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Leibniz Institute of Freshwater Ecology and Inland Fisheries (IGB)

IGB

The Leibniz Institute of Freshwater Ecology and Inland Fisheries (IGB) is Germany’s largest and one of the leading international research centres for freshwaters.

Lobbying Activity

Response to EU Ports Strategy

23 Jul 2025

The Leibniz-Institute of Freshwater Ecology and Inland Fisheries (IGB) is Germany's largest and one of the leading international research centres for inland waters. Based on our research expertise, we are providing feedback in the Call for Evidence for the planned EU Ports Strategy. In the information available to date on the priorities of the planned EU Ports Strategy, the focus is on the economy, energy and security. An integration of legally binding EU nature conservation laws and strategies is not yet recognisable. No reference is made to the Marine Strategy Framework Directive, the Water Framework Directive or the Natura 2000 Directive and, accordingly, there is no indication of how the new EU Ports Strategy will contribute to achieving these environmental goals. This view lacks a crucial reflection: Ports themselves are often massive stressors and disruptive factors for the very sea and river systems whose ecosystem services they themselves use and on which they are dependent. If the EU Ports Strategy is to make ports in Europe more resilient, this must include the resilience of the aquatic ecosystems that the ports rely on and that are surrounding them. The following applies in principle: massive investment in infrastructure, particularly in the port and waterway sector, does not automatically lead to increased demand and creation of economic impact. In contrast, this can lead to massive and expensive interventions in ecosystems that cannot be justified by overriding and long-term public interests and thus harm nature, the economy and people alike. This is a brief overview, please find attached a pdf document with the full and detailed IGB Feedback.
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Response to Towards a Circular, Regenerative and Competitive Bioeconomy

4 Jun 2025

Dear Sir or Madam, The Leibniz Institute of Freshwater Ecology and Inland Fisheries (IGB) is Germanys largest research centre for freshwaters. Our research findings help to tackle environmental changes and to develop strategies for sustainable water management true to our guiding principle Research for the future of our freshwaters. Based on our research and expertise, we comment on the Call for Evidence on the new EU Bioeconomy Strategy. Key message: One major critical bottleneck to consider is water, it plays an irreplaceable role across all areas of the bioeconomy as a foundational resource for ecological integrity, production systems, and sustainable development. Put simply: without water, there is no biomass. Please find our full IGB Feedback attached as a PDF file. Our scientists are at your service if you have any more questions.
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Response to European Water Resilience Strategy

4 Mar 2025

Dear Sir or Madam, The Leibniz Institute of Freshwater Ecology and Inland Fisheries (IGB), Germany's largest research centre for freshwaters, welcomes the possibility to give science-based advice on the planned European Water Resilience Strategy (EWRS). In the IGB Feedback (full version see attached PDF), the researchers underline the need to tackle the implementation and enforcement deficit of the already existing legislation, and emphasise that the fundamental basis for water resilience is, first of all, the resilience of freshwater ecosystems. Their proper functioning is required for further planning and taking actions with sustainable impact. Without resilient aquatic ecosystems, no overall water resilience will be achievable. The IGB researchers are at your service for background talks.
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Response to Commission Directive amending Annex III of the Nitrates Directive

14 May 2024

The Leibniz Institute of Freshwater Ecology and Inland Fisheries (IGB) is Germanys largest research centre for freshwaters. Our research findings help to tackle environmental changes and to develop strategies for sustainable water management true to our guiding principle Research for the future of our freshwaters. Based on our research and expertise, we comment on the EU Consultation on the planned update of the rules on the use of certain fertilising materials from livestock manure (Renure). The current limit of 170 kg nitrogen per hectare should be handled as a maximum level, which is, from an environmental research perspective only acceptable, if applied in areas with sufficient denitrification potential in soils and groundwater. Otherwise, nitrogen applications at this level potentially pose a major threat to aquatic ecosystems, their biodiversity, their functions and thus, also their ecosystem services. The policy objective of closing nutrient cycles serves justified objectives of agriculture and nature conservation. An increase in the total amount of applied nitrogen would counteract these objectives. Therefore, the current limits of 170kg nitrogen per hectare and year should not be exceeded, and Renure fertilizers should not profit from any exceptions from these limits. It is well known that several European regions are hotspots of livestock farming, leading to nutrient surpluses far too high. The adaptation of the Annex regulations should not be used as a political instrument to allow even more nutrients to be released into the environment in these regions. Instead, efforts should be made to mitigate these nutrient hotspots, and to foster more sustainable agricultural practices. The full IGB feedback has been attached as a PDF document.
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Response to Guidance on accelerating permitting processes for renewable energy projects and facilitating Power Purchase Agreements

