Memorandum submitted by the European Environmental
This submission reviews the commitment to environmental
integration made by all Member States of the European Community,
culminating in the Treaty of Amsterdam. It goes on to analyse
the current barriers to integration, citing the lack of provision
for monitoring and target setting on the environment; the sectoral
and vertical nature of policy making; and the lack of internalisation
of environmental costs. Finally, it suggests how the UK Government
could take a lead role in working through solutions to these issues,
on procedural, institutional and political levels.
In signing the Treaty of Amsterdam, Member States
of the European Union strengthened the already-existing commitment
to considering the environment in all policy areas. According
to the Treaty, all EU policy must be contribute to the goal of
sustainable development. In particular, the Treaty states that
"The Community shall have as its task.... a high level of
protection and improvement of the quality of the environment".
This treaty requirement was enacted through the process leading
up to the Cardiff Summit in June 1998, where the European Council
consisting of the heads of state asked "all relevant formations
of the Council to establish their own strategies for giving effect
to environmental integration and sustainable development".
Progress toward this goal will be reviewed at the Helsinki Summit
in December 1999.
The UK Government played a leading role in the
political momentum behind the drive for environmental integration,
particularly leading to the Cardiff Summit in June 1998. This,
together with the example of good practice provided by the UK's
Greening Government mechanisms and the White Paper A Better
Quality of Life (see the section below on indicators and targets),
gives the UK a strong basis for leadership on environmental integration.
There is much political capital to be made in leading the Union
on sustainable development, and the UK Government should provide
strong political support for the Helsinki Process.
Despite this process, actual achievement of
integration to date has been slow. The commitments offered by
Councils so far have been incrementalist in approach, lacking
the more fundamental policy rethink which sustainable development
necessitates. Within the other institutions, it remains an issue
dealt with in large part only by the Environment directorate of
the Commission and the Environment Committee of the Parliament.
Overall leadership is lacking.
In the UK's case, there is little explicit linkage
between the national sustainable development strategy and efforts
at European level - although the national strategy mentions the
European process, the way in which the two interact and complement
each other is not examined. This is a significant oversight, given
the central importance of EU policy in many areas.
The following section explains and outlines
the reasons for some of these difficulties.
European environmental policy has to date been
seen as a sector-specific issue. Individual environmental problemsair
quality, water, biodiversityhave been dealt with in isolation.
There are advantages in taking such a focused, specific approach.
It allows problems to be defined, with clear legislatory goals
such as emission levels for air pollutants. This in turn makes
implementation more straightforward. However, such an approach
does little to change the underlying social and economic reasons
for environmental deterioration. Setting emissions levels for
air pollutants may eventually lead to a re-think of transport
policy, but there is no direct policy linkage. The contribution
to the shift toward a more sustainable economy and society is
tangential at best. There is a strong case for working at both
ends of this equation - setting emissions levels, but also proactively
re-thinking transport policy to integrate environmental considerations.
Moving away from this sector-specific approach,
however, is problematic given the institutional structures in
place. Policy is carried out in issue-specific departments. In
the Commission, environment policy is managed by a different Directorate-General
to transport. There is little horizontal linkage between the two,
and "non-environment" Directorates-General have limited
incentive to take the sustainable development message to heart.
A similar situation arises with the Committee system of the European
Parliament. Any attempts to integrate the environment must address
Neither is there clear vertical linkage between
the EU as a whole and individual Member States. Member States
have a legislative responsibility to enact and enforce EU environment
legislation, but there is no such clear-cut responsibility for
them to address the wider issues of integration. This is complicated
by the demands of subsidiarity, which give Member States control
over sectors such as taxation, transport and housing policy, with
limited involvement from EU institutions. As a result, national
strategies for integration and sustainability have largely remained
separate from initiatives at the EU level.
