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Biom Association

Biom

Association Biom is a voluntary, non-governmental organization dedicated to nature conservation, promotion and popularization.

Lobbying Activity

Response to Roadmap towards Nature Credits

30 Sept 2025

The Association Biom BirdLife Croatia welcomes the opportunity to provide comments on the European Roadmap towards Nature Credits. The latest report by the European Environment Agency on the state of Europes environment presents alarming findings, showing that many ecosystems and species are at risk of irreversible damage or extinction. Additionally, the 4th Environmental Implementation Review highlights a serious funding gap in environmental protection. Engaging the private sector in nature conservation and unlocking new sources of finance therefore holds great potential. This is especially relevant for Croatia, where the funding gap exceeds the European average and only one third of the required funding for biodiversity and nature protection is currently allocated. However, considering the scale of investment needed to implement the Nature Restoration Law and manage the Natura 2000 network, nature credits can only cover a fraction of the required costs. They must not be seen as a substitute for robust public investment and broader policy reforms, including the phasing out of harmful subsidies. Nature credits can play a supporting role in driving innovation in biodiversity conservation and restoration, improving biodiversity monitoring and restoration techniques, and fostering more informed decision-making. As a BirdLife partner with long-standing experience in collaborating with companies and private entities on nature protection, we acknowledge the potential of such mechanisms when applied appropriately. To avoid potential loopholes in a future nature credits market, nature credits must be fully integrated and closely aligned with existing EU legislation such as the Nature Restoration Law. In order to increase transparency and minimise risks of greenwashing, it is essential to align the nature credits framework with the Corporate Sustainability Reporting Directive, Sustainable Finance Disclosure Regulation, EU Taxonomy Regulation, and the Green Claims Directive. Lessons from the voluntary carbon market must be taken seriously to avoid enabling harmful practices and greenwashing. Measuring biodiversity is inherently more complex than carbon, particularly in the context of offsets, which risk undermining the principle of ecological responsibility and do not guarantee tangible biodiversity outcomes. Nature credits should be designed to deliver clear, measurable, and additional biodiversity benefits that go beyond legal obligations not to serve as substitutes for regulatory compliance or compensation mechanisms. The metric used in the framework should be clearly defined, policy-oriented, and account for the risk of credit development failure. The system should be grounded in strict scientific standards, with clear criteria, independent monitoring, auditing and certification, and transparent rules regarding claims and potential breaches. Finally, strong environmental laws such as the Nature Restoration Law are key to creating demand for nature credits. The current deregulatory agenda risks undermining both the effectiveness and credibility of nature credits as a tool for conservation.
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Response to EU Civil Society Strategy

4 Sept 2025

Civil society organisations (CSOs) play a crucial role in safeguarding democratic society. They represent the public interest and ensure political participation for stakeholders who are often underrepresented, including citizens and various minority groups. CSOs promote human rights as well as environmental and climate justice - issues that, in the current global geopolitical context, are increasingly marginalised. They also serve as watchdogs, monitoring authorities and exposing discrimination, legal violations, and corruption. By strengthening citizen activism and local communities, CSOs contribute to democratic engagement and civic participation. Additionally, CSOs implement educational programmes, workshops, and initiatives that facilitate active citizen participation in political processes, while promoting volunteering and reinforcing democratic values. By fostering cooperation and solidarity, they create sustainable, interconnected communities and drive meaningful social progress and wellbeing. The work of CSOs is particularly critical in addressing the greatest environmental crises of our time: the climate crisis, biodiversity loss, and environmental pollution. Alongside indigenous communities, grassroots initiatives, and activists, CSOs are often on the frontlines of efforts to mitigate these crises and promote sustainable solutions for a liveable planet. Unfortunately, these vital roles have been increasingly undermined in recent years. Civil society organisations now face significant challenges, including constant attacks and smear campaigns, restricted access to funding, surveillance and censorship, SLAPP lawsuits, and attempts to delegitimise their work. The Association Biom supports the initiative to create an EU Civil Society Strategy. Such a strategy must include a comprehensive EU system for protecting human rights and environmental defenders, as well as civil society organisations. This should provide legal, financial, and digital security support, and include recommendations to promote civil society participation at the national level. Civil Dialogue must be preserved and expanded, with robust frameworks developed to ensure the meaningful engagement of civil society in policy processes and decision-making. We support the establishment of a binding agreement between the European Commission, the European Parliament, and the Council of the European Union that guarantees the regular participation of civil society actors at every stage of the policymaking process. The Strategy should also encourage Member States to develop national civil society engagement frameworks. In addition, dedicated support for civil society should be allocated within the new EU Multiannual Financial Framework (MFF). Specifically, the LIFE Programme and its Operating Grant should be maintained as a standalone dedicated programme managed by the European Commission and it should be further strengthened.
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Response to Export and import of hazardous chemicals

