SNB 2030: What Can We Expect from the New National Biodiversity Strategy?

Two years behind schedule and after several months of consultations and revisions, the final version of SNB 2030 (i.e., the National Biodiversity Strategy for 2030) was unveiled on Monday, November 27, 2023, in the presence of Prime Minister Elisabeth Borne, the Minister of Ecological Transition, Christophe Béchu, and the Secretary of State for Biodiversity, Sarah El Haïry.

What does this new strategic plan for biodiversity entail? What can we expect from it? Carbone 4 breaks it down for you.

The SNB—what is it all about?

The National Biodiversity Strategy, or NBS, is in line with France's commitment under the Convention on Biological Diversity(CBD)^[1]. This is a roadmap developed by the government that sets out the major national objectives and action plans regarding biodiversity. It should make it possible to implement, on a national scale, the Global Biodiversity Framework (GBF) adopted by the parties to the convention at COP15 in December 2022^[2] (see our article (on this topic).

The SNB 2030, or 3rd SNB, follows the two previous SNBs (2004–2010, 2011–2020) and the 2018 biodiversity plan. Its objective, in line with that set by the GBF, is to “halt and reverse the loss of biodiversity by 2030.” It is therefore a key document in ecological planning, in conjunction with the new National Low-Carbon Strategy (SNBC) and the new National Climate Change Adaptation Plan (PNACC).

SNB 2030: 40 Measures by 2030 to Reverse the Decline of Biodiversity

The SNB 2030 identifies 40 measuresby 2030, organized into four main areas:

1. reduce pressures on biodiversity
2. restore degraded biodiversity wherever possible
3. mobilize all stakeholders
4. ensure that the necessary resources are in place to achieve these goals.

Some Specific actions are associated with each measure, with their own timeline and plan of action. Details are provided in the “measurement data booklet” published by the government^[3].

Among the major measures proposed are:

• The announcement of funding allocated to biodiversity, with an unprecedented budget of one billion euros planned for 2024. A plan to gradually reorient or phase out subsidies that are harmful to biodiversity is also expected to be developed starting in 2024.
• "Strong protection" covering 10% of the national territory (compared with 4.2% today) by 2030. The government also announced the creation of another national park dedicated to wetlands, the location of which has yet to be determined.
• Renewed ambitions, for exampleon land development (halved by 2030, as part of the effort to achieve net-zero emissions by 2050) or reducing pesticide use (The Ecophyto 2030 plan is currently under public consultation, with the goal of reducing the use and environmental impact of plant protection products by 50% compared to the 2015–2017 period). Other areas of focus include reducing light pollution and plastic pollution along coastlines, as well as combating invasive alien species, etc.
• A National Biodiversity Restoration Plan, aimed in particular at restoring natural grasslands, hedgerows, wetlands, and forests.
• Various measures aimed at raising awareness, fostering integration, and encouraging action among public and private stakeholders, for example, through reporting requirements or support programs.

Overall, with the exception of a few specific points, The SNB will likely not take the form of binding regulations. As Sarah El Haïri’s office pointed out, “this strategy has no existing legal basis, and the government has no intention of establishing one.”^[4] . The rollout of the SNB should be based on cooperation with local authorities, through regional biodiversity strategies and the engagement of local stakeholders by organizing regional COPs in 2024. Follow-up should also be conducted annually, as the government has committed to providing an annual report on its progress to the National Biodiversity Committee (CNB).

What are the implications for businesses?

While the SNB is not directly binding on businesses, it does provide an indication of the necessary sector-specific directions and the systematization of new requirements for economic actors. Given the failure of previous SNBs, the involvement of all stakeholders in the region is crucial to achieving the stated objectives; businesses have a major role to play.

Several points in this 3rd National Health Plan directly or indirectly affect businesses:

• Under Priority 1 (“Reducing pressures on biodiversity”), several measures are proposed to support economic sectors identified as priorities : agriculture, fishing, aquaculture, energy, construction, transportation infrastructure, tourism, and culture (Measures 12 through 18).
• Under Priority 3 (“Mobilize All Stakeholders”), Measure 31, titled “support companies' commitment to biodiversity” brings together several initiatives that directly affect businesses^[5] :
  • The Implementation of Non-Financial Reporting Requirements, to ensure greater transparency and to ensure that these issues are taken into account in corporate strategies: the CSRD, along with the ESRS E4 standard specific to biodiversity, and the implementation of Article 29 of the Energy and Climate Law.
  • Supporting companies in implementation reporting and the integration of biodiversity into their strategies. This includes, in particular, support provided by BPI France and ADEME to microbusinesses and small and medium-sized enterprises (SMEs) in assessing their biodiversity challenges, as well as the widespread adoption of the OFB’s “Engagés pour la nature” program.
  • Work cycles in collaboration with industry associations and companies to raise awareness among economic stakeholders and identify the barriers and drivers specific to each sector.
• Finally, under Priority 4 (“Ensuring the resources needed to achieve these goals”), Measure 39 aims, in particular, to “mobilize private funding for biodiversity”. Among the objectives are: standardizing reporting on the biodiversity impacts of investment portfolios and financial products; promoting the integration of biodiversity considerations into savings products; and financing biodiversity restoration projects.

