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BirdLife Europe

BirdLife Europe is a leading partnership of conservation organizations working to protect birds and biodiversity across Europe.

Lobbying Activity

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

7 Jan 2026 · Delivering the green transition, EU Budget, Life Programme

Meeting with César Luena (Member of the European Parliament) and WWF European Policy Programme and EuroNatur - Stiftung Europäisches Naturerbe

19 Nov 2025 · LIFE programme

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development) and

16 Oct 2025 · Meeting following the EP Plenary vote on the CAP simplification package to discuss the next steps, ahead of the Trilogue.

Meeting with Jutta Paulus (Member of the European Parliament)

15 Oct 2025 · Speaker: The Energy-Nature Axis: Accelerating Renewable Growth through Biodiversity

BirdLife Europe urges rejection of pesticide regulation simplification package

14 Oct 2025
Topic — EU proposal to simplify food and feed safety regulations affecting pesticide authorisations.
Message — The organisation demands maintaining the highest environmental and health standards under current regulations, strengthening scientific risk assessment and transparency, prioritising capacity building for biocontrol assessment, and avoiding loopholes through exemptions. They call for full implementation of existing pesticide legislation rather than weakening protective frameworks.1234
Why — This would preserve existing biodiversity protections and prevent further insect and bird population declines.567
Impact — The pesticide industry loses potential administrative relief and faster market access for products.89
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BirdLife Europe urges Commission to prioritise efficiency over bioenergy

8 Oct 2025
Topic — EU Strategy on Heating and Cooling to accelerate decarbonisation and energy system integration.
Message — BirdLife requests the Commission prioritise energy efficiency and clean heating solutions like heat pumps, geothermal, and solar thermal. They call for ending subsidies for fossil fuels and bioenergy, redirecting funds towards renovation and future-proof technologies, and recognising the true carbon and biodiversity costs of biomass.1234
Why — This would reduce pressure on natural habitats and carbon sinks that BirdLife works to protect.56
Impact — Low-income households lose as biomass heating traps them in high-emission systems and exposes them to health risks.78
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BirdLife Europe calls for high-integrity nature credits to complement public funding

30 Sept 2025
Topic — EU roadmap on establishing a nature credits market for biodiversity restoration.
Message — The organization requests nature credits be closely linked to the Nature Restoration Law, ruled out from offsetting schemes, and started slowly with strong regulatory frameworks. They emphasize credits should complement rather than replace public investment.123
Why — This would ensure nature credits fund genuine restoration while protecting their core advocacy positions on nature law implementation.45
Impact — Companies seeking to use credits for greenwashing or offsetting biodiversity impacts lose flexibility.67
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BirdLife urges Commission to reject biomass carbon removal methodologies

22 Sept 2025
Topic — Certification methodologies for permanent carbon removal activities including BioCCS and biochar.
Message — BirdLife urges the Commission not to adopt the BioCCS and biochar methodologies in their current form. They argue the methodologies rely on faulty sustainability criteria, fail to account for land sector impacts, and dismiss legal requirements in the CRCF regulation.1234
Why — This would prevent methodologies that could increase emissions and harm ecosystems BirdLife works to protect.567
Impact — Forests and ecosystems lose protection as increased biomass harvesting drives further degradation of carbon sinks.8910
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Meeting with Paul Speight (Head of Unit Environment)

11 Sept 2025 · Lead in ammunition

Meeting with Eric Mamer (Director-General Environment) and

11 Sept 2025 · Exchange of views on the a) simplification agenda and the forthcoming omnibus on environmental policies, b) new MFF proposal, and c) implementation efforts for Nature Restoration Regulation (NRR) and EU Deforestation Regulation (EUDR)

BirdLife Europe urges EU to protect NGOs from smear campaigns

5 Sept 2025
Topic — The EU is creating a strategy to support civil society and protect civic space.
Message — The organization calls for a binding agreement to ensure systematic dialogue between EU institutions and civil society. They demand stable, directly managed funding to ensure non-governmental organizations can participate independently in policymaking. They also seek an early warning system to protect activists from repression.123
Why — The measures would provide BirdLife with secure funding and formal influence over EU policies.45
Impact — Governments and companies profiting from environmental crimes would face stricter monitoring and more legal challenges.67
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Meeting with Petr Lapka (Head of Unit Agriculture and Rural Development) and Natuur Milieu and

4 Sept 2025 · Exchange of views on the next CAP proposal

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

25 Aug 2025 · Methodology for Bioenergy with carbon capture and storage

BirdLife Europe opposes CAP simplification weakening environmental safeguards

31 Jul 2025
Topic — EU proposal to amend Common Agricultural Policy regulations and implementation rules.
Message — BirdLife Europe urges rejection of proposed changes that weaken environmental standards, particularly protection for permanent grasslands under GAEC 1. They call for maintaining Commission oversight, conducting proper environmental impact assessments, and ensuring CAP funding supports climate adaptation rather than short-term crisis payments.123
Why — This would preserve stronger environmental protections and maintain EU-level oversight of agricultural policy.45
Impact — Farmers lose long-term stability and support for climate adaptation and resilience building.67
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Meeting with Jessika Roswall (Commissioner) and

15 Jul 2025 · Exchange of views on the Common Agriculture Policy, the Water Resilience Strategy and simplification.

Meeting with Eva Maria Carballeira Fernandez (Head of Unit Maritime Affairs and Fisheries) and ClientEarth AISBL and

15 Jul 2025 · Recommendations on how to address shortcomings in the ICES advice and requests

Meeting with Michael Erhart (Director Budget) and

10 Jul 2025 · Discussion on the future Multiannual Financial Framework

BirdLife Europe demands nature protections in European grid expansion

7 Jul 2025
Topic — The European Commission is consulting on upgrading and expanding electricity grid infrastructure.
Message — BirdLife Europe demands mandatory EU-wide standards for bird-safe infrastructure design and mitigation. They argue that retrofitting existing lines must be prioritized before constructing any new corridors. New developments should strictly avoid sensitive ecological areas and align with nature restoration goals.12
Why — This would decrease bird deaths while improving the overall security of energy infrastructure.34
Impact — Grid operators could face higher costs and stricter conditions for securing EU funding.56
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Meeting with Alexandre Adam (Cabinet of President Ursula von der Leyen) and Transport and Environment (European Federation for Transport and Environment) and

1 Jul 2025 · Exchange of views on the next MFF climate change priorities

Meeting with Ricard Ramon I Sumoy (Acting Head of Unit Agriculture and Rural Development) and European Environmental Bureau and

24 Jun 2025 · Exchange on the Multiannual Financial Framework, Common Agricultural Policy, the Livestock Workstream, and Food

Meeting with Nicola Notaro (Head of Unit Environment)

20 Jun 2025 · Birdlife’s questions on INFR(2020)2345 and the CJEU ruling C23/23 concerning bad implementation of the Birds Directive in Malta

Meeting with Patrick Child (Deputy Director-General Environment) and

3 Jun 2025 · Exchange of views on LIFE

Response to European Democracy Shield

26 May 2025

BirdLife Europe and Central Asia welcomes this initiative which is an opportunity to rebuild trust, strengthen institutions, and reaffirm that democracy is a lived, participatory process. Civil society organizations (CSOs), including environmental NGOs, play a key role in a healthy democracy by being a channel of citizens voices, advocating for transparency, bringing in field expertise and scientific knowledge for policymaking. Therefore, the Democracy Shield (EUDS) must secure an enabling environment for CSOs in the EU, supporting their endeavours by: - Strengthening the Rule of Law and Access to Justice: they are the backbone of democratic accountability and effective environmental governance. But access to environmental justice remains uneven across the EU, with citizens and NGOs often facing legal and procedural barriers to hold public authorities accountable. It is paramount to strengthen the Aarhus Regulation implementation to guarantee that civil society and individuals have equal rights in all Member States; strengthen the role of the European Ombudsman to uphold the checks and balances in the EU administration. The EUDS should also support the establishment of Environmental Justice Hubs to provide legal support to local NGOs, particularly in countries with limited civic infrastructure. As well, the proper implementation of EU law through enforcement mechanisms and monitoring processes is key to bolster the trust of citizens in the Rule of Law. - Protecting CSOs against abuse, repression and undue restrictions: CSOs are threatened by the same disinformation and illiberal push than the EU institutions. They must be protected against the rise in legal and reputational attacks, including strategic lawsuits and defamation campaigns. Early detection and response can prevent the erosion of democratic space, particularly in politically sensitive fields like environmental protection. We call on the EU to develop a mechanism that allows to report all forms of attacks and to address them in a timely manner. Fighting disinformation requires investing in media training on environmental issues, fact-checking networks and media literacy programmes; regulatedigital platforms to ensure algorithmic transparency. The EU should also establish a European Democracy Semester, looking at the interplay between economic and social policies, and democracy. - Promoting structured civil society dialogue: Sound policy-making needs input from civil society through meaningful engagement, and CSOs are key to heed the voices of society in its full diversity. While the EU consults civil society, engagement often remains superficial or inconsistently applied across policy areas and institutions. It is necessary to create a binding EU framework for civil society participation, including minimum standards for consultation, feedback loops, and participation in implementation and monitoring as well as transparency requirements for stakeholder involvement. And to encourage Member States to involve civil society in policy formulation. - Guaranteeing the means to operate: Unlike well-funded actors such as foreign governments, business associations or multinational corporations, CSOs rely mostly on grants to operate. Dedicated EU public funding for CSOs ensures a level-playing field and balanced interest representation; and that civil society can maintain independent operations, reach marginalized communities, bring evidence-based, citizen-driven perspectives into EU policy development and implementation. Support can be delivered by maintaining and expanding operating grants which are essential to allow European environmental organisations to function. It can also be delivered with a dedicated EU Civil Society Facilitya streamlined funding mechanism designed to provide accessible financial support to CSOs of all sizes and sectors. The EUDS must not only defend civil societyit must empower it as a strategic partner in solving our common challenges.
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BirdLife Europe urges fossil fuel ban from Modernisation Fund

26 May 2025
Topic — This consultation evaluates the operating rules of the EU Modernisation Fund for energy transition.
Message — BirdLife Europe demands the exclusion of all fossil fuel and large-scale biomass projects from the Modernisation Fund. They argue for prioritising clean renewables and energy efficiency to ensure alignment with climate neutrality targets.12
Why — Eliminating biomass funding would protect the forest ecosystems and bird habitats BirdLife aims to defend.3
Impact — Gas infrastructure developers and the bioenergy industry would lose access to significant subsidy streams.4
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Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall), Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall) and

20 May 2025 · Ocean Pact and Water Resilience

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall), Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall) and

20 May 2025 · Exchange of views on the upcoming Ocean Pact and Water Resilience Strategy

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and European Environmental Bureau and

6 May 2025 · Protection status of the wolf

Meeting with Dan Jørgensen (Commissioner)

10 Apr 2025 · Nature reservation and renewable energy

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič), Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and

9 Apr 2025 · Sustainability agenda of the European Commission

Meeting with Jessika Roswall (Commissioner) and

31 Mar 2025 · Biodiversity issues

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen) and European Environmental Bureau and

13 Mar 2025 · Green Deal

Meeting with Mihail Dumitru (Deputy Director-General Agriculture and Rural Development)

10 Mar 2025 · Exchange of views on BirdLife/NABU report on ‘The untapped potential of eco-schemes’

Meeting with Humberto Delgado Rosa (Director Environment)

5 Mar 2025 · Exchange on the BirdLife report “Time to restore – progress and pitfalls in implementing the EU Biodiversity Strategy” (September 2024).

Meeting with Valérie Hayer (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

5 Mar 2025 · Green Deal

Meeting with Iratxe García Pérez (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

4 Mar 2025 · Just Transition

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall) and European Environmental Bureau and Naturschutzbund Deutschland e.V.

27 Feb 2025 · Implementation and enforcement of EU environmental legislation

Meeting with Christophe Hansen (Commissioner) and

3 Feb 2025 · Exchange of views on the Vision for Agriculture and Food and the European Board on Agriculture and Food

Meeting with Andrea Vettori (Head of Unit Environment) and European Environmental Bureau and World Wide Fund for Nature Belgium

28 Jan 2025 · Transposition of the future change of protection of the wolf under the Bern Convention into the EU legislation

Meeting with Costas Kadis (Commissioner)

24 Jan 2025 · BirdLife Europe’s Report: Progress and Pitfalls in Implementing the EU Biodiversity Strategy

Meeting with Nicola Notaro (Head of Unit Environment)

14 Jan 2025 · Discussion on the implementation of EUCJ ruling C-23/23 on the breach of the Birds Directive in Malta

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

14 Jan 2025 · Discussion on the mandate of the new Commission college

Meeting with Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

8 Jan 2025 · Discussion on financing biodiversity, Vision for Agriculture and Food

Meeting with Per Clausen (Member of the European Parliament, Shadow rapporteur) and Fern

3 Dec 2024 · Meeting on the ongoing negotiations on the Forest Monitoring file

Meeting with Bruno Tobback (Member of the European Parliament) and WWF European Policy Programme

20 Nov 2024 · Bioenergy, Forests and Land Use

Meeting with Catarina Martins (Member of the European Parliament)

13 Nov 2024 · environmental priorities

Meeting with Annalisa Corrado (Member of the European Parliament) and Lipu Odv

13 Nov 2024 · Biodiversity and nature conservation

Meeting with Biljana Borzan (Member of the European Parliament) and Biom Association

13 Nov 2024 · Consumption of lead in meat/illegal pesticides

Meeting with Marko Vešligaj (Member of the European Parliament)

12 Nov 2024 · Nature restoration

Meeting with Valdis Dombrovskis (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

28 Oct 2024 · Upcoming mandate, simplification and burden reduction, competitiveness and productivity, especially in the context of Green Deal.

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

17 Oct 2024 · follow-up meeting EU green deal

Meeting with Michal Wiezik (Member of the European Parliament) and WWF European Policy Programme and

15 Oct 2024 · Ocean Pact

Meeting with Cristina Guarda (Member of the European Parliament) and European Environmental Bureau and WWF European Policy Programme

2 Oct 2024 · Agricolture

Meeting with Anna Strolenberg (Member of the European Parliament) and European Environmental Bureau

2 Oct 2024 · Priorities for the upcoming mandate

Meeting with Florika Fink-Hooijer (Director-General Environment) and Transport and Environment (European Federation for Transport and Environment) and

20 Sept 2024 · Priorities of the new College

Meeting with Mélissa Camara (Member of the European Parliament) and FUNDACION OCEANA and Seas At Risk

10 Sept 2024 · Réunion de présentation de leurs travaux

Meeting with Marie Toussaint (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

17 Jul 2024 · Green Deal and environmental issues

Meeting with Ville Niinistö (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

17 Jul 2024 · Upcoming 2040 climate legislation

Meeting with Lena Schilling (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

16 Jul 2024 · Climate and Enviroment Policy

Meeting with Thomas Waitz (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

16 Jul 2024 · Climate and Enviroment Policy

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament) and European Environmental Bureau and WWF European Policy Programme

11 Jul 2024 · Climate policies

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and European Environmental Bureau and

25 Jun 2024 · Environmental priorities and maintaining course of Green Deal

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and WWF European Policy Programme

11 Apr 2024 · Implementation of the biodiversity pillar of the European Green Deal

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and WWF European Policy Programme

11 Apr 2024 · Implementation of the biodiversity pillar of the European Green Deal

Meeting with Maroš Šefčovič (Executive Vice-President) and European farmers and

14 Mar 2024 · High level dialogue on forest-based bioeconomy

Meeting with Kurt Vandenberghe (Director-General Climate Action) and Transport and Environment (European Federation for Transport and Environment) and

11 Mar 2024 · Discuss how to best advance the European Green Deal and ensure effective EU climate action

Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

BirdLife supports the prompt and effective designation and operation of RAAs in line with the more detailed comments in the attached document. This will require a step-change in the performance of public authorities and the renewables sector, with significant advances in public awareness, involvement and participation in the climate energy agenda in Member States. BirdLife therefore recommends that the Commission revises in late 2024 its guidance to Member States on NECP reporting (in time for the next progress reports due in March 2025), to request that they report on progress generally with RED transposition, and specifically, with RAA designation. BirdLife further recommends that the Commission identifies at least the following steps in its guidance to Member States on RAA designation. 1. Announce the timescale for the RAA designation process and associated Strategic Environmental Assessment (SEA), including proposals for communication, awareness-raising, public participation and community involvement in the steps 2-5 below, and for input from civil society actors, the renewables sector, other economic sectors, academic experts and government authorities (national, regional, municipal), beyond formal written consultation exercises. Publish in accessible format available information relevant to the RAA designation process and invite submission of further relevant information on potential environmental sensitivity. 2. Identify land and sea areas potentially suitable for renewables, as well as necessary grid and storage facilities, though combined mapping to assess resource availability (e.g., solar irradiance, wind speed), grid infrastructure availability and terrain conditions. 3. Use sensitivity mapping to identify areas where the development of renewable energy might impact sensitive sites, species and habitats, so that these areas, or potentially vulnerable areas lacking basic environmental data, will not be prioritized in (or will be specifically excluded from) RAAs, at least until 2030/the next NECP revision, or pending the availability of improved information on sensitive species and habitats. Consider other constraints, e.g. safety issues, military uses, certain types of agricultural land use, or buildings with high architectural or historic value, or structural and other limitations. Apply suitability criteria outside these sensitive areas to identify candidate RAAs. 4. Propose candidate RAAs in justified low impact areas, incorporating social aspects such as local ownership, renewable energy communities and community benefit sharing, with special attention to low-income and vulnerable households. Ensure that proposals contain clear information on intended regulatory and transparency arrangements and have guaranteed sufficient electricity grid access. 5. Designate RAAs through a plan published with the results of the accompanying SEA and analyse the gap between the potential production capacity of all identified suitable areas to ensure that they meet the highest possible percentage of the national contribution to the EU 2030 revised renewable energy target and the objective of climate neutrality by 2040 at the latest. Ensure that the SEA analysis, reflected in the plan and associated measures, sets out how the environmental impacts of renewables projects within RAAs will be minimized, mitigated and where necessary compensated; establishes clear monitoring and data transparency requirements to assess the impact of projects and ensure compliance with licence conditions; identifies and promotes opportunities for biodiversity restoration within RAAs, linked clearly to wider environmental objectives; and, where necessary, indicates clearly what further planning and licensing arrangements, informed by environmental sensitivity and zoning maps, will apply where the capacity to be installed within RAAs may be insufficient to meet overall renewable energy objectives.
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Meeting with Virginijus Sinkevičius (Commissioner) and

19 Feb 2024 · NGOs presented to the Commissioner their Manifesto: An Ocean of Change 2024, and in particular the idea of an Ocean Deal

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen) and Transport and Environment (European Federation for Transport and Environment) and

16 Feb 2024 · European Green Deal

BirdLife Europe demands mandatory action in forest monitoring law

7 Feb 2024
Topic — The European Commission is proposing a framework to harmonize forest data collection.
Message — BirdLife requests mandatory forest plans and immediate reporting for old-growth areas. They suggest including indicators for naturalness and carbon removal capacity.12
Why — Consolidated data helps the organization monitor biodiversity commitments and conservation goals.3
Impact — Biomass producers may lose forest classification and face higher transparency requirements.4
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Meeting with Maroš Šefčovič (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

30 Jan 2024 · Green Deal, 2040 climate target, strategic dialogue on the future of agriculture in the EU

Meeting with Delara Burkhardt (Member of the European Parliament) and WWF European Policy Programme

23 Jan 2024 · future of EU Green Deal

Meeting with Maroš Šefčovič (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

