The EU Nature Restoration Law (NRL) and the Common Agricultural Policy (CAP): State of the Art and Future Challenges for Italian Water Resources

Round 1

Reviewer 1 Report

Comments and Suggestions for Authors

The paper present an interesting analysis of the alignment of two major EU policy frameworks, ie the Nature Restoration Law (NRL) and the Common Agricultural Policy (CAP). The paper provides the reader a valuable reference in exploring these two policies. Below some suggestion to further improve the paper.

1. To ease the reader the column headings in table 1 sshould include also (or only) the keywords referring to the different objectives of the NRL
2. Page 9 Rows 310 - 320. The weak connection between CAP SOs referring to economic and social sustainability and the main goals of the NRL is not surprising. I invite the authors to discuss more in depth the fact that this evidence highlight the potential trade offs between the three pillars of sistainability, a problem that is often underestimated.
3. Page 9, row 335-336. The authors areccorrect in remrking that some NRL targets are not considered within the CAP framework. I am wondering if besides missing synergies between the two policy instruments, could be identified also potential conflicts. I strongly encourage the authors to review the CAP framework to assess if potential conflicting goals could be identified. This could lead to include in table 1 also adverse interactions (may be with red check marks).

Author Response

Comment 1 - To ease the reader the column headings in table 1 should include also (or only) the keywords referring to the different objectives of the NRL.

 

Answer to Comment 1 - Thank you for the suggestion. The Table 1 has been modified and improved.

 

 

Comment 2 - Page 9 Rows 310 - 320. The weak connection between CAP SOs referring to economic and social sustainability and the main goals of the NRL is not surprising. I invite the authors to discuss more in depth the fact that this evidence highlights the potential trade-offs between the three pillars of sustainability, a problem that is often underestimated.

 

Answer to Comment 2 - Thanks for the comment. The following part has been added at row 321, with relevant references: “This misalignment reflects a broader trend within the CAP 2023–2027 framework, where economic sustainability objectives, particularly those aimed at enhancing farmers' income and competitiveness (SO1, SO2, SO3), are often prioritized over social and – foremost - environmental goals (50–52). As the EU Court of Auditors recently observed, the CAP Strategic Plans for 2023–2027 are greener than those from the previous period, but they fall short of meeting the EU’s climate and environmental ambitions – while also lacking key elements needed to assess green performance (52)”.

 

 

Comment 3 - Page 9, row 335-336. The authors are correct in remarking that some NRL targets are not considered within the CAP framework. I am wondering if besides missing synergies between the two policy instruments, could be identified also potential conflicts. I strongly encourage the authors to review the CAP framework to assess if potential conflicting goals could be identified. This could lead to include in table 1 also adverse interactions (may be with red check marks).

 

Answer to comment 3 - Thanks for the comment. The following paragraph has been added at p. 10 "Despite the promising synergies between the CAP and the NRL targets, different hurdles due to differing priorities and implementation strategies still remain. This is evident especially for what regards environmental commitments, namely the area where an enhanced alignment is highly desirable in sight of the climate neutrality targets set by the Green Deal. In fact, it must be highlighted how, thanks to the high degree of decentralization and flexibility envisaged by the new delivery model of the CAP 2023-2027, a relevant part of the actual environmental ambition largely depends on Member States' implementation choices and on farmers’ voluntary measures. Therefore, without stringent guidelines, monitoring and accountability, there is a risk of minimal environmental progress (50)"

 

Reviewer 2 Report

Comments and Suggestions for Authors

The paper focuses on the research of the impacts of the EU Nature Restoration Law (NRL) and the Common Agricultural Policy (CAP) on Italian water resources. The overall structure is relatively complete, and the logic is relatively clear, providing valuable ideas for research in related fields. However, during the careful reading process, I found that some parts of the paper may still need further improvement. The following are some personal suggestions, hoping to contribute a little to the optimization of the paper:

