Opinion of the European Economic and Social Committee on the Communication from the Commission on Halting the loss of biodiversity by 2010 — and beyond — Sustaining ecosystem services for human well-being COM(2006) 216 final
Date: 2007-02-15
Institutions: European Economic and Social Committee
Subjects: EU programme, biodiversity, environmental protection, management of resources, natural resources, sustainable development

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Official Journal of the European Union

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Opinion of the European Economic and Social Committee on the Communication from the
Commission on Halting the loss of biodiversity by 2010 — and beyond — Sustaining ecosystem
services for human well-being

COM(2006) 216 final

(2007/C 97/03)

On 22 May 2006 the European Commission decided to consult the European Economic and Social
Committee, under Article 262 of the Treaty establishing the European Community, on the abovementioned
proposal.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing
the Committee's work on the subject, adopted its opinion on 25 January 2007. The rapporteur was
Mr Ribbe.

At its 433rd plenary session, held on 15 and 16 February 2007 (meeting of 15 February), the European
Economic and Social Committee adopted the following opinion by 137 votes to seven, with five absten-
tions:

1. Summary of the EESC's conclusions and recommenda-

tions

The EESC and the Commission are in agreement

1.1
in
defining the situation which we face: maintaining biodiversity is
an essential, key task which does not only represent an ethical
and moral obligation. There are also sufficient economic reasons
why it is necessary to act more quickly and more effectively.
The cost of the economic losses brought about by the decline in
ecosystem services is already at the present time estimated at
several hundred billion euros. This constitutes a waste of
resources which our economies simply cannot afford to bear.

1.2
Species decline in Europe is the result of millions of indi-
vidual value judgements which have been taken in recent
decades; the absolutely overriding majority of these decisions
have been taken in accordance with existing laws. The share of
responsibility for species decline in Europe which can be attrib-
uted to illegal measures is marginal.

1.3
Despite the political promises which have been made, the
trend as regards biodiversity regrettably continues to be nega-
tive; this cannot, however, be put down to a lack of knowledge
about how to tackle species decline. What has been missing up
to now is the political will also effectively to implement the
measures which have long been acknowledged to be necessary.
The experience gained with the Natura 2000 network speaks
for itself.

1.4
The reasons which lie behind this situation are rightly
identified by the Commission in its Communication and include
‘governance failures and the failure of conventional economics to recog-
nise the economic values of natural capital and ecosystem services’.
These elements, together with the fact that the ethical and moral
reasons for maintaining biodiversity tend to be treated as
matters of secondary importance in planning and political
appraisal processes, have brought about
the current critical
development of the situation.

1.5
There are tremendous gaps between the action which
needs to be taken and what is happening in reality; these gaps
must be closed if we are to counteract the imminent danger of a
loss of credibility.

1.6
The EESC welcomes the presentation of the action plan
and recognises the advisability of the some 160 measures which
it sets out; most of these measures are, however, by no means
new — they have been on the agenda for years. What happens
in future will thus demonstrate whether, with the presentation
of this action programme, the world of politics will now really
find the strength to bring about the ‘substantial changes’ which
are recognised as being necessary or whether, on the other
hand, the fears of many nature conservationists will turn out to
be true, namely that politicians are indeed once again discussing
a highly-charged area of social policy but they go no further
than paying lip service to the issues involved.

1.7
the
In the EESC's view, a key point of criticism of
Commission's Communication is the lack of a strategic debate
over the question raised in the Committee's exploratory opinion
of 18.5.2006 (1) as to how to explain the tremendous discrepan-
cies between the action which should be taken, the action which
has been announced and what actually happens in reality in
respect of maintaining biodiversity. The EESC deplores the fact
that
this problem is almost completely disregarded in the
Commission's Communication and action plan.

1.8
The EESC therefore attaches particular importance to
prioritising policy area 4, namely ‘Improving the knowledge
base’, so as to ensure that both the general public and politicians
are aware of the real consequences of their actions.

