Final environmental report

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  Change in net loss of biodiversity (if possible break down in relevant spices)
  
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  Change in size and/or condition of valuable natural areas
  

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  Change in human exposure to hazardous substances
  

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  Condition and extend of abandoned brownfield sites
  

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  Changes in emissions of hazardous substances to marine or fresh water environments
  
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  Changes in the water quality in marine or fresh water environments
  

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  Damages to material assets from air pollution
  
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  Possibilities to use land for social/commercial purposes after it has been cleaned up
  

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  number of listed buildings and archaeological sites at risk
  

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  Impact on landscape from new infrastructure
  

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  area and quality of land unfit for use for other purposes
  

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  use of energy per unit produced
  

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  share of renewable energy sources in the energy supply
  

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  Number of persons or buildings exposed to threats from extreme weather conditions
  

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  Increase in number of ton/km or parson/km
  

8.1Priority 1 Fostering innovations across the BSR;

8.3 Priority 3 Management of the Baltic Sea as a common resource;

8.4 Priority 4 Promoting attractive and competitive cities and regions.

Comments to the draft BSR programme have been forwarded to COWI as they may have relevance for the SEA.

See below for comments to specific sections:

The comment consists in a subsidiary clause and is factual in nature. Relates to a background section

The comment is purely editorial in nature.

- 1. Economic management of open sea areas and sustainable use of marine resources. It is suggested to introduce environmental requirements and best technologies and practices; and

- 3. Integrated development of off-shore and coastal areas. Joint actions to fulfil the requirements for cooperation and coordination within the Marine Region (the Baltic Sea) of the European Marine Strategy is suggested.

The comment relate to the Programme and not to the environmental report.

- joint actions to prevent transboundary pollution, and to promote environmental management and standards; and

- preparation of scenarios, strategies and intervention plans towards mitigation of impacts of climate changes.

- applying new advanced and cost-effective methods for water optical property measurements, and

- to set up a network of experts and resources for gathering monitoring data of water optical parameters for both ecological monitoring and sustainable quality map information production.

The suggestions should be considered in the BSR OP - or in plan/project applications.

International cooperation projects should be started for exchange of information and experiences.

Social cohesion should be strengthened

Cooperation in prevention of crossborder health and social problems (HIV/AIDS, tuberculosis, veneral diseases) is needed as well as in the area of social and health services.

Section 8.3 priority 3: Management of the Baltic Sea as a common resource, Sections 8.3.1 Background, and 8.3.2 Orientation, and

Section 8.4: Promoting attractive and competitive cities and regions, section 8.4.1 Background.

The comments relate to the BSR OP and not the Environmental report.

Comments based on meeting with 43 participants.

1) Information and Data Cooperation in the Barents Region

2) Sustainable Transport in the Barents Region Phase 2 (STBR II)

The project ideas do not relate to the Environmental Report.

The draft environmental report is based only on analysing the written programme draft (1st draft), and results of the environmental assessments remains on a very general level'.

- reflect not only EU level objectives but also BSR environmental objectives (HELCOM, ESPON), and national environmental programmes), and

- should be shorter.

A better feeling for how it might work in practice and how it would be possible to arrive at a comprehensive assessment of all relevant aspects of sustainable development is wished for.

It is not obvious to what extent the work with the programme and the environmental report has been made parallel in time and well integrated. For instance the fact that the procedure for making an assessment of the likely significant environmental effects of the specific projects before funding is granted under the programme is included in the environmental report instead of the operational programme indicates that the programme process and the environmental assessment have not been enough integrated.

It should be noticed that in this context the word “environment” include a broader area of aspects and issues than it does in general. Besides genuine environmental issues such as effects on climate, land, water, biodiversity etc. it also include effects on population, human health, material assets, cultural heritage and landscape. That should be taken into account not only when making the assessment of the significant environmental effects that the programme may cause (as in chapter 6) but also in the description of the state of the art.

Chapter three gives in principle a fair and correct description of the status of the environment and its development, although it is on a very general level. It could be added that the present and expected future environmental development differs a lot within the BSR area depending on differences in actions taken and planned, pressure on the environment and vulnerability of the environment.

The description of the current state of the environment constitute the base for the assessment when assessing if the program is likely to have significant environmental effects and if so which significant effects that can be expected. In order to fulfil that purpose the description of the environmental status has to be much more detailed and more regionalized.

Another example of long term problem that could be mentioned is the accumulation of cadmium in arable land due to air pollution and mineral fertilizer.

Specific selection criteria for proposed activities are not included in the Draft Operational Programme. However, since it is impossible to include the forthcoming projects and activities in the environmental assessment of this kind of superficial programmes it is of vital importance that the environmental assessment includes the selection criteria for forthcoming projects and activities.

The lack of knowledge regarding the forthcoming projects and activities in this kind of superficial programme makes the monitoring part of the process even more important than it is in general. Thus, it is of vital importance to conduct and work out thoroughly a plan for the monitoring of the environmental effects in order to identify and undertake appropriate remedial action against the unforeseen adverse environmental effects that might arise as a result of the programme.

The Swedish (EPA) recognizes that the nature of this kind of large and diffuse programmes makes it very difficult to perform an appropriate environmental assessment in accordance with the legislation.