14. 10. 91 Official Journal of the European Communities No C 269/3 
also on participation, as set out in the Framework 2.4. Annex: C — Actions without financial impli-
Directive. cations for the Community budget 
2.3.3. Actions 2 to 5 are also readily endorsed. The Committee endorses the actions proposed. 
Done at Brussels, 3 July 1991. 
The Chairman 
of the Economic and Social Committee 
Francis STAEDELIN 
Opinion on the Green Paper on the Urban Environment 
(91/C 269/02) 
On 17 July 1991 the Commission decided to consult the Economic and Social Committee, 
under Article 198 of the European Economic Community Treaty, on the Green Paper on the 
Urban Environment. 
The Section for Protection of the Environment, Public Health and Consumer Affairs, which 
was responsible for preparing the Committee's work on the subject, appointed Mr Boisseree 
as rapporteur. It adopted the Opinion on 4 June 1991. 
At its 288th plenary session, (meeting of 3 July 1991), the Economic and Social Committee 
adopted the following Opinion unanimously 
1. Preliminary comments: content and significance of 
the Green Paper 
1.1. After involving experts and taking into account 
specialized conferences in various European cities, the 
Commission issued on 6 July 1990 a 'Green Paper on 
the Urban Environment' as a Communication to the 
Council and Parliament. In accordance with Article 198 
of the EEC Treaty, the Commission requested the Opin­
ion of the ESC. 
1.2. The Green Paper contains a presentation of' 
the problems affecting the urban environment and a 
comprehensive analysis of the causes of urban decay. 
In a second chapter the targets and guidelines for urban 
environmental improvement are formulated. Possible 
instruments for Community action are presented, and 
the following areas for action at Community level are 
listed: 
— urban planning, 
— urban transport, — protection and enhancement of the historical heri­
tage of European towns, 
— protection and enhancement of the natural areas 
within towns, 
— water management, 
— urban industry, 
— urban energy management, 
— management of urban waste, 
— comparative information on the state of the urban 
environment, 
— inititatives in the information field, 
— social initiatives, 
— inter-regional cooperation. 
In these fields, lines of action are suggested for the 
Community: these are not to be regarded as plans 
for implementation, but as examples of possible or 
necessary measures. Recognizing the limited remit of 
the Community in this field, the Commission produces 
No C 269/4 Official Journal of the European Communities 14. 10. 91 
recommendations, promotion measures, etc., which for 
the most part are aimed at towns. 
1.2.1. The Commission regards the Green Paper as 
a stimulus for discussion. In addition to obtaining the 
views of the European Parliament and the ESC, the 
Green Paper is to be widely distributed in as many 
European municipalities as possible in order to base 
discussion on day-to-day practice in towns. The 
Council of Ministers is to take a decision on possible 
lines of action, drawing on the results of national con­
ferences which have been or will be held on the subject 
of the Green Paper. 
2. Assessment of the project 
2.1. General evaluation 
2.1.1. The Commission first announced in its Fourth 
Action Programme for Environmental Protection that 
it would give particular attention to the environmental 
problems of urban areas. The ESC welcomed this 
announcement in its Opinion on the action pro­
gramme (1). 
2.1.2. The problems of the urban environment 
addressed in the Green Paper—consequences of high 
population densities, urban development and traffic, 
social imbalance and decline of cultural values—are a 
complex phenomenon. 
On the one hand, there are specific environmental ques­
tions: towns are particularly energy-intensive, and they 
also contribute to regional and global problems (CO, 
emissions and global warming). On the other hand, 
there are a number of general subjects on which the ESC 
has commented separately or is at present preparing an 
Opinion (e.g. on the 'new poverty', 'Europe 2000', 
immigration, and Community programmes on trans­
port, energy and regional policy). 
2.1.3. 70-80% of the Community population live in 
towns or conurbations. About 50% of these live in 
medium-sized towns. Not enough attention has been 
paid so far in the European Community's environmen­
tal policy to the urbanization of Europe. It is therefore 
to Jbe welcomed that the Commission is now 
implementing its announcement by issuing the Green 
Paper. 
2.1.4. In the Green Paper and the preceding expert 
opinions a wealth of empirical data has been collected: 
on the basis of practical examples from European 
towns, the bases of solutions have been documented 
and put forward for discussion. This documentation in 
itself is of great value. 
