Communication from the Commission to the European Parliament pursuant to the second subparagraph of Article 251 (2) of the EC Treaty concerning the Common position of the Council on the adoption of a European Parliament and Council Directive establishing a Framework for Community Action in the field of Marine Environmental Policy (Marine Strategy Framework Directive)
Date: 2007-07-24
Institutions: European Commission
Subjects: EU programme, action programme, environmental policy, environmental protection, marine environment

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 24.7.2007 
COM(2007) 456 final 

2005/0211 (COD) 

COMMUNICATION FROM THE COMMISSION 
TO THE EUROPEAN PARLIAMENT 

pursuant to the second subparagraph of Article 251 (2) of the EC Treaty 

concerning the 

Common position of the Council on the adoption of a European Parliament and Council 
Directive establishing a Framework for Community Action in the field of Marine 
Environmental Policy (Marine Strategy Framework Directive)  

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2005/0211 (COD) 

COMMUNICATION FROM THE COMMISSION 
TO THE EUROPEAN PARLIAMENT 

pursuant to the second subparagraph of Article 251 (2) of the EC Treaty 

concerning the 

Common position of the Council on the adoption of a European Parliament and Council 
Directive establishing a Framework for Community Action in the field of Marine 
Environmental Policy (Marine Strategy Framework Directive)  

(Text with EEA relevance) 

1. 

BACKGROUND 

Date of transmission of the proposal to the EP and the Council 
(document COM(2005)505 final – 2005/0211/COD): 

Date  of  the  opinion  of  the  European  Economic  and  Social 
Committee: 

Date of the opinion of the Committee of the Regions: 

Date of the opinion of the European Parliament, first reading: 

Date of adoption of the Common Position: 

24.10.2005

20.04.2006

26.04.2006

14.11.2006

23.07.2007

2. 

OBJECTIVE OF THE COMMISSION PROPOSAL 

Europe’s  marine  environment  is  faced  with  increasing  and  severe  threats.  Europe’s  marine 
biodiversity  is  decreasing  and  continues  to  be  altered.  Marine  habitats  are  being  destroyed, 
degraded  and  disturbed.  Additional  difficulties  include  institutional  barriers  to  improved 
protection of Europe’s marine environment as well as significant information and knowledge 
gaps. 

The  current  deterioration  of  the  marine  environment  and  the  associated  erosion  of  its 
ecological capital jeopardises the generation of wealth and employment opportunities derived 
from Europe’s oceans and seas. If not addressed, this will undermine the capacity of the EU 
maritime cluster to make a strong contribution to the Lisbon agenda. 

The  objective  of  the  proposed  Marine  Strategy  Framework  Directive  is  to  restore  the 
ecological  health  of  Europe's  oceans  and  seas  by  achieving  and  maintaining  their  "Good 
Environmental  Status"  by  2021.  Given  the  diverse  conditions  and  problems  of  the  marine 
environment  in  the  EU,  the  proposal  establishes  European  Marine  Regions  on  the  basis  of 
geographical and environmental criteria.  

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No specific management measures will be set down at EU level. The Directive will provide 
an integrated policy framework taking into account all pressures and impacts and setting clear 
and  operational  actions  in  order  to  protect  the  marine  environment  more  effectively.  The 
Directive will have to be made operational and implemented at the level of Marine Regions.  

The Strategies will be based in a first phase on assessments of the state of the environment in 
order  to  develop  informed  policy-making  supported  by  the  best  scientific  knowledge 
available.  In  a  second  phase,  each  Member  State,  in  close  cooperation  with  other  Member 
States  and  relevant  third  countries  within  a  Marine  Region,  will  develop  and  implement 
Marine Strategies for its marine waters aimed at achieving "Good Environmental Status". In 
developing  Marine  Strategies,  Member  States  will  be  encouraged  to  work  within  the 
framework  of  existing  regional  seas  conventions  –  OSPAR  for  the  Northeast  Atlantic, 
HELCOM for the Baltic Sea, Barcelona Convention for the Mediterranean Sea and Bucharest 
Convention for the Black Sea. 