To work toward integration, then, there is a
need to develop explicit mechanisms and structures which delineate
responsibility both horizontallybetween directorates-general
and committees at the European level, and verticallybetween
the EU, Member States and regions. This will not work without
political commitment at each of these levels.
The following section outlines some solutions
to these issues, and next steps in the Helsinki process and beyond.
Indicators and targets
Indicators of sustainable development provide
a measure of quality of life which does not depend entirely on
economic information. They also spread responsibility for sustainable
development across policy areas, covering transport, energy and
housing, for example. This helps the integration process, as it
shifts responsibility from "environmental" policy-makers
Indicators also have an important public relations
function. A subset of "headline" indicators, which provide
accessible information on key sustainability issues, help to promote
the sustainable development message. Europe-wide indicators, if
linked to national indicators would reinforce this message. However,
confusion over different sets of indicators at national and European
level could have the reverse effect.
The UK is in a strong position to lead the EU
in the development of indicators and targets. The UK Government
White Paper A Better Quality of Life, which sets out a
range of 150 indicators, including 14 headline indicators, designed
to measure quality of life in its widest sense, provides a good
model. There has been little progress toward turning these indicators
into clear targets. However, the Government's commitment to reviewing
improvements or deteriorations in indicators, and adjusting policy
accordingly, should provide a minimum standard for the EU.
Much discussion about the merits of various
different indicators has taken place, and we do not propose to
rehearse these arguments once more. We draw the Committee's attention
to the set of indicators developed by the European Environment
Agency, as well as the EEB's suggestions for a set of headline
indicators, attached as an annex to this document. These indicators
measure air quality; water quality; climate change; hazardous
substances; land use; biodiversity; water use; materials use;
transport; and agriculture.
Several general points are important:
Although discussion on the precise
nature of indicators and targets is ongoing, the Helsinki process
should agree a basic set of headline indicators and targets, which
can subsequently be modified. A more detailed set of sectoral
targets should follow. The political leadership is equally, or
arguably more, important than detailed negotiation over the precise
nature of indicators.
Targets and indicators should be
a mixture of cause and effect, depending on the nature of the
environmental issue measured. For example, biodiversity is an
"effect", an outcome which has various natural, social
and economic causes. Carbon dioxide levels are a "cause"
indicatorreductions in carbon dioxide are necessary to
prevent climate change (the effect). Concentrating on "cause"
alone would mask the important message of environmental deterioration
whereas a focus on "effect" would not provide a clear
link to the policy changes necessary to prevent the "causes".
Indicators should be closely linked
to targets. As with the climate change process, targets should
be short, medium and long-termshort-term achievable targets
and longer-term aspirational targets.
Clear division of responsibility between regional,
national and European authorities should be allocated to targets.
This is important, because as an inevitable consequence of subsidiarity,
national, regional or local governments have control over many
policy areas which affect the achievement of targets. For example,
carbon dioxide emissions are largely influenced by national industrial,
transport and energy policy; but European policies in this area
have an impact too. The protection of biodiversity is both a national
issue and a European issue - the EU Common Agricultural Policy
in its current form encourages farming patterns that reduce biodiversity.
The EU's contribution to the achievement of targets is twofold:
EU policy, as agreed by the EU institutions
in areas such as energy and transport, must contribute toward
the improvement in indicators and the achievement of targets.
EU policies must be reviewed in the light of their contribution
to these targets. (see below, under "horizontal measures",
for details of assessment methods).
EU policy in areas such as competition
and harmonisation must not compromise individual Member States'
attempts to achieve targets. Environmental measures must not be
seen as barriers to trade. For example, a tax on packaging which
aims to reduce resource use must be allowed under competition
Sectoral strategies should be seen as part of
an integrated approach towards sustainable development. We comment
here on the three sectors for which a strategy is to be finalised
for the Helsinki Summit. However it is also important that cross
sectoral environmental problems are not forgotten in this process.
We need clear targets for burden sharing to make sure that overall
targets are reached.