1.9
Attention should be drawn to the need to help the EU's
neighbouring countries improve their biodiversity conservation
and to avoid situations where the EU and individual member
states co-finance projects that could result in a more rapid loss
of biodiversity in non-EU European countries.

resources

The EESC endorses the concept of the ‘global responsi-
1.10
bility’ of the EU, as defined by the Commission. Whilst the EU
and its Member States devote less that 0.004 % of
their
requisite global
economic
measures for developing and maintaining biodiversity,
their
in the tropical
responsibility for destroying biodiversity (e.g.
forests) continues to increase. In future, developments taking
place on the market
for biofuels may be responsible for a
further worsening of the situation.

funding the

towards

(1) OJ C 195 of 18.8.2006, p. 96.

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The EESC criticises the fact that the action plan itself is
1.11
available only in the form of a ‘technical annex’, i.e. as a separate
SEC document; furthermore, it is available only in English. The
EESC calls upon the Commission to ensure that the action plan
is translated into all official EU languages and that it is widely
distributed, both via the Internet and in the form of a printed
document.

Implementation of the objectives set out in the action
1.12
plan is to be overseen by the existing Biodiversity Expert Group
(BEG). In the EESC's view, there is a pressing need to involve
civil society much more closely in this task.

2. Key elements of and background to the Commission's

Communication

in 1998,

In its biodiversity strategy, set out

2.1
the EU
pointed out that the scale of the loss of biodiversity had ‘acceler-
ated dramatically’. At their meeting in 2001, the EU Heads of
State or Government reached agreement on the goal of halting
the ‘dramatic’ decline in biodiversity (in the EU) by 2010 (2). At
this summit the European public was also promised that steps
would be taken to ensure the restoration of habitats and natural
systems.

review,

is presented,

2.2
In the Communication under
in which the
the
‘Action Plan for Maintaining Biodiversity’
Commission once again sets out a detailed and impressive
description of the current situation with regard to the mainte-
nance of biodiversity or,
to be more accurate, the ongoing
decline in biodiversity. This decline continues to give rise to the
utmost anxiety, as demonstrated by all the studies drawn up by
the European Environment Agency (EEA) and by the ‘Red Lists’
of threatened animal and plant species drawn up at national
level. In its Communication, the Commission points out that we
are still a long way from achieving the goal of halting the loss
of biodiversity by 2010 and notes that the only way in which
the ongoing negative trend can be reversed is by means of
‘substantial changes in policy and practice’.

2.3
The Commission adds that ‘the pace and extent of imple-
mentation has been insufficient’ and calls for ‘accelerated implementa-
tion at both Community and Member State’
levels as, otherwise,
‘there is a real risk of failure to meet the global 2010 target’.

2.4
in the
Such a failure to achieve our objective would,
Commission's view, cause problems on two grounds. Main-
taining biodiversity is not only an ethical and moral obligation,
vis-à-vis creation,
it is also both advisable and necessary on
purely economic grounds. In its Communication, the Commis-
sion accurately points out that biodiversity provides the basis
for ecosystem services including ‘the production of food, fuel, fibre
and medicines, regulation of water, air and climate, maintenance of soil
fertility and cycling of nutrients’. The Commission also draws atten-
tion to the fact that ‘that some two-thirds of ecosystem services world-

wide are in decline’ and the attendant financial loss — which is,
admittedly, difficult to ascertain — is estimated by the Commis-
sion to amount to ‘hundreds of billions of euros’.

In its Communication,

the Commission goes on to
2.5
analyse the measures which have been taken up to now and the
degree to which they have proved successful. The Commission
does not only focus on the EU itself but also describes the
worldwide situation and defines the EU's global responsibility.

2.6
At the heart of the Communication lies the debate on
the issue as to what action needs to be taken in future. With
this aim in view, an EU action plan has been drawn up (only,
however,
in the form of an appended SEC document). The
action plan comprises four key policy areas and also sets out
ten priority objectives and a further four ‘key supporting
measures’.

2.6.1
Policy area 1 covers ‘Biodiversity in the EU’. Five of
the overall total of ten priority objectives are set out under this
heading. The five priority objectives in question are as follows:

— to safeguard the EU's most important habitats and species;

— to conserve and restore biodiversity and ecosystem services

in the wider EU countryside;

— to conserve and restore biodiversity and ecosystem services

in the wider EU marine environment;

— to reinforce the compatibility of regional and territorial

development with biodiversity in the EU; and

— to substantially reduce the impact on EU biodiversity of

invasive alien species and alien genotypes.

