On 30 April 2015 the Directorate-General on Environment launched a public consultation as part of the ‘fitness check’ of EU nature legislation, more specifically on the Birds Directive and the Habitats Directive, and on its implementation to date (the deadline is set for 24 July 2015).
Whilst welcoming this initiative, the Confederation of European Forest Owners (CEPF), the European Farmers and Agri-Cooperatives (COPA-COGECA), the European Landowners’ Organization (ELO), and the Union of Foresters of Southern Europe (USSE) representing the interests of Europe’s private forest owners and managers, expressed their views on the fitness check in a joint letter (see below) submitted to the Commissioner for Environment, Maritime Affairs and Fisheries, Mr Karmenu Vella.
The undersigning organisations consider both Directives as important tools for enhancing nature in Europe and are convinced that their strategic objectives are still of the utmost relevance for nature conservation in forests. However, it is their shared experience that 23 years after the introduction of Natura 2000 there are still gaps hampering its successful implementation. One common identified reason for this is the inadequate involvement of land owners and managers in the decision-making and implementation processes, in particular at national and regional level. In addition to this, the static approach to nature conservation that does not sufficiently acknowledge natural dynamics as well as the lack of recognition of technological developments in the forest sector are increasingly creating conflicts on the ground. Also, since there is often no clear understanding of the various terms used, e.g. good conservation status, or of the importance of active forest management in Natura 2000 areas, forest owners and managers are hesitant to commit.
The opportunity for maintaining an active contribution to the broad fitness check of EU nature legislation was highly welcomed by the above-mentioned organisations. Nevertheless, it was also noted that the ongoing public consultation fails to ensure a balanced approach between environmental protection and societal and economic needs. Due to the phrasing of the questions, there are concerns that the answers from private forest owners and managers could be misinterpreted, particularly as the questionnaire provides only very limited possibility to address specific aspects of the Directives, particularly concerning the difficulties in their implementation.
When assessing the answers to the public consultation, the joint letter also underlined that it is also important to recognise and take into account that rural populations, particularly in remote areas, are less likely to respond to an online consultation. As those living in rural areas are most affected by the implementation of EU nature legislation, it is important that their concerns are taken into account by using other more effective tools.
As communicated in a Commission press release on 29 July 2015, more than 550 000 citizens and organisations responded to its public consultation on the fitness check of the Birds and Habitats Directives, a record number of submissions for a Commission consultation. CEPF regards this high response rate as rather critical, as more than 520 000 responses were generated through a web-based campaign by environmental NGOs, providing the Commission with a biased picture of the state of this key EU nature legislation if the responses are evaluated without balanced weighting.
Therefore the organisations called on the Commission to give special consideration to the answers provided by regional, national and European associations representing the actors in rural areas, such as forest owners.
In their joint letter, CEPF, together with Copa-Cogeca, ELO and USSE concluded that there is a real need for improving the implementation of the Birds and Habitats Directives, allowing for sufficient flexibilities and good governance in terms of stakeholder / land owner participation, as these conditions are essential for ensuring that the directives are indeed relevant, effective, efficient and coherent.