Original: English
OSPAR CONVENTION FOR THE PROTECTION OF THE MARINE ENVIRONMENT OF THE NORTH-EAST ATLANTIC
MEETING OF THE OSPAR COMMISSION (OSPAR)
REYKJAVIK: 28 JUNE – 2 JULY 2004
WWF Position on the European Marine Strategy (EMS)
- Strategic Goals and Objectives (SGO) -
Presented by WWF
Background
1. Reference is made to documents OSPAR 04/10/01-E* and OSPAR 04/10/02-E* as well as the OSPAR-HELCOM Statement at JMM Annex 6.
2. WWF‘s baseline position with regard to the EMS was presented to OSPAR and HELCOM in document JMM 2003/Info.02-E*.
3. WWF is actively participating in the stakeholder consultation process on the EMS as facilitated by EC DG Environment. In this context, WWF puts particular emphasis on the development of an Ecosystem Approach to Management (EAM) and Strategic Goals and Objectives (SGO). In providing Annex 1 to OSPAR 2004, WWF would like to inform Contracting Parties about its view with regard to the latest state of SGO.
Action requested
4. The OSPAR Commission is invited to take note of WWF’s position.
Annex 1
Position statement on the European Marine Strategy
Strategic Goals and Objectives
SGO (3) 04/3/1
SGO (3) 04/3/1
WWF welcome the revised paper on Strategic Goals and Objectives as an important step forward in the development of the European Marine Strategy (EMS). In particular, WWF note that the paper generally covers all the policy issues of relevance to a Marine Strategy, and begins to outline issues relating to integration, implementation, action and institutional frameworks. WWF, however, has some outstanding concerns and comments which are outlined below.
Generic Comments:
The paper repeatedly highlights the need for, and challenges of integration of policies and sectors, and for cooperation and coordination. Whilst this is welcome, it will be imperative to show clear commitment to the challenges. Clarity on how this integration will take place and how the challenges will be met is necessary if all marine users are to contribute to achieving truly sustainable management of our seas and its resources. In particular, it will be important to develop and establish a formal mechanism or framework for sectoral integration between the relevant Commission Directorate Generals, with a process to reduce user conflict and secure maintenance of biodiversity and ecosystem integration. This can only be achieved through joined up governance, perhaps through an inter-directorate agency or a Marine Task Force.
A number of issues relating to policy integration are covered in the WWF report “Integrating Biodiversity and EU Fisheries Policy: Rebuilding healthy and productive ecosystems”. Although this report covers a specific, it sets out some generic concepts and principles that can be applied more broadly. A copy of the report will be forwarded to DG Environment for information.
WWF note, under paragraph 68, that the results and interactions of the working groups will be developed. In particular, greater clarity on the links between the SGO and EAM working groups would be beneficial. The EAM paper, to be produced as guidelines, outlines the key components necessary for developing, implementing and measuing achievement against the delivery. It is expected that the SGO paper will elaborate overall guidance on implementation. However, a clear plan/ framework, for example as an annex, which sets out a series of recommendations and actions, and which outlines the direct and indirect processes required, expected outputs and importantly a timeline would be useful. Clarification on how DG Environment intends to take forward and develop section VI will be important.
WWF welcome the indirect reference to footprint with respect to fisheries (paragraph 5) but believe a direct reference relating to the footprint of EU policies in other part of the world isnecessary. An additional example of the potential for footprint impacts is outline below under shipping (pollution).
WWF welcome the opportunity to further engage in the development of all aspects of the EMS, including discussion on the legal basis for the Strategy, both in the run up to, and at the forthcoming Rotterdam Stakeholder Conference in November 2004. With reference to the SGO paper WWF welcome the opportunity to comment further on the geographic scale of implementation via regional and sub-regional seas; text to be developed under paragraph 45; extended Impact Assessment (section V), and the development of issues outlined in section VI.
Specific Comments:
Section I
Data and references for European Seas other than the North Atlantic, such as the Mediterranean, would provide a more balanced view in this section.