1. In the introduction section, the review of existing research is not in - depth enough. It fails to fully sort out the achievements and deficiencies of previous studies on the relationship between NRL, CAP, and water resources, making the necessity and innovation of this research not fully reflected. It is recommended to supplement a comprehensive analysis of previous relevant research, summarize the main findings and unsolved problems of existing research in aspects such as policy coordination mechanisms and impacts on Italian water resources.
2. For Figure 1 mentioned in the paper, only the theme of the chart is briefly described in the text, but the key information, data trends, and symbol meanings in the chart are not explained in detail. It is recommended to add a detailed description of Figure 1 in the text to help readers better understand the content of the chart and its role in the research. In addition, the text in Figure 1 is not very clear, and its resolution can be further improved.
3. In the research methods section, the data collection and analysis methods can be further refined. Although the paper expounds on the data collection steps, the implementation details of each step, the reliability of data sources, and the specific operation process of the analysis method are not described in detail. Therefore, it is recommended to describe the specific implementation process of each data collection step in detail.
4. In the results and discussion section, when elaborating on the synergies and gaps between the CAP and NRL goals, there is a lack of specific case support, and the discussion is relatively abstract, making it difficult for readers to intuitively understand the actual associations and differences between the two. It is recommended to supplement specific cases. For example, when referring to the contribution of CAP - supported agricultural practices to NRL goals, list actual farm or regional cases.
5. In the Italian scenario analysis section, the description of the implementation status of some measures in the Italian CAP Strategic Plan is brief. For example, for the ACA2 measure, only the number of activated regions is mentioned, and the implementation effect, obstacles faced, and reasons are not analyzed in depth, making it impossible to comprehensively evaluate the impact of this measure on water resource management and NRL goals. It is recommended to conduct an in - depth investigation of the implementation effect of the ACA2 measure in the six activated regions and analyze the reasons why the measure is not implemented in non - activated regions.
6. The suggestions put forward in the conclusion section lack pertinence and operability. The responsible subjects and implementation paths are not clearly defined, making it difficult to guide actual policy - making and implementation. It is recommended to clarify specific responsible subjects such as government departments, agricultural institutions, and scientific research units according to the problems and challenges proposed in the previous text, and provide detailed implementation paths and time nodes.

 

 

Author Response

Comment 1 - In the introduction section, the review of existing research is not in - depth enough. It fails to fully sort out the achievements and deficiencies of previous studies on the relationship between NRL, CAP, and water resources, making the necessity and innovation of this research not fully reflected. It is recommended to supplement a comprehensive analysis of previous relevant research, summarize the main findings and unsolved problems of existing research in aspects such as policy coordination mechanisms and impacts on Italian water resources.

 

Reply to comment 1 - The authors enriched the introduction section with some additional references to more recent studies on the NRL and the CAP, and added the following part:

"However, it must be highlighted how the scientific research investigating the connections between the CAP instruments for water resources, on the one hand, and the NRL, on the other, is still moving its first steps, given the recent adoption of the regulation. In fact, there is a lack of studies focusing on the potential synergies between the CAP Strategic Plans’ interventions and the NRL objectives specifically targeting freshwater resources".

Given the novelty of the adoption of the NRL (August 2024), and the equally novel entry into force of the national CAP Strategic Plan (Jan 2023), the studies which specifically focus on the NRL/CAP relationship with a focus on freshwater resources is almost still non-existent today. This is one of the main reasons for this paper - i.e., for this first preliminary effort in recognizing the potential synergies and gaps on this specific aspect (synergies between the NRL targets and CAP interventions on freshwater resources in Italy. Please note that the authors discussed the main challenges of this novel aspect in the Results and Discussion part. 

 

 

Comment 2 - For Figure 1 mentioned in the paper, only the theme of the chart is briefly described in the text, but the key information, data trends, and symbol meanings in the chart are not explained in detail. It is recommended to add a detailed description of Figure 1 in the text to help readers better understand the content of the chart and its role in the research. In addition, the text in Figure 1 is not very clear, and its resolution can be further improved.

 

Reply to comment 2. Thank you for the suggestions. The resolution of the figure has been improved and the text has been reformulated with additional details on the outcome indicators examined.

 

 

Comment 3. In the research methods section, the data collection and analysis methods can be further refined. Although the paper expounds on the data collection steps, the implementation details of each step, the reliability of data sources, and the specific operation process of the analysis method are not described in detail. Therefore, it is recommended to describe the specific implementation process of each data collection step in detail.

 

Reply to comment 3. Thank you for the suggestions. The phases of the methodology used have been rewritten with greater detail, with increased attention to the adopted bibliographic references.

