1. Introduction

The conflict between the morpho-typology of urban tissue and quasi- or semi-natural areas is becoming more and more acute. This conflict is stronger in old human settlements that have developed organically, and in the current context, in ever faster urban sprawl and the development of systems, relationships, and specific connections at the territorial level. The most frequent conflicts of this type are found in rural–urban areas, located at the confluence between the urban tissue and its neighboring agricultural lands, but also in areas placed between the urban tissue and green spaces inside the cities. The second category is more problematic, considering the generally insular morphological layout of green spaces in relation to urban fabric. Protected urban areas are sometimes called “protected islands” due to their isolation from their surrounding environments [1]. All the borders and separation areas between these two types of tissues are most often areas of conflict that require careful management from the point of view of urban planning.

Unplanned urban development failing to preserve local character, without a coherent eco-sustainable and resilient strategy, represents a real threat to the conservation of biodiversity worldwide [2]. This statement is valid in particular in areas valuable from this point of view, such as natural protected ones [3]. Biodiversity conservation can have a considerable impact in terms of increasing ecosystem services [4]. Currently, urbanization follows two main trends: increases in building density (to create compact cities) and the expansion of peripheral areas through urban sprawl [5]. In this context, the ability to support the persistence of species in natural areas within cities becomes a conclusive and, at the same time, a difficult objective for maintaining long-term conservation [6]. Additionally, the competition for occupying space that occurs between activities such as agriculture and nature protection is one of the most obvious human imprints [7]. A major problem from this standpoint, evident especially in Europe, is the fragmentation of ecosystems [8], a major threat to nature conservation [9].

The urban planning process should also take into account natural protected areas, and land use regulations should complement and strengthen these natural protected areas and even be a pillar of biodiversity conservation, especially for land without a protection regime, but representing a special landscape feature with a high conservation value [10]. A common misconception sometimes also addressed by urban planning is that the term “protected area” designates a wild area devoid of human influence [11], but in reality, ecological systems (especially urban ones) are in an intense interaction with urban and social ones, thus facilitating an interdisciplinary research and planning framework, with the aim of ensuring the maintenance of biodiversity in urban areas [12]. These are so-called socio-ecological systems (SES), complex systems that take into account social and ecological variables [13].

Urban planners and political decision makers have experienced solutions that take into account both social and economic concerns, as well as environmental concerns, interconnected in a complex trans-disciplinary sense [14] to reduce environmental impacts [15]. Ecosystem services are crucial, especially those of urban green infrastructure [16]. In order to safeguard the values and natural resources of their territory, municipalities are mandated by European urban planning laws to draft “municipal green infrastructure plans” [17]. Urban planners are challenged to understand, temporally and spatially, ecosystem services [18]. Unfortunately, they are often underestimated and difficult to quantify, considering the lack of a complex integration of systems for monitoring the biodiversity and values of ecosystem services in natural protected areas [19]. Therefore, urban planning in accordance with the augmentation of ecosystem services becomes very difficult, especially given the limited guidance on how ecosystem services should be used in the context of land use and environmental planning [20]. Additionally, very few of the many publications have provided a structured analysis of the contribution and use of this concept in urban planning [21].

Therefore, the literature review highlights limited knowledge of urban planning in terms of developing multi-disciplinary or even trans-disciplinary approaches with ecology. It is important to consider that the creativity in the urban landscape stems from the ability to sensitively perceive space and surrounding landscapes, influenced by the unique perspectives and perceptions of each specialist [22]. Moreover, the analysis of previous studies identified no urban planning tools with the role of valorizing ecosystem services from the viewpoint of spatial relations. No tools were identified even for just analyzing/quantifying the compatibility between built urban tissue and the quasi-natural one. Additionally, no clear and specific recommendations were identified regarding what exactly this tool should analyze.

This research originated from the problem of lacking specific theoretical information about areas adjacent to natural protected ones in cities, from the viewpoint of urban development. Against the background of this theoretical void, the absence of planning guidelines is also noticeable. These guidelines could direct the planning process to support the interdependence between quasi-natural fabric, specific to natural protected areas, and its adjacent built fabric.

The purpose of this study is to provide a set of recommendations for urban planning in accordance with the needs of urban areas close to natural protected ones. These recommendations refer to quasi-natural areas in urban environments, with the most urgent need for correlation with their proximities. Such recommendations can substantiate an urban planning instrument aimed at reducing urban pressures on natural protected areas by adopting appropriate planning methods for the areas adjacent to sensitive natural ones lacking a conservation value.

In this sense, a comparative analysis of some urban planning models, selected for being as different as possible, can pinpoint the different approaches to the urban planning of areas close to protected urban natural areas. Therefore, we compared two types of approaches to urban planning and legislation dedicated to natural protected areas in cities and their adjacent areas. The evaluated models are the approaches of Nordic and eastern European countries, which represent particular situations from a historical–evolutionary point of view, but also from a morpho-urban typology standpoint. The aim is to discover the optimal planning attitude for ensuring resilient conservation and the development of these areas, and create a new instrument used in the vicinity of natural areas within cities. The purpose of this study is not to create the tool itself, which can take different forms (guidelines, urban indicators, and framework structure of urban plans for these areas, etc.), but to phrase a set of recommendations substantiating the development of this tool.

2. Materials and Methods

Selection of case studies: For the analysis of urban planning related to natural protected areas, relevant planning instruments and legislative acts were analyzed for the following countries: Nordic countries—Denmark, Finland, Iceland, Norway, and Sweden, and eastern European countries—Bulgaria, Czech Republic, Hungary, Poland, Slovakia, and Romania (Figure 1).

These two groups of countries were selected for comparison due to their different evolutions from the viewpoint of urbanization and, implicitly, of urban planning. The main historical aspects differentiating the two groups over time are listed below.

The emergence of cities: in Nordic countries, urbanization began to develop during the Middle Ages, with the emergence of trading cities and universities, while in eastern European countries, urbanization began later, in the 19th century, along with the industrialization process.

Post-industrial urban evolution: in Nordic countries, post-industrial urban transformation has been characterized by the regeneration of abandoned industrial areas into modern and sustainable housing and business areas. In contrast, in eastern European countries, post-industrial urban transformation has often been slowed down or blocked by a lack of resources and economic problems [23].

Urban size and density: Nordic countries generally have smaller and denser cities than eastern European countries. On the other hand, in eastern Europe, the tendency to decrease the area and density of cities, also known as “shrinking cities”, is becoming more and more common, due to a decrease in population.

The evolution of public policy: while Nordic countries had a stable democratic development in the 20th century, eastern European countries were under communist regimes for several decades, which had a significant impact on their economic and cultural development.

Establishing the analysis criteria: Taking into account the differences listed above, the study started from the premise that the two groups of countries also differ from the viewpoints of urban planning and its related legislation. Starting from this point, after identifying the differences at these two levels of the analysis, a set of recommendations were drawn up for each group of countries.

