EUROPEAN COMMISSION 
Brussels, 12.12.2011 
SEC(2011) 1542 final 
Volume 1 of 2 
  
COMMISSION STAFF WORKING PAPER 
IMPACT ASSESSMENT 
Accompanying the document 
Proposal for a Regulation  
on the establishment of a Programme for the Environment and Climate Action (LIFE) 
{COM(2011) 874 final} 
{SEC(2011) 1541 final} {SEC(2011) 1543 final} 
 
 
1 Disclaimer : This impact assessment commits only the Commission's services involved in its 
preparation and does not prejudg e the final form of any decision to be taken by the 
Commission. 
 
 
2 TABLE OF CONTENT 
1. Procedural Issues and Consulta tion of Interested Parties .........................................................3 
1.1. Procedural issues......................................................................................................... ..............3 
1.2. External expertise and consu ltation of interested parties..........................................................3 
1.3. Opinion of the Impact Assessment Board (IAB):.....................................................................4 
2. Current Stucture and Performance of LIFE and Problem Definition .......................................5 
2.1. Current structure and design of the LIFE Programme..............................................................5 
2.2. Problem definition ........................................................................................................ ............6 
2.2.1. Environmental and climate problems, their main drivers and underlying causes.....................6 
2.2.2. Performance of the LIFE Programme and pr oblems linked to its design and structure ...........9 
2.3. How will the problem evolve?.............................................................................................. ..18 
2.4. Who is affected and how?.................................................................................................. .....20 
2.5. The EU's right to act and justification................................................................................... ..20 
2.5.1. The EU's right to act on en vironment and climate policies ....................................................20 
2.5.2. Necessity of EU action.................................................................................................. ..........20 
2.5.3. EU added value of EU action of a specific financial instrument for Environment and Climate 
Action......................................................................................................................... .............21 
2.5.4. Proportionality of the EU action ........................................................................................ .....22 
3. Objectives .................................................................................................................. .............22 
3.1. Objectives related to the content of the LIFE Programme......................................................22 
3.2. Objectives related to the design of the Programme ................................................................22 3.3. Consistency with existing EU polic ies and strategies such as Europe 2020...........................23 
4. Policy Options.............................................................................................................. ...........26 
4.1. Description of the baseline as defined by the MFF Communication......................................26 
4.2. Development of the policy options ......................................................................................... 28 
4.3. Which options have been discarded and why? .......................................................................28 
4.4. Description of the options retained for further assessment.....................................................31 
5. Analysis of Impacts......................................................................................................... ........40 
5.1. Introductory remarks about impacts of the current LIFE+ Regulation and the Baseline 
derived from the MFF Communication ..................................................................................40 
5.2. Analysis of the options................................................................................................... .........43 
6. Comparing the Options....................................................................................................... ....59 
6.1. Summary of the assessments ................................................................................................ ..59 
6.2. Comparisons ............................................................................................................... ............66 
6.3. Preferred option .......................................................................................................... ............66 
7. Monitoring and Evaluation ................................................................................................... ..67 
8. Annexes ..................................................................................................................... .............69 
 
3 Introduction 
This impact assessment assesses the potential economic , social  and environmental  impacts 
of different options for managing a  financial instrument for the Environment and Climate 
Action (LIFE ) for the period 2014-2020 (successor to the LIFE+ Programme).  
The EU budget reform focuses on the creation of  European added-value and the achievement 
of the key priorities outlined in the Europe  2020 Strategy, which sets the framework for 
smart, sustainable and inclus ive growth. Investments in environmental protection, climate 
change mitigation and adaptation,  and resource efficiency  are investments in the 
modernisation of our economies and societie s that contribute dire ctly to two EU2020 
flagships, namely "the Innovation Union" and "R esource Efficiency", and the headline target 
for climate and energy.  
In the Communication of 29 June 2011, the Co mmission adopted its position for the Union's 
finances for the next Mu ltiannual Financial Framework (hereinafter the MFF 
Communication) for 2014-2020.1 This Communication outlines the main elements of the 
future LIFE Programme2, which will include two sub-programmes, one for the environment 
(€2.4 billion) and one for climate (€800 million). It  also mentions that the future Programme 
should remain centrally managed, but that mana gement tasks could to a large extent be 
delegated to an existing agency. 
1. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
1.1. Procedural issues 
This impact assessment has been prepared by Directorate General for the Environment (DG 
Environment) and Directorate General for Climate Action (DG Climate Action). Inter-service 
cooperation was ensured through the establishmen t of an Inter-Service Steering Group (ISG) 
set up in September 2010 and which met several tim es with all interested DGs, the Secretariat 
General and the European Agency for Comp etitiveness and Innovation (EACI). Members of 
the ISG also followed the supporting study ca rried out by consul tants GHK et al. and 
participated in the workshops organised both during the mid-term evaluation of LIFE+ and 
during the combined impact asse ssment/ex-ante evaluation.  
 
1.2. External expertise and consulta tion of interested parties 
External expertise:  Two independent studies were commi ssioned from external consultants: 
"Combined impact assessment and ex-ante evalua tion of the review of the LIFE+ Regulation" 
carried out by a consortium led by GHK and "C limate Change in the future multiannual 
financial framework" carried out by the Institute for European Environmental Policy. The results of the ex-post evalua tion carried out by COWI in 2009
3 and the Mid-term evaluation 
of LIFE+ carried out by GHK et al.4 in 2010 were also taken into account.5 
                                                 
1 COM(2011)500 final-A Budget for Europe 2020:  
http://europa.eu/press_room/pdf/a_budget_for_europe_2020_en.pdf . 
2 See details in Annex 2. 
3 http://ec.europa.eu/environment/life/publications/lifepublications/evaluation/index.htm#expost .  
4 http://ec.europa.eu/environment/life/publications /lifepublications/evaluation/index.htm#mte2010 .  
5 These are summarised in Annex 4. 
 
4 Consultation process: In the context of the budget review , the Commission has carried out 
studies, discussions and analys is, including a wide public consultation. This exercise 
identified climate change as a major challenge with two thirds of the contributors considering 
it Europe’s big test for the future. The politi cal conference closing the public consultation 
confirmed this and there were calls for incr easing priority spending for environment and 
climate action in EU expenditure plans.  
An open online consultation was carried out on 'Your Voice in Europe'.6 Around 1,000 
responses were received from a variety of stakeholders, of which 58% had never received 
LIFE funding. Some 35% of res pondents were organisations, 13%  were competent authorities 
and 53% were private individuals.  
More targeted consultations  have been carried out to complement the stakeholder survey: 
one organised with the LIFE Committee members and Member States' environmental attachés 
on 27 January 2011, an ad-hoc stakeholder  meeting7 with around 100 representatives on 28 
January 2011 (e.g. NGOs, farmers association, business, and public authorities), and a 
specific survey on territorial impacts coor dinated by the Committee of the Regions.  
The outcome of the consultation pr oces can be summarised as follows : The Programme is 
seen as generally performing well in bo th environmental and value-added terms.  
Reflecting this, there is overwhelming suppo rt for the continuation of LIFE+ from all 
stakeholders with a preference for 'evolution rather than revolution'. There was general 
support for the different interventions and pr oposals made by the Commission. Integrated 
Projects were seen as having potential, and once explained, gathered support including from 
Member States. General support  was provided as well for a more targeted focus, with 
biodiversity and climate adaptation as top priori ties, an increase in the budget and in the co-
financing rate, and partial exte nsion of the territorial scope.8  
1.3. Opinion of the Impact Assessment Board (IAB): 
A first version of the Impact Assessment wa s submitted to the IAB on 29 July 2011. The IAB 
Opinion was issued on 13 September and suggeste d a series of modifications to improve the 
quality and presentation of the assessment.  
Based on the IAB Opinion, section 2.2 has been modified to provide further information on 
the best preforming sectors and features of the LIFE Programme . In particular, information 
has been added regarding the type of funding that has been most successful in terms of 
environmental benefits, the absortion capacity of the Programme, and additional data on the 
problems with its design and functionning. Clea rer reference was made to the link between 
the problems in the implementation of the cu rrent Programme with the respective options. 
The synergies and potential risks of overlapping with other Union Funds were also developed 
more in detail (section 2.2.2(b)) and complemented with a summary of the the assessment of 
the zero option (which was originally only incl uded as an Annex) in section 4.2. This also 
allowed clarifying the policy areas  better  suited for Union interv ention through the LIFE 
Programme . 
                                                 
6 Hereinafter referred to as "YVIE". 
7 Hereinafter referred to as "EC workshop". 
8 The outcome from these consultations is summarised in Annex 3 and relevant elements are inserted 
throughout this report. 
 
5 More clarity has been provided in the s ection 4.4. regarding the Options. Firstly by 
developing in detail the Ba seline as presented in the M FF Communication, and secondly by 
further developing the options related to the th ematic concentration of Integrated Projects 
(Options B) and the allocation of resources betw een the different priority areas (Options C). 
Finally, more information is provided rega rding overhead costs and proposed changes, 
including all the improvements al ready undertaken or planned.  
For all options, the baseline sub-option (estab lished on the basis of the MFF Communication) 
has been clearly identified and the assessment of impacts has been modified accordingly (Section 6.2). Information included in annexe s, opinions of the stakeholders regarding 
different options and limitations of the appl ied methodology are also presented in a more 
systematic and transparent manner throughout the assessment. 
2. C
URRENT STUCTURE AND PERFORMANCE OF LIFE  AND PROBLEM DEFINITION  
2.1. Current structure and design of the LIFE Programme 
Launched in 1992, the LIFE Programme is one of the spearheads of EU environmental 
funding and has financed 3,115 projects with a contribution of €2.7 billion. The latest 
Financial Instrument for the Environment (L IFE+) was adopted thr ough Regulation (EC) No 
614/2007 (the Regulation).9 The Programme is centrally managed by the Commission. The 
list of projects is approved by comitology with parliamentary scrutiny.  
The purpose of the LIFE+ Regulation is to co ntribute to the impl ementation, updating and 
development of EU environmental policy and le gislation thereby contributing to sustainable 
development. Another objective is to cont ribute to communicatin g and disseminating 
environmental issues  throughout the EU. 
Three types of interventi ons are possible under LIFE+:  
• Action grants, traditional LIFE Programme, repres enting 78% of the budget with three 
strands (see box 1); 
• Operating grants for NGOs, former NGO Programme, representing 3% of the budget; 
• Public procurement contracts for services and studies relate d to the development, update 
and implementation of EU environmental and climate policy and legislation, representing 
13% of the budget; and Technical assistance  to the selection, monitoring and evaluation of 
LIFE projects and the Programme  representing 6% of the budget. 
 
 
 
                                                 
9 OJ L 149, 09.06.2007 Box 1: LIFE+ Strands 
Nature & Biodiversity : projects contributing to implementing the Bird s and Habitats Directiv es, including set-up and 
management of the Natura2000 network, and the Comm unication on "Halting the loss of biodiversity by 2010". 
 
Environment Policy & Governance (EPG) : innovative or demonstration projects rela ting to EU environm ental objectives. It 
includes 12 priority areas for action,  one of which is climate action. 
 
Information & Communication : communication & awareness raising campaigns on EU environmental policy and forest fires.  
 
6 Figure 1: Interventi on Logic for LIFE+ 
Underlying 
Pressures: 
Environmental 
degradation
Increasing 
incidence of 
transboundary
environmental 
problems and 
impacts
Biodiversity loss
Growing 
recognition of 
need to preserve 
socially and 
economically 
important 
ecosystem 
services
Issues being addressed 
:
Insufficient coverage of 
all environmental 
priorities by the existing 
set of Community 
financial instruments
Insufficient funding for the 
management of the 
Natura 2000 network by 
other instruments 
Inadequate 
implementation of 
Community 
environmental policy 
(namely 6th
Environmental Action Programme) across the 
Member States 
Dissemination of  best 
practice 
Environmental protection is one of the key dimensions of sustainable development of the 
European Union. It is therefore a priority for Union co-financing and should be funded 
primarily through the EU horizontal financial instruments. 
General objective: To contribute to the implementation, updating and development of EU 
environmental policy and legislation 
Contribute to 
implementation 
of EU nature 
and biodiversity 
policy and the 
implementation 
of Natura 2000 
network 
Contribute to 
consolidation of 
knowledge base for 
development, 
assessment, 
monitoring and 
evaluation of nature, 
biodiversity and 
environmental policy 
and legislation 
Support design / 
implementation of 
approaches to 
monitoring and 
assessment of 
nature, 
biodiversity, state 
of environment 
and factors 
impacting them
Provide 
support for 
better 
environmental 
governance 
through 
broadening 
stakeholder 
involvement 
Disseminate 
information 
and raise 
awareness 
on 
environment
al issues  
Action grants 
for 
demonstration / 
best practice 
projects relating 
to Birds and 
Habitats 
Directives 
implementation 
Action grants 
for 
demonstration 
/ innovation 
projects 
contributing to 
halting loss of 
biodiversity in 
EU
Action Grants 
for 
demonstration / 
innovation 
projects aimed 
at implementing 
EU 
environmental 
policy
Public 
procurement 
contracts to 
support  
development 
of EU 
environment 
policy
NGO 
Operating 
Grants 
Awareness 
raising 
campaigns 
and training 
activities 
for forest 
fire 
prevention
Operational Objectives (in blue)
Specific objectives:
 
The co-financing rate is 50% of eligible cost s but the maximum co-financing rate in Nature 
projects may be up to 75% if target ing priority habitats or species.  
The LIFE+ Regulation requires at least 50 % of the budgetary resources fo r LIFE+ projects to 
be allocated to measures to support the conservation of nature and biodiversity.  
LIFE+ projects are selected on  the basis of a call for propos als launched ever y year by the 
Commission. Operational funding for NGOs is also subject to an annual call for proposals run 
by DG Environment with a 70% co-financing ra te. Policy support expenditure is contracted 
on a continuous basis, upon demand from  DG Environment and DG Climate Action.  
2.2. Problem definition  
2.2.1.  Environmental and climate problems, th eir main drivers and underlying causes 
When analysing the design and focus of a specific programme for the environment and 
climate action, it is necessary to identify the drivers and underlying causes of environmental 
and climate problems to be addressed.  
Halting the loss of biodiversity and improving re source efficiency along with climate change, 
and environment and health related concer ns remain key cha llenges for the EU.1011Although 
difficult to quantify, an assessment of externalities indicates that the total environmental cost in the EU each year is more than €650 bil lion representing around 5.7% of EU GDP (details 
fo the calculation are provided in Annex 5). For example, the projected climate damage 
costs
12 are estimated at about €20 billion per year by 2020 to €100-150 billion per year by 
2050, if no adaptation meas ures are implemented. 
These problems are a consequence of wide ra nge of economic and social activity and 
behaviour, which constitute instit utional drivers, market and re gulatory failures. The role of 
LIFE is to act as catalyst for change in areas where such a small instrument would be effective 
                                                 
10 EEA, The European Environment St ate and outlook 2010 available at http ://www.eea.europa.eu/soer. 
11 SEC(2010) 975 final. 
12 Results from ClimateCost project using PAGE model. 
 
7 and achieve the highest EU added value. This  is attained by fundi ng start-up actions and 
innovative, demonstrative, and best  practices projects th at could be replicat ed, as well as by 
acting as a platform for knowledge-sharing. Given this, the instrument typically deals with 
institutional drivers (and in some cases market failures), which are described in this section and are further developed in Annex 5. 
(1) Uneven and inadequate level of environmental protection due to the insufficient 
implementation or scope of environmental and climate policy  
Despite the well documented health and socio-economic benefits of implementing 
environmental and climate legislation, a high rate of implementation failures remains.13 Its 
underlying causes vary between Member States. One driver to highlight is insufficient 
administrative capacity, which includes individu al competence, organisational capacities, the 
enabling environment and partnerships/network or ganisations. This leaves much room for the 
Commission to be proactive and promote implementation and compliance through the 
exchange and transfer of best practices, a nd knowledge and experience at EU level. The 
different evaluations show that LIFE can offer this platform. 
(2) Uneven integration of environment and climate concerns in to other policies  
The principle of environmental integration reco gnises that environmental policy alone cannot 
achieve the environmental improvements needed.14 However, evidence (e.g. see the latest 
Cohesion report) suggests there in unevenness in the way this happens on the ground. In 
particular, there are substantial divergences in  the way environmental and climate objectives 
are incorporated into national/ regional programmes and dealt w ith by the various authorities 
and the private sector. Underlying causes iden tified include different competing priorities, 
lack of absorption capacity and knowledge shar ing, lack of coordinatio n between authorities 
and insufficient strategic planni ng. Showing to regional and natio nal authorities the benefits 
of investing in the environmental sector and incentivising them to develop strategic 
frameworks require in some cases demonstr ative projects. LIFE could provide those 
examples, thereby becoming a catalyst and “leade r” for other EU instruments and help to 
addressing coordination failures. 
(3) Inadequate levels of awareness and sharing of information  
The problem of implementation and integration de scribed above arise in part because of an 
inadequate sharing of information. The probl em is twofold: insufficient understanding of 
environmental problems and challenges, and insufficient knowledge sharing (e.g., potential 
solutions to the problems). Most EU Funds do not include compulsory dissemination and 
awareness raising obligations focusing on enviro nmental and climate challenges, while LIFE 
does. As part of the strategy to promote full implementation of the acquis,  LIFE could 
provide the framework to substantially increase  environmental and climate related awareness.  
(4) Limited support to eco-innovation  
The pursuit of eco-innovation is not just develo ping new consumer products and technologies 
that are intrinsically cleaner an d greener than their predecessors. It is al so about engendering 
better practices and approaches across the economy.  While market failures are sufficiently 
                                                 
13 One third of all open cases for n on-compliance are environment relate d cases, which indicates that the 
implementation of environmental legislation remains far from satisfactory. 
14 COM(2004)394 "Integrating environmental considerations into other policy areas – a stocktaking of the 
Cardiff process". 
 
8 addressed by other EU Funds, institutional we aknesses are more insufficiently dealt with. 
This is particularly relevant for activities rela ted to developing policy driven and public sector 
oriented solutions to environmental problems w ith limited or no market replication potential 
and that simply promote new and more cost-effective ways to implement environmental policy. Similarly, low carbon technology devel opment is hampered by uncertainty and 
knowledge spill-over in ge neral. After technologies have b een developed, they need to be 
tested at a small scale. While market-replicat ion and large scale solu tions are increasingly 
covered by new initiatives like Horizon 2020, there is still much room to promote the development of local and public sector-oriented solutions as well as small-scale technologies 
focused on SMEs to help them improve their environmental and climate performance. LIFE 
has traditionally dealt with th ese local challenges by providing highly replicable smaller scale 
solutions.  
The problem tree in figure 2 below  shows that in addition to  the institutional drivers 
developed in this section, there ar e also market and regulatory failures that relate to the fact 
that the environment is a public good. As a cons equence, negative environmental externalities 
are not integrated in price, resulting in impe rfect competition and in positive spillovers from 
innovation being not recognised by the market . In addition, information failures cause 
consumers to make ill choices, and regulatory capture makes that particular interested parties 
have a disproportionate influen ce over policy and legislation. Most environmental challenges 
have been regulated at EU level thereby tackli ng regulatory and in many cases market failures 
(e.g., by imposing a price to use a resource, by homogenising standards for a particular 
environmental sector). Market-based instrument s also address many of the externalities and 
market failures identified.  
Figure 2: Problem Tree 
Costs to citizens
- Health effects
- Quality of life reduced 
- Fewer employment 
opportunities
Current and continuing 
environmental problems in 
the EU
Variable and inadequate levels of 
environmental protection 
- EU inadequate implementation
- EU inadequate scope
Environmental public goods Negative environmental externalities Positive spilloversfrom innovationInadequate response to market failures Inadequate prioritisation of environmental objectivesInadequate coordination 
and a lack of integration of 
EU  environmental policies  
(including in 3rdCountries)Inadequate sharing of information 
and EU environmental policy lessons 
and inadequate levels of awareness 
of environmental problemsInadequate 
system of 
support for 
eco-innovationEU has a range of environmental problems which impose economic and social costs. 
This reduces quality of life for all EU citizens and undermines  EU and global sustainabilityNew and emerging 
environmental problems 
in the EUIncreasing burden from 
global and non-EU 
environmental problems Inability to decouple economy 
from use of natural resources / 
environmental impactTransboundary
impacts Lack of burden sharing in 
maintaining EU 
environmental assetsLack of EU scale in 
innovation Costs to producers- Loss of resources and    
eco-system services, 
which raises costs
- Inefficient markets
- Loss of level playing fieldCosts to consumers
- More expensive products
- Products fail to provide 
full utility (sustainability)Costs to future generations
- Poorer quality environment 
- Lack of resources
- Higher costsConsequences 
for all actors
Environmental 
problems (with clear EU 
dimensions)
Institutional 
factors - The 
drivers of 
environmental problems
Market & Regulatory
failures 
(endemic features 
of the system )
Information failures Undermining of environmental 
policy by ‘race to bottom’
 
 
However, not all underlying causes and driv ers can be solved through legislation. For 
example, the first institutional driver mentioned in this section is precisely the insufficient implementation of environmental and climate legislation, which consolidates many of the 
environmental and climate challenges identifie d. Therefore, incentives and measures other 
than legislation and market-based instrume nts are required to address those barriers. 
 
