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GPSAZORES

GPS Azores – Geographical and Political Scenarios

and Maritime Spatial Planning for the Azores and North Atlantic

Report Title: Analysis and Comparison of the Legal Frameworks of the North Atlantic Countries Project Coordinator: Prof Helena Calado (University of the Azores) Report Authors: MD. Mostafa Monwar – (MM), Evangelia Tzika – (ET), Ana Vitoria Magalhães – (AVM), Henriette Grimmel – (HG); Fabiana Moniz - (FM); Marie Bonnin - (MB); Helena Calado – (HC)

WP and Task 1: International Legal and Political Framework

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PROJECT TEAM: Universidade dos Açores- Fundação Gaspar Frutuoso (FGF): Helena Calado (HC) (Coordinator) Fabiana Moniz (FM) Marta Vergílio (MV) Ana Cristina Costa (ACC) Mario Cana Varona (MCV) Artur Gil (AG) Daniela Gabriel (DG) Paulo Borges (PB) António Medeiros (AM) Mario Pinho (MRP) Seascape consultants Ltd David Johnson (DJ) Faculdade de Ciências Sociais e Humanas da Universidade Nova de Lisboa (FCSH-UNL) Carlos Pereira da Silva (CS) Catarina Fonseca (CF) Universidade de Sevilha Juan Vivero (JV) Faculdade de Ciências da Universidade de Lisboa José Guerreiro da Silva (JS) Kiat Ng (KN) Invited Experts Maria da Anunciação Ventura (MAV) Marie Bonnin (MB) Fernando Lopes (FL) Aldino Campos (AC) Marta Chantal Ribeiro (MCR) Marie Bonnin (MB) Invited Young Research Evangelia Tzika - (ET) Elisabetta Menini - (EM) Christine Ladiero – (CL) Ana Vitoria Magalhães – (AVM) MD. Mostafa Monwar (MM) Alison Thieffry (AT) External invited Young Research: Henriette Grimmel – (HG)

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This project was financed in 85% by FEDER and in 15% with regional funds through the Programa Operacional Açores 2020 (Operational Program Azores 2020), in scope of the

project « GPSAZORES -ACORES-01-0145-FEDER-00002».

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ABSTRACT The oceans’ future potential resources and uses, along with the impacts of current marine activities, require coherent management. In the European Union (EU), Member States already follow marine policy guidelines in the Integrated Maritime Policy. Nevertheless, in the North Atlantic Ocean, where regional sea bodies and conventions are in place, the United States (US) and Canada also play essential roles in the marine environment sphere. Providing insight into the marine environmental legislation frameworks of the countries in the North Atlantic Arc and generating a relative comparison of these countries with one another, as well as assessing whether these countries are taking measures to reach the same (policy) goals could set the stage for future strategic collaboration. A horrendogram, such as the one created by Boyes and Elliot (2014) for the United Kingdom (UK), nicely illustrates the existing complexity in environmental legislation. Hence, horrendograms for each studied North Atlantic nation (i.e. Ireland, Iceland, Portugal, Spain, France, the US and Canada) were prepared. They were then each compared to the original, UK, one in order to highlight not only the differences and thereby identify policy gaps but also highlight the commonality of approaches. A fact worthy to be used as a baseline for transnational North Atlantic cooperation.

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INTRODUCTION All global oceans face various environmental problems and are subject to competing spatial claims as well as to conflicts between the many uses and users. This is especially true for bodies of water adjoining developed, industrialized and agricultural regions such as the Atlantic Ocean (van Tatenhove, 2013). The increasing number of anthropogenic activities in the Atlantic Ocean need to be addressed with coordinated and sustained efforts to collectively improve ocean health. To date, certain measures have aimed to protect the marine environment overall but maritime affairs have been dealt with through separate sectoral policies without fully integrating all relevant sectors. The intensive use of the maritime space in the North Atlantic requires a strategic collaborative maritime spatial planning culture, as policies on maritime issues still lack proper integration and cross-sectoral coordination. Therefore, the GPS Azores project aims to fill the knowledge gap regarding the overlap of legislative approaches in the region and support the process of Maritime Spatial Planning (MSP) in Portugal.

The Work Package 1 – ‘Legal Framework’ analyzes the current legal structure of all countries from the North Atlantic Arc (i.e. the UK, Ireland, Iceland, Portugal, Spain, France, the US and Canada) with the exclusion of Greenland. Greenland is an autonomous constituent country of the kingdom of Denmark. In 1979, Denmark granted home rules to Greenland and in 2008, Greenlanders voted in favor of the Self-Government Act, which transferred more power to the local authorities. Under this structure, Greenland assumes responsibility for policing, judicial systems, laws, financial regulation and supervision while the Danish Government retains control of foreign affairs and defense (Michelsen, 2012). Information on existing rules and regulations relating to Greenland’s marine environment are scarce to find, thus an analysis of Greenland was excluded from the present study. The analysis aims to bring to light the most common gaps and investigate the similarities and differences in legal structures across the North Atlantic countries regarding marine environmental issues. It also reveals potential barriers and hurdles for maritime spatial planning (MSP) in the Atlantic. Particularly the identification of differences could be used in the future as guidance to deal with transboundary issues and to facilitate cooperation. The initial part of the project was the development of horrendograms on marine environmental legislation for each of the examined countries within this study. For this, the international, regional and national legislations relating to MSP were analyzed. Particular attention was given to how national circumstances influence ocean governance, linking the implementation of regional initiatives and agreements of ocean management. The study inspects the complexity across the vertical governance levels emanating from the United Nations (UN) as well as other international, regional and

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national bodies. The resulting process is the comparative analysis of international, regional and national legislations of the studied countries through horrendograms. The analysis also includes a more detailed review of MSP policies in place for each country and integrates these in the horrendograms. This focus on maritime spatial planning legislation and regulations presents the core of the project. Additionally, the similarities in legislative approaches and the respective character of the adopted policies are discussed. Finally, the conclusions summarize the focus points relevant for future research and consideration coming from this comparative analysis.