The two levels of analysis (legislation and urban planning instruments) were chosen in order to obtain an overview of how the areas adjacent to natural protected areas are treated from the point of view of urban planning. Another important aspect taken into account was the degree of attention given to them from a legislative point of view, especially considering the fact that not all planning instruments have legal value.

The legislation was selected to include legislative acts substantiating the urban–territorial planning systems specific to each country, those addressing quasi-natural areas in cities (for example, green spaces), natural protected areas and their adjacent areas, and the regulation of the relationship between natural protected areas and urban morpho-typological tissue, in the specific context of each area. Considering the multitude of existing legislative acts in the 11 analyzed countries, the acts substantiating the basis of urban planning and environmental protection were chosen for analysis first.

An important starting point, in this sense, consists of the brochures produced for each state by the Organization for Economic Co-operation and Development (OECD), a forum where the governments of 37 democracies collaborate to develop policy standards for promoting sustainable economic growth. These sheets can be found on the OECD website in the “countries” section and provide an overview of the urban planning tools used in each country, as well as the main laws that regulate these urban planning aspects.

Having these sheets as a starting point, the following steps were taken for selecting the laws analyzed. First of all, general laws related to urban planning and the environment, which generally address the subject of these two fields, were selected. In order to identify the general environmental and urban planning laws of each country, the following sources of information were used: the official website of the respective country’s government was accessed, and then its environment/urban planning/legislation sections were viewed, depending on the structure of the respective website. Online legislative databases (either at a national or European level), websites of environmental institutions, and those responsible for urban planning were also used.

Secondly, the legislative acts related to them, with a potential influence on the system of natural protected areas, were analyzed. Territorial planning instruments and their roles were also identified, especially with regard to the planning for areas adjacent to natural protected ones.

Comparison of case studies: After identifying the particular aspects of each country, a comparison was made between all the selected countries, depending on each analyzed level, but also on the territorial scale to which the respective instrument was applicable (legislative or planning). Other instruments considered relevant for the two fields were also taken into account—strategic instruments mentioned in the analyzed legislative acts.

Identification of principles used: Based on the comparison between the analyzed countries, we identified the main directions that each country follows with respect to environmental protection and urban planning. A parallel analysis of these issues facilitated the identification of the different aspects emphasized by each country/group.

Drawing up a set of recommendations for the two models: Comparing the two analyzed models—Nordic and eastern European—we noticed that the two adopted different instruments, in terms of territorial scale, required improvements, both from the urban planning and legislative viewpoints. For this purpose, a series of recommendations were made regarding the two levels of analysis, addressing the strategic approaches separately from the urban planning instruments, due to their lower legal value. The recommendations concerned the two groups, a single one, or a single country. Special attention was paid to Romania, first taking into account its specific natural heritage and environmental legislative proposals, differentiating it from the other analyzed countries.

Figure 2 presents a diagram of the methodology, indicating its main steps.

3. Results

3.1. Critical Analysis of Legislative Acts and Planning Instruments of Urban Protected Areas in the Analyzed EU Countries

3.1.1. Nordic Countries—Denmark, Finland, Iceland, Norway, and Sweden


At the national level, the Danish Planning Act is the main guide for territorial planning. One of its objectives consists of “creating and conserving valuable buildings, settlements, urban environments and landscapes” [24]. The designation of protected areas is carried out through municipal plans, which can then be detailed through local development plans (also called detailed plans/Lokalplan). The Planning Act provides for the direct obligation of municipal plans to propose solutions for nature conservation—“The municipal plan must contain guidelines for safeguarding nature conservation interests, which are made up of natural areas with special nature protection interests, including existing Natura 2000 land and other protected nature areas, co-ecological links, potential natural areas, and potential ecological links”—§11a, Planning Act [24]. These municipal plans also mark/reserve component areas of The Green Denmark Map (Grønt Danmarkskort), a natural network that supports the planning of natural areas, with the aim of counteracting the loss of biodiversity.

Two other important legislative acts for territorial planning are the Nature Protection Law [25] and Land Registration Act [26]. The Nature Protection Law aims to protect nature, so that “social development can take place on a sustainable basis, both with respect for human living conditions and for the preservation of animal and plant life”. The law contains provisions regarding protected areas from the viewpoint of protected species, public access, management, damages, and sanctions, but does not refer to the spatial relationship between them and the urban fabric.

The Land Registration Act contains provisions regarding property registration in the national real estate registration system. This act does not refer to protected natural areas.

No legislative act dedicated to protected areas located in urban areas was identified, thus concluding that they are subject to the same provisions as areas not directly spatially related to cities.


The Finnish planning system is mainly based on the Land Use and Building Act, but the Environmental Protection Act and Nature Conservation Act are also of particular importance, especially with regard to natural areas. The Land Use and Building Act has a chapter dedicated to national urban parks—chapter nine [27]. It mentions the way to establish one and the specific regulations for this. The establishment of such a protected natural area can be initiated upon the request of the local authorities, being completed by the institution made by the competent ministry. There are currently nine national urban parks established in Finland: Hämeenlinna, Heinola, Hanko, Kuopio, Pori, Forssa, Kotka, Turku, and Porvoo [28]. For each national urban park, a “maintenance and use scheme” is drawn up and approved by the responsible ministry; their regulations “must be taken into account in planning the areas of the park and in other planning and decision-making affecting the area” [27]. Therefore, urban planning and land use documentation must take this scheme into account. Plans are divided into the following categories, depending on the territorial scale at which they are designed: regional plans, local master plans, joint master plans (of several municipalities), and detailed local plans. The aspects that these plans must address include the “protection of the built environment, landscape and natural values”. It is recommended for these plans to provide regulations regarding protected areas (natural or built). Regarding the content of detailed local plans, it is mentioned that “the built and the natural environment must be preserved and their special values must not be destroyed. There must be sufficient parks or other areas suitable for local recreation in the area covered by the plan or in its vicinity” (see Section 54 of the Land Use and Building Act).

The importance of urban planning in the conservation of biodiversity is also emphasized by the Finnish Biodiversity Action Plan 2013–2020. The Plan aims to “slow down the loss of biodiversity in urban and built-up areas by increasing knowledge of the subject and developing the related land-use planning, so as to take into account the conservation of biodiversity” [28]. Its actions consist of: encouraging the evaluation of unbuilt areas (important from the point of view of urban biodiversity), the promotion of important areas for conserving biodiversity in the urban environment, and the development of planning methods in the urban environment, in accordance with the conservation of biological diversity (see Section 2.12—urban and built areas of the Finnish Biodiversity Action Plan 2013–2020).


A special aspect related to Iceland’s legislation is the fact that its laws do not refer to green areas [29]. Planning is carried out at four territorial scales, through the following types of plans/documents: national planning strategies, regional plans, municipal plans, and detailed development plans. Considering its strategic nature, national documentation has the role of establishing the general directions that must be followed in the planning process. Regional plans are the main planning tool, to which the lower plans are subordinated from the point of view of the territorial scale. Municipal plans should respect and detail the provisions imposed by regional ones, and local plans should respect and detail the provisions imposed by municipal ones.

