An institution dedicated to fighting pollution in the Black Sea

by Thomas Jensen

The Black Sea Commission collaborates with many to achieve its objectives

This article was featured in Eurofish Magazine 6 2021

The Black Sea Commission was originally created three decades ago to fight marine pollution, but its remit has since expanded to include marine litter, biodiversity, and integrated coastal zone management. The commission works closely together with a number of international organisations to monitor the environment in the Black Sea and it provides a legal framework to fight land-based and maritime pollution. It is also the only instrument related to international environmental law that has all the Black Sea riparian countries as signatories. Prof. Halil Ibrahim Sur, Executive Director, discusses here some of the environmental challenges facing the Black Sea and the role of the commission in solving them.

What are the main objectives of the Black Sea Commission (BSC) and as executive director of the institution what, in your view, are the foremost challenges towards achieving these?
What is the current and future role of the BSC as a regional player for the protection of the Black Sea?

The Black Sea Commission, for almost three decades, plays a major role in addressing issues of conservation of the environment of the Black Sea, being a Regional Sea Convention. As you may know, the Black Sea Commission was created as an executive body to implement the provisions of the Convention on the Protection of the Black Sea Against Pollution also known as the Bucharest Convention, signed back in 1992 and ratified by all the Black Sea riparian countries. The Black Sea Commission consists of representatives the Ministries of ­Environment of all six Black Sea riparian countries.

Initially our activities were focused mainly on marine pollution control, but over the years, we put on our agenda the issues of biodiversity; integrated coastal zone ­management; ­climate change, marine litter, and many others. For the moment, the Black Sea Commission is responsible for promoting the implementation of the Bucharest Convention and its Protocols, which foresees, inter alia, monitoring and assessing pollution, controlling pollution from land-based sources, ensuring the conservation of biological diversity, addressing environmental safety aspects of shipping and maritime policy, addressing environmental aspects of management of fisheries and other marine living resources and, last but not least, promoting integrated coastal zone management.

We have made substantive achievements in all these spheres, but still, despite the ongoing efforts of the Black Sea riparian countries, environmental deterioration continues and is being significantly affected by global and regional political, social and economic realities.

In recent years, the Black Sea Commission and its partners managed to put on the agenda some important issues of our cooperation in the sphere of the Black Sea environment. Among them let me mention the adoption of the Black Sea Integrated Monitoring and Assessment Program for 2017-2022 (BSIMAP), which foresees harmonization with the Marine Strategy Framework Directive (MSFD); defines the Good ­Environmental Status (GES) for the Black Sea; provides the common lists of indicators and parameters of reporting coordinated with our partners from UNEP, FAO GFCM (General Fisheries Commission for Mediterranean), ACCOBAMS Agreement, and ICPDR (the International Commission for the Protection of the Danube River) and many others. Together with our partners from the Mediterranean Sea, we elaborated the Regional Action Plan on Marine Litter in the Black Sea (which was already adopted by the Black Sea Commission in 2018) and draft Marine Litter Monitoring Guidelines. In fact, this work is the number one item on the agenda in our cooperation with our Mediterranean colleagues within the MoU between the Black Sea ­Commission and Barcelona Convention Secretariat signed in February 2016.

We collaborate closely with GFCM and ACCOBAMS Agreement, developing a draft Conservation Plan for Black Sea Cetaceans and contributing to the implementation of the so-called “Bucharest Declaration” on sustainable fisheries and aquaculture, signed in 2016 in Bucharest. Needless to say that we work closely together with all dedicated regional projects financed by different donors and support the implementation of our Black Sea Strategic Action Plan (2009). We also serve and, I hope, will continue to serve as an important stakeholder and end-user of their deliverables in the region.

The objectives of the Black Sea Commission and the GFCM overlap in areas such as the sustainable management of resources. How do the two bodies cooperate to prevent the duplication of efforts and to ensure the most effective implementation of policy measures?

Specific features of the Black Sea make it very vulnerable to disturbances of its environment and ecosystems. Eutrophication, pollution, and irresponsible fishing resulted in an overall decline of biological resources, the diversity of species and landscapes, and of the aesthetic and recreational values of the Black Sea. Algae blooms are still observed, pollution, although localised, affects the biological communities. The fish stocks of commercially valuable species, such as sturgeons and turbots, suffer from illegal fishing, pollution, and destruction of their habitats. At the same time, historically, fishing in the Black Sea has always been an important economic activity. Today, it still plays a central role, proving the sustainable development of the region. We need to admit that there are still gaps and lack of scientific knowledge and ­information on many processes and phenomena that are needed for policy and decision-making. And some concrete measures have been already taken by the individual countries, as well as within the collaboration of countries under the Bucharest Convention and GFCM in the region in addressing the ecosystem approach for fisheries.

