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Reaction of the European Landscape Contractors Association on the call for evidence:
The European Landscape Contractors Association (ELCA) has sent in a reaction on the call for evidence on the review of the delegated acts Climate and Environment in the EU Taxonomy. ELCA represents national associations of landscape garden companies in 23 EU member states and has associate representation in Canada, Japan, Norway, Saudi-Arabia, Singapore, Switzerland, Türkiye and the United Kingdom. We welcome the Taxonomy, part of the European Green Deal, focussing on incentivising investments for the green transition of the EU economy. In assessing the technical screening criteria our special attention went to the application of nature-based solutions in the urban area linked to the EU-objectives on climate change mitigation, climate change adaptation, sustainable use of water (urban waste water), and biodiversity.
ELCA has given the following observations and recommendations:
EU Nature Restoration Regulation
One of the pillars of the European Green Deal is the EU Nature Restoration Regulation. This regulation entered into force on August 18th, 2024. At that moment, the EU Taxonomy and its delegated acts on Climate (2021) and Environment (2023) were already implemented. The Nature Restoration Regulation covers all existing ecosystems in the EU. Since we now are in the stage that the national governments are drafting their national restoration plans, it is not clear yet which measures will be proposed and how they might fit in the EU Taxonomy. ELCA pleads for taking sustainable environmental restoration projects in the framework of the EU Nature Restoration Regulation into account while reviewing the EU Taxonomy.
Nature based solutions
ELCA appreciates that nature-based solutions are explicitly mentioned in the EU-Taxonomy. These solutions are based on and/or inspired by nature, which is a source of sustainability on itself. The landscape garden sector designs, creates and maintains nature-based solutions that contribute to a better climate, biodiversity and public health. We have the expertise on delivering ecosystem services in the context of a specific location, which can be either privately or publicly owned. The EU-Taxonomy is a great enabler of investments in green and sustainable projects, but we feel that the options in the urban ecosystem remain underexposed. As ELCA, we ask to look for technical screening criteria that enhance investments in urban nature-based solutions.
Example 1: Annex 1 sustainable use and protection of water
Nature-based solutions can be applied in the urban area to absorb storm water, store it and use this water in periods of drought. In paragraph 3.1 “Nature-based solutions for flood and drought risk prevention and protection for Disaster Risk Management” the following text is added: “The activity does not include small-scale nature-based solutions to reduce flood and drought, including green and blue solutions applied in urban settings such as green roofs, swales, permeable surfaces and infiltration basins for urban storm water management purposes or Sustainable Urban Drainage Systems”. ELCA pleads for adding these options to the screening criteria so that investments in these solutions can also be enhanced by the EU-Taxonomy.
Example 2: Annex 4 technical screening criteria related to the protection and restoration of biodiversity and ecosystems
This Annex links closely to the aims of the EU Nature Restoration Regulation and describes how to map a location and to manage and audit the activity. In the expert group on the EU Nature Restoration Regulation there are new documents developed on guidance, typologies and monitoring schemes. ELCA pleads for updating this Annex 4 with the available tools for the implementation of the EU Nature Restoration Regulation.
Conclusion:
ELCA welcomes the EU Taxonomy for incentivising sustainable green investments and askes extra attention for nature-based solutions options. Regarding the review of the Taxonomy, ELCA highlights in this call for evidence the following suggestions and needs: