OpenLobby.EU
Explore

Pravni center za varstvo človekovih pravic in okolja

PIC

PIC provides professional legal support to individuals, vulnerable groups and non-governmental organization in exercising and protecting their rights and strengthening their position in the society.

Lobbying Activity

Response to Roadmap towards Nature Credits

30 Sept 2025

PIC is not inclined towards the financial valuation of nature and its services. Humans are part of nature, which cannot be fully quantified or comprehended. It is a condition of life and life itself. It is our common good, which we must take better care of (like stewardship) for the benefit of all, including future generations. As a common good, it cannot be subordinated to market mechanisms. We understand the European Commission's intention and efforts to involve private capital in nature restoration, but we believe that this is not the best possible approach. Both individuals and legal entities should adjust their actions in a way that enables sustainable development. Indeed, the climate and biodiversity crises, along with severe pollution, are the greatest global threats to humanity, but they need to be addressed in a way that contribute to achieving other environmental and sustainable development goals. Such behavior should be rewarded with access to financial resources. Companies should commit more extensively to non-financial reporting and the related planning and implementation of environmental and social responsibility measures, including climate actions and nature restoration measures. We don't see nature credits to be able to contribute to holistic biodiversity improvements. Such improvements cannot generally be measured in the same way as greenhouse gas emissions in the climate sector, where emissions trading has some success in climate mitigation. Since the roadmap does not indicate any directions regarding future methodology for certification, we are concerned that such a methodology will be inadequate, as it will not be able to capture the necessary comprehensiveness in terms of long-term and cumulative effects, measurement and monitoring of these effects, the impact of such measures on the wider nature systems and the local community, for example, in terms of complexity as covered by the IUCN standard for assessing nature-based solutions. To finance the nature restoration, it would be essential to review and utilize all other possible sources of funding before introducing nature credits for example, the elimination and redirection of subsidies harmful to nature, more funding from mass tourism and possible others.
Read full response

Response to EU Civil Society Strategy

29 Aug 2025

We welcome a systematic approach to strategic support for the development and functioning of civil society organizations at the EU level, and we support the development of multi-level protection measures for environmental and human rights organizations at the EU level. However, we believe that the draft strategy has overlooked some important areas. These include environmental protection, rule of law, democratic and participatory decision-making principles, respect for fundamental principles of sustainable development, and protection of human rights. In these areas, it is not about advocating for specific social groups, but about upholding the fundamental values of a democratic, sustainable, and just society. The draft strategy should be supplemented with these areas and a supportive mechanism for such types of civil society organizations. Since these organizations do not represent specific social groups, they also find it more difficult to obtain financial resources for their operations, and are particularly targeted by criticism and discreditation from those in power. Environmental organizations are often subject to discreditation merely for conveying internationally recognized scientific findings regarding the climate and biodiversity crisi; therefore, we suggest that the strategy also includes an EU commitment to communicate scientific knowledge and findings from international scientific bodies regarding the environment, climate, and biodiversity even more effectively. Regarding participation processes in decision-making, we agree with the findings of the strategy and believe that the EU funding for the projects could be conditioned by conducting meaningful participatory procesess at decision making and implementation. (participation processes are broadly open, substantively meaningful, and professionally conducted). But it should also be demonstrated by its own example of cooperation with civil society organizations at the EU level. Countries should also encourage the participation of civil society organizations in formulating the state's positions on decisions at the EU level, which is particularly important in the area of environmental protection, where most decisions are made at this level. Regarding funding, equal access to funding for all civil society organizations in the EU is crucial. Smaller countries have smaller organizations that do not have a large (financial) scope of operations and therefore find it harder to meet the criteria for EU calls. However, the activities of smaller, often local organizations are crucial for key environmental initiatives climate change mitigation and adaptation, protecting and restoring nature, pollution reducing. The EU could condition part of the funds it allocates for the development of local communities on the inclusion of activities carried out by civil society organizations.
Read full response

