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CEEweb for Biodiversity

CEEweb

Established in 1994 and founded for public benefit, CEEweb for Biodiversity is a voluntarily established, self-governed professional organisation, with activities covering the Central and Eastern European (CEE) region.

Lobbying Activity

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

27 Oct 2023

CEEweb for Biodiversity is a regional environmental umbrella organisation and a network of 35 NGOs from Central and Eastern Europe striving to conserve the natural heritage of the region. CEEwebs mission is to work for the conservation of biodiversity through the promotion of sustainable development. We do so through advocacy, networking, influencing decision-makers, implementing national and transnational projects, and carrying out capacity-building and awareness- raising activities. We welcome the European Commissions proposal for a Directive on Soil Monitoring and Resilience (Soil Monitoring Law, SML). An EU legislation protecting soils is long overdue as soil protection, conservation and restoration in the EU has been fragmented, lacking clear and effective EU-wide rules. An ambitious EU Soil Law is a precondition for the success of the European Green Deal objectives as healthy soil is crucial for attaining climate neutrality, halting and reversing biodiversity loss, achieving zero pollution, food and water security and circular economy. The national soil-related policies in the CEE region (including Hungary, where CEEweb is based) are often fragmented, insufficiently integrated, lack clear targets, responsibilities and adequate measures with the required funding and political support. We believe that a strong and ambitious EU Soil Monitoring Law could provide Member States the necessary direction and incentive to develop improved policies and support more effective action on a national level. While the Commissions initiative is very positive, there are some notable shortcomings in the current proposal. As it stands, the proposal will not enable the achievement of healthy soils in the EU by 2050. The change of the name of the legislation, which was originally planned to be called Soil Health Law, is symbolic of its lack of ambition and its shift away from soil health towards largely soil monitoring. The proposal lacks ambition and must be significantly improved to lead to effective change. Based on the attached assessment developed together with the EEB Soil Working Group, which CEEweb is also a member of, we recommend considering the following points: I. Targets and ambition: We recommend an increase in ambition by setting clear and legally binding targets, for 2050 as well as additional time-bound milestones. II. Governance: The SML should include mandatory plans to offer a straightforward path for Member States to meet the Directives objective. Such plans are also a necessary element to complement the proposals overall positive provisions on access to justice. III. Monitoring and assessment of soil health: The SML should include adequate and scientifically robust soil biodiversity descriptors and ensure that they are included in the assessment of soil health. IV. Responsibility: The SML should make polluters pay by establishing mechanisms that hold big players whose activities degrade soil accountable. V. Sustainable soil management: The SML should ensure minimum mandatory sustainable soil management practices, building on the conditionality rules of the CAP. In addition, the article on land take should be considerably strengthened. VI. Soil pollution: Regarding contaminated sites, the SML should ensure harmonisation among Member States by setting mandatory EU-wide thresholds for a list of key pollutants. In addition, Member States should include in the assessment of soil health chemicals identified as ecotoxic, persistent, bioaccumulative, mobile and toxic. Achieving healthy soil ecosystems by 2050 is not a nice-to-have it is a necessity. For this reason, we invite the European institutions to consider the elements outlined in the attached assessment during their negotiations on this legislation.
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Response to Conversion to a Farm Sustainability Data Network (FSDN)

