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EUROPEAN TOPIC CENTRE ON BIOLOGICAL DIVERSITY Introduction to revised Art 12 and Art 17 reporting formats Expert group on Reporting under the Nature Directives 15 March 2016

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Page 1: circabc.europa.eu file · Web viewEUROPEAN TOPIC CENTRE ON BIOLOGICAL DIVERSITY. Introduction to revised Art 12 and Art 17 reporting formats. Additional Member State comments_Art

EUROPEAN TOPIC CENTRE ON BIOLOGICAL DIVERSITY

Introduction to revised Art 12 and Art 17 reporting formats

Expert group on Reporting under the Nature Directives15 March 2016

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Introduction to revised Art 12 and Art 17 reporting formats

IntroductionThe review of the 2007-20121 reporting revealed a need to further improve and streamline the reporting formats and guidelines. The review work targeting the update of the reporting formats and guidelines was launched at the October 2014 meeting of the Expert Group on Reporting under the Nature Directives when a plan identifying the objectives and principal milestones of this work was presented to the group.

Following preliminary discussions held within the Expert Group on Reporting in March 2015, first drafts of revised Art 12 and Art 17 reporting formats were prepared by ETC/BD and discussed at the meeting of the Expert Group meeting in November 2015. An updated version of the proposed revised formats was then prepared, taking into account the main comments gathered during the meeting. This updated proposal was sent by the European Commission to members of the Expert group on 1st December 2015, with a request for written comments before 31 December 2015.

Comments were received from 13 Member States (CZ, DE, DK, ES, FI, HU, IE, NL, PL, PT, SE, SK and UK) and from Birdlife on the draft revised Art 12 reporting format and from 17 Member States (BE, CZ, DE, DK, ES, FI, FR, HU, IE, IT, MT, NL, PL, PT, SE, SK and UK) on the draft revised Art 17 reporting format. Some of these comments were of direct relevance to the revision of the formats. Others also had relevance for discussions within e.g. the Ad hoc group on Structure and functions/Future prospects/Trends, for the preparation of discussion documents e.g. on ‘population units’ or ‘habitat for species’ or for the further development of the Explanatory notes and guidelines. Not all suggestions could be incorporated, either because of conflicting views among some Member States or because of the need to maintain a certain level of ambition for the next reporting round. All comments received and responses from ETC/BD (largely in consultation with EEA and European Commission), are provided in Excel spreadsheets, one each for the Art 12 and Art 17 formats. Additional general comments from some Members States on Art 12 and Art 17 formats are provided in word format respectively in Annex 1 and Annex 2 of this document.

The rationale for proposed changes as compared to the 2007-2012 (2008-2012 for Art 12) reporting formats was explained in detail in the document ‘Proposal to revise Art 12 and Art 17 reporting formats’ from November 2015 and most of the proposed changes were reflected in the draft revised version of the formats commented by members of the Expert Group. The present document summarises the main changes introduced between the version of the reporting formats commented on by members of the Expert Group and the proposed final draft version of 18 February, to be discussed at the next meeting on 15 March.

Types of changes to the reporting formatsChanges are of several types, i.e.:

changes related to editing, formatting, terminology and ensuring consistency between Art 12 and Art 17 formats

adaptation of the structure of the species format under Art 17, with a shift of the section related to Annex V species to the ‘National’ section of the format

clarification of the meaning of certain fields, such as e.g. specifying ‘SPA network’ under Art 12 and ‘pSCIs, SCIs and SACs’ under Art 17 instead of ‘Natura 2000; or the scope of the fields to be reported, such as ‘SPA coverage and conservation measures’ to be reported only for species triggering SPA classification, i.e. species listed in Annex I plus as selection of migratory species for which SPAs have been classified, as identified in the species checklist.

addition of options such as ‘Best estimate’ or ‘Unknown’ for some of the fields

deletion of fields such as ‘range maps’ both under Art 12 and Art 17, and of ‘reason for change in range area’ under Art 12; ‘type of estimate’ (of population size) under Art 17 as largely overlapping with field ‘Method used’ in the same section

integration of alternative field heading and content proposed by Member States as in the case of the section ‘Habitat for species’ where ‘Sufficiency of area and quality of occupied habitat’ replaces ‘Availability of habitat’

1 The review of the reporting for the period 2007-2012 also includes the review of the Art 12 reporting, which was for the period 2008-2012

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Introduction to revised Art 12 and Art 17 reporting formats

confirmation of optional and mandatory fields, including fields that will remain optional for the next reporting round. Although several Member States asked for fields related to ‘Short term trend of population size/ habitat area or structure and functions within the Natura 2000 network ’ to remain optional, at least for the next reporting round, it was decided (in consultation with EEA and European Commission) to keep this field mandatory, due to the importance of the underlying information

in some cases, options which had been considered during the Expert Group meeting in November 2015 and further supported by some Member States’ comments were eventually not retained. This is the case in particular for fields related to Short term trend of population size/ habitat area or structure and functions within the Natura 2000 network’: the Expert Group had considered to report on differences between short-term trends of species population/habitat area or structure and functions within and outside the network, instead of reporting on short term trends of species population/habitat area or structure and function within the network over the considered period. But it was felt (in consultation with EEA and European Commission) that the first option would lead to too much subjectivity

some sections were entirely revised such as ‘Annex V species’, ‘Pressures and threats’ and ‘Conservation measures’. Work is still on-going to finalise lists of ‘pressures & threats’ and of ‘conservation measures’

the finalisation of some sections, i.e. ‘Population’ for species under Art 17, ‘Structures and functions’for habitats under Art 17, ‘Conclusions’ under both the species and the habitat formats under Art 17, depends of decisions to be taken as part of the Ad hoc group on Structure and functions/Future prospects/Trends.

All the proposed changes to the reporting formats were reflected in a revised draft version of the field-by-field section of the Explanatory notes and guidelines for both Art 17 and 12 to be delivered together with the draft revised formats.

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EUROPEAN TOPIC CENTRE ON BIOLOGICAL DIVERSITY

Annex 1

Additional Member State comments on the Article 12 reporting format

(Birds Directive)

This document should be used in conjunction with the excel sheet (MS_Comments_Art.12_FINAL) containing all the Member State comments on the revised Article 12 reporting format.

The document is divided by Member State and contains a mixture of Member State extended comments and cases where Member States’ comments were summarized by the ETC/BD to fit into the excel sheet. In the latter, both the original MS comment and the ETC summarized version is presented in tables below. Some comments may refer to both Article 17 and Article 12.

The Member States’ comments can be reached by clicking on the cross-referenced acronym in the list below.

Birdlife: DE Error: Reference

source not found NL SE UK

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Introduction to revised Art 12 and Art 17 reporting formats

1. Birdlife:

We are writing to you in reaction to the German proposal for a so-called ’24 years rolling-window’ in reporting long-term trends for birds, supported by Portugal. We are very concerned about this proposal, and would advise you strongly against it.

In particular we think that this would create problems for many of the species in the EU that have suffered declines in the past and have now depleted populations. If a rolling window was introduced, at one point the depleted state would become the baseline.

An additional complication is that due to the fact that many bird species of conservation concern are relatively short-lived, and are unlikely to hit the threshold for alarming declines in 24 years. There are several bird species monitored under PECMBS have decline by more than 30% since 1980, but do not feature on the Red List because they decline too slowly to meet the criteria. However, the application of Article 2 of the Directive requires member state to maintain species in a favourable conservation status (‘adequate population levels’) – and this requires Member States to take action against population declines.

The hypothetical example below illustrates the risk of adopting a rolling time window approach. Under the current system, where long-term trends are permanently ‘anchored’ in 1980, the ongoing erosion of the population is clearly highlighted, and the species’ worsening status is obvious (it would be listed as Declining from 2012 onward). Under a rolling time window approach, however, the species never declines by more than 20% over any 24 year period – which means it would effectively be classified as Secure in successive 6-yearly Art 12 assessments. Only when its EU population has eventually collapsed to only a few thousand individuals would it then trigger other, higher Red List criteria and be flagged up as a species of concern – much too late to address via most mechanisms, and much more costly than would have been possible if the current early warning system had been heeded.