Response to Climate Law

30 Apr 2020

The Legal-informational centre for NGOs (PIC) strongly supports the initiative to set the climate-neutrality goal as an official goal of the EU, at the latest by 2050. As the proposed regulation mentions the Paris Agreement and achieving the binding temperature goal of the agreement, it is imperative that the Climate Law is an effective act from the practical point of view. The irreversible and gradual reduction of greenhouse gas emissions is critical, and thus the setting out a binding objective of climate neutrality in the Union by 2050 is welcomed, but must be further enhanced by clear and more ambitious intermediate goals for 2030, and also for 2040. We strongly encourage even separate goals for every 5-year period, in which the Commission shall evaluate national measures through the prism of achieving the climate-neutrality objective. There is not much time left until climate neutrality must be achieved. In this regard, it is imperative that the Climate Law is not simply a substantial act, but that it also presents, establishes and stresses a public and common fact: dealing with the climate crisis is the priority of the EU, across all its bodies, all its policy areas, all sectors and levels, including the financial and budget policies and issues. As this fact should be proclaimed as the European goal, it should also be the priority of all national governments. It is not simply a matter of the environmental sector; it is a crosscutting issue, which should be addressed as such, in substantive and declaratory fashion. The main global threat, which led the European Parliament to declare a climate and environmental emergency, demands aligning of all activities with the Paris Agreement’s 1.5 °C target. In this regard, we present further points which we believe are of the utmost importance to reach the EU objective and to make the Climate Law and its supplementing acts effective and successful. Attached, we are sending our concrete proposals and comments.
Read full response

Response to EU rules on industrial emissions - revision

21 Apr 2020

Legal-Informational Centre fro NGOs (PIC) from Slovenia supports the findings of the European Commission that a review of the IED is necessary in order to achieve a high level of environmental protection from industrial activities, with priority to pollution prevention over control. The current framework should be transformed, so that it leads to the transition to a truly sustainable industrial and energy production framework at EU level. We fully support the emphasis made on preventing pollution, in full integration with circular economy and decarbonization policies. We also fully support the position of the EEB (http://eipie.eu/storage/files/EEB%20draft%20input%20to%20IED%20Evaluation%20FINALv2.pdf) that has already identified a number of bottlenecks that require a review of the IED. Therefore, we welcome the conclusion of the European Commission that a review of the IED is necessary, and we support the preliminary list of problems identified and - to a large extent - the objectives and policy options identified. Attached, we are sending specific comments.
Read full response

Response to 2030 Climate Target Plan

10 Apr 2020

We strongly support setting the new 2030 climate goal and we propose to set it as high as possible. Since we support the CAN Europe call for an increase of the EUs 2030 climate target to at least 65% compared to 1990, we want the 2030 goal to be set on at least the proposed 55% compared to 1990. We believe it is necessary that this 2030 goal is included in the European Climate Law, because it would be a great weakness of this piece of legislation if it is not included. Adding this goal later is weakening the whole process of strengthening EU ambitions about climate action. The first imperative in the path towards this goal is that the loss of biodiversity should be stopped in the same time. Protecting biodiversity in this manner is not only the possible co-benefit as it is described in the chapter “Likely environmental impacts”, but it should be the defined co-effect. Climate mitigation measures should be tailored in the way that their effect would significantly contribute to stop biodiversity loss which is the second, equally life threatening global problem. There should be an emphasis on consumption patterns and general awareness raising about their impacts on climate. The environmental (GHG) cost should be internalised in all products that are consumed in EU (regardless if they are produced in the EU or outside) – financial and tax “tools” can be very effective in this matter. Although it seems the change of energy production is the core issue in addressing the climate change, the overall change in society – production and consumption - is necessary, specially in the fields of food production and transport. Food production should follow three imperatives: enough food for all, producing food that is healthy for people and has low environment/carbon footprint. The land should be used mostly for producing healthy food for people. Transport seems as it is something “outside our reach” – it has its own growth that “can’t be stopped”. This is not true. It is not logical that we reduce GHG emissions in transport sector in the way that they still grow. EU has to do some significant steps to allow member states to address transit transport with some “climate friendly” measures or to adopt some common measures to address this problem. We strongly support adopting measures for addressing the emissions from the maritime sector and aviation, not only inside EU, but also coming from outside. By declaring the climate crisis the European Parliament stated that all policies and regulations should be reviewed – for the crisis measures and the path towards 2030 climate goals, this review is very important. In essence, this is about “mainstreaming” climate change (and biodiversity) through all policies and regulation (on EU and national levels). We propose to strengthen the strategic environmental assessment as an already existing tool and expand it in a way in which it would be a practical and operative tool to assess the impacts of all plans and regulations on climate.
Read full response

