No C 281/20 Official  Journal  of the  European  Communities 27. 11.76 
doubt  that  the  changes  the Community  makes  each 
year to its  own  system  will  make  comparisons 
difficult  for several  years  to come.  It is thus  possible 
that unaligned  systems  will  continue  indefinitely. 
8. The  Commission's  proposals  for 1977  come  at a 
time  when  the  Community  is getting  ready  to 
negotiate  multilateral  tariff  concessions  in the GATT 
round.  It is proposed  that  the  tropical  products 
concession  which  is being  offered  in the  GATT 
negotiations  should  be applied  unilaterally  under  the 
Generalized  Preferences  Scheme  for 1 January  1977. 
The Committee  wonders  whether  going  ahead 
unilaterally  with  such  concessions  might  not  reduce 
the Community's  chances  of securing  worthwhile 
reciprocal  concessions  from  certain  developing 
countries  that  have  already  reached  a certain  level  of 
industrialization. 
9. The  Committee  is pleased  that  the Commission 
has taken  some  action  on  a point  which  the 
Committee  made  in its 1975  Opinion,  namely  that  it 
is becoming  essential  to  differentiate  between 
beneficiaries  of the Scheme  according  to their  degree 
of competitiveness,  so as to reserve  the benefits  of the 
Scheme  to the greatest  possible  extent  for the poorer 
countries. 
10. The  Committee  regrets,  however,  that  the 
Commission  has  restricted  the  application  of this 
principle.  The  Committee  wants  the principle  to be extended  as quickly  as possible  to all groups  of 
products  covered  by  the  Generalized  Preferences 
Scheme.  The  Commission  should  not  hesitate  to 
withdraw  generalized  preferences  from  those 
developing  countries  which  have  attained  a certain 
level  of competitiveness. 
11. More  generally,  the Committee  regrets  that  the 
Commission  has  so far  failed  to give  a practical 
demonstration  of the intention  — which  it announced 
particularly  in the Generalized  Preferences  Scheme  — 
of making  the  Scheme,  though  it was  to remain 
autonomous,  operate  within  an  economic  and 
commercial  system  governed  by international  rules 
and obligations  involving  rights  and  duties  both  for 
the donor  and  beneficiary  countries.  Already  in its 
opinion  of September  1975  the Committee  considered 
it very  important  that  countries  abided  by such  rules 
and obligations,  with  particular  reference  to 
international  trade  (dumping,  subsidies,  disregard  for 
standards  of wages  and  conditions  for labour,  etc.). 
(Adherence  to these  rules  should  first  be required  of 
beneficiaries  that  have  already  reached  a certain  level 
of industrial  development). 
Done  at Brussels,  29 September  1976. 
The Chairman 
of the  Economic  and  Social  Committee 
Henri  CANONGE 
Opinion  on the continuation  and  implementation  of a European  Community  policy  and 
action  programme  on the environment  (draft  resolution  of the Council,  presented  by the 
Commission) 
The text  referred  to the Committee  has not been  published  in the Official  Journal  of the 
European  Communities. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 6 April  1976,  the Council  referred  the abovementioned  subject  to the Economic  and 
Social  Committee  in accordance  with  Article  198  of the  Treaty  establishing  the 
European  Economic  Community. 
27. 11. 76 Official  Journal  of the  European  Communities No C 281/21 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  prepared  its opinion  on the above  matter  at its 
191st  plenary  session,  held  in Brussels  on 29 and  30 September  1976. 