Year % of 1980 population left % loss since 1980 % loss over previous 24 years1980 1001988 96 41994 92 82000 88 122006 84 162012 80 20 162018 76 24 162024 72 28 162030 68 32 162036 64 36 162042 60 40 16

Where there is solid evidence that species are experiencing ongoing declines across much of the EU, and especially where research has shown that those declines are linked to (if not driven by) EU and other policies, it is our absolute responsibility to ensure that they are flagged up as priorities for action.

2. DE:

*text from paper “Proposal to revise Art 12 and Art 17 reporting formats”*Extending reporting on pressures and threats to all birds (Art 12)The current Art 12 reporting format only requires main pressures and threats for SPA trigger species. As lists of SPA trigger species vary between the Member States this information is very difficult to exploit in a meaningful way. The information on pressures and threats is becoming increasingly important in communicating results of the status assessment to different sectors, like agriculture or forestry. To assure complete and coherent information on the main drivers to the status of birds population the pressures and threats should be reported for all (for all breeding species, for all species for which the reporting during the winter season is requested and for the ‘SPA trigger’ species on passage), not only for the SPA trigger species.

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Introduction to revised Art 12 and Art 17 reporting formats

MS extensive comment Summary as reflected in the Xcel sheetWe refuse an enlargement of the bird species for which pressures and threats should be reported. Restricting this item to a reasonable reporting burden has been one important precondition for Germany to accept the new birds reporting format in the last reporting round. We therefore welcome the reduction in the lists of the subspecific units and wintering species to be reported for the next reporting round. We also welcome that the Commission is no longer proposing that pressures & threats should be reported for all bird species but for Annex I species (as 2013) and for species that are “not secure” on EU-level (instead of national SPA- trigger species). This might result in some fluctuation between reporting cycles, however will reduce the burden considerably instead of simply adding up all trigger species lists of all member states.

We refuse an enlargement of the bird species for which pressures and threats should be reported. We welcome the reduction in the lists of the subspecific units and wintering species to be reported for the next reporting round. We also welcome that the Commission is no longer proposing that pressures & threats should be reported for all bird species

3. IE:

*text from paper “Proposal to revise Art 12 and Art 17 reporting formats”*Range maps (Art 12 and Art 17)GIS surface areas calculated from range maps were used in the past as a weight in the EU biogeographical assessment in the Art 17 reporting. This was used particularly for the reporting period 2000-2006, where sometimes a range map substituted a distribution map for species for which distribution was not known. The guidance for the range maps for the period 2007-2012 stipulates that the range map should be a spatial derivative of a distribution map. Due to this direct link between the distribution and range maps the importance of the range maps in the EU biogeographical assessment has significantly decreased. The range map is not used in the EU population status assessment under the Art 12.MS extensive comment Summary as reflected in the Xcel sheetIn Ireland the current distribution is determined in many ways. For some species the current known distribution is supplemented by historic distribution records where there is no evidence that a species has been lost. These historic records may not have been visited for decades or the resolution of the original record was such that it may be difficult to relocate.For well-recorded, abundant, wide-ranging species only the current distribution records were included. The range envelope is likely to include grids that were positive records in the last reporting cycle but not in the current reporting cycle. If a grid within the Range envelope appears absent it does not mean that the species does not occur within that grid.For mobile, poorly recorded species (in particular marine species) the current distribution was based on an amalgamation of records from often up to 20 years. Due to the vastness of the Marine Atlantic and the limited likelihood of determining a precise distribution, a generous Range envelope was derived based on habitat usage and expert judgement.Ireland will continue to derive national Range maps as we feel that it is important to keep track of how the Range figure was derived. It is the Range figure that is used to assess trends, determine distance from the FRR and ultimately assess the Range attribute. If the distribution maps are the only maps to be presented at an EU level, the viewer should have an understanding about the different methods employed by different MS to derive these maps, therefore field 2.3.2 Methods used Surface area of Range” is actually quite important and should be retained. Where the distribution maps deviate considerably from the Range maps then MS should be encouraged to submit these maps for information.

Retain field 2.3.2 (Methods used Surface area of Range"). Where the distribution maps deviate considerably from the Range maps then MS should be encouraged to submit these maps for information.

Range can be derived from the distribution in many ways (see comments on page 3 under “Range maps”), therefore the “methods used” should be retained.

*text from paper “Proposal to revise Art 12 and Art 17 reporting formats”*Trend of population and habitat area within the Natura 2000 network (Art 12 and Art 17)Together with the assessment of conservation/population status the assessment of contribution of Natura 2000 network to the conservation status is a key assessment done in the framework of the Nature Directives reporting. This assessment is linked to evaluation of impact of measures under the Article 6(1) of the Habitats Directive and Article 4(1) of the Birds Directive to the status of habitat and species. The assessment of impact of measures under the Article 6(1) is one of the requirements of the Article 17 of the Directive. The WP3 group (one the working groups under the Expert group on Reporting dealing with the review of 2007-2012 reporting guidance) identified the comparison of overall trends with the trends within the Natura 2000 network as one of components of this assessment. Short-term trend of population size and habitat area within the network is therefore crucial in assessing impact of the Natura 2000 network on conservation status. For the next reporting period this information should become mandatory.Ireland is still unclear about what is being reported by MSs, i.e. whether it is the area/population within the network or the area/population that is legally protected within the network – these estimates can vary considerably. We note Germany’s response to the format changes relating to Natura 2000 coverage within the network with a request that “it should be clarified that

IE request further clarification on whether it's area/population within the network or area/population legally protected within the network, have been advised previously that it’s the former but IE provided figures for the latter in the "other relevant information" field. IE commented that it is habitat quality rather than area that is likely to change.

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Introduction to revised Art 12 and Art 17 reporting formats

this refers to species/habitats for which the sites are designated = which occur in the SDFs (and not for species/habitats which occur in sites, but are not designated = not subject of legal protection).” When Ireland requested clarification on this issue in the last reporting round we were informed that it was the area/population within the network regardless of whether there was legal protection. Ireland opted to provide figures for the area/population that was legally protected in the “other relevant information” field where available. We request further clarification/discussion on this topic.Ireland has also commented on the fact that it is habitat quality rather than area that is more likely to change within the network. Further discussion is also warranted on this topic.

4. NL:

Annex 2:4.6 Why is 4.6 “Range surface area” still relevant?We do not have to report the range map, because it will be made on European level, we do not have to compare with FRR, the range figure is not used for anything.More relevant would be “Distribution surface area” and then 4.8 Quality will also refer to distribution. 4.9 (reason for change) can then be deleted.

Especially our bird experts (other species experts as well, but less passionate) are very much against the currently used concept of “range” for birds. They think it is a completely meaningless parameter, because there is so much information on the birds. The range “envelop” only adds “distribution” that is probably not filled with actual occurrences. Not reporting a figure on for a fictive feature will make them much happier. Same applies for range trend of course, but there the option to use distribution is already made possible (I hear cheering from 100 km east of me ;-))

5. SE:

*text from paper “Proposal to revise Art 12 and Art 17 reporting formats”*Range maps (Art 12 and Art 17)GIS surface areas calculated from range maps were used in the past as a weight in the EU biogeographical assessment in the Art 17 reporting. This was used particularly for the reporting period 2000-2006, where sometimes a range map substituted a distribution map for species for which distribution was not known. The guidance for the range maps for the period 2007-2012 stipulates that the range map should be a spatial derivative of a distribution map. Due to this direct link between the distribution and range maps the importance of the range maps in the EU biogeographical assessment has significantly decreased. The range map is not used in the EU population status assessment under the Art 12.MS extensive comment Summary as reflected in the Xcel sheetThe range maps, and other “range” information (Art 17, Art 12)We tend to prefer keeping the range maps in the reporting format. There are arguments for and against, however, and weighting these is rather a decision for the Habitats committee, not for the Expert Group on Reporting. So this is not a final position from Sweden.Since range is a necessary part in the evaluation of conservation status (FCS), it still needs to be calculated by the MS in order to reach a conclusion on FV/U1/U2 by the MS. It is a reduction in reporting burden, but it is minor, at least to us. The main job is to calculate/estimate the range, not to upload the file. We consider that we would anyway have to make the file publicly available somehow – and thus, the (minor) reduction of EU reporting burden would be an even smaller reduction of workload for us, perhaps none at all in the end.From what we come to think of, the main argument for keeping the range maps in the reporting is that it can be used by scientists and the public to understand the reporting results (transparency). They can be able to question if strange range maps are used, and be able to suggest improvements where relevant. Enhancing public participation is in line with the Aarhus convention, and increasing the possibility for the scientific community to improve the

We tend to prefer keeping the range maps in the reporting format. There are arguments for and against, however, and weighting these is rather a decision for the Habitats committee, not for the Expert Group on Reporting. So this is not a final position from Sweden.