 

 

Comment 4 - In the results and discussion section, when elaborating on the synergies and gaps between the CAP and NRL goals, there is a lack of specific case support, and the discussion is relatively abstract, making it difficult for readers to intuitively understand the actual associations and differences between the two. It is recommended to supplement specific cases. For example, when referring to the contribution of CAP - supported agricultural practices to NRL goals, list actual farm or regional cases.

Reply to comment 4 – The part has been enriched with some regional case studies represented by the Eco-Regions. Part added: “Other examples of synergies between the CAP-supported agricultural practices to NRL targets in Italy can be found in the case of the so-called “Bio-distretti” (“Eco-Regions”, in English), which operate in almost every Italian region [1]. Eco-Regions represent an innovative form of territorial governance in which citizens, institutions, farmers and other actors in the agricultural chain enter into a pact for sustainable land management, according to the principles of organic farming (66,67). Experiences such as the Lazio Eco-Regions demonstrate the effectiveness of integrating the CAP with local initiatives in favoring production models with a low environmental impact, with particular attention to the protection of aquatic ecosystems and biodiversity (68). For example, several organic farms in the Tuscia and Sabina areas (Lazio region) are already applying conservative soil management and low-consumption irrigation practices, combined with the creation of on-farm wetlands and rainwater harvesting basins, in line with the objectives of the NRL. These experiences show how the coordinated application of agricultural and environmental policies can lead to concrete solutions to mitigate the effects of climate change, promote ecological connectivity and ensure efficient management of water resources, while increasing agricultural incomes and territorial resilience.”

 

 

Comment 5 - In the Italian scenario analysis section, the description of the implementation status of some measures in the Italian CAP Strategic Plan is brief. For example, for the ACA2 measure, only the number of activated regions is mentioned, and the implementation effect, obstacles faced, and reasons are not analyzed in depth, making it impossible to comprehensively evaluate the impact of this measure on water resource management and NRL goals. It is recommended to conduct an in - depth investigation of the implementation effect of the ACA2 measure in the six activated regions and analyze the reasons why the measure is not implemented in non - activated regions.

 

Reply to comment 5 - The section 4.2. A focus on Italy: assessing the alignment between the national CAP Strategic Plan and the NRL targets for freshwater resources described in detail the framework of the objectives, scope, required commitments and regional specificities foreseen by the measure SRA 2- Specific commitments for the sustainable use of water, as defined in the CAP Italian Strategic Plan 2023-2027 and in the Regional Programming Complements. In particular, the specific objectives of the measure, the technical commitments, the eligibility conditions, the eligible crops and the regional diversification of the support amounts and intervention priorities defined in coherence with the local environmental and production characteristics were illustrated.

The part describing the ACA 2 measure has been expanded with an additional paragraph and a Table: “The measure SRA 2 of the Italian CAP Strategic Plan aims to promote sustainable water management in agriculture. The objective is to reduce water wastage and improve the adaptation of farms to the effects of climate change through the introduction of innovative systems that support the farmer in irrigating according to actual crop needs. The SRA 2 measure was foreseen in the Rural Development Complements 2023-2027 by six out of the twenty Italian regions, namely Calabria, Campania, Lazio, Toscana, Umbria and Veneto with specific adaptations to the territorial needs. The measure provides for an annual payment to farmers who voluntarily commit to advanced water management practices. These practices consist in the use of expert systems for calculating the soil-plant-atmosphere water balance that estimate the irrigation volumes needed for each crop according to the phenological phase and seasonal climatic conditions. These tools allow a sustainable use of water, ensuring efficiency in both the volumes delivered and the timing of irrigation interventions.

There are several commitments required from the beneficiary. First of all, water must be withdrawn according to regionally defined irrigation methods from authorised sources such as surface networks or groundwater tables, and high-efficiency irrigation systems such as micro-irrigation or sprinkling must be used, excluding low-efficiency systems such as run-off or lateral infiltration from furrows. Each plot must be equipped with a farm meter to monitor the irrigation volumes distributed. In addition, the farmer must subscribe to a regional web-based irrigation assistance system that provides indi-cations on the volumes to be administered and the timing of interventions. The volumes actually distributed must comply with the system's indications and irrigation opera-tions must be supervised to avoid malfunctions. Each intervention must be accurately recorded including dates of sowing, harvesting and all irrigations carried out. Records must be kept in digital or paper format. Then, adhesion to the measure involves specific eligibility criteria. Individual and associated farmers or public bodies managing agri-cultural holdings may join but the regions have established additional requirements such as the minimum area under commitment in relation to the farm area and the list of eligible crops. Eligible crops vary according to the regional context and range from horticultural and floricultural crops to irrigated arable land, fruit, olive trees and vines.