We have been closely collaborating with GFCM since we signed an MoU between our organizations in 2012. We have carried out joint activities, such as workshops on IUU (illegal, unregulated, unreported fisheries). On a regular basis we cooperate within activities of the GFCM Working Group on the Black Sea, within work of our dedicated Advisory Group on Fisheries (FOMLR Advisory Group), we are working on the joint initiative with GFCM and ACCOBAMS to address the issues of sustainable fisheries reflected in three bilateral MoUs signed between each of us, and, of course, we support our joint efforts. In order to avoid duplication of our activities in the region, as I mentioned, we agreed on the unique list of Fisheries Indicators for annual reporting and continuously supporting the BlackSea4Fish Project under GFCM umbrella and other similar initiatives in the region.

The BSC also cooperates with other institutions such as the ICPDR, EEA, ACCOBAMS, and UNEP. Which are the areas in which the BSC works together with these other organisations and what have been the results of this collaboration? Does the BSC also work with non-governmental organisations to achieve its goals?

Indeed, we have very close collaboration with all the organizations you mentioned. We all serve as observers to each other attend each other’s activities and with most of them we also have signed MoUs or similar arrangements.

Since 2001 we are implementing the MoU between the Black Sea Commission and ICPDR on common strategic goals, given the fact that we have common goals and objectives to prevent pollution loads and conservation of the riverine and marine environment and ecosystems by assessing the current status of Danube loads on the Black Sea ecosystems. For that, the Commissions agreed to regularly exchange the necessary data sets. The dedicated Danube – Black Sea Joint Technical Working Group (JTWG) was established in 2011 and the above-mentioned BSC-ICPDR reporting format was elaborated and agreed between the experts. Later on, this format was included as an Annex to our monitoring programme and we have already for some years exchanged summary reports which reflect the effect of the Danube loads on the marine ecosystem.

Since 2012, in line with the Memorandum of Understanding between the Black Sea Commission and ACCOBAMS, our Permanent Secretariat is exercising its role as the Black Sea Sub Regional Coordination Unit for ACCOBAMS regarding the conservation of the cetaceans of the Black Sea. As you may guess, since then we have coordinated all our efforts to a large extent, we meet on a regular basis and, of course, cetacean conservation activities were included in all our relevant regional strategic documents.

With the EEA we closely work on indicators and on the implementation of the MSFD Directive in the region, as we still have some countries who are not bound by its provisions and we need to make sure that the approaches on the regional level are harmonised to the extent possible.


As for UNEP, we are part and parcel of the UNEP Regional Seas family, meeting with other regional seas on a regular basis and closely collaborating on all issues of our common concern. We participated in UNEP activities on the elaboration of indicators for Global Assessment, in all the activities of UNEP Global Initiative on Marine Litter, as well as in UN Regular Process on Global Reporting (World Ocean Assessment II).

NGOs are represented as observers at our meetings and we are always happy to ­coordinate our dedicated project and public activities with them, let alone that we are also members of EU4Oceans Coalition.

The BSC will soon celebrate its 30th anniversary. What would you say have been the main achievements of the organisation since its founding in 1992? How have the challenges facing the Black Sea evolved over this period and how has the BSC responded to threats such as marine litter?

The main achievement of the Black Sea Commission since its founding was that it became one of the best known Regional Sea Conventions and instruments of the International Environmental Law in the Black Sea basin, it in fact serves as a framework, a forum for cooperation, it undoubtedly provided the legal ground for combating pollution from land-based sources and maritime transport, achieving sustainable management of marine living resources and sustainable human development in the Black Sea Region. Moreover, it is also the only existing legal instrument in the field of marine environment which has all the Black Sea riparian countries as signatories. The activities implemented so far by the relevant Convention bodies allowed a significant increase in public involvement, address transboundary environmental issues, and introduce sound environmental decision-making related to the sustainable use of the resources of the Black Sea.

At the same time, given the rapid development of environmental science, modern trends, and new challenges in the implementation of the Bucharest Convention’s provisions (which was elaborated and entered into force 30 years ago), newly arising partnerships, initiatives, and stakeholders. It is obvious that issues of sustainable management of marine resources are staying crucial on the agenda of the Convention’s implementing bodies. We did our best to take into account the issues of present common concerns, which were either not introduced or not enough reflected in the past in our activities, such as climate changes, marine litter, and many others.

Regarding marine litter, let me recall one of our major recent achievements – the adoption of the Regional Action Plan for ML management in the Black Sea (October 2018) and the elaboration of the draft ML Monitoring Guidelines, which are currently being discussed by all the stakeholders in the region. Both documents were elaborated within our collaboration with the Mediterranean Sea and in line with the Memorandum of Understanding between our Secretariats signed in 2016. The aim of the MoU was to increase interaction and exchange of information and experts among our regions, sharing the best practices on the topics of common concern. We also established a mechanism for regular bilateral cooperation between the Secretariats, which is now used as an example of successful collaboration between the Regional Seas on the global level. We organized already three annual joint meetings between both Secretariats, prepared a joint work plan, and carried out the regional workshop on marine litter, where we presented best practices and status of implementation of our Regional Monitoring Programme and Action Plan on Marine litter management, as well as updated ML indicators.