Policy area 2 is entitled ‘The EU and global biodiver-
2.6.2
sity’. This title has been selected for a number of reasons: the
fact that the loss of biodiversity is, of course, not confined to
the territory of the EU and the fact that both the EU and its
Member States have entered into commitments under interna-
law to participate in the world-wide conservation of
tional
biodiversity and bear joint responsibility for developments at
global
their trade relations. Three further
priority objectives are set out under this heading, namely:

level by virtue of

— to substantially strengthen the effectiveness of international

governance for biodiversity and ecosystem services;

— to substantially strengthen support

for biodiversity and

ecosystem services in EU external assistance;

— to substantially reduce the impact of international trade on

global biodiversity and ecosystem services.

2.6.3
change’. The following objective is set out under this heading:

‘Biodiversity and climate

Policy area 3 covers

(2) See the Presidency Conclusions of the Göteborg European Council of

15-16 June 2001.

— to support biodiversity adaptation to climate change.

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In Policy area 4, the Communication and the action
2.6.4
plan address the issue of the ‘knowledge base’ and define the
tenth and final priority objective, as follows:

— to substantially strengthen the knowledge base for conserva-
tion and sustainable use of biodiversity, in the EU and glob-
ally.

2.6.5
follows:

The four key support measures are defined as

— ensuring adequate financing;

— strengthening EU decision-making;

— building partnerships; and

— building public education, awareness and participation.

3. General comments on the provisions set out in the

Commission's Communication

The EESC welcomes the publication of the Commission's
3.1
Communication and the drawing up of an action plan on
22 May 2006, four days after the adoption by the EESC of its
exploratory opinion on the ‘EU campaign to conserve biodi-
versity — Position and contribution of civil society’. The
EESC notes that the analysis of the current situation and the
causes of this situation is practically identical
in both docu-
ments.

the sealing of

The EESC draws attention to the fact that the individual
3.2
causes of the decline in both species and biotopes, i.e. factors
such as: more intensive land usage or the abandonment of
previously extensively-used living areas;
land
surfaces; and overdevelopment, have been well known for a
number of years and have been widely scientifically docu-
mented. These factors are based on decisions and measures
taken by economic players or on political decisions taken in
accordance with existing laws. The extent of the threat to biodi-
versity brought about by illegal measures is relatively low. It is
thus perfectly legal policy decisions,
technical decisions and
value judgements which are leading to the loss of biodiversity
and such decisions are often backed up or initiated by decisions
and aid instruments of the EU, the Member States or municipa-
lities.

3.3
This consensus between the EESC and Commission's
Communication in respect of both the situation and the analysis
of the situation also applies with regard to the reasons why it is
essential to maintain biodiversity. Whilst the Commission refers
in its Communication to ethical and moral reasons, together
with economic grounds, the EESC for its part refers,
in its
exploratory opinion, to the ‘practical and intrinsic value’ of
countryside areas and biodiversity.

Biodiversity — the gap between political imperatives and reality

3.4
The Commission Communication under review joins a
long list of political documents announcing measures to stem
the loss of biodiversity. Political promises to this effect have
been made repeatedly, most recently at the meeting of EU Envir-
onment Ministers held in December 2006, at which the present
Communication was approved.

The EESC is, however, regrettably obliged to note that, all
3.5
too often, there is a yawning gap between what needs to be
done and the measures which are taken in reality. The public is,
of course, aware of this fact. By way of example, at the end of
December 2006 the EU fisheries ministers set catch quotas for
cod which, in the opinion of all marine biologists, are much too
high and will, in all probability, lead to the collapse of stocks of
this species. Despite this, the outcome of the meeting was hailed
as a ‘good result’. This is illustrative of either considerable differ-
ences in the appraisal of the issues involved and the relation
between cause and effect or it points to the fact that, although
the issue was discussed,
in reality a policy is still being
consciously pursued which will culminate in a loss of biodiver-
sity.