12 Apr 2022

The Leibniz Institute of Freshwater Ecology and Inland Fisheries (IGB) is Germany’s largest research centre for freshwaters. Our research findings help to tackle global environmental changes and to develop strategies for sustainable water management – true to our guiding principle “Research for the future of our freshwaters”. Based on our research and expertise, we comment on the Call for Evidence on “Renewable energy projects – permit-granting processes & power-purchase agreements”. Our general scientific advice focuses on aspects of the permit-granting processes and the potential jeopardy of environmental standards – this part is applicable for the whole sector of renewable energies, while our special focus is on issues of hydropower as a renewable but not environmentally friendly energy source. In summary, hydropower projects should neither be prioritised nor accelerated through the proposed initiative, and their approval processes should be especially precise and carefully follow rules for environmental impact assessments, due to the negative environmental impacts explained in our full feedback. Otherwise, the European Commission would jeopardize its own climate and environmental goals, and the highly valuable freshwater resource for the European population. The precautionary principle plays a central and major role, because once hydropower infrastructure is established, valuable habitats and populations of rare species can quickly disappear forever. This can already happen within the building phase – hence, an early start of construction without final official approval should not be allowed in any case. Instead of approval acceleration, the decommissioning and dismantling of small hydropower plants should be promoted. This approach fundamentally simplifies the implementation of restoration measures, also because this enables larger-scale restoration towards restoring 25,000 km free-flowing rivers as it is explicitly foreseen in the EU Biodiversity Strategy to 2030. In this way, important ecosystem services of water bodies for the environment and society, such as natural climate change mitigation including flood protection, stable land-scape water balance, self-purification, cooling effect and water-related local recreation, could be restored. This is particularly important in view of the expected consequences of climate change and strengthens the natural resilience of water bodies. You can find our full science-based feedback in the PDF file attached. Our experts are looking forward to exchanging knowledge on the topic.
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Response to Measures to reduce microplastic pollution

18 Jan 2022

The Leibniz Institute of Freshwater Ecology and Inland Fisheries (IGB) is Germany’s largest research centre for freshwaters. Our research findings help to tackle global environmental changes and to develop strategies for sustainable water management – true to our guiding principle “Research for the future of our freshwaters”. Based on our research and expertise, we comment on the Call for Evidence on microplastics (MPs) pollution and measures to reduce its impact on the environment. The IGB scientists underline the high relevance of freshwater ecosystems for nature and society alike. Freshwater systems provide us with the vital resource drinking water and harbour a unique diversity of life. However, rivers, lakes, ponds, wetlands and groundwater are among the most threatened ecosystems in Europe and worldwide. Their decline is associated with multiple stressors, including pollution by manifold human activities. Framing the legislation for the protection of our inland waters to safeguard ecosystem services such as clean drinking water, natural flood protection, fisheries resources, recreational spaces, and pollutant retention, will be vital for human livelihood in Europe in the coming decades. In this context, MPs and sub-micron-plastics (SMPs) pollution is an emerging and consistently increasing environmental stressor of high concern. European policy-making needs to address this topic with coherent and effective solutions. Regarding MPs and SMPs pollution, the IGB scientists highlight seven critical aspects. These are explained in the Institute's full feedback that is attached as a PDF file. Conclusion: From a research-based perspective, the IGB scientists underline that improved EU policies to efficiently prevent and mitigate MPs and SMPs emissions into the environment are urgently needed. A harmonised EU-wide monitoring would foster the production of crucial knowledge on the topic, and would directly support sustainable policymaking. Once released into the ecosystems, a retrieval of MPs and SMPs is basically impossible. Prevention directly at the source should be given priority, not costly end-of-pipe solutions. Given the high ecological and health risk of long-term MPs and SMPs emissions, current practices should be improved, and clear and consistent EU policy should be made, especially with perspective to the own environmental goals of the EU. Considerable attention must be paid to the indirect adverse effects of plastics, such as facilitating the development and spreading of antibiotic resistance genes, which might harm human and environmental health alike. All details can read in the attached full feedback.
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Response to Navigation And Inland Waterway Action and Development in Europe (NAIADES) III Action Plan 2021-2027