The full  text  of the opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  Treaty  establishing  the  Euro-
pean  Economic  Community,  and  in  particular 
Article  198  thereof, 
Having  regard  to the  request  made  by the  Council 
of the  European  Communities  on 6 April  1976  for 
an opinion, 
Having  regard  to the  decision  taken  by its Bureau 
on 30 March  1976  in anticipation  of the consultation, 
instructing  the Section  for Protection  of the Environ-
ment,  Public  Health  and  Consumer  Affairs  to draw 
up an opinion  and  a report  on the matter, 
Having  regard  to the  opinion  issued  by the Section 
for Protection  of the Environment,  Public  Health  and 
Consumer  Affairs  at its meeting  on  16  Septem-
ber 1976, 
Having  regard  to the  report  submitted  by the Rap-
porteur,  Mr Merli  Brandini, 
Having  regard  to the discussions  at its 141st  plenary 
session,  held  on 29 and  30 September  1976  (meeting 
of 29 September), 
Whereas  the second  programme  will  help  to clarify 
the scope  of the objectives  of the environment  policy 
and the  account  which  must  be taken  of the  policy 
in the choices  the Community  makes; 
Whereas  the  said  programme  will  only  be accepted 
if efforts  are intensified  to educate  the public  about 
the matters  with  which  the Programme  is concerned; 
Whereas  the programme  also  aims  to develop  suitable 
procedures  of environmental  impact  assessment  to 
predict  and  possibly  measure  the effects  of proposed 
decisions  and  measures  likely  to have  an influence 
on the environment; 
Whereas  the  resources  that  are  available  make  it 
necessary  to choose  carefully  the  content  of the 
proposed  measures  and  to make  a proper  assessment 
of the positive  contribution  of such  measures  to the 
national  product, HAS  ADOPTED  THE  FOLLOWING  OPINION 
with  no dissenting  votes  and  4 abstentions: 
The Committee  approves  the Commission  proposal, 
subject  to the comments  set out below: 
1. Preliminary  comments 
1.1. On  22 November  1973,  the Council  adopted 
the first  programme  of action  of the European  Com-
munities  on the  environment.  The  programme  set 
out the  Community's  plans  for  legislation  to safe-
guard  the environment  (with  the emphasis  on preven-
tion)  and  to improve  the quality  of life. 
1.2. The  Committee  expressed  its views  on the 
general  guidelines  and  priorities  of the programme  in 
its study  on the first  Commission  communication  on 
Community  environmental  policy  and  in its opinion 
on the  draft  Council  resolution  on a Community 
environmental  programme  (1). 
1.3. The  Commission  agreed  to  consult  the 
Committee  on the  various  proposals  it submitted 
under  the programme.  The  Committee  has  discussed 
about  40 draft  Regulations,  Directives  and  Decisions 
as a result.  In each  instance,  the  Committee  has 
demonstrated  that  the  various  economic  and  social 
groups  it represents  are keen  on radically  improving 
the working  and  living  conditions  of Community 
residents. 
1.4. Now,  three  years  after  the Council  Decision, 
the Commission  is seeking  to ensure  that  the 
measures  taken  under  the first  action  programme  are 
continued  and  have  more  of  an  impact  on 
Community  policy  decisions.  It also  proposes  to give 
a more  tangible  follow-up  to certain  principles  set 
out in the  first  action  programme.  This  would 
i 
(!) OJ  No C 88, 22. 10. 1973. 
No C 281/22 Official  Journal  of the European  Communities 27.11.  76 
include  adoption  of preventive  measures  long-term 
common  objectives,  coordination  of  national 
programmes,  approximation  of municipal  law  and 
the alignment  of international  conventions  with  each 
other  and  with  the material  Community  law. 
1.5. In  the  new  action  programme,  the 
Commission  puts  particular  stress  on:  (i) action  to 
reduce  the  waste  of all  kinds  which  invariably 
accompanies  industrial  production,  and  (ii) the need 
for closer  contacts  with  Third  World  countries  in this 
field  as part  of a fully-fledged  cooperation  policy. — prevention  of damage  to the environment  where 
this will  obviate  greater  expenditure  at a future 
date, 
— the  proposals  on  environmental  impact 
assessment  to  provide  the  greatest  possible 
amount  of data  (positive,  negative,  short-term, 
medium-term  and  on  possible  alternatives)  on 
which  to base  decisions, 
— the  development  of a mapping  system  to be used 
as a basis  for  decision-making  in land-use 
planning. 
1.6. The  Committee  supp'orts  the  Commission  in 
its endeavour  to take  account  of the  new  economic 
trends  which  are likely  to result  from  the continuing 
economic  crises  in the Community,  and  the world  as 
a whole. 
