The Finnish Archipelago Sea faces severe eutrophication due to agricultural runoff, harming its marine ecosystems. To address this issue, two case studies examine both local river basin management in the Archipelago and the broader Baltic Sea region.
The first case study focuses on local river basin management in the Archipelago Sea, while the second expands to the regional Baltic Sea level. Together, these studies explore the complex intersection of river basin management and marine strategies, emphasizing the need for coherence between the Water Framework Directive (WFD) and the Marine Strategy Framework Directive (MSFD).
Governance system
Main Findings
Synergies and incoherences between integrated planning processes and policy sectors (WFD, MSFD, MSPD and CAP, environmental licensing of aquaculture):
In Finland, the RBMPs and MS are prepared in close cooperation. The RBMS Act stipulates that the relevant ETE centre (Centre for Economic Development, Transport and the Environment) must coordinate the work between the MS and river basin management.
In the Archipelago Sea, both RBMP and MS describe different measures for each sector. They partly cover the same sectors, but also different ones, e.g. the RMBPs do not address marine sectors, such as maritime transport and underwater noise reduction. The MSP covers a wide range of water uses and their reconciliation, in particular energy, maritime transport, fisheries and aquaculture, tourism, recreation and marine environment protection.
The legal implications of the RBMP, the MS and the MSP differ in Finnish legislation. According to the Finnish Environmental Protection Act (527/2014, Section 51) and the Water Act (587/2011, Chapter 3, Section 6), the RBMP and the MS must be taken into account when issuing permits. On the one hand, the Finnish Supreme Administrative Court has stated (see e.g. case 2019:166), in line with the Weser ruling of the ECJ (C-461/13), that a project that jeopardises the achievement of the environmental objectives of water management cannot be granted a permit without an exemption provided according to the WFD and the RBMS Act. However, the legal implications of the RBMPs for the review of permits or the control of diffuse sources are unclear. On the other hand, the MS has not concrete legal implications for the permitting of point sources or the control of diffuse sources, while the MSP is not legally linked to any decision-making in Finnish law and has no legal implications.
With regard to nutrient loading to the Archipelago Sea, diffuse sources are otherwise excluded from a prior authorisation, but animal shelters above a certain size require an environmental permit under the Environmental Protection Act, and manure spreading is addressed in this permit. The MS includes measures related to nutrient loading, such as sea basin-specific nutrient quotas, but the RBMP is the only planning process that addresses land-based nutrient pollution. The Archipelago Sea RBMP highlights that the implementation of river basin management has been negatively affected by the voluntary nature of the measures and the lack of cross-sectoral cooperation.
According to the Archipelago RBMP, the Archipelago Sea Hot Spot Road Map project and our interviewees, the challenge in controlling nutrient run-off from agriculture lies in financing and subsidising the preventive measures and targeting them to the most problematic areas.
First, the voluntary system of agri-environmental support and eco-schemes remains inefficient and expensive and provides little incentive for innovation. Second, Finland’s agri-environmental scheme has provided implicit income support to farmers with insufficient water protection measures in agricultural areas1. Third, the Finnish scheme pays for management practices rather than for performance in reducing nutrient loads, which is costly, complicated and backward-looking2. The aim has been to enrol as many farmers as possible in to the scheme.
In relation to the licensing of open net pen fish farms in the Archipelago, there is incoherence at the level of policy objectives, which has led to a situation where it is unclear which direction the sector should take. Investment in the aquaculture sector is encouraged by EU and national blue bioeconomy policies, while at the same time the EU and national environmental objectives aim to achieve the good ecological status of waters and the subsequent reduction of cumulative nutrient load from different sectors, including aquaculture3
How can synergies between integrated planning processes (WFD, MSFD, MSPD) contribute to the delivery the GD objectives?
With regard to the zero pollution objective and nutrient loading, it is essential that the RBMP and MS planning processes are integrated. The land-based nutrient loading can only be addressed in the RBMP, but its reduction is relevant to the achievement of the MSFD objective of good environmental status of the marine environment. MSP, in turn, provides opportunities to plan the location of aquaculture and other activities in marine areas in relation to the good status objectives.
The Finnish RMBM and MS processes offer some positive elements for their integration. First, their geographical areas overlap. Both include coastal waters, although the RMBM has priority in their management. Second, the regional authority (TET Centre) has a central role in their preparation and, according to the RBMS Act, the regional authority must coordinate the work between the MS and RBMP.