3.6
The EESC has, in the meantime, highlighted these issues
in a whole series of opinions dealing with this subject and has
warned against an impending loss of credibility.

the extent

3.7
There are, quite clearly, differences between the Commis-
sion and the EESC in their respective appraisals of the question
of
the problem of
to which the importance of
declining biodiversity has already been recognised and appraised
by the public at large, persons exercising political responsibility
and the most important economic players and the extent to
which, in particular, political measures have been taken to coun-
teract this decline. The EESC acknowledges that there is an
awareness of the issue of loss of biodiversity. It also does not
wish to imply that anyone — be they members of the public or
politicians — consciously takes decisions designed to undermine
biodiversity. Considerable difficulties do, however, appear to
exist over the matter of being able, in reality, to gauge the long-
term consequences of one's own decisions and, where appro-
priate, to draw the requisite conclusions. One example which
further illustrates this situation is the irrigation activity under-
taken in some new Member States, including Poland, as part of
the Rural Development Programmes, during 2004-2006 and
planned for 2007-2013. ‘Water resource management for agri-
culture’ activity, which is financed from EU funds, primarily
involves the technical transformation of river basins. This in
turn leads to a whole series of adverse effects, starting with the
loss of biodiversity. Unfortunately, this action is also carried out
and planned in potential Natura 2000 areas.

3.8
The Commission refers to the fact that issues relating to
the maintenance of biodiversity would play a key role, inter alia,
in respect of the Lisbon Strategy. The Committee of Regions
also points out in its opinion on the Communication under
review that it ‘welcomes the Council Conclusions of 23-24 March
2006 calling for the integration of the 2010 objectives into all rele-
vant Lisbon agenda policies’. The EESC does, however, have the
utmost doubt whether this will indeed be the case. It is rather
obliged to conclude that the role and importance of biodiversity
are given only marginal consideration in the context of
‘economic policy’. It is clear from making an appraisal of the
documents relating to the Lisbon Strategy that terms such as
‘diversity’ and ‘nature conservation’ are referred to only in a
marginal way, if at all, and the situation is also no different with
regard to the national reform programmes.

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The Commission is absolutely right when it refers in its
3.9
Communication to ‘governance failures and the failure of
conventional economies to recognise the economic values of
natural capital and ecosystem services’.
these values were
really recognised and if external costs were consequently inter-
nalised, the problem would not arise in this form.

If

3.10
In its abovementioned exploratory opinion, the EESC
had already pointed out that the conflicts between, on the one
the various strategies designed to promote economic
hand,
growth and, on the other hand, biodiversity were at that time
tending to increase. Economic growth is, today, often identified
in too unqualified a way with the promotion of growth
measured by volume; economic growth of
this nature can
indeed be hampered or made more difficult to achieve by the
drive to maintain biodiversity. In the great majority of cases,
which concern, for example, technical and planning decisions,
nature conservation and biodiversity are thus not seen as
providing an opportunity for economic development but are
regarded, often, as an impediment to such development or seen
as preventing it. This is the only way to explain the ‘pressure’
which continues to be exerted, in some cases even more inten-
sively than before, against the Directive on the conservation of
natural habitats and fauna and flora (the ‘Habitats Directive’)
and the Directive on the conservation of wild birds (the ‘Birds
Directive’) and the resultant Natura 2000 network. Despite the
fact that the European Commission with responsibility for the
is currently speaking out against
environment, Mr Dimas,
abovementioned Directives (3),
amending the
is no
mistaking the fact that nature conservation is often regarded as
representing a rival when it comes to determining land-use and
seen as curbing development; it is regarded as providing a basis
for economic development only in extremely rare cases. Further-
more, the financial expenditure and obligations arising from, for
example, the establishment of the Natura 2000 network of sites
are looked upon in terms of a burden, rather than as an invest-
ment for the future, or the requisite facilities are not made avail-
able.

there

3.11
In addition to this ‘economic’ perception of nature
conservation and biodiversity, which is completely at odds with
the economic justification for maintaining biodiversity referred
to by the Commission, there is a second problem which has
been brought about by the parties responsible for nature conser-
vation themselves and which has intensified conflicts with land-
owners and land-users. The EESC has drawn attention on
several occasions to the fact that the way which the Natura
2000 network was planned and implemented was a classic
example of how certain nature conservation measures are
doomed to failure. In the case of the Natura 2000 scheme,
ministers at national and regional level suddenly started to criti-
cise the very legal bases which they themselves had established a
number of years earlier. Under the same scheme, funding was
also not provided to cover the compensation payments to
farmers which had been promised as part of the policy and deci-
sions were taken over the heads of the landowners or land-users
concerned, rather than enlisting their support. This type of
nature conservation measure is not credible and generates
mistrust.

