Select Committee on Environmental Audit Minutes of Evidence

Memorandum submitted by Dr Andrew Jordan[7] and Dr Andrea Lenschow[8]


  Achieving environmental policy integration (EPI) is the critical challenge confronting environmental policy makers at the dawn of the new millennium. EPI means moving beyond end-of-pipe environmental regulation to address the root causes of environmental damage. However, EPI is very different to traditional systems of pollution control, requiring a much more anticipatory and multi-sectoral approach to protecting the environment than that currently in place anywhere in the industrialised world.

  Environmentalists made an intellectually convincing case for the systematic application of EPI at the European level when European Union (EU) environmental policy was first founded in the early 1970s, but only now are their arguments being seriously addressed by the Commission and the Council of Ministers (CoM). Currently the so-called "Cardiff process" of reporting is primarily concerned with the challenge of implementing EPI at the European level. However, there are important reasons why policy makers must consider EPI as being as much a multi-level as a multi-sectoral challenge. In other words EPI initiatives should fully embrace all levels and sectors of government in the EU in order to ensure that the overall effort isco-ordinated and comprehensive in its coverage. In short, EPI cannot be pursued solely at the European level through the institutional mechanism of the Council of Ministers.

  An integrated, multi-level approach to EPI is necessary because the most significant "driving force" sectors of environmental damage (eg energy, transport etc) are not nearly as communitised (ie EU led) as EU environmental policy. Consequently, the EU's ability to steer them in a more sustainable direction remains relatively weak. Responsibility for achieving EPI therefore has to rest equally with Member States who, in accordance with the principle of subsidiarity, must take appropriate steps to "green" their own national policies in pursuit of sustainable development.

  This memorandum draws upon the preliminary findings of a comparative analysis of the implementation of EPI by Member States and the institutions of the EU (Lenschow, 2000). The evidence presented below suggests that EPI represents a far stiffer challenge to the policy status quo than even the most environmentally progressive "frontrunner" states of the EU (Germany, the Netherlands, Denmark and (at least on this issue) the UK) seem capable of overcoming. Having identified the main gaps and overlaps with and between actions currently being undertaken at all the main levels of environmental governance in the EU, we try to identify the potential for cross-national learning and lesson-drawing in this important domain of environmental policy.


  The thinking that lies behind the concept of environmental policy integration (EPI) is not at all new, although it only really began to achieve wider currency with the publication of the 1987 United Nations (Brundtland) Report entitled Our Common Future. Brundtland identified EPI as a necessary but insufficient condition for achieving sustainable development which, according to the 1999 Amsterdam Treaty, is now an overarching goal of the EU. Brundtland identified the fundamental mismatch between the integrated operation of ecosystems and the sectorised structures and operational procedures of those bodies administered to manage it, as one of the root causes of unsustainable development:

        "Those responsible for managing natural resources and protecting the environment are institutionally separated from those responsible for managing the economy. The real world of interlocked economic and ecological systems will not change; the policies and institutions concerned must" (WCED, 1987, 9).

  The EU's failure to attain this administrative ideal is demonstrated by the deeply sectorised structure of both the Commission and the CoM. Brundtland's intellectual solution to this sort of institutional mismatch was simple:

        "the major central economic and sectoral agencies of governments should now be made directly responsible and fully accountable for ensuring that their policies, programmes, and budget support development that is ecologically as well as economically sustainable" (WCED, 1987, 314).

  In practice EPI requires nothing less than a political revolution in European political governance: environmental agencies must now colonise the key centres of power at all the main administrative levels of the EU, by winning over more powerful sectoral agencies to their way of thinking. Given the historically low political status of most environmental directorates, departments and agencies at all levels of governance in the EU, and the deeply entrenched barriers to horizontally co-ordinated activity ("joined-up-policy making"), the political difficulty of achieving such a transformation even in the medium term should not be underestimated.