1 Aug 2025

As a concerned non-governmental organisation from Croatia working in the field of nature protection, we call on the European Commission to take decisive action and end the export of pesticides banned in the EU due to proven risks to human health and the environment. It is deeply unjust that substances deemed too dangerous for use within Europe - because they are linked to cancer, infertility, neurodevelopmental harm in children, and environmental degradation - are still being manufactured by EU companies and shipped to countries with weaker safety regulations. The consequences for communities and ecosystems in these regions are devastating. This is not simply a regulatory inconsistency - it is a clear case of double standards. And double standards of this kind are not only unethical, they undermine basic principles of human rights and global environmental justice. Any revision of Regulation (EU) 649/2012 must ensure that the EU fully bans the trade of all pesticides that are prohibited for use inside its borders. The current proposal falls short. Requiring only prior informed consent for exports does not meaningfully prevent the harm these substances cause. Take, for example, carbendazim - a known mutagen and reproductive toxicant. There is no ethical justification for exporting such a hazardous substance as a pesticide, regardless of consent or destination. This is not a technical issue. This is a matter of responsibility - and of ethics. The EU must uphold its values and lead by example. End the export of banned pesticides - without exceptions, and without delay. In the attachment we send the joint statement signed by 600 organisations, that was signed by the Association Biom, too.
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Response to Simplification of the implementation of CAP Strategic Plans

1 Aug 2025

The CAP must remain a tool for sustainable farming not a threat to nature At a time when the Common Agricultural Policy (CAP) should play a key role in aligning European agriculture with environmental and climate challenges, the proposed changes under the so-called Omnibus Regulation move in the opposite direction. Instead of reinforcing common rules and supporting sustainable practices, they propose further weakening of essential environmental standards, which could jeopardise nature, the climate, and the credibility of the CAP itself. Particularly concerning is the renewed attempt to dilute the the baseline standards for Good Agricultural and Environmental Condition that apply across all Member States. These standards are not just about protecting natural resources; they also ensure fair and equal conditions for farmers throughout the EU. When such rules are watered down or delegated to national interpretation, consistency is lost and the risk of unfair competition increases. In the past year, serious concessions have already been made the obligation to set aside non-productive land was removed, and rules on crop rotation and soil protection were relaxed. The new proposals go even further by targeting grasslands, peatlands, wetlands, and buffer zones along water bodies. Allowing up to 10% of regional grassland to be converted could result in the loss of vital habitats and significant carbon stocks. Especially problematic is the full exemption for organic farms, even though organic certification does not automatically guarantee grassland protection. In many regions, it was precisely the existing CAP rules that helped stop the decades-long decline of permanent grasslands. Weakening them now risks reigniting those negative trends, particularly in countries lacking complementary national safeguards. The same logic applies to peatlands and wetlands, which play a crucial role in climate mitigation, carbon storage, and resilience to extreme weather. Keeping water in the landscape is becoming increasingly vital, yet the proposal to shift responsibility for their protection to Member States opens the door to fragmented implementation and lower ambition. As for buffer zones along water bodies, the current GAEC rules already represent a minimum level of protection. The proposed changes point in a worrying direction towards fewer obligations and a weaker CAP, undermining its role as a common European framework for nature conservation and climate action. Farmers indeed need simpler and clearer rules, but simplification must not mean abandoning core environmental principles. Basic standards must not become bargaining chips they are the foundation on which a more sustainable system can be built, complemented by support for those who go further. If the CAP is to remain a relevant and fair European policy, we must ensure that everyone plays by the same rules not just on the market, but in their responsibility toward nature.
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Meeting with Biljana Borzan (Member of the European Parliament) and Stichting BirdLife Europe