Both the RBMP and the MS PoMs address a wide range of actors, but the measures they contain are only binding on the competent authorities. The different administrative sectors contribute to the implementation of PoM measures within their budgets and frameworks, while the implementation of measures for other actors is based on voluntary action and cooperation. The Archipelago RBMP states that in order to ensure effective implementation, the group of actors should be broadened, new active actors should be included and funding for the measures should be provided. Integration between different planning processes can provide opportunities for this.
In addition to their mutual integration, the RBMP, MS and MSP should be supported by other programmes and strategies in the Archipelago Sea. One of the interviewees stated:
“Several programs and strategies have been developed to support the implementation of river basin and marine management plans. Concerning eutrophication in the Archipelago Sea, a programme to enhance the effectiveness of water protection, led by the Ministry of the Environment is essential. It aims to improve water protection, particularly by reducing eutrophication. The programme brings stakeholders together, increases funding for measures and creates continuity in water protection.”
The impact of fish farming on water quality and biodiversity depends on the location of the farm and the technology used. A site management plan for aquaculture and its efficient implementation is therefore needed. This can then feed into the RBMP, MS and MSP processes.
Whether and how the operational implementation of River basin management plans (WFD), Marine Strategies (MSFD), and Marine Spatial plans (MSFD) are coherently contributing / considering measures to the delivery of the GD objectives of zero pollution?
One of the identified challenges in tackling eutrophication is the lack of a common understanding of which sectors should be included and how land-based activities should be involved in the operational implementation of different plans. In addition to agriculture and aquaculture, other important sectors in the Baltic Sea Region include fishing, tourism, and natural resource extraction4. For example, aquaculture is regulated by most Baltic States separately, while Denmark and Finland include it in their MSPs5.
Another problem that is raised in relation to the MSP’s is whether these plans are binding or not. In some countries, they are binding regulations, while in others they are closer to advisory tools6. The MSP are stringent depending on the country, and this could lead to incoherences in their implementation. Agriculture is the main contributor to eutrophication, but it is a land-based activity that is not taken into account in the operational implementation of the MS, and in particular the MSP, in the same way as in the implementation of the RBMP.
As nutrient pollution from agriculture is particularly high in this area, the Archipelago Sea is the only remaining hotspot area in the Finnish Baltic Sea7. The HELCOM Baltic Sea Action Plan (BSAP) recognises that agriculture has significant nutrient reduction potential, as diffuse sources have not achieved significant reductions over a 20-year observation period. The Archipelago Sea Hot Spot Road Map project has produced a separate document on the bottlenecks in agricultural water protection in the area.
According to the project report, the main reason for the incoherence between water protection and agriculture is the low profitability of agriculture and the low level of subsidies for conservation measures. The RBMP states that the challenge remains to finance the measures and to target them more precisely on the most problematic areas. The subsidies available for the measure are often insufficient. This has been the case, for example, with subsidies for buffer zones. This has led to calls for improvements in subsidies for individual effective measures (e.g. buffer strips and collector plants). As identified in the bottleneck project, the complexity of the subsidy system has slowed down the implementation of the measures; funding for agricultural water protection measures comes from several sources, and CAP-based targeting was perceived as complex.
Whether and how the operational implementation of River basin management plans (WFD), Marine Strategies (MSFD), and Marine Spatial plans (MSFD) are coherently contributing / considering measures for the management of aquaculture, diffuse pollution (agriculture and forestry) and point source pollution (industrial and urban waste water discharges)?
The RBMP, the MS and the MSP consider several measures for the management of aquaculture. First, the MS and the RBMP point to the need to update the Aquaculture location management plan. The plan aims to reconcile the interests of environmental use and water protection, thus identifying suitable areas for open net pen fish farming8.
Second, the development and adoption of new aquaculture technology, i.e. the construction of land-based fish farms with water recirculation, is one of the most important measures to reduce nutrient loads from aquaculture.
The area-specific development vision for the Archipelago under the MSP recognises that aquaculture will become increasingly important in the area by 2030. There is an objective to increase fish farming, but this objective is not consistent with the environmental objectives of the RBMP9. This challenge is also recognised in the MS PoM (Programme of Measures): it highlights the challenge of reconciling the aquaculture strategy and the blue bioeconomy with the objectives of water and marine management objectives10.
Both the RBMP and the MS consider measures to manage diffuse pollution from agriculture and forestry. For example, increasing the vegetation cover of fields is identified in the RBMP as one of the most important water protection measures for agriculture11. In forestry, one of the most important water protection measures is the use of protection strips for logging. This measure is included in both the RBMP and the Forest Programme for Southwest Finland 2021-2025 12.