To date, European policies have aimed to increase
transport as much as possible so as to increase trade within the
internal market and add to European economic activity. However,
over time it has become apparent that increasing transport for
the sake of economic growth has led to both economic inefficiency
and large scale harm to human health and the environment. The
response to the damage this transport has wreaked has thus far
been limited to mitigating the damage transport causes, rather
than tackling the underlying cause. This has prevented the development
of a truly sustainable transport policy which would de-couple
economic and transport growth. This is most clear in the case
of transport CO2 emissions where the sector is predicted to contribute
the vast majority of EU CO2 sectoral increases.
To reverse this trend the following first steps
are essential :
1. External costs of transport must be internalised
(eg via electronic road pricing and fuel duties)
2. EU policies (eg regional policies) must
promote local or regional production and consumption patterns
in order to reduce the need for transport. Furthermore, other
policies reducing demand for transport and de-coupling transport
from economic growth must be advanced eg planning policies bringing
working, recreation, and living areas closer together.
3. Direct and hidden subsidies for road and
air transport must be stopped. This would necessitate a re-appraisal
Sustainability in the transport sector will
require better technology, greater efficiency, modal shifts and
improved performanceboth environmental and social. But
it will also crucially depend on successfully tackling the growth
in transport demand. A transport policy will deliver a triple
dividend of less pollution, greater economic efficiency, and lower
EU energy policy rests, in theory, on security
of supply, competitiveness and environmental protection. In practice,
the policy framework is centred on liberalisation, which alone
addresses only competitiveness, and then only partly. For the
wider goals to be met, energy efficiency and the use of renewable
energy must be key priorities.
A clear commitment to renewable energy and energy
efficiency should be the explicit core of EU energy policy. To
ensure that the necessary changes are made a number of key policy
priorities need to be achieved in the short to medium-term.
1. External costs of energy consumption must
be internalised through a European energy tax. Ideally this should
be applied to all sectors, to all sectors since making exemptions
undermines the effect of such a measure. Even more importantly,
it must contain a progressive elementie a ratchet effect
signalling a steady increase. This will send a clear and reliable
signal to the market, encouraging timely and cost-effective investments
2. Explicit targets must be set for improvements
in energy intensity (energy used per unit of output.) Annual improvements
(ie reduction) of 2.5 per cent in energy intensity are essential
if the Kyoto target is to be kept in reach. This target must be
accompanied by a clear action plan for its implementation.
3. Subsidies for fossil fuels and nuclear
power must be phased out by the year 2005. In any case, there
must be an explicit guarantee that these reductions will precede
any reduction in support for renewable energy technologies. The
historical subsidies for conventional power sources, especially
in R&D, will be borne in mind in allocating R&D funding
to the newer renewable energy technologies.
4. The target for renewable energy (12 per
cent of energy supply) must be put into legally-binding renewables
targets for the Member States. These binding targets must include
interim targets for 2005 (totalling 8 per cent of EU energy supply),
and appropriate penalties in place for failure to meet these targets.
These targets must all be considered interim
objectives. An overall energy strategy must also address the issue
of how to build on these targets and further increase the sustainability
of EU energy policy.
To date little or no progress is visible on
these themes. For a serious sustainable energy policy to emerge
in the EU these policy measures must be seen as crucial items
on the political agenda, both at EU level and among the Member
The Common Agricultural Policy (CAP) of the
EU is the main driving force for agriculture intensification,
resulting in environmental degradation, loss of biodiversity,
loss of jobs in rural areas and loss of traditional landscape.
The recent reform of the CAP, has only partially begun to address
some of the general environmental issues, with the approval of
the cross compliance regulation, area payments in Less Favoured
Areas, national envelopes and the creation of the Rural Development
However, the success of these new measures will
largely depend on the extent and ways in which these measures
will be implemented. Therefore Commission and the Council should
pursue an effective implementation of the current legislation
to maximise the integration of environmental considerations into
the agriculture sector.