  What exactly does EPI involve? Unfortunately, EPI is a general principle of environmental policy making not a well-developed plan of action. Arild Underdal suggests that a policy is integrated when "the consequences for that policy are recognised as decision premises, aggregated into an overall evaluation and incorporated at all policy levels and into all government agencies involved in its execution" (in: Weale and Williams, 1992, 46). We would argue that policies are environmentally integrated when policy makers in "non" environmental sectors recognise the environmental repercussions of their decisions and adjust them when they undermine sustainable development. According to the European Environment Agency (EEA), EPI is a process of adjusting the focus of environmental policy away "from the environmental problems themselves to their causes . . .. [and] [f]rom "end-of-pipe" environment ministries to "driving force" sector ministries" (EEA, 1998, 283).


  The appearance of Article 6 of the 1999 Amsterdam Treaty marked an important watershed in thinking about EPI in Europe. Currently, however, the main focus of the so-called "Cardiff Process" of reporting on the environmental impact of different sectoral formations of the CoM (eg agriculture, energy, single market etc) is upon what should be done at the European level to achieve EPI. The European level is, of course, hugely important because many, if not most, aspects of national environmental policy are now decided there. But it is also vitally important to remember that EPI is (and always will be) a multi-level challenge which bears upon and requires co-ordinated responses from all levels of government in the EU—European, national, regional and local.

  National governments perform a particularly important role in this respect because the most significant "driving force" sectors of environmental damage are not nearly as communitised (ie EU led) as EU environmental policy. Consequently, the EU's ability to steer them in a more sustainable direction is relatively weak. Responsibility for achieving EPI therefore has to rest equally with Member States who, in accordance with the principle of subsidiarity, should make appropriate adjustments to their own national policies in areas such as transport and energy to achieve sustainable development. For example, local land use planning[9] is a potentially important tool for managing the demand for transport, but it is mainly under the control of states. Similarly, alterations in national energy policies have a significant impact upon total European emissions of various pollutants, but they too are mainly state controlled. The same also can be said of structural (regional) development policies. Thus, funds may be made available by the EU for infrastructural projects, but most of the planning and decision-making—ie the key decision-points where EPI has to bite if it is to be effective—is undertaken by the Member States. EU legislation provides a legal framework for achieving EPI at these lower (ie national and sub-national) levels of governance (ie the environmental impact assessment (EIA) directive) but there are limits upon its overall effectiveness. Crucially, the primary responsibility for undertaking EIAs and other forms of policy appraisal, currently rests with national or regional authorities.

  All these examples illustrate the complicated interdependencies that exist between different levels of governance in the EU. For many environmentally-related issues, it is Member States (and their emanations) acting individually within their own territories rather than collectively in the various sectoral formations of the CoM that make (or fail to make) many important "integrated" decisions. The protracted political battles surrounding the allocation of emission reductions strategies within the EU's climate change "bubble" provide a sobering reminder of potentially difficult it can be in practice to achieve co-ordinated action across the various level of the EU in pursuit of a goal agreed jointly at the Ministerial level in the Environment Council.


  Ultimately the acid test of how well EPI measures are performing has to be the extent to which they contribute to the achievement of sustainable development. Unfortunately, sustainable development is not a sufficiently clear endpoint to employ as an evaluative yardstick. It is, as the EU recognises, more useful to break the term down into a series of more specific targets or "benchmarks" (see: EEB, 1999). The European Environment Agency (EEA, 1998, 284) has usefully provided a suite of possible indicators expressed in the form of a checklist of questions which includes the following:

    —  Has an environmental impact assessment been undertaken at the planning stage of a new policy (ie strategic environmental assessment (SEA))?

    —  Have the potential environmental impacts been identified and, where possible, quantified?

    —  Have any environmentally damaging subsidies been withdrawn?

    —  Do government purchasing strategies take sufficient account of environmental issues?

    —  Are there environmental management measures within government and is implementation monitored?

  To these we would add that there should also be a common set of what the Cardiff process refers to as "sector-specific targets, timetables . . . and indicators." These would measure the overall performance of EPI measures and, where necessary, flag the need for corrective measures when deviant sectoral policies threaten the attainment of sustainability objectives agreed jointly.