9 The budget is an essential policy instrument to achieve EU objectiv es, and to recognise 
solidarity and effort sharing. 
In fact, EU2020 has set out specific targets and object ives that will require a combination of 
different policy instruments  if they are to be achieved. Among these policy instruments, 
mobilisation of possible funds is essential to support implementation costs as well as to drive 
change. The different EU funding programmes t hus address different drivers at different 
levels ensuring the coherent and compleme ntary approach of the EU's intervention. 
Whereas many EU funding instruments mos tly focus on supporting implementation costs 
(particular in relation to investments in infr astructure) and research needs on a larger EU 
scale, LIFE, as shown in this section, focuses mo re on institutional barrie rs (linked to lack of 
adequate capacity to implement and integr ate environmental and climate concerns or 
deficiencies in knowledge/best practice sharing) , and addresses information failures through a 
wide dissemination of project results and networking obligations . LIFE addresses main gaps 
(institutional, procedural, territorial) identified in Cohesion policy funds, Common  
Agricultural Policy (CAP) Funds, and the Re search and Innovation Framework Programme. 
LIFE in particular helps addressing the challe nge of establishing adequate mechanisms for 
coordination for environment and climate (cont ributing to the success of mainstreaming and 
addressing uptake problems). In addition, LIFE pr ovides solutions that can be scaled-up and 
mainstreamed into these bigger Funds. More detailed discussion on the relation between LIFE 
and each fund is provided in section 3.2 (consis tency with existing EU policies) and section 
4.1 (zero option).  
2.2.2.  Performance of the LIFE Programme and probl ems linked to its design and structure  
The evaluations mentioned in se ction 1.2 confirm that LIFE is a successful EU instrument 
crucial to implementing EU environmental polic y. It has a significant EU added value and has 
performed well. 
a.  The best performing sectors a nd features of the LIFE Programme 
(1) LIFE contribution to implemen tation and to creating environmental benefits has been 
particularly successful in certain sectors  
Since projects supported by way of action grants  focus on concrete environmental 
improvements (such as restoring habitats) or finding solutions to environmental problems, 
action grants are the type of funding that led to direct environmental and climate benefits 
(e.g., reduction of CO 2 emissions, less hazardous substances in  water, etc.). This implies that 
environmental and climate benefits are easier to quantify for action grants.  
LIFE has worked best when focused on a particul ar sector and thus is able to create critical 
mass. These sectors tend to be as well those in which LIFE has also brought more direct 
environmental benefits. 
One of the main success of the Programme is the LIFE Nature component . LIFE has played 
a major role in implementing the Habitats a nd Birds Directives, firstly, by financing the 
inventories required for the designation of th e Natura2000 sites; seco ndly, by restoring and 
improving the conservation status of habitats  and species; thirdly, by building the capacity 
required to manage the network in the long te rm; and fourthly, by eliminating the initial 
resistance in many sectors, including the pub lic administration, to implement the Nature 
 
10 Directives (for more details  see Table 1.2 of Annex 7).15 This success derives to a great extent 
from concentrating 50% of resources on two Dir ectives and from the close links between the 
Programme and EU policy priorities. Projects' si ze in the Nature component has been steadily 
increasing over time to cover larger portions of the territory of a region or a Member State, 
which also contributes to increasing the cap acity of these projects to provide direct 
environmental benefits (see Box 3 in secti on 2.2.2(b)1 for an example of a large scale 
project). 
In the Environment component , Eco-innovation projects  (around 42% of projects financed 
under the LIFE Environment strand) bring more direct environmental benefits since they 
focus on demonstrating environmental improvement s as a result of innovative/demonstrative 
solutions to environmental problems. Action grants in the area of climate change, water, 
waste  and to a certain extent air can be considered as the most  successful in achieving direct 
environmental benefits (see Table 1.4 of Annex 7). In addition, the ex-post evaluation noted a 
positive pump-priming effect (with projects being replicated and thus increasing direct environmental benefits) in the waste and water sectors.  
For other projects funded under LIFE Environmen t that aim at testing and developing new 
policy or management approaches and proposa ls, quantification of direct environmental 
benefits is not possible. This would be th e case particularly for strategic approaches, 
chemicals, urban, noise, or soil where few direct environmental benefits are reported although 
successful management systems have been established.   
In any case,  the lack of focus of the Environment st rand meant that projects even within a 
common and successful theme such as waste or c limate change addressed in fact a wide range 
of issues. As a consequence, the overall body of projects lack coherence, reducing the 
capacity for direct environmental benefits, mutu al learning exchange, transferability and the 
delivery of multipliers.  
Information and communication projects  have not been particularly successful. This is 
partially due to the current design of the LIFE Informa tion & Communication component, 
which is not adapted to communication and awar eness needs. However, it should be noted 
that when an Information project is ade quately designed and ha s a sufficiently large 
geographic scope it has a great potential for ch anging behaviours (see examples in Box 2 
below). It is not always possi ble to quantify direct environm ental benefits resulting from 
Information projects. 
Box 2: Illustrations of a LIFE Information & Communication strand 
European day 'In town, without my car?'  (subsequently becoming the European  Mobility Week): In 2002, the campaign 
succeeded in establishing a truly European  initiative with 320 cities from 21 countries taking part in European Mobility 
Week. A second event held in Septembe r 2003 consisted of a week-long series of  awareness-raising events focusing on 
various aspects of sustainable mobility. Mobility Week succesfu lly continues taking place in Europe and is now spreading to 
the rest of the world via grassroots networks. 
The European Week of Waste Reduction. The LIFE project EWWR  aims to reduce the amount of  waste generated in the 
EU by mobilising all relevant actors in a EU-wide awaren ess-raising campaign and changi ng behaviours of different 
stakeholders in their waste generation. 4 Member States have joined to develop a common strate gy as well as tools to carry 
out awareness-raising activities on recyc ling around the EU over one week every year . In 2009, 2,672 initiatives were carried 
out, in 2010 there were 4,346 in 24 countries reflecting the su ccess of the event. In 2011 expectations are even higher. 
                                                 
15 Between 1992 and 2006 and with only €70million a year LIFE covered 9% of the Natura2000 terrestrial 
network. The actual coverage in relation to areas in needs of intervention is higher, but lack of data 
makes it impossible to determine how much higher. For the period 2007-2013 LIFE+ will cover around 6% of the terrestrial Natura2000 with a big increas e in the coverage of the marine network. Around 
37% of birds species and 50% of animals species have been targeted by LIFE pr ojects with half of them 
achieving "favourable conservation status" for one or more of the targeted species in the long term. 
 
11 Finally, it should be highlighted that some of  the most successful projects in terms of 
environmental benefits have also been those where LIFE funding was complemented, scaled-
up or continued via other funds. Particularly successful in term s of environmental benefits 
were those projects where LIFE funding was used  in combination with other EU and national 
funds because it also help covering larger por tions of the territory and addressing different 
and complementary needs (see Box 4 in sect ion 2.2.2(b)(3)). 
NGOs activities funded by operational grants  have also being successful in achieving 
environmental and climate objectives. There are numerous examples of environmental 
investigation and studie s carried out by NGOs in relation to  environmental policy, many of 
which have contributed directly  to the policy process to iden tify environmental and climate 
problems or even define policy options. NGOs contribute to the knowledge-base for 
environmental policy by feeding in specific expe rtise, research and studies. For instance, an 
investigation by the Pesticides Action Network (PAN) Europe in 2008 of bottles of wine 
purchased inside the EU found evidence that some  wines contain residues of "a large number 
of pesticides".16 In addition, through their networks a nd specific expertise,  NGOs are effective 
in promoting implementation of EU policy on the ground. They can for example draw attention to cases of  non-compliance and publishing black  lists, scoreboards and reports 
contribute to improving implementation. They also  act as centres of expertise helping local 
authorities and economic actors to comply w ith legal or policy re quests, or setting up 
implementation initiatives themselves.  Direct environmental impacts cannot be quantified. 
(2) LIFE has played a significant role in  increasing awareness, good governance and 
public participation  
LIFE projects  have made a significant contribution to increase information and awareness on 
environmental and climate related matters as, on average, between 5-10% of resources are 
dedicated to these aspects (Table 1 shows a total investment of around €36.5 million) which is 
compulsory for all projects. Thes e projects have performed well.  
Table 1 - Budgeted amounts for dissemination and aw areness activities under LIFE projects (2007-2009) 
 
Activity € (budgeted) 
Educational acti vities 2.010.334  
Media activities 10.704.716  
Publications 7.477.340  
Trainings 6.858.612  
Workshops 9.507.216  
TOTAL 36.558.218 
In addition, the EU contributi on under the Information & Comm unication strand to awareness 
raising campaigns has been of €34.1 million. 
LIFE has also improved governance and public participation. Operating grants  for NGOs 
facilitated their involvement in developing and implementing EU environmental policy and 
legislation as required by the Aarhus Convention. NGOs played an  important role  in ensuring 
good governance policy by articulati ng the interests of civil so ciety. Funded NGOs play an 
important role in coordinating the positions of their members, providing the Commission with 
a single interlocutor and giving a voice to a large number of lo cal organisations which would 
otherwise have difficulties reaching EU d ecision-makers. NGOs reply regularly to public 
consultations, providing useful input and perspe ctive to the policy proc ess. Operation grants 
                                                 
16 PAN Europe (2008) European wine systematically contaminated with pesticides residues. Available 
from: http://www.pan-europe.info/Media/PR/080326.html. 
 
12 are considered a tool to protect the level pl aying field in the public debate and the policy 
development between environmental NGOs and s ector-federations or other organisations 
funded by industry. However only 31% of the NGOs in the Mid-term evaluation thought a 
level playing field is effectively being r eached with the actual operational funding. NGOs 
receive on average around €9 million per year in operating grants.   
Finally, the participative nature  of LIFE projects which brings together public and private 
organisations has improved effectiveness. 
(3) The flexibility of the Programme and management mode  
Stakeholders appreciate the fact that LIFE is close to local and regional realities and needs 
allowing for flexibility to devel op ideas and approaches adapted to the particular context. The 
management of the Programme was considered by different evaluations and stakeholders as 
one of the elements of success of the Programme. 
(4) LIFE is the most adapted EU funding inst rument in the environmental sector as 
reflected by a continuously increasing demand and thus is particularly successful in 
mobilising national and private sector funds for the environment  
Demand for LIFE action grants is continuously growing, and with it, its capacity to mobilise 
both private sector and national funds. The overa ll level of applications and co-financing 
requested is oversubscribed for all strands. For example, for 2010 call for proposals, 748 
proposals were submitted requesting €884 milli on co-financing while only €244 million were 
available. Total investment would have imp lied around €1.8 billion (the refore around 53% of 
the total investment would have come from na tional and private funds). As a consequence of 
the limited funds available under LIFE, out of th e 250 projects that were eligible for funding, 
only 148 (i.e., a selection rate of approx. 1 proj ect out of 3) could be funded representing a 
total investment of €530 million. The 2011 call for proposals confirm this trend (around 1078 
proposals have been received). Th is data provides evidence of the capacity of LIFE+ to 
mobilise funds even during this tim e of crisis and even when th e co-financing rate remains at 
50%.17 No risk of crowding out is foreseen, especially since the increase in LIFE funding is 
inferior to current and expected demand. 
Since LIFE action grant funding covers up to 50% of the eligible project costs (up to 75% for 
Nature projects targeting prio rity species and/or habitats ), matching funds are brought by 
project beneficiaries and, where relevant, co-fin ancers from the public or private sectors. In 
some Member States, national funds provide matc hing funds to LIFE funding as co-financers. 
The best example is Poland, which has led to a significant increase in the number of 
applications to LIFE funding.  
                                                 
17  It should be noticed that the incr ease in proposals is for the three stra nds. In the nature strand were there 
is the possibility for a co-financing rate of up to 75% for projects targeting priority species, the increase 
is observed for all types of projects.  
 
13 Figure 3: Major beneficiaries in LIFE + projects per strand (2007-2008) 
71
58114
36
11452
74513
83121
0%10%20%30%40%50%60%70%80%90%100%
Nature and 
BiodiversityEnvironment 
Policy and 
GovernanceInformation and 
CommunicationProfessional organisations
NGO-foundations
Universities/Research institutions
Enterprises
Public authorities and development agencies
 
Action grants in the LIFE NAT  predominately mobilise publ ic sector funds (public 
authorities and development agencies represent 71% of lead beneficiaries under LIFE Nature 
& Biodiversity component). Only 4% of lead beneficiaries were  enterprises. However, an 
increasing tendency for the privat e sector to be more involved in nature, and especially 
biodiversity, projects has been observed in the last calls. Usually, the private sector 
participates as associated beneficiaries thr ough their organisations (e .g., famers, hunters and 
fishermen associations) or directly.  Inform ation and dissemination activities funded through 
action grants predominantly mobilise public sector and NGO funding.    
Action grants in the LIFE Environment  component have been pa rticularly successful in 
mobilising private funding. 48% of beneficiaries of LIFE Environment projects are 
enterprises (mostly SMEs) and professional or ganisations (e.g., busin ess associations or 
institutions dependant on busines s). Since the co-financing rate for environmental projects is 
of 50%, this means that a substantial mobilisat ion of private funds has been possible through 
LIFE Environment. 
NGOs operating grants  do not aim at mobilising privat e sector funds but rather to 
strengthening the participation of NGOs in the dialogue process in environmental policy-
making and its implementation.   
b.  Problems with the design and functioning of the Programme 
(1) Lack of strategic approach and critical mass  
The main criticism of the current instrument is the absence of a strategic approach , which 
means that EU policy priorities are not fully reflected. For example, climate change was a 
priority for 2007-2009 calls, but given the ope n competition, it only obtained 14% of LIFE 
budget for action grants. Similarly, compliance promotion, good practice for enforcement, as 
well as other governance-related aspects have not received sufficien t attention under the 
current system, and individual proj ects in these areas have not been co-ordinated in a way that 
delivered high multiplier effects. The same applies to the Information & Communication component, which often finances very loca lly-oriented dissemination campaigns each 
focusing on a different environmental or clim ate problem, thus limiting the impact of 
behavioural change.  
This is the consequence of th e bottom-up approach combined with the broad scope of areas 
for action, which provides little opportunity fo r the Commission to stimulate demand in 
priority areas. Indeed, even with in an individual thematic area, the projects financed are very 
 
14 diverse limiting the ability to generate impacts beyond an indi vidual project. Therefore, the 
ability to make greater use of project results in support of polic y needs (the so-called catalytic 
or multiplier effect of the Programme) is underdeveloped.  
Many good projects are financed, but because thes e are not concentrated on a single issue at 
the same time, their impact is dissipated. The exception is Nature, which does have a critical 
mass, as it focuses on two Directives concentra ting 50% of resources on  their implementation 
and dissemination of good practices.  
This experience would call inter alia  for earmarked resources  for other policy priorities, in 
particular Climate Action, and higher visibili ty for some elements (e.g. governance) of the 
LIFE Environment strand. In addition, the Mid-term and ex-ante evaluations propose 
establishing a strategic progr amming framework (such as 2-3 years rolling plan) to set 
priorities.  
Finally, the different evaluations call for increasing the size of the projects  to ensure a 
higher impact and more extensive outreach (i.e . more/larger areas of Natura2000 involved and 
significant capacity building). There are exam ples under the current programming period 
where these large size projects (i.e., €10-30 million) have been financed showing their 
benefits and increased impacts.18 
 
Box 3: LIFE and the Iberian lynx (Spain and Portugal) 
The Iberian lynx ( lynx pardinus) is the world’s most endangered feline sp ecies and the most endangered carnivorous 
mammal in Europe. The lynx is an umbrella species that helps in the conservation of a whole ecosystem but only two 
populations located in Andalucía remain in the world.  
To build on and move beyond the findings of regional projec ts, the Andalusian government applied for a €25 milion LIFE 
project (EU contribution €9.8 million) to develop a partnership project to consolidate and guarantee the future of the lynx 
populations, principally by restoring rabbit populations. The LI FE project allowed including other partners crucial to the 
protection of the lynx. These partners included organisations  representing hunters and landowne rs, as well as environmental 
NGOs and international experts on carnivores conservation.  
The project far exceeded expectations. Not only was it able to pr event further loss of the species in the two areas, but it eve n 
managed to increase the populations. When LIFE funding star ted, only 102 specimens remained in the entire world. 
Population has increased now up to 270 sp ecimens, it is being reintroduced in new areas and further reintroduction in 
Portugal and other Spanish regions is expected. Hopes are hi gh to upgrade the conservation status from critically endangered 
to endangered in the next years. A new LIFE project w ith €34 million (EU contribution €20 million) will aim at achieving 
this ambitious target.  
Following recommendations from the Mid-term  evaluation, the Commission has included in 
the Guide for applicants for the 2010-2011 calls for action grants indicative lists of favoured focus areas. However, the LIFE+ Regulation do es not allow for annual work plans or for 
limiting the number of priority areas. Therefore, this solution is not sufficient to address the 
problem identified.  
The need for a strategic planning (top- down versus bottom-up) is addressed under Options A . 
Options for the allocation of re sources between different prior ity areas, including earmarking 
are developed under Options C .  
The possibility to increase the size of projects to improve impact and environmental benefits 
and more extensive outreach was addressed by the MFF Communication  where a new type 
of projects - "Integrated Projec ts" - is proposed (see the baseli ne description in section 4). 
                                                
 
18 See Annex 7 for further details. 
 
15 (2) Role and objectives to be better defined for certain strands and territorial scope  
The LIFE Nature  strand is clearly focused on implemen tation and capacity building, whereas 
LIFE Environment has evolved from promoti ng technological eco-innovation to a more 
policy oriented instrument demonstrating be tter ways of implemen ting EU legislation.  
The ex-post evaluation and some stakeholders felt the LIFE Environment  str an d  lack ed  a 
clear profile. The mid-term ev aluation and the ex-ante evaluation suggest the strand should 
focus more on implementation and creating multipliers rather than promoting the development of new technologies. The strand ha s to prioritise on addressing those weaknesses 
that most undermine the performance of EU envi ronmental policy, and wh ere it can have an 
effective impact. 
As to Biodiversity , the mid-term evaluation indicate d that the focus on innovation was 
inefficient as biodiversity projects tend to work best when applying 'tried and tested' methods 
and not 'innovative' approaches. Both the mid-te rm and the ex-ante evaluation call for the 
actions to be aligned with LIFE Nature and fi nance best practices and demonstration projects. 
Also, LIFE does not sufficiently  focus on new emerging priori ties from the Biodiversity 
Strategy, such as green infrastructure, or  exploring the use of innovative financing 
mechanisms (i.e., biodiversity banking). 
As to the LIFE Information & Communication  strand, the mid-term ev aluation criticises its 
current local focus. The ex-ante evaluation argues for eliminating this strand and for 
strengthening communication oblig ations in the projects themselves as well as Commission 
dissemination activities instead. 
The evaluations also found that constraints regarding funding  activities outside the EU  
have reduced the effectiveness of the Programme . In some cases, for action to be effective 
within the EU, investment outside the EU may be required, e.g. migratory species, 
international river basins, climate change or marine environment.  
Following recommendations from the Mid-term evaluation, the Commission has substantially 
revised the Guide for applicants for the 2010 -2011 calls for action gr ants including more 
examples and flexible approaches.  However, additional clarification effort is needed. 
The issue of the need for a bette r definition of LIFE strands a nd more flexible approach to 
funding activities outside the EU has been addressed by the MFF Communication  where a 
clear shift towards implementation, best pr actices and demonstration has taken place for 
Environment and Biodiversity, as reccom ended by the different evaluations.  
The issue of LIFE Information & Comm unication has also been addressed by the MFF 
Communication which has broadened the scope of the component to include also 
Governance aspects and a more targeted approach  to information and dissemination activities. 
More specific aspects related to Gove rnance and Information are developed under Options E.  
(3) Need to improve complementarity and synergies with  other EU funds
 
The evaluations show that sustainability of project results and replicabilty also depends inter 
alia on securing recurrent funding af ter project completion. The mo st successful projects are 
those that prepare the ground for continued management through other Funds, such as the EAFRD, or that are combined with other Funds , such as the Cohesion Fund, or can be scaled-
up with Structural Funds. However, challeng es remain to ensure more synergistic and 
complementary use of Funds. 
 
16 The evaluations suggest that LIFE+ could be used to enhance uptake by adopting a more pro-
active attitude towards complementarity with other programmes and by effectively promoting 
the integrated use of different EU funds at  EU, national, regional and local level.  
Box 4: An example of combined funding - Protecti on and usage of aapa mires with a rich avifauna 
The aim of this project was to prepare conservation and manage ment plans for five areas within the central Lapland aapa 
mire zone, so that ecotourism and recrea tional use can be organised on a sustainabl e basis. The project combined resources 
from different EU sources (LIFE for planning and ERDF for co nstruction of the tourism infrastructure) and national funds 
(for construction of barns on the hay meadow s). The funds were managed efficiently. 
The project manager of this LIFE  project noted the following: 
• It was not difficult to align the project to the diffe rent objectives of different funding sources as the 
various project objec tives were clear.  
• The use of various funding sources provided the opportunity  to make environmental objectives more ambitious. 
The beneficiary also stated that Integrated Projects can  create positive publicity and e nhance the status of Natura 
2000. 
• The combination of funds has not resulted in significant additional administrative costs. If the project objectives 
are mutually supportive, the overall benefit is greater than any additional costs. 
By combining funds, the projects can impl ement measures that LIFE would have b een unable to support, such as service 
structures. Implementation of the servi ce structure in Lapland has increased in terest in Natura 2000 areas and brought 
positive publicity to the project and to the LIFE Programme more generally.  
Another area for complementarity is enhancing LIFE’s role as provide r of new approaches 
that can be mainstreamed into national solutions and other EU funded programmes. 
On the other hand, there are some overlaps with  other EU funds, which may cause confusion 
– in particular, for eco-innovation. The mid-term evaluation identified overlaps with the Eco-
innovation section of the Competitiveness a nd Innovation Programme (CIP) and potential 
overlaps with the FP7. Between 15-25% of projects funded under LIFE+ as eco-innovation 
projects could have b een financed by other EU instrume nts, mostly market-replication 
projects.  
As to projects that c ould have been funded by Interreg, these were environmental projects 
involving several Member States and that have  significant socio-economi c benefits linked to 
tourism. For example, a project to improve the conservation status of the floodplain bird 
species that are protected in the Natura 2000 sites SPA Dunajské luhy (Slovakia) and SPA 
Szigetkoz (Hungary). Projects that could ha ve been financed by FP7 were certain 
demonstration projects applying new technologie s where more than 3 Member States were 
involved, especially in relation to modelling. When  such cases are detected, these projects are 
rejected during the evaluation process. In ot her cases, certain measures and activities are 
removed from a LIFE project during the revisi on process when they are considered better 
fitted for other EU funding programmes.  
It is more difficult to single out a type of pr oject that could have been financed anyway by 
national or private funding . In the case of projects managed by public authorities , these 
tend to be projects which are part of a broa der strategy and some political commitment to 
undertake the activities included in the LIFE proj ect already exist (for example, a project to 
adapt electric pylons to avoid bird s electrocution). However, the ev aluations show that in this 
case the project would have been developed at a later stage (when all necessary funds would 
have been available based on the responsible authority's annual budget) or on smaller scale 
(instead of covering the entire region, it woul d have covered the most important spots), 
therefore reducing its direct environmental im pacts.  In the case of projects managed by 
private entities , it would be projects that were part  of the company strategy to improve 
performance. These are the least innovative and demonstrative projects in many cases as the 
 
17 purposes tend to be to help the company to appl y best available techniqu es. As in the case of 
projects managed by the responsible authoritie s, in absence of LIFE funding, the company 
would have adopted these technologies or approaches later in time.   
The issue of the need to improve synergies and complementarity with  other EU Funds and 
avoiding overlaps is addressed by the MFF Communication , firstly through the creation of a 
new type of project, namely Integrated Projects, secondl y by foreseing a structured 
cooperation between LIFE and the main EU fu nds within the Common Strategic Framework, 
and thirdly by excluding market replicati on eco-innovation from the Environment sub-
programme.  
(4) Project results should be better utilised and transf er of know-how improved  
Sharing of best practices fo r the implementation of EU acquis  should be reinforced, especially 
at EU level. The ex-post evaluation showed that between 10-20% of LIFE projects were 
replicated. At project level, compulsory ne tworking is contributing to creating networks 
around the EU to learn from each others' expe riences and to prepare joint applications. 
However, stakeholders and the evaluations hi ghlighted that improving the replication and 
transfer of results requires a more pro-act ive dissemination and knowledge sharing support by 
the Commission.  
Following the recommendations of the Court of Auditors and the diffe rent evaluations, the 
Commission has reinforced and improved disse mination activities in this programming 
period. Improvements include publishing more tailo red thematic brochures, the organisation 
of thematic conferences to exchange experien ce and disseminate projec t results, production of 
thematic reports for policy uptake, clustering of  projects, compulsory obligation for project 
networking, improving the website and creating a discussion forum for LIFE+ projects. These 
experiences have proved successful. However, a more systematic approach to knowledge 
sharing and results promotion is still re quired. The ex-ante evaluation recommends 
strengthening project obligations, but also suppo rting specific projects  targeting dissemination 
of results, and enhancing NGOs support. 
The issue of the need for a better utilisation of projects' results and improvement of the 
transfer of know-how is addressed under Options A (strategic planning: top-down versus 
bottom-up) and especially Options E  (Governance and Awareness raising). 
(5) Simplify application an d selection procedures  
One of the criticisms of th e Programme was the long selec tion procedures which require 
comitology with Parlimentary scrutiny and burdensome paper submission, including submission to National Contact Points. A new set of IT applications is currently being developed (eProposal) to ensure a simpler acces s and a paperless selection and follow-up of 
financed projects. This allows for a reducti on in the administrative burden and also for 
improving the quality of the pr oposals (clearer presentation, automatic verification of the 
correctness of figures etc.). In  addition, the introduction of Inte grated Projects also calls for a 
reflection upon ways to further simplify sele ction procedures. Following recommendations 
from the Court of Auditors and the Mid- term evaluation, the Commission has already 
shortened the selection procedur e but this is not sufficient to  address the problems identified. 
The issue of the need for measures to simplify further, in particular with regard to the 
application and selection pr ocedures, are developed under Options F  (simplification). In 
 
18 addition, the MFF Communication  already proposes moving towa rds larger-size projects, 
which will also lead to simplifcation benefits.  
(6) Distibutional impacts of national allocations  
National allocations are a remnant of the or iginal Commission’s proposal for LIFE+ in 2004 
which envisaged a decentralised management system. Despite the final decision in the 
Regulation to maintain central manageme nt by the Commission, national allocations 
remained. However, they have not led to a more  balanced distribution of projects across the 
EU (e.g., projects from Italy, Spain and Germany receive most of the funding).19 In fact, 
national allocations may lead to selecting pr ojects of lower quality, which would have an 
impact on the effectiveness of the Programme to  provide EU added valu e and had a perverse 
impact on smaller Member States (smaller al locations do not enco urage submission of 
proposals). On the other hand, they can be used  as a representation of solidarity sharing 
especially in the area of nature conservation where natural assets ar e unevenly distributed 
around the EU. The mid-term evaluation and the ex-ante evaluation sugge st either not to 
include national allocations or develop a differe nt system based on diffe rent criteria but only 
when such geographical balance serves the purpose of solidarity and effort sharing.  
The Commission is actively working to dissem inate good practice to in crease success rate in 
Member States with lower programme uptake rate of success through improved 
communication efforts. These increased efforts include promoting better quality proposals. 
The issue of the geographical distributi onal impacts is being addressed under Options D .  
Box 5: Other recommendations from the Ex-post and MTE 
Improved focus on results and performance , and their measuring: monitoring and evaluation were largely considered as 
effective and efficient. However, the mid-term evaluation suggested the Program me had been too much focused on outputs 
with specific indicators devel oped for this, while result indicators underpinning proposed activities have not been developed. 
Guidance to project co-ordinators to advice on indicators w ould be required. Following recommendations from the Court of 
Auditors and the Mid-term evaluation, the Commission has impr oved the mechanisms for carrying out more systematic ex-
post visits to assess sustaina bility of proj ect results. 
Co-financing rates : the mid-term evaluation indicated that the success of the Biodiversity, and Information & Communication 
strand could be improved by increasing the intervention rate. Th ese are new sectors for which no or very few alternative 
funding opportunities exist. 65% of YVIE respondents thought current  co-financing rate was too low. Also, during the first 
moments of the financial crisis, concerns were raised about the difficulties for the private sector to mobilise additional 
funding. 
However, the continuous increase in th e submission rate for 2009, 2010 and 2011 cal ls for proposals, with beneficiaries 
requesting in many cases less than the maximum co-financi ng rate available shows no problems in mobilising funds. For 
example, Spain and Italy, despite economic problems, contin ue submitting more proposals than any other Member State and 
mobilising private and public sector funds.   In addition, in order to ensure that beneficiaries maintain ownership of their 
projects and to reach a high leverage of the LIFE instrument, the co-financing rate is considered balanced. 
2.3. How will the problem evolve? 
The ex-post evaluation, the mid-term evaluatio n and the ex-ante evalua tion all insist on the 
importance to improve the strategic focus  of LIFE to increase the coherence of the 
                                                 
19  These 3 Member States totalled €98 million in 2008, accounting for almost half of the total LIFE+ 
budgetary resources. Beneficiaries in new Member St ates have in general a lower rate of success. A 
study carried out by Arcadis consultants identified several underlying causes for differentiated rates of success: active support to applicants by national authorities or acces s to matching funds. In old Member 
States, low success rates are mainly related to the number of applications submitted. The higher the 
number of applications, the higher the probability that more quality proposals are submitted, and thus the higher the probability of being funded. However, EU added value partially derives from the quality 
of the projects funded. Compliance with national allocations should not lead to finance projects of 
lower quality. 
 
