Opinion of the European Economic and Social Committee on ‘realities and prospects for appropriate environmental technologies in the candidate countries’.
Date: 2004-03-31
Institutions: European Economic and Social Committee
Subjects: Central and Eastern European countries, clean technology, environmental protection, water, water treatment

30.4.2004

EN

Official Journal of the European Union

C 112/83

Opinion of the European Economic and Social Committee on ‘realities and prospects for appro-
priate environmental technologies in the candidate countries’.

(2004/C 112/23)

On 17 July 2003, the European Economic and Social Committee decided to draw up an opinion, under
Rule 29(2) of its Rules of Procedure, on the following subject: realities and prospects for appropriate envir-
onmental technologies in the candidate countries.

The Section for Agriculture, Rural Development and Environment, which was responsible for preparing
the Committee's work on this subject, adopted its opinion on 4 March 2004. The rapporteur was Mr
Ribbe.

At its 407th plenary session, held on 31 March and 1 April 2004, (meeting of 31 March), the European
Economic and Social Committee adopted the following opinion by 80 votes to one, with two abstentions:

1. Starting point — general observations on environ-

mental technologies

introduction of these measures. Furthermore, this political
debate appears to be stirring again, this time in connection
with diesel-particulate filters;

1.1
It is clear from a large number of studies and public
reports that, whilst much has already been done in order, for
example, to provide clean air and water, considerable efforts
undoubtedly still have to be made, both in the existing Member
States and also in the candidate countries, in order to safeguard
for human life,
the fundamental natural
to
conserve Europe's national heritage,
to comply with the
existing environmental laws and to set Europe on the road to
achieving sustainable development.

requirements

— environmental technologies are not without their limits;
whilst it has been possible to decisively reduce nitrogen
oxide and sulphur dioxide emissions, in particular, there are
still no technologies which can be readily applied in prac-
tice for curbing, for example, CO2 or CFC emissions, which
are clearly responsible for one of the greatest environmental
challenges with which we will have to contend in future,
namely climatic problems.

It is well known that environmental technologies have
1.2
an important role to play in providing solutions to particular
environmental problems. The Commission is fully aware of this
and has drawn up an Environmental Technologies Action Plan
for the EU (1), which is currently being discussed with the insti-
tutions involved and organised civil society. The EESC has
welcomed this measure since the application of environmental
technologies (e.g. sewage plants and filtration plants) has
brought about important progress in the field of environmental
conservation in recent years and decades. This applies in the
case of both fixed plants, such as industrial plants or power
stations, and also in the case of mobile technical facilities.

1.3
The setting — and subsequent tightening — of motor
vehicle exhaust emission limits are an example of a clean envir-
onment technology which has undergone constant technical
development. This example does, however, also demonstrate
that:

— particularly progress as regards the development and intro-
duction of environmental
technologies such as catalytic
converters, can frequently only be realised in the wake of
remember how
intense political debate; people will
opposed the motor-vehicle industry was at the time to the

(1) COM(2004) 38 final of 28.1.2004.

1.4
Environmental technologies have therefore become a key
element of environmental policy. In cases where technical solu-
tions, alone, cannot provide an adequate, successful answer to
problems, structural changes will however be required. In this
opinion, the EESC will however confine itself to examining
various aspects of the field of environmental technologies.

1.5
Environmental technologies are, however, important not
just on grounds of environmental policy. The scientific work
and industry involved in environmental technologies have now
become an important economic factor and source of employ-
ment; turnover in this field in the EU is in excess of EUR 183
billion (2). The EESC has also already welcomed the European
Commission's recent communication entitled Developing an
action plan for environmental technology (3).

Past experience does, however, show that, as is the case
1.6
in many other sectors of the economy, there is not enough
funding available in the field of environmental technologies to
enable all the projects which have been identified and recog-
nised as being essential to be implemented within the desired
timeframe. Many essential environmental measures may there-
fore not be realised.

(2) See the European Commission Report on environmental technology

for sustainable development – COM(2002) 122 fin.

(3) See the EESC Opinion on the Commission's Communication entitled
Developing
technology
(COM(2003) 131 fin), CESE 1027/2003; this opinion has not yet
been published in the OJ.

environmental

action

plan

for

an

C 112/84

EN

Official Journal of the European Union

30.4.2004

The situation in the candidate countries

Funding for environmental conservation in the candidate countries

It is neither possible nor desirable for this opinion to
1.7
make a general appraisal of the situation and the trend, as
regards the environment and environmental conservation,
in
the candidate countries. The situation is much too complex to
enable this trend to be summed up in purely positive or nega-
in the last few
tive terms. One thing which is clear is that,
years, the situation with regard to many of the directly obvious
(local) cases of environmental damage in the candidate coun-
tries has undergone a tremendous improvement. On the other
less directly obvious, environmental problems
hand, other,
have arisen (1). There is, however, no doubting the fact that the
closure of particularly polluting industries and the introduction
of ‘clean’ technologies has, in recent years, made it possible to
reduce many direct health risks caused by environmental pollu-
tion.

1.8 Nonetheless, very much still has to be done if the envir-
onmental standards prescribed by EU law are to be met. Invest-
ments in environmental infrastructure totalling, approximately,
between EUR 80 billion and EUR 110 billion will be required
in order to apply the existing body of EU law in the CEEC (2).
Funding is, however, in short supply in the candidate countries,
too, and public investments in the environment also have to
compete with the demands of other forms of public expendi-
ture in fields such as social policy, education and infrastructure.
In the case of investments by industry and private individuals,
too, the aim is to avoid the misallocation of funds, wherever
possible. It will therefore be necessary to make the most effec-
tive use of the available funding and to seek efficient solutions
which provide good value for money.