Additional comment on the threats include:
Climate Change:
· It would be useful to add some text which recognises the need for concerted action on mitigation and adaptation, and to highlight the cross cutting nature of this threat, for example the reference to the threat to fisheries (section III), equally applies to biodiversity and habitat protection , eutrophication and coastal defences/ erosion etc. This is also alluded to in paragraph 54, but falls short of making the direct link.
Biodiversity and Habitat Protection:
· The text in paragraph 5 refers to the threats from fisheries on fish stocks but does not mention those affecting non-target species and habitats, and indirect threats to the ecosystem, such as food web interactions.
· A reference to the WFD should also be added in paragraph 8 with respect to the tools addressing the protection of species and habitats
Eutrophication:
· WWF suggest the inclusion of text referring to harmful algal blooms associated with eutrophication events, and subsequent relevance to the Shellfish Hygiene Directive.
· WWF suggest a more positive reference for the need for concerted cooperation between EU and regional seas conventions on this issue in paragraph 11
Pollution:
· Paragraph 16; after (first sentence) ‘…preventing discharges of oil’ add ’and other substances such as vegetable oil…’
· Para 17; replace first sentence with ‘Despite preventative measures shipping accidents are a recognised threat’.
· Para 18: is important, however, careful attention needs to be applied in the context of unilateral community legislation on shipping so as to avoid pushing sub-standard shipping to less developed parts of the world which are less likely to be able to cope with pollution and waste from shipping (this represents a potential example of EU footprint).
Health and Environment:
Paragraph 23 should read ‘non-Community countries in the Mediterranean…’ and not ‘’regions’
Section II
WWF would like to see the inclusion of text under section II ‘Knowledge Base’ which acknowledges that we may never have all the information desirable for making management decisions, consequently action must be taken on the basis of best available information and the precautionary principle.
WWF acknowledge the conclusions given in paragraph 32, but note the vague nature of the statement. It is important to clarify here what will need to be done, how and by when, and suggest a reference to later sections covering implementation and action.
Section III
WWF suggest that this section could be improved by grouping all the opportunity text in one sub-section and challenges in another.
WWF agree with the principles of the challenges outlined in paragraphs 33 – 36, however with respect to paragraph 36, note that an ecosystem approach is a means to an end and requires specific input and actions from users, and this should be reflected i.e. second sentence ‘Addressing this will require all users working towards common goals, outlined and implemented through an ecosystem approach to the management of human activities impacting the marine environment’.
Paragraph 40; WWF would like to see the first sentence rephrased to ‘Environmental integration is a key condition for progressing towards sustainability’.
In line with previous position statements WWF suggest some amendments with respect to paragraph 42:
Transport:
Add specific text reflecting the opportunity for ratification by Member States of relevant global shipping instruments including the Anti-Fouling Systems and Ballast Water Conventions.
Fisheries:
In addition to the points outlined in this section WWF believe that the protection of habitats and species can be achieved through a package of measures including the use of more selective gears and other tools such as No-Take Zones. These measures should be supported through structural funds, and considered as part of MPA management plans.
WWF note that whilst fishing effort can be a useful guide in assessing likely impact on fish stocks for example, it is irrelevant in the context of impacts on habitats, as even minimal effort can have dire consequences on sensitive and vulnerable habitats such as cold water corals.
Paragraph 43; WWF recommend the inclusion of a reference to:
- COM(2004)394 when referring to ‘its review’ (first sentence).
- Fisheries Biodiversity Action Plans, in particular, to incorporate the objective and targets on fisheries coming out of the Malahide Conference, May 2004 (Attachment A).
Paragraph 45 (to be developed) would be a relevant section to incorporate issues relating to EU footprint in the other parts of the world, such as distant water fleets, and external dimension i.e. marine conservation and sustainable fisheries should become an integral part of the Regional and Country Strategy Papers and of the Action Plans to be set up with Neighbour Countries.
Section IV
WWF believe that one of the aims of the Strategy should be to address the challenges of policy and sector integration through, for example, consideration of an EU Inter-Directorate Marine “Agency” or Marine Task Force with clear terms of reference, strategies, responsibilities and processes for coherent and effective use and management of the marine environment.
