11.6.2014   

EN

Official Journal of the European Union

C 177/84

1.1

The EESC welcomes the Commission communication and the desire to adopt an EU legal instrument, which is all the more necessary given the climate problems (natural migrations towards the north), but emphasises that the response may well appear overdue to those who raised alarms long ago. The EESC believes that the Commission would be advised to ensure that the actual title of the communication in the Unions' various languages meets with scientists' approval. The Committee prefers the term ‘espèces allogènes invasives’ (or ‘envahissantes’, EEE) for the French text.

1.2

The EESC believes that combating invasive species should be considered as a major European concern. It welcomes the Commission's commitment to introduce a general mechanism for combating invasive alien species. Nevertheless, the EESC advises it to explain the causes of these problems more clearly, in order to make clear the need for a large-scale mobilisation of stakeholders to provide all the relevant details to the body responsible for the question. The EESC also advises the Commission to point out the efforts already made in conducting experiments to combat the proliferation of introduced species that are problematic, such as the LIFE programmes. The Committee has doubts about limiting the list of invasive species to 50.

1.3

The EESC appreciates the Commission's desire to involve the public in combating the proliferation of alien species already identified. But the EESC would appreciate it if the Commission also called on the public to find out about and take part in preventive measures. The EESC also emphasises the important role played by civil society organisations, particularly in the management of natural or recreational areas.

1.4

The EESC thus calls on the Commission to examine the possibility of setting up a European invasive alien plant monitoring centre to be responsible for both the European scoreboard and for exchanges with countries outside the EU. What the EESC understands by a monitoring centre is a clearly identified focal point that would bring together scientists and the public by mobilising them on specific problems. It would then be possible to build on local initiatives and emphasise points of convergence in a modest publicity programme (Internet web pages). The EESC believes that setting up a monitoring centre responsible for managing horizontal and trans-disciplinary issues would probably encourage the required generalised mobilisation of experts, motivators on the ground and project promoters.

1.5

The EESC hopes that the mechanism will actually be presented during the European Parliament's current term of office, which would enable it to be operational before 2016. The monitoring system as proposed should be based on a validation by scientific communities and help to draw up a list of indicators recommended by the Convention on Biological Diversity, particularly those set out in target 9: ‘By 2020, invasive alien species and pathways are identified and prioritised, priority species are controlled or eradicated, and measures are in place to manage pathways to prevent their introduction and establishment.’ The EESC calls on the Commission to consider setting up, on the basis of Regulation (EC) No 338/97, a Scientific Study Group, which might amend the list.

1.6

The EESC welcomes the fact that the IAS issue is prompting the Commission to take an interest in derelict land (poor land, disused railway lines, etc.) which are often sources of infestation, pathways for dissemination and colonisation. The EESC hopes that efforts to eradicate problematic colonising species will make it possible to develop specialised companies and jobs.

2.1

The impact of invasive alien species (IAS) on biodiversity is significant. IAS are one of the major, and growing, causes of biodiversity loss and species extinction. When it comes to social and economic impacts, IAS can be vectors of diseases or directly cause health problems (e.g. asthma, dermatitis and allergies). They can damage infrastructure and recreational facilities, hamper forestry or cause agricultural losses, to mention but a few. IAS are estimated to cost the Union at least EUR 12 billion per year and this is continuing to rise (1).

2.2

Member States are already taking measures to tackle some IAS, but such action is predominantly reactive, seeking to minimise the damage already being caused without sufficient attention to prevention or to detect and respond to new threats. Efforts are fragmented, with substantial gaps in species coverage, and are often poorly coordinated. IAS do not respect borders and can easily spread from one Member State to another. Thus, action taken at national level will be insufficient to protect the Union from the threat of certain IAS. Moreover, this fragmented approach can lead to action in one Member State being undermined by a lack of action in neighbouring Member States.