This opinion will

1.9
therefore deal with environmental
technologies in the central and eastern European countries
(CEEC). A large number of the examples used in this opinion
derive from Poland. Poland is, on the one hand, the largest of
the candidate countries which will
receive a considerable
proportion of future EU aid. Poland is, on the other hand, also
characterised,
like virtually no other candidate country, by
sharp distinctions between urban and rural areas; as this
opinion will demonstrate, this situation is of considerable rele-
vance in the context of environmental technologies. Poland is
also virtually in a class of its own amongst the candidate coun-
tries as regards the further radical changes in the industrial
sector facing the country. Finally, Poland was also chosen as an
example in view of the fact that the EESC has a long history of
cooperating with Poland in the field of environmental conser-
vation.

1.10
The observations and demands expressed in this
opinion are, however, applicable to all of the candidate coun-
tries and are also valid with regard to many of the existing EU
Member States.

(1) e.g. problems brought about by the increased use of personal forms
of transport: mention should also be made of problems relating to
the protection of species and environmental pollution problems
such as those brought about by agri-industrial investments e.g. the
establishment of enormous pig-rearing plants in Poland by the US
investor Smithfield.

(2) COM(2001) 304 final – The challenge of environmental financing

in the candidate countries, page 6.

investment

1.11
In the last few years, i.e. in the run-up to enlargement,
the EU has already demonstrated its commitment by making
grants towards environmental
in the candidate
countries. This is an important and welcome new departure
vis-à-vis earlier EC enlargements. By making available this
funding, the Commission highlights the growing importance of
environmental conservation. Up to now, the EU has made
available a number of programmes, including Phare and ISPA
and, to a certain extent, SAPARD;
in this context, attention
should be drawn to the difficulties repeatedly underlined by the
Commission with regard to the use of funds.

1.12
In the period 1995 to 2000 EUR 398.2 million was
made available under the PHARE programme and EUR 460.2
million under the ISPA programme for investments in the
environmental sector; the bulk of the investment was devoted
to water projects (which accounted for some 82.3 % of all
funding), followed by waste-disposal projects (15.7 % of the
funding) and measures to combat air pollution (2 % of the
funding) (3). Over the six-year period 1995 to 2000, Poland
received funding totalling EUR 233.4 million (representing an
average allocation of approximately EUR 40 million per year).

1.13
It should, however, be borne in mind, in this context,
that the ISPA programme was not introduced until 2000. Since
its establishment,
the ISPA programme has made available
approximately EUR 500 million for investment in environ-
mental projects in the CEEC each year. Poland's share of this
funding amounts to between 30 and 37 %.

1.14 Whilst the financial assistance already provided by the
EU undoubtedly provided valuable help to the candidate coun-
tries, in the past, it should, however, be pointed out that the
bulk of the funding was provided by the candidate countries
themselves and this will also have to be the case in the future.
Funding provided by the PHARE and ISPA programmes is able
to cover only a small part of the funding requirements of the
candidate countries in the environmental sector: 1.1 % of
funding requirements in respect of water projects;
overall
0.75 % in respect of waste-disposal projects; and only 0.03 %
of the funding requirements in respect of measures to combat
air pollution (figures provided by the European Court of Audi-
tors) (4).

environmental measures

In the period up to 2000, overall foreign assistance in
1.15
financing
generally
accounted for ‘only’ some 5 % of the total amount of invest-
ment in environmental measures; contributions from the EU
also represented only part of the external aid.

in Poland,

(3) Source: EU News, Nr. 20 dated 28.5.2003, calculations made by the

European Court of Auditors.

(4) Ibid.

30.4.2004

EN

Official Journal of the European Union

C 112/85

1.16
This situation will, however, change substantially once
Poland has joined the EU. Of the EUR 7.3 billion in funding to
be provided to Poland by the EU Structural Funds in the period
2004-2006, the sum of EUR 545 million will, according to the
Polish Environment Ministry, be devoted to environmental
measures. Aid provided under the ISPA programme will subse-
quently be replaced by aid from the Cohesion Fund, which will
make available almost EUR 7.6 billion in the period 2004-
2006. Poland is due to be allocated between 45 % and 52 % of
this sum, which represents an allocation of between EUR 3.4
billion and almost EUR 4 billion. Aid from the Cohesion Fund
is, as is well known, divided equally between investments in
environmental projects and transports projects. In future a sum
of between EUR 1.3 billion and EUR 1.5 billion in EU funding
for environmental projects will be made available to Poland
each year.

1.17
The use of EU funding to finance environmental
conservation measures in the candidate countries has, up to
now, been far from optimal. If substantially more money is
now to be made available in the future, closer attention must
be paid than has hitherto been the case to ensuring that these
sizeable sums are used effectively and not frittered away on illu-
sory growth plans or inappropriate projects,
for
example, the use of disproportionate and excessively expensive
technology. In its Special Report No. 5/2003 on the financing
of environmental infrastructure projects in the candidate coun-
tries, the European Court of Auditors criticised, inter alia, the
fact that projects were repeatedly being approved even though
there was a risk of establishing excess capacity and therefore a
danger of making uneconomic use of EU funding and giving
rise to unnecessarily high operating costs. One of several exam-
ples quoted in the special report is the sewage treatment plant
at Szczecin in Poland, which operates at only 40 % of its capa-
city.

involving,

2. What are ‘appropriate’ technologies and why are they

needed?

