EURAF’s briefing #18 (v5) adds (p6 onwards) information on the Commission Notice providing “Guidance on a framework for developing methodologies to monitor high-diversity landscape features pursuant to Article 14(7) of the Nature Restoration Regulation”. We conclude that this 20-page note could have been avoided if EURAF’s advice had been followed and the distinction between “productive” and “non productive” trees had been removed from NRR text. There is no such thing as a non-productive tree in agriculture, all trees are potentially productive since they not only give environmental services, but timber, fuel wood, shade, shelter fruits, fodder etc. Given the pressure on European forests to meet carbon removal and bioeconomy needs, and growing the risks from climate change, it must be clear that Trees outside the Forest are a productive resource which must be managed. The “Rural Simplification Omnibus”, promised for Q4 of 2025, should therefore remove all mention of “non-productive” trees from the NRR and make it clear that the woody landscape features measured for NRR compliance are exactly those which must be measured for CAP compliance, and which were previously measured in the EFA layer of the LPIS as part of compliance with the Greening Regulation in the previous CAP.
