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Latvijas Ornitoloģijas biedrība

LOB

LOB mērķis ir sekmēt tādu apstākļu saglabāšanos, kas ļautu ilgstoši pastāvēt visām ar Latvijas teritoriju dabiski saistītajām putnu populācijām.

Lobbying Activity

Response to New EU Forest Monitoring and Strategic Planning Framework

5 Feb 2024

Latvian Ornithological Society strongly supports the need for EU Framework for Forest Monitoring and Strategic Plans and thanks EC for the current proposal. The forests of Latvia are under pressure from intensive clearcut-based forest management, leading to habitat loss and fragmentation, population declines of forest-specialist species, loss of forest carbon sink etc. However, the forest area is increasing. This highlights the problems with the currently accepted definition of forest which includes also tree-less areas (i.e., clear-cut areas before reforestation) and intensively managed plantations. Harmonised and data and strategic forest plans are very much needed to ensure that the demand for wood and biomass does not threaten forest ecosystem integrity, including biodiversity. However, the current monitoring data in the EU suffer from methodological differences among countries, lack relevant information on ecosystem health and biodiversity and well as thresholds and targets for sustainable forest management. Furthermore, it should be ensured that the monitoring data are transparent and publicly available to any interested stakeholder in appropriate detail. It is important and commendable that the proposal will serve the aims of EU Biodiversity and Forest Strategy. Mapping of the remaining old-growth forests is an important positive step. However, as the old-growth forests, are still being destroyed, including in Latvia, the already mapped forests should be reported immediately, without having to wait until 2028. We appreciate that the proposal has good indicators, including the Forest Bird Index. However, reporting should 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. Though our assessment of the proposed law is overwhelmingly positive, the fact that strategic forest plans, which would require positive action based on the monitoring data, are not mandatory is an important drawback of the current proposal.
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Response to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species

18 Dec 2017

Overall Latvian Ornithological Society (LOB) is very supportive of the Delegated Act as it is currently drafted. LOB does not believe any substantive amendments are needed to the draft. LOB considers that this draft Delegated Act meets, and in no way exceeds, the scope of the Delegated Act as determined by Article 5(3) the EU IAS Regulation 1143/2014. LOB considers that the distinction between Risk Assessment and Risk Management is crucial and praise the Commission for clearly highlighting this distinction within the Explanatory Memorandum. As clearly detailed in Article 5(3) of Regulation 1143/2014, this Delegated Act exists to further specify the evidence requirements for the Risk Assessments required under Article 5(1) of Regulation 1143/2014. It is clear from Article 5(3) that the Delegated Act does not exist to specify the evidence requirements for any Risk Management analyses. Consequently, LOB praises the Commission for ensuring the scope of this Delegated Act has been limited to that of specifying the evidence required for Risk Assessment, and not deviated to considering the evidence required for Risk Management. Article 5(1)(h) of Regulation 1143/2014 requires Risk Assessments to include ‘a description of the known uses for the species and social and economic benefits deriving from those uses’. Article 5(1)(h) is therefore asking for a description of the Risk Management considerations, so as to provide initial context to the Risk Assessment. However Article 5(1)(h) is clearly not requiring a detailed analysis of the Risk Management considerations, as this can be provided if necessary directly to the EU IAS Committee when it considers whether to include the species on the EU IAS List or not. LOB considers the wording of the section relating to Article 5(1)(h) of the Annex of Common Elements to be appropriate and entirely within the aim and the spirit of Regulation 1143/2014. However, for the avoidance of doubt, LOB wonders whether there would be value in adding a note to this section which clearly states that the Regulation merely requires a brief description of social and economic considerations to provide context to the Risk Assessment, and not a full analysis of the Risk Management considerations. Furthermore, LOB considers it unnecessary to specify that only economic experts can compile evidence relating to Article 5(1)(h) as this would be an unnecessary burden for what is merely a descriptive section. The primary aim of Regulation 1143/2014 is to prevent future damaging invasions by alien species. Due to the nature of invasive alien species, an invasive alien species may become established and cause harm within the EU before it is possible to complete rigorous scientific studies into the impact of that species in Europe. Consequently, as per international best practice, it is not appropriate to rely solely on peer reviewed literature when assessing the risk that an invasive alien species poses. However, it is entirely appropriate, as per international best practice, to consider expert opinion and grey literature when assessing the risk that species poses. But only if peer-reviewed evidence is not available and the uncertainty surrounding such material is appropriately articulated. As this Delegated Act allows for the use of non-peer reviewed evidence, with appropriate and proportional caveats, LOB praises the mature and considered approach to evidence that this Delegated Act presents. With regards to the section of the Annex of Common Elements relating to Article 5(1)(f), within Paragraph (3) LOB suggest that ‘endangered habitats’ is changed to simply ‘habitats’. A habitat may become endangered by the presence of an IAS, so merely focusing on endangered, as opposed to all, habitats may miss significant elements of the risk assessment. Yours faithfully, Viesturs Kerus Chief Executive Officer Latvian Ornithological Society (LOB)
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