COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT
Date: 2011-12-12
Institutions: European Commission
Subjects: biodiversity, climate change, environmental impact, financial instrument, management of resources, sustainable development

EUROPEAN COMMISSION 

Brussels, 12.12.2011 
SEC(2011) 1542 final 

Volume 1 of 2 

COMMISSION STAFF WORKING PAPER 

IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a Regulation  

on the establishment of a Programme for the Environment and Climate Action (LIFE) 

{COM(2011) 874 final} 
{SEC(2011) 1541 final} 
{SEC(2011) 1543 final} 

 
 
 
 
  
 
Disclaimer: This impact assessment commits only the Commission's services involved in its 
preparation  and  does  not  prejudge  the  final  form  of  any  decision  to  be  taken  by  the 
Commission. 

1 

 
 
TABLE OF CONTENT 
1. 
1.1. 

Procedural Issues and Consultation of Interested Parties .........................................................3 
Procedural issues.......................................................................................................................3 

1.2. 

1.3. 

2. 
2.1. 

2.2. 

External expertise and consultation of interested parties..........................................................3 

Opinion of the Impact Assessment Board (IAB): .....................................................................4 

Current Stucture and Performance of LIFE and Problem Definition .......................................5 
Current structure and design of the LIFE Programme ..............................................................5 

Problem definition ....................................................................................................................6 

2.2.1. 

Environmental and climate problems, their main drivers and underlying causes.....................6 

2.2.2. 

Performance of the LIFE Programme and problems linked to its design and structure ...........9 

2.3. 

2.4. 

2.5. 

How will the problem evolve? ................................................................................................18 

Who is affected and how?.......................................................................................................20 

The EU's right to act and justification.....................................................................................20 

2.5.1. 

The EU's right to act on environment and climate policies ....................................................20 

2.5.2.  Necessity of EU action............................................................................................................20 

2.5.3. 

EU added value of EU action of a specific financial instrument for Environment and Climate 
Action......................................................................................................................................21 

2.5.4. 

Proportionality of the EU action .............................................................................................22 

3. 
3.1. 

3.2. 

3.3. 

4. 
4.1. 

4.2. 

4.3. 

4.4. 

5. 
5.1. 

5.2. 

6. 
6.1. 

6.2. 

6.3. 

7. 
8. 

Objectives ...............................................................................................................................22 
Objectives related to the content of the LIFE Programme......................................................22 

Objectives related to the design of the Programme ................................................................22 

Consistency with existing EU policies and strategies such as Europe 2020...........................23 

Policy Options.........................................................................................................................26 
Description of the baseline as defined by the MFF Communication......................................26 

Development of the policy options .........................................................................................28 

Which options have been discarded and why? .......................................................................28 

Description of the options retained for further assessment.....................................................31 

Analysis of Impacts.................................................................................................................40 
Introductory remarks about impacts of the current LIFE+ Regulation and the Baseline 
derived from the MFF Communication ..................................................................................40 

Analysis of the options............................................................................................................43 

Comparing the Options ...........................................................................................................59 
Summary of the assessments ..................................................................................................59 

Comparisons ...........................................................................................................................66 

Preferred option ......................................................................................................................66 

Monitoring and Evaluation .....................................................................................................67 
Annexes ..................................................................................................................................69 

2 

 
Introduction 

This impact assessment assesses the potential economic, social and environmental impacts 
of different options for managing a financial instrument for the Environment and Climate 
Action (LIFE) for the period 2014-2020 (successor to the LIFE+ Programme).  

The EU budget reform focuses on the creation of European added-value and the achievement 
of  the  key  priorities  outlined  in  the  Europe  2020  Strategy,  which  sets  the  framework  for 
smart, sustainable and  inclusive  growth.  Investments in environmental protection, climate 
change  mitigation  and  adaptation,  and  resource  efficiency  are  investments  in  the 
modernisation  of  our  economies  and  societies  that  contribute  directly  to  two  EU2020 
flagships, namely "the Innovation Union" and "Resource Efficiency", and the headline target 
for climate and energy.  

for 

the  next  Multiannual  Financial  Framework 

In the Communication of 29 June 2011, the Commission adopted its position for the Union's 
finances 
the  MFF 
Communication)  for  2014-2020.1  This  Communication  outlines  the  main  elements  of  the 
future LIFE Programme2, which will include two sub-programmes, one for the environment 
(€2.4 billion) and one for climate (€800 million). It
 also mentions that the future Programme 
should  remain  centrally  managed,  but  that  management  tasks  could  to  a  large  extent  be 
delegated to an existing agency. 

(hereinafter 

1. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

1.1. 

Procedural issues 

This impact assessment has been prepared by Directorate General for the Environment (DG 
Environment) and Directorate General for Climate Action (DG Climate Action). Inter-service 
cooperation was ensured through the establishment of an Inter-Service Steering Group (ISG) 
set up in September 2010 and which met several times with all interested DGs, the Secretariat 
General and the European Agency for Competitiveness and Innovation (EACI). Members of 
the  ISG  also  followed  the  supporting  study  carried  out  by  consultants  GHK  et  al.  and 
participated  in  the  workshops  organised  both  during  the  mid-term  evaluation  of  LIFE+  and 
during the combined impact assessment/ex-ante evaluation.  

1.2. 

External expertise and consultation of interested parties 

External expertise: Two independent studies were commissioned from external consultants: 
"Combined impact assessment and ex-ante evaluation of the review of the LIFE+ Regulation" 
carried  out  by  a  consortium  led  by  GHK  and  "Climate  Change  in  the  future  multiannual 
financial  framework"  carried  out  by  the  Institute  for  European  Environmental  Policy.  The 
results of the ex-post evaluation carried out by COWI in 20093 and the Mid-term evaluation 
of LIFE+ carried out by GHK et al.4 in 2010 were also taken into account.5 

1 

2 
3 
4 
5 

COM(2011)500 final-A Budget for Europe 2020:  
http://europa.eu/press_room/pdf/a_budget_for_europe_2020_en.pdf. 
See details in Annex 2. 
http://ec.europa.eu/environment/life/publications/lifepublications/evaluation/index.htm#expost.  
http://ec.europa.eu/environment/life/publications/lifepublications/evaluation/index.htm#mte2010.  
These are summarised in Annex 4. 

3 

 
 
                                                 
Consultation process: In the context of the budget review, the Commission has carried out 
studies,  discussions  and  analysis,  including  a  wide  public  consultation.  This  exercise 
identified climate change as a major challenge with two thirds of the contributors considering 
it  Europe’s  big  test  for  the  future.  The  political  conference  closing  the  public  consultation 
confirmed  this  and  there  were  calls  for  increasing  priority  spending  for  environment  and 
climate action in EU expenditure plans. 

An  open  online  consultation  was  carried  out  on  'Your  Voice  in  Europe'.6  Around  1,000 
responses  were  received  from  a  variety  of  stakeholders,  of  which  58%  had  never  received 
LIFE funding. Some 35% of respondents were organisations, 13% were competent authorities 
and 53% were private individuals.  

More  targeted  consultations  have  been  carried  out  to  complement  the  stakeholder  survey: 
one organised with the LIFE Committee members and Member States' environmental attachés 
on 27 January 2011, an ad-hoc stakeholder meeting7 with around 100 representatives on 28 
January  2011  (e.g.  NGOs,  farmers  association,  business,  and  public  authorities),  and  a 
specific survey on territorial impacts coordinated by the Committee of the Regions.  

The outcome of the consultation proces can be summarised as follows: The Programme is 
seen  as  generally  performing  well  in  both  environmental  and  value-added  terms. 
Reflecting  this,  there  is  overwhelming  support  for  the  continuation  of  LIFE+  from  all 
stakeholders  with  a  preference  for  'evolution  rather  than  revolution'.  There  was  general 
support  for  the  different  interventions  and  proposals  made  by  the  Commission.  Integrated 
Projects were seen as having potential, and once explained, gathered support including from 
Member  States.  General  support  was  provided  as  well  for  a  more  targeted  focus,  with 
biodiversity and climate adaptation as top priorities, an increase in the budget and in the co-
financing rate, and partial extension of the territorial scope.8  

1.3. 

Opinion of the Impact Assessment Board (IAB): 

A first version of the Impact Assessment was submitted to the IAB on 29 July 2011. The IAB 
Opinion was issued on 13 September and suggested a series of modifications to improve the 
quality and presentation of the assessment.  

Based on the IAB Opinion, section 2.2 has been modified to provide further information on 
the  best  preforming  sectors  and  features  of  the  LIFE  Programme.  In  particular,  information 
has  been  added  regarding  the  type  of  funding  that  has  been  most  successful  in  terms  of 
environmental benefits, the absortion capacity of the Programme, and additional data on the 
problems  with  its  design  and  functionning.  Clearer  reference  was  made  to  the  link  between 
the problems in the implementation of the current Programme with the respective options. 

The synergies and potential risks of overlapping with other Union Funds were also developed 
more in detail (section 2.2.2(b)) and complemented with a summary of the the assessment of 
the  zero  option  (which  was  originally  only  included  as  an  Annex)  in  section  4.2.  This  also 
allowed  clarifying  the  policy  areas  better  suited  for  Union  intervention  through  the  LIFE 
Programme. 

6 
7 
8 

Hereinafter referred to as "YVIE". 
Hereinafter referred to as "EC workshop". 
The  outcome  from  these  consultations  is  summarised  in  Annex  3  and  relevant  elements  are  inserted 
throughout this report. 

4 

 
                                                 
More  clarity  has  been  provided  in  the  section  4.4.  regarding  the  Options.  Firstly  by 
developing in detail the Baseline as presented in the MFF Communication, and secondly by 
further  developing  the  options  related  to  the  thematic  concentration  of  Integrated  Projects 
(Options B) and the allocation of resources between the different priority areas (Options C). 
Finally,  more  information  is  provided  regarding  overhead  costs  and  proposed  changes, 
including all the improvements already undertaken or planned.  

For all options, the baseline sub-option (established on the basis of the MFF Communication) 
has  been  clearly  identified  and  the  assessment  of  impacts  has  been  modified  accordingly 
(Section  6.2).  Information  included  in  annexes,  opinions  of  the  stakeholders  regarding 
different  options  and  limitations  of  the  applied  methodology  are  also  presented  in  a  more 
systematic and transparent manner throughout the assessment. 

2. 

CURRENT STUCTURE AND PERFORMANCE OF LIFE AND PROBLEM DEFINITION 

2.1. 

Current structure and design of the LIFE Programme 

Launched  in  1992,  the  LIFE  Programme  is  one  of  the  spearheads  of  EU  environmental 
funding  and  has  financed  3,115  projects  with  a  contribution  of  €2.7  billion.  The  latest 
Financial Instrument for the Environment (LIFE+) was adopted through Regulation (EC) No 
614/2007  (the  Regulation).9  The  Programme  is  centrally  managed  by  the  Commission.  The 
list of projects is approved by comitology with parliamentary scrutiny.  

The  purpose  of  the  LIFE+  Regulation  is  to  contribute  to  the  implementation,  updating  and 
development of EU environmental policy and legislation thereby contributing to sustainable 
development.  Another  objective  is  to  contribute  to  communicating  and  disseminating 
environmental issues throughout the EU. 

Three types of interventions are possible under LIFE+: 

•  Action  grants,  traditional  LIFE  Programme,  representing  78%  of  the  budget  with  three 
strands (see box 1); 

•  Operating grants for NGOs, former NGO Programme, representing 3% of the budget; 

•  Public procurement contracts for services and studies related to the development, update 
and  implementation  of  EU  environmental  and  climate  policy  and  legislation,  representing 
13% of the budget; and Technical assistance to the selection, monitoring and evaluation of 
LIFE projects and the Programme representing 6% of the budget. 

Box 1: LIFE+ Strands 
Nature  &  Biodiversity:  projects  contributing  to  implementing  the  Birds  and  Habitats  Directives,  including  set-up  and 
management of the Natura2000 network, and the Communication on "Halting the loss of biodiversity by 2010". 

Environment Policy & Governance (EPG): innovative or demonstration projects relating to EU environmental objectives. It 
includes 12 priority areas for action, one of which is climate action. 

Information & Communication: communication & awareness raising campaigns on EU environmental policy and forest fires. 

9 

OJ L 149, 09.06.2007 

5 

 
 
 
 
                                                 
 
 
Underlying 
Pressures: 
Environmental 
degradation
Increasing 
incidence of 
transboundary
environmental 
problems and 
impacts
Biodiversity loss
Growing 
recognition of 
need to preserve 
socially and 
economically 
important 
ecosystem 
services

Issues being addressed 
:

Insufficient coverage of 
all environmental 
priorities by the existing 
set of Community 
financial instruments

Insufficient funding for the 
management of the 
Natura 2000 network by 
other instruments 

Inadequate 
implementation of 
Community 
environmental policy 
(namely 6th
Environmental Action 
Programme) across the 
Member States 

Dissemination of  best 
practice 

Figure 1: Intervention Logic for LIFE+ 

Environmental protection is one of the key dimensions of sustainable development of the 
European Union. It is therefore a priority for Union co-financing  and should  be funded 
primarily through  the EU horizontal  financial instruments. 

General objective: To contribute to the implementation, updating and development of EU 
environmental policy and legislation 

Specific objectives:

Contribute to 
implementation 
of EU nature 
and biodiversity 
policy and the 
implementation 
of Natura 2000 
network 

Contribute to 
consolidation of 
knowledge base for 
development, 
assessment, 
monitoring and 
evaluation of nature, 
biodiversity and 
environmental policy 
and legislation 

Support design / 
implementation of 
approaches to 
monitoring and 
assessment of 
nature, 
biodiversity, state 
of environment 
and factors 
impacting them

Provide 
support for 
better 
environmental 
governance 
through 
broadening 
stakeholder 
involvement 

Disseminate 
information 
and raise 
awareness 
on 
environment
al issues  

Action grants 
for 
demonstration / 
best practice 
projects relating 
to Birds and 
Habitats 
Directives 
implementation 

Action grants 
for 
demonstration 
/ innovation 
projects 
contributing to 
halting loss of 
biodiversity in 
EU

Action Grants 
for 
demonstration / 
innovation 
projects aimed 
at implementing 
EU 
environmental 
policy

Public 
procurement 
contracts to 
support  
development 
of EU 
environment 
policy

NGO 
Operating 
Grants 

Awareness 
raising 
campaigns 
and training 
activities 
for forest 
fire 
prevention

Operational Objectives (in blue)

The co-financing rate is 50% of eligible costs but the maximum co-financing rate in Nature 
projects may be up to 75% if targeting priority habitats or species.  

The LIFE+ Regulation requires at least 50 % of the budgetary resources for LIFE+ projects to 
be allocated to measures to support the conservation of nature and biodiversity.  

LIFE+  projects  are  selected  on  the  basis  of  a  call  for  proposals  launched  every  year  by  the 
Commission. Operational funding for NGOs is also subject to an annual call for proposals run 
by DG Environment with a 70% co-financing rate. Policy support expenditure is contracted 
on a continuous basis, upon demand from DG Environment and DG Climate Action.  

2.2. 

Problem definition  

2.2.1.  Environmental and climate problems, their main drivers and underlying causes 

When  analysing  the  design  and  focus  of  a  specific  programme  for  the  environment  and 
climate action, it is necessary to identify the drivers and underlying causes of environmental 
and climate problems to be addressed.  

Halting the loss of biodiversity and improving resource efficiency along with climate change, 
and environment and health related concerns remain key challenges for the EU.1011Although 
difficult to quantify, an assessment of externalities indicates that the total environmental cost 
in the EU each year is more than €650 bil lion representing around 5.7% of EU GDP (details 
fo  the  calculation  are  provided  in  Annex  5).  For  example,  the  projected  climate  damage 
costs12  are  estimated  at  about  €20  billion  per  year  by  2020  to  €100-150  billion  per  year  by 
2050, if no adaptation measures are implemented. 

These  problems  are  a  consequence  of  wide  range  of  economic  and  social  activity  and 
behaviour,  which  constitute  institutional  drivers,  market  and  regulatory  failures.  The  role  of 
LIFE is to act as catalyst for change in areas where such a small instrument would be effective 

10 
11 
12 

EEA, The European Environment State and outlook 2010 available at http://www.eea.europa.eu/soer. 
SEC(2010) 975 final. 
Results from ClimateCost project using PAGE model. 

6 

 
 
                                                 
and  achieve  the  highest  EU  added  value.  This  is  attained  by  funding  start-up  actions  and 
innovative, demonstrative, and best practices projects that could be replicated, as well as by 
acting  as  a  platform  for  knowledge-sharing.  Given  this,  the  instrument  typically  deals  with 
institutional drivers (and in some cases market failures), which are described in this section 
and are further developed in Annex 5. 

(1) 

Uneven  and  inadequate  level  of  environmental  protection  due  to  the  insufficient 
implementation or scope of environmental and climate policy  

Despite  the  well  documented  health  and  socio-economic  benefits  of  implementing 
environmental  and  climate  legislation,  a  high  rate  of  implementation  failures  remains.13  Its 
underlying  causes  vary  between  Member  States.  One  driver  to  highlight  is  insufficient 
administrative capacity, which includes individual competence, organisational capacities, the 
enabling environment and partnerships/network organisations. This leaves much room for the 
Commission  to  be  proactive  and  promote  implementation  and  compliance  through  the 
exchange  and  transfer  of  best  practices,  and  knowledge  and  experience  at  EU  level.  The 
different evaluations show that LIFE can offer this platform. 

