Registrationnumber:M2022/01470
European Forum of Northern Sweden (EFNS) is a network for politicians at the local and regional lev- els from Norrbotten, Västerbotten, Jämtland Härjedalen and Västernorrland. EFNS is a meeting place and knowledge arena where EU policies are analysed and discussed in respects where it affects north- ern Sweden. EFNS monitors European issues to influence EU legislation, EU strategies and action pro- grammes, and the EU budget. The purpose of EFNS is to safeguard the interests of northern Sweden both in the European arena and in relation to national level issues with a clear European perspective.
EFNS agrees with the need to protect ecosystems, ensuring functioning ecosystems and biodiversity gains. However, we question whether the European Commission’s proposal for legally binding and detailed objectives for restoration of nature is in fact a legislation that is both effective and reasona- ble.
The proposal concerns all types of land areas, i.e. forest, soil and water. These are already regulated by national legislation and are oftentimes an important resource in local business activities, such as forestry and agriculture.
EFNS finds that the proposed legislation stands the risk of clashing with the right of ownership and use, the municipal self-government and the planning monopoly, national targets on fossil independ- ence, bioeconomy growth, agricultural policy, food strategy and national self-determination in forest matters.
EFNS would like to share our standpoints in short:
The EFNS positions in brief:
- Self-determination in forest-related matters. We support the Swedish Parliament’s objection as of 21 September 2022 that the proposal violates against the principles of subsidiarity and proportionality.
- Definition of restoration. Ecosystem restoration should be about restoring ecosystems’ abil- ity to deliver benefits, such as biomass, agricultural products, habitats or biodiversity.
- The problem with percentages. Several of the objectives of the law proposal are set in per- centages instead of absolute figures. This can entail disproportionate consequences in cases where a city, region or country already performs well within a certain area.
- Uncertainty with reference levels. EU countries’ reporting of biodiversity, habitat and defini- tion for share of protected forest land area should be calculated on the same premises in all Member States in order to be comparable.
- The need for a productive rural area. In troubled times of energy scarcity, scarcity in fertiliz- ers and increasing food prices, EFNS considers it irresponsible to propose shutdowns and conversions of productive land.
Self-determination in forest-related matters.
According to our EU-treaty, forests are a national concern. EFNS supports the Swedish Parliament’s objection as of 21 September 2022 that the proposal on the restoration of nature violates against the principle of subsidiarity.
EFNS supports the Swedish Parliament’s statement that the proposal entails a detailed regulation of agriculture and forestry that is disproportionate to the proposal’s specific objectives and overall pur- pose. We believe that efforts to increase biodiversity linked to land use should be carried out in co- operation with local forces and with respect for local knowledge, ownership rights, and use rights.
Definition of restoration
There has been a gradual shift in the definition of ecosystem restoration by the European Commis- sion. It has previously applied to ecosystems that have been damaged and need to be restored. In the proposal, however, the balance has shifted to the fact that restoration can imply that well-func- tioning productive land is taken out of use to create “nature”. We believe that this needs to be clari- fied. Ecosystem restoration should once again be about restoring ecosystems’ ability to deliver one or more benefits, such as biomass, agricultural products, habitats, biodiversity or other biobased re- source benefits.
The problem with percentages
Several of the proposed objectives are set in percentages instead of absolute figures. This setup can entail disproportionate consequences in cases where a city, region or country already performs well within a certain area, considering that the requirements for a marginal percentage increase will be significantly higher for the top performers. Sweden already has municipalities with vast green spaces. Increasing the green space area by, for instance, five percent can simply be unfeasible. According to the same logic, a city in central Europe with a very low share of green spaces will have very low de- mands for change. Sweden is a sparsely populated country, consisting predominantly of forests, lakes, streams and mountains. Despite this, according to the proposal, Sweden has been burdened with more than twice the cost for restoring nature as compared to other EU Member States, i.e.0.13 % of GDP (EUR 638 million) for Sweden compared to 0.06 % of GDP, which is the EU average.
Uncertainty with reference levels
EFNS believes that the status reporting of biodiversity, habitat and share of protected forest land area by all Member States should be calculated on the same premises. Today large differences arise when Sweden reports losses vis-à-vis pre-industrial times, while many other EU Member States re- port with the 1950s as the base reference. With the current Swedish choice of reference level, Swe- den appears to be performing worse compared to several other countries. The proposal from the Eu- ropean Commission therefore risks leading to disproportionate consequences when they are based
on such different reference levels. As such, reporting related to the proposal on nature restoration needs to be harmonized across EU Member States.
The need for a productive rural area
In troubled times of energy scarcity, scarcity in artificial fertilizers and expected problems within the food supply, EFNS considers it irresponsible to propose shutdowns and conversions of productive land. On the contrary, we need to expand areas mainly aimed at food production. Farmland in north- ern Sweden currently accounts for less than two per cent of the total land area and is scattered in an otherwise dominant forest landscape. Declining profitability has for a long time led to closure of farms and a decrease in agricultural land. Large numbers of species depend on the small-grown agri- cultural landscape, while grazing animals help create some of our species-richest soils and contribute to biodiversity. We wish to emphasize the great importance of northern Sweden’s agriculture and the fact that increasing food production in northern Sweden goes hand in hand with the protection of biodiversity. Overgrown arable land needs to be taken back into production.
Adopted by European Forum of Northern Sweden on 14 October 2022
Glenn Nordlund (S) President EFNS,
Region of Västernorrland
Åsa Ågren Wikström (M)
Vice president EFNS, Region of Västerbotten
Jonny Lundin (C)
Region of Västernorrland
Erik Lövgren (S)
Association of municipalities, Region of Västernorrland
Rickard Carstedt (S)
Region of Västerbotten
Ann Åström (S)
Region of Västerbotten
Nils-Olov Lindfors (C)
Region of Norrbotten
Britta Flinkfeldt (S)
Municipalities of Norrbotten
Anders Josefsson (M)
Municipalities of Norrbotten
Elise Ryder Wikén (M)
Region of Jämtland Härjeda- len
Robert Uitto (S)
Region of Jämtland Härjedalen
Jonas Andersson (S)
Municipalities of Jämtland County
Daniel Danielsson (C)
Municipalities of Jämtland County