Firms To Watch: Environment

With notable experience in the renewable energy space, Johan Forsling heads up DLA Piper Sweden’s environmental law practice, which supports the firm’s energy and property teams, regularly handling permit applications for large-scale wind and solar projects.

Environment in Sweden

Mannheimer Swartling

With notable experience in a wide range of traditional and modern industries, from steel and chemicals to hydrogen projects and solar parks, Mannheimer Swartling’s experienced environmental practice continues to play a leading role in the climate and energy transition in Sweden and across the EU. With expertise in permit issues in relation to heavy industry and mining, Anna Bryngelsson in Malmö leads the team. Therese Strömshed, also in Malmö, specialises in energy infrastructure, offshore wind, and electricity market matters, while Stockholm-based Joel Mårtensson focuses on permit applications as well as environmental disputes; he also has considerable experience handling land and water contamination cases.

Practice head(s):

Anna Bryngelsson


Other key lawyers:

Therese Strömshed; Joel Mårtensson; Madeleine Edqvist


Testimonials

‘The team is full of strategic thinkers who are up to date on practices in the environmental law field.’

‘Mannheimer Swartling has the largest environmental legal team in Sweden that is always able to respond to requests within agreed timeframes and without compromising quality.’

‘Joel Mårtensson walks the line between going above and beyond while also ensuring that the cost base of the future business will not be burdened by additional costs that do not contribute to improved environmental outcomes.’

‘Madeleine Edqvist is very skillful, helpful and makes time for you.’ 

‘A strong and knowledgeable team.’ 

‘They are dedicated, service minded and up to date with the legislation in the energy sector.’

‘They really find every small and important detail in each case and bring a calm presence in the courtroom.’

Key clients

OX2 AB


Stockholm Exergi


Heidelberg Materials Group


Perstorp Oxo AB


Skyborn Renewables


Copperstone Resources AB


Talga AB


Metsä Group


Boliden Mineral AB


Energinet A/S


Ovako


Svensk Kärnbränslehantering


Work highlights


  • Acted for OX2 AB in all permit proceedings regarding its large scale offshore wind portfolio development located on the Swedish Exclusive Economic Zone.
  • Successfully represented Perstorp Oxo in the permitting process for a first-of-a-kind CCU project at Perstorp’s factory in Stenungsund, Sweden, aiming at producing fossil free methanol.
  • Successfully represented Talga in the permitting processes for a natural graphite mine in Kiruna and a natural graphite battery anode plant in Luleå.

Setterwalls

Setterwalls’ environmental law practice has a strong reputation for advising major public and private sector clients on the full spectrum of matters, including regulatory, advisory, transactional and contentious issues, with notable recent experience in resource extractions, renewable energy projects, and land contamination cases. With extensive experience handling industry, water, and natural resources permit applications for domestic and international entities, Anders Linnerborg leads the department; he is also an expert in matters concerning the extraction of rare earth minerals. Tove Andersson’s broad practice includes large-scale permit and transactional work, while Malin Wikström specialises in hazardous facilities and water activity cases.

Practice head(s):

Anders Linnerborg


Other key lawyers:

Malin Wikström; Tove Andersson; Linnea Ljung; Sunniva Rosqvist


Testimonials

‘The environment practice at Setterwalls offers efficient and available partners that really commit to cases and do their absolute best for clients, with excellent results.’

‘Malin Wikström handles permit-related matters very competently and skillfully. She delivers on time, with strong arguments based on careful investigations. She is also very experienced in the political to economic aspects of a business or operation, and is excellent at risk identification and risk management.’

‘Tove Andersson is extremely competent in environmental matters, with long experience in the area.’

‘Linnea Ljung is one of the smartest lawyers around. She is very analytical in her thinking, good at complex problem solving, and has very very good presentation skills.’

‘Sunniva Rosqvist is an incredibly focused, driven and organised lawyer. She is efficient and thorough, which makes her legal reviews efficient and of good quality.’ 

‘Tove Andersson possesses a wealth of experience within the field. She always puts together a highly competent team for each unique situation and understands the dilemmas of clients, always giving concrete and well-thought-out advice.’ 

‘This is an extremely competent network of lawyers with strong business acumen. They are quick, accurate and not afraid of guiding clients.’

