Coherence within policies

• The EU Sustainable Blue Economy Strategy promotes both biodiversity related objectives and economic objectives, which may potentially conflict with each other.
• The Dutch Programme North Sea 2022-2027, incorporates both the national Marine Spatial Planning efforts of designating areas for offshore wind energy generation and other economic activities, as well as the programme of measures for achieving a Good Environmental Status under the Marine Strategy Framework Directive. Although the overarching objective is to promote the sustainable use of the sea towards maintaining a healthy Dutch North Sea, there are possibilities for conflict between the economic and environmental objectives within the same policy instrument.

The European Green Deal ‘Farm to Fork’ Strategy aims to reduce the use of fertilizers and pesticides by 50% by 2030 while the Common Agricultural Policy supports agricultural productivity, which under conventional practices often relies on the use of fertilizers and pesticides. The Common Agricultural Policy might therefore not directly support the ambitions of the ‘Farm to Fork’ Strategy.

• The objectives of the Industrial Emission Directive are closely aligned with those of the European Green Deal, particularly in the areas of pollution prevention and control, creating notable synergies between the directive and the Green Deal.
• The EU Climate Law and the Green Deal share the same aim to reduce net greenhouse gas emissions by at least 55% by 2030, compared to 1990 levels.
• The Nature Restoration Regulation was created with the overarching Green Deal in mind, which means that the deadlines for different obligations have been aligned with the objectives of the Green Deal.

The Common Agricultural Policy (CAP) contains both binding requirements and softer, voluntary objectives meaning that not all CAP objectives hold the same regulatory weight, potentially affecting coherent implementation.

• An environmental policy that aims to reduce carbon emissions by 40% by 2030 but exempts agriculture and aviation sectors. These exemptions create incoherence by undermining the policy's primary goal, leading to contradictory objectives, uneven implementation, reduced effectiveness, and potential public distrust.
• The Common Fisheries Policy aims to ensure the sustainable exploitation of marine biological resources, amongst others through setting limits on the amount of fish that can be caught to prevent overfishing. As an exemption, certain levels of bycatch (unintended catch of non-target species) are allowed to be discarded without penalty. The exemptions for bycatch can lead to significant mortality of non-target species, undermining the sustainability objectives of the Common Fisheries Policy.
• There are multiple objectives within the Nature Restoration Regulation, amongst which climate change mitigation and biodiversity restoration. The first objective is supported by multiple exemptions for renewable energy projects from biodiversity restoration requirements and by prioritizing these projects as of overriding public interest. The objective to restore biodiversity is not supported by similar legal exemptions and requirements, creating the risk of incoherent implementation of the Nature Restoration Regulation.

• The Nature Restoration Regulation cross-references several overarching objectives of the Green Deal, such as those related to climate adaptation and biodiversity restoration, ensuring alignment with broader EU environmental goals.
• In France, all the River Basin Management Plans now have an overarching objective of ‘climate change mitigation’ to ensure alignment with EU carbon neutrality objective.

• The Common Agricultural Policy has funds that provide financial aid with minimal requirements for environmental consideration, increasing the risk of pollution from agricultural practices. It also has funds for farmers who voluntarily commit to follow agricultural practices beneficial for the climate and the environment, potentially decreasing agricultural pollution, and improving the environment.
• The Dutch Programme North Sea 2022-2027 contains multiple objectives, which are not all similarly supported by clear measures. To illustrate, the programme of measures necessary for the achievement of Good Environmental Status under the Marine Strategy Framework Directive is not coordinated with the process for the designation of offshore wind areas nor with the planning processes of other economic activities under the programme. So, it is not clear how these various measures are (if at all) taken into account in allocating space for different uses or in combining them, and how this affects the achievement of the programme objectives.
• The Maritime Spatial Plan for the Finnish Archipelago Sea aims to support achieving the good environmental status objective of the Marine Strategy in the Archipelago Sea. However, the Marine Strategy objective is not legally binding in the spatial planning process. As a result, maritime spatial plans might allocate areas to projects, like for example new aquaculture installations, that can have a negative impact on the marine environment in the Archipelago Sea.
• The EU Common Fisheries Policy aims at ensuring the long-term environmental sustainability of fishing and aquaculture activities. However, the Maximum Sustainable Yield objective has been postponed several times between 2020-2025. Measures are not always strong enough. For example, in France, at least until 2022, ⅘ of the European Maritime, Fisheries and Aquaculture Fund spendings have supported economic fishing activities and not the environmental transformation of the sector.
• The establishment of a climate fund under the Dutch North Sea Agreement aimed to balance the green energy transition at sea with the interests of other users that are directly affected by it. However, it seems that it will mostly be beneficial for fisheries, as fishers will be the ones receiving subsidies and compensation from this fund to cover for the fact that they may be excluded for fishing in particular areas.

• The Common Agriculture Policy includes objectives concerning environmental protection. However, other objectives within the same policy can result in degradation of the environment through increased production and promoting rural development. There are no clear links between the different objectives or measures. In the absence of mechanisms to minimize trade-offs, this has led to contradictory measures being enacted under the CAP.
• The possibility to financially compensate, if no other forms of compensation are feasible, for the negative impacts of renewable energy projects that are deemed necessary for the overriding public interest, is a mechanism to resolve trade-offs between biodiversity protection and offshore renewable wind development. This provision in the Renewable Energy Directive III applies to Renewables Acceleration Areas but has received criticism for its unclarity.
• The Marine Strategy Framework Directive provides a coordinating mechanism, bringing together the measures developed sectorally under other policies into one implementation document (i.e. Programme of Measures).
• In the context of the Common Fisheries Policy, the European Maritime, Fisheries and Aquaculture Fund is a mechanism that can be allocated to a wide range of measures, from developing the industry to changing to more fuel-efficient boats. As such, it can be used to minimize negative trade-offs. It can also have the opposite effect through, if the fund is applied to other measures that are deemed important for other reasons that enhancing coherence.