The  proposed  Marine  Strategy  Directive  is  included  in  the  Sixth  Environment  Action 
Programme adopted in 2002. The Directive is also to be seen within the broader context of the 
development of a new EU Maritime Policy announced in the Green Paper entitled Towards a 
future Maritime Policy for the Union: A European vision for the oceans and seas adopted by 
the  Commission  on  7  June  20061.  The  proposed  Marine  Strategy  Framework  Directive  will 
deliver the environmental pillar of the future EU Maritime Policy. 

3. 

COMMENTS ON THE COMMON POSITION 

3.1 

General Comments 

The Commission accepted totally, in part or in principle 52 of the 87 amendments voted by 
the European Parliament in the first reading. 37 of these 52 amendments are incorporated in 
the Common Position.  

The Commission accepted amendments which led to the recognition of the importance of the 
ecosystem approach to managing Europe's marine environment; of joint cooperation between 
Member  States  and  non-EU  countries  for  developing  and  implementing  marine  strategies 
regionally;  and  of  the  need  to  advance  environmental  integration.  The  Commission  also 
accepted  amendments  which  led  to  clarifications  of  the  text,  in  particular  with  regards  to 
definitions; links with relevant Directives (e.g. Water Framework Directive, Birds Directive, 
Habitats  Directive);  geographical  coverage  (extension  of  the  scope  of  the  Directive  to  the 
Black  Sea);  references  to  relevant  international  agreements;  and  inclusion  of  certain 
descriptors of "Good Environmental Status".  

The  Commission  rejected  amendments  which  would  bring  forward  the  timetable  for 
implementation  as  this  would  not  be  realistic.  The  Commission  also  rejected  amendments 
introducing  the  compulsory  designation  of  marine  protected  areas  in  the  Directive.  These 
areas should be seen as a means to reaching "Good Environmental Status" rather than as an 
end in themselves and should therefore be optional. On the important issue of the introduction 
of  descriptors  of  "Good  Environmental  Status",  the  Commission  could  accept  some  of  the 
suggestions  of  the  Parliament,  but  has  a  clear  preference  for  descriptors  focused  on 

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environmental  quality  elements  rather  than  on  specific  pressures.  Taking  only  a  pressure-
based approach would inevitably lead to overlooking potential risks and threats and would not 
enable the EU to move away from a fragmented approach to the management of the marine 
environment.  Finally,  the  Commission  rejected  amendments  calling  for  ad  hoc  financial 
support  to  implementation  of  the  proposed  Marine  Directive  or  granting  certain  regions  a 
special status. 

3.2 

Detailed Comments 

3.2.1 

Parliamentary Amendments accepted by the Commission and incorporated in full or 
in part in the Common Position 

The following amendments were adequately introduced into the Common Position: numbers 
1, 3, 6, 7, 8, 12, 15, 16, 18, 22, 23 (recitals), 25, 26, 27, 28, 29, 31, 33, 36, 37, 39, 41, 42, 43, 
47, 48, 49, 50, 51, 53, 56, 60, 63, 70, 75, 77 and 84 (articles). 

Amendment 1 on the expansion of the geographical coverage of the Directive in particular to 
the Black Sea has been taken on board by the Council apart from the reference to the Arctic 
Ocean. Amendment 3, highlighting demands on oceans and seas, Amendment 6, stressing the 
importance  of  ecosystems  and  Amendment  7,  referring  to  biological  and  environmental 
targets, were retained in part. 

Amendment  8  was  introduced  in  part.  The  reference  to  integration  was  redrafted  in  such  a 
way that it is now fully acceptable to the Commission.  

Amendment  12  on  the  importance  of  cooperation  with  third  countries  was  largely  taken  on 
board (e.g. 18), with the exception of the idea of launching partnerships.  

Amendment 15 on cost-effectiveness and research and monitoring needs was incorporated.  

Amendment 16 adding a reference to ecological functions was also largely integrated.  

Amendment  18  on  the  importance  of  marine  research  in  the  7th  Framework  Programme  for 
Research was largely taken on board.  

Amendment  22  underlining  the  need  for  the  Common  Fisheries  Policy  to  take  into  account 
this Directive was retained.  

Amendment  23, 
precautionary approach was incorporated in recitals (5), (7) and (40). 

inserting  references 

the  ecosystem-based  approach  and 

to 

to 

the 

Amendment  25,  introducing  useful  references  to  the  quality  of  waters  in  applicant  and 
associated states, is indirectly covered in Article 6, addressing cooperation between Member 
States and with third countries. 

