Profiling the Current Curriculum of Land Use Planning and Management Practices in the EU

1. Introduction

Land use change, defined as the modification of land from one use to another, plays a vital role in shaping environmental, socio-economic, and territorial dynamics. This process includes various transformations such as the intensification of agriculture, reforestation initiatives, and urban expansion. Such changes have a profound effect on climate regulation, the integrity of biodiversity, and the resilience of food systems, thereby serving as a crucial element in both environmental degradation and the prospects for sustainable transitions. Originating from agronomy, the term land-take refers to investigating factors responsible for the loss of agricultural land [1]. It is regarded as a critical phenomenon that plays a role in numerous environmental challenges, such as soil sealing, declining biodiversity, erosion, soil degradation, flooding, and desertification. Additionally, land-take is perceived as a factor that aggravates the consequences of climate change and leads to indirect modifications in land use. The complex interrelations of previously outlined processes often render delineating conceptual boundaries challenging. Land-take is associated with urbanization and the development of artificial surfaces, suggesting a progressive increase in settlement areas or artificial surfaces over time, usually at the cost of rural landscapes [2].

As the world’s most developed and urbanized continent, Europe has undergone significant land-use transformations, primarily driven by urbanization and industrialization, resulting in a steady decline in cropland and a moderate increase in forested areas and pastures [3,4,5]. Mediterranean landscapes are an example, as they have safeguarded a diverse agricultural heritage for many years. However, this has been increasingly compromised by the spread of dispersed and spatially discontinuous urbanization, especially around cities [6].

The ongoing trend of urban sprawl, a primary concern for European metropolitan structures and socio-economic activities [7] has significant implications. Urban sprawl and land-use transformations have been manifested differently across various countries, driven by localized factors tied to geographical, demographic, and socio-economic conditions, along with the historical, political, and cultural narratives of each area [8]. For instance, the residential sprawl observed in many British and French cities contrasts sharply with the semi-dense, unregulated urbanization patterns in southern Europe and the highly regulated, compact urban models in eastern European cities [9]. As Europe becomes increasingly susceptible to natural disasters, it is essential to mitigate biodiversity loss, adapt to climate change, and halt land degradation by rehabilitating wetlands, peatlands, coastal ecosystems, forests, grasslands, and agricultural lands. Between 2012 and 2018 (Figure 1), urban areas in the EU-27 and the UK experienced a land take of 3,581km², accompanied by an estimated increase in soil sealing of 1,467km², mainly at the expense of croplands and pastures. This soil sealing has resulted in a loss of potential carbon sequestration, quantified at approximately 4.2 million tons of carbon during the observed period. Notably, almost 80% of the land appropriated in urban settings was situated in commuting zones, vital for wildlife habitats, carbon storage, flood mitigation, and food production [10].

Currently, the EU lacks a legally binding policy target for land-take. However, the new EU Soil Strategy 2030 requires Member States (MS) to establish land-take targets for 2030 to attain neutrality by 2050 [10]. Recognizing that the EU does not have direct control over spatial planning is essential. Even though the EU’s role is limited to defining the regulatory framework and potential restrictions in this area, it grants MS considerable autonomy in developing their legislative frameworks for spatial planning. To illustrate, specific MS have outlined their aims for reducing land take. In 2002, Austria committed to significantly decreasing land-take, aiming to drop it from 0.25km² per day to 0.025km² per day by 2020. In 2002, Switzerland also set a goal to limit land consumption to 400m² per person gradually. In contrast, Germany emphasized the preservation of agricultural land for food production and established a target of 0.3 km² per day by 2020, as indicated in its 2016 report [2]. On the contrary, Poland’s agricultural land conversion rates are currently among the highest in Europe [11]. Such alterations in land use and the depletion of soil resources may lead to irreversible consequences for fragile landscapes, influencing or entrenching inequalities in access to high-quality soils among different actors [12]. Thus, the soil consumption resulting from urbanization can be interpreted as a spatial justice concern, notably when it modifies the distribution of high-quality soils along the urban continuum [13]. Studies have shown that soil resource depletion is associated with territorial disparities, economic underdevelopment, poverty, and increased human pressure on sensitive rural areas [14].

This study intends to illuminate the conceptual distinctions among diverse legal frameworks and provisions related to land use in the five countries examined. The research scope has been explicitly identified and articulated, focusing on providing a detailed exploration of the national legislative frameworks related to soil consumption and land use alterations. The primary aim of this study is to delineate the key provisions, highlight the distinctions among various regulations, and identify any significant gaps or deficiencies. In summary, this study seeks to contribute to the ongoing dialogue on how legal provisions can be improved to efficiently address the evolving land use challenges in a rapidly changing world.

