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Joukko ympäristöjärjestöjä kirjoitti Euroopan komissiolle huolensa siitä, ettei meristrategian direktiiviin liittyviä asioita valmisteltaisi kansalaisyhteiskunnan selän takana.

Itämeri ja Jurmo. Ulla Pulkki/SLL


NGO Concerns around Informal ad-hoc MSFD Group

We are writing to you concerning the creation of the so-called informal ad-hoc “Friends of the Directive” group for ‘implementers’ of the Marine Strategy Framework Directive as discussed in the last Marine Strategy Coordination Group on the 28th May 2021.

We note that in your minutes circulated on the 18th July 2021 for this meeting you stated that this group would be a platform for Member State experts to share implementation experiences in an informal way, meaning that members of the group will be expected to contribute as individuals and not as MS representatives.

Whilst you state in your note regarding this group that it would be informal, that no decisions would be taken and that all MSCG representatives from Member States would have a standing invitation to the group, the question still remains as to what extent this group will influence what takes place in the other working/technical/drafting/focus groups.

We are concerned that this ad-hoc group, which does not include NGOs and other third parties, will frame discussions around what will be discussed within the various groups relevant to the review and implementation of the MSF Directive. For example, it is noted that meetings would be back to back with MSCG meetings. It is not realistic to believe that discussions and topics on the official agenda will not be continued in this group or that statements made will not be reflected upon by participants in other conversations in the home office and so on.

Whilst we note that the regional sea conventions and NGOs may be invited to attend these future informal ad-hoc group meetings on a case-by-case basis, it is nonetheless our opinion based on the response of the Member States in the most recent Marine Strategy Coordination Group, that this will be at the discretion and consensus of the participating Member States. Furthermore, if these meetings are informal and no agendas are made or no minutes are taken, how could anyone know if it is relevant to invite others?

We would appreciate it if you could address the following questions in order to address observer concerns, including the perceived lack of transparency.


  • What is the remit and purpose of this group, and why does it have to be a closed group linked to that purpose?


  • What are the terms of reference, informal or otherwise?


  • What can be discussed in this ad-hoc informal group between implementers that cannot already be addressed in other forums and other informal/formal groups, ad-hoc or otherwise?

  • What is the rationale for excluding NGOs, some of whom already advise and interact with national implementers on a regular basis?


It is our opinion that the closed nature of this ad-hoc group runs contrary to the conclusions by the marine directors in their meeting held in December 2020, that you referred to in the MSCG note. In this note, in the context of discussing the ‘Future of the MSFD, against the background of non-achievement of Good environmental status (GES) in 2020’, it was said that the marine directors stated that they saw the need for a continuation of this discussion in “a soon to be established informal ad hoc forum that is transparent and open.” This needs to be reflected in practice.

We are also concerned that the establishment of such a group undermines the principles of environmental democracy, access to information, and public participation in decision-making, as enshrined in the Aarhus Convention (and Regulation No. 1367/2006 which is binding on the Commission), and in Articles 2, 6, 10, and especially 11 of the Treaty on the European Union.

In order for an informal ad-hoc group to meet these criteria of transparency and openness, it is important that NGOs have the option to attend and participate.

We are happy to discuss this with you further, and we look forward to your response.

Kind regards,

Odran Corcoran, WWF EPO

Nils Höglund, Coalition for Clean Baltic

John Condon, ClientEarth

Tapani Veistola, Finnish Association for Nature Conservation

Bettina Taylor, Friends of the Earth Germany

Tobias Troll, Seas at Risk

Gaelle Haut, Surfrider

Cathrine Pedersen Schirmer, Naturfredningsforening

Nicolas Entrup, OceanCare


Ympäristöpäällikkö, va. toiminnanjohtaja Tapani Veistola

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