19 Programme and its EU added value. This woul d allow to create critical mass and assess 
Programme results and impacts in a given environmental or climate area. If the lack of strategic focus and critical mass is not addressed: 
• LIFE would not be able to overcome the shortcomings of the bottom-up approach 
and drive demand towards those areas wher e funding might be most needed or that 
are in need of more examples for know ledge-base development and sharing. As a 
consequence, funds will continue being scattered along the acquis;  
• LIFE would be less suited to deal with emerging challenges in relation to EU2020 
objectives and targets, in particular in relation to the implementation challenge in 
sectors where a more programmatic and larg er-scale approach fo r funding is required 
and that are approaching the most impor tant implementation phase, such as the 
Habitats Directive, the Water Framework Directive, or are more linked to meeting resources efficiency targets (such as the, water, waste, air and soil legislation).  
The introduction of Integrated Projects will allow for increased geographical outreach and 
impact of LIFE projects. However, if no thematic concentration  takes place, there is a risk 
that the impact of the Program me will remain diffuse along the acquis .  
If activities to increase the dissemination of project results  are not undertaken, projects will 
continue establishing networks and disseminati ng results but replica tion and transfer of 
lessons learned will continue being underdev eloped and the Programme will underperform 
remaining in some cases anecdotic. This would undermine the EU added value of the Programme as a platform for development a nd exchange of best practice and knowledge 
sharing;  
If simplification  measures are not adopted: 
• the workload on both Commission and beneficiar ies' side will continue to increase,  
• there will be risks that the number of submitted Integrated Project will not be 
sufficient to achieve targets because the complexity of curre nt selection (e.g., 
extremely detailed analytical budget and techni cal forms) is not fit for larger projects. 
If national allocations  are maintained as under the LIFE+ Programme, it risks concentrating 
funds again in few Member States while sma ll Member States might be underrepresented. 
This might be a problem for the success of Inte grated Projects since th e Programme will not 
have enough examples from different administra tive types, Member Stat es sizes or different 
environmental/climate challenges. 
The situation for 2014-2020 is exp ected to improve compared to the current programming 
period in that earmarked resources  and a stronger focus on c limate action should increase 
the expected success rate in line with the ear marking applicable under LIFE+ for the current 
Nature strand. However, nothing has been fore seen for other areas, where such earmarking 
traditionally exists, i.e., Nature and Biodiversity. If no earmark resources are ensured, the risk of more limited uptake as compared to curren t situation will increa se and it may undermine 
the success of the strand.   
 
20 2.4. Who is affected and how? 
All Member States' authorities and public bodies (at national, regional and local level), the 
private sector (including SMEs), NGOs and ot her non-profit organisations, and civil society 
groups are affected by the problems and underlying causes identified.  
Most of the capacity needs are located in the EU  convergence regions and in particular in the 
Member States that most recently joined the EU. However, it should be noted that some 
regions have additional pressures due to the presence of specific environmental assets (high value biodiversity areas) or cross-border a nd transboundary problems. These will also be 
particularly affected. Similarly private stak eholders in sectors that enter a crucial 
implementation phase or where compliance cost s are higher would also  be particularly 
affected.  
Vulnerability to climate change varies widely  across regions and sect ors in Europe. Economic 
sectors that are sensitive to climatic cha nges in terms of, for example, temperature, 
precipitation, storms, vector borne diseases, et c. are at risk of significant climate change 
impacts and will require substantial investments in adaptation measures. 
Extreme weather events such as heat waves and floods pose a di rect risk to the health and 
safety of people. Climate change  is happening so fast that many plant and animal species will 
struggle to cope. Warming of 1.5º C-2.5º C be yond today's levels would put as many as 20-
30% of plant and animal species at increased risk of extinction. 
2.5. The EU's right to act and justification  
2.5.1.  The EU's right to act on en vironment and climate policies 
The European Union’s environmental objectives are enshrined in Title XX of the Treaty on 
the Functioning of the European Union (T FEU). The most common legal basis for 
environmental and climate legislation is Ar ticle 192 of the TFEU which empowers the 
European Parliament and the Council to decide  what action should be taken by the Union in 
order to achieve the environmental objectives which are set out in Ar ticle 191 of TFEU. The 
Lisbon Treaty in particular strengthened the emphasis on climate action by making combating 
climate change an explicit part  of the environmental objectives. 
Article 11 of the TFEU
20 sets out the integration principle which seeks to apply environmental 
considerations across all policy areas. The ai m is to avoid otherwis e contradictory policy 
objectives that result from a failure to take into account environmental protection or resource 
conservation goals. 
2.5.2.  Necessity of EU action 
Most environmental problems have a transboundary or transnational nature and cannot be 
adequately solved by Member States alone w ithout international coope ration. EU intervention 
is required to establish adequate mechanisms  for dealing with thes e environmental problems 
and avoid coordination failures. 
Furthermore, environmental assets often have  a public good nature (environment, climate) 
and are unevenly distributed acr oss the EU. The obligation to preserve them calls for a 
consistent application of the prin ciple of responsibility  sharing and solidarit y. In this context, 
                                                 
20 Formerly Article 6 of the Treaty establishing the European Community 
 
21 Article 8 of the Habitats Directive explicitly links the delivery of conservation measures to the 
provision of EU co-financing.  
2.5.3.  EU added value of EU action of a specific financial instrument for Environment and 
Climate Action  
See Annex 6 for examples regarding the different  manifestation of the EU added value of a 
specific instrument for the Environment and Climate Action. 
"The EU budget should add European adde d value by maximising the effectiveness and 
efficiencies with which all publ ic expenditures in th e EU support the achi evement of common 
EU goals and not simply to add a (thin) layer of expenditures on top of those already financed 
directly by Member States."21 
The EU added value  of a specific instrument for the envi ronment and climate derives from the 
specificity of its approach and focus on these sectors, which makes it especially adapted to 
interventions on environment and climate as th e only instrument with funds earmarked for 
environmental protection and climate action.  
• By being the EU platform for exchange of  practice and knowledge-sharing  for 
implementing EU legislation and policy, LIFE  allows actors across the EU to learn 
from each other's experience in addre ssing specific environmental and climate 
problems more effectively and efficiently . LIFE attracts part nerships that would 
otherwise be difficult to set-up ensuring a more effective intervention than Member States' individual action by an increased pooling of resources and expertise ;  
• By assisting Member States that host the most valuable EU natural capital or are 
confronted with transboundary  or transnational environmental and climate problems, 
LIFE allows for a better  distribution of responsibility and solidarity  in preserving 
the EU environmental common good; 
• LIFE acts as a catalyst  to start-up action, providing one -off investment needed in a 
specific area, eliminating initial barriers  to the implementation of EU 
environmental and climate policy and testing new approaches for future scaling-up;  
• LIFE addresses gaps and ex ternalities, raises awaren ess and demonstrates the 
benefits of environmental and climate pr otection ensuring the sustainability and 
expansion of project results; 
• LIFE helps Member States and stakeh olders to accelerate and improve the 
implementaton of EU legislation by creating synergies across EU funds and 
national funds while levering additional  public and private sector sources; 
• Increased coherence of the EU intervention : A dedicated Environmental and 
Climate Action instrument allows the Commission to better shape priorities and 
ensure that resources are effectively used  for environmental and climate protection, 
selecting the best projects  across the EU. More homoge nous implementation of EU 
legislation is achieved thanks to the dissemination of best practices (e.g., methodologies that have been developed and now are widely applied, management 
plans etc); 
                                                
 
21 SEC(2011)867 final- Commission Staff Working Paper "The EU added value of the EU budget", p.54. 
 
22 • Gap filler and more effective central intervention : A specific instrument is more 
flexible and  finances projects that could not be  otherwise financed by other funds 
(e.g., projects managed by beneficiaries that  are non eligible u nder other funds);  
• A specific instrument would provide high visibility to EU environmental and 
climate action  bringing the EU closer to its citi zens, showing the EU's commitment 
to environmental and climate obj ectives and thus making those objectives more 
relevant ; 
• Bringing solutions to upcoming environm ental and climate challenges of EU 
interest : Stakeholders are often confronted with environmental problems for which 
no solutions have been found yet, and which, if not addressed at an early stage, will 
lead to higher costs.  
2.5.4.  Proportionality of the EU action 
Achieving critical mass : the calculation of the different  options has been based on an 
assessment of resources required to achieve cr itical mass for proposed objectives (especially 
regarding Integrated Projects, the development of multipliers, and dissemination of information/knowledge base). This analysis will be developed more in detail in section 5.  
Risk of overlapping with national action : the ex-ante evaluation concluded that national 
funding is generally inadequate and there is la ck of resources to compensate for the heavy 
reliance on EU fuding instruments. For exampl e, only 5% of project s funded under LIFE 
could have been carried out only with the natio nal support but later in time and on a smaller 
scale. Similarly, there is no or little alternative na tional funding for information campaigns or 
European wide NGO activity.  
3. O
BJECTIVES  
3.1. Objectives related to the co ntent of the LIFE Programme 
LIFE’s overall objective is to catalyse and leverage changes  in environmental and climate 
policy development and implementation by pr oviding solutions to achieve the specific 
objectives. In doing so, it should  contribute to the implemen tation, updating and development 
of EU environmental and climate policy and le gislation including the integration of these 
concerns into other policies. The specific a nd operational objectives as well as expected 
results are included in Annex 10.  
The potential beneficiaries of the LIFE Programme will be all Member States' authorities and 
public bodies at national, regional and local le vels, the private sector, including SMEs, NGO's 
and other non-for-profit organisatio ns and civil society groups.  
3.2. Objectives related to the design of the Programme  
The analysis of LIFE Programme included under se ction 2 has led to the definition of specific 
objectives for the design of the new instrument.  
Specific Objective  Specific problem 
1. Ensure a better alignment with EU policy 
priorities, including climate action Lack of strategic focus and planning 
Need for a better definition of role and objectives for the strand.  
Lack of critical mass 
 
23 Specific Objective  Specific problem 
Need to improve dissemination of knowledge 
2. Promote the funding of integrated projects and 
their share in LIFE projects funded Lack of strategic focus 
Lack of critical mass 
Challenges in ensuring complement arity and building synergies with 
other EU Funds 
3. Develop synergies a nd complementarity with 
other EU Funds, notably by establishing a structured 
relationship.  Challenges in ensuring complement arity and building synergies with 
other EU Funds. 
Need to better define role and objectives of the strands to avoid 
possible overlaps with other EU Funds  
4. Align selection criteria  with EU added value and 
solidarity/effort sharing  Avoid distributional allocation probl ems created by current national 
allocation system including lack of flexibility 
Simplify selection 
Predominantly Brussels-bas ed well known NGOs funded.  
5. Simplify and streamline the LIFE Programme Administrative burden crea ted by long selection process.  
 
3.3. Consistency with existing EU policies and strategies such as Europe 2020 
As shown above, the ex-post evaluation, the mi d-term evaluation and the ex-ante evaluation 
concluded that only a very sma ll proportion of projects could have been financed by other 
Funds (mainly by the CIP and the FP7 ) in the absence of LIFE. For LIFE Information & 
Communication, alternative sources fo r funding are almost non-existent. 
LIFE is also very much linked to other EU funds, such as Cohesion policy Funds ( ESF, 
ERDF, CF ), the Rural Development Fund ( EAFRD ) and the European Maritime and 
Fisheries Funds ( EMFF ). LIFE complements these Funds, si nce it finances specific types of 
activities and measures that ca nnot be financed under them but  are required to implement 
environmental legislation. Thus, LIFE works as a gap filler . The complementarity and 
coherence of LIFE with other EU funding prog rammes have been reinforced in the MFF 
Communication. In this sense, LI FE may become one of the main EU instruments to finance 
nature conservation (in areas where CAP cannot play a substantial ro le) and environmental 
sectors in "more developed" give n that these regions would have  limited choice of priorities 
under the new Cohesion policy instruments.  
• Cohesion policy Funds  (ERDF, ESF and Cohesion Fund) traditionally focuses on 
major investments whereas LIFE is more focused on management approaches, 
environmental restoration (especially for nature and ecosystems) and demonstration 
of new solutions to environmental problems with no or little market replication. 
Whereas under Cohesion policy a socio-econo mic benefit is required for obtaining 
funding, in LIFE the focus is on the e nvironmental benefit,  making it the only 
funding available for many purely restor ation projects. Furthermore, the MFF 
Communication has limited the choice of more developed regions and transition 
regions to few sectors (primarily energy efficiency and renewable energy). This 
implies that LIFE may become in many cases  the only possibility for these regions to 
carry out environmental projects with EU support.  
• CAP post 2012,  linking its objectives to EU 2020 becomes greener by supporting 
nature and biodiversity through direct paym ents, 30% of which are proposed to be 
conditional on three 'greening' measures aimed at benefitting the climate and environment. The award of all direct payments and certain rural development 
payments will continue to be linked to the respect of a number of baseline 
 
24 requirements relating to environment, anim al welfare and plant and animal health 
standards (cross-compliance). EAFRD will rein force its large scope of possibilities to 
finance the environment and sustainable management of natural resources and 
climate actions through a modified set of  rural development measures. Given the 
shared management characteristics of CAP funds, eligibility  criteria (e.g., 
beneficiaries, types of measures to be f unded) will still vary from Member State to 
Member State. LIFE offers funding opportuni ties for measures that cannot receive or 
that complement CAP funding. The typical  example is the testing of agro-
environmental measures that may at a late r stage be incorporat ed into national or 
regional rural development programmes.  
• The situation is similar for the European Maritime and Fisheries Policy , where 
coordinating mechanisms have been establis hed to ensure that measures (e.g., more 
sustainable fishing practices) tested will  be scaled-up by EMFP and to address 
environmental problems in the cont ext of Integrated Projects.  
In relation to all these funds, LIFE not only cove rs identified gaps (terri torial, procedural and 
so on) but also complements the new approach  that aims at establishing a structured 
cooperation for all funds available. LIFE  will address capacity, including absorption capacity 
needs . It will provide examples on how to ensure the coordination of different EU funds to 
achieve environmental and climate objectives us ing demonstrative Integrated Projects that 
could be replicated in other regions. LIFE will strengthen its catalytic  and leveraging  role by 
becoming a driver for mobilising other EU Funds  e.g., through Integrated Projects, becoming 
in the environmental field, a catalyst and “leader” (or “lead fund”) for the other EU 
instruments. LIFE also provides examples that can be scaled-up by Cohesion funding and 
CAP funds. A more coherent approach w ith other funds will be required. The MFF 
Communication established a structured rela tion by making a reference to "Integrated 
Projects" in the Common St rategic Framework (CSF).  
LIFE complements the research cycle of the FP7.  Horizon 2020  has become the major 
instrument for research and i nnovation covering all aspects of the life cycle from conception 
to the market. Major parts of the CIP have be en incorporated into the instrument. The new 
structure of the Fund mostly affects activit ies currently funded under LIFE Environment 
Policy and Governance component. The type of projects financed under this component can 
be summarised as follows:  
 
Table 2: Type of projects funded under LIFE+ Environment Policy and Governance 
Main purpose of activity   Type of activity 
Environmental investigation / collecting data on the extent of a problem / 
barriers to implementation / better ways of addressing environmental 
challenges  A.  Problem definition – 
measuring environmental 
impacts  
 Developing a new approach / tec hnique /process for monitoring of 
environmental impacts within a municipality or sector  
Develop / demonstrate and introduce methods and action plans for reducing 
environmental impacts (approach / manage ment system/ process / plans) to 
reduce environmental impact, informing policy. Mainly at the level of 
municipality. Sometimes with other national / international partners 
Stimulate behaviour change throu gh new market based instruments B. Improvements in 
implementing environmental 
policy  
 
Assistance in purchasing infrastructure / capital costs that reduces 
environmental impacts  
 
25 Set up public private partnerships (PPPs ) to show more effective ways of 
reducing environmental impacts  
Demonstrate good practice / produce instructions / tools / kits/ guidelines to 
industry on how to reduce environmental impacts  C. Improvements in the 
environmental management of 
economic activities, integrating 
environmental objectives  Pro-actively engaging with stakeholde rs (industry involved) to change 
behaviour  
D.  Developing particular 
solutions to environmental 
problems and improving 
compliance (eco-innovation) Testing and demonstrating / developing a technology / technique / process / 
product that reduces envir onmental impacts within a municipality or sector 
• As shown in Annex 8, most of these activ ities cannot be funded by other EU funds.  
However  Market-driven private sector innovation  seems to some extent equally 
well served by Horizon 2020. For this reason, LIFE Environment will no longer cover private sector-oriented eco-innovati on with a market replication purpose and 
both the LIFE Environment sub-programme and the LIFE Climate Action sub-
programme will focus more on policy impl ementation by public administrations. 
This implies more investment in type B and C projects, inter alia  through Integrated 
Projects. A structured cooperation will be established with the future Horizon 2020 
and the future Competitiveness and SME instrument to ensure adequate project pipelines. For example, ideas develope d under Horizon 2020 c ould be tested and 
demonstrated in the context of implemen ting specific EU legislation through a LIFE 
project.  
• The focus and scale of LIFE is differen t from the activities to be covered by Horizon 
2020 . LIFE develops specific solutions, approa ches or tools that are adapted to the 
local context or to a specific sector. These projects do not require large-scale investments, or involvement of various Me mber States, but rather they propose small 
solutions. This does not mean that these ac tivities do not have EU added value. On 
the contrary, EU added value derives from  the demonstrative significance of the 
project and its capacity to be replicated elsewhere w ithin the EU (e.g., by other 
municipality will similar characteristics or problems) or transferre d to other sectors.  
For being successful, the EU2020 Strategy also needs knowledge-base development 
and sharing of simple/small solutions that can be widely replicated.  
Connecting Europe will finance  projects that have already been identified in the MFF 
Communication (transport, energy an d ICT). These projects are of a very large scale and they 
could not be funded through LIFE. Furthermore, the objectives are very different from LIFE 
as they aim to combine market based instrument s and EU direct support to facilitate access to 
capital for huge investment needs. 
As to External Action Instruments, LIFE focuses on activities within the EU. Activities 
outside the EU are supposed to be anecdotic and only provided that action outside the EU is 
required to achieve EU environmental and climate objectives or to ensure the effectiveness of 
activities carried out within the EU. The benefici ary of the project has to be based in the EU 
and the bulk of project activitie s must be carried out within the EU. Therefore, no risk of 
overlap has been identified, and therefore no need for additional coordinating mechanisms 
with external action instruments beyond usual c oordinating mechanisms for project selection 
seems required.  
The MFF Communication indicates that the Commission intends to increase the proportion of 
climate related expenditure across the EU budge t to at least 20%, with contribution from 
 
26 different policies, subject to impact assessm ent. A sub-programme for Climate Action has 
been proposed in LIFE+ with 25% resources earmarked and specific objectives related to 
climate, and accompanied by result indicators. 
4. POLICY OPTIONS  
4.1. Description of the baseline as defined by the MFF Communication 
The MFF Communication has outlined the main f eatures of the future LIFE Programme. Two 
sub-programmes are proposed w ith a total financial envelope  of €3.2 billion (an around 45% 
increase compared to 2 007-2013 programming period).  
The main three changes in the Programme addre ss some of the problems identified in Section 
2.2.b. These changes are: 
• The creation of a Climate Action sub-programme  (€800 million , including procurement) 
with 25% of the Programme's resources and focusing on the following priorities: 
- Mitigation : Support for the reduction of greenhouse gas emissions. Actions for setting 
up pilot projects, which can be used to te st innovative approach es including through 
support to SMEs, to improve the knowledge base and to facilitate the implementation 
of the climate acquis. 
- Adaptation : Support to efforts leading to incr eased resilience to climate change. 
Actions to support the development or implementation of national/regional/local adaptation strategies. Actions enabling deci sion makers to effectively use knowledge 
and data about climate change impacts in particular for adapta tion related planning. 
- Governance  and Awareness : support for efforts leading to increased awareness, 
communication, cooperation and dissemination on climate mitigation and adaptation actions. Actions for awareness-raising amongs t EU citizens and stak eholders including 
on behaviour changes.  
This change addresses some of the problems identified regarding better focus and critical 
mass (problem 1).  
• The definition of strands for the Envi ronment sub-programme (€2.4 billion, including 
procurement ):  
- For the LIFE Biodiversity  strand, while still focusing on Natura 2000, biodiversity 
will move away from innovation and will focus on the development and sharing of 
best practices;  
- LIFE Environment  will focus on supporting the implementation of EU 
environmental policy by the public and priv ate sectors. The Co mmission proposed in 
the MFF Communication the initiative Horiz on 2020 which brings together future EU 
research and innovation funding programme s. LIFE Environment will therefore 
exclude those eco-innovation activi ties that overlap with this initiative (see in section 
3.2 "Consistency with other EU Funds"). 
- Finally, LIFE  Governance  becomes a single strand supporting the creation of 
platforms for the exchange of best pr actices, policy development and knowledge-
 