7 Nov 2023 · Transition towards sustainable food systems

Response to EU-Senegal fisheries Agreement and Protocol – Way forward

26 Sept 2023

Please find BirdLife Europe's feedback in the attached document developed with input from BirdLife's African Secretariat.
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Response to Mid-term evaluation of the LIFE programme 2021-2027

15 Sept 2023

Funding through LIFE is highly efficient: investing through co-financing projects pays off many times over, in the form of enabling ecosystem services, job creation and improving environmental democracy. LIFE has made a significant contribution to saving species from extinction, such as the Spanish Imperial Eagle. The LIFE NGO Grant is an essential lifeline for environmental NGOs and in the scope of the current Biodiversity crisis, we argue that the general funding of LIFE should be maintained and even increased to 1% of the MFF, while retaining a focus on Biodiversity related projects. In our experience the following aspects have proven to work well: - The new EC online portal to manage the grants has overall improved the application process. - The two-step application process helps develop the project proposal, and helps diminish the workload at application level. And in general, the external monitoring process works well. - The built-in flexibilities to manage projects are very useful as they help to adapt the project plans to occurring changes and prevent them from being abandoned. The following aspects require improvement: - The co-financing rule is the biggest challenge, especially for NGOs. We suggest the co-financing rate be increased to at least 75% for all projects, and up to 95% in well-argued cases depending on the GDP per capita of the region(s) where the activities take place. - Environmental problems respect no borders. As such the rate of agreements made with third countries need to be accelerated. - LIFEs budget constitutes just over 0.5% of the EUs long-term budget. The funding requirements for proposed projects are significantly higher than the available budget and both efficiency and the uptake of LIFE funds are high. Therefore, this number should be increased to 1% of the MFF. - We have found the key performance indicator tool to be overcomplicated and difficult to interpret. Measuring performance is of course essential to any funding activity. But using the indicator tool has proved to be very burdensome and failed to provide legal certainty. Simplification or more straight forward guidance is needed. - The protection of biodiversity should remain the main goal of LIFE as it remains the most important source of funding for biodiversity at the EU level. Thus, the proportion of Biodiversity funding within the four sub-programmes of LIFE should be increased. For the sub-programme Nature and Biodiversity, funding should be increased to at least 1bn/a. - LIFE should increase synergies with other EU programmes to enhance biodiversity protection in multiple policy areas. CAP and other funds should take up lessons learned, so as to improve their effectiveness in terms of biodiversity, and ensure investment in LIFE is coherent with other policies outcomes. - Simplify and revise the EC portal for advanced user friendliness. The new portal, through which all applications and communications with the LIFE Team happen, is difficult to operate: the messaging system doesnt always work, guidelines dont match templates, templates are not always relevant. The platform should be more responsive and guidelines more exhaustive. Furthermore, external evaluator and monitoring experts opinions are at times at odds with LIFE guidelines and information shared with grantees and is not always understood by the LIFE team. This creates difficulties when answering questions sent from the evaluators these additional reviews are often cumbersome and require a lot of resources both on the NGO and LIFE Teams. - Enhance the accessibility for smaller projects and organizations, by easing bureaucratic obstacles for them. This low threshold access would increase the popularity and usage of the funds, paving the way for bigger projects in the future. - Ensure the external monitoring experts align their operations and requirements to the LIFE guidelines.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Royal Society for the Protection of Birds

5 Sept 2023 · Discussion on forthcoming REACH restriction on lead

BirdLife Europe demands ban on misleading nature-friendly imagery

20 Jul 2023
Topic — The EU is consulting on rules to prevent misleading environmental claims.
Message — The group wants the law to cover implicit messages like pictures of flowers or insects. They advocate for public agencies to handle certifications to ensure higher consumer trust. They also call for environmental groups to be involved in setting label criteria.123
Why — Direct involvement in criteria setting would increase the group's institutional influence over labels.4
Impact — Intensive farming companies would lose the ability to use generic nature-inspired marketing.5
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BirdLife Europe urges EU net-zero target by 2040

23 Jun 2023
Topic — The European Commission is developing a climate target for 2040 to ensure neutrality.
Message — The EU should target net zero by 2040 and a 65% gross emission cut by 2030. They suggest ending incentives for bioenergy from trees and crops while reforming agricultural subsidies. They also emphasize protecting native forests and wetlands to maintain natural carbon sequestration.12
Why — More ambitious targets would protect the vital natural habitats and biodiversity the organization represents.3
Impact — The bioenergy industry and intensive livestock farmers would lose financial incentives and market demand.4
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Meeting with Michal Wiezik (Member of the European Parliament) and Royal Society for the Protection of Birds

7 Jun 2023 · REACH proposal on the use of lead

Meeting with Pascal Canfin (Member of the European Parliament) and European Environmental Bureau and

31 May 2023 · Green Deal

Meeting with Marie Toussaint (Member of the European Parliament)

24 May 2023 · nature restauration law

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

10 May 2023 · To discuss the EU REACH regulation process on the restriction of lead in ammunition and in fishing weights

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur for opinion)

4 May 2023 · Nature Restoration

Meeting with Emma Wiesner (Member of the European Parliament)

3 May 2023 · Naturrestarurering

Meeting with Tom Vandenkendelaere (Member of the European Parliament)

3 May 2023 · Nature restoration law

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and WWF European Policy Programme and Compassion in World Farming Brussels

3 Apr 2023 · Taxonomy and agriculture

BirdLife urges nature-positive rules for EU carbon removal certification

23 Mar 2023
Topic — A proposed EU regulatory framework to monitor and certify high-quality carbon removals.
Message — BirdLife calls for mandatory positive biodiversity impacts and separate accounting for emission reductions versus removals. They argue that land-based sequestration cannot be used to offset fossil fuel emissions.123
Why — Prioritizing nature-based solutions would direct financial support toward ecological restoration and biodiversity.4
Impact — Industrial carbon capture developers and monoculture foresters would face exclusion from certification.56
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Meeting with Virginijus Sinkevičius (Commissioner) and

20 Feb 2023 · To explain the “Fisheries and Oceans “ package adopted during that week: CFP Communication, Marine Action Plan and Decarbonisation Initiative.

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

19 Jan 2023 · to discuss the biodiversity policy and legislation

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

19 Jan 2023 · discussion on the biodiversity policy and legislation

Meeting with Antonius Manders (Member of the European Parliament, Rapporteur) and European Environmental Bureau

11 Jan 2023 · Environmental crime

BirdLife Europe warns biofuel expansion risks biodiversity loss

22 Dec 2022
Topic — EU review of eligible feedstocks for sustainable biofuels and biogas production.
Message — BirdLife calls for mandatory waste hierarchy and cascading principles, stricter degraded land definitions with clear soil organic matter figures, caps on animal manure from large farms, and safeguards requiring intermediate crops be grown without fertilizers, pesticides, or irrigation.1234
Why — This would prevent industrial farming intensification and protect agricultural land from diversion to biofuel crops.56
Impact — Industrial livestock operations lose incentives to produce manure-based biogas at scale.7
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Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and WWF European Policy Programme

19 Dec 2022 · The Habitats Directive and the protection status of the wolf in Europe

Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

The polluter pays principle (PPP), whether its rationale is consistent with a society that seeks to respect and come within the planetary boundaries, it remains today overall not sufficiently or well applied as it was pointed out by the Court of Auditors special report 12/2021. In this report, they examined how the EU integrated the PPP in key legislative areas, such as the IED for industrial pollution, the Waste Framework Directive for waste, the Water Framework Directive for water pollution, and various directives and regulations related to soil pollution. One major observation is that while the PPP can be easily applied to the most polluting installations, the cost of the residual pollution to society remains high. One major polluting sector, only partially captured by the PPP, is the agriculture sector. In fact, to a large extent EU policy works against PPP in this sector. - The Common Agriculture Policy is one of the fundamental policies that steer the agriculture system, hence this policy has a major influence on the different farming practices and their related impacts on environment. The CAP mostly goes against the PPP, either implicitly or explicitly. Agri-environment schemes and eco-schemes (greening until recent reform) are postulated on the principle of paying polluters to pollute less, with an upfront exemption from the PPP. This is leading to perversions such as per hectare premiums that are systematically higher for farmers harming the environment the most. In many cases this is compounded by schemes designed to reward business as usual which means polluters are paid to keep polluting, rather than to reduce pollution . Even more problematic are pillar I decoupled payments, which often strongly correlate with pollution and other environmental harm. These are supposed to be conditional on respect of legislation (SMRs) and basic good practice (GAEC) but these have repeatedly been showed to be weak and poorly enforced . In any case, this system does not include any element of PPP. To the contrary, heavy polluters are being paid with higher payments often correlating with worse pollution. A case in point is nutrients pollution. So far, the CAP has not succeeded to reduce the N and P pollution from agriculture albeit CAP direct payments are given if farmers comply with the national Nitrate Directive requirements. But the latter is neither properly assessed by MS nor it gives clear target to comply with. Indeed, under the SMR 1 (nitrates), Member States are only required to establish a programme of actions which is compulsory in nitrate vulnerable zones and whose items are verified under cross-compliance. Moreover, CAP coupled support for livestock and investment support have increased the livestock densities, which is proportionally correlated with nitrogen pollution of air, soil and water and methane emissions. The CAP instead of reducing the GHG pollution, has in some cases increased it . Coupled support is particularly perverse as payment level strongly correlates to pollution (and other impacts such as biodiversity loss). This means that the more the farmer pollutes, the more money he gets. In practice this is EU pollution support scheme, the very negation of the PPP. For a more detailed response, refer to the uploaded document.
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Meeting with Pierre Karleskind (Member of the European Parliament, Committee chair) and FUNDACION OCEANA

6 Dec 2022 · Politique commune de la pêche

Response to Energy transition of EU fisheries and aquaculture sector

5 Dec 2022

We are amidst a nature and climate emergency and evidence shows that ocean health is vital if we are to successfully address both. If left undisturbed, significant volumes of blue carbon can remain stored in the marine environment for millennia, decreasing the volume of carbon in the atmosphere that contributes to climate change. Fisheries have a crucial role to play in the solutions to reaching carbon neutrality by 2050. A future EU strategy on fisheries and aquaculture energy transition should address the overall fisheries impact on blue carbon: -The disturbance of blue carbon habitats in marine systems: Fisheries primarily impact blue carbon through the contact made between towed bottom fishing gears and the seabed. Disturbed carbon re-mineralizes into the water column and can eventually re-enter the atmosphere where it adds to global greenhouse gas (GHG) levels. In order to support recovery of blue carbon, it is necessary to ban mobile bottom-contacting gears within MPAs and in high carbon areas outside of MPAs and create buffers around sensitive features to avoid smothering from disturbed sediment. This should be supported by mandating REM and VMS to track vessel activity, and by financing the development, testing and rollout of gear modifications. Incentives for fishers and fish farmers to restore marine habitats and species should be developed. - The extraction of fish and disruptions to ecosystem function: The fishing industrys extraction of fish above sustainable levels is an extraction of blue carbon, further contributing to GHG emissions. Fisheries have significantly depleted some fish and shellfish stocks relative to pre-industrial levels, thereby removing large volumes of carbon in the form of marine organisms. Overfishing practices further impact blue carbon by contributing to biodiversity loss and changes in ecosystem function. Fishing above sustainable levels can lead to the removal of enough fish biomass within certain trophic levels to unbalance food webs. It is vital to set fishing opportunities (TACs) below MSY, and to include the impact of climate on fish stocks1 and the ecosystem role of forage fish when setting TACs and quotas. Increased research and knowledge on blue carbon habitats, stocks, bycatch and the fishing sectors GHG emissions and blue carbon impact are essential. It is necessary to provide greater transparency, monitoring and traceability throughout the EU fisheries sector (by mandating REMs and VMS on all vessels) in order to improve the health of stocks, increase biomass and the necessary scientific knowledge. - Industry-wide fossil fuel use: powering fisheries requires significant fossil fuel use causing a significant industrial carbon footprint through GHG emissions. It is necessary to remove fuel subsidies, eliminate inefficient fleet structures and support alternative, small-scale and low-impact fishing gear. Public funds should never be allowed where they contribute to overfishing, and investment in fuel alternatives, alternative gear and low carbon propulsion systems should always be part of an overall reduction in fisheries capacity and alongside establishment of no-take zones allowing effective and long-term marine restoration, to avoid further marine ecological degradation. At the same time, it is vital to consider potential impacts from any changes to fishing practices and gears, e.g., increased bycatch of certain species in some passive gears, and take mitigation measures. To fill the knowledge gaps, emissions should be tracked, calculated, and the information made transparent and publicly available. In conclusion, this future strategy should pave the way for a just transition to low-carbon fisheries, encompassing all the impacts of fishing on blue carbon and biodiversity, be part of an overall strategy to reduce fishing levels and seafood consumption in the EU and be aligned and developed in parallel of marine restoration under the NRL.
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Meeting with Sirpa Pietikäinen (Member of the European Parliament) and European Environmental Bureau and WWF European Policy Programme

10 Nov 2022 · Nature Restoration Law (NRL

Meeting with Arunas Ribokas (Cabinet of Commissioner Virginijus Sinkevičius) and WWF European Policy Programme and

10 Nov 2022 · the EU forest policy, including on biomass

Meeting with Carmen Preising (Cabinet of Commissioner Virginijus Sinkevičius), Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and

14 Oct 2022 · Implementation of the EU Biodiversity Strategy for 2030 and the preparation of the Action Plan to conserve fisheries resources and protect marine ecosystems

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and ClientEarth AISBL and

14 Oct 2022 · Implementation of the EU Biodiversity Strategy for 2030 and the preparation of the Action Plan to conserve fisheries resources and protect marine ecosystems

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen) and THE NATURE CONSERVANCY IN EUROPE gemeinnützige GmbH and

5 Oct 2022 · Biodiversity and forests. Financing.

Response to Communication on the functioning of the Common Fisheries Policy

23 Sept 2022

Despite the CFP's objectives to make EU fisheries economically, socially and environmentally sustainable, progress in implementation has been too slow to effectively protect and restore marine ecosystems. This was clearly confirmed by the European Court of Auditors in its Special Report 26/2020. The CFP is not sufficiently implemented, controlled, and enforced. The tools to address the implementation gaps exist in the policy itself or in other available legal instruments. What is needed is a strong (political) will from the Commission and the Member States and better cooperation for the full implementation of the CFP. One of the main challenges in the implementation of the CFP, which needs to be urgently addressed, is the failure of Member States to adopt management measures to reduce the harmful impacts of fisheries on marine species and habitats and to adequately monitor the impact of fisheries. This runs counter to the objectives of the EU Biodiversity Strategy for 2030, including the future marine targets of the Nature Restoration Law. In particular, the regionalisation process has proved deeply flawed and ineffective in ensuring sustainable fisheries. It leads to time consuming processes, in which too many exemptions and flexibilities hamper the CFP`s implementation. Scientific advice and the precautionary approach are often ignored. Lack of clear guidance, leadership and political will leads to delays, veto blockages, lowest common denominators and undermining of legal obligations. The EC should play a more outspoken role in monitoring the regionalisation process (including the role of the advisory councils). The EC must also hold MS legally responsible for not adhering to the environmental objectives of the process in a timely manner. The failure of the Article 11 CFP process should be at the heart of the CFP review process and the future report. The European Commission should take stock of this failure and take specific action to ensure the future implementation of the CFP, for example by launching infringement proceedings against Member States that have not established appropriate fisheries management and conservation measures to protect sensitive species in Natura 2000 sites and by using its emergency powers under the CFP to impose immediate closure of fisheries in cases of non-compliance The European Commission should establish a clear annual timetable for Article 11 procedures, similar to that for discard plans, with dates for submission of joint recommendations, evaluation by STECF and publication of the evaluation by the Commission. Improvements need to be made in terms of timeliness and legal obligations when developing and agreeing recommendations on measures to improve selectivity or restrict fisheries in order to contribute to EU environmental legislation. In addition, the Commission should further assess the poor implementation by Member States of the Data Collection Framework Regulation and the Technical Measures Regulation regarding bycatch data collection and mitigation, and urgently take appropriate measures to ensure enforcement, such as infringement proceedings against Member States for lack of implementation. The attached report draws on the latest information about seabird bycatch in EU and non-EU waters, and the implementation of current EU legislation. It proposes specific recommendations in order to achieve the objective to minimise, and where possible eliminate, seabird bycatch in EU fisheries in domestic and external waters.
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Meeting with Caroline Roose (Member of the European Parliament) and ClientEarth AISBL and

21 Sept 2022 · Loi européenne sur la restauration de la nature

BirdLife Europe demands stricter rules and EU pesticide tax

19 Sept 2022
Topic — The consultation addresses the revision of EU rules for the sustainable use of pesticides.
Message — The organization calls for closing loopholes that allow Member States to ignore pesticide reduction recommendations. They demand a ban on preventative pesticide use and strict definitions for pest management. They also propose an EU-wide pesticide tax to reduce dependency on chemicals.123
Why — Stricter regulations would protect bird habitats and strengthen the legal framework for nature conservation.4
Impact — Chemical pesticide manufacturers and intensive farmers would face higher operational costs and market restrictions.5
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Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

13 Sept 2022 · gas - biomethane

BirdLife Europe demands mandatory farm environmental data collection

9 Sept 2022
Topic — Initiative to expand farm accounting data to include environmental and social performance metrics.
Message — BirdLife Europe demands mandatory environmental variables like biodiversity and pesticides. They urge starting data collection before 2025 while ensuring database interoperability.12
Why — Enhanced data access would empower the group to monitor agricultural impacts on wildlife.3
Impact — Intensive agricultural producers would face mandatory reporting on their chemical inputs and footprints.4
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Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament) and European Environmental Bureau and

8 Sept 2022 · exchange on RED II

Meeting with Caroline Roose (Member of the European Parliament, Rapporteur for opinion) and European Environmental Bureau and

1 Sept 2022 · Environmental Crime Directive (Protection of the environment through criminal law )

Meeting with Sara Cerdas (Member of the European Parliament) and WWF European Policy Programme and ClientEarth AISBL

1 Sept 2022 · Restauração da Natureza

BirdLife Europe warns against pitting nature protection against renewable energy

27 Jul 2022
Topic — EU proposal to accelerate renewable energy permitting and deployment under REPowerEU.
Message — The organization supports go-to areas for renewables using strategic spatial planning and sensitivity mapping, but opposes blanket exemptions and weakening environmental assessments. They emphasize that understaffing of licensing authorities is the real barrier, not environmental protections.123
Why — This would maintain their influence over renewable energy siting decisions and preserve environmental assessment requirements.45
Impact — Protected species and ecosystems lose safeguards if blanket exemptions allow projects without proper environmental review.67
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Meeting with Virginijus Sinkevičius (Commissioner) and

19 Jul 2022 · To exchange views, upon NGO request, on the upcoming Action plan to conserve fisheries resources and protect marine ecosystems, on Commission implementing act on vulnerable marine ecosystems and on European eel status

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

15 Jul 2022 · To discuss the nature restoration law

Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and Naturschutzbund Deutschland e.V. and

12 Jul 2022 · staff only: Sustainable Use Regulation, exchange of views on the Commission proposal

BirdLife Europe demands environmental monitoring for agricultural subsidies

30 Jun 2022
Topic — EU regulation on monitoring and evaluating the Common Agricultural Policy's performance.
Message — The organization requests that 2% of each intervention budget fund independent scientific monitoring with EU-level methodological guidelines. They want Member States to provide raw data in broad categories rather than aggregated data, and make data accessible to scientists and research organizations.123
Why — This would enable independent verification of whether agricultural subsidies actually protect biodiversity and environment.45
Impact — Farmers and Member States lose flexibility as they face stricter monitoring requirements and data transparency.67
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and Greenpeace European Unit

2 Jun 2022 · Sustainable food systems and CAP

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and Climate Action Network Europe and

10 May 2022 · To discuss the RePower EU

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and Climate Action Network Europe and