(2) 

Uneven integration of environment and climate concerns into other policies  

The principle of environmental integration recognises that environmental policy alone cannot 
achieve  the  environmental  improvements  needed.14  However,  evidence  (e.g.  see  the  latest 
Cohesion  report)  suggests  there  in  unevenness  in  the  way  this  happens  on  the  ground.  In 
particular, there are substantial divergences in the way environmental and climate objectives 
are incorporated into national/regional programmes and dealt with by the various authorities 
and  the  private  sector.  Underlying  causes  identified  include  different  competing  priorities, 
lack of absorption capacity and knowledge sharing, lack of coordination between authorities 
and insufficient strategic planning. Showing to regional and national authorities the benefits 
of  investing  in  the  environmental  sector  and  incentivising  them  to  develop  strategic 
frameworks  require  in  some  cases  demonstrative  projects.  LIFE  could  provide  those 
examples,  thereby  becoming  a  catalyst  and  “leader”  for  other  EU  instruments  and  help  to 
addressing coordination failures. 

(3) 

Inadequate levels of awareness and sharing of information  

The  problem  of  implementation  and  integration  described  above  arise  in  part  because  of  an 
inadequate  sharing  of  information.  The  problem  is  twofold:  insufficient  understanding  of 
environmental  problems  and  challenges,  and  insufficient  knowledge  sharing  (e.g.,  potential 
solutions  to  the  problems).  Most  EU  Funds  do  not  include  compulsory  dissemination  and 
awareness raising obligations focusing on environmental and climate challenges, while LIFE 
does.  As  part  of  the  strategy  to  promote  full  implementation  of  the  acquis,  LIFE  could 
provide the framework to substantially increase environmental and climate related awareness. 

(4) 

Limited support to eco-innovation  

The pursuit of eco-innovation is not just developing new consumer products and technologies 
that are intrinsically cleaner and greener than their predecessors. It is also about engendering 
better  practices  and  approaches  across  the  economy.  While  market  failures  are  sufficiently 

13 

14 

One third of all open cases for non-compliance are environment related cases, which indicates that the 
implementation of environmental legislation remains far from satisfactory. 
COM(2004)394 "Integrating environmental considerations into other policy areas – a stocktaking of the 
Cardiff process". 

7 

 
                                                 
addressed  by  other  EU  Funds,  institutional  weaknesses  are  more  insufficiently  dealt  with. 
This is particularly relevant for activities related to developing policy driven and public sector 
oriented solutions to environmental problems with limited or no market replication potential 
and  that  simply  promote  new  and  more  cost-effective  ways  to  implement  environmental 
policy.  Similarly,  low  carbon  technology  development  is  hampered  by  uncertainty  and 
knowledge  spill-over  in  general.  After  technologies  have  been  developed,  they  need  to  be 
tested  at  a  small  scale.  While  market-replication  and  large  scale  solutions  are  increasingly 
covered  by  new  initiatives  like  Horizon  2020,  there  is  still  much  room  to  promote  the 
development of local and public sector-oriented solutions as well as small-scale technologies 
focused on SMEs to help them improve their environmental and climate performance. LIFE 
has traditionally dealt with these local challenges by providing highly replicable smaller scale 
solutions.  

The  problem  tree  in  figure  2  below  shows  that  in  addition  to  the  institutional  drivers 
developed in this section, there are also market and regulatory failures that relate to the fact 
that the environment is a public good. As a consequence, negative environmental externalities 
are not integrated in price, resulting in imperfect competition and in positive spillovers from 
innovation  being  not  recognised  by  the  market.  In  addition,  information  failures  cause 
consumers to make ill choices, and regulatory capture makes that particular interested parties 
have a disproportionate influence over policy and legislation. Most environmental challenges 
have been regulated at EU level thereby tackling regulatory and in many cases market failures 
(e.g.,  by  imposing  a  price  to  use  a  resource,  by  homogenising  standards  for  a  particular 
environmental  sector).  Market-based  instruments  also  address  many  of  the  externalities  and 
market failures identified.  

Consequences 
for all actors

Costs to citizens
- Health effects
- Quality of life reduced 
- Fewer em ploym ent 

opportunities

Costs to producers
- Loss of resources and    
eco-system  services, 
which raises costs
- Inefficient m arkets
- Loss of level playing field

Costs to consumers
- More expensive products
- Products fail to provide 
full utility (sustainability)

Costs to future generations
- Poorer quality environment 
- Lack of resources
- Higher costs

Figure 2: Problem Tree 

Environmental 
problems (with 
clear EU 
dimensions)

Transboundary
impacts 

Lack of burden sharing in 
m aintaining EU 
environm ental assets

Underm ining of environmental 
policy by ‘race to bottom’

Lack of EU scale in 
innovation 

Current and continuing 
environm ental problems in 
the EU

New and em erging 
environmental problems 
in the EU

Increasing burden from  
global and non-EU 
environm ental problems 

Inability to decouple econom y 
from use of natural resources / 
environm ental impact

EU has a range of environmental problems which im pose economic and social costs. 
This reduces quality of life for all EU citizens and underm ines  EU and global sustainability

Variable and inadequate levels of 
environm ental protection 
- EU inadequate im plementation
- EU inadequate scope

Inadequate coordination 
and a lack of integration of 
EU  environm ental policies  
(including in 3rd Countries)

Inadequate sharing of information 
and EU environm ental policy lessons 
and inadequate levels of awareness 
of environm ental problems

Inadequate 
system of 
support for 
eco-innovation

Inadequate response to market failures

Inadequate prioritisation of environmental objectives

Environm ental public goods 

Negative environmental externalities

Positive spillovers from  innovation

Information failures 

Institutional 
factors  - The 
drivers of 
environmental 
problems

Market &  Regulatory
failures 
(endemic features 
of the  system  )

However,  not  all  underlying  causes  and  drivers  can  be  solved  through  legislation.  For 
example,  the  first  institutional  driver  mentioned  in  this  section  is  precisely  the  insufficient 
implementation  of  environmental  and  climate  legislation,  which  consolidates  many  of  the 
environmental  and  climate  challenges  identified.  Therefore,  incentives  and  measures  other 
than legislation and market-based instruments are required to address those barriers. 

8 

 
 
 
The  budget  is  an  essential  policy  instrument  to  achieve  EU  objectives,  and  to  recognise 
solidarity and effort sharing. 

In fact, EU2020 has set out specific targets and objectives that will require a combination of 
different  policy  instruments  if  they  are  to  be  achieved.  Among  these  policy  instruments, 
mobilisation of possible funds is essential to support implementation costs as well as to drive 
change.  The  different  EU  funding  programmes  thus  address  different  drivers  at  different 
levels ensuring the coherent and complementary approach of the EU's intervention. 

Whereas  many  EU  funding  instruments  mostly  focus  on  supporting  implementation  costs 
(particular  in  relation  to  investments  in  infrastructure)  and  research  needs  on  a  larger  EU 
scale, LIFE, as shown in this section, focuses more on institutional barriers (linked to lack of 
adequate  capacity  to  implement  and  integrate  environmental  and  climate  concerns  or 
deficiencies in knowledge/best practice sharing), and addresses information failures through a 
wide dissemination of project results and networking obligations. LIFE addresses main gaps 
(institutional,  procedural, 
in  Cohesion  policy  funds,  Common 
identified 
Agricultural Policy (CAP) Funds, and the Research and Innovation Framework Programme. 
LIFE  in  particular  helps  addressing  the  challenge  of  establishing  adequate  mechanisms  for 
coordination for environment and climate (contributing to the success of mainstreaming and 
addressing uptake problems). In addition, LIFE provides solutions that can be scaled-up and 
mainstreamed into these bigger Funds. More detailed discussion on the relation between LIFE 
and each fund is provided in section 3.2 (consistency with existing EU policies) and section 
4.1 (zero option). 

territorial) 

2.2.2.  Performance of the LIFE Programme and problems linked to its design and structure  

The  evaluations  mentioned  in  section  1.2  confirm  that  LIFE  is  a  successful  EU  instrument 
crucial to implementing EU environmental policy. It has a significant EU added value and has 
performed well. 

a.  

The best performing sectors and features of the LIFE Programme 

(1) 

LIFE contribution to implementation and to creating environmental benefits has been 
particularly successful in certain sectors  

Since  projects  supported  by  way  of  action  grants  focus  on  concrete  environmental 
improvements  (such  as  restoring  habitats)  or  finding  solutions  to  environmental  problems, 
action  grants  are  the  type  of  funding  that  led  to  direct  environmental  and  climate  benefits 
(e.g., reduction of CO2 emissions, less hazardous substances in water, etc.). This implies that 
environmental and climate benefits are easier to quantify for action grants.  

LIFE has worked best when focused on a particular sector and thus is able to create critical 
mass.  These  sectors  tend  to  be  as  well  those  in  which  LIFE  has  also  brought  more  direct 
environmental benefits. 

One of the main success of the Programme is the LIFE Nature component. LIFE has played 
a  major  role  in  implementing  the  Habitats  and  Birds  Directives,  firstly,  by  financing  the 
inventories  required  for  the  designation  of  the  Natura2000  sites;  secondly,  by  restoring  and 
improving  the  conservation  status  of  habitats  and  species;  thirdly,  by  building  the  capacity 
required  to  manage  the  network  in  the  long  term;  and  fourthly,  by  eliminating  the  initial 
resistance  in  many  sectors,  including  the  public  administration,  to  implement  the  Nature 

9 

 
Directives (for more details see Table 1.2 of Annex 7).15 This success derives to a great extent 
from concentrating 50% of resources on two Directives and from the close links between the 
Programme and EU policy priorities. Projects' size in the Nature component has been steadily 
increasing over time to cover larger portions of the territory of a region or a Member State, 
which  also  contributes  to  increasing  the  capacity  of  these  projects  to  provide  direct 
environmental  benefits  (see  Box  3  in  section  2.2.2(b)1  for  an  example  of  a  large  scale 
project). 

In the Environment component, Eco-innovation projects (around 42% of projects financed 
under  the  LIFE  Environment  strand)  bring  more  direct  environmental  benefits  since  they 
focus on demonstrating environmental improvements as a result of innovative/demonstrative 
solutions  to  environmental  problems.  Action  grants  in  the  area  of  climate  change,  water, 
waste and to a certain extent air can be considered as the most successful in achieving direct 
environmental benefits (see Table 1.4 of Annex 7). In addition, the ex-post evaluation noted a 
positive  pump-priming  effect  (with  projects  being  replicated  and  thus  increasing  direct 
environmental benefits) in the waste and water sectors. 

For  other  projects  funded  under  LIFE  Environment  that  aim  at  testing  and  developing  new 
policy  or  management  approaches  and  proposals,  quantification  of  direct  environmental 
benefits  is  not  possible.  This  would  be  the  case  particularly  for  strategic  approaches, 
chemicals, urban, noise, or soil where few direct environmental benefits are reported although 
successful management systems have been established.   

In  any  case,  the  lack  of  focus  of  the  Environment  strand  meant  that  projects  even  within  a 
common and successful theme such as waste or climate change addressed in fact a wide range 
of  issues.  As  a  consequence,  the  overall  body  of  projects  lack  coherence,  reducing  the 
capacity  for  direct  environmental benefits,  mutual learning exchange, transferability and the 
delivery of multipliers.  

Information  and  communication  projects  have  not  been  particularly  successful.  This  is 
partially  due  to  the  current  design  of  the  LIFE  Information  &  Communication  component, 
which  is  not  adapted  to  communication  and  awareness  needs.  However,  it  should  be  noted 
that  when  an  Information  project  is  adequately  designed  and  has  a  sufficiently  large 
geographic  scope  it  has  a  great  potential  for  changing  behaviours  (see  examples  in  Box  2 
below).  It  is  not  always  possible  to  quantify  direct  environmental  benefits  resulting  from 
Information projects. 

Box 2: Illustrations of a LIFE Information & Communication strand 

European day 'In town, without my car?' (subsequently becoming the European Mobility Week): In 2002, the campaign 
succeeded  in  establishing  a  truly  European  initiative  with  320  cities  from  21  countries  taking  part  in  European  Mobility 
Week.  A  second  event  held  in  September  2003  consisted  of  a  week-long  series  of  awareness-raising  events  focusing  on 
various aspects of sustainable mobility. Mobility Week succesfully continues taking place in Europe and is now spreading to 
the rest of the world via grassroots networks. 

The European Week of Waste Reduction. The LIFE project EWWR aims to reduce the amount of waste generated in the 
EU  by  mobilising  all  relevant  actors  in  a  EU-wide  awareness-raising  campaign  and  changing  behaviours  of  different 
stakeholders in their waste generation. 4 Member States have joined to develop a common strategy as well as tools to carry 
out awareness-raising activities on recycling around the EU over one week every year. In 2009, 2,672 initiatives were carried 
out, in 2010 there were 4,346 in 24 countries reflecting the success of the event. In 2011 expectations are even higher. 

15 

Between 1992 and 2006 and with only €70million a year LIFE covered 9% of the Natura2000 terrestrial 
network.  The  actual  coverage  in  relation  to  areas  in  needs  of  intervention  is  higher,  but  lack  of  data 
makes it impossible to determine how much higher. For the period 2007-2013 LIFE+ will cover around 
6%  of  the  terrestrial  Natura2000  with  a  big  increase  in  the  coverage  of  the  marine  network.  Around 
37% of birds species and 50% of animals species have been targeted by LIFE projects with half of them 
achieving "favourable conservation status" for one or more of the targeted species in the long term. 

10 

 
                                                 
Finally,  it  should  be  highlighted  that  some  of  the  most  successful  projects  in  terms  of 
environmental benefits have also been those where LIFE funding was complemented, scaled-
up  or  continued  via  other  funds.  Particularly  successful  in  terms  of  environmental  benefits 
were those projects where LIFE funding was used in combination with other EU and national 
funds  because  it  also  help  covering  larger  portions  of  the  territory  and  addressing  different 
and complementary needs (see Box 4 in section 2.2.2(b)(3)). 

NGOs  activities  funded  by  operational  grants  have  also  being  successful  in  achieving 
environmental  and  climate  objectives.  There  are  numerous  examples  of  environmental 
investigation  and  studies  carried  out  by  NGOs  in  relation  to  environmental  policy,  many  of 
which  have  contributed  directly  to  the  policy  process  to  identify  environmental  and  climate 
problems  or  even  define  policy  options.  NGOs  contribute  to  the  knowledge-base  for 
environmental policy by feeding in specific expertise, research and studies. For instance, an 
investigation  by  the  Pesticides  Action  Network  (PAN)  Europe  in  2008  of  bottles  of  wine 
purchased inside the EU found evidence that some wines contain residues of "a large number 
of pesticides".16 In addition, through their networks and specific expertise, NGOs are effective 
in  promoting  implementation  of  EU  policy  on  the  ground.  They  can  for  example  draw 
attention  to  cases  of  non-compliance  and  publishing  black  lists,  scoreboards  and  reports 
contribute  to  improving  implementation.  They  also  act  as  centres  of  expertise  helping  local 
authorities  and  economic  actors  to  comply  with  legal  or  policy  requests,  or  setting  up 
implementation initiatives themselves.  Direct environmental impacts cannot be quantified. 

(2) 

LIFE  has  played  a  significant  role  in  increasing  awareness,  good  governance  and 
public participation 

LIFE projects have made a significant contribution to increase information and awareness on 
environmental  and  climate  related  matters  as,  on  average,  between  5-10%  of  resources  are 
dedicated to these aspects (Table 1 shows a total investment of around €36.5 million) which is 
compulsory for all projects. These projects have performed well.  

Table 1 - Budgeted amounts for dissemination and awareness activities under LIFE projects (2007-2009) 

Activity 

€ (budgeted) 

Educational activities 

2.010.334  

Media activities 

Publications 

Trainings 

Workshops 

TOTAL 

10.704.716  

7.477.340  

6.858.612  

9.507.216  

36.558.218 

In addition, the EU contribution under the Information & Communication strand to awareness 
raising campaigns has been of €34.1 million. 

LIFE  has  also  improved  governance  and  public  participation.  Operating  grants  for  NGOs 
facilitated  their  involvement  in  developing  and  implementing  EU  environmental  policy  and 
legislation as required by the Aarhus Convention. NGOs played an important role in ensuring 
good  governance  policy  by  articulating  the  interests  of  civil  society.  Funded  NGOs  play  an 
important role in coordinating the positions of their members, providing the Commission with 
a single interlocutor and giving a voice to a large number of local organisations which would 
otherwise  have  difficulties  reaching  EU  decision-makers.  NGOs  reply  regularly  to  public 
consultations, providing useful input and perspective to the policy process. Operation grants 

16 

PAN  Europe  (2008)  European  wine  systematically  contaminated  with  pesticides  residues.  Available 
from: http://www.pan-europe.info/Media/PR/080326.html. 