1.7. The  Committee  considers  that  Member  States 
environment  policy  measures  need  to be coordinated 
as well  as those  of the  Commission.  Otherwise  the 
policy  could  be  crippled  because  of divergent 
measures  being  taken.  To  keep  the  initiative  and 
develop  a comprehensive  policy,  the Committee  urges 
the Commission  to adopt  an increasingly  forceful 
approach  in its administration  of the  information 
agreement. 
1.8* The  Commission  emphasizes  that  nowadays 
industrial  development  is facing  obstacles:  the 
shortage  of natural  resources,  and  the rejection  of the 
consumer  society  ethic  by growing  sections  of the 
population.  But  the answers  the Commission  suggests 
— harmonious  development  of the  economy  and 
linking  the  Community's  environment  policy  to 
economic  and  social  development  —  are  not 
sufficient. 1.11.  The  Committee  considers  that  these 
instruments  will  help  resolve,  in the  best  possible 
manner,  the  dilemma  of assigning  priorities  when 
resources  are limited.  It also  considers  that  they  will 
serve  to highlight  the  progress  made  and  broaden 
public  support  for implementation  of the programme 
on an ever-increasing  scale. 
1.12.  In  this  connection,  the  Committee 
recommends  the  Commission  to make  sure  that 
economic  interests  and  social  groups  are  as fully 
represented  as possible  at the  Conference  on urban 
problems. 
2. General  comments 
2.1. The  Committee  welcomes  the  Commission's 
proposals  for  the  next  stage  of the  Community's 
environmental  policy,  but  deplores  the  slow  start 
that has  been  made.  To  date,  the  Council  has 
adopted  22 Directives,  Decisions,  recommendations 
and resolutions.  But  a greater  number  of proposals 
for Community  legislation  are  still  before  the 
Council. 
1.9. It  is difficult,  of course,  to suggest  more  than 
the Commission  is suggesting,  namely  measures  to 
cure the most  obvious  ills.  A more  positive  approach 
to environment  policy  — stating  the kind  of society 
we want  — will  be difficult  as long  as we continue  to 
see the environment  in negative  terms  (the  degree  of 
air and  water  pollution,  shortage  of time,  etc.). 2.2. The  time  the Member  States  have  been  given 
to act  in the  instruments  that  have  already  been 
adopted  means  that  it will  probably  be 1977  before 
we can  see what  legislation  the Member  States  have 
passed  to implement  the  first  action  programme. 
Only  after  this  will  it be possible  to know  and  assess 
the results  of the decisions  taken. 
1.10.  Nevertheless,  the  Committee  endorses  the 
principles  and  objectives  of the  proposed  action 
programme,  which  are  repeated  from  the  first 
programme.  It attaches  particular  importance  to the 
following: 2.3. The  results  of past  measures  are  important 
when  deciding  what  should  be the priorities  in future 
action,  because  the  study  of results  shows  how 
effective  particular  methods  have  been  and  indicates 
the best  ways  of matching  available  resources  to the 
27. 11. 76 Official  Journal  of the European  Communities No C 281/23 
ends  in view.  A table  of priorities,  with  a suitable 
timetable  for carrying  them  out,  needs  to be drawn 
up, to enable  more  control  to be exercised  over  the 
use of the limited  resources  available  and  ensure  that 
the Programme  is carried  out realistically. 
2.4. The  Committee  subscribes  to the  view  that 
effective  control  of pollution  and  nuisances  and 
action  to improve  the quality  of life are essential  for a 
harmonious  development  of economic  activity.  To 
appreciate  better  the  importance  of environment 
policy  for  economic  and  social  progress,  the 
traditional  economic  calculation  methods  should  be 
revised. 
3. Specific  comments 
3.1. Cost  analysis  of environment  protection 
3.1.1.  It  is not  enough  to base  the calculation  of 
economic  growth  and  gross  national  product  solely 
on the increase  in material  wealth.  Such  an approach 
leads  operators  in the public  and  private  spheres  to 
get things  out  of  perspective.  The  traditional 
assumption  that  some  resources,  such  as the air and 
water,  are  unlimited  and  may  be consumed  or 
degraded  at will,  is proving  to be  ever  more 
fallacious. 
3.1.2.  A  more  accurate  calculation  would  set 
against  the  increases  in output  the  destruction  and 
degradation  of natural  resources  (air,  water,  soil)  that 
has taken  place  in order  to produce  these  increases 
and the  outlay  which  is necessary  in order  to 
regenerate  these  resources. 
