Stockholms universitet
SU
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Lobbying Activity
Response to Implementing Act on the provision applying as from January 2026 of the amended Fisheries Control Regulation
25 Aug 2025
The Baltic Sea Centre at Stockholm University submits the following comments on the proposed regulation. We note that the proposed regulation contains numerous and detailed rules. Given the current relation between fishing capacity and fishable fish in the Baltic Sea, it is unfortunately necessary to strengthen fisheries controls and to regulate them more stringently. The current inadequate control system undermines the effectiveness of the Common Fisheries Policy and the Baltic Sea multiannual plan, for example by increasing uncertainties in scientific assessments and forecasts. It is not only the penalties that need to be high enough to be effective, proportionate and dissuasive. The control system as such need to be effective, proportionate and dissuasive. This includes, in addition to the size of the penalties, the risk for getting caught and the risk for getting some kind of penalty when caught. Therefore, the strengthened controls and stricter common minimum rules in the draft implementation act are to be welcomed. For example, there have been reports of vessels port shopping when one country strengthens its fisheries controls. That is, vessels choose to simply land their catches in Member States with less effective controls. This has in practise provided Member States with incentives to not strengthen controls. We would therefore also like to underscore the importance of the exchange of inspection and surveillance related data under the proposed Article 64, where the inspecting Member State shall promptly forward inspection and surveillance reports to the flag Member State. The results of the inspections should, of course, in suitable form, be made available to other stakeholders such as researchers and media. Independent audits of companies conducting fisheries controls in designated ports should also be made available to flag Member State authorities and other stakeholders. As other examples of detailed rules, it is important that fishing gear is clearly labelled at a high level of detail (e.g. Article 12 2(c)). Given recent court rulings on the consequences of a fish stock being classified as by-catch, together with the unstable definition of by-catch and the need for restoration also of some fish stocks considered by-catch, more detailed rules on reporting non-target stocks are needed. At the same time, it should be recoqnised that detailed rules can constitute an administrative burden on both fishers and other operators and on Member States. As a rule of the thumb, the worse state fish stocks are in and the greater the actual capacity to catch fish is in relation to the amount of fish that can be sustainably caught, the more detailed control and control regulations are needed. To the extent that this burden is considered too high, therefore, the solutions should be sought in measures to strengthen fish stocks and reduce overcapacity. Only when such measures have been successful can the administrative burden be reduced. A possible exception, in some circumstances, is small-scale, coastal fishers fishing for direct human consumption.
Read full responseResponse to Sustainable fishing in the EU: state of play and orientations for 2026
3 Jul 2025
This submission from the Stockholm University Baltic Sea Centre focusses on conditions in the Baltic Sea. References may be found on our website https://www.su.se/stockholm-university-baltic-sea-centre/ . EELS The mismanagement of the European eel offers a clear illustration of the state of play of the common fisheries policy. - The immediate economic interests of a small group of people are allowed to dominate over the conservation of our common biological heritage and the resource base some of their income depends on. - Scientific advice is used when it suits these interests, disregarded otherwise. - Governments that use failures in another policy area here, habitat destruction to justify continued overfishing are the same governments that delay action in that very area. - Ineffective measures here, closures of fisheries during periods when there has been little fishing anyway give a false appearance of action. MSY OBJECTIVE The Commissions communication presents the MSY objective as fishing activity at Fmsy. This disregards the biomass objective in the CFP and MAP regulations - restore and maintain stocks above levels that can produce MSY. The STECF report, referred to by the Commission, reports on both of these objectives. Incidentally, it is impossible to fish at Fmsy for all stocks in a mixed fishery. The Commission carries its misinterpretation of the CFP into its request for advice from ICES. It should request that ICES, in an executive summary, informs on whether the two MSY objectives are met, and on other important information in the body of the report. It should also indicate if the advice takes into consideration the impact of catch levels on key aspects of good environmental status under the Marine Strategy Framework Directive such as biodiversity, food webs and habitat integrity. By its faulty interpretation of the MSY objective, the Commission delays progress on restoring fish stocks. Due to inherent problems in the MSY approach as such, including the weakness of the scientific basis for making assessments and forecasts, we suggest that the MSY approach is used with a stronger precautionary buffer. STATE OF THE FLEET, BALANCE Efforts to achieve balance between fishing fleets and fishing opportunities are undermined by the continued subsidies for fuel, in the form of exemptions from carbon emission pricing. These subsidies also reduce incentives to decarbonise the sector and are harmful to the marine environment and sustainability of the fishing sector. Funds for decarbonisation and fleet renewal should be conditional on full carbon pricing. Better capacity indicators are needed. ENVIRONMENTAL AND SOCIO-ECONOMIC OBJECTIVES The Communication implies that the Commission will continues to disregard the environmental objectives in the CFP and MAP when making its proposals for fishing opportunities. The Commission should clarify that environmental objectives are not taken into account in the proposal, but should be under the CFP, and that this would normally result in lower TACs than those proposed unless there is evidence suggesting otherwise. A further step towards a more ecosystem based fisheries management would be to differentiate between forage and predator fish. It is difficult to untangle the relative impact of various of environmental pressures on Baltic fish stocks. The existence other environmental pressures should lead to more precautionary TACs until these pressures are reduced. Socio-economic impact assessments should look beyond the coming year and highlight the longer term socio-economic consequences of rapidly restoring fish stocks. Economic analyses should disaggregate the fleet into at least the small-scale coastal fleet and the large-scale mobile fleet. Employment and down-stream value for the local economy per ton fish are likely greater for the SSF than the LSF, or with fishing for direct human consumption instead of fish meal, for example in the Baltic pelagic fisheries.
Read full responseResponse to The European Oceans Pact
13 Feb 2025
The Baltic Sea Centre at Stockholm University offers these comments on the proposed Ocean Pact OBJECTIVES: The primary objective of an Ocean Pact should be to restore and maintain ocean good environmental status; the short term goal should be improvement, while avoiding damage. The environmental dimension should be prioritised in short-term decision-making, not put off until the long run. Even an objective of sustainability, if understood as three equal dimension of environmental, social and economic is too broad and vague. As was pointed out already by Larkin (1977), in fisheries management all these dimensions tend to be subordinated to an unnamed but overriding dimension of political sustainability. PARTIES TO THE PACT: The notion of a pact suggests a negotiated deal between parties. This brings to mind the old adage if you arent at the table, you end up on the plate. The environmental interest should be guaranteed a seat at the table. SOURCE TO SEA: As what happens on land has a major impact on the marine environment the focus of an Ocean Pact should not be limited to sectors that impact directly on the sea. That is, a source-to-sea approach is needed. Greater consideration of the impacts on the marine environment should be integrated into all relevant policy sectors. While some blame the poor state of some fish stocks on hypoxia and eutrophication, this is ignored when it comes to decision-making on agriculture policy. SCIENTIFIC UNCERTAINTY: As irreversible and substantial damage can have occured before scientific certainty has been reached, there is broad support for a precautionary principle. Decision-makers should be aware that this can be undermined when decision-making relies too heavily on scientific consensus in bodies like IPCC or ICES. BLUE ECONOMY: An ambition in discussions of Blue Economy is to expand or develop new markets built on marine-based resources. When there are expectations of good profitability there is a tendency for overinvestment; then, when restrictions are needed to conserve resources these are opposed as costs. When developing new markets, effective mechanisms to prevent overinvestment and overexploitation must also be in place. Increased aquaculture is no replacement for decimated fish stocks. FINANCING: For market based solutions to be efficient, negative environmental impacts need to be internalised, e.g. by taxes, fees, emission trading rights etc. As a corollary is the principle that the pollutor shall pay (the costs of reducing negative environmental impacts), subsidies should be avoided. For example, to promote decarbonisation of the fishing fleet it is more efficient to put a price on emissions rather than subsidize new engines. Possible subsidies for good behaviour might be subsidized by fees for bad behaviour (bonus-malus). COMPETITIVENESS: Markets distortions such as the existence of negative externalities in some trading partners should not be allowed to facilitate destruction of the marine environment, with all its social, economic, cultural and political consequences. To the extent that European producers are feared to be at a competitive disadvantage when producers in trading partners are permitted to have more negative environmental externalities, this should primarily be rectified by high minimum standards in trade agreements or compensatory tariffs in line with the thinking behind the CBAM. SECURITY/FOOD SECURITY: During periods of conflict or trade disruptions locally accessible food resources can increase in importance. Risk for trade disruptions or conflicts gives added importance of restoring and maintaining fish stocks in European seas, and maintaining and restoring the marine environments that support these fish stocks. See the attached file for more detailed comments on environmental issues. Link to Larkin (1977) https://afspubs.onlinelibrary.wiley.com/doi/abs/10.1577/1548-8659%281977%29106%3C1%3AAEFTCO%3E2.0.CO%3B2