3.12
There are many examples which demonstrate that
reasonable cooperation has been able to bring about perfectly
respectable levels of
success provided that politicians and
administrations also honour their promises and on condition
that the parties concerned enter into genuine partnerships.

(3) A stance which is welcomed by the EESC.

Financial decisions by the EU provide an example of the kind of action
which should be avoided.

to determining political priorities,

3.13
At the EU Summit in December 2005, the financial
decisions taken on the financial perspective for the period
2007-2013 involved cuts in funding for the second pillar of the
CAP, which is of particular importance in the drive to safeguard
biodiversity; this is clear evidence of the fact that, despite all the
lofty declarations and goals which have been set out, when it
the objective of
comes
conserving biodiversity is sacrificed. Six months after the above-
mentioned financial decisions were taken, in its action plan the
Commission then describes the need for ‘ensuring adequate finan-
cing’
the ‘four key supporting
measures’. Whilst this is a right and proper demand as regards
its form and content, it is, however, regrettably out of step with
political reality and tends rather to demonstrate the discrepancy
between word and deed.

for Natura 2000 as one of

3.14
The EESC has on a number of occasions expressed the
view that the second pillar of the CAP is completely under-
funded now that additional tasks, such as the funding of the
Natura 2000 network and the implementation of the Water
Framework Directive have been assigned to it. What kind of
opinion are members of the public to have of a policy which is
so clearly contradictory and which gives rise to conflicts at local
level?

3.15
The CoR is therefore perfectly right when, in its above-
mentioned opinion, it ‘argues …, in the framework of the 2008
review of the 2007-2013 financial perspective, for a substantial shift
of funding towards sustainable forms of farming and landscape preser-
vation’.

3.16
Similar observations apply in the case of the, funda-
mentally correct, call made by the Commission for steps to be
taken to ensure ‘that Community funds for regional development
benefit, and do not damage, biodiversity’ and to build up ‘partner-
ships between planners, developers and biodiversity interests’. The
EESC also firmly supports this demand, which has since been
reiterated on several occasions. Here, too, however there are
clear discrepancies between (right and proper) announcements
and day-to-day political practice, since nothing has changed in
principle. Infrastructure projects (some of which are co-financed
by the EU) continue to be constructed through areas which are
the greatest value in terms of nature conservation and,
of
despite the fact that the necessary compensatory and replace-
ment measures for the benefit of nature conservation are taken,
the end result is — as indicated in the description of the situa-
tion in the EU — a loss of biodiversity.

3.17
Furthermore, the EESC takes the view that the demand
set out in respect of the Structural Funds must also apply in the
case of all EU expenditure if the Community is to live up to its
self-established claim to operate a coherent policy.

3.18
The EESC is thus able to identify lines of approach in
all areas for which the EU has responsibility by virtue of its
remit. Agricultural policy would be a case in point. As the
current situation demonstrates, the existing legal provisions are,
however, not up to the task of ensuring widespread conserva-
tion of biodiversity.
If agricultural payments are then linked
‘only’ to compliance with existing laws, it soon becomes clear
that this situation is not conducive to promoting biodiversity.

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As things stand at present, direct payments to farmers,
3.19
which comprise the greater part of the agricultural budget, are
not geared to promoting biodiversity, but are designed rather to
prepare farmers to meet the challenges of world markets. The
EESC has, however, drawn attention on a number of occasions
the European Agricultural model, which also
to the fact
numbers amongst its objectives the maintenance of biodiversity,
is not compatible with world market conditions. Making
farmers competitive on the world market whilst, at the same
time, expecting them to promote biodiversity is not a feasible
proposition.

that

3.20
In an earlier opinion, the EESC pointed out that ‘as long
as world-market conditions tend to hinder the widespread adoption of
farming practices which are in line with the goals of nature conserva-
tion, special policy measures will be required …’ which could, for
example, mean that ‘agri-environmental aid should be increased to a
level where all farmers in the EU are prompted to switch to green
production measures’ (4). Here, too, what has been achieved in
reality lags behind the goals which have been announced.