2.3.1 Cle a n a i r / e ne r g y e ffi c i e n cy

2.3.1.1 When Poland definitively severed its links with its
communist past at the end of the 1980s, environmental conser-
vation became a matter of the utmost importance in the poli-
tical arena. This is hardly surprising in view of the fact that
many people were severely affected by the extremely high level
of environmental pollution, caused mainly by the industrial
plants but also brought about coal-fired domestic heating.

2.3.1.2
In Krakow investigations were carried out to deter-
mine how the level of sulphur dioxide pollution could be
reduced; this pollution was not only endangering public health
but it was also responsible for the large-scale destruction of the
facades of houses which represented a cultural and architectural
heritage of extremely high value. One of the first planned
measures was to carry out a large-scale renovation of two
power stations.

Alternative calculations, made at the same time, had,
2.3.1.3
however, shown that, for the same cost as that incurred in
technically upgrading the power stations, twice as high a reduc-
tion in the level of sulphur dioxide could have been achieved
by using the money to replace coal-fired domestic heating
systems and to carry out domestic energy-saving measures
(through the use of measures such as insulation and heat-
saving glazing).

Implementation of the latter measures would also
2.3.1.4
have enhanced the living conditions of the local population
and given a shot in the arm to local craft industries, thereby
making a much higher contribution towards boosting the local
economy. Despite this, the funding was used to renovate the
power stations; the selection of this option can undoubtedly be
put down to the fact that it was also in the interests of the
large foreign companies, which ultimately picked up the bulk
of the orders.

2.1
In the EESC's view, ‘appropriate’ environmental technolo-
gies can play a very important role when the following objec-
tives are being pursued:

2.3.2 S e w a g e tr e a tme nt

— devising effective projects for resolving local problems;

— making financial savings, perhaps not at the planning stage
but certainly at the investment stage and in respect of
ongoing costs; and

— creating jobs at local and regional levels.

In the view of the EESC, the term ‘appropriate technolo-
2.2
in every single case, solutions have to be
implies that,
gies’
sought which are geared not only to technical feasibility and
technical effectiveness but also pay close attention to the local
situation and the situation of local people.

2.3
A number of examples are set out below to illustrate
what, in the EESC's view, is meant by the term ‘appropriate
technologies’.

is

Poland

tremendous,

currently making

2.3.2.1
and
welcome, efforts to improve sewage treatment. After a start
was made on the construction or renovation of sewage-treat-
ment plants, first of all mainly in large towns and cities, many
planning and building measures are now also underway — or
have already been completed — in smaller towns and villages,
too.

2.3.2.2
In the case of lightly populated rural areas the kind
of central solutions which are undoubtedly right for conurba-
tions are frequently less appropriate, both on technical and
financial grounds. Nonetheless, in virtually all cases, such ‘state
of the art’ solutions are planned.

A case in point

2.3.2.3
is the district of Sokoly in the
Province of Podlaskie in north-east Poland. This district covers
160 km2 and comprises over 29 villages which, under the
current plans, are all to be linked to the sewage-treatment plant
currently in the course of construction in the central town of
the district.

C 112/86

EN

Official Journal of the European Union

30.4.2004

2.3.2.4
In addition to the construction of the technical plant
itself, the system of drains always constitutes one of the main
items in the investment and maintenance budgets. Poland's
national sewage disposal programme of December 2003 stipu-
lates that the construction or modernisation of sewage-treat-
ment plants is to account for only one third of total invest-
ment; two-thirds of total investment has to be allocated to the
drainage system. In the case of Sokoly, it is planned to install
pressure pipes (together with the corresponding cost-intensive
pumping stations),
in order to transport the sewage to the
central treatment plant. In the case of conurbations the length
of drain constructed per inhabitant is generally 0.5 metres – 2
metres, whereas in rural areas a drain length of 5-10 metres
per inhabitant may be the bare minimum.
In the case of
Sokoly, it is planned to construct, in some cases, far more than
20 metres and even as much as 40 metres of drain per inhabi-
tant, excluding the drains connecting individual houses to the
network.

2.3.2.5
The proposals put forward by the persons respon-
sible for sewage-disposal planning can, in no way, be regarded
as constituting an appropriate solution in the light of the local
conditions. The proposed solution is very strongly reminiscent
of the bad planning in the field of sewage disposal carried out
in the former German Democratic Republic (GDR) following
re-unification which led to the levying of exorbitant sewage-
disposal charges and which now constitutes a real disincentive
from a business-location standpoint. In the former GDR, too,
projects were carried out which were based on illusory expecta-
tions of growth and an inappropriate transfer of large struc-
tures to rural areas.

Very high sewage charges resulting from the adop-
2.3.2.6
inappropriate solutions have a damaging effect on
tion of
economic development in the regions concerned in two ways:
on the one hand, money which has to be spent on excessively
high sewage charges could be used to promote economic devel-
opment in other fields and, on the other hand, higher sewage
charges can deter businesses — particularly businesses which
require a high level of water consumption — from becoming
established in the areas concerned.

