The experts of “ARC” pay permanent attention to maritime ecology issues and informed already the authoritative international ecologic unions on situation in waters of  the Black Sea and the Sea of Azov, including the Kerch Strait and bays, adjacent to the Crimean peninsula. Now the relevant submission was sent to the questionnaire of the UN Special Rapporteur on Toxics and Human Rights decided to impact analysis of the International Maritime Organisation.

“ARC” informed the Rapporteur that Russian de-facto “authorities” do not have the adequate organizational level of prevention and response of the marine pollution, including oil pollution in port waters and maritime spaces adjacent to Crimea, especially in Kerch Strait, Feodosia Bay and Sevastopol’s bays. We mentioned the set of incidents with oil pollutions that happened in 2015-2020 without any systematic further work of de-facto authorities on their reasons’ reducing.

As “ARC” pointed in submission, since 2015-2020 the local land-origin pollution of maritime waters increased from Crimea. The main sources of this pollution are the urban waste waters of Crimea’s settlements, and the most dangerous situation appeared in Sevastopol. This city as the main Russian military base, got the increase of own population due the ongoing militarization, from 350 thousands in 2013 to 550 thousands in 2020. The main Sevastopol sewage treatment plant “Southern” collapsed in 2015-2016 and wastes of this city goes directly to Black Sea.

Similar situation was described by “ARC” for the UN Rapporteur on local examples of Yevpatoria, Yalta, Koktebel and Feodosia. We point special attention of the UN representative on plans of Russia’s de-facto “authorities” in Crimea cover two desalination stations’ placement in Frunze, Saksky District, and Yalta city for 20 thousands cubic meters per day, wasting toxic salt dumps directly to the Black Sea.

“ARC” informed the Rapporteur that Russia’s Sevastopol naval base and related locations of Russia’s Black Sea Fleet are the main sources of ship pollution to sea, including oil products, non-controlled ballast exchange, and rocket fuel chemicals. Shelf platforms of “Chernomornaftogas”, as a company controlled by Russia and excavating gas and gas condensate in the Northern part of Black Sea, are the sustainable source of relevant maritime pollution. Black Sea currents transfer those pollutions to entire basin.

Also “ARC” gave to the Rapporteur some examples dangerous shipbreaking incidents happened in maritime waters around the Crimea in 2015-2021 without relevant investigations regarding the basic international demands. Negative impact of the gas, excavated illegally by Russia from Ukraine’s continental shelf in the Black Sea (Arkhangelskoye, Golitsinskoye, Odeskoe, Shtormovoye oil shelf fields) to the emissions of greenhouse gases and climate change was mentioned.

“ARC” informed the Special Rapporteur that non-controlled area of vessel cargo overload in the Black Sea to the south of the Kerch Strait is the district of intensive maritime ship pollution, including ore, sulfur and oil product. Such pollution happens as during usual overload, so by often incidents, and in 2017-2020 as minimum three tankers sank after fire on board in those waters as it was reflected in the Association’s submission.

Also the submission mentioned on the chemical plants “Titan” and “Krasnoperekopsk Soda Plant” located in Northern Crimea, that pollute the atmosphere by a broad set of chemicals and cause the acid rains on the Black Sea Karkinit Bay and other parts of basin. The incident with dangerous dumping of hazardous wastes, that  happened with “April” vessel in the Kerch Strait in February 2021, was also described.

So, as “ARC” summarized in mentioned submission, Black and Azov Sea spaces around the Crimea become a “grey zone”, where the IMO demands are not executed. Russian illegal armed presence on the high-risk objects – gas-excavation platforms in the Northern part of the Black Sea, permanent trainings of Russian navy, including usage of the automatic maritime drones and floating mines also established the system threats for the maritime ecology in the region.

Borys Babin