To achieve this:
The Commission should give clear
guidance and make sure that full application and monitoring of
a mandatory Cross-Compliance measure in Member States is achieved.
Member States should implement the
Rural Development Regulation, allocating appropriate economic
support to the co-funded measures and ensuring a balanced allocation
of funds to different measures within the plans.
Member States should make effective
use of the National Envelopes to support extensive farming systems
which go beyond basic environmental conditions to deliver real
additional environmental benefits.
Member States should increase the
funding of agri-environmental measures, to rebalance the unfair
competition with compensation payments, and give more support
to conversion to organic food production.
The Commission should enforce the
full implementation of the Nitrates, Habitats, & Wild Birds
Directives as required by the EU environmental legislation, with
no further delays.
As many opportunities to promote environmental
integration have been lost in the last reform, a new one is urgently
needed in the near future. The next stage of reform of the CAP
should give priority to:
de-coupling agricultural support
from production, shifting funds to a new integrated rural policy
to address the decline of rural economies, promote sustainable
forms of agriculture, creating jobs and safeguarding the environment.
Economic support should promote diversification of sustainable
rural activities to benefit the whole rural community, including
increasing the level of funding and
expanding the coverage of agri-environmental measures to address
specific environmental needs, and the creation of an effective
monitoring system on the environmental benefits of the schemes;
including strategic environmental
assessment of policy reforms: future reforms of the CAP should
have a thorough assessment of the environmental impact on biodiversity
and landscape, as well as on the socio and economic aspects, of
Sectoral strategies and targets must be complemented
by horizontal mechanisms that address the cause of environmental
problems. For example, a Europe-wide CO2 reduction target must
be accompanied by horizontal mechanisms that will ensure CO2 reduction
across sectors, such as a European energy tax. Possible horizontal
Ecological tax reform: increasing
the cost of resource consumption, while decreasing labour costs
will induce a new type of productivity increase - focussing more
on productivity and less on labour. It will increase efficiency
in resource use and create jobs.
Targeted reforms of VAT schemes and
other indirect taxes: Promote environmentally friendly products
and services with lower rates. For example, allow a reduced rate
for products and services that have been awarded with European
Ecolabels and official national ecolabels.
A systematic review of subsidy policy,
which is damaging to the environment, such as price intervention
in agriculture or coal subsidies in many Member States.
Intensification of the EU's "greening
the budget" initiativewith sustainability assessments
explicit in all budget proposals put forward both by the Commission
and the Parliament.
Environmental Liability as a means
to internalise the social costs of risk in order to correct market
failure by risk externalisation.
The following are methods of assessment, auditing
and reporting. All these techniques should refer to established
indicators and targets (see section on indicators and targets,
Strategic Environmental Assessment
for policies, plans and programmes in order to make strategic
sectoral planning environmentally more accountable, as proposed
in the draft directive currently awaiting adoption by the Council.
Appraisals of each Commission policy
proposal and budgetary proposal, in the form of a statement on
its contribution to sustainable development, including details
of its effects on the environment.
Transparency and public participation.
And, as endorsed by the Fifth Environmental
Action Programme, modify GNP so as to reflect the value of natural
and environmental resources in generating current and future incomes
and to account for environmental losses and damage on the basis
of assigned monetary values.
Our analysis of the EU's institutional structures
(see the "barriers to integration" section above) shows
that there will be a need to modify institutional structures to
promote integration. The forthcoming Intergovernmental Conference
provides an opportunity to look at this. Priorities for institutional
reform are as follows:
At present, the Council of Ministers
is the only institution required to produce sustainability strategies.
This requirement should be extended to the Commission Directorates-General,
who will be called upon in any case to implement the proposals
of the Council. The European Parliament should scrutinise the
The European Parliament should be
asked to consider how to promote integration within its committee
structures, and to establish more efficient systems of horizontal
linkage between committees.
