Marine Strategy Framework Directive Implementation: Issues of interest
The recent meeting of the Marine Startegy Framework Directive Co-ordination Group (MSCG) was attended by Jan Brooke, on behalf of the MSFD NAVI*. The notes of Ms Brooke prepared for NAVI can be downloaded below. Ms Brooked identified the following main issues for the dredging and navigation sectors:
- scale and aggregation: this topic was not discussed at the MSCG meeting. However, from the content of the consultants' report to COM it seems to me to be inevitable now that certain aspects of MSFD implementation will be focused at a much smaller scale than the level of the marine region and sub-region as foreseen by the Directive, particularly in coastal water bodies. This is because certain habitat types occur only in inshore waters. Thus it is also possible that greater attention will be paid to port and navigation activities than might otherwise have been the case. This does not necessarily change the implications of the Directive for the sector, but it does reinforce the need to remain vigilant, particularly with regard to the forthcoming Programmes of Measures
- exceptions: COM presented a first draft of their paper on how they envisage the exceptions provisions being implemented. Whilst COM stressed its ‘first draft' nature, the paper is worrying insofar as it seems to overlook the scale issue - citing lessons from the Habitats Directive to define the term ‘significant', and then suggesting that ‘even a small project can have significant impacts'. From my viewpoint, having participated in the equivalent process for the WFD, such interpretations appear to me to be totally inappropriate. I spoke to several Member States and made them aware of my concerns. COM has proposed that a drafting group take this forward, so hopefully common sense will prevail.....
- invasive alien species (IAS): whilst Albert has been following this for a while, particularly in terms of the biofouling and biocide aspects, it is possible that there is an emerging relating to the potential for IAS to use port and navigation infrastructure as ‘stepping stones', moving and colonising both existing and new structures as water temperatures rise. This is of concern because it comprises a mechanism whereby port and navigation infrastructure could contribute to an effect at a more significant scale (in MSFD terms) than the primarily ‘local' (also in MSFD terms) effects on hydrographical conditions.
* The Marine Strategy NAVIgation Group (NAVI) is a "thematic Cluster"of nine navigation and dredging sector bodies that coordinates the responses of the participating associations to the European Commission's MSFD Common Implementation Process based on their collective knowledge, experience and views. NAVI members are: Central Dredging Association (CEDA), European Boating Association (EBA), European Boating Industry, European Community Ship-owners Association (ECSA) European Seaports Organisation (ESPO), European Dredging Association (EuDA), International Council of Marine Industry Associations (ICOMIA) International Salvage Union and the International Navigation Association (PIANC).
NAVI is chaired by CEDA (Dr Noemi von Meijenfeldt, Witteveen-Bos, the Netherlands).