Read full responseResponse to Evaluation of the Common Fisheries Policy
6 Sept 2024
The Stockholm University Baltic Sea Centre offers the following comments: Regarding the evaluation criteria 1. Based on results in the Baltic sea fish stocks, implementation of the CFP is far from fulfilling its purpose 2. There has been little effort to achieve coherence between fisheries and environmental policy. For example, the Basic Agreement between the Commission and ICES explicitly states that environmental impacts on key indicators of Good Environmental Status under the MSFD is not be taken into consideration in ICES advice on fishing opportunities. 3. Comparisons with a situation without the EU are hypothetical. Based on the situation before EU expansion in the Baltic region, the CFP may have somewhat slowed acceleration towards an ecological breakdown. Regarding the instruments, 1. There has been an overreliance on trying to achieve MSY. In short, a) it is much more difficult to estimate MSY than some have thought, leading to large uncertainties and b) attempts to capture the MAXIMUM of the (often overestimated) sustainable yield have contributed to the continued depletion of major Baltic stocks which was foreseeable. 2. Lack of adequate control and compliance appears to have undercut the effectiveness of the landing obligation in demersal fishing. Together with abuse of flexibilities under art. 15 this has also contributed to misreporting and uncertainties in estimating MSY in pelagic fishing. 3. The Baltic MAP has not achieved the two primary objectives of increasing and maintaining fish stocks above levels capable of producing MSY (art. 3.1) or minimizing the negative impact of fisheries on the marine environment (art. 3.3). 4. The capacity ceiling for the fleet is largely meaningless, as it does not take into account the incremental increase in actual capacity to catch fish (technological creep, estimated in the Green Paper from 2009 as 2-3% per year, i.e. at present about 40% compared to 2009). ITQ, by creating a protected oligopoly market and increasing capitalisation and profitability, may even have led to increased capacity to catch fish through substantial investments in more modern, effective vessels. The impact of the increase in vessel size and corresponding increase in spatial and temporal catch intensity on vulnerable stock components and the marine environment in general has not been taken into consideration. 5. Regionalisation has led to a slow-down in adoption of conservation as well as a decrease in transparency as negotiations on conservation measures and TACs de facto occur in Baltfish. Managers and stakeholders appear to treat ICES estimates of current F in a stock and target Fmsy as certainties instead of the highly uncertain forecasts that they are. Fishing quotas are then awarded to countries based on what, in retrospect, often turns out to be overestimates of yield. This has been particularly apparent in the Gulf of Bothnia, where fishers have not managed to fill their quotas for some years. Further, managers tend to ignore warnings from ICES about future impacts of e.g. low recruitment. Focus has instead been on short term profitability for fishers and processers. ICES forecasts for catches corresponding with MSY are measured in tonnes of biomass, with no consideration to the impacts on sub-populations or stock components (i.e. production units of a stock), on the age and size distribution (which can have consequences for the marine environment) or on the marine environment. If these impacts were taken into account fishing opportunities would normally have been lower. In the short run, due to the inherent uncertainties about stock development and environmental impacts, managers should base fishing opportunities on a lower level of the forecast MSY, for example at 50%. Further, the goal of restoring and maintaining stocks to robust levels should be made central in fisheries management. In the longer term, management should focus on what is needed for more healthy ecosystems and f
Read full responseStockholm University researchers urge expansion of EU Nitrates Directive
7 Mar 2024
Message — The university recommends expanding the current directive to include uniform nutrient budgeting and mandatory surplus limits. They advocate for reducing fertilizer levels below economic optimums and implementing targeted land management.123
Why — Stricter regulations would help achieve international environmental targets for the Baltic Sea.45
Impact — Intensive livestock farmers face reduced production and costs from mandatory animal limits.6
Response to Correction to the multiannual programmes for fisheries
30 Jan 2024
The Stockholm University Baltic Sea Centres comments below refer primarily to the proposal to amend the Baltic MAP. They are to a large extent also relevant for the other MAPs. Summary - The Commission proposal should be withdrawn. It is faulty in content and the process leading up to the proposal was deficient. - The Commission proposal would increase the level of risk permitted by the MAP. - The Commission justification for the weakening of the MAP is based on a misunderstanding of the science and of the structure of the MAP. - The MAP, as implemented, has major deficiencies. These should be urgently remedied. A PROPOSAL TO INCREASE RISK Deletion of Art. 4.6, with no compensating measures, removes a safeguard and increases the level of risk in management of Baltic fisheries. It allows the Council to decide on TACs with a high probability of SSB falling below Blim, as the October 2023 Council did when, disregarding Art. 4.6, it set a TACs for two herring stocks with a probability of SSB falling below Blim next year of over 20% - more than four times the risk level than the MAP currently allows. This is not compatible with the objective of stronger stocks in Art 3.1 in the MAP regulation and in Art. 2.2 in the CFP regulation. FAILURE TO MEET MAP OBJECTIVES Most of the fish stocks covered by the MAP in the Baltic have declined since its adoption, contrary to the objectives in the MAP and CFP. This is the reason why Art. 4.6 has come into focus. The development of fish stocks is dependent on a number of factors, both internal and external to management. To the extent that environmental factors contribute to the decline of fish stocks it is important that management, if possible, counteracts these rather than making it worse and applies a more precautionary rather than a riskier approach. Declining environmental conditions are reasons to reduce fishing pressure below present uncertain estimates of levels around MSY. Further, the environmental objective of the MAP (Art. 3.3) and the CFP (Art.2.3) appears to be completely ignored when implementing the MAP, underlining the risk-prone acceptance in management. The MAP, as implemented, has major deficiencies. These need to be urgently remedied. An opportunity to start is the report on the results and impact of the MAP required in July 2024 under Article 15 of the MAP. A MISUNDERSTANDING OF THE SCIENCE AND THE MAP The Commissions justification for its proposal is based on a misunderstanding of the science. The Commission has also confused the remedial measures to be taken under Article 5 to be substitutes to the provisions for setting fishing opportunities under Art. 4, instead of supplements. This is explained in more detail here: https://www.su.se/stockholm-university-baltic-sea-centre/news/analysis-weakening-the-management-of-baltic-fisheries-1.703587 FAULTY PROCESS We disagree with the COM conclusion in its proposal that no proper public consultation or impact analysis is necessary. This consultation itself is inconsistent with that contention. Further, the socio-economic arguments mentioned appear to only consider the immediate short-term (the following fishing year). The Commission has not assessed the medium- and long-term socio-economic consequences or the environmental consequences of this increased risk level. The process of preparing this proposal is difficult to reconcile with the Interinstitutional Agreement on better law-making. This is explained in more detail here: https://www.su.se/stockholm-university-baltic-sea-centre/news/analysis-forgetting-the-deal-1.706421 REVISING THE MAP Any revision of the MAP needs clearer definitions (so that e.g. herring caught in fish-meal fisheries is not classed as a by-catch) as well as substantially more precise and precautionary rules.
