KIMO International
KIMO
KIMO is a network of more than 80 local governments from northern Europe, working together for healthy seas, cleaner beaches, and thriving coastal communities.
ID: 625948112312-41
Lobbying Activity
Response to Measures to reduce microplastic pollution
16 Jan 2024
Microplastics, and in particular plastic pellets, are one of the greatest threats to the marine environment. KIMO International members, from 9 countries across Europe) have been working for 35 years to keep issues or marine pollution high on the agenda. We first raised the issue of microplastic pollution in 2009 and despite our efforts and those of many similar organisations across Europe, pollution from microplastics has still not been adequately addressed by the EU. As plastic production is set to rise, the situation will only get worse unless it is dealt with through strong and coherent legislation, which addresses maritime transport as a source but also careless handling by the industrial sector of plastic pellets - spills have been documented at every stage of the value chain! The recent pellet spill off the coast of Portugal is now affecting the coast of Galicia, as spilled pellets are washing up in their millions. It is indefensible that taxpayers are paying for the clean up whilst the polluters are not held accountable. The proposal for a regulation, tabled in October 2023, is far too weak to make any tangible difference. The EU must implement a much more ambitious and strong regulation that obligates the polluters to pay. Similarly, prioritisation of pellet loss must be made mandatory and all pellet handlers made accountable.
Read full responseResponse to Measures to reduce microplastic pollution
18 Jan 2022
KIMO International welcomes this initiative on measures to reduce the impact on the environment of (unintentionally released) microplastics.
The UN’s Food and Agriculture Organisation recognises microplastics as one of the ‘Chemicals of Emerging Concern’ due to its detrimental effect on soil health. In the marine environment, microplastics substitute for natural prey of many organisms with negative effects on growth, reproduction and survival. Zooplankton ingest microplastics with potential ramifications throughout the food web. European Commission Decision 2010/477/EU relating to the Marine Strategy Framework Directive includes a requirement for EU states to monitor microplastics in order to ensure that they “do not cause harm to the coastal and marine environment”.
Sustainable coastal communities depend on healthy marine ecosystems. In order to meet Sustainable Development Goal Targets 12.4, 12.5, 14.1 and in line with the precautionary principle, all reasonable steps should be taken to reduce the emission of microplastics from artificial grass playing fields into the environment.
Please find attached some of KIMO's work to address this issue. We would be happy to work with the EC and other partners to raise awareness and provide tangible best practice solutions to mitigate microplastics release into the environment.
Read full responseResponse to Revision of the Urban Wastewater Treatment Directive
31 Aug 2020
KIMO International (www.kimointernational.org) is an international association of local authorities in northern Europe with a shared concern for the state of the marine environment. KIMO was founded to give environmentally conscious municipalities a political voice at regional, EU and international level. We are a fully independent environmental organisation driven by the collective opinions and ambitions of our member municipalities and have more than 30 years experience in environmental advocacy. We also engage in a number of practical environmental projects such as the highly successful 'Fishing for Litter' initiative.
KIMO is supportive of the direction that the EU is taking with the revision of the UWWTD and wishes to make the following specific point.
1. We support the intention that the revision will address storm water and surface run since these are a hitherto unaddressed but major source of contaminants and should be given high priority in the revision.
2. The proposed approach to develop and implement preventive measures aimed at reducing pollution at source is, in our view, the most effective, and most likely to result in a sustained decline in contamination.
3. Interim targets will be fundamentally important to the achievement of the proposal. These should be entered into legislation and should be robustly monitored to ensure that objectives are fully met.
4. Implementation of a robust Action Plan is imperative, with SMART targets that are realistic, achievable and sustainable in the longer term.
5. Better governance - local authorities are key actors in the implementation of EU policy and legislation and should be fully consulted and involved. Effective mechanisms should be implemented nationally to ensure that this is achieved.
6. Other stakeholders (NGOs, citizens groups, businesses, industry) are also key to implementation and should be fully integrated into policy decisions.
Read full responseResponse to Climate Law
6 Feb 2020
KIMO (www.kimointernational.org) is an international association of local authorities in northern Europe with a shared concern for the state of the marine environment. KIMO was founded to give environmentally conscious municipalities a political voice at regional, EU and international level. We are a fully independent environmental organisation driven by the collective opinions and ambitions of our member municipalities and have more than 25 years experience in environmental advocacy. We also engage in a number of practical environmental projects such as the highly successful 'Fishing for Litter' initiative.
Whilst KIMO is generally supportive of the direction in which the EU is heading with Climate Law, we have the following concerns:
1. The IPCC Special Report concludes that 2050 is the latest date by which neutrality for GHG emissions must be achieved. Therefore an earlier target date should be agreed and incorporated into legislation to mitigate the chances of missing the 2050 critical point.
2. Interim targets are fundamentally important to the achievement of the target. These should be entered into legislation and should be robustly monitored to ensure that objectves are fully met.
3. Implementation of a robust Action Plan is imperative, with SMART targets that are realistic, achievable and sustainable in the longer term.
3. Better governance - local authorities are key actors in the implementation of EU policy and legislation and should be fully consulted and kept informed. Effective mechanisms should be implemented nationally to ensure that this is achieved.
