Campaign for Nature

H.E. Ms. Egriselda López, Permanent Representative of El Salvador to the United Nations H.E. Mr. Rein Tammsaar, Permanent Representative of Estonia to the United Nations Co-Chairs, Global Dialogue on AI Governance April 30, 2026 Dear Co-Chairs, We welcome the Global Dialogue on AI Governance and the call for written inputs ahead of the July session in Geneva. We work on the implementation of the Kunming-Montreal Global Biodiversity Framework adopted at COP15 in 2022, and we are writing because we think there is a significant blind spot in how AI governance is currently being framed that deserves attention before the agenda is set. The four proposed thematic clusters cover important issues, but none of them addresses what AI's current and potential future impact will have on the natural world. AI is increasingly functioning as a general-purpose accelerator for economic activity lowering the cost and friction of resource extraction, infrastructure development, and land conversion. Meanwhile, the Kunming-Montreal Framework commits governments to halting and reversing biodiversity loss. This goal could be jeopardized by AI-driven resource exploitation that current governance frameworks were not designed to address. We are not raising this to argue against AI. We are raising it because the window to build nature into foundational AI governance frameworks is genuinely short, and once it closes, retrofitting will be much harder. Specifically, we would ask the Dialogue to consider three things. First, planetary boundaries should be treated as a cross-cutting dimension of AI governance, recognized as a non-negotiable threshold alongside human rights and safety. The science on this is clear: biodiversity loss, land system change, and freshwater use are planetary boundaries that, once crossed, are not reversible on any timescale relevant to human governance. Second, the Dialogue should explore what meaningful disclosure would look like for AI-related nature impacts. Third, we would strongly encourage the Co-Chairs to establish a formal link between this process and the CBD, particularly ahead of COP17 in Yerevan this October. Similar links should be established to the other Rio Conventions. AI governance and biodiversity and climate governance are currently running on entirely separate tracks. That separation is not sustainable. We would welcome the opportunity to engage further on any of these points. Respectfully, Brian O'Donnell Director, Campaign for Nature Marco Lambertini Executive Chair, Nature Positive Initiative Secretariat Martin Harper Chief Executive Officer, BirdLife International Wildlife Conservation Society

Safe, secure and trustworthy AI

There is not even an option to select ecological impacts of AI. Other species that we share this planet with are not considered at all in the dialogue so far - that option for biodiversity impacts of AI must be a fundamental part of the dialogue.

The impacts on nature and biodiversity are completely absent from the themes. There are millions of species on the planet in addition to humans that will be directly impacted through AI via data centers and through AI's role as a general purpose economic accelerator. Nature is declining rapidly via resource use, extraction and consumption. AI will increase all pressures rapidly. Nature seems totally absent from the agenda but it is potentially the most at risk from AI. It must have a central part of the agenda. This process is also not well connected with the Kunming Montreal Global Biodiversity Framework and its goal to halt and reverse biodiversity loss by 2030 on which there is a global agreement.

The lack of biodiversity governance and planetary limit safeguards for AI mean that it is being developed without concern about planetary boundaries and is accelerating the loss of biodiversity at exactly the time when we need to be halting and reversing biodiversity loss.

It can develop principles and a framework that can lead to national legislation and a global treaty.

It should incorporate the principles of the Nature Positive Coalition and the goals and targets of the Kunming Montreal Global Biodiversity Framework.

The should be opportunities for written participation and some online forums so that travel to Geneva is not the only way to participate.

Environmental leaders, Indigenous voices.

This process needs to move much faster than usual UN processes or it will be left behind by AI companies.

To be honest, there aren't any currently. World leaders are woefully behind in any form of effective AI governance. It cannot remain segregated and voluntary.