Amendment 84, including a reference to Marine Protected Areas in a new recital, was fully 
included.  

Amendment  26  relating  to  existing  obligations,  commitments  and  initiatives  at  international 
level  is  partly  introduced  in  the  definition  of  'marine  waters'  (Article  3)  in  the  Common 
Position through the reference to the UN Convention on the Law of the Sea.  

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Amendment  27  is  introduced  in  Article  3  listing  definitions.  As  in  the  amendment  of  the 
European  Parliament,  definitions  cover  'Marine  Waters',  'Environmental  Status',  'Good 
Environmental  Status',  'Pollution'.  However,  definitions  sometimes  differ  in  substance.  In 
particular, the definition of 'Marine Waters' introduced in the Common Position is limited to 
waters  on  the  seaward  side  of  the  baseline  from  which  the  extent  of  territorial  waters  is 
measured,  limiting  cross-coverage  with  the  waters  on  the  seaward  side  of  the  baseline  to 
which  the  Water  Framework  Directive  applies  to  the  coverage  of  elements  relevant  for  the 
protection  of  the  marine  environment  which  are  outside  the  scope  of  that  Directive.  On  the 
contrary, the definition in Amendment 27 includes tidal waters, thus creating a broader cross-
coverage with the waters covered by Water Framework Directive. In addition, the definition 
of  'Good  Environmental  Status'  provided  in  the  Common  Position  is  not  as  detailed  as  in 
Amendment  27.  Finally,  Amendment  27  includes  a  definition  of  'Marine  Protected  Areas' 
which  is  not  introduced  in  the  Common  Position;  and  conversely,  the  Common  Position 
introduces  definitions  which  do  not  appear  in  Amendment  27  ('Environmental  target', 
'Specific Area', 'Regional Cooperation' and 'Regional Seas Cooperation').  

Amendment 28 is retained through the addition of the Black Sea to the list of Marine Regions 
(Article 4). 

Amendment  29,  which  introduces  a  reference  to  the  need  for  coherence  with  relevant 
international  agreements,  is  indirectly  and  partly  introduced  in  the  Common  Position  (i.e. 
reference to coherence with the UN Convention on the Law of the Sea in Article 3). 

Amendment  31  is  included  in  the  Common  Position  if  coordinated  marine  strategies  per 
region are understood as a compilation of national strategies and not a single regional marine 
strategy.  Indeed,  the  stronger  emphasis  placed  on  regional  cooperation  in  the  Common 
Position  (Article  6)  should  contribute  to  the  preparation  of  well  coordinated  strategies  at 
regional  and  sub-regional  level.  Amendments  33,  37  and  47,  which  also  suggest  the 
preparation of regional marine strategies, are also introduced (Article 6) on the condition that 
regional  marine  strategies  are  again  understood  as  a  compilation  of  national  strategies,  not 
implying collective responsibility. 

Amendment 36 is introduced (Article 5(3)) to the extent that it would recognise a fast-track 
implementation mechanism. The link to EU support introduced is partly taken on board – in a 
way  which  is  acceptable  to  the  Commission  –  in  Article  5  through  the  reference  to  an 
invitation for supportive action from the Commission. 

Amendment  39  on  Marine  Protected  Areas  is  introduced  in  Article  13.4  in  the  Common 
Position,  with  the  exception  of  the  obligation  to  establish  such  areas  introduced  by  the 
Parliament, which was not acceptable to the Commission. 

Amendment 41 on regional cooperation is covered in Article 6 of the Common position. The 
same holds for Amendments 42 and 43 – apart from the reference to cooperation with third 
countries whose flag vessels operate in EU marine regions.  

Amendment 48 suggests introducing a reference to ecosystem functions in Article 8. This is 
catered  for  in  the  Common  Position  although  such  a  reference  appears  in  Article  3(4) 
(definition of 'Environmental Status') instead.  

Amendment  49  relating  mainly  to  the  need  to  take  into  consideration  relevant  existing 
assessments when producing the initial assessment foreseen in Article 8 is introduced in the 

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Common Position through the inclusion of a reference to "other relevant assessments such as 
those carried out jointly in the context of Regional Seas Conventions" in Article 8(2). 

Amendment  51,  which  establishes  specific  requirements  as  regards  coordination  and 
consistency of assessments, is indirectly introduced in the above mentioned addition to Article 
8.2 as well as stronger language on regional cooperation in the Common Position. 