27 based decision-making, support to envir onmental NGOs, and promoting awareness-
raising, advocacy and dissemination of environmental information. 
This change addresses problem 2 (better definition of strands) and recommendations 
from the Ex-post and Mid-term evaluatio n regarding moving towards implementation.  It also 
addresses problem 3 (improve complementarity  and synergies ) by excluding identified 
overlaps with other EU Funds. In addition, th e new structure of the LIFE Governance 
component addresses problem 4 and recommendations from Mid-term evaluation and the 
Court of Auditors to bett er utilise project results and transfer of know-how.  
• The introduction of Integrated Projects  and their progressive incr eased share compared to 
traditional projects over the programming pe riod. Integrated Projects are designed to 
demonstrate the sustainable implementation of environmental and climate action plans 
relating to major EU legislation in these fiel ds. The Commission consid ers that Integrated 
Projects can play an essential role as a catalyst for achieving goals such as the protection and restoration of biodiversity and ecosystem s, effective management of the Natura 2000 
network, the promotion of environmental gove rnance, waste and water management, and 
mitigation and adaptation strategies. Integrated Projects will allow to effectively mobilise other funds for environmental and climate e nds, as availability of other funds for co-
financing of the developed action plans w ould be a pre-conditi on for obtaining LIFE 
Funds. This will allow the deve lopment of synergies between LIFE and other EU funds 
such as the Cohesion and Stru ctural Funds, funding from th e Common Agricultural Policy, 
or Horizon 2020, and also the coordination of environmental and climate expenditure from 
these programmes. Integrated Projects are larg er in size: for budget calculations purposes, 
it has been considered that Integrated Projects will require in average €10 million EU co-financing and will last about 5-6 years.  
This change addresses the recommendations  of the Ex-post evaluation, the Mid-term 
evaluation and the ex-ante eval uation to move towards bigger projects, thereby addressing 
problem 1 (critical mass) and problem 5 (simplification).  In addition, Integrated Projects 
and more structured cooperation through th e Common Strategic Fr amework addresses 
problem 3 (need to improve complementarity  and synergies  with other Funds). 
There is a great potential for synergies betw een environmental and climate objectives as 
projects can benefit multiple purposes e.g., climat e activities related to forests may bring co-
benefits for biodiversity and e .g. water projects may facilitate the transi tion towards a more 
climate resilient society and be linked to ad aptation. Similarly, Integrated Projects, by 
covering large territories in sectors such as Natura2000 and water, will deliver positive cross-benefits in terms of adaptation to climate ch ange. For example, Integrated Projects on the 
nature sector will help building ecosystem res ilience and Integrated Projects focusing on the 
implementation of the Water Framework Di rective and the Flood Directive or the 
Communication on water scarcity and droughts w ill have clear benefits for adaptation to 
climate change. 
This Impact assessment and the options belo w aim to address those aspects not already 
decided by the MFF Communication and focus on options for the implementation of a 
new LIFE Programme.  These options, which are presented in section 4.4 a nd are assessed in 
section 5, are: 
A. Options for strategic planning: top down versus bottom up 
B. Options for thematic concentr ation of Integrated Projects 
 
28 C. Options for allocation of resources  between different priority areas 
D. Options for geographical distribu tional impacts (national allocations) 
E. Options for funding activities und er Governance and Awareness raising 
F. Options for simplification G. Options for externalisation 
Box 6: Options for other operational as pects that have not been discussed 
Making support to a project conditional on the level of expected environmental benefits : As shown in Section 2, direct 
environmental benefit is very difficult to quantify for certain activities under LI FE. However, environmental benefits are 
evaluated as part of EU added value and contribution to EU  objectives. However, most focus is on demonstration value. 
Selection of financing instruments : Member States and beneficiaries expre ssed support for continuing with the current 
financial instruments and wanted evolution to include also Integrated Proj ects. During the evaluation and impact assessment, 
the possibility of using innovati ve financial instruments was an alysed and discussed. Member States and beneficiaries were 
reluctant to move towards innovative fi nancial instruments. Instead, LIFE c ould focus on testing and developing new 
financial instrument (e.g., taxes or biodive rsity banking) that if effective could be widely adopted in the EU. For this reason , 
the MFF Communication mostly refers to action grants, operatin g grants for NGOs and public procurement. Nonetheless, as 
shown in Option A2, if innovative financia l instruments under debt and equity work  properly for envir onmental and climate 
purposes, the work programmes would allow diverting part of the funds allocated to grants towards equity and debt 
instruments.  
4.2. Development of the policy options 
All the different evaluations ha ve highlighted that a major problem of the LIFE Programme 
was the lack of strategic focus.  This is especially relevant for the Environment Policy and 
Governance, and the Informational & Communication strands. In addition, environmental and climate related needs are evolving and the Programme should be able to provide timely answers to those needs: a clearer focus on areas where LIFE could make a difference was needed. 
However, stakeholders did not support a limitati on in the thematic areas covered, although 
they did support an increased focus on implem entation and integration of environment and 
climate objectives into other policies. 
4.3. Which options have been discarded and why? 
(a) "Zero Option": Disconti nuation of the LIFE Programme
22 
This option implies the discontinuation of LIFE with spending on the environment and 
climate entirely reliant upon Member States' ac tivities and other EU funding instruments (e.g., 
Cohesion policy, Common Agricultural policy) . Only support for policy implementation 
through public procurement would be retain ed. The full assessment of the zero option, 
including different types of interv ention is provided in Annex 8.  
The MFF Communication proposes major reform s in the main EU funding instruments. 
However, these changes do not address all driv ers for environmental and climate challenges 
outlined in Section 2.1. For this reason, the M FF Communication foresees the continuation of 
the LIFE Programme:  
                                                 
22 Detailed assessment of the Zero option is provided in Annex 8. 
 
29 1. Institutional weaknesses, in relation to capacity (administrative capacity and 
absorption capacity) and integration  
The MFF Communication has laid down the basis for the coordination of all major EU Funds 
to ensure a more effective functioning and ach ievement of EU objectiv es. Given the current 
low uptake of funds for environmental and clim ate objectives (see last  Cohesion report), the 
system could be reinforced with examples of  strategic frameworks for environmental and 
climate intervention. These will demonstrate to regional and national au thorities the benefits 
of investing in the environmental sector and how to mobilise resources by coordinating with 
different responsible authorities and stak eholders, ensuring the most cost-effective 
implementation of major environmental legi slation. It would also  demonstrate that 
complementarity of EU and domestic funds and integration of environm ent and climate into 
other policies is possible in practice and delivers sustainable results.   
Without LIFE and this new feature, the prob lem of absorption capac ity in the area of 
environment may continue despite the Comm on Strategic Framework, and integration of 
environmental concerns in practice may fail again.   
2. Activities and measures no t covered by other funds linked to implementation, 
innovation and information sharing:  
Each EU fund focus on a series  of activities and m easures. As shown in the assessment of 
Zero option in Annex 8, LIFE covers certain ac tivities that are not su fficiently covered by 
other funds. 
- Specific activities for nature conservation and biodiversity : some two thirds of the estimated 
costs of running the Natura2000 network relate to  management activities, which are largely 
ineligible for funding under other funds.  It is  in these management activities where most 
needs are concentrated and where best practices and demonstration of new approaches is most 
required. In addition, Natura2000 enters its cr ucial implementation phase. The challenge of 
meeting the Biodiversity strategy targets will require the Natura2000 network to move from 
the site-based approach to the network appro ach requiring a more stra tegic and programmatic 
approach to funding which is largely dependant  of public funds. The ab sence of these funds 
most probably may lead to faili ng to achieve N2000 objectives.  
- Specific activities linked to environmen tal demonstration ac tivities and innovation : Other 
EU funds will also cover major environmental funding needs but they do not cover all the 
demonstration activities that are required to fight against the drivers to environmental 
problems identified in section 2.1,  in particular to focus on the environmental benefit. The 
Environmental activity least ca pable of being funded by alte rnative instruments is the 
preparation of new or revised management pl ans and capacity building for the improvement 
of environmental policies, as well as the de velopment of new envi ronmental policies and 
solutions.  
LIFE also carries out demonstration solutions an d best practice activitie s with a local/regional 
focus on implementation. Some solutions are of ten developed with th e sole purpose of 
addressing a particular problem faced by a local authority, although it may have no 
commercial value. LIFE would have a more im portant role to play in financing such 
solutions, which will play a significant role in shifting towards a re source-efficient economy. 
These more local activities are also needed, especi ally to deal with environmental assets that 
are only located in a spec ific region or country.  
 
30 - Specific activities linked to knowledge sharing and awareness : This aspect is  not covered by 
other instruments where dissemination and awaren ess raising is not co mpulsory. There is no 
other alternative EU  instrument to fund projects aiming to raise awareness amongst a broad 
set of stakeholders specifically about environmen tal issues at a local a nd regional level, or to 
bridge the ‘communication gap’  between policymakers at the European level and citizens. 
The Mid-term evaluation also f ound that communications activi ties were often ranked low as 
a priority by most Member States, suggesting that alternatives for funding these type of 
activities remain low. 
- Specific activities to enhance governance and NGO support funding : none of the EU 
funding instruments includes objectives specif ically aiming and enhancing environmental 
governance at EU level since they mostly have a national or regi onal focus. Yet, the EU needs 
a balanced decision making process where all inte rested parties are able to participate. In 
absence of a specific EU funding programme  aiming at empowering civil society for 
participating in the decision making process at EU  level, LIFE offers the only possibility to 
fight against regulatory capture in the e nvironmental field. Without funding from the 
programme through Operating Grants, NGOs w ould need to substantially reduce their 
activities either because they l ack the direct means for continui ng them or because they lose 
their internal supporting capacity.  
Some NGOs, to avoid any risk or allegation of non-independence,  refuse all subsidies from 
governmental sources and all pr ivate sponsoring. Only very la rge and interna tional renowned 
NGOs can afford to limit their resources to membership contributions and own 
merchandising.  
The removal of operating grants would severely hamper NGOs' ability to contribute to policy 
development and implementation, awareness rais ing and to identify problems and potential 
solutions with regards to environmental polic y. The absence of NGO activity leads to major 
costs. Examples of such costs are the risk of unbalanced influence by interested parties, 
reduced effectiveness of polic y through lack of NGO particip ation in the process, and 
increased costs of consultation as further described in Annex 8.   
3. Procedural, territorial and thematic  gaps not covered by other funds  
Due to shared management characteristics of mo st Funds, priorities ar e specified at regional 
and national levels and are adapted to their spec ific needs and characteristics. This implies 
that in some cases, e.g., certain stakeholders are not eligible for f unding. As shown above in 
section 3.3, the proposal for Cohesion policy may limit the choice of more developed regions 
and transition regions to few s ectors (primarily energy efficien cy and renewable energy). This 
implies that LIFE may become almost the only  possibility for these regions to carry out 
environmental investments. This is an important  element of solidarity and effort sharing.  
Finally, there are some environmental themes that tend to be more neglected by other EU 
Funds. For example, soil, chemicals, noise, I PPC, environment and health among others, are 
sectors that do not receive much focus under ot her EU instruments, except when there are 
clear economic benefits or the focus is on research (e.g., modelling). Although Horizon2020 
will put more emphasis on green chemicals, res ource use or climate change, as seen above, 
specific demonstration activities to improve e nvironmental performance of these sectors or 
the effective integration of environment into the activities of economic operators in these 
particular sectors is not c overed by other EU schemes.  
 
31 The quantified environmental and socio-economic benefits  of the current LIFE+ 
Programme have been included in Section 5.1 a nd are developed in detailed in Annex 8. One 
could assume that the costs of non continuation of  LIFE would be at least equivalent to the 
benefits obtained under the current Regulation (i .e., €600 million a year which extrapolated to 
the baseline could represent €750-1,000 million a year).   
It is very difficult to obtain accurate informati on on the social costs of no action. In particular 
because data on social, especially employment benefits, from the LIFE Programme has been 
very difficult to gather, since projects do not traditionally collect da ta about employment 
benefits. For this reas on, social costs of no  action have only been  estimated based on the 
social benefits of the current LIFE Program me summarised in section 5.1. Only anecdotic 
evidence has been gathered showing the positive employment impacts of LIFE. For example, in the Extremadura Region a LIFE project was the catalyst for the creation of the Region 
environmental department going from 10 people to 200 in ten years and through different 
LIFE projects.  
As to health aspects, these again are estimat ed based on access to clean water and air. As 
mentioned in section 5.1 indicators of envir onmental quality have be en excluded because of 
the difficulties to monetise environmental benefits. However, as shown in Annex 7 and in 
Section 5.1 substantial health impacts aff ecting 12 million people are expected under the 
current Programme. Therefore in absence of the LIFE Programme one could assume that 
these benefits would be lost. However, there are too many assumptions, such as the expected 
impacts derived from Integrated Projects or the po tential benefits derived from an increase in 
investments in urban and energy efficiency  under Cohesion policy (and how this could 
compensate for the loss of LIFE as proposed  in the MFF Communica tion, especially in 
relation to Integrated Projects)  as to be able to provide a more detailed assessment.  
(b) A separate Instrument for Climate Action 
Reflecting the climate challenge (adaptation and mitigation) in the EU budget is crucial. The 
LIFE+ Regulation has so far served as the lega l base for environment expenditure, including 
for climate action, which represented some  14% of the LIFE Programme. The Commission 
therefore considered whether a separate legal base for Climate Action  would be 
appropriate. There were also discussions ab out creating large scal e separate funds and 
instruments to deliver EU support in Biodiversity or Resource Efficiency areas .  
These options were discarded si nce they would rather increase  the EU administrative costs 
and increase the administrative burden for reci pients. The College has decided upon a single 
legal basis for both Climate and Environment sin ce this approach will exploit synergies and 
co-benefits between the tw o programmes to the full. 
(c) A Programme with a restricted thematic scope ("Biodiversity and Climate Action Option") 
The impacts of such an instrument would be much lower than those of the current LIFE+, 
thus significantly limiting the Programme's im pact on EU environmental policy. This option 
was discussed with stakeholders and met w ith strong opposition. In general, stakeholders 
were opposed to any limitation in the thematic scope of the Programme.  
4.4. Description of the options ret ained for further assessment 
The options described in this section cover a ll sub-programmes unless it is specifically stated 
differently. The first option always refers to the
 baseline , i.e. aspects as already decided by 
 
32 the Commission in its MFF Co mmunication. Stakeholders' opi nions regarding different 
options are provided in Section 5.  
A. Options for strategic planni ng: top down versus bottom up 
As shown in Problem 1 described in secti on 2.2.2(a), unlike other EU centrally managed 
funds, LIFE does not have an annual work programme or any mechanism that allows 
establishing priorities and allo cating resources among different types of interventions to be 
able to meet specific targets. This makes it impossible for the Programme to drive demand by reducing the number of priority themes and activities on which the Programme should focus.  
The MFF Communication emphasises that the Co mmission intends to increase the financial 
share of Integrated Projects over the life- time of the Programme. This requires the 
Commission to stir up the process. However, al l stakeholders (Member States authorities, 
private and public sector benefi ciaries, and NGOs) were opposed to focus the Programme ex-
ante on only few environmental themes and to setting out annual priorities. For this reason, 
the different options to set priorities discu ssed below take these concerns into account. 
• Option A1: Baseline- Bottom up approach
 
The MFF Communication does not sp ecify the method for priority  setting and allocation of 
resources. Therefore, it is assumed that the "bottom up" application practice for projects under 
the LIFE+ Programme will continue. Thematic priorities are set for the entire programming 
period, and could be included in the Regulation, as per Annex II of current LIFE+ Regulation; 
therefore the list of  eligible policy themes could be d ecided in cooperation with the Member 
States. Under this option, an annual call for proposals would continue  including lists of 
indicative favoured actions within  the twelve priority themes included in the Regulation, but 
without being able to restrict the themes. No limitations regard ing the thematic areas in which 
Integrated Projects are to be financed would be done.  
• Option A2: A top down-approach  for all types of projects  (with a more flexible top-
down applied to traditional projects and a rigid top-down approa ch to Integrated 
Projects)   
Under this option, the Commission develops multiannual (2-3 years) work plans where it 
specifies thematic priorities on which projects are needed linked to the achievement of targets 
defined in relation to the Programme (see expect ed results and outputs in Annex 10). This will 
allow the Commission to drive demand in all t ype of projects giving emphasis to projects 
matching the thematic priorities. The top-down approach will also apply to Integrated Projects, which will only focus on a limited number of sectors as defined in the work plans.  
However, priorities would be non-exhaustive  (proposals can be submitted in themes not 
included in the work plan) so as not to ne glect particular environmental sectors (such 
aschemicals or noise) not covered by any othe r EU funding instrument. This represents a 
compromise between the flexibil ity of the bottom-up approach a nd the need for more strategic 
focus. It would require as well the alignment of selection criter ia, and in particular EU added 
value, with the priorities set in the work pr ogramme. Applicants shoul d know that all things 
equal, priority would be given to projects falling under the priorities set in the work plan. This 
non-exclusivity will also allow the programme to react to new challenges that might arise in 
sectors not included in the work plan. 
The priorities would be reflecte d in the annual calls for propos als and further specified or 
 
33 tailored by the Commission, if required. Given that  it would be a rolling plan, the annual calls 
will be able to make corrections regarding the pr iorities as per the targets. This would also 
allow, for example, for determining whether in  one year more resources should be dedicated 
to specific activities within a priority sector. The op tion of using innovative financial 
instruments should also be kept in order to ma ke use of the potential  opportunities from the 
new instruments (equity and debt) en visaged to be set up across the EU. 
The mid-term evaluation proposed these plans to  be annual. However, discussions with the 
stakeholders made clear that potential applicants needed some stability in the priority areas for 
action to be able to plan, prepare and submit proposals. For this reason, these priorities will 
remain constant for 2-3 years.   
• Option A3: An approach combining the top- down approach for Integrated Projects 
and bottom-up approach for all other types of interventions  
Under this option, the Commission will only a pply the top-down approach to Integrated 
Projects by limiting ex-ante their thematic focus to on a number of sectors in the Environment 
sub-programme until targets are achieved. The bottom-up approach, i.e., demand open for 
submitting proposals in any environmental sector, w ill continue applied to traditional projects. 
No 2-3 years work plans would be  elaborated and no priority them es will be identified, beside 
the focus of Integrated Projects.  
B. Options for thematic concen tration of Integrated Projects 
Under the current LIFE+ Progra mme, few projects could be considered as 'Integrated 
Projects'. They are essentially funded under th e Nature & Biodiversity strand and concern the 
sustainable management of Natura 2000 areas. 
• Option B1: Baseline- No thematic concentration of Integrated Projects  
In the MFF Communication, it is considered that In tegrated Projects can pl ay an essential role 
as a catalyst for achieving goals in areas such as  the protection and restor ation of biodiversity 
and ecosystems, effective management of the Natura 2000 network, the promotion of 
environmental governance, waste and water manage ment. There is no sect oral restriction for 
Integrated Projects. 
Under this option, Integrated Projects will be allowed in all areas  where such an approach is 
possible. Since Integrated Projects aim at implementing environmental and climate action 
plans, only those sectors where EU legislati on requires some planning or programming (i.e., 
programmed-base Directives) coul d be considered for Integrated  Projects funding. This is the 
case for Prioritised Action Frameworks under the Habitats Directive, a River Basin 
Management Plan under the Water Framework Di rective, Waste management plans under the 
Waste Framework Directive, Air pollution abatement plan to meet the air quality 
requirements of the CAFÉ legislation and th e Programme of measures under the Marine 
Strategy Framework Directive.  These sectors are also those th at require a planned and large 
territorial scale action and have been identifie d as suitable for Inte grate Projects funding.  
Urban has been embedded into the Air sector a nd Integrated Coastal Zone Management into 
the Water Framework Directive (which covers transitional waters) and the Marine Strategy Directive (which covers Coas tal waters). Integrated Projects in the Climate Action sub-
programme will be allowed both in the areas of  mitigation and adaptation and could be used 
for the implementation of national, regional, cr oss-regional or local adaptation or mitigation 
 
34 strategies, national or cross- border action plans on specific themes such as on peat land 
restoration or forest protection (e .g. Restoration of ore mountains). 
• Option B2: Thematic concentra tion of Integrated Projects   
Given the limited resources of LIFE and the cr iticism regarding lack of strategic focus, 
Integrated Projects could concentrate on specific  sectors. The criteria used for selecting 
sectors from those mentioned above  (i.e., those where an integrat ed approach is possible) are 
sectors (1) where implementation and integrat ion problems are more significant, (2) more 
linked to achieving Europe 2020 resources e fficiency targets and direct environmental 
benefits (see section 2.2.2(a)); and (3) have mo re possibility to link to, and therefore mobilise, 
other EU funds.  
Additional criteria could be the maturity of the sector (i.e., the development of these plans and 
programmes is required by the legislation and are largely already in place), or the success of 
the environmental sector in LIFE (as reflec ted in demand and success rate as per data 
provided in section 2.2.2(a)). The stakeholders' opinion could also be used to discriminate 
between one or another sector.   
Transboundary and cross-border elemen ts do not play an essential role in defining the priority 
sectors although cross-border cooperation should be promoted where relevant (e.g., water and 
nature). However, it should not be forgotten that Natura2000 needs are more regional and 
what is more important is to obtain examples at the regional level moving from the current 
site-specific approach to the network approach  starting at regional level and moving towards a 
pan-regional and pan-EU approach. The same applies for waste, where needs are more localised at regional level.  
Applying these criteria,  two sub-options coul d be envisaged:  
o Sub-option B2a: Thematic concentrati on on 3 sectors: Natura2000, water, waste;
 
o Sub-option B2b: Thematic concentrati on on 4 sectors: Natura2000, water, waste 
and air.  
These sub-options only apply to the Envir onment Sub-programme. The Climate Action sub-
programme is considered sufficientl y concentrated in two sectors.  
C. Options for allocation of resou rces between different priority areas 
As seen in the description of Problem 1 in  section 2.2.2(b), earmarking of resources has 
played a significant role in providing a relative strategic focus to the LIFE Programme on 
Nature. The MFF Communicati on recognises this and has upgraded the strand “climate 
change” of the LIFE Environment Policy and Governance component into a specific sub-
programme with earmarked resource s. Nothing is said about allocation of resources within the 
specific components of the Environment sub- programme. However, in the current LIFE+ 
Programme, and traditionally in all previous LI FE Programmes, 50% of resources allocated to 
projects were earmarked for Nature (and in LIFE+ to Biodiversity as well). Two options could thus be envisaged: 
• Option C1- Baseline – the MFF Communication allocation
 
Allocation of resources would follow the M FF Communication with 75% of the budget for 
the Environment sub-programme and 25% to th e Climate Action sub-programme. Under this 
 
35 option, no additional pre-allocation of resources will be carried out among the various 
components within each sub-programme. 
• Option C2: The MFF Communication allo cation and 50% allocation of the 
Environment Sub-Programme  funds to Biodiversity  
This option involves the pre-alloca tion of resources for specific EU priorities, in particular 
50% for Biodiversity in the Environment sub-progr amme as has been the case in the previous 
LIFE programmes.  
D. Options for geographical distributio nal impacts (national allocations) 
Under the current LIFE+ Regulation, indicative a nnual national allocations  are established in 
order to ensure a proportionate distributi on of projects for the period 2007-2010 and 2011-
2013 based on two pre-defined crit eria related to population, a nd nature and biodiversity. As 
seen in Problem 6 described in section 2.2.2(a ) they have not led to a more balanced 
geographic distributi on of projects.  
Introducing a minimum number of  countries that would need to participate (as opposed to 
simple geographical balance) was not considered  as an option retained. Participation of a 
minimum number of countries is generally linke d to the concept of EU  added value (e.g., see 
the FP7). It was discussed during the ex-post ev aluation and rejected because it would imply 
changing the focus of LIFE, which is local/reg ional solutions. In addition, EU added value 
under LIFE is more linked to the demonstration value of a project, which does not necessarily 
derive from the participation of  several Member States. Furtherm ore, it would be contrary to 
the principle of responsibility sharing and solidarity, especially  for nature and biodiversity: 
many nature conservation projects focus on habita ts or species of EU interest that are endemic 
to a region, island or Member State. Imposing a minimum number of countries as one of the 
eligibility criteria would undermin e the effort sharing and solid arity dimension. Nevertheless, 
EU added value for NGOs operating grants does currently incorporate the obligation to be 
active in at least 3 Member States. 
• Option D1: Baseline- All projects selected on merit  
The MFF Communication indicates th at projects will continue to be selected for their EU 
added value and potential for transfer of know-how . This implies that a ll types of projects 
(traditional and Integrated) would be selected acco rding to specific selection criteria similar to 
today, which concentrate on technical and fina ncial coherence, and EU added value (i.e., 
demonstration and replication potential, innovative characte r, contribution to EU policy 
priorities etc). No geogr aphical key would apply.  
• Option D2: All projects selected on mer it but ensuring geogr aphical balance for 
Integrated Projects  
Different selection criteria would apply to traditional and Integrated Projects.  
Traditional projects, which are mostly aimed at  developing multipliers, would be selected on 
merit only, as described above in option 1.  
As for Integrated Projects, a system to ensure  geographical balance would be established, and 
would be adapted to the relevant sectors where su ch projects are possible. Integrated Projects 
aim to develop capacity in Member States and to  contribute to solidarit y and effort sharing. A 
 
36 prioritisation list could be established ensuring that Member States which have benefited from 
Integrated Projects one year are considered le ss favourably for the next call for proposals. An 
additional distributional elemen t for Natura2000 Integrated Pr ojects could be that all bio-
geographical regions are covered.  
• Option D3: Traditional projects selected on merit only and national allocations 
(specific amounts per MS) for IP for the whole programming period  
Under this option, traditional projects would be  selected on merit only, as per option D1. For 
the reasons indicated under opt ion D2, a system of indicat ive national allocations for 
Integrated Projects would be established for each Member State and each sector.  
For Natura2000, criteria similar to those used under the current LIFE+ Re gulation (population 
and % of the territory declared Natura2000) co uld be used. For water and waste, population 
could still be used as criteria and other specifi c criteria could be established. For example, for 
water the criteria could be linked to km2 of river basin district in  the territory of a Member 
State.  
These indicative allocations would be calcula ted and applied for th e entire programming 
period instead of annually as today to allow mo re flexibility in the selection procedure. 
E. Options for funding activities u nder Governance and Awareness raising 
As shown in Problem 4 described in se ction 2.2.2(b), although some improvements are 
currently made for increased dissemination of information and project results, these are not 
sufficient. The MFF Communication takes an additional step by proposing a combination of activities:  
− funding NGOs;  
− enhanced project communication/traini ng activity, supported by programme level 
synthesis of project results and dissemination. 
The MFF Communication remains ambiguous as to whether these activities include specific 
information and communication projects. As s hown in section 2.2.2(a), the success rate of 
information projects has been lo w compared to other components. 
• Option E1: NGO funding, Commission communication activities and 
communication/dissemination obligations for projects  
Funding to support the operation of European environmental NGOs: NGOs make a 
necessary contribution to good governance by partic ipating in policy development, including 
by knowledge-based input, contri buting to better implementa tion, raising awareness and 
acting as channels between citizens and d ecision makers. Continued support to NGOs is 
included in the MFF Communication. A future Pr ogramme will seek to address the functional 
weaknesses identified in the review process. 
Enhancing project communication activity : Adopting a stronger strategic approach, 
including the generation of multiplier effects, will  also be translated into greater responsibility 
on project co-ordinators for identifying and communicating findings w ith target users and, 
when necessary, providing training to relevant stakeholders.  At the same time, networks of 
similar projects around priority  themes will be promoted.  
 
