Official Journal of the European Union

C 317/75

Opinion of the European Economic and Social Committee on the ‘Mid-term assessment of implementing the EC Biodiversity Action Plan’

COM(2008) 864 final

(2009/C 317/13)

Rapporteur: Mr RIBBE

On 16 December 2008 the Commission decided to consult the European Economic and Social Committee, under the first paragraph of Article 262 of the Treaty establishing the European Community, on the

Mid-term assessment of implementing the EC Biodiversity Action Plan

COM(2008) 864 final.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 18 June 2009. The rapporteur was Mr Ribbe.

At its 455th plenary session, held on 15 and 16 July 2009 (meeting of 15 July), the European Economic and Social Committee adopted the following opinion by 162 votes to 3 with 7 abstentions.

1.   Conclusions and recommendations

1.1   The EESC is very disappointed that the goal of halting the loss of biodiversity by 2010 will not be achieved.

1.2   However, it is encouraging that the Habitats and Birds Directives have resulted in positive developments for some habitats and species. This shows that European legislation on nature conservation works if it is properly applied.

1.3   All the same, it is unable to halt the continuing serious biodiversity loss outside protected areas resulting from economic practices which are completely legal. The EESC agrees with the Commission that the mainstreaming of biodiversity considerations has not yet gone nearly far enough.

1.4   Nevertheless, the EESC feels that no fundamental changes are needed to the objectives. Rather, the Commission and Member States must themselves show greater commitment to the existing appropriate objective of stopping biodiversity loss and restoring natural habitats, which was already defined in 2001, and defend it more energetically in future.

1.5   From the perspective of economic policy, nature conservation is often seen as an obstacle or a threat. The argument that biodiversity has economic value has yet to be taken on board in political practice. We would like to ask the Commission to explain how it intends to resolve this problem, for example in relation to the discussion on stronger internalisation of the external costs.

1.6   More publicity should be given to examples of positive developments showing the close correlation between regional economic development and biodiversity (e.g. tourism).

1.7   The Council decision to fund Natura 2000 from Structural Fund resources and the second pillar of the CAP has not worked; Member States are simply not giving nature conservation and biodiversity protection enough priority in the relevant programmes. For the 2014-2020 funding period, the EESC is in favour of giving biodiversity its own budget line. The incentive component of agro-environmental programmes must be reinstated.

1.8   In numerous regions and on many sites, such as moorland, mountains, coastal areas, grasslands and river basins, protecting and restoring natural habitats also helps significantly to combat climate change. Although there are clearly many other reasons for preserving biodiversity than combating climate change, climate and biodiversity policies should still be linked even more closely.

1.9   To enable species to adapt to changing climate conditions, their habitats need to be more closely inter-connected. We should consider creating a ‘trans-European nature network’.

1.10   One major nature conservation problem is that more and more land is being built on or used for roads and thus ‘closed off’ to nature. This type of land use must be reduced in Europe.

1.11   Nature conservation enjoys extensive support in civil society, but people do not know nearly enough about it. The EESC is pleased that greater attention is finally to be given to raising awareness of the need for understanding of the reasons for biodiversity loss, and to promoting the necessary counter-measures. Such measures include improved information to consumers on the impact of various production processes and the development of sustainable production practices.

2.   The European Commission communication

2.1   In its communication, the Commission comes to the worrying conclusion that, despite the Biodiversity Action Plan presented in 2006 and the 160 measures which it envisages, ‘it is highly unlikely … that the overall goal of halting biodiversity loss in the EU by 2010 will be achieved. This will require significant additional commitment by the European Community and the EU Member States over the next two years, if we are even to come close to our objective’. Since then, European environment Commissioner Dimas has admitted that the goal of halting biodiversity loss by 2010 will not be achieved!

2.2   Biodiversity loss at global level is described as ‘disastrous’. Not only are natural processes disrupted, but there are also severe economic and social impacts. The Commission notes that Europe shares the blame, not least for negative developments at global level. For example, ‘new issues, such as expansion of the agricultural sector to meet increasing demand for food, and the emergence of alternative market outlets such as biofuels, have emerged as major challenges’.

2.3   Although there are many reasons for the general lack of results achieved by biodiversity policy so far, the Commission sums it up in its mid-term review: ‘Integration of biodiversity considerations into other sectoral policies remains a key challenge’. One decisive factor in the sobering picture painted by the mid-term review is that no real progress has been achieved over the past few years on mainstreaming biodiversity concerns into other policy areas.

