In October 2024 our Association, continuing permanent cooperation with United Nations’ bodies, sent relevant submission to UN Special Rapporteur on the human right to a healthy environment Dr. Astrid Puentes Riaño for her thematic report regarding oceans and human rights, to be presented to the 58th session of the UN Human Rights Council in February 2025.
Now our submission, together with many other inputs from states, international structures, recognised environmental NGOs and academicians, is published on official UN web-sources. ARC’s input, prepared by Dr. Borys Babin and other experts, reminded that Russia’s aggressive acts are totally supported by their naval activities on the Black Sea and Sea of Azov.
ARC’s submission stressed on the gross and systematic violations by Russia the demands of international humanitarian and human rights law, also as maritime safety, guaranteed by the UNCLOS, SOLAS, MARPOL and STCW Conventions, and reminded that Russian aggression de-facto destroyed fishery perspectives in the Black Sea.
ARC’s submission reminded on IMO Assembly’s Resolution A.1183(33) “The impact of the Russian Armed Invasion of Ukraine on International Shipping”, adopted in 2023 and added that Russia’s provocations against safety of shipping are connected with illegal “federal state unitary enterprise” “Research and Design Institute of Testing Machines, Instruments and Mass Measuring Instruments” (“NIKIMS”) that “operates” by Russia-controlled “Kerch Ferry Lane” that makes illegal cargo transfer via Kerch Strait.
ARC’s submission pointed on examples or Russia’s missile attacks from the Crimea, against the civil ship “Optima” IMO 9528691 flying Palau flag, and against civil container ship “Shui Spirit” IMO 9216729 flying Panama flag, which were committed in October, 2024. Also our submission reminded the UN of the Kakhovka HPP destruction, committed by Russian forces in June, 2023, that caused ecological and humanitarian disaster.
ARC’s submission stressed that in March, 2024 Russia was excluded from the Danube Commission for broadscale violations of Belgrade convention during Russia’s ongoing aggression against Ukraine.
ARC’s submission added again that Russia’s membership in FAO, IMO and ILO, in regional organizations such as Black Sea Commission, also as any participation of Russian citizens, acting as public servants of those organizations, must be stopped also.
ARC’s submission added that special attention must be paid to illegal activities of Russian classification societies such as “Russian Maritime Register of Shipping” and “Russian Classification Society”, formerly “Russian River Register”. Submission stressed that vessels flying the Russian flag and using the “Russian Maritime Register of Shipping” and “Russian Classification Society” must be included in black lists of all regional Memorandums of Understanding on Port State Control.
After UN’s official publication of our submission we additionally informed recognised environmental NGOs and academicians from many states, that also cooperated with UN Special Rapporteur in above-mentioned report preparation, on current ecological disaster in Black Sea, caused by catastrophe with Russian tankers “Volgoneft-212” and “Volgoneft-239” near Kerch Strait in December, 2024. Also this information, with grounds on IMO position, granted to us this January and above-described UN publications were sent by us to key ecologic NGOs of Bulgaria, Moldova and Romania.
Reaction of some environmental structures, including World Wildlife Fund preliminary information, give us hope that global environmental networks and structures will be well-aware of real grounds and current negative processes in Black Sea and Sea of Azov, caused by Russian naval aggression against Ukraine.