37 • Option E2: NGO funding, Commission communication activities and 
communication/dissemination obligations for projects, and specific Communication 
campaigns financed through grants  
Under this option, in addition to  the activities mentioned above, specific projects  funded 
through action grants  (similar as under the current In formation and Communication strand) 
will be possible to support selective activities  defined by the policy units where awareness 
raising, information sharing or governance-related as pects are key issues for a particular 
policy. These information projects could also be initiated to take on the synthesis and 
dissemination activity of results from the ‘tra ditional’ projects under selected themes and 
promote the dissemination of knowledge base. Projects will also aim at developing and 
deploying adequate tools for information- handling and active dissemination and for 
preparation of training and provisi on of toolkits for stakeholde rs. Finally, these projects would 
also focus on best practices on enforcement and compliance implementation plans. 
F. Options for simplification 
As seen in Problem 5, the Commission has alre ady undertaken different measures to simplify 
the selection procedure for projects. However additional simplification measures are required 
to reduce the administrative burde n for applicants and beneficiaries, as well as management 
costs for the Commission (these are dealt with below under Sec tion G). While simplification 
of procedures is generally recognised as ne cessary, this can be re ached through different 
measures. These are presented as different optio ns but they do not exclude each other. Rather, 
they can be combined to increase effectiveness gains.  
• Option F1: Baseline- On-line tools and larger projects  
On-line tools:  The MFF Communication does not refer to any specific “tools” for the 
simplification of the LIFE Pr ogramme. However, as mentioned in section 2.2.2(b), in the 
current programming period, a new IT tool calle d eProposal has been de veloped and could be 
used from 2012 onwards. Applicants will be able  to submit their application online and thus 
costs of paper submission and the previous step  of submission to the Member States will be 
avoided. The system will allow identification of errors during the submission process, thereby reducing the number of applications excluded in the first phase of selection. It will also allow 
calculating and aggregating relevant data s ubmitted with the proposal, thereby improving 
monitoring of project results.  
Moving to larger projects:  The MFF Communication includes as a simplification measure the 
progressive phasing in of large proj ects, in particular Integrated Projects. It is expected that, 
by the end of the Programming pe riod, two-thirds of resources within the Environment sub-
programme will be allocated to Integrated Proj ects largely decreasing the number of projects 
managed (from 230 projects selected annually to 115 in average going  below 100 projects by 
the end of the programming period). This will  reduce management costs for the Commission 
(see below options G). In addition, applicants th at would submit several smaller projects as 
different implementation phases will now be able to submit only one proposal which is 
expected to decrease submission costs over time. 
• Option F2. Baseline + New selection proced ures: 2 stage proce dure and simplified
 
reporting for Integrated Projects, multi-annual selection for NGOs  
2-step selection procedure and reductio n of reports for Integrated Projects : Under this 
system, there will be only one call for proposals for all strands and types of projects (e.g., 
 
38 organised in lots). Given the characterist ics of Integrated Projects, one option for 
simplification is to introduce a 2-step approach  for the selection. The proposal for Integrated 
Projects would consist of a short concept pape r (such as maximum 20 pages compared to the 
100-200 pages for traditional projects) submitted t ogether with the environmental action plan 
that it is supposed to be implemented through th e project. In the concep t paper, the applicant 
outlines the measures of the environmental acti on plan to be financed by LIFE Integrated 
Project, with milestones for the implementa tion phases, and a global estimated budget per 
cost category for the whole project duration. At the same time, the applicant would submit the 
underlying financial plan, establishing the gene ral framework for intervention by different 
funding instruments. Only if the concept pa per is deemed sound, wo uld the applicant be 
invited to submit a more detailed proposal an d more analytical budget covering the first 2 
years of implementation within  the overall budget frame. No tice that the average life of 
traditional projects is 4 years; the proposal for Integrated Projects will only cover in detail 2 
years and therefore it is expected to be relatively simpler than a proposal for a traditional project.  
Reporting and re-programming  will be based on a two years cycle. Six months before the 
end of the first phase, a report will be sent to the Commission together with a new detailed 
plan and budget for the next phase for agreem ent with the Commission. This cycle will be 
repeated until the end of the project. The paymen t schedule will also be adapted to follow the 
periodic planning to ensure a constant cash flow  to the project. The coordinating beneficiary 
will have a large margin of freedom in adapti ng its project. Only critical changes should be 
subject to the prior Commission approval.  
Multiannual selections for NGO operating grants : There seems to be general support for a 
change to multi-annual framework partners hips instead of an nual grants.    
• Option F3: Baseline + Outputs and results pa yments vs. lump-sums, ineligibility of 
certain costs  
Under this option, more use of lump sums  would be done. The clearest example is application 
of standard EU per-diems for travel costs, and standard staff costs (per staff category) 
provided there is an agreement at Commission level of what the standard staff cost should be.  
An option of payment based on outputs  could be examined. In fact, LIFE already has 
developed output indicators and the activities to be funded are constructed around Programme 
outputs. Under this option, payments woul d be linked to the specific outputs.  
Result-based payment schemes  were considered in early stages of the process and not 
adopted because of the risks asso ciated to the nature conserva tion projects (nature is indeed 
unpredictable) and information campaigns. The experience of e .g., DG EMPL with the 
European Social Fund could be closely followed to identify areas in the future where such 
payment scheme could be adopted. If successful, these could be incorporated in the mid-term 
review of the Regulation.   
Ineligibility of certain costs:  In order to reduce the administrative burden linked to the 'real 
costs' management of grants, both on the side  of the Commission and of the beneficiaries, 
eligibility of costs for which accurate reporting and monitoring are difficult, such as personnel 
costs or VAT, could be restricted. 
G. Options for externalisation  
This section analyses the different management  options for the LIFE Programme taking into 
account the conditions laid down in the MFF Communication (baseline). In this 
 
39 Communication, the Commission announced that  the LIFE Programme should remain 
centrally managed, but that management tasks could be largely delegated to an Executive 
Agency. The extent, conditions and terms of the de legations will have to take into account the 
need of the Commission to mainta in strong policy links as regard  Integrated Projects. These, 
as the simplification measures mentioned under Option F, also aim at reducing management 
costs of the Programme (currently at 6%). 
Whilst some aspects of this delegation were fi xed in the MFF Communication – in particular, 
that it should be an existing Executive Agency  - other details on the extent, conditions and 
terms of the delegation were left open and are dea lt with in this Impact Assessment, especially 
how to ensure strong policy links as regard Inte grated Projects. Options are described below. 
• Option G1: Baseline-  Externalisation  
Under this option, most of the management task s carried out by the Commission in relation to 
selection and monitoring of LIFE projec ts and NGOs operating funding, as well as 
communication/dissemination activities (inc luding gathering and disseminating lessons 
learned to stakeholders) will be transferred to  an existing agency, for both traditional and 
Integrated Projects. The governance, supervis ion and evaluation of the Programme would 
remain within the Commission.  
The Commission is currently assisted by teams of external sub-cont ractors that provide 
support in selection, technical  monitoring, and communication a nd information workshops at 
national level. Two sub-options are therefore possible:  
o Sub-option G.1.a. Externalisation w ithout replacing tech nical assistance  
Only the management tasks directly carried  out by the Commission would be externalised 
(i.e., evaluation of mid-term and final re ports, financial monitoring and payments, 
correspondence with beneficiary, visits to proj ects once in their life time). External sub-
contractors will still be needed to carry out support activit ies (e.g., technical monitoring, visits 
to all projects every year, ev aluation of progress reports). Ag ency staff would be able to 
concentrate in extracting information from pr ojects and transferring this to the Commission 
through structured communication channels. 
o Sub-option G.1.b. Externalisation replacing technical assistance  
In addition to the tasks described above, the Ag ency staff would replace the tasks currently 
undertaken by external contract ors under technical assistance. This would require a broad 
range of geographical and thematic expertise, as  well as full coverage of  the EU languages.  
• Option G.2: Hybrid solution: externalisation of traditional projects and keeping 
Integrated Projects within the Commission  
Under this option, the manageme nt of traditional projects and operating grants for NGOs, 
would be externalised to an existing agency. Activities to remain within the parent DGs 
would include the governance, supervision a nd evaluation of the Programme, as above. 
The management of Integrated Projects for e nvironment is retained within the Commission. 
The main reasons are to secure integration of project results into EU policy, to ensure Integrated Projects are desi gned in the most adequate wa y and developed under close 
monitoring, and liaison with Co mmission thematic units.   
 
40 5. ANALYSIS OF IMPACTS  
5.1. Introductory remarks about impacts of  the current LIFE+ Regulation and the 
Baseline derived from the MFF Communication 
Methodology and its limits 
The environmental benefits of the current LI FE+ Regulation, including climate have been 
examined using a series of indicators reflectin g the nature of the projects, and as far as 
possible, consistent with the indicators used  in the ex-post assessment of the LIFE III 
Programme. The relevant estimates of the valu e of the environmental impacts have been 
sourced from the literature. Project beneficiarie s were asked about the impacts of the current 
projects at the end of the project, and then fi ve years after the projec t end. The results were 
grossed-up based on the share of tota l project investment reported.   
The reported environmental impacts for Nature & Biodiversity  have been converted into 
an estimated economic value using published ex ternality values for eco-system services 
associated with different types of habitat. Thes e are applied to estimates of the environmental 
impacts by habitat type as repor ted by projects. Given the lack  of detailed knowledge of the 
individual projects (e.g. the leve l of quality of the ecosystems within these projects) and the 
related eco-system benefits, the es timates provided in Table 1.3 of Annex 7 should be taken as 
providing only an approximate estimate of the economic value of the environmental benefits. 
The externality values are based on case studies of the economic value of eco-system services. 
These cases include the impacts of substa ntial changes in eco -system services. 
Three habitat types are responsible for most of the benefits calculated as they are often the 
main focus of valuation studies: freshwater hab itats (accounting for half of the benefits), and 
coastal habitats and forests each accounting for around 20% of benefits. The estimated value 
of benefits takes a conservativ e approach, assuming the benefits  are between 5% and 15% of 
the published externality values  to provide an i ndicative estimate only. This indicates an 
annual benefit of between €400m and €1,200m. It is  extremely unlikely that the benefits are 
less than this, but likely that benefits in fact exceed this range. On an annual basis, taking the 
low estimate, the benefits represent twice the to tal investment cost of the projects. Using the 
higher estimate, benefits are six times the inve stment cost. This excludes any economic or 
social impacts (described below). The benefits  are also expected to last for many years 
(although management costs will be required). 
The analysis of Environment Policy & Governance (EPG) projects, including climate  has 
focused on those projects anticipating physical e nvironmental outcomes. It is difficult without 
knowing the specific details and cont ext of the project to be conf ident that the application of 
externality values is justified. However, in the case of estimates of reductions in emissions or 
wastes (rather than changes in environmental qua lity), externalities can be applied with more 
confidence to provide a conservative assessment. This means that indicators of changes in air 
and water quality are not included. Significant impacts are reported in terms of expected reductions in CO
2 emissions, the area and people likely to benefit from improved air quality, 
the area of soil erosion prevented, and the reductions in non-hazardous solid waste generation.  
The economic value of these environmental be nefits is based on published externality 
estimates. The externality values relevant to eac h indicator are taken from the literature (see 
Annex 12). It should however be emphasised that  the transfer of externality estimates does 
lead to some uncertainty, which has been mini mised by excluding indicators of environmental 
quality (as mentioned above), and has not theref ore been reflected in the calculation of a 
range – whilst the benefit estimates should only be taken as being indicative, because of the 
exclusions they can be taken as the minimum or a ‘low’ estimate. On this basis, the economic 
 
41 value of the environmental benefits provided by E nvironment projects could be in the order of 
€200 million per year (Table 1.5 of Annex 7). This  represents the minimum level of benefit. 
Substantial economic benefits are also potentially  associated with health benefits (improved 
air quality and reduced particulates and improved forest protection). 
For Information & Communication activities,  environmental benefits cannot be quantified. 
The main aim of the component has been to  actively promote EU environmental policies 
through information, communication, awareness-ra ising and dialogue, helping to ‘empower’ 
individuals and groups in the Eu ropean civil society, as well as  other stakeholders such as 
industry and local authorities to participate in an informed an d active manner in the protection 
of the environment and the sustainable use of resources. The aim is that, by enhancing their ownership of environmental policy, more effective implementation can be achieved. 
Furthermore, most projects have not been fi nalised, which means that it is impossible to 
evaluate the impact in the target ed population at this stage.  
 For Operating grants , as for Information Projects, en vironmental benefits cannot be 
quantified. An analysis of the operational f unding of NGOs for 2007 and 2008 undertaken in 
the mid-term evaluation showed that a substant ial proportion of the budge t is used for policy 
development (27%), policy impl ementation (28%), with extern al capacity building and  
awareness raising being smaller fields of activ ity. A large number of NGOs have undertaken a 
broad range of activities to contribute towards improved EU policy implementation and development. For example, they have: served  as hubs for a growing number of national and 
international environmental organisations; defend or increase the ambitions  of EU legislation, 
and campaign for real implementation of legisla tion or policy priorities; assist in increasing 
transparency and public participation; contribute to integration of environmental concerns into 
other policies through the provisi on of specific expertise; help  members better understand EU 
environmental policies, and to better mobilis e the public and decision makers to support a 
progressive role for the EU on environment a nd sustainable development.  However, as a 
result of the indirect influence the NGO activity  has on realising environmental benefits, it is 
not possible to quantify speci fic environmental benefits.   
Environmental and socio-economic impacts of the LIFE+ Regulation 
The environmental impacts  under the current LIFE+ Regulation are substantial (see Annex 7 
for full assessment). In addition to the quant ified benefits of some €600 million a year 
(therefore twice its annual budget),
23 which are based on conservative estimates, the 
instrument leads to the improved conservation a nd restoration of some 4.7 million hectares of 
land, representing some 6% of the total area of th e designated Natura 2000 terrestrial sites. It 
also supports a wide range of environmental improvements including improvements in water quality over an area of approximately 3 mi llion hectares; improvements in air quality 
affecting some 12 million people; and reductio ns in waste of some 300,000 tonnes and the 
recycling of a further 1 million tonnes; a nd reduction of 1.13 million tonnes of CO
2 per year24.  
                                                 
23 Benefits in the nature strand double investment cost (€199 million) and for the environment strand 
equals investment cost (€223) but excluding significant environmental benefits that cannot be 
monetised (because limited literature exists on externalities) such as changes in environmental quality for water and air sectors, as well as social and economic benefits, which are substantial. 
24 These benefits are also expected to last for many  years (although management cost will be required in 
some cases. Taking the low estimates of benefits an d assuming the benefits will last for 10 years, the 
discounted (at 4%) present value for nature and biodiversity would be €3.2 billion (almost six times the 
total investment costs) and €1.6 billion for environment (two and a half times the total investment 
costs). In total, €4.8 billion of benefits ar e estimated for the current LIFE+ Programme.  
 
42 Economic and Social Impacts of Nature and EPG Projects: The economic and social 
impacts of the Action Grants, as report ed by Nature and EPG projects include:  
• a total investment of some €600million is being made in technology outcomes by 
EPG projects. In addition, Nature projects are investing €380m in new approaches 
and techniques for nature conservation;  
• the additional sales generated by the de velopment of new products from EPG 
projects of €2.7 billion, generating around €1.1 billion of GVA25;  
• substantial health impacts both from the investment in improved natural 
environments and from improvements in environmental quality, especially from 
reductions in air pollution, affecting over 12 million people; 
• modest but positive employment impacts of some 2,000 jobs26 associated with the 
continuation of project activity post LIFE f unding and indirect economic benefits of 
a further 18,000 jobs based on ad ditional sales of new products.27 These impacts are 
particularly important given that Nature projects tend to create and retain employment in areas that are being depopulat ed and/or have lower relative incomes.  
It is difficult to quantify the impacts of the changes introduced by the MFF 
Communication . One could as a minimum expect in absolute terms an increase in the 
environmental and socio-economic impacts propor tionate to the increase in budget. Given that 
the biggest increase is in Climate action activ ities, probably a most significant increase in 
environmental impacts can be expected on climate mitigation and adaptation.  
As a consequence, one could as a minimum expect environmental benefits between €750 and 
€900/1,000 million benefits.
28 The exclusion of market-replication eco-innovation from the 
Environmental sub-programme could reduce the overall increase in socio-economic benefits, 
since as shown in section 2.2.2( a) eco-innovation projects bring most environmental benefits. 
However, market replication eco-innovation (which has been excluded from LIFE) represent 
only between 15-25% of the current Programme  (and are better carried out under other 
instruments).  
                                                 
25 GVA accounts for 40% of environmental technology sales, based on DG Environment, 2007, Table 4.4. 
Total sales of eco-industries was estimated to be €319 billion in 2008 (2008 prices), (Ecorys, 2009). 
26 A recent analysis concluded that the Natura 2000 network could support 122, 000 full-time equivalent 
(FTE) jobs in the regions where the sites are located, if adequately resourced and managed. If indirect 
and induced effects are taken into account, this co uld amount to 207,000 FTE jobs. However, these job 
estimates must be treated with some caution as it is not possible to control for negative or positive 
impacts in other sectors (Rayment et al (2009) within Kettunen et al (2011). 
27 €147k of environmental technology sales supports one job (inclu ding multiplier effects), based on DG 
Environment, 2007, Table 4.4. 
28 Climate change related benefits, as calculated in terms of CO 2 emissions, for the current programming 
period are around €135 million (50% benefit compared to investment costs). Given that the climate budget doubles compared  to the current Programme, it is expected that the environmental benefits will 
also double, i.e., €270 million. The increase in the environmental side has been more modest (overall 
increase of 8% with a higher increase for the governance and environmental strands). Nature benefits in 
the current programming period are around €400 million (twice the investment costs) and for 
Environment (discounting climate ch ange) of around €58-65 million. Applying the different increase 
ratio to the specific benefits per strand, and consider ing a modest increase of the nature part by 5%, the 
minimum increase in benefits would be €750 mill ion. If the calculation is based on the ratio 
benefits/investment costs applied to the different increases, then the overall benefit would be around €870-1,045 million. In the current programming period, the environmental benefits are around €600 
million (twice the annual budget ). The new budget represents an  overall increase of around 50%. 
Applying the ratio benefits/budget to the programme,  the environmental benefits will be €900 million.  
 
43 This calculation does not take into account th e larger impact expected from Integrated 
Projects29 given the difficulties in monetising those benefits. However, based on the results of 
the ex-post evaluation (that called for larger si ze projects) and contacts with stakeholders, 
these benefits would be: 
• environmental priorities become embedded into all the project activities as a 
requirement; 
• cost savings because of the larger size and effectiveness of the projects30; 
• as a result of their scale, Integrated Pr ojects provide a greater ability to create 
employment opportunities linked to c ontinuing environmental management;  
• because of their scale, Integrated Projects can establish a structured relationship with 
and develop project pipelines for the main EU funds, thereby promoting the 
mobilisation of their much larger res ources to support environmental objectives; 
• Integrated Projects provide a major role for regional and lo cal authorities as potential 
lead beneficiaries, which are also often the environmental and climate responsible 
authorities (e.g., for Natura 2000 Prioritised Action Framework) as well as being responsible for leading pr ojects funded by Rural Development, the Operational 
Programmes for Structural Funds.
31 
5.2. Analysis of the options 
A. Options for strategic planning: top down versus bottom up 
Box 7: What do stakeholders think? 
 
Strategic programming  (flexible top-down approach)  was the most popular option  among workshop participants (which 
included Member States authoriti es, private and public sector be neficiaries and NGOs). There was no support for limiting 
the thematic focus  of the Programme. However, it wa s recognised that having priorities could increase the EU added value 
provided these priorities were non-exclus ive and enough certainty for potential applic ants would be provided (e.g., there was 
opposition to annual priorities but more support to 2-3 year s priorities). 60% of YVIE respondents support a better 
prioritisation.   
• Option A1: Baseline: Bottom up approach   
Under this option, the problems identified under the current programming period regarding 
lack of focus and undermined capacity to create cr itical mass in specific sectors will remain. 
With the exception of the Natura2000 section of the Programme that concentrates on two Directives, a myriad of projects will be financed, even in sectors,  such as climate change, with 
earmarked resources. As shown in section 2.2.2(a) and (b), even when a sector concentrates 
large parts of the budget, the bottom-up approach  and projects and the environmental sectors 
financed are so diverse that no lessons can be drawn for mutual learning.   
• Option A2: A top down-approach  for all types of projects  (with a more flexible top-
down applied to traditional projects and a rigid top-down approa ch to Integrated 
Projects)   
This option is intended to increase the EU adde d value, through stronger priority setting and 
related targeting, and through increase in  the leverage and multiplier effects.  
                                                 
29 See Annex 11 for more detailed analysis of Integrated Projects.  
30 The larger size of Integrated Pr ojects responds to the call for larger projects made in the ex-post 
assessment of the LIFE III programme. 
31 Noted as a benefit of Inte grated Projects by the Committee of the Regions (2011) DRAFT OPINION of the 
Commission for the Environment, Climate Change and Energy on THE EU LIFE PROGRAMME.THE WAY FORWARD.  
 