11 

 
 
                                                 
are  considered  a  tool  to  protect  the  level  playing  field  in  the  public  debate  and  the  policy 
development  between  environmental  NGOs  and  sector-federations  or  other  organisations 
funded  by  industry.  However  only  31%  of  the  NGOs  in  the  Mid-term  evaluation  thought  a 
level  playing  field  is  effectively  being  reached  with  the  actual  operational  funding.  NGOs 
receive on average around €9 million per year in operating grants.    

Finally,  the  participative  nature  of  LIFE  projects  which  brings  together  public  and  private 
organisations has improved effectiveness. 

(3) 

The flexibility of the Programme and management mode 

Stakeholders  appreciate  the  fact  that  LIFE  is  close  to  local  and  regional  realities  and  needs 
allowing for flexibility to develop ideas and approaches adapted to the particular context. The 
management of the Programme was considered by different evaluations and stakeholders as 
one of the elements of success of the Programme. 

(4) 

LIFE  is  the  most  adapted  EU  funding  instrument  in  the  environmental  sector  as 
reflected by a continuously increasing demand and thus is particularly successful in 
mobilising national and private sector funds for the environment 

Demand for LIFE action grants is continuously growing, and with it, its capacity to mobilise 
both  private  sector  and  national  funds.  The  overall  level  of  applications  and  co-financing 
requested  is  oversubscribed  for  all  strands.  For  example,  for  2010  call  for  proposals,  748 
proposals were submitted requesting €884 milli on co-financing while only €244 million were 
available. Total investment would have implied around €1.8 billion (the refore around 53% of 
the total investment would have come from national and private funds). As a consequence of 
the limited funds available under LIFE, out of the 250 projects that were eligible for funding, 
only 148 (i.e., a selection rate of approx. 1 project out of 3) could be funded representing a 
total investment of €530 million. The 2011 call  for proposals confirm this trend (around 1078 
proposals  have  been  received).  This  data  provides  evidence  of  the  capacity  of  LIFE+  to 
mobilise funds even during this time of crisis and even when the co-financing rate remains at 
50%.17 No risk of crowding out is foreseen, especially since the increase in LIFE funding is 
inferior to current and expected demand. 

Since LIFE action grant funding covers up to 50% of the eligible project costs (up to 75% for 
Nature  projects  targeting  priority  species  and/or  habitats),  matching  funds  are  brought  by 
project  beneficiaries  and,  where  relevant, co-financers from the public  or private sectors. In 
some Member States, national funds provide matching funds to LIFE funding as co-financers. 
The  best  example  is  Poland,  which  has  led  to  a  significant  increase  in  the  number  of 
applications to LIFE funding.  

17  

It should be noticed that the increase in proposals is for the three strands. In the nature strand were there 
is the possibility for a co-financing rate of up to 75% for projects targeting priority species, the increase 
is observed for all types of projects.  

12 

 
                                                 
Figure 3: Major beneficiaries in LIFE+ projects per strand (2007-2008) 

3

45

14

4

71

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

12

13

52

36

58

1

8

7

1

11

Nature  and 
Biodiversity

Environment 
Policy and 
Governance

Information and 
Communication

Professional organisations

NGO-foundations

Universities/Research institutions

Enterprises

Public authorities and 
development agencies

Action  grants  in  the  LIFE  NAT  predominately  mobilise  public  sector  funds  (public 
authorities and development agencies represent 71% of lead beneficiaries under LIFE Nature 
&  Biodiversity  component).  Only  4%  of  lead  beneficiaries  were  enterprises.  However,  an 
increasing  tendency  for  the  private  sector  to  be  more  involved  in  nature,  and  especially 
biodiversity,  projects  has  been  observed  in  the  last  calls.  Usually,  the  private  sector 
participates as associated beneficiaries through their organisations (e.g., famers, hunters and 
fishermen associations) or directly.  Information and dissemination activities funded through 
action grants predominantly mobilise public sector and NGO funding.    

Action  grants  in  the  LIFE  Environment  component  have  been  particularly  successful  in 
mobilising  private  funding.  48%  of  beneficiaries  of  LIFE  Environment  projects  are 
enterprises  (mostly  SMEs)  and  professional  organisations  (e.g.,  business  associations  or 
institutions dependant on business). Since the co-financing rate for environmental projects is 
of 50%, this means that a substantial mobilisation of private funds has been possible through 
LIFE Environment. 

NGOs  operating  grants  do  not  aim  at  mobilising  private  sector  funds  but  rather  to 
strengthening  the  participation  of  NGOs  in  the  dialogue  process  in  environmental  policy-
making and its implementation.   

b.  

Problems with the design and functioning of the Programme 

(1) 

Lack of strategic approach and critical mass 

The main criticism of the current instrument is the absence of a strategic approach, which 
means  that  EU  policy  priorities  are  not  fully  reflected.  For  example,  climate  change  was  a 
priority  for  2007-2009  calls,  but  given  the  open  competition,  it  only  obtained  14%  of  LIFE 
budget for action grants. Similarly, compliance promotion, good practice for enforcement, as 
well  as  other  governance-related  aspects  have  not  received  sufficient  attention  under  the 
current system, and individual projects in these areas have not been co-ordinated in a way that 
delivered  high  multiplier  effects.  The  same  applies  to  the  Information  &  Communication 
component,  which  often  finances  very  locally-oriented  dissemination  campaigns  each 
focusing  on  a  different  environmental  or  climate  problem,  thus  limiting  the  impact  of 
behavioural change.  

This is the consequence of the bottom-up approach combined with the broad scope of areas 
for  action,  which  provides  little  opportunity  for  the  Commission  to  stimulate  demand  in 
priority areas. Indeed, even within an individual thematic area, the projects financed are very 

13 

 
 
diverse  limiting  the  ability  to  generate  impacts  beyond  an  individual  project.  Therefore,  the 
ability to make greater use of project results in support of policy needs (the so-called catalytic 
or multiplier effect of the Programme) is underdeveloped.  

Many good projects are financed, but because these are not concentrated on a single issue at 
the same time, their impact is dissipated. The exception is Nature, which does have a critical 
mass, as it focuses on two Directives concentrating 50% of resources on their implementation 
and dissemination of good practices.  

This experience would call inter alia for earmarked resources for other policy priorities, in 
particular  Climate  Action,  and  higher  visibility  for  some  elements  (e.g.  governance)  of  the 
LIFE  Environment  strand.  In  addition,  the  Mid-term  and  ex-ante  evaluations  propose 
establishing  a  strategic  programming  framework  (such  as  2-3  years  rolling  plan)  to  set 
priorities.  

Finally,  the  different  evaluations  call  for  increasing  the  size  of  the  projects  to  ensure  a 
higher impact and more extensive outreach (i.e. more/larger areas of Natura2000 involved and 
significant  capacity  building).  There  are  examples  under  the  current  programming  period 
where  these  large  size  projects  (i.e.,  €10-30  million)  have  been  financed  showing  their 
benefits and increased impacts.18 

Box 3: LIFE and the Iberian lynx (Spain and Portugal) 

The  Iberian  lynx  (lynx  pardinus)  is  the  world’s  most  endangered  feline  species  and  the  most  endangered  carnivorous 
mammal  in  Europe.  The  lynx  is  an  umbrella  species  that  helps  in  the  conservation  of  a  whole  ecosystem  but  only  two 
populations located in Andalucía remain in the world.  

To build on and move beyond the findings of regional projects, the Andalusian government applied for a €25 milion LIFE 
project  (EU contribution  €9.8  million)  to  develop  a  partnership  project  to consolidate and  guarantee the  future of  the lynx 
populations,  principally  by  restoring  rabbit  populations.  The  LIFE  project  allowed  including  other  partners  crucial  to  the 
protection of the lynx. These partners included organisations representing hunters and landowners, as well as environmental 
NGOs and international experts on carnivores conservation.  

The project far exceeded expectations. Not only was it able to prevent further loss of the species in the two areas, but it even 
managed  to  increase  the  populations.  When  LIFE  funding  started,  only  102  specimens  remained  in  the  entire  world. 
Population  has  increased  now  up  to  270  specimens,  it  is  being  reintroduced  in  new  areas  and  further  reintroduction  in 
Portugal and other Spanish regions is expected. Hopes are high to upgrade the conservation status from critically endangered 
to endangered in the next years. A new LIFE project with €34 million (EU contribution €20 million) will aim at achieving 
this ambitious target. 

Following recommendations from the Mid-term evaluation, the Commission has included in 
the Guide for applicants for the 2010-2011 calls for action grants indicative lists of favoured 
focus  areas.  However,  the  LIFE+  Regulation  does  not  allow  for  annual  work  plans  or  for 
limiting the number of priority areas. Therefore, this solution is not sufficient to address the 
problem identified.  

The need for a strategic planning (top-down versus bottom-up) is addressed under Options A. 
Options for the allocation of resources between different priority areas, including earmarking 
are developed under Options C.  

The possibility to increase the size of projects to improve impact and environmental benefits 
and more extensive outreach was addressed by the MFF Communication where a new type 
of projects - "Integrated Projects" - is proposed (see the baseline description in section 4). 

18 

See Annex 7 for further details. 

14 

 
 
                                                 
(2) 

Role and objectives to be better defined for certain strands and territorial scope 

The LIFE Nature strand is clearly focused on implementation and capacity building, whereas 
LIFE  Environment  has  evolved  from  promoting  technological  eco-innovation  to  a  more 
policy oriented instrument demonstrating better ways of implementing EU legislation.  

The  ex-post  evaluation  and  some  stakeholders  felt  the  LIFE  Environment  strand  lacked  a 
clear  profile.  The  mid-term  evaluation  and  the  ex-ante  evaluation  suggest  the  strand  should 
focus  more  on  implementation  and  creating  multipliers  rather  than  promoting  the 
development of new technologies. The strand has to prioritise on addressing those weaknesses 
that most undermine the performance of EU environmental policy, and where it can have an 
effective impact. 

As  to  Biodiversity,  the  mid-term  evaluation  indicated  that  the  focus  on  innovation  was 
inefficient as biodiversity projects tend to work best when applying 'tried and tested' methods 
and  not  'innovative'  approaches.  Both  the  mid-term  and  the  ex-ante  evaluation  call  for  the 
actions to be aligned with LIFE Nature and finance best practices and demonstration projects. 
Also,  LIFE  does  not  sufficiently  focus  on  new  emerging  priorities  from  the  Biodiversity 
Strategy,  such  as  green  infrastructure,  or  exploring  the  use  of  innovative  financing 
mechanisms (i.e., biodiversity banking). 

As to the LIFE Information & Communication strand, the mid-term evaluation criticises its 
current  local  focus.  The  ex-ante  evaluation  argues  for  eliminating  this  strand  and  for 
strengthening  communication  obligations  in  the  projects  themselves  as  well  as  Commission 
dissemination activities instead. 

The  evaluations  also  found  that  constraints  regarding  funding  activities  outside  the  EU 
have  reduced  the  effectiveness  of  the  Programme.  In  some  cases,  for  action  to  be  effective 
within  the  EU,  investment  outside  the  EU  may  be  required,  e.g.  migratory  species, 
international river basins, climate change or marine environment.  

Following recommendations from the Mid-term evaluation, the Commission has substantially 
revised  the  Guide  for  applicants  for  the  2010-2011  calls  for  action  grants  including  more 
examples and flexible approaches.  However, additional clarification effort is needed. 

The  issue  of  the  need  for  a  better  definition  of  LIFE  strands  and  more  flexible  approach  to 
funding activities outside the EU has been addressed by the MFF Communication where a 
clear  shift  towards  implementation,  best  practices  and  demonstration  has  taken  place  for 
Environment and Biodiversity, as reccomended by the different evaluations.  

The  issue  of  LIFE  Information  &  Communication  has  also  been  addressed  by  the  MFF 
Communication  which  has  broadened  the  scope  of  the  component  to  include  also 
Governance aspects and a more targeted approach to information and dissemination activities. 
More specific aspects related to Governance and Information are developed under Options E. 

(3) 

Need to improve complementarity and synergies with other EU funds 

The evaluations show that sustainability of project results and replicabilty also depends inter 
alia on securing recurrent funding after project completion. The most successful projects are 
those  that  prepare  the  ground  for  continued  management  through  other  Funds,  such  as  the 
EAFRD, or that are combined with other Funds, such as the Cohesion Fund, or can be scaled-
up  with  Structural  Funds.  However,  challenges  remain  to  ensure  more  synergistic  and 
complementary use of Funds. 

15 

 
The evaluations suggest that LIFE+ could be used to enhance uptake by adopting a more pro-
active attitude towards complementarity with other programmes and by effectively promoting 
the integrated use of different EU funds at EU, national, regional and local level.  

Box 4: An example of combined funding - Protection and usage of aapa mires with a rich avifauna 

The  aim  of  this  project  was  to  prepare  conservation  and  management  plans  for  five  areas  within  the  central  Lapland  aapa 
mire zone, so that ecotourism and recreational use can be organised on a sustainable basis. The project combined resources 
from different EU sources (LIFE for planning and ERDF for construction of the tourism infrastructure) and national funds 
(for construction of barns on the hay meadows). The funds were managed efficiently. 

The project manager of this LIFE project noted the following: 

• 

• 

• 

It  was  not  difficult  to  align  the  project  to  the  different  objectives  of  different  funding  sources  as  the 
various project objectives were clear.  

The use of various funding sources provided the opportunity to make environmental objectives more ambitious. 
The beneficiary also stated that Integrated Projects can create positive publicity and enhance the status of Natura 
2000. 

The combination of funds has not resulted in significant additional administrative costs. If the project objectives 
are mutually supportive, the overall benefit is greater than any additional costs. 

By  combining  funds,  the projects can  implement measures  that  LIFE would  have  been  unable  to  support,  such as  service 
structures.  Implementation  of the  service  structure  in  Lapland  has  increased  interest  in  Natura  2000  areas  and  brought 
positive publicity to the project and to the LIFE Programme more generally.  

Another  area  for  complementarity  is  enhancing  LIFE’s  role  as  provider  of  new  approaches 
that can be mainstreamed into national solutions and other EU funded programmes. 

On the other hand, there are some overlaps with other EU funds, which may cause confusion 
– in particular, for eco-innovation. The mid-term evaluation identified overlaps with the Eco-
innovation  section  of  the  Competitiveness  and  Innovation  Programme  (CIP)  and  potential 
overlaps  with  the  FP7.  Between  15-25%  of  projects  funded  under  LIFE+  as  eco-innovation 
projects  could  have  been  financed  by  other  EU  instruments,  mostly  market-replication 
projects.  

As  to  projects  that  could  have  been  funded  by  Interreg,  these  were  environmental  projects 
involving several Member States and that have significant socio-economic benefits linked to 
tourism.  For  example,  a  project  to  improve  the  conservation  status  of  the  floodplain  bird 
species  that  are  protected  in  the  Natura  2000  sites  SPA  Dunajské  luhy  (Slovakia)  and  SPA 
Szigetkoz  (Hungary).  Projects  that  could  have  been  financed  by  FP7  were  certain 
demonstration  projects  applying  new  technologies  where  more  than  3  Member  States  were 
involved, especially in relation to modelling. When such cases are detected, these projects are 
rejected  during  the  evaluation  process.  In  other  cases,  certain  measures  and  activities  are 
removed  from  a  LIFE  project  during  the  revision  process  when  they  are  considered  better 
fitted for other EU funding programmes.  

It is more difficult to single out  a type of project that could have been  financed anyway  by 
national  or  private  funding.  In  the  case  of  projects  managed  by  public  authorities,  these 
tend  to  be  projects  which  are  part  of  a  broader  strategy  and  some  political  commitment  to 
undertake the activities included in the LIFE project already exist (for example, a project to 
adapt electric pylons to avoid birds electrocution). However, the evaluations show that in this 
case the project would have been developed at a later stage (when all necessary funds would 
have  been  available  based  on  the  responsible  authority's  annual  budget)  or  on  smaller  scale 
(instead  of  covering  the  entire  region,  it  would  have  covered  the  most  important  spots), 
therefore  reducing  its  direct  environmental  impacts.    In  the  case  of  projects  managed  by 
private  entities,  it  would  be  projects  that  were  part  of  the  company  strategy  to  improve 
performance. These are the least innovative and demonstrative projects in many cases as the 

16 

 
purposes tend to be to help the company to apply best available techniques. As in the case of 
projects  managed  by  the  responsible  authorities,  in  absence  of  LIFE  funding,  the  company 
would have adopted these technologies or approaches later in time.   

The  issue  of  the  need  to  improve  synergies  and  complementarity  with  other  EU  Funds  and 
avoiding overlaps is addressed by the MFF Communication, firstly through the creation of a 
new  type  of  project,  namely  Integrated  Projects,  secondly  by  foreseing  a  structured 
cooperation between LIFE and the main EU funds within the Common Strategic Framework, 
and  thirdly  by  excluding  market  replication  eco-innovation  from  the  Environment  sub-
programme.  