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LITERATURE REVIEW Aside from the preparation of the different horrendograms for the comparative analysis, further data were obtained through the review of scientific literature, which concerns the objectives of this study. Moreover, official organizations’ websites and especially reports from the United Nations’ sister agencies, as well as from the European Union (EU), were examined to support the study. METHODOLOGY Information regarding the status of present legislation for the protection of the marine environment in each of the Atlantic countries (i.e. Portugal, Spain, France, Ireland, Iceland, the US and Canada) was obtained from renowned international, regional and national organizations. It was summarized in the form of ‘horrendograms’ following the example of Boyes and Elliott (2014) with their horrendogram for the United Kingdom. A ‘horrendogram’ illustrates the vertical integration of current legislation, policies and regulations. Each horrendogram consists of five layers as illustrated below (Fig. 1). Legislative and comparative analysis The basis of legislative approaches and comparison to was provided by the first horrendogram of the UK published by Boyes and Elliott (2014). In face of change within the European Union (EU) from a focus on sectoral policies to holistic framework directives and with the passing of the Maritime Spatial Planning (MSP) directive soon after, the authors saw need for a synthesis analysis of EU legislation affecting marine environmental policy and management and provided an example of its complexity with the example of the UK ‘horrendogram’. Since the UK had initiated MSP with a new institutional framework, before the MSP Directive of the EU, it is essentially considered the comparative core between the long established US and Canadian marine policies and the recent European ones. The ‘BREXIT’ factor, however, was not taken into consideration within the frame of this research as it will take another year to come into full effect. The UK has a highly structured legislation system and especially MSP processes are not expected to be radically affected. However, emphasis needs to be put on the collaboration aspects all the more. The figures in the results section present the level of contrasts in the legislative scenery of each country in comparison to the UK, except for Canada. The latter compares best to the United States as both are federal states and have similar institutional approaches.

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Fig. 1: Conceptual diagram of a ‘horrendogram’, explaining the different categories across the circles (Boyes and Elliott, 2014).

The comparison is illustrated in figures, the horrendograms, describing in a clockwise fashion the inner to outer circles and legislative content, thereby reviewing only existing differences. For better representation, discrepancies in the legislative approaches are listed explicitly, though grouped in broader categories based on their legislative targets such as fisheries and aquaculture, food security, flood and risk assessment, MSP, nature conservation, marine heritage, strategic environmental assessment (SEA), environmental impact assessment (EIA), shipping, ocean management, water quality or environmental standards. The last column of the table shows observations and comments to pinpoint the differences in each category. In the horrendograms figures and analysis, colours are used to display the different approaches across the countries in a more illustrative manner. Green represents a country’s unique legislation or policy whereas yellow signifies the differences between the country in question and the UK (except Canada, which is only compared to the US). In order to avoid duplications, the unique characteristics of the UK, being the baseline country in the analysis, are only mentioned once in the first comparison, though all UK figures in the following comparisons include these characteristics. In

International Bodies &

Conventions

International Law or

Commitment

EC Directive

or Strategy

EC Directive

or Strategy

Target / Status

Target / Status

Enabling / Primary

Legislation / National Strategy

Enabling / Primary

Legislation / National Strategy

Implementation method / Protection

afforded

Implementation method / Protection

afforded

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conclusion, the study presents a comparative overview of all selected countries, highlighting differences and showing similarities in legislative approaches. The main aim of the analysis was to provide a general idea of common and shared as well as unique legislative approaches in the North Atlantic Arc region. Thus, the items of legislation with similar document titles were considered similar approaches. Different approaches have been highlighted with a colour within the horrendograms. The assumptions made regarding similarities are not considered to have affected the core of this research nor alter its broad perception, thus the quality of the process was maintained. Adaptations to the horrendograms The development of the individual horrendograms through the analysis of legislation followed, as previously mentioned, the structure of the original horrendogram by Boyes and Elliot (2014). The latter included the Regional Seas Conventions of HELCOM and Bucharest in the circle of International bodies and Conventions, relevant to the UK. However, these conventions were not taken into account within this study as only those Regional Seas programs were considered that the countries are an actual part of (the UK is only part of the OSPAR Convention). The same was applied to other countries, which are members of the OSPAR Convention (OSPAR, 2017). The US, Canada and Iceland participate in another, independent, Regional Seas program for the Arctic Sea, which was included in their corresponding horrendograms to provide a holistic view of their marine environmental legislation despite the Arctic not being part of the study area (UNEP, 2017). The fact that the US recently announced their withdrawal from the United Nations Educational, Scientific and Cultural Organisation (UNESCO) will only come into effect at the end of the next year, so this event remains without affect to the current report. Further, in accordance with the original horrendogram (Boyes and Elliot, 2014), the Biosphere Reserves program was not included within the circle of ‘International Law or Commitment’. However, being as an important conservation program at international level, it was included in the updated versions of the initial horrendograms, with the exception of Iceland, which has not established biosphere reserves to date (UNESCO, 2017). Another critical legislative document regarding marine ecosystem conservation is the Honolulu Strategy - safeguarding the oceans from marine debris - and hence contained within the US’ horrendograms. It was adopted in a cooperative effort of both the National Oceanic and Atmospheric Administration (NOAA) and the United Nations Environment Programme (UNEP) (NOAA, 2017). Outside of the US, except for a few projects in Canada and Europe, no actions were found coming directly from this strategy in the other countries examined. Therefore, the Strategy was removed from the Canadian horrendogram to avoid misinformation (Marine Litter Network, 2017).