44 The scale of this improvement is difficult to quantify; it depends on how much of the best 
practice currently achieved for most performi ng sectors could be ex panded and used to 
replace less effective activity. On the assumption that there c ould be a 50% improvement in 
the least effective part of the Programme (say the bottom-up quartile of activity), and a 25% improvement in the second least effective quartile, this would re present an overall 
improvement of 19% (say 20%). 
Taking the minimum value of the environmental be nefits expected to be achieved, i.e., €750 
million a year, and excluding the substantial social and economic benefits, this would 
represent an increase of €150 million of environmen tal benefits per year attributed to this 
option. Taken the maximum level and increase of €210 million of environmental benefits per 
year could be obtained through this option.  
Other considerations:
  
A more strategic focus will also increase the capacity to create cri tical mass for specific 
sectors, and multipliers. Under the current LIFE+ Regulation, there are significant examples 
of projects that have demonstrated environmen tal benefits, which have subsequently been 
disseminated and have catalysed subsequent take-up, thereby increasing environmental 
benefits.  
Box 8: The following projects serve to illustrate exampl es of projects which have had ’multiplier’ effects. 
 
Given the need for elapsed tim e, these exemplars are taken from the LIFE III Programme 
The catalytic role of LIFE – NATURE : IBA MARINAS - Important Bird Areas fo r Seabirds (Marine Ibas) in Spain  
(LIFE04 NAT/ES/000049) 
The project aimed to prepare a detailed inventory, using objec tive methodological criteria, to  determine marine IBAs for 
seabird species listed in Annex I of the Birds Directive that live in Spanish marine waters. The project worked closely in co-
ordination with a similar LIFE project covering Portuguese territorial waters. The project  developed a model methodology 
for defining future marine IBAs. This appr oach has now been adopted by members of  BirdLife International as part of a 
global standard (in Greece, Malta, the Baltic Countries, Argentina, Peru, USA, South Africa and New Zealand). 
The catalytic role of LIFE – EPG:  Reducing Emissions of Greenhouse Ga ses in Rome (LIFE04 ENV/IT/000453) 
The project funded a local action plan in Rome to reduce GHG emissions by 6.5%  by 2012 (compared to 1990), in line with 
the Kyoto target for Italy. The project in cluded eight small pilot projects to test act ions that might be included in the plan.  
These pilot actions proved successful and were consequently models for demonstration and replication . The pilot on local 
traffic planning gave important i nputs that have now been adopted in the new Strategic Mobility Plan  for Rome.  An Action 
Plan for the Reduction of GHGs in Rome was drawn up and approved by the municipal council in March 2009, building on 
the results of the pilot projects.  
The added value of LIFE is increased by con centrating the resources of the Environment 
strand on environmental policy improvements, wh ich relates largely to the development of 
action plans, management plans and strategies  at the level of a competent authority or 
municipality; and on funding enviro nmental solutions that can help integration directly and 
through being mainstreamed in the major funding instruments. 
More significant impacts in terms of awarene ss raising and dissemination of lessons learned 
are expected. The system woul d allow for targeting specific sectors which may lead to 
quantifiable changes in attitude towards an e nvironmental challenge. The examples included 
in Box 2 (at section 2.2.2(a)1) illustrate how the new system could help designing call for 
proposals to complement EU campaigns and targ eting resources in sp ecific policy areas, 
thereby increasing impact. 
The 2-3 years rolling plans would also be adap table so that adjustments can be done based on 
the evolution in achieving targets. For example,  if sufficient Integrated Projects have been 
financed in the nature sector as to provide enough examples for the di fferent Member States 
and bio-geographic regions, the ro lling plan will allow targeting other sectors. However, the 
 
45 system could be too rigid and discourage potential  applicants, especially as Integrated Projects 
may take up almost all annual resources in the second half of the programming period.  
As to subsidiarity considerations, Member States will participate in the preparation of the 2-3 
years work plans and the elaboration of the se lection criteria, there by ensuring that Member 
States needs are also reflected in the programming. On the othe r hand, this participation could 
lead to lengthy negotiations hamp ering the endorsement of the rolling plans. Participation in 
an advisory capacity could diminish this risk. 
• Option A3: An approach combining the top- down approach for Integrated Projects 
and bottom-up approach for all other types of interventions  
Increased environmental impacts compared to option A1 will be those linked to the capacity 
to focus Integrated Projects on specific se ctors that require speci fic EU intervention.  
For traditional projects, however, there would be no possibility for creating priority sectors or 
specify needs linked to concrete Directives wi thin one sector. This could lead again to a 
myriad of projects wi ll little links to policy development and implementation. No possibility 
for adjustments during the programming period, no t even after a mid-term evaluation, because 
there would be no formal planning system to re allocate resources, if needed. This could be 
done only for Integrated Projects in an info rmal basis and dependi ng on the geographical 
distribution system adopted.  
However, the system could be considered mo re flexible, especially by the end of the 
programming period where only a limited number of  traditional projects is expected to be 
financed.  
B. Options for thematic concentrat ion of Integrated Projects 
Box 9: What do stakeholders think? 
Respondents to the Committee of Regions  survey suggested that Integrated Projects could most realistically and 
effectively be used to address a wide variety of  environmental problems/challenges met within their 
region/municipality, notably: ‘freshwater management’ (21. 5% of responses); ‘nature and biodiversity’ (18% of 
responses); ‘resource use and waste’ (14% of responses); as well as ‘urban environment’, ‘air pollution’ and 
‘land use’ (each counting for 9% of responses). In add ition, a total of 14% of the related responses concerned 
climate change issues (either adaptation or mitigation). Almost 55% of respondents to YVIE survey supported 
Integrated Projects with 42% supporting the approach for Natura2000 (only 16% of respondents were opposed), 
50% for other sectors such as water, marine and waste.  
A mode detailed assessment of benefits of In tegrated Projects is provided in Annex 11. 
• Option B1: Baseline: No thematic concentration of Integrated Projects  
Given the resources allocated to the Environm ent sub-programme of the future LIFE, an 
analysis of ‘what will it take’ to  produce a step change in th e impact of the Programme has 
been made. The number of Integrated Projects  required relates to the relevant territorial 
‘units’ for each environmental theme identif ied as having a potential for integrated 
approaches. A statistical relevan ce of 15-20% of the relevant terr itorial unit has been used to 
determine the number of projects required in a specific sector to  have enough examples 
applicable to different administ rative and regional characteristics (including levels of capacity 
development) so that different experiences can  be widely disseminated among Member States 
and regions. Applying the statistical relevance it is possible to identify how many Integrated 
Projects would be required to have cr itical mass in the sector concerned.  
Integrated Projects in Nature  – The relevant unit is the NUTS 2 region, given than regions 
tend to be responsible for the management of Natura2000. This also has the merit of linking 
 
46 directly to possible regional funding. There ar e 271 NUTS 2 regions in the EU. Assuming the 
minimum level of action required, one Integrated  Project for nature conservation, in say 
between 15-25% of the regions over a 7-year  Programme period would be needed. This 
means between 6 and 10 Nature Integr ated Projects in average per year.32 
Integrated Projects in Environment  – In this case the relevant unit depends on the 
environmental theme.  
• Waste management – the appropriate unit is also probably th e NUTS 2 region, given 
the nature of regional waste management pl ans. 15% Integrated Project activity over 
the Programme would provide a minimum leve l of catalytic effect – say an average 
minimum of 6-10 projects a year; 
• Water management – the appropriate unit is th e river basin district  of which there are 
110 river basin districts and 176 national branches. Given the important issues 
associated with transposition and implement ation of the Water Framework Directive 
(WFD), and the interest in ensuring cross-compliance with  the WFD as a condition of 
regional funding, then a greater share of ‘ units’ should be covered – 15-25%. This 
would require an average mini mum of 3-4 projects a year; 
• Air quality management – activity in large cities to combat urban air pollution (e.g. 
particulates, low level ozone and nitrogen di oxide) would also benefit from the use of 
Integrated Projects. Building on the 2013 Europ ean ‘Year of Air’, 3 IP projects a year 
would allow action in 20 of th e most polluted EU cities. Th is could be combined with 
other urban elements; 
• Marine environment – probably 1-2 Integrated Projects per sea basi n (3-5 projects per 
year in average).    
The Environment strand would therefore require a minimum of  13-19 Integrated Projects a 
year, if the use of these projects was to really  tackle the institutional weaknesses that underpin 
the lack of adequate policy implementation a nd effective policy integration in the entire 
acquis . 
Given that these projects are larger in size  (EU contribution €10 million per project), the 
current allocation would probabl y be not sufficient to achieve  all abovementioned targets, 
thereby undermining the Programme’s capacity to achieve critical mass of projects in specific 
sectors. This would imply not a ddressing the main criticism relate d to lack of prioritisation 
and focus. The possibility to reach concrete results and provide enough examples for different 
administrative organisations and sectors may not be possible. On the other hand, a large 
thematic scope will allow testing the approach in a bigger number of sectors.  
A large thematic scope for Integrated Projects would also imply that if the Programme wants 
to have any chance of reaching targets in so me sectors, traditional projects could not be 
financed. These traditional projects cannot be  completely phased out (as recognised by the 
MFF Communication). Firstly, thes e projects address the needs of  stakeholders that are not 
necessarily public au thorities, such as SME. In addi tion, not all environmental activities 
require a planned and large territ orial scale action. Finally, not all public authorities would be 
ready at the beginning of the programming period to submit an Integrated Project in some 
cases due to lack of capacity.   
                                                 
32 25% of 271, divided by 7. 
 
47 Based on the experience under LIFE+, between 8-10 traditional project per environmental 
sector would be required to achieve critical  mass and create multipliers. If environmental 
sectors are grouped in 6 sectors (biodiversity, water, natural re sources and waste, environment 
health, which would include noise and chemi cals, emissions, which would include air and 
IPPC, and green economy) around 56 to 60 tradit ional projects per year are required in 
addition to information projects. 
Integrated Projects would gra dually be introduced in the Cl imate Action sub-programme in 
the area of mitigation and adaptation, in order to allow time build up capacity needed for such 
projects. 
• Option B2: Thematic concentra tion of Integrated Projects  
 
Given above considerations, it would seem that some thematic concentration for the 
Environment sub-programme may be required. In tegrated Projects could concentrate on:  
(1) Sectors where implementation or in tegration problems are more significant 
As to implementation problems, a good indicator  is infringement cases. Nature conservation, 
waste and water legislation accounts for 59% of the infringement case load for the 
environment sector, with the sectors "impact a ssessment" and air contributing the bulk of the 
remainder (27%). Other sectors, such as Marine, are still in a development phase.33  The last 
few years have seen a marked increase in cases in the air sector.  
Implementation problems often reflect inte gration problems. For example, the high 
percentage of cases concerning na ture protection legislation can be explained by the fact that 
many infrastructure developments proposed in Member States that lead to complaints are 
those affecting in some way Natura 2000 sites or  EU protected species. As shown above when 
analysing consistency with othe r EU funds and the Zero option, Nature conservation also has 
problem of absorption capacity in other EU pr ogrammes, partially because authorities do not 
always perceive the socio-economic benefit of nature conservation.  
The overall percentage share of waste and water cases reflects the fact that they have entered 
crucial implementation phases. The waste sector also has problems of ab sorption capacity in 
other EU programmes. As in the case of Na ture, the capacity to develop and prepare 
investments, and to channel large amounts of EU  funding, is still lacking in some Member 
States. There is a risk that some funds from the 2007-2013 programming period will not be 
spent in time. 
Nature, water and waste are entering crucial imp lementation phases. In the near future, the 
Habitats Directive will move from designa tion to active manageme nt and restoration; 
similarly, under the Water Framework Directiv e (WFD), the river basin management plans 
will need implementation to achieve the ob jective of good environmental status. Air 
legislation will be revised in 2013, which implie s that in the period 2014-2020 will also enter 
its crucial implementation phase. The Marine legislation will enter as well the crucial 
implementation phase, since by 2020 Member States  should have achieved or maintain a good 
environmental status. 
Management and implementation costs for Natura2000, water and waste are very high i.e., 
€5.8 billion per year for Natura2000,  €30 billion per year for water,  €7-12 billion per year for 
municipal waste compared to Air which requir es about €1 billion per year (see Annex 5).  
(2) Sectors that are more linked to achievi ng Europe 2020 resource efficiency targets and 
                                                 
33 http://ec.europa.eu/environment/legal/law/statistics.htm. 
 
48 direct environmental benefits  
The Resource efficiency roadmap indentifies biodiversity, water, waste, air and soil as the 
main environmental sectors that are essential to shift towards a more resource efficient 
economy. Of these, biodiversity, water, waste and air are suitable for Integrated Projects. 
As to direct environmental benefits, as show n in section 2.2.2(a) and Annex 7, Nature, water 
and waste are the sectors with more direct en vironmental benefits. In addition, air provides 
many socio-economic benefits linked to healt h. Not enough information about marine projects 
exists as to determine the envi ronmental benefits generated.  
(3) Sectors that have more possibility to link to, and therefore mobilise, other EU funds.  
Mainstreaming of nature, water and waste is much consolidated and has been improved under 
the MFF Communication proposals thereby pr oviding more opportunities for generating 
examples for integrated funding to solve the significant absorption capacity problems 
identified. Air has also improved mainstreaming due to its health im pacts, and many links 
with climate change (especially in urban area s). The new European Ma ritime and Fisheries 
policy has also improved the in tegration of Nature Directives and the Marine Strategy 
Framework Directive.  
Additional criteria : 
(4) The maturity of the sector  (i.e., the development of plans and programmes is required by 
the legislation and they are already in place) , including the success of  environmental sectors 
in LIFE. 
Nature, water and waste are probably the most mature environmental sectors in terms of 
planning and programming. Management plan s for Natura2000, River Basin Management 
Plans and Waste management plans have alread y been developed. The Habitats Directive will 
require a programme approach applied to th e network (and not only to a site) through 
Prioritised Action Frameworks. The Water Fram ework Directive’s River Basin Management 
Plans already foresees an integrated approach, and there is an increasing call for overreaching 
waste strategies.  
As to the consolidation of the sectors in LI FE, Nature, water and waste are the traditionally 
successful sectors: 50% of resources are allocated  to Nature, and water and waste applications 
amount to almost 70% of all LIFE Environm ent applications, with an average of 50-60 
applications for water and 80- 100 for waste compare with 12 a pplications for air. Marine 
applications tend to be done in the context of the Habitats Directive.  
(5) The stakeholders’ opinion co uld also be used to discri minate between one or another 
sector.  As seen in Box 9 above, nature, water and waste are the sectors signalled by 
stakeholders. Air is also men tioned but to a lesser extent. 
  
o Sub-option B2a: Thematic concentrati on on 3 sectors: Natura2000, water, waste  
 
Natura2000, water and waste  rate first in almost all the criteria mentioned above. Although 
it is difficult to quantify the environment and so cio-economic benefits of LIFE projects (see 
some examples in Annex 11), the more targeted  approach for Integrated Projects will allow 
covering at least 15% of the Natura2000 network (doubling th e coverage under the 2007-2013 
period), 10-15% of the river basi n districts and up to 15% of regions for waste management. 
Only for the Natura 2000 network, this could represent a 30-40% increase of environmental 
benefits compared to the baseline. In addition it will be possible to create synergies between Natura2000 and Water Framework Directive.  
 
49 Since nature, water and waste are very cons olidated sectors under LIFE funding, risks of 
failure of the approach (e.g., lack of demand) wo uld be reduced. This is  especially important 
for water and waste (so far covered by the LI FE Environment component) which had mostly 
focused on innovation and demonstration of tec hnologies and now will shift focus towards 
implementation.  
The Marine Strategy Directive could be partia lly covered by either Natura2000 (marine and 
coastal habitats and species) or the Water Fr amework Directive (coastal and transitional 
waters). Air legislation could be partially  covered by Climate adaption and mitigation 
Integrated Projects. However, it would mean ex cluding the sector that provides more health 
benefits and which has been identified by the Co mmission as a priority for the coming years, 
also in relation to the Resource Effiency Roadmap. 
o Sub-option B2b: Thematic concentrati on on 4 sectors: Natura2000, water, waste 
and air  
This option will increase the potential of the Progr amme to provide direct benefits, especially 
in relation to health. As shown in section 5.1, the current LIFE+ Regulation, with only an 
average of 2-6 air projects per year, will be ab le to improve the quality of air of 12 million 
citizens. Air projects covering the 40 most po lluted cities through 20 tw inning projects could 
imply reaching about 10% of the EU’s popula tion. Air is, however, a sector with a low 
application rate for LIFE funding. Therefore, there might be demand problems. On the other 
hand, one of the Integrated Projects  precursors was an air project.  
Given the limited resources under the Environmen t sub-programme, the number of traditional 
projects per year may go below the threshold. It might also require lowering targets for the 
water and waste sector thereby reducing the fo cus and overall demonstrative relevance of the 
Programme. One possibility to overcome this risk is by lowering the expected EU co-financing rate for Air Integrated Projects. As shown above, management costs for Air are 
significantly lower than for other environmental s ectors. This suggests that Integrated Projects 
may also be smaller (e.g., let’s say about €7,5 million co-financing). However, the size of 
Integrated Projects is only assumed based on examples of projects financed under LIFE+. 
For both sub-options, Integrated Projects would gradually be introduced in the Climate Action 
sub-programme in the area of mitigation and adap tation, in order to allow time to build up the 
capacity needed for such projects. 
C. Options for allocation of resources  between different priority areas 
• Option C1: Baseline- MFF Communication allocation 
 
Under this option, better targeting for climate ch ange will be achieved (thus solving one of the 
problematic aspects highlighted under Problem 1 in section 2.2.2(b). This will increase direct 
benefit at least associated to climate impacts (Concentra tion on climate may increase 
environmental benefits by 50% from €135 millio n a year to €270 million- see section 5.1). 
However, the Environment sub-programme, and more precisely, the Nature & Biodiversity 
component would lose the feature that has be en partially responsible for the success and 
strategic focus of the component. Therefore, instead of solving Probl em 1, the option would 
increase risks of further dilution of thema tic focus for the Environment sub-programme.  
This will also impact the capacity of the Progr amme to provide direct benefits. As shown 
above (sections 2.2.2(a) and section 5.1), Nature is responsible for the highest and most cot-
effective environmental benefits for the Programme. Similarly, implementation problems 
(driver 1) and integration deficiencies on the ground (driver 2) are especially significant for 
nature. In many cases, LIFE is the only F und available for specific Natura2000 management 
 
50 measures. If resources are no earmarked, and given the more complex characteristics of 
developing a nature project, the higher demand in  projects in the environmental sector could 
significantly reduce the chances for nature and biodiversity projects  to be funded. In fact, this 
higher demand derives from the large spectrum of sectors covered. 
• Option C2: MFF Communication allocation a nd allocation of 50% of resources to 
biodiversity  
This option will continue the positive impacts already identified under the current Regulation 
and will increase them. This is b ecause there is an increase in funds dedicated to nature and a 
more targeted and integrated approach increasi ng projects size and thus territorial impact (A 
minimum of additional €450-500 million environmental benefits could be expected - see section 5.1). Such option is in line with stakeh olders' expectation in particular concerning the 
financial support expected for Na tura 2000 under the Biodiversity st rand. It is also consistent 
with the findings of LIFE mid term evaluatio n. These confirm that implementation gaps and 
integration problems are more significan t for Nature and Biodiversity.   
The con of this option is that it may impact the ability to finance standa rd action grants and/or 
Integrated Projects if too many sectors are included in the Environment component. 
 
D. Options for geographical distributional impacts (national allocations) 
Box 10: What do stakeholders think? 
As to national allocations , these were only discussed with the Member States in the Committee meeting. The positions were 
divided between those Member States opposin g all kind of pre-allocation of funds a nd others supporting the current system. 
The EESC is clearly opposed to national allocations.  
• Option D1: Baseline - All projects selected on merit   
Under this option, the risk is that Italy and Spai n will continue to be main beneficiaries, as 
under the LIFE+ Programme. Figure 3 shows the im pact of national allo cations on current 
selection. If the selection ha d been based on merit only (hi ghest points on the main four 
evaluation criteria, i.e., their technical and financial quality, and demonstrative value for the 
EU), some Member States would have receive d additional projects and others fewer. For 
example, Austria would have received two ad ditional projects (one under the environment 
strand and another under the information and communication strand) wh ereas others would 
have received fewer projects. Because of the national allocation, proposals from a Member 
State that pass the minimum quality criteria bu t with fewer points than  those submitted by 
other Member States get funded.  
However, as shown below, it is impossible to identify a clear trend, such as a general 
advantage to those with less experience in the Programme or those with fewer resources. In 
one case (Italy), the effect of the current system  is simply a re-allocatio n of funds, within the 
same Member State, between diffe rent strands of the Programme. 
If the projects were selected on merit only, this would mostly  favour Spain and to a certain 
extent Italy, which are the Member States already receiving most funding, whereas other 
Member States, like Latvia, Romania or the UK (which already do not use their national 
allocation) may obtain fewer projects. To summar ise, merit only will - w ith some exceptions - 
favour again the current winners.   
 
51 Figure 4: Impact of National a llocations under the current system 
-6-5-4-3-2-101234
AT BE BG CY CZ DE DK EE ES FI FR GR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK ENV
INF
NAT
 
 
On the other hand, the system will lose part of  the solidarity rationale and justification for 
burden sharing, especially rega rding nature conservation, sin ce natural assets are unevenly 
distributed among Member States.  
• Option D2: All projects selected on mer it but ensuring geogr aphical balance for 
Integrated Projects  
Traditional projects have histor ically been financed mainly in Italy, Spain and Germany. It is 
expected that some Member States would increase the number of traditional projects (as shown above probably Austria, Belgium a nd Greece) should the evaluation be based 
exclusively on the quality and demonstrative value for the EU. 
Integrated Projects are linked to the development of regional  strategies, implementation and 
capacity building. Therefore a geographical balan ce is desirable to ensu re that all Member 
States obtain at least one Inte grated Project (subject to othe r concerns). For example, the 
Commission would ensure at least one Integrat ed Project per Member State in waste and 
nature sectors and at least one Integrated Project per transboundary river basin district 
(Danube, Rhine, etc), and at l east two projects per bio-geog raphical region. Member States 
with more capacity deficiencies, Member States  with high nature assets (e.g., Bulgaria, Spain 
or Slovenia) and Member States hosting transbou ndary river basin distri cts (France, Hungary, 
Germany or Austria) woul d probably be favoured.  
Priority to transboundary projects, especially un der the water sector and to create synergies 
between water and Natura2000 (e.g., in the Danube).  This option is also flexible and allows 
Member States that are ready to submit propos als during the first half  of the programming 
period to do so, and it gives time to other Member  States to learn from the first experiences 
and submit proposals later. This option would work better with Strategic programming 
(option A2) because it would allow adjustments if one Member State has not received any 
Integrated Project.   
• Option D3: Standard/traditional projects  selected on merit only and national 
allocations (specific amounts per Member Stat e) for Integrated Projects for the whole 
programming period  
Same as D2 but indicative allocations will be created ex-ante based on environmental needs 
agreed with the Member States. These indicativ e allocations would be calculated and applied 
for the entire programming period instead of annually  as today to allow more flexibility in the 
selection procedure (e.g., one Member State coul d fulfil its national allocation the first years 
whereas another could need more time and wo uld only submit proposals in the second half).  
This option would also work better with the strategic programming (option A2) because it 
would allow adjustments.  
 