2. Materials and Methods

A comprehensive review of the literature and regulatory sources provided a wide-ranging overview of the existing legal frameworks, concentrating on the contrasting approaches to land-use matters. The keywords selected to conduct the analysis were “land use management,” “land use–land take,” “land-use change,” “land-use, land cover (LULC),” and “land degradation”. The study incorporated a wide array of resources, including official websites of relevant government ministries, legislative databases such as those of the European Parliament, legal databases like Eur-Lex, FAO-Lex, Normattiva, the official portal of the Parliament of Ukraine, as well as research through platforms like Google Scholar and European databases, including the official website of the EU and the EEA. The timeframe for the above search was set between 2018 and the present to capture and derive the most updated results. Overall, the study presents a comprehensive assessment of land-use regulations, highlighting key challenges and emphasizing the need for robust, transparent, and harmonized guidelines to effectively support sustainable land-use planning.

3. Results

Land use and land cover are closely related, with land use acting as a catalyst for changes in land cover [15]. Human activities associated with land use significantly impact the characteristics and processes, resulting in ongoing transformations of land cover. Consequently, alterations in land use or unsustainable management practices affect the supply of services, impacting not just individual services but the entire ecosystem [16]. In 2018, the EU set Regulation 2018/841 regarding greenhouse gas emissions (GHG) and Land Use, Land Use Change, and Forestry (LULUCF) removals. Among the targets set for 2030, the GHG removal is expected to be 310 million tons of CO₂ equivalent. The regulation emphasizes the enhancement of governance, the promotion of transparency, and the strengthening of the connection between climate mitigation initiatives and environmental protection policies¹. The newly adopted Regulation 2023/839 of 19 April 2023 has already been amended. In conjunction with the Directorate-General for Climate Action and the EEA, the EU has assigned a consortium of contractors to create a Handbook² to support the execution of the updated regulation. This Handbook delivers practical insights, examples, and case studies from MS. It incorporates the latest methodologies and monitoring data to enhance the reliability of GHG emissions and removals within the LULUCF sector’s emission inventory. Moreover, it promotes disseminating knowledge and experiences to strengthen GHG monitoring in the land sector, ensuring that it accurately represents the effects of various policies and measures. The initial edition of the Handbook was introduced in December 2023 during a workshop held in Copenhagen.

From an international perspective, the United Nations Sustainable Development Goals (SDGs) for 2030, which aim towards climate neutrality, have incorporated Land Degradation Neutrality (LDN) into target 15.3. The target supports other targets, such as SDG Target 11.3, which addresses sustainable urban development, and SDG Target 15.1, referring to ecosystem conservation and restoration [17]. The notion of LDN was brought into the global discourse to foster a more robust policy response to the challenges of land degradation and, based on UNCCD, 2016, is “a state whereby the amount and quality of land resources necessary to support ecosystem functions and services and enhance food security remain stable or increase within specified temporal and spatial scales and ecosystems” [18]. The pursuit of LDN involves a strategic alignment of actions that include a) preventing the degradation of healthy land, b) lessening the degree of land degradation, and c) restoring or rehabilitating degraded land [19]. Table 1 presents all relevant EU missions, strategies addressing land degradation, and the target commitments.

Various factors, including agroclimatic conditions, historical land uses, deregulation of land use and cover, socioeconomic factors, and land management schemes, significantly influence the patterns of land systems in the EU. Historical land use significantly influences the current condition of land systems, with effects that can last for decades or even centuries [20]. For instance, the eastern border of Germany experienced its first wave of agricultural intensification in the late nineteenth century, characterized by extensive farming estates [21]. In contrast, neighboring Polish regions were dominated by family and small-scale farming, a difference that is still apparent today. These Polish areas exhibit high-intensity management systems, particularly in crop production and forestry. Agroclimatic conditions also significantly influence the patterns of land systems in Europe. Despite the introduction of technological innovations and significant investments to counteract these conditions, such as drainage, fertilization, and irrigation, agroclimatic factors continue to be a key determinant of land-use intensity. Delving deeper, the urbanization trends are notably strong in certain European areas, particularly along coastal regions and Western Europe, often accompanied by the abandonment and declining intensity of land use in the hinterlands. This situation can be partially linked to rural-urban migration, driven by rising per capita GDP in urban areas and diminishing income opportunities in rural regions [22]. Such trends have been observed in Italy [23], the Mediterranean [24], Switzerland [25] and Eastern Europe [26]. Consequently, the phenomenon of abandonment in Europe can be divided into two main types: (a) the rural exodus type, where urbanization and reduced income opportunities in rural areas lead to abandonment, especially in mountainous and Mediterranean regions, and (b) the post-socialist type, triggered by significant socio-economic and institutional changes after 1990. Both trends occurred in Eastern Europe.