7 Sept 2022

AGROMIX’s response to the EC “Have your say call” on FSDN regulation The AGROMIX Consortium welcomes the new Council Regulation (EC) No 1217/2009 as regards conversion of the Farm Accountancy Data Network into a Farm Sustainability Data Network. The Consortium highlights the importance in the new regulation that it takes efforts to - avoid overlapping in data collection, - embed other EU level data collections to FSDN and vice versa (IACS, IFS, CMEF), - continue data collection started in FADN, not to lose long term data sets and - the design and elaboration of the process of the formalization of the new regulation - highlight the urgent need of the implementation of the regulation. In the meantime, the Consortium highlights the following weaknesses of the actual regulation: 1. The regulation would benefit from a mechanism to ensure its even implementation across the Union. 2. Regulation should also contain guaranties of the EU level to reduce as much as possible differences of the implementation (date collection) from each member country. 3. Not well defined how the regulation will serve / match F2F and Carbon Farming Initiative. For the further elaboration of the regulation, the Consortium takes the following basic recommendation (using FLINT indicators and see beyond) - Make it clear how to fill-in gaps between socio-environmental data - how to transfer data into each data collection system – solve GDPR issues - - Social objectives are not clear - - Labor conditions not easy to provide - - Identify flow of products/more information on economic flows are needed based on farm level - - Pesticide, herbicide, nutrition use to be registered - Involve several already existing datasets and solve the harmonization of them and also integrate national spatial data: - - national census, FSS - - parcel level registry systems - - LUCAS  - - Soil database - Share all data on the IACS (Integrated Administration Control System) (solve the GDPR issues) and don’t keep information back! - Avoid overlapping on data collection as stated in the regulation, not as in FLINT indicators, avoid multiple use of the same data in different aggregated indicator to avoid multiplied errors. - Avoid generic indicators, rather use already existing datasets for these cases, concentrate on specific indicators, even if follow-up studies are needed at the identical farm level - Data collection might be needed around the actual farm to provide a broader context e.g., ecological connectivity, biodiversity status, target species status of the actual environment - Habitat heterogeneity might be equally important as the amount of semi-natural land cover when it comes to increasing general biodiversity. Therefore, the spatial arrangement of different land cover/habitats within the farm and between farms might be a very relevant factor, and probably relatively easy to estimate from remotely sensed data. AGROMIX’s specific recommendations: - Existing classifications based on income are not effective to understand the complexity of integration of different farm activities (i.e., trees and arable) or among farm components (forest and livestock). - Provide information on mixed system combinations, by a more detailed classification of land use (i.e., agro-forestry, combination of filed and arable crops.) - Lack of data on forestry and agro-forestry activities, to solve the remote sensing difficulty is crucial. AGROMIX Dr. Sara Burbi, project coordinator, Coventry University Dr. Nagy Gabriella Mária, policy expert, CEEweb for Biodiversity Prof. Fabio Bartolini, work package lead Economics and Value Chain, Università degli Studi di Ferrara Prof. Daniele Vergamini, work package co-lead Economics and Value Chain, Università di Pisa Prof. Dr. Ulrich Schmutz, policy work package lead, Coventry University Dr. Ülle Püttsepp, work package lead, theoretical background analysis, Estonian University of Life Sciences
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Response to Common Agricultural Policy: Performance framework and data for monitoring and evaluation

30 Jun 2022

The evaluation criteria of the CAP Strategic Plans should ideally not only assess the effectiveness, efficiency, relevance, coherence of the plans, but also evaluate the actual environmental and climate impacts of interventions (e.g., impact of direct payments or coupled support on water quality, soil health, air quality, GHG emissions, habitat and vegetation etc.). It should be also evaluated to what extent the CAP plans actually contribute to achieving the Green Deal objectives. To ensure an effective assessment of the performance of the new CAP, Member States must put in place adequate and well-resourced monitoring mechanisms. Here, the collection of different types of data is essential: visible or observable data such as land use changes, linear features (hedges, buffer strips), crop types and hence crop rotation practices, presence or absence of vegetative cover can be linked to potential environmental outcomes or more direct environmental effects, such as algal blooms, flooding, and air pollution. In addition, for issues such as water or air quality, there are opportunities to gather data remotely from particular locations, for example using in situ monitoring devices from which data can be uploaded remotely on a regular basis. As outlined in the ECA special report on big data in Common Agricultural Policy (2022), there is an urgent need to make better use of existing data and to address remaining data barriers to appropriately evaluate climate and environmental aspects of the CAP. Data is not being collected for example on farming inputs, such as the quantity of chemical and non-chemical pesticide applied, or the quantity of mineral/organic fertiliser applied and to which crop. Cross-linking existing data sources is another key challenge in ensuring there are appropriate data to evaluate the CAP. For the CAP objective on natural resource management and climate mitigation/adaptation, a long period can elapse between applying a policy measure and witnessing its impact. In order to determine a causal link between a CAP (baseline) measure and its results (e.g., for biodiversity and climate), various data have to be combined and external factors considered. Since available indicators are currently insufficient to draw conclusions on the environmental and climate impact of CAP measure, Member States and the Commission should improve the design and list of monitoring indicators. For instance, indicators of climate change mitigation must cover the main sources of GHG emissions and there should be adequate monitoring of the CAP’s impacts on grassland types and quality, forest and forestry areas and management, crop rotation and crop diversity. In addition, most of the data that the Commission collects from Member States are aggregated, thus limiting the extent to which it can extract value from them. In order to more effectively assess the impact of the CAP it is necessary that Member States provide not only aggregated data but raw data in broad categories defined by the EC. The EC should establish a technical and administrative framework for sharing and re-using disaggregated data and ensure that raw data is made public to allow scientists and civil society organisations to conduct their own impact assessments. Lastly, 2% of the budget for each intervention should go to an independent, scientific monitoring, based on a robust sampling methodology with methodological guidelines at EU level. Results of monitoring and evaluation activities should be widely disseminated and ultimately used to inform the design and implementation of future CAP interventions so that they deliver observable, measurable improvements in environmental and climate performance.
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Response to New EU Forest Monitoring and Strategic Planning Framework

