LRFrapport_2013015

More documents

Recommendations

Info

16 Version 2, 15.04.2013 environmental lawyers Bjällås and Fröberg. LRF agree with the criticism made in this report and believes that the current method of implementation in Sweden could lead to very serious and politically undesirable consequences including Swedish employment, economy and food production. The analysis of the economic impacts of Sweden's commitments within the BSAP done by the Swedish Environmental Protection Agency and the Swedish Board of Agriculture in 2008, showed that the Swedish reduction targets would lead to unreasonable consequences for Swedish agriculture, including large areas lay fallowed as the only opportunity to achieve the reduction targets. Based on this analysis, it would be fair to assume that the consequences of the Swedish implementation of reduction targets under the current model with legally binding EQS probably will have dramatic consequences for Swedish agriculture. Meanwhile, the environmental benefits to the Baltic Sea are highly uncertain because food production can be assumed to move to countries with a similar or greater environmental impact. LRF's view is also in harmony with the report of the Environment and Agriculture Committee in the Swedish Parliament, in connection with the reform the national system of environmental quality objectives, in which the Committee stated that the environmental quality objectives certainly should be ambitious and challenging but they must not be formulated so that they become impossible to achieve. 3.4.2 LRF's proposal Marine Environmental policy indeed must remain a political matter in Sweden. The current Swedish system, in which governmental decisions are made within HELCOM BSAP and then transferred directly down to the agencies without passing the parliamentarian level, is not the result of a conscious policy choice, but rather a consequence of a unique way to introduce the EU WFD and MSFD. LRF is of the opinion that this is highly questionable, an opinion recently confirmed in the report to the Environmental Advisory Council. The Parliament, the Government and the authorities therefore need to urgently review and adjust the method to implement EU WFD and MSFD and HELCOM BSAP, to ensure that Sweden not unilaterally exposes itself to politically undesirable and unreasonable consequences for the economy, employment and food production, with highly uncertain environmental benefits. Such changes would also be necessary for the general improvement of the framework for marine and water policies in Sweden and to restore confidence in environmental governance.
17 Version 2, 15.04.2013 Furthermore, the Government must ensure that there is a preliminary socio-economic impact assessment of the proposed ecological targets and reduction target before they are decided within HELCOM. The Government should present a report to the Parliament in time for the HELCOM meeting in October 2013. It should be based on the latest available knowledge and recognize the socio-economic consequences. The report should be looked upon as the start of a revised and continued ambitious Baltic Sea policy in Sweden and throughout the region, with the goal of fastest possible restoration of the Baltic Sea to the lowest possible cost and recognizing that persistence and patience will be required. 3.5 Other comments and suggestions 3.5.1 LRF's basic views on a Swedish Baltic Sea policy For Sweden to maintain a strong macro-regional position within HELCOM and EU in the process of handling and combatting the eutrophication in the Baltic Sea, it is essential that the problems are being handled in a manner that: Is based on all relevant scientific knowledge, even possibly politically inconvenient knowledge. The uncertainty of this knowledge must be recognized and presented in a transparent manner. New research results must be taken seriously and result in change of policy when justified and appropriate, otherwise the principle of decision-making based on the best available knowledge will be undermined. Considers all possible cost-effective measures to combat eutrophication, including measures both in the catchment area and directly in the Baltic Sea. Respects the Parliamentary decision that the environmental objectives within the national system of environmental quality objectives must be "ambitious, but achievable". This is also a valid principle in good governance generally speaking. Is understandable, transparent and practicable. Reward and encourage food production with high nutrient efficiency and overall high performance, instead of punishing those farms with possible closure as a consequence.
Page 1 and 2: Hur återställer vi Östersjön? E
Page 3 and 4: 3 Version 2, 15.04.2013 3.3 Cost-ef
Page 5 and 6: samspela med målen för EU-direkti
Page 7 and 8: 7 Version 2, 15.04.2013 gånger st
Page 9 and 10: politisk process som sedan följdes
Page 11 and 12: från jordbruket som publicerades 2
Page 13 and 14: equired. A major reason why the dec
Page 15: calculated. This inevitably leads t
Page 19 and 20: 4 Rapportens syfte Denna rapport sy
Page 21 and 22: Senast under Sveriges ordförandesk
Page 23 and 24: stater att havsmiljöpolitiken i EU
Page 25 and 26: Arbetet stöds ekonomiskt av EU, sv
Page 27 and 28: Redan 1998 var LRF drivande och med
Page 29 and 30: Sverige måste fortsätta ha hög p
Page 31 and 32: 31 Version 2, 15.04.2013 I början
Page 33 and 34: tillförselsnivå som eftersträvad
Page 35 and 36: 35 Version 2, 15.04.2013 ökningar
Page 37 and 38: 37 Version 2, 15.04.2013 genomförs
Page 39 and 40: havsbaserade vindkraftverk 32 ), al
Page 41 and 42: myndighetsutövning och beslutsfatt
Page 43 and 44: Risken är att det uppstår förvir
Page 45 and 46: i reduktionsbetingen. Vidare använ
Page 47 and 48: ordning några nämnvärda bekymmer
Page 49 and 50: 49 Version 2, 15.04.2013 JCP från
Page 51 and 52: 51 Version 2, 15.04.2013
Page 53 and 54: 53 Version 2, 15.04.2013 tidsperspe
Page 55 and 56: 55 Version 2, 15.04.2013 ton. Dessu
Page 57: ”Det övergripande målet för mi

LRFrapport_2013015

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?