(») OJ No C 328, 7. 12. 1987. 2.1.5. Although the list of the presentation of the 
problems and their analysis are interesting and compre­
hensive the list of measures needed at Community and 
national levels is incomplete. However, the Green Paper 
is merely intended to serve as a stimulus to an open 
debate on the situation of european towns. Hence this 
ESC Opinion, too, can only be an interim assessment. 
The ESC is very interested in participating in further 
discussion, which should involve the social and econ­
omic organizations concerned with these problems. It 
would be good if the ESC could also find a valid 
representative organization for the interests of towns 
and municipalities at European level; perhaps the body 
representing those interests could be developed into a 
forum for this exchange of views. 
2.2. Special environmental problems of towns 
2.2.1. The Green Paper deals with urban environ­
ment problems not by specific types of environmental 
damage but horizontally, and justifies this by the multi­
plicity of interactions between the specific types of 
urban environment. 
The Commission assumes that the 'urban environment' 
complex should be dealt with uniformly since the con­
centration of population, industry, transport, etc., 
characteristic of towns (and conurbations) results in a 
disproportionate increase in environmental problems, 
but, on the other hand, also offers opportunities for 
economically, socially and culturally sensible solutions. 
2.2.2. The appropriateness of this approach is diffi­
cult to assess, since the Commission has not given a 
definition of the 'urban environment' problem area. In 
the ESC's view it is not possible to convert the Green 
Paper's approach into practical environmental policy 
without a clear definition. The ESC assumes that not 
only towns in the legal sence are meant, but also resi­
dential conurbations which have problems similar to 
those of towns; these conurbations also include the 
'development corridors' which have built up around 
new industrial activities. The repercussions of urban 
problems on the hinterland should also be considered. 
2.2.3. It may be advisable to subdivide into: 
— metropolitan areas, 
— medium to large towns, 
— other urban concentrations, 
since environmental problems, as dealt with in the 
Green Paper, vary from one of these categories to 
another. 
14. 10. 91 Official Journal of the European Communities No C 269/5 
As an example of such differentiation, the ESC would 
draw attention to the Directive on municipal water and 
sewage plan(1). 
2.2.4. A further difficulty lies in the question of 
whether the symptoms described the Green Paper are 
really attributable to a uniform set of problems in all 
Member States and regions. The Green Paper contains 
a wide range of relevant examples. From these and 
from the Committee's own findings it emerges that: 
— in large and constantly expanding parts of towns, 
especially on the outskirts, the same or similar prob­
lems characteristic of the 'urban environment' com­
plex are found, 
— the varying outward symptoms in the centres of 
European towns do not prevent the identification 
of a uniform set of problems, 
— the investigation begun with the Green Paper should 
be continued. 
2.2.5. Finally, it is particularly important to differen­
tiate between general environmental policy measures 
and specific measures for towns and similar areas. In the 
ESC's view measures to deal with urban environmental 
problems cannot be an alternative to the continuation 
and improvement of the Community's general environ­
mental measures. Indeed the improvement and intensifi­
cation of this general environmental protection will 
benefit the cities as well. Conversely, the situation of 
the town must lead to a intensification and acceleration 
of European environmental projection. 
2.3. Assessment of the analysis in the Green Paper 
2.3.1. The presentation here of urban environmental 
and their causes may be to the point, but is in no way 
complete. 
2.3.2. The Green Paper describes the situation as it 
was in 1989. It does not take account of the likely 
development in the coming years, which is predicted to 
entail a serious degradation of the environment; this 
applies particularly to: 
— the effects of the European Internal Market [see the 
1989 Report of the EC Commission Task Force and 
the ESC Own-initiative Opinion of 19 September 
1990 (2)], 
— the likely further concentration of population in 
certain large urban regions [see the ESC Opinionon 
the FAST Programme^)], 
— the regional shifts connected with structural change 
in industry. 
The Green Paper makes no assessment of positive devel­
opments in many towns (4). 
(!) OJ No C 168,10. 7. 1990. 
(2) OJ No C 332, 31. 12. 1990. 
(3) OJ No C 80, 28. 3. 1988. 