‘The strength is their open-minded approach to discussing difficult issues. They create a environment focused on the issues/challenges at hand and that allows for all input.’ 

Key clients

Borås Energi och Miljö AB


Arise AB


AB Sydsten


SR Energy AB


Svevia AB


Arkema Group


Befesa Scandust AB


Sydvatten AB


NCC Industry AB


Sveriges geologiska undersökning


O Kavli AB


Skanska AB


Swedavia AB


Port of Gothenburg, City of Gothenburg


Dannemora Iron AB


Skyborn Renewables Sweden AB


Holmen Energi AB


Skellefteå Kraft


Cloudberry Clean Energy ASA


Borås stad


Work highlights


  • Successfully represented Dannemora Iron AB, owned by Grängesberg Exploration Holding AB, in the permit proceeding for the restart of the Dannemora mine in Östhammar municipality.
  • Representing the municipality of Östhammar in the ongoing permit proceedings regarding the Swedish Nuclear Fuel and Waste Management Company’s application for a permit to construct and operate plants in a cohesive system for the final disposal of spent nuclear fuel and waste and permit for the Final Repository for Short-Lived Radioactive Waste.
  • Advising the Geological Survey of Sweden (SGU) on its role as remedial principal in the project to remediate a large perchloroethylene contamination under several existing residential buildings in the city of Jönköping.

Advokatfirman Delphi

Advokatfirman Delphi’s Malmö-based environmental practice group has experience handling matters in the construction, transport, infrastructure, waste management, chemical production, and energy sectors, among others. Erica Nobel specialises in environmental permit applications and land contamination cases, regularly advising infrastructure companies, municipalities, and energy clients. Christian Härdgård is particularly strong on environmental permits for quarry and aggregate operations, infrastructure projects, and petroleum product storage assets. Elisabeth Werner works on permit proceedings involving heavy industry, energy, waste treatment, and land contamination issues, and Oskar Frankki is an expert in land contamination matters.

Practice head(s):

Erica Nobel; Christian Härdgård; Elisabeth Werner; Oskar Frankki


Testimonials

‘A professional yet personal, service-minded and skilled team that is easy to work and communicate with.’

‘Erica Nobel is well-educated in her field. She is regionally, nationally, and internationally knowledgeable and is always updated on court decisions and precedents.’

‘Elisabeth Werner is great; she goes to great lengths to argue and define issues both before and during negotiations. Her knowledge in the environmental sector is sharp, especially within the aggregates industry.’ 

Key clients

HSB Skåne ek för


Oresund Heavy Industries AB


Peab Bostad AB


Sun Chemical


Swerock AB


Nordic Storage AB


Scandinavian Tank Storage AB


MKB Fastighets AB


RGS Nordic AB


Copenhagen Malmö Port AB


SPI Miljösaneringsfond AB (SPIMFAB)


Malmö Stad


Hummeltorp Sverige AB


Norrköpings kommun


Rönnarp Recycling AB


Lantmännen Ek. För.


Norrköpings Hamn AB (the harbour of Norrköping)


Ystad Hamn Logistik AB (the harbour of Ystad)


Johansson Ballast AB


AB Nybrogrus


Finja AB


BDX Företagen AB


Kustvind AB


Brogårdsand AB


Work highlights


  • Advises Malmö stad (Malmö municipality) in a matter concerning the filling in of the ocean (Öresund).
  • Advised Swerock AB in relation to a permit for a large combined quarry, waste management, landfilling and recycling project.
  • Advising VA Syd, a municipality-owned organisation, on the permitting process relating to a water treatment plant.

Foyen Advokatfirma

Foyen Advokatfirma‘s multidisciplinary environmental law team assists clients in the mining, infrastructure, heavy industry, and energy sectors, among others, with a broad range of issues, including permit applications, waste management projects, and Natura 2000 and species protection issues; the team also has notable experience in the forestry industry. Stockholm and Gothenburg-based Pia Pehrson, who has considerable experience in the mining, infrastructure and energy industries, leads the practice. Tomas Fjordevik, who was promoted to partner in January 2023, focuses on permit applications, with experience handling processes concerning airports, chemical production plants, wind farms, waste treatment facilities, and thermal power plants.

Practice head(s):

Pia Pehrson


Other key lawyers:

Tomas Fjordevik; Michelle Jansson


Testimonials

‘The team is always thorough in their advice and practice, leaving no loose ends.’