Other factors, such as transferring land-based production to regions outside the EU, significantly influence the stability of Europe’s land systems. The “outsourcing” of agricultural activities to areas with lower production costs now constitutes roughly one-third of the land required to meet Europe’s demands [27]. Finally, the deregulated urban development, especially prominent in Italy and Greece, in conjunction with ineffective land management, has sometimes caused a divergence in the quality of natural resources, which could influence the socio-ecological conditions in the area [28]. Historically, Mediterranean regions have relied on low-quality soils to support forests and pastures, with fertile soils dedicated to agriculture. However, urban expansion increasingly competes with agricultural land for these high-quality soils [29]. This trend has had a detrimental impact on the economic health of the primary sector and the sustainable delivery of vital ecosystem services in peri-urban settings [30].

Table 2 systematically presents the five countries’ legislative frameworks, highlighting their respective targets and goals for minimizing land-take. The accompanying data and information delineate the critical articles and chapters of the laws and the rationale behind their creation.

According to the findings of Chatzitheodoridis et al. (2024), Greece is notable for its lack of a unified national urban strategy and a “non-planning” heritage [31]. Various studies have pointed out the deficiencies in spatial planning within Greece, highlighting the ineffectiveness of enforcing building and planning regulations and the notably protracted timeline for land use plan approvals [32]-[33]. The state does not systematically and intentionally select which regions to govern through spatial planning. Instead, it tends to respond in a fragmented manner, often reflecting on past actions rather than planning proactively [34]. Due to remarkable urban sprawl over thirty years spanning from 1990 to 2018, the country’s rapid and uncontrolled land change has significantly altered more than 1,700 km², from rural and forested lands into urban uses. If this trajectory continues, urban land coverage is expected to double the extent recorded in 1990 by 2030 [35]. The national government assumes the most significant responsibilities in Greece’s multifaceted spatial planning system. It manages the essential legislative framework concerning regional and urban planning, environmental safeguarding, and regional development initiatives. Additionally, the authority endorses almost all spatial plans implemented throughout the country. Of the 25 distinct types of spatial plans available, 22 have been officially supported by the national government. The role of regions in land use is largely restricted. They primarily engage in advisory capacities, assisting in formulating various spatial planning documents [36]. In the same report, the OECD notes that many spatial plans remain in effect despite being replaced by recent ones, resulting in considerable convergence between the various plans.

Italy is a unitary country; nonetheless, its land-use planning system adopts characteristics commonly associated with federal structures. The primary legal guidelines governing the planning process are derived from regional laws and regulations. Municipalities play a crucial role in determining land use at the local level, primarily through implementing the Local Development Plan (LDP) [37]. In 1942, the national legal framework established a three-level planning system, comprising regional plans (Piano Territoriale di Coordinamento Regionale- PTCR), commonly integrated into a web-GIS data system called SITAP³⁰, founded in 1996, which focuses on the management, consultation, and distribution of information concerning restricted areas as per the prevailing landscape protection legislation. The second tier of the hierarchy pertains to the provincial plans, known as the Piano Territoriale di Coordinamento Provinciale (PTCP), while the third tier is associated with municipal planning. The aforementioned plans are implemented in conjunction with the Piano di Assetto Idrogeologico– PAI, which aims to mitigate hydrogeological risk while ensuring compatibility with existing land uses, thereby protecting public safety and reducing potential damage to vulnerable properties. This system provided an overarching regulatory context for the local plan (Piano Regolatore Generale- PRG), incorporating zoning stipulations [38]. The LDP delineates strategies designed to protect and improve the landscape, potentially imposing restrictions on the nature and scale of development permitted in areas recognized for their natural, cultural, or historical importance. This legal framework for planning in Italy has been in effect since 1942. The system was initially established to control the outward spread of urban agglomerations, with a strong emphasis on expropriation and public development efforts. Although later reforms and court decisions have reduced this emphasis, the LDP has remained fundamentally unchanged as the primary planning instrument [37].

