Nature restoration targets under EU biodiversity strategy
Oesterreichs Energie fully supports the European Green Deal and its initiatives and stresses the importance to tackle the twin challenge of biodiversity and climate change. Binding EU-targets for nature restoration could help restoring the EU's ecosystems, but should go hand-in-hand with the urgently needed acceleration the roll-out of of renewables and be fully in line with existing environmental legislation.
We therefore would like to highlight the following key aspects of the European Commission's proposal for a Regulation on nature restoration:
The proposed Regulation on nature restoration should contribute to the achievement of the EU's climate and energy targets. The Commission's proposal for a Directive amending Directive (EU) 2018/2001 ("RED II") on the promotion of the use of energy from renewable sources requires Member States to identify "renewables go-to areas" - priority areas for renewables projects. According to the Commission's proposal, protected areas should be avoided when designating renewables go-to areas. However, as the objective of go-to areas is an acceleration of the approval procedures, areas outside “go to areas” should also benefit from faster permit-procedures and shall not be negatively affected. For projects outside of “go to areas” the approval procedure should continue to be done on a case to case basis, no matter if it is inside or outside a protected area. We therefore would like to highlight the importance of taking a holistic view, considering the impacts of new environmental legislation on the achievement of our climate and energy goals. The designation of renewables go-to areas should hence not exclude projects in protected areas; Member States should decide on a case-by-case basis whether to build a project by recognising renewable energy as an overriding public interest.
Targets and measures for freshwater systems in the Regulation on nature restoration should be fully coherent with existing environmental legislation (i.e. the Water Framework Directive, "WFD"). Member States define measures in River Basin Management Plans ("RBMP") to achieve the targets of the WFD. Oesterreichs Energie and its members actively support the implementation of the WFD's targets and continuously improve environmental restoration and compensation measures. Investment and planning decisions, however, require clear and coherent legislation. The WFD with its RBMPs provides a clear framework with EU-wide binding targets for freshwater ecosystems. Additional requirements in national restoration plans, however, could hamper the practical implementation of existing environmental legislation. We hence call for effectively implementing the WFD at Member States' level instead of defining additional obligations to restore freshwater ecosystems through an EU-wide Regulation on nature restoration.
Freshwater ecosystem restoration targets and measures should be based on objective evidence and promote measures that have a scientifically documented benefit to ecosystems. Annex VII of the proposal includes a list of examples of restoration measures Member States should make use of when drafting national restoration plans. Many of these measures could have negative effects on the operation of hydropower plants, i.e. a decrease of hydropower generation and flexibility. For some measures in Annex VII, research projects funded by a governmental department and the hydropower sector are currently exploring cost effective and ecological-effective implementation. We therefore would like to highlight the importance of clear guidance based on objective evidence prior to implementing measures that would have negative effects on renewable power generation.
Finally, we would like to highlight that restoration measures should not have adverse effects on renewable energy generation technologies, including hydropower. With the WFD, a broad legal framework for management of freshwater bodies is already in place, additional targets and measures for management of freshwater bodies as included in the proposed Regulation on nature restoration could hinder the urgently needed acceleration of renewable power generation in the EU.