‘Tomas Fjordevik is very experienced and skillful in environmental law matters. He is very responsive and understand the needs of clients, providing very good legal advice relevant to the situation.’ 

‘Michelle Jansson is very dedicated and easy to work with.’

‘The team has great commitment to tasks, broad knowledge of environmental issues, and extensive experience.’ 

‘You know that you will always get an excellent result back from each individual.’

‘A dedicated and skilled team made up of very nice people who are available and responsive to the needs of the client.’

Key clients

Ellevio (former Fortum Distribution)


Nordion Energi (Swedegas/Weum)


Södra Skogsägarna


Skellefteå Kraft


SR Energy and the Stena companies


Björkdalsgruvan


Mandalay Resources


Dragon Mining


Metso Outotec


Tertiary Minerals


Equinor (Statoil)


OX2


Övik Energi Nät AB


RWE


LKAB


Eolus Vind AB


Work highlights


  • Advising RWE Renewable (Sweden) on its permit applications under the Environmental Code, Continental Shelf Act and the Swedish Exclusive Economic Zone Act for two offshore wind farms in the waters south of Sweden, especially the project Södra Victoria at Södra Midsjöbanken including 100 wind turbines.
  • Representing LKAB in a permit process under Chapters 9 and 11 of the Environmental Code in a matter regarding a circular industrial park which comprises, among other things, several chemical industries (IED and Seveso plants) and several water industry operations.
  • Advising Eolus on the process of a new investment for an offshore wind power project with the construction of up to 70 wind turbines in Hanöbukten within the municipalities of Sölvesborg and Karlshamn.

Fröberg & Lundholm Advokatbyrå

Fröberg & Lundholm Advokatbyrå’s environmental practice advises a wide range of large and medium-sized companies, both domestic and international, from various sectors, including the steel, mineral, paper, waste management and energy industries. The department has a particularly strong reputation for handling environmental permitting processes. Emma Lund, who has recent experience handling permit applications for large-scale industrial developments as well as matters concerning offshore wind sites, leads the team. Magnus Fröberg has over 30 years’ experience in a wide range of matters, and Mikael Hägglöf and Mikael Berglund have notable permitting and infrastructure projects experience, respectively.

Practice head(s):

Emma Lund


Other key lawyers:

Magnus Fröberg; Mikael Hägglöf; Mikael Berglund


Testimonials

‘The lawyers at Fröberg Lundholm are top notch when it comes to quality and service, no ask is too big or complex and they are proactive in meeting clients’ needs. Their problem solving attitude is second to none.’

‘Magnus Fröberg’s in-depth commercial and legal knowledge confers a value to his advice and work.’

‘The firm possesses a solid understanding of the challenges facing businesses and therefore provides hands-on legal advice that can be implemented practically.’

‘A very knowledgeable, professional, pragmatic and efficient team.’

Key clients

SCA


Vattenfall AB


H2 Green Steel (H2GS) AB


Northvolt AB


Boliden AB


Orsted A/S


Södra Skogsägarna ekonomisk förening


Re:NewCell AB


Ragn-Sells


SSAB


Work highlights


  • Advised Northvolt on obtaining several environmental permits.
  • Advised H2 Green Steel on obtaining an environmental permit for a new “green steel” production site.
  • Advised one of Europe’s largest energy companies in relation to three major offshore wind parks in the Swedish Exclusive Economic zone.

Magnusson Sweden

Magnusson Sweden’s environmental team offers broad combined expertise, including experience in permit applications under the Environment Code, arbitration proceedings, and wastewater treatment and contaminated soil issues. The department is instructed by several major public sector clients, including the Swedish Environmental Protection Agency and Swedish Agency for Marine and Water Management. Gothenburg-based Mårten Tagaeus, who has over 25 years’ contentious and non-contentious experience, leads the practice. Associate Sascha Andersson is also a key contact, assisting both private and public sector clients in connection with development projects.

Practice head(s):

Mårten Tagaeus


Other key lawyers:

Sascha Andersson


Testimonials

‘They are professional, correct, and focus on solving problems.’

‘Mårten Tagaeus has an excellent strategic approach to problems and challenges.’

‘Sascha Andersson and Mårten Tagaeus are a good mix of personal and professional.’

‘The team’s strength lies, in addition to their expertise, in the strategic approach to the client’s problems.’

