment is essential. WWF note the opportunity of the mid-term review of the CAP in 2003 and the reform of the CAP in 2006 to address this issue. WWF urges the Commission to use these opportunities to deliver radical reform – from a policy that supports farming that causes environmental damage (harming species and habitats that the Commission seeks to protect under the Habitats Directive (92/43)), and which damages the socio-economic interests of the Community (for example the estimated costs of treating drinking water for nitrate and algal toxins in England and Wales is £39 million (approximately 62.4 million Euros)) to one that supports sustainable rural development. Chemicals The actions covering hazardous substances, in particular, necessitate integration with the EU Chemicals Policy, and the WFD. WWF urges the EU in developing the EU Chemicals Policy to: Adopt a precautionary approach Ensure that the new authorisation procedure is designed to phase out the use of chemicals of very high concern, only authorising their use if no safer alternative is available and there is an overriding societal need for use. Ensure that the definition ‘of very high concern’ includes chemicals that are persistent, bioaccumulative and toxic (PBT), very persistent and very bioaccumulative (vPvB) or have endocrine disrupting properties. Regulate the production and use of chemicals within Europe, and the import of chemicals, preparations and articles into Europe. Ensure the availability and accessibility of data on market volumes and patterns of use, therefore assisting with the identification of hazardous substances that may end up in the marine environment. Note the long-term strategy including the principles and standards, on hazardous substances adopted by the Regional Seas Conventions (RSC) Climate Change In addition to delivering on obligations under the Kyoto Protocol WWF highlights the need for the Strategy to: Put offshore development (renewable energy) in the context of SEA and spatial planning emphasising delivery of an ecosystem approach. Consider the assessment of the effects of climate change on marine ecosystems and on the consequences for biodiversity and fisheries, and for coastal processes and implications for coastal defence. MARINE AND COASTAL ISSUES Fisheries WWF welcomes the fisheries objectives, particularly the need to look globally as well as just in EU waters. However we have some concerns: Unfortunately, achievement of the objectives relies on the CFP reform and its implementation. As the reform process is expected to be finalised during 2003 followed by the implementation, this doesn’t necessarily constitute a long term objective. The objective lacks a deadline. The Johannesburg Plan of Implementation included a target for the replenishment of fish stocks by 2015 (a target which the Fisheries Commissioner said he hoped to achieve along time before that). The new proposals under the reformed CFP are considered to be the bear minimum required to achieve restoration and sustainable management of fisheries and the wider ecosystem in the future. If the CFP reform is watered down by the Fisheries Council, the EU Marine Strategy must address the additional requirements to achieve the objective. Although the Strategy relies for its fisheries actions on the CFP framework regulation and other strategies and action plans produced as a result of the CFP reform, it must also seek coherence with the EC Biodiversity Action Plan for Fisheries and the EC Action Plan to Integrate Environmental Protection requirements into the CFP. Nature Conservation and Habitat Destruction WWF welcomes the commitment from the European Commission to pursue its efforts to fully implement the Habitats and Birds Directives in the marine environment. However, the implementation of the Natura 2000 network in the marine environment has been dramatically overlooked during the last ten years of the process resulting in further damage to sites and negative impacts to species. WWF welcomes the proposed reference to integration of policy issues with nature conservation goals, and notes the need for sustainable management of areas of high biodiversity and productivity. WWF welcomes the reference to adapt the annexes to the Habitats Directive (92/43/EEC of 21 May 1992) noting the opportunity to increase the range of marine and coastal habitats and species, so increasing representivity in the marine environment. However, WWF wishes to stress that this should not deter Member States and the European Commission from increasing their efforts to effectively implement the existing provisions for the protection of the marine species and habitats. This refers in particular to the designation, protection and management of marine Natura 2000 sites for species and habitats already listed in the Directives, and the establishment of a system of strict protection of species and the monitoring of incidental capture and killing. Coastal Zone Management WWF note that the adoption of the EU Recommendation for the implementation of Integrated Coastal Zone Management (ICZM) in Europe (May 2002/413/EC) should also lead to a more integrated approach for management of the coastal environment and adjoining seas. It recommends management of the coastal zone with reference to the 6 th Environmental Action Programme. Implementation of the Recommendation, for example by facilitating integrated working of stakeholders, can aid implementation of this Strategy. It will, therefore be advantageous to recognise the obvious links between this Strategy and the Recommendation, and plan to establish strong links between each set of actions. Offshore Activities WWF welcomes the proposed EU action to make proposals for the implementation of the International Maritime Organization (IMO) Convention on Harmful Anti-foulants, and urges the EU to