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Notwithstanding, another important legislative document considered in this report is the Nagoya Protocol, addressing the access to genetic resources and the fair and equitable sharing of benefits arising from their utilisation to the Convention on Biological Diversity (CDB). The UK, Spain and France ratified it and Portugal approved it. However, the US, Canada, Ireland and Iceland are not parties of the Nagoya Protocol (CBD, 2017). Despite its significance, it is not included in the horrendograms, since the protocol refers to more than just marine genetic resources. The Cartagena Protocol, on the other hand, was included in the horrendograms because the UK, Spain and Ireland ratified it, France approved it and Portugal accepted it. The US, Canada and Iceland, once again, are not parties to the Protocol (CBD, 2016). Further, the information on which countries are parties to the London Protocol and/or Convention was derived from the last International Maritime Organisation (IMO) map (IMO, 2017). Aside from the above-mentioned adaptations to the inner circles of the figures, the only alterations made to the horrendograms’ structure otherwise was the integration of the so-called ‘Blue Flag program’, which is not referred to in the original horrendogram of the UK. It is included in the initial horrendogram of Ireland and integrated in the updated versions of the other countries. It is noteworthy that the US Virgin Islands are the only participating party in the program representing the rest of the US (Blue Flag, 2017). Restrictions of analysis The attempt of comparing marine environmental legislation across several countries has certain risks and limitations. The process of acquiring in-depth knowledge on all policies in all categories goes, in its extent, beyond the scope of the project. Hence, the risk of potentially not evaluating the differences across legislative frameworks thoroughly enough was accepted. Nevertheless, the horrendograms show existing contrasts in the content of the frameworks. RESULTS a) Analysis of existing legislative conditions in the North Atlantic countries Legislative baseline or existing conditions of each of the examined countries were summarised and displayed in the respective horrendograms. Several international conventions, treaties and protocols as well as marine international governing organisations, aiming at the protection of the marine environment, exist. Many countries worldwide have signed and agreed to uphold these conventions, laws and/or commitments. The countries in the present study have common international bodies and conventions, international law or commitments, albeit with some exceptions. All EU North Atlantic countries (i.e. Spain, Portugal, France, the UK and Ireland) abide by the European Commission’s (EC) directives and strategies except for Iceland. The

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United States and Canada on the other hand abide by their own laws. The horrendograms of the eight analysed North Atlantic countries are presented below (Fig. 2 - 9). b) Comparative analysis of the marine environmental policies of the North Atlantic countries The following section goes through the each country’s separate comparison with the UK. Since shared and unique legislation are highlighted in the horrendograms, each comparison is accompanied by two figures (one for each country). As mentioned earlier the policy situation of Canada is compared to the US’ and finally the analysis results of the US versus the UK are presented. Additionally, the maritime spatial planning sector and the relevant approaches are examined for each country more thoroughly, thereby providing the base for the geospatial scenarios in the GPS project. Comparison of the UK (Fig. 2) and Ireland (Fig. 3) The UK and Ireland have similar approaches with regard to their marine environmental policies. Both nations follow the same regulations in respect to international law, commitments and bodies (orange and blue coloured boxes). The red colour-coded boxes of the second circle (from the center) also have the same content as they are comprised mostly of EU directives, conventions and, in general, regulations. Thus, the only concernible differences are at national level (green boxes), though both countries use the same implementation methods (brown boxes). In the fisheries sector, the UK has regulations mostly on salmon, while Ireland has regulations mostly on aquaculture. Furthermore, the latter country has specifications in the safe consumption of fish and shellfish with special policies regarding animal welfare and a monitoring programme on marine biotoxins (COP Biotoxins). Another particularity is observed in Ireland having an Arterial Drainage Act for Flood and Risk Assessment. On the other hand, the UK leads in the marine conservation sector with an Offshore Marine Conservation Act and regulations on endangered species. The last distinctions at national level are apparent in different measures on marine heritage and Environmental Impact Assessment (EIA) categories. It also regulates marine and harbour works with regard to their environmental impact; regulations that the UK stands out with when compared to all other studied countries.

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Fig. 2: Horrendogram of the UK, when compared to the horrendogram of Ireland. Showing international, European and UK legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between the UK and Ireland and highlighted ones in green show legislative policies unique to the UK within the comparison at hand.

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Fig. 3: Horrendogram of Ireland, when compared to the horrendogram of the UK. Showing international, European and Irish legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between Ireland and the UK and highlighted ones in green show legislative policies unique to Ireland within the comparison at hand.

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Ireland has a unique additional Act on Planning and Development of Heritage, while the UK protects its military remains. With regard to the implementation of policies, the UK regulates artificial and heavily modified water, while Ireland regulates surface and ground water through their respective river management plans. Moreover, the UK has three protection measures only found in their horrendogram: one for Good Ecological Status (GES) (using multi-metric indices), one on conserving wider biodiversity and one for environmental standards, the H1 Method of Environmental Assessment and Appraisal of Best Available Techniques. Comparing the UK (Fig. 4) and Iceland (Fig. 5) The second analysis presents UK legislation in comparison to that of Iceland. At international level, Iceland has not created a Biosphere Reserve yet and is not part of the Cartagena Protocol, as mentioned earlier. As a non-EU country, it also has several differences within its horrendogram’s circle of policies. Where the UK adheres to the EU’s Common Fisheries Policy (CFP) and has its Basic Fish Regulations, Iceland has a Fisheries Management Plan and a bilateral agreement with the EU, while also conforming to other directives (European Commission, 2017). Once again, the largest discrepancies are found at national level. Regarding fisheries, Iceland follows an economical focus with Exclusive Economic Zone (EEZ) fisheries, while the UK’s main target remains conservation. In terms of food security, Iceland has regulations on seafood products that are more explicit than those of the UK, whereas the opposite is the case concerning flood risk assessment. Iceland is currently in the process of implementing a flood directive. Further, although both countries have similarly Acts implementing conservation measures, it is worth mentioning that the UK has a Customs and Excise Management Act for the protection of endangered species. With regard to marine archaeology, the UK observes specific legislation on wrecks and merchant shipping, whereas Iceland has an Act on returning cultural goods to the owner countries. In shipping, the UK focuses strongly on coastal and maritime security. Comparing the UK (Fig. 6) and France (Fig. 7) France does not deviate from the UK, as much as other EU countries do; at least not in the first and second circle. The main exception is the targeted aims for the maintenance of healthy and rich biodiversity for conservation purposes. Within the national context, France has adopted extensive aquaculture legislation, similar to Ireland. Further, France has National Strategic Plans to distribute European Fisheries Funds (EFF) as well as a law covering navigation issues. In the energy sector, Climate Change and Electricity Acts as seen in the UK legislation find no equivalent on the French side. Another noticeable difference is concerning water quality. France has its own Public Health Code instead of adhering to the Bathing Water Regulations like the rest of the EU countries.

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Fig. 4: Horrendogram of the UK, when compared to the horrendogram of Iceland. Showing international, European and UK legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between the UK and Iceland and highlighted ones in green show legislative policies unique to the UK within the comparison at hand.

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Fig. 5: Horrendogram of Iceland, when compared to the horrendogram of the UK. Showing international, European and Icelandic legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between Iceland and the UK and highlighted ones in green show legislative policies unique to Iceland within the comparison at hand.