3.1.3.  Calculation  of the  cost  of environment 
measures  should  always  include  the cost  of failure  to 
act, i.e.,  the  extra  costs  which  will  arise  from  the 
deterioration  of the  environment  and  health  if 
nothing  is done.  Calculation  of the  benefits  should 
include  not only  quantifiable  elements,  but also  take 
into consideration  the qualitative  improvement  in the 
environment  and  in living  conditions  generally. 
Improvements  in human  health,  the  time  spent  in 
recreation  and  housework  should  thus  be credited  to 
the gross  national  product,  whilst  damage  to the 
environment  should  be debited  from  it. 
3.1.4.  The  problem  is to introduce  qualitative 
elements  into  the calculation  of economic  growth,  in 
other  words  the  traditional  method  of calculation 
must  be supplemented  with  qualitative  and  social 
indicators. 3.1.5.  One  of the  tasks  which  the  Commission 
should  undertake  is to continue  the studies  that  are 
going  on at international  level  into  a cost/benefit 
analysis  of  environment  policy  taking  into 
consideration  the  qualitative  elements.  Obviously, 
there  are many  snags  to be overcome  before  common 
criteria  can  be  established  for  evaluating  and 
measuring  such  qualitative  elements.  But,  it is 
nonetheless  necessary  to work  out  a method  of 
calculating  national  economic  performance  in which 
qualitative  objectives  are included,  and  the notions  of 
cost and  benefit  are modified  to take  account  of such 
qualitative  objectives. 
3.2. Prevention  and  reduction  of  pollution  and 
nuisances 
3.2.1.  Such  unresolved  difficulties  often  prompt 
the question  whether  environmental  policy  objectives 
conflict  with  other  economic  and  social  goals. 
3.2.2.  Certainly,  environmental  goals  demand 
compromises  of the conventional  goals,  but they  are 
not at odds  with  the conventional  goals. 
3.2.3.  Even  in terms  of conventional  accounting, 
action  to prevent  pollution  and  damage  to the 
environment  has  quantitative  effects  in that  it alters 
the make-up  of income  and  the pattern  of investment 
(e.g.,  air and  water  purifying  plants,  etc.). 
3.2.4.  Such  forms  of income  alter  the  qualitative 
make-up  of the  national  income  and  have  possible 
effects  on consumption  patterns.  For  these  reasons, 
the costs  and  benefits  of environmental  action,  and 
its implications  as regards  accounting,  must  be spelt 
out clearly.  In the final  analysis,  this  is essential  if the 
programmes  are to receive  public  support  and  if the 
public  is to understand  and  accept  the  resultant 
changes  in the structure  of its income. 
3.3. Education  of the public 
3.3.1.  The  Committee  welcomes  the attention  the 
Commission  intends  to give  to education  of the 
public  about  environment  policy.  In the Committee's 
view,  an education  programme  should  concentrate 
on the following: 
— involvement  of  the  traditional  centres  of 
education,  the home  and  school,  in developing  an 
awareness  of  environmental  problems,  and 
instilling  the  lifelong  habit  of respect  for  the 
environment,  in the younger  generation, 
No C 281/24 Official  Journal  of the European  Communities 27.11.  76 
— involvement  of all the mass  media  (press,  radio 
and television)  in informing  the  public  of the 
results  of environment  measures.  Methods  of 
presentation  should  be developed  (summaries  of 
the measures,  their  cost  and  benefits  and  their 
effects  on the state  of the air,  water  and  soil  and 
on the  wastage  of resources)  which  give  the 
information  in a more  easily  digestible  form  and 
make  the  public  take  an active  interest.  The 
Commission  should  promote  the development  of 
appropriate  programmes  in direct  collaboration 
with  the  national  organizations  responsible  for 
the mass  media, 
— programmes  directed  at specific  sections  of the 
population,  e.g.,  motorists,  farmers,  tourists, 
consumers  of particular  polluting  products.  These 
could  be  developed  with  the  help  of  the 
advertizing  campaigns  for particular  products, 
— introduction  of general  environment  courses  and 
special  courses  for environmental  technicians  and 
other  jobs  connected  with  the  environment  in 
upper  secondary  education  syllabuses. 