(4) E.g. Montpcllicr, to mention only one example among many. 2.3.3. The completeness of Commission's analysis 
cannot be assessed in detail in this Opinion. All the 
ESC can do is pick out examples of important subjects 
which, in its view, the Green Paper does not treat with 
the necessary thoroughness [complementary analyses 
and proposals for improvements may be drawn from 
the Organization for Economic Co-operation and 
Development (OECD) Study, Environmental Policies 
for Cities in the 1990s' — Paris, 1990]. 
2.3.4. The following subjects are listed without any 
indication of priority; the ESC reserves the right to 
express a view on the priority to be given to the various 
measures and decisions in a later additional Opinion 
after further discussion prompted by the Green Paper. 
a) The spatial separation or combination of residential 
areas and places of work is regarded as the most 
important problem of urban structure and develop­
ment. It has a decisive influence on traffic problems. 
The points made in the Green Paper are endorsed; 
in any case they are already the basis of town 
planning in Europe. The Commission's criticism of 
planning concepts of the past ('Athens Charter') can 
however play an important part in the rehabilitation 
and revitalizing of older urban areas (e.g. develop­
ment of derelict industrial sites, establishment of 
small and medium-sized firms). Attention must also 
be paid in future to leaving the necessary distance 
between polluting industries and residential areas. 
b) The relationship between town centres and outskirts 
is important; here too there should be more inter­
mixing (residential population in the inner city and 
an increase in retail, service, cultural, sport and 
recreational facilities in the outskirts). 
c) Differentiated allocation of public spaces (green 
areas, transport, services) and greater care taken in 
urban architecture and conservation of historic are­
as are decisive for the attitude of citizens to the 
urban environment (urban identity). 
d) In many parts of Europe there must be efforts to 
prevent patchy, extensive settlement in the open 
spaces between cities and the surrounding area; 
development axes for concentrated settlement must 
take account of available local public transport, and 
particularly rail transport. 
e) Noise pollution and its significance for the health 
of the urban population must receive more attention 
in town planning, and particularly in transport plan­
ning and management. Protection against noise can 
be assisted by the building of protective walls and 
No C 269/6 Official Journal of the European Communities 14. 10. 91 
embankments along traffic axes, maintaining pro­
per distances between these axes and residential 
areas, and using underground links (this is also 
sensible in terms of the cost/benefit ratio). 
f) A major problem in cities and conurbations is the 
lack—or loss—of social cohesion (rapid growth 
of towns, concentration of immigrants from other 
countries and those moving in from the surrounding 
countryside); a planned programme of residential 
building measures is required, along with measures 
to make up for shortcomings in training and further 
training, not least to make it possible to establish 
the necessary political and economic priorities. 
g) It is often recognized that urban environment prob­
lems are a result of the 'enforcement gap' in public 
administrations. This includes: 
— the lack of urban building plans and provisions 
capable of preventing chaotic development, 
— the failure to supervise compliance with building 
and planning provisions, so that illegal develop­
ments occur in urban areas. 
The distribution of decision-making powers at the vari­
ous levels (local, regional, or central) is therefore of 
special importance. Optimization of the allocation of 
powers should strive for autonomy, closeness to the 
problems and interdependence of town and hinterland. 
Where the local population has been able to participate 
in the planning process, this has made for environmen­
tally compatible urban development. 
3. Implementation of the Green Paper in terms of 
practical environmental policy 
3.1. Framework for Community action 
A positive assessment of measures to improve the urban 
environment does not automatically mean that these 
measures are suitable for Community action. The Com­
mission gives an inconclusive answer to the question of 
which action programmes (e.g. European legislation, 
financing programmes) can be derived from the con­
clusions of the Green Paper. The debate so far has 
shown that some lines of action appear to be entirely 
acceptable while others are thought to be very contro­
versial. 
3.2. Consideration of the urban situation in the con­
text of European environmental policy 
3.2.1. The Green Paper does indeed deal with many 
local solutions, but does not have so much to say about 
the European dimension, e.g. the necessary adaptation 
of European environment law and environmental policy 
to the problems of towns and conurbations. An 
improvement and intensification of Community environment protection in general would assist the sol­
ution of urban environment problems. Environmental 
protection standards are incomplete (e.g. air quality 
limit values only for SO,, N02, lead, dust and other 
particle emissions) and do not always correspond to 
the latest scientific findings [e.g. to World Health 
Organization (WHO) Directives]. 
