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European Commission
Commissioner Karmenu Vella
September 18th 2015
Fitness Check of the Nature Directives
Dear Commissioner
On behalf of the Nature Conservation societies in Denmark, we first would like to thank you, as
representative of the European Commission, for your institution’s efforts towards protecting
and improving our nature in Europe, especially within the framework of Natura 2000.
We are pleased to note that reports and evaluations on efforts under the Birds- and Habitats
Directives show that, where management obligations are taken seriously by authorities, the
efforts undertaken within the framework of the Nature Directives yield positive results.
As environmental NGOs we are very much aware of any potential and actual conflicting inter-
ests between nature protection efforts and the interests of the business community, especially
in the sectors of agriculture, forestry and fisheries. As the Birds Directive dates back to 1979,
and the Habitats Directive to 1992, it has obviously been a long and hard road to achieve the
buy-in of various stakeholders and put the necessary measures in place to reach set manage-
ment targets.
The Directives are a means of ensuring similar nature management efforts among Member
States, establishing a much needed level playing field ensuring that no Member State can se-
cure a short-term competitive advantage at the expense of its wildlife. Changing the scope of
management efforts, and thereby changing the long term efforts of most Member States so
far, would be to change the rules of the game in the middle of the game.
We are nevertheless acutely aware of the important challenges both Member States and indi-
vidual landowners may face in living up to their management targets and obligations.
In this context we particular welcome the Commission’s efforts to mitigate unintended side
effects and unfair consequences on individual farmers, foresters and fishermen. We believe
that the persistent lack of concrete and significant positive incentives for "housing" and man-
aging nature is the main cause of the persistence of conflicts between nature management
under Natura 2000 and the business community.
We therefore strongly recommend that the EU in particular intensifies its effort to improve the
state of Europe’s threatened biodiversity by meeting its commitment to eliminate incentives
harmful to biodiversity, and apply positive incentives in alignment with Aichi Target 3 in the
decision X/2 Strategic Plan for Biodiversity 2011-2020 under the CBD.
Conflicts between business and Natura 2000 obligations and efforts would obviously be signifi-
cantly reduced, if farmers and foresters were given more positive incentives, at similar levels
across all EU Member States.
c/o: Danmarks Naturfredningsforening
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Masnedøgade 20
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2100 København Ø
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Tlf. 39 17 40 00
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