The main legislative act by which the documentation is guided is the Planning and Building Act [30]. Chapter III, “Preparation and implementation of development plans”, Article 9, specifies that local conservation provisions are included in development plans, if there are valuable natural features in the area regulated by the plan considered to be desirable for preservation [30].

The main national law for environmental protection is the Nature Conservation Act [31]. According to Article 67, the Ministry of the Environment has the obligation to issue a comprehensive register of sites of natural interest once every 5 years at most, published in the Official Journal of Iceland. It can be completed at any time, if new areas are added to this register. The Nature Conservation Agency, in collaboration with the Icelandic Institute of Natural History, nature research centers, and nature conservation committees in question, is in charge of the preparation and collection of the data on register additions.

No legislative act adopted at the national level dedicated to natural protected areas located in urban areas was identified.


The law that governs the Norwegian planning system is the Planning and Building Act [32]. As mentioned in this act, Norway has the following planning instruments, different in terms of their legal power and territorial scale: national master plans (with a role in coordinating the planning process), regional planning strategies (determine where regional plans are needed), regional plans, municipal planning strategies (determine the areas where zonal plans are needed), municipal master plans (establish land use regulations), and zonal plans (detail the urban regulations for a given area; can be initiated both by local authorities and private actors). Additionally, at the national level, there are also sectoral plans, such as those for transport/mobility and the management of protected areas. An important mention included in the Planning and Building Act, regarding municipal master plans, is made in its Section 11-8—“Zones requiring special consideration”. The Act specifies that, when protection regulations are adopted for a new protected area or when those in a management plan are revised, they can also be applied to the areas adjacent to national parks or protected landscapes. The aim is to prevent reducing the conservation value of these protected areas.

Regarding the content of zonal/detailed plans (see Section 12-5 “Land-use objectives in a zoning plan” of Norwegian Planning and Building Act), point three mentions “green structures” (“grønnstruktur”), consisting of nature areas, green corridors, outdoor recreation areas, and parks. These “green structures” are also provided for the content of municipal master plans, in the category of areas that require special attention. Therefore, this green system is established from the macro level through municipal master plans and then detailed at the mezzo level by zonal plans.

Another important legislative act for the conservation of natural protected areas is the Nature Diversity Act—Act of 19 June 2009 no. 100, relating to the management of biological, geological, and landscape diversity [33]. Its purpose consists of protecting biological, geological, and landscape diversity and ecological processes. Chapter V is dedicated to natural protected areas, but it does not include provisions dedicated to areas located inside or in the vicinity of urban areas.

The Act on natural areas in Oslo and its nearby municipalities [34] aims to “promote and facilitate outdoor life, nature experiences and sport”. The law must also ensure the borders of the Marka—the area of forests and other quasi-natural lands around the city of Oslo, but the law does not deal with the protected areas that fall under the Nature Diversity Act and only refers to the creation of protected areas with special qualities for outdoor life—protected areas for recreation, which are established by the King.

In addition to these legislative acts that refer to natural protected areas, another two documents are available with roles in guiding/directing the planning process—Planning green structures in cities and towns [35]. As specified in this act, green structure planning should be based on the knowledge of animals, plants, their movement patterns, and their vulnerabilities, and should start from an overview of biotopes. An interesting aspect is the fact that the principles taken into account in the establishment of a green area, mentioned and explained in the guide, are similar to the principles for the establishment of a protected area, reported by John Wilson and Richard Primack [36] in their book, Conservation Biology in Sub-Saharan Africa. However, in this document, no special mentions are made regarding protected areas spatially related to urban fabric.


The Swedish planning system is based on two legislative acts: the Planning and Building Act [37] and the Environmental Code [38]. As it appears from the Planning and Building Act, in Sweden, there is no planning at the national level, i.e., there is no national plan. However, the objectives of national interest are taken into account by documents at lower territorial scales. Additionally, at the regional level, planning is restricted, being currently regulated only for two regions—Skåne and Stockholm (through an addition to the act in 2019). At the level of each municipality, a municipal plan (comprehensive plan) must be adopted, containing guidelines for land use, but these plans are not legally binding. The next documentation at the territorial scale is a detailed regulation and development plan. This documentation has legal value and “can be” employed in certain areas for the urban regulation of land, through which the urban indicators for the studied area are established. For areas not covered by detailed regulatory plans, the municipality can adopt “zonal regulations”, whose restrictive character is narrow, and which deal with aspects such as: land use, maximum buildable area, and buildable land sizes. The Planning and Building Act does not regulate natural protected areas.

The first mention of natural protected areas contained in the Environmental Code is made in its chapter three—“Basic provisions concerning the management of land and water areas”, Section 2, which establishes that land/water surfaces that are not affected or are affected to a small extent by development projects must be protected from measures that can significantly affect their character. An interesting aspect appears in Section 15 of chapter 7—“Protection of areas” in the same Swedish Environmental Code, mentioning that “in special circumstances”, the protection regime of a shore area (established at a distance between 100 and 300 m from the edge of the shore) may be suspended during the validity period of a detailed regulatory plan being adopted for the respective area.

Section 7 of the same chapter contains the first and only reference to an urban natural protected area, more precisely to the national urban park that covers the Ulriksdal-Haga-Brunnsviken-Djurgården area in Stockholm. It is mentioned here that interventions are allowed in national urban parks only if they can be implemented without affecting the park’s landscapes or any natural or cultural assets.

3.1.2. Eastern European Countries—Bulgaria, Czech Republic, Hungary, Poland, Slovakia, and Romania


The Bulgarian planning system includes four types of documentation, taking into account the territorial scale at which they are made: the National concept for spatial development, the Regional scheme for the spatial development of a region of level two, the Regional scheme for the spatial development of a district, and the Municipality concept for spatial development and detailed plans.

The National concept for spatial development 2013–2025 [39] includes six strategic objectives, one of which is dedicated to the protection of natural and cultural heritage—strategic objective four: “Well-preserved natural and cultural heritage”. Subchapter 3.5.1. Natural values of the same Bulgarian act begins with the specification that “Protected nature areas account for a significant portion of the non-urbanized territories in the national space”, and the document does not refer to protected areas in urban environments. The National concept for spatial development is not legally binding.

The following two types of documentation, made for NUTS-2- and NUTS-3-(/district)-type areas, generally include provisions regarding the functional and hierarchical structures of settlement networks, agglomeration areas, and their impact and development axes for infrastructure. The Regional scheme for the spatial development of a district should also include guidelines for plans made at the municipal level. Regional plans are not legally binding. The last two types of documentation—the Municipality concept for spatial development, the Municipality Spatial Development Concept, and the detailed plans have legal value and include specific functional regulations for targeted territories.

There are a series of legislative acts related to spatial planning and/or natural protected areas: the Spatial development act no. 1/2001 [40], The Regional Development Act no. 50/2008 [41], Environmental protection Act no. 91/2002 [42], Protected Areas Act no. 133/1998 [43], and Biodiversity Act no. 77/2002 [44].