4. Other stakeholders (NGOs, citizens groups, businesses, industry) are also key to implementation and should be fully integrated into policy decisions.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
KIMO (www.kimointernational.org) is an international association of local authorities in northern Europe with a shared concern for the state of the marine environment. KIMO was founded to give environmentally conscious municipalities a political voice at regional, EU and international level. We are a fully independent environmental organisation driven by the collective opinions and ambitions of our member municipalities and have more than 25 years experience in environmental advocacy. We also engage in a number of practical environmental projects such as the highly successful 'Fishing for Litter' initiative.
KIMO works closely with stakeholders from the fishing industry, ports and harbours, waste management and independent industry initiatives to collect, process and revalue waste from the oceans. A sea change is needed in order to reduce the waste that ends up in our oceans and we believe that extensive investment in entrepreneurship, design and technology is the best way to achieve this, so that new materials are developed and implemented into items for consumer use that can be valorised at end of life usage. KIMO sees a need for this particularly within the fishing industry so that manufacturing of fishing gear takes place with circularity as a fundamental objective. This means it can be properly disposed of at end of life and is far less likely to end up in the oceans causing danger to marine mammals, fish and shipping, and adversely affecting local economies; tourism and recreation industries.
KMO believes that the proposed Action Plan must be SMART with realistic, measurable and enforceable targets. KIMO urges the EU to work closely with actors at local level, both state and non-state, to ensure that local voices are heard and that implementation of the proposed action plan is supported.
Read full responseResponse to EU 2030 Biodiversity Strategy
20 Jan 2020
KIMO (www.kimointernational.org) is an international association of local authorities in northern Europe with a shared concern for the state of the marine environment. KIMO was founded to give environmentally conscious municipalities a political voice at regional, EU and international level. We are a fully independent environmental organisation driven by the collective opinions and ambitions of our member municipalities and have more than 25 years experience in environmental advocacy. We also engage in a number of practical environmental projects such as the highly successful 'Fishing for Litter' initiative.
Decline and loss of biodiversity is an issue of great concern to our members and we welcome this roadmap and the EU's plans to address this. Key considerations for KIMO are:
1. Existing legislation is strengthened, fully monitored and enforced to ensure that biodiversity objectives are met.
2. Implementation of a robust Action Plan with SMART targets that are realistic, achievable and sustainable in the longer term.
3. Better governance - local authorities are key actors in the implementation of EU policy and legislation and should be fully consulted and kept informed. Effective mechanisms should be implemented nationally to ensure that this is achieved.
4. Other stakeholders (NGOs, citizens groups, businesses, industry) are also key to implementation and should be fully integrated into policy decisions.
Read full responseResponse to Reducing marine litter: action on single use plastics and fishing gear
12 Jan 2018
KIMO welcomes this initiative and supports rapid and urgent implementation of dedicated legislation to combat single-use plastics and ALDFG. We have made general comments here in the expectation that a focussed and researched consultation will be available for more detailed comment.
The inception document appears to be focussed more on single-use plastic items than on ALDFG, the content for which is lacking in detail. We feel it is imperative that the impact assessment addresses ALDFG fully and comprehensively, making clear the risks it poses, the harm caused to marine life and the economic losses to the fishing and shipping industries.
We note the lack of reference in this document to primary and secondary microplastics - microbaeds in cosmetics could be considered a source of single-use plastic and secondary microplastics are generated through degradation of single-use plastic, therefore we feel consideration should be given to include these in the impact asessment. We also note that there is no reference to the roles that rivers and waterways play in plastic pollution and feel that their inclusion should also be considered.
We would like to see a much greater emphasis on the importance of education and awareness-raising as part of the circular economy as these are the strongest contributors to changing public perception and behaviours.
We believe that education rather than financial incentivisation to fishermen to collect ghost nets or other ALDFG from the oceans is more sustainable long-term, but that fisherment should not be charged for landing ALDFG waste collected at sea in the course of their fishing activities. The Fishing for Litter scheme supports the landing and removal of this waste for free. To withdraw this would disincentivise fisherment to continue to land this waste.
A greater emphasis on the economic, social and health impacts of marine plastics should also be given. They foul fishing gear leading to lost time and repair costs; they wash up on beaches impacting on social and recreational oportunities and causing financial losses to local businesses; they leach chemicals creating a hazard for swimmers and marine life; as microplastics they enter the human food chain causing risk to human health. The importance of the detrimental affects should be adequately raised and set within a context of the UN's recognition of marine plastics as a global issue.
According to the principle of the polluter should pay, we strongly support any scheme which advocates extended producer responsibility for single use plastics and ALDFG. KIMO believes it is imperative that the costs for cleaning up of plastic pollution should not be the responsbility of the local authorities and a combination of EPR and education to change public behavious is likely to be the best way to address the problem.
With 27 years in environmental advocacy, KIMO is an international organisation of coastal municipalities which works to protect and preserve the marine environment of the northern seas. KIMO was responsible for the Fishing for Litter initiative and continues to coordinate a large number of Fishing for Litter projects across Europe. We would welcome the opportunity to bring our experience and contribute to a fuller consultation on plastics in the oceans.
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