An umbrella body, established in the German
2.3.2.6.1
Federal State of Thuringia in the period since re-unification,
which brings together citizens campaigning against expensive
sewage-treatment projects, maintains that, in the case of local
authority joint ventures to provide water and sewage services,
costs go through the roof once investments are partly
supported by the Structural Funds. The Friedrichsroda local
authority has, for instance, recently informed residents that
they would be asked to pay a contribution of over EUR 10,000
in order to be connected to water-supply and sewage-disposal
systems; in one case a resident was even charged EUR 99,000
to be connected to these services (1). Residents who were earlier
cajoled into approving sewage-treatment projects through talk
of high-capital
investment grants are now responding with
indignation when they hear about the subsequent costs, which
were earlier concealed from them.

In this context, the EESC would also draw attention
2.3.2.7
to the criticism expressed by the European Court of Auditors

(1) Thüringische Landeszeitung/Eisenach Presse of 24.10.2003.

relating not only to excessively large sewage disposal projects
but also to the activities of somewhat incompetent advisors
who sell expensive projects virtually ‘off the peg’.

2.3.2.8
Another example, this time from Miroslawice, in the
municipality of Trzebiatow on the Baltic, demonstrates that the
fear expressed by the EESC that there would be a repetition of
the earlier bad planning in this field is a real fear; it also shows
that the examples identified by the European Court of Auditors
are not isolated occurrences. This situation may have serious
consequences, also with regard to the use of appropriate tech-
nologies. In Trzebiatow financial aid was used to construct an
excessively large sewage treatment plant. In Miroslawice, which
is part of the municipality of Trzebiatow, the German Federal
Foundation for Environmental Conservation wanted to provide
assistance for the establishment of a demonstration project
involving the construction of a sewage treatment plant using a
treating sewage,
technology based on natural processes of
which had been specially developed for small
towns and
villages on the Baltic Sea coast. After the project had been two
years in preparation and despite the fact that the local authority
had given its approval and planning and building permission
had been granted, the local authority ended up by withdrawing
from the project because it was discovered that the central
sewage treatment plant in Trzebiatow, which had been built a
short time before, urgently needed, because of its excessively
large size, other towns and villages to be connected to it in
order to enable it to operate more effectively. The project to
utilise a decentralised, appropriate solution for the treatment of
sewage, and to provide a demonstration project in that field,
was thus dropped.

2.3.3 S e w a g e -slu dg e tr e a t me nt

2.3.3.1
As the proverb says, necessity is the mother of inven-
tion. The official in charge of sewage treatment for the local
authority Zambrow in north-east Poland had (hitherto) no
funding available to enable him to install technical equipment
for sewage-sludge treatment. He came up with the following
solution: part of the sewage sludge is composted, making use
of earthworms, which he describes as ‘his most faithful and
most effective workers’; a further part of the sewage sludge is
spread on reed beds in the sewage-treatment plant, which have
developed into a real paradise for nature. Members of the
public and farmers are keen to take away the compost as they
value its soil-enriching properties (2). In Zambrow the cost of
sewage-sludge treatment amounts to only 5 % of the equivalent
costs incurred by treatment plants which process and dispose
of the sewage sludge using technical solutions. A factor of deci-
sive importance here — and this is also one aspect of deter-
mining whether the technique employed is ‘appropriate’ — is
that,
the sewage sludge is not
contaminated by harmful substances (and this is the case in
many rural communities in the candidate countries). As a result
of the process described above, the local district of Zambrow
has the lowest sewage-treatment costs of the region. Although
Zambrow has an effective and cost-efficient
sewage and
sewage-sludge treatment plant, the solution devised by the local
official himself is only rarely put forward as a model for new
systems.

in the case of Zambrow,

(2) The EESC recognises the problems associated with the use of
sewage sludge as a fertiliser for agricultural
It very often
happens that a strict ban has to be imposed on this practice because
of concentrations of pollutants in the sewage sludge. For further
observations on the general issue of sewage sludge, see the EESC
Opinion on the revision of Council Directive 86/278/EEC on the
use of sewage sludge in agriculture, OJ C 014 of 16.1.2001, pages
141 to 150.

land.

30.4.2004

EN

Official Journal of the European Union

C 112/87

2.3.3.2
The EESC points out that, particularly in the case of
rural areas, there are perfectly practical (appropriate) sewage
treatment technologies in respect of which the problem of
sewage sludge does not even arise, e.g. in the case of plant-
based sewage-treatment facilities.

Further examples

2.3.4 Whilst not claiming to have come anywhere near to
further possible examples of
producing an exhaustive list,
appropriate
technologies may be quoted,
namely decentralised energy-generation facilities.

environmental

Germany is a country which, for the past few years,
2.3.5
has been making increased use of renewable sources of energy,
which have a neutral effect on levels of carbon dioxide.
Germany can thus be cited as an example of how the use of
appropriate environmental technologies can also establish a
beneficial link between environmental issues and employment.

2.3.6
Germany is now using more steel for the construction
of windmills than is used in the ship-building industry. In par-
ticular areas suffering from structural weaknesses, such as East
Friesland, the use of wind power has made it possible to create
several thousand new jobs.

promoting environmental technologies, of the reasons behind
such differences in the use of appropriate environmental tech-
nologies. The EESC does of course realise that it is especially
necessary for the right basic economic conditions to apply.
Particularly in those countries (such as Poland) which continue
to have a highly subsidised coal industry, which is not matched
by the provision for support for alternative forms of energy,
even energy saving measures are, in some cases, uneconomic.