3.21
The political situation in respect of the protection of
biodiversity clearly differs in a fundamental way from the situa-
tion which applies in other political fields, such as financial
policy and stability policy. In the latter cases the Commission
endeavours — sometimes in the face of the most tremendous
opposition — to force through a clearly recognisable political
line and instruments are available, c.f. the Maastricht Criteria, in
order to require that the course of action deemed to be correct
is pursued. In the case of the conservation of biodiversity, we
have, as yet, barely gone beyond the stage of expressing political
lip service to the pursuit of this goal.

For these very reasons,

3.22
the EESC highlighted in its
exploratory opinion the question of identifying the social back-
ground which gives rise to a situation in which everyone is
speaking out in support of biodiversity but a dramatic decline
in biodiversity is nonetheless occurring.
It concluded that
society (and large parts of the world of politics) were not suffi-
ciently aware of both the intrinsic and practical value of biodi-
versity.
If both reasons for maintaining biodiversity are not
really taken on board and understood, no policy in this field
can be effective. The EESC therefore called for political emphasis
to be placed on communicating the need to maintain biodiver-
sity. Although the EU action plan, proposed by the Commission
addresses this issue in policy area 4 and under the four key
supporting measures,
is not given the requisite detailed
consideration.

it

The EESC does not wish to reiterate here the observa-
3.23
tions on this matter set out in its opinion of 18 May 2006. It
can only request the Commission, Council and the European
Parliament to take a fresh look at the views which it expressed
in this earlier opinion. The dramatic situation with regard to the
trend in biodiversity is well known and it has been brought
about largely as a result of action which is, in each case, legal.
Some measures have,
indeed, been introduced by the EU to
tackle this situation but one of the reasons why they have failed
to be effective is because they have either not been taken up at
all or only taken up in a half-hearted fashion. Furthermore,
many decisions continue to be taken despite the fact that they
are counter-productive.

4. Specific comments

The very fact

4.1
that over 160 different proposals for
improving the situation have been put forward in an action plan

(4) See the EESC opinion of 21.3.2002 on the future of the CAP (OJ C 125

of 27.5.2002, pp. 87-99).

demonstrates, first of all, that there must hitherto have been
shortcomings in very many policy areas and at the greatest
possible variety of levels. At the same time, the question must,
however, also be raised as to whether all the proposed measures
are equally important and whether they should all be addressed
simultaneously. The fact that these questions have been raised
should not be taken to mean that the EESC regards even one of
the listed measures as being erroneous.
It merely doubts
whether it is really the case that all of the measures have to be
seriously pursued.

4.2
The EESC believes that addressing policy area 4 thor-
oughly and without delay is a matter of key importance. There
is an urgent need to improve the knowledge base with regards
the real
long-term
importance of biodiversity and the real
consequences for biodiversity of the various decisions which are
taken. It is a fact that only if the requisite knowledge base is
actually available and really endorsed by both the world of poli-
tics and society at large, will it be possible to develop the sense
of involvement which is politically essential if we are to bring
about the ‘substantial changes in policy and practice’, which the
Commission regards as being of vital
importance. Whether
what is lacking at the moment is rather the requisite knowledge
and ideas or, on the other hand, rather the political will or
ability to implement measures represents a question which is
extremely difficult to answer.

4.3
The EU will undoubtedly have to let itself be judged by
the criterion of whether it carries out the measures announced
in its action plan, including its plan to reshape its policy for
tackling loss of biodiversity and its expenditure policy. The
financial decision taken in December 2005 prompt many of the
parties concerned to express scepticism as to whether this
reversal of policy is being taken up seriously. This scepticism is
strengthened by the fact that, in the past, hardly any successes
have been recorded even in areas where there were not even
any economic interests standing in the way of more effective
measures for the protection of biodiversity.

By way of example, one problem area may be highlighted
4.4
which is not addressed at all at any point in the Commission's
Communication, despite the fact that it is a matter of particular
importance to many threatened species, namely the issue of
hunting. Every year approximately 102 million birds, including
some 37 million songbirds, are either shot or caught in the
27 EU Member States, Switzerland and Norway. These figures
are based on hunting statistics. One thing is certain, the high
losses suffered by migratory species of birds as a result of
hunting represent a key mortality factor.