With regard to forest management instruments, the RBPM outlines the need to develop cross-sectoral cooperation in water protection 13. The shared use of water protection structures should be improved, as demonstrated by the establishment of shared surface water drainage fields and wetlands. This could create synergies between agricultural and forestry water protection.
Nutrient loads from wastewater treatment plants and industry are controlled through environmental permits, which set requirements for phosphorus, nitrogen, etc 14.The RBPM states that wastewater treatment should be further improved and expanded, with particular attention to risk management. One of the key measures in the RBPM is the voluntary improvement of nutrient removal through the national agreement on urban wastewater treatment 15.
What needs to be done to enhance horizontal coherence to contribute the goal of addressing eutrophication?
There are two horizontal coherence challenges in tackling eutrophication in the Archipelago Sea area. Firstly, there is a challenge between the coherence of water and agricultural policies, not so much between the RBMP, the MS and the MSP in this regard. Second, there is a challenge between the horizontal coherence of agriculture and aquaculture.
While agricultural water protection is regulated by the Nitrates Regulation, there is little binding legislation on agricultural water protection measures in Finland and it is largely based on the environmental payment system16, which is part of the agricultural subsidy system.
86% of farmers in Finland are committed to the environmental payment system17. In the RBPM, the proposed agricultural measures are closely linked to the environmental payment system. The plan explains that the central financial form of financing for reducing the environmental impact of agriculture is the environmental subsidy system included in the CAP. The measures are coordinated through the agricultural subsidy system. In relation to the funding of water protection measures, one of the targets of the RBMP for agricultural water protection is the targeting of CAP project subsidies to water protection measures18.
In addition to the environmental subsidy system, water protection in agriculture is also promoted through project activities19. Project work plays an important role because water protection measures under the environmental payment system alone are not sufficient to improve water quality20.
The ongoing, separately funded programmes are the programme to promote nutrient recycling21 and the programme to improve water protection22,23. In the Archipelago Sea, gypsum spreading has been carried out for several years under the Water Protection programme24.
According to our interviewees, the aquaculture sector has improved a lot in reducing its nutrient load to the Baltic Sea, while the agricultural sector has done little or even increased its nutrient load. In order to tackle this problem, a cross-sectoral policy coordination would be required, aiming at managing the cumulative nutrient load to the Baltic Sea through improved coherence, technological development and nature-based solutions (NBS)25. Consequently, the development of the entire aquaculture sector is hampered by incoherent policy goals, lack of effective measures to manage the cumulative nutrient load, tightening permit requirements and a lack of a clear strategy for the renewal of the aquaculture sector26. Further policy integration of environmental concerns into the core of economic policies is also needed.
What needs to be done to enhance vertical coherence that would contribute to the delivery of the GD objectives of zero pollution?
- The complexity of the agricultural subsidy system has slowed down the implementation of the measures; for example, CAP-based targeting has been perceived as complex. In addition, the project funding of measures has faced problems in engaging farmers and ensuring continuity27.
- In addition to funding challenges, there are problems with targeting. Water protection measures have not been sufficiently targeted to areas where they would bring the greatest benefits28.The Archipelago Programme highlights the of upgraded environmental subsidies in the national CAP plans for the Archipelago Sea basin, despite the intensive agriculture in the area and the need to improve the state of the sea. Furthermore, one of the reasons for the low level of implementation of agricultural water protection measures is the lack of information among farmers in the Archipelago catchment area29. As the measures are voluntary and operators are responsible for their implementation, information is essential.
- On the basis of the bottlenecks, the Archipelago Sea Program has developed a roadmap describing the most effective agricultural water protection measures in the region. This programme, developed with stakeholders, identifies 10 effective measures that still have gaps in their implementation or funding30.
References
Laukkanen, M. & Nauges, C. (2014). Evaluating Greening Farm Policies: A structural Model for Assessing Agri-environmental Subsidies. Land Economics, 90(3), 458–481; Ollikainen, M., Hasler, B., Elofsson, K., Iho, A., Andersen, H. E., Czajkowski, M., & Peterson, K. (2019). Toward the Baltic Sea Socioeconomic Action Plan. Ambio, 48, 1377–1388. https://doi.org/10.1007/s13280-019-01264-0
Shortle, J., Ollikainen, M., & Iho, A. (2021). Water Quality and Agriculture: Economics and Policy for Nonpoint Source Water Pollution. Springer International Publishing.
