On 19 August, nine environmental non-governmental organisations (ENGOs), including Palombar – Conservation of Nature and Rural Heritage, submitted a joint contribution as part of the public consultation on the draft National Nature Restoration Plan (PNRN), in which they set out proposals, recommendations and warnings. One of their main concerns is the gap between existing needs in terms of ecological restoration and the measures proposed to achieve it.

The organisations involved in the initiative (Palombar, GEOTA, FAPAS, LPN, Quercus, SPEA, WWF Portugal, Sciaena and AEPGA) recognise the importance of the National Nature Restoration Plan and the technical work carried out over the past year, which has been put forward for public consultation. The proposal brings together relevant information, acknowledges gaps in knowledge and incorporates essential principles for the plan’s development, such as the recognition of the importance of natural regeneration, soil and water protection, ecological connectivity and community involvement in the development of restoration initiatives. This starting point, however, has not yet been consistently translated into decisions, responsibilities, timetables, funding and verifiable results.

The main concern is the gap between the assessment and implementation. In the documentation submitted for public consultation, 188 of the 406 restoration measures have unknown areas or scopes of application, whilst the sources of funding broken down by measure have not been made available. In many cases, it is also not possible to clearly link each action to the pressure it aims to reduce, the habitat and territory covered, the responsible body or the expected ecological outcome.

This lack of a clear framework may lead to research and planning activities, existing instruments or routine management operations being counted as restoration. A new afforestation project, a supported agricultural practice or a post-fire intervention, for example, do not in themselves constitute nature restoration initiatives. For this to be the case, an additional ecological improvement compared to the initial situation must be demonstrated, and its maintenance over time must be guaranteed.

River Connectivity and Floodplains

With regard to rivers and floodplains, inventories of barriers, ichthyofauna and hydromorphological conditions remain incomplete and poorly harmonised. The methodology focuses primarily on the longitudinal movement of fish, paying less attention to the connections between rivers and floodplains and aquifers. The organisations propose common national protocols, field surveys and the complementary use of technologies such as LiDAR and environmental DNA, as well as a technical framework capable of coordinating river inventories and restoration at a national level.



Forest Ecosystems

With regard to forest systems, there is still no national map of degraded areas and no clear definition of what can or cannot be considered restoration. There are inconsistencies in the targets set, and the link between the PNRN and agricultural, energy or forest fire prevention policies is not made explicit. It is necessary to distinguish between the conditions prevailing in urban-forest interfaces, fuel management strips, ecological corridors and inland conservation areas, reconciling ecosystem recovery with the protection of people, buildings and infrastructure.

Agricultural Ecosystems

In agriculture, organisations warn of the risk of counting as restoration measures that are already funded by the PEPAC – the Strategic Plan for the Common Agricultural Policy – or routine management practices that do not demonstrate additional ecological benefits. This is the case with the integrated production scheme, identified as a restoration measure, but whose rules still permit the use of synthetic pesticides, herbicides and fertilisers. Agricultural support should only contribute to the PNRN’s targets when linked to measurable objectives, such as carbon sequestration in soils, the effective reduction of pesticides and herbicides, the conservation of habitats, and the promotion of pollinators and other beneficial wildlife.



Urban Ecosystems

In urban areas, it is not enough simply to count the creation or regeneration of green spaces; excluding urban areas with the highest proportion of green spaces may undermine the targets and leave parts of the territory unable to address increasingly pressing challenges. It is necessary to define objective criteria for evaluating the interventions carried out, including benchmarks for vegetation density and diversity, carbon sequestration and increased soil permeability, as well as the adoption of appropriate urban tree management practices, the capacity-building of relevant local stakeholders and the involvement of qualified experts in the design of solutions tailored to each social, urban and climatic context.

Marine Ecosystems

In marine ecosystems, despite the solid technical basis and the transparency with which gaps in knowledge are acknowledged, there remains an imbalance between the production of information and action on the ground, with only two of the 27 measures classified as direct restoration, very limited recovery targets and funding arrangements yet to be defined. A lack of knowledge regarding the state of degradation of a significant proportion of habitats cannot be interpreted as an absence of degradation, nor can it justify postponing action, particularly where pressures have been identified. It is therefore necessary to adopt the precautionary principle, set more ambitious and measurable targets, harmonise assessment methodologies, strengthen ecological connectivity and clearly distinguish new restoration measures from the fulfilment of previous obligations, whilst ensuring funding and the involvement of the fishing sector, coastal communities and all users of the sea.



The plan lacks a common framework for implementation

Overall, the PNRN continues to lack a common framework for implementation, monitoring and follow-up, with robust baselines, clear protocols and measurable indicators that enable a distinction to be made between the implementation of measures and the ecological outcomes actually achieved, and allow for the assessment of changes in the condition and functionality of ecosystems, whilst avoiding double counting of restoration areas. Monitoring should underpin an adaptive management approach, allowing measures and priorities to be adjusted in line with the results obtained. It is also necessary to set out in detail the costs and sources of funding for each measure, including long-term maintenance and monitoring costs.

Mechanisms for consultation, co-decision-making and communication with stakeholders, as well as the strategy for public engagement and the use of mechanisms to mobilise private funding, should be clearly defined. The latter should comply with criteria of transparency, additionality and monitoring of ecological outcomes, ensuring that they do not replace legal obligations to prevent, mitigate or remedy impacts.



Operational coordination must also be ensured with sectoral policies on forestry and rural fire management, agriculture, fisheries and energy, through transparent criteria designed to prevent and resolve territorial conflicts; the Strategic Environmental Assessment should help to analyse this coherence, as well as the cumulative effects of the options set out in the Plan. This analysis should, furthermore, identify and review public subsidies or incentives that may run counter to the restoration objectives, ensuring consistency between public investment and the targets of the PNRN.

The nine environmental NGOs that have signed this contribution, which over recent months have participated in other consultation stages and mechanisms, call for the suggestions submitted during this final phase of consultation to be duly considered and reflected in the final version of the PNRN to be submitted by Portugal to the European Commission, which is intended to be clear, ambitious and operational.

The PNRN can, and must, be a decisive instrument for restoring ecosystems and strengthening the resilience of the territory, but this will depend on the ability to translate scientific knowledge into concrete restoration actions – adequately funded and involving public participation – whose effectiveness is demonstrated through measurable and lasting ecological outcomes.

The environmental NGOs signing this submission to the Public Consultation on the PNRN:

AEPGA - Associação para o Estudo e Protecção do Gado Asinino
FAPAS - Associação Portuguesa para a Conservação da Biodiversidade
GEOTA - Grupo de Estudos de Ordenamento do Território e Ambiente
LPN - Liga para a Protecção da Natureza
Palombar - Conservação da Natureza e do Património Rural
Quercus - Associação Nacional de Conservação da Natureza
Sciaena - Associação de Ciências Marinhas e Cooperação
SPEA - Sociedade Portuguesa para o Estudo das Aves
WWF Portugal