This document constitutes the contribution of four environmental non-governmental organizations (ANP|WWF, LPN, Palombar and SPEA) for the second stage of the extended consultation process of the Portuguese Strategic Plan under the Common Agricultural Policy for 2023-2027.
We would like to emphasize that this contribution is far from what these NGOs want, even though we tried to do it under the limitations imposed by the non-participatory consultation model of PEPAC, considering that the public consultation process was open during the unacceptable period of 11 working days. This is obviously a very short period to analyse the documentation related to 95 PEPAC measures that were only made available to the public in the first day of public consultation.
Furthermore, the isolated contributions we presented before (one of the times under the first extended public consultation and two other times following contacts to the GPP by these NGOs initiative, in May 2020 and November 2021) were never answered from GPP. Given the content of the intervention sheets in public consultation in this stage, we can easily conclude that none of these contributions was integrated in the PEPAC proposals, which further limits the possibility of a constructive participation by NGOs.
This document is divided in two parts: Part A, with the general and transversal comments to the documents that were possible to analyse; Part B, with specific comments about each one of the analysed measures (there are some sentences in the beginning highlighted in grey that are transcripts from the intervention sheets to help identify the commented aspect).
Read the complete version of the technical advice here (in Portuguese).
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