Select Committee on Environmental Audit Appendices to the Minutes of Evidence


Memorandum from the Royal Society for the Protection of Birds


  The Royal Society for the Protection of Birds (RSPB) is Europe's largest wildlife conservation organisation with over 1 million members. In encouraging the conservation and protection of wild birds and their habitats, the Society takes an active interest in a wide range of issues relating to environmental integration in the EU, and employs specialist staff to advise on such matters.

  The RSPB is also the UK Partner to BirdLife International, a global partnership of conservation organisations focused on the protection of wild birds and their habitats. The RSPB plays an active role in a range of BirdLife sectoral policy task-forces, working with its partners across the EU to influence the work of the European Commission, the European Parliament and the Council of Ministers.


  The RSPB welcomes the opportunity to give evidence to the Environmental Audit Committee inquiry into EU Policies: Environmental Integration. This evidence draws upon the science-based policy and advocacy experience of RSPB's policy specialists and upon their collaborative work with fellow BirdLife Partners across the European Union.

  Our submission will provide some introductory comments on the recent history of the integration process in the EU, followed by a summary of general, cross-cutting and sector-specific recommendations. An annex contains a sector by sector analysis of progress to date and detailed recommendations for future action. We restrict our comments to sectoral areas where the RSPB and BirdLife have been most closely involved, namely: Agriculture, Development, Enlargement, Energy, Transport, and Fisheries.

  Environmental and biodiversity indicators, such as the populations of many species of birds, are showing serious and long term declines across Europe[1]. The reasons for these declines are complex but linked by a common theme, the current rapid changes in land and sea use which are placing unsustainable pressures on ecosystems and natural regenerative biological cycles. The integration of environmental considerations into all areas of policy is a manifest necessity if this downward spiral is to be halted and reversed.

  The process of EU environmental integration was launched at the Luxembourg Summit in December 1997. The process became know as the "Cardiff process", following the Cardiff Summit in which the European Council invited all relevant sectoral Councils to establish their own strategies for integrating environment and sustainable development within their policy areas. The Transport, Energy and Agriculture Councils were asked to start this process. Following the Vienna Summit, integration plans were invited from the Development, Internal Market and Industry Councils with special additional emphasis on the impacts of climate change as well as employment and enlargement.

  The Cologne European Council considered reports from the sectors above and went further, calling upon the Fisheries, General Affairs and EcoFin (Finance Ministers) Councils to report back to it in 2000 on the integration of environmental issues and on sustainable development in these sectors.

  The next few months offer an unparalleled opportunity for the EU to chart an environmentally, socially and economically sustainable path into the next millennium. The Helsinki Council Meeting on 11 and 12 December 1999 represents the next milestone in this process, at which the European Council will review the overall progress on integrating the environment and sustainable development in order to link the sectoral strategies developed by the various Councils. It will also consider a co-ordinated report on indicators for the various sectors as well as the global assessment of the 5th Environmental Action Programme.


General Recommendations

  The RSPB believes that the UK Government should press for the following actions and measures in order to integrate environmental considerations effectively into EU policy:

    —  Specific means of protecting and conserving Europe's biodiversity should be identified within sectoral plans. There is already a requirement for most sectors to produce biodiversity action plans under the EC Biodiversity Strategy[2].

    —  It should be recognised that those short strategy papers which have already been produced for some sectors, such as agriculture and transport, are wholly inadequate and the deficiencies remedied.

    —  A clear vision of what the EU means by sustainable development must be articulated, with clearly defined and measurable objectives, coupled to a firm timetable for implementing integrated sectoral and cross-sectoral plans.

    —  The key problems and obstacles to achieving the vision must be clarified, as well as opportunities. All strategies should address the EU footprint outside its boundaries and address policy coherence between sectors, as well as the EC's contribution to the achievement of the International Development Targets[3].

    —  Appropriate structures, processes, instruments and funding should be established for ongoing co-ordination, monitoring, assessment and reporting on integration.

    —  Appropriate public and private sector players should be encouraged and enabled to help realise the vision. The UK Government should take the lead by encouraging dialogue in the UK about its position at the various Councils.

    —  Full endorsement should be given to the principles of: the precautionary approach, the use of targets and indicators, strategic environmental assessment of all policy making, de-coupling economic growth and resource use, establishing environmental liability and producer responsibility, and resource use taxation.

    —  There should be an acknowledgement of the potential need for regional strategies for accession countries in an enlarged EU.

