Response to the Report from the Commission to the European Parliament and the Council

Prague, 11 January 2022

Dear Madam, dear Sir

We are sending this public letter to you as a response to the REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of the common monitoring and evaluation framework, including an assessment of the performance of the common agricultural policy 2014-2020, published by DG AGRI on 16 December 2021. Paragraph 1.3. Experience drawn from the CMEF states: „However, there were also some shortcomings in the framework, not all linked to the CAP: the impact indicators on biodiversity (e.g. farmland bird index) and water (e.g. abstraction) were incomplete and of low quality due to the lack of a legal basis for data collection or reliance on voluntary surveys…. “

This surprising statement was not substantiated by any evidence, and we feel deeply upset by publishing such harmful and misleading comments on the commendable work of tens of leading scientists and thousands of skilled volunteers across Europe.

The Farmland Bird Index is a part of the set of wild bird indicators produced annually by the Pan-European Common Bird Monitoring Scheme (PECBMS), a joint initiative of the European Bird Census Council (EBCC) and BirdLife International with financial support from DG Environment. The common bird indicators were derived by leading scientists. Besides being used as indicators for rural development plans, they have been accepted as the biodiversity indicators for the EU´s Structural Indicator and Indicators of Sustainable Development of the EU. They have been used in several high-level global biodiversity assessments, the most recent being the Convention on Biological Diversity’s Global Biodiversity Outlook 5 . Other international institutions, e. g. Organisation for Economic Co-operation and Development (OECD) and European Environment Agency (EEA) have used the indicators, and the data are included in WWF‘s Living Planet Index (LPI). The indicators produced by the PECBMS are widely recognised as of the very highest scientific quality, and your unsubstantiated comments are without foundation.

The reliability of the indicators has been confirmed many times as the PECBMS results have been widely used in scientific research. The papers published in respected peer-reviewed scientific journals cover various topics such as the statistical development of bird indicators in general, exploration of driving forces behind bird population trends, development of climate change indicators, investigation of the land-use change, and its impact on farmland birds. A complete list of the nearly 40 peer-review scientific papers is publicly available on the PECBMS website.

In this public letter, we ask (1) that you explain fully what is meant by Farmland Bird Index being ‚incomplete‘. For example, the 2021 update of the index is based on high-quality data from 29 European countries, including all but one EU MSs, covering 39 different bird species. The only missing state is Malta, where no regular bird monitoring scheme is running so far but hosts very low proportions of common European bird populations. The data behind the indicators covers 40 years, and the indicators are published annually, with no interruption since 2003. Please substantiate your claim that the Farmland Bird Index is ‚incomplete‘and the implied criticism that comes with that claim.

We also (2) demand an explanation of the statement saying that the Farmland Index is ‚of low quality due to the lack of a legal basis for data collection or reliance on voluntary surveys‘. The wild bird indicators are based on structured data collected by well-designed and carefully operated biological monitoring schemes via standardised, scientifically tested, proven field methods by thousands of highly skilled and dedicated volunteers. The formal random-stratified sampling designs guarantee representative and robust data collection, and the data are carefully checked and analysed using advanced bespoke statistical models. The surveys conducted by trained and skilled volunteers are led and coordinated by professional scientists who ensure the robustness of the data.  All of our methods are fully peer-reviewed and published as best practices. We would very much welcome binding legislation that would secure stable funding of field monitoring. Still, we cannot see how monitoring of proven scientific quality could be qualified as “low quality“ on that basis.

We are confident that our outputs are as reliable as is reasonably possible. Note again, this scheme and our quality control development have been guided and funded by DG Environment since its inception.

We, therefore, ask you for a full public apology and rectification for your very misleading public statement. We are, of course, open to any facts based criticism and welcome relevant feedback to improve our work. However, we find your uninformed criticism of the Farmland Bird Index unsubstantiated and harmful both to the project, and all the scientists and citizen scientists involved, who have invested their time and efforts over decades, to create one of the most complete, well-respected and long-term databases, not only regarding birds but for biodiversity as a whole.

Yours sincerely

Dr Alena Klvaňová, PECBMS project manager, Head of the department of international monitoring and research at the Czech Society for Ornithology

Dr Petr Voříšek, PECBMS project advisor, Czech Society for Ornithology

PECBMS Steering  and Technical Group members:

Prof Richard Gregory, PECBMS project supervisor, Head of Monitoring at the RSPB Centre for Conservation Science, Honorary Professor at the Centre for Biodiversity and Environment Research (CBER) at the University College London

Dr David Noble, Head & Principal Ecologist at the British Trust for Ornithology

Anna Staneva, Head of Conservation at Birdlife Europe & Central Asia

Zoltán Benkő, Researcher at the Department of Conservation, Romanian Ornithological Society

Zdeněk Vermouzek, Director of the Czech Society for Ornithology