In addition to the lack of the requisite legal bases, atten-
3.2
tion should also be drawn, above all, to the comparatively poor
financing conditions. When interest rates can be as high as
investments are not always redeemed within a short
20 %,
period,
in some cases despite the considerable energy-saving
potential involved. Contracting models (privately funded, unit-
linked, etc. models) could therefore become highly important
and should be promoted to a greater extent.

3.3
It must be in the interests of the European Commission
— also from the point of view of promoting sustainable devel-
opment — to identify the shortcomings which continue to
hamper the use of appropriate environmental technologies and
to help to remove these shortcomings.

It

is now becoming increasingly worthwhile

2.3.7
for
farmers in Germany to build and operate methane gas plants in
order to provide a new, additional source of income. Schools
and other public buildings are increasingly being heated using
locally-produced renewable sources of energy, such as wood
shavings, rather than the traditional fossil fuels, such as oil and
gas, which have to be imported over long distances. In the
coal-producing area of Nordrhein-Westfalen alone, over 1000
wood pellet combustion plants have been set up, thereby not
only making for a cleaner environment but also creating new
jobs.

3.4 With this aim in view, attention should also not be
focused solely on the candidate countries; we should certainly
also take a look at the situation in the existing Member States.
In this context it is clear, that in addition to the basic economic
conditions, a number of other factors also play a role. In the
course of its work, the EESC has been very interested to note
that in the various EU Member States, where the initial situa-
tion is almost the same, there is a very different level of use of
for
appropriate
example, almost every house now has a solar energy device
mounted on the roof (for the purpose of providing hot water
and, increasingly, also for the generation of electricity). The use
of such devices is much less common in Italy or Spain.

environmental

technologies.

In Greece,

For every heating installation burning wood shavings
2.3.8
used to heat, for example, town halls, schools, municipal halls,
residential homes for old people or hospitals in small towns,
there is soon a need for three, four or even five farmers to
obtain supplies of small-dimensioned wood from forests, to cut
the wood and to see to its transport to the heating plants.

there has,

In countries such as Austria and the Scandinavian
2.3.9
for example, been a boom in the
too,
states,
construction and operation of wood pellet plants. In the candi-
date countries, on the other hand, virtually no renewable
energy plants have so far been established.

3.5
Although in countries such as Poland and other CEEC
similar approaches have barely got off the ground, the country
is nonetheless already benefiting from the increasing use of
appropriate, decentralised environmental technologies in the
EU Member States. This is due to the fact that a number of
wood pellet production plants have recently come into opera-
tion in Poland;
the wood pellets produced are, however,
destined almost exclusively for export to Sweden, Finland and
Austria.

3. Lessons

to be learned from the abovementioned

examples

3.1
closer

The EESC recommends the Commission to carry out a
its planned strategy for
examination, as part of

3.6
In this context, the EESC wishes to draw attention to the
fact that consideration should be given to using not only stand-
ard environmental technologies but also appropriate technolo-
gies in apparently not directly related fields, since these latter
technologies, too, may have a very beneficial effect on environ-
ment and regional policy.

C 112/88

EN

Official Journal of the European Union

30.4.2004

3.7
To give another example, small cheese dairies or farm
dairies, which in many EU Member States are the veritable
epitome of regional specialities and regional identity, have been
hitherto unknown in Poland. It was even argued by representa-
tives of the authorities that, under EU provisions, the construc-
tion and operation of small cheese dairies would not be
authorised. Such decentralised processing plants are, however,
not only of importance to local agriculture and also to local
craft industries but also contribute indirectly towards stabilising
economic circulation at regional level and stabilising small-scale
farming production, thereby also helping to preserve nature
and the environment.

3.8
The abovementioned examples selected by the EESC
should not give rise to the mistaken belief that it is opposed to
the adoption of large-scale solutions in the field of environ-
mental technologies. There is no doubt that, in particular cases,
large-scale solutions, too, may represent appropriate solutions.
When we bear in mind that half of the pollution of the Danube
in Hungary is produced by the city of Budapest, we neither
want to, nor can we, reject the notion of large sewage-treat-
ment plants. The EESC is rather seeking to draw attention to
the fact that it is necessary to seek solutions best suited to the
respective local conditions, in order to:

— avoid the misallocation of funding;

— implement measures which are the most advisable in the
interests of the local population and the local economy;

— make progress with sustainable development through the
use of appropriate environmental technologies, which can
massively reduce energy and raw material inputs and help
to promote growth and the creation of jobs.

3.9
The EESC would therefore to a certain extent warn
against a ‘fascination’ with large projects, a phenomenon which
can be observed in some quarters; this fascination may be
given a further boost
the abovementioned
in the CEEC if
increase in funding occurs in the next few years. The EESC is
not seeking to stand in the way of certain measures but rather
to promote other measures.

tives, people believe that they are acting ‘on the safe side’ by
using ‘established’ technology.

3.11
The latter motive also frequently lies behind the action
taken by administrations, ranging from that of the European
Commission to that of local authorities. Furthermore, concen-
trating on a small number of large projects gives rise to a lower
level of administrative expenses; it should be borne in mind
that, in Brussels and at other levels, administrations frequently
lack the staff capacity to enable them to switch to appropriate
solutions, which are often on a smaller technological scale. The
fact that the economic cost of concentrating on a smaller
number of large projects far outweighs increased expenditure
on staff brought about by adopting ‘appropriate solutions’
appears to be a matter which is of interest to no-one. A further
factor to be taken into consideration is that large-scale facilities
also frequently do not require a high level of aid at all since, in
such cases,
it is easier to find private investors than when
funding has to be obtained from small and medium-sized local
authorities.