52 For the nature sector, if the current system  (population and % of te rritory designated as 
Natura2000) applies, the biggest financial enve lops would be for Germany, France, Spain, 
Italy and the UK, which is also largely in line with the management costs as reported by Member States (costs tend to be greatest in  areas which require th e highest levels of 
intervention and management su ch as agricultural areas in North-Western Europe and which 
face greater pressure from development and disturbance such as islands and in Southern Europe). If the criteria were only based on the percentage of territory designated as 
Natura2000, Slovenia, Bulgaria, Slovakia, Cy prus, Spain, and Greece will probably have 
larger allocations as well as UK, Germany and Fr ance (for marine).  This does not imply that 
smaller Member States would be overrepres ented, since currently the smaller annual 
allocation is about €2.5 million which implies that, for a 7 year programming period, the 
minimum allocation could be around €18 million, i.e., two Integrated Projects.  
For the water sector, given the significance of  transboundary river basin districts and the 
pressures on them, priority c ould be given to thos e. Probably France, Germany, Austria, 
Hungary or Romania would have larger allo cations. If the criteria used were the km
2 (ha) of 
river basin districts compared to the national territory, agai n, the abovementioned countries 
and probably Spain and Italy woul d have larger allocations, wher eas others, such as Malta, 
would hardly have.  
For the waste sector, capacity needs would pr obably concentrate on new Member States.  
This option might be more acceptable for Member  States, especially if strategic programming 
(option A2) is adopted but could increase rigidi ty and problems in agreement of criteria (as 
per the experience with current LIFE+ Regula tion) and complicate th e selection procedure 
(different steps are required to ensure the alloca tions are fulfilled). There is also the risk that 
the envelops are reserved and not used by the Member State (as per current experience) and 
targets not achieved, in which case a mechanism for allocation of unused funds will be needed.   
Box 11: Main assumptions in assessing geographical balance 
 - Environmental needs, especially in relation to instituti onal and capacity weakness, and management costs needs remain 
largely the same during 2014-2020 (the analys is of evolution and scale of environm ental problems in Annex 5 so seem to 
confirm). For Nature, data used is in formation available regarding management  costs for Member States reported by 
themselves as well as th e number and share of Natura2000 network in relation to the territory, since this is a good indication 
of burden and effort sharing (Member States with a larger proportion of their territory designated should have a greater 
responsibility in conserving, preserving and restoring those habita ts and species which are consid ered of EU interest). The 
assessment assumes that there would not be dramatic changes in designation in the next years, especially since the terrestrial 
N2000 network is considered largel y complete. A similar logic and a ssumption was followed for water.  
- Level of demand in all Member State remain similar to cu rrent levels. The crisis has not prevented vulnerable Member 
States (such as Italy, Spain or even Greece) from increasing the number of proposals submitted in 2011. It would seem fair to 
assume that the situation will remain the same in the coming years.  
-  A minimum number of Member States are ready to submit In tegrated Projects at the begi nning of the programming period. 
In this sense, the assumption is that Member States with mo re experience in managing larger  projects or precursors of 
Integrated Projects (e.g., Belgium, Spain, Italy, Slovenia, the Netherlands, or Finland) will be ready to submit Integrated 
Projects at the beginning of the Programming period, whereas ne w Member States, such as Romania or Bulgaria, will have 
more difficulties. Risks mitigation measures in relation to demand have been developed. Already LIFE+ is financing 
necessary strategic frameworks required under the specific Directives and activel y promoting Integrated Projects, so some 
examples may already exist at the moment of entry into force of the new Regulation.   
 
 
53 E. Options for funding activities unde r Governance and Awareness raising 
• Option E1: Baseline - NGO funding, Co mmission communication activities and 
reinforced communication/dissemi nation obligations for projects  
Impacts are difficult to quantify but they coul d be assessed qualitatively based on the mid-
term evaluation and efficiency/effectiveness ga ins. As noted above, NGO contribute to civil 
society participation in policy development,  promoting implementation, strengthening the 
knowledge base and raising awareness.  
Given the relatively small size of the Info rmation & Communication component (for the 
2007-2009 calls, the INF component accounted for only 4% of the EC’s contribution in 
LIFE+), more strategic value can be gained from strengthening the mandatory information 
and communication activity in projects. As sh own in section 2.2, the close links between the 
projects and the local populations place them in  a unique position to influence behaviour and 
empower citizens. One could expect these imp acts to increase by adopting a stronger focus on 
the generation of multiplier effect s, which is translated into greater responsibility on project 
co-ordinators for identifying and communicating findings with target users and providing 
training. In particular, networks of similar projects around prior ity themes could be promoted. 
• Option E2: NGO funding, Commission communication activities and 
communication/dissemination obligations for projects, and specific Communication 
campaigns financed through grants .  
The positive impacts of option C1 are exp ected to increase by complementing all the 
abovementioned activities with specific inform ation and communication projects financed 
through grants that will target a particular sector or stakeholder group as defined by the 
Commission. These projects could al so be initiated to take on the synthesis and dissemination 
activity of results from the traditional projects under selected themes. This would allow these 
campaigns to be better focused: th e strand has been hampered to date by its attempt to cover a 
broad range of themes and by the fact that  only a small number of projects have been 
successfully funded so far (38 selected for f unding from 329 proposals for the first 3 calls). 
This has affected its strategic impact (‘spread to o thinly’) and its ability to concentrate on the 
issues of greatest priority. In  addition, these more specific projects could complement DG 
ENV and DG CLIMA own communication and gove rnance efforts increasing the multiplier 
effect of the campaign and the sense of owne rship regarding results. Indeed, since these 
projects will be carrie d out by national stakeholders, it woul d be easier to adapt the specific 
characteristics of a particular Member State. This option works better with a strategic programming approach to determine the priority communication and dissemination 
campaigns to be financed for 2-3 years. 
 
F. Options for simplification 
• Option F1: Baseline: On-line tools and larger projects
 
On-line tools:  It is difficult to assess administrative gain regarding the us e of on-line tools. 
Current bidding costs are about €3.4 million. On-line tools will mostly simplify the procedure for submission of proposals which accounts fo r around 20% of the bidd ing costs (including 
technical and administrative staff costs). Appl ying an increase in efficiency of 50% for 
administrative staff costs and 10% for technical staff would lead to 7% savings. If applying 
50% gains in efficiency for both, 12% in crease in savings would be expected.  
 
54 Larger projects and Integrated projects : Regarding the selection, it is difficult to quantify, 
but moving to larger projects  imply bidding savings for th e beneficiary for the entire 
programming period, since instead of submitting 3 or 4 projects in a 10-year period, , only 
one project will be submitted. In addition, risks associated to multiple bidding, and therefore 
that one of the projects may not be selected  because of competition, will be reduced. The 
example below illustrates these gains.   
Box 12:   Potential LIFE Integrated Project-PM10 control in urban areas 
Four Austrian LIFE projects  are interconnected and all have PM10 control in urban areas as a main objective. Each project 
has been used as a further step in developing a more holistic a pproach and contributing to a long term plan. The four projects 
could theoretically have been combined into a single integrat ed project, which drew on several funding sources. Even if the 
resources to prepare a proposal for an Integrated Project would increase as compared to smalle r projects, they would still be 
fewer than the resources needed to prepare 4 different appl ications and go through 4 diffe rent negotiation procedures.  
As to management costs savings, see Options G. 
• Option F2: Selection procedures:  2 stag e procedure and simplified reporting for 
Integrated Projects - moving to larger projects  
Integrated Projects:  The simplification in the reporting cycle will imply for the projects 
beneficiaries a reduction by 25% in reporting costs (a  2-year reporting cycle - instead of 18 
months - would imply, for a 6-year  project, 3 reports instead of 4). Given that administrative 
costs are around €1.7 million a year and that re porting costs represent between 60-75% of 
administrative costs for projects and that Integrated Projects will represent between 20 and 40% of projects financed every year, it c ould mean reporting savings between €178,500 and 
€357,000 a year. In addition, in terms of manage ment costs for the Commission, for a 6-year 
project, 2 amendments and 4 payments will be done. Considering that an  Integrated Project 
could correspond to at le ast 5 traditional projects for whic h 15-20 reports, 15 payments and 3-
5 amendments would be necessary, this repres ents a reduction of 70% in the number of 
transactions. 
Multiannual selection for NGOs : This will ease the administrative burden of yearly selection 
procedures (reducing by at leas t by 50% cost). One disadvantag e identified is the loss of 
flexibility as compared to the yearly select ions, but this would be  outweighed by improved 
stability and coherence of stra tegy and planning for NGOs, as we ll as reduced administrative 
burden. The periodicity preferred by stakeholders is 2 or 3 years. 
• Option F3: Outputs and results payments vs lump-sums, ineligibility of certain costs
 
An option of payment based on outputs  could be examined.  However, it would take time to 
develop a methodology to calculate cost/ha a nd type of habitats for restoration and 
management activities.  
The use of lump sums  will be a better option since it simplifies reporting costs for the 
beneficiary. For example, by introducing stan dards staff costs, obligations regarding time 
sheets could be eliminated to a large extent wi thout restraining beneficiaries to only recruit 
new people.  
Ineligibility of certain costs:  Considering VAT cost non-eligib le will simplify reporting since 
beneficiaries, especially some categories, ha ve to go through complicated systems to obtain a 
certification that shows they are not eligible to  obtain a refund. As to personnel costs, limiting 
eligible costs to only additional staff recruited specifically for the project will have significant impacts on simplification in terms of financ ial reporting and monitoring for the project 
beneficiary. Specific timesheets tend to duplicat e the system in place by the beneficiary. Most 
 
55 cases of recoveries are curren tly associated to personnel costs. Such a limitation would also 
make it easier for the Commission to monitor job creation for the project.  
Considering ineligible above costs would imply a reduction in the total real costs of about 5-
10% for VAT and 20-40% for personnel, which c ould discourage potentia l applicants. If the 
EU intervention (i.e., 50% of eligible costs) is to remain at the same level as today for the project as a whole, the current co-financing rate  will need to increase up to 70% for projects 
which currently have a co-financing rate of 50% and up to 80% for projects which currently 
have a co-financing rate of 75%.   
G. Options for externalisation  
Options for externalisation should be considered  within the context of  the overall Commission 
intention to reduce management costs for the funding programmes.  
As mentioned in section 1, the management costs of the LIFE Pr ogramme are around 6%. 
LIFE compares well to other EU funding pr ogrammes. The ex-post evaluation compared 
LIFE with EACEA as per its interim evaluation. The average ratio of administrative costs as 
% of total commitments was 9% in 2007. However,  this covers large di fferences between the 
various programmes that EACEA manages. Th e ratio changes between  8.3% and 13.6% (five 
components), 2% (for one large component ) and 20.6% (one small component). The 
administrative costs as share of the tota l budget for EACEA repres ented 8.7% in 2007, 7.6% 
in 2008 and 11.8% in 2009. 
The ex-post evaluation concluded that the LIFE  Programme seems within the same range and 
in some cases below the range of other similar programmes. However the basis for 
comparison is limited. Given that EACEA is  an executive agency where the potential 
efficiency gains from externalising the tasks should have been achieved, the similarity in 
range points in the direction of a high degree of efficiency of the LIFE Programme most 
probably explained by the fact that main tasks linked to selection and monitoring have been 
already outsourced. In fact from LIFEIII to LIFE +, costs passed from 8% to 6% thanks to 
further outsourcing at the consolidation of di fferent programmes (Forest focus, Urban, NGOs 
operating grants) into one programme, saving 4 full-time posts.
34  
The decision of the MFF Communi cation to move towards larger projects is a further attempt 
to reduce management costs. Moving to larger projects also implies a reduction in the number 
of projects and thus on the staff required to  manage them. As seen above, further 
simplification measures related to reporting and eligibility of costs could further reduce these 
costs. Externalisation to an existing Executive Agen cy is also part of the efforts to continue 
this trend.  
It is difficult to compare the costs of direct centralised ma nagement by the Commission with 
the costs of management by an Executive Agen cy (hereafter, called 'Agency'). Doing so 
requires assumptions to be ma de, in particular, on the performance by any Agency and on 
'efficiency gains'. Many of these assumptions will be tested when negotiating a contract with an Executive Agency, but even the benefits of  any improved performanc e will not be seen 
until later.  
It should be noted that at the time of any de legation the Commission will publish a fuller cost 
benefit analysis going into fu rther detail, and informed by negotiations with the Executive 
Agency. Therefore, the estimation of resources  for both the Agency and the Commission, the 
                                                
 
34  As to EACI the Interim evaluation indicates that  EACI has a ratio of administrative staff (defined 
differently to “administrative support”) significantly below the average (10.2% for EACI in 2010, while 
the average of all EAs was 14.4%) but no more details are provided regarding the costs of the overheads 
costs compared to the budget managed. 
 
56 cumulative impacts across the entire programmi ng period as well as the impacts of the 
transitional arrangements35 will need to be a carefully developed, reviewed and validated at 
the time of preparing the de tailed cost/benefit analysis. 
The Court of Auditors36 has already highlighted some of th e problems with past analyses of 
an Agency option: 
• emphasis is placed mainly on savings from the use of cheaper contract staff rather than 
permanent staff but aspects of improved perf ormance and efficiency gains are rarely 
considered;  
• costs of additional staff needed in the Co mmission to supervise agencies and at the 
agencies for horizontal functions, are not accurately included or not included at all; 
• comparison is often made using the single av erage unit cost for th e various categories 
of contract staff but in practice they vary in grade and therefore cost. Analysis shows the composition of the Commission consists largely of lower grades compared to 
specialised personnel so this would lead to an overestima tion of Commission costs in 
cost comparisons. 
In this analysis, the costs of additional staff to supervise agencies has been estimated, but 
potential performance and efficiency gains fr om implementing a larger programme in one 
Agency have only been partially considered, which may leave the Agency option in a less favourable light. 
Current cost of Programme Management as a percentage of Programme value : The 
number of full-time equivale nt posts to manage all aspects of the Programme, including 
external contractors and EU officials is approximately 125 full-time equivalent  posts. The 
total administrative cost is just ov er €15 million (€15,084,000). This currently represents 
6.2%  of the total annual Programme budget.
37  
• Option G1: Baseline- Externalisation  
In the MFF Communication, the Commission cons iders that the future  Programme should 
remain centrally managed, but that management ta sks could to a large extent be delegated to 
an existing executive agency. 
o Sub-option G1.a: Externalisation w ithout replacing technical assistance  
In terms of costs, based on the experience ga ined with the extern alisation of the eco-
innovation part of the CIP Progr amme, the same number of staff currently managing the 
LIFE+ Programme within the Commission (44 pos ts) could be needed in the Agency (of 
whom 9 would be officials seconded fr om the parent DGs to the Agency).38 In addition, some 
                                                 
35 There are projects currently financed that will last until 2018. Around 200- 230 projects are selected in 
average in the last call for proposal s. Assuming that only projects that were financed in the second half 
of the Programme will likely still be active when th e new Programme starts that gives around 600-700 
projects from LIFE+ still alive when the ne w LIFE Regulation enters into force.  
36 European Court of Auditors Sp ecial Report No. 13, ‘Delegating implementing tasks to Executive 
Agencies: a successful option?’ (2009). 
37 Estimated to be €244 million (annual EC contribution to action grants and expenditure on technical 
assistance). 
38 Based on experience and conversations with EACI, a minimum of 6 staff need to be seconded to the 
Agency when transfer occurs. Acco rding to figures for existing agenci es like EACI, the percentage used 
for seconded staff is 24% of the staff used in the parent DG. A 20% level is used here since it is 
expected that the number of projects financed w ill decrease as well as overall Commission staff (5% 
target).   
 
57 staff would need to remain in the parent DGs to take up coordination and control tasks (for 
governance, supervision and monitoring of the Programme, including establishing links 
between the parent DGs, other DGs and the Agency).  
In addition, there will be an additional sta ff requirement related to supplying additional 
administrative services (human resour ces etc) to the new Agency staff.39 There are also 
additional overhead costs (e.g., office costs) asso ciated with the posts and contractual agents 
to be transferred to the Agenc y. The total cost of this option, represents 6.3% of the 
Programme budget.40  
As for aspects related to policy links, the overa ll programming and design will remain within 
the parent DGs ensuring a link between traditi onal projects and policy priorities. Adequate 
feedback mechanisms between the Agency and the parent DG will be established to ensure 
project results feed into policy making.  
Since most day-to-day   tasks (e.g., visiting projects every year, answ ering project queries) 
will be implemented through technical assistan ce, the Agency staff could concentrate on 
ensuring information flow towards the pare nt DGs,  and  on financial management and 
control, including gathering of project data.  Staff in the parent DG will concentrate on ensuring that results of the projects are duly integrated in the policy definition and 
implementation and on transferring informati on to other DGs. Promotion of Integrated 
Projects and networking could be done eith er by the Agency or by the parent DGs.  
However, there might be some risks that an additional layer of communication between 
projects and the parent DGs reduces the informa tion flow and thus the capacity to use project 
results into decision making.   
o Sub-option G1.b: Externalisati on replacing technical assistance
 
Most probably, the Agency staff can provide  the services undertak en by the technical 
assistance external contractors at the same leve l of effectiveness and efficiency. At an annual 
staff cost of €64,000, the additional 80 fulltime e quivalent contract posts would cost €5.1 
million. There is also a requirement for additional administrative posts, adding a further 16 posts. The total staff cost would be €6.1 million.  In addition, there would be overhead costs 
and since the staff would be based in Brusse ls, there would be the additional mission costs 
currently avoided by using contract or staff based in the Member States. The total cost of this 
option, with the replacement of external assistance, would be €14.6 million, representing 
6.0% of the Programme budget ; a saving of €0.5 million (3.0%) on the centrally managed 
option.  
On the other hand, there would also be cost savi ngs if the work is brought in-house rather than 
the parent DG (or Agency) having to manage and supervise the contracting and undertaking 
of this technical assistance ex ternally. In addition, the Agency staff would have a constant 
direct contact with the proj ects through the close technical and financial monitoring, and 
annual visits which will help ea rly detection of problems and if needed rapid contact with the 
parent DGs. However, arguably, the workload  of the Agency staff would increase. 
   
                                                
 
39 Additional staff for horizontal (administrative) tasks is based on current demand from EACI that 
estimates a need of 20%. 
40 Applied to current programme budget assuming that for some years the  transitional costs will be 
standing still. 
 
58 Box 13 – Summary of advantages and disadvant ages of the full ext ernalisation option 
Advantages   
• The majority of the staff in the Agency (up to 75%) can be contract posts that are significantly cheaper.  
• The recruitment of such contract staff will be of a high quality and tailored technical expertise.41 The Agency employees 
could therefore undertake the bulk of work that is currentl y undertaken by the LIFE Unit staff and external contractors 
(under the option that includes technical assistance): 
- Management tasks – specific tasks rela ting to Programme management such as  financial and tec hnical management 
e.g. payment processing (and finding ways to improve the processing)42; 
- Programme implementation e.g., ensuring reports processed wi thin deadlines and selection of projects takes place on 
time; 
- Communication and dissemination activities. 
• The recruitment of staff with a specific technical profile coul d also increase the effectiveness of technical monitoring and 
improve the communication of lessons learned to the parent DGs (provided the organisationa l arrangements are based on 
thematic expertise rather than ge ographical or a mixture of both).  
• The use of contract posts in the Agency  also ‘frees up’ the Commission’s human res ources in terms of ‘saving’ permanent 
posts and allowing for the re-allocation of th em to core policy tasks, which in itself reduces the need for contract posts. In 
fact, the Agency option could free up 19 posts;43 of which two thirds would be AST posts and one third AD posts. 
However, this would materialise only af ter a number of years and only if all ongo ing projects would be transferred. 
 
Disadvantages  
• Integrated Projects are to act as a catalyst for effective ma instreaming into the other EU financial instruments. This will 
require careful design and cooperation with the policy units in the parent DGs and other DGs to ensure their success.  
• Integrated Projects are also to provide examples of how inte gration is possible in practice. Therefore it is important to 
know whether this approach works and to identify at an early stage problems and to react rapidly. Close monitoring by the 
Commission and contact with the benefici aries is needed to ensure this early detection and quick solution finding.  
• The preferred option for the Programme is one which concentr ates on strategic sectors, re quiring enhanced cooperation 
and management to effectively contri bute to policy design and im plementation and high quali ty technical support to 
ensure replication of results is achieved. As a result, there is a risk that the Ag ency option would decrease the ability of 
this option to deliver the expected added value. For example, Integrated Projects for Nature will test the development and 
implementation of the Prioritised Action framework (PAFs) requi red by the Habitats Directive. It is essential that the 
Commission closely follows how these new fr ameworks are developed in different Me mber States and is able to quickly 
react to demands for advice. This is more  effectively done if the monitoring and ma nagement of the project remain within 
the Commission.  
• There is also a clear link between Integrated Projects and implementation and compliance of  some of the most demanding 
legislation (Water Framework Directive or the Waste Fr amework Directive). In the case of the Water Framework 
Directive, the projects will be implementing plans that are directly assessed by the Commission to determine whether a 
Member States is meeting its obligations under the Directive.  In addition, based on the experience with Nature projects, 
this type of project provides technical in formation that can be used for infringement  cases or pilot cases . Therefore, strong 
policy link with thematic  units during design and implem entation of these projects is ne cessary, and could not be done 
efficiently by an Agency.  
• If the level of the Programme remains similar to current levels , or if the budget increase is associated with a similar or 
fewer numbers of projects but with a larger average size, a nd especially if technical assistance is used because of the 
importance of maintaining the current networks, the Agen cy option becomes less attractive on cost saving grounds. 
                                                 
41 See Technopolis (2006), ‘Cost Benefit Analysis of the externalisation of the certain tasks regarding the 
implementation of the Competitiveness and Innovatio n Framework Programme (2007-2013) through an 
executive Agency’. 
42 According to the European Court of Auditors Special Report No. 13, ‘Delegating implementing tasks to 
Executive Agencies: a successful  option?’ (2009), the contracting time for the ‘Public health’ 
programme dropped from 345 days to 219 when managed by an Agency; payment period shortened 
from 503 to 91 days and approval time for technical/financial reports dropped from 90 to 42 days. 
43 36 post minus 9 seconded and less 8 staff used in parent DGs for governance. 
 
59 • G2: Hybrid solution: externalisation of traditional projects - keeping Integrated 
Projects for the Environment s ub-programme within the Commission  
Given the need to ensure that Integrated Projects feed back into policy design, provide more 
effective information for policy implementation and maximise their demonstration value, one 
option which would address these objectives in an  efficient way would be  to keep Integrated 
Projects for the Environment sub-programme  under direct central management.   
In terms of costs, the option remain more or less at the same level as option G1 (around 6- 
6.3% of the Programme budget). As a form of sens itivity analysis, the calculations used for 
externalisation costs can be tested to see if they  change with the change  in number of projects 
that is likely to occur with the introduction of  Integrated Projects and thus an approximation 
to calculating costs for the Hybrid solution. Th is is done comparing central management with 
the Agency option of Agency where t echnical assistance is not replaced.  
The average number of projects managed under the current Programme is 600 projects per 
year. The total number of projects will de crease in absolute and relative terms as a 
consequence of the phasing-in of Integrated Pr ojects (which are larger  in size). Applying a 
complexity factor of "2" to Integrated Projects,  it would mean that on average the equivalent 
of 155 traditional projects would start each ye ar, and over time the equivalent of around 400 
projects would be running at any one time.  
If Integrated Projects are kept within the parent  DG, the cost will be similar to externalisation 
but the policy links will be ensured. The parent  DGs have direct access to  Integrated Projects 
making it easier to transfer information about the project results and identification of the 
funds mobilised under other EU instruments as well as to provide inputs to Common Strategic 
Framework and Investment partne rship contracts. This would be  mainly done through regular 
contacts with beneficiaries, including on-site  visits and close technical monitoring of the 
achievement of outputs and targets. However, in  the second half of the programming period, it 
could be that the parent DGs managed almost a ll projects (due to the progressive phase-in of 
Integrated Projects), making the externalisation option ineffective for traditional projects under the environmental sub-programme. The mi d term evaluation of the new Programme 
will need to revisit the analys is to assess whether Integrat ed Projects should be managed 
directly or by an Agency. 
6. C
OMPARING THE OPTIONS  
6.1. Summary of the assessments  
The different options assessments as scored in  the previous section are summarised in the 
assessment grid (Table next page) 
 
 60     Effectiveness  Coherence  Efficiency  
Options (down) / Specific Objectives 
(across) 1. Better alignment with EU policy 
priorities including climate action 2. Promote the funding of IP 
and their share in LIFE 
project funded 3. Develop synergies and 
complementarity with other EU 
funds 4. Align selection criteria with EU 
added value  and solidarity/effort 
sharing Simplify and streamline the LIFE 
Programme 
A. Options for strategic planni ng: top down versus bottom up 
A. 1- Baseline  A1. – Limited 
- Better focused on Biodiversity and 
Climate due to pre-allocation of resources: 
25% of LIFE for Climate Action sub-
programme. However within sectors, great diversity of projects financed. 
- Very flexible: largely bottom-up 
approach for projects, including IP.  - Impacts: €750-1,000 million/year.  A1. – Neutral:  
Progressive phase-in of larger 
IP in all sectors. 
 A1. - Excellent :   
Structured cooperation with other EU funds and positive 
complementarity enhanced through 
integrated projects.  A1. – Neutral:  
No specific selection criteria attached to 
priorities. A1. – Neutral:  
No change compared with business as 
usual. 
A.2 Top-down approach for all 
types of projects 
(flexible for traditional projects 
and rigid for IP) A2. – Excellent 
- Specific constant priorities, Biodiversity 
and Climate Action.  
- Possibility to establish more precise priorities for action within rolling plan 
translated into the annual calls. 
- IP focused on three sectors: nature, water and waste in line with biodiversity and 
resources efficiency targets. 
- Impacts: 20% increased compared to A1 (between €900 and 1,210 million/year). A2. - Excellent:  
Progressive phase-in of larger 
IP in priority sectors. 
Possibilities for adjustment.  
 A2. -  Excellent :   
Structured cooperation with other 
EU funds and positive 
complementarity enhanced through integrated projects.  A2. -  Excellent :   
Selection criteria will be adapted to 
priorities.  A2. -  Excellent :   
Mechanism for increased focus will 
simplify the way the Programme 
works.  
A.3. Top-down 
approach for IP and 
bottom-up for other 
interventions A3. - Good 
- Better focus on Biodiversity and Climate 
due to pre-allocation of resources: 50% of 
Environment sub-programme to Biodiversity. 25% of LIFE for Climate 
Action sub-programme. However within 
sectors, great diversity of projects financed. 
- IP focused on three sectors: nature, water 
and waste in line with biodiversity and resources efficiency targets. 
- Flexible: largely bottom-up approach for 
projects.  
 A3. – Excellent 
As above. Progressive phase-in 
of larger Integrated Projects in 
priority sectors (water, waste and nature). But more limited 
possibility for adjustment.  A3. -  Excellent :   
Structured cooperation with other 
EU funds and positive 
complementarity enhanced through integrated projects.  A2. -  Good :   
Selection criteria will be adapted to 
priorities, but only for IP.  A2. -  Good :   
Mechanism for increased focus will 
simplify the way the Programme 
works.  
 