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Introduction to revised Art 12 and Art 17 reporting formats

reporting is in line with the intentions of the Habitats directive.If range maps are removed, it should be clearly stated in the proposal and acknowledged by those taking the decision that they choose this small, if any, reduction of workload knowing that transparency is lost (at least some) for this aspect. A risk of less harmonization between MS is possible if the range maps are removed. Removing it could perhaps be criticized on the grounds of public access to environmental information, as follows from the Aarhus convention, at least if some MS choose not to publish their range maps using other channels.On a more general note, regarding “range”, it seems questionable to us to ask for a lot of details for different time-frames, for example since the underlying assumptions – when calculating range from distribution – can make large impacts on the results. A simplification should be sought.*text from paper “Proposal to revise Art 12 and Art 17 reporting formats”*Trend of population and habitat area within the Natura 2000 network (Art 12 and Art 17)Together with the assessment of conservation/population status the assessment of contribution of Natura 2000 network to the conservation status is a key assessment done in the framework of the Nature Directives reporting. This assessment is linked to evaluation of impact of measures under the Article 6(1) of the Habitats Directive and Article 4(1) of the Birds Directive to the status of habitat and species. The assessment of impact of measures under the Article 6(1) is one of the requirements of the Article 17 of the Directive. The WP3 group (one the working groups under the Expert group on Reporting dealing with the review of 2007-2012 reporting guidance) identified the comparison of overall trends with the trends within the Natura 2000 network as one of components of this assessment. Short-term trend of population size and habitat area within the network is therefore crucial in assessing impact of the Natura 2000 network on conservation status. For the next reporting period this information should become mandatory.About ”Trend of population and habitat area within the Natura 2000 network, trend direction should become mandatory” (Art 17, Art 12)Expanding the format to include separate data for population size and habitat area for Natura 2000 areas is to ask for a whole lot of new data, when it comes to the situation in Sweden. In Sweden, a clear majority of most of the annex 1 habitats and annex 2 species occurrences are outside Natura 2000. Existing sampling systems for monitoring of species and habitats would have to be complemented with a lot of new samples within Natura 2000. In other words, if such new items is introduced in the format, it would require major efforts to increase our monitoring system and also add work in the analysis phase before the article 17 report (since we need to evaluate twice instead of once: not just the area as a whole, but also the subset of area included in Natura 2000).For a scientific point of view, we understand the interest of this information, but there are also other ways to get information about the efficiency of the management of Natura 2000 areas (see previous notes about future improvements of the format). Depending on the intended use and prioritized users of the information, there might be a simpler and cheaper way to obtain enough information without introducing these new questions in the format. Perhaps, for example, an expert judgement on differences inside and outside Natura 2000 borders? Thus, we do not state a position from Sweden in this issue here during the work in the Expert group on reporting.

Increase in reporting burden. Depending on the intended use and prioritized users of the information, there might be a simpler and cheaper way to obtain enough information without introducing these new questions in the format. Perhaps, for example, an expert judgement on differences inside and outside Natura 2000 borders? Thus, we do not state a position from Sweden in this issue here during the work in the Expert group on reporting.

*text from paper “Proposal to revise Art 12 and Art 17 reporting formats”*Information related to sustainability of hunting or exploitation of species (Art 12 and Art 17)The Annex II of the Birds Directive and Annex V of the Habitat Directive include species, which can be hunted or exploited in the wild. The Article 7 of the Birds Directive stipulates that ‘owing to their population level, geographical distribution and reproductive rate throughout the Community, the species listed in Annex II may be hunted under national legislation’, this should not however jeopardize the conservation of these species. The Article 16 of the Habitats Directive requests Member States (in the light of results of the Article 11 monitoring) to take measures to ensure that the taking in the wild of specimens of species of wild fauna and flora listed in Annex V as well as their exploitation is compatible with their being maintained at a favourable conservation status. For both Birds Directive and Habitats Directive hunting or exploitation is closely linked to conservation objectives outlined in the Directives (maintaining good conservation status of species populations). It is therefore important to establish a regular flow of information relevant for assessing sustainability of hunting or exploitation and their impact on conservation status. This information should be collected as a part of the Art 12 and Art 17 reporting.For huntable bird species it is proposed that it involves information on demographic factors influencing ability to withstand hunting pressure (productivity and adult survival) and hunting kill (bag) statistics. *see tables in document*

MS extensive comment Summary as reflected in the Xcel sheet“Sustainability on hunting of annex 5 species HD and annex 2 of BD should be introduced” (Art 17, Art 12)The language in the proposal for further information on sustainability of hunting of annex 5 species should be reviewed –

Review of language used in this section is needed (e.g. provided) and more information on how this data will be used. This will increase the reporting burden. Recommend narrowing the scope of the species of certain interest.

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Introduction to revised Art 12 and Art 17 reporting formats

for example, annual reproductive success and population growth rate are different measures. We would like to see some further information on the intended use of this information before we reach a conclusion about this proposal. The data obtained is likely to be difficult to assess on an EU scale, especially Annual hunting bag and Annual breeding success, as the quality will probably vary greatly between MS, Obviously it would increase the reporting burden since it is new items of information to report. In general, the Swedish position has been negative towards such increases in reporting burden, so you might want to consider removing something equally burdensome (or more) if you want to get such a proposal approved by the Habitats Committee. Narrowing the scope to only species of certain interest (not all annex 5 species for example) might also make the suggestion more palatable.

6. UK:7. Art. 12, 7. d) Main Pressures and Threats table

Logical possibilities are:

a) Inside MS Y/Nb) Inside EU Y/Nc) outside EU Y/N

Thus the logical combinations are:A onlyB onlyC onlyA+BA+CA+B+CB+Cunknown

(I think) So there are 8 possibilities only 5 of which are given. Actually only four options are given as option 1 is the same as options 3+4 (*d) Location, options 2 to x

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Annex 2

Additional Member State comments on the Article 17 reporting format

(Habitats Directive)This document should be used in conjunction with the excel sheet (MS_Comments_Art.17_FINAL) containing all Member State comments on the revised Article 17 reporting format.

The document is divided by Member State and contains a mixture of Member State extended comments and cases where Member States’ comments were summarized by the ETC/BD to fit into the excel sheet. In the latter, both the original Member State comment and the ETC summarized version is presented in tables below. Some comments may refer to both Article 17 and Article 12.

The Member States’ comments can be reached by clicking on the cross-referenced acronym in the list below.

DK HU Error: Referencesource not found

MT:

NLPL:

SEUK

10

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1. DEDK :

*text from paper “Proposal to revise Art 12 and Art 17 reporting formats”*Trend of Future prospects/Future trends (Art 17)According to the Art 17 guidelines the status of Future prospects should reflect the likely Conservation status of the habitat or species in two reporting cycles. This link between the status of Future prospects and anticipated status of the habitat or species in two reporting cycles will be further strengthened in the updated guidelines.For many habitat and species which are currently in unfavourable status but are expected to show the first signs of improvement in close future (two reporting periods) the Conservation status will not reach better category in two reporting periods, as much longer periods are needed for restoration. In these cases it is however important to report on anticipated positive future trends (or on future mitigation of current negative trends,) mainly if these are linked to implemented conservation measures, even if these future trends will not result in change in the Conservation status category in two reporting periods. It is therefore suggested to add to the reporting format a new field for aggregated assessment of future trends. (See the Outcomes from the 2nd meeting of the ad hoc group for more details.)The trend in overall Conservation status (qualifier) should be based according to current Art 17 guidelines on trends over the reporting period that are expected to continue into the future. Defined in this way the qualifier encompasses two time horizons, the actual period and the foreseeable future. For the next reporting period the guidance for the qualifier should be updated to strengthen its link with trends during the reporting period (the future perspective should be removed from this assessment). The future perspective will be then reflected in the abovementioned new field for aggregated assessment of future trends.MS extensive comment Summary as reflected in the Xcel sheetDenmark does not agree to this proposal and did intervene on this point in the last reporting meeting in Copenhagen. Addition of a future trend category will increase the reporting burden and may be a politically judgement as it hardly can be documented by data or evidence. Hence Denmark finds that the resources used to undertake this exercise hardly can be justified in a time where MS ask for a decrease in reporting burden. If for example a future trend is guessed and reality turns out differently resources may additionally be used on explaining such differences again with no data backing on part of the future trend estimate.