3.2.2. But this also means that in general stricter 
requirements must be allowed for conurbations than 
elsewhere (example: measures for industry and trans­
port in the event of local or regional smog risk). All 
environmental provisions should—in accordance with 
Article 130t of the EEC Treaty—include a proviso on 
such rules for local conurbations. Such a deviation from 
the principle of uniformity can be necessary. 
3.2.3. The particularly urgent tasks in conurbations 
include that of solving waste problems. The stricter 
Community rules in preparation will help to solve these 
problems. In the ESCs view it must be possible for 
cities to prescribe local solutions. Out of consideration 
for the cities the Community must do everything it can 
to avoid the creation of waste (especially the growing 
mass of waste packaging), reduce it considerably, or 
collect it in such a was as to permit recycling. The legal 
framework must be such that municipalities can cope 
with waste problems, partly by using 'economic models' 
(e.g. waste disposal by private sector firms). This also 
applies to questions of liability and the provision of 
funds for the removal of so-called 'old waste'; the 
presence of such waste often makes it impossible to 
redevelop derelict industrial sites. 
3.2.4. The Commission rightly states that a large 
proportion of urban environment problems are caused 
by road traffic. The aim of measures must be not merely 
to reroute environmentally damaging road traffic, but 
to reduce it; the traffic aspect of environmental policy 
must therefore aim to promote the development and 
acceptance of local public transport. 
It would be logical to concentrate the Community's 
environmental policy more on the following problems: 
— faster adaptation of provisions on motor vehicle 
exhausts and noise (including that of lorries) to 
the latest technology, and provisions on vehicle 
equipment, e.g. catalytic converters, 
— intensified and accelerated support for the develop­
ment of 'environment-friendly' vehicles (including 
electric cars), 
14. 10. 91 Official Journal of the European Communities No C 269/7 
— promotion of work on parking and traffic guidance 
systems to achieve environmental optimization of 
traffic management (taking account of the exchange 
of relevant experience between national adminis­
trations, towns, regions, environmental associations 
and industry — an exchange which should be pro­
moted on a European scale), 
— in addition, more should be done to induce the 
Member States to improve the supervision and 
implementation of existing environmental protec­
tion measures, particularly those on the limitation 
of vehicle exhaust gases. 
3.3. Integration of environmental policy in other pol­
icy fields 
3.3.1. There is general agreement that urban 
environmental problems can be best alleviated at Euro­
pean level by incorporating environmental policy 
requirements into other policy fields of the Community 
and coordinating them at an early stage [Article 130r(2) 
of the EEC Treaty]. European measures should be made 
subject to an 'urban compatibility' audit. 
3.3.2 Examples of Community policies of consider­
able importance for the development and rehabilitation 
of towns and conurbations: 
— European transport policy: inter-urban transport 
infrastructures influence inner-city priorities 
(cf. Commission Communication on Environment 
and Transport), 
— regional policy: EC programmes and development 
projects should entail an assessment of their 
environmental impact, 
— energy policy: the expected concentration in the 
energy sector stands in the way of 'environment-
friendly' decentralized solutions (e.g. district 
heating by combined power plants) and of adapting 
energy production capacity to people's needs 
{cf. Commission Communication on Environmental 
and Energy), 
— research and technology policy; the development of 
alternative (renewable) energy sources, which are 
also important for environmental protection in 
towns, is impossible without an intensified pro­
motion effort. 
There are similar ramifications in social policy and 
cultural policy fields. 
3.3.3. The effects of the European Internal Market 
(1992/1993) will be particularly important for the urban 
environment: 
a) The Internal Market (frontier-free Europe) will give 
rise to activities which will also benefit urban, social 
and economic development. b) On the other hand, the Internal Market may lead 
to a further worsening of urban traffic problems, 
for example, bringing greater freedom of movement 
in transport {cf. the ESC's own-initiative Opinion 
on environmental policy and the Single European 
Market (*) and the Task Force Report on The 
environment and the internal market — 1992: The 
environmental dimension). In the lines of action 
suggested in the Green Paper, the ESC finds no 
attempt to convert findings into internal market 
measures; yet this is how a town-related environ­
mental policy should immediately begin! 