Is the SNB up to the challenge?

The international framework emerging from COP15 had been hailed as historic by many stakeholders, although it remained vague, as we had pointed out in this article. During the presentation of the SNB 2030, Environment Minister Christophe Béchu announced that “this is France’s most ambitious biodiversity strategy to date.” It is indeed clear that the level of ambition has increased compared to previous SNBs, whose objectives and associated resources had proven to be rather meager. In particular, this time around we can welcome the unprecedented announcement of dedicated funding : This is the first time the SNB will be allocated specific funding—a budget of one billion euros for 2024—entirely dedicated to water and biodiversity.

However, there are several points that call for caution. First of all, while the texts may sometimes seem promising, it is important to remember that The goals of the two previous SNBs—which were far less ambitious—were not met at all. In the introduction to the SNB 2030 report, the government itself acknowledges that "The pressures affecting biodiversity were not significantly reduced by the previous strategy." The same is true of the evaluation report published regarding the first National Health Plan. There is reason to fear that the same cause—namely, a non-binding document that more or less reiterates broad recommendations that have been known for decades—might produce the same results.

Subsequently, several environmental NGOs, institutions, and national councils voiced their criticisms of the content of this National Biodiversity Strategy during the process of drafting and revising the text. While these comments were partially taken into account, Several omissions and inaccuracies are still regretted and criticized :

• While the agricultural sector is one of the most affected, both in terms of impacts and dependencies, The proposed agricultural strategy has been criticized as largely inadequate. The measures are primarily based on national programs currently being rolled out (the Water Plan, the Hedge Pact, the Ecophyto Plan, etc.), and the announced ambition appears to rely heavily on the National Strategic Plan (PSN), an extension of the CAP that is not expected to be revised until 2025. Furthermore, “despite the stated ambition regarding hedgerows and legumes, (…) grasslands, and the reaffirmation of a 50% reduction in pesticides by 2030, the strategy defers the issue of agricultural subsidies harmful to biodiversity to a new inspection mission by government agencies, less than a year after an initial IGF/IGEDD mission that had estimated them at nearly 7 billion euros.”^[6]. Jean Burkard, director of advocacy at WWF France, believes that “if France does not better integrate agriculture into its biodiversity strategy, it will fail to meet 8 of the 23 targets of the Global Biodiversity Framework by 2030.”
• Furthermore, as previously criticized regarding the Global Biodiversity Framework (GBF) adopted at COP15, To date, there is no precise definition that standardizes the term “strong protection,” andwhat this implies in terms of protected area management, leaving room for many interpretations^[7].
• The restoration plans are also open to criticism on several points, such as the apparent lack of integration of biodiversity into the announced forest management plan^[8].
• Finally, it is regrettable that the fight against subsidies that are harmful to biodiversity is not yet on the agenda, with the review postponed until 2024. Even if the measure is deemed necessary, it will still be some time before it is implemented. Yet it is hard to believe that these ambitious goals can be achieved in just over six years unless we very quickly stop using public funds—amounting to several billion euros a year—to finance activities that are harmful to biodiversity.

It is also important to note that a large portion of the proposed measures rely on the implementation of programs and laws that have already been adopted, such as the ZAN target on land conversion or the Ecophyto plan on pesticide use. Given the difficulties and failures encountered so far (the successive failures of the Ecophyto plans since 2008^[9], widespread resistance and negotiations regarding the ZAN among local elected officials^[10], etc.), implementing these measures poses a real challenge; their effectiveness therefore remains to be seen in the coming months and years. Given these challenges, the lack of a binding legal framework for most of the measures unfortunately risks limiting the plan’s broader impact.

However, the existence of a timeline with specific deadlines and metrics for tracking progress offers hope that that the outcome of this National Biodiversity Strategy will be better than in previous periods. The National Biodiversity Committee will conduct an annual review of progress.

In any case, the mobilization and involvement of all stakeholders, including businesses and financial institutions, will be essential to bringing about real change; as will the establishment of effective governance and genuine cooperation with civil society.