2.4   Results from the first major 'health check' of the Biodiversity Action Plan show that 50 % of species, and possibly up to 80 % of habitat types which are protected under the Habitats Directive (1) and are of European conservation interest ‘have an unfavourable conservation status’.

2.5   However, a few species protected under the Habitats Directive or the Birds Directive are also showing some incipient positive trends. The decline of some protected species has been halted: ‘the Directive has clearly helped these species, especially through the designation of Special Protection Areas’.

2.6   The Commission notes that the Natura 2000 network now comprises more than 25 000 sites, covering around 17 % of the total land area of the European Union. Trends are particularly negative outside protected areas.

2.7   The Commission discusses the initial findings of the study on The Economics of Ecosystems and Biodiversity (TEEB) (2) (the Sukhdev Report). On similar lines to the Stern report on climate change, this report concludes that biodiversity should be preserved not only in view of moral considerations but also economic ones. ‘This loss of biodiversity and ecosystems is a threat to the functioning of the planet, our economy and human society. The annual welfare loss generated by the loss of ecosystem services by 2050 in a “business-as–usual” scenario has been estimated at 6 % of global GDP’.

3.   General comments

3.1   For the first time, the EU is now publicly admitting that one of the key environmental promises made to the public by both heads of states and governments and by the European Commission concerning the halting of biodiversity loss by 2010 will not be kept.

3.2   For the EESC this admission comes as no surprise, given that its opinion on the Action Plan the Committee agreed with the Commission's critical analyses and felt that all of the 160 proposed measures were fundamentally correct and necessary, while at the same time expressing serious doubts as to whether government departments, policies and politicians not directly involved in biodiversity policy were ready and committed to making the requisite efforts. Unfortunately, these doubts have now been borne out.

3.3   Unfortunately, the EESC's views on the biodiversity action plan remain just as true as at the time of their adoption two years ago at its plenary session. At the time, the Committee's exact words were as follows (3):

The EESC and the Commission agree in their assessment of the situation: maintaining biodiversity is an essential, key task which does not only represent an ethical and moral obligation. There are also sufficient economic reasons why it is necessary to act more quickly and more effectively. The cost of the economic losses brought about by the decline in ecosystem services is already at the present time estimated at several hundred billion euros. This constitutes a waste of resources which our economies simply cannot afford to bear.

Species decline in Europe is the result of millions of individual value judgements which have been taken in recent decades; the absolutely overriding majority of these decisions have been taken in accordance with existing laws. The share of responsibility for species decline in Europe which can be attributed to illegal measures is marginal.

Despite the political promises which have been made, the trend as regards biodiversity regrettably continues to be negative; this cannot, however, be put down to a lack of knowledge about how to tackle species decline. What has been missing up to now is the political will to effectively implement the measures which have long been acknowledged to be necessary. The experience gained with the Natura 2000 network speaks for itself.

The reasons which lie behind this situation are rightly identified by the Commission in its Communication and include ‘governance failures and the failure of conventional economics to recognise the economic values of natural capital and ecosystem services’.

What happens in future will thus demonstrate whether, with the presentation of this action programme, the world of politics will now really find the strength to bring about the ‘substantial changes’ which are recognised as being necessary or whether, on the other hand, the fears of many nature conservationists will turn out to be true, namely that politicians are indeed once again discussing a highly-charged area of social policy but they go no further than paying lip service to the issues involved.

The EESC therefore attaches particular importance to prioritising policy area 4, namely ‘Improving the knowledge base’, so as to ensure that both the general public and politicians are aware of the real consequences of their actions.

3.4   In its current communication, the Commission confirms many of the factors previously noted, which are continuing to impact on biodiversity loss. In view of this, no fundamentally new EESC opinion is needed; instead, we shall discuss aspects which are new or have changed over the past two years.

4.   Specific comments

Legislative framework and governance

4.1   Recent years have clearly shown that EU nature conservation directives can be used to encourage positive developments, provided they are properly applied and that the concerns of landowners are properly dealt with (4). However, the EESC also notes that there are still many problems within the N2000 areas which need to be addressed. Besides, ‘only’ 17 % of the EU's land area is under the protection of the relevant EU directives.

4.2   Now that establishment of the NATURA 2000 network is, after considerable delays, finally nearing completion, European nature conservation is entering a new stage. Appropriate management plans must be drawn up for the designated areas. The EESC doubts whether sufficient human and financial resources are in place in the Member States to ensure that their development is planned and implemented at national level. It is vital that such plans be drawn up in close coordination with all social groups concerned, as this is the only way to secure acceptance for them.