2.3

This proposal aims to establish a framework for action to prevent, minimise and mitigate the adverse impacts of IAS on biodiversity and ecosystem services. Furthermore, it will seek to limit social and economic damage. This will be achieved through measures to ensure coordinated action, focusing resources on priority species and on increasing preventive measures, in accordance with the Convention of Biological Diversity approach and with the Union’s plant and animal health regimes. In practical terms, the proposal seeks to attain these objectives through measures addressing the intentional introduction of IAS into the Union and their intentional release into the environment, the unintentional introduction and release of IAS, the need to set up an early warning and rapid response system, and the need to manage the IAS spread throughout the Union.

2.4

The ‘Citizens' Summary’ which was produced after the consultation and is on the Commission website is clear.

3.1

The Commission is responding to the alarms raised by professional and amateur naturalists and frequently conveyed by journalists in all the media. The Commission is also responding to those in charge of regional authorities who have already begun to take action locally. The Commission is proposing a sensible application of the precautionary principle to draw up a prevention policy when a risk is established or a new problem identified. The Committee is particularly pleased that the communication is ambitious and fit for the enormous task in hand. On 11 June 2009, the NAT/433 opinion (2) was adopted completely unopposed. The Committee was already drafting considered recommendations at that time. It is unhappy that it is taking so long to implement biodiversity action plans, particularly when social or economic activities are underpinned by exceptional ecosystems.

3.2

The Commission proposal aims to use a regulation to launch the fight against any biological invasion, a phenomenon whereby introduced species proliferate and invade an area causing damage (definition of the International Union for Conservation of Nature (IUCN)). There are three kinds of damage: a threat to the biodiversity of our ecosystems, a threat in some cases to the health of certain groups of people, and a threat to certain economic activities. Cases of species from one region proliferating and causing a problem in another should be managed directly by the Member States. Problems caused by populations of catfish should thus be treated on a case-by-case basis, applying the subsidiarity principle.

3.3

The Committee has appreciated the educational work undertaken by the European Environmental Agency and DG Environment which recently published a thematic brochure on IAS (Science For Environment Policy: Thematic issue on Invasive Alien Species, 18/09/2013).

3.4

The Commission has chosen as its guiding principle an initial ceiling on the number of priority species of 3% of the approximately 1 500 invasive alien species established in Europe. The EESC notes that this choice is not founded on any scientific basis, but is imposed by limited funding. The EESC appreciates that the Commission is working at international level and is talking with Member States already geared up to manage IAS. The EESC calls on the Commission to consider setting up, on the basis of Regulation (EC) No 338/97, a Scientific Study Group, which might amend the list.

4.1

The Commission has carefully examined all of the problems. However, there would appear to be a problem of terminology in French (and perhaps in other languages). A distinction should be made between ‘espèce invasive’ (non-indigenous invasive species) and ‘espèce envahissante’ (indigenous invasive species): the former comes from elsewhere, whilst the latter could be an indigenous species with a reproductive potential that might disproportionately dominate an environment and thus impoverish it. If this definition were to be accepted, reassurances would be needed that the French title of the communication was accepted by all. The Commission has used the term ‘espèces allogènes envahissantes’ for the Citizens' Summary. It would thus seem necessary to make sure that the term ‘espèce exotique envahissante’, which is often used (for example, in Wallonia), does not trigger a negative reaction from certain biologists specialising in the area. The question concerning the French text should be raised for the other EU languages.

4.2

The communication should explain more clearly why the situation is so serious, particularly as it is getting worse. It is imperative to explain that proliferation essentially occurs when species are of no interest to consumers (predators), when they are not interfering with human activities (urban areas) and finally because they are spreading in areas that are difficult to access. In all of these cases, the problem relates to sources of infection: water primrose, water milfoil, Japanese knotweed, etc. in wet areas, and wild cane, buddleia, box elder, Japanese varnish tree, etc. more generally. On the other hand, the communication rightly points out that some species have been positively welcomed. In this respect, it is perhaps worthwhile bearing in mind that items brought in from abroad were valued because they had acclimatised: the false acacia (Robinia pseudoacacia) is still much appreciated: for stakes, sturdy wood for outdoor furniture, honey, etc. By contrast, it is unfortunate that Sosnowsky's Hogweed (Heracleum spp.) has spread through its use in silage, as its proliferation is threatening biodiversity and the toxin it secretes can cause severe burns.