10 May 2022 · To discuss the RePower EU

Meeting with Janusz Wojciechowski (Commissioner) and

22 Apr 2022 · Farm to Fork Strategy for food security

Response to Evaluation of the LIFE Programme 2014-2020

13 Apr 2022

We welcome the opportunity to provide our view on the LIFE programme. Funding through LIFE is highly efficient. 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, for example the Spanish Imperial Eagle. In our experience the following aspects have proven to work well: - Funding projects in overseas territories/third countries should be maintained. As environmental problems respect no borders, funding should not be restricted to the EU. - The built-in flexibilities are very useful as they help to adopt the project plans to occurring changes. - In general, the external monitoring process works well. However, the key performance indicator tool is too complicated. - We are aware of complaints about LIFE being too bureaucratic. We cannot confirm. Given the need to avoid misuse of funds, the application process seems manageable. The two-step application process helps develop the project proposal. The following aspects require improvement: - The co-financing is the biggest challenge, 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(s) where the activities take place, in well-argued cases further to up to 95%. - The budget 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 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 MFF. - We have found the key performance indicator tool to be overcomplicated and difficult to interpret. Measuring performance is of course essential to any funding activity. But using the indicator tool has proved to be very burdensome and failed to provide legal certainty. Simplification or more straight forward guidance is needed. - The protection of biodiversity should remain the main goal of LIFE. Also other funds (most notably the CAP) need to improve their effectiveness in terms of biodiversity as well; a task which, according to our assessment of the National Strategic Plans for the CAP, will probably be failed by most MS (https://www.birdlife.org/news/2022/03/17/cap-national-strategic-plans-intensive-agriculture/). 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 projects that create results in multiple policy areas. - The new EC portal through which all applications and communications with the LIFE Team have to go is a bit difficult to operate. For example, the messaging system doesn’t always work, guidelines don’t match the templates, templates contain sections that don’t seem relevant but just a copy-paste from the Horizon Programme. This year we also needed to basically prepare contracts ourselves, which was an additional complication and admin.
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Meeting with Giorgos Rossides (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and

9 Mar 2022 · VTC meeting: Revision of the SUD Proposal

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and European Environmental Bureau and

4 Mar 2022 · EU Nature Restoration Law preparations

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

4 Mar 2022 · EU Nature Restoration Law

Response to Improving environmental protection through criminal law

9 Feb 2022

BirdLife Europe and Central Asia welcomes the Commission’s proposal revising the directive. Strengthening the protection of the environment through criminal law is essential to support the enforcement of the European Green Deal, and places the EU as a leader in the fight against global biodiversity loss and climate change. As the environment cannot represent itself, and given the lack of resources dedicated to the detection of environmental crime by Member States, we especially welcome the inclusion of provisions on the protection and involvement of environmental whistle blowers, ensuring that civil society organisations and individual environmental defenders can take their role in reporting environmental crime. We also welcome the strengthened approach via national strategies, reporting duties and minimum requirements for resources, training, and investigative tools. We also support the inclusion of serious negligence, intentional attempt and endangerment crime, as well as the more detailed provisions for aggravating and mitigating circumstances, and the reference to additional penalties and sanctions. We published an article where you can read more here: https://tinyurl.com/44tswwmb. There are a few points we would like to highlight for improvement: Scope: • The proposed system still relies upon a list of secondary legislation and lacks a general definition of what constitutes an environmental crime. • It does not make the directive future proof, as it regrettably continues to rely on future legislative amendments whenever the EU environmental law acquis is extended. • Should be extended to cover also the most serious infringements of illegal, unreported and unregulated fishing. • We welcome the reference to ecocide in the recitals but believe that ecocide should also be included in the operational part of the Directive. Sanctions: • The proposed minimum standards for maximum limits for penalties and sanctions should be increased to be truly effective, proportionate and dissuasive. The new legal basis of article 83(2) TFEU should be utilised to its fullest potential and a minimum standard for a maximum sanction of 15% of annual turnover for legal persons should be aimed at. Remediation of environmental damage • The payment of civil liability should complement penal sanctions under this directive. Civil liability, equal to the cost of reinstatement of the environment, as well as the reinstatement of the environment, should be paid, particularly if environmental reinstatement is no longer possible Enforcement: • Provisions for the establishment of specialised coordination bodies in every member state should be made. • Jurisdiction should be extended as much as possible to increase environmental protection. Definitions: • the term “substantial damage” should be further defined, as it continues to be too vague. It had already been identified in the current text as a major obstacle to effective prosecution on the ground. The proposed list of elements to be taken into account when assessing “substantial damage” should be extended. Data collection and statistics • Statistical data gathered at Member State level should be made public in its raw format rather than via consolidated reviews; its access by civil society should be guaranteed. • Data gathered should also include information quantifying the actual crimes committed (eg. hectares of damaged habitats; number of individuals and species of birds poisoned; tonnes of waste illegally dumped; etc) Finally, we would like to point out that the revision of the Environmental Crime Directive is an opportunity to discuss the extension of the European Public Prosecutors Office’s jurisdiction to include environmental crimes with known links to organised crime, as has also been called for by the European Parliament. BirdLife supports the general direction of the Commission’s proposal and is ready to support it during the legislative procedure.
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Meeting with Janusz Wojciechowski (Commissioner) and

16 Dec 2021 · CAP Strategic Plans and the European Green Deal’s objectives

Meeting with Virginijus Sinkevičius (Commissioner) and

28 Oct 2021 · NGOs presented their expectations for an ambitious reform and shared views on specific topics in the revision of the EU fisheries control system.

Response to Sustainable food system – setting up an EU framework

26 Oct 2021

BirdLife Europe welcomes the Sustainable EU food system initiative and the opportunity to give feedback on the Inception Impact Assessment. The evidence shows that food systems in Europe are unsustainable and the way how we produce and consume food is driving biodiversity loss, causes environmental pollution and contributes to climate crisis. There is also problem with food poverty and the obesity crisis. We believe that public policies have a critical role to play in transformation of the food system as voluntary approaches have failed. The nature and scale of the challenges requires new comprehensive legal framework (option 4) setting a clear vision and direction of travel for EU food systems and driving an ambitious, just and systemic transition to environmentally-sound, fair and healthy food systems. There is a need for: common goals, objectives and targets; relevant EU policies, including the CAP, to be coherent and to remove policy levers that are impeding progress; and systems and metrics to measure, assess and report on sustainability. The new law must have greater focus on the sustainability of the entire food system, including production and consumption to avoid a product-centric approach. It must also create a framework to make sustainable food choices the easy and default option. There is a need for a strong EU governance framework to implement the new Sustainable Food system law, enforce the obligations it contains and ensure coordinated multilevel action.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

13 Oct 2021 · Transparent and inclusive process of CAP plans

Response to Restoring sustainable carbon cycles

7 Oct 2021

BirdLife Europe welcomes the EC’s efforts to develop a robust legislative framework for carbon dioxide removals (CDR). The latest IPCC report recognises the need to deploy solutions for CDR, and this requires careful steering from policymakers to avoid negative externalities and harness co-benefits. However, the highest priority must remain to drive deep and rapid cuts in GHG emissions at source. Natural solutions through ecosystem restoration hold huge potential for CDR: - deploying agroforestry on 9% of farmland could deliver 235 Mt CO2e removals per year - restoring 250Mha of degraded peatlands could bring their net emissions down from 220 Mt CO2e to -25 Mt CO2e/y - deploying agroecological land management on croplands and grasslands (on mineral soils) could increase the sequestration of that land by ~135 Mt CO2e - passive restoration and protection of marine protected area can be deployed easily at scale (by banning bottom trawling or declaring ‘no-take’ or ‘no-go’ zones) and would stop high losses of C from the ocean sink and enable new C sequestration In addition, these ecosystem restoration-based CDR solutions deliver significant benefits on other environmental dimensions (biodiversity, climate adaptation, water quality and management) and are much cheaper than technological solutions. In comparison, technological CDR solutions come with major trade-offs: e.g. BECCS has a high land footprint and could add pressures on biodiversity, DAC is highly energy-intensive. CCU is merely a tool to delay the release of C to the atmosphere and should thus not be considered as a CDR technology. All are still in early days and very expensive. BirdLife Europe therefore believes the primary focus of CDR efforts should lie in nature-based solutions which must be deployed with equal attention to biodiversity, adaptation, and socio-economic objectives as to climate mitigation. Importantly, afforestation and agroforestry must not be planted in areas already important for biodiversity including semi-natural grasslands, or important areas for climate such areas with peat soils. It is critical that ecological survey and assessment informs planting of trees. The large-scale deployment of technological solutions could divert crucial resources away from more cost-effective and holistic solutions, or at worst delay genuine climate action, and should therefore not be a priority for the EU. BirdLife Europe only supports the targeted deployment of CCS for non-abatable emissions in industrial processes, we do not support the use of CCS in the oil & gas sector. The EU agri-food system is currently highly linear, with a high inputs footprint and high waste and pollution. This is true for carbon/biomass but also other nutrients (N, P, etc). To restore sustainable C cycles, the EU should establish a hierarchy of biomass use and define sustainable levels of biomass use within ecosystems’ biocapacity. BirdLife Europe supports the following hierarchy: 1. Sustainable food provision, 2. Maintaining the fertility of agriculture and forest soils by returning nutrients to the system, 3. Production of bio-based materials to replace less sustainable materials (eg. bioplastics), 4. Energy production based on waste and residues within a strict cascading logic. (cf https://tinyurl.com/2y77xsdd & https://tinyurl.com/enxu9k62). Food waste must be reduced as a priority, then fully recycled. The EU’s carbon farming initiative should contribute to this by deploying nature-based solutions (as defined by the IUCN) and promoting holistic, circular approaches to “the management of land-based GHG fluxes, including carbon pools and flows in soils, materials and vegetation, with the purpose of reducing emissions and increasing carbon removal and storage.” This can only happen if carbon farming schemes enroll the whole farm and account for all GHG fluxes linked to land management practices.
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)

4 Oct 2021 · the upcoming EU nature restoration targets

Response to Amendment to the delegated act on the functioning of the Advisory Councils under the Common Fisheries Policy

10 Sept 2021

BirdLife Europe & Central Asia welcomes the Commission’s draft Delegated Act (DA) and efforts on the improvement of the functioning of the Advisory Councils (ACs), but we would like to bring to your attention some fundamental improvements that are still needed to ensure the functioning and the legitimacy of the ACs. Having been actively participating in the ACs for many years, we have experienced that transparent, balanced, and informed recommendations and suggestions by ACs are critical to comply with Art. 43(1) of the Common Fisheries Policy (CFP) and that the current way the ACs are organised can prevent these from being formed. We support the requirements on working methods under art. 5, as well as article 7a, which would require an independent performance review to be conducted at least once every 5 years for each AC. These evaluations, and the requirement for an action plan to address any identified shortcomings, will contribute to improving ACs’ contribution to the objectives of the CFP provided that they are followed up with immediate consequences when ACs are not performing well, and when shortcomings are not properly addressed. We, therefore, consider that this DA should provide for the possibility of sanctions and of suspending ACs funding in case of failure to deliver the independent performance review and adequately improve or address identified deficiencies. We welcome the efforts to clarify the classification of members in one of the two categories of stakeholders. However, while recognizing the importance to keep the door open to any interest groups affected by the CFP (per article 45(1)(b) CFP), we are concerned about the specific inclusion in the “other interest group” of any ‘organisation that represents or has direct or indirect economic interests linked to the use of the marine environment or maritime space other than commercial fishing, aquaculture or the processing, marketing, distribution and retail of seafood.' (Annex, art. 2(b)). We believe that these organisations representing or having direct or indirect economic interests should rather be included in the sector organisation group, as their interests, although not directly linked to fisheries or aquaculture, remain economic. This should be the main criterion for differentiating between sector organisations and other interest groups, and the Commission should define general criteria for the categorisation of economic and non-economic interest in expert groups, as stated by the European Ombudsman in its decision OI/6/2014/NF. In addition, it is regrettable that the DA fails to address the persisting lack of compliance with the required balanced composition of ACs as per Article 43(1) CFP. In particular, we regret that it does not introduce a more balanced composition between sector organisations and other interest groups, ensuring a strictly 50/50 representation when voting. Furthermore, when consensus is not possible to reach, the DA must ensure minority positions and dissenting opinions are duly recorded by the ACs. Finally, we believe that the DA should clarify that the ACs are “Commission expert groups” as defined by the Commission’s decision C(2016)3301 and that they should, as such, align with the horizontal rules stated in this decision and with the Ombudsman's decision OI/6/2014/NF. In particular, the Commission should guarantee that the rules for setting up and governing the ACs, including the chairmanship, the assessment of potential conflicts of interest between participants, the conditions for membership and participation, and all other operational issues remain under the responsibility and review of the Commission. As already stated in the joint letters sent to the Commission in April 2019 and July 2020, we are convinced that all these improvements are necessary to create the conditions for a constructive structured dialogue in these ACs, which is an essential precondition for our full engagement and participation.
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Response to Non-compliance cases and serious non-compliance cases with Common Fisheries Policy rules by Member States under EMFAF

23 Aug 2021

While we welcome the opportunity to provide feedback on this draft implementing act (IA), we expected it to clarify as much as possible the rules set out in the EMFAF regulation. As it stands, however, several grey areas remain, making this provision difficult to implement or inapplicable in the future. As for the triggering of the procedure: we consider that the interruption/suspension of a payment is a tool that can be extremely effective, capable of dissuading Member States (MS) from maintaining situations of non-compliance, or strongly encouraging them to remedy such situations, in the same way as the compliance tools provided for in Title XI of Regulation 1224/2009. It would therefore be normal for an interruption of payment to be triggered at the very moment when the Commission has identified situations of non-compliance that are sufficiently significant to open a pre-litigation procedure against a given MS, as it is not normal for a MS to receive money from European public funds to implement the CFP when there is an identified non-compliance situation concerning its implementation. We therefore encourage the Commission to refer to Title XI of Regulation 1224/2009 and to clearly specify when such a procedure may be triggered, in order to give it full effect. As for the severity criteria: Articles 42.3 and 43.3 of the EMFAF Regulation provide that interruption/suspension shall be proportionate to the "nature, severity, duration and repetition of the non-compliance". However, the draft IA gives no indication as to the possible definition and application of such criteria. While we understand that a case-by-case analysis must be carried out to take into account certain specific contextual elements, this leaves considerable room for manoeuvre in the interpretation of these criteria and their use, and undermines legal certainty. As it stands, it is impossible to know at what point the Commission will consider that a situation of non-compliance may justify the initiation of such a procedure. There is a serious risk of never being able to trigger these procedures without provoking objections that the criteria mentioned have not been fulfilled. We invite the Commission to specify in greater detail what is meant by the criteria mentioned in the EMFAF regulation, articles 42 and 43. As for the deadline for a MS to submit information on the situation of non-compliance: Articles 42.2 and 43.2 of the EMFAF Regulation provide that a MS concerned has a reasonable time to respond and submit information. This time limit is vague and needs to be specified in the IA in order to avoid lengthy procedures jeopardizing the application of the provisions of the EMFAF Regulation, since triggering the interruption or possible suspension of a payment linked to an irregularity when this payment has already been made would make this procedure ineffective or at least unnecessarily complicated (leading to calculations of reimbursements, etc). As for the transparency of the solutions implemented by the MS to remedy cases of non-compliance: Article 2 of the draft IA does not define the rules governing the resolution of a situation of non-compliance, i.e. the rules which make it possible to establish/conclude that such a situation is no longer problematic and will therefore not lead to the suspension of a payment. It is also necessary to define transparency rules regarding the publication of concrete solutions (actions and deadlines for implementation) put in place by the State targeted by an interruption procedure. As for the effective interruption/suspension of payments: we consider that this should apply to the EU contribution allocated to the EMFAF specific objectives related to the cause of the non-compliance, and not to the effects of non-compliance (e.g., environmental objectives). As for the cases of non-compliance referred to in Article 1: please find attached a document with additional suggestions to the Annex of the draft IA.
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Meeting with Virginijus Sinkevičius (Commissioner) and

13 Jul 2021 · To exchange views with the ‘’blue’’ NGOs on the upcoming Action Plan on sustainable fisheries and protection of marine resources, annual exercise of fixing total allowable catches and ongoing WTO negotiations on fisheries subsidies.

Meeting with Virginijus Sinkevičius (Commissioner) and

2 Jul 2021 · To mark the engagement of 104,000 citizens in the EU Open Public Consultation for an EU Nature Restoration Law and to shortly discuss some issues related to biodiversity and the nature restoration law.

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and

7 Jun 2021 · Renewable Energy Directive (RED II) review

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

BirdLife Europe and Central Asia welcomes the chance to provide feedback on the EU Taxonomy Article 8 delegated act. Overall, the draft reflects a thorough review process – it is important that this process generates transparency and facilitates efficient and comprehensive information disclosure on the environmental performance of companies. We would like to reinforce that ultimately this must prevent greenwashing and support sectors making genuine efforts to align with the Paris Agreement, the Sustainable Development Goals and other associated global targets. We welcome parameters for consistency and comparability of disclosure requirements through Article 8 and the opportunity for increased visibility on companies’ environmental performance via their investment and operational decisions and avoid greenwashing. We similarly welcome the opportunity for voluntary disclosures, such as by non-EU companies, which will facilitate global engagement and integration, as the Taxonomy will set a precedent for global action. We commend the relative user-friendly and clear nature of the templates across the different stakeholder groups. We also welcome KPIs of non-financial undertakings for ‘substantial contribution’ criteria, on top of ‘do no significant harm’ criteria and across the environmental objectives. Globally there must be a shift in the approach towards sustainable business and investment and to do this we require net-positive social and environmental outcomes over the coming decades. Despite the above positives, BirdLife Europe considers that the following items should be reflected in the revised draft: - It is important that the situation for small and medium size enterprises (SME’s) be well clarified in the delegated act. We would recommend more thought goes in to this process, and suggest they be appropriately included in the directive scope, to prevent a lack of financing incentive from investors (access green finance) and reduce bias towards larger companies. Noting this, we would also expect the review of SME exposure and impact assessment process to be well in advance of the proposed 2025 date, to reflect the complexity of the process and enable a fair and representative review of SME challenges. - Similarly, the proposed review of public exposures to central governments and central banks in 2025 is too far down the line. We would expect this to happen sooner to ensure alignment, transparency and suitability. - Greater clarity of reporting requirements and disclosure obligations for the phasing in/first time adoption of the delegated act is required. - Once the screening criteria are defined, reference to steps for credit institutions to calculate the GAR for each environmental objective for the other four objectives should include a breakdown of the steps. - We would suggest clarification of the vague term ‘associated with’, as referenced throughout the draft – e.g. ‘to what extent their activities are associated with environmentally sustainable economic activities as defined under the EU Taxonomy legislation’. This should be defined to help stakeholders e.g. ‘meet taxonomy criteria’ (or meet DNSH or significant contribution criteria).
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European Environmental Bureau and

1 Jun 2021 · Restoration law

Response to Delegated act framing the programming of the Neighbourhood, Development and International Cooperation Instrument (NDICI)

