LRFrapport_20130521_ny

aimed to reduce emissions at source and remedial measures, such as liming efforts in affected
countries such as Sweden and Norway, for example, for faster recovery in targeted places.
3.2 Estimated time for recovery
3.2.1 The problem
According to a unanimous marine research community, the internal load of phosphorus
inevitably will result in the restoration of the Baltic Sea with respect to eutrophication taking
considerably longer than the current, politically set target years (2021 according to BSAP and
2020 under the EU MSFD). At least another 25-50 years after 2020 are required according to
the same scientist supporting HELCOM in calculating the reduction targets. The current target
year is therefore completely unrealistic. From a good governance perspective this is
counterproductive for several reasons.
(i) It may create a serious uncertainty about HELCOM as a science-based
organisation – an issue of scientific legitimacy and trust.
(ii) It may lead to concerns about an unjustified driven urgency on matters that may
lead to economically unsound choices are being made – an issue of whether
rational decision-making is taking place.
(iii) It may lead to a strong reluctance and non-acceptance of the entire governance
process among countries and sectors – an issue of governance trust.
(iv) It makes assessments of progress towards targets unjust and unfair, insofar that the
assessment criteria is a physical impossibility. This will lead to, whatever
measures done and resources spent, a negative assessment of ability to meet target.
It will lead to an immeasurable governance system – an issue of reasonability and
proportionality.
3.2.2 LRF's proposal
The target years in the BSAP and the EU MSFD must be adjusted according to the new
knowledge on the internal phosphorous load and the resulting extended restoration time, yet
still remain ambitious. The target years must at least be physically possible to achieve. This is
of particular importance for Sweden as Sweden on a unilateral basis has made the
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Remissversion, 21.05.2013