6 May 2022

CEEweb for Biodiversity welcomes the initiative to propose an EU-wide Framework for Forest monitoring and Strategic Plans. While it’s general knowledge that forests are crucial for biodiversity and climate, not enough has been done so far to harmonise the collection of information about their status, health, and impacts of different management practices. Currently, reporting mechanisms are scattered and vary greatly across the EU, making data hard to access and compare. In addition, only a small portion of forests in Europe is monitored for biodiversity under the EU Nature Directives, with CO2 emissions from land being monitored only in some protected areas, making the links between actions for climate and impacts on biodiversity difficult to assess. Having a solid monitoring framework is crucial so that we can track the effectiveness of policy measures, and properly measure the impact of forest management practices on biodiversity and climate. A legal framework for Forest Monitoring and Strategic Plans provides a great opportunity to address this gap with harmonised definitions and data. The new legal framework should build upon and create synergies with existing indicators where possible and appropriate while ensuring: • Standardised definitions and criteria, including ‘forests’ and sustainability • Holistic indicators on the impact of management practices on biodiversity and climate • A uniform reporting format that ensures comparable data across all Member States • Maximum transparency through fully public and accessible information • Monitoring of the effectiveness of policy interventions by integrating indicators for e.g. strict protection, nature restoration • The inclusion of a landscape-level approach that also takes fragmentation and the broader ecosystem integrity into account
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Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

CEEweb for Biodiversity, an umbrella organisation of 32+ Central and Eastern European environmental NGOs, welcomes the European Commission’s initiative for a new legislative proposal on soil health by 2023. CEEweb is committed to support, by advocacy, awareness-raising, and lobbying, achieving the target of having all soils in healthy condition by 2050 and to make the protection, sustainable use, and restoration of soils the norm. CEEweb for Biodiversity is calling upon the European Commission to adopt a strong and harmonised EU legislative approach to address soil- and land degradation, to advocate and ensure sustainable soil management practices based on agroecology principles and to create a governance framework that enables for inclusive, participatory policy- and decision-making. Agroecology and agroecological practices (such as crop diversification, the integration of crop and livestock systems, agroforestry, protecting and establishing farmland biodiversity and soil management measures, like reduced tillage, continuous soil coverage, and the reduced use of chemical inputs) must be integral elements of establishing a comprehensive EU legal framework for soil health. CEEweb, furthermore, calls upon the Commission 1. to ensure that the future Soil Health Law (SHL) requires Member States to translate its ambition and objectives into national soil health Action Plans that are in line with the SHL, national circumstances and are sufficiently aligned with other existing policies (e.g. CAP SP); 2. to provide tools, funding and training to farmers and landowners to support their decision-making for adopting sustainable, agroecology-based soil management practices; 3. to implement a farmer-friendly, participatory multi-criteria framework for soil health assessment and monitoring; 4. to increase awareness on and encourage the protection of soil biodiversity and farmland biodiversity, as essential factors for healthy soils; and 5. to establish an expert group with the participation of diverse stakeholder groups (including NGOs) to support the development, implementation and monitoring process of the SHL. For additional points, please, refer to the attached joint NGO position.
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