31 May 2021

Addressing the environmental crisis is a pre-condition to alleviating inequalities and poverty, preventing conflicts over natural resources, and achieving the Sustainable Development Goals (SDGs). It is a cross-border challenge that can only be addressed through better cooperation and the EU must build on its historical responsibility in driving the environmental crisis and its capacity to act to support the global south, which comprises amongst the countries the hardest hit by climate change and biodiversity loss. In line with article 48 of the provisional agreement on the regulation, the delegated regulation should reflect the EU commitments to implement the Green Deal and the SDGs, by mentioning the target of 30% expenditures supporting climate objectives. Moreover, we recommend recalling in the delegated regulation the contribution of the Global Europe instrument to the overarching biodiversity target spanning across the Multiannual Financial Framework – 7.5% of annual spending to be dedicated to biodiversity from 2024, and 10% from 2026 – to make sure it starts contributing as early as possible to this objective, including through its geographical pillar. This is all the more important that the NDICI will play a major role in implementing the new Global Biodiversity Framework which should be agreed at the COP15 of the Convention of Biological Diversity (CBD). The SDGs, the Paris Agreement and CBD’s global biodiversity framework should act as guiding frameworks for prioritising action under the NDICI. Annex on objectives and priority areas of cooperation per sub-region • We welcome the inclusion of the protection of the environment and the fight against climate change as priority area and recommend mainstreaming these objectives into all priority areas. • As we are entering the UN Decade on Ecosystem Restoration, the delegated regulation must recall the key role of nature-based solutions in protecting but also restoring nature, linking this to support to climate adaptation, and highlighting that this should be mainstreamed in all NDICI programmes. The EU has an obligation to achieve a balance between mitigation and adaptation finance under the Paris Agreement and is currently falling short on delivering on adaptation finance and the Global Europe instrument has an important role to play in delivering this. • Objectives should be formulated around the better recognition of Key Biodiversity Areas and OECMs, including through the deployment of better monitoring tools to identify and expand these areas, and ensure habitats connectivity. • More resources should also be allocated to addressing the loss of critically endangered species that don’t fit within the integrated landscape/ecosystem approaches (e.g. the crisis facing African vultures), and their associated threats. • The NDICI must also ensure that strong biodiversity safeguards are in place for EU funded developments, including through supporting investments in environmental impact assessments and providing guidance to financial bodies. • Where applicable (e.g. in West Africa), the NDICI should coordinate with funding coming out of other sources such as the Sustainable Fisheries Partnership Agreements to make sure that there is greater support and safeguard to ensure the protection for the marine environment. • The EU should support increased civil society capacity for environmental protection and restoration, and democratic engagement, and ensure the full participation of Indigenous Peoples and Local Communities, women and youth. It should foster greater transparency in publicly consulting about funding priorities to be considered by the EU and train local communities in engaging around associated policy processes. Attached, you can find a briefing highlighting the major challenges which are preventing Nigeria to implement a green recovery. This provides a concrete example of priorities the NDICI should better address in its implementation.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and WWF European Policy Programme and

19 May 2021 · Forests, climate and biodiversity

Response to Action plan to conserve fisheries resources and protect marine ecosystems

11 May 2021

Seabirds are an important component of marine ecosystems foraging over large areas of sea and feeding on a variety of species within marine food chains. As umbrella species, actions to conserve seabirds have benefits for wider marine biodiversity. To restore and recover the oceans there is an urgent need to transition to low-impact fisheries by banning non-selective fishing gear and destructive fishing practices that harm biodiversity. Bycatch levels for sensitive species remain alarmingly high in Europe. It is estimated that more than 200,000 seabirds are killed each year as bycatch in EU waters, especially in gillnet and longline fisheries, involving at least 29 species listed in Annex I of the Birds Directive. Almost 10 years have passed since the publication in 2012 of the “Action Plan for reducing incidental catches of seabirds in fishing gears”. Little significant progress has been made to address the issue in the EU waters and by EU vessels. Yet seabird bycatch can be greatly reduced in most fisheries through relatively simple and inexpensive technical measures or adaptations of existing fishing practices. Considering the lack of measures to address seabird bycatch and ensure the protection of marine ecosystems, it is imperative that the upcoming "Action Plan to conserve fisheries resources and protect marine ecosystems" effectively addresses the problem of bycatch of seabirds in fishing gears and include a clear roadmap on urgent actions and compulsory measures for the next years to ban destructive fishing practices. The new Action Plan should include in priority the following specific actions: -Immediately assess Natura 2000 sites’ management plans, existing mitigation measures to reduce bycatch, and MS compliance with existing rules. -Urgently launch infringement proceedings against MS that did not take the appropriate management measures and adopt emergency measures to impose the immediate closure of fisheries that are not respecting the mitigation measures and fisheries with high bycatch rates without viable technical mitigation. -Imperatively reduce the fishing effort in EU waters to sustainable levels and restricted to stocks that have been scientifically assessed, with ICES catch advice for stocks subject to the MSY and precautionary approaches treated as an upper limit for fishing mortality, ban non-selective fishing gear, and ensure fully documented fisheries with 100% monitoring and control of all vessels. -Urgently strengthen the protection of seabirds, by ensuring consistent application of existing rules and mitigation measures, by improving the network and the management of protected areas, by establishing systematic and standardised monitoring programmes, and by implementing scientifically tested mitigation solutions. -Pressingly improve the data collection of seabird bycatch with the development of standardised methodology at sea basins level with harmonised reporting formats applied in national programmes. EU should urgently require all vessels to record bycatch in Elogbooks and to use trained onboard observers or REM systems covering a sufficiently high percentage of fishing effort to ensure that the data is accurate, representative, and enables robust estimates of bycatch rates. -Crucially increase education and training to fishermen in the use and benefits of mitigation measures and accurate identification of seabirds for reporting purposes and continually invest in research and development of practical and effective mitigation measures for all fishing methods. The new Action Plan must not become another action plan without any concrete follow-up actions. It should: -Identify the accountable party for each action -Include obligations for regular reporting by MS on its implementation -Include regular assessments and evaluations by the EC to establish an evidence base for infringements against MS that do not fulfill their obligations -Ensure all actions are supported by financial commitments
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Response to Protecting the environment in the EU’s seas and oceans

5 May 2021

The MSFD is the cornerstone of EU marine environmental policies and a national, regional, and international reference. It provides an essential structure for bringing together the different policies affecting the marine environment (e.g. fisheries, energy, transport). With this Directive “the EU has a holistic and comprehensive marine policy in place that puts into practice the ecosystem-based approach to manage human activities in Europe’s seas. Importantly, it also helps in delivering key international commitments” (MSFD 2020’s Implementation report). However, despite more than 10 years of implementation, the main objective of the Marine Strategy Framework Directive (MSFD) has not been reached, in particular reaching GES in EU marine waters by 2020. Its implementation has been too slow, due principally to limited ambition from Member States (MS) in setting up appropriate definitions, targets, and measures to reach GES, lack of political will to adequately fund and enforce the necessary measures, and limited involvement of the relevant sectors. We recognise the weaknesses of the Directive’s implementation. Nevertheless, as stated in the implementation report, it is the responsibility of the MS and the EC to deploy the necessary resources to ensure that the EU seas are in GES by allocating sufficient resources and ensure effective implementation and compliance. The EC, together with the MS, should identify the regulatory and administrative changes necessary to protect sensitive species and habitats, which both facilitate the faster application of conservation measures under the MSFD and other areas such as the CFP (European Court of Auditors Special Report: Marine environment: EU protection is wide but not deep). We believe that existing legislative tools, delegated/implemented acts, development of further guidance or infringement procedures and additional funding should ensure better implementation and compliance with the Directive and help to improve MS’s GES definitions. These should increase the effectiveness of measures to address obvious pressures, strengthen coordination on a regional level and between MS, ensure timely reporting from MS, increase protection, management, and enforcement of MPAs, increase synergies with other policies and raise the level of international cooperation and coordinated action. There is an urgent need for greater coherence with the new EU environmental ambition under the Green Deal and the 2030 Biodiversity Strategy. To that end, the MSFD must be strengthened by developing complementary approaches for better implementation and coverage of issues currently missing, with targeted new legislative and non-legislative tools as the upcoming EU Action plan to conserve fisheries resources and protect marine ecosystems and the future EU restoration law. The primary goal and scope of a review should be to reach GES in European waters as soon as possible. The evaluation of MSFD should lead to a strengthening of its implementation, to push MS to meet its objectives. A revision of the MSFD, even targeted, is a lengthy process and carries the risk of causing further delays and failings in implementation. We are concerned that it will send the wrong signal to MS that are already failing to meet their own targets, and it may be used as an opportunity to further weaken or postpone the achievement of the GES until the revision process is concluded, by giving priority to adapt to a new framework instead. The EC should use all possible legal pathways, to improve the implementation of the Directive without re-opening it. Furthermore, any attempt to simplify and reduce the administrative burden for MS must not result in lowering the overall level of ambition of the MSFD. For all these reasons, BirdLife Europe strongly supports option 3: “Strengthen implementation and enforcement of the Directive without changing its provisions”.
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BirdLife Europe urges end to forest biomass subsidies

28 Apr 2021
Topic — EU regulation on sustainability criteria for forest biomass used in bioenergy production.
Message — The organization calls for removing forest biomass eligibility from renewable energy incentives. They argue current criteria fail to prevent destructive harvesting practices like clear-cutting and don't ensure net emissions reductions over climate-relevant timescales.123
Why — This would redirect billions in member state subsidies toward their conservation priorities.4
Impact — The bioenergy industry loses subsidies and market access for forest-based fuel production.5
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

23 Apr 2021 · Discussion on CAP

Meeting with Frans Timmermans (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

19 Apr 2021 · Foreseen review of the renewable energy directive and use of forest biomass for energy production

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Transport and Environment (European Federation for Transport and Environment) and

14 Apr 2021 · Videoconference discussion on the use of biomass for energy, especially forest biomass, and on transport biofuels.

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and WWF European Policy Programme and

13 Apr 2021 · Preparation for the meeting with EVP Timmermans

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis) and

8 Apr 2021 · Recovery and resilience plans

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Transport and Environment (European Federation for Transport and Environment) and

26 Mar 2021 · Taxonomy

Response to Revision of EU Programme for biological, environmental and socio-economic data collection in fisheries and aquaculture

15 Mar 2021

The lack of data on the occurrence and level of bycatch of sensitive species hinders the ability to manage and apply rules on fishing vessel activities. Even where data exists, the lack of statistically robust and harmonised sampling designs limits its value. Due to the irregularity of catches of vulnerable species, calculations based on limited observer data lead to high biases, resulting in an underestimate of bycatch. Adequate monitoring programmes and frameworks providing sound bycatch data collection, with adequate coverage and reliable information, are urgently required. Therefore, the Delegated Decision should include the following: • All EU fishing vessels, fishing inside and outside EU waters, should be required to record their catches electronically in logbooks. Logbooks should include fields to record the bycatch of all sensitive species. The information recorded in elogbooks should include not only the number of individuals and species that were bycaught, but also other relevant information such as how the individuals were captured (e.g. during setting/hauling, gear type) and any particular features that might prompt the catch (e.g. type of bait, season, time, depth). • Data collection via elogbooks should be supplemented by data collected by independent and adequately trained observers onboard vessels. The use of trained observers, deployed in a representative manner, is recognised as the most reliable way to ensure a robust estimate of the actual bycatch and potential mortality of vulnerable species caused by fishing operations. Where operational, safety, or other concerns, prevent or impose limits on vessels accepting observers onboard, Remote Electronic Monitoring (REM) systems, including cameras, should be used to collect independent data on bycatch of sensitive species. Tracking of all fishing vessels, including small-scale vessels, should be implemented in order to understand the impact of fisheries on the marine environment. • Data on bycatch should be collected following a standardised data collection methodology adopted at the regional level, to ensure data are harmonised and comparable enabling the issue of bycatch to be characterised at the regional level. An example of a regional methodology for data collection is the one adopted by the GFCM: http://www.fao.org/gfcm/data/vulnerablespecies • Data collection by observers should cover all fleet segments and métiers where there is a risk of bycatch, or where there is insufficient data to assess the risk. • Fishing effort per métier should be recorded in meaningful units (e.g. net length combined with soaking time in the case of static nets, number of hooks for longlines) to enable comparable bycatch rates to be estimated. • Data collection by observers should cover a sufficiently high percentage of fishing effort to ensure that the data is accurate, representative and enables robust estimates of bycatch rates. The level of coverage should be determined by the objectives of the monitoring programmes and informed by previous knowledge of bycatch in the targeted fishery. The required level of coverage needs to be adapted to the characteristics of the fishery. Some literature review suggests that coverage levels of at least 20% for common species, and 50% for rare species, would give reasonably good estimates of total bycatch (Babcock et al., 2003). Bycatch should be reported at species level with the number of bycaught individuals recorded. Fishers and onboard observers should receive adequate training, including on the identification of sensitive species. • Synergies should be ensured with data collection to assess the achievement of Good Environmental Status under the MSFD. • Data collection should be conducted in the context of any Sustainable Fisheries Partnership Agreements (SFPAs) concluded by the EU. • Collected data must be freely available and easily accessible for public use. Data collection process must be transparent.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

BirdLife welcomes the proposal for the revised TEN-E Regulation. The European Commissions` decision to take out the energy infrastructure categories for natural gas projects and oil transport projects is a necessary step forward. A study by Artelys (2020) found that existing gas infrastructure is able to meet future gas demand scenarios. The proposal needs to pave the way towards fulfilling the EU`s commitment to its climate long term target and the 2030 biodiversity strategy. Europe remains insufficiently connected and deploys too little renewable energy, which is caused by severe delays due to missing nature-sensitive building of electricity infrastructure. The revised TEN-E Regulation needs to strengthen the role of nature protection. There is a high risk that fast track permit granting procedures undermine EU-Nature Directives, SEA and EIA Directives. Sustainability as priority criteria across most infrastructure categories is not sufficient. Sustainability needs to include nature conservation, climate protection and social criteria. A clear definition in Article 2 should widen the scope of the sustainability criteria. Explicit sustainability criteria for electricity infrastructure projects should be added, including biodiversity protection and excluding fossil-fuel based electricity generation. Hydrogen networks and smart gas grids must also be sustainable, fully based on renewable energy and should contribute to a reduction in greenhouse gases. Projects supporting the transportation of unsustainable biogases should not be included as they lead to indirect land-use change and increased GHG-emissions. In the electricity section, offshore hybrid projects were explicitly added as a further subcategory and a top-down approach is introduced with integrated offshore development plans. The development of offshore hybrid projects, offshore grids and offshore wind parks need to account for the ecological carrying capacity and for pressures from competing uses of the sea. BirdLife proposes to using environmental data and sensitivity analysis to focus on low impact areas based on the sensitivity of protected species and habitats. The planning of offshore grids and hybrid projects should be combined with an effort to restore the ecological health of marine areas by setting aside areas for marine ecosystem restoration. BirdLife is concerned about a missing coherence within the submission of marine spatial plans (due end of March 2021) and the submission of integrated offshore development plans (July 2023), as these need to be developed hand in hand. BirdLife welcomes Article 5 of the proposed TEN-E Regulation and the reference to the do-no significant harm principle, if this is in line with the TEG-Report and science-based criteria. With indirect reference to Article 17 of the taxonomy regulation, there is a need to specify that overhead and underground power lines must avoid routings with heavy impact on marine and terrestrial ecosystems, UNESCO World Heritage Sites and Key Biodiversity Areas, as recommended by TEG. Infrastructure projects that do not exclude protected areas for its nature value in Europe should then consequently not be eligible for receiving PCI-status. The proposed governance still insufficiently takes into account the commitments to the Paris Agreement and biodiversity goals. BirdLife recommends science-based assumptions for the TYNDP scenario building process and a Strategic Environmental Assessment for the TYNDP before granting PCI-status to projects. Furthermore, cost-benefit methodologies for all PCIs and for the energy system wide cost-benefit analysis should include information on potential environmental impacts, including whether all or part of a project is likely to fall within a site protected for its nature value in Europe.
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Meeting with Virginijus Sinkevičius (Commissioner) and

12 Feb 2021 · To discuss different blue/marine related issues, in particular bycatch emergency measures, EU-UK negotiations and implementation of the Biodiversity Strategy.

Meeting with Virginijus Sinkevičius (Commissioner) and

12 Jan 2021 · To discuss the implementation of the Biodiversity strategy, the actions under the zero-pollution ambition as well as green funding under the new MFF and the recovery funds.

Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

BirdLife Europe welcomes the draft delegated act (DA) of the taxonomy regulation, as an important step towards a climate neutral EU. To develop technical screening criteria, the EU Commission (EC) convened a Technical Expert Group (TEG) in 2018, to recommend criteria for climate mitigation and adaptation. We recognize that the DA has taken into account TEG criteria to a large extent, but would stress the need to strengthen areas in which the scientific advice of the TEG was not followed, and recommends to go, in certain cases, beyond. We see the exclusion of fossil fuels for electricity generation as a necessary step and congratulate the EC for maintaining the 100 gCO2/KWh threshold. We recommend to reinclude that the threshold should be tightened at least every 5 years, as proposed by the TEG and to exclude hydrogen from non-renewable sources. Further, the threshold should fully apply to the distribution and transmission of electricity, or at least follow TEG-recommendations. However, we stress that biomass criteria are too weak and TEG recommendations should be followed. Forest biomass, which includes wood sourced directly from forests, can be burned as feedstock, and by referring to the Renewable Energy Directive, the use of dedicated cropland is counted as sustainable. Burning wood biomass for energy production emits more greenhouse gases than coal and increases pressure on forests leading to further biodiversity loss. For this reason, we recommend classifying forest biomass as non-sustainable and excluding any bioenergy that increases greenhouse gases compared to fossil fuels and causes irreversible ecosystem damage. Hydropower is classified as a sustainable economic activity if natural habitats and species are protected. New hydropower plants should be excluded due to their intrinsically high levels of ecological damage. At the very least the TEG recommendation to avoid small hydropower plants below 10 MW should be followed, as these do not provide any significant added value for energy generation. Wind farms can be beneficial in tackling climate change and can be deployed at large scale with minimal negative impacts if strategically sited. Yet, poorly-sited or inappropriately operated wind farms can negatively impact biodiversity. A lack of upstream planning at landscape scale represents a major potential barrier to the rapid investment and effective roll-out of clean energy infrastructure. Requirements should be identified for cumulative impact assessments that identifies and addresses any significant regional or landscape-scale environmental impacts. We welcome the criteria referring to the EU 2030 Biodiversity Strategy. We recommend not including livestock activities in the taxonomy for now, as TEG recommendations are completely insufficient to ensure effective GHG reduction, deal with supply chain impacts and account for biodiversity impacts. Give the extremely high impact of the livestock sector, and scientific consensus on the need to shrink its size, more thorough work must be done before making any sustainability claims. The industry as a whole is highly carbon-intensive, polluting, and strongly linked to deforestation. In addition, there are major animal welfare and human health concerns. Including livestock risks slowing down the transition to a more sustainable, plant-based diet, as per Paris-compliant climate scenarios. Organic livestock could be an exception and could therefore be included. If this is judged impossible, the DA should at least refocus on reduction of herd sizes rather than the technical solutions (such as livestock feed adjustments) which it currently favours. BirdLife welcomes specific reference under DNSH criteria ‘(6) Protection and restoration of biodiversity and ecosystems’ to Key Biodiversity Areas, being the most important places in the world for species and their habitats. We also commend the inclusion of robust screening criteria for forestry and crop growing which must be kept.
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Meeting with Carmen Preising (Cabinet of Commissioner Virginijus Sinkevičius) and ClientEarth AISBL and Seas At Risk

14 Dec 2020 · Fisheries related matters

Response to Green Recovery for the Blue Economy (tentative)