4.3   Given the enormous pressure on land, which the Commission rightly notes, the question of whether extensive regeneration of destroyed biotopes is feasible remains unanswered. The EESC points out that at the Gothenburg summit, the heads of state and government promised to take steps not only to halt biodiversity loss by 2010, but also to restore habitats and natural systems. The mid-term review does not comment on this.

4.4   The NATURA 2000 network has only just been established, and already people are discussing how to withdraw individual sites or parts of sites from the network, mostly for infrastructure projects, many of which are co-financed by the EU. The Commission's communication actually mentions the best-known example – the Rospuda Valley in north-east Poland. Although the new Polish government is now looking for alternative Via Baltica routes, it is very clear that we are not even close to resolving the conflict between nature conservation and economic development.

4.5   In view of this, we can hardly doubt that EU departments will be faced over the next few years with a flood of applications for similar ‘exemptions’. At present, the EESC does not feel that the Commission has the necessary human resources to process these requests or to find appropriate solutions.

4.6   In its opinion on the biodiversity action plan, the EESC itself pointed out that biodiversity is clearly still being lost from our man-made landscapes, notwithstanding good practices and what are described in EU legislation as good agricultural and environmental conditions - not as a result of illegal activity but in compliance with legislation, which is unacceptable.

4.7   For this very reason, there is also considerable controversy surrounding the ‘cross-compliance criteria’. Together with good agricultural and environmental conditions and best practices, these should ensure that biodiversity issues are taken into account. However, given that much of the damage to biodiversity takes place in compliance with existing laws, one can easily understand the controversy surrounding these criteria. This point is backed up by the European Court of Auditors in its special report on cross compliance. The Member States, together with the Commission, must finally take action.

4.8   This also applies to many proposed laws which at first sight are of no direct relevance to biodiversity. In order to combat BSE/TSE, Regulation 1774/2002 prohibited leaving dead animals in the open countryside. This has resulted in a severe lack of food for scavengers such as wolves, bears or vultures. Sightings of vultures far from their few habitats is by no means a positive sign, but simply reflects the fact that hunger is forcing these rare animals to travel large distances. It was environmental groups and a Spanish MEP who drew attention to this problem in EU legislation – the Commission only responded after a very lengthy delay. It would seem that preliminary biodiversity impact assessments are not being carried out.

Political implications/funding

4.9   Especially outside protected areas, the conflict between economic land use and nature conservation/biodiversity remains unresolved. The Commission also points out that it has made various proposals in this respect as part of the health check on agricultural policy, for example making available ‘additional rural development funding for inter alia biodiversity, via an increased transfer of money from the first to the second pillar of the CAP (i.e. modulation)’. Unfortunately, the Council did not decide to adopt all of these proposals. The Member States are not taking enough of the steps which the EU acknowledges as necessary.

4.10   One such problem is the funding of the N2000 network, including compensation for special requirements. The EESC is very concerned that after programming by the Member States not nearly enough money has been made available to Natura 2000, resulting in extreme conflicts. It is therefore in favour of giving biodiversity its own budget line for the 2014-2020 period.

4.11   Overall, the Committee strongly advocates better and more target-oriented financing of nature conservation. In its opinion on the biodiversity action plan, the EESC has already pointed out that:

direct payments to farmers, which comprise the greater part of the agricultural budget, are not geared to promoting biodiversity, but are designed rather to prepare farmers to meet the challenges of world markets;

‘as long as world-market conditions tend to hinder the widespread adoption of farming practices which are in line with the goals of nature conservation, special policy measures will be required’ which could, for example, mean that ‘agri-environmental aid should be increased to a level where all farmers in the EU are prompted to switch to “green” production methods’  (5). Here, too, what has been achieved in reality lags behind the goals which have been announced.

4.12   We would ask the Commission to finally clarify the situation with regard to forthcoming CAP reforms and the budget. Agri-environmental programmes can only succeed when they offer economic incentives to farmers. Getting rid of the incentive component was a mistake, which must be reconsidered. The political message to farmers (and society) must be that we as a society appreciate when farmers go over and above legal requirements to preserve biodiversity.

