Opinion on the proposal for a Council Regulation (EC) amending Council Regulation (EEC) No 1973/92 establishing a financial instrument for the environment (LIFE) ()

(96/C 18/03)

On 5 July 1995 the Council decided to consult the Economic and Social Committee, under Article 130s of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for Protection of the Environment, Public Health and Consumer Affairs, which was responsible for preparing the Committee's work on the subject, adopted its Opinion on 19 September 1995. The Rapporteur was Mr Colombo.

At its 329th Plenary Session (meeting of 25 October 1995), the Economic and Social Committee adopted the following Opinion unanimously.

1. Introduction

1.1. The Community's environment policy has achieved a high level of development with the fifth Action Programme on the Environment and the adoption of a huge number of legislative and regulatory instruments based on EC Treaty Articles 130r and 130s.

1.2. However, in order to be implemented fully, this policy needs adequate technical and scientific assistance as well as technologically innovative projects that can demonstrate the feasibility and advantages of a strategy aimed at sustainable development and based on the prevention of pollution through the use of clean technologies, the rational use of energy, resource and energy savings, the preservation of the natural environment, sensible waste management and the improvement of urban and rural living conditions.

1.3. The LIFE Programme (Council Regulation (EEC) No 1973/92) has proved to be a reasonably adequate instrument for financially supporting these necessary actions, even though it is not yet possible to provide an overall assessment of the extent to which it has given added value to environmental policy throughout the Community. The limiting factors in any comprehensive assessment are the number of projects financed and the vast range of topics covered.

1.4. Welcoming the establishment of this instrument in its 1991 Opinion (), the ESC pointed out that LIFE would provide an important stimulus for the effective implementation of policy, but only if it were appropriately funded; the Committee also affirmed that LIFE would have to be closely linked to the fifth Action Programme if it is to become the financial instrument of a coherent long-term Community strategy in the environmental field (cf. point 2.1.1 of the 1991 Opinion).

1.5. In analysing the present proposal amending this parent Regulation, the Committee would again stress the critical importance of the following: an adequate level of funding, long-term coherence, and a feasible strategy of sustainable development. It is also important, given the participatory approach and the principle of sharing out responsibilities under the fifth Action Programme, to evaluate the stimulus given to partnership schemes involving socio-economic actors and non-governmental organizations and producing multiplier effects.

1.6. Finally, it is essential to set up monitoring systems to verify results as projects move forward.

2. Areas of activity

2.1. The Commission points out in its proposal that during the lifetime of LIFE I the modest level of funding, coupled with the large number of areas originally selected, reduced the impact of individual projects and led to high administrative costs in processing applications. The Commission therefore considers it necessary to limit areas of activity and define selection criteria more clearly.

2.2. The Committee is in agreement with the general principle of reducing the number of areas of activity and defining them more carefully, but believes that the Commission's current choice is too restrictive and does not adequately highlight at least two areas where Community action is necessary and opportune.

2.3. By way of example we might mention the prevention and reduction of atmospheric emissions and the protection of air quality. This area of activity has major trans-national implications in terms of pollution, bearing in mind global phenomena such as acid rain, the greenhouse effect and the reduction of the ozone layer.

2.4. Another example concerns protection of the quality of the soil and the remediation of contaminated soil. Despite the seriousness and scale of the problem of reclaiming contaminated sites in Europe, efforts by individual Member States to improve the level of know-how, introduce homogenous environmental quality standards, and lay down appropriate and economically sustainable land-recovery criteria and technologies, have hitherto proved inadequate. Major Community support here could make a significant contribution to the development of uniform and incisive intervention strategies.

2.5. In selecting projects it is important that the instrument be used to incorporate and stimulate the use of other Community support instruments, particularly in the case of sectors identified by the fifth Programme (agriculture, energy, transport and tourism) but to which insufficient attention has been paid by LIFE. Examples are projects to safeguard and maintain the quality of inland waterways, and demonstration projects in rural areas designed to help reduce the environmental impact of agriculture and the agri-food sector.

2.6. The financing of such carefully selected demonstration projects may make a substantial contribution to passing beyond the research and identification stages to pinpointing concrete actions that offer more incisive prevention and improvement strategies.

2.7. This role of providing an inter-sectoral stimulus might be enhanced if more funds were made available (cf. chapter 6 below).