13 Nov 2024 · Consumption of lead in meat/illegal pesticides

Meeting with Gordan Bosanac (Member of the European Parliament)

15 Oct 2024 · Environmental situation in the Adriatic Sea, Repower EU, Green Deal

Meeting with Biljana Borzan (Member of the European Parliament)

1 Oct 2024 · ENVI topics in general

Response to New EU Forest Monitoring and Strategic Planning Framework

7 Feb 2024

The forest cover in Croatia is in increase for decades but that does not reflects the state of the forests in Croatia. The current definition of forest is misleading, as it can include land that is or has recently been used for agriculture, as well as non-native plantations and even tree-less areas (i.e., clearcuts where forest regeneration is planned). Tree plantations used primarily to produce biomass should be regarded as agricultural crops or tree farms rather than forests. The effects of climate change and harmful management practices, such as large-scale clear cutting of old-growth forests, are actively threatening forest ecosystem integrity. At the same time the demand for wood and biomass and long-term carbon storage is increasing. To effectively align management with external pressures and the increasing demand for wood, harmonised data is needed. The current forest monitoring data in the EU suffers from some notable differences in standards, detail-depth, and collection methods, and even the basic definition of forest is different in different countries. Because of this, there is an urgent need to consolidate and harmonise this patchwork and to add ecosystem data in greater detail. This data must be accessible to any stakeholder involved in forests in the EU, not only forest management agencies, reflecting the broad range of ecosystem services delivered to different stakeholders. BirdLife also highlights the importance of the proposal in serving the aims of the Green Deal and the EU Forest and Biodiversity Strategy by monitoring the ecological integrity of forests to a greater extent as well as further aspects relevant for healthy and resilient forests. Association Biom (BirdLife Croatia), also sees the mapping of all still existing old-growth and primary forests as a positive step of great importance but would strongly encourage that the already mapped old-growth forests be reported immediately, without having to wait until 2028. Furthermore, Biom recognises that old-growth forests could benefit from EU wide definition. Association Biom also recognises the importance of the proposal reflecting economic aspects and wood flows by allowing the full traceability of logged wood and by tracking forest financial flows. Association Biom also appreciates that the proposal has good indicators, which actually represent the status quo and reflect harmonised definitions. However, ideally reporting could be extended to include yet more indicators such as naturalness of composition, carbon stock and carbon removal capacity, origin of forests, existence of any certification in the forests, ecosystem services evaluation, and restoration needs. This last indicator can be pivotal in assisting MS in fulfilling their obligation under Article 10(1) of the NRL Member States shall put in place the restoration measures necessary to enhance biodiversity of forest ecosystems (...). The harmonisation of monitoring proposed also increases the transparency of the EUs forest state and management. It also provides accessible, traceable and coherent data to support management and societal discourse. Whilst all this is undoubtedly positive, the addition of a specific provision on improving public access to forest management plans could be beneficial. Association Biom also supports that the proposal will allow for the tracking and identification of illegal logging and facilitate the monitoring of the values of ecosystem services and see trends in their change. BirdLifes assessment of this proposed law is overwhelmingly positive, but the fact that long term forest plans are not mandatory and that there is no obligation for MS to take positive strategic action based on data collected are noteworthy hindrances that need addressing. Furthermore, we welcome the inclusion of a Forest Bird Index as it will also bring more clarity on the real state of EU forests. Potentially lists could be split between specialists and generalists as done in the UK.
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Response to Energy transition of EU fisheries and aquaculture sector

