# IMMC.EESC-2021-05504-AC.ENG.xhtml.EESC-2021-05504-00-02-AC-TRA-EN.docx

| OPINION |
| --- |
| European Economic and Social Committee |
| Nature restoration targets under EU biodiversity strategy |
| _____________ |
| Proposal for a Regulation of the European Parliament and of the Council on nature restoration
  [COM(2022) 304 final — 2022/0195 (COD)] |
| |
| NAT/841 |
| |
| Rapporteur: Arnold PUECH d'ALISSAC |
| |

OPINION

European Economic and Social Committee

Nature restoration targets under EU biodiversity strategy

_____________

Proposal for a Regulation of the European Parliament and of the Council on nature restoration
  [COM(2022) 304 final — 2022/0195 (COD)]

NAT/841

Rapporteur: Arnold PUECH d'ALISSAC

EN

Referral

| Referral | Council of the European Union, 11/07/2022


  European Parliament, 14/07/2022 |
| --- | --- |
| Legal basis | Article 304 of the Treaty on the Functioning of the European Union |
| | |
| Section responsible | Agriculture, Rural Development and the Environment |
| Adopted in section | 10/01/2023 |
| Adopted at plenary | 25/01/2023 |
| Plenary session No | 575 |
| Outcome of vote
  (for/against/abstentions) | 201/4/11 |

Referral

Council of the European Union, 11/07/2022

Council of the European Union, 11/07/2022

European Parliament, 14/07/2022

European Parliament, 14/07/2022

Legal basis

Legal basis

Article 304 of the Treaty on the Functioning of the European Union

Article 304 of the Treaty on the Functioning of the European Union

Section responsible

Section responsible

Agriculture, Rural Development and the Environment

Agriculture, Rural Development and the Environment

Adopted in section

Adopted in section

10/01/2023

10/01/2023

Adopted at plenary

Adopted at plenary

25/01/2023

25/01/2023

Plenary session No

Plenary session No

575

575

Outcome of vote
  (for/against/abstentions)

Outcome of vote
  (for/against/abstentions)

201/4/11

201/4/11

1.Conclusions and recommendations

1.

Conclusions and recommendations

1.1The EESC agrees with the Commission and the European Parliament that the approach and measures taken so far in favour of biodiversity are not effective and welcomes the overall objective of the proposed Regulation to stepping up efforts in nature restoration in order to halt the loss of biodiversity and put Europe's biodiversity on the path to recovery. Member States will thus be subject to legally binding obligations. The EESC notes that the approach adopted is in line with the decisions of the COP 15 in Montreal.

1.1

The EESC agrees with the Commission and the European Parliament that the approach and measures taken so far in favour of biodiversity are not effective and welcomes the overall objective of the proposed Regulation to stepping up efforts in nature restoration in order to halt the loss of biodiversity and put Europe's biodiversity on the path to recovery. Member States will thus be subject to legally binding obligations. The EESC notes that the approach adopted is in line with the decisions of the COP 15 in Montreal.

1.2However, the EESC has a number of comments and concerns about the formulation of the objectives and the methodology defined by the Commission. The most serious shortcoming is that the economic impact of the necessary measures on – mostly private – land users is, for all intents and purposes, not taken into account. The EESC has already stated in its opinion on the EU Biodiversity Strategy for 2030 that "farmers and forest owners cannot be expected to bear the cost of protecting biodiversity. Rather, providing this "public good and value" should become a useful source of income for them. It considers that "the new economic recovery plan could include specific focus on this issue with investment in staff and resources to protect the content of the strategy"
  1
  . This recommendation has not been followed by either the Commission or the Member States. In previous opinions, the EESC has criticised, among other things, the disastrous underfunding of Natura 2000 measures. The Committee is convinced that the Commission's new chosen approach will fail if sufficient funding is not made available. This is essential in order to offset the financial losses (and also to reward biodiversity services) that land users will incur when they extend their land use in order to provide for more "biodiversity". The EESC therefore calls for the creation of a European fund dedicated to biodiversity and the exploration of new ways for the various EU policies (CAP, energy, housing, transport...) to help achieve the binding objectives of the regulation.