Read full responseStockholm University urges faster adoption of EU soil law
1 Nov 2023
Message — They call for passing the law before the 2024 elections to prevent delays. They also emphasize monitoring nutrient leakage and aligning soil rules with sewage sludge regulations.12
Why — Better data on soil health helps the university's researchers tackle Baltic Sea eutrophication.3
Impact — Industrial waste managers could face higher costs from stricter sewage sludge disposal requirements.4
Response to Sustainable fishing in the EU: state of play and orientations for 2024
30 Aug 2023
1. EU fisheries management should, for stocks with populations above or around MSYBtrigger, normally aim to set fishing opportunities at levels corresponding to half the estimated Fmsy instead of maximizing extraction. There are a number of reasons for this: - One of the leading scientists behind the MSY concept has argued that it is uneconomical to try to harvest as much as Fmsy and proposed fishing at a much lower level for that reason. - Assessments of fish stocks and MSY are uncertain. It is more damaging to overshoot than not, which is an argument for more prudent management targets. - Calculations of MSY do not take into consideration the impact of the fishing activity on sub-populations. This will tend to impact on the weaker sub-populations, eroding the genetic diversity and the reproductive potential of the fisheries, as well as impacting on local environments. - Calculations of MSY do not take into consideration the impact of fishing activity on the ecosystem, including descriptors of Good Environmental Status under the Marine Strategy Framework Directive such as food-webs, sea floor integrity or biodiversity. Too high extraction, i.e. at Fmsy levels, of forage fish at lower trophic levels may, for example, cause severe reductions in or even decimate higher trophic levels. - When environmental conditions are changing due to factors such as global heating, eutrophication and/or contamination, there is a risk that uncertainty in assessments will be even greater. That is reason to apply a bigger safety buffer. 2. A clarification is needed on the topic of by-catches and the concept of choke species. It is what is needed for rebuilding the depleted stocks that should be prioritized, not adapting quotas to unavoidable by-catches in other fisheries. Allowing business as usual for the stronger stocks and granting by-catch quotas based on such fishing levels will lead towards depletion instead of rebuilding the weaker stocks. 3. Two essential factors for an energy transition of the fishing fleet are rebuilding stocks (so less energy is expended to catch a given amount of fish) and getting rid of the fuel subsidy in the form of exemption from energy taxation or emissions trading costs. Both of these would have positive synergy effects for the marine environment. 4. Fisheries management should have a much stronger focus on restoring populations of harvested species to or above levels which can produce the maximum sustainable yield. The Commission should request better information from ICES on progress towards rebuilding stocks that are below such levels and on what is needed for better progress. 5. The Commission should request ICES to provide estimates of median level of Bmsy. This can make it clearer to managers that stocks need to be restored. At present, it appears that the de facto objective is to keep stocks at the lower level MSYBtrigger. Given natural fluctuations and assessment uncertainties this de facto objective gives an unacceptably high level of risk for the fish stocks, the marine environment and in the longer term the fisheries sector and coastal communities. 6. If rebuilding of stocks is unsuccessful and the risk of stock depletion is realized, safeguards in multiannual plans should be applied for stocks where there is a low probability of SSB>Blim, possibly with exemptions for small-scale fishers fishing for human consumption where such fishing accounts for a very small share of total catches. Warnings of stock decline from small-scale fishers should be taken more seriously. The EU should recall and apply the lesson of the successful closure of the North Sea herring fishery in the late 1970s-early 1980s. 7. There is no excuse for continued fishing for eels at any stage of the life-cycle.
Read full responseResponse to Energy transition of EU fisheries and aquaculture sector
1 Dec 2022
The Baltic Sea Centre submits the following comments: SUMMARY - Fuel subsidies in the form of tax exemptions or reductions are a barrier to implementation of better energy technologies and practices. - Important synergies between removal of fuel subsidies, the energy transition and a healthier marine environment should be exploited. - More robust fish stocks make for more efficient use of energy in fishing and thereby contribute to the energy transition. SUBSIDIES A key financial and governance barrier that hinders the uptake of technologies and practices necessary to reduce the climate impact of fisheries are the subsidies to fisheries, in particular the exemption from full carbon pricing via taxes or emission trading rights. This makes all other measures less efficient and less effective. Fuel subsidies reduce incentives to invest in more efficient engines or use less fuel-intensive practices. It is inefficient to try to solve problems caused by subsidies with more subsidies. The Commission has proposed a much lower tax for the fisheries sector than other sectors in the Energy Tax Directive. The consequence would be a continued massive subsidy to fishing. When a revised ETD requires unanimity, it may fall. Therefore, inclusion of fisheries in the emissions trading system should be prepared as an alternative. Purchases of fuel outside the EU by vessels with quota to fish in EU waters are in effect imports of fuel to the EU and should be taxed as such. There may be a risk that EU fishers who pay a full carbon price will be outcompeted in the European market by fishers from countries. If so, protection under the Carbon Border Adjustment Mechanism should be extended to the fishing sector. In a market economy, economic crises are a corrective to overcapacity such as has plagued fishing. By repeatedly responding to crises with subsidies, the EU sets an important market mechanism out of force. Short-term crisis measures must be combined with compensatory measures, or goal achievement will be delayed. Thus, the latest emergency support should have gone hand in hand with effective measures to reduce overcapacity. Fuel subsidies contribute to the overcapacity that the Commission has identified as a core contributor to problems of European fisheries, including poor profitability and lax compliance, depleted stocks and degraded marine environments. Subsidies such as fuel tax exemptions have been therefore been classified as harmful. (Skerritt, Sumaila 2021). Failure to account for the decreased natural carbon sequestration caused by fishing can is in effect also a subsidy. (Martin et al 2021). EFFICIENCY Efficiency in energy use is a key aspect of the energy transition. Methods such as bottom trawling tend to be less energy efficient than others. (Sala et al 2022) Larger fish stocks require less energy to catch a given amount of fish than do more depleted stocks. Therefore, an efficient energy transition requires that the EU achieves the objective of progressively restoring and maintaining populations of fish stocks above biomass levels capable of producing MSY as mandated by Article 2.2 of CFP Regulation. The EU should not achieve the objective by reinterpreting biomass levels capable of producing maximum sustainable yield as Btrigger or some other target significantly lower than Bmsy. If it is not possible to reliably estimate Bmsy a more suitable proxy such as 2 x Bpa should be used. (Froese et al 2016). Reducing fishing pressure to levels consistent with the environmental objectives of the CFP would further increase energy efficiency. The Commission should routinely request ICES to provide advice on the likely impact of such limitations on the catch as may be required to achieve environmental objectives such as biodiversity (including genetic diversity within the target stock), habitat integrity and foodwebs, under the Specific Grant Agreement between the European Union and ICES.
Read full responseStockholm University supports new EU chemical hazard classes
14 Oct 2022
Message — The university supports the new hazard classes but recommends refining criteria for persistence and bioaccumulation. They suggest using sediment-water mixtures and incorporating modern animal-free assessment methods.123
Why — Scientifically accurate criteria ensure regulators can effectively prioritize and restrict the most problematic chemicals.4
Response to Communication on the functioning of the Common Fisheries Policy
22 Sept 2022
A fundamental problem with the CFP as implemented in the Baltic Sea is the effort to fish at levels corresponding to a narrowly estimated maximum sustainable yield (Fmsy, our emphasis).
This approach was criticized already in the run-up to the reform, including by one of the leading scientists associated with the concept of MSY, Sidney Holt, who instead suggested that fishing at 50% of Fmsy would be far more profitable.
Calculations of Fmsy are based on modelling, assuming correct data, robust models and stable environmental conditions. It can be questioned if these apply in the Baltic Sea, which increases the inherent uncertainties in estimating Fmsy. Declining environmental conditions due to global warming, ocean acidification, eutrophication etc, can be expected to lead to an even greater tendency than otherwise to overestimate Fmsy.
It is more damaging to fish stocks, the marine environment, the fishing sector and fishing communities to fish above Fmsy than below Fmsy. This is another reason to aim below estimated maximum sustainable yield.
EU fisheries are in practice seldom based on the ecosystem-based approach to fisheries management or the precautionary principle, as these terms are defined in the CFP Basic regulation.
The Commission should take a step towards implementation of an ecosystem-based approach and better coherence with the Green Deal and EU environmental policy by requesting ICES to a) list relevant factors not adequately taken into consideration in the advice and b) for each factor, indicate if taking consideration would lead to higher or lower quotas than following ICES Fmsy advice as currently calculated. Such factors include:
- The impact of fishing on other associated commercially fished stock
- The impact of fishing on other associated species e.g. in the food web
- The impact of fishing on sea-floor integrity
- Impacts on sub-populations or stock components
- Impacts on the age and size structure of the stock
- If the condition of the stock seems to be improving or declining
- The consequences of the dominance of a relatively strong year class, and the impact of fishing it or leaving it in the water
- The general degree of uncertainty in the assessment, e.g. due to the quality of the data, to changing environmental factors or evidenced by Spawning Stock Biomass not increasing despite fishing at or below estimated Fmsy.
