1
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NO - MoE
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NO - MoE agrees with COWI that the BSR programme is abstract which makes it difficult to carry out SEA of the programme.
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÷
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2
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NO - MoE
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NO - MoE agrees with COWI that as accessibility is an aim, the likeliness of supporting projects leading to increased overall traffic volume and related environmental problems is considerable
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÷
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3
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NO - MoE
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NO - MoE agrees with COWI that a guideline for downstream assessment of projects will be a valuable contribution
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÷
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4
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FI - Finnish public organizations
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The comments relate to the Draft BSR Programme chapter 8. Priorities of the Programme, sections:
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:
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See below
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5
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FI - Finnish public organizations
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Comment to section 8.1.1. Background:
The comment consists in a subsidiary clause and is factual in nature. Relates to a background section
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÷
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6
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FI - Finnish public organizations
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Comment to section 8.1.3 Directions of support.
The comment is purely editorial in nature.
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÷
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7
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FI - Finnish public organizations
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The comment relates to section 8.3.1 Background of the draft BSR programme and is purely editorial in nature. Relates to a background section
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÷
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8
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FI - Finnish public organizations
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The comment relates to section 8.3.2 Orientation of the draft BSR programme and is purely editorial in character. Relates to a background section
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÷
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9
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FI - Finnish public organizations
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The comment relates to section 8.3.3 Directions of support of the draft BSR programme, It consists mainly in editorial amendments of which some concretize directions for support. These relates to the issues of:
- 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.
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÷
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10
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FI - Finnish public organizations
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The comment consists in suggestions for additional activities in the programme under section 8.4.3 Directions of support. It is suggested to include:
- 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.
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÷
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11
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FI - Finnish Environment Institute (SYKE)
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SYKE suggests
- 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.
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÷
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12
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FI - Finnish Ministry of Social Affairs and Health
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The programme should be seen in its totality to ensure that projects go in the same direction. The need for relevant indicators is emphasised.
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÷
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13
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The administration of the Interreg. programmes must be streamlined and simplified
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÷
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14
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It is important to generate projects to study socio-economic health differences between regions as well as their connection to changes in societies.
International cooperation projects should be started for exchange of information and experiences.
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÷
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15
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Missing themes:
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.
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÷
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16
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FI - National Board of Antiquities
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The comments relate to Chapter 4. Summary of trends challenging the programme and Chapter 8 Priorities of the Programme - more concretely:
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.
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÷
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17
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Organisers: Finnish MoE, MOI, Association of Finnish Local and Regional Authorities
Comments based on meeting with 43 participants.
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Is it really necessary that all project applicants will have to implement SEA? Seed money is not enough to cover the expenses of SEA in transport projects
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√
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18
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Is it possible to use the Baltic Sea Region programme to prevent the waste water emissions from ships on the Baltic Sea?
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÷
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19
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FI - ??
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Two project ideas have been forwarded to COWI:
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.
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÷
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20
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FI - MoE, Land Use Department, Tina Tihlman.
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Programming, Ex-ante and SEA, should be carried out as an interactive process in order to assess different alternatives from an environmental perspective.
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'.
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÷
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21
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Outcomes of hearings, discussions with the EC and consultation with ex-ante evaluators have resulted in changes to the programme draft - including on financing shares have been discussed. The environmental report should be updated according to the revised programme (3rd version).
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÷
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22
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Chapters 3 Overall Development context of the BSR Programme and 4 The Environmental Policy Framework should be revised so as to
- reflect not only EU level objectives but also BSR environmental objectives (HELCOM, ESPON), and national environmental programmes), and
- should be shorter.
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÷
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23
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'Results of the environmental assessment are presented on sections 5 and 6 and also in annexes. The titles of 5 and 6 do not differ much from each other. They should be clarified'
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√
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24
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'The appendix 2 is disorganised. It contains titles and headings, and it is not always clear if they are programme or SEA titles. As appendix in this case is an essential part of the content of the report, attention should be paid to presenting the information more clearly'
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√
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25
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Comments to Appendix 1. Titles are confusing.
