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Scientists and experts in the field of wildlife conservation and management of natural resources wrote an open letter to the President of the European Commission Ursula von der Leyen, Vice-President of the European Commission Frans Timmermans, and the EU Commissioner for the Environment Virginijus Sinkevicius addressing the risks associated with the construction of a 186-kilometer long and 5.5 meters high fence along the border between Poland and Belarus. The border wall will cut through the Białowieża Forest, Europe’s last old-growth woodland, scarring protected areas of a UNESCO World Heritage site.
We are publishing the full letter below.
As scientists and experts in the field of wildlife conservation and management of natural resources, we call the European Commission to take all the possible measures to immediately halt the construction of the wall along the border between Poland and Belarus until an environmental impact assessment of this project on the coherence of the Natura 2000 network is carried out in accordance with European law and nature conservation requirements, and until the project design ensures the minimization and mitigation of the potential impacts on valuable species and natural habitats.
Białowieża Forest is the last remaining temperate lowland forest in Europe, existing with little human disturbance since the end of the last ice age. Other forests of this kind were destroyed as a result of the development of civilization in Europe. Białowieża Forest spans across the Polish-Belarusian border making its conservation a delicate international issue.
The construction of a permanent, 186km-long wall along the border of Poland with Belarus has already started on 25th January 2022. According to the Polish Ministry of Interior and Administration, the wall will be 5.5 meters high and will consist of 5 meters high steel poles set on a concrete foundation, topped with a coil of razor wire. In addition, as part of the new Uniformed Services Modernisation Programme for 2022-2025, the Polish Border Guard plans to build an electronic fence along the entire length of the Eastern border of the European Union. In November 2021, an Act on the Construction of the State Border Security entered into force. As a result, the border wall project has been exempted from the application of, inter alia, the current construction law, water law, environmental law, regulations on the provision of environmental information and the protection of agricultural, forest and environmental land. The construction work is to be carried out in three shifts (24 hours/day) and completed within 150 days. The project costs have been estimated at PLN 1.6 billion (EUR 350 million).
Many sections of the planned wall will cross protected and valuable natural areas, including six Natura 2000 sites: Białowieża Primeval Forest, Augustów Forest, Ostoja Knyszyńska Forest, Biebrza Marshes, Ostoja Nadbużańska, Bug River valley.
The construction of the wall will create a barrier with devastating consequences, leading to permanent interruption of the functional connectivity of the ecological corridors of the Natura 2000 network on the national and European scale. The impacts on these Natura 2000 areas also during the construction phase, involving logging and road development, will be detrimental for the conservation status of species and habitats.
For instance, the border wall will cross an ecological corridor of pan-European importance: GKPn-2 Białowieża Primeval Forest. Being the main axis of the Northern Corridor, this corridor is among the ecological corridors most important for preservation of forest and water and marsh habitats in Central Europe. The GKPn-2 corridor constitutes a functional connection between the Białowieża Forest and the forest habitats of Belarus and Ukraine, with the forests of central and western Poland and, further, with western Europe, being the main dispersal route of large mammals at the continental scale (key species: grey wolf, Eurasian lynx, European bison, European elk).
The ecological consequences of the collision of the wall with the GKPn-2 corridor will be multifaceted and large-scale, as the barrier the wall will result in the isolation of the habitats in the western and eastern parts of the Białowieża Forest, which will prevent movements of many animal species and their gene flow, which may lead, among others, to the collapse of the Polish lowland lynx population. The GKPn-2 corridor is also of priority importance for the preservation of the cohesion of the Natura 2000 network on continental scale with regards to forest, water and marsh habitats.
The creation of such an ecological barrier as a result of construction of the wall will cause, among others, functional and spatial isolation of the Polish part of the Białowieża Primeval Forest from its eastern part on the Belarusian side. As a result, the Białowieża Forest, which is especially important for the preservation of integrity and ecological connectivity of water and wetland and forest habitats, will be spatially and functionally divided. This will threaten the preservation of many key natural processes which underlie fulfilling the criteria for the Białowieża Forest's inscription on the UNESCO World Heritage List.
Despite this, in the process of planning the wall construction, no assessment of the environmental impact of the project on the conservation objectives of the Natura 2000 site Białowieża Primeval Forest was carried out, which constitutes a clear infringement of Article 6(3) of the Habitats Directive.
Such key issues as the collision of the wall with ecological corridors of priority importance for the preservation of forest habitats connectivity on a central European scale, or the impact of the project on populations of large mammals such as the European bison, wolf, lynx, elk and deer were neither diagnosed nor assessed.
The design of the "animal crossings" structures which have been presented to the public may not be effective as functional wildlife crossings allowing a sufficient level of animal movement and guaranteeing an effective minimization of the wall barrier effects on forest habitats and species. Taking into account the cumulative effects of breaking the integrity of the other five Natura 2000 sites, all these issues should be subject to a substantive and in-depth analysis.
While understanding the need to protect the integrity of the European Union border and being aware of other aspects of the situation on the Polish-Belarusian border, we take the firm view that this project must be implemented in accordance with European Union law and with utmost care for the protection of our common natural heritage.
We, therefore, call for all possible steps to be taken to halt the construction of the wall until an environmental impact assessment is carried out and until it is ensured that appropriate mitigation measures are implemented. We would also like to encourage European Leaders to raise environmental and conservation issues in their diplomatic contacts with the Belarussian government.
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