Failure to take these uncertainties and limitations into account, together with recurring questionable short-term socio-economic considerations, has led to serious negative socio-economic impacts in the medium (=longer than one year) term. This has been exacerbated by a failed fleet policy that does not take regional considerations or account of technological creep, and by massive subsidies in the form of exemptions from fuel taxes.
/Submitted on behalf of Stockholm University, Baltic Sea Centre by Charles Berkow, Policy Officer
Notes:
1. Michael Earle, Maximum sustainable yield in the EU’s Common Fisheries Policy - a political history, ICES Journal of Marine Science, Volume 78, Issue 6, September 2021, Pages 2173–2181, https://doi.org/10.1093/icesjms/fsab037
2. SLU svarar på frågor om sill/strömming https://www.slu.se/globalassets/ew/org/inst/aqua/externwebb/radgivning/faq-sillstromming/faq-sill-stromming-pdf-v2021-06-01-komplettering-2022-03-15.pdf
3. Baltic Sea Centre, Policy Brief, Adapt herring fisheries to scientific uncertainty https://www.su.se/polopoly_fs/1.580543.1635509572!/menu/standard/file/PBsillosakerEngWEBB.pdf
Read full responseResponse to Sustainable fishing in the EU: state of play and orientations for 2023
24 Aug 2022
• A key cause of the disastrous development of fishing stocks in the Baltic Sea is A key problem is an over-emphasis on trying to achieve a narrowly defined Maximum Sustainable Yield for single stocks, with little or no consideration of its environmental limitations or interrelationships. Important information is not considered, or not included, or not highlighted in the scientific advice used as the basis for decision-making.
• ICES advice would be more helpful for managers and contribute better to healthy fish stocks for the benefit of both the environment, the fishing sector and coastal communities if it would answer questions like:
o What factors, that could be relevant for managers has ICES not taken into account when preparing its advice?
o For each factor, would consideration of this factor would further uncertainty be acknowledged, pointing to the necessity of keeping TAC substantially below what can be estimated from current MSY procedures?
The Commission should consider requesting ICES to provide this information in a clear and transparent manner in the advice sheets, highlighting the factors contributing to the uncertainty related to a specific advice.
• Measures of fleet capacity need to be updated to reflect the effects of “technological creep” and the Commission should more actively use the tools at its disposal to reduce overcapacity. Regional considerations should be included in the estimation of fleet capacity, ensuring a viable basis for regional fisheries.
• Exemptions from fuel taxes are a particularly harmful subsidy that contributes to overcapacity and excess fishing pressure, damages the marine environment and increase climate-heating emissions. The fishing sector should pay the same price for climate emissions as other sectors.
Read full responseStockholm University calls for ecological efficiency in nutrient plan
25 Apr 2022
Message — The university advocates for ecological efficiency to be the central goal of nutrient management. They recommend replacing chemical fertilizers with manure and limiting livestock numbers in intensive areas.123
Why — These measures would protect the Baltic Sea ecosystem, fulfilling the centre's core environmental mission.4
Response to Environmental Implementation Review 2022
18 Oct 2021
In general greater coherence between the environmental legislation and sector oriented legal frameworks is required, for instance regarding the CAP and CFP – policy areas where the EU Commission is highly involved and has greater powers than many environmental areas.
It would also be of general concern to make sure that the EU Commission has enough resources to monitor member state implementations and if necessary start infringement cases.
The Commission correctly notes the failure of the CFP to contribute to achievement of the objectives of the Marine Strategy Framework Directive from 2008. It is significant that 13 years after adoption of the MSFD and one year after the target year of 2020 has passed, there are still not threshold values for descriptors such as sea-floor integrity or reference values for criteria such as age and size distribution. This appears due in part to a genuine scientific uncertainty, but also largely to a lack of political will to supply the resources that would be needed. Indeed, it might even be the case that there are perceived to be incentives, from the short-term perspective of parts of the fishing sector, to NOT realize such reference points and threshold values as these, were they incorporated into fisheries management decisions, might lead to lower quotas in the short term.
Therefore, it is not enough as the Commission proposes that together with scientists “the Commission will further speed up work on the ecosystem effects of fishing, to feed those factors into fisheries management.”
Further, ICES writes “[l]imitations on fisheries may be required in order to achieve environmental objectives, especially regarding biodiversity, habitat integrity, and foodwebs. This will not affect the catch that can be taken from a stock in accordance with the objectives of MSY and the precautionary approach, and will therefore not affect ICES advice on fishing possibilities. The limitations may, however, affect the fisheries’ opportunities to fully utilize the advised fishing possibilities. ICES may, if requested, advise on the likely impact of such limitations on the catch but will, as explained, not include such considerations in the advice on fishing opportunities.”[1]
The Commission should therefore consistently request ICES to advise on the likely impact of such limitations on the catch so that the Commission can take those impacts into account in making its proposals for TACs and other regulations. As an alternative, or if ICES is unable to supply the requested advice, the Commission should propose an “ecological share” of, say, 20% as a proxy for reduced impacts of fisheries on the ecosystem aspects reflected in the descriptors in the MSFD. This would be a material step in contributing to fulfilment of the objective in article 3.3 of the MAP and the intentions of the EU Biodiversity Strategy.
Read full responseResponse to Policy Statement 2022
20 Aug 2021
SUMMARY
1. Management has not been successful in the Baltic.
2. To take account of uncertainty in the scientific assessments, the Commission should propose TACs in line with F-lower for stocks assessed as being in good shape; for others, TACs should by 50% of Fmsy.
3. Until further information is available, the Commission should propose an “ecological share” of 20% of the TAC as a proxy for reduced impacts of fisheries on the ecosystem.
4. Efforts to improve selectivity should be focused on species selectivity, not size selectivity.
5. The Commission should propose measures to restrict the indiscriminate fishing of large industrial trawlers in the Baltic as a step towards giving greater consideration to the issue of sub-populations in management. The Commission should conduct a survey of how Member States in the Baltic are using the opportunities provided by Article 17 in the CFP to incentivise more sustainable fishing.
6. The Commission should request that STECF develop a pilot programme for the Baltic with a method of identifying overcapacity and capacity reduction options that does not favour large industrial trawlers at the expense of small-scale, coastal fishers.
EXPLANATORY NOTES
1. Seven years into the reform from 2014 and five years after the adoption of the Baltic multiannual plan (MAP) we feel it is time to draw more substantial conclusion than the Commission does in its Communication. The background is the serious situation of some of the historically most important stocks in the Baltic. This year, ICES:
- Notes that the SSB for Central Baltic herring appears to have dropped below Btrigger and recommends a decrease of the TAC of 36% or more. This is on top of the reductions in the past years: 36% for 2021, 10% for 2020 and 26% for 2019.
- Recommends a 0 TAC for the western Baltic spring spawning herring for the fourth year in a row
- Recommends a 0 TAC for the eastern Baltic cod for the third year in a row
- Was unable to present a recommendation for the western Baltic cod.
Clearly, management has not been successful in the Baltic.
2. One reason for the failure of management for a number of key species is the uncertainty in the scientific advice and the failure of managers to draw the consequences of this uncertainty in their decisions. A review of the ICES advice for the Central Baltic herring shows that the stock and its potential yield have often been overestimated. Thus, management decisions that at the time were believed to have been in line with scientific advice have, in retrospect, been shown to be too high.
The consequences for the fish stocks, the fishery and the environment of TACs that are too high are much more serious than if the TACs are set below the estimated Fmsy. Therefore, a reasonable conclusion of the consequences of the scientific uncertainty is that TACs should consistently be set substantially below estimated Fmsy. For stocks assessed as being in good shape we recommend F lower as allowed for in Article 4.2 in the MAP. For other stocks we propose 50% of Fmsy as allowed for in Article 4.3 of the MAP.
For further explanation and details, see our Policy Brief: Adapt herring fisheries to scientific uncertainty https://balticeye.org/en/policy-briefs/adapt-herring-fisheries-to-scientific-uncertainty/
More detailed explanations for points 3-6 are contained in the attached file.
Read full responseResponse to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals
31 May 2021
We welcome a careful and limited revision of the EU legislation on registration, evaluation, authorisation and restriction of chemicals, REACH, to better protect humans and the environment against hazardous chemicals and promote a sustainable use of chemicals. It is key, however, that a revision does not lead to a weakened chemicals regulation, in any aspect. A targeted opening of the REACH legislation is therefore needed.