Denmark does not agree to this proposal and did intervene on this point in the last reporting meeting in Copenhagen. Addition of a future trend category will increase the reporting burden and may be a politically judgement as it hardly can be documented by data or evidence.

2. HU:

Art. 17 – Field 5.3 bMS extensive comment Summary as reflected in the Xcel sheetHungary suggests that independently from the results of discussion on population units, the method to convert data (5.3.b – Additional information on population estimates/conversion, b) method to convert data) should be mandatory field in every case. The method of converting data into individuals should be given to all species where this unit is used, to be able to see how the data was calculated. It is crucial even for those species whose population size is provided in individuals (and no other population unit is used), because it is important to see how robust and reliable the data is behind the population size (number of sampling sites etc.). This field may remain non-public information. We think that the fields “5.3 a) Additional information on population estimates / conversion, a) definition of locality” should not be deleted. If a MS uses locality, the definition is important to add and the problems to provide population size estimation is also crucial.

Hungary suggests that independently from the results of discussion on population units, the method to convert data (5.3.b – Additional information on population estimates/conversion, b) method to convert data) should be mandatory field in every case.We think that the fields “5.3 a) Additional information on population estimates / conversion, a) definition of locality” should not be deleted.

5.1 Population:There is a discussion on how the population units should be set, but the format can be only finalized when there is a consensus on that issue.Hungary suggests that independently from the results of discussion on population units, the method to convert data (5.3.b – Additional information on population estimates/conversion, b) method to convert data) should be mandatory field in every case. The method of converting data into individuals should be given to all species where this unit is used, to be able to see how the data was calculated. It is crucial even for those species whose population size is provided in individuals (and no other population unit is used), because it is important to see how robust and reliable the data is behind the population size (number of sampling sites etc.). This field may remain non-public information.

We think that the fields “5.3 a) Additional information on population estimates / conversion, a) definition of locality” should not be deleted. If a MS uses locality, the definition is important to add and the problems to provide population size

There is a discussion on how the population units should be set, but the format can be only finalized when there is a consensus on that issue.

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estimation is also crucial.

The “5.5 Type of estimate” field does not give good information on converting data. This field should be worked out in line with the results of the discussion on population units. For example, other individual method and extrapolation is recommended to be added to this field.

3. IE:

4.e iv Principles for update of the Art 17 checklist

Review of categories of occurrence

For information - There are two large projects underway surveying the distribution, abundance and seasonal movements of cetaceans in the Irish offshore. These projects run til 2017 and it is possible that the findings will lead to us changing the category of occurrence for certain cetacean species. We hope that we will be able to undertake this task later in the reporting cycle.

Proposed changes in reporting for anadromous fish

Ireland, for similar reasons to Germany, is not in a position to send additional reports for marine regions. We will include Marine pressures/threats if appropriate.

*text from paper “Proposal to revise Art 12 and Art 17 reporting formats”*Range maps (Art 12 and Art 17)GIS surface areas calculated from range maps were used in the past as a weight in the EU biogeographical assessment in the Art 17 reporting. This was used particularly for the reporting period 2000-2006, where sometimes a range map substituted a distribution map for species for which distribution was not known. The guidance for the range maps for the period 2007-2012 stipulates that the range map should be a spatial derivative of a distribution map. Due to this direct link between the distribution and range maps the importance of the range maps in the EU biogeographical assessment has significantly decreased. The range map is not used in the EU population status assessment under the Art 12.MS extensive comment Summary as reflected in the Xcel sheetIn Ireland the current distribution is determined in many ways. For some species the current known distribution is supplemented by historic distribution records where there is no evidence that a species has been lost. These historic records may not have been visited for decades or the resolution of the original record was such that it may be difficult to relocate.For well-recorded, abundant, wide-ranging species only the current distribution records were included. The range envelope is likely to include grids that were positive records in the last reporting cycle but not in the current reporting cycle. If a grid within the Range envelope appears absent it does not mean that the species does not occur within that grid.For mobile, poorly recorded species (in particular marine species) the current distribution was based on an amalgamation of records from often up to 20 years. Due to the vastness of the Marine Atlantic and the limited likelihood of determining a precise distribution, a generous Range envelope was derived based on habitat usage and expert judgement.Ireland will continue to derive national Range maps as we feel that it is important to keep track of how the Range figure was derived. It is the Range figure that is used to assess trends, determine distance from the FRR and ultimately assess the Range attribute. If the distribution maps are the only maps to be presented at an EU level, the viewer should have an understanding about the different methods employed by different MS to derive these maps, therefore field 2.3.2 Methods used Surface area of Range” is actually quite important and should be retained. Where the distribution maps deviate considerably from the Range maps then MS should be encouraged to submit these maps for information.

Retain field 2.3.2 (Methods used Surface area of Range"). Where the distribution maps deviate considerably from the Range maps then MS should be encouraged to submit these maps for information.

Range can be derived from the distribution in many ways (see comments on page 3 under “Range maps”), therefore the “methods used” should be retained.

*text from paper “Proposal to revise Art 12 and Art 17 reporting formats”*Trend of population and habitat area within the Natura 2000 network (Art 12 and Art 17)Together with the assessment of conservation/population status the assessment of contribution of Natura 2000 network to the conservation status is a key assessment done in the framework of the Nature Directives reporting. This assessment is linked to evaluation of impact of measures under the Article 6(1) of the Habitats Directive and Article 4(1) of the Birds Directive to the status of habitat and

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species. The assessment of impact of measures under the Article 6(1) is one of the requirements of the Article 17 of the Directive. The WP3 group (one the working groups under the Expert group on Reporting dealing with the review of 2007-2012 reporting guidance) identified the comparison of overall trends with the trends within the Natura 2000 network as one of components of this assessment. Short-term trend of population size and habitat area within the network is therefore crucial in assessing impact of the Natura 2000 network on conservation status. For the next reporting period this information should become mandatory.Ireland is still unclear about what is being reported by MSs, i.e. whether it is the area/population within the network or the area/population that is legally protected within the network – these estimates can vary considerably. We note Germany’s response to the format changes relating to Natura 2000 coverage within the network with a request that “it should be clarified that this refers to species/habitats for which the sites are designated = which occur in the SDFs (and not for species/habitats which occur in sites, but are not designated = not subject of legal protection).” When Ireland requested clarification on this issue in the last reporting round we were informed that it was the area/population within the network regardless of whether there was legal protection. Ireland opted to provide figures for the area/population that was legally protected in the “other relevant information” field where available. We request further clarification/discussion on this topic.Ireland has also commented on the fact that it is habitat quality rather than area that is more likely to change within the network. Further discussion is also warranted on this topic.

IE request further clarification on whether it's area/population within the network or area/population legally protected within the network, have been advised previously that it’s the former but IE provided figures for the latter in the "other relevant information" field. IE commented that it's habitat quality rather than area that is likely to change.

Comment on 4.e i Population units

Ireland are also supporting the arguments from Tony (UK), Stefania (Italy, ISPRA), Zita Zsembery (HU), Nevena Ivanova (BU) and Axel Ssymank (De) to further explore the issue of population units.

The Directive does not equate Population size with the number of individuals. Even if there is a conversion to the number of individuals, this does not mean that the number of individuals have been used to set the FRP or used for the analysis of trends. These units are more likely to be based on the units used for monitoring which are often the most ecologically meaningful and specific to that Member State.

Ireland does not think that the topic of Population units has had adequate scrutiny and exchange of views/approaches (particularly conversion approaches) from the scientists that are collecting the data in the field. Several experts in Ireland are ready to join in this discussion.

Even where Ireland made every effort to provide an estimate for individuals we provided detailed text in the “population_additional_problems” field where we believed that the unit may not be fit for purpose or where the figures should be treated with caution as the values were often excessively derived.