3.12
In those candidate countries which used to have a
strongly centralised system there is clearly the additional factor
that the belief in centralised, uniform solutions is not yet, by
any means, finally overcome in all quarters.

3.13
The examples described above demonstrate that the use
of appropriate small- or medium-scale technologies to elimi-
nate environmental pollution at local level makes it possible to
achieve the same or, in some cases, even better results at lower
cost. Such appropriate technologies:

— are, in some cases, clearly more difficult to apply and more

expensive at the planning stage;

— are generally cheaper in the investment phase; this has the
benefit of enabling more plants to be constructed for the
same sum, thereby enabling more to be achieved in creating
a cleaner environment;

— involve much cheaper maintenance costs, thereby enabling
savings in costs to be made by local populations; these
‘savings’ can be used to finance other measures which
promote the economy (1);

— in many cases also provide employment opportunities for
industries, whereas large-scale solutions can
local craft
this
frequently only be carried out by specialist
should be seen as a benefit for the local and regional econo-
mies.

firms;

The EESC expresses its concern over the widespread
3.10
lack of knowledge of appropriate technologies in the candidate
countries and also over the fact that the (quite small number)
of engineering offices and authorisation bodies tend to prefer
large-scale solutions, even in cases where the use of such solu-
tions is not a sound idea. This frequently substantially puts up
the cost of investments, which has a clearly beneficial impact
on the fees received by engineering offices. It should also be
borne in mind that, in the light of the environmental objec-

Curiously enough, appropriate, cost-effective solutions

3.14
tend to have a negative image.

(1) In the case of Kamieniec in the Grodzisk district of western Poland
(Wielkopolskie), it is planned to construct a total of 917 individual
sewage treatment plants, rather than one single central facility. It is
assumed that this will bring a 60 % reduction in investment and
operating costs vis-à-vis the corresponding costs of a central facility
backed up by a drainage network (W. Halicki, Zielona Góra, 2003).

30.4.2004

EN

Official Journal of the European Union

C 112/89

4. Shortcomings and barriers and how they can be

removed

4.1
In the next few years the candidate countries will thus be
provided with a considerable amount of aid for environmental
investments. The way in which these sums are used will mainly
depend on the decisions taken by the responsible authorities in
these countries.

4.2
The EESC realises that the EU will not place any direct
obstacles in the way of the candidate countries if they consider
making use of appropriate environment technologies. This is,
however, an inadequate response. In the EESC's view, the EU
needs to provide active technical and financial assistance.

4.5
It also happens not infrequently that the bodies which
draw up the plans also have links with construction companies
or suppliers of technology. The interest of planning bodies,
industry and also politicians in selecting large ‘off the peg’
projects should not be under estimated: the level of fees paid to
architects and engineers provide good reasons for this, as does
the interest of the construction industry in obtaining large
contracts. Observations like that which a manufacturer of
drainpipes was heard making to a young technician: ‘Of course,
they, too, earn money from every metre’ are not isolated cases,
and the likelihood of
in a showy, prestigious
taking part
opening ceremony for a major project, with TV and press
coverage, may appear to be a more attractive proposition to
some local politicians than the implementation of 20, 50 or
100 small projects which attract virtually no attention.

The EESC confirms that the prospects of increased use
4.3
being made of such technologies will only really be enhanced
if:

— the blatant knowledge deficit as regards the opportunities
provided by appropriate environmental
is
removed by a transfer of expertise, which will need to be
expanded on a very large scale;

technologies

— good examples are publicised and if demonstration plants

are established;

— the requisite basic legal and economic conditions are

created;

— the financial prerequisites and possibilities are improved,

possibly by setting up a special fund; and

— political decision-makers at all levels are given the opportu-
nity to have possible alternative planning measures exam-
ined to determine their feasibility and compatibility with
the relevant EU (and national) laws;

— the social partners and civil

society organisations are
in order to promote popular awareness in this

involved,
field.

Promotion of knowledge and awareness of appropriate environmental
technologies

increasingly be taken at the local

4.4 Decisions on investments in environmental projects will,
in future,
level. Decision-
makers, and in particular those in small municipalities, who do
not have their own specialist staff, almost always have to rely
on external expertise in respect of planning work and the
subsequent implementation of investments. Some of the engi-
neering offices which are consulted do not have sufficient
knowledge, and in some cases also do not have the will, to
propose more appropriate and cheaper solutions than ‘state of
the art’ solutions and solutions which are better on social or
environmental grounds.
the services
provided by engineering offices are, as a rule, paid for in
accordance with the volume of building work to be carried out,
rather than in accordance with whether the offices have chosen
the solution which is the most favourable in the long term and
is best suited to local conditions.

In the final analysis,

The provision of incorrect information, either deliber-
4.6
ately or
inadvertently, happens more often than may be
imagined. For example, the EESC heard of cases in which poli-
tical decision-makers were clearly given to understand that,
apparently, EU law authorises only the building of central
sewage treatment plants to which all parts of a town or village
are connected. We are, of course, dealing here with incorrect
information, but such a case also provides an indication of the
problems resulting from a lack of knowledge.