1.2

However, the EESC has a number of comments and concerns about the formulation of the objectives and the methodology defined by the Commission. The most serious shortcoming is that the economic impact of the necessary measures on – mostly private – land users is, for all intents and purposes, not taken into account. The EESC has already stated in its opinion on the EU Biodiversity Strategy for 2030 that "farmers and forest owners cannot be expected to bear the cost of protecting biodiversity. Rather, providing this "public good and value" should become a useful source of income for them. It considers that "the new economic recovery plan could include specific focus on this issue with investment in staff and resources to protect the content of the strategy"

1

. This recommendation has not been followed by either the Commission or the Member States. In previous opinions, the EESC has criticised, among other things, the disastrous underfunding of Natura 2000 measures. The Committee is convinced that the Commission's new chosen approach will fail if sufficient funding is not made available. This is essential in order to offset the financial losses (and also to reward biodiversity services) that land users will incur when they extend their land use in order to provide for more "biodiversity". The EESC therefore calls for the creation of a European fund dedicated to biodiversity and the exploration of new ways for the various EU policies (CAP, energy, housing, transport...) to help achieve the binding objectives of the regulation.

1.3With regard to the financial aspects, the EESC calls for a prior assessment of the exact surface area of agricultural land, forests and waterways covered by the proposals in the regulation. Additionally, the EESC draws the Commission's attention to the need to set aside funds to compensate in particular farmers and forest owners who risk losing their production areas completely.

1.3

With regard to the financial aspects, the EESC calls for a prior assessment of the exact surface area of agricultural land, forests and waterways covered by the proposals in the regulation. Additionally, the EESC draws the Commission's attention to the need to set aside funds to compensate in particular farmers and forest owners who risk losing their production areas completely.

1.4While nature restoration is necessary in protected areas due to deteriorating conditions, not all restored areas can nor must become protected areas. Even though the EESC considers it "essential" that "some parts of the protected areas should be subject to strict protection (with non-intervention management)"
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  , it is even more important to ensure uses that maintain biodiversity across the board. Most areas must aim to restore their ecosystems without excluding specific and adapted economic activities. In fact, extensive agriculture and forestry have contributed to the high level of biodiversity that today needs to be protected. These extensive forms of agriculture and forestry, which are more and more abandoned nowadays because of their low economic viability, should therefore be additionally supported
  3
  .Rehabilitation is therefore perhaps a more suitable scientific term also used in policies coined to ensure a balance between living and producing. The EESC therefore recommends dropping the term "restoration" in favour of "rehabilitation"
  4
  , especially as nature is not static and cannot be "restored" to its original state like a broken house or car. Numerous studies have shown that rewilding measures, for peatlands for example, in many cases have significant costs, without really being able to deliver actual full restoration of the "original state". We need to think about what we are aiming to achieve: the aim of the regulation should not be to restore the natural state of the environment, but to restore the ecosystem services of the environment and thus to support a sustainable, multifunctional use of these areas. With humans having modified the natural environment over the years, it is scientifically impossible to achieve a "restoration of nature". Progressive climate change can also be a factor in why the conditions of some ecosystems from the past can no longer be fully achieved. Conversely, ensuring the sustainability of environments by promoting the viability of ecosystem services is a realistic objective. The EESC would like to see an appropriate policy framework; this is where the Commission's document is disappointing.

1.4

While nature restoration is necessary in protected areas due to deteriorating conditions, not all restored areas can nor must become protected areas. Even though the EESC considers it "essential" that "some parts of the protected areas should be subject to strict protection (with non-intervention management)"

2

, it is even more important to ensure uses that maintain biodiversity across the board. Most areas must aim to restore their ecosystems without excluding specific and adapted economic activities. In fact, extensive agriculture and forestry have contributed to the high level of biodiversity that today needs to be protected. These extensive forms of agriculture and forestry, which are more and more abandoned nowadays because of their low economic viability, should therefore be additionally supported

3

.Rehabilitation is therefore perhaps a more suitable scientific term also used in policies coined to ensure a balance between living and producing. The EESC therefore recommends dropping the term "restoration" in favour of "rehabilitation"

4

, especially as nature is not static and cannot be "restored" to its original state like a broken house or car. Numerous studies have shown that rewilding measures, for peatlands for example, in many cases have significant costs, without really being able to deliver actual full restoration of the "original state". We need to think about what we are aiming to achieve: the aim of the regulation should not be to restore the natural state of the environment, but to restore the ecosystem services of the environment and thus to support a sustainable, multifunctional use of these areas. With humans having modified the natural environment over the years, it is scientifically impossible to achieve a "restoration of nature". Progressive climate change can also be a factor in why the conditions of some ecosystems from the past can no longer be fully achieved. Conversely, ensuring the sustainability of environments by promoting the viability of ecosystem services is a realistic objective. The EESC would like to see an appropriate policy framework; this is where the Commission's document is disappointing.