Recalling Ireland’s comments from April 2015 we have not changed our position on any of the species (updated version below).

Ireland is unlikely to be in a position to provide a value for mature individuals or agreed exceptions for the following species for the next reporting round. We may be in a position to refine the grid square resolution.

-1092 White-clawed Crayfish – This species is widespread and abundant in Ireland. Monitoring schemes have focussed on presence/absence recording. Any attempts at conversions to individuals have resulted in such large error margins that would make a national estimate meaningless, therefore a 10 km grid square estimate was submitted.

-1065 Marsh Fritillary – Irish colonies occur in a complex mosaic of habitats that are difficult to categorise. They occupy patches in a cycle of extinction and recolonisation. Any conversion to mature individuals would be excessively derived. Any conversion examples from 10km grid squares would be appreciated.

-1024 Kerry slug - it is not possible to assign estimates of numbers to rapidly reproducing, cryptic species of invertebrates that occurs in different densities in different habitat types. Any conversion examples from 10km grid squares would be appreciated.

-1099 River Lamprey and 1096 Brook Lamprey – these species are monitored as juveniles and are indistinguishable at this life stage.

Ireland are also supporting the arguments from Tony (UK), Stefania (Italy, ISPRA), Zita Zsembery (HU), Nevena Ivanova (BU) and Axel Ssymank (De) to further explore the issue of population units. Link to wider document:

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Any conversion examples from 10km grid squares would be appreciated.

-Although we submitted a population estimate for 1833 Najas flexilis in the last reporting round this figure was very derived. This species is an annual with fluctuating densities in different euphotic zones.

-The agreed exception was used for 1395 Petalwort, however this is a clonal, often subterranean, early coloniser that can have high densities in certain areas in one year and then be seemingly absent in subsequent years, therefore m2 may not be the most appropriate measure for this species.

-1400 White cushion moss – This is a very widely distributed species in Ireland that occurs in different densities in different habitat types, deriving a m2 population estimate would not be possible. Many records are only available at the 10km scale.

4. MT:

Emailed comment – Population size (Art 17)

MS Extensive comment Summary as reflected in the Xcel sheetWith reference made to the request to submit comments, on the updated list of species where alternative populations size units should be used; subspecific units proposed for 2013-2018 reporting and key species/subspecific units proposed for winter reporting and species for which it is proposed to submit a separate Article 17 report and newly recognised species for which it is proposed to submit a joint report, below please find Malta’s comments, for your consideration:Whilst acknowledging the importance of reporting populations as ‘number of individuals’ so as to have better EU population estimates and for ease of communication with the general public and the policy makers, Malta tends to agree with the Member States (MSs) suggesting to further explore the issue of population units.Having went through several of the comments submitted by other Member States, we agree with most comments regarding difficulties in reporting population units as individuals. Of particular concern is the provision of data as individuals for amphibians and reptiles. When considering these species, there are various aspects which lead to constraints to attain population units as individuals, such as the variability of the population from one year to another, requiring extensive efforts, and disturbance to species to attain reliable data. This apart from the fact that the reptiles reported for Malta were assessed as having a favourable conservation status, based on sound expert advice. It is felt that the monitoring frequency and scientific detail considered (apart from resources) should be relative to the status of the habitats/species; in this regard, priority is considered for those assessed as having an unfavourable status. Meanwhile, assessments of migratory species are not considered relevant when done by single Member States, especially when considering certain species (e.g. when species is within the margins of its distribution).Malta also believes that the following issues in connection with reporting as ‘number of individuals’ need to be considered:• Species which grow in inaccessible sites: As was pointed out during the expert group meeting, certain species (such as chasmophytic vegetation) are very difficult to count in view of the very inaccessible nature of the habitats that support them, such as cliff faces. Methods to get to realistic estimations in such cases would involve a combination of costly exercises, such as boat surveys and professional climbing. Boat surveys would still not allow for reporting at individual level easily, noting the species habit of growing clusters. Professional climbing would lead to physically impacting the habitat of the species themselves; it is not deemed relevant to cause impact, while noting that certain such habitats are normally exposed to minimal impact.• Conversion methods to estimate population at individual level: The development of conversion methods would require studies, which apart from increasing burden on resources (including financial burden) on MSs, they would also require lengthy trial periods to assess their relevance. The development of a conversion tool by ETC, as suggested by Italy, whilst alleviating MSs from the financial burden, would possibly be a complex matter noting that different circumstances would call for different conversion criteria between MSs. For Malta, in view of its limited surface area, the conversion would need to consider amongst other things the

Malta tends to agree with the Member States (MSs) suggesting to further explore the issue of population units. We agree with most comments regarding difficulties in reporting population units as individuals.

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habitat/zonation compression and habitat mosaics, which in turn would have an influence on the range, distribution and populations. For this reason, feasibility and relevance need to be given proper weighting when considering the development of such tool/s. Should a tool/s be developed, this would need to account for variables that may affect the conversion in different MSs and proper guidelines to ensure standard usage of such.Malta meanwhile acknowledges and welcomes the decision taken to include Elatine gussonei and Gibbula nivosa in the list of exceptions. However, it again requests the inclusion of the following in the list of exceptions for population size units: the endemic, chasmophytic plant species Hyoseris frutescens, Helichrysum melitense, Cremnophyton lanfrancoi and Palaeocyanus crassifolius. One should consider that Malta reports these species in 1x1km grid cells (not 10x10km grid cells), hence the data is already of relatively high resolution. Furthermore, with reference to the note on ‘Lists of Exceptions (Recommended Population Units)’ [available at: http://bd.eionet.europa.eu/activities/Natura_2000/Folder_Reference_Portal/list_of_exceptions.pdf], the statement “For species occurring in only one Member State there is no need to change the unit from the last reporting round as the Member State already has 100% of the population” is deemed to remain plausible when considering endemic species.

5. NL:

4.e i Population units

In contrast with most other Member States (who send their comments to the whole group), we would like to express that we are in favor of reporting individuals:1. The primary reason why to report individuals is for the Commission (EEA/ETC) to be able to weigh the

population between member states. It is not possible to assess a biogeographical conservation status if one Member State has 3 locations, another 3 5x5 grid cells and another one 3.000.000 individuals. There is no way of telling how much each Member State contributes to the European conservation status.

2. Individuals is the most feasible unit for the purpose of weighing populations over Member States. Grid cells and locations are not comparable, even if they have the same size or definition, because for ETC/EEA there is no way of knowing the difference (or not) in density within the grid cells or locations: if the density in one Member State is 10 individuals per km2, and in another 1000, then 100 grid cells in the first Member State is a ten times smaller (instead of ten times bigger) population than 10 grid cells in the second Member State.

3. Grid cells, especially close to 10x10 km grids (or any other size used for distribution), give no additional information to the distribution (or even the range).

4. The discussion on alternative population units is an endless one. A common used example is Bombina variegata, with the request to be able to use grid cells, preferably in a large scale. This means that the Netherlands will have 2 or 3 grid cells, and any change in that will mean that the species is on the edge of extinction. Individuals is a far more relevant unit for us, as there are only a few. This kind of differences exist for many species.

5. We think that preferably the Member State itself does the calculation to individuals. However inaccurate, the calculation of ETC/EEA will be more inaccurate. However little we know about population densities in our country, we know more than they do.

6. There is no need to have a complete survey to report individuals, so the efforts and costs for monitoring purely depends on how detailed you want to have your information yourself (for whatever purposes): a. some research (literature?) to min-max-mean population densities will enable you to make a

reasonable estimation on individuals (as in “rational” not necessary as in “accurate”)b. you do not need to use the exact number of individuals to assess the trend and/or conservation status:

we have a monitoring system that gives accurate trends, but no hint on the population size (bases on yearly samples). You can do the assessment based on any population unit you think is desirable. (Like Deirdre wrote: “Even if there is a conversion to the number of individuals, this does not mean that the number of individuals have been used to set the FRP or used for the analysis of trends. These units are more likely to be based on the units used for monitoring which are often the most ecologically meaningful and specific to that Member State.”)