According to the Spatial development act no. 1/2001, Art. 7 (1), the category of land designated as protected territories includes reserves, national parks, natural sites, maintained reserves, nature parks, protected areas, beaches, dunes, and water sources with sanitary protection zones, water areas, humid zones, and protected coastal strips. According to (2), the territories included in urbanized territories can be designated as protected territories. Article 62 (3) mentions that: “Existing green areas which are public ownership shall be developed and preserved as protected areas”.

The Regional Development Act no. 50/2008 mentions natural and protected zones only as categories used in the functional zoning of space. There are no references to natural protected areas within cities.

The mentions regarding natural protected areas included in the Environmental Protection Act no. 91/2002 refer to the legislative act dedicated to them, which is analyzed below.

The Protected Areas Act no. 133/1998 regulates the categories of protected areas, the regimes for their protection and use, their designation, management, security, financing, and the penalties/fines in the case of non-compliance with the provisions of this act. In the legislative act, no references are made to natural protected areas spatially related to urban fabric.

The Biodiversity Act no. 77/2002 includes a chapter dedicated to the national ecological network. This chapter consists of: sites belonging to the Natura 2000 Network, protected areas of national importance, Corine sites, Ramsar wetlands, important areas for flora, and important areas for birds. Until 2005, the law included a section dedicated to the buffer zones of protected areas, whose articles were, however, repealed. The act does not refer to natural protected areas within or near urban environments.

Czech Republic

In the Czech Republic, there are three levels of government—levels at which spatial planning documents are drawn up: national, regional, and municipal. The national planning framework is represented by the National Development Policy [45]. This has the role of directing the national planning system, without having legal value. The protection of natural values is one of the priorities identified at the national level, together with the location of development projects that have the risk of significantly affecting the character of landscape. The importance of territorial systems with ecological stability, the protection of natural elements in the countryside, and the creation of conditions to ensure the permeability of landscapes for wild animals are also mentioned.

At the regional level, the Development Principles play a role similar to that of the National Development Policy at the national level. They highlight planning priorities at the regional level, but at the same time, coordinate planning at a municipal level, without having a legal character.

There are three types of plans drawn up at the municipal level—Local Territorial Plans, Regulatory Plans, and Planning Studies—out of which, only the first two have legal value. Local Territorial Plans cover the administrative area of an entire municipality and regulate land use. However, in many cases, these Plans leave a margin of appreciation for the Building Office, which is responsible for issuing building permits. Regulatory Plans are drawn up only for certain areas, where a need to detail the regulations from Local Territorial Plans is found. Planning Studies are documents that have the role of supporting the planning process by identifying possible solutions to certain problems. Territorial planning is regulated by The Building Act of 14 March 2006 [46].

Natural protected areas fall under the incidence of two legislative acts: the Act on the Environment [47] and the Act on Nature and Landscape Protection [48]. The first act has a general character and does not directly specify the term “natural protected area”, speaking, in general, about environmental protection. The Act on Nature and Landscape Protection details how to protect each type of natural protected area. For example, for national parks and protected landscapes, it is mandatory to create both conservation and zoning plans (valid for 10 years in the case of national parks and between 10 and 15 years for protected landscapes). National parks are divided into three natural conservation zones, depending on their natural values, which differ in terms of the strictness of regulations. Regulations and zoning are mentioned in the legal act by which these protected areas are established. Similarly, protected landscapes are divided into three or four natural conservation zones.


The Hungarian planning system includes three or four levels, depending on the region: National Spatial Plans, Spatial Plans for Special Regions, Spatial Plans for Counties, and Settlement Structural Plans. National Spatial Plans include a series of guidelines, strategic plans, and plans for a narrower scale of land use. These are documents with legal value and are renewed every seven years.

The following instruments, from a territorial scale viewpoint, are Spatial Plans for Special Regions. At the national level, there are two such plans—Budapest together with its adjacent urban agglomeration and the tourist area around Lake Balaton, which include both general provisions and strategic or land use plans and which have legal value. The main objectives of these two plans are to stimulate economic potential, support sustainable development, and protect natural and cultural heritage.

According to the Long-Term Development Concept of the City of Budapest 2030 [49], the main dangers for valuable natural areas are the “dynamic” mode of the spatial expansion of the city (sometimes insensitive to the limits of forests or borders between the natural and built environment), the occupation of land without a legal basis, and the lack of financial resources dedicated to the protection and management of these areas. For the preservation of natural values, the following “possible means of implementation” are proposed: the establishment of new green areas (to reduce the pressure on nature conservation areas—for example, by creating recreation areas), ensuring a balanced financing fund for nature conservation areas, the legal protection of areas significant from the point of view of nature but not yet protected, and environmental education. Within the plan, special attention is paid to the Danube, with its adjacent area being addressed in a dedicated chapter. The importance of the existing protected natural areas along the Danube, both from the Natura2000 network and in terms of national importance, is mentioned.

Within the Balaton Territorial Development Concept 2014–2030 [50], the significant set of natural protected areas that are components of the regulated area is mentioned, but no special mention is made about the natural protected areas near urban settlements.

Spatial Plans for Counties ensure the link between National Spatial Plans and local plans, detailing the regulations provided in national plans. Through them, regulations are established for the control of the development and protection of natural and built heritage.

The planning tool used at the local level, Settlement Structural Plans, includes both strategic planning and specific land use regulations. This document works together with local building regulations, which detail the approved types of use.

The framework legislation for the Hungarian spatial planning system is made up of three laws: Act XXI 1996 on Regional Development and Spatial Planning [51], Act LXXVIII 1997 on the Development and Protection of the Built Environment [52], and Act XXVI 2003 on the National Spatial Plan [53]. The first legislative act does not make specific references to natural protected areas. Act LXXVIII 1997 on the Development and Protection of the Built Environment refers only to green spaces important from the point of view of a settlement’s structure, for which the provision of buffer zones is recommended. These areas are also specified in Act XXVI 2003 on the National Spatial Plan, where natural protected areas and the protection areas of natural protected areas are mentioned as “regional and county priority areas”. Additionally, according to Chapter V, areas regarding national areas, Section 13, Article 4 of the same act, the natural ecological network is made up of natural protected areas, natural areas, and ecological corridor areas and must be included in regional- and county-level spatial plans. No specific references are made to natural protected areas in urban environments.


The legislative act substantiating spatial planning in Poland is the Spatial Planning and Development Act [54]. Planning is carried out on three levels, through the following types of documentation: national development plans, spatial development plans at the voivodship level, and local development/revitalization plans. The National Development Plan is valid for 20 years, and the one currently in force is The National Spatial Development Concept 2030—NSDC 2030 [55]. Its content highlights the importance of establishing ecological networks and conservation planning in protected areas. The plan does not refer to urban natural protected areas. NSDC is not legislative in nature.