1.5Fixed timetables and rigid thresholds do not work perfectly well with the unpredictable ways of nature. Imposing strict deadlines on Member States is only appropriate in terms of the administrative and planning conditions to be put in place. However, a flexible approach is needed to take into account the precise needs, conditions, opportunities, production and income status, and starting point of each natural area. The proposed regulation is unclear about the prioritisation and allocation of restoration measures that should be made by the Member States and thus, imposes a risk to achieving high quality results cost-effectively. Decision-making at the level of Member States is clearly a justified principle since it also secures the fulfilment of the rights of landowners and reflects the principles of subsidiarity and proportionality.

1.5

Fixed timetables and rigid thresholds do not work perfectly well with the unpredictable ways of nature. Imposing strict deadlines on Member States is only appropriate in terms of the administrative and planning conditions to be put in place. However, a flexible approach is needed to take into account the precise needs, conditions, opportunities, production and income status, and starting point of each natural area. The proposed regulation is unclear about the prioritisation and allocation of restoration measures that should be made by the Member States and thus, imposes a risk to achieving high quality results cost-effectively. Decision-making at the level of Member States is clearly a justified principle since it also secures the fulfilment of the rights of landowners and reflects the principles of subsidiarity and proportionality.

1.6The Commission's document is disappointing as regards the overall impact assessment, which should focus especially on economic, social and food issues, and the EESC therefore calls for an additional impact assessment.

1.6

The Commission's document is disappointing as regards the overall impact assessment, which should focus especially on economic, social and food issues, and the EESC therefore calls for an additional impact assessment.

1.7The EESC recommends that adjacent areas that are initially unproductive but which are also of value for biodiversity be included in the 10% target. The EESC stresses that the text sets particularly ambitious targets for farmers, and points out that it is important to take into account all natural habitats. However, it is important to involve the whole of society in improving our ecosystems. In this respect, the EESC recalls the principle of proportionality of measures (fair distribution of burdens and costs, but also of benefits) between the various stakeholders.

1.7

The EESC recommends that adjacent areas that are initially unproductive but which are also of value for biodiversity be included in the 10% target. The EESC stresses that the text sets particularly ambitious targets for farmers, and points out that it is important to take into account all natural habitats. However, it is important to involve the whole of society in improving our ecosystems. In this respect, the EESC recalls the principle of proportionality of measures (fair distribution of burdens and costs, but also of benefits) between the various stakeholders.

1.8The EESC supports the objective, as it is relevant to a strategic ambition for the future of the EU, and recommends strengthening the targets by encouraging, in particular through extensive agricultural activities, the restoration of all aquatic environments, including the rewetting of peatlands, while securing the social and economic sustainability of agriculture and forestry.

1.9The EESC is aware that Europe needs a completely new water policy. The policy of draining water from landscapes as quickly as possible, practised for centuries, has had many negative consequences for biodiversity, but in the meantime – partly as a result of climate change – the negative impact on forestry and agriculture (dryness/fires) and on local people (floods) has also become apparent. The EESC therefore stresses that water must return to nature or be retained there, while not forgetting that human action remains beneficial in many situations, in particular through the maintenance of watercourses.

1.10The EESC recommends limiting land take that harms natural areas. It also encourages the creation of green spaces in cities and the unsealing of cities to be able to mitigate the effects of climate change by 2030.

1.11The EESC supports establishing a safeguard mechanism under the common fisheries policy for marine restoration targets. It also encourages establishing EU financial support to stimulate the search for innovative solutions and improved knowledge of ecosystems.

1.12 The EESC stresses that the economic and social perspective must be fully acknowledged in the context of nature restoration. Recognising and ensuring economic and social sustainability is a prerequisite for the acceptability of the proposed legislation and for its successful implementation since the outcomes will largely depend on the motivation, support and future involvement of landowners and other actors on the ground. It is of the utmost importance to respect the rights of landowners through open communication, active involvement and full monetary compensation of all possible economic losses. In this regard, the EESC highlights the potential of approaches based on voluntary action and economic incentives.

1.13The EESC recommends that EU support be put in place for the emergence and development of forestry activities carried out both before the trees are planted and after they are cut down, so that agroforestry is a viable economic concern.