7 Dec 2020

Environmental sustainability is a key pillar in the Green Recovery. To make its blue economy more sustainable, the EU must: - Eliminate harmful fisheries subsidies in the EU and negotiate a deal at WTO level to eliminate them too. This is the only way to achieve SDG 14.6; - Ensure proper management of its MPAs. Currently, EU MPAs are largely paper parks. - Ensure the application of ecosystem-based approaches to marine spatial planning, which include undertaking sensitivity analyses of species & habitats to human activities (e.g. offshore wind, fishing, shipping, etc.). The Commission should reject any plans that do not undertake such analyses for species protected in legislation; - Establish systematic data collection on and monitoring of marine ecosystems. This is key to understanding fisheries’ (but also other activities’) impacts on marine ecosystems; - Improve reporting on the bycatch of sensitive species by EU fishing vessels, as well as by foreign vessels fishing in EU waters; - Test new technologies to identify new ways to mitigate the impacts of different fisheries/gears on sensitive species. Effective methods identified should then be made compulsory; - Ensure appropriate enforcement of technical rules that aim to mitigate the impacts of human activities on the environment, such as bycatch mitigation rules. To help achieve this, the EU must ensure that all fishing vessels are tracked at sea; - Transition to low-impact fisheries and only issue fishing quotas for low-impact fishing activities; - Aim for MEY over MSY and leave one third of forage fish for predators, such as birds, to ensure the stability of their populations; - Eliminate IUU; - Encourage the reduction of seafood consumption; - Ensure that any expansion of aquaculture is properly regulated and that it takes into account analyses of environmental (species’ and habitats’) sensitivities to human activities. Any expansion will need to account for nature protection (aligning development w/ nature legislations); systematic data collection (monitoring); identification of species'/habitats' sensitivities; & finding solutions for conflict areas (i.e. alternative sites, mitigation options). - Encourage ocean research, in particular systematic monitoring of marine species and habitats as well as their interactions with human activities. This research is fundamental for marine spatial planning (e.g. the allocation of human activities at sea); - Stop marine pollution at its source, including chemical pollution from agriculture; and - Commit to a moratorium on deep sea - Improve transparency and public participation prior to negotiations on SFPAs. Sectoral aid should be spent to help local needs, managing fisheries more sustainably & environmental conservation. SFPAs should include provisions for monitoring vessels; - Help set up an international court to deal with infractions in the high seas; - Raise citizen concern on the alarming state of our natural environment to increase the demand for transparent, traceable and environmentally accountable supply chains; - Ensure that environmental due diligence is applied in seafood supply chains. Businesses importing/exporting seafood into/out of the EU should be held accountable for any environmental damage they cause. - To ensure transparency & accountability, data on marine resource exploitation & on supply chain due diligence, including rule compliance records, must be made publicly available. This includes data on fishing vessels’ positions and sensitive species. Transparency will increase sector rule compliance & allow consumers to drive more sustainable seafood markets.
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Response to Protecting biodiversity: nature restoration targets

1 Dec 2020

BirdLife welcomes the initiative for binding restoration targets and recommends the following: A. Aspects guiding the next steps 1. With this restoration initiative, the Commission should focus on binding nature restoration targets. 2. The also mentioned possibility of an EU wide methodology to map and assess ecosystems and their delivery on soil, pollination etc. should be addressed with specific initiatives such as the soil strategy or the follow-up to the Biodiversity Strategy (10% biodiverse landscape features, 50% pesticides reduction). 3. Given the time needed for the legislative process with the Co-legislators and implementation in the Member States, the Commission should speed-up the process, to not only propose the law in Q4 2021 but earlier. 4. The Commission should assess putting forward the new legislation as Regulation, given that this saves transposition time. A Regulation often also leads to short, clear and thus enforceable legislation. B. Suggestions for the future restoration legislation I. Objectives 1. As the main objective, the law must contribute to halting and reversing biodiversity loss, resulting in the large-scale (nature) restoration of habitats, species and ecosystem functioning, connectivity and resilience at landscape level across the EU. 2. In order to be of added value, the new legislation must explicitly go beyond what is already required by the Habitats Directive and other EU legislation. Therefore, the new legislation cannot merely add a deadline to already existing requirements in protected areas. 3. The new legislation should put a specific focus on biodiverse ecosystems with significant carbon storage and sequestration potential. Contributing to climate change mitigation and adaptation should hence be the supportive (but not primary) objective. II. Restoration targets The binding EU targets for nature restoration on land and sea should be expressed in quantitative and similar terms for each Member State (i.e. without effort sharing). EU-wide, the targets should be to restore by 2030: 1. at least 650.000 km2 of land and at least 1.000.000 km2 of sea (15% of the EU land and sea area, sea area to be adapted to EU27 EEZ). 2. at least 25.000 km of free flowing rivers, and to scale-up this ambition to achieve 15% of rivers restored to a free-flowing state in 2030 through inter alia barrier removal and floodplain restoration; 3. and should include a target for CO2 removal by sinks, in addition to the 2030 emissions reduction target. III. Restoration criteria 1. Restoration measures should result in permanent change aiming to restore high quality and resilient nature, with a very significant improvement from the starting condition. 2. Restoration measures must result in significant management change that puts nature on a path towards sustaining ‘high quality’. 3. Action on restoration should not discriminate between restoration activities inside or outside already protected areas. 4. Restoration measures should also increase connectivity between habitats. IV. Governance aspects 1. The new legislation should require Member States to draft national restoration plans. The plans should include clear quantitative targets in terms of locations, areas, types of ecosystems to be restored, financial tools to be used, requirements for active public participation, deadlines etc. 2. Restoration plans should be assessed by the Commission to ensure that the proposed measures contribute to the objectives of the restoration law. 3. The restoration law should explicitly include obligations for Member States to actively engage the public at the start of and throughout the restoration plan process. 4. To be effective, the restoration law must contain clear deadlines regarding the establishment of the restoration plans and the implementation of all restoration measures. 5. The restoration law further needs to include safeguards to ensure the restoration and protection of the restored habitats is permanent.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

We welcome the strengthening of the LULUCF regulation with the aim to protect and restore the forests needed to sequester carbon dioxide in the effort to keep climate change below 1.5 degrees. However, this must not lead to a decrease of efforts to reduce emissions in other sectors with the hope of off-setting them through LULUCF removals. The review of the LULUCF regulation must not increase the flexibility between the land sector and other sectors including those under the Emissions Trading System (ETS), the Effort Sharing Regulation (ESR) and non-CO2 emission from the agricultural sector. Increasing this flexibility would lead to lower ambitions to reduce emission in other sectors. It would also go against discussions to reduce offsets allowed under the ETS. Removals in the land sector are not as measurable, stable or permanent as emissions reductions and cannot be considered equivalent. The EU should instead set a separate and demanding target for removals in the land use sector, consistent with the ecosystem restoration approach set out in the Biodiversity Strategy, and keep non-CO2 emissions from agriculture within the scope of the ESR. In addition the EU urgently needs to close the loopholes in LULUCF accounting system as highlighted by NGOs [1]. In particular the EU needs to close the accounting loophole for bioenergy, which is counted as zero-carbon in the energy sector, with the idea to account for the emission in the land sector. However, these emissions often go unaccounted (see attached briefing paper), in particular where bioenergy is imported from outside the EU. In this context it is particularly concerning that the LULUCF Inception Impact Assessment emphasises the role of bioenergy in Europe’s Climate ambition, when it’s net-impact could be an increase - not a reduction - of CO2 in the atmosphere over climate relevant timescales. There is an urgent need for the revision of the LULUCF regulation to ensure that EU policy makes better links between what is needed to safeguard, manage, increase and account for natural carbon stocks and what is needed to account for and influence the flows to and from those stocks – within and outside the EU. In addition, LULUCF regulations need to ensure coherence with the EU’s biodiversity goals. There are inadequate safeguards within forestry procedures. Afforestation and reforestation may well have negative impacts on biodiversity if their planning does not include ecological expertise. This is a real threat in open areas where forest is not the naturally occurring succession stage. Examples include planted forests in the Scottish highlands or in the Dutch coastal sand dunes, which are a threat to the biodiversity of such, naturally open, habitats. In Ireland, planting on peat soils continues to impact on biodiversity and climate. In addition, forest ageing is mentioned as a problem, leading to less carbon storage in the future. However, this is only true for plantations where most trees have similar ages. Natural forests, with a mixed composition of species and ages of trees, continue to sequester carbon even when very old. Also, biodiversity of such forests increases with age. The amendment must therefore not be (mis)used to replace aged natural forests with young plantations. When biodiversity takes a more central position in the planning – rather than just seen as a co-benefit - such adverse effects will be prevented. [1] Joint NGO submission on Greenhouse gas emissions from land use/forestry – CO2 offsets, https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12247-Commission-Delegated-Regulation-amending-Annex-IV-to-the-LULUCF-Regulation/F552669
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

24 Nov 2020 · Discussion on CAP

Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development) and European Environmental Bureau and Greenpeace European Unit

20 Nov 2020 · Green architecture CAP

Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

16 Nov 2020 · Eliminating harmful subsidies and investing in making the seas sustainable

Response to Action plan for the development of EU organic production

21 Oct 2020

Organic farming has been shown to be beneficial for biodiversity with one study showing species richness on organic farms 30% higher than conventional farming systems [1]. However, results vary between studies and are dependent on the landscape context. In more heterogenous landscapes the differential between the two systems in reduced. The benefits of organic farming systems for biodiversity stem from a number of factors including reduced management intensity (e.g. reduced fertiliser and pesticide use) and increased habitat diversity on farm (resulting from rotational management, diverse cropping). Hence biodiversity benefits often rely on the attributes of the whole system creating heterogeneity[2]. Where management techniques /approaches are applied which reduce the heterogeneity but are compatible with the certification requirements, then the benefits for nature can be reduced. For example, if the system is simple or the management intensive, then biodiversity may not be able to thrive under that management. The role of semi-natural vegetation is also important. The Ten Years For Agroecology report [3] states that ‘all forms of semi-natural vegetation (SNV)—permanent grasslands, hedges, ponds, stone walls, sunken paths—play a crucial role in three respects, for both immobile and mobile species: (i) as sources of food; (ii) as stable habitats for reproduction; and (iii) as a form of territorial connectivity (Benton et al., 2003; Le Roux et al., 2008)’. They further conclude that in order to restore biodiversity an increase in semi-natural vegetation is required, they suggest that this should include agro-ecological infrastructures (AEIs) across at least 10% of the area under cultivated land, which is in line with the Biodiversity Strategy target. Although organic principles require growers to ’foster biodiversity and protect sensitive habitats and landscape features’, biodiversity management is often not sufficiently codified into organic certification and so its delivery is not guaranteed. This could be at least partly addressed by incorporating the 10% of natural vegetation/ wildlife habitat as a minimum into organic certification requirements. It should be clear that this is a minimum requirement and that greater benefits may accrue from a larger area being devoted to this management. The appropriate amount in any given area would depend on the productivity of the area, population trends in that area and the requirements of any priority species which occur there. There would then need to be investment in advice and knowledge transfer to ensure that the optimal management was deployed to bring the maximum benefit to species in any given areas. In addition to areas of semi natural habitat this 10% might also be managed through agri-environment interventions which can be an effective way of delivering the requirements of nature which may be affected by a change in practice. [1] Tuck et al https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4299503/ [2] Benton et al https://www.sciencedirect.com/science/article/abs/pii/S0169534703000119 [3] https://www.soilassociation.org/media/18074/iddri-study-tyfa.pdf
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Meeting with Pascal Canfin (Member of the European Parliament) and European Environmental Bureau and Greenpeace European Unit

15 Oct 2020 · CAP

Meeting with Janusz Wojciechowski (Commissioner) and

13 Oct 2020 · CAP reform and Farm to Fork Strategy.

Meeting with Kyriacos Charalambous (Cabinet of Commissioner Johannes Hahn) and Naturschutzbund Deutschland e.V.

9 Oct 2020 · Green deal, new MFF and Biodiversity

Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and WWF European Policy Programme and

16 Sept 2020 · Workings of the Advisory Councils

Response to Long term vision for rural areas

7 Sept 2020

Saving and restoring species and habitats in Europe must be a fundamental tenet of any long-term vision for rural areas. Across Europe, Farmland birds, insects and mammals declining dramatically, with unsustainable agriculture as the major cause. Other drivers include unsustainable land uses such as bioenergy from forests and biofuels. By far the biggest future challenges facing many rural areas, are climate related. Storms, floods, droughts and fires will make many areas unliveable and farmers will be among the most hurt. Nature-based solutions and climate adaptation are therefore social and economic imperatives. These must be supported in place of practices which increase floods like monocultures, irrigation systems that deplete water and forestry plantations that increase risks of forest fires. Restoring nature and establishing farming systems and rural communities that work with nature, and within nature’s limits—alongside being essential for our long-term survival—has numerous associated benefits, including public health, and creates many opportunities for jobs. In fact, the future of rural areas increasingly depends on their quality of life and hence on environmental quality. Farming accounts for very few jobs and, increasingly, the viability of farming will depend on whether rural areas can attract and retain young people. Addressing pollution and environmental degradation is a prerequisite for healthy and attractive rural areas. We strongly support the European Deal, the Farm to Fork and the Biodiversity Strategies, which set out the needed direction, especially, the restoration of nature and the transition to agro-ecology in Europe. We therefore believe that in order to safeguard biodiversity and deliver this transition, the Long Term Vision for Rural Areas should prioritise the following: • Large-scale nature restoration as envisaged in the Biodiversity Strategy to 2030. • Move to nature-friendly agricultural systems, building on the EU Biodiversity and Farm to Fork Strategies; covering space for nature on farms, reduction of pesticides and fertilisers, boosting organic production, reducing meat and dairy production and consumption, and supporting high nature value farming systems. • Implementation and enforcement of Europe’s nature laws in rural areas and Natura 2000 sites, as set out in the EU Green Deal. • Transform Europe’s agricultural policies; the current CAP should be transformed into a new European Food and Land-Use Policy designed to meet the European Green Deal objectives as well as the global Sustainable Development Goals (SDGs). There is a huge social and economic dynamism around sustainable farming and land use. However, the CAP and a range of other policies are an obstacle to rural renewal. Most current policies are about slowing down the decline and not about reinventing rural areas in a way fit for the 21st century. Most notably, direct payments lock in failed practices while making land expensive for new entrants. A transformed EU agriculture and food policy should reward farmers and landowners for delivering public goods, and include a set of investments to build up sustainable value chains, reduce food waste and increase the demand for healthy and environmentally sound food at fair prices. • Address other drivers of unsustainable land use and biodiversity loss, including unsustainable bioenergy production and monoculture forest plantations. Rather, the EU should prioritise restoring native forests and natural carbon sinks like peatlands, which are more beneficial than commercial forestry or biofuel production for both the climate and biodiversity. Any policymaking in these areas, and new EU policy areas like the bioeconomy, must be driven by scientific evidence rather than industry claims. • Environmental authorities, scientists and environmental NGOs need be fully involved in policymaking and implementation, to ensure that the environmental elements are based on the best expertise available.
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Response to Offshore renewable energy strategy

13 Aug 2020

BirdLife Europe and Central Asia welcomes the chance to give feedback to the process of the European Commission’s Initiative for an Offshore Renewable Energy Strategy. With this written input BirdLife would like to ensure that any future strategic framework for offshore renewable energy in the EU also ensures the protection of marine biodiversity, therefore contributing to halting biodiversity loss, one of the most critical environmental threats, and help achieve the sustainable development goals by 2030. The EU has failed in delivering on the current EU Biodiversity Strategy to 2020 objectives. See our analysis here: https://bit.ly/35O48ZU. The European Commission set out an ambitious Biodiversity Strategy by 2030 and in order to achieve that, in the next 10 years, the EU must enforce nature laws and restore the natural environment at sea and this includes ensuring offshore renewable activities are compatible. BirdLife Europe therefore considers that the following recommendations should be reflected in the new strategy: 1) The backbone of the strategy should be a win-win solution for energy generation and nature conservation that reflects the recovery of nature set out in the EU Biodiversity Strategy for 2030 as well as environmental strong sustainability [1]. 2) The strategy should be compatible with the goals of the Paris Agreement and climate neutrality before 2050. By 2030, renewable offshore energy should help reduce greenhouse gas emissions by 65 percent by 2030 compared to 1990 (without offsets), while ensuring these targets do not come at the expense of biodiversity in the marine environment. 3) Assumptions, scenarios and modelling should provide the basis for nature-compatible offshore renewable development that is realistic, feasible, and fully considers nature-sensitive indications on how much offshore capacity can be developed in European seas while accounting for the carrying capacity and pressures from competing uses of the sea. 4) Spatial planning on Member States and EU-level, should identify areas to be preserved and suitable and nature-compatible areas for the use of offshore renewable energy, focusing on low impact areas based on the sensitivity of protected species and habitats. 5) The planning of offshore renewable energy and offshore grid development should be coordinated with an ambitious and well-resourced effort to restore the ecological health of marine areas and marine food chains, in particular by setting aside areas for marine ecosystem restoration, eliminating other causes of human induced mortality of vulnerable species (eg fishing by catch) and reducing fishing pressure to allow build-up of food resources for seabirds and other species. 6) Prioritise energy efficiency as set out in the EU Governance of the Energy Union Regulation as to ensure cost-efficient energy savings. 7) Renewable energy installations and electricity grid network infrastructure should contribute to achieving the objectives of environmental legislation, in particular the Birds Directive and the Habitats Directive. 8) Ban further development of fossil fuel energy infrastructure and harmful subsidies and reorient investment to nature-sensitive renewable energy. Policies, regulations and incentives to promote such investments and a technology transfer should be introduced. 7) Renewable energy installations and electricity grid network infrastructure should contribute to achieving the objectives of environmental legislation, in particular the Birds Directive and the Habitats Directive. Please see the attachement for a more profound feedback.
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Response to Sustainable use of pesticides – revision of the EU rules

6 Aug 2020

The widespread use of pesticides is exacting an unacceptable impact on Europe’s ecosystems and wildlife – from plants, to insects and up the food chain to birds. Ecosystems also deliver essential services to agriculture – therefore, we need to rebuild functioning ecosystems for their own sake, but also for a healthy and long-term sustainable farming system. Intensive agriculture practices, including heavy pesticide use, are the main driver of the EU’s collapsing biodiversity (EEA, 2015). The EU must take urgent action to implement the Green Deal’s complementary targets on pesticide reduction and space for nature on farms: together these can bring nature back to farms and contribute to the transition to sustainable farms including through conservation biological control and other ecosystem services. The Sustainable Use of Pesticides Directive (SUD) could be a powerful tool to reduce pesticide use and risks, if properly implemented by Member States. The recent EU Auditors (ECA) report, along with the Commission’s own progress reports on the SUD, already outlined the reasons for the failed implementation of the SUD and what policy changes are needed (key is the CAP). Given the need for urgent action, BirdLife would like to know why the Commission is proposing an evaluation of the SUD implementation and impact assessment (IA)? The reasons for the lack of implementation/ limited effectiveness of the SUD to date are already well established, and the need for action is already known. An evaluation/IA would therefore only lead to losing significant and precious time in taking the action that we have known is necessary since before 2007. The Better Regulation Guidelines from the Commission allow it not to conduct an IA in case of any “political imperative to move ahead quickly”. Indeed, there is an urgent political and ecological imperative to act based on the Green Deal target of a 50% reduction of pesticide use by 2030, and the need to operationalise this in the CAP strategic plans. For the CAP, operational guidance is needed now so that of enforcement of SUD is provided in the national CAP strategic plans being finalised by 2021 (see the ECA recommendation to enforce the SUD through conditionality, in particular IPM (integrated pest management). We therefore recommended that rather than conducting an IA which is unlikely to tell the EU much, if anything new, the EU should set to work immediately on revising the SUD, and operationalising the Farm to Fork’s risk reduction target by: a) establishing an indicator for how the risk reduction will be measured, b) establishing baselines given the current data deficiencies, also pointed out in the ECA report, and c) already making proposals for regulation and policy changes based on what the Commission already knows are the main issues (e.g. Commission and ECA report findings and recommendations). Further, regarding any eventual IA, this should not cause any delays in action, and the framing would need to be sufficiently holistic to cover costs to biodiversity (flora, insects, mammals, birds) and to ecosystem services of maintaining business as usual. It must not also assume lowering production is a problem in Europe, or necessarily reduces prices–on the contrary science points to the need to lower overall production in the EU, and especially of meat and dairy (and the associated feed) and non-food crops like biofuels [2]. Tackling over production should also have a positive impact on prices. Many examples already exist that show moving to nature-friendly farming model that is pesticide-free, or drastically reducing their use, is feasible both at EU level (e.g. IDDRI, ibid.) and local level [3] in terms of food production and economic viability, and the EU has the funds through the CAP to support farmers in the transition. [1] Planetary Boundaries framework https://tinyurl.com/y6dusrub [2] E.g. IDDRI, 2018 https://tinyurl.com/y3pbrccm [3] E.g. PAN, 2018 https://tinyurl.com/y4u4otg5
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Response to Negotiation mandate for a new Sustainable Fisheries Partnership Agreement between the EU and Guinea