3.3.2.  The  Committee  urges  the  Commission  to 
arrange  programmes  on the lines  indicated  above  in 
addition  to those  it is already  pursuing.  All  these 
measures  will  allow  us to focus  better  the efforts  of 
our society  and  to assess  the results  of those  efforts. 
3.4. Community  action  against  water  pollution 
3.4.1.  The  Committee  has  supported  the measures 
that have  been  taken  to combat  pollution  of rivers, 
lakes  and  the sea.  It has drawn  attention,  however,  to 
the need  to evaluate  the  economic  and  social 
repercussions  on industry  located  near  stretches  of 
water  subject  to the  new  EEC  provisions,  so as to 
make  sure  that  the standards  are feasible  and  can  be 
met in the  time  allowed.  It therefore  thought  that 
transitional  periods  should  be allowed  before  full 
introduction  of the  measures,  and  also  urged  that 
research  be done  into  water  pollution,  to ensure 
consistency  between  the environmental  measures  and 
the economic  and  social  aspects. 
3.4.2.  In  the case  of the measures  to reduce  water 
pollution  from  wood  pulp  mills  and  the  titanium 
dioxide  industry,  the  Committee  has  stated  that  if 
these  created  economic  or social  difficulties  for these industries  it was  better  to overcome  this  problem  by 
providing  specific  aids  from  public  funds,  rather  than 
by granting  exemptions  from  the Directives.  It also 
advocated  a Community  fund  for such  aids  so that 
they were  administered  on a Community  basis. 
3.4.3.  The  Committee  is  pleased  that  the 
Commission  wants  to continue  the  Community's 
action  against  water  pollution,  and  that  this  is given 
priority  in the  new  action  programme.  But  the 
Committee  is concerned  about  the  protection  of 
aquatic  fauna,  which  are  being  reduced  by  the 
large-scale  of river  sand. 
3.4.4.  The  Committee  recommends  that  the 
Commission  study  the effects  of sand  extraction  on 
the reproduction  rates  of the most  threatened  species 
of aquatic  fauna. 
3.4.5.  On  the  protection  of water  resources  the 
Committee  suggests  that  the  Commission  propose 
common  methods  for  measuring,  checking  and 
assessing  water  resources  in relation  to the trend  in 
demand  for water. 
3.4.6.  Lastly,  the  Committee  recognizes  that  it is 
important  that  international  conventions  on marine 
pollution  be  applied  uniformly  throughout  the 
Community,  and  become  incorporated  in Community 
law where  the  Community  has  concluded  such 
conventions  as a single  party  under  international  law. 
In the  opinions  it has  issued  on this  subject,  the 
Committee  has also  urged  the Commission  to pursue 
its work  on a number  of matters  not  covered  by the 
Conventions. 
3.5. Air and  soil  pollution 
3.5.1.  The  Committee  has  commented  on  the 
serious  problems  caused  by air and  soil  pollution  in 
earlier  opinions.  It has welcomed  measures  restricting 
the use  of numerous  dangerous  substances,  for 
instance  polychlorinated  biphenyls  (PCBs)  and 
pesticides,  in view  of the serious  damage  they  cause 
to the environment.  It has also  endorsed  the proposal 
to set up a system  for gathering  from  the Member 
States,  and  circulating,  information  on atmospheric 
pollution  caused  by sulphur  compounds  and  airborne 
particulates.  The  Committee  has  also  raised  the 
question  of pollution  at the workplace,  which  usually 
involves  contamination  which  gradually  spreads  to 
the outside  environment. 
27.11.  76 Official  Journal  of the European  Communities No C 281/25 
3.5.2.  Although  the  Committee  does  not  dispute 
the contribution  that  agriculture  makes  towards 
nature  conservation,  it  stresses  that  the 
ever-increasing  use  in agriculture  of pesticides, 
chemical  fertilizers  and  plant-health  products  in 
general  is apt  to have  many  serious  environmental 
side-effects  and  direct  repercussions  on  human 
health.  This  probably  also  applies  to the large-scale 
use of antibiotics  in large  rearing  units. 
