In response to the European Commission’s consultation on the Marine Strategy Framework Directive (MSFD), ECOncrete has submitted a public comment calling for a clearer prioritization of impact mitigation at source.
Embedding the Mitigation Hierarchy
Leading environmental frameworks follow a structured sequence – Avoid → Minimise → Restore → Offset – ensuring impacts are addressed before compensation is considered. The MSFD does not yet explicitly apply this hierarchy. In practice, this can lead to mitigation or offsetting being applied after impacts occur, rather than designing projects to avoid and minimise them from the outset.
We recommend formally embedding this sequence within the Directive to prioritize prevention at source.
On-Site Mitigation Through Design
Nature-inclusive design enables infrastructure to function as on-site mitigation. By integrating ecological features directly into marine structures, projects can:
- Reduce impacts within the project footprint
- Support biodiversity and ecosystem functioning
- Deliver measurable ecological uplift alongside engineering performance
- This shifts infrastructure from a source of pressure to part of the solution.
Aligning Policy with Practice
The MSFD revision is an opportunity to align marine governance with EU frameworks that already prioritize direct impact reduction, including the Habitats Directive and Climate Law. Strengthening this alignment will reduce reliance on disconnected offsetting and support more effective, scalable environmental outcomes.
Download Our Full Public Comment:
👉 ECOncrete’s response on MSFD Public Consultation