European Economic and Social Committee
NAT/491
An EU Biodiversity
Strategy to 2020
Brussels, 26 October 2011
OPINION
of the
European Economic and Social Committee
on the
Communication from the Commission: Our life insurance, our natural capital: an EU
Biodiversity Strategy to 2020
COM(2011) 244 final
_____________
Rapporteur: Mr Ribbe
_____________
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Tel. +32 25469011 — Fax +32 25134893 — Internet: http://www.eesc.europa.eu
EN
-1On 3 May 2011, the European Commission decided to consult the European Economic and Social
Committee, under Article 262 of the Treaty on the Functioning of the European Union, on the:
Communication from the Commission: Our life insurance, our natural capital: an EU
Biodiversity Strategy to 2020
COM(2011) 244 final.
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 6 October 2011. The rapporteur
was Mr Ribbe.
At its 475th plenary session of 26 and 27 October 2011 (meeting of 26 October 2011) the European
Economic and Social Committee adopted the following opinion by 120 votes to 5 with 6 abstentions.
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1.
Summary of the EESC's conclusions and recommendations
1.1
In this, its fourth opinion on biodiversity policy in only four years the EESC again welcomes
the fact that the Commission makes it clear that much more needs to be done if the objectives
set by the European Council are to be met.
1.2
The EESC is, however, critical of the fact that the Commission does not really analyse the
reasons why requirements which have been known for years and which have always been
welcomed by the Committee - e.g. the 160 actions of the 2006 Biodiversity Action Plan have been inadequately implemented, if at all. An analysis of the reasons for the nonimplementation or failure of the comprehensive programme of actions contained in the 2006
Biodiversity Action Plan is particularly important because only on that basis will it be
possible to draw up new, more promising actions and strategies.
1.3
The strategy now submitted contains nothing substantially new. The problem cannot be
tackled by submitting a new strategy paper which contains old, well known proposals. When
it comes to maintaining biodiversity there is no shortage of laws, directives, programmes,
model projects, political declarations or recommendations, but there is a lack of
implementation and concerted action at all political levels.
1.4
Politicians have not yet found the strength or the will to implement measures which have been
acknowledged to be necessary for years, although the communication repeatedly makes the
point that society and the economy will benefit equally from a stringent biodiversity policy.
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-2Not even the EU's central nature conservation directives have been fully implemented by the
Member States – 19 or even 32 years after their entry into force.
1.5
The EESC does recognise that there have been partial successes in maintaining biodiversity.
But this should not blind us to the fact that, overall, biodiversity is declining dramatically.
The EU is thus faced with the challenge of developing an implementation-orientated strategy.
1.6
Unfortunately it is not clear how the lack of political will can be remedied. In this sense the
biodiversity strategy now submitted does not represent real progress. The debates on the
communication which have so far taken place in the Council of Ministers show that we are
still a long way from integrating biodiversity policy into other policy areas.
1.7
It is therefore of the greatest importance that the forthcoming political reform processes (e.g.
fisheries, agricultural, transport, energy and cohesion policy) be closely linked to the
biodiversity strategy. But the EESC believes that there are still major shortcomings in this
respect. This also applies to the plans submitted for the 2014-2020 financial perspective,
which do not appear to the EESC to be suitable for ensuring sufficient financial resources.
The Commission must take its own biodiversity strategy more seriously!
1.8
During the drafting of this opinion parallels were drawn on this point with the debt and
euro zone crisis. If the EU Member States do not take their own principles and criteria
seriously, whether they are nature conservation rules or the stability criteria for monetary
union laid down in the Maastricht Treaty, it is hardly surprising if a) political problems occur
and b) people lose confidence in politicians.
1.9
There is a clear need for information and knowledge about biodiversity and its complex
interactions with development and employment as well as for the identification and support of
success stories.
1.10
The Commission is urged finally to submit the list of environmentally harmful subsidies
which it promised as early as 2006.
2.
Key elements of and background to the Commission's Communication
2.1
In 2001 the Gothenburg European Council adopted the EU sustainability strategy which also
formulated a clear objective for biodiversity policy: Protect and restore habitats and natural
systems and halt the loss of biodiversity by 20101.
2.2
In March 2010 the heads of state and government of the EU acknowledged that they had not
achieved their objective. They therefore came out in favour of a new objective, proposed by
the Commission in its Communication on Options for an EU vision and target for
1
COM(2001) 264 final, 15.4.2001, p. 14.
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-3biodiversity beyond 20102. It focuses on 2020 and entails: Halting the loss of biodiversity and
the degradation of ecosystem services in the EU, and restoring them in so far as feasible,
while stepping up the EU contribution to averting global biodiversity loss.