At the regional level, intervention is implemented in a differentiated manner. In Calabria Region, for example, horticultural, floricultural, arboreal and irrigated arable crops are eligible, and all selection criteria are applied to favour environmental effectiveness. The Lazio Region limits eligible crops to spring-summer arable crops, kiwi and hazelnuts and focuses on vulnerable areas. The Region of Tuscany only includes species for which irrigation assistance is available with a focus on protected and Natura 2000 areas. In the Umbria Region intervention is only available for certain crops such as vegetables, tobacco and fruit. The Veneto Region activates the intervention only in the plain and hills, in regional irrigation districts, with the obligation of drawing from the surface network and excluding the water table. Each Region also establishes the amount of support, which varies from a minimum of around 100 euro to over 800 euro per hectare per year with degressivity thresholds applied only in some Regions.

In sum, the ACA2 intervention aims to support the climate resilience of agro-ecosystems, while contributing to the objectives of the WFD and the NRL by facilitating the transition to low water uses production models. The expected impacts of ACA2 implementation are:

• Active farmer participation: ACA2 encourages the adoption of monitoring and decision-making systems based on climate data, promoting dynamic management of irrigation volumes and times.
• Optimisation of irrigation volumes: A structural reduction in agricultural water withdrawals is envisaged through precision irrigation techniques and improved system efficiency.
• Climate adaptation: ACA2 will strengthen the ability of farms to respond to periods of water stress and mitigate production losses due to drought and extreme weather events.
• Contribution to biodiversity conservation: Reduced water abstraction and calibrated water use limits pressure on aquatic ecosystems and promotes the conservation of associated habitats.

On the other hand, some barriers to the ACA 2 implementation are:

• Limited access to initial investment: modernising irrigation practices requires large financial resources, which are not always available to small farms, especially in marginal or disadvantaged areas.
• Low levels of digitalisation and technical skills: the transition to 'data-driven' irrigation practices requires advanced technical skills that not all farms have, especially in less innovative areas.
• Fragmented institutional coordination: the complex governance of water re-sources in Italy, between river basin districts, regions and irrigation con-sortia, slows down the homogeneous application of ACA2 measures at national level.
• Climatic variability and lack of data: the rapidity of meteorological changes and the lack of local monitoring stations hinder the correct planning and calibration of irrigation practices.

The following table summarizes the key impacts and the main obstacles regarding the implementation of the ACA2 at the regional level:

 

Region	Key Impacts	Main Obstacles
Calabria	Modernization of irrigation systems (drip and meteorological monitoring); water efficiency improved.	Difficulty for small businesses to access investment funds.
Campania	Improved irrigation management in fruit and vegetable farming; enhanced quality and yield.	Fragmented farming sectors and low digital literacy.
Lazio	Improved precision irrigation and meteorological monitoring; benefits for productivity and water resources.	Coordination challenges between water resource managers and farmers.
Toscana	Infrastructure restoration and adoption of sustainable irrigation in viticulture and olive cultivation.	Bureaucratic barriers for small businesses to access funds.
Umbria	Good adoption of irrigation techniques in cereals and viticulture, integration with climatic models.	Infrastructure maintenance challenges for secondary irrigation networks.
Veneto	Advanced adoption of sensors and irrigation practices in viticulture and specialized horticulture.	Limited access to resources for small hilltop farms.

Source: Authors’ elaboration from the SWOT analysis before the drafting of the Italian CAP Strategic Plan (71) and from the Italian CAP Strategic Plan (51).

 

 

Comment 6 - The suggestions put forward in the conclusion section lack pertinence and operability. The responsible subjects and implementation paths are not clearly defined, making it difficult to guide actual policy - making and implementation. It is recommended to clarify specific responsible subjects such as government departments, agricultural institutions, and scientific research units according to the problems and challenges proposed in the previous text, and provide detailed implementation paths and time nodes.