‘The lawyers here are knowledgeable and hardworking as well as friendly but still sharp and to the point. They offer clear and persuasive argumentation in both verbal and written form.’

Key clients

Wallhamn AB


Jönköpings Kommun (Municipality of Jönköping)


Trosa Vagnhärads Mark AB


AB Gröna Lunds Tivoli (Parks & Resorts Scandinavia AB)


Hans Andersson Entreprenad AB


Gryaab AB


Varbergs Bostadsaktiebolag


Luleå Hamn AB


Sjöfartsverket (Swedish Maritime Administration)


Havs- och Vattenmyndigheten (Swedish Agency for Marine and Water Management)


Energimyndigheten (Swedish Energy Agency)


Naturvårdsverket (Swedish Environmental Protection Agency)


Work highlights


  • Assisting Wallhamn AB with its major port project, including the renovation of quays, in relation to an environmental permit application.
  • Representing the Municipality of Jönköping in a permit application for the municipality’s wastewater treatment plant named ‘Simsholmens avloppsreningsverk’.
  • Represented Trosa Vagnhärads Mark AB in the matter where the client was granted permit for environmentally hazardous activities and water activities concerning the construction and operation of one of Sweden’s largest landfills for inert waste.

Advokatfirman Vinge

Advokatfirman Vinge handles a range of contentious and non-contentious matters, including disputes concerning waste handling operations and permit applications for renewable energy projects. Johan Cederblad in Stockholm, Christoffer Thalin in Malmö, and Robert Deli in Gothenburg jointly lead the department. Thomas Sjöberg has extensive experience advising public and private sector clients on environmental law issues, while senior associate Lina Österberg is a key contact for contaminated land mandates and permit applications.

Practice head(s):

Johan Cederblad; Christoffer Thalin; Robert Deli


Other key lawyers:

Thomas Sjöberg; Lina Österberg


Testimonials

‘The team always delivers in a timely manner, with high quality and clarity. They have deep knowledge within the wind industry.’ 

‘Johan Cederblad is very competent. He is proactive in addressing any questions before they become problems and he is very easy to communicate with. His calm way of working inspires security.’

‘Johan Cederblad is super smart. He is able to identify the crux of issues quickly and provides clear advice. He is ably supported by Lina Österberg. They both are responsive, analytical in a user-friendly way and deliver consistently high-quality advice.’

‘Vinge and Johan Cederblad provide top-drawer legal support in a highly professional and pragmatic way. They are very precise in their advice and make the complicated simple.’

‘A professional, competent team led by Johan Cederblad which delivers succinct advice on time and in a clearly defined way. They are a pleasure to work with and able to deal with a raft of queries relating to environment law matters and sustainable developments relating to products and companies.’

‘Vinge has a good grasp of its subject areas and keeps up with ongoing development. They are effective and solution-oriented.’

Key clients

Vasa Vind AB


Njordr AB


Njordr Offshore Wind AB


IPCO Sweden AB


Norra Åsbo Renhållnings AB


Work highlights


  • Advised Cameco Corporation on its acquisition of Westinghouse Electric Company in a deal valued at $7.8bn.
  • Representing Njordr Offshore Wind AB in an application for the construction and operation of a large offshore wind farm in the south of the Baltic sea.
  • Advised Ingka Investments, the investment arm of Ingka Group, on its purchase of a 49% share in three offshore wind development projects in Sweden.

CMS Wistrand

CMS Wistrand’s environment practice is an established presence in the market that counts major players among its client base, specialising in matters concerning contaminated land, environmental damages, and waste handling and treatment. Gothenburg-based Rudolf Laurin has over 30 years’ experience in environmental matters, while Emilie Steen, also in Gothenburg, has experience litigating before the Land and Environmental Courts in waste facility, contamination and permitting matters.

Practice head(s):

Rudolf Laurin


Other key lawyers:

Emilie Steen; Emilia Ohlin


Testimonials

‘Rudolf Laurin is very experienced. He is very responsive to clients’ situations and has an ability to find practical solutions.’

‘A very experienced and dedicated team with broad competence in the environmental field.’