Amendment  53  is  partly  taken  on  board  in  the  Common  Position.  While  the  wording 
adjustments  introduced  by  the  Parliament  were  not  included,  both  institutions  agreed  to  the 
need to include a reference to a new Annex (Annex I) on generic qualitative descriptors. It has 
to be noted, however, that there are strong divergences between the Council and the European 
Parliament on the contents of these Annexes.  

Amendment 56, which relates mainly to the inclusion of references to the Birds and Habitats 
Directives  (79/409/EC  and  92/43/EC)  in  Article  11  (Monitoring  Programmes)  is  partly 
covered  as  the  Common  Position  introduces  references  to  both  Directives  in  Article  13 
(Programmes  of  measures).  The  additional  reference  to  Global  Monitoring  for  Environment 
and Security (GMES) in Amendment 56 is not taken on board. While references to specific 
water directives (91/271/EEC, 2006/7/EC) made in Amendments 50 and 63 are not formally 
retained, the Common Position includes references to 'other relevant assessments' in Article 
8(2)  and  to  'relevant  measures  required  under  Community  legislation'  in  Article  13.2,  thus 
implicitly covering these points. 

Amendment 60 is indirectly covered, albeit partly. Indeed, a reference to the ecosystem-based 
approach  appears  in  the  Common  Position  (Article  1).  A  reference  to  the  precautionary 
principle  appears  in  recitals.  Prevention  action,  the  polluter  pays  principle  or  transboundary 
impacts are not explicitly included. 

Amendment 70 requiring the Commission to produce a report four years after implementation 
on potential conflicts was only partly and indirectly taken on board in the Common Position 
(Article 20) which includes under (g) 'a summary of the contribution made by other relevant 
EC policies to the attainment of the objectives of this Directive'. 

Amendments  75  and  77,  which  bring  the  text  in  line  with  decision  2006/512/EC  on 
Comitology, have been taken on board (Articles 22 and 23).  

3.2.2 

Parliamentary  Amendments  accepted  by  the  Commission  but  not  in  the  Common 
Position 

On  the  recitals,  Amendment  2  stating  the  fact  that  the  EU  is  a  peninsula  was  not  taken  on 
board. Amendment 9 on regional cooperation was not retained.  

Amendment 46, qualifying competent authorities ("national"), was not incorporated.  

Amendments 52 and 58 on data access and availability rules have not been taken on board in 
the  Common  Position  although  Article  8(2)  does  refer  to  other  relevant  assessments  carried 
out  in  the  context  of  regional  seas  conventions.  However,  the  reference  to  the  obligation  to 
transmit the assessments and monitoring programmes to the European Environment Agency 
has  not  been  taken  on  board.  Finally,  the  Commission  reservation  about  the  absence  of 
reference  to  the  INSPIRE  Directive  in  the  Parliament's  amendments  is  addressed  in  Article 
19(3) in the Common Position.  

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Amendment 55 was not taken on board. Neither the reference to the need to take into account 
elements  of  transboundary  importance  when  establishing  environmental  objectives,  which 
was  acceptable  to  the  Commission,  nor  the  rest  of  the  amendment  relating  to  the 
implementation timetable, which the Commission did not support, was included.  

Amendment 57, relating to the introduction of a requirement for cooperation among Member 
States to ensure that monitoring methods are coherent, was not taken on board in the Common 
Position. 

Amendment  66  was  essentially  not  taken  on  board,  although  both  institutions  agreed  to 
rename Article 14 'Exceptions'. The Common Position does not include a reference to climate 
change  which  the  Commission  could  support.  Moreover,  the  elements  of  the  Parliament's 
amendments  which  were  not  acceptable  to  the  Commission  because  of  their  geographical 
focus were not taken on board. However, the Parliament's introduction of an obligation to the 
Commission to respond to Member States when the power to adopt measures rests with the 
Community  is  largely  taken  on  board  in  the  Common  Position,  but  in  a  different  article 
(Article 15).  

Amendments 67 and 68, concerning the establishment of stakeholder consultation processes, 
were not taken on board.  

Amendment 73, clarifying the objectives of the review of the directive, was not included in 
the Common Position.  