 

Reply to comment 6 - Thank you for the suggestions. The authors agree on the need to make the proposals more operational and relevant. At present, with regard to the Nature Restoration Law (NRL), it remains challenging to define a common strategic approach, as an official framework for drafting the NRL plan has yet to be adopted.

 

The national restoration plans will have to set a clear timeframe for implementation, indicate the financial resources required, specify the expected sources of funding and illustrate the expected benefits, with a focus on the contribution to climate change adaptation and mitigation. Member States will also be required to identify synergies with other relevant policy areas such as combating soil degradation, natural disaster prevention, agriculture, fisheries, forestry and renewable energy development.

Each country will have to submit a draft plan to the Commission within two years of the Regulation's entry into force, i.e. by mid-2026. This draft will have to define the milestones for achieving the targets set for 2030, 2040 and 2050. The plans will have to be developed in a transparent and participatory manner, ensuring the involvement of the public and all stakeholders.

The European Commission, in addition to assisting the national authorities in preparing the plans, will assess the drafts submitted and may make comments which Member States will be invited to take into account when preparing the final documents. Within six months of receiving any comments, each country will have to finalise, publish and submit its final plan to the Commission.

Implementation will be monitored by the European Environment Agency, which will produce regular technical reports on progress towards the targets. Member States will also have to revise their plans at least twice, by 2032 and 2042.

In Italy, responsibility for drawing up the plan has been given to the Ministry of the Environment. At this stage, however, it is too early to assume the formal involvement of institutional actors at the local level or to clearly define their possible role in the process.

This paper, however, serves as a starting point for the authors to stimulate further discussion and gather contributions that may inform the development of concrete strategies in the future.

 

[1] In Italy there are fifty-one established Eco-Regions in 2025, and five Eco-Regions in way of development. The Map of all the EU Eco-Regions is available here.

Reviewer 3 Report

Comments and Suggestions for Authors

General comments

This manuscript focused on the identification of “synergies between the EU Nature Restoration Law (NRL) targets and the Common Agriculture Police (CAP) to enhance the alignment of conservation priorities with policy and practice”. This is a novel subject, as it hasn´t been addressed before. The article is well organized very well written.

The introduction is consistent, and addresses the main issues that support the status of the subject studied. The objectives are clearly exposed at the end of this section. A succinct outline is also included.

Then, a section is devoted to “context analysis”. This includes three subsections devoted to: a) an overview of the current state of Italian internal surface water bodies (SWBs), b) the NRL targets for freshwater resources, and c) a review of water resource management within the framework of the 2023-2027 CAP reform.

The material and methods section is adequate and robust. In this section, the methodology used to assess the potential alignment between NRL targets for freshwater resources and the CAP Specific Objectives (SOs) are clearly described.

The results and discussion section is consistent and well presented. All analyses, figures, tables and supplements are relevant and necessary to the discussion that the article addresses. First, the alignment between the NRL targets are scrutinized and the CAP objectives at in the studied period are scrutinized, and then, they insight on the Italian scenario is considered. Also, synergies between the national CAP Strategic Plan and the NRL targets for freshwater resources are assessed.

Conclusions are correctly derived from the results and linked to the objectives of the study.

From a total of 59 references 38 were published in the last five years (2010-2025), highlighting the fine quality the paper.

In summary, this is an interesting article, brings significant scientific contributions and can be accept to published in this journal with minor modifications.

 

Specific Comments:

1) Following “Land” guidelines, keywords shouldn’t be capitalized, with exception of the first key word.

2) Please, consider to redraw and simplify Figure 1. This Figure could be clearer after re-elaboration.

3) Although the manuscript is very well written, some minor corrections of the text are needed. Please, see my comments below.

 

 

 

 

Comments on the Quality of English Language

Please, double check the text to correct several minor issues, and to increase readability, as for example:

• For example, see Line 96. Please, change “3rd” by 3^rd
• Idiomatic expressions. For example, Line 114. Please, consider to use “Regarding…”
• Punctuation marks. For example, Line 171, change (;) by (.). Pay attention to several errors in the references. For example, Lines 632. 636, 646, etc., etc.
• Several sentences are too long, repetitive or even difficult to understand.