Key clients

Scandinavian Enviro Systems AB


Göteborg Energi AB


Deep Wind Offshore DWO Sverige AB


Spawer Kraft AB


Environmental Resources


Skogsägarna Mellanskog Ekonomisk förening


Västsvenska Miljökonsult/Hål i Betong i Världen AB


Gasum Clean Gas Solutions AB


Panier Svenska AB and Svanskog AB


Etikhus AB


Anticimex AB


Lidl Sverige KB


Work highlights


  • Advising Göteborg Energi AB in relation to the development of the Rya CHP plant in Gothenburg, an investment of more than SEK2bn.
  • Advising Deep Wind Offshore in relation to the construction of two new offshore wind farms located in the Swedish exclusive economic zone (EEZ) in the Baltic Sea.
  • Advising Scandinavian Enviro Systems in relation to the establishment of a plant where end-of-life tires are recycled to recover valuable raw materials such as carbon black, oil and steel.

Hellström Law

Hellström Law’s environment practice in Stockholm focuses on the environmental issues associated with renewable energy projects, including permit applications, as well as water quality regulations. Ingela Sundelin has considerable experience advising operators, authorities, and municipalities in relation to permit procedures as well as expertise in land and water contamination issues; she leads the practice alongside Arvid Sundelin, who specialises in hydro power and environmental standards regulations.

Practice head(s):

Ingela Sundelin; Arvid Sundelin


Testimonials

‘The team has profound knowledge of environmental issues generally, and water regulations issues in particular, which enables excellent and precise investigations and detailed proposals.’

‘Ingela Sundelin has a deep knowledge of environmental law, especially of the permitting issues relating to renewable energy projects. She is committed and very easy to work with.’

‘Arvid Sundelin has deep and extensive experience and knowledge of the energy business and its environmental regulations.’

‘Ingela Sundelin and Arvid Sundelin are highly skilled in environmental permitting procedural law.’

‘Their experience and competence is top notch and they have a ‘down-to-earth’ approach.’

‘The team demonstrates a professionalism based on many years of practical experience in court. The team is engaged, alert and agile.’

‘They have unique expertise in water law.’

Key clients

Arctic Sustainability Group AB


Circle K Sverige AB


Fiskarheden Trävaru AB


Svemin


Eko-Service Skandinavien


Vargön Alloys AB


Vattenfall Vattenkraft AB


Vattenfall Vindkraft Sverige AB


Statkraft Sverige AB


Freja Offshore AB


Swedenergy


Svea Vind Offshore AB


Småkraft AB


Umeälvens Vattenregleringsföreag


Confederation of Swedish Enterprise


Rockwool AB


Fortum Sverige AB


Streamgate North AB


Södra Skogsägarnas Ekonomiska Förening


Holmen Energi AB


Vattenfall AB


Work highlights


  • Representing Freja Offshore AB in the environmental permit procedures regarding building four wind power parks offshore in the Swedish economic zone, including floating wind parks and bottom-fixed wind parks.
  • Representing Svea Vind Offshore AB in the environmental permit procedure regarding building a bottom-fixed wind power park off the Swedish coast.
  • Representing Vattenfall Vattenkraft AB and Umeälvens Vattenregleringsföretag in several review processes for hydro power plants. The review processes aim is to determine new or modified permit conditions for the hydro power plants.

Advokatfirman Lindahl KB

Advokatfirman Lindahl KB’s environment practice handles a wide range of matters for private and public clients in Sweden and overseas, including permit applications for energy production and storage projects, and land and water contamination matters. Mikael Wärnsby leads the department from Malmö and has considerable experience in both transactional and contentious work. Johanna Rugart in Helsingborg operates at the intersection of energy and environmental. Specialist counsel Johanna Lindqvist in Gothenburg is also a key contact, noted for her contamination and wastewater treatment expertise, and senior associate Sara Andersson excels in contentious work.

Practice head(s):

Mikael Wärnsby


Other key lawyers:

Johanna Lindqvist; Johanna Rugart; Sara Andersson


Testimonials

‘Johanna Lindqvist has exceptional knowledge of environmental matters and is very responsive to questions. She has a very good understanding of the global manufacturing industry.’

‘Lindahl has great breadth of knowledge and expertise in Swedish environmental matters. Their intimate knowledge of local regulations as well as their connections with local experts is invaluable.’

‘Good and consistent advisers that offer pragmatic advice.’ 

‘Johanna Lindqvist is calm, analytic, to the point and can take lead in meetings and negotiations when needed. Highly recommended.’

