Introduction

This reads more like a summary of the report, not really as an introduction.

Could you maybe introduce the key risks and governance challenges when it comes to Sea-Level-Rise?

Sub-chapter 5.2.1 “Geopolitical context in European Sea Basins”

This report is about SLR governance. It would make this sub-chapter on the geopolitical context more interesting and relevant to the subject of the report, if the geopolitical context was link to the issues of Sea-Level-Rise and adaptation measures (e.g. how the geopolitical context such as cooperation mechanisms, existing conflict(s) or the development of strategic sectors, will be affected or affect SLR governance and the implementation of adaptation measures?)

This sub-chapter highlights certain policy documents per basin, introduced as “key policies documents. In the Mediterranean Sea you mentioned the “2021 European Neighbourhood Policy ”, in the Baltic  Sea it’s the Interreg Baltic Sea region program (which is first and foremost a financial instrument), while in the North Sea you mentioned the “North Sea Region 2030 Strategy”, why not mentioning the European Baltic Sea Strategy, or the other Interreg programs in place in all sea basins?

In the Black Sea it is the Black Sea Synergy initiative as “the EU’s key regional policy framework for the region in force since 2007” while regional actor would mention,  the Bucharest declaration or the Common Maritime Agenda.

The EU marine security strategy as a geopolitical policy instrument might be worth mentioning…

As a result the choice of the key policy documents presented per basin pose question...

If the intention is to bring a geopolitical perspective, instead of introducing certain policy documents, I would suggest focusing this sub-chapter on the key actors at play including regional organizations, considering you have another chapter dedicated to governance where you are listing key policy documents (table1)?

Sub-Chapter 5.2.2 Economic context in European Sea Basins

Table1: It would be nice to have the source of the statistic mentioned.

Regarding the Black Sea, the numbers stated for the weight of the Oil and Gas industry mentioned might be out-of-date following the Russian-Ukraine war... Is the statistic mentioned from 2022-2023?

In table 2, the description of the situation of the NE Atlantic Ocean is a little surprising and would better fit the Mediterranean coast description…Mentioning the total population of the 4 countries of the region is not pertinent as it does not relate specifically to the NE Atlantic coastline.

Chap. 5.3 Coastal governance

The choice of introducting this chapter by the UNCLOS as key governance frameworks currently in place to tackle the impacts of climate change (ligne 295) is surprising as the United Nations Convention on the Law of the Sea does not include any reference to climate change (see Amstrong C. 2023^[1]). Only the very recent agreement of the new Biodiversity Beyond National Jurisdiction (BBNJ) treaty, reached in November 2023, include clear reference on climate chance and marine environment protection. At this stage the effectiveness of this  instrument is unknown. It is even more surprising that no mention is made of the Agenda 2030 and the SDG 13, the Paris Agreement, or the European Green Deal. One would expect it is, a minima mentioned, in table 3 (ligne 325) When introducing the regional sea conventions (RSC) (ligne 316), the text would benefit if the different types of agreement with UNEP were mentioned (UNEP-administered / UNEP-Non administered / Independent [2] ), not all RSC are "part of UNEP”, some simply cooperate with.

Table 4: update MSP status of Romania

Ligne 412: the example of France is very approximate; the country is generally referred as a vertical type of territorial management even more regarding marine space. The country has specific regional and local documents to tackle climate adaptation and more specifically SLR as a climate risk (e.g. "plans de prévention des risques littoraux" and strategic sea basin documents). “Conservatoire du littoral” cannot be cited as the “central public authority in charge of coastal management”, different administrations have competences regarding coastal adaptation measures tackling SLR risks.

Chap 5.3.4 Coastal adaptation financing arrangements

A note on private finance, green bounds would have been welcomed.

See also:

• European Union, European Economic and Social Committee (EESC), Expert for the Opinion: “Financing the transition to a low-carbon economy and challenges in financing climate change adaptation (NAT/778)”, 2020.
• Koundouri, P., et al., 2022. Financing the Joint Implementation of Agenda 2030 and the European Green Deal. 2nd Report of the SDSN Senior Working Group on the European Green Deal. Available: https://resources.unsdsn.org/financing-the-joint-implementation-of-agenda-2030-and-the-european-green-deal

Chap. 5.4 Complexity and challenges

Paragraph line 644-650: Can you justify your statement when you said: “Most countries are adopting a low-regret approach and considering SLR estimates that occur in all projections independent of climate and emission scenarios - i.e., between 0.15 and 0.35m by 2050, 2050 including Albania, Croatia, Cyprus, Denmark, France, the Netherlands, Norway, Portugal, Spain, Ukraine.” ?