The case of voivodeship plans is similar, as they are only indicative, have no legal value, and delimit, among others, protected areas. Additionally, at the regional level, it is mandatory to carry out landscape audits—territorial planning acts at the voivodeship level, through which the characteristics and value of local landscapes are determined.

Local development plans are legally binding documents (for more details, see Nowak et al., 2023 [56] and Blaszke et al., 2022 [57]). They regulate land use, urban indicators, and the protection of cultural assets. Local plans also estimate the costs of infrastructure projects and detail how the expropriation of the affected properties will be carried out following the implementation of these projects. No special specifications were identified for urban natural protected areas.

An important component of spatial planning in Poland is the system of environmental impact assessments—EIA [58], an auxiliary instrument for territorial development, the preparation of which is mandatory for all planning documents. The structure of the report that must be drawn up includes: a description of the project, a description of the natural elements that may be affected, a description of the historical monuments in the area (if applicable), a forecast in case the project is not carried out, a description of some development scenarios with the motivation of the most advantageous options, a description of the project monitoring, and a summary of the report. The legislative act contains a chapter (no. six) dedicated to the protection zoning of protected areas. It provides for the establishment of protection zones adjacent to protected natural areas, established by the same authority that established the respective natural protected area. If a protection zone is not provided, the area between the limit of the protected zone and a distance of 50 m from it is considered to be the protection zone. No special mentions were identified regarding natural protected areas located inside or in the vicinity of urban areas.


The Slovak Republic is characterized by three levels of government—national, regional, and municipal, and by four levels regarding the territorial planning system—the Slovak Spatial Development Perspective (at the national level), Regional Land Use Plans, and two types of local plans—Local Land Use Plans and Local Zoning Plans.

The Slovak Spatial Development Perspective [59] includes a chapter dedicated to landscape—Chapter 12, “Landscape structure of the Slovak Republic”, which contains mentions about natural protected areas, but this refers to the Territorial System of Ecological Stability (TSES), a concept adopted by The Slovak Republic through the Decision of the Government no. 394 of 23 July 1991. The implementation of projects is carried out from the macro-territorial scale to the mezzo-/micro-territorial scale: the supraterritorial system of ecological stability (STSES) at the national scale, the regional territorial system of ecological stability (RTSES), and the local territorial system of ecological stability (LTSES). The local territorial system of ecological stability (LTSES) offers a landscape ecological basis for the elaboration of municipal plans [60]. The role of these planning tools is to conserve the biodiversity of landscapes, restore the connectivity of natural landscapes, and maintain or even improve ecosystem services [61] (for a more detailed discussion, see Popescu et al., 2022 [62]). It is important for the component elements of the TSES systems—bio-centres, bio-corridors, and interactive elements—to be included in the system of natural protected areas, as they are not fully legally protected.

Regional Land Use Plans establish strategic principles, include land use plans, establish the locations of major infrastructure and technical equipment, and establish indications for the protection of natural and cultural heritage. From a legal point of view, they are mandatory for local land use plans.

The first type of plan drawn up at the local level, Local Land Use Plans, must be adopted for settlements with over 2000 inhabitants. However, many settlements with less than 2000 inhabitants have adopted or are in the process of adopting a Local Land Use Plan, because they either have planned extensive developments or public buildings, or they have been obliged to by regional plans. Additionally, the preparation of a Local Land Use Plan is mandatory for settlements within which there are major infrastructure or public buildings.

The second type of local plan, Local Zoning Plans, describe the permitted use of land and are the most detailed ones, being usually drawn at a scale of 1:1000 or 1:500. Their preparation is necessary if required by Local Land Use Plans, or for planning public buildings.

Probably the most important three legislative acts for territorial planning are the Act on Land-use Planning and Building Order (Act 50/1976 Coll.), the Environmental Impact Assessment Act (Act 24/2005 Coll.), and the Act on Nature and Landscape Protection (Act 543/1994 Coll.).

According to the Act on Land-use Planning and Building Order [63], protected and protection areas are defined in land use planning documents. No special references are made to urban natural protected areas.

The Environmental Impact Assessment Act [64] regulates the professional and public assessment procedure for anticipated environmental impacts, the competence of the authorities responsible for this impact assessment, and the rights and obligations of the participants in the assessment process. If it is found that a strategic document has a negative impact on the system of protected areas, the only accepted reasons for it to be approved are related to human health, public order, national security, or other urgent reasons for which it has received the approval of the European Commission. No special references are made to urban natural protected areas.

The Act on Nature and Landscape Protection [65] regulates the territorial conservation of nature and landscapes at five levels of protection, the extent of its limitation increasing with the increase in the level of protection. In the legislative act, no references are made to urban areas and the spatial relationship between them and natural protected areas.


The basis of the planning system in Romania is Law 350/2001 on Territorial Development and Urban Planning [66]. According to Annex 1 of this law, the planning system includes three types of spatial planning documentation and three types of urban planning documentation. Territorial planning documents have a strategic character and are: national territorial planning plans (PATN), county territorial planning plans (PATJ), and zonal territorial planning plans (PATZ). PATNs include six sections, for six distinct levels—Section 3 is dedicated to protected areas, both natural and built, and constitutes the framework for identifying heritage areas, vulnerabilities, conservation priorities, and necessary financial support. PATJs and PATZs correlate with PATNs, and must indicate in their written part and graphic form the natural factors affected by human actions and unprotected or insufficiently protected natural heritage.

Urban plans have a regulatory character (normative character) and are divided into the following three categories: General Urban Plans (PUG), Zonal Urban Plans (PUZ), and Detailed Urban Plans (PUD). PUGs are drawn up at the level of an administrative territorial unit (municipality, city, or commune) and some of their objectives are to delimit areas with a special protection regime legally enforced and set urban growth boundaries. PUGs are most common land use policy instruments for managing urban land change, with a direct-impact on the land use conversion in cities [67]. PUZs are drawn up at the level of an area in an administrative territorial unit, for different purposes, among which is the protection of historical monuments. The development of a PUZ is mandatory for protected built-up areas. On the other hand, Law 350/2001 does not include special mentions regarding the preparation of PUZ-type documentation for green areas that have other characteristics than urban ones or for urban natural protected areas and/or their adjacent areas. PUDs are drawn up only for a single piece of land and their regulatory character is much more limited compared to PUZs, through PUDs not being able to change, for example, the regulated height regime for the respective land. For a more detailed presentation of these institutional actors and legal provisions, see Popescu and Petrisor, 2021 [68].

The written part of town planning plans, Local Town Planning Regulation (RLU), is based on the provisions of the General Town Planning Regulation (RGU), adopted by Government Decision no. 525/1996 [69]. RGU contains an article dedicated to areas with landscape value and natural protected areas (Article 8), from Section 1—“Rules regarding the preservation of the integrity of environment and protection of natural and built heritage”, which mentions the prohibition of authorizing constructions/developments that depreciate the value of a landscape and the approval procedure for the execution of construction in natural areas protected by national interest. RGU does not contain mentions dedicated to natural protected areas spatially related to urban fabric, so has no correlation with the unique and particular urban morpho-typology of a territory.