3.5.3.  Some  such  substances  are  only  partly 
eliminated  and  remain  in the  various  stages  of the 
food  chain. 
3.5.4.  The  Committee  therefore  supports  all the 
measures  that  the  Commission  plans  to take  to 
eliminate  the above  dangers.  It also  recommends  that 
measures  be prepared  as soon  as possible  laying 
down  stock-rearing  methods  that  are not detrimental 
to the environment. 
3.5.5.  With  regard  to air pollution,  the Committee 
believes  that  the proposed  objectives  can be achieved 
by laying  down  both  air  quality  targets  and  air 
quality  standards.  Such  Community  standards  are 
essential  for protection  of the environment,  but  they 
do not  mean  that  all the  Member  States  must  take 
the same  measures  to achieve  them.  However,  the 
various  national  measures  must  be aligned  at least  to 
the extent  that  they  accord  with  the  jointly  agreed 
objectives  of the policy. 
3.6. Community  action  in  relation  to  energy 
production 
3.6.1.  Public  fears  and  reaction  to proposals  for 
the building  of new  power  stations  vary  in intensity 
depending  on whether  the power  station  is nuclear  or 
of the conventional  thermal  type. 
3.6.2.  Such  reactions,  which  may  be attributable  to 
insufficient  or partially  incorrect  information,  delay 
the necessary  expansion  of energy  production. 
3.6.3.  A  lot  of work  is being  done  in the 
Community's  energy  and  environmental  research 
programmes  on  how  to prevent  or reduce  the 
problems  associated  with  new  power  station  building. 
3.6.4.  All  the  same,  the  hostile  reaction  will 
continue  to be partly  justified  until  such  time  as there 
is an adequate  programme  to inform  the  public  in 
detail  and  in terms  that  it can  understand  about  the real risks  and  problems,  the  measures  taken  to 
prevent  or reduce  them,  and  the  results  achieved  by 
the measures  so far. 
3.6.5.  One  of the  major  problems  is the siting  of 
power  stations,  and  more  particularly  the clustering 
of power  stations  in small  areas.  There  should  be 
close  contact  between  Member  States  over  the siting 
of power  stations,  particularly  in border  areas.  This 
contact  should  take  the  form  of exchanges  of 
information  (on  construction  projects  and  on the 
criteria  used  to determine  whether  and  where  to build 
power  stations)  with  a view  to protecting  the 
environment. 
3.6.6.  A  Community  Directive  establishing 
common  criteria  for the siting  of future  power  stations 
would  be highly  desirable.  With  such  criteria  and  a 
classification  of land  according  to ecological  features, 
power  stations  could  be  sited  better  and  the 
concentration  of power  stations,  particularly  in 
frontier  areas,  could  be avoided. 
3.7. Community  action  on particular  products  and 
the drive  against  waste 
3.7.1.  The  Committee  has  repeatedly  stressed  the 
need  to encourage  more  and  more  the manufacturers 
of particular  products  to stop  using  materials  and 
substances  that  endanger  human  health  or present 
major  waste  disposal  problems.  In parallel  and  with 
the same  end  in view,  users  and  consumers  must  be 
recommended  to cut down  their  use of such  materials 
and substances  to the minimum. 
3.7.2.  The  Committee  has  advocated  total 
approximation  of national  provisions  in such  cases, 
since  this  type  of approximation  affords  the  best 
protection  for the consumer  and  does  not disturb  the 
operation  of the common  market. 
3.7.3.  The  Committee  has also  called  for a massive 
campaign  at all levels  to educate  the public  about  the 
meaning  of information  given  on product  labels, 
particularly  in the  case  of toxic  substances,  so that 
people  know  the dangers  and  take  the recommended 
precautions.  All  these  Community  measures  should 
contain  provisions  on  adequate  labelling  so that 
consumers  know  what  they  are buying. 
3.7.4.  On  the  drive  against  waste,  the Committee 
supports  the  Commission  recommendations, 
particularly  the  proposed  overall  policy  on waste 
No C 281/26 Official  Journal  of the European  Communities 27. 11. 76 
recovery.  To help  the  success  of this  policy,  special 
prizes  or awards  could  be offered  for  deserving 
experiments  in this  field.  In this  connection,  all 
measures  designed  to set  up  scrap  markets  and 
coordinate  their  activities  at EEC  level  should  be 
encouraged. 