recognise the goal to move towards the use of non-toxic alternatives, and to note the need to ensure that a ban on the use of organotins can be properly enforced. Maritime Transport On maritime transport WWF would welcome: More explicit action on measures to prevent maritime pollution accidents, for example risk assessment and development of proposals including the IMO designation of Particularly Sensitive Sea Areas (PSSAs), and other risk reduction measures such traffic separation schemes and areas to be avoided. Consideration of an immediate ban of single-hull oil tankers within PSSAs. Speeding up the implementation of the Erika I and Erika II packages addressing port state control, activities of classification societies, phasing out single-hull vessels globally, establishing a European Agency of Maritime Safety, monitoring of traffic passing through European waters and payment of compensation to victims of oil spills. Review of the Erika I and Erika II packages to ensure that once fully implemented they would have prevented recent tanker disasters such as the Prestige, Erika and Baltic Carrier Support a fundamental change in the way the shipping industry is operated and regulated globally. CO-OPERATION AND CO-ORDINATION WWF recognise the importance of co-operation and co-ordination between the EU and relevant regional and international bodies, in particular the Regional Seas Conventions (OSPAR1, HELCOM2 and BARCOM3). Clarity on this issue is vital to ensure there is no duplication of effort and to recognise the validity and contribution of the Regional Seas Conventions (RSCs) to the management of Europe’s seas. It is imperative that the EU and RSCs work in concert and not in variance to each other. For example co-operation with the OSPAR strategy on hazardous substances on work covering priority and candidate list substances, and the allocation of a timeframe for action i.e. 2010. RESEARCH, KNOWLEDGE BASE AND ACCESS TO INFORMATION WWF welcome the initiative to develop products promoting the improvement of the knowledge base (action 23), but note: The collation of information should not be used as an excuse for inaction, the use of best available information and the precautionary principle can form the basis for action now. The need to integrate with existing processes and strategies including those developed under the RSCs and the proposed UNEP global marine assessment (2004). The referenced Quality Status Reports (QSR) do not duplicate the exercise conducted by OSPAR in 2000 and due for review in 2009. The collation of region specific information that allows for the assessment of synergies and cumulative effects of human impacts would be useful and contribute to an ecosystem approach. Topic assessments should be relevant to the full range of issues. WWF believe that it is essential that all stakeholders are made aware and have access to current information that directly or indirectly relates to the Strategy. This should be clearly stated in the text of the Strategy as done in Article 14 of the WFD. The Aarhus Convention on Access to information, public participation in decision-making and access to justice in environmental matters (Aarhus, June 1998) also has implication for this Strategy. The Convention recognises that “every person has the right to live in an environment 1 Convention for the Protection of the Marine Environment in the North East Atlantic 2 Convention for the Protection of the Marine Environment of the Baltic Sea 3 Convention for the Protection of the Marine Environment and the Coastal Region of the Mediterranean adequate to his or her well being, and the duty, both individually and in association with others, to protect and improve the environment for the benefit of present and future generations”. It also considers that “to be able to participate in decision-making and have access to justice in environmental matters”. Furthermore the Convention recognises that “in the field of the environment, improved access to information and participation in decision-making enhance the quality and implementation of decisions, contribute to public awareness of environmental issues, give the public the opportunity to express its concerns, and enable public authorities to take due account of such concerns”. There is a severe lack of scientific knowledge, in particular regarding the marine offshore and deep sea environments which needs to be addressed in the new 6th EU Framework Programme for Research and Technology. However, the draft work programmes known so far do not reflect this need for information and its relevance for implementation of existing EU legislation (e.g. EU Habitats Directive). RECOMMENDATIONS Cross cutting issues such as CAP, CFP, WFD, EU Chemicals policy are fully considered and integrated into the development of the Strategy There is full co-ordination and co-operation with regional and international bodies and processes (administrative, institutional, policy and scientific), and the process is complimentary to relevant work being conducted under the RSCs Development and implementation of an ecosystem approach to marine management, incorporating an integrated marine policy by 2010 (in line with WSSD commitments) WWF LOOKS FORWARD TO THE DEVELOPMENT OF THE STRATEGY AND NOTES ITS INTEGRATION AND CONTRIBUTION TO THE 6TH ENVIRONMENTAL ACTION PLAN AND SUSTAINABLE DEVELOPMENT STRATEGY, AND URGES THE EU AND MEMBER STATES TO IMPLEMENT THE STRATEGY AS A PRIORITY AND IN FULL. Position Statement for WWF European Endangered Seas Programme. For more information please contact: Dr Sian Pullen: Head, European Endangered Seas Programme, WWF International ([email protected]) Alison Champion: Marine Policy Officer, WWF-UK ([email protected]) Panda House, Weyside Park, Catteshall Lane, Godalming, Surrey, GU7 1XR, UK Tel: +44 (0)1483 426444 Fax: +44 (0)1483 426409