1.14The EESC warns about the risk of negative repercussions on generational renewal in the agricultural sector, and reiterates its recommendation
  5
  that villages and rural areas be made more attractive by securing the possibilities for the continuation of economically viable livelihoods based on the sustainable use of natural resources.

2.Introduction

2.1Against a general backdrop of scientists warning how climate change will affect our societies, the European Commission has promised to do its part by developing a strategy to support biodiversity with ambitious targets to be met by all Member States by 2030 and 2050. On 22 June 2022, the Commission adopted a draft regulation on nature restoration. While nature conservation and restoration in the EU had previously fallen mainly under the Habitats and Birds Directives and the Aichi Targets, the Commission has opted for a new binding framework to ensure that restoration measures are actually implemented by the Member States.

2.2The European Environment Agency has confirmed that currently, 81% of protected habitats in the EU are in poor condition. Only 9% have seen any improvement. Additionally, 84% of peatlands – essential for capturing and storing carbon and for filtering water – have a poor conservation status. Over the last decade, 71% of freshwater fish and 60% of amphibians have suffered population decline. However, more than half the world's GDP depends on nature and the services it provides, and more than 75% of global food crops depend on animal pollination
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  .

2.3Furthermore, EU legislation is being proposed during the United Nations Decade for Ecosystem Restoration, which is led by UNEP and the United Nations' Food and Agriculture Organization. This is a major global movement aiming to accelerate restoration projects and to ensure that the world is on the path towards a sustainable future. Restoring degraded ecosystems is key to achieving the Sustainable Development Goals, particularly those related to climate change, eradicating poverty and food security.

2.4Originally built around a biodiversity strategy for 2030 with voluntary targets, the Commission's approach was quickly bolstered by proposals for texts which are binding upon the Member States. Like the international community, the Commission has been forced to react quickly to the findings on biodiversity decline and to the consequences also highlighted in recent IPCC publications. Thus, in the midst of international negotiations on the Convention on Biological Diversity, the Commission has chosen to play a leading role in order to put Europe on the path to restoring all its ecosystems by 2050.

2.5The proposal accordingly aims to impose legally binding targets on the Member States. The overall goal is to contribute to the continuous, long-term and sustained recovery of biodiverse and resilient nature across the Union's land and sea areas through the restoration of ecosystems. This will require Member States to lose no time in rolling out effective and area-based restoration measures; these measures must cover at least 20% of the Union's land and sea areas by 2030, and all ecosystems in need of restoration by 2050.

2.6These provisions reflect and are linked to the targets set out in the Habitats and Birds Directives, the Water Framework Directive, the Marine Strategy Framework Directive, the Invasive Alien Species Regulation, the CAP, the EU Pollinators Initiative and the New EU Forest Strategy for 2030.

2.7Intended to be integrated into the Member States' national policies, this text is innovative in that it addresses both climate and biodiversity challenges. Politicians were informed years ago about global warming, but scientists have only recently highlighted the direct link between climate change and the serious impact on biodiversity. The Commission has broken new ground by calling for a holistic approach to these issues which breaks down the silo-based approach to policies taken to date.

3.Analysis of the draft regulation

3.1The draft raises a number of profound questions and concerns, both in terms of the targets to be achieved within a limited time frame, and in terms of definitions and indicators. For example, some measures are based on concepts arising from the rights of nature; in order to ensure that this aspect is understandable, the draft regulation should refer to this. In addition, the extent to which the subsidiarity of the Member States is preserved should be made clearer for certain content. In particular with regard to Article 10, which contains indicators for the restoration of forest ecosystems, it should be noted that the responsibility for forestry mostly lies with the Member States
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  .

3.2Drawing up an opinion on a draft regulation aiming to restore the Member States' ecosystems without accurate information on the challenges and efforts facing those Member States is no easy task. The draft text refers to the drafting and implementation of "national restoration plans" to be established on the basis of the latest national scientific analyses.

3.3The terms chosen in the draft regulation are paramount, as they harmonise terminology and inform the Member States about the reasoning underpinning the targets to be achieved. While definitions such as "good condition", "favourable reference area" and "sufficient quality and quantity of a species' habitat" should draw on commonly agreed scientific phrasing, their actual implementation has limitations. There are policy considerations behind these scientific definitions. How does one select a "favourable reference area"? Who determines the "sufficient quality and quantity of a species' habitat"? The absence of a previous baseline makes it difficult to set targets or to draw up an informed opinion on this proposal. The EESC stresses that, when undertaking the quantification under Article 11 of the draft Regulation, it is appropriate to pay attention both to past biodiversity loss over a certain period (the Commission arbitrarily proposes the last 70 years) and to likely future changes in environmental conditions. The risk that national disparities in the implementation of the proposed measures end up resulting in a distortion of competition among EU farmers has to be avoided. Moreover, the proposal provides for continuous ecosystem improvement, the success of which is to be assessed every three years after 2030. But what about the ecosystems that may take more or less time to get back to where they should be? It is questionable whether significant improvements can be measured within these short reporting periods. Will the Member States then be held accountable when nature simply needs more time?