Looking at the 2050 SLR projections,  IPCC scenarios don’t foreseen an increase of more than .35cm (it is generally around 20 cm) which can explain why government are not planning for above .35 SLR by 2050  (see https://sealevel.nasa.gov/ipcc-ar6-sea-level-projection-tool)

Could you define “low-regret” approach?

5.4.3 Equity and social vulnerability

A very interesting chapter with added value!

Table 6 is very interesting. Could we also have measures with positive justice factor (such as NBS)?

 It would be welcome to also have as, part of the text, an introduction and an explanation of the adaptive response typology (source?).

Box 8 and 9 should also be referenced in the text.

Line 934: Could you define distributive justice?

The report would benefit from an actual concluding part instead of a summary of “ key developments per basin” which would also summarize the key elements of chapter 5.4.

The report needs revision as it contains many approximations and questionable statements.

The sub-chapter on geopolitical context seems a bit disconnected to the subject of the report.

An introduction including the key risks, challenges and governance issues related to Sea-Level-Rise would be welcome.

Properly refers website pages: author of the article or website name / year. You could also use a footnote

General comments

My comments are offered with the caveat that I can only opine on issues relating to the North Sea.

In general, it is a difficult document to navigate. It would be easier for the reader if the authors clearly articulated the common European/global problems, and perhaps discuss how current horizontal and vertical governance structures help solve them or are barriers to resolving them. As the document stands, all these structures are discussed simultaneously, together, which makes it hard to understand what works.

In addition, the authors should consider discussing policy instruments, their benefits and shortcomings, in a more structured way. As it stands, norms and normative approaches are discussed interchangeably with soft law instruments and voluntary initiatives. 

Last, tools and resources, or lack thereof,  are discussed in fairly generic terms, which makes it hard to learn something about their effectiveness.   

Specific comments

There should be a clearer articulation of the nature and structures of governance. Specifically regarding the governance of the North Sea basin, I am missing the aknowledgement that there is currently no formal North Sea Basin strategy, it is work in progress. On page 5, a voluntary initiative, the North Sea Region 2030 Strategy, is refered to as a key policy for th eEU, which is not factually correct. This is a voluntary intiative across regions around the North Sea, including UK and Norwegian regions, which are not part of the EU. The 2030 NSR Strategy is not anchored on any EU policy. 

When discussing the socioeconomic context there are a lot of statements which are not backed by evidence. They thus read more as claims an opinions rather than facts.  

Dear editor,

The chapter presents a review of progress in Europe on the governance of adaptation to SLR, by describing the geopolitical and socio-economic context of SLR governance, EU policy priorities, the status of regional and national frameworks and specific governance challenges.

A main objective/research question is missing. The chapter is descriptive, theoretical observations and reflections are made in section 5.4

The chapter starts with describing the geopolitical and socio-economic characteristics and context of the different European sea basins. This is done in a general, but good way.  However why did the authors start with this general description. For me it would have made sense to start with an introduction of how they understand SLR/coastal governance for example as an analytical model and/or as a model of transition/intervention. When the chapter had started with a definition SLR/coastal governance and relevant analytical themes/concepts of SLR/coastal governance (such as equity, vulnerability, justice etc.) it would have given the authors a framework which would have made it possible to present a more focuses analysis of relevant geopolitical and socio-economic developments from a SLR/coastal governance perspective and to understand the enabling and constraining conditions of the institutional context, geopolitical developments, relevant EU and national policies and how to govern the uncertainties related to SLR in a just, fair and democratic way .

Section 5.3 coastal governance gives a good overview of coastal policy frameworks and objectives relevant for SLR both on the international and national level.

Section 5.4 presents interesting building blocks how to govern economic and societal activities and developments given the uncertainties of SLR. My suggestion would be to develop with these building blocks a governance approach presented at the beginning of the chapter. 

Section 5.5 presents key developments per basin. It would have been interesting not only to mention what policies are in place and whether countries have reported about SLR, but also to identify the enabling and constraining on the level of a sea basin to govern SLR and what the possibilities are of transboundary cooperation.

Thank you to the authors for an interesting and useful read

My overarching comments are below with detailed comments attached.

Style - the paper reads like a 'chapter' of a report. It should be recast as a standalone as a science paper.

Conciseness - The text is overly long.  Brevity would improve readability in places. 

Referencing all assertions - sometimes the evidence in support of an assertion is unclear. Greater referencing or methods statements are needed.

Social justice - great to see, but this section reads a bit as an add on. Less general introduction to the theory and more what policies exist in which countries and how they are implemented would be very interesting to see.

Good luck with the revisions - the basis of a nice paper!