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Fig. 6: Horrendogram of the UK, when compared to the horrendogram of France. Showing international, European and UK legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between the UK and France and highlighted ones in green show legislative policies unique to the UK within the comparison at hand.

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Fig. 7: Horrendogram of France, when compared to the horrendogram of the UK. Showing international, European and Icelandic legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between Iceland and the UK and highlighted ones in green show legislative policies unique to Iceland within the comparison at hand.

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The implementation methods and the protection afforded to the marine environment show additional discernible disparities. In fisheries, France implements catch restrictions and imposes proper labelling for fish and shellfish for safe consumption. France shows a decentralised, shared governing aspect in case of flood and risk assessment, while the UK demands flood risk and hazard maps. Concerning nature conservation in France, stakeholder engagement is emphasized along with strong partnerships, while the UK regulates, as other countries do, by means of site designations, biodiversity and species plans as well as management plans and schemes. Moreover, the UK’s EIAs incorporate nationally significant infrastructure projects, going beyond solely providing marine licenses, whereas France provides consents and authorizations through specific laws. Comparison of the UK (Fig. 8) and Portugal (Fig. 9) Portugal and the UK, both countries following the European approach, do not differ in their first and second circles, with the exception that Portugal is party of the London Convention but not the Protocol, unlike the UK, which is party to both. However, Portugal and the UK have disparities with regard to their national strategies and implementation methods. Portugal has a fisheries strategy based on allocation of EU funds and aquaculture legislation along regulatory licenses for deep-sea fisheries while the UK regulates salmon and freshwater fisheries. Notably, in terms of ocean management, Portugal is the only EU country that has established its own strategy, which is the reason why it is included in the ecological status category. Regulations on maritime spatial planning exist in both countries, with the UK following a national approach and Portugal having specific regulations concerning the Azores region. In nature conservation, the UK takes into consideration the rural communities with the Natural Environment Research Council (NERC) Act and a Wildlife and Countryside Act, whereas Portugal uses a Sustainable Development and a Conservation and Biodiversity strategy. The national approach deriving from the Convention on International Trade in Endangered Species of Wild Fauna and Flora, also known as the Washington Convention (CITES), will change for Portugal, one its Animal Protection Law comes into place. Further, the UK has measures regulating coastal recreation, specific biodiversity and species action plans as well as site designations while Portugal applies the approach of sustainable use of natural resources.

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Fig. 8: Horrendogram of the UK, when compared to the horrendogram of the Portugal. Showing international, European and UK legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between the UK and Portugal and highlighted ones in green show legislative policies unique to the UK within the comparison at hand.

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Fig. 9: Horrendogram of the Portugal, when compared to the horrendogram of the UK. Showing international, European and Portuguese legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between Portugal and the UK and highlighted ones in green show legislative policies unique to Portugal within the comparison at hand.

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In Portugal, decrees and laws regulate Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) while in the UK they are legislated through Acts. The national strategies of these two countries for the implementation of the EIA Directive are different in such that in the UK, the process involves Marine and Harbour work regulations, Town and Country Planning regulations and the Localism Act. Shipping and energy are the last national categories differentiated in the compared countries; the UK has the Harbours, Docks and Piers Clauses Act and Portugal has Law Decrees on salvage and wreck removal and the Island Sustainable Energy Action Plan. In terms of implementation methods, more differences are observed. The focus of flood risk assessment in the UK is having a legally regulated riverine area. In Portugal, it is Flood and Coastal Erosion Risk Management. The implementation of the Water Framework Directive (WFD) differs in the Portuguese and UK approach, as in Portugal it follows licensing, planning, surveillance, supply, demand and infrastructure management measures (a fact unique among all the studied countries), whereas the UK adopts river basin, management plans for heavily modified and artificial water bodies. The application of the Urban Waste Water Treatment (UWWT) Directive is different in both countries. The UK concedes licenses, consents and authorisations on waste treatment and applies waste hierarchy and good practices, whereas Portugal promotes recycling, analysis, inspection and implementation of urban wastewater treatment. Comparison of the UK (Fig. 10) and Spain (Fig. 11) In the following comparative analysis, Spain follows the pattern of other EU countries across the three inner circles, having the same international commitments, EC directives and shared targets as the UK. Hence, the first difference is observed in the national approach, in fisheries. In addition to aquaculture regulations, which all countries analysed up to this point have, and in contrast to the UK, Spanish legislation also regulates illegal fishing. Coastal uses are taken into account by Spanish marine laws. Moreover, similar to the previously compared countries, Spain has Royal Decrees regarding the safe consumption of fish and shellfish (highlighting proper product labelling and hyaline production), though the UK seems to have the least amount of regulations on this issue. The Spanish transposition of the Water Framework Directive involves adopting different legislative tools, such as a Water Act and Water Policy. With regard to nature conservation, the UK remains the only country explicitly conserving offshore regions. However, Spain has a national declaration for Marine Protected Areas (MPAs) and one for the protection of animals. The UK’s approach distinguishes itself further with the Planning and Compulsory Purchase Act on SEAs and the Harbours Acts on shipping. Notwithstanding, Spain is the only studied country that regulates alien invasive species.

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Fig. 10: Horrendogram of the UK, when compared to the horrendogram of Spain. Showing international, European and UK legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between the UK and Spain and highlighted ones in green show legislative policies unique to the UK within the comparison at hand.

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Fig. 11: Horrendogram of Spain, when compared to the horrendogram of the UK. Showing international, European and Spanish legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between Spain and the UK and highlighted ones in green show legislative policies unique to Spain within the comparison at hand.