Response to Access to Justice in Environmental matters

1 Apr 2020

Legal informational centre for NGOs (Pravno-informacijski center nevladnih organiazacij – PIC) is a Slovenian NGO working in the fields of human rights and environmental protection. It has a national status of working in public interest in the area of environmental protection. It is dedicated to a thorough implementation of the Aarhus Convention. We strongly support the changes of the Aarhus regulation (1367/2006) in the direction of upgrading or redefining the term »individual scope« in such a way, that the implementation of the Article 263(4) TFEU would fit the essence of legal protection in environmental matters under Aarhus convention. The Aarhus regulation should provide the legal ground for a less restrictive interpretation. We support the changes that would address the problems presented in the roadmap. Regarding access to justice on the EU level it is very important to us NGOs to have access to justice in cases, where a regulatory act contravenes the provisions relating to the ratified Convention. Such was the People’s Climate Case. As further developments in the EU climate politics showed that the current regulation's climate goals are not sufficient to reach Paris agreement goals, it should be the right of NGOs to address such acts. We support all activities to strengthen the access to justice on the national level, because while persuing such actions, we NGOs need strong support from the EU side. Our efforts on the national level are usually not welcome. For the national level we have proposals for (strengthening) the recommendation for member states: - for the national implementation of the Article 3(8) of the Aarhus convention, and - to enable public participation in decisions about the opinions of the state on environmental legislation on the EU level. In Slovenia there is no public participation in the process of preparing and adopting the state decisions on environmental regulatory acts. NGOs have the option to participate in public consultation on the EU level, but without any influence on the national level in the sense of what kind of decision the government will support on the EU level.
Read full response

Response to Climate Law

6 Feb 2020

In PIC, we strongly support the initiative to tackle climate change on the European level, since the national or local initiatives simply need to work together towards the urgently necessary and common European goal of climate-neutrality by 2050. The current 2030 greenhouse gas emission reduction targets take us on the path towards more than 3°C increase in global temperature, even though the EU agreed to the 1.5°C goal. The European Parliament declared a climate and environmental emergency, thus demanding an alignment of all activities in the EU community with the 1.5°C target. In our view, the main threat at this very moment is the lack of concrete measures in various fields to address the findings of the IPCC Special Report and the global action under the Paris Agreement. We particularly target and emphasize the fact, that climate change is not an issue that should be addressed solely through measures in the energy sector and the replacement of the energy sources. The measures discussed should encompass all parts of the EU community, thus striving for energy and material efficiency in all sectors, through vigorous protection of a healthy environment for humans and other species, with an emphasis on biodiversity and ecosystems protection. The new Climate Law should be the basis that connects all the various sectors and brings a common purpose to all. The main contributions and goals of the Climate law should be: - declaring that dealing with the climate emergency is a priority of the EU and the national governments, in all their sectors and institutions on all governmental levels; - defining a clear path towards fulfilling the expectations laid down by the Paris agreement and the IPCC with the ultimate goal of keeping the temperature rise until the end of the century under 1.5°C; - setting up more comprehensive, concrete, clear and ambitious goals for greenhouse emissions reduction for the entire EU respectively for 2030, 2040 and 2050, by which zero net emissions should be achieved, with the target for 2030 being ambitious, at least following and even increasing the proposed European path of 55% reduction towards 60-65%; - setting up an obligation of the EU and national governments to review existing policies and legislation which have an impact on European climate goals and making them coherent and thus aligned with the 1,5 °C goal; - setting up clear tools for monitoring climate progress and a regular periodic review system of the Climate law and the following policies, which is performed by an independent body of experts and has the aim of correcting the implementation towards achieving EU climate goals – a thorough review every 5 years; - aligning all of public and private financing from EU sources with the EU climate goals and defining a quick transition from harmful subsidies towards zero net carbon economy, with a ban on all subsidies, tax breaks, advertising and other benefits for coal, oil and gas; - defining phase out dates for ending all activities related to finding or exploiting fossil fuels; - creating an EU policy on natural carbon sinks, that demands protecting, conserving and restoring natural carbon sinks; - defining nature conservation, biodiversity and ecosystems protection as vital goals of the EU climate policy; - defining spatial-planning policies as a key part of tackling climate change and reviewing them in a way which demands that national governments consider the impacts of spatial planning on strategic level and on the level of concrete projects; - enabling meaningful public participation in the process of creating and implementing the Law and all following laws and policies on the EU level.
Read full response