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BirdLife Cyprus (Πτηνολογικός Σύνδεσμος Κύπρου)

BirdLife Cyprus is a non-governmental, not for profit conservation organization, working for the protection of birds, their habitats and wider biodiversity in Cyprus.

Lobbying Activity

Response to Guidance on accelerating permitting processes for renewable energy projects and facilitating Power Purchase Agreements

25 Jul 2022

We understand that there is a need for accelerated development on renewable energy supply and ther eis need for greater ambition by the European Commission. However, as the IPCC states, climate change is further exasperated by biodiversity loss (and vice versa) and therefore one crisis cannot be solved without solving the other crisis. So, only by considering climate and biodiversity as parts of the same complex problem, can solutions be developed that maximize beneficial outcomes for both limiting climate change and stopping biodiversity loss while safeguarding social and public support. More specifically, we have the following comments on the European Commission's proposal to change the Renewable Energy Directive: 1. The Process: We have doubts about the way the REPowerEU Package was published without having been properly discussed 2. Go-to areas: Designated go-to areas (provided they are outside protected areas and areas valuable for biodiversity) can be part of the solution. However these should be designated through strategic spatial planning based on sensitivity mapping that is scientifically backed up and technology specific (excluding hydropower and bioenergy). This could be a win-win in tackling climate and biodiversity crises. We believe that this should be combined with no-go areas to have maximum effects. All this should also comply with the needs from the EU Biodiversity Strategy that calls for 30% protected area across EU's land and sea with 10% strict protection. 3. Planned Permitting procedure rules: We are gravely concerned about changes to permitting procedures. Environmental Impact Assessments cannot be replaced by any Strategic Assessment and should be taking place at project level regardless. Ignoring the EIA and Appropriate Assessment process has serious risks and sets a very bad precedent. Strategic Planning should be used for guiding the EIA Process and not to replace it. We also believe that it is not the EIA process that delays development, In Cyprus for example, since a baseline has been set, setting no-go areas based on a Spatial Planning that takes into account protected areas and areas important for biodiversity as well as other sensitivities, the EIA process has been much more fast and efficient, with projects being granted permit within only a couple of months in cases (depending also on the quality of the EIA study and the need for back-and-forth, with the weight of delays falling on the developers who do not submit high-quality studies and not on the EIA process). Such an exemption would have serious consequences also on ensuring strict species protection from the Birds and Habitats Directives leaving legal uncertainty. 4. Procedures outside go-to areas and deadlines: If go-to areas are set we see not reason to make changes outside those in terms of permits. Also, setting strict deadlines for maximum duration of permitting procedures may lead to unlawful permitting as legal processes may be circumvented as a result. 5. Overriding Public Interest and general provisions to apply it: A blanked IROPI designation for renewables is a very dangerous path to lead Member States on, especially Member States such as Cyprus who have a very high track record of mis-using IROPI repeatedly. This could also potentially lead to other industries requesting blanket IROPI and thus lead to environmental deregulation which clashes with the aim which is to tackle climate change. One of the most important barriers to granting faster permits is staffing of authorities in charge of licensing. In the example of Cyprus, where the Environment Authorities are faced with hunderds of solar park applications every year, the first step to support faster and better assessment of the impact and permitting is to give the authorities more staff and allocate appropriate resourses. Not to remove environmental regulation. We warn against biodiversity being sacrificed for climate action as the two go together.
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Response to Evaluation of the LIFE Programme 2014-2020

8 Apr 2022

We thank the European Commission for the chance to give our views on the LIFE programme 2014-2020. BirdLife Cyprus is the most active non-governmental, non-profit nature conservation organisation in Cyprus. Through science, advocacy, education and on the ground conservation work, we work to protect wild birds, their habitats and wider biodiversity in Cyprus. In our opinion, the importance this programme for environmental projects cannot be overstated. Funding through LIFE is highly efficient in reaching the goals of the programme. The input in the form of co-financing projects pays off many times over for example in the form of enabling ecosystem services, job creation and improving environmental democracy. In some cases, LIFE made a significant contribution to saving species from extinction, or restoring degraded sites, for example the Oroklini Lake in Cyprus. In our experience the following aspects have proven to work well: 1. Funding projects in overseas territories and third countries should be maintained. As environmental problems respect no borders, funding should not be restricted to the EU but continue to be open to applications for projects in overseas territories and EU neighbouring countries. 2. The built-in flexibilities are very useful as they help to adopt the project plans to occurring changes. 3. In general, the external monitoring process works well. However, the key performance indicator tool is too complicated, see below. 4. We are aware of complaints about LIFE being too bureaucratic. We cannot confirm this and given the need to avoid misuse of funds, the application process seems manageable. The two-step application process also helps develop the project proposal. However, although LIFE is a successful piece of EU policy overall, the following aspects require improvement: 1.The co-financing requirement is the biggest challenge when it comes to receiving LIFE funds, especially for NGOs. Therefore, we suggest the co-financing rate to be increased to at least 75% for all projects. Depending on the GDP per capita of the region or regions where the activities take place, in well-argued cases the co-financing should be further increased to up to 95%. 2.The budget for LIFE should be increased. For the period 2014-2020, LIFE constituted only 0.3% of the EU’s budget. For the current period of 2021-2027 this number increased only slightly: LIFE’s €5.43 billion budget constitute just over 0.44% of the EU’s long-term budget (and only 0.27% if the NextGenerationEU recovery instrument is also taken into consideration). The funding requirements for proposed projects are significantly higher than the available budget. Therefore, we think this number should be increased to 1% of the Multiannual Financial Framework. This would also be in line with the goals of the European Green Deal and the EU Biodiversity Strategy 2030 which stress the importance of biodiversity protection. 3.We have found the key performance indicator tool to be overcomplicated and exceedingly difficult to interpret. Measuring performance is of course essential to any funding activity. But in our experience using the indicator tool has proved to be very burdensome and failed to provide legal certainty. Simplification or more straight forward guidance is needed here. 4.We think that the protection of biodiversity should remain the main goal of the LIFE programme. Of course, other funds - most notably the CAP - need to improve their effectiveness in terms of biodiversity protection as well. But LIFE remains the most important source of funding for biodiversity at the EU level. Thus, instead of shifting the focus away from nature protection, increased synergies with the other sub-programmes should be sought by funding project
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Response to EU Pollinators Initiative