2.3
The Council instructed the Commission to draft a new strategy to achieve this objective,
which is submitted with the communication.
2.4
In it the Commission underlines the need finally to act - with facts which have been known
for years:
2.5
2
3
4
5

Biodiversity loss is described, alongside climate change, as the most critical global
environmental threat; the Commission adds that the two are inextricably linked;
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Species extinction is occurring at an unparalleled rate: species are currently being lost 100
to 1 000 times faster than the natural rate;
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In the EU, only 17% of habitats and species and 11% of key ecosystems protected under
EU legislation are in a favourable state3 4;
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The few benefits of the measures introduced since 2001 have been outweighed by
continued and growing pressures on Europe's biodiversity: land-use change,
over-exploitation of biodiversity and its components, the spread of invasive alien species,
pollution and climate change have either remained constant or are increasing;

The fact that biodiversity's economic value is not reflected in decision-making is also
taking a heavy toll on biodiversity.
Greater attention is paid in the communication than in previous EU papers to the economic
aspects of biodiversity loss, and this is illustrated by the increasing use of the concept of
"ecosystem services". Reference is again made to the TEEB study5and the point is made that
insect pollination is estimated to be worth EUR 15 billion to the EU every year. From this it is
deduced that the continued decline in bees and other pollinators could have serious
consequences for Europe’s farmers.
COM(2010) 4 final.
http://www.eea.europa.eu/publications/eu-2010-biodiversity-baseline/.
No information is given on unprotected habitats and species, although they are of course also important for biodiversity.
The Economics of Ecosystems and Biodiversity (TEEB), see: http://teebweb.org.
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-42.6
Part 3 of the communication sets out a framework for action for the next decade, with six
targets:
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Target 1: Fully implement the Birds and Habitats Directives;
Target 2: Maintain and restore ecosystems and their services;
Target 3: Increase the contribution of agriculture and forestry to maintaining and
enhancing biodiversity;
Target 4: Ensure the sustainable use of fisheries resources;
Target 5: Combat invasive alien species; and
Target 6: Help avert global biodiversity loss.
2.7
Each target has actions designed to tackle the associated challenges. A total of 37 actions are
described.
2.8
The communication repeatedly states that biodiversity policy needs to be more effectively
integrated into other areas of EU policy, such as agricultural and fisheries policy.
2.9
There is a need for funding in two areas in particular: completing the Natura 2000 network
and implementing global commitments6.
2.10
It is also pointed out that the reform of harmful subsidies (…) will also benefit biodiversity.
3.
General comments
3.1
The EESC issued opinions on biodiversity policy in February 2007, July 2009 and September
2010.
3.2
The EESC notes that the areas, targets and actions listed in the current draft strategy were a
key component of the 2006 action plan.
3.3
The strategy now submitted contains nothing substantially new. It does, however, once again
show which approaches are absolutely essential and which are the most urgent and the most
promising ones. The strategy is to a large extent a "copy-paste" of old, well-known facts,
proposals and measures. The issues are all sufficiently understood. There is no need to
consider again what needs to be done, only to ask why it is not being done and how we can
act in a focused way. But the strategy so far provides no answer to this key question.
3.4
The Commission paper is therefore extremely unsatisfactory. The EESC therefore calls for a
greater emphasis on implementation in the biodiversity strategy 2020.
6
See COP 10 conference in Nagoya 2010.
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-53.5
The EESC would like to reiterate what it said in 2007.
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Maintaining biodiversity is an essential, key task which does not only represent an ethical
and moral obligation. There are also economic reasons why it is necessary to act more
quickly and more effectively.
Species decline in Europe is the result of millions of individual value judgements which
have been taken in recent decades; the absolutely overriding majority of these decisions
have been taken in accordance with existing laws.
Biodiversity continues to decline. What has been missing up to now is the political will to
effectively implement the measures which have long been acknowledged to be necessary.
The reasons which lie behind this situation are rightly identified by the Commission as
governance failures and the failure of conventional economics to recognise 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.
The EESC welcomed the 2006 action plan and recognised the advisability of the some
160(!) measures which it set out; most of these, however, were even then by no means
new and had been on the agenda for years. The EESC regrets that the lack of a strategic
debate over the question raised in the Committee's exploratory opinion of 18 May 20067
as to how to explain the tremendous discrepancies between the action which should be
taken, the action which has been announced and what actually happens in reality in
respect of maintaining biodiversity is almost completely disregarded in the Commission's
communication and action plan.
