Opinion of the European Economic and Social Committee on the Communication from the Commission to the Council and the European Parliament — Stimulating technologies for sustainable development: an environmental technologies action plan for European Union (COM(2004) 38 final)
Date: 2004-06-02
Institutions: European Economic and Social Committee
Subjects: EU action, EU environmental policy, action programme, applied research, new technology, sustainable development, technological change

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3.4
The Committee welcomes Article 5, which permits posi-
tive action. This provision should not, however, endanger vital
services provided both by the public service and by NGOs for
men and women, such as single-sex housing for disadvantaged
persons and shelters for women who have been subject to
domestic or other forms of violence.

Brussels, 3 June 2004.

The Committee approves the provision on dialogue with
3.5
non-governmental
provision must,
however, guarantee regular contact with organised civil society.

organisations.

This

3.6
Information and publicity of the Directive when adopted
will be vital to ensure that consumers are fully aware of their
rights and that providers of goods and services understand
their obligations under it.

The President

of the European Economic and Social Committee

Roger BRIESCH

Opinion of the European Economic and Social Committee on the ‘Communication from the
Commission to the Council and the European Parliament — Stimulating technologies for sustain-
able development: an environmental technologies action plan for European Union’

(COM(2004) 38 final)

(2004/C 241/14)

On 28 January 2004 the Commission decided to consult the European Economic and Social Committee,
under Article 262 of the Treaty establishing the European Community, on the ‘Communication from the
Commission to the Council and the European Parliament — Stimulating technologies for sustainable devel-
opment: an environmental technologies action plan for European Union’.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing
the Committee's work on the subject, adopted its opinion on 6 May 2004. The rapporteur was Mr Buffe-
taut.

At its 409th plenary session (meeting of 2 June 2004) the European Economic and Social Committee
adopted the following opinion by 177 votes to one with five abstentions.

1. Introduction

The Commission lists three:

1.1
This communication is one in a long line of non-legisla-
tive Commission texts which take stock of past initiatives and
future options in a particular sector. It forms a sort of general
framework for Commission thinking on environmental tech-
nologies.

— to remove the obstacles so as to tap the full potential of

environmental technologies,

— to ensure that the EU takes a leading role in developing and

applying environmental technologies, and

From the very start, the communication is set in the
1.2
context of the EU sustainable development strategy and the
Lisbon strategy, pointing out — in the words of the now
familiar refrain — that the aim is to make the EU ‘the most
competitive and dynamic knowledge-based economy in the
world, capable of sustainable economic growth with more and
better jobs and greater social cohesion’.

— to mobilise all stakeholders in support of these objectives,

with the ultimate aim being to reduce pressures on our natural
resources, improve the quality of life for Europe's population
and promote economic growth.

1.3
But after this now ritual reminder, the real question is
raised, namely what are the aims of this environmental technol-
ogies action plan (ETAP)?

The Commission thinks that politically the time is right
1.4
for launching this action plan, but the question is how is this
to be done and what concrete actions are to be taken. It is the
responses to these two questions which structure the text.

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2. Gist of the action plan

2.2.3 A ct i ng g lob a lly

2.1 Building the action plan

2.1.1
which are to underpin the action plan:

The Commission starts by noting a number of points

— the existence of a potential

to promote environmental

technologies,

— the underuse of these technologies,

— the importance of targeted and effective incentives for the
tech-

introduction and development of environmental
nologies,

— the need to develop a long-term perspective for the markets
tech-
investment

in environmental

to permit

in order
nologies,

— the need to coordinate and facilitate exchanges of good

practice,

— the need to create an environment that encourages those
tech-

environmental

who develop, purchase and use
nologies,

— the recognition that the introduction and development of
environmental technologies is a medium- and long-term
activity.

2.2 Acting

The Commission proposes three main areas of action:

— Getting from research to markets,

— Improving market conditions,

— Acting globally.

2.2.1 G e tt i ng fr om r e se a r c h t o ma r ke ts

2.2.1.1
The Commission is advocating that funds from, inter
alia, the EIB and the EBRD be used to increase and focus
research, the aim being to develop commercial applications.

The Commission plans to promote technology plat-
2.2.1.2
forms for promising environmental technologies, the main aim
of which would be to improve the effectiveness of research,
mobilise resources, provide for the development of public-
private partnerships, and improve technology transfer to devel-
oping countries.

2.2.1.3
and standardisation in relation to environmental technologies.

Finally, the Commission wishes to improve testing

2.2.2 Imp r ov i ng ma r ke t condi ti ons

Europe's ambitions with regard to environmental
2.2.3.1
technologies are not confined to the old continent. The
Commission thinks that the European Union has a duty to act
resolutely in promoting sustainable development worldwide.