(4) 

Project results should be better utilised and transfer of know-how improved 

Sharing of best practices for the implementation of EU acquis should be reinforced, especially 
at  EU  level.  The  ex-post  evaluation  showed  that  between  10-20%  of  LIFE  projects  were 
replicated.  At  project  level,  compulsory  networking  is  contributing  to  creating  networks 
around  the  EU  to  learn  from  each  others'  experiences  and  to  prepare  joint  applications. 
However,  stakeholders  and  the  evaluations  highlighted  that  improving  the  replication  and 
transfer of results requires a more pro-active dissemination and knowledge sharing support by 
the Commission.  

Following  the  recommendations  of  the  Court  of  Auditors  and  the  different  evaluations,  the 
Commission  has  reinforced  and  improved  dissemination  activities  in  this  programming 
period. Improvements include publishing more tailored thematic brochures, the organisation 
of thematic conferences to exchange experience and disseminate project results, production of 
thematic  reports  for  policy  uptake,  clustering  of  projects,  compulsory  obligation  for  project 
networking, improving the website and creating a discussion forum for LIFE+ projects. These 
experiences  have  proved  successful.  However,  a  more  systematic  approach  to  knowledge 
sharing  and  results  promotion  is  still  required.  The  ex-ante  evaluation  recommends 
strengthening project obligations, but also supporting specific projects targeting dissemination 
of results, and enhancing NGOs support. 

The  issue  of  the  need  for  a  better  utilisation  of  projects'  results  and  improvement  of  the 
transfer  of  know-how  is  addressed  under  Options  A  (strategic  planning:  top-down  versus 
bottom-up) and especially Options E (Governance and Awareness raising). 

(5) 

Simplify application and selection procedures 

One  of  the  criticisms  of  the  Programme  was  the  long  selection  procedures  which  require 
comitology  with  Parlimentary  scrutiny  and  burdensome  paper  submission,  including 
submission  to  National  Contact  Points.  A  new  set  of  IT  applications  is  currently  being 
developed (eProposal) to ensure a simpler access and a paperless selection and follow-up of 
financed  projects.  This  allows  for  a  reduction  in  the  administrative  burden  and  also  for 
improving  the  quality  of  the  proposals  (clearer  presentation,  automatic  verification  of  the 
correctness of figures etc.). In addition, the introduction of Integrated Projects also calls for a 
reflection  upon  ways  to  further  simplify  selection  procedures.  Following  recommendations 
from  the  Court  of  Auditors  and  the  Mid-term  evaluation,  the  Commission  has  already 
shortened the selection procedure but this is not sufficient to address the problems identified. 

The  issue  of  the  need  for  measures  to  simplify  further,  in  particular  with  regard  to  the 
application  and  selection  procedures,  are  developed  under  Options  F  (simplification).  In 

17 

 
addition,  the  MFF  Communication  already  proposes  moving  towards  larger-size  projects, 
which will also lead to simplifcation benefits.  

(6) 

Distibutional impacts of national allocations 

National allocations are a remnant of the original Commission’s proposal for LIFE+ in 2004 
which  envisaged  a  decentralised  management  system.  Despite  the  final  decision  in  the 
Regulation  to  maintain  central  management  by  the  Commission,  national  allocations 
remained. However, they have not led to a more balanced distribution of projects across the 
EU  (e.g.,  projects  from  Italy,  Spain  and  Germany  receive  most  of  the  funding).19  In  fact, 
national  allocations  may  lead  to  selecting  projects  of  lower  quality,  which  would  have  an 
impact on the effectiveness of the Programme to provide EU added value and had a perverse 
impact  on  smaller  Member  States  (smaller  allocations  do  not  encourage  submission  of 
proposals).  On  the  other  hand,  they  can  be  used  as  a  representation  of  solidarity  sharing 
especially  in  the  area  of  nature  conservation  where  natural  assets  are  unevenly  distributed 
around  the  EU.  The  mid-term  evaluation  and  the  ex-ante  evaluation  suggest  either  not  to 
include national allocations or develop a different system based on different criteria but only 
when such geographical balance serves the purpose of solidarity and effort sharing.  

The Commission is actively working to disseminate good practice to increase success rate in 
Member  States  with 
improved 
communication efforts. These increased efforts include promoting better quality proposals. 

lower  programme  uptake  rate  of  success 

through 

The issue of the geographical distributional impacts is being addressed under Options D.  

Box 5: Other recommendations from the Ex-post and MTE 

Improved  focus  on  results  and  performance,  and  their  measuring:  monitoring  and  evaluation  were  largely  considered  as 
effective and efficient. However, the mid-term evaluation suggested the Programme had been too much focused on outputs 
with specific indicators developed for this, while result indicators underpinning proposed activities have not been developed. 
Guidance to project co-ordinators to advice on indicators would be required. Following recommendations from the Court of 
Auditors and the Mid-term evaluation, the Commission has improved the mechanisms for carrying out more systematic ex-
post visits to assess sustainability of project results. 

Co-financing rates: the mid-term evaluation indicated that the success of the Biodiversity, and Information & Communication 
strand  could  be  improved  by  increasing  the  intervention  rate.  These  are  new  sectors  for  which  no  or  very  few  alternative 
funding opportunities exist. 65% of YVIE respondents thought current co-financing rate was too low. Also, during the first 
moments  of  the  financial  crisis,  concerns  were  raised  about  the  difficulties  for  the  private  sector  to  mobilise  additional 
funding. 

However,  the  continuous  increase  in  the  submission  rate  for  2009,  2010  and  2011  calls  for  proposals,  with  beneficiaries 
requesting  in  many  cases  less  than  the  maximum  co-financing  rate  available  shows  no  problems  in  mobilising  funds.  For 
example, Spain and Italy, despite economic problems, continue submitting more proposals than any other Member State and 
mobilising  private  and  public  sector  funds.   In  addition,  in  order  to  ensure  that  beneficiaries  maintain  ownership  of  their 
projects and to reach a high leverage of the LIFE instrument, the co-financing rate is considered balanced. 

2.3. 

How will the problem evolve? 

The  ex-post  evaluation,  the  mid-term  evaluation  and  the  ex-ante  evaluation  all  insist  on  the 
importance  to  improve  the  strategic  focus  of  LIFE  to  increase  the  coherence  of  the 

19  

These  3  Member  States  totalled  €98  million  in  2008,  accounting  for  almost  half  of  the  total  LIFE+ 
budgetary  resources.  Beneficiaries  in  new  Member  States  have  in  general  a  lower  rate  of  success.  A 
study carried out by Arcadis consultants identified several underlying causes for differentiated rates of 
success: active support to applicants by national authorities or access to matching funds. In old Member 
States,  low  success  rates  are  mainly  related  to  the  number  of  applications  submitted.  The  higher  the 
number of applications, the higher the probability that more quality proposals are submitted, and thus 
the higher the probability of being funded. However, EU added value partially derives from the quality 
of  the  projects  funded.  Compliance  with  national  allocations  should  not  lead  to  finance  projects  of 
lower quality. 

18 

 
                                                 
Programme  and  its  EU  added  value.  This  would  allow  to  create  critical  mass  and  assess 
Programme  results  and  impacts  in  a  given  environmental  or  climate  area.  If  the  lack  of 
strategic focus and critical mass is not addressed: 

• 

• 

LIFE  would  not  be  able  to  overcome  the  shortcomings  of  the  bottom-up  approach 
and drive demand towards those areas where funding might be most needed or that 
are  in  need  of  more  examples  for  knowledge-base  development  and  sharing.  As  a 
consequence, funds will continue being scattered along the acquis; 

LIFE  would  be  less  suited  to  deal  with emerging  challenges  in  relation  to  EU2020 
objectives  and  targets,  in  particular  in  relation  to  the  implementation  challenge  in 
sectors where a more programmatic and larger-scale approach for funding is required 
and  that  are  approaching  the  most  important  implementation  phase,  such  as  the 
Habitats  Directive,  the  Water  Framework  Directive,  or  are  more  linked  to  meeting 
resources efficiency targets (such as the, water, waste, air and soil legislation).  

The  introduction  of  Integrated  Projects  will  allow  for  increased  geographical  outreach  and 
impact of LIFE projects. However, if no thematic concentration takes place, there is a risk 
that the impact of the Programme will remain diffuse along the acquis.  

If activities to increase the dissemination of project results are not undertaken, projects will 
continue  establishing  networks  and  disseminating  results  but  replication  and  transfer  of 
lessons  learned  will  continue  being  underdeveloped  and  the  Programme  will  underperform 
remaining  in  some  cases  anecdotic.  This  would  undermine  the  EU  added  value  of  the 
Programme  as  a  platform  for  development  and  exchange  of  best  practice  and  knowledge 
sharing;  

If simplification measures are not adopted: 

• 

• 

the workload on both Commission and beneficiaries' side will continue to increase,  

there  will  be  risks  that  the  number  of  submitted  Integrated  Project  will  not  be 
sufficient  to  achieve  targets  because  the  complexity  of  current  selection  (e.g., 
extremely detailed analytical budget and technical forms) is not fit for larger projects. 

If national allocations are maintained as under the LIFE+ Programme, it risks concentrating 
funds  again  in  few  Member  States  while  small  Member  States  might  be  underrepresented. 
This might be a problem for the success of Integrated Projects since the Programme will not 
have enough examples from different administrative types, Member States sizes or different 
environmental/climate challenges. 

The  situation  for  2014-2020  is  expected  to  improve  compared  to  the  current  programming 
period in that earmarked resources and a stronger focus on climate action should increase 
the expected success rate in line with the earmarking applicable under LIFE+ for the current 
Nature  strand.  However,  nothing  has  been  foreseen  for  other  areas,  where  such  earmarking 
traditionally exists, i.e., Nature and Biodiversity. If no earmark resources are ensured, the risk 
of more limited uptake as compared to current situation will increase and it may undermine 
the success of the strand.   

19 

 
2.4.  Who is affected and how? 

All  Member  States'  authorities  and  public  bodies  (at  national,  regional  and  local  level),  the 
private sector (including SMEs), NGOs and other non-profit organisations, and civil society 
groups are affected by the problems and underlying causes identified.  

Most of the capacity needs are located in the EU convergence regions and in particular in the 
Member  States  that  most  recently  joined  the  EU.  However,  it  should  be  noted  that  some 
regions have additional pressures due to the presence of specific environmental assets (high 
value  biodiversity  areas)  or  cross-border  and  transboundary  problems.  These  will  also  be 
particularly  affected.  Similarly  private  stakeholders  in  sectors  that  enter  a  crucial 
implementation  phase  or  where  compliance  costs  are  higher  would  also  be  particularly 
affected.  

Vulnerability to climate change varies widely across regions and sectors in Europe. Economic 
sectors  that  are  sensitive  to  climatic  changes  in  terms  of,  for  example,  temperature, 
precipitation,  storms,  vector  borne  diseases,  etc.  are  at  risk  of  significant  climate  change 
impacts and will require substantial investments in adaptation measures. 

Extreme  weather  events  such  as  heat  waves  and  floods  pose  a  direct  risk  to  the  health  and 
safety of people. Climate change is happening so fast that many plant and animal species will 
struggle to cope. Warming of 1.5º C-2.5º C beyond today's levels would put as many as 20-
30% of plant and animal species at increased risk of extinction. 

2.5. 

The EU's right to act and justification  

2.5.1.  The EU's right to act on environment and climate policies 

The European Union’s environmental objectives are enshrined in Title XX of the Treaty on 
the  Functioning  of  the  European  Union  (TFEU).  The  most  common  legal  basis  for 
environmental  and  climate  legislation  is  Article  192  of  the  TFEU  which  empowers  the 
European Parliament and the Council to decide what action should be taken by the Union in 
order to achieve the environmental objectives which are set out in Article 191 of TFEU. The 
Lisbon Treaty in particular strengthened the emphasis on climate action by making combating 
climate change an explicit part of the environmental objectives. 

Article 11 of the TFEU20 sets out the integration principle which seeks to apply environmental 
considerations  across  all  policy  areas.  The  aim  is  to  avoid  otherwise  contradictory  policy 
objectives that result from a failure to take into account environmental protection or resource 
conservation goals. 

2.5.2.  Necessity of EU action 

Most  environmental  problems  have  a  transboundary  or  transnational  nature  and  cannot  be 
adequately solved by Member States alone without international cooperation. EU intervention 
is required to establish adequate mechanisms for dealing with these environmental problems 
and avoid coordination failures. 

Furthermore,  environmental  assets  often  have  a  public  good  nature  (environment,  climate) 
and  are  unevenly  distributed  across  the  EU.  The  obligation  to  preserve  them  calls  for  a 
consistent application of the principle of responsibility sharing and solidarity. In this context, 

20 

Formerly Article 6 of the Treaty establishing the European Community 

20 

 
                                                 
Article 8 of the Habitats Directive explicitly links the delivery of conservation measures to the 
provision of EU co-financing.  

2.5.3.  EU added value of EU action of a specific financial instrument for Environment and 

Climate Action  

See Annex 6 for examples regarding the different manifestation of the EU added value of a 
specific instrument for the Environment and Climate Action. 

"The  EU  budget  should  add  European  added  value  by  maximising  the  effectiveness  and 
efficiencies with which all public expenditures in the EU support the achievement of common 
EU goals and not simply to add a (thin) layer of expenditures on top of those already financed 
directly by Member States."21 

The EU added value of a specific instrument for the environment and climate derives from the 
specificity  of  its  approach  and  focus  on  these  sectors,  which  makes  it  especially  adapted  to 
interventions  on  environment  and  climate  as  the  only  instrument  with  funds  earmarked  for 
environmental protection and climate action.  

• 

• 

• 

• 

• 

• 

21 

By  being  the  EU  platform  for  exchange  of  practice  and  knowledge-sharing  for 
implementing EU legislation and policy, LIFE allows actors across the EU to learn 
from  each  other's  experience  in  addressing  specific  environmental  and  climate 
problems  more  effectively  and  efficiently.  LIFE  attracts  partnerships  that  would 
otherwise be difficult to set-up ensuring a more effective intervention than Member 
States' individual action by an increased pooling of resources and expertise;  

By  assisting  Member  States  that  host  the  most  valuable  EU  natural  capital  or  are 
confronted with transboundary or transnational environmental and climate problems, 
LIFE allows for a better distribution of responsibility and solidarity in preserving 
the EU environmental common good; 

LIFE acts as a catalyst to start-up action, providing one-off investment needed in a 
specific  area,  eliminating 
implementation  of  EU 
environmental and climate policy and testing new approaches for future scaling-up;  

initial  barriers 

the 

to 

LIFE  addresses  gaps  and  externalities,  raises  awareness  and  demonstrates  the 
benefits  of  environmental  and  climate  protection  ensuring  the  sustainability  and 
expansion of project results; 

LIFE  helps  Member  States  and  stakeholders  to  accelerate  and  improve  the 
implementaton  of  EU  legislation  by  creating  synergies  across  EU  funds  and 
national funds while levering additional public and private sector sources; 

Increased  coherence  of  the  EU  intervention:  A  dedicated  Environmental  and 
Climate  Action  instrument  allows  the  Commission  to  better  shape  priorities  and 
ensure that resources are effectively used for environmental and climate protection, 
selecting the best projects across the EU. More homogenous implementation of EU 
legislation  is  achieved  thanks  to  the  dissemination  of  best  practices  (e.g., 
methodologies  that  have  been  developed  and  now  are  widely  applied,  management 
plans etc); 

SEC(2011)867 final- Commission Staff Working Paper "The EU added value of the EU budget", p.54. 

21 

 
                                                 
• 

• 

• 

Gap filler and more effective central intervention: A specific instrument is more 
flexible  and  finances  projects  that  could  not  be  otherwise  financed  by  other  funds 
(e.g., projects managed by beneficiaries that are non eligible under other funds);  

A  specific  instrument  would  provide  high  visibility  to  EU  environmental  and 
climate action bringing the EU closer to its citizens, showing the EU's commitment 
to  environmental  and  climate  objectives  and  thus  making  those  objectives  more 
relevant; 

Bringing  solutions  to  upcoming  environmental  and  climate  challenges  of  EU 
interest: Stakeholders are often confronted with environmental problems for which 
no solutions have been found yet, and which, if not addressed at an early stage, will 
lead to higher costs.  

2.5.4.  Proportionality of the EU action 

Achieving  critical  mass:  the  calculation  of  the  different  options  has  been  based  on  an 
assessment of resources required to achieve critical mass for proposed objectives (especially 
regarding  Integrated  Projects,  the  development  of  multipliers,  and  dissemination  of 
information/knowledge base). This analysis will be developed more in detail in section 5.  

Risk  of  overlapping  with  national  action:  the  ex-ante  evaluation  concluded  that  national 
funding  is  generally  inadequate  and  there  is  lack  of  resources  to  compensate  for  the  heavy 
reliance  on  EU  fuding  instruments.  For  example,  only  5%  of  projects  funded  under  LIFE 
could have been carried out only with the national support but later in time and on a smaller 
scale. Similarly, there is no or little alternative national funding for information campaigns or 
European wide NGO activity.  

3. 

OBJECTIVES 

3.1. 