9 Jul 2020

*See attached BirdLife's complete answer to the public consultation. We consider that concluding an SFPA is preferable than perpetuating private agreements in Guinean waters that often fall under the Commission’s radar. However, before concluding any agreement, the EU and the Guinean government should make a comprehensive assessment of the conditions required for EU vessels to fish sustainably in Guinean waters, looking at the state of marine ecosystems in Guinean waters and the sensitivity of species occurring there. In the light of the European Green Deal, and commitments highlighted in the EU Biodiversity Strategy, the EU must be coherent and ensure its environmental footprint is not higher outside of EU waters. - The sustainable management of fisheries resources and the protection of marine ecosystems are critical conditions to support the development of Guinea and the resilience of the populations there. - The sectoral support provided by the EU to Guinea has a key role to play in concretely ensuring sustainable fishing on the ground – it should in priority: 1) Support Scientific Research To prevent the bycatch of sensitive species, Guinea needs to undertake research to : • map the sensitivity of species such as seabirds to fishing vessels and their likelihood to be caught in fishing gears; • track sensitive species such as seabirds to establish the risks of geographical interactions between these species and fishing vessels. • Use this data to inform the management of fishing activities from EU vessels To help improve the availability of scientific data through the agreement, data must be systematically collected, through scientific observers or remote electronic systems. 2) Support the implementation of bycatch mitigation measures Should be included in the SFPA the obligation to implement bycatch mitigation measures in line with the requirements for EU vessels fishing in EU waters (Technical Measures Regulation) and the precaution principle. The sectoral support should help support the testing of bycatch mitigation measures adapted to local waters and the ecology of species occurring in Guinea waters. 3) Support Monitoring Control and Surveillance Before concluding an SFPA, a full assessment of MCS capacity in Guinea should be undertaken. On that basis, the SFPA should explicitly label the areas where sectoral support will be needed to allow for Guinea MCS authorities to be able to better control EU vessels fishing in their waters. - Participation of civil society The Commission should use SFPAs as a tool to encourage more participation of civil society and enhance democratic values. Stakeholders are crucial in bringing knowledge that can strengthen the content of the agreement and ensure it is not detrimental to their marine resources and the resilience of their marine environment as a whole.
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Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries)

9 Jul 2020 · +other NGOs: Discussion on maritime issues

Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

BirdLife Europe and Central Asia welcomes the European Commission’s attempt to revise the TEN-E Regulation. Our recommendations to the TEN-E Inception Impact Assessment are: 1) Revise the TEN-E Regulation in line with the Green New Deal, the Climate Neutrality Objective by 2050, the Climate Law and the Paris Agreement, the EU-Nature Directives, the SEA- and IEA-Directives as well as the new Biodiversity-Strategy in order to provide policy coherence. 2) Provide only financial assistance for infrastructure which can provide net-zero energy and is nature compatible. Exclude fossil fuel infrastructure and fossil gas dependent technologies as they will not be relevant for a climate neutral future and would provide a possible lock-in. Protect habitats and vulnerable species through the PCI-label in line with the Nature Directives and the Biodiversity-Strategy. PCI status should only be given to projects that exclude protected areas based on nature value. 3) Selection Criteria: 3.1.) The sustainability criteria must be widened to take into account nature conservation and climate criteria in a smart way. This should include emissions reduction, nature compatibility of infrastructure, the mitigation of impacts according to the mitigation hierarchy and the precautionary principle for the avoidance of harm to biodiversity and ecosystems. It must be assessed in how far the sustainability criteria can be made obligatory. 3.2) The legally binding principle of energy efficiency first from the Governance Regulation must be strengthened in the revised TEN-E Regulation. The principle must be applied from the scenario development to the project assessment, to ensure maximal cost-effectiveness, lowering GHG-emissions, increase security and avoid wasting energy. 4) A strict climate and strategic environmental impact assessment at an early stage before granting PCI-status to any project should be included in the selection procedure. This should take into account present, planned developments and cumulative impacts for ecosystems. It should be fully rooted in scientific knowledge and consider tools, such as wildlife sensitivity mapping. 5) Governance: The TEN-E Regulation must be revised in line with the Aarhus Convention. Ensure full transparency on information and mandatory participatory stakeholder engagement from communities and civil society at an early stage to verify that the PCIs which are being selected are the most necessary ones to meet Europe’s needs and have an added value. For the preliminary Assessment of Expected Impacts it will be crucial to assess environmental impacts further than climate impacts. Environmental impact refers to the impact on the ecosystem thus impacts to biodiversity need to be taken into account. Energy infrastructure, such as the promoted Projects of Common Interests by TEN-E are integral for the renewable energy transition but they also pose risks to biodiversity. Collision of birds being a well-known risk for high voltage lines. Several bird species are especially endangered by collisions, including ducks, swans, and geese among others. High voltage lines also lead to a fragmentation of landscapes and alter the structure in open countryside, therefore not only effecting birds, but the composition of the avifauna. Energy infrastructure furthermore leads to habitat impairment, to a reduction of vegetation (forest is cut away), and to a barrier effect for smaller animals and birds that lose their breeding and nourishment grounds. Also underground cables pose significant risks for biodiversity, especially during construction. In line with the mitigation hierarchy, precautionary avoidance of harm to biodiversity and ecosystems is essential. Therefore the assessment of the expected impacts needs to provide solutions on how to minimize the impact of energy infrastructure on nature conservation and on climate protection. See more recommendations in the attached BirdLife Briefing.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

18 May 2020 · EU Green Deal and biodiversity

Response to Climate Law

29 Apr 2020

To ensure the Climate Law is an effective tool for climate governance, the Climate Law, in addition to enshrining a long-term climate target into law, should govern ambitious policy making to deliver on the European Green Deal and should avoid specific pitfalls related watering down the speed or ambition of climate action. 1.) If the Commission wants to fulfill its promise it should reach climate neutrality already by 2040 and increase its 2030 climate target to at least 65%. The NDC increase by 2030 target should not include offsetting, but be an emission reduction target only. 2.) Separate emission reductions from emissions removals: Targets and accounting for negative emissions should be explicitly set and managed separately from existing and future targets for emissions reduction. For emissions removals priority should be given to Nature-based solutions by restoring and protecting natural carbon sinks through legally binding targets and appropriate funding. Member States should set plans to restore priority habitats for the dual purpose of biodiversity restoration, climate change mitigation and adaption. Worldwide, nature-based solutions absorb almost half of the CO2 emissions caused by human activities every year, and are thereby key in tackling the climate crisis. 3.) Coupled with nature-based emissions removals is the need to build resilience of ecosystems to adapt to climate change by removing destructive activities that hinder ecosystem ability to adapt. Ecosystem destructive practices damage ecosystem functioning leaving ecosystems less resilient to adapt to climatic changes resulting in potential ecosystem collapse, the loss of ecosystem services and carbon sinks turning into sources. This requires money to go to restoration, protection and enforcement for current nature legislation including the Birds Directive, Habitats Directive and Marine Strategy Framework Directive. Protection through enforcement will mean that once restored, healthy and functioning, ecosystems remain carbon sinks or stores, supportive of biodiversity, that are able to make a significant contribution to climate change mitigation. 4.) Avoid putting false hope in large-scale geo-engineering, these proposed 'technical sinks' have not been proven to work at scale and reliance on such technology risks delays in reducing emissions. We have no substitute for keeping fossil fuels in the ground, and we are not decarbonizing rapidly enough. 5.) Mainstream climate policy and ambition in line with biodiversity throughout all EU policy e.g. considering the impact consumption and land use practises have on the climate, along with energy, transportation and industry. The proposed “Do no harm” policy of the European Commission should be the body to adjust all EU-policies and sectoral legislation that are not consistent with the EU`s climate objective and biodiversity goals. Including revision and strengthening of the Renewable Energy Directive and related legislation, in particular on biomass and planning for 100% nature-compatible renewable energy. The Climate Law should also bring the EU budget in line with the 1.5°C goal and make change possible by redirecting funds. 6.) Commit to periodic review of the EU’s targets, strategies and policies to tackle the climate emergency through an independent scientific body deployed to prevent backsliding and to advise EU policies based on science. The establishment of an independent Council of Experts on Climate Policy at EU-level, which annually monitors the progress of the Union and provides technical advice to the EU Institutions, will ensure that the EU keeps on track to achieve climate goals. If it becomes clear that the budget or the interim targets are not being met, the Climate Law should oblige the Commission to submit legislative proposals in the area concerned. This requires a robust five-year review and ambition-raising mechanism, and for this to be reflected in EU Long Term Strategy.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

BirdLife Europe and Central Asia (transparency register ID 1083162721-43) broadly supports the work of the TEG, which has been balanced and of high technical quality. I should however still be improved by removing and restricting a few problematic sectors and tightening up the ‘do no significant harm’ criteria for infrastructure to exclude harm to biodiversity, especially in protected areas. In particular we support the complete exclusion of fossil fuels and waste incineration which are inherently at odds with Climate Action and the Circular Economy. Indeed we believe that the 100 gCO2/KWh threshold identified by the TEG should be lowered. Similarly, nuclear power should remain excluded as it is hard to see how the production of essentially eternal toxic waste can be compatible with the “do no significant harm principle”. These sectors should not be reintroduced through loopholes such as allowing for subsectors, “midstream” operations and the like. While the TEG proposals are overall positive, they do include a few sectors that should really be removed, most notably the Livestock sector and transport biofuels (including biogas). The livestock sector is a main diver from climate change and air and water pollution and the main driver for biodiversity loss. At the current stage of development there are no criteria allowing safe separation from investment in certain sustainable forms of grazing and the vast majority of ongoing investments in livestock which are environmentally harmful. At the very least, inclusion of the sector should wait for a full set of biodiversity criteria to be developed. Supporting vehicles and infrastructures for biofuels use would de facto provide a hidden subsidy to fossil fuels blended or co-used with them. More broadly bioenergy is scientifically demonstrated NOT to be “low carbon” and is indeed often worse than the fossil fuels it replaces. There is also massive biodiversity loss associated with increased logging and land clearing for plantations. The only bioenergy that should be allowed under “green investment” should be from genuine waste and residues that are not already otherwise used, and for increase efficiency in ongoing traditional use for heating. But these exceptions require much tighter criteria than actually proposed. Forestry rules also require significantly tightening up. Logging is a main cause of loss of carbon stocks and a lead cause of biodiversity loss. In no circumstances should increase logging pressure result from a green investment. To the contrary, what is needed is investments in forest conservation and restauration and in reconversion of intensive logging operations to close to nature forestry. Hydropower is another problematic sector due to its devastating ecological impacts. Green investments in Europe should be limited to retrofitting of existing installations and globally there should be an exclusion of large scale dams. The TEG would allow vehicles with tailpipe emission intensity of 50 g CO2/km to be eligible until 2025. For full compliance with the EU’s 2050 targets, the threshold for this activity should be set at 0g of CO2/km. We believe that preserving the integrity of the green taxonomy is crucial for establishing its credibility and solidity. The precautionary approach should thus guide the EU. Where there is uncertainty or a contentious debate, the invetment should be excluded at least provisionally until more work can be done and tighter criteria be developped. Including any high impact activities that will inevitably then be exposed by scandals when things go wrong on the ground will seriously hurt the standing of the EU taxonomy before it can properly establish itself.
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development) and European Environmental Bureau and

17 Apr 2020 · Exchange of views on CAP and Green Deal

Meeting with Thierry Breton (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

15 Apr 2020 · Priorities for the Coronavirus recovery

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and WWF European Policy Programme

6 Apr 2020 · Better regulation and green deal implementation

Response to Access to Justice in Environmental matters

1 Apr 2020

Dear Commission, As an organisation working on protecting the environment we know about the importance of access to justice for ensuring compliance with EU law and to address the ecological crisis, both at Member State / EU level. We therefore very much welcome the Commission consultation on the Roadmap. We’d like to stress the following points: A. Revision of the Aarhus Regulation Amending the Aarhus Regulation to broaden its scope and effectiveness is the only way of ensuring compliance with the Aarhus Convention. The Commission should cover the following when amending the Aarhus Regulation: • Include acts and omissions of general scope, as opposed to only acts of individual scope. The category of administrative acts thereby needs to be extended to all non-legislative regulatory acts. Limiting the scope to administrative acts that do not entail implementing measures does not provide effective access to justice. • Ensure that the scope is amended to include all acts that contradict the EU’s environmental law. The amendment would fall short when only referring to acts that positively contribute to EU’s environmental law. • Clarify that any act that is “legally binding” is included in the scope of the future Aarhus Regulation, instead of sticking to the recent and unclear criteria foreseeing that an act needs to have “external and legally binding” effects. • Narrow the derogations for administrative review bodies to ensure that also state aid decisions are included in the scope, and only procedures by the European Ombudsman, infringement procedures and OLAF proceedings to be excluded. • Ensure that costs are not prohibitive for applicants, to comply with Art. 9(4) Aarhus Convention. You could therefore clarify that EU bodies might not apply for costs exceeding a reasonable amount, and that the applicant doesn’t have to pay for the intervener. • Ensure an effective review of the challenged administrative act, by also enabling the Court of Justice of the EU (CJEU) to amend the challenged decision to bring immediate relief, wherever possible. The Commission should also open a consultation on the proposal of the amendment once the draft has been finalised. B. Directive on Access to Justice In 2003, the Commission was working on a proposal for a Directive on Access to Justice, but the proposal got abandoned. The jurisprudence of the CJEU unequivocally shows that there is a legal vacuum with respect to access to justice. In the absence of legislation at EU level, there is not only a persisting lack of legal certainty and thus predictability for investors, but the CJEU will also need to repeatedly interpret the Aarhus Convention in lengthy rulings. In general there is widespread failure of the Member States to provide adequate remedies and large disparities in the extent to which civil society can challenge decisions of public authorities. We therefore call on the Commission to re-start working on an ambitious Access to Justice Directive, focusing inter alia on the following: • Ensure a legal framework to bring all Member States in line with the provisions of Art. 9(3) and 9(4) Aarhus Convention. • Thereby foresee standards ensuring effectiveness, a broad scope, timeliness and non-prohibitive costs of any remedy taken. • Work on an Access to Justice Directive should be opened to further public consultation. A final call: Access to justice activities from organisations like ours seem to more and more replace missing implementation and enforcement work done by authorities automatically. We therefore want to stress that public authorities at Member State and EU level need to remain the last line of defence. We also call on the Commission to address the serious issue of under-staffing of its compliance bodies. This is necessary to deliver effective access to justice at EU level and to avoid that the “zero tolerance” approach in the field of environmental compliance promised by Ursula von der Leyen remains empty. Yours, BirdLife Europe
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Butterfly Conservation Europe and

13 Mar 2020 · Green Deal

Response to Farm to Fork Strategy

12 Mar 2020

Birdlife Europe welcomes the decision of the European Commission to develop a Farm to Fork Strategy (hereafter, the Strategy), and the intention to achieve coherence with the rest of the Green Deal, including the Biodiversity Strategy. For the Strategy to accelerate the transition into more sustainable food systems, including through the CAP and CFP as set out in the Roadmap, environmental sustainability must be taken as the basis for all other aspects of sustainability – economic and social. Healthy ecosystems are the foundation for food production on both land and at sea, yet they are at breaking point by the current system. We must therefore transition urgently to a paradigm where planetary boundaries are the starting point for all economic activities. Scientific evidence shows that the CAP and CFP are not fit to deliver on this in their current form, in particular because they still finance harmful activities. We welcome the recognition of current EU agriculture as a key driver of biodiversity loss, an important source of GHG emissions and pollution of water, and the aim to achieve a food system with zero or positive environmental impact. We are also positive that the Strategy intends to tackle fertilisers and pesticide use, which would need quantified reduction targets to be successful. However, the roadmap omits the main measure that would make the difference for biodiversity on land - a target for at least 10% of green infrastructure at farm level. Science shows that this target would begin the recovery of farmland biodiversity, without which Europe is facing the collapse in a matter of years of the pollinators and other ecosystem services on which food production depends. Unfortunately, there is no clear action in the roadmap for addressing the key drivers of biodiversity loss at sea, in particular fishing and aquaculture. Fishing activities in the EU are extremely destructive, with 87% of the Mediterranean and 40% of the North East Atlantic to be overfished, as well as bycatching dolphins, whales, seabirds and sea turtles. The EU should aim to eliminate bycatch of sensitive species i.e. have zero bycatch. Furthermore, aquaculture production drives further destruction at sea through the depletion of fish for aquaculture feed, bad spatial placement of farms at sea and allowing for open cage farming which weakens the genetics of fish populations. The EU should incentivise low impact activities such as EU wide environmental criteria for fish quota distribution. It should also support ocean restoration by closing at least 15% of its seas, including from fishing and aquaculture activities. Further key areas missing from the Roadmap are: • Environmental compliance assurance within the agriculture, fisheries and aquaculture sectors should be included in the Strategy – especially with the Birds and Habitats Directives, Nitrates Directive, Sustainable Use of Pesticides Directive, Water Framework Directive, Air Quality Directive, and Marine Strategy Framework Directive. • The Strategy should ensure that the over use of water, primarily driven by demand for irrigation in agriculture, should be addressed as it is a key barrier to sustainability of food systems, with major negative impacts on wildlife. • The Strategy must address food consumption not just because of its health risk, but also because we are consuming resources beyond the earth’s carrying capacity. The Strategy must include a quantified reduction of consumption and production of meat, dairy and fish, seafood, as their consumption in the EU is far above environmental, and health limits. These targets should reduce meat and dairy consumption by 50%, and fish and seafood by 40%, by 2030. It should also incentivise a 30% target for organic production and consumption. • The Strategy should not automatically assume that specific technologies, such as precision farming, are sustainable because their impact can be positive or negative, depending on their deployment.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and European Environmental Bureau and Greenpeace European Unit

6 Mar 2020 · Biodiversity and Farm to Fork Strategies

Meeting with Daniel Calleja Crespo (Director-General Environment)