2.2.3.2
The Commission plans to develop partnerships with
developing countries and to get closely involved in the initia-
tives taken at the Johannesburg summit with regard to environ-
mental technologies.

3. Coordination and monitoring

The drawing-up of an action plan supposes that

3.1
its
implementation will be monitored. The Commission makes
provision for various instruments to that effect:
two-yearly
report, European panel on environmental technologies, coordi-
nation, information on best practice, etc.

4. General comments

4.1
The Committee's comments also take account of the
remarks and suggestions of the Consultative Commission on
Industrial Change (rapporteur: Mrs Sirkeinen, co-rapporteur:
Mr Reichel).

4.2
Environmental technologies, by definition, cover a very
wide field. Their purpose can be to use natural resources in a
sustainable manner, avoid or reduce damage to the environ-
ment, develop alternative energy sources, or be a part of inte-
grated products policy, etc. As the EESC has already pointed
out (1), it is very important for the definition of environmental
technologies not
technologies. The
to be limited to ‘clean’
ongoing improvement of processes and service provision
methods in order to reduce the negative impact on the environ-
ment, research, innovative know-how and development with a
view to upgrading traditional technologies and incorporating
an environmental dimension therein is also one way of devel-
oping environmental technologies and must be encouraged.
The effectiveness of an environmental technique is gauged in
the light of its favourable impact on the environment and not
on the basis of a predetermined definition of environmentally
‘virtuous’ technologies.

4.3
There is the danger of a very broad action plan being
too wide-ranging and hence its resources being scattered too
widely. One of the major challenges for such a plan's success is
probably the ability to define priorities and establish a hier-
archy and hence to assess not only the effectiveness of environ-
mental technologies but also their economic viability. This idea
hardly comes across at all in the Commission document, but it
is of major practical importance. However, it must also not be
forgotten that the sustainable development concept rests on
three pillars — economic development, protection of the envir-
onment and natural resources, and personal self-fulfilment
within society.

The Commission describes how to bring about this
2.2.2.1
improvement in the market in terms of investment, removing
economic barriers, influencing the economic weight of public
procurement and mobilising civil society.

(1) See the European Economic and Social Committee opinion on the
Communication from the Commission on developing an action
plan for environmental technology, COM(2003) 131, OJ C 32 of
5.2.2004, pp. 39-44 (CESE 1390/2003).

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4.4
Environmental technologies are always used when their
use is either of direct benefit to the user or a legal requirement.
Since the free market alone does not fulfil all the socially
accepted ethical, social and environmental goals, the legislator
has always had to step in to create the appropriate legal frame-
work. Whilst such legislation may result in higher costs at a
microeconomic level, these costs may prove to be worthwhile
in macroeconomic terms. When establishing the legal frame-
work, the legislator should take into account the innovative
strength of the economy and of science, by setting targets
without specifying the steps or technologies that are needed to
achieve those targets. The increasing awareness that fulfilling
additional social and environmental criteria may bring opportu-
nities for increasing sales is an important driving force for the
action plan and for strengthening the competitiveness of the
European economy.

4.5
Another determining factor for the success of the envir-
onmental technologies plan is market access and conditions.
There is no point in hoping that environmental technologies
will take off if they cannot find a buoyant and competitive
market. Partly because of non-internalised environmental costs,
but also partly because they have not been developed or pene-
trated the market to such a degree that economies of scale can
be made to reduce costs, effective environmental technologies
often cannot be produced as cheaply as less environment-
friendly technologies. The challenge is therefore to define ways
and means (loans, subsidies, tax incentives) of promoting the
proven
development
processes and corresponding environmental technologies,
in
order to encourage and facilitate market access, or even market
creation. The EESC would stress that if incentives are to form a
coherent whole and be put to good use, it will be necessary to
establish some sort of classification or hierarchy: risk capital for
launches, more traditional loans during the development phase,
tax incentives to consolidate the market, and possibly taxes
which internalise the environmental costs of less environmen-
tally-friendly technologies.

environmentally

desirable

and

of

4.6
In this respect, incentives or deterrents — in the form of
legal and regulatory provisions — are necessary but cannot
treat economic and social realities with disdain. Nor can they
result in the unfair distortion of competition. Environmental
technologies must not be an unattainable luxury or result in
the distortion of competition, brought about by the acceptance
of products and services from economic areas which have not
imposed similar rules. The Commission text makes a point of
this vital fact. The briefing and mobilisation of civil society and
public opinion in support of environmental technologies will
be futile if reality and economic feasibility are overlooked. One
factor in gaining the support of public opinion is that it must
not be forgotten that citizens and consumers are also working
if old technologies have to be
men and women. Therefore,
abandoned because of sustainable development requirements, it
is necessary to foresee the need for retraining and the cost
thereof.