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c. The samples for the trend monitoring can also be used for assessing differences in population densitiesd. We have the obligation to have a coherent monitoring system that provides the information needed

form implementing the Directives…Our proposal:1. Keep reporting of individuals obligatory to facilitate the assessment of biogeographical conservation

status, however inaccurate the numbers or how broad the ranges (10-10.000 comparing to 1.000-1 million still gives an idea about the differences between Member States)

2. Reporting of an alternative population unit - which is more suitable in your Member State and/or which you used for the assessments and/or which you wish to make available for the public – is optional (and will not be used by the ETC/EEA).

3. Exceptions can be made for species that occur in only one or a few Member States within a biogeographical region and all Member States concerned can agree on another population unit that is comparable between the Member States. (but, again the example of B. variegata: I think in the Atlantic region Germany and the Netherlands can agree on individuals, but France probably not…)

4. I understand that experts are wary to report exact (minimum and maximum) numbers for individuals in an official document like the national report. Maybe it is better to ask for “the best possible estimation with uncertainty”. This is more in line with publications in papers, and probably experts will be more willingly to answer (thinks one of my experts!). -> is possible in proposed new format.

Proposed changes to the list of exceptionsLucanus cervus no longer an exception = OK!

Vertigo species: with almost the same calculations, and with the same accuracy (maybe even better) we can assess the number of individuals instead of m2. The m2 is more an indication of the habitat area and is not a good indicator for population.

4.e iv Principles for update of the Art 17 checklist

Review of categories of occurrenceProposal = OK

Proposed changes in reporting for anadromous fishThe Netherlands, for similar reasons to Germany and Ireland, is not in a position to send additional reports for marine regions. We will include Marine pressures/threats if appropriate.

Taxonomical changesProposal = OK, no problems expected because generally we have only one of the (new) subspecies, except for Cottus gobio, where we are probably able to separate the subspecies (by distribution/habitat)

Annex 2:4.6 Why is 4.6 “Range surface area” still relevant?We do not have to report the range map, because it will be made on European level, we do not have to compare with FRR, the range figure is not used for anything.More relevant would be “Distribution surface area” and then 4.8 Quality will also refer to distribution. 4.9 (reason for change) can then be deleted.

Especially our bird experts (other species experts as well, but less passionate) are very much against the currently used concept of “range” for birds. They think it is a completely meaningless parameter, because there is so much information on the birds. The range “envelop” only adds “distribution” that is probably not filled with actual occurrences. Not reporting a figure on for a fictive feature will make them much happier. Same applies for range trend of course, but there the option to use distribution is already made possible (I hear cheering from 100 km east of me ;-))

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6. PL:

Population size units (17-18 November 2015, EEA)

We support the opinion that “individual” is not the most suitable unit for many animal species (amphibians, invertebrates). With some exceptions our monitoring schemes for animals are not focused on counting individuals, and only rarely on estimating local densities. For most species population data collected at the network of surveyed sites are only observations made in a standardized manner and cannot be used for estimates of local densities; they can be used only for comparative purposes between sites and investigating changes in time but not for estimating the total population (in numbers of individuals). And we do not see the need of establishing such monitoring schemes for every species which would give reliable data for estimating the number of individuals. This lack of data for part of species cannot be treated as “gaps in knowledge”. To assess the conservation status and define conservation goals for amphibians or invertebrates you need not to know how many individuals you have. Conversion of our monitoring data into individuals will result in so rough estimates that they will be useless for comparative purposes on the biogeographical level; the conversion task will be time-consuming and the data obtained – nonsensical. You cannot use such data for estimating trends.

From our point of view the list of exceptions is unsatisfactory as it do not give possibility to assess the populations of invertebrates and amphibians in the number of localities and because the number of inhabited trees is not a suitable unit for certain species, e.g. Buprestis splendens, Pytho kolwensis, Phryganophilus ruficollis. In Poland they are extremely rare. For example, on the basis of long-term studies it has been stated that to consider the population of Phryganophilus ruficollis in the Białowieża Forest to be in a good state, it is enough to observe or catch one individual during the period of 9 years. Other example: our first attempts to establish the monitoring scheme for Rosalia alpina based on counting of inhabited trees have completely failed. The majority of records of these species come from piles of logs (cut-wood) which act as “traps” for the species. On the other hand, our monitoring scheme for Osmoderma eremita (or rather O. barnabita in Poland) is based on counting inhabited trees (the recommended unit). But it is time-consuming and only a limited number of localities can been investigated in that way. The species is wide-spread, known from over 100 grid cells of 125 km2, so extrapolation of monitoring data to assess the population size in the number of inhabited trees at a biogeographical level seems unjustified. Moreover, this scheme is of no use for forest localities of this species (e.g. in Białowieża Forest).

Summing up, we propose still maintain the possibility to assess the population size in other units than recommended (individuals and other recommended units) and do not treat the conversion of other units into individuals as obligatory. For most invertebrates and for amphibians we can assess their populations in the number of localities.

In case of plants, we suggest to add to the table of species where alternative population size units should be used (List of exceptions) the species and population unit listed below in the table:

Species name Population unit

Adenophora lilifolia clump of individualsCaldesia parnassifolia number of leaves. On average 6 leaves = 1 individualCladonia spp. (subgenus Cladina) area covered by population in sq mSphagnum spp.-we suggest to extendto all genus from 1 species Sphagnum pyloesii

area covered by population sq m

Lycopodium spp. area covered by population sq mLigularia sibirica clump of individualsTrichomanes speciosum area covered by population (gametophytes) in sq dm [or sq m]

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7. SE:

Range maps (Art 12 and Art 17)GIS surface areas calculated from range maps were used in the past as a weight in the EU biogeographical assessment in the Art 17 reporting. This was used particularly for the reporting period 2000-2006, where sometimes a range map substituted a distribution map for species for which distribution was not known. The guidance for the range maps for the period 2007-2012 stipulates that the range map should be a spatial derivative of a distribution map. Due to this direct link between the distribution and range maps the importance of the range maps in the EU biogeographical assessment has significantly decreased. The range map is not used in the EU population status assessment under the Art 12.MS extensive comment Summary as reflected in the Xcel sheetThe range maps, and other “range” information (Art 17, Art 12)We tend to prefer keeping the range maps in the reporting format. There are arguments for and against, however, and weighting these is rather a decision for the Habitats committee, not for the Expert Group on Reporting. So this is not a final position from Sweden.Since range is a necessary part in the evaluation of conservation status (FCS), it still needs to be calculated by the MS in order to reach a conclusion on FV/U1/U2 by the MS. It is a reduction in reporting burden, but it is minor, at least to us. The main job is to calculate/estimate the range, not to upload the file. We consider that we would anyway have to make the file publicly available somehow – and thus, the (minor) reduction of EU reporting burden would be an even smaller reduction of workload for us, perhaps none at all in the end.From what we come to think of, the main argument for keeping the range maps in the reporting is that it can be used by scientists and the public to understand the reporting results (transparency). They can be able to question if strange range maps are used, and be able to suggest improvements where relevant. Enhancing public participation is in line with the Aarhus convention, and increasing the possibility for the scientific community to improve the reporting is in line with the intentions of the Habitats directive.If range maps are removed, it should be clearly stated in the proposal and acknowledged by those taking the decision that they choose this small, if any, reduction of workload knowing that transparency is lost (at least some) for this aspect. A risk of less harmonization between MS is possible if the range maps are removed. Removing it could perhaps be criticized on the grounds of public access to environmental information, as follows from the Aarhus convention, at least if some MS choose not to publish their range maps using other channels.On a more general note, regarding “range”, it seems questionable to us to ask for a lot of details for different time-frames, for example since the underlying assumptions – when calculating range from distribution – can make large impacts on the results. A simplification should be sought.

We tend to prefer keeping the range maps in the reporting format. There are arguments for and against, however, and weighting these is rather a decision for the Habitats committee, not for the Expert Group on Reporting. So this is not a final position from Sweden.