Italy does not possess a national law dedicated to reducing land-take or revitalizing urban environments. Since 1970, however, it has delegated all legislative and executive functions of these areas to the Regions, which enact their laws (Leggi Regionali Urbanistiche) delineating urban planning procedures. A case in point is the Basilicata Regional Planning Law (L.R. 23/1999³¹), which oversees territorial planning to ensure the robust protection of natural and cultural resources, facilitate effective urban regeneration, and support the establishment of resilient infrastructure. The lack of a unified strategy has resulted in regional laws exhibiting considerable variation in scope and detail. Each region may have numerous plans that cover the full extent of the regional area, specific conservation zones, and a wide array of municipal land use plans [39]. Differing regulations, geographical scopes, and designated authorities characterize these plans. The overarching goal of most existing laws in Italy, which vary by region concerning land use management, does not emphasize planning as a fundamental aspect. Instead, it views urban regeneration primarily as enhancing specific segments of urbanized land, achieved through physical-spatial and urban development planning, sometimes supported by volumetric or economic incentives [40].

In France, the challenges associated with land use planning are multifaceted, mainly stemming from the inherent discord within a governance system that features a dominant national government actively involved in nearly all areas of French society, juxtaposed with a strong tradition of local democracy. This dynamic has given rise to many elected local governments, commonly known as communes [41]. Land use planning is merely one of the many responsibilities that these governmental entities manage. France’s planning system has traditionally been characterized as a “regional economic” approach, which seeks to achieve various social and economic objectives, particularly in addressing regional disparities in wealth, employment, and social conditions [42]. Recently, this system has begun to evolve towards a “comprehensive, integrated” approach, emphasizing spatial coordination through a hierarchy of plans, moving away from a primary focus on economic development [42]. Until the 2000s, the predominant purpose of spatial planning in France was to orchestrate urban development and locate economic activities. Today, however, the focus has shifted towards curbing urban sprawl, conserving natural and agricultural environments, and steering development to prioritise energy efficiency, resulting in lower GHG emissions [43]. France’s approach to spatial planning is increasingly characterized by an integrated framework that spans several thematic areas, including ecosystem protection, climate change adaptation and mitigation, and land use management. Moreover, there is a significant focus on comprehensive strategies that advocate for inter-municipal planning initiatives [41]. France does not have a comprehensive national spatial planning system; the country utilizes only sectoral guidelines articulated through the Schémas de Services Collectifs (SSC) [44]. Established in 2000, the Schéma de Cohérence Territoriale (SCoT) functions as the essential document at the local level. Voluntary groups of municipalities formulated it, including the Projet d’Aménagement et de Développement Durable (PAAD), which tackles essential concerns regarding spatial quality and environmental protection [45]. Within macro-regional planning, the Directive Territoriale d’Aménagement (DTA) is an obligatory instrument to tackle the pressing environmental challenges encountered in expansive natural territories, including areas such as the Alpes Maritimes [46].

The evolution of spatial planning in Poland over the last twenty-five years has been marked by a significant shift from a centrally planned, communal land tenure system under socialism to a decentralized and privatized approach within a market economy. Currently, the planning landscape encompasses national, regional, and local levels, where higher-order plans guide the more detailed lower-order plans. The national spatial policy articulates the overarching goals and objectives of the nation’s spatial development. It establishes a general planning framework and clarifies the responsibilities of subnational governments. Subsequently, regional authorities are tasked with creating more comprehensive plans and coordinating substantial public investments. Local governments, in turn, produce local spatial development plans that contain the most intricate details regarding specific land uses, policies, and practices. Despite this, the Polish planning system contains various inconsistencies contributing to suboptimal planning outcomes. Notable issues include a) the frequent invocation of special infrastructural acts by the national government, which effectively suspend local planning laws, b) the existence of areas devoid of local spatial development plans, which are instead governed by isolated planning decisions and c) the establishment of Special Economic Zones (SEZ) that lack alignment with local spatial objectives [47].

In Poland, the structure of subnational government is organized into three levels: voivodeships (provinces), powiats (counties or districts), and gminas (communes or municipalities). The 16 voivodeships are predominantly based on historical regions. The country is further divided into 379 powiats, which include 65 cities that are granted powiat status, and 2,479 gminas. Each level serves distinct political and administrative purposes, with essential differences in their functions. The regional level incorporates both regional self-governances. The coordination of regional-level planning, encompassing aspects such as infrastructure, cultural development, and environmental protection, falls under the purview of regional governments. These authorities create comprehensive regional spatial development plans and strategies that cover the entire territory of the voivodeship. Nonetheless, the non-binding nature of these plans on municipalities restricts their practical impact [47]. Between 2002 and 2016, Poland experienced significant changes in land use, with a decline of over 541,000 hectares in agricultural land and an increase of more than 568,000 hectares in forest land, as reported by cadastral statistics [48]. An issue that needs to be highlighted concerns the overly vague definitions of land use classifications, as identified by Kwartalnik-Pruc, which hinder the practical enforcement of legal provisions [49]. The challenge is not limited to land use classification within Poland; instead, it involves many datasets and indicators informed by geographical and statistical data about land use and land cover. In a similar vein, Marquard et al. [44], along with Bielecka and Jenerowicz [49], suggested that developing a more precise conceptualization of land-take and its related concepts could significantly aid in understanding the complexities of the issue, thereby enhancing monitoring efforts and facilitating communication among countries.