Strategic Goals:
Under related objectives 3 (Goal A) WWF advocate the inclusion of ‘effective’ prior to ‘representative networks’.
WWF suggests that related objectives (Goals B and C) are qualified with a timeline.
WWF advocate a reference to the EU CFP within related objective 11 (Strategic Goal C).
WWF would like to see the text for Goal D and related objectives strengthenedby replacing ‘to promote…’ with ‘to ensure…’.
Section VI
Paragraph 63 highlights that the Strategy will be made operational by means of an ecosystem approach. The text being developed by EAM represent guidelines for delivery, and it will therefore, be imperative for a proposed programme of action to deliver an ecosystem approach to managing marine activities to be clarified and outlined. As outlined earlier, whilst the concepts of favourable conservation status and good ecological status may be compatible with an ecosystem approach, and allow the evaluation in achieving these aims, there is still much work to be done to clarify the above concepts for the marine environment. Tools such as spatial planning, including ICZM and SEA etc are tools that can be used now, and represent the foundation for the integrated conservation of marine biodiversity and resources, and must be highlighted as critical components in implementation of the Strategy.
WWF agree with the statement that ‘the challenge will be to find means for ‘integration’ that do not disrupt existing partnerships in regional organisations’. In order to take the opportunities presented, however, steps should be suitably challenging to ensure meaningful and effectives measures both within the EMS and Regional Seas Conventions.
WWF seek clarification on how, when and by whom the regional management / action plans will be developed (paragraph 66).
WWF would like to see a specific section on how integration of policies and sectors will be developed and implemented in part 3 of section VI (to be developed).
Comments on the Annex covering existing objectives
The 1st reference to the WFD could be complemented by also mentioning the final paragraph of Article 1:
“and thereby contributes to:
- "achieving the objectives of relevant international agreements, including those which aim to prevent and eliminate pollution of the marine environment, by Community action under Article 16(3) to cease or phase out discharges, emissions and losses of priority hazardous substances, with the ultimate aim of achieving concentrations in the marine environment near background values for naturally occurring substances and close to zero for man-made synthetic substances."
With reference to fisheries WWF advocate the inclusion of the following text:
EU Common Fisheries Policy:
The Council regulation on the conservation and sustainable exploitation of fishereis resources (Council Regualtion (EC) NO. 2371/2002) extends the CFP to take into account conservation, management and exploitation of liveing aquatic resources whenever adopting managmentment regulations. The revised CFP is intended, through the implementation of an environmental integration action plan, to have an improved focues on the wider environment.
FAO:
A reference to article 7.2.2 (g) of the Code of Conduct for Responsible Fisheries i.e. the need to minimise pollution, waste, discards, catch by lost of abandoned gear, catch of non-target species, and to minimise impacts on associated and dependent species through the use of selective, environmentally safe and cost effective gear and techniques. It is partly intended to discourage the practice of finning sharks- removing the fins and discarding the remainder of the fish at sea, but is obviously of much wider relevance to shark fisheries (both target and bycatch).
Position Statement for WWF European Endangered Seas Programme.
For more information please contact:
Paloma Agrasot: Marine Coordinator, WWF European Policy Office ()
Alison Champion: Marine Policy Officer, WWF-UK ()
Attachment A
Outputs from the Malahide Conference (May 2004) on EU Biodiversity Action Plans
Fisheries:
Objective
To further promote the conservation and sustainable use of commercial stocks and to continue to reverse impacts of fishing and aquaculture on species and habitats making full use, in particular, of the CFP instruments.
Targets
2010 and earlier targets:
7.1 New Regulation on Structural Funds in the field of fisheries, with an increased allocation of funds for investments aiming at environmentally-friendly management adopted by 2006.
7.2 Recovery plans prepared and implemented as soon as needed for any stocks outside safe biological limits.
7.3 Technical measures, including marine protected areas, effectively implemented to help ensure favourable conservation status of marine habitats and species not commercially exploited, in line with the process initiated at the Dundalk Conference including measures aimed at the reduction of unwanted by-catch and of damage to the benthos.