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The UK and other European countries lack a tool for managing this issue. Similar to France and Portugal, Spain does not have distinctive regulations on climate change; it legislates more on renewable energy, specifically on photovoltaic projects with a Royal Decree. A particularity is observed concerning the legislation on water quality where Spain regulates water reuse instead of urban wastewater treatment as the UK and the rest of the studied countries do. With regard to the environmental standards regulations, Spain presents a more integrated approach than others with a Decree on Landfills and Incineration. From the implementation point of view, there are illegal-fishing-relevant restrictions and strong penalties in Spain. It manages floods risk in terms of riverine areas, similar to Portugal, instead of having coastal erosion risk management such as the UK. For conservation purposes, the UK has implemented biodiversity and species Action Plans, whereas Spain affords care to animals during exploitation, transport, experimentation or sacrifice, being a signatory of the Ramsar Convention. When investigating the differences across national levels, it is worth pointing out that the targets for EIAs are more focused in the UK while enforcement methods for the regulation of invasive species is stronger in Spain. Same as Portugal, Spain emphasizes analysis, inspection and implementation of regulations when it comes to urban wastewater treatment and environmental standards. The UK approaches these categories with hierarchy and good practices. The approach differs further from all others, due to the Annex for Air Emissions and the multimetric indices. Comparison of the US (Fig.12) and Canada (Fig. 13) When it comes to the comparison of the US and Canada the legislative scenery alters overall, yet between them as federal states there are many similarities. The core circles the two horrendograms only differ in the lack of ratifications of the US of the United Nations Convention on the Law of the Sea (UNLCLOS) and the London Protocol. On the other hand, the Honolulu strategy is only relevant in the case of the US; for reasons explained in the methodology. The next legislative level presents many similarities as well, as both the US and Canada have developed most strategies from their international commitments. Thus, a radioactive waste policy and energy strategy are found in both horrendograms. Nevertheless, regarding flood management for instance, the US has a risk management program while Canada has a one for flood damage reduction. The clearest distinction between the two countries is in the nature conservation sector, where the US has bird conservation partnerships and initiatives and Canada has a Biodiversity Outcomes Framework alongside a Strategy Plan for wildlife service. Beyond that, there are few policies only applied at national level such as the system of MPAs in the US and Canada’s federal marine strategy for protected areas.

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Moving outwards to the next horrendogram circle, the requirements for obtaining the targets largely follow the previously identified pattern. Where the strategies are the same or similar the status to be met tends to be same or similar.

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Fig. 12: Horrendogram of the US, when compared to the horrendogram of Canada. Showing international, American and US legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between the US and Canada and highlighted ones in green show legislative policies unique to the US within the comparison at hand.

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Fig. 13: Horrendogram of Canada, when compared to the horrendogram of the US. Showing international, American and Canadian legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between Canada and the US and highlighted ones in green show legislative policies unique to Canada within the comparison at hand.

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Even with regard to flood risk assessment, both countries aim to manage the risk and in fisheries, they try to achieve sustainable use of resources. The conservation aspect is the most diverse. Canada envisages a prosperous life for Canadians with sustainable natural assets and favourable conservation status trying to prevent wildlife species from disappearing. In the US, conserving biodiversity is the general purpose followed by an additional objective to manage and protect wetlands from destruction and degradation and the preservation of birds’ abundances. The comparative analysis of the national approaches has a more abstract character but in order to stay focused on the general differences between the two states the figures explicitly mention the different policies. To begin with, both countries have unique legislation on flood risk management; the Disaster, Relief and Emergency Assistance Act in the US and the municipal collaboration in Canada. In fisheries, again uncommon in other countries, Canada uses the precautionary approach, by-catch guidelines and an aboriginal policy, while the US has adopted rules to combat illegal fishing, as Spain has done. The rest of the policies in Canada address the conservation of salmon, pest control and inspections as well as companies’ licences. The US legislation, on the other hand, has aquaculture regulations and a strategy on fish and wildlife. A point worth mentioning is the Insecticide, Fungicide and Rodenticide Act of the US, which is more precise in its controls than the respective Canadian policies. At sea, Canada further aims to enhance cooperation and minimize adverse transboundary impacts. Despite many commonalities, when looking at ocean management the approaches of the two countries differ completely. Canada’s aspiration to ensure healthy, safe and prosperous oceans stands opposite the US’ drive towards economic growth and states’ empowerment. Lastly, regarding its energy strategy Canada has set renewable targets for 2030 while the US intends to increase energy security and reduce general carbon pollution. A Navigation Protection Act is included in the legislation for ocean management in Canada, whereas the US has an implementation plan. In the energy sector, Canada has a significant Atlantic Gateway policy meanwhile the US tries to overturn the current energy scene with a Recovery and Reinvestment Act. For water quality management, the US has adopted an Ocean Dumping Ban Act along with other environmental protection policies, thereby going beyond pure solid waste treatments, like Canada. The situation is reversed for legislation regarding radioactive waste where Canada has additional regulatory policies and guidelines. The conservation sector, as mentioned before, has the most apparent differences. Indeed, in the US horrendogram it is obvious that many Acts were put in place to preserve the environment. The Wetland Acts exist only in the US, the shore protection and the outer continental shelf ones likewise, as well as the Coral Reef along with the Marine Mammal Act. In terms of legislation protecting cultural heritage, EIA and alien species, the US outnumbers Canada’s regulations with specificities on archaeological and underwater cultural heritage (military remains are another focus point), a code

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and an Administrative Act on EIAs, aside from a task force specifically created for targeting invasive species. The implementation methods have more similarities than the legislation across the previous circles within the horrendograms. For flood assessment, Canada focuses on mapping and evaluating the hazards, while the US also takes preparation and rehabilitation after a flood event into consideration. Consequently, looking at the national approach in fisheries, the latter focuses on transparency and traceability in the seafood supply chain while the former prepares fishery management plans. Nature conservation presents another example, with Canada having less national legislation but more implementation methods and protection afforded. Concretely, it foresees regulations and consents as well as capacity building and coordination for wildlife and integrated planning for improving the wellbeing of inhabitants. Further particular aspects are that the US concentrates on public education and research around wetlands, while Canada focuses on MPAs. For the latter country, the policies for CITES are retained under domestic amendments. The last differentiation is regarding SEAs and shipping. Canada applies early integration, develops alternatives and evaluates the process of SEAs, at the same time that the US deals with licenses and consents for the assessments. Additionally,, in enforcement of alien species regulations Canada has stronger and more precise implementation means. Comparison of the US (Fig. 14) and the UK (Fig. 15) In this analysis, the horrendogram of the UK follows a certain order because categories are located in different places across the circles unlike in previous cases. The UK and the US are similar in their approaches relevant to the first circle on International Laws and Conventions. Both countries are party to the same International Conventions (e.g. Ramsar, 2001 UCH Protection, Espoo, Kyoto, Marpol) with the exceptions of UNCLOS and the London Protocol not having been ratified by the US. The US is also not a signatory of the Cartagena Protocol and as explained in the methodology the Honolulu Strategy only appears in the US’ horrendogram. The considerable differences between the two countries appear evident when looking at the second circle. The US follows policies as a federal state, whereas the UK, as an EU Member State, follows European Union Directives and Strategies. These differences are detectable in the legislative approaches across the categories of fisheries, nature conservation, shipping, ocean management, water quality and environmental standards. Whilst UK fisheries regulations derive from the EU Common Fisheries Policy, the US has put a Fisheries Policy Regulation in place at national level.