3.8. Environmental  impact  assessment 
3.8.1.  The  Committee  approves  the Commission's 
proposal  that  the Community  develop  a procedure  of 
environmental  impact  assessment.  Since  some 
Member  States  have  already  introduced  environmen-
tal impact  assessment,  or are  studying  the question, 
the Committee  considers  it extremely  important  that 
the Community's  work  in this  field  should  include  an 
alignment  of existing  procedures  and  should  build  on 
the experience  that  has been  gained  so far. 
3.8.2.  The  purpose  of such  a procedure  should 
initially  be to predict  and  possibly  measure  the effects 
of proposed  decisions  or measures  which  are thought 
likely  to have  an influence  on the environment.  This 
will make  it possible  to prevent  or  minimize 
pollution  or other  damage  to the environment  from 
the proposed  measures. 
3.8.3.  The  size  of this  goal  inevitably  raises 
problems  of definition,  to which  precise  and  pertinent 
answers  must  be found.  Also,  the pursuit  of the goal 
must  not be allowed  to delay  or impede  the taking  of 
decisions  or measures  which  are  necessary  for 
beneficial  development. 
3.8.4.  In  such  a procedure,  one  of the  following 
verdicts  could  be passed  on the  projected  measure 
without,  however,  delaying  the project: 
— the  scheme  could  be approved,  or 
— the  scheme  could  be  rejected,  either  with 
suggestion  of alternatives  or the request  that  the 
parties  themselves  come  up  with  alternative 
proposals,  or 
— the parties  could  be asked  to modify  their  scheme 
to accord  with  environmental  requirements. 
3.8.5.  The  recommendations  made  under  such  a 
procedure  should  not  defeat  the  object  of the 
proposed  schemes. 
3.8.6.  A  procedure  of this  type  should  be based  on 
the following  principles: — determination  of objective  criteria  for the degree 
of environmental  impact  a project  must  be 
expected  to  have  in  order  to  require  an 
investigation  of its impact  and  an opinion  by the 
relevant  authority, 
— obligatory  assessment  of  the  environmental 
implications  of decisions  or schemes  proposed  by 
national  or local  public  authorities, 
— obligatory  assessment  of  the  environmental 
implications  of decisions  or schemes  proposed  by 
private  persons  where  such  projects  are subject  to 
official  planning  permission, 
— vetting  of all other  schemes  not  falling  into  the 
above  two  categories  which  might  have  an effect 
on the environment, 
— naming  of the public  authorities  which  are to be 
responsible  for  assessing  the  environmental 
impact  of projects  on the  basis  of the  initial 
information  supplied  by the  promoters  and  for 
issuing  opinions  on the projects, 
— such  opinions  must  either  approve  the  project 
unreservedly,  or reject  it, suggesting  modifications 
or alternatives  or requiring  the parties  themselves 
to modify  the project  or seek  alternatives, 
— the  opinions  could,  in addition,  contain  any  other 
relevant  comments  by  the  authorities  on  the 
projects,  especially  with  regard  to the  more 
long-term  effects  and  the  extent  to which  the 
effects  of the project  would  be reversible, 
— time  limits  for the submission  of opinions, 
— inclusion  of  the  opinions  procedure  in the 
normal  decision-making  processes  of  the 
institutions  or  other  agencies  undertaking 
projects. 
3.9. International  economic  competition 
3.9.1.  Studies  carried  out  by both  national  and 
international  organizations  (such  as the  OECD)  all 
indicate  that  the  additional  costs  involved  in good 
environmental  management  are not prohibitive.  But it 
may seriously  lower  the EEC's  or a Member  State's 
competitiveness  if it acts  on these  matters  alone  (c.f. 
titanium  dioxide,  pollution  from  woodpulp  mills). 
27.11.  76 Official  Journal  of the European  Communities No C 281/27 
3.9.2.  This  applies  not  only  to  anti-pollution 
regulations,  but  also  to  introduction  of  long 
procedures  before  the  marketing  of products,  and  to 
forcing  industries  to provide  detailed  information  on 
energy  and  raw-material  consumption,  investment, 
production  and  pollution. 