1.   The United Kingdom

  Since the publication of the 1990 White Paper, the UK Government has, through its "greening government" initiative, made comparatively good progress in implementing EPI at the national level, although critical bottlenecks remain. The initiative tries to build an environmental element into the comparatively strong and centralised system of policy development and co-ordination that exists in the UK (for an historical overview, see: Hill and Jordan, 1993; Jordan, 2000). In principle, the machinery of government in the UK is strong. The problem, as the Audit Committee's own investigations have regularly revealed, lies in its continuing reluctance to take environmental protection requirements as seriously as social and economic concerns (HC 517-I, Session 1997-8, paragraph 4). The failure to attain higher levels of EPI is often put down to a combination of weak political leadership at the centre of government and resistance from other departments, who see little to be gained politically or economically by voluntarily adjusting their policies to reflect environmental requirements. The clear impression given by their Lordships when they investigated the White Paper process in 1995 (HL 72, Session 1994-5) was that there was no systematic inter-policy co-ordination on environmental matters outside that dictated by EU Directives and political expediency generated by controversial events and electoral considerations. The Audit Committee referred to this very minimalist interpretation of EPI as "green proofing". Crucially, this highly truncated form of EPI fails to penetrate that most fundamental of all government activities—the setting of a national budget (HC 326, Session 1998-9, 3).

  In terms of the EEA's evaluative criteria, the UK continues to resist the Commission's attempts to introduce a more systematic process of SEA in the EU, even though most of the main elements are in fact already in place. The Audit Committee has done much to reveal how inconsistently the UK's applies its preferred alternative—policy appraisal. Estimating the total level of environmentally damaging subsidies in the UK is an extremely difficult task. However, the British Government Panel on Sustainable Development's (1997) conservative estimate of £20,000 million p.a. indicates the scale of the change that is theoretically possible. Pressure from the Audit Committee has been instrumental in encouraging several departments to adopt environmental management systems but there are parts of Whitehall where commitment remains weak. Finally, the UK has adopted a suite of national sustainability indicators but they will only really support the attainment of EPI if they are tied directly to sectoral policies. In particular, it is still unclear which, if any, policy levers the Government will pull if the indicators selected begin to move in an unfavourable direction.

2.   The Netherlands

  The Netherlands was one of the first countries to recognise the inter-coupling of environmental and sectoral policies, and has been a "frontrunner" with regard to the implementation of EPI ever since. The Dutch National Environmental Policy Plan (NEPP), published in 1989, was the first policy outcome of an emerging awareness among governmental elites that EPI could not be achieved by the state acting alone. The Plan was jointly drafted by a number of Ministries, but the intention was always to develop a wider "social contract" with Dutch civic society. The NEPP and its successors (NEPP3 was adopted in 1999) have all adopted a new problem-solving approach to environmental issues which addresses the attitudes and behaviour of all societal actors (the so-called verinnerlijking strategy). In this, the internalisation of environmental concerns is seen as a vital prerequisite for effective EPI feeding through to alterations in consumption and production patterns. Consequently, at the planning stages "target groups" were formed to draw in and engage the most important stakeholders.

  In detail, the Plan reflects Brundtland's emphasis upon long-term planning, wide stakeholder engagement and positive-sum relationships between environment and the economy. The Plan has a 25-year time horizon and includes cost-figures for environmental measures to achieve long-term targets (eg. acidification, waste generation). The target groups have remained important in the implementation process of the NEPP (Le Blanch, 1996). Sectoral target groups were asked to define policy objectives for themselves and select appropriate policy instruments. The advocates of consensual policy making believed such an approach would facilitate the recognition of "win-win" situations and prevent conflicting interests from becoming entrenched (Bressers and Plettenburg 1997, 124). The environment department acted as the overall coordinator and facilitator for the different target groups looking after the implementation of the NEPP. Within the environment department policy activities flowing from the NEPP process have been divided among the different directorates. A training programme was established called the Implementation Challenge to train the 400 or so officials affected by EPI. Other departments soon followed with the development of their own environmental policy plans. They also acted as conveners for various target groups covering issues such as an energy saving programme, agricultural protection, and land use planning etc.

  How successful has the Dutch target group approach been? Glasbergen and Driessen (1994) cite several examples (the Genre Valley, the Green Heart, Schiphol Airport) of relatively successful "network management" resulting in integrated approaches to infrastructural projects. However, even with these EPI initiatives the actual environmental performance of the Netherlands is far from perfect. Critics point to continuing sectoral rigidities particularly in the agricultural sector whose contribution to water pollution has long been recognised (Hajer 1992; van der Straaten and Ugelow 1994). Network management has proven to be a complex process requiring good communication skills on the part of the convenors and the facilitators (in order to prevent that stakeholders becoming adversaries of the process, for instance) (cf DeJongh 1998).

  To conclude, the Dutch interpret EPI as a societal responsibility. In spite of continuing problems, they have made considerable progress in integrating environmental concerns into sectoral policies at all levels of government. With respect to the EEA's checklist, SEA has been formally required in the Netherlands since 1987 for sectoral plans relating to waste management, drinking water and energy supply. SEA arrangements were extended and formalised by the NEPP. Economic appraisal techniques have been extensively used to determine policy strategies to reach the targets identified in negotiations with stakeholders.

3.   Germany

  Whereas the Dutch have relied upon a partnership approach between state and society to deliver EPI, the German approach remains largely state-centred. Along with the Netherlands and Denmark, Germany has traditionally been one of the environmental leaders of the EU. It gained this reputation by advocating and adopting strict environmental legislation, most notably in the fields of water and air pollution. However, in spite of repeated political commitments to implement precautionary action, the German public discourse overwhelmingly supports technological solutions to pollution control. These are now routinely seen as a sufficient policy response to the contemporary problem of achieving sustainable development through EPI (Beuermann and Burdick 1997). For instance, in its official submission to the 1992 Rio Summit the German government argued that its advanced pollution control policies were "to a large extent identical with the aims and demands of . . . Agenda 21" (cited in Beuermann and Burdick, 1997, 91).

  Having such an extensive and highly profitable clean technology industry (OECD, 1993, 207), it is hardly surprising that Germany adopted this particular interpretation of EPI. If anything, re-unification has served to dilute still further Germany's political appetite for the new agenda that is rapidly forming around the concept of sustainability. In issue areas such as nature conservation, biodiversity and land use, the positive sum relationship between growth and environment is less powerful. On these issues economic objectives in Germany have indeed ranked higher than environmental goals, especially in the new Eastern Lander. This was the gist of the OECD's recent review of German environmental policy, which praised continuing attempts to decouple growth from pollution flows but criticised the failure to integrate environmental sectoral and environmental decision-making (OECD, 1993, 205-215).

  Edda Mu­ller (1999) suggests that EPI has always been something of a one-way street in Germany in that: environmental policy makers have always been powerfully constrained by sectoral departments and the Chancellory from taking ambitious measures, whereas the transport, agricultural or economic departments have used normal inter-ministerial mechanisms to achieve their own goals. While environmental policy formulation has always had to take other sectoral policy priorities into account at a very early stage, environment only enters policy making in these other domains at a relatively stage when the die of policy is effectively already cast.

  The complicated federal structure of the German government has been another factor complicating EPI. Permanent Conferences involving state and federal governments are organised to iron out conflicts. However, Federal Ministers are not bound by firm institutional procedures that grant access to environmental representatives. Particularly in the fields of agricultural and the transport, Federal Ministers have found they can build a vertical alliance in an early stage of policy formulation, making it difficult for policy makers in subsequent stages of government decision making to inject a strong environmental dimension let alone stop an individual development take place. The environment ministry's second best response is therefore to wait until an invitation to meet is received from the sectoral ministry in question. Only then can the environmental implications of the draft policy be negotiated (Mu­ller 1999, 10). Other aspects of German environmental policy are similarly uncoordinated. For example pollution control policies and laws have traditionally addressed different environmental media (air, water, soil) separately, producing several important discontinuities. For instance, water pollution is mainly a La­nder responsibility whereas the federal government has a much bigger say over the running of air pollution.

  The impetus for more co-ordinated thinking gained ground in 1992 when an independent expert commission was set up by the federal ministry for the environment to prepare an Environmental Statute Book. The Statute Book, which is supposed to enter into force in 2000, aims to better integrate German legal structures (UBA, 1999). Following UNCED, an inter-ministerial working group assisted by the federal statistical office and the federal environment agency (UBA) was set up to test a suite of sustainability indicators. The results of this test phase have not yet been integrated into a systematic federal level process of SEA. In 1992 a Parliamentary Enquete Commission was established to give sustainability and EPI a stronger push. After a slow start the Commission was reinstated in 1995 to develop a national a national ecological action plan. In the Spring of 1998, Environment Minister Merkel presented a first draft, which focused on identifying targets for climate change, resource use, transport, land use and water quality with environmental indicators attached. The bringing together of sectoral targets, indicators and policy strategies is still at a relatively early stage of development, and should be viewed against the background of continuing efforts to harmonise basic legal structures.

  To summarise, EPI initiatives are slowly being introduced in Germany, but the main bottleneck remains the lack of effective horizontal co-ordination at the ministerial level. Judged against the EEA's criteria, Germany still lacks a systematic system of SEA (Lee and Hughes, 1996). Crucially, on many critical EPI-related issues the environment ministry's power of veto at the final decision stage is considerably weaker than the finance ministry's. The Federal and La­nder governments provide extensive subsidies to the German coal industry for economic, social and security reasons. Recently German environmentalists claimed that environmentally damaging subsidies totalled some euros 15.3 billion per annum in Germany (ENDS daily, 1999).

4.   Denmark

  Denmark has adopted a relatively decentralised approach to implementing EPI (see: Skou Anderson 1997, OECD 1999). Many sectoral ministries were initially asked to develop strategies for sustainable development, but no inter-ministerial mechanism exists to address sustainable development in general. The success of the whole initiative has been mixed. The impetus for the process often came from those wishing to water down existing environmental legislation (eg in the agricultural sector) but this had the unintended effect of opening up previously closed sectors to outside political pressure and scrutiny. However, Denmark now has many sectoral "action plans" rather than an all-embracing Dutch style NEPP. The plans themselves are often quite explicit with regard to the measures that have to be taken. For instance, the 1993 Traffic 2005 plan establishes the management of transport demand and the need to curb traffic growth as well as several emission targets as key policy objective. At the local level, the Danish Environmental Protection Agency has provided direct support to the 73 largest municipalities to establish and implement integrated transport and environment plans. In the energy sector, [10]the current Energy 21 Action Plan for sustainable development provides a range of economic and regulatory measures designed to shape energy supply and demand. The Agriculture sector is currently undergoing a similar set of reforms with longer terms goals such as the removal of sensitive land from agricultural production. Finally, major efforts are being made to green spatial planning. Even though most responsibilities lie with the municipalities and counties, the Ministry of Environment and Energy draws up a national SEA-style report on spatial planning for submission to Parliament which is designed to ensure the compatibility of development goals and environmental concerns.

  Strong inter-ministerial planning is compensated for by a system of SEA at the governmental planning level. Under a 1993 government circular (Circular 31) all bills presented to Parliament which have major environmental effects must include an assessment of their environmental impact. Sectoral ministries use guidelines from the Ministry of Environment and Energy when preparing them. In the Parliamentary year 1996/7, 77 per cent of all proposals were subject to an assessment. The whole system is currently under review. In principle, Circular 31 does apply to the national budget, but as in the UK, its overall impact remains questionable. An evaluation was made of the environmental impact of the 1998 budget, co-ordinated by the Ministry of Finance following guidelines agreed with the Ministry of Environment and Energy.

  On the whole, then, the Danes score relatively highly on the EEA's checklist. EPI has been given a further boost by the green tax reforms adopted in 1993 and now being applied across the full range of economic activities. The aim is to increase environmental taxes to 1.2 per cent of GDP by 2000. However, there is still scope for removing environmentally damaging subsidies which are extensively applied in the agriculture and forestry sectors.


  What does our comparison reveal about the prospects for achieving EPI in the EU? Interestingly but not surprisingly, states have chosen to follow different pathways that reflect their own cultural and political make-up. Crucially, each path or perspective has its shortcomings. Our analysis clearly reveals that even the most environmentally progressive Member States of the EU are still a long way short of achieving what might be considered "full" or strong EPI.

  The UK has chosen to try and green its traditionally strong and internally well co-ordinated systems of central government. Compared to other states, this amounts to a relatively top down approach to achieving EPI. However the performance to date demonstrates unequivocally that EPI requires more than just strong governmental structures and procedures. It also requires strong political backing from the highest levels of government in order to win over more reluctant departments. If the UK is experiencing difficulties then it is safe to assume that states with far weaker structures and coordinating mechanisms (most notably the cohesion Member States in the South of the EU 15 and of course the new applicants) have a veritable mountain to climb if they are to achieve anything remotely approaching strong EPI.

  The Dutch and German cases are instructive because they highlight the political and organisational difficulties of moving beyond pollution regulation to address the driving forces of environmental damage. EPI means asking tough questions about politically highly sensitive issues such as the subsidisation of economically and socially just activities. Interestingly, the Dutch have made the greatest progress in identifying "sector-specific targets, timetables . . . and indicators" of EPI, but the critical issue is just how concretely are they linked to the performance of sectoral policies in the short and in the long-term? In theory, sectoral policies should be re-steered if and when they undermine the pursuit of sustainability objectives, otherwise target setting risks becoming a purely symbolic exercise. The OECD's performance review of the Netherlands identifies short term coordination problems in sectors such as agriculture and transport. Only now are the Dutch beginning to realise that solving them may require more top-down (ie regulatory) intervention. For the moment the jury is still out on whether the Netherlands' decision to rely upon more consensual approaches to achieve long-term attitudinal changes will succeed in delivering a form of EPI that will endure.

  To conclude, EPI is a multi-level challenge requiring simultaneous and co-ordinated action at more than one level of governance in the EU. There is an obvious danger in expecting too much to emerge from the Cardiff process if states do not take appropriate measures to implement EPI at home. It is potentially inconsistent and counter-productive for states to set targets and timetables for different formations of the CoM, if the dynamics of policy making in the sectors concerned are determined mainly or wholly at the national level. It is, at least on subsidiary grounds, entirely appropriate for states to follow different pathways towards EPI at the national and sub-national level. However, in order to be strong and enduring EPI initiatives in the EU need to be coordinated both vertically and horizontally with one another.

  The EU is politically and institutionally very different to a state, but lessons learnt at one level can none the less be fruitfully applied at other levels. For example, Member States can learn important lessons from the Cardiff process in terms of how to encourage and engage sectoral agencies in a long-term process of review and target setting. Possibly the greatest lesson that EU policy makers can learn from the unfolding experience of EPI at the national level is the need for strong central coordination to iron out contradictions between sectoral policies. This may take the form of inter-ministerial coordination (UK), SEA at the ministerial level according to common guidelines (DK) to government-coordinated target group negotiations (NL). Federal Germany has had the most problems in devising an appropriate coordination process. However, absent a basic level of central coordination and support, all four case studies suggest that EPI will remain an "environmental" objective pursued solely by environmental agencies. In the EU the most appropriate candidates for the job of brigading sectoral agencies are probably the Commission President and the European Council. EPI needs the very highest level of political backing in the EU if it is to stand any chance of succeeding.


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  Skou Andersen, Mikael (1997) Denmark. In: M Ja­nicke and H Weidner, (eds) National Environmental Policies: A Comparative Study of Capacity Building. Springer Verlag: New York. Pp 157-174.

  UBA, (1999) Umweltbundesamt [].

  Van der Straaten, J and J Ugelow (1994) Environmental Policy in the Netherlands: Change and Effectiveness. In: M Wintle and R Reeve (eds) Rhetoric and Reality in Environmental Policy. Aldershot: Avebury. Pp 118-144.

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7   Lecturer, School of Environmental Sciences and Senior Research Fellow, CSERGE; University of East Anglia, Norwich, NR4 7TJ. Back

8   Lecturer, Senatsinstitut fu­r Politikwissenschaft, University of Salzburg, Rudolfskai 42, A-5020, Austria. Back

9   "Town and country planning" and energy supply issues are two of three policy areas which were exempted from qualified majority voting by the 1993 Maastricht Treaty, a decision subsequently confirmed by the 1999 Amsterdam Treaty. For details see Wilkinson (1992, 228). Back

10   Denmark is the only OECD country that has a single ministry dealing with environmental and energy matters. Back

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