Trend of population and habitat area within the Natura 2000 network (Art 12 and Art 17)Together with the assessment of conservation/population status the assessment of contribution of Natura 2000 network to the conservation status is a key assessment done in the framework of the Nature Directives reporting. This assessment is linked to evaluation of impact of measures under the Article 6(1) of the Habitats Directive and Article 4(1) of the Birds Directive to the status of habitat and species. The assessment of impact of measures under the Article 6(1) is one of the requirements of the Article 17 of the Directive. The WP3 group (one the working groups under the Expert group on Reporting dealing with the review of 2007-2012 reporting guidance) identified the comparison of overall trends with the trends within the Natura 2000 network as one of components of this assessment. Short-term trend of population size and habitat area within the network is therefore crucial in assessing impact of the Natura 2000 network on conservation status. For the next reporting period this information should become mandatory.About ”Trend of population and habitat area within the Natura 2000 network, trend direction should become mandatory” (Art 17, Art 12)Expanding the format to include separate data for population size and habitat area for Natura 2000 areas is to ask for a whole lot of new data, when it comes to the situation in Sweden. In Sweden, a clear majority of most of the annex 1 habitats and annex 2 species occurrences are outside Natura 2000. Existing sampling systems for monitoring of species and habitats would have to be complemented with a lot of new samples within Natura 2000. In other words, if such new items is introduced in the format, it would require major efforts to increase our monitoring system and also add work in the analysis phase before the article 17 report (since

Increase in reporting burden. Depending on the intended use and prioritized users of the information, there might be a simpler and cheaper way to obtain enough information without introducing these new questions in the format. Perhaps, for example, an expert judgement on differences inside and outside Natura 2000 borders? Thus, we do not state a position from Sweden in this issue here during the work in the Expert group on reporting.

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we need to evaluate twice instead of once: not just the area as a whole, but also the subset of area included in Natura 2000).For a scientific point of view, we understand the interest of this information, but there are also other ways to get information about the efficiency of the management of Natura 2000 areas (see previous notes about future improvements of the format). Depending on the intended use and prioritized users of the information, there might be a simpler and cheaper way to obtain enough information without introducing these new questions in the format. Perhaps, for example, an expert judgement on differences inside and outside Natura 2000 borders? Thus, we do not state a position from Sweden in this issue here during the work in the Expert group on reporting.Population size (Art 17)For the reporting period 2013-2018 and as a general rule, the population size should be reported as the number of individuals (apart from agreed exceptions). Estimating population size in other units (such as numbers of localities or number of grids) at the national level is fully acceptable, but for the purpose of the reporting these estimates should be converted to number of individuals. Reporting population size in agreed units is essential for aggregation of data at the EU biogeographical scale and for producing the EU biogeographical assessments. At the EU level the information on the population size in local units cannot be systematically exploited. This information can therefore be provided in the un-structured textual way together with other information relevant for estimating the population size. The fields related to Alternative population size can be removed from the reporting format.The population size in individuals can be based directly on monitoring data with different levels of confidence or it can be converted from local units. A new field to report on type of estimate is therefore needed. This will for example allow distinguishing cases where the population size was measured using the reported units, or where it was converted from the local units. Further it will enable to flag that only minimum value is known or that instead of minimum-maximum interval an exact value (best estimate) is available for population size.Population size units (Art 17, Art 12)The discussion on population size units is important and should continue. We assume that it will not be possible to solve all these issues before the next reporting format needs to be decided, however. A few of the most obvious problems could perhaps be identified and discussed in time, trying to find better units for those. The rest will probably have to wait until the next revision (which could start as soon as the current format has been set).In general, we consider “individuals” to be a good starting point for the discussion, with exceptions as needed. Any proposed units should be evaluated regarding key aspects, including how well they will allow a detection of relevant (population size) changes in time to take action and how well data from different MS will be comparable.From these considerations, it follows that reporting “population size” by species occurrence or not in a large, 10 x 10 km grid is not a good option from a scientific perspective, in our view. (If we heard right, another MS has suggested this before.) This would give distribution or range data, not population size. However, if the grid is 1 x 1 meter, the data might in some cases be able to serve the intended purpose, as a proxy for population size. For stationary species (or almost stationary, like Vertigo snails) this can be easier to monitor, compare and evaluate than a number of “individuals“ – at least as long as the “population size“ is combined with useful information about habitat quality.As an example, for Vertigo snails, the density is much higher in rich fens in southern Sweden than in the northern alpine biogeographical region. This however does not necessarily mean that a loss of 10 square meters of Vertigo occurrence in the alpine region would be a less important impact on the population conservation status, than the same 10 square meters in the south. In other words, the choice of unit for “population size” is connected to the question of how a favorable conservation status is defined, and how the analysis is done. Our view is thus that the list of population units should be further reviewed, and if no better solution is found, keeping an option to report alternative population units should remain. When conversions are made, each MS should make sure that they keep documentation of those, available for anyone interested.

It's not possible to solve all population units issues before the next reporting format decision. Reporting “population size” by species occurrence or not in a large, 10 x 10 km grid is not a good option from a scientific perspective, in our view. This would give distribution or range data, not population size. However, if the grid is 1 x 1 meter, the data might in some cases be able to serve the intended purpose, as a proxy for population size.his can be easier to monitor, compare and evaluate than a number of “individuals“ – at least as long as the “population size“ is combined with useful information about habitat quality.

Trend of Future prospects/Future trends (Art 17)According to the Art 17 guidelines the status of Future prospects should reflect the likely Conservation status of the habitat or species in two reporting cycles. This link between the status of Future prospects and anticipated status of the habitat or species in two reporting cycles will be further strengthened in the updated guidelines.For many habitat and species which are currently in unfavourable status but are expected to show the first signs of improvement in close future (two reporting periods) the Conservation status will not reach better category in two reporting periods, as much longer periods are needed for restoration. In these cases it is however important to report on anticipated positive future trends (or on future mitigation of current negative trends,) mainly if these are linked to implemented conservation measures, even if these future trends will not result in change in the Conservation status category in two reporting periods. It is therefore suggested to add to the reporting format a new field for aggregated assessment of future trends. (See the Outcomes from the 2nd meeting of the ad hoc group for more details.)

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The trend in overall Conservation status (qualifier) should be based according to current Art 17 guidelines on trends over the reporting period that are expected to continue into the future. Defined in this way the qualifier encompasses two time horizons, the actual period and the foreseeable future. For the next reporting period the guidance for the qualifier should be updated to strengthen its link with trends during the reporting period (the future perspective should be removed from this assessment). The future perspective will be then reflected in the abovementioned new field for aggregated assessment of future trends.About “Future prospects”(Art 17)In our view, the format should be simplified in the section for future prospects, not expanded (as in your latest suggestion). Some looking into this future is obviously necessary, but answering for example if the trend in future prospects will be better or worse in 12 years from now would be guesswork. There is normally no way of knowing which political decisions that will be taken in the coming 12 years. We suggest that the reporting format is limited to questions which can be answered with reasonable certainty. If the main issue is to get information about positive changes or decisions (taken or perhaps even about to be taken), to be able to communicate those good examples, we suggest that the format asks for this instead. We would also like to point out that adding “trend of future prospects” increase the reporting burden, and we know from experience that this is hard to get approval for such increases from for example Sweden, unless the reasons are very good.When ”future prospects” are evaluated, the current format and guidelines can give counter-intuitive results for habitats threatened by climate change. For example, glaciers can be reported to have FCS even though the prognosis is bad in the long term (since the destruction is expected to go slow enough). A suggestion is to allow the future prospects evaluation to look further into the future if habitats or species are known to be threatened by climate change. After all, the directive itself does not state a limit of 12 years for “the foreseeable future”.

In our view, the format should be simplified in the section for future prospects, not expanded (as in your latest suggestion).