5 Dec 2022

Economic viability and resilience of the EU fisheries and aquaculture sector should take into an account the environmental sustainability as well as the fact that fisheries and aquaculture depend on natural resources and their sustainable use. EU climate ambitions clearly state the need to move from the dependence on fossil fuels to renewable energy sources (RES). And these sectors need to contribute to mitigation of the climate change. Therefore, fossil fuels should not be subsidized, instead RES should be supported. Fleet that is old and inefficient should not be supported. Investment in fuel alternatives, alternative gear and low carbon propulsion systems should always be part of an overall reduction in fisheries capacity. Environmental friendly aquaculture practices and low-impact fishing gear are the ones that will ensure sustainability and resilience of the sector. Overfishing, over MSY is not economically viable in the long-term. Due to depletion of fish stocks, fishing efforts are increasing, which results in even more usage of fossil fuels. Therefore public funds should not be allowed where they contribute to overfishing. In order to support the energy transition, it is necessary to provide greater transparency, monitoring and traceability throughout the EU fisheries sector (by mandating REMs and VMS on as many as possible vessels). Considering that the initiative is expected to contribute to tackling the problems that result from unsustainable and vulnerable food production (such as air and water pollution, climate change and the degradation of ecosystems), the overall approach should take into an account: - serious impacts that bottom-trawling has on sediment, habitats, fish stocks and other marine species - to set fishing opportunities (TACs) below MSY, and to include the impact of climate on fish stocks and the ecosystem role of forage fish when setting TACs and quota - establishment of no-fishing zones allowing effective and long-term marine restoration - impacts from any changes to fishing practices and gears, e.g., increased bycatch of certain species in some passive gears, and take mitigation measures.
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Response to Sustainable use of pesticides – revision of the EU rules

19 Sept 2022

We strongly support in its entirety PAN Europe's position paper on the SUR draft. Therefore and in addition, we ask for: - a clear plan for the gradual replacement of all synthetic pesticides with non-chemical solutions until 2035, as asked by EU citizens in ECI Save Bees and Farmers - food security is to be ensured by establishing a system based on the experiences and results of the existing successful agroecological farms that have been providing positive results, both in yields and income, for many years, on a large scale CAP to incentivize low-impact, climate and environmentally friendly agriculture, redirecting incentives from livestock production to plant production - the change of the name of the regulation - products that destroy plants are not the products for the protection of plants all areas inhabited by people, or used by people, should be classified as "sensitive areas"; pesticide use should be prohibited in all sensitive areas - obligation for NAPs to be approved by the European Commission - immediate ban of use for 54 candidates for substitution - improvement of indicators for calculating the use and risk of pesticide use, so that the actual risk can be calculated, taking into account the weight of less toxic substances - improvement of advisory systems that should be completely independent of the industry and that should strongly promote IPM - competent authorities responsible for the implementation of the system for the training and certification cannot be by any means related to the agroindustry - establishment of a unique data collection system for recording the use of IPM and the sale and use of pesticides - all data on pesticide use should be made public - public has the right to know about the emissions into the environment - introduction of regular independent controls that will verify the regularity of record keeping in the application of IPM and the use of pesticides - ban the advertisement of pesticides
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Response to Guidance on accelerating permitting processes for renewable energy projects and facilitating Power Purchase Agreements

25 Jul 2022

- On the process: We criticize that the REPowerEU package with changes to the Renewable Energy Directive was not discussed properly before being published. - Go-to areas: We believe designating go-to areas outside protected and vulnerable areas can be part of the solution to achieving faster deployment of renewable energy installations. The designation of “go-to areas” should identify locations that have adequate energy and economic potential, but where it can be expected that the impact of renewable energy projects will be less. If they are designated using strategic spatial planning using scientifically sound sensitivity mapping, are technology-specific (excluding hydropower and bioenergy), they can create a win-win for tackling both the climate and biodiversity crisis and helps speed up the deployment because strategic planning minimizes conflicts between renewable energy projects and biodiversity. In order to achieve the purpose of steering renewables to “go-to” areas, we see the need for further improvements, through at the same time designating certain areas as “no-go areas”. - Concerning the planned permitting procedure rules: The biggest point of concern with the EU proposal to change the RED relates to the changes for permitting procedures: While SEA should be undertaken for all renewable energy and network infrastructure plans, these are supplementary and cannot replace an EIA at the project level. EIAs and the HD AAs as well as the WFD assessments are important to not only determine environmental impacts but also socio-economic, cultural, and human health impacts. Instead of disregarding EIAs, which are not the cause of the delay in development, understanding local needs and environmental impacts will make the energy transition faster, more accepted, and legitimate. Upstream, proper strategic planning should help faster deployment because it can streamline EIAs. The more problems have been avoided upstream, the less long and detailed EIAs would need to be. The now proposed changes will not speed-up procedures, as it heavily impacts existing legislation, not only on the EIA, but also on the strict species protection from the BD and HD. - Permitting procedures outside go-to areas and strict max deadlines for permitting procedures: There is no need for having changes to the permitting procedure outside “go-to areas”, as we should focus renewables into those “go-to areas”. Also, having strict deadlines for the maximal duration of permitting procedures is not helpful, as it might lead to unlawful permitting, given that there is high probability that authority staffing is not sufficient to work on all permitting requests. Examples of this are seen in the letter of formal notice issued towards Croatia in May 2020 due to incorrect application of EIAs. - Concerning the general provision of the Overriding Public Interest: Blanket exemptions under the pretense of IROP will also not help speed up development. It opens a pandora's box and could lead to further environmental deregulation that has neither useful for climate action nor any biodiversity value, such as the extraction industry. - Staffing of authorities: The biggest barriers to the fast deployment of renewable energy sources so far have been inefficiencies in the licensing process and understaffing of the public authorities in charge of licensing. The competent Ministry in Croatia has only 3 staff working on state-level appropriate assessments for projects and a similar number for strategies. Without these issues being tackled, renewable energy projects will not be able to be built in an adequate time. Member States need to allocate appropriate resources to licensing authorities, and remove unnecessary, obsolete, incoherent, or excessive obstacles in their licensing procedures.
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Response to Evaluation of the LIFE Programme 2014-2020

10 Apr 2022

LIFE Program has been instrumental for nature conservation organisations in Croatia. There exists no national funding scheme / program for nature conservation organisations. Unfortunately this resulted in many environmental NGOs not having staff any more, as they are not big enough for EU funding. LIFE is the most important EU nature conservation program and a very successful one. Even though it is envisaged as "seed" program, the reality is that some MS do not have any nature conservation / biodiversity funding available at all. LIFE Program should get more funding as it contributes greatly to the implementation of the Nature Directives and increase of funding should not go towards governments only, as MS such as Croatia are still very inadequately equipped to implement strategic / integrated projects (there has not been one strategic / integrated LIFE project in Croatia). Higher financing rates, at least for NGOs, would significantly contribute to higher application rate, as NGOs need to secure very high rate of co-financing even when they use all available national co-funding mechanisms (there are 2 available to NGOs - which means 1 NGO reports to at least 3 entities for the implementation of 1 project). Technical monitoring system works really well, but similar is needed for project administration - e.g. financial monitors should be available. For new grantees there should be more administrative / financial support available as it is too long to wait until the Midterm report to be sure one is on a right track. Better integration of rural development (CAP) and LIFE Program should be enabled, so that ex-agri-environment schemes of the rural development program could be used for co-funding LIFE projects. The same goes for EMFAF which should also support biodiversity conservation through co-funding LIFE projects. Concept notes should be reintroduced. Also, funding for project preparation should also be allowed, as is allowed by the Interreg Program.
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Response to Revision of EU Programme for biological, environmental and socio-economic data collection in fisheries and aquaculture