Ukraine has undergone excessive transformations in land use and land cover dynamics following the dissolution of the Soviet Union in 1991 [50]. Given that around 70% of Ukraine’s territory is allocated to agricultural activities, the alterations within this sector have been remarkably significant. In the past five to ten years, these changes have been exacerbated by the (i) ongoing military conflict in Ukraine [51], (ii) the escalation in temperatures has facilitated the adoption of double-cropping practices [52], (iii) the persistent activity of incinerating agricultural lands, and (iv) the development of strategies to facilitate the opening of the land market [53]. Investigating the current institutional configuration related to land resources and land use in Ukraine highlights a management system characterized by multiple levels and considerable complexity. This complexity arises from the diverse range of authorities and managerial organizations responsible for regulating and overseeing the management of land resources. The Ministry of Environmental Protection and Natural Resources, the State Ecological Inspection, the Ministry for Development of Communities and Territories of Ukraine, and the State Service of Ukraine for Geodesy, Cartography and Cadastre are involved in land use–land change processes. The foremost concern is the absence of a systematic approach to coordinating executive actions, which leads to ineffective monitoring of the appropriate execution of responsibilities by the governing bodies [54].

4. Discussion

Land use planning systematically integrates various administrative, economic, legal, and technical strategies to fulfil socio-economic and ecological objectives. This process is designed to maintain a socially responsible framework for land ownership, govern interactions related to land, and oversee operations associated with land use. The necessity for appropriate land use planning stems from the need to address environmental concerns, socio-economic development, and human survival challenges. An integrated, holistic framework for sustainable land use planning will facilitate the sustainable utilization of natural resources. However, to achieve such a framework, it is crucial to acknowledge that it is not feasible to meet all competing objectives. Favoring the use and protection of one resource over another can lead to detrimental consequences. It is crucial to sustain an equilibrium between the losses and gains associated with various land types. This necessitates foresight to predict cumulative losses. Implementing the LDN strategy, for instance, may require adjustments in users’ land management practices and could lead to shifts towards alternative land uses [19]. Moreover, establishing clear guidelines is crucial in formulating a practical and effective land-use framework, as it provides the basis for sound landscape-ecological decision-making in land-use practices. By applying these guidelines, one can evaluate the current functional utilization of the area and co-develop strategies for the optimal allocation and management of various land use alternatives [55].

Examining the legislative frameworks at the national level across the five countries, our findings reveal marked differences and several commonalities. France, which maintained a centralized governance structure until the 1960s, has undergone a significant decentralization process focused on regional and economic planning. This evolution has led to inter-community cooperative associations that are pivotal in shaping spatial development strategies through the SCoT instrument. On the same axis, Greece has integrated the policy of developing and implementing strategies within a central state administrative framework. In contrast, Italy has delegated all planning authority to regional governments, resulting in a fragmented legislative framework and a lack of effective coordination at the national level. The country is presently amid a territorial-administrative reform that aims to replace some provinces with metropolitan cities. Upon reviewing the planning instruments utilized in France, Italy, and Poland, several commonalities can be identified, particularly in the normative nature of local-level plans that offer direction for lower-tier planning efforts. In Greece and Ukraine, the regulatory landscape is notably intricate, featuring overlapping legal provisions and a diverse array of national stakeholders responsible for the issuance, implementation, and oversight of regulations. Environmental factors are integrated into spatial planning laws across all five countries. Additionally, each planning system contains components dedicated to conserving valuable natural landscapes, with the French model of sensitive natural spaces illustrating a taxation strategy that facilitates the management of these critical areas [46].

The next stage of future research should create an integrative ecosystem of tools, frameworks, and strategies that bridge the gap between scientific knowledge and policy implementation. This holistic approach will support sustainable, inclusive, and EC-aligned land-use planning that responds to both global sustainability objectives and local development needs.