The SERE Legal Working Group (LWG) has provided in-depth feedback on the Draft Regulation for a Uniform Format for National Restoration Plans by the European Commission, emphasizing the need for a strong, science-based, and transparent framework to ensure the successful implementation of the Nature Restoration Law (NRL). Our recommendations highlight critical gaps in the current draft and propose concrete solutions to enhance its effectiveness.
Key Comments & Recommendations:
Scientific Basis & Clarity
- National restoration plans must be explicitly grounded in scientific evidence, as required by the NRL, to ensure restoration efforts are effective and measurable.
- Optional fields in the format should align with legal obligations to avoid gaps in compliance, as flexibility should not come at the cost of accountability or scientific rigour.
Regional Considerations & Public Participation
- Federal states require a more regionally flexible approach to restoration planning, as biodiversity policies are often implemented at the regional rather than national level.
- Stakeholder engagement must be transparent, inclusive, and meaningful, with early public access to draft plans, ensuring that civil society, scientists, and policymakers can contribute effectively before decisions are finalised.
Targets, Mapping & Financial Planning
- Clear guidance is needed on what qualifies toward the 20% area-based restoration target, as ambiguity could lead to inconsistent reporting and ineffective restoration strategies.
- Mandatory, precise mapping should be included for ecosystems, urban greening, and river restoration to enable effective monitoring and assessment of restoration progress over time.
- Stronger provisions on phasing out harmful subsidies and aligning restoration plans with the Common Agricultural Policy (CAP) are necessary, as conflicting subsidies could undermine restoration efforts if not addressed in a systematic transition plan.
Legal & Policy Alignment
- Automatic adoption of existing national data from the Habitats and Water Framework Directives must be evaluated for scientific validity, as outdated or incomplete data may not reflect current environmental conditions.
- Specific non-deterioration measures should be required, rather than broad “approaches,” to ensure that restoration gains are protected and maintained in the long term.
- Transboundary ecosystems demand coordinated restoration efforts between neighboring countries, as fragmented policies could result in inconsistent outcomes and reduced ecological effectiveness.
Conclusion
The SERE Legal Working Group urges policymakers to refine the draft regulation to ensure national restoration plans are scientifically robust, legally enforceable, and effectively coordinated. Strengthening these provisions will be key to achieving the ambitious goals of the Nature Restoration Law and ensuring Europe’s ecosystems are restored for future generations.