4.13   Discussions are beginning in the Member States on how to develop agricultural policy, and these are – not least in view of the need to make more extensive use of renewable energy sources, including bio-energy – relevant to biodiversity, at both national, European and international level. The European Commission notes that ‘a key challenge will be to ensure that the recommendations made in Sustainability Impact Assessments (SIAs) are acted upon and to enhance our understanding of the impact of EU consumption of food and non-food commodities (e.g. meat, soy beans, palm oil, metal ores) that are likely to contribute to biodiversity loss. This could lead to considering policy options to reduce this impact’. The EESC calls on the Commission to work intensively on the relevant studies.

4.14   The post-2013 CAP reform will therefore show whether we can succeed in bringing more biodiversity protection and sustainability into agricultural policy.

Overarching and economic aspects

4.15   The EESC notes that consistent nature conservation efforts can also support climate policy objectives. For example, protecting and restoring moorlands and wetlands helps to combat climate change. The same applies to the use of European grasslands in all their various forms (such as the Dehesas on the Iberian peninsula). However, many of the agricultural activities needed to maintain such habitats have become less and less viable for farmers over the last few years – biodiversity has no marketable value! Prices do not reflect the environmental impact of manufacturing a product. European and national policies have not found an adequate solution to this problem yet.

4.16   For example, in May 2006, the very same month in which the Commission launched its biodiversity action plan, 15 of the 16 German Länder called for an amendment – i.e. watering down – of the EU's Nature Directives. The Land of Hesse in particular has continued to advocate such changes, invoking, among other things, the (economic) argument that industrialised countries cannot afford to comply with such rigorous nature conservation requirements. This shows that many politicians are unaware of the economic significance of biodiversity.

4.17   What is striking is the almost complete indifference of the public and politicians in response to the estimate in the TEEB Report that biodiversity loss could cost up to 6 % of global GDP, whereas the current financial and economic crisis – which has cost a far smaller percentage of GDP – has triggered crisis summits and billion dollar recovery programmes. One of the Commission's main tasks will be to raise awareness of the economic value of biodiversity together with its moral and ethical significance, and to translate this into actual policies.

4.18   Biodiversity in the Member States remains under intense pressure; one major nature conservation problem is that more and more land is being built on or used for roads and thus ‘closed off’ to nature. Land is still far too heavily used for such purposes, and the pressure on the countryside is constantly rising. Nature conservation concerns are at risk of being marginalised.


4.19   In Section E. 4 of its communication (‘Building public education, awareness and participation’), the Commission observes that ‘only a minority of EU citizens considered that they were well informed on the subject of biodiversity loss’. The same might be said of politicians and civil servants. These are the worst possible conditions for achieving political success. If the Commission and Member States are considering ‘priority actions for a public communication campaign to be launched in support of national and other campaigns’, they can count on the EESC's full support.

4.20   There are already many positive awareness-raising initiatives, including in cities, where people often have less direct access to nature. Such initiatives should be given more government support. For example, there is an annual ‘Long Urban Nature Day’ event in Berlin, attracting several hundred thousand people.

4.21   The Committee feels that it is important for the public to be made aware in as concrete and direct a way as possible of specific nature conservation issues, for example, by explaining locally where – and why – areas are designated as part of the NATURA 2000 network, which species occur there, how they can be protected, and by whom. The public must be able to truly experience and understand nature conservation. Not many people understand the concept of ‘biodiversity’, and it conveys very little to them.

4.22   In the interest of consumer information, the EESC urges that producers be given the option of stating on product labels whether particular production processes favouring nature conservation have been used.

Active public involvement in environmental protection and biodiversity preservation is vital. Commission campaigns to promote more sustainable lifestyles are not enough. We also need strategies to equip consumers with practical tools enabling them to assess the impact of their daily actions, thus bringing about the necessary change in consumption patterns.

Such measures could include:

including lessons with practical information on environmental protection and biodiversity in school curricula; and

devising instruments to measure the impact of consuming particular foodstuffs on biodiversity (based on a shopping basket of selected daily products and possible alternatives) on a methodological basis of lifecycle analysis.

Brussels, 15 July 2009.

The President of the European Economic and Social Committee

Mario SEPI

(1)  Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora (Habitats Directive).

(2)  http://ec.europa.eu/environment/nature/biodiversity/economics/pdf/teeb_report.pdf.

(3)  OJ C 97, 28.4.2007, p. 6.

(4)  OJ C 97, 28.4.2007, p. 6.

(5)  ‘The situation of nature and nature conservation in Europe’ (OJ C 221 of 7.8.2001, pp. 130-137).