Key clients

E.ON Energidistribution AB


Nordion Energi AB Group


Vellinge Municipality


Skandia Fastigheter Storstockholm AB


Coeli Investment Holding AB (previously Coeli Real Estate)


Eolus Vind AB


European Energy A/S


Sydkraft Hydropower AB


PreZero Recycling AB


Växjö Energi AB


Fabege AB


Orrakullen AB


Borgholm Energi AB


Flowserve Corporation


Work highlights


  • Acted for Vellinge (a municipality) in the Land and Environment Court of Appeal on the licensing of one of Sweden’s largest embankment projects.
  • Acting for European Energy A/S in the Land and Environment Court of Appeal in a landmark case regarding authorisation of one of Sweden’s largest solar power plants.
  • Advising Eolus Vind AB on licensing issues and further decisions regarding several wind power plants of varying sizes.

MAQS Advokatbyrå

With practitioners in Gothenburg, Malmö, Stockholm and Sundsvall, MAQS Advokatbyrå’s nationwide environmental department specialises in permitting matters, recently advising on the application process for a biogas plant construction project, as well as land contamination liability assessments. The team also handles disputes, recently acting in a species protection case before the Land and Environment Court. Environmental regulations expert Magdalena Persson leads the team alongside newly promoted partner Anna Almroth, who is particularly strong operating at the intersection of environmental and real estate law.

Practice head(s):

Magdalena Persson; Anna Almroth


Testimonials

‘The team is highly professional, structured and communicative.’

‘Magdalena Persson has a very high competence within the environmental field and she is very service minded and efficient. She also understood my problem and delivered a legal statement in time with solution oriented conclusions that helped me a lot.’

‘The law firm’s environment practice is service minded, supportive, effective and have a very good knowledge of the subject.’

Key clients

Ale kommun


Räddningstjänsten i Storgöteborg


Sundfrakt AB/Delta Terminal AB/Åkerigrus I Sundsvall AB (Sundfrakt group of companies)


Östersund Municipality


Krokom Municipality


PHS Hasselbacken AB


Vik Strand Holding AB


din-X Energy AB


Work highlights


  • Represented PHS Hasselbacken AB in a matter regarding a demolition permit for a pavilion, which it was claimed represented cultural/natural heritage values to Djurgården in Stockholm.
  • Assisting Östersund Municipality with the application process for an environmental permit to build and run a biogas plant, together with seven other municipalities in Jämtland County.
  • Representing Vik Strand Holding AB in a matter regarding species protection in a supervisory case which was tried by the Land and Environment Court in Växjö and finally decided by the Land and Environmental Court of Appeal.

Morris Law

Morris Law’s environmental practice handles a wide range of matters, including permit applications for traditional and renewable energy projects as well as land contamination cases. Gothenburg-based practice head Christina Rydell Ahlström offers clients broad expertise which covers permits for environmentally hazardous activities and contamination liability matters.

Practice head(s):

Christina Rydell Ahlström


Testimonials

‘Morris Law’s environmental law team is very professional and efficient. They are experienced enough to be pragmatic and focus on the important matters.’

‘Christina Rydell Ahlström is a flexible and problem-focused environmental lawyer with the ability to explain and make legal questions understandable for clients.’

‘Christina Rydell Ahlström is very competent in environmental law generally, and specifically in contaminated land issues.’

‘Christina Rydell Ahlström is always there when she is needed. She has a high level of competence in the work of municipal environmental authorities and legal issues, which inspires confidence. She is a very nice person, easy to talk to and discuss with, and she always delivers on time.’

‘Great individuals with a great mix. Everyone is agile.’

‘There is a broad knowledge within the practice and a family atmosphere that creates trust. They are easy to communicate and do business with.’

Key clients

The municipality of Ale


Varberg Energi AB


Hammarö Energi AB


Tekniska verken i Linköping Vind AB


Gasum AB


Work highlights


  • Advising the municipality of Ale regarding the liability for contaminated land within the former industrial area Älvängen.
  • Advising Varberg Energi AB, a municipality-owned energy company in western Sweden, regarding a restructuring of the company’s organisational structure.
  • Assisting Hammarö Energi AB, a municipality-owned energy company, with a case regarding a solar park that is supposed to be built within an area covered by shore protection.