Feedback from:
Bioenergy Association of Finland

Feedback reference

Submitted on
20 January 2020

Submitted by
The Bioenergy Association of Finland

User type
Business association
Bioenergy Association of Finland

Organisation size
Micro (1 to 9 employees)

Transparency register number

Country of origin

Safeguarding nature – EU 2030 biodiversity strategy

An official website of the European Union How do you know?
We support the proposed roadmap for preparation of the biodiversity strategy. It is
important that the EU addresses the remaining challenges in a well-prepared,
targeted, balanced and cost-effective way. In order to reach this, Member States
should actively participate in a bottom-up approach.

1. Effective implementation of existing EU-policies should be ensured.
2. The new strategy should take into account the current differences in percentage and
quality of protected lands in different Member States. It is also vital to recognize the
differences of Member States with regard to the economic role of managed forests and
their role for energy security.
3. The strategy should address synergies and trade-offs with e.g. climate change
4. The strategy should make full use of and build on voluntary certification systems
already widely in use and acknowledged by different interest groups. The established
certification systems can greatly benefit the EU 2030 biodiversity strategy e.g. by their
continuous updating processes and dialogue with important stakeholders of
5. Irrespective of whether the actions to improve biodiversity are based on legislation
or on voluntary actions we need effective financing instruments to speed up the
actions. Increasing biodiversity in parallel in conservation areas and in forests and
agricultural land that are in economic use can provide faster and deeper results. We
support enabling “the implementation of the strategy by securing adequate financial
resources, improving knowledge and engaging citizens and stakeholders across
sectors. “ We see the need to further develop models and incentives for farmers and
forest owners that can create the necessary push. The EU could look into the
possibilities to establish a fund with private investors to finance acquisition of new
conservation areas. This way participation to protection of biodiversity could be fair,
market-based and more equitably dispersed between EU member states.
6. We also support the target to “promote the sustainable use of forest, agriculture,
marine, freshwater and urban ecosystems”. Several pieces of legislation already
contribute to this direction, but it can take some time to get the results in our nature.
The EU’s land use is facing multiple challenges simultaneously: climate change
mitigation, biodiversity loss and urbanisation to name few. It is not an easy task to
solve all of the issues on the same land area. Land use planning needs a multidisciplinary
approach where synergies are considered. New digitalised systems can
help in adding several layers of data and optimise the land use based on the best
available information and local and national decisions.
7. In our understanding there are large differences in up-to-date information on
biodiversity development across Europe. This is an obstacle to effectively plan and
monitor actions, and the quality of the data is key in any new strategy. It is crucial to
improve the quality with the best available technology and secure a race to the top vs.
a race to the bottom in that regard in EU member states.
8. Finally, we would like to draw attention to the possible risk of externalisation of
biodiversity effects outside the Union. We encourage to deepen understanding and
cooperation on statistics of consumption and the related external effects.