JTF should not be used to support any peat products or peat extraction

Dear Commissioners Elisa Ferreira and Virginijus Sinkevičius

We are writing to you on behalf of the Finnish Association For Nature Conservation, the oldest and one of the biggest environmental NGO’s in Finland.

Referring to our earlier correspondence with Mr Peter Berkowitz about the use of Just Transition Fund for developing new peat products and peat extraction for other than energy use. As stated in the letter (Ref.Ares(2021)4657916 – 19/07/2021) by Mr Berkowitz “In this context, the JTF should not support activities that harm the environment. Member States should take the ‘do no significant harm’ principle into account during the
programming stage, as for all other cohesion policy funds, and during the process of defining the types of operations in the territorial just transition plans.”

We are concerned that the regional plans for Finland fail to recognize and apply the ‘do no significant harm’ principle when it comes to peat products and other ways to use peat besides burning and peat extraction. Peat extraction is a harmful practice causing a loss of a peatland habitat and ecosystem, CO₂ emissions from the drained peatland soil and leaching of nutrients from peat to waters. In our opinion the JTF should not be used to support any peat products or peat extraction.

Further information: Liisa Toopakka, Policy Officer, liisa.toopakka@sll.fi, +358 40 5042 989

Yours sincerely,

SUOMEN LUONNONSUOJELULIITTO RY

Harri Hölttä                                      Tapani Veistola
Chair                                                   Acting Executive Director

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