Objectives related to the content of the LIFE Programme 

LIFE’s overall objective is to catalyse and leverage changes in environmental and climate 
policy  development  and  implementation  by  providing  solutions  to  achieve  the  specific 
objectives. In doing so, it should contribute to the implementation, updating and development 
of  EU  environmental  and  climate  policy  and  legislation  including  the  integration  of  these 
concerns  into  other  policies.  The  specific  and  operational  objectives  as  well  as  expected 
results are included in Annex 10.  

The potential beneficiaries of the LIFE Programme will be all Member States' authorities and 
public bodies at national, regional and local levels, the private sector, including SMEs, NGO's 
and other non-for-profit organisations and civil society groups.  

3.2. 

Objectives related to the design of the Programme  

The analysis of LIFE Programme included under section 2 has led to the definition of specific 
objectives for the design of the new instrument.  

Specific Objective  

Specific problem 

1.  Ensure  a  better  alignment  with  EU  policy 
priorities, including climate action 

Lack of strategic focus and planning 
Need for a better definition of role and objectives for the strand.  
Lack of critical mass 

22 

 
Specific Objective  

Specific problem 

2.  Promote  the  funding  of  integrated  projects  and 
their share in LIFE projects funded 

3.  Develop  synergies  and  complementarity  with 
other EU Funds, notably by establishing a structured 
relationship. 

4.  Align  selection  criteria  with  EU  added  value  and 
solidarity/effort sharing 

Need to improve dissemination of knowledge 

Lack of strategic focus 
Lack of critical mass 
Challenges in ensuring complementarity and building synergies with 
other EU Funds 

Challenges in ensuring complementarity and building synergies with 
other EU Funds. 
Need  to  better  define  role  and  objectives  of  the  strands  to  avoid 
possible overlaps with other EU Funds 

Avoid distributional allocation problems created by current national 
allocation system including lack of flexibility 
Simplify selection 
Predominantly Brussels-based well known NGOs funded.  

5. Simplify and streamline the LIFE Programme 

Administrative burden created by long selection process.  

3.3. 

Consistency with existing EU policies and strategies such as Europe 2020 

As shown above, the ex-post evaluation, the mid-term evaluation and the ex-ante evaluation 
concluded  that  only  a  very  small  proportion  of  projects  could  have  been  financed  by  other 
Funds  (mainly  by  the  CIP  and  the  FP7)  in  the  absence  of  LIFE.  For  LIFE  Information  & 
Communication, alternative sources for funding are almost non-existent. 

LIFE  is  also  very  much  linked  to  other  EU  funds,  such  as  Cohesion  policy  Funds  (ESF, 
ERDF,  CF),  the  Rural  Development  Fund  (EAFRD)  and  the  European  Maritime  and 
Fisheries Funds (EMFF). LIFE complements these Funds, since it finances specific types of 
activities  and  measures  that  cannot  be  financed  under  them  but  are  required  to  implement 
environmental  legislation.  Thus,  LIFE  works  as  a  gap  filler.  The  complementarity  and 
coherence  of  LIFE  with  other  EU  funding  programmes  have  been  reinforced  in  the  MFF 
Communication. In this sense, LIFE may become one of the main EU instruments to finance 
nature  conservation  (in  areas  where  CAP  cannot  play  a  substantial  role)  and  environmental 
sectors in "more developed" given that these regions would have limited choice of priorities 
under the new Cohesion policy instruments.  

• 

• 

Cohesion  policy  Funds  (ERDF,  ESF  and  Cohesion  Fund)  traditionally  focuses  on 
major  investments  whereas  LIFE  is  more  focused  on  management  approaches, 
environmental restoration (especially for nature and ecosystems) and demonstration 
of  new  solutions  to  environmental  problems  with  no  or  little  market  replication. 
Whereas  under  Cohesion  policy  a  socio-economic  benefit  is  required  for  obtaining 
funding,  in  LIFE  the  focus  is  on  the  environmental  benefit,  making  it  the  only 
funding  available  for  many  purely  restoration  projects.  Furthermore,  the  MFF 
Communication  has  limited  the  choice  of  more  developed  regions  and  transition 
regions  to  few  sectors  (primarily  energy  efficiency  and  renewable  energy).  This 
implies that LIFE may become in many cases the only possibility for these regions to 
carry out environmental projects with EU support.  

CAP  post  2012,  linking  its  objectives  to  EU2020  becomes  greener  by  supporting 
nature  and  biodiversity  through  direct  payments,  30%  of  which  are  proposed  to  be 
conditional  on  three  'greening'  measures  aimed  at  benefitting  the  climate  and 
environment.  The  award  of  all  direct  payments  and  certain  rural  development 
payments  will  continue  to  be  linked  to  the  respect  of  a  number  of  baseline 

23 

 
 
requirements  relating  to  environment,  animal  welfare  and  plant  and  animal  health 
standards (cross-compliance). EAFRD will reinforce its large scope of possibilities to 
finance  the  environment  and  sustainable  management  of  natural  resources  and 
climate  actions  through  a  modified  set  of  rural  development  measures.  Given  the 
shared  management  characteristics  of  CAP  funds,  eligibility  criteria  (e.g., 
beneficiaries, types of measures to be funded) will still vary from Member State to 
Member State. LIFE offers funding opportunities for measures that cannot receive or 
that  complement  CAP  funding.  The  typical  example  is  the  testing  of  agro-
environmental  measures  that  may  at  a  later  stage  be  incorporated  into  national  or 
regional rural development programmes.  

• 

The  situation  is  similar  for  the  European  Maritime  and  Fisheries  Policy,  where 
coordinating mechanisms have been established to ensure that measures (e.g., more 
sustainable  fishing  practices)  tested  will  be  scaled-up  by  EMFP  and  to  address 
environmental problems in the context of Integrated Projects.  

In relation to all these funds, LIFE not only covers identified gaps (territorial, procedural and 
so  on)  but  also  complements  the  new  approach  that  aims  at  establishing  a  structured 
cooperation for all funds available. LIFE will address capacity, including absorption capacity 
needs. It will provide examples on how to ensure the coordination of different EU funds to 
achieve  environmental  and  climate  objectives  using  demonstrative  Integrated  Projects  that 
could be replicated in other regions. LIFE will strengthen its catalytic and leveraging role by 
becoming a driver for mobilising other EU Funds e.g., through Integrated Projects, becoming 
in  the  environmental  field,  a  catalyst  and  “leader”  (or  “lead  fund”)  for  the  other  EU 
instruments.  LIFE  also  provides  examples  that  can  be  scaled-up  by  Cohesion  funding  and 
CAP  funds.  A  more  coherent  approach  with  other  funds  will  be  required.  The  MFF 
Communication  established  a  structured  relation  by  making  a  reference  to  "Integrated 
Projects" in the Common Strategic Framework (CSF).  

LIFE  complements  the  research  cycle  of  the  FP7.  Horizon  2020  has  become  the  major 
instrument for research and innovation covering all aspects of the life cycle from conception 
to  the  market.  Major  parts  of  the  CIP  have  been  incorporated  into  the  instrument.  The  new 
structure  of  the  Fund  mostly  affects  activities  currently  funded  under  LIFE  Environment 
Policy and Governance component. The type of projects financed under this component can 
be summarised as follows:  

Table 2: Type of projects funded under LIFE+ Environment Policy and Governance 

Main purpose of activity  

Type of activity 

A.  Problem definition – 
measuring environmental 
impacts 

Environmental  investigation  /  collecting  data  on  the  extent  of  a  problem  / 
barriers  to  implementation  /  better  ways  of  addressing  environmental 
challenges  

Developing  a  new  approach  /  technique  /process  for  monitoring  of 
environmental impacts within a municipality or sector  

B. Improvements in 
implementing environmental 
policy  

Develop / demonstrate and introduce methods and action plans for reducing 
environmental impacts (approach / management system/ process / plans) to 
reduce  environmental  impact,  informing  policy.  Mainly  at  the  level  of 
municipality. Sometimes with other national / international partners 

Stimulate behaviour change through new market based instruments 

Assistance  in  purchasing  infrastructure  /  capital  costs  that  reduces 
environmental impacts  

24 

 
 
 
 
Set  up  public  private  partnerships  (PPPs)  to  show  more  effective  ways  of 
reducing environmental impacts  

C. Improvements in the 
environmental management of 
economic activities, integrating 
environmental objectives 

Demonstrate good practice / produce instructions / tools / kits/ guidelines to 
industry on how to reduce environmental impacts  

Pro-actively  engaging  with  stakeholders  (industry  involved)  to  change 
behaviour  

D.  Developing particular 
solutions to environmental 
problems and improving 
compliance (eco-innovation) 

Testing and demonstrating / developing a technology / technique / process / 
product that reduces environmental impacts within a municipality or sector 

• 

• 

As shown in Annex 8, most of these activities cannot be funded by other EU funds. 
However  Market-driven  private  sector  innovation  seems  to  some  extent  equally 
well  served  by  Horizon  2020.  For  this  reason,  LIFE  Environment  will  no  longer 
cover  private  sector-oriented  eco-innovation  with  a  market  replication  purpose  and 
both  the  LIFE  Environment  sub-programme  and  the  LIFE  Climate  Action  sub-
programme  will  focus  more  on  policy  implementation  by  public  administrations. 
This implies more investment in type B and C projects, inter alia through Integrated 
Projects. A structured cooperation will be established with the future Horizon 2020 
and  the  future  Competitiveness  and  SME  instrument  to  ensure  adequate  project 
pipelines.  For  example,  ideas  developed  under  Horizon  2020  could  be  tested  and 
demonstrated in the context of implementing specific EU legislation through a LIFE 
project.  

The focus and scale of LIFE is different from the activities to be covered by Horizon 
2020.  LIFE  develops  specific  solutions,  approaches  or  tools  that  are  adapted  to  the 
local  context  or  to  a  specific  sector.  These  projects  do  not  require  large-scale 
investments, or involvement of various Member States, but rather they propose small 
solutions. This does not mean that these activities do not have EU added value. On 
the  contrary,  EU  added  value  derives  from  the  demonstrative  significance  of  the 
project  and  its  capacity  to  be  replicated  elsewhere  within  the  EU  (e.g.,  by  other 
municipality will similar characteristics or problems) or transferred to other sectors.  
For being successful, the EU2020 Strategy also needs knowledge-base development 
and sharing of simple/small solutions that can be widely replicated.  

Connecting  Europe  will  finance  projects  that  have  already  been  identified  in  the  MFF 
Communication (transport, energy and ICT). These projects are of a very large scale and they 
could not be funded through LIFE. Furthermore, the objectives are very different from LIFE 
as they aim to combine market based instruments and EU direct support to facilitate access to 
capital for huge investment needs. 

As  to  External  Action  Instruments,  LIFE  focuses  on  activities  within  the  EU.  Activities 
outside the EU are supposed to be anecdotic and only provided that action outside the EU is 
required to achieve EU environmental and climate objectives or to ensure the effectiveness of 
activities carried out within the EU. The beneficiary of the project has to be based in the EU 
and  the  bulk  of  project  activities  must  be  carried  out  within  the  EU.  Therefore,  no  risk  of 
overlap  has  been  identified,  and  therefore  no  need  for  additional  coordinating  mechanisms 
with external action instruments beyond usual coordinating mechanisms for project selection 
seems required.  

The MFF Communication indicates that the Commission intends to increase the proportion of 
climate  related  expenditure  across  the  EU  budget  to  at  least  20%,  with  contribution  from 

25 

 
different  policies,  subject  to  impact  assessment.  A  sub-programme  for  Climate  Action  has 
been  proposed  in  LIFE+  with  25%  resources  earmarked  and  specific  objectives  related  to 
climate, and accompanied by result indicators. 

4. 

POLICY OPTIONS 

4.1. 

Description of the baseline as defined by the MFF Communication 

The MFF Communication has outlined the main features of the future LIFE Programme. Two 
sub-programmes are proposed with a total financial envelope of €3.2 billion (an around 45% 
increase compared to 2007-2013 programming period).  

The main three changes in the Programme address some of the problems identified in Section 
2.2.b. These changes are: 

•  The creation of a Climate Action sub-programme (€800 million , including procurement) 

with 25% of the Programme's resources and focusing on the following priorities: 

-  Mitigation: Support for the reduction of greenhouse gas emissions. Actions for setting 
up pilot projects, which can be used to test innovative approaches including through 
support to SMEs, to improve the knowledge base and to facilitate the implementation 
of the climate acquis. 

-  Adaptation:  Support  to  efforts  leading  to  increased  resilience  to  climate  change. 
Actions  to  support  the  development  or  implementation  of  national/regional/local 
adaptation strategies. Actions enabling decision makers to effectively use knowledge 
and data about climate change impacts in particular for adaptation related planning. 

-  Governance  and  Awareness:  support  for  efforts  leading  to  increased  awareness, 
communication,  cooperation  and  dissemination  on  climate  mitigation  and  adaptation 
actions. Actions for awareness-raising amongst EU citizens and stakeholders including 
on behaviour changes.  

This change addresses some of the problems identified regarding better focus and critical 
mass (problem 1).  

•  The definition of strands for the Environment sub-programme (€2.4 billion,  including 

procurement):  

-  For  the  LIFE  Biodiversity  strand,  while  still  focusing  on  Natura  2000,  biodiversity 
will  move  away  from  innovation  and  will  focus  on  the  development  and  sharing  of 
best practices;  

-  LIFE  Environment  will  focus  on  supporting 

implementation  of  EU 
environmental policy by the public and private sectors. The Commission proposed in 
the MFF Communication the initiative Horizon 2020 which brings together future EU 
research  and  innovation  funding  programmes.  LIFE  Environment  will  therefore 
exclude those eco-innovation activities that overlap with this initiative (see in section 
3.2 "Consistency with other EU Funds"). 

the 

-  Finally,  LIFE  Governance  becomes  a  single  strand  supporting  the  creation  of 
platforms  for  the  exchange  of  best  practices,  policy  development  and  knowledge-

26 

 
based  decision-making,  support  to  environmental  NGOs,  and  promoting  awareness-
raising, advocacy and dissemination of environmental information. 

This  change  addresses  problem  2  (better  definition  of  strands)  and  recommendations 
from the Ex-post and Mid-term evaluation regarding moving towards implementation. It also 
addresses  problem  3  (improve  complementarity  and  synergies)  by  excluding  identified 
overlaps  with  other  EU  Funds.  In  addition,  the  new  structure  of  the  LIFE  Governance 
component addresses problem 4 and recommendations from Mid-term evaluation and the 
Court of Auditors to better utilise project results and transfer of know-how. 

•  The introduction of Integrated Projects and their progressive increased share compared to 
traditional  projects  over  the  programming  period.  Integrated  Projects  are  designed  to 
demonstrate  the  sustainable  implementation  of  environmental  and  climate  action  plans 
relating to major EU legislation in these fields. The Commission considers that Integrated 
Projects can play an essential role as a catalyst for achieving goals such as the protection 
and restoration of biodiversity and ecosystems, effective management of the Natura 2000 
network,  the promotion of environmental  governance, waste and water management, and 
mitigation and adaptation strategies. Integrated Projects will allow to effectively mobilise 
other  funds  for  environmental  and  climate  ends,  as  availability  of  other  funds  for  co-
financing  of  the  developed  action  plans  would  be  a  pre-condition  for  obtaining  LIFE 
Funds.  This  will  allow  the  development  of  synergies  between  LIFE  and  other  EU  funds 
such as the Cohesion and Structural Funds, funding from the Common Agricultural Policy, 
or Horizon 2020, and also the coordination of environmental and climate expenditure from 
these programmes. Integrated Projects are larger in size: for budget calculations purposes, 
it has been considered that Integrated Projects will require in average €10 million EU co-
financing and will last about 5-6 years.  

This  change  addresses  the  recommendations  of  the  Ex-post  evaluation,  the  Mid-term 
evaluation  and  the  ex-ante  evaluation  to  move  towards  bigger  projects,  thereby  addressing 
problem 1 (critical mass) and problem 5 (simplification). In addition, Integrated Projects 
and  more  structured  cooperation  through  the  Common  Strategic  Framework  addresses 
problem 3 (need to improve complementarity and synergies with other Funds). 

There  is  a  great  potential  for  synergies  between  environmental  and  climate  objectives  as 
projects can benefit multiple purposes e.g., climate activities related to forests may bring co-
benefits for biodiversity and e.g. water projects may  facilitate the transition towards a more 
climate  resilient  society  and  be  linked  to  adaptation.  Similarly,  Integrated  Projects,  by 
covering large territories in sectors such as Natura2000 and water, will deliver positive cross-
benefits  in  terms  of  adaptation  to  climate  change.  For  example,  Integrated  Projects  on  the 
nature sector will help building ecosystem resilience and Integrated Projects focusing on the 
implementation  of  the  Water  Framework  Directive  and  the  Flood  Directive  or  the 
Communication  on  water  scarcity  and  droughts  will  have  clear  benefits  for  adaptation  to 
climate change. 