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√
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26
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'An alternative, that the programme would not be implemented, should be evaluated, too'
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√
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27
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'Downstream assessment procedure (section 7) in application phase could be considered. Still, the applicants should present the environmental impacts of their projects, and also clarify how the project reflects to the EU level and also other environmental objectives.
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÷
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28
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SE - The Swedish Association of Local Authorities and Regions, Growth and Community Development Division
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General comment: The environmental report is ambitious, which is excellent. But it is also difficult to get a good grasp of and rather theoretical.
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.
Below the specific comments are presented.
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See below
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29
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'How would the objectives and framework conditions established at the EU-level be adapted and broken up to be meaningful and achievable at the regional and local level?'
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30
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'How would specific local and regional conditions be reflected when balances are struck and priorities made at the local and regional level?'
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31
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'How can we guarantee that reliable data are available and how can the quality of the data be ensured?'
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32
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'We would like to underline the need to develop a well-functioning management system for sustainable development to meet the demands underlined in the programme'
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33
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'We would like to see more done in the area of developing targets that can be measured but not only in monetary terms, such as public health, biodiversity, etc.'
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34
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'We welcome the ambitions to monitor and evaluate the results of the programme both in terms of content and with respect to form. However, we also wish to stress the need to monitor and evaluate the process as well.
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35
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SE - County Administrative Board of Skåne-Sweden
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The Board stresses '…the positive initiative by the report to launch recommendations of using "check-lists" (Appendix 3) when evaluating project applications.
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36
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SE - Swedish EPA
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The Swedish EPA recognises that this kind of programme is by nature diffuse and less specific which makes it difficult to assess the significant environmental effects.
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÷
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37
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The environmental report should include information of the considerations taken when preparing the programme regarding “environmental protection objectives established on international, community level or member state level which are relevant to the programme (EC directive annex 1 e). For the environmental report in question the objectives and policies taken to account are those of the European union. Those of national level are missing.
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38
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The integration of the programme and the environmental report
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.
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39
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The meaning of “environment”
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.
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40
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Environmental development in the region
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.
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41
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Regarding the description of the environmental development in section 3.2.2 it is important to notice that although the deposition of sulphate and nitrogen oxides has decreased significantly and is expected to continue to do, the critical loads for acidification and eutrophication are and will be exceeded for several decades in sensitive areas. And these areas include several hundreds of square km.
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.
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42
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Selection of projects and precision in project design.
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.
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43
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The Swedish EPA agrees on the importance to develop a procedure to make an assessment of the likely significant environmental effects of the specific projects before funding is granted under the programme. The proposed procedure (chapter 7) should have been included in the programme and then been subjected to the environmental assessment. However, one advantage and main reason for introducing environmental assessment on program and plan level and not only rely on the assessment on project level as in EIA (Environmental Impact Assessment) is the possibility to include the total effect (cumulative effect) from all projects and activities at the same time. EIA has also other limitations for example when considering alternatives and non project activities. Thus, it is important not to abandon the advantages that are linked to the use of environmental assessment on programme level and put the focus only on single projects.
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44
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According to section 5.4 in the environmental report only half of the directions of activities relating to projects designs are described on sufficiently detailed level to make it possible to assess the likely significant environmental effects. The direction for projects design should be made more detailed in order to make it possible to assess the likely significant process.
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45
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Special importance of monitoring
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.
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46
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Modified environmental assessment with focus on monitoring and selection of projects
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.
But to exclude these kinds of programmes from the requirement to make environmental assessment would not be a good idea. However, one could consider if not a modified version of environmental assessment that takes into account the special nature of these programmes is more preferable. Such modified assessment should probably focus more on selection criteria for activities and projects and on the monitoring of the programme.
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