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Fig. 14: Horrendogram of the US, when compared to the horrendogram of the UK. Showing international, American and US legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between the US and the UK and highlighted ones in green show legislative policies unique to the US within the comparison at hand.

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Fig. 15: Horrendogram of the UK, when compared to the horrendogram of the US. Showing international, European and UK legislation giving protection to the marine environment (after Boyes and Elliott, 2014). Highlighted boxes in yellow show common approaches between the UK and the US and highlighted ones in green show legislative policies unique to the UK within the comparison at hand.

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Conservation in the US differs from that in the UK as the US has specific regulations such as the Wetlands Protection Legislation whereas the UK has none. The UK, however, has adopted all EU Policy Directives including the Integrated Maritime Policy, the Habitats Directive and the Environmental Liability Directive. Nevertheless, the US has a national system of MPAs and it is obvious that in its primary legislation it outmatches the UK in every aspect of conservation. Further, the US has an ocean policy and a policy addressing radioactive waste, while the UK covers an overall smaller spatial area with the management of bathing water quality, nitrates and only general integrated pollution prevention and control. Within the next circle, the two countries have more differences than similarities also in common categories such as for example SEAs where the UK takes into account transboundary effects. Safe shipping, navigation and pollution are part of the UK’s targets, while the US focuses on the environmental effects of shipping. Moving on to the national legislation level, in terms of fisheries, the UK showcases the same differences it has in comparison with other countries in that it controls salmon services but lacks aquaculture regulations, control of illegal fishing (as Spain) and a recreational fisheries policy. The US goes so far as to have legislation on insecticides, pollution control resources and drugs for animals that all find provisions for in fisheries regulations. Both countries regulate their flood risk, with only the Act on Disaster Relief, previously mentioned in the US-Canada comparison, representing more in-depth legislation efforts. Regarding nature conservation all unique characteristics of the aforementioned comparison are in place, therefore the only comment for this category is pointing out the high number of policy documents in the US, where all aspects of conservation have their own legislative approaches (e.g. fish and wildlife, migratory birds, neotropical migratory birds etc.). Marine (maritime) conservation heritage in the US and the UK are similar, with focus on protecting archaeological remains, wrecks and military remains, although the US has more regulations on the latter one as well as on antiquities. However, the situation is different in the case of EIAs. Even though EIAs and SEAs are similar at domestic and at implementation level (in the horrendograms), with only slight contrasts in terminologies of the Law, the UK envisages assessments specifically targeted at marine related projects. As noted in the targets circles, in the US, shipping is managed through ballast water treatment and the UK has the Harbours and Merchant Shipping Acts. The energy sector has separate approaches for each country. The UK focuses on renewable energy and the US on independence and energy security. Related to these strategies are the distinguishable approaches to water quality and environmental standards, with waste regulations and pollution control in the UK and specific Acts on nuclear waste, river and water in the US. In the following, only the most essential differences in implementation methods are pointed out as it is obvious from the highlighted colouring in the horrendograms that

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they are disparate. Fisheries management in the US has strategic methods for protection, though the commonly acceptable levels for the safe consumption of shellfish are not as clearly reported on as in the UK. The US controls water quality through guidance, monitoring, prevention measures and evaluation along with resolutions on waste problems, whereas the UK follows good practices and licensing methods. Lastly, in the US environmental standards are very thoroughly controlled with specific regulations on radioactive waste exists, that also assess uncertainties. Conservation in the latter country has methods of descriptors, delineated areas and assessments, while the US more strongly promotes research, public awareness, capacity building and precautionary measures. In the US marine spatial planning (MSP) is connected to conservation, while in the UK due to EU Directives and previous experiences in maritime spatial planning, it is associated with a more holistic and economical approach (based on the horrendograms comparison). This is due to the existence of the Marine and Coastal Act, which also includes the implementation level of coastal recreation. With regard to invasive species, the UK does not have regulations and the focal point in shipping remains lies on harbour licenses, while the US invests in research, prevention and awareness of aquatic nuisance/invasive species. Ocean management is a category, which appears only in the horrendograms of the US (and Canada) and is centralised around the National Ocean Policy, with specific targets relating to economic growth and empowerment of communities and states. This National Strategy is implemented at local level through Acts, such as the Oceans Act, the Ocean Action Plan and Ocean Policy Implementation Plan. It provides implementation methods of an integrated approach and helps aid the coordination across government levels. Distinctive aspects of the horrendograms In the analysis of the legislative approaches of all studied countries compared to the UK (and Canada with the US), policies highlighted in the horrendograms with green colour are ones that no other country has, at least not as individual pieces of legislation. Below, these distinctive aspects of countries are described categorically. In fisheries, Canada uses national policies for precautionary measures, by-catch and aboriginal communities. In flood risk management, the same country promotes municipal collaboration at national scale, while France has as an implementation method of decentralization and participation. At the same time, the US considers upcoming flood events with a national Disaster Relief and Emergency Assistance Act. Across all good ecological status policies, there are only distinctive implementation methods in the cases of the UK and Portugal. The former country uses multimetric indices, while the latter explicitly implements licensing, planning, surveillance, supply, demand and infrastructure management.