The Parliament could take a lead
on integration by refusing to consider Commission proposals unless
accompanied by an environmental appraisal and a statement of how
the appraisal has been incorporated into the proposal.
Neil Kinnock, Vice-President of the
European Commission with responsibility for institutional reform,
should be mandated by the Council to consider the integration
issue when drawing up his proposals.
The European Spatial Development
Perspective could prove useful in encouraging horizontal integration
by injecting a sense of geography into EU policy and programmes.
The UK's "Greening Government"
initiative, the Green Ministers system, the Cabinet Committee
on the Environment, the Sustainable Development Unit and the Environmental
Audit Committee, could be provide a useful model of institutional
structures for integration to be adapted for the European situation.
A SUSTAINABLE DEVELOPMENT
The EU's Fifth Environmental Action Plan, Toward
Sustainability, was an important step in the process of integration,
as it laid down the principle of sustainable development in the
European context. Its success has been limited, however, partly
due to the lack of political commitment to it, and the consequent
leadership vacuum (see below). Ownership of the Plan has remained
with the Commission's DG XI, without buy-in from the other Directorates-General,
the Parliament or indeed civil society.
Discussions on a replacement for the Plan are
under way. EEB supports the proposal for a Sustainable Development
Strategy for Europe, going beyond environmental considerations
and being led from the centre.
This would fulfil the commitment that the EU made
in 1997 to UNGASS, to report to the 2002 special UN assembly.
The following elements of the plan are crucial:
The plan needs clear leadership from
a senior, "non-environmental" figure, such as the Commission
Vice-President, who should be known as Commissioner for Sustainable
Development, and a champion of the cause. It should not be the
Environment Commissioner who takes responsibility, as this negates
the very idea of integration.
It must contain a clear vision of
a sustainable European Union, with short-term achievable goals
and longer-term objectives.
It must be explicit in its linkages
with national sustainable development strategies of member-states.
It must incorporate a sustainability
plan for relations both with accession countries and with third
countries, particularly those in the developing world.
It must be legally binding, with
updates and revisions by future European Councils.
The Council should aim to adopt the
Strategy during the Swedish Presidency.
The drive for sustainable development and integration
requires political leadership, in as well as the structures and
mechanisms listed in this evidence. In addition to the proposal
for a "Commissioner for Sustainable Development", (see
previous section) each new Commissioner should be made aware of
their responsibility under the Treaty to ensure integration, and
to oversee this work within the Directorates-General of the Commission.
The clearest sense of leadership must come from
the Council itself. Governments with solid experience in the integration
agenda, such as the UK, are in a strong position to lead the agenda.
UK NEGOTIATING POSITION
Based on the above analysis, EEB-UK calls on
the Environmental Audit Committee to support the following recommendations
to the UK Government:
Provide strong leadership on sustainable
Promote the UK's greening government
initiative as a model for institutional structures promoting integration
which provides useful lessons at the EU level.
Capitalising on the UK's authority
on sustainable development indicators, ask for political agreement
on a set of headline indicators at Helsinki, and give a clear
mandate, with timescale, for the development of a single set of
more detailed proposals, rather than the conflicting range of
initiatives currently on the table.
Use indicators to establish targets
for the shortand mediumterm, with clear responsibility
for achievement of the targets allocated horizontally (between
sectors) and vertically (between the EU, member states and regions).
Call for a Sustainable Development
Strategy for Europe, under the leadership of a Commissioner for
Make explicit the linkages between
our national strategy, A Better Quality of Life, and the European
Call for the continuation of the
process of drawing up sectoral sustainability strategies for each
Council, with ongoing revisions to ratchet up standards; and ask
the Commission to go through the same process with its Directorates-General.
Call for environmental appraisals
from the Commission of policy proposals in all Council meetings
and refuse to consider proposals which do not include an appraisal
of environmental effects.
Support the Finnish Presidency initiative
to reach agreement on the Directive on Strategic Environmental