25 Feb 2020 · Biodiversity

Meeting with Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and

19 Feb 2020 · Sustainable food systems

Response to Climate Law

6 Feb 2020

BirdLife Europe supports the European Commission’s initiative for a Climate Law enshrining a legally binding climate neutrality commitment for Europe, with decarbonisation plan and specific time commitments, into law. Doing so will confirm the commitment of the EU and its member states to the Paris Agreement targets. BirdLife Europe stresses the need for the Climate Law to: - Set clear concrete emission reduction targets - Include wording, and thus have legal requirements, that these targets are achieved without increasing pressure on terrestrial and marine biodiversity (including sensitivity and risk analysis per species and habitats prior to developing spatial plans – as to ensure coherence with the Birds and Habitats Directives) - Include aspiration to hasten the decarbonisation process if scientific consensus shows it is necessary. - Ensure climate action in harmony with biodiversity, through: 1) Increase the EU’s emission reduction target to at least 60 % reduction below 1990 levels by 2030 (without offsetting). A 50 - 55 per cent reduction, as proposed in the communication of the Green Deal, has been shown through modelling to not be enough to fill the large emission gap of 15 TgCO2 in order to meet Paris Agreement goals and keep global warming well below 2°C. 2) Set dates for fossil fuel phase-out and ensure removal of legal barriers in EU law to do so and end fossil fuel subsidies. 3) Mainstream climate policy. The proposed “Do no harm” policy of the European Commission should require all EU-policies to be consistent with the EU`s climate objective. This includes changes in sectoral legislation on emissions trading, land use, energy efficiency, renewable energy, agriculture, fisheries, trade, transport, finance, and consumption. The Climate Law should build the resilience of ecosystems. > Restoration and protection of natural carbon sinks by restoring 15% of Member States territories and sea areas by 2030. > Reduced consumption. Reduce production and consumption of meat and dairy by 50% by 2030. In the marine sector 30% of EU sea area is primarily managed for nature, 15% of areas as no-take zones and 40% reduction in fish consumption. > Nature-based solutions and decarbonisation in harmony with nature and nature legislation including the Birds Directive, Habitats Directive and Marine. > The Renewable Energy Directive needs to be strengthened in order to limit the amount and the kinds of biomass sources that are used for energy. > Planned investments must be redirected to promoting environmentally compatible renewable energies. > Additionally, the EU needs to develop an Offshore Wind Strategy that fully accounts the impacts on plants on marine ecosystems. > Strategy Framework Directive to cut harmful subsidies www.europarl.europa.eu/doceo/document/B-9-2019-0174_EN.html (See elaboration in the attached document). 4) Commit to periodic review of the EU’s targets, it’s strategies and policies to tackle the climate emergency. This needs to be completed by an independent scientific body to prevent backsliding and to advice EU policies based on science. The establishment of an independent Council of Experts on Climate Policy at EU-level, which annually monitors the progress of the Union and provides technical advice to the EU institutions will ensure that the EU keeps on track to achieves its goals. If it becomes clear that the budget or the interim targets are not being met, the Climate Law should oblige the Commission to submit legislative proposals in the area concerned. This requires a robust five-year review and ambition-raising mechanism that also ensures a link to the UNFCCC processes. A review mechanism in line with the Paris Agreement will make sure that the targets are on path and up to date with the EU long term strategy. The mechanism should review climate targets in combination with member states.
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Meeting with Virginijus Sinkevičius (Commissioner)

17 Jan 2020 · To discuss biodiversity

Response to EU 2030 Biodiversity Strategy

16 Jan 2020

The EU has failed in delivering on the current EU Biodiversity Strategy to 2020 objectives. See our analysis here: https://bit.ly/35O48ZU OUR VISION (See attached our position in details or here: https://bit.ly/2FOwXus): • By 2030, 30% of EU land and EU sea areas is primarily managed for nature and biodiversity; • By 2030, the EU will have reversed the negative trends for common species, as measured by appropriate indicators such as those for common birds and butterflies. Across Europe, robust monitoring will have been put in place and indicators are developed for additional key taxonomic groups. MISSION TARGETS: 1. ENFORCEMENT • Make the Biodiversity Strategy objectives legally binding; • Provide adequate capacity at the European Commission and Member States level to enforce nature laws through an adequate increase in staff and financial capacities; • Zero tolerance to illegal wildlife persecution, within and outside EU; • Put in place a Natura 2000 surveillance system by 2025. 2. MAKE EU AGRICULTURE COMPATIBLE WITH A BIODIVERSE LAND • Give at least 10% of space for nature, and make it a condition at EU level for receiving EU agriculture subsidies; • Reach 30% organic agricultural production; • Introduce obligations for MS to protect their soils; • Adopt a legislation making sure that land is efficiently used, and that brown-field sites are repurposed so they can be reused, or restored into natural habitats. 3. MAKE EU EXTRACTION OF FISH AND SEAFOOD COMPATIBLE WITH OCEANIC LIFE • Eliminate destructive fishing practices such as bycatch of endangered, threatened and protected species, non-selective fishing gear, fishing of stocks that are not scientifically assessed; • Ensure that fisheries are fully disclosed and surveilled; • Limit forage fish catch to 2/3 of fishing mortality; • Recover the historical range of top predators, including seabirds, as indicators for recovery of marine food chains; • Plan aquaculture development with respect to marine protected areas; • Forbid aquaculture fed with wild caught fish instead of vegetarian and insect-based feeds; The strategy must also cross link with actions under the Farm to Fork Strategy and ensure that consumption patterns support policies to protect biodiversity. This includes the EU enabling a crucial reduction of fish consumption, given the overexploitation of fish, as well as reduction of meat and dairy consumption given the immense environmental impact of intensive livestock production on biodiversity. 4. RESTORATION OF THE NATURAL ENVIRONMENT • Crosscutting legally binding target for Member States to restore 67 million hectares of natural habitats on land in the EU for biodiversity; • Binding legislation with a target to restore 15% of EU Member States’ sea areas, by designating them as permanent no take zones or with regulated access to restore and recover oceanic life; • Plan afforestation in the context of the restoration agenda; • Ensure that any financing for climate action delivers active restoration of habitats on land and at sea. 5. BIODIVERSITY FUNDING • Deploy €21 billion/year for management of existing Natura 2000 network, and at least €1bn EUR/year for marine-based N2000 network; • Mobilise €150 billion for restoration, as a minimum, to 2030; • Secure 50% of External Financing Instruments to address global environment needs; • Ensure no public subsidies and investments, by the European Commission and Member States, are spent on harmful activities to biodiversity; • Mandatory biodiversity reporting on all publicly listed private funding. The EU must internationally lead into reversing the status quo that is destroying nature. BirdLife Europe calls for the EU to pursue its ambition in global fora, including through leading the international community at the CBD COP 15 in Kunming towards strong and ambitious targets to restore and protect biodiversity.
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Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans) and WWF European Policy Programme and

20 Nov 2019 · Exchange of views on sustainability, climate change and maritime issues

Meeting with Daniel Calleja Crespo (Director-General Environment)

7 Oct 2019 · European Green Deal, biodiversity

Response to Environmental Crime Directive Evaluation

5 Apr 2019

BirdLife welcomes the European Commission's initiative to evaluate the Environmental Crime Directive (ECD). Its revision will allow the EU to confirm its leadership in the fight against environmental crime. Environmental crime is causing irreversible damage to our health, lives and natural heritage. It benefits from low detection probability, prosecution rates and penalties. Of particular concern to BirdLife are threats to species and habitats (eg. illegal land-use change, poisoning and shooting of birds of prey and scavengers, illegal hunting tourism, large-scale trapping of passerines). Below are highlighted the main points BirdLife would like the evaluation to address. Our full contribution can be found http://www.birdlife.eu/ECD-feedback. On: - Effectiveness: the EC should look at how have MS have transposed criteria of ‘significant effect on conservation status’, ‘non-negligible quantity of protected species’ and ‘significant deterioration of a habitat’; and what terms of imprisonment and fines they set. Beyond transposition, the evaluation should look at effectiveness in protecting the environment, and results achieved at each link of the enforcement chain (surveillance, inspection, investigation, prosecution and sentencing). It should assess the capacity of MS to fight environmental crime, prosecution and sentencing rates, and penalties imposed. The evaluation should also ask how MS integrate aggravating circumstances (ie recidivism or organised crime) and other criminal/administrative penalties (ie obligation to restore the environment; etc); and the criteria used by MS to evaluate damages caused by an environmental crime. It should evaluate effectiveness of data collection, who is in charge of collecting data, and access to it. It should also look into NGOs access to justice. The evaluation should look at powers given to authorities to conduct compliance monitoring and enforcement. - Relevance: does Article 3 on offences encompass all conducts that cause substantial damage to the environment? Since environmental crime rarely occurs in isolation, the evaluation should look at how ECD affects the whole criminal economy chain. - Efficiency: the evaluation should focus on the societal cost of crimes. Has implementation of ECD led to a more efficient tackling of environmental crime, through better cross-border cooperation, harmonised penalties and sentencing guidelines, specialised and trained courts and prosecutors, and specialised and trained police units? - Coherence with other legislation: the evaluation should look at 2008/841/JH on the fight against organised crime, 2014/42/EU on the freezing of proceeds of crime, the SOCTA, the Commission Action Plan on environmental compliance and governance, the EU Roadmap towards eliminating illegal killing, trapping and trade of birds, as well as to agricultural (CAP), marine and fisheries policies and legislation, and MEAs regulating environmental crimes. - EU-added value, the evaluation should look beyond the cross-border dimension of criminal networks, but also at the cross-border impacts of environmental crime (e.g. migratory species, water pollution, or trans-boundary ecosystems). Given the sensitivity of the issues at stake, it is of utmost importance that the EC actively seeks testimonies of local authorities and of civil society through workshops and interviews, and guarantee confidentiality. Seeing as organised crime can infiltrate every level of power, it is the only way to guarantee a truthful evaluation. We regret that the consultation is likely to take place during the summer break and hope that EC will extend the consultation period to ensure wide participation
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BirdLife Europe Urges EU to Categorize Soy as High-Risk Biofuel

6 Mar 2019
Topic — This consultation defines criteria for biofuels with high and low land-use change risks.
Message — The organization recommends a lower threshold to include soy and palm co-products as high-risk. They want low-risk criteria fixed to prevent large palm oil quantities from entering the market. This requires a strict additionality test for all projects without exceptions.12
Why — Stricter regulations would help the group protect biodiversity and meet international habitat conservation targets.3
Impact — Producers of high-emitting biofuels would lose financial support on the European market.4
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Response to Evaluation of the Protocol to the Sustainable Fisheries Partnership Agreement with Cabo Verde

15 Feb 2019

West African waters support at least 39 seabird species, half of which are migratory. 10 Marine Important Bird Areas (IBAs) have been identified in Cape Verde and many migrant European species such as the Scopoli’s shearwater, protected under the Birds Directive, are dependent on the region for wintering grounds or as a stopover. Fishing is a top threat to seabirds worldwide, where some are on the verge of extinction. Surface longliners are amongst the fishing vessels incidentally catching seabirds in EU, and are also the most present in Cape Verde in the framework of the Sustainable Fisheries Partnership Agreement (SFPA). These vessels are very likely to have the same impact on birds in Cape Verde, including European birds wintering there. As part of the CFP, the EU is obliged to tackle its fishing impact on the marine environment, including outside of the EU. It is also legally obliged to protect migratory species under the Birds and Habitats Directives. SFPAs are key for the EU to control its Distant Water Fleet, gather data and tackle its impact on the wider marine environment, and the next EU-Cape Verde SFPA protocol still needs to be strengthened with BirdLife’s following recommendations: • EU tax payers’ money used to finance the access of EU vessels to Cape Verdean EEZ should be spent transparently and explicitly support the implementation of the Sustainable Development Goals 10, 12, 14, 15 and 17; • The EU adopted in 2012 an Action Plan for reducing incidental catches of seabirds in fishing gears. It acknowledges that incidental catches of seabirds in non-EU waters leads to “concern on the long-term ecological effects on populations” and commits the European Commission to “ensure that observers routinely deployed on vessels operating in external waters accurately record seabird bycatch.” • The EU Data Collection Framework obliges since 2017 EU vessels to collect and report data on the impact of their activity on the marine environment, including incidental catches of seabirds. In the protocol, the monitoring mechanism of scientific data related to the species caught should not only target sharks but also allow the drawing up of a national action plan for the conservation and management of seabirds, sea turtles and marine mammals in the Cape Verdean EEZ. On-board scientific observers should cover 100% of EU vessels and data should be collected on incidental catches following a harmonised protocol. The use of cameras on board should be tested to monitor observers’ activities and data should be placed in an electronic database by the EU and shared with Cape Verde; • Should this observer scheme help proving the need to reduce levels of by-catch in Cape Verdean waters, the protocol should be adjusted and require EU longline vessels to apply mitigation measures that have been tested and known to reduce incidental catches of seabirds as per FAO guidelines (e.g. a combination of scaring devices, weighted hooks, night-settings or hook shields where permitted). Other technical mitigation measures (e.g. spatial measures) should also be identified and required as appropriate; • The next protocol should ensure that European fishers release by-caught individuals that are still alive, following technical procedures shared during specific training supported by the EU; • Civil society representatives should be observers to the Joint Scientific Committee to contribute to assessing the environmental impacts of the protocol and adapting the way it should be implemented according to collected data. • An effective Vessel Monitoring System is required to control the DWF through better coordination and increased financial and technical support provided by the EU. This includes providing training to Cape Verdean inspectors on checking the testing of technical mitigation measures and ensuring that all EU vessels’ positioning can be monitored. Contact: Justine Guiny, EU Fisheries Policy Officer, Justine.guiny@birdlife.org
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Response to Negotiation mandate for a Sustainable Fisheries Partnership Agreement (SFPA) Protocol between the EU and Madagascar

15 Feb 2019

West African waters support at least 39 seabird species, half of which are migratory. 10 Marine Important Bird Areas (IBAs) have been identified in Cape Verde and many migrant European species such as the Scopoli’s shearwater, protected under the Birds Directive, are dependent on the region for wintering grounds or as a stopover. Fishing is a top threat to seabirds worldwide, where some are on the verge of extinction. Surface longliners are amongst the fishing vessels incidentally catching seabirds in EU, and are also the most present in Cape Verde in the framework of the Sustainable Fisheries Partnership Agreement (SFPA). These vessels are very likely to have the same impact on birds in Cape Verde, including European birds wintering there. As part of the CFP, the EU is obliged to tackle its fishing impact on the marine environment, including outside of the EU. It is also legally obliged to protect migratory species under the Birds and Habitats Directives. SFPAs are key for the EU to control its Distant Water Fleet, gather data and tackle its impact on the wider marine environment, and the next EU-Cape Verde SFPA protocol still needs to be strengthened with BirdLife’s following recommendations: • EU tax payers’ money used to finance the access of EU vessels to Cape Verdean EEZ should be spent transparently and explicitly support the implementation of the Sustainable Development Goals 10, 12, 14, 15 and 17; • The EU adopted in 2012 an Action Plan for reducing incidental catches of seabirds in fishing gears. It acknowledges that incidental catches of seabirds in non-EU waters leads to “concern on the long-term ecological effects on populations” and commits the European Commission to “ensure that observers routinely deployed on vessels operating in external waters accurately record seabird bycatch.” • The EU Data Collection Framework obliges since 2017 EU vessels to collect and report data on the impact of their activity on the marine environment, including incidental catches of seabirds. In the protocol, the monitoring mechanism of scientific data related to the species caught should not only target sharks but also allow the drawing up of a national action plan for the conservation and management of seabirds, sea turtles and marine mammals in the Cape Verdean EEZ. On-board scientific observers should cover 100% of EU vessels and data should be collected on incidental catches following a harmonised protocol. The use of cameras on board should be tested to monitor observers’ activities and data should be placed in an electronic database by the EU and shared with Cape Verde; • Should this observer scheme help proving the need to reduce levels of by-catch in Cape Verdean waters, the protocol should be adjusted and require EU longline vessels to apply mitigation measures that have been tested and known to reduce incidental catches of seabirds as per FAO guidelines (e.g. a combination of scaring devices, weighted hooks, night-settings or hook shields where permitted). Other technical mitigation measures (e.g. spatial measures) should also be identified and required as appropriate; • The next protocol should ensure that European fishers release by-caught individuals that are still alive, following technical procedures shared during specific training supported by the EU; • Civil society representatives should be observers to the Joint Scientific Committee to contribute to assessing the environmental impacts of the protocol and adapting the way it should be implemented according to collected data. • An effective Vessel Monitoring System is required to control the DWF through better coordination and increased financial and technical support provided by the EU. This includes providing training to Cape Verdean inspectors on checking the testing of technical mitigation measures and ensuring that all EU vessels’ positioning can be monitored. Contact: Justine Guiny, EU Fisheries Policy Officer, Justine.guiny@birdlife.org
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Meeting with Miguel Arias Cañete (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

21 Jan 2019 · Implementation of the RED Directive

Response to Stepping up EU Action against Deforestation and Forest Degradation

14 Jan 2019

BirdLife welcomes this vital initiative. Urgent EU action is essential to help keep natural and intact forests standing if global biodiversity objectives, Sustainable Development Goals and the Paris Agreement are to be met. The EU has a global responsibility to play a leadership role as one of the primary markets for forest commodities. BirdLife has the following comments: 1. BirdLife would like to see more explicit links to biodiversity across the proposed actions. The expansion and intensification of agricultural activity is globally threatening 5,407 species on the IUCN Red List and unsustainable logging is contributing to the decline of more than 4,000 forest-dependent species (Maxwell et al, 2016). Together they are the leading causes of global biodiversity loss. This initiative should play a fundamental role in delivering the EU’s commitment to increase its contribution towards averting global biodiversity loss. However, biodiversity must be explicitly embedded across the actions, monitoring and evaluation to avoid perverse outcomes or missed opportunity for synergies. For example, actions to reduce pressure on forests through afforestation must not then further contribute to biodiversity loss through conversion of other important wildlife habitats. Future policies must also acknowledge the irreplaceable public goods value of intact forest ecosystems, Key Biodiversity Areas and natural forest cover which cannot be replaced through non-native plantation forestry. 2. Bridging the gap between legality and sustainability. The EU’s Forest Law Enforcement, Governance and Trade support demonstrated the essential role of multi-stakeholder participation within producer countries. This provides a basis for further financial and technical support towards other forest commodity producer countries on land use governance and tenure reform. However, it should be recognised that support for forest commodity legality does not necessarily equate to sustainability. To close any gap between legality and sustainability definitions will require dedicated support for improving the quality and monitoring of mandatory sustainability standards for producer countries and EU supply chains, in particular for biodiversity. Any new trade agreements must also incorporate the highest environmental and social safeguards. Many EU companies have taken voluntary action to reduce risks in their supply chains, which should be welcomed. However it must be recognised that voluntary measures alone are clearly insufficient to address the scale of environmental and social risk involved or achieve the level of compliance required to have a meaningful impact on reducing deforestation and forest degradation (http://ww2.rspb.org.uk/Images/usingregulation_tcm9-408677.pdf ). The positive corporate voluntary action should be used as stepping stones to accelerate progress towards mandatory measures with a common sustainability baseline. This will help create a level playing field for sustainable supply chains to flourish, enhance innovative solutions and build confidence for EU consumers on top of the EU timber regulations. 3. BirdLife supports the need to mainstream actions across EU policies and measures. This should include a risk analysis of key supply chains, financial flows, subsidies and EU policies that impact deforestation and forest degradation. For example, the EU’s bioenergy policy has substantial embodied deforestation and biodiversity impacts beyond the EU, which must be urgently addressed through policy reform to reflect the real footprint of different fuels (http://www.birdlife.org/sites/default/files/attachments/Bioenergy_post_2020_NGO%20recs.pdf) BirdLife welcomes the proposed action to work with other key consumer countries to reduce risk of displacing the EU’s overseas footprint. Other essential components of an effective strategy must address the key drivers of EU consumption and waste, including reducing demand for meat and dairy.
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Response to Evaluation of the impact of the CAP on habitats, landscapes and biodiversity

