Feedback on National Restorations Plans’ format

The European Commission’s proposed uniform format for National Restoration Plans (NRPs) represents a thoughtful and comprehensive framework to support member states (MS) in achieving the ambitious targets set by the Nature Restoration Law (NRL). Nevertheless, reference to a core aspect that is key to the success of this Regulation is missing: youth. This omission is particularly significant, as young people will inherit the long-term consequences of environmental policies and have a crucial role to play in driving innovation, advocacy, and community engagement for successful restoration efforts. We therefore highly recommend the inclusion of the following:

Recognition of Youth Input in the Participation Process for NRPs

We propose adding a distinct priority under section 2.1, titled “Youth Participation,” within the “Public Participation” section. Young people’s lack of participation in environmental decision-making has been evident in the creation of National Energy and Climate Plans (NECPs). However, the NRL, and in particular, the NRPs, offer a valuable opportunity to address this gap by ensuring clear and dedicated participation pathways for young people within the NRL framework.

Following this, and for the purposes of Article 15(3(w)), we recommend more specificities to be added under Public Participation, such as subsections categorising the involvement of different stakeholders and the inputs they put forward. This way, the NRPs could provide a detailed explanation of the views expressed per category of stakeholder. We further recommend the addition of a section detailing the participation methods that the states followed (such as public consultations, multi-stakeholder group meetings, deliberations, etc…) and a short summary of each.

Youth Contributions to Restoration Targets

In addition to youth involvement in public consultations, we recommend that the NRP format include specific sections that highlight youth contributions to project implementation, citizen science, and advocacy efforts for restoration. For example, we suggest adding a new point (e.g., 14.5.5) to the format: “Describe the role of young people in the implementation of this measure.” This inclusion would support the alignment of restoration activities with national environmental citizen service programs or youth environmental corps, ensuring that young people are actively contributing to these important efforts.

Intergenerational Equity

We propose requiring MS to explicitly document how their plans address the rights of future generations. Intergenerational solidarity is recognised as a fundamental principle within the Treaty on European Union (TEU) and the Charter of Fundamental Rights. To incorporate this in NRPs and contribute to intergenerational equity, we suggest the following:

• Section 4.1.4: Include “intergenerational equity” as an example under “Other potential co-benefits.” Additionally, we support making this section mandatory instead of optional.
• Section 2.4: Introduce a new section titled “Consideration of Future Generations” to emphasize the importance of long-term planning.
• Section 14.3.4: Add a new section titled “Intergenerational Benefits” to highlight the advantages of prioritizing sustainability for future generations.

Environmentally Harmful Subsidies

In addition to Section 4.3.2, which gives an indication of the harmful subsidies that may negatively impact the achievement of the goals set under the regulation, we would like MS to explicitly include what actions are being taken to phase out the subsidies in question. We recommend expanding the section to include Subsection 4.3.2.1 titled “Actions taken to phase out environmentally harmful subsidies not in line with meeting the goals of the regulation”. In a parenthesis, examples can be included, such as “…(e.g. market-based instruments and green budgeting and financing tools)”. A reference to the supportive actions a state takes to phase out the specific subsidies, in line with the NRL Article 15(3(v)), would also be a useful addition to the format. This would also contribute to fulfilling Decision (EU) 2022/591 Art 3(2(h)),  according to which MS “shall identify other environmentally harmful subsidies and report them regularly to the Commission”. Incorporation of more information about environmentally harmful subsidies in the NRL would therefore have multiple positive effects. In support of the latter, we would also like to draw attention to Recommendation 9 of a joint CSO statement on the EU budget for biodiversity, which calls for the harmonisation of the identification of environmentally harmful subsidies, and of a reporting mechanism. Lastly, we would like to draw attention to point 3.2 of NAT/926 of the EESC’s own initiative opinion titled “A comprehensive strategy for biodiversity at COP16”, which highlights the urgency of phasing out environmentally harmful subsidies for the purposes of biodiversity governance.