- Soininen, N., Belinskij, A., Similä, J., Kortet, R. (2019). Too important to fail? Evaluating legal adaptive capacity for increasing coastal and marine aquaculture production in EU-Finland. Marine Policy, 110, 103498. https://doi.org/10.1016/j.marpol.2019.04.002
BSAP (4) 8.
HELCOM-VASAB Maritime Spatial Planning Working Group (25) 8.
HELCOM-VASAB Maritime Spatial Planning Working Group (25) 5.
Westberg, V., Bonde, A., Koivisto, A. M., Mäkinen, M., Puro, H., Siiro, P., & Teppo, A. (2022). Kokemäenjoen-Saaristomeren-Selkämeren vesienhoitoalueen vesienhoitosuunnitelma vuosille 2022–2027: Osa 1: Vesienhoitoaluekohtaiset tiedot. [River Basin Management Plan 2022–2027 for Kokemäenjoki – Archipelago Sea – Botnian Sea River- Basin Area, Part 1: Information by river basin district]. Elinkeino-, liikenne- ja ympäristökeskus raportteja 15/2022. Etelä-Pohjanmaan elinkeino-, liikenne- ja ympäristökeskus, Vaasa, Finland. https://www.doria.fi/bitstream/handle/10024/184724/Raportteja%2015%202022.pdf
The National aquaculture location management plan, p. 10.
River Basin management plan 2022-2027 for Kokemäenjoki – Archipelago Sea – Botnian Sea River- Basin area, part 1: Information by river basin district, p. 48.
Finnish Marine Strategy part III: Program of measures of the Finnish Marine Strategy 2022–2027, p. 85.
Programme of measures of the River Basin Management Plan 2022-2027 for Southwest Finland and Satakunta, pp. 122-124.
Programme of measures of the River Basin Management Plan 2022-2027 for Southwest Finland and Satakunta, p. 119.
Programme of measures of the River Basin Management Plan 2022-2027 for Southwest Finland and Satakunta, p. 121.
Programme of measures of the River Basin Management Plan 2022-2027 for Southwest Finland and Satakunta, p. 106.
The Green Deal Agreement on urban wastewater treatment, available at: https://sitoumus2050.fi/documents/20143/614957/Yhdyskuntaj%C3%A4teveden+puhdistamisen_green+deal_allekirjoitettu.pdf/693d2817-dfdb-8af2-96ec-919832e5cadc.
The environmental payment system is nationally regulated by the Government Decree on environmental payment system (78/2023).
Program of measures of the River Basin Management Plan 2022-2027 for Southwest Finland and Satakunta, p. 122.
Program of measures of the River Basin Management Plan 2022-2027 for Southwest Finland and Satakunta, p. 122, 127.
Planning document for water management measures for 2022-2027: Agriculture, fur production and acidification control, p. 7.
The Archipelago Sea Hot Spot Road Map Project: bottlenecks of agricultural water protection, p. 28.
Ministry of Environment, Nutrient recycling programme, available at: https://ym.fi/ravinteidenkierratys.
Ministry of Environment, Water protection programme, available at: https://ym.fi/en/water-protection-programme.
River Basin management plan 2022-2027 for Kokemäenjoki – Archipelago Sea – Botnian Sea River- Basin area, part 1: Information by river basin district, p. 126.
The Archipelago Sea Hot Spot Road Map Project: Road map of water protection in agriculture, p. 8.
Puharinen, S.T. (2021). Good Status in the Changing Climate? – Climate Proofing Law on Water Management in the EU. Sustainability, 13(2), 517. https://doi.org/10.3390/su13020517
Valve, H., Lukkarinen, J., Belinskij, A., Kara, P., Kolehmainen, L., Klap, A., Leskinen, R., Lähteenoja, S., Marttila, T., Oikarinen, M., Pitzén, S. (2019). Lisäarvoa kalasta ja maatalouden sivuvirroista Varsinais-Suomessa: Sinisen biotalouden murrosareenan tulokset. Demos Helsinki.
The Archipelago Sea Hot Spot Road Map Project: bottlenecks of agricultural water protection pp. 27, 30.
The Archipelago Sea Hot Spot Road Map Project: bottlenecks of agricultural water protection p. 25.
The Archipelago Sea Hot Spot Road Map Project: bottlenecks of agricultural water protection p. 26.
- The Archipelago Sea Hot Spot Road Map Project: Road map of water protection in agriculture, p. 2.