The EESC endorses the concept of the "global responsibility" of the EU.
3.6
These key points of the opinion adopted in plenary session in 2007 are as relevant today as
they were then. The EESC deeply regrets that nothing has really changed decisively in the
intervening years.
3.7
The Commission communication contains no analysis of the reasons for the
non-implementation or failure of the comprehensive programme of actions contained in the
2006 Biodiversity Action Plan. A thorough analysis of the failure is needed because only on
that basis will it be possible to draw up new, more promising actions and strategies. The
problem cannot be tackled by submitting a new strategy paper which contains old, well
known proposals.
3.8
Although the Commission has for years been attempting to place greater emphasis on the
economic arguments for maintaining biodiversity, the results have been meagre. The EESC,
which once described biodiversity policy as a long-term economic issue, which the ministers
7
OJ C 195, 18.8.2006, p. 96.
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-6for economic and financial affairs should therefore finally address8, welcomes the fact that an
attempt has been made to highlight the economic consequences of failed biodiversity policy.
But biodiversity policy has not so far been integrated into the EU's economic and financial
policy. The new strategy needs to suggest ways of remedying this.
3.9
And on the other hand the EESC would like to highlight a potential danger of the increasing
emphasis on economic issues. The danger that protection of biodiversity might in future focus
mainly on areas which offer, or appear to offer, a short-term economic payback. The
Commission should therefore consider how one should deal with species and habitats whose
economic value cannot be directly calculated. It would be difficult to estimate the value of
large mammals like the wolf, the bear or the lynx for example in euros and cents; the same is
true of the common frog, the grasshopper, the white stork or thousands of other species. At
the same time species whose economic value cannot be overestimated are left completely out
of the political debate: where are the conservation programmes for bacteria, fungi or
earthworms, the decomposers without which the decomposition of organic substances would
not be possible?
3.10
The strategy focuses strongly on agriculture and forestry as well as on fisheries policy. In one
sense this is justified, as a) they affect biodiversity and b) they are policies which affect
extensive areas and can be influenced by the EU. On the other hand, however, there is too
little emphasis on other kinds of pressure on biodiversity such as transport and urbanisation.
3.11
The Commission is no doubt correct to point out in the draft strategy that the reform of
harmful subsidies (…) will also benefit biodiversity. Only: it should finally produce the list of
harmful subsidies. It promised to do this in 2006 and still has not done so.
3.12
The EESC welcomes the Commission's announcement that all expenditure will in future be
checked for its biodiversity compatibility and that a "no net loss" initiative will ensure no
further damage to biodiversity.
4.
Comments on the specific targets
4.1
The EESC would like to show, by looking at the six individual targets and a few actions, why
it considers the newly submitted biodiversity strategy to be lacking in ambition from a
technical point of view. The reason for the Commission's reticence in the formulation of the
actions is probably political. The extremely tough negotiations in the Environment Council on
the individual actions show that biodiversity is still not integrated into other policy areas.
8
OJ C 48, 15.2.2011, p. 150, point 1.6.
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-74.2
Target 1:
4.2.1
The 1979 Birds Directive and the 1992 Habitat Directive are of key importance for European
nature conservation. Nature conservation in Europe has no chance if these are not fully
implemented. However, the fact that Target 1 of the new biodiversity strategy is entitled
Fully implement the birds and habitats directives could be seen as a most unfortunate signal.
The EESC regards the fact that these directives have still not been fully implemented 19 or
even 32 years after their adoption as the greatest problem facing biodiversity policy in
Europe. This provides convincing proof that, when it comes to maintaining biodiversity, it is
the political will which is missing rather than legal bases or strategies. There is clearly a role
for the European Court of Justice here, as even good strategies cannot compensate for the
apparent lack of political will.
4.2.2
The EESC's disappointment at the slow implementation of these directives is all the keener,
given that most of the practical actions with successful outcomes were associated directly or
indirectly with these nature conservation directives. Now and again the question is raised in
political circles as to whether these directives and their objectives are still relevant, to which
the EESC responds with a clear and unambiguous "yes!". The Committee sees no chance of
achieving the new targets without rapid and complete implementation of the existing
directives.
4.2.3
During the drafting of this opinion parallels were drawn on this point with the debt and
euro zone crisis. If the EU Member States do not take their own principles and criteria
seriously, whether they are nature conservation rules or the stability criteria for monetary
union laid down in the Maastricht Treaty, it is hardly surprising if a) political problems occur
and b) people lose confidence in politicians.
