Natuur en Recht
Legal advice and legal assistance on species protection and animal welfare legislation
ID: 567956234479-34
Lobbying Activity
Response to Update of the list of Invasive Alien Species of Union concern
11 Apr 2019
The risk of introduction, establishment and spread of aquatic plants is mainly due to pollution by man (extreme nutrient levels, unfavourable pH-levels) combined with high water and air temperatures, also in several cases caused by man (river Erft). Native plants show extreme growth as well under these conditions, causing the exact same problems. The sollution is not restricting plants (that are a sollution themselves as they are phytoremediators) but putting an end to water pollution.
As far as the RA is concerned, the following must be mentioned:
The risk assessment for plants cover the EPPO area, including North-Afrika, Israel, Turkey, the Ukrain and Russia. The assessment of the risk is influenced by the risk in these non-EU EPPO Member States and therefore does not meet the requirements of the principle of transparancy and due dilligence. Furthermore, the Salvinia molesta and the Pistia stratiotes have, according to the scientific data used in the RA, very specific requirements concerning nutrients, temperature (water and air) pH-level, electric conductivity etc, leading to the conclusion they can only introduce, establish and spread under conditions of high temperature combined with a high nutriënt level, specific pH-level and/or high electic conductivity. Neverthess, almost all freshwater bassins in the EU have been appointed in the RA as suitable, even oligotrophic bassins, characterised by low nutriënt levels and distrophic freshwater basins with way to low pH-levels. Also, the risk assessments contains conclusions, referring to scientific reports, while these reports do not mention these conclusions at all, exagerrating the risk of introduction, establishment and spread without any scientific basis.
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