15 Mar 2021

The lack of data on the occurrence and level of bycatch of sensitive species hinders the ability to manage and apply rules on fishing vessel activities. Even where data exists, the lack of statistically robust and harmonised sampling designs limits its value. Due to the irregularity of catches of vulnerable species, calculations based on limited observer data lead to high biases, resulting in an underestimate of bycatch. Adequate monitoring programmes and frameworks providing sound bycatch data collection, with adequate coverage and reliable information, are urgently required. Therefore, the Delegated Decision should include the following: • All fishing vessels, fishing inside and outside EU waters, should be required to record their catches electronically in logbooks. Logbooks should include fields to record the bycatch of all sensitive species. The information recorded in elogbooks should include not only the number of individuals and species that were bycaught, but also other relevant information such as how the individuals were captured (e.g. during setting/hauling, gear type) and any particular features that might prompt the catch (e.g. type of bait, season, time, depth). • Data collection via elogbooks should be supplemented by data collected by independent and adequately trained observers onboard vessels. The use of trained observers, deployed in a representative manner, is recognised as the most reliable way to ensure a robust estimate of the actual bycatch and potential mortality of vulnerable species caused by fishing operations. Where operational, safety, or other concerns, prevent or impose limits on vessels accepting observers onboard, Remote Electronic Monitoring (REM) systems, including cameras, should be used to collect independent data on bycatch of sensitive species. Tracking of all fishing vessels, including small-scale vessels, should be implemented in order to understand the impact of fisheries on the marine environment. • Data on bycatch should be collected following a standardised data collection methodology adopted at the regional level, to ensure data are harmonised and comparable enabling the issue of bycatch to be characterised at the regional level. An example of a regional methodology for data collection is the one adopted by the GFCM: http://www.fao.org/gfcm/data/vulnerablespecies • Data collection by observers should cover all fleet segments and métiers where there is a risk of bycatch, or where there is insufficient data to assess the risk. • Fishing effort per métier should be recorded in meaningful units (e.g. net length combined with soaking time in the case of static nets, number of hooks for longlines) to enable comparable bycatch rates to be estimated. • Data collection by observers should cover a sufficiently high percentage of fishing effort to ensure that the data is accurate, representative and enables robust estimates of bycatch rates. The level of coverage should be determined by the objectives of the monitoring programmes and informed by previous knowledge of bycatch in the targeted fishery. The required level of coverage needs to be adapted to the characteristics of the fishery. Some literature review suggests that coverage levels of at least 20% for common species, and 50% for rare species, would give reasonably good estimates of total bycatch (Babcock et al., 2003).Bycatch should be reported at species level with the number of bycaught individuals recorded. Fishers and onboard observers should receive adequate training, including on the identification of sensitive species. • Synergies should be ensured with data collection to assess the achievement of Good Environmental Status under the MSFD. • Data collection should be conducted in the context of any Sustainable Fisheries Partnership Agreements (SFPAs) concluded by the EU. • Collected data must be freely available and easily accessible for public use. Data collection process must be transparent.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