 61     Effectiveness  Coherence  Efficiency  
Options (down) / Specific Objectives 
(across) 1. Better alignment with EU policy 
priorities including climate action 2. Promote the funding of IP 
and their share in LIFE 
project funded 3. Develop synergies and 
complementarity with other EU 
funds 4. Align selection criteria with EU 
added value  and solidarity/effort 
sharing Simplify and streamline the LIFE 
Programme 
B. Options for thematic concentration of Integrated Projects 
B1. Baseline B1. – Neutral:  
The broad scope for the projects will not 
allow financing a critical mass of IP to 
have a better alignment with EU policies. B1. – Good 
A wide scope of sectors to be 
covered will encourage 
submission of IP. B1. – Good 
Synergy and complementary with 
other funds will be developed. B1. – Neutral 
Thematic concentration has no specific 
impact. B1. – Neutral 
Funding of larger projects is part of 
simplification, but thematic 
concentration has no specific impact. 
Thematic concentration of IP 
B2a. Concentration on 3 sectors B2a – Good 
Concentration on limited sectors will allow 
a better alignment with EU priorities B2a – Excellent 
Submission of IP will be 
encouraged in few concentrated sectors B2a - Good 
Synergy and complementary with 
other funds will be developed. B2a – Neutral 
No specific impact B2a – Excellent 
Concentration is part of 
simplification. Focusing on three sectors will only require specific 
criteria for three sectors.  
Thematic concentration of IP 
B2b.  Concentration on 4 sectors B2b – Excellent 
Concentration on limited sectors will allow 
a good alignment with EU priorities B2b – Good 
Submission of IP will be 
encouraged but increased risks for achieving targets in a less 
successful sector. B2b – Good + 
Synergy and complementary with 
other funds will be developed for 4 sectors. B2b – Neutral 
No specific impact. B2b – Good 
Concentration is part of 
simplification. Focusing on four sectors will only require specific 
criteria for four sectors. 
C. Options for allocation of resourc es between different priority areas 
C1. Baseline C1. – Limited 
The alignment with EU priorities will only 
be limited (for Climate Action). 
 C1. Neutral 
No specific impact.  
 C1. – Neutral 
No specific impact. 
 C1. - Neutral 
No specific impact.  C1. - Neutral 
No specific impact. 
 
 
C2. Allocation of 25% of the Programme funds to 
climate action and 
50% to biodiversity C2. – Good 
Projects would better a ddress EU priorities. 
 C2.- Good 
IP will be promoted in 
Biodiversity. 
 
 C2.- Neutral 
No specific impact.  C2. – Good 
- Better EU added value and solidarity. 
- New Member States with high nature 
assets (e.g., ES, SL , BG) would probably 
be favoured.  C2. - Neutral or slightly negative 
No specific impact. Ensuring 50% 
nature may add an additional 
complication to the selection. 
D. Options for geographical distributional impacts (national allocations) 
D1. Baseline D1. – Neutral 
Distribution of all projects based only on 
the quality of the application and their demonstration value (capacity to develop 
multipliers). No geographical key.  D1. - Limited 
Small and less developed MS 
may be not prepared to submit IP and be discouraged by a 
purely merit based approach.  
 D1. – Limited 
Based on quality onl y. Therefore, 
no possibility to take into account the fact that some MS will have 
limited choice in obtaining funding 
from other EU funds.   D1. - Neutral 
- Distribution all projects based on the 
quality of the application and their capacity to develop multipliers.  
- Prioritisation of transboundary project, 
however, no consideration of solidarity and effort sharing. Probably IT, ES, DE 
will continue being most successful.  D1. - Excellent 
Criteria based on EU added value will 
reduce the steps in selection procedure. 
 
 
D2. Traditional 
projects merit only, D2. – Good 
Distribution of integrated projects to D2.- Good 
- Discretion by the Commission D2.- Good 
Discretion by the Commission to D2. – Good 
- Traditional projects to be selected based D2. - Neutral or slightly negative 
Geographical balance may add an 
 
 62     Effectiveness  Coherence  Efficiency  
Options (down) / Specific Objectives 
(across) 1. Better alignment with EU policy 
priorities including climate action 2. Promote the funding of IP 
and their share in LIFE 
project funded 3. Develop synergies and 
complementarity with other EU 
funds 4. Align selection criteria with EU 
added value  and solidarity/effort 
sharing Simplify and streamline the LIFE 
Programme 
ensuring 
geographical balance 
for IP ensure geographical balance to allow for 
some reflection of solidarity and effort 
sharing. Priority to transboundary projects.  
 to ensure geographical balance 
may encourage small and less 
developed MS to apply with 
quality proposals.  - Flexible and allows for 
adjustments. 
 
 ensure geographical balance may 
take into account that certain 
MS/regions cannot obtain funding 
from other EU funds.  on their demonstration and replication 
potential. Priority to transboundary 
projects.  
- Distribution of IP to ensure geographical balance: at least one IP per MS in waste 
and nature sectors and at least one IP per 
transboundary RBD (Danube, Rhine, etc). At least two projects per bio-geographical 
region.  
- New Member States with big capacity deficiencies, MS with high nature assets 
(e.g., ES, SL, BG) and MS hosting big 
transboundary RBD (FR, HU, DE, AT, RO) would probably be favoured.  
- Flexible and allows for adjustments.  additional sub-step in the selection 
process. 
 
 
D3. Traditional 
projects merit only 
and national allocations for IP D3. – Good 
- Distributional allocation pre-established 
and agreed with MS based on environmental needs per each sector for 
Integrated Projects.  
- Fixed allocations for the programming period may imply selecting projects that 
are of less quality than projects submitted 
by other MS . D3. – Good 
- Existence of allocations may 
encourage all MS to apply but allocations may remain unused. 
- Not flexible . D3.- Good 
Fixed national allocations may 
reflect the fact that certain MS cannot obtain funding from other 
EU funds. However, it will be 
difficult for MS where only some regions are excluded.  D3. - Good 
- Traditional projects selected as above. 
Distributional allocation pre-established and agreed with MS based on 
environmental needs per each sector for 
Integrated Projects. Will encourage smaller or less devel oped MS to apply for 
an IP.  
- Fixed allocations for the programming 
period may imply selecting projects that 
are of less quality than projects submitted 
by other MS.  -Will reduce flexibility. 
-Allocation may remain unused.    D3. - Negative 
Fixed allocation largely increase the 
number of sub-steps in the selection process complicating and lengthening 
the selection process.  
E. Options for funding activities under Governance and Awareness 
E1. Baseline 
Enhanced NGOs, 
Commission 
communication and communication 
obligations in 
projects E1. – Neutral 
Possibility to carry out tailored campaigns 
and enhanced obligations for NGOs and 
communication activities on projects not much dependent on planning. E1. – Good 
Possibility to carry out some 
dissemination activities to 
promote IP through enhanced Commission communication 
activities and communication 
obligations in projects. E1.- Good 
Possibility to carry out disseminate 
project results for mainstreaming 
under other EU Funds through enhanced Commission 
communication activities and 
communication obligations in E1.-Good:  Selection criteria for NGOs to 
favour newly create d and most active 
NGOs.  E1 - Neutral 
 
 63     Effectiveness  Coherence  Efficiency  
Options (down) / Specific Objectives 
(across) 1. Better alignment with EU policy 
priorities including climate action 2. Promote the funding of IP 
and their share in LIFE 
project funded 3. Develop synergies and 
complementarity with other EU 
funds 4. Align selection criteria with EU 
added value  and solidarity/effort 
sharing Simplify and streamline the LIFE 
Programme 
 projects.  
E2. Enhanced NGOs, 
Commission communication and 
communication 
obligations in projects, and specific 
grants projects for 
information and communication E2.- Excellent 
Activities specifically designed to 
disseminate lessons learned, including 
specific projects. 
 E2.- Excellent 
Activities specifically designed 
to disseminate lessons learned, 
including IP examples.  E2.- Excellent 
Activities (e.g., projects) 
specifically designed to disseminate 
lessons learned for mainstreaming.  E2.-Good:   
Selection criteria for NGOs to favour 
newly created and most active NGOs.  E1.- Neutral 
F. Options for simplification 
F1. Baseline  F1.-Good 
Package of measures aligns with EU 
priority of simplifying EU funding 
instruments. F1.-Good 
Larger projects and IP part of 
the simplification measures to 
be included.  F1.-Neutral 
No particular impact F1.-Neutral 
No particular impact. F1.-Good 
- Simplification of the application 
procedure through ensuring paperless 
and more effective submission and 
avoiding mistakes. - Funding of larger projects is part of 
simplification. 
F2 Baseline + Selection procedures F2.-Excellent 
Through 2-step approach the Commission 
will ensure that only most relevant IP are admitted to the second stage.  F2.-Excellent 
- 2-step approach designed to 
facilitate and promote the submission of IP. 5-page 
concept paper instead of 100-
200 pages proposal. Proposal in the second stage only focused 
on first 2 years and measures 
included in the already prepared environmental action plan 
(significantly less than current 
proposals for 4-5 years).  - Simplification in reporting 
also designed to promote 
submission of IP (2 year cycle reporting -25% less than for 
traditional projects), at least 4 
payments instead of 3. F2.-Good 
Those IP submitting a concept 
paper where high synergies with other EU funds are ensured will be 
admitted to the next stage.   F2.-Good 
Through 2-step approach the Commission 
will ensure that only most relevant IP are admitted to the second stage. F2.-Good+ 
- Multiprogramming for NGOs to 
limit the number of call for proposals and thus bidding costs.  
IT tools to reduce bidding costs 
between 7-12% . Reporting obligations for IP to reduce 
reporting obligations by 25% with a 
proportional reduction of reporting costs. 
- 2-step approach to reduce bidding 
costs for unsuccessful applicants. For successful applicants, savings may be 
outweighed by increase costs for 
negotiation with large number of associated beneficiaries.  
 
 64     Effectiveness  Coherence  Efficiency  
Options (down) / Specific Objectives 
(across) 1. Better alignment with EU policy 
priorities including climate action 2. Promote the funding of IP 
and their share in LIFE 
project funded 3. Develop synergies and 
complementarity with other EU 
funds 4. Align selection criteria with EU 
added value  and solidarity/effort 
sharing Simplify and streamline the LIFE 
Programme 
- Ineligibility of certain costs 
together with increased co-
financing rate designed to easy 
reporting and reduce error rate especially in large projects (as 
is the case with IP).  
F3- Baseline+ 
Payments F1.-Good 
No particular impact compared to the 
baseline. F3.-Excellent 
Simplification of reporting 
costs because of reduction of eligible costs and increased use 
of lump sums may encourage 
submission of IP. Possible negative impact of ineligibility 
of certain personnel costs would 
be compensated with increased co-financing rate.  F1.-Neutral 
No particular impact. F1.-Neutral 
No particular impact. F3.-Excellent 
Simplification of reporting costs 
because of reduction of eligible costs and increased use of lump sums and 
reduction of error rate.  
G. Options for externalisation 
G1 Baseline 
G1a – Agency without TA 
 
G.1b- Agency with TA G1a & G1b-Neutral  
- Programming  within the parent DG 
ensuring a link between the projects and 
policy priorities. 
- Solid feedback mech anisms to ensure 
project results feed into policy making. 
Technical expertise of recruited staff make 
improve effective management and transfer of results and lessons learned. However, if 
also carrying out tasks normally performed 
by technical assistance will increase workload. 
- Risks that an additional layer of 
communication between projects and the parent DGs reduces the transfer of 
information and therefore the policy link  
This would be particularly significant for IP that are closely link to MS 
implementation obligations under the 
specific Directives and require to close G1a & G1b - Neutral 
- IP promoted through 
communication activities. In E1 
those communication activities 
will be managed by the Agency as per Commission guidelines. 
- However, the LIFE units have 
expertise based relationship with the MS, which may be lost 
if IP were to be managed as 
well by the Agency. 
 G1 - Limited or Neutral 
- The parent DG and the Agency to 
retain relation with the other funds. 
However no direct information 
from the projects.  - If there are defaults in the transfer 
of knowledge between the Agency 
and the parent DG, the chances of building synergies with the other 
funds may be reduced. 
- In addition, increased risks if not timely spotting projects that may be 
compensatory measures to 
infrastructure projects that should be financed by the MS or the 
private operator.   
 G1.- Neutral The three options in economic terms 
are rather neutral  with: 
- Option 1a representing around 6.2% 
of the Programme. 
- Option 1b represents around 6.0%. - Hybrid will remain in between . 
 
 65     Effectiveness  Coherence  Efficiency  
Options (down) / Specific Objectives 
(across) 1. Better alignment with EU policy 
priorities including climate action 2. Promote the funding of IP 
and their share in LIFE 
project funded 3. Develop synergies and 
complementarity with other EU 
funds 4. Align selection criteria with EU 
added value  and solidarity/effort 
sharing Simplify and streamline the LIFE 
Programme 
monitoring by the thematic units in relation 
to the achievement of policy targets, policy 
development and drawing lessons. 
G2. Hybrid G2 - Good 
As above, but risks of loss of policy link 
between the IP and policy priorities will be reduced.   G2 - Neutral or a bit better  
In both cases, the Commission 
will promote IP through communication activities. In G1 
those communication activities 
will be managed by the Agency as per Commission guidelines. 
However, the LIFE units have 
expertise based relationship with the MS, which may be lost 
if IP were to be managed as 
well by the Agency.  G2 - Good 
The parent DGs have direct access 
to IP and the other DGs so it would be easier to transfer information 
about the project results and 
identification of the funds mobilised under other EU 
instruments as well as to provide 
inputs to CSF and Investment partnership contracts to ensure IP 
are included therein, and solve any 
deadlock situation that may arise. 
IP are supposed to bring greatest 
added value in terms of link with 
policy. G1.- Neutral The three options in economic terms 
are rather neutral  with: 
- Option 1a representing around 6.2% of the Programme. 
- Option 1b represents around 6.0%. 
- Hybrid will remain in between.  
 
 66    6.2. Comparisons  
 Effectiveness Coherence Efficiency 
 SO1 SO2 SO3 SO4 SO5 
Option A1 : Baseline 0 0 0 0 0 
Option A2:  Top-down approach for all type s of projects (flexible for 
traditional projects and rigid for IP)  +++ ++ 0 ++ ++ 
Option A3:  Top-down approach for IP and bottom-up for other 
interventions  ++ ++ 0 + + 
Option B1:  Baseline  0 0 0 0 0 
Option B2a:  Concentration on 3 sectors  + + 0 0 ++ 
Option B2b : Concentration on 4 sectors  ++ 0 0/+ 0 + 
Option C1:  Baseline  0 0 0 0 0 
Option C2:  Allocation to climate action and biodiversity  ++ + 0 + 0/- 
Option D1: Baseline  0 0 0 0 0 
Option D2 Geographical balance for IP  + ++ ++ + 0/- 
Option D3 : National allocations (specific amounts per MS) for 
IP  + ++ ++ + -- 
 Option E1 : Baseline: Enhanced NGOs, Commission activities 
and obligations for projects 0 0 0 0 0 
Option E2:  Enhanced NGOs, Commission communication, 
obligation for projects AND specific information and 
dissemination projects ++ + + 0 0 
Option F1 : Baseline 0 0 0 0 0 
Option F2:  Baseline + Selection procedures: comitology, 2 
stage procedure for IP and simplified reporting for IP + + + + + 
Option F3:  Baseline + Payments  0 + 0 0 + 
Option G1a:  externalisation wit hout replacing technical 
assistance 0 0 0 0 0 
Option G1b : externalisation replacing te chnical assistance 0 0 0 0 0 
Option G2:  Hybrid solution: externalisation of standard projects 
- keeping Integrated Projects within the Commission + 0/+ + 0 0 
6.3. Preferred option 
Based on the above comparison of the different sub-options, the prefer red option would be a 
LIFE Programme: 
• With overall thematic priorities for the en tire programming peri od inserted in the 
Regulation, a 2-3 year work plan with non exhaustive priorities defined by the 
Commission with the advice of the Member States ( Option A2 ). 
• With Integrated Projects focussi ng primarily on 3 or 4 sectors ( Option B2a or B2b ). 
• With allocation of Programme funds to climate action and other EU priorities 
(biodiversity) ( Option C2 ). 
• With a system to select traditional projects based on merit and a system to select 
Integrated Projects that en sures geographical balance ( Option D2 ). 
 
 67    • That enhances NGOs role in dissemination and different approaches for governance: 
enhanced Commission communication thr ough public procurement and specific 
dissemination and information projects financ ed through grants, as well as enhanced 
obligations on projects regarding dissemination and communication ( Option E2 ).   
• That uses IT-tool mechanisms for submitting proposals as well as a 2-step approach 
for Integrated Projects with 2-year cycle reporting obligations; and increases the use 
of lump sums, and simplifies eligibility of costs by restricting the eligibility of some 
costs ( a combination of Options F ). 
• With externalisation of the management of traditional projects to an existing agency 
while keeping the governance of the Progr amme within the pa rent DG (including 
comitology and programming) as well as th e management of Integrated Projects. 
Based on an evaluation to be carried out at  the end of the firs t programming period, 
the management of these projects co uld be progressively externalised ( Option G2 ). 
The preferred option will address efficientl y the main recommendations for improvement 
from the mid-term evaluation, in  terms of better thematic pr ioritisation of the Programme, 
simplification and good manageme nt. Synergies with other EU Funds would be significantly 
developed, both from the Commission's and nati onal authorities’ points of view, ensuring a 
better use of available funds for environment and climate policies. 
Finally, this option will generate around €900-1,210 million/year of environmental benefits, 
and savings of between 7-12% of bidding costs and 25% for reporting obligations.  
7. MONITORING AND EVALUATION  
The mid-term evaluation considered current m onitoring and evaluation largely effective and 
efficient. However, more focus on results was desirable. The mon itoring framework thus 
builds on the framework proposed for the current instrument44 but is revised according to both 
the new intervention logic and the changes made to the baseline scenario in the preferred 
option. Since there is no change in the ac tivities undertaken under the public procurement 
budget, the framework does not include these ac tivities. The framework is organised around 
two levels: 
1. Monitoring of outputs, results and im pacts, at project and Programme level 
At project level , as is the case now, projects will ha ve to accompany their proposals with 
expected outputs tables. They will be submitted with the proposal and will serve as basis for monitoring of progress. Some of the output indicat ors currently used, especially for the 
environmental part, will be adapted to reflect  the new features of the Programme. The updated 
output tables will be submitted with the mid-te rm and final reports. The after-LIFE plans will 
include a list of expected impacts that will serve as a basis to assess the sustainability of the 
project results. Current practice of ex-post m onitoring visits for selected projects will 
continue.   
At programme level,  thematic reports summarising the main achievements for a particular 
sector will be developed period ically (e.g., every two years after the end of the rolling plan). 
They will also serve as a basis for disseminating results and feed them into policy development and implementation. The practice of  organising yearly conference focusing on a 
sector will continue. A mid-term evaluation an d an ex-post evaluation of the Programme will 
also be carried out. However, it is important th at the mid-term evaluation is carried out when 
                                                
 
44 Proposed monitoring and evaluation framework for the LIFE+ Regulation, DG Environment, 2007 
 
 68    there are already some projec t results. Annex 10 develops th e relationship between output 
indicators (and other indicat ors) and the objectives.  
2. Tracking of expenditure at programme level 
In order to provide evidence of the co-benefits  that both sub-programme s can bring to specific 
priorities such as climate action and biodiversity, and better illustrate the level of spending available throughout the Programme for these prio rities, the mon itoring framework will also 
include the methodology for tracking of climat e and biodiversity-related expenditure as 
defined in the June 2011 MFF Co mmunication and derived from th e OECD "Rio markers".   
In relation to climate action, the MFF Communicat ion stated that mainstreaming of climate 
action must be visible, robust and accompanied by a clear cross-cutting obligation to identify 
where the Budget promotes climate action or energy efficiency so that th e EU is able to set 
out clearly how much of its sp ending relates to climate acti on, by using a comm on tracking 
procedure for climate related expenditure.   
Tracking of climate-related expenditure will be performed according to three categories, 
based on an established OECD  methodology ("Rio markers"): e xpenditure where climate is 
the principal (primary) objective (counted as 100% - climate related onl y); expenditure where 
climate is significant, but not predominant obj ective (counted as 40% - significantly climate- 
related); and expenditure not ta rgeted to climate objectives (counted as 0% - not climate 
related).  
As regards biodiversity, the 'Rio markers' es tablished by the OECD and already used by the 
Commission for external instruments will be  integrated in the existing methodology for 
measuring performance used for EU programmes. They will also help to demonstrate the co-
benefits of climate and biodivers ity expenditures, and to highlight  the biodiversity co-benefits 
of climate spending on REDD+ (Reducing Em issions from Deforestation and Forest 
Degradation) actions.  
Better tracking of climate and biodiversity expenditure could be possible by applying “Rio 
markers” for instance also at project level. This could be done by continuing the current 
practice of including in the call  for proposals an option for appli cants to indicate whether their 
proposal could be considered climate or biodiversity-related according to the OECD 
methodology. This would allow identifying each y ear the expenditure de dicated to the two 
priorities by the entire Programme beside th e 50% earmarked resources to biodiversiy under 
the Environment sub-programme and 25% earmarked resources for Climate Action sub-programme under LIFE.  
 
 69    8. ANNEXES  
(1) List of Abbreviations  
(2) The LIFE Programme as per the Communi cation from the Commission on a Budget 
for Europe 2020, 29th June 2011 
(3) Summary of Stakeholders' consultations  
(4) Summary of conclusions and recommendati ons from the Ex-post evaluation of the 
LIFE Programme (1996-2006) and from  the Mid-term evaluation of the 
implementation of the LIFE+ Regulation (2007-2009) 
(5) Scale of the environmental problem, unde rlying causes and benefits of action 
(externalities) 
(6) Examples illustrating the EU adde d value of the LIFE Programme  
(7) Assessment of the LIFE+ Regulation: data used to calculate the impacts of the 
baseline scenario 
(8) Full assessment of the zero op tion and of the expanded option 
(9) Calculation of externals costs  
(10) Objectives and Monitoring framework 
(11) Integrated Projects 
(12) References