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Marine conservation is a unique category in that uncommon characteristics can be found in most of the circles of the horrendograms. France strives for a healthy, diverse and rich environment beyond the existing EU targets. At national level, the US presents concrete Acts on wetlands, outer continental shelf, coral reefs, marine mammals, shore protection and urban birds, while the UK envisages offshore marine conservation regions. Undoubtedly, most of the countries examined, include provisions for these aspects in their policies, yet it can work as good guidance to review what policies the US and the UK have on these issues. One representing the North America and one Europe. The implementation approach for marine conservation is especially remarkable in France. It promotes shared governance with stakeholders, their efficient involvement in relevant processes and strong partnerships besides the integration of conservation aspects in policies. The UK envisages conserving wider biodiversity, while Portugal focuses on the sustainable use of natural resources. In Spain, animal care in case of exploitation (i.e. experimentation) is explicitly stressed in the legislative documentation. Another particularity is noticed in Ireland, which has a Planning and Development Act in marine archaeology. Next, regarding EIAs, the UK has national regulations on Marine and Harbour Works, something not encountered in any of the other horrendograms. It is also worth mentioning that Spain is the only European country that deals with invasive species in shipping, though Canada and the US have further provisions, therefore it is not an entirely unique characteristic. In the energy sector, there are two distinctive national policies, the American and the Canadian; the American Recovery and Reinvestment Act and the Atlantic Energy Gateway respectively. In the former country, an Ocean Dumping Ban Act is in place for the maintenance of water quality. This is in addition to the solid waste provisions that other countries have as well. Unique legislations for environmental standards is also observed in Canada with a regulatory guide and policies for radioactive waste management. The UK applies the H1 Environmental Assessment and Appraisal of Best Available Techniques in the upkeep of environmental standards, as mentioned previously in the comparisons. All these aspects, distinguishing categories across countries, should be taken into consideration in an effort of optimizing legislation for the marine environment in the North Atlantic region. MSP comparison The legislation on maritime spatial planning is discussed separately for all the countries since a focus on MSP policies and regulations was part of the GPS project. Principally, in the EU, the UK developed the Marine Coastal and Access Act of 2009, which constitutes the foundation of British MSP by establishing new legislation in the country. It is comprised of regulations on fisheries, marine conservation zones, licensing and further organises the administrative processes (Marine and Coastal Act,

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2009). Portugal adopted a law on MSP (National Law of Planning and Management of Maritime Space – Law 17/2014), just before the EU Directive of 2014, and put it into force a year later with a Law Decree (38/2015) (European Commission, 2017). Spain, on the contrary, only recently established legislation on MSP with a Royal Decree (363/2017). With the 352/2016 Irish Law, the MSP Directive has also been transposed in Ireland a year ahead of Spain, with regulations setting the framework for planning (MSP Platform, 2017). According to a European Commission’s study, the French Grenelle laws are considered to have creatied the basic tools for MSP in France, until 2011. Since then, only strategic frameworks and action plans on the marine environment haven been published, while the transposition of the EU Directive is still pending (DIRM, 2017). For all non-EU countries there are no obligations regarding MSP legislation. Hence, Iceland still lacks an integrated management framework and presents only an Ocean Policy. The US has established both ocean management and planning through Acts spanning the spatial extent from the coasts to the high seas inclusively, and not separately as in the EU. Moreover, marine planning in the US has an environmental basis while in Europe it is characterized as economically driven (i.e. Blue Growth). Canada adopted an Ocean Act and Action Plans as well, but has no planning legislation. It is notable that from all investigated EU countries only Portugal has its own national ocean strategy. In an overview of the legislative tools of each country, the US, Canada, the UK, Ireland and Iceland all use Acts and Plans for regulating their marine environment, while Spain and Portugal have binding tools as Law Decree for governing. France has mixed all kinds of policies in their legislative MSP approach. This is supported by bibliography since in terms of marine knowledge origin France and the UK have bottom-up approaches, while Portugal supports a top-down process (Pinto, Cruz and Combe, 2015).

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DISCUSSION AND CONCLUSIONS Reviewing the structure of the horrendograms, the inner circle comprises the international laws or commitments that the respective country has either signed or ratified along with the international bodies and conventions of which it is a signatory. In the case of UNCLOS, as mentioned earlier, the US has signed but not ratified the convention. It does, however, comply with it. In this inner circle, there are no major differences between the examined countries. The next level of the horrendograms, the second circle from the center, presents the directives, policies or strategies of a more regional and national scale of federal administrations or unions. Therefore, at this stage, all EU countries have the same approach; the countries that do not belong to the European Union but are European have similar legislation influenced by bilateral agreements. The US and Canada, geographical neighbors, follow similar approaches that differ to those of the European nations. Moving to the next circle further out, the targets and status that need to be fulfilled in order to meet the legislative mandates of the previous two circles are illustrated. The approaches are analogous in their similarities across countries with the aforementioned circle. Nevertheless, within the fourth circle of the horrendogram, the approaches across countries diverge more as this is the level of primary national legislation. Hence, this is the circle, which gives the most indicative perspective on differing and shared marine legislation of the studied countries. The outermost circle shows the implementation methods, which indicate the least differences across all countries. From the results of this analysis, three major groups, differing in their legislative approach to the marine environment, can be identified. Ireland, Iceland and the UK have the most similarities in their individual approaches, making up the first group, legislating mainly through Acts and regulations. The second group, the US and Canada, due to the shared governmental format of federal states has very similar approaches, yet at the national level there are nevertheless many differences. In terms of common legislative tools used, this group could be incorporated into the first one, as both principally use Acts. Then the third group, made up of Portugal and Spain, is based on the use of Law Decree. France is not grouped with any of the above countries because even though is has a very similar approach to the first group it also uses binding tools seen in the approaches of the first and third group. It has been the intention of this report to present the different approaches of marine environmental management based on existing legislation for the North Atlantic region. The related bibliography highlights that undergoing a comparative analysis of legal frameworks can take many shapes and forms, with an extent of uncertainty about the result, as no pre-defined methodological framework for a successful comparison exists (van Hoecke, 2015). Thus, it is critical to note that this research is not focused on comparing the legislative tools used in each country with regard to the marine environment themselves. Nevertheless, a selection of legislative pieces is illustrated throughout the horrendograms in order to point out the differences in national

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approaches. Another essential remark is that the general legislative framework involves numerous different legislative tools (treaties, acts, laws etc.). Therefore, the horrendograms present only a sample of the basic and relevant ones and not an exhaustive list.