Currently, there is a “Legislative proposal regarding the regime of urban protected natural areas and preservation of urban biodiversity” in preparation. This was adopted by the Romanian Senate and sent for debate in the Chamber of Deputies. According to the legislative proposal, natural urban protected areas and green corridors must be highlighted in urban planning and land development plans. This step could adapt the planning process toward the conservation needs of these areas (see also Popescu et al., 2022 [62]).

Regarding natural areas, especially those in cities, the most important legislative acts are Law no. 137 of 29 December 1995—the Environmental Protection Law [70], Emergency ordinance no. 195/2005 on environmental protection [71], and Law no. 24 of 15 January 2007, regarding the regulation and administration of green spaces in urban areas [72].

Law no. 137 of 29 December 1995—the Environmental Protection Law—regulates the regimes of natural protected areas and the activities subject to environmental impact assessment procedures within them.

Emergency ordinance no. 195/2005 on environmental protection prohibits changes in land use within and near natural protected areas, but “the vicinity of the natural protected area” is defined in vague terms: “the area outside the limit of a natural protected area, from which an impact on the natural protected area can be generated by a project or an activity, depending on their nature, size and/or location”.

Law no. 24 of 15 January 2007, regarding the regulation and administration of green spaces in urban areas, does not refer to natural protected areas.

3.2. Comparison of the Existing Models and the Approach to the Problem of Conservation of Natural Protected Areas in Urban Areas in the Nordic Countries and in the Eastern European Countries

Figure 3 presents an outline of the Nordic countries, which is discussed in detail below.

Nordic countries do not attach particular importance to territorial planning carried out at the national level—Denmark, Finland, and Sweden do not have planning instruments at the national level. Additionally, the national plans for Iceland and Norway are of a strategic nature and presented in written form. For all Nordic countries, the actual planning starts at the regional or municipal level, through plans that regulate land use. Denmark is the only one of the countries for which no regional plans are provided, with planning starting at the municipal level. For the other countries, plans made at the mezzo-territorial level are drawn up at the regional and municipal levels. At the micro-territorial level, detailed plans are provided—for Finland and Iceland, zonal plans—for Norway or both types of plans—for Denmark and Sweden.

From a legislative point of view, each country has a law responsible for its planning system—The Planning and Building Act (in the case of Iceland, Norway, and Sweden), The Land Use and Building Act (Finland), and The Planning Act (Denmark). Regarding the mentions of natural protected areas contained in these acts, the Finnish law stands out in a chapter dedicated to national urban parks and the provision of a “maintenance and use scheme” for each of them. A basic law for environmental protection is also provided in each country. The Nature Conservation Act of Iceland mentions the obligation to create a register with areas that are of interest from the point of view of natural heritage. The Environmental Code of Sweden specifies the possibility of suspending the regime for the protection of coastal areas through a detailed regulatory plan during its validity period. Another interesting approach was identified in the Act on Nature Areas in Oslo and Nearby Municipalities. Here, attention is paid to the establishment of protected areas with special qualities for outdoor activities, especially with the aim of reducing the pressure on natural protected areas with special conservation value.

Among the strategic documents, even if they have no legal value, the following two mentions stood out: The Finnish Biodiversity Action Plan 2013–2020, which highlights the importance of developing planning methods in urban environments, in accordance with the conservation of biological diversity, and the Planning Green Structures in Cities and Towns document adopted for Norway, which draws attention to the planning of the system of green spaces based on an overview of the biotopes.

The planning systems adopted by eastern European countries are much more branched compared to those identified in the Nordic countries, at least from the point of view of the hierarchy of planning instruments. All the analyzed countries have adopted plans at the national level. Their analysis brought out the following mentions: The National Development Policy of the Czech Republic highlights the importance of locating development projects that endanger the natural heritage, The National Development Plan of Poland gives special importance to the creation of ecological networks, and The National Territory Development Plan of Romania contains a section dedicated to protected areas, both natural and built-up.

The next analyzed level is represented by urban planning plans at the mezzo-territorial level, which are considered in this case to be plans drawn up at regional, county, or municipal levels. Hungary has adopted two plans at the regional level—one for Budapest and its adjacent urban agglomeration and one for the tourist area near Lake Balaton, but these do not make special references to natural protected areas and their spatial relationship with the urban fabric. In parallel, a strategic concept was also adopted for these two areas. The one adopted for the Budapest area recommends the creation of new green spaces to reduce the pressure on valuable natural areas from a conservative point of view. Additionally, in the case of Hungary, the content of these plans made at a county level highlights the importance of establishing regulations for controlling development and protecting natural and built heritage.

At the next planning level, the micro-territorial level, the types of plans adopted at a zonal/detail level were analyzed. All the countries provide for the drafting of such plans, but no special mentions have been identified regarding natural protected areas and the planning of areas in their vicinity.

Regarding their legislative acts, each country has a basic law for its territorial planning system, with different names: The Spatial Development Act (Bulgaria), The Building Act (Czech Republic), the Act on Regional Development and Spatial Planning (Hungary), The Spatial Planning and Development Act (Poland), The Act on Land Use Planning and Building Order (Slovakia), and the Law on Land Use and Urban Planning (Romania). In Bulgaria, this act mentions the importance of public green spaces through a recommendation that they should be treated similarly to protected areas. It is very important to balance conservation requirements and the public use of an area [73]. Poland provides that the ecological network must be included in territorial and county plans. In Slovakia, the law mentions that protected areas and their areas of protection are defined in territorial planning documents.

Compared to the environmental legislation specific to the Nordic countries, eastern European countries seem to be more specific regarding the natural elements with conservative value. Figure 4 presents an outline of the eastern European countries, which is discussed in detail below.

Bulgaria adopted a law for the protection of biodiversity, which includes a chapter dedicated to the national ecological network. The Czech Republic has a law for the protection of nature and landscapes, which details the regulations and zoning for each type of natural protected area. In Hungary, it is recommended to provide a buffer zone for green spaces through its law on the development and protection of the built environment. In Poland, there is a law stating that all planning documents should contain an environmental impact assessment. Slovakia has paid special attention to planning a Territorial System of Ecological Stability (TSES), divided into three levels depending on the scale: supraterritorial, regional, and local, through a Government decision from 1991. At the same time, the nature protection laws and landscapes provide for five levels of protection, with the strictness of the regulations increasing with the level of protection.

In Romania, the General Urban Planning Regulation forbids the authorization of constructions that depreciate the value of a landscape. Despite this, the legislation in force is uncertain and too little focused on all the components of a landscape, allowing for changing the admissible function and indications of land use under certain conditions. It should be noted that these components of a landscape are important in constituting a planning and regulatory tool in the study, research, analysis, diagnosis, and prognosis of the resilience of human settlements, and with a significant role in increasing quality of life [74]. The law on environmental protection regulates the regimes of natural protected areas and the activities subject to environmental impact assessment procedures within them, but it does not clearly intervene with regard to green spaces with environmental potential but without historical and/or environmental heritage value (see also Stan, 2022 [75]). The Emergency Ordinance on Environmental Protection prohibits a change in land use near natural protected areas. In Romania, the adoption of a law dedicated to natural protected areas in urban environments is currently under debate.