3. Project selection criteria

3.1. The Commission underlines in its proposal the importance of defining project selection criteria more carefully so that the decision-making process is more transparent, the administrative costs of processing applications are kept under control, and potential beneficiaries are given greater guidance. To this end, Article 9a lays down a general set of conditions and criteria to be met by applicants.

3.2. The Committee considers that these criteria are spelt out with sufficient clarity. To be effective, however, the priority actions and strategies within each area of activity - which applicants must take into account and adhere to when preparing their projects - must be clearly defined at an early stage of the annual publication of the invitation to submit applications.

4. Dissemination of information

4.1. The Commission underlines the need to financially support the promotion of specific actions, surveys, analyses and the dissemination of the results of projects financed (3% of the annual budget). The funds set aside for these are amply justified but insufficient.

4.2. If we are to accept that the aim of the LIFE instrument is to support 'demonstration projets' and 'projects setting examples' for the transfer and dissemination of findings, then we have to accept the need for strong, on-going action to ensure the dissemination of know-how and information. Account must also be taken of the need to set in motion systematic procedures for monitoring and checking the progress of projects receiving financial support so that appropriate preventive action can be taken to limit the failure rate.

4.3. A significant proportion of the funds allocated to accompanying measures adopted on the initiative of the Commission should therefore be reserved for the above-mentioned actions. Administrative expenditure should be kept on as tight a rein as possible whilst fixed appropriations reserved for the monitoring of projects and the dissemination of results should, if necessary, be increased.

4.4. Socio-economic and non-governmental organizations have an important role to play in increasing transparency and improving the dissemination of information; the crucial role however continues to be played by national, regional and local authorities - where necessary through the creation of appropriate networks possibly funded by the Commission and offering free access.

4.5. For the sake of more effective utilization of the limited funds for disseminating information, the Commission should devise an information strategy that makes use of a wide variety of channels. In addition to using the instruments referred to above, the findings of at least the most important and significant projects should also - and first and foremost - be disseminated through scientific publications and/or trade journals. This would ensure that the economic sectors concerned are directly informed.

5. Forms of financing

5.1. The Commission notes that during the first phase (LIFE I) the 'interest rebate' system of financing has not been used adequately. Greater use of this type of financing might have a multiplier effect, with available funds topped up by third-party financing. The Commission considers that this type of financing should continue to be on offer.

5.2. The Committee endorses the line taken by the Commission, believing that it satisfies the requirement that third parties should be more closely involved and that market support should be obtained for environmental spending. At the same time, however, the Committee notes that the Commission does not submit concrete proposals in support of this type of financing which would probably require an organization offering mediation services.

5.3. The Committee considers that specific action needs to be taken to encourage this type of financing. The way to do this is to promote and support the presentation of projects requiring interest-rate subsidies, perhaps stipulating that a proportion of the total funds made available must be reserved for this type of financing.

5.4. With regard to projects presented by non-governmental organizations, it is obvious that the funding level cannot be limited to 50%. By analogy with what is said in Article 8(3) regarding Community financial support for technical assistance projects and accompanying measures, action supported by NGOs should be covered 100% to enhance the status of voluntary involvement.

6. Coordination with other financial instruments

6.1. A comparison between funds available under LIFE II and environmental expenditure earmarked under other funds (Structural Funds, Cohesion Fund, RTD, Phare, Tacis, EAGGF, etc.) shows the former to be at a disadvantage. This can be explained by the specific nature of the LIFE instrument whose sole purpose is to support demonstration projects and projects serving as examples.

6.2. We cannot however help but make the point that the various financial instruments need to be closely coordinated, with uniform aims, strategies and concrete decisions, so that Community action is not contradictory and does not lead to duplication.

6.3. With this in mind LIFE - even though its own financial resources are relatively modest - should play a dynamic role in stimulating and guiding all other environmental funding from a variety of Community instruments. Existing horizontal links between appropriate departments should if necessary be stepped up.

6.4. In the light of what is said in points 2.5, 2.6 and 2.7, it is obvious that the role of LIFE might in future be expanded with more adequate funding.

Done at Brussels, 25 October 1995.

The President

of the Economic and Social Committee

Carlos FERRER

() OJ No C 184, 18. 7. 1995, p. 12.

() OJ No C 191, 22. 7. 1991.