Further, it is well to keep in mind that the original horrendogram was published before the EU MSP Directive came into place and there was no knowledge of Brexit at the time. The latter of which was remedied by the original authors in an update of the original horrendogram in face of the pending exit of the UK from the European Union (Boyes and Elliott, 2016). Albeit, the ever-changing policy sphere is presented in a well-structures manner through horrendograms, providing a comprehensive overview of the current legislative situation, it can be difficult to keep up to date. Consideration needs to be taken of impacts sudden political changes can have on the legislative sphere and thus increase the potential of having an ‘out of date’ horrendogram. Nevertheless, as better trans-national integration is required for a more holistic approach to ocean management and MSP (at Regional Seas level, ocean level or globally), horrendograms such as the ones derived in this study can provide essential information quickly as to where new efforts have to be made or common interests lie, which could improve the chances of successful collaboration. The presented comparative analysis proves useful for better identification of gaps and necessary improvements in the inner (national) maritime policies of each assessed country as well as a means to inform an integrated coordinated approach across countries for the North Atlantic region. Once again, it is necessary to mention the risks (particularly in the unique characteristics, that are distinguished in the horrendograms in green color) of a target, implementation method or national policy potentially being mentioned in broader policy which might not have been identified within the scope of this research. Hence, expert reviews on each country’s legislation and policies undertaken in the future could diminish this possibility of overlap and double-inclusion. The EU countries of the North Atlantic Arc region may have some differences across their policy approaches but do not differ radically on their progress status regarding the development and implementation of maritime and environmental policy due to shared regional interests. This cannot be said about the North American countries’ approaches where the focal points strongly diverge, albeit a shared belief on best practice for marine environmental management exists, through means of international conventions and strategies. Therefore, this study succeeds in providing an overview over the present complex policy frameworks of the North Atlantic countries that is able to serve as a base for future improved management coordination. It thereby provides a milestone in thorough assessment of similarities and differences in legislative approaches within the same geographical marine region. However, further studies on the potential for integrated marine legislation and common drivers are suggested. As this research, ultimately, represents a preliminary study into the legislative marine approaches of the North Atlantic Arc countries, future exploration of additional tools and an in-depth comparison of the legislative frameworks will be necessary and might

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give better insight into the individual policy situations for each of the studied countries. New holistic as well as sectoral legislation might need to target the integration of different national legislation for cooperative transnational or regional work. Shifting baselines, especially regarding climate change (Elliott et al., 2015) and resulting effects on the entire structure, across vertical and horizontal levels, of legislation should also be investigated in the future. In conclusion, it can be said that this study provides a scientifically relevant input for ocean and coastal management as well as maritime/marine spatial planning in the North Atlantic region and provide a new baseline for better and more integrated legislative approaches for the North Atlantic Ocean and beyond.

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BIBLIOGRAPHY Articles Boyes, S. J., and Elliott, M. (2014). Marine legislation – The ultimate ‘horrendogram’: International law, European directives & national implementation. Marine Pollution Bulletin, 86(1), 39-47. Boyes, S.J., and Elliott, M. (2016). Brexit – The marine governance horrendogram just got more horrendous! Marine Pollution Bulletin, 111, 41-44. Elliott, M., Borja, Á., McQuatters - Gollop, A., Mazik, K., Birchenough, S., Andersen, J.H., Painting, S. and Peck, M. (2015). Force majeure: Will climate change affect our ability to attain Good Environmental Status for marine biodiversity? Marine Pollution Bulletin, 95, 7-27. Pinto, H., Cruz, A. R., and Combe, C. (2015). Cooperation and the emergence of maritime clusters in the Atlantic: Analysis and implications of innovation and human capital for blue growth. Marine Policy, 57, 167–177. Van Hoecke, M. (2015). Methodology of comparative legal research. Law and Method, 1-35. Van Tatenhove, J. P. (2013). How to turn the tide: developing legitimate marine governance arrangements at the level of the regional seas. Ocean & Coastal Management, 71, 296-304. Figures Greenland in Figures (2012) Edited by Michelsen D., 9th revised edition. Available at: www.stat.gl/publ/en/GF/2012/content/Greenland%20in%20Figures%202012.pdf, Accessed at 06 October, 2017 Online Material Blue Flag Programme, Blue Flags sites awarded around the world, accessed on 15 July 2017 <http://www.blueflag.global/> Convention on Biological Diversity, Cartagena Protocol, Parties to the Protocol and signature and ratification of the Supplementary Protocol, accessed on 15 July 2017 <http://bch.cbd.int/protocol/parties/> Convention on Biological Diversity, Signatory Parties to the Nagoya Protocol, accessed 1 July 2017 <https://www.cbd.int/abs/nagoya-protocol/signatories/> Directive 2014/89/EU of the European Parliament and of the Council of 23 July 2014 establishing a framework for maritime spatial planning, accessed on 18 July 2017 <http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32014L0089>

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European Maritime Spatial Planning Platform, accessed on 18 July 2017 <http://www.msp-platform.eu/> International Maritime Organisation (IMO), Parties to the London Convention and Protocol, accessed on 08 May 2018 < http://www.imo.org/en/OurWork/Environment/LCLP/Documents/Parties%20LC%20and%20LP%20Oct%202017.pdf> Interregional Direction for the North Alantic, Manche Ouest, accessed on 20 July 2017 <http://www.dirm.nord-atlantique-manche-ouest.developpement-durable.gouv.fr/plans-d-action-pour-le-milieu-marin-etapes-cles-r165.htm> Marine Debris, NOAA, Honolulu Strategy, accessed 1 July 2017, <https://marinedebris.noaa.gov/solutions/honolulu-strategy> Marine Litter Network, Global Partnership on Marine Litter, accessed 1 July 2017, <http://marinelitternetwork.engr.uga.edu/global-projects/> Marine and Coastal Act 2009, accessed on 18 July 2017 <http://www.legislation.gov.uk/ukpga/2009/23/contents> Portugal National Law of Planning and Management of Maritime Space – Law 17/2014, accessed on 18 July 2017 <https://webgate.ec.europa.eu/maritimeforum/sites/maritimeforum/files/LBOGEM_Blueweek%20DGRM.pdf> United Nations Environment, Regional Seas, Arctic Region, Protection of the Arctic Marine Environment, accessed 20 July 2017 <http://drustage.unep.org/regionalseas/arctic-region>