4.7
There is also a number of additional considerations,
some of which are of a practical nature and some of a psycho-
logical nature, as set out below. It is often quite a simple matter
to construct ‘state of the art’ plants; the process proceeds from
the drawing board in the engineering office. Decentralised,
appropriate solutions frequently require a higher level of plan-
ning input, much more detailed knowledge and frequently
require a high level of determination to succeed, whilst, at the
same time, they are likely to result in a smaller payment. Who
wishes to embark upon a more difficult course of action, if the
straightforward route is also the more lucrative route? By
employing available,
the art’, solutions,
large-scale ‘state of
planners and political decision-makers are convinced that they
are acting ‘on the safe side’. People do not so readily have
confidence in small-scale solutions, which are often regarded as
tending to be ‘poor’, primitive and unsafe solutions. Returning
to the example of Zambrow (see point 2.3.3 above), how can a
simple official responsible for a sewage treatment plant come
up with an idea which did not occur to engineers (or maybe
the engineers did not want to come up with such a solution)?

4.8
In the EESC's view, it is particularly important to provide
both political decision-makers and engineering offices with
information and training. The Commission would be well
advised to consider, for example, setting up independent ‘skill
centres for appropriate technologies’
in the candidate states.
Such centres could have the task of organising the requisite
transfer of expertise and providing advice to both local-level
decision-makers and civil society bodies; the proposed skill
centres could therefore virtually have the role of stimulating
demand for appropriate environmental technologies. If neces-
sary, they could also play a role in the administration of special
assistance funds (see point 4.16 et seq. below).

C 112/90

EN

Official Journal of the European Union

30.4.2004

4.9
Support could be provided for the work of these skill
centres by setting up a European database; the European Envir-
onment Agency could be involved in the establishment and
maintenance of this database, which could contain information
on cost-effective,
technologies
which have proved their worth in the view of authorities in the
EU and therefore acquire a form of ‘quality label’. The Guide to
Alternative Sewage Treatment Processes issued by the European
Commission's Environment DG may be regarded as a step
towards the achievement of the above goal.

environmental

appropriate

appropriate

environmental

4.10 No method is more impressive and better at removing
distrust of
than
enabling the parties concerned to inspect practical examples of
such technologies. The Mayor of Sokoly (see point 2.3.2.3
above) halted his plans for connecting systems in all parts of
the municipality to the central sewage treatment plant after he
had been able to inspect operational alternative methods (1).

technologies

4.11
The EESC therefore takes the view that the supply and
transfer of appropriate technologies must also be ‘appropriate’;
in particular,
these aspects must be backed up by actions
designed to secure social acceptance, which is not always
readily forthcoming amongst the general public, on the one
hand, and local administrations, on the other hand.

4.12 With this aim in view, information, consultation and
participation procedures should be introduced,
involving the
socio-economic players and the general public.

4.13
It might also be a valuable exercise to promote partner-
ships between, on the one hand, regions and/or municipalities
in the EU which have gained interesting experience in the
application of appropriate technologies and, on the other hand,
regions and/or municipalities in the new Member States which
are on the point of making similar (or indeed, different)
choices. Furthermore, a degree of priority should be given to
projects under the Interreg Programme and other Community
programmes which promote the use of appropriate environ-
mental technologies.

training

Appropriate

The European Action Plan for Environmental Tech-
4.14
nology, currently being elaborated, considers ways of removing
barriers which impede the dissemination of EU environmental
technologies.
and
programmes of visits — which would be welcomed by EESC
— would undoubtedly provide one way of achieving this objec-
tive. Here, too, the important issue is the form taken by such
programmes. Programmes of visits are not, in all cases, bound
to be geared to showing participants only the most advisable
solutions. Not
infrequently, purely purchasing factors play
more of a central role.

programmes

Financial aspects

4.15
The Commission is rightly able to point out that in its
aid arrangements it does not, in general, exclude the use of
technologies. Criticism may,
appropriate

environmental

however, be expressed over the fact that, for example, projects
funded under the Cohesion Fund have to involve a minimum
investment of EUR 10 million in order to be eligible for assis-
tance. Many extremely effective small projects are thus debarred
from benefiting from aid amounting up to 85 % of the invest-
ment sum.

4.16
It is clear from an analysis of aid practice pursued up
to now that priority was given to the larger towns and cities.
This is initially understandable, insofar as investments in these
areas were able to bring about correspondingly higher reduc-
tions in environmental pollution and also in view of the fact
that, for example, the Waste Water Directive makes provision,
first of all, for sewage treatment in larger towns and cities. At
the same time, however, there is a need to set out ideas for
promoting the use of appropriate technologies as the course of
future investment is now already being mapped out.

for

for,

example,

assistance

smaller projects

The EESC is fully aware of the fact that the Cohesion
4.17
Fund does not only provide assistance for projects in cities; it
also provides
implementing
sewage-treatment plans drawn up by associations. Whilst it is,
to be bundled
therefore, conceivable for
together, this does, however, seldom happen. As the decision
on the provision of grants from the Cohesion Fund is taken in
Brussels, the EESC recommends that applications for aid should
include a clear calculation of the respective costs (investment
costs and subsequent costs) of centralised, semi-centralised and
decentralised technical projects. By thus encouraging applicants
for aid to address, at least in general terms, alternative concepts,
this could help to bring about considerable financial savings in
the investment stage and also help to avoid high subsequent
costs.

these funds will, however,

In Poland there is a variety of possible sources of
4.18
funding for environmental measures, for which projects invol-
ving a small level of investment are also, in principle, eligible,
namely: national, regional and, in some cases, local environ-
mental conservation funds, the Ecofund (2) and other funds. In
increasingly be used to
future,
provide the requisite finance for projects co-funded by the EU.
In concrete terms, this means that it may be assumed that
funding arrangements for appropriate environmental technolo-
gies will not be made any easier, even though projects invol-
ving such technologies are frequently quickly amortized or do,
in the long term, involve the lowest level of follow-up costs.