Section Problem the initiative aims to tackle:
In general, we agree with the identification of the problems described in the roadmap, which the initiative aims to tackle. However, under the point ‘The evaluation of registration dossiers and substances is too complex and insufficient.’ we find the phrasing ’too complex’ somewhat worrying. It is very important that rationalisations and simplifications of the registration process, incl. the compliance check and substance evaluation, does not lead to a deterioration in the quality of the registration dossiers, or their control, as their completeness and accuracy is a fundament for the risk assessment.
Section Objectives and policy options:
Under this section we have identified complementary measures that should be included to improve risk assessment of chemicals:
• Increasing the transparency of data: Full transparency should be the general rule for the whole chain of events from generation of information, via reporting of data, to hazard and risk assessment. The current developments in the food law are very welcome and should be expanded to all chemicals.
In a system where manufacturers are responsible for assessing their own products sufficient resources to control the quality of this work must be secured. The overall aim must be full legal compliance.
• Making use of academic studies: change the requirements to also include academic studies, if available, in hazard and risk assessment, as a complement to the toxicity studies commissioned by the chemical industry. Increasing the use of academic studies is also expressed in the Chemicals Strategy for Sustainability.
Under ‘Reforming the authorisation process’ supplement the current wording with text within quotation marks:
• Reforming the authorisation process: Options include clarifications and simplifications of the current provisions, national authorisation for smaller applications, removing the authorisation title from REACH, integrating the REACH authorisation and restriction systems into one and improving the interface with other pieces of legislation (complementing actions under the one-substance one-assessment action under the Chemicals Strategy), 'and the concept of essential use should be aligned with the authorisation process'.
We strongly support the ambition in the Chemicals Strategy for Sustainability to ’introduce endocrine disruptors, persistent, mobile and toxic and very persistent and very mobile substances as categories of substances of very high concern’ within REACH restriction processes.
For relevant research and findings that support our ideas, please see the links below:
For more information about the need for grouping and mixture risk assessment in European chemicals legislation, please read here: https://balticeye.org/en/policy-briefs/time-for-smarter-and-safer-chemical-management/ and here: https://www.government.se/legal-documents/2019/11/sou-201945/
For more information about the need for increased transparency in REACH, please read here: https://balticeye.org/en/pollutants/policy-brief-european-chemicals-regulation-needs-more-transparency/
Read full responseResponse to Revision of EU legislation on hazard classification, labelling and packaging of chemicals
31 May 2021
We strongly support the ambition in the Chemicals Strategy for Sustainability to "propose new hazard classes and criteria in the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation", by inclusion of PMT and vPvM as new hazard classes.
Read full responseResponse to Action plan to conserve fisheries resources and protect marine ecosystems
12 May 2021
• The EU needs to actually implement ecosystem-based fisheries management including requesting ICES to integrate ecosystem considerations into its fisheries advice, a survey of herring sub-populations in the Baltic, special considerations for prey fish and banning industrial trawling and bottom trawling inside the 12 nautical mile zone.
• The EU should apply a precautionary buffer as a proxy until threshold values have been established under the MSFD.
• Greater transparency is needed to improve governance in the regional fisheries cooperation bodies.
• Fuel subsidies should be phased out.
• Reporting needs to be comprehensive and clear, open and honest.
• Commercial fishing of the European eel should be stopped.
Read full responseResponse to Protecting the environment in the EU’s seas and oceans
5 May 2021
Stockholm University Baltic Sea Centre comments on EU Commission combined evaluation roadmap/inception impact assessment of the MSFD
Summary of BSC comments on roadmap/inception impact assessment of the MSFD. For more information, see enclosed file.
The marine ecosystems are not in good environmental status so a stronger directive is necessary. The BSC has yet not a final view on the best future policy option.
A fundamental problem is that measures need to be taken in other policy areas in order to achieve the goals of the MSFD. In particular the fisheries policy area has failed to deliver despite the explicit connection to the MSFD in the reformed CFP.
In the absence of agreed threshold values for descriptors and criteria a precautionary principle should be applied for sectors such as fisheries whose impacts can delay achievement of good environmental status.
MPAs are an important tool but have no or too weak restrictions on permitted activities.
Areas free of human disturbance are essential reference tools for research.
The cumulative impacts of multiple stress factors on ecosystems and/or species must be taken into regard in marine spatial planning and in management plans for protected areas.
Monitoring should be better designed to enable evaluation of effectiveness of specific measures and temporal trends in emissions of hazardous substances and environmental levels.
In the revision of the Urban Wastewater Treatment Directive, UWWTD, criteria need to be developed for minimum chemical wastewater quality that address micropollutants and their mixtures and a clear connection must be established to the Marine Strategy Framework Directive.
The connection between the CAP and the MSFD should inprove.
Read full responseResponse to Towards a strong and sustainable EU Algae sector
12 Jan 2021
Stockholms universitets Östersjöcentrum anser att man i diskussioner om algodling måste beakta följande:
• I Östersjön innanför Öresund och de danska sunden, är förutsättningen för algodling tyvärr betydligt sämre än i många andra europeiska havsområden p g a den låga salthalten. På längre sikt kan det kanske bli aktuellt med algproduktion även i Östersjön om forskning och utveckling hittar metoder för lämpliga arter som går att använda, beroende på syftet med odlingen (biogas/foder/proteinutvinning). Det som finns idag i/nära Östersjön i större skala är i stor utsträckning odlingar på land, t ex i Simrishamn.
• Följaktligen är möjligheterna för den närmaste tiden till lönsam storskalig algodling i Östersjön mycket små. Omfattande forskning och utvecklingsarbete krävs för att produktionen ska bli något som fungerar och är ekonomiskt lönsam. Några av utmaningarna rör begränsande miljöfaktorer och platsbrist i många områden.
• Vid all planering och utvecklingsarbete av algodling, även i områden med goda förutsättningar, är det viktigt att beakta möjliga konflikter med annat användande av havet. Tillståndsprocessen för att bedriva vattenbruk i Sverige idag behöver ses över för att ge en rättvisare prövning av bland annat algodlingar.
Read full responseResponse to 8th Environment Action Programme
18 Dec 2020
The Stockholm University Baltic Sea Centre’s comments to the Environmental Action Programme to 2030 (COM(2020) 652 final
1. An action programme covering such a broad area needs clear, coherent and mutually supporting policies. Although it contains a lot of positive elements, it is doubtful if the proposal meets these criteria.
2. While it is positive that the proposal takes a step in the direction of better implementation by the roles, and resources, envisioned for the EEA and ECHA, a much stronger emphasis on implementation is needed. A comparison with e.g. points 22, 31 and 32 in the Presidency’s conclusions from the EU Summit in Göteborg 2001 shows that the EU have not made significant progress in the nearly 20 years since then. Reformulating worthy goals is not enough.
3. It is positive that the proposal includes regular reporting on progress. To be useful, such reporting must be much more open, transparent and honest than much of the reporting on already existing commitments.
4. We welcome the initiative under the Chemicals Strategy to work to increase accessibility to data by streamlining methodologies and interoperability between legislations and structures. Pooling data together in a systemic way will be crucial to reach goals in EAP, Green Deal etc, which also strengthen transparency principles.
5.The proposal rightly acknowledges the important role of environmental monitoring. We stress the importance of long-time data series. Such series have proven useful in discovering slow changes in the environment and tracking drivers, and being essential for evaluating actions both regarding costs and effects.
6. An analysis of the lack of progress towards reaching the goal of Good Environmental Status for marine areas by 2020 under the MSFD shows that in addition to data, lack of analysis has been a bottleneck, e.g. in determining target threshold values. One lesson from this is the need for adequate data and analyses. Another is the need for rules of thumb for measures to be taken while waiting for necessary data and analyses. If we know in what direction we need to move and that we are already short of time, it is hardly cost effective to delay measures while waiting for data and analyses to determine how far we have to move. The longer we continue with business as usual, the more costly the efforts to rectify the problems.
7. We question the value of attempting to focus on a small number of overarching indicators for assessing the general condition of the environment.
8. While we applaud the aim of living a good life within the planetary boundaries, this needs to be made more operational in order to impact on actual policies.
9. The ambitions for seabed mining in the Blue Growth strategy show the need for developing assessments of planetary boundaries for the marine environment and for extraction and use of non-renewable resources.