ENFORCEMENT: Make the Biodiversity Strategy objectives legally binding; Provide adequate capacity at the European Commission and Member States level to enforce nature laws through an adequate increase in staff and financial capacities; Zero tolerance to illegal wildlife persecution, within and outside EU; Put in place a Natura 2000 surveillance system by 2025. MAKE EU AGRICULTURE COMPATIBLE WITH A BIODIVERSE LAND: Give at least 10% of space for nature, and make it a condition at EU level for receiving EU agriculture subsidies; Reach 30% organic agricultural production; Introduce obligations for MS to protect their soils; Adopt a legislation making sure that land is efficiently used, and that brown-field sites are repurposed so they can be reused, or restored into natural habitats. MAKE EU EXTRACTION OF FISH AND SEAFOOD COMPATIBLE WITH OCEANIC LIFE: Eliminate destructive fishing practices such as bycatch of endangered, threatened and protected species, non-selective fishing gear, fishing of stocks that are not scientifically assessed; Ensure that fisheries are fully disclosed and surveilled; Limit forage fish catch to 2/3 of fishing mortality; Recover the historical range of top predators, including seabirds, as indicators for recovery of marine food chains; Plan aquaculture development with respect to marine protected areas; Forbid aquaculture fed with wild caught fish instead of vegetarian and insect-based feeds. RESTORATION OF THE NATURAL ENVIRONMENT: Crosscutting legally binding target for Member States to restore 67 million hectares of natural habitats on land in the EU for biodiversity; Binding legislation with a target to restore 15% of EU Member States’ sea areas, by designating them as permanent no take zones or with regulated access to restore and recover oceanic life; Plan afforestation in the context of the restoration agenda; Ensure that any financing for climate action delivers active restoration of habitats on land and at sea. BIODIVERSITY FUNDING: Deploy €21 billion/year for management of existing Natura 2000 network, and at least €1bn EUR/year for marine-based N2000 network; Mobilise €150 billion for restoration, as a minimum, to 2030; Secure 50% of External Financing Instruments to address global environment needs; Ensure no public subsidies and investments, by the European Commission and Member States, are spent on harmful activities to biodiversity; Mandatory biodiversity reporting on all publicly listed private funding.
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Response to Evaluation of the impact of the CAP on habitats, landscapes and biodiversity

3 Dec 2018

Biom’s Feedback on: Evaluation of the impacts of the CAP on habitats, landscape, biodiversity The following areas constitute Biom’s recommendations for what should be covered in the European Commission’s Evaluation of the impacts of the CAP on habitats, landscape, biodiversity: 1. Impact of CAP on drivers of biodiversity loss, covering impact on: a. direct land-use change and habitat conversion b. water use c. agricultural run-off d. pesticide use e. fertiliser use f. direct persecution of wildlife g. destruction/maintenance/restoration of landscape features h. intensification of management (spanning livestock density, increased mowing of grasslands and increased tillage) 2. Knock on impacts of CAP subsidies, including: a. Impact on aquatic habitats from run off b. Extra-EU impacts, notably impact on demand for animal feed imports 3. Impact of individual CAP tools: a. Direct payments b. Greening payments c. Coupled support (broken down by sectors) d. Areas of Natural Constraint e. Investment aid under the EAFRD f. Agri-environment schemes g. Natura 2000 payments 4. Impact of other CAP provisions, covering: a. Eligibility conditions – the impact of definitions such as on permanent grassland, impact of land needing to be kept in production-ready condition b. Impact of the EU enlargement and thus the roll out of the CAP on biodiversity in new Member States 5. CAP and data gathering: a. Whether and to what extent the CAP is contributing to appropriate gathering and use of biodiversity-relevant data and evidence (such as on protected areas, monitoring land use changes), including LPIS, IACS and monitoring and evaluation of agri-environment schemes. 6. Process and transparency: a. Ensure that scientists and experts are properly and separately consulted on the Fitness Check. Several of scientists have been very much involved already in a separate exercise with over 800 publications listed and evaluated as potentially relevant for the CAP’s assessment (see link to the full database: https://idata.idiv.de/DDM/Data/ShowData/248). This has been coordinated from IDIV (German Centre for Integrative Biodiversity Research (iDiv), more information can be found here: https://www.idiv.de/web/cap_fitness_check.html. b. Use of peer-reviewed science as much as possible. c. Use of additional interviews with experts to identify relevant grey literature, anecdotal evidence and understanding of malpractice that might not be recorded by official data. d. Identify gaps in the literature and where further evidence is needed regarding topics 1-4. e. Ensure full transparency of sources of data and full referencing of all sources of evidence and conclusions. f. Ensure that citizens can have a more accessible public consultation to allow for a wider reach to citizens. g. Ensure that environmental NGOs are properly consulted in the analysis, with ample time for consultation and feedback. And, very important, when comments are sent, there should be feedback on why a feedback has been taken up or not. h. DG Environment should be co-leading on this study, since they are the responsible DG on reaching the Biodiversity objectives. i. The objectives of the Birds and Habitats Directives should be strongly integrated and the effects of the CAP on the implementation of these directives should be properly analysed. j. Ensure that Article 191 of the Treaty of the Functioning of the European Union is respected.
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Response to Multiannual Financial Framework - CAP Strategic Plans