The EESC therefore proposes that consideration be also
4.19
given to introducing a degree of earmarking of funding specifi-
cally for investments involving appropriate technologies. A
given percentage of funding under the Cohesion Fund could,
for example, be set aside for projects involving less than a
given level of investment. Projects funded in that way could
clearly no longer be approved on an individual basis by the EU
Commission; the introduction of such a special fund would,
however, represent a milestone in the campaign to spread ideas
relating to appropriate technologies.

(1) In connection with a project organised by the German Federal Foun-
dation for the Environment, the German Federal Ministry of the
Environment and the environmental organisation ‘Euronature’.

(2) The Ecofund is financed on the basis of remission of debt, granted
on a bilateral basis. This fund will continue in existence to 2010.

30.4.2004

EN

Official Journal of the European Union

C 112/91

4.20
In connection with the drawing-up of this opinion,
there also was renewed discussion in the EESC of a demand,
once raised by, amongst other people, the former President of
the European Court of Auditors, Prof. Bernhard Friedmann,
namely that EU aid programmes should no longer provide
grants, which were not repaid, but should offer (lower-interest
rate or interest-free) loans (1).

Under the aid arrangements adopted up to now,
4.20.1
assistance was provided for, for example, the construction of
sewage-treatment plants in some municipalities, whereas aid
was not forthcoming for such projects in other municipalities,
on grounds of limited financial resources. This situation does,
in principle, lead to injustice. In the environmental field, this
means that at present (poorer) rural municipalities are slipping
further and further behind (generally more affluent) towns and
cities as a result of the aid arrangements pursued up to now.

If, on the other hand, funding was provided not in
4.20.2
the form of grants but rather in the form of loans made avail-
able from a revolving fund, this could potentially result in the
launching of an increased number of projects. There could also
be an additional benefit in that parties in receipt of loans may
possibly use the money in a more careful and responsible way
than is the case with grants.

4.20.3 One problem which, for example in Poland, could
make it difficult to restructure aid programmes in the above-
mentioned way is the current indebtedness of municipalities.
High levels of indebtedness are already frequently impeding
preparations for investments to comply with EU requirements
at local level. In 2001 local government bodies in Poland were
indebted to the tune of 12.3 billion Polish Zlotys (PLN) (equiva-
lent to EUR 3 billion); in 2002 the corresponding figure was
PLN15.4 billion (c. EUR 4 billion) and the trend in indebtedness
is rising. This means that many municipalities have reached the
legally admissible threshold for indebtedness and are unable to
take on any more loans.

4.21
In the case of private investments in appropriate tech-
nologies (in fields such as energy-saving measures and the
increased use of
renewable sources of energy alternative
building materials and building constructions), the abovemen-
tioned special revolving fund providing interest-free loans or
loans at favourable rates of interest could provide an attractive
alternative form of funding. Consideration should be given to
linking such a fund to the proposed skill centres.

4.22
A possible way in which additional funding can be
mobilised is through the participation of the private sector in
the provision of public services (public-private partnerships -
PPP).

Brussels, 31 March 2004.

4.23
Public-private partnerships do not, however, only offer
opportunities - they also involve risks. The adoption of a PPP
model which is not properly balanced may, for example, lead
to considerable price increases. A project carried out in the
Hungarian capital of Budapest, for example, involved massive
price increases of over 200 % which led to considerable ill-
feeling between the private operator and the city authorities.

5. Summary

5.1
Environmental technologies have a key role to play in
reducing environmental pollution and bringing about sustain-
able development.

5.2 With a view to avoiding the misallocation of funding, it
is important to pay very careful attention to ensuring that the
solution adopted is that which is best suited to the situation
concerned.

5.3 Whilst the use of appropriate environmental technology
may, in some cases, involve higher planning costs, considerable
savings may be made in both the investment and the opera-
tional phases and more,
lasting jobs may be created. The
savings made in this way could be used to ease the burden on
both public and private budgets. Appropriate environmental
technologies are thus one of the measures which the situation
now calls for.

Appropriate technologies are however often methods
5.4
which are unknown and all too infrequently unused in both
the candidate countries and the current EU Member States. This
can be put down, in part, to the tremendous shortage of know-
how and uncertainty over whether it is indeed possible to
comply with the prescribed standards by using alternative tech-
nologies.

5.5
The EESC calls upon the Commission to address this
issue in-depth in connection with the implementation of the
technologies. The
action plan for promoting environmental
establishment of skill centres for appropriate technologies in
the candidate countries might be one way of starting to reduce
this information shortfall.

Part of the aid made available should be paid into a fund
5.6
used,
to finance smaller measures. The
first and foremost,
Cohesion Fund, which does not provide assistance to any
projects involving sums of less than EUR 10 million, gives too
little aid to appropriate solutions. When applications are made
for assistance from the Cohesion Fund, it would be helpful if
applicants were to provide information indicating why they
had opted to use the proposed technology and what alterna-
tives had been rejected.

The President

of the European Economic and Social Committee

Roger BRIESCH

(1) ‘Financial control – helping to promote the European venture’, an
address given by Prof. Friedmann on the occasion of the award of
the ‘Europäischer Bulle’ Prize 2001, offered by the European
Taxpayers' Association.