This Impact assessment and the options below aim to address those aspects not already 
decided by the MFF Communication and focus on options for the implementation of a 
new LIFE Programme. These options, which are presented in section 4.4 and are assessed in 
section 5, are: 

A. Options for strategic planning: top down versus bottom up 

B. Options for thematic concentration of Integrated Projects 

27 

 
C. Options for allocation of resources between different priority areas 

D. Options for geographical distributional impacts (national allocations) 

E. Options for funding activities under Governance and Awareness raising 

F. Options for simplification 

G. Options for externalisation 

Box 6: Options for other operational aspects that have not been discussed 

Making  support  to  a  project  conditional  on  the  level  of  expected  environmental  benefits:  As  shown  in  Section  2,  direct 
environmental  benefit  is  very  difficult  to  quantify  for  certain  activities  under  LIFE.  However,  environmental  benefits  are 
evaluated as part of EU added value and contribution to EU objectives. However, most focus is on demonstration value. 

Selection  of  financing  instruments:  Member  States  and  beneficiaries  expressed  support  for  continuing  with  the  current 
financial instruments and wanted evolution to include also Integrated Projects. During the evaluation and impact assessment, 
the possibility of using innovative financial instruments was analysed and discussed. Member States and beneficiaries were 
reluctant  to  move  towards  innovative  financial  instruments.  Instead,  LIFE  could  focus  on  testing  and  developing  new 
financial instrument (e.g., taxes or biodiversity banking) that if effective could be widely adopted in the EU. For this reason, 
the MFF Communication mostly refers to action grants, operating grants for NGOs and public procurement. Nonetheless, as 
shown in Option A2, if innovative financial instruments under debt and equity work properly for environmental and climate 
purposes,  the  work  programmes  would  allow  diverting  part  of  the  funds  allocated  to  grants  towards  equity  and  debt 
instruments.  

4.2. 

Development of the policy options 

All the different evaluations have highlighted that a major problem of the LIFE Programme 
was  the  lack  of  strategic  focus.  This  is  especially  relevant  for  the  Environment  Policy  and 
Governance, and the Informational & Communication strands. In addition, environmental and 
climate  related  needs  are  evolving  and  the  Programme  should  be  able  to  provide  timely 
answers  to  those  needs:  a  clearer  focus  on  areas  where  LIFE  could  make  a  difference  was 
needed. 

However,  stakeholders  did  not  support  a  limitation  in  the  thematic  areas  covered,  although 
they  did  support  an  increased  focus  on  implementation  and  integration  of  environment  and 
climate objectives into other policies. 

4.3.  Which options have been discarded and why? 

(a) "Zero Option": Discontinuation of the LIFE Programme22 

This  option  implies  the  discontinuation  of  LIFE  with  spending  on  the  environment  and 
climate entirely reliant upon Member States' activities and other EU funding instruments (e.g., 
Cohesion  policy,  Common  Agricultural  policy).  Only  support  for  policy  implementation 
through  public  procurement  would  be  retained.  The  full  assessment  of  the  zero  option, 
including different types of intervention is provided in Annex 8.  

The  MFF  Communication  proposes  major  reforms  in  the  main  EU  funding  instruments. 
However, these changes do not address all drivers for environmental and climate challenges 
outlined in Section 2.1. For this reason, the MFF Communication foresees the continuation of 
the LIFE Programme:  

22 

Detailed assessment of the Zero option is provided in Annex 8. 

28 

 
                                                 
1. 

Institutional  weaknesses,  in  relation  to  capacity  (administrative  capacity  and 
absorption capacity) and integration  

The MFF Communication has laid down the basis for the coordination of all major EU Funds 
to ensure a more effective functioning and achievement of EU objectives. Given the current 
low uptake of funds for environmental and climate objectives (see last Cohesion report), the 
system  could  be  reinforced  with  examples  of  strategic  frameworks  for  environmental  and 
climate intervention. These will demonstrate to regional and national authorities the benefits 
of investing in the environmental sector and how to mobilise resources by coordinating with 
different  responsible  authorities  and  stakeholders,  ensuring 
the  most  cost-effective 
implementation  of  major  environmental  legislation.  It  would  also  demonstrate  that 
complementarity of EU and domestic funds and integration of environment and climate into 
other policies is possible in practice and delivers sustainable results.   

Without  LIFE  and  this  new  feature,  the  problem  of  absorption  capacity  in  the  area  of 
environment  may  continue  despite  the  Common  Strategic  Framework,  and  integration  of 
environmental concerns in practice may fail again.   

2. 

Activities  and  measures  not  covered  by  other  funds  linked  to  implementation, 
innovation and information sharing:  

Each  EU  fund  focus  on  a  series  of  activities  and  measures.  As  shown  in  the  assessment  of 
Zero  option  in  Annex  8,  LIFE  covers  certain  activities  that  are  not  sufficiently  covered  by 
other funds. 

- Specific activities for nature conservation and biodiversity: some two thirds of the estimated 
costs of running the  Natura2000 network relate to  management  activities,  which  are  largely 
ineligible  for  funding  under  other  funds.    It  is  in  these  management  activities  where  most 
needs are concentrated and where best practices and demonstration of new approaches is most 
required.  In  addition,  Natura2000  enters  its  crucial  implementation  phase.  The  challenge  of 
meeting the Biodiversity strategy targets will require the Natura2000 network to move from 
the site-based approach to the network approach requiring a more strategic and programmatic 
approach to funding which is largely dependant of public funds. The absence of these funds 
most probably may lead to failing to achieve N2000 objectives.  

-  Specific  activities  linked  to  environmental  demonstration  activities  and  innovation:  Other 
EU  funds  will  also  cover  major  environmental  funding  needs  but  they  do  not  cover  all  the 
demonstration  activities  that  are  required  to  fight  against  the  drivers  to  environmental 
problems  identified  in  section  2.1,  in  particular  to  focus  on  the  environmental  benefit.  The 
Environmental  activity  least  capable  of  being  funded  by  alternative  instruments  is  the 
preparation of new or revised management plans and capacity building for the improvement 
of  environmental  policies,  as  well  as  the  development  of  new  environmental  policies  and 
solutions.  

LIFE also carries out demonstration solutions and best practice activities with a local/regional 
focus  on  implementation.  Some  solutions  are  often  developed  with  the  sole  purpose  of 
addressing  a  particular  problem  faced  by  a  local  authority,  although  it  may  have  no 
commercial  value.  LIFE  would  have  a  more  important  role  to  play  in  financing  such 
solutions, which will play a significant role in shifting towards a resource-efficient economy. 
These more local activities are also needed, especially to deal with environmental assets that 
are only located in a specific region or country. 

29 

 
- Specific activities linked to knowledge sharing and awareness: This aspect is not covered by 
other instruments where dissemination and awareness raising is not compulsory. There is no 
other alternative EU instrument to fund projects aiming to raise awareness amongst a broad 
set of stakeholders specifically about environmental issues at a local and regional level, or to 
bridge  the  ‘communication  gap’  between  policymakers  at  the  European  level  and  citizens. 
The Mid-term evaluation also found that communications activities were often ranked low as 
a  priority  by  most  Member  States,  suggesting  that  alternatives  for  funding  these  type  of 
activities remain low. 

-  Specific  activities  to  enhance  governance  and  NGO  support  funding:  none  of  the  EU 
funding  instruments  includes  objectives  specifically  aiming  and  enhancing  environmental 
governance at EU level since they mostly have a national or regional focus. Yet, the EU needs 
a  balanced  decision  making  process  where  all  interested  parties  are  able  to  participate.  In 
absence  of  a  specific  EU  funding  programme  aiming  at  empowering  civil  society  for 
participating in the decision making process at EU level, LIFE offers the only possibility to 
fight  against  regulatory  capture  in  the  environmental  field.  Without  funding  from  the 
programme  through  Operating  Grants,  NGOs  would  need  to  substantially  reduce  their 
activities either because they lack the direct means for continuing them or because they lose 
their internal supporting capacity.  

Some NGOs, to avoid any risk  or allegation of non-independence, refuse all subsidies from 
governmental sources and all private sponsoring. Only very large and international renowned 
NGOs  can  afford 
to  membership  contributions  and  own 
merchandising.  

their  resources 

limit 

to 

The removal of operating grants would severely hamper NGOs' ability to contribute to policy 
development  and  implementation,  awareness  raising  and  to  identify  problems  and  potential 
solutions with regards to environmental policy. The absence of NGO activity leads to major 
costs.  Examples  of  such  costs  are  the  risk  of  unbalanced  influence  by  interested  parties, 
reduced  effectiveness  of  policy  through  lack  of  NGO  participation  in  the  process,  and 
increased costs of consultation as further described in Annex 8.   

3. 

Procedural, territorial and thematic gaps not covered by other funds  

Due to shared management characteristics of most Funds, priorities are specified at regional 
and  national  levels  and  are  adapted  to  their  specific  needs  and  characteristics.  This  implies 
that in some cases, e.g., certain stakeholders are not eligible for funding. As shown above in 
section 3.3, the proposal for Cohesion policy may limit the choice of more developed regions 
and transition regions to few sectors (primarily energy efficiency and renewable energy). This 
implies  that  LIFE  may  become  almost  the  only  possibility  for  these  regions  to  carry  out 
environmental investments. This is an important element of solidarity and effort sharing.  

Finally,  there  are  some  environmental  themes  that  tend  to  be  more  neglected  by  other  EU 
Funds. For example, soil, chemicals, noise, IPPC, environment and health among others, are 
sectors  that  do  not  receive  much  focus  under  other  EU  instruments,  except  when  there  are 
clear economic benefits or the focus is on research (e.g., modelling). Although Horizon2020 
will put more emphasis on green chemicals, resource use or climate change, as seen above, 
specific  demonstration  activities  to  improve  environmental  performance  of  these  sectors  or 
the  effective  integration  of  environment  into  the  activities  of  economic  operators  in  these 
particular sectors is not covered by other EU schemes.  

30 

 
The  quantified  environmental  and  socio-economic  benefits  of  the  current  LIFE+ 
Programme have been included in Section 5.1 and are developed in detailed in Annex 8. One 
could assume that the costs of non continuation of LIFE would be at least equivalent to the 
benefits obtained under the current Regulation (i.e., €600 million a year which extrapolated to 
the baseline could represent €750-1,000 million a year).   

It is very difficult to obtain accurate information on the social costs of no action. In particular 
because data on social, especially employment benefits, from the LIFE Programme has been 
very  difficult  to  gather,  since  projects  do  not  traditionally  collect  data  about  employment 
benefits.  For  this  reason,  social  costs  of  no  action  have  only  been  estimated  based  on  the 
social  benefits  of  the  current  LIFE  Programme  summarised  in  section  5.1.  Only  anecdotic 
evidence has been gathered showing the positive employment impacts of LIFE. For example, 
in  the  Extremadura  Region  a  LIFE  project  was  the  catalyst  for  the  creation  of  the  Region 
environmental  department  going  from  10  people  to  200  in  ten  years  and  through  different 
LIFE projects.  

As  to  health  aspects,  these  again  are  estimated  based  on  access  to  clean  water  and  air.  As 
mentioned in section 5.1 indicators of environmental quality have been excluded because of 
the  difficulties  to  monetise  environmental  benefits.  However,  as  shown  in  Annex  7  and  in 
Section  5.1  substantial  health  impacts  affecting  12  million  people  are  expected  under  the 
current  Programme.  Therefore  in  absence  of  the  LIFE  Programme  one  could  assume  that 
these benefits would be lost. However, there are too many assumptions, such as the expected 
impacts derived from Integrated Projects or the potential benefits derived from an increase in 
investments  in  urban  and  energy  efficiency  under  Cohesion  policy  (and  how  this  could 
compensate  for  the  loss  of  LIFE  as  proposed  in  the  MFF  Communication,  especially  in 
relation to Integrated Projects) as to be able to provide a more detailed assessment.  

(b) A separate Instrument for Climate Action 

Reflecting the climate challenge (adaptation and mitigation) in the EU budget is crucial. The 
LIFE+ Regulation has so far served as the legal base for environment expenditure, including 
for  climate  action,  which  represented  some  14%  of  the  LIFE  Programme.  The  Commission 
therefore  considered  whether  a  separate  legal  base  for  Climate  Action  would  be 
appropriate.  There  were  also  discussions  about  creating  large  scale  separate  funds  and 
instruments to deliver EU support in Biodiversity or Resource Efficiency areas.  

These  options  were  discarded  since  they  would  rather  increase  the  EU  administrative  costs 
and increase the administrative burden for recipients. The College has decided upon a single 
legal basis for both Climate and Environment since this approach will exploit synergies and 
co-benefits between the two programmes to the full. 

(c) A Programme with a restricted thematic scope ("Biodiversity and Climate Action Option") 

The  impacts  of  such  an  instrument  would  be  much  lower  than  those  of  the  current  LIFE+, 
thus significantly limiting the Programme's impact on EU environmental policy. This option 
was  discussed  with  stakeholders  and  met  with  strong  opposition.  In  general,  stakeholders 
were opposed to any limitation in the thematic scope of the Programme.  

4.4. 

Description of the options retained for further assessment 

The options described in this section cover all sub-programmes unless it is specifically stated 
differently. The first option always refers to the baseline, i.e. aspects as already decided by 

31 

 
the  Commission  in  its  MFF  Communication.  Stakeholders'  opinions  regarding  different 
options are provided in Section 5.  

A. Options for strategic planning: top down versus bottom up 

As  shown  in  Problem  1  described  in  section  2.2.2(a),  unlike  other  EU  centrally  managed 
funds,  LIFE  does  not  have  an  annual  work  programme  or  any  mechanism  that  allows 
establishing  priorities  and  allocating  resources  among  different  types  of  interventions  to  be 
able to meet specific targets. This makes it impossible for the Programme to drive demand by 
reducing the number of priority themes and activities on which the Programme should focus.  

The MFF Communication emphasises that the Commission intends to increase the financial 
share  of  Integrated  Projects  over  the  life-time  of  the  Programme.  This  requires  the 
Commission  to  stir  up  the  process.  However,  all  stakeholders  (Member  States  authorities, 
private and public sector beneficiaries, and NGOs) were opposed to focus the Programme ex-
ante on only few environmental themes and to setting out annual priorities. For this reason, 
the different options to set priorities discussed below take these concerns into account. 

•  Option A1: Baseline- Bottom up approach 

The MFF Communication does  not specify the method for priority setting and allocation of 
resources. Therefore, it is assumed that the "bottom up" application practice for projects under 
the LIFE+ Programme will continue. Thematic priorities are set for the entire programming 
period, and could be included in the Regulation, as per Annex II of current LIFE+ Regulation; 
therefore the list of eligible policy themes could be decided in cooperation with the Member 
States.  Under  this  option,  an  annual  call  for  proposals  would  continue  including  lists  of 
indicative favoured actions within the twelve priority themes included in the Regulation, but 
without being able to restrict the themes. No limitations regarding the thematic areas in which 
Integrated Projects are to be financed would be done.  

•  Option A2: A top down-approach for all types of projects (with a more flexible top-
down  applied  to  traditional  projects  and  a  rigid  top-down  approach  to  Integrated 
Projects)  

Under  this  option,  the  Commission  develops  multiannual  (2-3  years)  work  plans  where  it 
specifies thematic priorities on which projects are needed linked to the achievement of targets 
defined in relation to the Programme (see expected results and outputs in Annex 10). This will 
allow  the  Commission  to  drive  demand  in  all  type  of  projects  giving  emphasis  to  projects 
matching  the  thematic  priorities.  The  top-down  approach  will  also  apply  to  Integrated 
Projects, which will only focus on a limited number of sectors as defined in the work plans.  

However,  priorities  would  be  non-exhaustive  (proposals  can  be  submitted  in  themes  not 
included  in  the  work  plan)  so  as  not  to  neglect  particular  environmental  sectors  (such 
aschemicals  or  noise)  not  covered  by  any  other  EU  funding  instrument.  This  represents  a 
compromise between the flexibility of the bottom-up approach and the need for more strategic 
focus. It would require as well the alignment of selection criteria, and in particular EU added 
value, with the priorities set in the work programme. Applicants should know that all things 
equal, priority would be given to projects falling under the priorities set in the work plan. This 
non-exclusivity will also allow the programme to react to new challenges that might arise in 
sectors not included in the work plan. 

The  priorities  would  be  reflected  in  the  annual  calls  for  proposals  and  further  specified  or 

32 

 
tailored by the Commission, if required. Given that it would be a rolling plan, the annual calls 
will  be  able  to  make  corrections  regarding  the  priorities  as  per  the  targets.  This  would  also 
allow, for example, for determining whether in one year more resources should be dedicated 
to  specific  activities  within  a  priority  sector.  The  option  of  using  innovative  financial 
instruments should also be kept in order to make use of the potential opportunities from the 
new instruments (equity and debt) envisaged to be set up across the EU. 

The  mid-term  evaluation  proposed  these  plans  to  be  annual.  However,  discussions  with  the 
stakeholders made clear that potential applicants needed some stability in the priority areas for 
action to be able to plan, prepare and submit proposals. For this reason, these priorities will 
remain constant for 2-3 years.  

•  Option  A3:  An  approach  combining  the  top-down  approach  for  Integrated  Projects 

and bottom-up approach for all other types of interventions 

Under  this  option,  the  Commission  will  only  apply  the  top-down  approach  to  Integrated 
Projects by limiting ex-ante their thematic focus to on a number of sectors in the Environment 
sub-programme  until  targets  are  achieved.  The  bottom-up  approach,  i.e.,  demand  open  for 
submitting proposals in any environmental sector, will continue applied to traditional projects. 
No 2-3 years work plans would be elaborated and no priority themes will be identified, beside 
the focus of Integrated Projects.  