3.4The EESC believes that areas located within the existing protected area network, especially Natura 2000 sites, need to be prioritised for restoration to unlock the full potential of those areas. This best supports the target of achieving a good condition of the habitats listed in Annex I of the Habitats Directive. Targeting restoration measures to protected areas not only secures the long-lasting benefits of restoration measures, but also helps to avoid possible conflicting interests related to land use. Thus, the EESC is of the opinion that the very broad and strict non-deterioration requirement regarding habitats also situated outside the protected area network is unbalanced and disproportionate.

3.5The mechanism for holding Member States accountable for implementing restoration measures and reaching the targets contains very few details about monitoring delivery. This lack of precision is cause for concern as regards whether the measures are distributed fairly across the Member States, different sectors and different groups of people. While the decision to opt for a regulation has real advantages in terms of harmonising efforts between Member States and keeping a level playing field, it does not leave enough room for the Member States to make decisions on restoration based on their national needs and circumstances. Although a monitoring and reporting mechanism must accompany the targets, any additional administrative burden must be minimised. The existing national and EU mechanisms for continuous assessment and reporting on progress should be utilised as much as possible.

4.Challenges for EU agriculture and forestry

4.1Overall agricultural ecosystem restoration

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  The EESC notes that most of the restoration targets relate to private farmland. Successful implementation of the targets is therefore dependent on farmers being fully engaged. Additional regulatory constraints in management, that may be needed to increase biodiversity on agricultural land, may nevertheless be an additional burden for already heavily regulated agricultural activities. The EESC stresses that farmers and forest owners cannot be expected to bear the costs of protecting biodiversity. Rather, providing this "public good and value" should become a useful source of income for them. The success of the restoration targets will inevitably require strong and lasting support for the men and women working to feed Europe. It is here that the Commission proposal is disappointing, because it overlooks this key economic issue in the same way that the Commission's previous biodiversity strategies and action programmes did. So the regulation is likely destined to fail.

4.2Rewetting drained peatlands as provided for in Article 9 of the regulation

This target will have a significant economic impact on professional activities, and it concerns especially certain regions of some Member States. For those regions, the proposed target might be too ambitious from the viewpoint of balancing different objectives. The EESC points out that continuing the productive use of restored and rewetted peatlands in alternative ways requires economic viability. Furthermore, with regard to the time frame for achieving it, a 2012 study carried out by researchers on more than 620 sites where ecological restoration efforts were undertaken in wetlands found that even after a century, these operations only recovered an average of between 65% and 70% of native biodiversity and various hydrological and ecological functions (water filtration, carbon storage) compared to an appropriate, non-degraded reference ecosystem. This raises questions about both the Commission's time line for restoration and the ecological target. However, while peatlands account for only 3% of the Earth's surface, they capture one third of the carbon dioxide stored in the soil. They are therefore a highly strategic sector for the fight against climate change.

4.3Restoring natural river connectivity as provided for in Article 7

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  Our deteriorating climate and water management problems are creating an increasingly degraded environment. As well as being important and valuable for nature, water is crucial for sustainability and thus for security. Sometimes excess water needs to be drained, and other times action must be taken to retain it and to assist natural cycles. The EESC agrees that in order to restore the natural connection of rivers and the natural functions of the associated floodplains, barriers preventing the longitudinal and lateral connection of surface waters can be transformed, subject to strict technical supervision. However, the EESC flags up the risk of flooding that could be triggered when hydraulic infrastructure is removed. Restoring biodiversity requires water, so strategic interventions can be an opportunity to manage water and direct it to where it is needed. Care must be taken to keep water in the landscapes and prevent it from flowing away too quickly. For Europe, the summer of 2022 was a striking example of the real and present risk of drought. The EESC recommends that a dialogue be organised on this subject, with the involvement of civil society organisations. The EESC also recommends urging Member States to implement green infrastructure projects that can help to combine improving flood protection, preserving sensitive aquatic areas that are important for biodiversity at European level, and economic and tourism development. Accordingly, the EESC would point to rivers such as the Danube or the Elbe, where flooding has caused major damage.