Amendments  80,  81,  82,  91  and  92  concerning  descriptors  of  Good  Environmental  Status 
constitute a much more extensive list of descriptors than the equivalent list established in the 
Common Position (21 elements against 11). The principal difference lies in the inclusion by 
the Parliament of some nine descriptors which require the description of good environmental 
status  in  terms  of  pressures  from  specific  human  activities  (such  as  offshore  industry 
(elements  l,  n),  shipping  (elements  m  and  o),  other  human  activities  (elements  p  to  t)).  The 
Common Position does reflect, albeit in a more synoptic manner, a number of the other 'state' 
or 'impact'-based descriptors. 

3.2.3 

Parliamentary  Amendments  rejected  by  the  Commission  but  part  of  the  Common 
Position 

Amendment 38 granting the Baltic Sea pilot status was not explicitly taken on board but the 
possibility of the designation of 'pilot projects' as part of the implementation of the directive 
was recognised in the Common Position (Article 5(3)).  

Amendments  62  and  64  introducing  an  obligation  to  designate  Marine  Protected  Areas 
(MPAs) were not incorporated in the Common Position to the full extent. However, they were 
partly  reflected  in  the  addition  of  two  sub-paragraphs  on  the  inclusion  of  MPAs  as  part  of 
programmes of measures to be developed (Article 13(4)). It is to be noted that the wording of 
the Common Position does not introduce an obligation to establish MPAs.  

3.2.4 

Parliamentary amendments rejected by the Commission and not incorporated in the 
Common Position 

On  recitals,  Amendment  4  singling  out  the  Baltic  Sea  was  rejected.  Amendment  5  on 
quantitative  and  qualitative  objectives  was  not  retained.  Amendment  10  calling  for 

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coordination  between  Member  States  and  third  countries  as  regards  flag  states  operating 
fishing  vessels  in  EU  marine  waters  was  rejected.  Amendment  11  on  the  rationality  of  the 
Natura 2000 network  was  also  rejected. Amendments 13 and  17, giving research priority to 
certain areas, were note retained.  

Amendments 14 and 88, requiring the setting up of ad hoc structures at Member State level to 
organise cross-sectoral cooperation, were rejected. 

Amendments  19  and  74,  relating  to  Community  financial  support  to  implementation,  were 
also rejected. 

Amendments 20, 34, 35, 69, 79 and 85, bringing all implementation deadlines forward, were 
not taken on board. 

Amendment 21, which contradicts the Treaty as regards treatment of fisheries management, 
was not retained. 

Amendment 30, adding Croatia to the list of Member States in the Adriatic Sea (Article 4), 
was  not  retained.  Indeed,  the  Council  opted  for  a  complete  deletion  of  any  references  to 
Member States in that Article.  

Amendment  32,  strengthening  the  obligation  to  achieve  'Good  Environmental  Status',  was 
rejected. The Common Position softened the initial Commission text on this important issue. 

Amendment 40, modifying the title of Article 6, was not retained.  

Amendment  44,  introducing  a  specific  regulatory  framework  focused  on  infrastructure 
projects in the marine environment, was rejected. 

Amendment 45, concerning the Common Agricultural Policy, was not retained. 

Amendment  54,  deleting  all  references  to  comitology  for  the  further  development  of 
descriptors of 'Good Environmental Status', was not retained. 

Amendments 59 and 61, including language on the adoption of measures and programmes on 
traceability and tracking of marine pollution, were rejected.  

Amendment  65,  requiring  the  Commission  to  produce  criteria  for  good  oceans  governance, 
was not retained.  

Amendment 71, introducing obligations for the protection of the Arctic Ocean, was rejected. 

Amendment  72,  which  deals  with  Marine  Protected  Areas  and  requires  the  production  of 
progress reports on their establishment, was not retained. 

Amendment  76,  requiring  the  new  scrutiny  regulatory  procedure  on  comitology  for  the 
adoption of methodological standards, was rejected. 

Amendment 78, which would introduce obligations for Member States in waters beyond EU 
jurisdiction or sovereignty, was not retained. 

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Amendment  90,  which  would  result  in  the  deletion  of  radio-nuclides  from  the  list  of 
substances to be assessed, was not taken on board.  

3.2.5 

Additional Changes made to the Proposal by the Council 

The  Common  Position  contains  a  number  of  important  changes  compared  to  the 
Commission’s original proposal. These changes regrettably weaken the proposal.  