B. Options for thematic concentration of Integrated Projects 

Under  the  current  LIFE+  Programme,  few  projects  could  be  considered  as  'Integrated 
Projects'. They are essentially funded under the Nature & Biodiversity strand and concern the 
sustainable management of Natura 2000 areas. 

•  Option B1: Baseline- No thematic concentration of Integrated Projects 

In the MFF Communication, it is considered that Integrated Projects can play an essential role 
as a catalyst for achieving goals in areas such as the protection and restoration of biodiversity 
and  ecosystems,  effective  management  of  the  Natura  2000  network,  the  promotion  of 
environmental governance, waste and water management. There is no sectoral restriction for 
Integrated Projects. 

Under this option, Integrated Projects will be allowed in all areas where such an approach is 
possible.  Since  Integrated  Projects  aim  at  implementing  environmental  and  climate  action 
plans, only those sectors where EU legislation requires some planning or programming (i.e., 
programmed-base Directives) could be considered for Integrated Projects funding. This is the 
case  for  Prioritised  Action  Frameworks  under  the  Habitats  Directive,  a  River  Basin 
Management Plan under the Water Framework Directive, Waste management plans under the 
Waste  Framework  Directive,  Air  pollution  abatement  plan  to  meet  the  air  quality 
requirements  of  the  CAFÉ  legislation  and  the  Programme  of  measures  under  the  Marine 
Strategy Framework Directive.  These sectors are also those that require a planned and large 
territorial scale action and have been identified as suitable for Integrate Projects funding.  

Urban has been embedded into the Air sector and Integrated Coastal Zone Management into 
the  Water  Framework  Directive  (which  covers  transitional  waters)  and  the  Marine  Strategy 
Directive  (which  covers  Coastal  waters).  Integrated  Projects  in  the  Climate  Action  sub-
programme will be allowed both in the areas of mitigation and adaptation and could be used 
for the implementation of national, regional, cross-regional or local adaptation or mitigation 

33 

 
strategies,  national  or  cross-border  action  plans  on  specific  themes  such  as  on  peat  land 
restoration or forest protection (e.g. Restoration of ore mountains). 

•  Option B2: Thematic concentration of Integrated Projects  

Given  the  limited  resources  of  LIFE  and  the  criticism  regarding  lack  of  strategic  focus, 
Integrated  Projects  could  concentrate  on  specific  sectors.  The  criteria  used  for  selecting 
sectors from those mentioned above (i.e., those where an integrated approach is possible) are 
sectors  (1)  where  implementation  and  integration  problems  are  more  significant,  (2)  more 
linked  to  achieving  Europe  2020  resources  efficiency  targets  and  direct  environmental 
benefits (see section 2.2.2(a)); and (3) have more possibility to link to, and therefore mobilise, 
other EU funds.  

Additional criteria could be the maturity of the sector (i.e., the development of these plans and 
programmes is required by the legislation and are largely already in place), or the success of 
the  environmental  sector  in  LIFE  (as  reflected  in  demand  and  success  rate  as  per  data 
provided  in  section  2.2.2(a)).  The  stakeholders'  opinion  could  also  be  used  to  discriminate 
between one or another sector.   

Transboundary and cross-border elements do not play an essential role in defining the priority 
sectors although cross-border cooperation should be promoted where relevant (e.g., water and 
nature).  However,  it  should  not  be  forgotten  that  Natura2000  needs  are  more  regional  and 
what  is  more  important  is  to  obtain  examples  at  the  regional  level  moving  from  the  current 
site-specific approach to the network approach starting at regional level and moving towards a 
pan-regional  and  pan-EU  approach.  The  same  applies  for  waste,  where  needs  are  more 
localised at regional level.  

Applying these criteria, two sub-options could be envisaged:  

o  Sub-option B2a: Thematic concentration on 3 sectors: Natura2000, water, waste; 

o  Sub-option  B2b:  Thematic  concentration  on  4  sectors:  Natura2000,  water,  waste 

and air. 

These sub-options only apply to the Environment Sub-programme. The Climate Action sub-
programme is considered sufficiently concentrated in two sectors.  

C. Options for allocation of resources between different priority areas 

As  seen  in  the  description  of  Problem  1  in  section  2.2.2(b),  earmarking  of  resources  has 
played  a  significant  role  in  providing  a  relative  strategic  focus  to  the  LIFE  Programme  on 
Nature.  The  MFF  Communication  recognises  this  and  has  upgraded  the  strand  “climate 
change”  of  the  LIFE  Environment  Policy  and  Governance  component  into  a  specific  sub-
programme with earmarked resources. Nothing is said about allocation of resources within the 
specific  components  of  the  Environment  sub-programme.  However,  in  the  current  LIFE+ 
Programme, and traditionally in all previous LIFE Programmes, 50% of resources allocated to 
projects  were  earmarked  for  Nature  (and  in  LIFE+  to  Biodiversity  as  well).  Two  options 
could thus be envisaged: 

•  Option C1- Baseline – the MFF Communication allocation 

Allocation  of  resources  would  follow  the  MFF  Communication  with  75%  of  the  budget  for 
the Environment sub-programme and 25% to the Climate Action sub-programme. Under this 

34 

 
option,  no  additional  pre-allocation  of  resources  will  be  carried  out  among  the  various 
components within each sub-programme. 

•  Option  C2:  The  MFF  Communication  allocation  and  50%  allocation  of  the 

Environment Sub-Programme funds to Biodiversity 

This  option  involves  the  pre-allocation  of  resources  for  specific  EU  priorities,  in  particular 
50% for Biodiversity in the Environment sub-programme as has been the case in the previous 
LIFE programmes.  

D. Options for geographical distributional impacts (national allocations) 

Under the current LIFE+ Regulation, indicative annual national allocations are established in 
order  to  ensure  a  proportionate  distribution  of  projects  for  the  period  2007-2010  and  2011-
2013 based on two pre-defined criteria related to population, and nature and biodiversity. As 
seen  in  Problem  6  described  in  section  2.2.2(a)  they  have  not  led  to  a  more  balanced 
geographic distribution of projects.  

Introducing  a  minimum  number  of  countries  that  would  need  to  participate  (as  opposed  to 
simple  geographical  balance)  was  not  considered  as  an  option  retained.  Participation  of  a 
minimum number of countries is generally linked to the concept of EU added value (e.g., see 
the FP7). It was discussed during the ex-post evaluation and rejected because it would imply 
changing  the  focus  of  LIFE,  which  is  local/regional  solutions.  In  addition,  EU  added  value 
under LIFE is more linked to the demonstration value of a project, which does not necessarily 
derive from the participation of several Member States. Furthermore, it would be contrary to 
the  principle  of  responsibility  sharing  and  solidarity,  especially  for  nature  and  biodiversity: 
many nature conservation projects focus on habitats or species of EU interest that are endemic 
to a region, island or Member State. Imposing a minimum number of countries as one of the 
eligibility criteria would undermine the effort sharing and solidarity dimension. Nevertheless, 
EU  added  value  for  NGOs  operating  grants  does  currently  incorporate  the  obligation  to  be 
active in at least 3 Member States. 

•  Option D1: Baseline- All projects selected on merit  

The  MFF  Communication  indicates  that  projects  will  continue  to  be  selected  for  their  EU 
added  value  and  potential  for  transfer  of  know-how.  This  implies  that  all  types  of  projects 
(traditional and Integrated) would be selected according to specific selection criteria similar to 
today,  which  concentrate  on  technical  and  financial  coherence,  and  EU  added  value  (i.e., 
demonstration  and  replication  potential,  innovative  character,  contribution  to  EU  policy 
priorities etc). No geographical key would apply.  

•  Option  D2:  All  projects  selected  on  merit  but  ensuring  geographical  balance  for 

Integrated Projects  

Different selection criteria would apply to traditional and Integrated Projects.  

Traditional projects, which are mostly aimed at developing multipliers, would be selected on 
merit only, as described above in option 1.  

As for Integrated Projects, a system to ensure geographical balance would be established, and 
would be adapted to the relevant sectors where such projects are possible. Integrated Projects 
aim to develop capacity in Member States and to contribute to solidarity and effort sharing. A 

35 

 
prioritisation list could be established ensuring that Member States which have benefited from 
Integrated Projects one year are considered less favourably for the next call for proposals. An 
additional  distributional  element  for  Natura2000  Integrated  Projects  could  be  that  all  bio-
geographical regions are covered.  

•  Option  D3:  Traditional  projects  selected  on  merit  only  and  national  allocations 

(specific amounts per MS) for IP for the whole programming period 

Under this option, traditional projects would be selected on merit only, as per option D1. For 
the  reasons  indicated  under  option  D2,  a  system  of  indicative  national  allocations  for 
Integrated Projects would be established for each Member State and each sector.  

For Natura2000, criteria similar to those used under the current LIFE+ Regulation (population 
and % of the territory declared Natura2000) could be used. For water and waste, population 
could still be used as criteria and other specific criteria could be established. For example, for 
water the criteria could be linked to km2 of river basin district in the territory of a Member 
State.  

These  indicative  allocations  would  be  calculated  and  applied  for  the  entire  programming 
period instead of annually as today to allow more flexibility in the selection procedure. 

E. Options for funding activities under Governance and Awareness raising 

As  shown  in  Problem  4  described  in  section  2.2.2(b),  although  some  improvements  are 
currently  made  for  increased  dissemination  of  information  and  project  results,  these  are  not 
sufficient. The MFF Communication takes an additional step by proposing a combination of 
activities:  

− 

funding NGOs;  

−  enhanced  project  communication/training  activity,  supported  by  programme  level 

synthesis of project results and dissemination. 

The MFF Communication remains ambiguous as to whether these activities include specific 
information  and  communication  projects.  As  shown  in  section  2.2.2(a),  the  success  rate  of 
information projects has been low compared to other components. 

•  Option  E1:  NGO 

funding,  Commission 

communication 

activities 

and 

communication/dissemination obligations for projects  

Funding  to  support  the  operation  of  European  environmental  NGOs:  NGOs  make  a 
necessary contribution to good governance by participating in policy development, including 
by  knowledge-based  input,  contributing  to  better  implementation,  raising  awareness  and 
acting  as  channels  between  citizens  and  decision  makers.  Continued  support  to  NGOs  is 
included in the MFF Communication. A future Programme will seek to address the functional 
weaknesses identified in the review process. 

Enhancing  project  communication  activity:  Adopting  a  stronger  strategic  approach, 
including the generation of multiplier effects, will also be translated into greater responsibility 
on  project  co-ordinators  for  identifying  and  communicating  findings  with  target  users  and, 
when necessary, providing training to relevant stakeholders.  At the same time, networks of 
similar projects around priority themes will be promoted.  

36 

 
•  Option  E2:  NGO 

and 
communication/dissemination  obligations  for  projects,  and  specific  Communication 
campaigns financed through grants  

funding,  Commission 

communication 

activities 

Under  this  option,  in  addition  to  the  activities  mentioned  above,  specific  projects  funded 
through action grants (similar as under the current Information and Communication strand) 
will  be  possible  to  support  selective  activities  defined  by  the  policy  units  where  awareness 
raising,  information  sharing  or  governance-related  aspects  are  key  issues  for  a  particular 
policy.  These  information  projects  could  also  be  initiated  to  take  on  the  synthesis  and 
dissemination  activity  of  results  from  the  ‘traditional’  projects  under  selected  themes  and 
promote  the  dissemination  of  knowledge  base.  Projects  will  also  aim  at  developing  and 
deploying  adequate  tools  for  information-handling  and  active  dissemination  and  for 
preparation of training and provision of toolkits for stakeholders. Finally, these projects would 
also focus on best practices on enforcement and compliance implementation plans. 

F. Options for simplification 

As seen in Problem 5, the Commission has already undertaken different measures to simplify 
the selection procedure for projects. However additional simplification measures are required 
to reduce the administrative burden for applicants and beneficiaries, as well as management 
costs for the Commission (these are dealt with below under Section G). While simplification 
of  procedures  is  generally  recognised  as  necessary,  this  can  be  reached  through  different 
measures. These are presented as different options but they do not exclude each other. Rather, 
they can be combined to increase effectiveness gains.  

•  Option F1: Baseline- On-line tools and larger projects 

On-line  tools:  The  MFF  Communication  does  not  refer  to  any  specific  “tools”  for  the 
simplification  of  the  LIFE  Programme.  However,  as  mentioned  in  section  2.2.2(b),  in  the 
current programming period, a new IT tool called eProposal has been developed and could be 
used from 2012 onwards. Applicants will be able to submit their application online and thus 
costs of paper submission and the previous step of submission to the Member States will be 
avoided. The system will allow identification of errors during the submission process, thereby 
reducing the number of applications excluded in the first phase of selection. It will also allow 
calculating  and  aggregating  relevant  data  submitted  with  the  proposal,  thereby  improving 
monitoring of project results.  

Moving to larger projects: The MFF Communication includes as a simplification measure the 
progressive phasing in of large projects, in particular Integrated Projects. It is expected that, 
by the end of the Programming period, two-thirds of resources within the Environment sub-
programme will be allocated to Integrated Projects largely decreasing the number of projects 
managed (from 230 projects selected annually to 115 in average going below 100 projects by 
the end of the programming period). This will reduce management costs for the Commission 
(see below options G). In addition, applicants that would submit several smaller projects as 
different  implementation  phases  will  now  be  able  to  submit  only  one  proposal  which  is 
expected to decrease submission costs over time. 

•  Option  F2.  Baseline  +  New  selection  procedures:  2  stage  procedure  and  simplified 

reporting for Integrated Projects, multi-annual selection for NGOs 

2-step  selection  procedure  and  reduction  of  reports  for  Integrated  Projects:  Under  this 
system,  there  will  be  only  one  call  for  proposals  for  all  strands  and  types  of  projects  (e.g., 

37 

 
organised  in  lots).  Given  the  characteristics  of  Integrated  Projects,  one  option  for 
simplification is to introduce a 2-step approach for the selection. The proposal for Integrated 
Projects would consist of a short concept paper (such as maximum 20 pages compared to the 
100-200 pages for traditional projects) submitted together with the environmental action plan 
that it is supposed to be implemented through the project. In the concept paper, the applicant 
outlines  the  measures  of  the  environmental  action  plan  to  be  financed  by  LIFE  Integrated 
Project,  with  milestones  for  the  implementation  phases,  and  a  global  estimated  budget  per 
cost category for the whole project duration. At the same time, the applicant would submit the 
underlying  financial  plan,  establishing  the  general  framework  for  intervention  by  different 
funding  instruments.  Only  if  the  concept  paper  is  deemed  sound,  would  the  applicant  be 
invited  to  submit  a  more  detailed  proposal  and  more  analytical  budget  covering  the  first  2 
years  of  implementation  within  the  overall  budget  frame.  Notice  that  the  average  life  of 
traditional projects is 4 years; the proposal for Integrated Projects will only cover in detail 2 
years  and  therefore  it  is  expected  to  be  relatively  simpler  than  a  proposal  for  a  traditional 
project.  

Reporting  and  re-programming  will  be  based  on  a  two  years  cycle.  Six  months  before  the 
end of the first phase, a report will be sent to the Commission together with a new detailed 
plan  and  budget  for  the  next  phase  for  agreement  with  the  Commission.  This  cycle  will  be 
repeated until the end of the project. The payment schedule will also be adapted to follow the 
periodic planning to ensure a constant cash flow to the project. The coordinating beneficiary 
will have a large margin of freedom in adapting its project. Only critical changes should be 
subject to the prior Commission approval.  

Multiannual selections for NGO operating grants: There seems to be general support for a 
change to multi-annual framework partnerships instead of annual grants.    

•  Option  F3:  Baseline  +  Outputs  and  results  payments  vs.  lump-sums,  ineligibility  of 

certain costs 

Under this option, more use of lump sums would be done. The clearest example is application 
of  standard  EU  per-diems  for  travel  costs,  and  standard  staff  costs  (per  staff  category) 
provided there is an agreement at Commission level of what the standard staff cost should be.  

An  option  of  payment  based  on  outputs  could  be  examined.  In  fact,  LIFE  already  has 
developed output indicators and the activities to be funded are constructed around Programme 
outputs. Under this option, payments would be linked to the specific outputs.  

Result-based  payment  schemes  were  considered  in  early  stages  of  the  process  and  not 
adopted because of the risks associated to the nature conservation projects (nature is indeed 
unpredictable)  and  information  campaigns.  The  experience  of  e.g.,  DG  EMPL  with  the 
European  Social  Fund  could  be  closely  followed  to  identify  areas  in  the  future  where  such 
payment scheme could be adopted. If successful, these could be incorporated in the mid-term 
review of the Regulation.   

Ineligibility of certain costs: In order to reduce the administrative burden linked to the 'real 
costs'  management  of  grants,  both  on  the  side  of  the  Commission  and  of  the  beneficiaries, 
eligibility of costs for which accurate reporting and monitoring are difficult, such as personnel 
costs or VAT, could be restricted. 