    —  It should be recognised that environmental integration cannot take place without appropriate funds being available to implement environmental objectives and obligations. In the case of nature conservation for example, there is a massive shortfall in funds required to fully implement the Natura 2000 network under the Birds and Habitats Directives.


  The following sections contain specific recommendations which we believe the UK Government should press for to be included in the relevant sectoral integration strategies.


  For the effective implementation of existing policy instruments the UK Government should press for the strategy to contain the following recommendations.

    —  Mandatory Cross-Compliance measures should be applied in all Member States. Payments should be withdrawn where appropriate environmental conditions are not respected.

    —  Member States should make effective use of the National Envelopes to support extensive farming systems.

    —  Member States should implement the Rural Development Regulation, allowing the full participation of environmental NGOs in the appraisal of rural development plans.

    —  Priority should be given to supporting rural development projects with clear environmental and socio-economic benefits.

    —  Member States should increase the funding of agri-environment measures and give more support to conversion to organic food production. Agri-environment measures should be primarily funded in areas where the Community has defined a priority of interest, including SPAs (Special Protection Areas) and SACs (Special Areas of Conservation).

    —  The Commission should enforce the full implementation of the Nitrates, Habitats, & Wild Birds Directives as required by EU environmental legislation, with no further delays.

    —  A commitment should be undertaken to pursue the reduction of market protection through export subsidies and import levies in the forthcoming World Trade Organisation round.

    —  The Precautionary Principle should be applied in order to ensure that no genetically modified organisms are released into the agricultural environment until the potential risks to biodiversity have been rigorously assessed.

    —  Funds for LIFE-Nature projects in agricultural areas should be increased.

    —  The Water Framework Directive should be used to ensure the sustainable use of water in agriculture.

  The UK Government should also press for the agriculture integration strategy to address the next round of reforms to the Common Agricultural Policy, giving priority to:

    —  De-coupling agricultural support from production, addressing the decline of rural economies, promoting sustainable forms of agriculture, creating jobs and safeguarding the environment.

    —  Shifting funds to a new integrated rural policy that delivers support to rural communities, including farmers, and that promotes diversification of sustainable rural activities.

    —  Increasing the level of funding and expanding the coverage of agri-environmental measures to address specific environmental needs, and creating an effective monitoring system on the environmental benefits of the schemes.

    —  Eliminating competition for funding between different measures (eg the agri-environment regulation 2078/92 and the afforestation regulation 2080/92) by prescribing a balance of funding for different activities.

    —  Undertaking strategic environmental assessment of policy reforms; future reforms of the CAP should have a thorough assessment of their environmental impact on biodiversity and landscape, as well as on the social and economic aspects of proposed changes.


    —  The UK Government should consult stakeholders in the UK on the Commission's strategy so that it can take these views into account in its position at the Development and Helsinki Councils.

    —  The integration strategy should set out a timetable for the drafting of an environmental policy to be applied to development co-operation which should be subject to consultation and be a key element of the Commission's overall development policy to be adopted in 2000.

    —  The Commission should increase the number of staff with environmental expertise through recruitment, re-organisation and reform of the development DGs and training. This expertise will be needed in the delegations as well as in Brussels.

    —  The integration strategy should contain a commitment to annual reporting on the implementation of the strategy, including indicators and targets (covering number of staff with environmental expertise, the proportion of resources allocated to environmental projects, application of environmental impact procedures, and direct measures of the environment such as CO2 emissions, deforestation, water reserves, etc). This could form part of the overall annual report on EC development assistance which has been called for by the Development Council.

    —  Environmental targets and indicators should be included in country strategies, in sectoral communications such as the proposed Commission Communication on Forests and Development and in the project cycle. These should not be confined to the small number of projects which have environmental protection as their principal objective.

    —  The integration strategy should make a commitment to maintain separate environmental budget lines until significant progress can be demonstrated on mainstreaming of the environment into other development co-operation spending. Amalgamating budget lines should also be conditional on the implementation of a clear system for tracking environmental spending on projects, including those with multiple objectives.

    —  The integration strategy should include joint measures on policy coherence with other DGs to address the impacts of the EC's other policies on development co-operation, particularly agriculture, fisheries and trade.


    —  Projects funded by the Instrument for Structural Policies for Pre-Accession (ISPA) Regulation should be subject to rigorous environmental impact assessment.