4.7
Finally, it should be pointed out that it is necessary for
the EU's various policies to be generally consistent so that there
is no policy clash. For example, it would be pointless to formu-
late a sustainable development policy that is in conflict with
the policy pursued by the EU in the context of the WTO or in
connection with market liberalisation. In this regard, there is a
vital need for both a serious debate on this issue within the
WTO and a resolute stance against the acceptance of products
and services — irrespective of their origins — which do not
confine the impact of
technologies and processes to the
minimum.

5. Specific comments

5.1 Introduction

The EESC endorses the action plan's objectives and in
5.1.1
particular the desire to exploit environmental
technologies'
potential to the full in order to improve the state of the envir-
onment while at the same time boosting competitiveness and
economic growth. This point has already been made in an
earlier opinion (see footnote 1).

5.2 Incentives for adopting environmental technologies

The Committee stresses the importance of incentives
5.2.1
for developing environmental technologies, but it would point
out that these incentives must not lead to artificial support for
technologies which will never be able to find a real market.
Above all, the market should, however, be geared, through the
use of a properly targeted mix of taxation, subsidy, licence and
regulatory instruments, in such a way as to ensure that the
external costs of various alternative technologies are taken into
account.

5.2.2
Efforts must also focus on improving more traditional
technologies so that they comply increasingly with sustainable
development requirements. In practice, the modernisation and
adaptation of equipment and advances made in technology and
manufacturing or service provision methods have already led
to the application of certain environmental technologies. This
is one way of developing environmental technologies which
may go unnoticed but which is very real.

5.3 Getting from research to markets

5.3.1
One of the major challenges is finding concrete appli-
cations for research into environmental technologies. Research
funds should therefore also be earmarked for applied research
and provision made for the large-scale involvement of enter-
prises — and particularly SMEs. It must also be pointed out
that certain SMEs play a locomotive role in the development
and perfection of environmental technologies.

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5.4 Aid for technology platforms

The EESC thinks that the idea of establishing tech-
5.4.1
nology platforms for promising environmental technologies is
interesting. Bringing together interested stakeholders with real
expertise to focus on a given technology, technologies serving
a given sector or the implementation of technologies suitable
for solving a specific environmental problem is an interesting
move. Intellectual property, patent and trade mark issues will
be governed by the research framework programme's rules and
intellectual property law without giving rise to any particular
problems. The EESC thinks that if the secretariat is provided by
the Commission at the outset, a form of public-private partner-
ship should be able to develop insofar as these technology plat-
forms meet a real need and are of real interest.

ments could provide an opportunity to involve local authorities
in the development of environmental
technologies and to
devise public-private partnerships.

5.7.2
Investments made by enterprises to reduce the adverse
impact of their activities on the environment or to make their
activities more in tune with sustainable development often
represent considerable financial commitments, especially in
heavy industry. Tax incentives should be devised to encourage
such investments, and inversely the tax system should penalise
enterprises that make no effort
to improve their activities'
impact and thus gain a competitive edge by
environmental
producing more cheaply.

5.5 Evaluation and standardisation of environmental technologies

5.8 Public procurement

5.5.1
The spread of environmental technologies is based on
economic considerations but also on their technical effective-
ness. A validation mechanism and networking system for data
on certain key technologies — as advocated by the Commis-
sion — would be very useful for both enterprises and the
public authorities, especially if there is a wish to include some
form of ‘best environmental value’ in public procurement. In
this context, the EESC would draw attention to the call which
it has made for the establishment of a European database. The
European Environment Agency could be involved in the
setting-up and maintenance of this database, which would list
proven, cost-effective/appropriate environmental technologies
and thus provide them with a form of ‘quality label’ (2).

5.6 Performance targets

5.6.1
The Commission stresses that these targets must be
based on best environmental performance while being realistic
from an economic and social efficiency point of view. The
EESC can only endorse this point and would underline that real
sustainable development takes account of not only environ-
mental concerns but also economic competitiveness, the crea-
tion of more and better jobs, and social cohesion.

The idea of using ‘best environmental value’

to
5.8.1
promote environmental technologies is not new. It must be
assessed in the light of the reliability of environmental technol-
ogies and public finance constraints. It can provide an opportu-
nity to develop performance-based invitations to tender. What-
ever happens, however, it cannot be a gimmick used merely for
the sake of having a clear conscience.

