Restructuring APA and ICNF: simplification or weakening?

Milvoz considers it essential to closely monitor the Government’s announcement regarding the restructuring of the Portuguese Environment Agency (APA) and the Institute for Nature Conservation and Forests (ICNF), as part of efforts to streamline environmental, agricultural and maritime licensing procedures.

We recognise that there are structural problems in the functioning of these bodies, notably a shortage of human and technical resources, procedural delays, administrative fragmentation and insufficient capacity for on-the-ground monitoring. Improving administrative efficiency and modernising procedures are legitimate and necessary objectives.

However, administrative simplification must not result in a lowering of environmental standards, a weakening of independent technical assessment, or a reduction in the capacity to prevent ecological impacts. At a time when Portugal’s ecosystems are facing increasing pressures, it is essential to ensure that any institutional reform strengthens, rather than undermines, the mechanisms for environmental protection and biodiversity conservation.

The area in which Milvoz operates is also home to important biodiversity hotspots, many of which remain vulnerable to multiple threats and lack adequate legal protection. The association’s experience on the ground has shown that many environmental impacts are widespread across the landscape and irreversible: the destruction of native habitats, ecological simplification or the loss of populations of endangered species cannot be addressed through an approach based on retrospective enforcement.

We therefore consider it essential to ensure that this restructuring process:

- maintains the technical independence of the APA and the ICNF;

- preserves the rigour of environmental assessments;

- strengthens active enforcement and on-the-ground monitoring;

- ensures transparency and effective public participation;

- is accompanied by a genuine increase in human and scientific resources.

Protecting nature is not an obstacle to development. On the contrary, it is an essential prerequisite for ecological resilience, for people’s quality of life, and for long-term economic sustainability.

Milvoz will continue to monitor this process closely, advocating for environmental management based on scientific knowledge, the precautionary principle, and the protection of the region’s and the country’s valuable natural heritage.