    —  Projects supported by Special Action for Pre-Accession measures for Agriculture and Rural Development (SAPARD) should stimulate rural economies, create jobs and safeguard the environment, helping to maintain the numbers of people working and living in rural areas.

    —  A significant percentage of SAPARD funds should be allocated to agricultural activities that protect or enhance the environment.

    —  The proportion of funding for biodiversity projects and projects to build the capacity of NGOs in accession countries should be increased significantly under PHARE. PHARE is the major EU institution-building and investment fund.

    —  Extra Community funds should be allocated to collect, analyse and document data with respect to potential candidate Natura 2000 sites under the Birds and Habitats Directives.


    —  A timetable for implementing energy saving measures should be drawn up in all sectors. Zero cost or net benefit options exist for between 10 per cent and 20 per cent emission reductions in almost all states.

    —  A timetable should be established to reduce and eventually abolish all subsidies on fossil fuels.

    —  Measures should be identified and implemented to deploy increased renewable electricity generation capacity. EU policy to have 12.5 per cent of renewable electricity generation by 2010 should be implemented. For renewable thermal systems, such as biomass burning, generation capacity based on combined heat and power should be strongly encouraged.

    —  An EU wide energy tax should be developed and implemented as soon as possible.

    —  The EU should insist on capping the ability to trade emissions under the Kyoto Protocol at 50 per cent of the total required reduction and should make every effort to exceed its own 8 per cent emission reduction target.

    —  The EU should push hard for an international commitment to greater cuts in the near future.


    —  Environmental concerns should be placed at the centre of the Common Transport Policy (CTP) and Trans-European Transport Network (TEN-T) policy—including the review of the 1996 TEN-T Guidelines—rather than being viewed or treated as an "add-on", as has historically been the case.

    —  The Strategic Environmental Assessment (SEA) of the TEN-T a whole should be completed as soon as possible. The Commission should also carry out an SEA of the planned extension of this Network into the accession countries, (ie the TINA) before works actually begin.

    —  For the purposes of sustainable development, there is a need for a broad set of indicators which take into account transport intensity, land use patterns, severance effects, etc, as well as more conventional indices of either transport volumes or environmental impacts.

    —  It is essential that TEN-T and TINA developments be compatible with existing EU environmental legislation, notably the requirements of the Birds and Habitats Directives and the setting up of the Natura 2000 network.

    —  The integration strategy for the transport sector should cover the main EU sources of transport funding: the European Investment Bank, the Structural Funds, the Cohesion Fund and the Instrument for Structural Policies for Pre-Accession (ISPA).

    —  Measures should be developed to cut emissions from transport, by discouraging the use of cars and trucks and encouraging the greater use of public transport, especially trains. In particular, air transport, the fastest growing emission sector, should be subject to a fuel tax. (International aviation and marine "bunker" fuels are currently tax-exempt.) As a first step towards imposing a levy, the EU must resolve the bunker fuel emission allocation issue in the Climate Change Convention process, NOT in ICAO or the IMO.


    —  Detailed strategies should be established for integration, along with implementing guidelines, a timetable for fulfilling strategies, and indicators for monitoring progress.

    —  The application of the Precautionary Approach should be given priority, along with the development of an Ecosystem Approach to fisheries management, not just in Community waters but also in third country waters.

    —  A commitment should be made to establish a regime at whose core is the delivery of environmental objectives through the revised CFP.

    —  A strategic shift should be made towards sustainable development in all aspects of the CFP and to have kindred strategies on (notably) markets, structural funds and external policy. This will require a substantial shift in resources away from investment in increased capacity and towards traditional, smaller-scale vessels and gears.

    —  A commitment should be given to the application of greater environmental provisions and safeguards to all fisheries structural measures, requiring a broader set of indicators for sustainability.

1   Tucker G et al (1994) Birds in Europe, their conservation status. BirdLife International Conservation Series No 3. This study revealed that 195 species (38 per cent of the European Avifauna) have an unfavourable conservation status. See also, European Environment Agency (1999) Environment in the European Union at the turn of the century. This not only reports on past trends but provides an assessment for the future. It highlights that major barriers remain to environmental improvement. Back

2   Communication from the Commission to the Council and the European Parliament on A European Community Biodiversity Strategy. COM (1998) 42 final. Back

3   The International Development Targets draw on major UN Conferences and recognise that poverty reduction requires action on a wide range of fronts including access to education, gender equality and the environment. They have been adopted by the OECD's Development Assistance Committee and are included in the DFID White Paper on International Development. Back

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