 

 

Author Response

Comment 1 - Following “Land” guidelines, keywords shouldn’t be capitalized, with exception of the first key word.

 

Answer to Comment 1 - Thank you for the suggestions. The suggestion has been acknowledged and incorporated into the revised text.

 

Comment 2 - Please, consider to redraw and simplify Figure 1. This Figure could be clearer after re-elaboration.

 

Answer to comment 2 - Thank you for the suggestions. The suggestion has been acknowledged and incorporated into the revised text. The figure will also be attached separately during the resubmission.

 

 

Comment 3 - Although the manuscript is very well written, some minor corrections of the text are needed. Please, see my comments below.

 

Answer to comment 3 - Thank you for the suggestions. It has been done, also thanks to final Language editing service.  

Round 2

Reviewer 2 Report

Comments and Suggestions for Authors

This manuscript addresses a highly relevant and timely topic: the interactions between the EU Nature Restoration Law (NRL) and the Common Agricultural Policy (CAP), with a specific focus on water resource management in the Italian context. The paper presents a well-organized structure, a solid methodological framework, and an in-depth analysis of policy measures, particularly the SRA02-ACA2 intervention. The research offers significant policy insights, especially in the light of the European Green Deal and the increasing relevance of ecosystem-based water governance.

The manuscript makes a useful contribution to the ongoing discourse on sustainable agriculture and environmental restoration under the evolving EU legislative landscape. The authors’ use of a keyword-based cross-referencing matrix, supported by detailed case-level analysis, is appropriate and effective.

However, the manuscript would benefit from minor revisions aimed at improving clarity, language precision, and consistency in terminology. No major methodological or conceptual revisions are necessary.

1.Simplify and shorten overly long and complex sentences throughout the manuscript. For example: “The integration of CAP and NRL policies presents an opportunity to promote sustainable agriculture while protecting water resources and restoring natural ecosystems.”

2.Avoid repeating the same policy analysis (especially on SRA02-ACA2) in both Section 4.2 and the conclusion.

3.Improve transitions between major sections (e.g., from policy background to methodology) with clearer linking sentences.

4.Ensure consistent use of acronyms and abbreviations. The term “Nature Restoration Law (NRL)” should be defined at first use and consistently abbreviated thereafter.

5.Define all lesser-known abbreviations at first mention (e.g., EAFRD = European Agricultural Fund for Rural Development).

Author Response

 

Comment 1 - Simplify and shorten overly long and complex sentences throughout the manuscript. For example: “The integration of CAP and NRL policies presents an opportunity to promote sustainable agriculture while protecting water resources and restoring natural ecosystems.” 

 

Answer to Comment 1 - Thank you very much for the valuable suggestion. The manuscript has been carefully revised to simplify and shorten overly long and complex sentences, as recommended. Where necessary, sentences have been restructured to improve clarity and readability. Corrections have been highlighted in red. 

 

 

Comment 2 - Avoid repeating the same policy analysis (especially on SRA02-ACA2) in both Section 4.2 and the conclusion. 

 

Answer to Comment 2 - Thank you for the helpful comment. The text has been revised to avoid repetition of the policy analysis on SRA02-ACA2 in both Section 4.2 and the conclusion. Redundant content has been removed or rephrased to ensure clarity and avoid duplication. Corrections have been highlighted in red. 

  

 

Comment 3 - Improve transitions between major sections (e.g., from policy background to methodology) with clearer linking sentences. 

 

Answer to comment 3 - Thank you for the suggestion. Transitions between major sections have been improved with clearer linking sentences, and the changes are marked in red in the manuscript. 

 

 

Comment 4 - Ensure consistent use of acronyms and abbreviations. The term “Nature Restoration Law (NRL)” should be defined at first use and consistently abbreviated thereafter. 

 

Answer to comment 3 - Thank you for the suggestion. The necessary corrections have been made, acronyms have been used consistently throughout the manuscript, and "Nature Restoration Law (NRL)" has been defined at first use and abbreviated where necessary. 

 

 

Comment 5 - Define all lesser-known abbreviations at first mention (e.g., EAFRD = European Agricultural Fund for Rural Development). 

 

Answer to comment 3 - Thank you for the suggestion. All lesser-known abbreviations, including "EAFRD" (European Agricultural Fund for Rural Development), have been defined in the manuscript.