The open consultation is the first step in a probably lengthy process maybe leading up to a reviewed directive.

Below is a summary of the comments from the Baltic Sea Centre.

Read our full reply to the EU Commission combined evaluation roadmap/inception impact assessment of the MSFD

The marine ecosystems are not in good environmental status so a stronger directive is necessary. The Baltic Sea Centre has yet not a final view on the best future policy option.

A fundamental problem is that measures need to be taken in other policy areas in order to achieve the goals of the MSFD. In particular the fisheries policy area has failed to deliver despite the explicit connection to the MSFD in the reformed CFP.

In the absence of agreed threshold values for descriptors and criteria a precautionary principle should be applied for sectors such as fisheries whose impacts can delay achievement of good environmental status.

MPAs are an important tool but have no or too weak restrictions on permitted activities.

Areas free of human disturbance are essential reference tools for research.

The cumulative impacts of multiple stress factors on ecosystems and/or species must be taken into regard in marine spatial planning and in management plans for protected areas.

Monitoring should be better designed to enable evaluation of effectiveness of specific measures and temporal trends in emissions of hazardous substances and environmental levels.

In the revision of the Urban Wastewater Treatment Directive, UWWTD, criteria need to be developed for minimum chemical wastewater quality that address micropollutants and their mixtures and a clear connection must be established to the Marine Strategy Framework Directive.

The connection between the CAP and the MSFD should inprove.