The most important changes relate to: 

–  The  lower  level  of  ambition  of  the  Directive  resulting  from  the  modification  of 
Article 1.  While  the  original  Commission  proposal  required  the  development  of  Marine 
Strategies  'designed  to  achieve  Good  Environmental  Status',  the  Common  Position 
softened  this  obligation  by  referring  to  'with  the  aim  of  achieving  Good  Environmental 
Status'. 

However,  and  more  positively,  Member  States  will  still  be  required  to  demonstrate  an 
overall positive trend towards Good Environmental Status by 2021. Based on the Common 
Position, it would not be enough to produce Marine Strategies by 2021 if those Strategies 
did not lead to enhanced protection of the marine environment.   

In  addition,  the  ultimate  objective  of  the  Directive  does  remain  the  full  achievement  of 
Good  Environmental  Status  as  other  references  to  this  concept  in  the  Directive  have  not 
been modified (e.g. in Article 13).  

–  Introduction  of  a  new  provision  exonerating  Member  States  from  taking  certain 
implementation steps where there is no significant risk to the marine environment or 
where  costs  would  be  disproportionate:  The  introduction  of  this  new  provision  is  an 
addition  to  already  existing  safeguards  on  implementation  costs  in  the  draft  proposal  (in 
particular  Article  13(3)).  The  need  to  demonstrate  the  absence  of  significant  risks  or  the 
occurrence  of  disproportionate  costs  is  not  made  sufficiently  explicit  in  the  Common 
Position.  

Other important changes are as follows: 

–  Geographical  articulation  between  the  Marine  Strategy  and  the  Water  Framework 
Directive: The definition of marine waters in Article3 was modified to indicate that marine 
waters shall be extended to marine waters covered by the Water Framework Directive as 
far  as  important  marine  ecosystem  elements  not  covered  by  the  Water  Framework 
Directive  are  concerned.  An  extension  of  the  scope  of  the  Marine  Directive  to  marine 
waters covered by the Water Framework Directive is necessary in order to ensure coherent 
implementation  of  both  Directives  as  marine  ecosystems  do  not  respect  artificial 
administrative  boundaries.  A  more  comprehensive  geographical  interaction  between  the 
two  directives,  covering  also  coastal  and  even  transitional  waters  (i.e.  bodies  of  surface 
water in the vicinity of river mouths which are partly saline in character as a result of their 
proximity to coastal waters) would have been preferable.  

–  Commission  control  of  implementation  (Articles  12  and  16):  The  Common  Position 
loosens Commission control of implementation, now limited to advice based on Member 
States' notifications.  

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–  New provision on a fast-track implementation scheme for pilot projects (Article 5(3)): 
The  Common  Position  inserts  a  new  provision  on  the  possibility  to  speed  up 
implementation  in  so-called  pilot  project  regions  to  be  identified  by  Member  States 
concerned.  

–  Deletion of references to Member States in Article 4: The Common Position simply lists 
Marine  Regions  and  suggested  Sub-Regions,  without  specifying  which  Member  States 
border these Regions and Sub-Regions.  

4. 

CONCLUSION 

The Commission considers that the Common Position, adopted by all but one Member States 
(Italy abstained), is an important step towards the adoption of the Marine Strategy Framework 
Directive.  

However,  the  Commission  notes  that  the  Common  Position  is  not  as  ambitious  as  the 
Commission's initial proposal in particular as regards its overall ambition, the binding nature 
of the good environmental status objective, and implementation costs. On this last point, the 
Commission  wishes  to  recall  that  good  policy  depends  on  high-quality  information  and 
current  assessment  and  monitoring  programmes  at  EU  level  are  neither  integrated  nor 
complete.  

More  positively,  the  Commission  is  pleased  that  the  Common  Position  fully  recognises  the 
strong  need  for  a  European  integrated  approach  to  protect  our  oceans  and  seas  more 
effectively. References to the importance of co-operation and co-ordination between Member 
States  and  non-EU  countries  for  developing  and  implementing  marine  strategies  regionally 
are  also  positive.  Finally,  the  addition  of  elements  of  definition  of  "Good  Environmental 
Status" is also useful although the Commission would prefer definitions which are focused on 
environmental quality elements rather than specific pressures.  

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