10. We note that water and seas are mentioned but would like to underline the importance of water and the marine environment for both ecosystems and for the provision of their essential services.
11. Environmental considerations must be systematically integrated in other policy areas. Too little progress has been made since this was proposed in point 32 in the Presidency conclusions from 2001. The EAP is therefore a concern for policy areas such as agriculture, energy, transportation, growth, trade, and fisheries.
12. The role of trade agreements in the ambition from the Göteborg summit to “Getting prices right” (point 22) should be included in the ongoing revision of the EU trade policy.
13.Welcoming the extra resources for ECHA and the EEA, we point to the need for more resources for the disbursement and management of funds. Management of new funds in the Recovery and Resilience Facility need extra resources. Conditionality needs to be more robust than it has been in eg the EMFF. The Commission should to give more emphasis to its role as Guardian of the Treaty instead of Maker of Deal.
Read full responseResponse to Evaluation of the Sewage Sludge Directive 86/278/EEC
19 Aug 2020
The Stockholm University Baltic Sea Center thinks that the present directive has little relevance for environmental protection and circular economy since it is too weak. A new directive must focus not only on preventing harmful effects on soil, vegetation, animals and man, but also on preventing harmful effects on drinking water, freshwater and the marine environment, by leakage of nutrient, pollutants, pharmaceuticals or microplastics from application of sludge.
A new directive should not consider the spread of sludge as the only solution, but should also be open to new techniques that can extract nitrogen and phosphorus while limit the spread of hazardous substances (e.g. heavy metals and persistent organic pollutants), pharmaceuticals and microplastics.
Phosphorus is a finite resource; efficient usage and recycling are essential. The EU Circular Economy Action Plan has generated interest in recycling phosphorus contained in human sewage in agriculture. This effort is an important step in closing the phosphorus cycle. However, there is greater potential to improve the efficiency of manure used as crop fertiliser. In the Baltic Sea catchment, the amount of phosphorus in manure is more than 3 times greater than in human sewage. By using manure more efficiently, mineral fertiliser imports could be reduced by 0,11 - 0,17 million tons, compared to about 0,036 million tons by using sewage sludge. This would reduce phosphorus surpluses and the risk of leakage to inland waters and the Baltic Sea.
Untreated sludge should never be allowed to be spread on agricultural land, not even if it is injected or incorporated into the soil.
We find it problematic that only handful of heavy metals have limit values in the present SSD, it is probably not enough to protect human health and the environment. The EU should further investigate which substances that should be included in the SSD, and which concentrations that should be the limit values for these, or whether the focus should be on effects or other "broad" parameters that can be used to assess the risks of sludge. The SSD should also be ready to respond to and act on newly discovered hazardous substances, instead of relying on a pre-determined list of substances.
Plant availability of P in sludge must be taken into consideration when calculating allowable maximal loads.
We support “it is important that what is used as a resource is not contaminated, otherwise recycling will result in increasing pollution of soil, water and/or air.”
Read full responseResponse to A New Consumer Agenda
2 Jul 2020
Today, information on the chemical composition of articles is very scarce, making it difficult to understand which potentially hazardous chemicals are being released to the environment. The lack of chemical ingredient lists also hinders the assessment of human indoor exposure and forms a barrier to implementing a circular economy with non-toxic material cycles.
There is an urgent need for standardised methods and legal incentives to increase the availability of information on chemicals in articles for authorities, researchers, and consumers.
Please see our attached policy brief for recommendations.
Read full responseResponse to Chemicals strategy for sustainability
17 Jun 2020
Stockholm University Baltic Sea Centre welcomes the initiative to increase the level of protection of the environment from hazardous chemicals and believes that this needs to be the guiding principle before, not on par, with promoting innovation. The costs from loss of health and biodiversity may prove to be very high. Clear protection goals are therefore needed to make this the overarching rule.
We further strongly agree with the statement that the regulatory framework on chemicals needs to be strengthened. Two aspects of this are crucial for overcoming the gaps, overlaps and inconsistencies stated by the European Commission, namely to manage chemicals in groups and introduce mixture risk assessments into all chemicals legislation.
Science no longer deems the single substance assessment approach to be sufficient to assess and control the risks associated with the chemical exposure of the modern world. The risk associated with a chemical mixture exceeds the risk of each individual chemical in the mixture. This needs to be reflected in European chemical legislation.
-> Establish consistent requirements for mixture risk assessments in all pieces of chemical legislation. Without such requirements, effective protection against risks from exposure to mixtures will not occur.
Today there are inconsistencies between the different regulatory frameworks covering chemicals, with only little exchange of information between them and no overarching or systematic attempts to harmonise across. Consequently, the risk assessment of chemicals is largely carried out in regulatory silos – dictated by how and in which sector the individual chemicals are used, rather than by their exposure patterns and interactions with other chemicals in real-life scenarios. In order to move towards “one substance – one assessment”:
-> Establish a crosscutting European policy framework for dealing with mixtures of chemicals falling under different legislation. Chemical mixtures cannot be fully evaluated and managed by sectorial pieces of legislation.
Managing chemicals in groups has been identified as a key approach for making regulatory risk assessment and management less fragmented and more transparent. Organising chemicals with similar molecular structure, hazard, risk, or function into well-defined groups helps to reduce the complexity of chemical risk assessment and management.
-> Strengthen the mandate in REACH to manage groups of chemicals to avoid regrettable substitution. Grouping will also contribute to increase efficiency and to reduce mixture risks.
For achieving and maintaining good chemical status of water bodies under the Water Framework Directive, the current focus on a limited number of priority chemical substances is insufficient to deal with the present situation, where hundreds of different organic chemicals can be found in water samples. With no obligation to perform mixture risk assessments – combined with the fact that there is no clear mandate in the directive to group substances when developing quality standards – there is room for improvement.
-> Improve mixture risk assessment and grouping of substances in the context of European water management. The directive is recipient-oriented and in principle should be able identify and undertake measures against chemical pollution created by chemical mixtures.
To read our policy brief "Time for smarter and safer chemical management" please visit: https://balticeye.org/en/policy-briefs/time-for-smarter-and-safer-chemical-management/
Read full responseResponse to Farm to Fork Strategy
13 Mar 2020
Stockholm University Baltic Sea Centre welcomes the initiative and agrees that the transition to more sustainable food systems need to accelerate.
Given an increasing population, increasing incomes and the resulting increases in environmental pressures, we need an accelerating eco-efficiency in our production and consumption of food. Eco-efficiency should be the overarching objective of the strategy.
Agriculture
An aspect of eco-efficiency is the necessity to improve the eco-efficiency of our nutrient cycles, as concluded in the UNEP report Our Nutrient World.
Agriculture is the single largest source of new nutrients to the Baltic Sea. Most of mineral fertiliser and livestock feed which is imported to the catchment area is transformed into manure; however, the nutrients in manure are often not used efficiently in crop production, increasing the risk of losses to the waters. These nutrient losses can be reduced by improving manure management and substituting imported mineral fertilisers with manure, as well as by reducing the import of livestock feed and the number of animals in regions with high livestock. Read more at balticeye.org/english
Whether or not reduced consumption of animal products leads to less eutrophication of waters depends on which animal products, how and where they are produced and the alternative production/action at farm level. For a full fact sheet read here.
Marine biodiversity
F2F must link strongly to the Biodiversity Strategy and both clearly and consistently include the marine dimension.
Healthy marine habitats are a precondition for long-term sustainability of fisheries – and thus sustainable primary production of seafood. At the same time, fisheries can impact on marine biodiversity beyond direct effects on commercially fished stocks. The F2F strategy should ensure that decisions taken under the CFP actively contribute to the realisation of ecosystem-based fisheries management and the achievement of the objectives of the Nature Directives and the MSFD.
Fisheries
Current inefficiencies in nutrient management contribute to the oxygen depletion that is one cause of the negative situation for the Baltic cod.
Given uncertainties in data and modelling and changing conditions in nature, short term attempts to maximize sustainable yield (fish at MSY) risk continuing to lead to overshoot and long-term depleted fish stocks. Fishing pressure needs to be kept considerably below FMSY.
Aquaculture can only be sustainable if due consideration is given to factors such as the available sustainably produced resource base, local impacts of nutrient emissions and the use of antibiotics.
Research suggests that fish has a lower environmental and climate impact if it goes to direct human consumption instead of aquaculture via fishmeal. Fishing for human consumption should be promotes rather than fishing for fishmeal.
