BirdLife Europe and Central Asia

BirdLife Europe and Central Asia welcomes this Directive as it sets to address the greenwashing we are currently attesting in every sector. Although the general direction of the law is the right one, we think that some aspects are either overlooked or need to be improved. Today there is a profusion of different labels, competing and adding more confusion to the consumer .

The proposed provisions in the Regulation for the speeding up of environmental assessments (part of the Environmental Omnibus package) risk fundamentally altering the architecture of EU environmental law and creating long-term systemic risks when it comes to nature and wider environmental protection, and access to justice.

Despite its existing framework to protect the marine environment, the EU is not on track to reach its environmental targets and to halt marine biodiversity loss by 2030 , due mainly to a lack of policy coherence, poor implementation, and siloed governance.

BirdLife Europe urges using nature-based solutions (NbS) for climate adaptation and disaster risk reduction, as recommended by the 2021 European Climate Risk Assessment. Nature is our best ally against effects of climate change by increasing resilience and providing many other societal benefits. Grey solutions risk having contrasting effects, while NbS reduce such risks.

Birdlife contribution to the call for evidence highlights the importance of grid modernisation to meet climate and renewable energy targets, while insisting that this must not come at the cost of nature. Grid expansion and upgrades must respect existing EU environmental legislation and actively contribute to biodiversity protection and restoration.

BirdLife Europe welcomes the application of the DNSH principle to the Multiannual Financial Framework. Effective DNSH implementation requires that EU spending contributes to climate and nature objectives, with robust, science-based criteria applied to all six objectives. All DNSH criteria must be met before EU funds are disbursed.

We welcome the Commissions initiative to set out a strategy for heating and cooling that delivers affordability, resilience and climate integrity. To achieve this, the strategy must put energy efficiency first, prioritise clean, non-polluting solutions, and avoid reliance on bioenergy. Heating and cooling account for half of the EUs energy demand, with 70% still met by fossil fuels.

Fishing remains a cultural and economic mainstay across Europe, but its survival directly depends on functioning ecosystems. The common notion of balancing environmental, economic, and social interests as equal pillars is misleadingenvironmental limits are not merely one consideration among others but the essential bedrock on which lasting social wellbeing and economic livelihoods depend.

The EUs forests are increasingly under pressure even though the area covered by forests is increasing. The current definition of forest can be misleading, as it can include land that is used, or has recently been used for agriculture, as well as monoculture non-native plantations and even tree-less areas (i.e., clearcuts where forest regeneration is planned).

BirdLife supports the prompt and effective designation and operation of RAAs in line with the more detailed comments in the attached document. This will require a step-change in the performance of public authorities and the renewables sector, with significant advances in public awareness, involvement and participation in the climate energy agenda in Member States.

MEMBER STATES NEED TO INCREASE THEIR LULUCF AMBITIONS. Data shows that the worrying declining trend of the LULUCF sink persists and Member States are not taking effective measures to reverse this . As a consequence, the EU is not projected to meet the 2030 obligations with existing measures in place .

Despite claims that the proposal is intended to benefit farmers, it primarily reduces administrative burdens for Member States while weakening the Commissions oversight of CAP spending and undermining key environmental safeguards - measures that ultimately do not serve farmers long-term interests.

The CAP, as the EUs main tool shaping land use, has a key role in addressing environmental and climate challenges. This is where it can bring clear EU added value, requiring coordinated EU action to protect shared natural resources and meet common environmental goals. It is also essential for the long-term viability and resilience of farming systems.

As the main funding mechanism aiming to ensure the long-term sustainability of EU fisheries, the EMFAF plays a crucial role in supporting the Common Fisheries Policy, effectively protecting the marine environment, and fostering the resilience of the fishing sector.