3.9.3.  The  Committee  calls  upon  the  Commission 
to go into  this  matter  more  thoroughly. 
3.10.  The  Committee  is disappointed  that  so few 
of the  positive  suggestions  made  in the  discussion document  on  the  second  programme  are  actually 
proposed  as concrete  measures  in the  programme. 
This  is the  case,  for  example,  with  the  suggestion 
about  action  on the  composition  and  durability  of 
products  (Section  3). 
Done  at Brussels,  30 September  1976. 
The Chairman 
of the  Economic  and  Social  Committee 
Henri  CANONGE 
ANNEX 
to the opinion  of the Economic  and  Social  Committee 
I. The  following  amendments  were  rejected: 
Paragraph  3.3.1 
Insert  a first  indent  reading  as follows: 
'— systematic  checking  of what  people  look  for in their  environment,  so as to find  out 
exactly  what  their  environmental  priorities  are,  and  how  these  priorities  change 
with the passage  of time.' 
Reason 
The public  must  be involved  in environmental  matters,  since  they  are  the  ones  most 
affected  and their  wishes  and traditions  should  be taken  into  account. 
Voting 
For: 3, against:  9, abstentions:  8. 
Paragraph  3.5.5 
Delete  the second  sentence,  and 'However'  in the third  sentence. 
Reason 
The idea  expressed  here  seems  to be contrary  to the EEC's  aim  of alignment. 
Voting 
For: 1, against:  17, abstentions:  11. 
Delete  paragraph  3.6.2  and amend  paragraph  3.6.4  to read: 
'We must  face  the fact  that  the  various  stages  of the  nuclear  fuel  cycle  can  pose 
hazards,  which  need  to be evaluated.  An objective  evaluation  of the risks  to health 
No C 281/28 Official  Journal  of the European  Communities 27.11.  76 
should  be carried  out,  and  an adequate  programme  should  be launched  to inform  the 
public.  Apart  from  this,  the Committee  would  also  refer  to the opinion  which  it is 
shortly  to issue  on this  subject.' 
Voting 
For: 5, against:  14, abstentions  8. 
Paragraph  3.8.6 
Make  the following  text the first  indent: 
'— identification  of the environmental  aspects  to be taken  into  consideration.' 
Reason 
This  consideration  needs  to be inserted  since  it forms  the starting  point  for  a better 
understanding  of the proposed  procedure,  a procedure  based  on the other  factors. 
Voting 
For: 3, against:  13, abstentions:  11. 
II. The  following  parts  of the opinion  of the section  for protection  of the environment,  public 
health  and  consumer  affairs  were  amended: 
Paragraph  1.4 
'long-term  common  objectives,  coordination  of national  programmes  and alignment  of 
national  policies.' 
Voting  on the amendment 
Adopted  unanimously. 
Paragraph  3.4.6 
'The Economic  and Social  Committee  is at present  considering  a series  of proposals  for 
Community  legislation  concerning  water  pollution.  As the  Section  will  have  to 
comment  on these  proposals  elsewhere,  it will  not discusis  any specific  issues  here,  but 
merely  stress  the need  for faster  and faster  progress  in this area.' 
Voting  on the amendment 
Adopted  unanimously. 
Paragraph  3.5.2 
'Although  the Section  does  not dispute  the contribution  that  agriculture  makes  towards 
nature  conservation,  it stresses  that  the ever-increasing  use in agriculture  of pesticides, 
chemical  fertilizers  and  plant-health  products  in general  is apt to have  many  serious 
environmental  side-effects  and direct  repercussions  on human  health.' 
Voting  on the amendment 
Adopted  unanimously. 
27. 11. 76 Official  Journal  of the  European  Communities No C 281/29 
Paragraph  3.5.3 
'Such  substances  are only  partially  eliminated  and  remain  in the various  stages  of the 
food  chain.' 
Voting  on the amendment 
Adopted  unanimously. 
Paragraphs  3.9 and  3.10  are additions  to the Section's  opinion. 
Voting  on the amendment 
Adopted  unanimously.