Hazardous substances
Pesticides are commonly found in levels exceeding thresholds set for single compounds in some marine waters. Overall, marine organisms are exposed to a mixture of chemicals that accumulate and transfer through the marine food chain resulting in higher levels in top predators. And there is growing concern that declines in wildlife populations and loss of species are linked to chemicals interfering with the endocrine system.
Reduced emissions of hazardous substances is necessary for sustainable consumption of seafood since residues may contaminate fish and make it unsuitable for direct human consumption.
A study from Stockholm University shows that 87% of all measurements of chemicals in fish target just 20% of all monitored substances. These chemical analyses may be biased towards known past problems. This may lead to society failing in identifying risks posed by yet unknown hazardous chemicals. Strong links need to be made between the F2F and the Chemical Strategy, incentivising ways to identify priority chemicals for environmental analysis
Read full responseResponse to A new Circular Economy Action Plan
16 Jan 2020
Stockholm University Baltic Sea Centre agrees with the basis for an EU intervention. Ensuring policy coherence, certainty and harmonisation of rules in the field of product, consumer and chemicals legislation need to take place at European level.
The roadmap states that “insufficient information regarding the presence or not of substances of concern in products and waste often hampers their recycling and uptake”, and we will focus our comments on this aspect.
Information on the chemical composition of articles is scarce, making it difficult to understand which chemicals that may be released from products to the environment. There is an urgent need for legal incentives to increase the availability of information on chemicals in articles for authorities, researchers, and consumers. Here is why and how:
• Many substances that are banned or identified as being SVHCs, continue to circulate in society via recycled materials. Currently the likelihood of identified hazardous substances occurring in recycled materials is high. Yet it is not often known in which products these chemicals have originally been used. Providing information on chemical content to waste handling companies would make it possible to exclude materials or articles that contain hazardous substances from the recycling stream. This however requires that the chemical content of the materials and finished articles is known in the first place, and that this information is retained throughout the full product life cycle. Legislation to ensure this information transfer and conservation is currently lacking.
• If manufacturers and retailers themselves had complete information on chemical content, they would be better prepared for new chemical regulations and it would help them to proactively phase out substances from their supply chains that are likely to be listed as new SVHCs.
• Voluntary actions to phase out substances that are not yet regulated at the EU level require knowledge about the presence of all chemicals in articles, i.e. not just those currently regulated. REACH Article 33 only gives downstream users and consumers right to information regarding SVHCs. Thus, companies and consumers that want to avoid other potentially hazardous chemicals have no possibility to do so.
• Only a minor fraction of all chemicals on the European market has been thoroughly risk assessed. Where and how chemicals are emitted are important pieces of information needed to identify which chemicals to prioritise in risk assessments and to develop cost-efficient measures to reduce emissions of already identified hazardous substances. The list of substances to monitor needs constant updates to include all substances that contribute significantly to any negative impact arising from the current chemical contamination of the environment.
Our policy recommendations:
• Continue the development of harmonised tools across sectors to track chemical composition of products throughout the supply chain, including imported and recycled articles.
• Establish a system to disclose chemical content in articles to authorities, researchers, and the general public in order to help identification of new environmental contaminants and to fulfil the consumers’ right-to-know.
• Introduce labelling of articles containing substances that are identified by the EU as being SVHCs in order to enable consumers to make informed choices.
• Legally oblige suppliers and companies to grant authorities responsible for the management of chemicals (e.g. ECHA) full access to chemical composition data of articles which, in the long run, will assist the circular economy and reduce emissions of hazardous chemicals to the environment.
Read full responseResponse to EU 2030 Biodiversity Strategy
16 Jan 2020
The Baltic Sea Centre at Stockholm University welcomes the biodiversity strategy to 2030 and look forward to the EU being the global leader with its commitments at the CBD in October. Our comments below are categorised as per the bullet points under section B.
Protect nature: Increasing the coverage of protected areas is positive but solely if the level of protection is adequate and fulfils its purpose. Management requirements must be strongly incentivised and monitored as per full implementation of the Nature Directives and Marine Directive.
The quality of protection is key, relating for instance to what kind of human activities are allowed in the protected area. Today, activities like commercial fishing, dredging, construction and boat traffic occur in large proportions in Natura2000 areas.
The same goes for connectivity, ensuring that the network of protected areas is functional for the species and habitats it aims to preserve. Protection should not only be geographically defined but also have temporal dimensions, e.g. taking spawning areas and times for fish into consideration.
Restore damaged ecosystems: With the Commission’s proposal for at least 30% of the EMFF contributing to climate action, it is advisable to expand the coverage under article 22 to include protection and restoration underwater vegetation. Not only does underwater vegetation function as nursery grounds for fish and as such are important for ocean productivity; meadows of eelgrass, for instance, can store large amounts of carbon dioxide and thus act like natural carbon sinks.
Promote sustainable use: Healthy underwater habitats are a precondition for long-term sustainability of fisheries. But fisheries and the marine environment are managed more or less separately and often with different goals. The strategy should therefore envisage and incentivise tools ensuring that by the end of 10 year period, decisions taken under the realm of CFP are actively fulling targets of ecosystem-based fisheries management and are beneficial to fulfilling commitments under the Nature Directives and the Marine Directive.
Integrate biodiversity considerations: The sea is the stage for a growing range of new ocean-related economic activities. It is therefore crucial to ensure that these Blue Economy activities are species and habitat friendly from the start. Biodiversity considerations should permeate EU policies to the same extent as with similar climate ambitions.
Enable the implementation: Compared to terrestrial areas in the EU, the sea is still vastly unknown. To be able to make informed decision, better mapping and knowledge of the marine ecosystem as well as the distribution of species, habitats and areas of biological significance is crucial.
Read full responseResponse to Evaluation of the Eel Regulation
9 May 2018
We appreciate the initiative of the Commission to assess existing EMPs on a national level; we think it is a necessary step to ensure recovery of the European eel. The eel stock is in crisis due to many causes, which have led to a severe decline in recruitment. Because continuous reductions in recruitment will give rise to even lower amounts of adult eels in future generations, we now need to increase the escapement of adult eels from all kinds of habitats. Otherwise, the species is seriously threatened as the next generation of recruitment will be even lower.
The national EMP, formulated at the request of the European Commission, should thus ensure the fulfilment of the aims declared at the political level. Too many times are the management objectives confounded by the conflict between conserving the species and the fishery, so the prioritisation is unclear. Therefore, we suggest that:
• Due to the acute status of the European eel, we should prioritise actions that intend to increase the present escapement.
• Management efforts focus on achieving the conservation objective rather than mitigating the negative consequences of the fishery.
• The basic assumptions and estimates are uncertain. Uncertainties should not give room to continue the fishery.
It is essential that the external evaluation process of ICES advice as well as of MS’ reports is achieved independently and competently. Which is then important to keep in mind when identifying the ideal consultancy to carry out this work.
There is further a lack of judicial instruments to enforce measures that could protect the eel from becoming virtually extinct. As eel management includes other areas than managing fisheries, a strong push towards policy coherence is needed both at national level and EU level.
It is vital that the practice of restocking with glass eels and elvers (i.e. translocation of wild fish) as a conservation measurement is scrutinised. The protective value of restocking eels from glass eel rich areas around the Bay of Biscay to other parts of Europe still has to be evidenced. The number of eels that will eventually take part in the spawning is unknown, and this type of action should be less prioritised. The practice of stocking young eels above hydro-electric power plants should be banned as turbine mortality is high. Long-term actions should instead focus on habitat restoration, for instance, by removing obstacles in rivers.
Read full responseResponse to Reducing marine litter: action on single use plastics and fishing gear
12 Jan 2018
We welcome the initiative to tackle these macroplastic sources. Given the recent UNEA resolution on marine litter and microplastics, the EU has both the opportunity and the responsibility to implement effective source-to-sea reduction measures.
In doing so, there needs to be a link made to microplastics as both single use plastics and fishing gear may fragment into microplastics or even nanoplastics, which can be taken up by aquatic organisms and cause harm.
Additionally, if the aim is to get to grips with marine litter, then two missing aspects in the inception impact assessment are littering and illegal dumping of waste from ships as well as wear and tear from floating devices, e.g. buoys and docks of expanded polystyrene.