Information related to sustainability of hunting or exploitation of species (Art 12 and Art 17)The Annex II of the Birds Directive and Annex V of the Habitat Directive include species, which can be hunted or exploited in the wild. The Article 7 of the Birds Directive stipulates that ‘owing to their population level, geographical distribution and reproductive rate throughout the Community, the species listed in Annex II may be hunted under national legislation’, this should not however jeopardize the conservation of these species. The Article 16 of the Habitats Directive requests Member States (in the light of results of the Article 11 monitoring) to take measures to ensure that the taking in the wild of specimens of species of wild fauna and flora listed in Annex V as well as their exploitation is compatible with their being maintained at a favourable conservation status. For both Birds Directive and Habitats Directive hunting or exploitation is closely linked to conservation objectives outlined in the Directives (maintaining good conservation status of species populations). It is therefore important to establish a regular flow of information relevant for assessing sustainability of hunting or exploitation and their impact on conservation status. This information should be collected as a part of the Art 12 and Art 17 reporting.For huntable bird species it is proposed that it involves information on demographic factors influencing ability to withstand hunting pressure (productivity and adult survival) and hunting kill (bag) statistics. *see tables in document*“Sustainability on hunting of annex 5 species HD and annex 2 of BD should be introduced” (Art 17, Art 12)The language in the proposal for further information on sustainability of hunting of annex 5 species should be reviewed – for example, annual reproductive success and population growth rate are different measures. We would like to see some further information on the intended use of this information before we reach a conclusion about this proposal. The data obtained is likely to be difficult to assess on an EU scale, especially Annual hunting bag and Annual breeding success, as the quality will probably vary greatly between MS, Obviously it would increase the reporting burden since it is new items of information to report. In general, the Swedish position has been negative towards such increases in reporting burden, so you might want to consider removing something equally burdensome (or more) if you want to get such a proposal approved by the Habitats Committee. Narrowing the scope to only species of certain interest (not all annex 5 species for example) might also make the suggestion more palatable.

Review of language used in this section is needed (e.g. provided) and more information on how this data will be used. This will increase the reporting burden. Recommend narrwoing the scope of the species of certain interest.

About section 5.1 (Projects and plans with compensation measures) (Art 17)About section 5.1 (Projects and plans with compensation measures) (Art 17)Our suggestion regarding „which year to use“ for projects or plans with compensation measures (article 6.4) is the year of _final approval_ in the member state. But: This depends on the intended use of the data (like everything else). What is the most important question to answer from this section? It should be clarified. Perhaps giving a number on how many plans or project that are given a definitive go-ahead under the 6.4 conditions? If so, it is perhaps enough to ask for that number. If the number is

Our suggestion regarding „which year to use“ for projects or plans with compensation measures (article 6.4) is the year of _final approval_ in the member state

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remarkably low, it can be for at least two different reasons: projects which cause harm are instead authorised using 6.3 without compensation measures, or because projects that do harm are rejected. To separate those might be hard in the A17 report. If you want to try, perhaps questions could be added (5.1.7-8?) regarding if the plan/project actually went ahead, why it was not if it wasn’t (withdrawn, rejected…) and the section 5 should be stated/changed to include all plans and projects which by _any_ competent authority were deemed to cause harm, not only those which were given a go-ahead by the final decision (by the highest possible instance, if it was appealed).About habitat for the (annex) species (Art 17)

We support removing the estimation of habitat area from the format. For many species in Sweden it is difficult or impossible to come up with a well-founded figure to report, using current knowledge. Making such figures comparable between MS would also require work which it not started yet.

The new question, if there is enough habitat or not, is good in general. However, we consider that estimating if there is enough of unoccupied habitat (if there is not enough of occupied one) is often a difficult or impossible question, given the current limited knowledge of many species. If the use of this information cannot be clearly described, and the benefits outweigh the problems, we advise against it. Telling if an area is good enough habitat but still unoccupied, or if it is unoccupied because of some factor we are not aware of, is often difficult.

We support removing the estimation of habitat area from the format. The new question, if there is enough habitat or not, is good in general. Perhaps the question could be rephrased as “Is habitat availability limiting for the species to reach FCS?” with possible answers as yes, no and unknown.

8. UK:SUPPLEMENTARY UK COMMENTS TO EGR

ON THE ARTICLE 17 REPORTING FORMAT AND REPORTING

We are pleased to see significant positive progress in the revision of the Article 17 and 12 reporting formats.

In addition to our submission of UK comments embedded within the Article 17 and 12 reporting formats, we have a number of additional wider observations/suggestions for the Article 17 reporting format and the approach to Article 17 Conservation Status assessments:

Fields proposed for deletion or to at least be made optional In order to assess which reporting fields are of limited value and could be removed to reduce reporting

burden on MS, the UK has reviewed all of the habitat and species reporting fields, asking:i. how does the info in the field relate to the assessment of conservation status;

ii. how has the info been used to assess data quality or other purposes.

This has identified a set of fields that we have grouped under 5 headings:

1) List of published sources (1 habitat + 1 species fields) 2) Year or period of data (2 habitat + 3 species fields) 3) Trend period (4-5 habitat + 5-6 species fields) 4) Methods used, typical species (1 habitat field) 5) Methods used, pressures, threats (2 habitat + 2 species fields)

We have concluded that these fields should be removed (or at least made optional) because they contain information that:i. does not relate directly to the assessment of conservation status;

ii. has not been used by the Commission to assess data quality;iii. contains free text comparable to that in other fields that have been proposed for deletion;iv. does not need to be specified (e.g. the short-term and long-term trend periods are fixed at 12 and 24

years, so there is no need to specify this in each habitat/species report);v. provides information that is not meaningful; and/or

vi. is better seen as information that belongs in information audit trail retained by MS.

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Trends

We believe that it should be up to each Member State to decide whether either short-term or long-term trend magnitude, or both short-term and long-term trend magnitude should be assessed for each species and habitat type. Current proposals are that short-term trend is mandatory and long-term-trend is optional. MSs should be able to use the relevant trend period(s) to suit the ecology of the species and to make the most accurate conservation status assessment through the individual parameters.

We believe long-term trend should normally be used to assess conservation status across all parameters, i.e. short-term trend should only be used when long-term trend info is unavailable. This is because long-term trends are more readily measured, more detectable, and more meaningful:i. it unfeasible to compressively sample large populations and numerous sites over short periods of time,

such that any change over the short-term is often viewed as potentially being non-genuine;ii. short-term trends are more likely to arise in species that are prone to rapid changes in population

size, so-called ‘r’ strategists or ruderals (as opposed to ‘k’ strategists or competitors/stress-tolerators);iii. short-term declines, therefore, do not necessarily equate to unfavourable status, whereas longer-term

declines do;iv. it can be argued that the most relevant timeframe for the assessment of conservation status under the

Habitats Directive is the trend since a MS adopted the Directive;v. further, it can be argued that provided a population/habitat is not less than its corresponding FRVs it

should be assessed as favourable, i.e. trend information should not on its own be used to assess favourability (see diagram below)

Illustrative diagram to show why trend information can be misleading in assessing conservation status – provided the range and size of a population or habitat are not less than their FRVs, these parameters should be considered viable and therefore favourable

We recommend that the categories used for trend direction (see above) are revised to include: (i) decrease of 1%; and (ii) decrease of 1% or more – these relate directly to the thresholds in the evaluation matrix used to assess conservation status, reducing the need to report specific trend magnitude values.

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increasi

increasi

declinin

declinin

stabl

stabl

Unfavoura

Favourabl

2

1

Time

Pop/habitat size

FR

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Art. 17 & Art. 12 - Data quality fieldsThe current wording used for the categories in the ‘method used’ fields is hard to interpret and should be improved on:

Current wording Suggested revised wording3 = Complete survey or a statistically robust estimate

3 = Based mainly on comprehensive or reasonably comprehensive data or a representative sample

2 = Estimate based on partial data with some extrapolation and/or modelling

2 = Based mainly on extrapolation from a limited amount of data

1 = Estimate based on expert opinion with no or minimal sampling

1 = Based mainly on expert opinion with very limited data

0 = Absent data 0 = Insufficient or no data available

Art. 17 – Annex A additional fields.

7.1.3 Alternative species scientific name

OptionalScientific name used at the national level if different to 1.2.2

7.1.4 Common nameOptional In national language

Art. 17 – Annex D additional fields.

6.1 Proportion (%) of habitat type area with unfavourable Structures & Functions

Unfavourable Percentage of habitat type area.

OR less than 5% habitat type area unfavourable (<5%)

Tick if applicable

between 5 and 25% habitat type area unfavourable (5-25%)

Tick if applicable

greater than 25% habitat type area unfavourable (>25%)

Tick if applicable

?could also have a much greater than 25% habitat type area unfavourable (>>25%)

Tick if applicable

Art. 12, 7. Main Pressures and Threats tableLogical possibilities are:a) Inside MS Y/Nb) Inside EU Y/Nc) outside EU Y/NThus the logical combinations are:A onlyB onlyC onlyA+BA+CA+B+CB+Cunknown(I think) So there are 8 possibilities only 5 of which are given. Actually only four options are given as option 1 is the same as options 3+4 (*d) Location, options 2 to x

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