20 Jul 2018

Association Biom and BirdLife Europe would like to take this opportunity to express its dissatisfaction with the way in which the public consultations, and other input, especially scientific evidence, have been all but disregarded with regards to the post-2020 CAP reform process. During the 2017 public consultation, over 250.000 citizens, representing around 80% of the responses, asked for a radical transformation of the CAP towards sustainability. However, these responses were essentially disregarded, or at least not included in the official analysis (carried out by Ecorys), in clear violation of the EU’s own Better Regulation guidelines, which state that responses resulting from campaigns should be analysed and summarised in the main report (Better Regulation Toolbox #54, p. 419). There is no justification for ignoring an EU citizen’s response which has been individually submitted, simply because it has been stimulated by a public campaign. To do so is to deny the agency of individual EU citizens. As it happened, those answers that were analysed officially, did also show a strong preference amongst respondents, especially citizens, but also farmers, for the CAP to do more for the environment and climate. However, the way in which the results were presented, including by Commissioner Hogan, as an endorsement of direct payments, was completely misleading. All this adds to the general picture that when it comes to the CAP, it is politics rather than evidence and citizens’ wishes that prevails. This is supported for example, by the Commission’s political decision not to conduct a REFIT compliant fitness check of the CAP, despite this being demanded by the REFIT Stakeholder’s platform and many NGOs. At the same time, the Commission has subjected much of the EU’s environmental legislation to the REFIT process. Excluding the CAP from the same scrutiny, when it has been shown by countless studies, including most recently an independent ‘shadow’ Fitness Check to be failing, or falling short, on most of the Better Regulation criteria, simply exposes a bias in decision making that is ultimately harmful for the legitimacy of the EU itself. Finally, the Commission and Member States continue to untruthfully represent the CAP as a policy which is good for the environment. In fact, the overwhelming scientific evidence, and even the EEA’s own studies on the state of the environment, point to the opposite: that intensive agriculture, fuelled by the CAP, is the number one driver of species and habitat loss in the EU. Not to mention the other environmental pollution being imposed by intensive farming: over abstraction from irrigation; pollution of water from fertilisers and other agro-chemicals; degradation and contamination of soils; air pollution from ammonia and methane; and contribution to GHG emissions. Association Biom in cooperation with BirdLife Europe has actively participated in the EU’s consultations on the CAP, expecting that its views and evidence presented would be taken seriously and analysed, along with best available scientific evidence, in the Commission’s proposals. However, it seems that the CAP reform process is overwhelmingly biased and captured by special interests, most notably, the intensive farm lobby. Because the results of the public consultation were not in line with these interests, they were either ignored, or misrepresented. The current consultation thus strikes us as a mockery. Why would any contribution would be taken more seriously this time? To restore the legitimacy of the consultation process, and thus encourage participation by representatives of the public interest, it would be necessary to follow the EU’s Better Regulation guidelines in a transparent and consistent way.
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