5.9 Support of civil society

5.9.1
Every generation is accountable for the society it
hands down to its children. Our contemporaries are becoming
increasingly aware that they are answerable for the environ-
ment they are bequeathing to future generations. Promoting
environmental technologies requires that people be educated
and provided with information which — if it is to be effective
— must be realistic, must underline the advantages of such
technologies, and must be easy to understand and access. This
means organising a real dialogue with stakeholders and the
general public and mobilising local authorities, which often
have a major responsibility in the environmental field.

5.7 Investments

5.10 Acting globally

5.7.1
The use of existing financial instruments and creation
of new ones to share the risk of investing in environmental
technology projects and companies, notably through risk
capital
funds, requires skilled analysts who can assess the
projects' technical and economic feasibility. Otherwise there
would be a risk of wasting loans, which could be useful else-
where. Projects must be assessed on the basis of sound and
objective scientific and technical facts and not on the basis of
instru-
preconceived ideas. The application of new financial

(2) See the EESC's own-initiative opinion on Realities and prospects for
appropriate environmental technologies in the candidate countries
(CESE 12/2004 fin).

5.10.1
The Commission's wish to act globally is commend-
able. The EESC would point out that in the case of most devel-
oping countries the main concerns are economic growth and
the fight against poverty. In addition, these countries' financial
capabilities are poor. The Committee therefore thinks effective
aid must be based more on the transfer of simple and cheap
‘intermediate’ technologies which would already be an improve-
ment on the present situation and need not necessarily be
inferior to more complex, more expensive solutions in terms of
their performance. It should be pointed out that, in the case of
less complex solutions, those receiving the technologies will
face lower costs relating to intellectual property rights and
patents.

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5.10.2
The EESC thinks that it would be interesting for the
EU to participate in the action taken under the auspices of
UNITAR (3) to promote sustainable urbanisation in developing
and transition-economy countries. It notes that in this context
research, study and training centres have been opened in Kuala
Lumpur (Malaysia), Curitiba (Brazil) and Ouagadougou (Burkina
Faso). UNITAR is also planning activities in central Europe. The
Committee also draws attention to its recommendation that
‘independent skill centres for appropriate technologies’ be set
up in the new Member States (4). Such centres could organise
the requisite transfer of expertise and provide advice to both
local decision-makers and civil society bodies, and do not
necessarily need to be restricted to the new Member States.

5.11 Moving forward

5.11.1
The EESC thinks that of the proposed initiatives, the
exchanging of information on good practice and the establish-
ment of indicators to compare best practice are the most inter-
esting. If the biennial report for the Council and the European
Parliament is not very concrete and compact, it is in danger of
becoming just another report. Also, calling the European panel
on environmental technologies a committee in some language
versions is a bad choice of words, since it is not a committee in
the usual sense but rather a forum bringing together scientists,
technologists,
industrialists, entrepreneurs and NGOs, etc.
However, there is also a case for asking whether the tasks
assigned to this panel could not be performed by the
DG Environment and the DG Research without setting up yet
another body, the effectiveness of which may be open to ques-
tion if it is too large?

5.11.2
In an earlier opinion the EESC, reflecting the wish to
‘move forward’, proposed an ‘environmental ombudsman’, who
would be responsible in particular for highlighting the obstacles
to the development of environmental technologies created by
rules and regulations. This proposal would be more operational

Brussels, 2 June 2004.

than the establishment of a vast forum, which would be in
danger of getting lost in generalities.

6. Conclusions

6.1
The EESC recognises the importance of the Commis-
sion's action in drawing up the environmental technologies
action plan, which has given rise to wide-ranging consultations.
At a general level, the importance of this type of non-legislative
document is that it provides an overview within the framework
of a flexible procedure and lays down general guidelines.

The EESC considers that the practical development of
6.2
environmental technologies inevitably means making choices,
establishing a hierarchy for these choices and drawing up a
classification for funding, which is limited and must be used
wisely. The ability to make pertinent choices will determine the
success of the European strategy in this field. It necessitates a
realistic and practical approach.

6.3
The EESC would emphasise the importance of a system
for validating the effectiveness of environmental technologies
and the dissemination of the data available on such technolo-
gies. This is one of the prerequisites for the spread of environ-
mental technologies and their application by enterprises and
public authorities.

the

Ultimately, one must ask whether the whole question
6.4
does not boil down to determining the environmental technol-
ogies which it is advisable to develop in the light of their effec-
tiveness,
environmental
conditions on the market,
constraints, the employment situation in both quantitative and
qualitative terms, living standards and the level of development.
It is a matter of scientific, technical, economic and social judg-
ment and competence which the Union has a duty to address if
it wishes to promote environmental technologies effectively.

The President

of the European Economic and Social Committee

Roger BRIESCH

(3) United Nations Institute for Training and Research.
(4) See footnote 2.