14 Jan 2021

Analysis: target conflicts in EU policies The Leibniz Institute of Freshwater Ecology and Inland Fisheries (IGB) is Germany’s largest research centre for freshwaters. From a research-based perspective, the IGB scientists underline that inland waters such as rivers must not merely be seen as existing or potential traffic corridors, but they also provide multiple provisioning, regulating and cultural ecosystem services, including flood retention. In the first place, they represent highly threatened habitats for aquatic biodiversity, protected by European laws and regulations. This water-dependent biodiversity has a value in itself, and also forms the basis for functioning and resilient ecosystems. Thus, there exist severe target conflict in the legal and political sphere between the TEN-T programme on one side, and the Water Framework Directive (WFD), Natura 2000, and the recent EU Biodiversity Strategy on the other side. Waterway development in natural rivers very often puts the aquatic ecosystems and its services at risk, with a high probability of destroying irreplaceable habitats and species communities, and as a result adversely affecting biodiversity. Therefore, while inland navigation is “greener“ than other means of transport due to lower carbon emissions, one needs to pay attention not to blindly develop it without taking other environmental impacts into consideration. The above mentioned conflicts of political and legal targets between the EU transport policy and the European environmental policy (which plans to restore 25.000 km of free-flowing rivers according to the EU Biodiversity Strategy) are obvious and have not been solved. According to the EU Green Deal plan, climate and environmental policies have to be integrated and not set against each other. The NAIADES III roadmap does not reflect this integrative approach, and does not include suggestions to mitigate those target conflicts. Environmental targets of European directives have to become cross-cutting obligations for all other sectors operating in or utilizing European environments. Correspondingly, the NAIADES III roadmap needs to be subjected to a pan-sectoral cost-benefit check and prioritisation rather than counteract with the targets of the Green Deal. Climate change adaptation, cost-benefit analyses and environmental impact assessments In general, inland navigation development is very costly and, since it depends upon year-round precipitation, it is highly affected by climate change. Therefore, synergies and risk potentials, efficiency and sustainability of inland navigation projects should be carefully analysed already in the strategic planning phase. The desired “continuous financial support aimed at improving the quality and the climate resilience of inland waterways infrastructure, including of the inland ports infrastructure“ is based upon development plans that in some cases are already several decades old. Therefore, development projects should be carefully proven, and subsidies must only be granted if the measures are fully in line with EU environmental evaluated, especially the WFD that has proven its efficiency in securing biodiversity and sustainable management (IGB 2019). Therefore, inland waterway development or maintenance projects under the present initiative cannot automatically be awarded the status of an “overriding public interest“ according to respective exemption regulations in the WFD and Natura 2000, but the impacts should be verified on a case by case basis. An external, independent and objective environmental impact assessment should be mandatory, as should be significantly positive cost-benefit analysis that should include a comparison with alternative transport modes such as the railway sector. Water supply and its sustainable distribution among societal sectors represents a major issue in European policymaking in the 21st century, which the transportation sector has to consider, too. Full feedback attached, see PDF.
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