Overall, although the anticipated results showed major differences in terms of the attention given to natural heritage, it can be seen that both Nordic and eastern European countries have adopted important and, at the same time, very varied provisions, both within territorial planning instruments and through legislative acts, at different levels of approach (Figure 5).

Very few dedicated provisions regarding natural protected areas within urban environments have been identified at the spatial level and with respect to urban morpho-typological structures, i.e., the regulation of national urban parks in Finland and the legislative act under debate for urban natural protected areas in Romania. It should be noted that these two areas are totally different from the viewpoints of the local natural and built environments or cultural particularity and specificity, and are in different situations of historical evolution, subject to the acute pressures of urban development, and, especially, are under different territorial statuses from a strategic viewpoint. In the case of territories with such a rich heritage, the need to create large natural protected areas is felt even more. Considering major natural elements, such as rivers, their protection requires the careful management of a larger area (at the scale of a hydrographic basin), which, in many cases, exceeds the limits of the natural protected area [76].

4. Discussion

4.1. The Significance of Results

The previous parallel made between the main conclusions extracted from the analysis of legislative documents and planning instruments, summarized in Figure 5, reveals that improvements can be made for the model of Nordic countries in terms of their approach to natural heritage and especially that directly related to their urban fabric, as well as in the case of eastern European countries.

This can only be achieved with the prospective, efficient, and, above all, ethical adaptation of possible models, only with a preservation of the specificity and particularity of local morpho-typologies and natural anthropic and cultural landscapes, as a priority in the strategy and planning processes for different typologies and concerted and correlated multiscale interventions, respectively, at different scales: urban, spatial, peripheral, rural–urban, territorial, national, cross-border, regional, or European.

The main differences in terms of the main aspects considered by the two groups of countries concern urban morpho-typologies and different historical, social, and cultural evolutions (Figure 5). These differences are highlighted in the case of their urban and territorial planning and strategy instruments. The Nordic countries do not attach importance to planning instruments drawn at the national level, with their actual planning starting from the mezzo-territorial level. Eastern European countries make important clarifications through national plans—the planning of protected areas, national ecological networks, or the locations of projects that depreciate the landscape character. Thus, the adoption of plans at the national/macro-territorial level has the potential to support these practices nationally.

The plans adopted at the mezzo-territorial level in Nordic countries do not make specific references to natural heritage. They were identified, however, in the cases of Denmark and Norway, and references are made to the system of green spaces. In eastern European countries, the only specific provision was identified in Hungary, which controls the development and protection of natural and built heritage. Planning at the mezzo-territorial level can be considerably improved at the levels of the two groups of countries by adopting specific regulations regarding the system of natural protected areas, including their protection/adjacent areas.

At the zonal/detailed territorial level, the plans drawn up for eastern European countries, perhaps due to the historical and political context of the communist regime that changed quite late in the 90s, do not make specific statements about natural heritage. Regarding the Nordic countries, Iceland provides conservation provisions included in its development plans, and in Norway, there is a detailing of the green system. Similar to the situation identified in the case of planning at the mezzo-territorial level, at this scale, the need to implement specific regulations, which are especially important for the planning of areas adjacent to natural protected areas, is noted.

From a legislative point of view, after the 90s, eastern European countries adopted more specific provisions for natural elements of conservative interest, an aspect highlighted in the diagram in Figure 5. However, similarities were also identified in the ways of treating certain problems: Norway provides protection regulations applied to areas near natural protected ones, while Hungary mentions the provision of some buffer zones, but for green spaces; Iceland has a national register of sites of conservation importance, while Bulgaria, Hungary, and Slovakia pay attention to the national ecological network. Eastern European countries bring important additional specifications regarding detailing the regulations and zoning for each type of natural protected area, the system of environmental impact assessments (EIA), protected and protection areas defined within land use planning documents, the levels of protection, and the prohibition of changing land use inside and near natural protected areas. From these points of view, important additions could be made to the environmental legislation of Nordic countries.

Norway signals the importance of creating protected areas from the viewpoint of the quality of outdoor activities through a legislative act. At the same time, Poland emphasizes the creation of new green spaces to reduce the pressure on natural protected areas, but through a strategic document without legal value. We note, therefore, the importance of the legal value of the acts through which regulations regarding natural protected areas are proposed, considering their value from a conservative point of view. However, a common element in all the countries was identified in terms of accessibility for people with disabilities and the provision of necessary visiting infrastructure. This element consists of emphasizing the importance of improving on and investing in accessible and inclusive tourism [77].

Additionally, taking into account the complex spatial conflict between natural protected areas and the urban fabric, a law dedicated to the regulation of natural protected areas in the urban environment would support the elimination of/reduction in pressure on these natural areas. Such a law was identified only in Romania, being currently, however, only at the level of a legislative proposal.

The approaches to protecting heritage and the natural landscape are very different from country to country, although similar aspects have been identified between the legislation of Nordic countries and that of eastern European countries. The main purpose of our study was the analysis of the legislation and planning instruments aimed at natural protected areas in inner cities. In the end, it was observed that these focused more on the generic, multiscale treatment of natural heritage, at different scales of approach. The reason for directing the analysis in this sense was the lack of specifications with reference to natural protected areas in urban environments. Very few mentions have been identified that address this subject, with the heritage and natural landscape in urban environments being subject to different urban-anthropic investment pressures [78], which are totally different in Nordic countries compared to Eastern countries, and with differences due to historical, social, cultural, or geo-strategic contexts.

From a legislative viewpoint, Finland is the only country that has provisions regarding the type of natural protected area in an urban environment—chapter nine of The Land Use and Building Act is dedicated to regulating national urban parks, providing a “maintenance and use scheme” for each national urban park in its content.

So far, no country has adopted a law dedicated to natural protected areas in urban environments, but in Romania, there is a legislative proposal for urban natural protected areas and urban biodiversity conservation, which was adopted by the Romanian Senate and sent for debate in The Chamber of Deputies. Through this legislative initiative, Romania’s interest in natural protected areas in urban environments is noted, an interest that could be due to the large number/large areas belonging to these types of valuable areas. Approximately 59% of the cities in Romania overlap with at least one natural protected area and approximately 5% of the built areas of the urban settlements in Romania overlap with at least one natural protected area [79].

On the other hand, the territorial planning instruments provided by Romanian legislation may undergo advantageous changes in terms of a suitable approach possible for the natural heritage in urban areas. Urban territorial plans address natural protected areas to an insignificant extent, or even completely ignore them.