Let me also mention that we are being involved in all global activities within the work of UNEP Global Group on Indicators, in drafting the World Ocean Assessment Report II, within activities of Sustainable Ocean Initiative (SOI), UNEP Global Initiative on Marine Litter, and others.

The Mediterranean and Black Sea have the highest proportion of stocks fished at unsustainable levels of any of the FAO’s 16 major fishing areas, according to SOFIA 2020. What initiatives is the BSC taking that will help to improve the status of stocks in the Black Sea?

As it was already mentioned, sustainable marine living resources management is a subject of BSC cooperation with its observers, partners, and projects, i.e. UN GFCM and ACCOBAMS Agreements.

Apart from cooperation with GFCM, which I already mentioned, within our structure, we have dedicated groups dealing with issues of protection and sustainable management of fisheries and marine living resources, i.e. Advisory Group on the Environmental Aspects of the Management of Fisheries and other Marine Living Resources (FOMLR AG), Advisory Group on the Conservation of Biological Diversity (CBD AG) and Advisory Group on the Pollution Monitoring and Assessment (PMA).

The FOMLR AG is responsible for preparation the recommendations and documents to be considered by the Black Sea Commission and the regional coordination of (1) development of fisheries specific indicators; (2) creation, maintenance and upgrading of the Black Sea Fisheries Database; (3) development and promotion of standardized techniques of the catch estimates, assessment methods for stocks and exploitable biomass of key species; (4) facilitation of annual exchanges of national fisheries statistics data and National Fishery Researches Reports; (5) coordination of regular stock assessments and common vessel surveys; (6) preparation of recommendations for management plans for selected key fish stocks and draft common fisheries management procedures; (7) preparation and coordination of the specific projects for protection and rehabilitation of the critical habitats and threatened key species; (8) preparation and coordination of specific projects for development of marine aqua culture in the Black Sea area; (8) cooperation with relevant international and regional fisheries organizations; (9) development of a set of technical guidelines to assure the uniformity of measurements and establish the quality assurance system in the regional and national fishery monitoring efforts.

At the same time, the Bucharest Convention may be classified as a “soft law” instrument which in fact means that no instruments of enforcement are foreseen and there is also a lack of infringement procedures. This leads to a fact that sustainable management of fisheries and other living resources is not accurately ensured in the Black Sea basin, therefore, further steps to fight these challenges are needed.

While the environment in the western Black Sea has improved thanks to a decline in nitrogen and phosphorus discharges, overfishing is still a threat. Fisheries have economic, social, and cultural implications that make it a difficult subject for countries to tackle. How can the BSC assist countries in bringing fishing capacity in balance with the available resources?

Indeed, eutrophication, pollution, and irresponsible fishing resulted in an overall decline of biological resources, the diversity of species and landscapes, and of the aesthetic and recreational values of the Black Sea. The fish stocks of commercially valuable species, such as sturgeons and turbots, suffer from illegal fishing, pollution, and destruction of their habitats.

Illegal, unreported and unregulated (IUU) fishing has always been a problematic issue for the Black Sea basin. In fact, it is not effectively covered by the Bucharest Convention itself and none of its satellite documents. Given this, the first activity under the MoU with GFCM was a Joint GFCM-BSC Workshop on IUU fishing. The extent and the nature of IUU fishing were carefully assessed and consequences associated with IUU fishing were also examined together with measures to fight it available at the international and regional levels. The main outcome of this activity was the development of a Roadmap identifying actions, objectives, means, and actors of relevance for the Black Sea in order to fight IUU fishing. Within the legal aspects of the Roadmap, the two main objectives were identified: (1) Develop a regional plan of action to fight IUU fishing and related activities in the Black Sea due to the lack of common rules shared by Black Sea riparian States, coupled with the joint dimension of the problems posed by IUU fishing, and (2) Elaborate a regional strategy to regulate small scale fisheries in the Black Sea due to the fact that small scale fisheries account for an important share of the fish caught in the GFCM area. Unfortunately, the Roadmap along with the Regional Strategy has not yet been endorsed by the Black Sea Commission and stays on the agenda for the entire Black Sea region.

Global warming is among the stressors that threaten fish stocks, in particular those that are poorly managed. What manifestations of global warming are apparent in the Black Sea and what mitigation measures is the BSC encouraging riparian countries to implement?

Climate change is a comparatively new challenge for us and it was recognized as a threat to the environment, but for different reasons, this concept was not properly introduced to the text of the Bucharest Convention and its Protocols. The mentioning of this issue one may find only in the latest version of the Black Sea Strategic Action Plan (2009), where climate change was considered to be a global contributory factor to all four transboundary problems, but it was included in our activities with the intention only to investigate the impacts of this phenomenon. At the moment we collect annual information on the precipitation and changes in the sea level, at the same time, considering the global nature of this phenomenon, the climate changes need to be introduced into the activities and documents of the Bucharest Convention and additional efforts must be taken to assess and eliminate the consequences of the climate changes for the Black Sea.

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