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.
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.
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.
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
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
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
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
A commitment should be undertaken
to pursue the reduction of market protection through export subsidies
and import levies in the forthcoming World Trade Organisation
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
De-coupling agricultural support
from production, addressing the decline of rural economies, promoting
sustainable forms of agriculture, creating jobs and safeguarding
Shifting funds to a new integrated
rural policy that delivers support to rural communities, including
farmers, and that promotes diversification of sustainable rural
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
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
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) policyincluding
the review of the 1996 TEN-T Guidelinesrather 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
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
Communication from the Commission to the Council and the European
Parliament on A European Community Biodiversity Strategy. COM
(1998) 42 final. Back
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