21 Dec 2017

Birdlife Cyprus welcomes the decision of the European Commission to adopt the Pollinators Initiative. For the initiative to achieve its aims of tackling the decline of pollinators, it should focus on the key driver of biodiversity loss in Europe: industrial agriculture. The initiative must deliver legally binding and effective tools able to radically change farming practices on the ground. The initiative must therefore not be limited to simply research and monitoring activities, but policymakers must fulfil their role of implementing and enforcing legislation. The areas that the initiative should focus on due to their importance as drivers of pollinator decline are: a) fixing the many harmful subsidies and incentives in the Common Agricultural Policy that either have a direct or indirect impact on pollinators, and offering alternative payments for practices that actually benefit pollinators, 2) a better implementation of the Birds and Habitats Directives, and 3) additional legislative tools that the Initiative throws up as necessary to reverse the decline in pollinators across Europe. Within the CAP, there are a number of key areas that the initiative must focus on in order to effect real change in pollinator populations. For a start, there is a pressing need for natural vegetation on farms, i.e. genuine Ecological Focus Areas (EFAs) must be made mandatory at EU level in the next CAP. By genuine, we mean 1) that they must apply to all types of farm (therefore current exemptions for non-arable farmers, or for permanent grassland and permanent crops etc. should be removed), and 2) EFAs should only involve natural vegetation with a demonstrable link to supporting pollinator numbers, rather than protein crops and catch crops etc. which do not provide habitats for biodiversity. The Initiative should also take a holistic approach and investigate all measures concerning the sustainability of farming that can help to tackle pollinator decline, such as soil protection and limiting practices such as ploughing and early mowing, which impact on the ground breeding of insects. On pesticides, an immediate strict implementation of the Sustainable Use Directive must be ensured, including legal action against Member States not in compliance, in particular regarding their failure to make the principles of Integrated Pest Management mandatory, which was supposed to happen by 2014. There must also be an immediate ban more heavily toxic pesticides such as neonicotinoids, plus a massive reduction in the use of both pesticides that directly harm or kill pollinators (insecticides) and those with indirect effects such as destroying breeding habitats for pollinators (e.g. herbicides). There must also be much tighter screening of the ecological impacts of pesticides, going beyond the EU’s current risk management approaches, for example taking into account ‘cocktail effects’ on pollinators (see Sgolastra, F., et al., 2016), as a basis for more rigorously informed and therefore effective legislative tools. Finally, the initiative must lead to better implementation of the Birds and Habitats’ Directives as highlighted in the 2016 Fitness Check. This would include measures that support the good management of, and funding for, the protection of Natura 2000 sites for the benefit of pollinators.
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Response to Changes to greening rules and clarifications of certain other direct payments' rules

12 Jan 2017

It is a glaring inconsistency that pesticides can be used in EFAs, and directly counterproductive to meetings its aims. The primary objective of the 'Ecological Focus Area' requirement for the Greening payment is to protect and enhance biodiversity in the agricultural landscape. Biodiversity declines have been well documented for decades, which is most concerning as it jeopardizes the fundamental structures which allow us to produce our food. Lower biodiversity results in lower soil fertility and pollinator numbers, which in turn effects agricultural yield. Therefore, it is vital that EFA delivers on its vital objective of protecting biodiversity. For BirdLife Cyprus, there is absolutely no justification to continue to the use of pesticides, particularly in the context of the better regulation agenda, and the growing expectation that public expenditure should meet the required aims. There is increasing evidence to show not only equivalent but also increased in yields can be achieved when biodiversity is used to provide pest control functions. Utilizing this 'functional' biodiversity reduces input costs, potentially increases yield, which are significant determinants of Farmer income. This is alongside the benefit of a public subsidy for delivering the public good of conserving biodiversity.
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