We further believe that efforts regarding fishing gear should include not only nets, but also other types of plastic litter generated from the fisheries sector, such as plastic boxes, ropes and dolly ropes.
The basis for an EU intervention in this area is clear, and building on the experience of e.g. the implementation of the plastic bag directive, there is scope to introduce similar measures tackling other single use plastics (SUPs). For instance, deposit return schemes for bottles have proven successful in both new and old Member States.
But as a 100 percent capture rate can never be guaranteed, the first hand choice should be to replace SUPs. With any new material proposed, whether bioplastics or other, a thorough analysis including life-cycle assessments, which take the risk of littering and material degradation into consideration, needs to be carried out.
In this context, standards for an acceptable degradation, including degradation time, need to be established for all new materials. These standards need to take environmentally relevant conditions into account, which means to include both fresh, brackish and saline water, with and without UV exposure, and in different temperatures, including cold water.
Oxoplastics or other types of plastics that are designed to fragment, but which do not degrade, should be banned.
The first hand choice for fishing gear, as with SUPs, should be to develop more environmentally appropriate materials. Further, experiences from local and national Fishing for Litter initiatives, where the fisheries industry take on the responsibility for bringing marine litter back to ports, can be built on at EU level. In order for such an upscaling to be successful, port reception facilities need to be made more accessible, something that can be facilitated by designated EU level funding opportunities.
A deposit refund scheme should also be explored for the fisheries sector and could be introduced for nets and equipment that risk being lost or discarded at sea. This would also help in raising recycling rates. Additionally, vessels could be mandated to report the loss of gear, and a ban should be considered for materials that are designed to break apart during their use in the industry.
Finally, in order to evaluate if the measures stemming from this impact assessment actually will contribute to a significant reduction of the environmental damage in the future, the EU needs to address the lack of common definitions, harmonized standards and methodologies for measurement and monitoring of marine litter.
Read full responseResponse to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)
27 Oct 2017
In our reply the Stockholm University Baltic Sea Centre focuses on the relevance criteria.
Our primary message is that the UWWTD needs to be part of the solution to fulfil and reach the targets under both the current and future WFD, its daughters, and MSFD. For this to happen the directive needs to be revised to include removal of hazardous substances in addition to the currently regulated removal of nitrogen, phosphorous and organic matter in UWWTPs.
In an SDG and circular economy context, the directive is highly relevant. If well-structured, it can be part of ensuring that the flow between wastewater and drinking water is contaminant free, that the reuse of water for irrigation and sludge for fertilisation does not pollute fields and crops and that the release of microplastic particles and fibres to the environment is minimised.
The focus of abatement of legacy pollutants such as PCBs and dioxins have traditionally been focussed on industrial point sources, but in recent decades it has become evident that households, workplaces, official institutions and urban areas comprise a significant source of many chemical contaminants occurring in the aquatic system. More than 1000 chemicals that are rarely monitored, but known or suspected to cause adverse ecological effects, have been identified in European waters. Almost half of the European freshwater bodies have been identified as likely threatened by chronic long-term effects on sensitive aquatic organisms. Many synthetic chemicals or naturally occurring substances emitted as a result of human activities reach the waterways via UWWTPs. The quality of treated wastewater should therefore also be defined in terms of hazardous substances.
Chemical legislation and upstream measures to reduce the chemical load must remain key. But in particular pharmaceuticals are difficult to regulate based on environmental risks as they have invaluable benefits for humans. They are also often poorly removed as many are by design highly water-soluble compounds that are resistant to biodegradation. This problem is foreseen to increase as with an ageing European population, ever more pharmaceuticals will be consumed.
In a review of the UWWTD, the possibilities to demand more stringent treatment of wastewater to remove substances of environmental concern should be assessed, in particular for UWWTPs that serve large agglomerations. The largest UWWTPs collect the majority of generated wastewater, and are therefore important collection points for many chemical flows. To give an example, out of the 615 WWTPs within 20 km from the Baltic Sea coast, ca 45 plants receive wastewater from more than 100 000 p.e. and together treat wastewater from almost 70% of the coastal population. Upgrading these large WWTPs with advanced treatment technologies would on average remove 70-80% of the micropollutants in outgoing water, reducing the total load from all coastal WWTPs by approximately 50%.
In a review of the directive the definition of “sensitive area” under Art. 5 should be looked at, especially in relation to “fulfilling Council Directives” by going beyond eutrophication and include e.g. limit values for priority substances. The compliance level with the current treatment requirements in these areas is 88% (8th Implementation Report). This gives grounds for the possibility to expand the scope of the meaning of sensitive areas and give priority to reducing pollution according to its impact on the chemical quality of receiving waters.
A modern UWWTD has the opportunity to facilitate innovation. Requirements for more advanced wastewater treatment will drive down costs and energy demand per cubic meter as technologies develop and prices drop with growing market demand.
With increasing water scarcity the potential price of inaction may prove more costly than taking action now.
For more information and references please see http://balticeye.org/en/pollutants/policy-brief-advanced-wastewater-treatment/
Read full responseResponse to Strategic approach to pharmaceuticals in the environment
26 May 2017
We welcome the Commission’s initiative to reduce harmful effects of pharmaceuticals in the environment and believe that the issue needs to be addressed at several stages of the lifecycle of a pharmaceutical substance.
Important upstream measures include facilitating for public procurement to put requirements on ERA for products and withdrawing OTC status for APIs with negative environmental effects (e.g. Diclofenac). The actual reduction potential associated with these measures needs to be quantified as they may not suffice to reduce environmental levels below relevant toxicity thresholds. End-of-pipe measures like advanced wastewater treatment thus become important to complement source control.
In April 2017, the Swedish EPA published a report on advanced treatment of pharmaceutical substances in wastewater. It concludes that there is a need for introducing advanced wastewater treatment. The need is [quote] "justified on the basis of the risk of long-term effects of a constant exposure to low levels of pharmaceutical substances in the aquatic environment with possible adverse effects on aquatic organisms, as well as the fact that some pharmaceutical substances are persistent and will remain in the environment and accumulate in biota. As future impacts on the environment and human health are difficult to predict, the introduction of advanced treatment can be justified on the basis of the precautionary principle."
We support these conclusions. Lowering the risk of what today remain unanticipated adverse effects is particularly important for water soluble and persistent pharmaceuticals and other micropollutants since they easily escape conventional wastewater treatment plants (WWTPs), spread in waterways and accumulate in the aquatic environment.
Conventional WWTPs often poorly remove pharmaceuticals as many are by design highly water-soluble compounds that are resistant to biodegradation. In the case of advanced treatment, the removal efficiencies vary depending on substance, technology and wastewater quality, but is currently on average around 70-80% in full scale applications of single additional treatment steps. Combinations of technologies such as advanced oxidation (O3), adsorption onto activated carbon (AC) and ultrafiltration (UF) can increase removal efficiencies, removing a wider range of micropollutants and pathogens. Costs for full scale implementation are in the range of ca 0.014 (O3, large WWTP) – 0.19 (UF + PAC or UF + GAC, medium size WWTP) euro/m3 treated wastewater. Energy consumption ranges between 0.01 (GAC) – 0.5 (UF + GAC) kWh/m3. (Estimated for WWTPs between 20 000–500 000 PEs in Sweden by Swedish EPA and Swedish Environmental Research Institute IVL). Costs and energy consumption are anticipated to decrease with technology development, operation optimisations and increased market demand.
It should be noted in the strategy that a generally improved quality of wastewater to reduce risks associated with pathogens, APIs and other micropollutants, is crucial for a transition to a circular economy, where reuse of wastewater for irrigation and aquifer recharge is encouraged. Generally reduced chemical emissions via UWWTPs also increases chances of reaching good chemical status under the WFD for substances that enter the aquatic environment via these pathways.
Legal incentives are needed to encourage implementation of advanced wastewater treatment. As with nutrients and organic matter today, treatment efficiency requirements or threshold levels of concentration of selected pharmaceuticals and other indicator substances should be included in new legislation related to wastewater such as in future revision of the UWWD. Furthermore, the polluter pays principle should be considered in the strategy. Finding legal measures that make the chemical industry pay for removal of their products from the water cycle can constitute a possibility to finance the upgrade of wastewater treatment.
Read full responseMeeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)
17 Jan 2017 · Policies that foster resilience