3.4. Urban planning and design 
3.4.1. Urban environment problems are partly due 
to wrong decisions and shortcomings of urban planning 
(construction, settlement and infrastructure planning) 
and regional planning. Under the EEC Treaty town 
planning and regional planning are outside the remit 
of the Community bodies. In the Member States they 
fall within the tasks of the local authorities (municipalit­
ies, cities, districts, etc.), which are more or less auton­
omous in the physical planning of the local or regional 
environment. 
Even where intervention at Community level would be 
possible for environmental protection purposes, the 
ESC feels that care should be taken to check whether 
the subsidiarity principle (Article 130r of the EEC 
Treaty) does not rather require the allocation of these 
tasks to the national and local authorities, especially 
since the solution of complex urban environment prob­
lems requires integrated plans which are only possible 
at the local or regional level. 
In view of this the ESC agrees with the Commission's 
statement that it does not intend to propose legal instru­
ments on urban or regional planning at the Community 
level, even for purposes which might be environmen­
tally desirable. The ESC would however, like to see 
ideas on an environment-orientated 'urban policy' 
developed at Community level, and regional associ­
ations promoted to coordinate such a policy on a cross-
frontier basis. 
3.4.2. In the ESC's view the EC Directives on 
environmental compatibility assessment (2) should be 
extended to municipal planning, building and infra­
structure projects; this is already done in some Member 
States. 
Moreover, the ESC's point [in its own-initiative Opin­
ion on environmental policy and the Single European 
Market (J)—point 9.2] is reiterated—that a revision of 
the EEC Treaty should give the Community additional 
framework powers for environmentally orientated 
town and country planning in cases of European 
importance, or of urban areas which straddle frontiers. 
(!) OJ No C 332, 31. 12. 1990. 
(2) OJ No L 175, 5. 7. 1985. 
No C 269/8 Official Journal of the European Communities 14. 10. 91 
3.4.3. The Commission includes the risks to the 'his­
torical heritage of European cities' among urban 
environment problems and proposes activities to pro­
tect monuments and the unity of blocks, streets, etc. 
This approach has been criticized in experts' discussions 
on the Green Paper. The ESC wonders whether the 
Community's terms of reference on environmental pro­
tection include this subject, especially since there are 
cultural and scientific (e.g. archaeological) implications. 
Certainly, the Green Paper's intention is not to develop 
legislative activities at the Community level for protec­
tion of monuments and whole blocks or streets. In any 
case, environmental protection requirements must take 
account of the vulnerability and intrinsic value of 
ancient monuments and similar objects. This means 
intensifying environmental protection with regard to 
the historical heritage of European cities. 
But apart from all this, the ESC feels that consideration 
should be given to placing objects of European cultural 
significance under the special protection of the Com­
munity and to contributing financially towards their 
upkeep, as expressly provided for recently in the LIFE 
Programme C1). 
4. Further ESC proposals for implementing the Green 
Paper 
4.1. The ESC supports the setting-up of a scientific/ 
consultative institution for urban environment ques­
tions at Community level (such as the plan, put forward 
at national conferences of the Green Paper, for a Euro­
pean academy for urban environment questions). The 
Community should at least share the costs, in order 
— to ensure a Europe-wide approach, 
— to use the above-mentioned institution for 
implementing the Green Paper (exchange of infor­
mation and promotion of cooperation), 
— to ensure cooperation with the recently established 
European Environment Agency. 
The scientific/consultative institution could draw up 
guidelines for solving municipal environment problems, 
collect and collate data from the various fields, provide 
expert opinions on the need for and scope of rehabili­
tation in practical cases, train specialists, provide furth­
er training for officials which draws on the latest know­
ledge, and operate as a clearing house for the 
(!) Doc. COM(91) 28 final. transfer of knowledge and experience on the transre-
gional aspects of the urban environment. If such an 
institution were set up, it should cooperate closely with 
national and regional bodies whose tasks are similar, 
in order to ensure coordination. 
4.2. The ESC reiterates the proposal in its Own-
initiative Opinion on Environmental Policy—an 
important factor in economic and social develop­
ment (2)—that a European Environment Fund be set up 
to finance or co-finance solutions to problems in the 
fields covered by the Green Paper. The existing 
Regional and Social Funds can only be used in a very 
limited way for this, since their priorities are elsewhere. 