28 Nov 2018

The following areas constitute BirdLife Europe and Central Asia’s recommendations for what should be covered in the European Commission’s Evaluation of the impacts of the CAP on habitats, landscape, biodiversity: 1. Impact of CAP on drivers of biodiversity loss, covering impact on: a. direct land-use change and habitat conversion b. water use c. agricultural run-off d. pesticide use e. fertiliser use f. direct persecution of wildlife g. destruction/maintenance/restoration of landscape features h. intensification of management (spanning livestock density, increased mowing of grasslands and increased tillage) 2. Knock on impacts of CAP subsidies, including: a. Impact on aquatic habitats from run off b. Extra-EU impacts, notably impact on demand for animal feed imports 3. Impact of individual CAP tools: a. Direct payments b. Greening payments c. Coupled supports (broken down by sectors) d. Areas of Natural Constraint e. Investment aid under the EAFRD f. Agri-environment schemes g. Natura 2000 payments 4. Impact of other CAP provisions, covering: a. Eligibility conditions – the impact of definitions such as on permanent grassland, impact of land needing to be kept in production-ready condition b. Impact of the EU enlargement and thus the roll out of the CAP on biodiversity in new Member States 5. CAP and data gathering: a. Whether and to what extent the CAP is contributing to appropriate gathering and use of biodiversity-relevant data and evidence (such as on protected areas, monitoring land use changes), including LPIS, IACS and monitoring and evaluation of agri-environment schemes. 6. Evaluation process, methods and transparency: a. Ensure that Scientists and experts are properly and separately consulted on the Fitness Check. Several of scientists have been very much involved already in a separate exercise with over 800 publications listed and evaluated as potentially relevant for the CAP’s assessment (see link to the full database: https://idata.idiv.de/DDM/Data/ShowData/248 ). This has been coordinated from IDIV (German Centre for Integrative Biodiversity Research (iDiv), more information can be found here: https://www.idiv.de/web/cap_fitness_check.html b. Use of peer-reviewed science as much as possible c. Use of additional interviews with experts to identify relevant grey literature, anecdotal evidence and understanding of malpractice that might not be recorded by official data d. Identify gaps in the literature and where further evidence is needed regarding topics 1-4 e. Ensure full transparency of sources of data and full referencing of all sources of evidence and conclusions. f. Ensure that citizens can have a more accessible public consultation to allow for a wider reach to citizens. g. Ensure that environmental NGOs are properly consulted in the analysis, with ample time for consultation and feedback. And very important when comments are sent, they should give feedback on why a feedback has been taken up or not. h. DG Environment should be co-leading on this study, since they are the responsible DG on reaching the Biodiversity objectives i. The objectives of the birds and habitats directives should be strongly integrated and the effects of the CAP on the implementation of these directives should be properly analysed. j. Ensure that Article 191 of the Treaty of the Functioning of the European Union is respected.
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Meeting with Daniel Calleja Crespo (Director-General Environment)

8 Nov 2018 · Joint meeting with DG MARE on fisheries management measures in Natura 2000 sites

Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries)

8 Nov 2018 · Joint meeting with DG ENV: CFP, Natura 2000 sites

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

17 Sept 2018 · lead shots in wetland under REACH

Response to Multiannual Financial Framework - CAP Strategic Plans

25 Jul 2018

BirdLife Europe would like to take this opportunity to express its dissatisfaction with the way in which the public consultations, and other input, especially scientific evidence, have been all but disregarded with regards to the post-2020 CAP reform process. During the 2017 public consultation, over 250.000 citizens, representing around 80% of the responses, asked for a radical transformation of the CAP towards sustainability (https://www.living-land.org/). However, these responses were essentially disregarded, or at least not included in the official analysis (carried out by Ecorys), in clear violation of the EU’s own Better Regulation guidelines, which state that responses resulting from campaigns should be analysed and summarised in the main report (Better Regulation Toolbox #54, p. 419). There is no justification for ignoring an EU citizen’s response which has been individually submitted, simply because it has been stimulated by a public campaign. To do so is to deny the agency of individual EU citizens. As it happened, those answers that were analysed officially, did also show a strong preference amongst respondents, especially citizens, but also farmers, for the CAP to do more for the environment and climate. However, the way in which the results were presented, including by Commissioner Hogan, as an endorsement of direct payments, was completely misleading. All this adds to the general picture that when it comes to the CAP, it is politics rather than evidence and citizens’ wishes that prevails. This is supported for example, by the Commission’s political decision not to conduct a REFIT compliant fitness check of the CAP, despite this being demanded by the REFIT Stakeholder’s platform and many NGOs. At the same time, the Commission has subjected much of the EU’s environmental legislation to the REFIT process. Excluding the CAP from the same scrutiny, when it has been shown by countless studies, including most recently an independent ‘shadow’ Fitness Check to be failing, or falling short, on most of the Better Regulation criteria, simply exposes a bias in decision making that is ultimately harmful for the legitimacy of the EU itself. Finally, the Commission and Member States continue to untruthfully represent the CAP as a policy which is good for the environment. In fact, the overwhelming scientific evidence, and even the EEA’s own studies on the state of the environment, point to the opposite: that intensive agriculture, fuelled by the CAP, is the number one driver of species and habitat loss in the EU. Not to mention the other environmental pollution being imposed by intensive farming: over abstraction from irrigation; pollution of water from fertilisers and other agro-chemicals; degradation and contamination of soils; air pollution from ammonia and methane; and contribution to GHG emissions. BirdLife Europe has actively participated in the EU’s consultations on the CAP, expecting that its views and evidence presented would be taken seriously and analysed, along with best available scientific evidence, in the Commission’s proposals. However, it seems that the CAP reform process is overwhelmingly biased and captured by special interests, most notably, the intensive farm lobby. Because the results of the public consultation were not in line with these interests, they were either ignored, or misrepresented. The current consultation thus strikes us as a mockery. Why would any contribution would be taken more seriously this time? To restore the legitimacy of the consultation process, and thus encourage participation by representatives of the public interest, it would be necessary to follow the EU’s Better Regulation guidelines in a transparent and consistent way.
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Response to Evaluation of the EU Biodiversity Strategy to 2020

17 Jul 2018

BirdLife welcomes the chance to give feedback to the process of drafting an EU Biodiversity Strategy post-2020. With this written input BirdLife wants to contribute to halting biodiversity loss, as one of the most critical environmental threats, and help achieve the sustainable development goals by 2030. This draft roadmap is quite good in particular in what concerns consultation of citizens and stakeholders and data collection. However, there is still some room for improvement. Regarding the context presented, we are missing references to the broader sustainable development policy discussion, in particular to the SDGs. We also urge the Commission to take into account the evaluation of the Action Plan for Nature, People and the Economy and the EU Pollinators Initiative and integrate them into the post 2020 Biodiversity Strategy. Regarding the purpose and scope of the evaluation, we are missing some key questions that need to be addressed to fully understand the reasons behind the lack of progress towards the overarching target of halting biodiversity loss: - Effectiveness: Have sub targets of the current strategy been formulated in a SMART way? Has progress on them been adequately measured? Have those targets actually contributed effectively to reversing the decline of biodiversity? It is important that the evaluation looks at actual biological end results and not just at progress against the narrowly defined targets, eg. not only progress on achieving MSY but also at whether that progress has translated in wider recovery of marine species and ecosystems - Efficiency: Efficiency should not be framed just as costs vs results of the strategy. It should look at the efficiency of actions included in the strategy. Eg. the strategy approach to agriculture is entirely based on CAP agri-environmental payments. Evaluation should look at whether it wouldn’t be more efficient to address the collapse of farmland biodiversity (also) by other means such as hard regulation, rewilding or scrapping of perverse subsides. - Relevance: To what extent are voluntary objectives the correct tool to address biodiversity loss? Would legally binding targets be needed to achieve the desired strategy objectives? These are particularly relevant when considering that the current strategy’s mid-term review found that biodiversity targets can only be reached if implementation and enforcement efforts become considerably bolder and more ambitious. The evaluation should explicitly look at gaps in the current strategy (possibly missing targets/objectives). - Coherence: Coherence must be assessed in both directions: not just contribution of the biodiversity strategy to other policies, but also coherence of the other policies with biodiversity objectives. In particular: Are there any other EU policies that undermine the fight against biodiversity loss, and if so why? To what extent are policy coherence mechanisms being considered in the fight against biodiversity loss? To what extent are current funding levels appropriate to address the fight against biodiversity loss? What are the reasons for failure to appropriately fund conservation? The assessment should explicitly look into perverse subsidies and main policy choices that directly drive biodiversity decline. - EU-added value: the evaluation should explicitly look at migratory species and obligations to protect them emanating from the Convention on Migratory Species and its offshoots. It should also look systematically at the impact of conservation efforts driven by EU policy vs those driven by domestic policies (eg impact of Natura 2000 designation vs national protected areas). Regarding timing, we find it worrying that this exercise will only be finalised by the end of 2020, when most discussions for a future EU and global biodiversity strategy will already have happened. It will be very important to have the preliminary findings for stakeholder discussions as soon as possible in 2019.
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Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

4 Jun 2018

BirdLife Europe has a lot of experience with implementing the Aarhus Convention, both on the ground through complaints and court cases of its members and at EU level. We therefore would like to give the following input to the European Commission’s Inception Impact Assessment: The EU is a party to the Aarhus Convention in its own right; it therefore constitutes an integral part of the EU legal order. The EU is in non-compliance with the Convention and therefore violates international law and primary EU law. Based on one of the fundamental principles of the international legal order (article 27 of the Vienna Convention of the Law of Treaties), the EU cannot avoid performing its obligations by invoking its internal law.Therefore, the only option open to the European Commission to remedy this violation of international law is to propose an amendment of the Aarhus Regulation. In short, we believe that the amendment of the Aarhus Regulation is the only means available to the EU legislature to bring the EU into compliance with its international law obligations. Please, read the letter attached for additional information.
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Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan) and European Environmental Bureau and WWF - UK

3 May 2018 · Objectives and indicators of the future CAP

Meeting with Phil Hogan (Commissioner) and

23 Apr 2018 · New CAP and the environment

Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

Please find Stichting BirdLife Europe's feedback in the attached PDF file
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Meeting with Frans Timmermans (First Vice-President) and European Public Health Alliance and CSR Europe, The Business Network for Corporate Social Responsibility

20 Mar 2018 · handover of the position paper of the SDG multi-stakeholder Platform on MFF

Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans) and European Environmental Bureau and WWF European Policy Programme

16 Mar 2018 · Exchange of views on Future of Food and Farming

Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan) and WWF - UK

7 Mar 2018 · Environmental and climate objectives of the future CAP

Meeting with Kathiana Ghio (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and WWF European Policy Programme

28 Feb 2018 · Future of LIFE & Biodiversity in the context of MFF

Meeting with Karmenu Vella (Commissioner) and

23 Jan 2018 · common fisheries policy, multi-annual plans and fisheries control regulation

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella) and WWF European Policy Programme and

11 Jan 2018 · Fisheries Control Regulation

Response to EU Pollinators Initiative

21 Dec 2017

Birdlife Europe 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. Secondly, monitoring under the Habitats Directive by EU Member States has shown that grassland ecosystems dependent on agriculture are one of the most threatened habitats and in the poorest conservation status. The Initiative must therefore deliver provisions for the protection and appropriate management of semi-natural permanent grassland (in particular flower-rich grassland), against the conversion to arable or permanent crops and intensification of these lands for example through ploughing and reseeding, along with other practices that reduce flower diversity and hence habitats for pollinators, such as switching from haymaking to silage-making. 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 Commission Delegated Regulation on the methodology for risk assessments of invasive alien species

19 Dec 2017

Please see the attached document for the consultation response from Stichting BirdLife Europe, known as BirdLife Europe and Central Asia.
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Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans), Helena Braun (Cabinet of First Vice-President Frans Timmermans) and WWF European Policy Programme

7 Dec 2017 · CAP Communication

Meeting with Phil Hogan (Commissioner)

27 Nov 2017 · Environmental Issues

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella) and ClientEarth AISBL and

24 Nov 2017 · implementation of the Common Fisheries Policy

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

5 Sept 2017 · meeting on LIFE and Nature directives enforcement

Meeting with Daniel Calleja Crespo (Director-General Environment) and European Environmental Bureau and WWF European Policy Programme

5 Sept 2017 · Better implementation, Biodiversity and CAP

Response to REFIT evaluation of the SEA Directive on Strategic Environmental Assessment

25 Jul 2017

BirdLife Europe registers its interest in the REFIT process of the SEA Directive. We believe that the SEA Directive is a core piece of the EU environmental acquis. We have partner organisations in every EU member state. Through their work protecting the best sites for wildlife, they have experience and knowledge of how SEA has been, and is being applied throughout the union. We will therefore be contributing to the public consultations outlined in the roadmap, and encourage the Commission consultants to contact us.
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Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and European Environmental Bureau and

4 May 2017 · Green Ten contribution to the White Paper reflection on the future of Europe

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

8 Mar 2017 · Birds and habitats directive

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu) and European Environmental Bureau and WWF European Policy Programme

16 Feb 2017 · Commission's Action Plan for Nature, People and the Economy

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Transport and Environment (European Federation for Transport and Environment) and

1 Feb 2017 · A Union of Democratic Change; Energy Union; Jobs, Growth and Investment; A stronger Global Actor

Meeting with Phil Hogan (Commissioner)

24 Jan 2017 · Agri Facts

Response to Changes to greening rules and clarifications of certain other direct payments' rules

12 Jan 2017

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. It is a glaring inconsistency that pesticides can be used in EFAs, and directly counterproductive to meetings its aims. For birdlife Europe, 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. Last month, a study from the Institute or European Environmental Policy (IEEP) investigated the likely impacts on biodiversity of the EFA requirements. The research illustrated that EFAs are currently are unlikely to deliver for biodiversity, and a main recommendation to improve the policy was to exclude the use of pesticides. http://www.ieep.eu/publications/2016/12/ecological-focus-areas-what-impacts-on-biodiversity Furthermore, many leading agricultural Academics have made the same conclusion. - http://onlinelibrary.wiley.com/doi/10.1111/conl.12333/full If the estimated 12 Billion Euro expenditure on Greening payments is to remain credible in the eyes of the public, it must improve its performance through excluding pesticides. Finally, Birdlife believes that the potential economic benefits of a functioning EFA requirement have not been duly discussed. 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. In order for farmers to truly benefit from functional biodiversity, the performance of EFAs must be improved http://www.research.lancs.ac.uk/portal/en/publications/-(270245b3-6bd6-483e-ba38-fdf9ca6719f3).html
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Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and European Environmental Bureau

19 Dec 2016 · EU nature legislation

Meeting with Daniel Calleja Crespo (Director-General Environment)

15 Nov 2016 · Fitness Check of the Nature Directives

Response to Interservice consultation on a Commission proposal for the GES Decision

11 Oct 2016

We would like to bring to your attention some fundamental improvements that are still needed to ensure that the revised Decision leads to a more effective implementation of the MSFD. We recognise that the proposed draft Decision is an improvement upon Decision 2010/477/EU by providing for a clearer and simpler approach to the determination and assessment of GES. We welcome the greater importance given to regional and EU-level processes, increasing chances of a coherent implementation of the MSFD. However, we are concerned that the search for clarity and simplicity risks lowering the overall level of ambition of the Directive. We therefore urgently request you to consider the following: 1. Include a clear safeguard mechanism for the setting of threshold values: The revised Decision relies extensively on the setting of ‘threshold values’ as the intrinsic mechanism by which Member States are to determine GES. In the present text, there is neither an independent process that is established to recommend these values, nor is the European Commission empowered to review and agree to these values. Furthermore, Member States are left to put forward these values without any clear guidance on timeline. The use of the expression ‘as soon as possible’ leaves far too much room for interpretation and a cut-off date is essential to ensure that Member States do not indefinitely delay doing so. Finally, the application of the precautionary principle, as per Article 4(1), should also apply at national level and not just at regional/EU level, reflecting the potential risks to the marine environment, the need to be consistent across different criteria when they relate to the same ecosystem element, and the necessity to make use of best available science. 2. Include a control mechanism in case Member States decide not to use secondary criteria: The current text gives a large degree of discretion to Member States in the selection and use of secondary criteria. This is not compensated by an appropriate control mechanism that would guarantee that this selection is made in the circumstances foreseen by the Decision, i.e. as complement to a primary criterion or when the marine environment is at risk of not achieving or not maintaining GES. This is particularly worrying when considering that certain Descriptors are now covered only by secondary criteria. At least, Member States should be required to provide the Commission with a justification for their selection, as is foreseen in Article 3(1) for the primary criteria. 3. Ensure that the revised Decision is fully coherent with other EU policies and objectives: Inconsistencies have been identified, which are extremely worrying at this late stage in the process. Specifically, the language used for criterion D3C1 on fishing mortality needs to be brought in line with the language used in Article 2(2) of the CFP Regulation. We also strongly object to the possibility given to Member States to define a ‘maximum allowable extent’ of habitat loss under criteria D6C4 and D6C5. Allowing Member States to set an acceptable level of habitat loss is contrary to the spirit of the Directive, as well as to the ‘Not Net Loss’ objective of the EU Biodiversity Strategy and the objective of the Convention on Biological Diversity to halt biodiversity loss. Finally, we have come to understand that the ongoing public consultation is a mere ticking box exercise without any scope for the responses to be taken on board in the final text. While we appreciate the efforts made by the Commission to organise in March 2016 a stakeholder consultation involving the observers of the MSCG, this cannot be seen as a replacement for an open public consultation. We request an evaluation of how the feedback collected during the public consultation is reflected in the final Decision.
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Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Transport and Environment (European Federation for Transport and Environment) and Fern

29 Sept 2016 · Energy Union

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Fern

23 Sept 2016 · bioenergy sustainability

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans) and Royal Society for the Protection of Birds

31 May 2016 · Refit platform and CAP

Meeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and WWF European Policy Programme

23 Feb 2016 · Nature Refit, SDGs, Air Quality

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and Dogwood Alliance

10 Nov 2015 · Biomass

Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries) and WWF European Policy Programme and

10 Nov 2015 · Implementation of CFP / fighting against IUU

Meeting with Daniel Calleja Crespo (Director-General Environment)

15 Oct 2015 · Presentation of Birdlife activities

Meeting with Daniel Calleja Crespo (Director-General Environment)

5 Oct 2015 · Fitness check of Nature Directives & Biodiverisy Objectives

Meeting with Karmenu Vella (Commissioner) and WWF European Policy Programme and

22 Sept 2015 · Common Fisheries Policy

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Environment Council Preparation

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

8 Sept 2015 · Rural Development Programmes

Meeting with Miguel Arias Cañete (Commissioner) and

4 Sept 2015 · International Climate negotiations and Commission Working Programme

Meeting with Elisabeth Werner (Cabinet of Vice-President Kristalina Georgieva)

27 Aug 2015 · Meeting with Birdlife Europe

Meeting with Miguel Arias Cañete (Commissioner) and

23 Jun 2015 · ETS review, Energy Union implementation and International Climate negotiations

Meeting with Karmenu Vella (Commissioner) and WWF European Policy Programme and

23 Jun 2015 · Ocean Governance

Meeting with Karmenu Vella (Commissioner) and Federation of Associations for Hunting & Conservation of the EU

17 Mar 2015 · REFIT of Nature Legislation

Meeting with Frans Timmermans (First Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

13 Feb 2015 · Meeting with Representatives of Green 10 on CWP 2015

Meeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella) and Natural Resources Defense Council and

11 Feb 2015 · Biomass sustainability

Meeting with Karmenu Vella (Commissioner) and WWF European Policy Programme and

4 Feb 2015 · Blue and green growth, Marine Strategy Framework Directive, Marine litter, Aquaculture, Seabed mining

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Transport and Environment (European Federation for Transport and Environment) and

18 Dec 2014 · Energy Union

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete) and European Environmental Bureau

10 Dec 2014 · BIO ENERGY

Meeting with Karmenu Vella (Commissioner) and

4 Dec 2014 · Implementation of the reformed Common Fisheries Policy, Ocean Governance, Deep Sea Access

Meeting with Miguel Arias Cañete (Commissioner) and

13 Nov 2014 · Lima climate talks; climate and energy priorities