Protecting nature is often about spotting problems early, asking the right questions and knowing how to use the tools available. As members of the monitoring committee for the European Funds for Wielkopolska 2021-2027 programme, we did exactly that when we uncovered an EU-funded project that was destroying a valuable peatland in the name of climate adaptation. What followed shows how civil society, scientists and monitoring committees can work together to prevent environmental harm and improve the way EU funds are managed. 

In every EU Member State, monitoring committees made up of representatives of government, civil society, business and trade unions oversee each EU-funded programme, and sitting on one means staying on top of things. In addition to verifying selection criteria and discussing calls for proposals with the managing authority – the body that administers the funds, in this case the Marshal’s Office of Wielkopolska – committee members also have to monitor how the money is actually spent. This requires constant attention because no one keeps them informed about the projects being implemented. 

This was the case with the ‘pond restoration’ project in Kostrzyn in west-central Poland. Although we sit on the region’s monitoring committee, we learned about the project from local media. It looked far more like digging up an existing peatland than restoring a water body. The site, a historic peatland formerly known as Lake Pło, consists of several water bodies surrounded by peat-forming ecosystems. Until recently, the peat was still largely hidden beneath meadow vegetation, but local authorities later decided to excavate part of the site and transform it into a recreational pond. Despite its ecological value and significant role in carbon storage, the peatland was increasingly treated as undeveloped land rather than a sensitive wetland requiring protection.  

Experts warned that the project ran counter to its own stated aim of climate adaptation. As it was financed by EU funds earmarked for climate adaptation, we could not stand by and ignore such an obvious misuse of public money. 

Checking the documentation

The project was launched in May 2025 with support from the European Regional Development Fund and was due to be completed by September 2025. Its stated aim was to improve climate resilience by creating a retention reservoir. By the time we started investigating, construction was already underway. 

We immediately called for the project to be suspended until its environmental impacts could be properly assessed. The local authorities refused, and work on the peatland accelerated. While our campaign gained momentum, the ecosystem was disappearing day by day. 

After analysing the documentation and consulting peatland experts, what struck us most was that it made essentially no mention of a peatland at the site. As a result, the Regional Directorate for Environmental Protection in Poznań did not require an environmental impact assessment. It evaluated the project without the full picture. 

Our analysis also revealed a broader, systemic problem with how wetlands are classified and managed under Polish law. Official planning documents still described the area as a meadow, despite the presence of a peatland ecosystem, while the funding application described it as a pond. This may sound like a technicality, but it had important legal consequences. 

In Poland, meadows are often treated as ‘wasteland’ for economic purposes, and areas classified this way frequently escape the environmental procedures that would normally apply to protected ecosystems. Wetlands can therefore be altered or excavated with limited scrutiny – a loophole that contributes to the degradation of peatlands across the country. 

Our main objection was that spending EU funds on the project was inconsistent with the goal of climate adaptation. We also highlighted a flawed assessment of compliance with the ‘do no significant harm’ principle, which is meant to prevent EU money from funding projects that damage nature. Because the site’s ecological value had been mischaracterised, the assessment failed to consider the project’s impact on the ecosystem actually present: a peatland. Wielkopolska is a region highly vulnerable to drought, and peatlands are a natural ally in the fight against climate change.   

Our investigation found further procedural irregularities. The Regional Directorate had not been given complete information about the excavation works, as the assessment relied on outdated documentation prepared for a different investment. Following our intervention, the full documentation had to be resubmitted for reassessment. We therefore also maintained that an environmental impact assessment should have been carried out. 

We called on the authorities to: 

• stop further work on all projects funded under this call that may not be in line with climate adaptation objectives; 
• apply financial corrections to the Kostrzyn project, which conflicts with the objectives of the Ramsar Convention on Wetlands, the Nature Restoration Regulation, the European Water Resilience Strategy, and the Water Framework Directive;  
• introduce wetland protection standards in the regional programme; 
• train staff at the Marshal’s Office of Wielkopolska and project evaluators on climate adaptation; 
• introduce additional horizontal criteria to stop EU funds going to projects that conflict with climate adaptation objectives; and 
• make expert consultation mandatory for climate adaptation projects. 

Cooperation is key

Working groups attached to monitoring committees serve as forums for more in-depth discussion of EU funds, including specific projects and calls for proposals. The working group meeting we initiated, held in July 2025, was the first opportunity for a broader dialogue among everyone involved in the Kostrzyn peatland case. It brought together environmental organisations, peatland experts, staff from the Marshal’s Office, representatives of the project beneficiaries, and representatives of the European Commission. 
 
During the discussion, the question of peat extraction came up. This turned out to be significant, as we had initially been assured that there was no peat at the site. A geotechnical analysis, however, showed otherwise – and for unexplained reasons, it had not been included in the documentation submitted for review. 

These discussions led to concrete action at a follow-up meeting in April 2026. New evidence that peat had been excavated at the Kostrzyn site prompted the submission of updated documentation to the Regional Directorate for re-evaluation. 

The impact of our monitoring work went beyond this single case. Another municipality, Czerwonak, withdrew its plans for a similar wetland project before construction began, following interventions by our team and wetland experts, and revised them in line with the experts’ guidance. These experts also delivered training sessions and field visits for local authorities to build understanding of the vital role wetlands play in climate adaptation. 

Their expertise informed new wetland conservation guidelines for the regional programme, which are now a mandatory part of the ‘do no significant harm’ assessment for projects affecting wetlands. The regional authorities have since recommended that the guidelines be adopted across Poland – showing how one local case can drive wider change. 

In July 2026, the Regional Directorate ruled that the Kostrzyn project did not require an environmental impact assessment. Even so, the effects of our work are already visible. Systemic changes are in place that will help protect wetlands in future, and municipalities will now scrutinise planned projects more closely. What made this possible was cooperation between environmental organisations, scientists and government officials. Without it, environmental initiatives are far more likely to fail. 

This case is also a concrete example of why the partnership principle matters for the quality of EU-funded investments. A cornerstone of cohesion policy, the principle is put into practice through monitoring committees, which act as eyes and ears on the ground, making sure cohesion policy funds comply with legislation and serve local needs. As a recent report by Civil Society Europe and CEE Bankwatch Network shows, partnership and dialogue with civil society are not optional – they are firmly anchored in EU law and values, and they bring real benefits, as this case demonstrates.

Special thanks for their help with the activities described here go to Miłosława Stępień (member of the monitoring committee for the European Funds for Wielkopolska 2021-2027 programme, CEE Bankwatch Network), Mariusz Lamentowicz (Adam Mickiewicz University in Poznań), Bogdan Chojnicki (Poznań University of Life Sciences), Katarzyna Doroszewska-Chyrowicz and Adrian Chochoł (Frank Bold Foundation), and Aneta Mikołajczyk (member of the monitoring committee for the European Funds for Wielkopolska 2021-2027 programme, ZaZieleń Coalition, Poznań). Without you, we would not have been able to bring this matter to a successful conclusion.