The ESC is pleased to note that the Commission 
recently presented a proposal for a financing instrument 
for the environment (LIFE), which includes the ESC's 
points; it remains to be seen whether the planned budget 
is enough (3). A European Environment Fund could 
promote pilot projects serving as models. However, the 
ESC thinks it worth bearing in mind certain objections 
to its use for such pilot projects: 
— the greater administrative capacity and better con­
tacts of very large towns should not lead to smaller 
towns—often with very serious unsolved problems 
—obtaining practically no share in such pro­
grammes, 
— pilot projects which merely implement tried and 
tested technological method should not be eligible 
for assistance, 
— towns should be able to obtain funds only if they 
can produce an integrated planning scheme for this 
field. 
It could also assist in individual cases with dealing with 
trans-regional problems. The Commission itself has 
considered such an instrument [in its Opinion of 
21 October 1990 on revising the Treaties of Rome with 
a view to political union — Doc. COM(90) 600 final]. 
4.3. The ESC is aware that these proposals would 
require the allocation of additional funds for environ­
mental policy purposes. The intractable urban environ­
ment problems cannot be solved without funds from 
the Member States and the Community, even if the 
basic costs of urban rehabilitation are met locally or 
regionally. 
4.4. The ESC feels that solving these problems calls 
for greater awareness on the part of the general public. 
This environmental awareness is found only sporadi­
cally. It should include the realization that a change 
(2) OJ No C 56, 7. 3. 1990. 
(3) OJ No C 191, 22. 7.1991, p. 7. 
14. 10. 91 Official Journal of the 
in consumption habits and production structures is 
necessary to ensure lasting improvement in the environ­
ment, particularly in towns. A strengthening of the 
citizen's rights to information [cf. the Directive on 
Environmental Information (*)] and participation by 
citizens and their groups in the planning process also 
accord with the principles of municipal autonomy. The 
enforcement and supervision of environmental law can 
be brought about by regularly informing the public on 
the state of the environment in terms of the most 
important pollutants and the costs of rehabilitation; 
the Directive on Environmental Information should be 
expanded where necessary. 
Using suitable instruments, the Community should 
make possible and promote all measures to inform, 
assist and advise citizens and to train the officials con­
cerned. This also includes the preparation of training 
and educational material, the promotion of seminars 
or similar events, and the organization of travelling 
exhibitions to give clear information on urban and 
environmental problems and good suggested solutions. 
Support and better specialized information for local 
and regional decision-makers is always more likely to 
improve the situation in towns than is the ad hoc 
promotion of individual projects. 
The Economic and Social Committee suggests a Europ­
e-wide town-focused publicity campaign on improving 
the urban environment (possibly involving compe­
titions). 
(J) OJ No C 139, 5. 6. 1989, OJ No L 158, 23. 6. 1990. 
Done at Brussels, 3 July 1991. European Communities No C 269/9 
The Commission should encourage towns to strengthen 
municipal environmental education (including setting 
up local environmental education centres) and further 
develop environmental administration and planning. 
Efforts to provide basic and further training for politi­
cal, administrative and social bodies active in this field 
should also involve tried and tested institutions and 
procedures, and particularly the existing town-twinning 
arrangements; town-twinning could be further 
developed in specialized fields. 
5. Conclusions 
The Green Paper on the Urban Environment is intended 
to give rise to a wide-ranging discussion. The possible 
lines of action are to be further examined by govern­
ments and experts. The ESC expects to participate in 
this debate, in particular when the Commission, in 
accordance with the decisions of the Council of Minis­
ters of 21 December 1990, spells out its proposals. Thus 
the ESC reserves the right to supplement this Opinion 
with its own proposals for action. 
The ESC proposes that the social and economic groups 
represented among its members should also be rep­
resented on any panel of experts set up to pursue the 
aims of the Green Paper further. The ESC might well 
be a suitable organizer and forum for this exchange of 
experience. 
The ESC assumes that—in accordance with the 
Council of Ministers' decisions—the Commission will 
cooperate with other European and with international 
organizations concerned with the urban environment, 
in order to avoid duplication. 
The Chairman 
of the Economic and Social Committee 
Francois STAEDELIN