Additionally, considering the special natural heritage of Romania—the only country in Europe that has five biogeographical regions (continental, alpine, pannonic, pontic, and steppe)—considerable steps have been taken regarding areas of considerable conservation value, such as the adoption of the Framework Convention for the Protection and Sustainable Development of the Carpathians and the EU Strategy for the Danube Region, a major natural element that plays the role of a structuring axis at the European level.

The principles followed on the three analyzed levels—planning, legislation, and strategic approaches—were grouped according to the territorial scale of application in Figure 6.

The figure shows that, although planning instruments contain fewer and fewer regulations regarding natural protected areas and their adjacent areas as the territorial scale decreases from macro to micro, the situation is totally opposite from the viewpoint of laws and strategic documents. The provisions mentioned in the legislative and strategic acts are, in general, applicable on a micro scale, due to their specificity.

Planning instruments do not have generally valid models, nor do they generally provide for regulations at different scales of specific and particular approaches for areas adjacent to natural protected areas.

Thus, heritage and protected landscapes must be analyzed sensitively, treated as living organisms with their own changing internal metabolism and metamorphosis determining the urban metabolism [80], protected and conserved in an integrated correlation.

4.2. The Inner Validation of Results

The reason for choosing the two groups of countries was, as specified in the methodology, their different evolution from urban, political, and demographic viewpoints, starting from the premise that these different evolutions generated the creation of different models in terms of urban planning and its related specific legislation.

Although this analysis initially aimed to identify the way in which natural protected areas and their adjacent areas are approached in the documents mentioned above (legislative and related to urban planning), it was found that there are very few provisions strictly related to these areas, so all types of natural protected areas were included in the analysis, taking into account their possible treatment as any other natural protected area that does not necessarily have a direct spatial connection with an urban environment.

In the end, the hypothesis from the beginning was confirmed, with the analysis revealing two models with very different approaches, which created the possibility of making a comparison yielding later recommendations for all the countries, setting the grounds for an exhaustive urban planning approach for areas adjacent to natural protected areas.

4.3. The External Validation of Results

The natural heritage present in cities is not a new topic of research. There is a wide range of publications on this topic. However, as mentioned at the beginning of the paper, very few of them provide the guidelines needed in urban planning and territorial development to amplify the benefits generated by the presence of nature in a city, i.e., ecosystem services.

Despite the evolving role of cities as both consumers and producers of ecosystem services, challenges remain. These include the need for better methods and indicators for capturing urban ecosystem heterogeneity, a limited understanding of the link between urban ecosystem services and biodiversity, uncertainty regarding data transferability, and the lack of an analysis integrating people’s preferences and values, particularly in assessing cultural ecosystem services [81]. Although there is still no tool for quantifying and locating ecosystem services, their presence is undeniable, even more so for natural protected areas, taking into account the increased diversity of species, including native ones, the value of landscapes, or any other resources that were the basis for establishing a protection regime for that area.

Marques et al. [23] concluded in their work, published in 2022, that urban planning needs to apply research/analysis methods related to urbanism, respectively, biophysical, socio-cultural, and economic methods, which can be combined and integrated to be able to analyze the urban–natural relationship and the benefits of ecosystem services from quantitative and qualitative points of view. More studies are needed to map the benefits of nature in order to be able to formulate appropriate solutions.

Although 13 of the Sustainable Development Goals adopted by the Aichi 2030 Agenda are relevant for the management of natural protected areas [82], none of them make specific references to those in urban environments.

No articles have been identified that dealt strictly with the subject of urban planning or legislative provisions regarding natural protected areas located within urban environments, even less with regard to a specific country. Although multiple sources of information are available for performing a comparative analysis between Nordic and eastern European countries in terms of environmental and urban planning legislation and its related instruments, until now, this analysis had not been carried out. Thus, our study is a premiere. Its objective was to fill in this gap by highlighting the specific challenges encountered by each country, but also the good practices and possible directions for improvement in each individual country. Therefore, this research can contribute to a deeper understanding of the specific context of each country and important lessons can be drawn for developing and improving the legislation and urban planning tools throughout the entire region and beyond, with an emphasis on the appropriate approach to natural protected areas.

There are many publications addressing the advantages of the presence of these areas in cities, but the information related to their capitalization from the viewpoint of planning for their adjacent areas is currently very limited.

4.4. The Importance of Results

The accentuated differences between the two groups of countries made it possible to phrase more recommendations due to the different approaches in this field. Considering that, currently, there are no in-depth studies on urban planning near natural protected areas, our results can constitute a starting point for developing an urban planning tool applicable for these areas. This tool could support the planning process in a bidirectional way, i.e., by approaching the natural protected area as a component of the urban fabric or by approaching urban natural protected areas as part of the network of natural protected areas.

4.5. Summary of the Study Limitations and Directions for Overcoming Them in the Future Research

This research was constrained by a series of practical limitations. The most obvious of these is the current very limited knowledge of the analyzed subject—that of the urban planning for areas adjacent to natural protected areas in urban environments. Another limitation was the very limited approach to this issue within the legislative and urban planning acts.

An elimination of these two limitations or their reduction would require the development of studies and the discovery of methods by which the ecosystem services generated by natural protected areas in urban environments could be quantified and located spatially. Subsequently, the creation of an urban planning tool could be adaptable according to the particularities of a respective area and could even be part of urban planning documentation.

5. Conclusions

The freedom to choose the tools for managing urban biodiversity conservation and planning the quasi-natural system in a city offers the possibility of developing plans adapted to the concerned territory/area [83]. However, upon comparing the two analyzed models—the Nordic and eastern European ones—it was found that the two have adopted different instruments in terms of the territorial scale of their application, but also that they both require improvements, from the viewpoints of both territorial planning and legislation.

As it emerged from the results of the analysis carried out individually for each of the 11 countries, and later in parallel (individually, but also based on the two groups), there was a major difference in the attention given to natural heritage. Although all the countries have adopted important and, at the same time, remarkably diverse provisions, only a few provisions dedicated to natural protected areas in urban environments have been identified (the existing provisions in the legislative acts of Finland and provisions contained in a draft law of Romania).

For this purpose, a series of recommendations were made regarding the two levels of analysis and the strategic approaches being approached separately from the urban planning instruments, due to a lower legal value. Certain recommendations target both groups of countries, such as the need to adopt specific regulations regarding the system of protected natural areas and their protection/adjacent areas in planning at the mezzo-territorial level and at the zonal and detailed levels. Others target only one of the two groups of countries or only one country in particular, such as the recommendation for the Nordic countries to bring specific additions to the regulation of each type of natural protected area or the need for Romania to draft provisions for approaching natural heritage in its urban planning documents.

Urban planning, together with its related legislation, must become a well-clarified process, in the sense of supplementing legislative acts with regulations as specific as possible for local heritage and, at the same time, appropriate to the particularities and context that define it.

The need for completion was identified at the two levels of analysis—urban planning legislation, in all the sensitive aspects and typologies of heritage and natural, anthropic, and cultural landscapes, in close development and connection with the historical evolution of unique and particular morpho-typological germs—this being the main particular characteristic at the EU level of all the countries, especially Romania.

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