4.4Reversing pollinator decline

The EESC fully supports this measure which is key for food security. However, the Committee notes that the draft regulation fails to provide any measures concerning available food resources for pollinators. The long-term survival of these species cannot be achieved unless there are sufficient numbers of nectar- and pollen-rich plants to feed pollinators in the long term. Nesting places and a non-toxic environment are also essential.

4.5Agricultural objectives referred to in Article 9 of the regulation

The EESC expresses concern regarding the target whereby 10% of EU utilised agricultural area must comprise highly diverse landscape features. It is particularly problematic that, according to Annex IV, these areas may not be used for productive agriculture (including grazing and fodder production). It should not be forgotten that in many areas it is the cultivation (in particular, for example, grazing on alpine pastures, hay meadows or litter meadows) that makes a great biological diversity possible in the first place. To exclude management in these areas from the outset is therefore excessive; this condition should be deleted. Furthermore, early 2022 showed us all too clearly just how important food sovereignty is for coping with the many perils ahead, and while dedicating 10% of the agricultural land in use to this purpose would improve the biodiversity which is so crucial for agricultural productivity, it would also lead to significant yield losses. The 10% target should therefore not focus solely on agricultural land: it should encompass the areas around it. For example, roadsides and rural verges are very important for biodiversity. These areas could accommodate flower strips that would benefit pollinators and crop auxiliaries. Additionally, these landscape features would only be fully effective if they were to be organised in a network. Studies have shown the value of installing several flower strips in a network, rather than one large patch of flowers. The EESC also points out that equal attention should be paid to all natural environments so that all species living in different environments can benefit. For example, hedges and borders are basically irrelevant to lapwings and skylarks. Preservation policy must therefore apply to the entire area or use of the land, beyond agricultural and forestry areas, taking into account the different needs of our societies.

4.6Forestry ecosystems as provided for in Article 10 of the regulation

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  Restoring degraded forest areas in Europe is instrumental in adapting our societies to climate change and enabling economic activities to contribute to the biodiversity targets. Internationally, the general objectives of the draft regulation are in line with a global approach on a global scale. The EESC commends the Commission's political will to encourage the Member States to restore their forest environments. However, it stresses that, due to the heterogeneous conditions in forests across Europe, restoration measures may be adapted to local conditions as long as competition among European forest owners is not distorted. The EESC also points out the importance of integrating this restoration into the landscape of the regions concerned and of taking into account the climate disasters that Europe is now experiencing (such as small and very large-scale fires). Land use in any landscape is interconnected and must therefore meet both environmental and socio-economic requirements. For example, reforesting at the expense of agricultural land can result in economic losses for local communities and may not be sustainable, whereas including native trees in an agroforestry approach could be more appropriate and generate local support. It is therefore important to steer Member States towards approaches that strike a balance between preserving natural resources and economic development. The forestry objective cannot be achieved without lasting support for the emergence and development of activities carried out both before the trees are planted and after they are cut down, so that agroforestry is a viable economic concern.

5.Challenges for the EU's urban areas

5.1Reintroducing nature in cities is a key objective that the EESC supports. Greening European cities is quite clearly important both for the well-being of Europeans and for the sustainability of European biodiversity. The scorching temperatures that Europe experienced in July 2022 are a reminder of the essential role that trees play in reducing temperatures in cities. Trees reduce the surface temperature by up to 12°C.

5.2What is more, European cities now cover large areas, hindering the movement of species and damaging their habitat. It is imperative to direct Member States towards measures limiting the take of natural areas. These measures should not be based on programmes proposing land swaps.

5.3Lastly, biodiversity restoration should be strengthened in cities by fostering green infrastructure as an integral part of habitat development. Parks, footpaths and even green roofs and walls improve the urban climate without being prohibitively expensive. The EESC therefore reiterates the recommendations set out in opinion NAT/607
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  .

6.Challenges for the EU's seas and oceans

6.1Marine restoration is essential for preserving biodiversity, given the number of marine species and ecosystems and the strategic importance of marine environments with a view to climate change. The EESC supports the proposed targets for restoring the seas and oceans, given that it has been proven that human activities have destroyed the balance of marine ecosystems. In addition to protecting species and restoring habitats, responsible fishing and pollution reduction measures should also be adopted. The EESC is in favour of establishing a safeguard mechanism under the common fisheries policy to manage the negative impacts on marine environments. In order to reach the targets for these environments, the Member States must agree to manage fisheries resources together. However, in view of just how important action on the seas and oceans is, the Commission should be able to intervene in order to ensure that the protection and restoration targets are met.