4.3

The Commission does not sufficiently highlight the crucial environmental problems that have been clearly identified by the managers of the Natura 2000 sites, for example. The EESC wonders whether there is not an underlying feeling of guilt. NGOs remember calling in vain for years for bans on imports of exotic varieties of turtles. This request was only met when proof of reproduction in natural environments was provided. The EESC feels that this communication is long overdue, but welcomes the fact that it is never too late to do the right thing.

4.4

The Commission refers to legislation in other countries. This is all well and good, but why not state candidly that a decision has been reached to draw inspiration from best practices elsewhere. One international initiative is worthy of mention: Ragweed Day on the first Saturday in summer to combat the proliferation of allergenic plants (Ragweed (Ambrosia artemisifolia) is a colonising plant that grows on any land where competition is not unduly fierce. The EU has shown the way in industry by identifying and drawing on the best available techniques (BATs).

4.5

The Commission emphasises that ‘existing Union action leaves most IAS unaddressed’. The EESC deplores this situation as much as the Commission, but must remind it that the environment is supposed to be included in all sectoral policies. The EESC would appreciate it if the Commission could explain, for example, how the problem could be dealt with as part of the Common Agricultural Policy. For instance, the problem of grasslands invaded by water primrose (Ludwigia grandiflora) needs to be tackled.

4.6

The Commission has analysed the problem perfectly, but in an abstract fashion. The EESC wonders whether it might not be useful to illustrate the reasoning with examples, such as: the harlequin ladybird (Harmonia axyridis) or the wild black cherry (Prunus serotina) as an example of intentional introduction and Caulerpa taxifolia (killer algae) and the Asian predatory wasp (Vespa velutina) as examples of unintentional introduction. The current irresponsible introductions of catfish (a specific case of intentional introduction) should perhaps also be added. Failing that, the EESC advises the Commission to quote its own work (the excellent brochure published in May 2009) and add links to internet sites of interest.

4.7

The analysis of the models of proposals for a regulation is clear and the reason for choosing option 2.4 is obvious: it will be the responsibility of the Member States to act as soon as a new problem is identified (transmission of information, analysis of the situation, proposed action).

4.8

The legal elements appear to be appropriate and the proposal must make it possible to address any situation past, present or future. The Committee has doubts as to whether it is legitimate to limit the list of invasive alien species potentially harmful for the Union to a maximum of fifty species.

4.9

However, the financial analysis seems too optimistic. When the mechanism becomes operational, the upward flows of information will actually be such that the dedicated service will have difficulty in processing all the information, in which case the Commission will have to pay the price for its own success!

4.10

At the present stage, not all the details are settled and it will be the task of Member States to come up with a practical response to the various issues, the most frequent undoubtedly being the most appropriate means for destroying a living species. The EESC fears that this might give rise to local disputes.

4.11

The question of information and public involvement is included in chapter 5 of the proposal when cross-cutting aspects of the problem are addressed. Prevention cannot be the exclusive domain of specialists. The EESC would like to point out that alerts are often raised by local stakeholders and sent directly to governments and/or to DG Environment. It would seem sensible that requests from members of the public — who often have no contact with research bodies, even though the latter frequently call on them to provide them with data — might also be able to make an active contribution. Moreover, the case of the Asian predatory wasp epitomises the problem very well: it competes with the European wasp, it stings and is a predator of bees close to their hives. Members of the public tried every possible method for eliminating the invader, then — accepting that it was impossible — tried to find a sufficiently clean chemical option (SO2), only finally to discover that it was enough to station chickens around hives to provide a biological defence. The EESC thus calls on the Commission to involve as many members of the public as possible via their organisations (unions, NGOs, etc.).

4.12

Application of the regulation (Article 27) seems satisfactory inasmuch as the EU should not repeat the same timetables that caused problems for other products, such as certain chemical products. The destruction of species of no great commercial interest and amendment of the authorisation process for others seem well thought out.