4.5
Species such as the lapwings, snipe, garganey, skylark,
quail, turtle-doves and jacksnipe — all of which are in decline
either throughout Europe or in parts of Europe — must, and
could, therefore be exempted from hunting. It should be borne
in mind in this context that in the majority of European coun-
tries hunting migratory species is pursued as a leisure activity by
only a small minority of the population. There are no economic
grounds for it; hunting is an activity which is carried out purely
for pleasure. Nevertheless — or perhaps for this very reason —
no success has been achieved in this field up to now. This
underlines yet again how difficult it is to change even customs
of this type and how much more difficult it is to implement
‘substantial changes in policy and practice’ accordingly.

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The Greek island of Tilos provides a remarkably positive
4.6
example of what can be achieved by introducing a ban on
hunting. Therev has been no hunting on this island since 1993
and this has led to a tremendous increase in both the variety of
species and the numbers of
individuals within the various
species. The EU has promoted this development using a number
of instruments, including a project implemented under the LIFE
programme.

4.7
The EESC would, in conclusion, also like to reiterate that
it supports the concept of ‘global responsibility’ referred to by
the Commission. The EU does, however, not yet win any laurel
wreaths for its action in this field. The Commission itself notes
in its Communication that, at present, only ‘1/100th of Com-
munity and Member States' total annual development aid budgets’, i.e.
less than 0.004 % of all expenditure, is devoted to international
projects designed to maintain biodiversity.

4.8
There is also the issue of the high level of joint responsi-
bility for the destruction of biodiversity in other parts of the
world. In its Communication, the Commission cites the example
of the destruction of tropical forests. The EESC draws attention
to the fact that this clearing of forests is counter-productive not
only from the standpoint of the need to safeguard biodiversity
but also on climate-protection grounds; 20 % of CO2 pollution
worldwide is brought about by the destruction of forests.

4.9
The EESC highlights the clear risk faced by arable and
livestock farmers due to the rapid erosion of genetic resources
for food production.

that,

for example,

The EESC wishes to express its grave concern over the
4.10
fact
the EU's biofuel
implementation of
strategy could result in additional massive destruction of tropical
forests if use is made of cheaper imports rather than domestic
products produced in accordance with the principles of conser-
vation of nature and the environment. Malaysia currently
produces some 5 million tonnes of palm oil per year; the plan-
tations which were established for this purpose were responsible
for around 90 % of the total area of rain forest cleared in this
country in the period 1985-2000. A further 6 million ha is

Brussels, 15 February 2007.

now to be cleared — in Indonesia the figure is as high as
16.5 million ha — in order to establish palm-oil plantations.
The palm oil produced is destined for export. A combined heat
and power station in the German municipality of Schwäbisch-
Hall, often referred to as an exemplary energy-policy develop-
ment, will derive over 90 % of its fuel from palm oil!

4.11
In addition to the abovementioned divergent stand-
points with regard to content and strategy, the EESC wishes to
draw attention to two further key issues of a formal nature:

It

4.11.1
is a source of considerable irritation to those
concerned and interested parties when they have to search for
several different EU documents together in order to obtain a
complete overview of one and the same policy area. In order to
satisfy the administrative requirement to ensure that Commis-
sion documents remain concise,
the actual action plan —
which, in the table of contents of the Commission's Communi-
cation, is listed as taking the form of Annex 1 to this document
— is in fact not appended to this Communication. It can only
be obtained in the form of a separate SEC document, the cover
page of which does not even mention the term ‘action plan’.
Reference is made solely to a ‘technical annex’. Furthermore, the
action plan is available only in English (i.e. not in other official
languages) and it is printed using a type face which is difficult to
read. All of this is a source of irritation. The EESC therefore
calls upon the Commission to have the action plan translated
into all of the official languages and to ensure that the docu-
ment is widely distributed, both via the Internet and in print
form.

The Commission proposes that

4.11.2
implementation of
the objectives of the action plan should be overseen by the
existing Biodiversity Expert Group (BEG). The EESC, for its part,
would however propose that civil society be much more closely
involved in this process, particularly in view of the abovemen-
tioned problem — described in detail in the EESC's exploratory
opinion — that there is much too little awareness of the issues
at stake and consequently also much too little feeling of ‘invol-
vement’.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS