Memorandum submitted by Dr Andrew Jordan
and Dr Andrea Lenschow|
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
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
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).
EPI AS A
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 EUEuropean, national, regional and
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
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-makingie the key decision-points where EPI has
to bite if it is to be effectiveis 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
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
activitiesthe setting of a national budget (HC 326, Session
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 alternativepolicy 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
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.
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
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).
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, 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
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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7 Lecturer, School of Environmental Sciences and Senior
Research Fellow, CSERGE; University of East Anglia, Norwich, NR4
7TJ. A.Jordan@uea.ac.uk Back
Lecturer, Senatsinstitut fur Politikwissenschaft, University
of Salzburg, Rudolfskai 42, A-5020, Austria. Andrea.Lenschow@sbg.ac.at Back
"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
Denmark is the only OECD country that has a single ministry dealing
with environmental and energy matters. Back