Healthy and productive ecosystems are a prerequisite for a continued green transition in harmony with nature. However, increasing demands for space (such as renewable energy, industry, raw materials, food production, urban- and rural development, infrastructure, housing, recreation) can negatively influence nature and ecosystems. Therefore, nature restoration is important for preserving and enhancing biodiversity, delivering ecosystem services, ensure ecosystem resilience and respond to the ongoing climate challenges.
To achieve nature restoration objectives, nature restoration measures should be cost-effective and targeted where they will have the greatest impact. Due to the high diversity of challenges that Member States face in relation to biodiversity loss, they should be provided with more flexibility and authority to prioritize restoration in their own areas. This should lead to a balance between nature restoration and socioeconomic challenges that allows the restoration of nature and the development of a strong economy.
A careful legal and factual examination of ecological as well as other socioeconomic interests is necessary in order to achieve this goal. However, we do not see this adequately reflected in the proposed NRR. The mandatory legal provisions outlined in the regulation will impede (economic) activities needed to realise important ambitions related to renewable energy, industry, raw materials, infrastructure and housing. Since every Member State faces different challenges when it comes to biodiversity loss, more flexibility must be allowed for Member States to prioritize restoration needs based on national circumstances.
In addition, we need to make sure that the objectives within the Nature Restoration Regulation do not lead to conflicts with ambitions and goals within different EU-legislations such as, the Net Zero Industry Act, Critical Raw Material Act and Renewables Directive.
We are concerned that the regulation risks Europe’s competitiveness, growth, self-sufficiency and green transition.