4.2.4
Among the actions listed for the achievement of this target, Ensure adequate financing of
Natura 2000 sites is described as a priority. The EESC agrees but cannot find anything in the
draft financial perspective for 2014-2020 to suggest that the substantial improvements needed
are likely to be achieved in the new financing period. A premium for the management of
Natura 2000 areas, e.g. by agriculture, would be a positive signal, but unfortunately the CAP
reform makes no provision for this.
4.2.5
Only 17% of habitats and species and 11% of key ecosystems protected under EU legislation
are in a favourable state. The EESC asks the Commission to confirm whether the objective of
having 100% more habitat assessments and 50% more species assessments under the
Habitats Directive show an improved conservation status by 2020 will actually be sufficient
to halt biodiversity loss. The Committee interprets the wording to mean that the Commission
would be satisfied if by 2020 34% of legally protected habitats and species were in a
favourable state (and presumably 2/3 in an unfavourable state).
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-84.3
Target 2:
4.3.1
Target 2 is entitled Maintain and restore ecosystems and their services, a promise made by
the heads of state and government as early as 2001. By 2020, improvements are to be made,
inter alia by establishing green infrastructure and restoring at least 15% of degraded
ecosystems9.
4.3.2
The EESC stresses that land use conflicts have escalated dramatically in the past decades, in
all areas (e.g. agriculture and forestry, energy extraction, transport, urbanisation). Clearly,
restoring degraded ecosystems under current conditions will exacerbate land use conflicts, as
land users will perceive nature conservation as an additional competitor for land. The EESC
calls for the implementing strategy announced for 2012 to suggest ways of solving these
conflicts.
4.4
Target 3:
4.4.1
Target 3, Increase the contribution of agriculture and forestry to maintaining and
enhancing biodiversity, has been the subject of discussion for years, without producing any
solution to the problem. The EESC has repeatedly pointed out that farmers and foresters have
a high level of affinity with nature and biotope conservation. Many model projects show that
positive results can be achieved from working together in partnership.
4.4.2
Farmers are willing to meet the challenge assigned to them by society of practising
"multifunctional" rather than purely production-orientated agriculture. But they are faced with
tasks which cost money but bring none in, as producer prices do not take account of the
expected additional contribution of agriculture.
4.4.3
The common agricultural policy therefore needs to be adapted in order to solve this dilemma.
The Committee would refer to its relevant past opinions and it will continue to monitor the
forthcoming CAP reform intensively from this perspective too.
4.4.4
Financing methods outside the EU agricultural budget should also be looked at in order to
provide the necessary incentive.
4.5
Target 4:
4.5.1
Target 4, Ensure the sustainable use of fisheries resources, addresses EU fisheries policy
directly. The interests of commercial fisheries and the protection of biodiversity come into
conflict again and again. It is therefore no wonder that the targets laid down for agriculture
and fisheries (e.g. Action 13: Improve the management of fished stocks) remain very general
and contain hardly any quantifiable nature conservation objectives. The EESC welcomes the
9
This target corresponds to the relevant objective of the Convention on Biological Diversity (CBD).
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-9target of maintaining and restoring by 2015 (and not only 2020) fish stocks to levels that can
produce maximum sustainable yield, although it must be recognised that this is an objective
for fisheries rather than nature conservation policy. And yet the discussions in the Council
have shown that there is significant opposition even to such relatively non-binding wording.
For the EESC this shows that biodiversity policy continues to be assigned lower priority than
production methods which have long since been recognised as unsustainable. The Committee
will closely monitor the progress of the negotiations on reform of fisheries policy.
4.6
Targets 5 and 6:
4.6.1
The Committee has already commented on Target 5, Combat invasive alien species, in an
opinion10. This problem is not new and it too still awaits a solution, as does Target 6, Help
avert global biodiversity loss. On this issue the Committee notes that many of the
announcements and promises on global biodiversity maintenance are clearly not being
implemented. The Yasuni National Park in Ecuador is a case where the global community
promised financial support in return for the abandonment of an oil extraction project. The
promised level of funding was not forthcoming, however, with the result that oil extraction is
now to go ahead, to the detriment of the rain forest.
4.6.2
The EESC calls on the Commission, the Council, and the European Parliament to make it
clear how much money will be made available for "global biodiversity policy" in the new
2014-2020 financing period. This is not clear from the existing documents. So far the EU and
the Member States have devoted less than 0.004% of their economic output to global
biodiversity maintenance and development actions. The problems, which are in fact likely to
increase as a result of global competition for land, cannot be solved in this way.
Brussels, 26 October 2011.
The President
of the
European Economic and Social Committee
Staffan Nilsson
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10
OJ C 306, 16.12.2009, p. 42.
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