6.2The EESC would also highlight the crucial role of marine environments in the fight against climate change. Preserving marine carbon capture capacity is pivotal for our future. The EU must therefore provide financial support for innovation and research in order to encourage the search for innovative solutions and improve our understanding of these ecosystems. For example, studies have proven the importance of small coastal beds, which are essential habitats for many species of fish which grow to adulthood there before striking out for the areas where they will live later on. However, these areas are often degraded by coastal infrastructure (ports, dykes, etc.), and so new solutions must be found. Experiments are being conducted to secure artificial reefs and sea grass beds to the seabed in the Toulon and Vieux Port de La Seyne-sur-Mer harbours. This activity aims to revitalise the ecological functions of the coastal environment.

7.The financial challenges of nature restoration

7.1The EESC highlights the remarkable political will shown by the Commission with this ambitious and innovative regulation. However, it points out that political will will be hamstrung unless it has financial resources commensurate with the commitments. In this regard, the Commission's work on identifying the potential costs of ecosystem restoration offers an initial picture of the commitment that Member States will need to make, but also raises questions. This work indicates a cost/benefit ratio of 1 to 8 for biodiversity preservation, but does not shed any light on the economic, social and cultural impact of achieving the targets. What will be the economic and social impact of the restoration measures put in place on land? The EESC calls for a prior assessment of the exact surface area of agricultural land, forests and waterways that will be covered by the proposals set out in the regulation. The EESC also reiterates the comments made in opinion NAT/786 calling for financing commensurate with the issues at stake. For example, the Natura 2000 Network, which offers a unique opportunity in Europe to improve the quality of notable natural environments, provides only 20% of the funds pledged and needed. The EESC places particular emphasis on the financial commitments announced by the Commission. It reiterates the importance of matching funds to expectations, without which additional regulations will not deliver any results.

7.2The EESC warns of the dangers inherent in falling short on generational renewal in the agricultural sector. Setting targets that are irreconcilable with the reality of farm life will lead to major financial difficulties in this sector, which is already struggling to recruit professionals. The Commission must pay particular attention to the financial impact on these farms in order to ensure long-term viability, while at the same time supporting the development of climate-sensitive practices.

Brussels, 25 January 2023

Christa Schweng
  The president of the European Economic and Social Committee

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N.B.: Appendix I overleaf

APPENDIX I

to the committee opinion

The following amendments, which received at least a quarter of the votes cast, was rejected during the discussion:

Point 3.4 – Amendment 11

Amend as follows:

Section opinion

| Section opinion | Amendment |
| --- | --- |
| The EESC believes that areas located within the existing protected area network, especially Natura 2000 sites, need to be prioritised for restoration to unlock the full potential of those areas. This best supports the target of achieving a good condition of the habitats listed in Annex I of the Habitats Directive. Targeting restoration measures to protected areas not only secures the long-lasting benefits of restoration measures, but also helps to avoid possible conflicting interests related to land use. Thus, the EESC is of the opinion that the very broad and strict non-deterioration requirement regarding habitats also situated outside the protected area network is unbalanced and disproportionate. | The EESC believes that areas located within the existing protected area network, especially Natura 2000 sites, need to be prioritised for restoration to unlock the full potential of those areas. This best supports the target of achieving a good condition of the habitats listed in Annex I of the Habitats Directive. Paying particular attention to Natura 2000 sites can ensure the implementation of the Habitats Directive adopted back in 1992, and can also help to avoid possible conflicting interests related to land use. |

Amendment

The EESC believes that areas located within the existing protected area network, especially Natura 2000 sites, need to be prioritised for restoration to unlock the full potential of those areas. This best supports the target of achieving a good condition of the habitats listed in Annex I of the Habitats Directive. Targeting restoration measures to protected areas not only secures the long-lasting benefits of restoration measures, but also helps to avoid possible conflicting interests related to land use. Thus, the EESC is of the opinion that the very broad and strict non-deterioration requirement regarding habitats also situated outside the protected area network is unbalanced and disproportionate.

The EESC believes that areas located within the existing protected area network, especially Natura 2000 sites, need to be prioritised for restoration to unlock the full potential of those areas. This best supports the target of achieving a good condition of the habitats listed in Annex I of the Habitats Directive. Paying particular attention to Natura 2000 sites can ensure the implementation of the Habitats Directive adopted back in 1992, and can also help to avoid possible conflicting interests related to land use.

Result of the vote

For
     91

Against
     108

Abstentions
     
     18

Point 4.2 – Amendment 12

Amend as follows:

Section opinion

| Section opinion | Amendment |
| --- | --- |
| Rewetting drained peatlands as provided for in Article 9 of the regulation


  This target will have a significant economic impact on professional activities, and it concerns especially certain regions of some Member States. For those regions, the proposed target might be too ambitious from the viewpoint of balancing different objectives. The EESC points out that continuing the productive use of restored and rewetted peatlands in alternative ways requires economic viability. Furthermore, with regard to the time frame for achieving it, a 2012 study carried out by researchers on more than 620 sites where ecological restoration efforts were undertaken in wetlands found that even after a century, these operations only recovered an average of between 65% and 70% of native biodiversity and various hydrological and ecological functions (water filtration, carbon storage) compared to an appropriate, non-degraded reference ecosystem. This raises questions about both the Commission's time line for restoration and the ecological target. However, while peatlands account for only 3% of the Earth's surface, they capture one third of the carbon dioxide stored in the soil. They are therefore a highly strategic sector for the fight against climate change. | Rewetting drained peatlands as provided for in Article 9 of the regulation


  This target will have a significant economic impact on professional activities, and it concerns especially certain regions of some Member States. For those regions, the proposed target might have a particular impact from the viewpoint of balancing different objectives. The EESC recognises the particular importance of peatlands for biodiversity and the climate, and regards the Commission's objectives (restoration measures on 70% of drained peatlands by 2050, of which half shall be rewetted[3]) as a compromise between economic and environmental interests. Furthermore, with regard to the time frame for achieving it, a 2012 study carried out by researchers on more than 620 sites where ecological restoration efforts were undertaken in wetlands found that even after a century, these operations only recovered an average of between 65% and 70% of native biodiversity and various hydrological and ecological functions (water filtration, carbon storage) compared to an appropriate, non-degraded reference ecosystem. This raises questions about both the Commission's time line for restoration and the ecological target. However, while peatlands account for only 3% of the Earth's surface, they capture one third of the carbon dioxide stored in the soil. They are therefore a highly strategic sector for the fight against climate change. |

Amendment

Rewetting drained peatlands as provided for in Article 9 of the regulation

This target will have a significant economic impact on professional activities, and it concerns especially certain regions of some Member States. For those regions, the proposed target might be too ambitious from the viewpoint of balancing different objectives. The EESC points out that continuing the productive use of restored and rewetted peatlands in alternative ways requires economic viability. Furthermore, with regard to the time frame for achieving it, a 2012 study carried out by researchers on more than 620 sites where ecological restoration efforts were undertaken in wetlands found that even after a century, these operations only recovered an average of between 65% and 70% of native biodiversity and various hydrological and ecological functions (water filtration, carbon storage) compared to an appropriate, non-degraded reference ecosystem. This raises questions about both the Commission's time line for restoration and the ecological target. However, while peatlands account for only 3% of the Earth's surface, they capture one third of the carbon dioxide stored in the soil. They are therefore a highly strategic sector for the fight against climate change.

Rewetting drained peatlands as provided for in Article 9 of the regulation

This target will have a significant economic impact on professional activities, and it concerns especially certain regions of some Member States. For those regions, the proposed target might have a particular impact from the viewpoint of balancing different objectives. The EESC recognises the particular importance of peatlands for biodiversity and the climate, and regards the Commission's objectives (restoration measures on 70% of drained peatlands by 2050, of which half shall be rewetted[3]) as a compromise between economic and environmental interests. Furthermore, with regard to the time frame for achieving it, a 2012 study carried out by researchers on more than 620 sites where ecological restoration efforts were undertaken in wetlands found that even after a century, these operations only recovered an average of between 65% and 70% of native biodiversity and various hydrological and ecological functions (water filtration, carbon storage) compared to an appropriate, non-degraded reference ecosystem. This raises questions about both the Commission's time line for restoration and the ecological target. However, while peatlands account for only 3% of the Earth's surface, they capture one third of the carbon dioxide stored in the soil. They are therefore a highly strategic sector for the fight against climate change.

Result of the vote

For
     99

Against
     104

Abstentions
     
     18

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