G. Options for externalisation  

This section analyses the different management options for the LIFE Programme taking into 
account  the  conditions  laid  down  in  the  MFF  Communication  (baseline).  In  this 

38 

 
Communication,  the  Commission  announced  that  the  LIFE  Programme  should  remain 
centrally  managed,  but  that  management  tasks  could  be  largely  delegated  to  an  Executive 
Agency. The extent, conditions and terms of the delegations will have to take into account the 
need of the Commission to maintain strong policy links as regard Integrated Projects. These, 
as the simplification measures mentioned under Option F, also aim at reducing management 
costs of the Programme (currently at 6%). 

Whilst some aspects of this delegation were fixed in the MFF Communication – in particular, 
that  it  should  be  an  existing  Executive  Agency  -  other  details  on  the  extent,  conditions  and 
terms of the delegation were left open and are dealt with in this Impact Assessment, especially 
how to ensure strong policy links as regard Integrated Projects. Options are described below. 

•  Option G1: Baseline-  Externalisation 

Under this option, most of the management tasks carried out by the Commission in relation to 
selection  and  monitoring  of  LIFE  projects  and  NGOs  operating  funding,  as  well  as 
communication/dissemination  activities  (including  gathering  and  disseminating  lessons 
learned  to  stakeholders)  will  be  transferred  to  an  existing  agency,  for  both  traditional  and 
Integrated  Projects.  The  governance,  supervision  and  evaluation  of  the  Programme  would 
remain within the Commission.  

The  Commission  is  currently  assisted  by  teams  of  external  sub-contractors  that  provide 
support in selection, technical monitoring, and communication and information workshops at 
national level. Two sub-options are therefore possible:  

o  Sub-option G.1.a. Externalisation without replacing technical assistance 

Only  the  management  tasks  directly  carried  out  by  the  Commission  would  be  externalised 
(i.e.,  evaluation  of  mid-term  and  final  reports,  financial  monitoring  and  payments, 
correspondence  with  beneficiary,  visits  to  projects  once  in  their  life  time).  External  sub-
contractors will still be needed to carry out support activities (e.g., technical monitoring, visits 
to  all  projects  every  year,  evaluation  of  progress  reports).  Agency  staff  would  be  able  to 
concentrate  in  extracting  information  from  projects  and  transferring  this  to  the  Commission 
through structured communication channels. 

o  Sub-option G.1.b. Externalisation replacing technical assistance 

In addition to the tasks described above, the Agency staff would replace the tasks currently 
undertaken  by  external  contractors  under  technical  assistance.  This  would  require  a  broad 
range of geographical and thematic expertise, as well as full coverage of the EU languages.  

•  Option  G.2:  Hybrid  solution:  externalisation  of  traditional  projects  and  keeping 

Integrated Projects within the Commission 

Under  this  option,  the  management  of  traditional  projects  and  operating  grants  for  NGOs, 
would  be  externalised  to  an  existing  agency.  Activities  to  remain  within  the  parent  DGs 
would include the governance, supervision and evaluation of the Programme, as above. 

The management of Integrated Projects for environment is retained within the Commission. 
The  main  reasons  are  to  secure  integration  of  project  results  into  EU  policy,  to  ensure 
Integrated  Projects  are  designed  in  the  most  adequate  way  and  developed  under  close 
monitoring, and liaison with Commission thematic units.   

39 

 
5. 

ANALYSIS OF IMPACTS 

5.1. 

Introductory remarks about impacts of the current LIFE+ Regulation and the 
Baseline derived from the MFF Communication 

Methodology and its limits 

The  environmental  benefits  of  the  current  LIFE+  Regulation,  including  climate  have  been 
examined  using  a  series  of  indicators  reflecting  the  nature  of  the  projects,  and  as  far  as 
possible,  consistent  with  the  indicators  used  in  the  ex-post  assessment  of  the  LIFE  III 
Programme.  The  relevant  estimates  of  the  value  of  the  environmental  impacts  have  been 
sourced from the literature. Project beneficiaries were asked about the impacts of the current 
projects at the end of the project, and then five years after the project end. The results were 
grossed-up based on the share of total project investment reported.   

The reported environmental impacts for Nature & Biodiversity have been converted into 
an  estimated  economic  value  using  published  externality  values  for  eco-system  services 
associated with different types of habitat. These are applied to estimates of the environmental 
impacts by habitat type as reported by projects. Given the lack of detailed knowledge of the 
individual projects (e.g. the level of quality of the ecosystems within these projects) and the 
related eco-system benefits, the estimates provided in Table 1.3 of Annex 7 should be taken as 
providing only an approximate estimate of the economic value of the environmental benefits. 
The externality values are based on case studies of the economic value of eco-system services. 
These cases include the impacts of substantial changes in eco-system services. 

Three  habitat  types  are  responsible  for  most  of  the  benefits  calculated  as  they  are  often  the 
main focus of valuation studies: freshwater habitats (accounting for half of the benefits), and 
coastal habitats and forests each accounting for around 20% of benefits. The estimated value 
of benefits takes a conservative approach, assuming the benefits are between 5% and 15% of 
the  published  externality  values  to  provide  an  indicative  estimate  only.  This  indicates  an 
annual benefit of between €400m and €1,200m. It is
 extremely unlikely that the benefits are 
less than this, but likely that benefits in fact exceed this range. On an annual basis, taking the 
low estimate, the benefits represent twice the total investment cost of the projects. Using the 
higher  estimate,  benefits  are  six  times  the  investment  cost.  This  excludes  any  economic  or 
social  impacts  (described  below).  The  benefits  are  also  expected  to  last  for  many  years 
(although management costs will be required). 

The analysis of Environment Policy & Governance (EPG) projects, including climate has 
focused on those projects anticipating physical environmental outcomes. It is difficult without 
knowing the specific details and context of the project to be confident that the application of 
externality values is justified. However, in the case of estimates of reductions in emissions or 
wastes (rather than changes in environmental quality), externalities can be applied with more 
confidence to provide a conservative assessment. This means that indicators of changes in air 
and  water  quality  are  not  included.  Significant  impacts  are  reported  in  terms  of  expected 
reductions in CO2 emissions, the area and people likely to benefit from improved air quality, 
the area of soil erosion prevented, and the reductions in non-hazardous solid waste generation.  

The  economic  value  of  these  environmental  benefits  is  based  on  published  externality 
estimates. The externality values relevant to each indicator are taken from the literature (see 
Annex  12).  It  should  however  be  emphasised  that  the  transfer  of  externality  estimates  does 
lead to some uncertainty, which has been minimised by excluding indicators of environmental 
quality  (as  mentioned  above),  and  has  not  therefore  been  reflected  in  the  calculation  of  a 
range – whilst the benefit estimates should only be taken as being indicative, because of the 
exclusions they can be taken as the minimum or a ‘low’ estimate. On this basis, the economic 

40 

 
value of the environmental benefits provided by Environment projects could be in the order of 
€200 million per year (Table 1.5 of Annex 7). This  represents the minimum level of benefit. 
Substantial economic benefits are also potentially associated with health benefits (improved 
air quality and reduced particulates and improved forest protection). 

For Information & Communication activities, environmental benefits cannot be quantified. 
The  main  aim  of  the  component  has  been  to  actively  promote  EU  environmental  policies 
through information, communication, awareness-raising and dialogue, helping to ‘empower’ 
individuals  and  groups  in  the  European  civil  society,  as  well  as  other  stakeholders  such  as 
industry and local authorities to participate in an informed and active manner in the protection 
of the environment and the sustainable use of resources. The aim is that, by enhancing their 
ownership  of  environmental  policy,  more  effective  implementation  can  be  achieved. 
Furthermore,  most  projects  have  not  been  finalised,  which  means  that  it  is  impossible  to 
evaluate the impact in the targeted population at this stage.  

For  Operating  grants,  as  for  Information  Projects,  environmental  benefits  cannot  be 
quantified. An analysis of the operational funding of NGOs for 2007 and 2008 undertaken in 
the mid-term evaluation showed that a substantial proportion of the budget is used for policy 
development  (27%),  policy  implementation  (28%),  with  external  capacity  building  and  
awareness raising being smaller fields of activity. A large number of NGOs have undertaken a 
broad  range  of  activities  to  contribute  towards  improved  EU  policy  implementation  and 
development. For example, they have: served as hubs for a growing number of national and 
international environmental organisations; defend or increase the ambitions of EU legislation, 
and  campaign  for  real  implementation  of  legislation  or  policy  priorities;  assist  in  increasing 
transparency and public participation; contribute to integration of environmental concerns into 
other policies through the provision of specific expertise; help members better understand EU 
environmental  policies,  and  to  better  mobilise  the  public  and  decision  makers  to  support  a 
progressive  role  for  the  EU  on  environment  and  sustainable  development.    However,  as  a 
result of the indirect influence the NGO activity has on realising environmental benefits, it is 
not possible to quantify specific environmental benefits.  

Environmental and socio-economic impacts of the LIFE+ Regulation 

The environmental impacts under the current LIFE+ Regulation are substantial (see Annex 7 
for  full  assessment).  In  addition  to  the  quantified  benefits  of  some  €600  million  a  year 
(therefore  twice  its  annual  budget),23  which  are  based  on  conservative  estimates,  the 
instrument leads to the improved conservation and restoration of some 4.7 million hectares of 
land, representing some 6% of the total area of the designated Natura 2000 terrestrial sites. It 
also supports a wide range of environmental improvements including improvements in water 
quality  over  an  area  of  approximately  3  million  hectares;  improvements  in  air  quality 
affecting  some  12  million  people;  and  reductions  in  waste  of  some  300,000  tonnes  and  the 
recycling of a further 1 million tonnes; and reduction of 1.13 million tonnes of CO2 per year24.  

23 

24 

Benefits  in  the  nature  strand  double  investment  cost  (€199  million)  and  for  the  environment  strand 
equals  investment  cost  (€223)  but  excluding  significant  environmental  benefits  that  cannot  be 
monetised (because limited literature exists on externalities) such as changes in environmental quality 
for water and air sectors, as well as social and economic benefits, which are substantial. 
These benefits are also expected to last for many years (although management cost will be required in 
some cases. Taking the low estimates of benefits and assuming the benefits will last for 10 years, the 
discounted (at 4%) present value for nature and biodiversity would be €3.2 billion (almost six times the 
total  investment  costs)  and  €1.6  billion  for  environment  (two  and  a  half  times  the  total  investment 
costs). In total, €4.8 billion of benefits ar e estimated for the current LIFE+ Programme.  

41 

 
 
                                                 
Economic  and  Social  Impacts  of  Nature  and  EPG  Projects:  The  economic  and  social 
impacts of the Action Grants, as reported by Nature and EPG projects include: 

• 

• 

• 

• 

a  total  investment  of  some  €600million  is  being  made  in  technology  outcomes  by 
EPG  projects.  In  addition,  Nature  projects  are  investing  €380m  in  new  approaches 
and techniques for nature conservation;  

the  additional  sales  generated  by  the  development  of  new  products  from  EPG 
projects of €2.7 billion, generating around €1.1 billion of GVA 25;  

in 

the 

investment 

impacts  both  from 

substantial  health 
improved  natural 
environments  and  from  improvements  in  environmental  quality,  especially  from 
reductions in air pollution, affecting over 12 million people; 
modest  but  positive  employment  impacts  of  some  2,000  jobs26  associated  with  the 
continuation of project activity post LIFE funding and indirect economic benefits of 
a further 18,000 jobs based on additional sales of new products.27 These impacts are 
particularly  important  given  that  Nature  projects  tend  to  create  and  retain 
employment in areas that are being depopulated and/or have lower relative incomes.  

It  is  difficult  to  quantify  the  impacts  of  the  changes  introduced  by  the  MFF 
Communication.  One  could  as  a  minimum  expect  in  absolute  terms  an  increase  in  the 
environmental and socio-economic impacts proportionate to the increase in budget. Given that 
the  biggest  increase  is  in  Climate  action  activities,  probably  a  most  significant  increase  in 
environmental impacts can be expected on climate mitigation and adaptation.  

As a consequence, one could as a minimum expect environmental benefits between €750 and 
€900/1,000  million  benefits. 28  The  exclusion  of  market-replication  eco-innovation  from  the 
Environmental sub-programme could reduce the overall increase in socio-economic benefits, 
since as shown in section 2.2.2(a) eco-innovation projects bring most environmental benefits. 
However, market replication eco-innovation (which has been excluded from LIFE) represent 
only  between  15-25%  of  the  current  Programme  (and  are  better  carried  out  under  other 
instruments).  

25 

26 

27 

28 

technology sales supports one job (including multiplier effects), based on DG 

GVA accounts for 40% of environmental technology sales, based on DG Environment, 2007, Table 4.4. 
Total sales of eco-industries was estimated to be €319 billion in 2008 (2008 prices), (Ecorys, 2009). 
A recent analysis concluded that the Natura 2000 network could support 122,000 full-time equivalent 
(FTE) jobs in the regions where the sites are located, if adequately resourced and managed. If indirect 
and induced effects are taken into account, this could amount to 207,000 FTE jobs. However, these job 
estimates  must  be  treated  with  some  caution  as  it  is  not  possible  to  control  for  negative  or  positive 
impacts in other sectors (Rayment et al (2009) within Kettunen et al (2011). 
€147k of environmental 
Environment, 2007, Table 4.4. 
Climate change related benefits, as calculated in terms of CO2 emissions, for the current programming 
period  are  around  €135  million  (50%  benefit  compared  to  investment  costs).  Given  that  the  climate 
budget doubles compared to the current Programme, it is expected that the environmental benefits will 
also double, i.e., €270 million. The increase in the environmental side has been more modest (overall 
increase of 8% with a higher increase for the governance and environmental strands). Nature benefits in 
the  current  programming  period  are  around  €400  million  (twice  the  investment  costs)  and  for 
Environment  (discounting  climate  change)  of  around  €58-65  million.  Applying  the  different  increase 
ratio to the specific benefits per strand, and considering a modest increase of the nature part by 5%, the 
minimum  increase  in  benefits  would  be  €750  mill ion.  If  the  calculation  is  based  on  the  ratio 
benefits/investment  costs  applied  to  the  different  increases,  then  the  overall  benefit  would  be  around 
€870-1,045  million.  In  the  current  programming  period,  the  environmental  benefits  are  around  €600 
million  (twice  the  annual  budget).  The  new  budget  represents  an  overall  increase  of  around  50%. 
Applying the ratio benefits/budget to the programme, the environmental benefits will be €900 million.  

42 

 
                                                 
This  calculation  does  not  take  into  account  the  larger  impact  expected  from  Integrated 
Projects29 given the difficulties in monetising those benefits. However, based on the results of 
the  ex-post  evaluation  (that  called  for  larger  size  projects)  and  contacts  with  stakeholders, 
these benefits would be: 

• 

• 

• 

• 

• 

environmental  priorities  become  embedded  into  all  the  project  activities  as  a 
requirement; 
cost savings because of the larger size and effectiveness of the projects30; 

as  a  result  of  their  scale,  Integrated  Projects  provide  a  greater  ability  to  create 
employment opportunities linked to continuing environmental management;  

because of their scale, Integrated Projects can establish a structured relationship with 
and  develop  project  pipelines  for  the  main  EU  funds,  thereby  promoting  the 
mobilisation of their much larger resources to support environmental objectives; 

Integrated Projects provide a major role for regional and local authorities as potential 
lead  beneficiaries,  which  are  also  often  the  environmental  and  climate  responsible 
authorities  (e.g.,  for  Natura  2000  Prioritised  Action  Framework)  as  well  as  being 
responsible  for  leading  projects  funded  by  Rural  Development,  the  Operational 
Programmes for Structural Funds.31 

5.2. 

Analysis of the options 

A.  Options for strategic planning: top down versus bottom up 

Box 7: What do stakeholders think? 

Strategic programming (flexible top-down approach) was the most popular option among workshop participants (which 
included Member States authorities, private and public sector beneficiaries and NGOs). There was no support for limiting 
the thematic focus of the Programme. However, it was recognised that having priorities could increase the EU added value 
provided these priorities were non-exclusive and enough certainty for potential applicants would be provided (e.g., there was 
opposition  to  annual  priorities  but  more  support  to  2-3  years  priorities).  60%  of  YVIE  respondents  support  a  better 
prioritisation.   

•  Option A1: Baseline: Bottom up approach  

Under  this  option,  the  problems  identified  under  the  current  programming  period  regarding 
lack of focus and undermined capacity to create critical mass in specific sectors will remain. 
With  the  exception  of  the  Natura2000  section  of  the  Programme  that  concentrates  on  two 
Directives, a myriad of projects will be financed, even in sectors, such as climate change, with 
earmarked resources. As shown in section 2.2.2(a) and (b), even when a sector concentrates 
large parts of the budget, the bottom-up approach and projects and the environmental sectors 
financed are so diverse that no lessons can be drawn for mutual learning.   

•  Option A2: A top down-approach for all types of projects (with a more flexible top-
down  applied  to  traditional  projects  and  a  rigid  top-down  approach  to  Integrated 
Projects)  

This option is intended to increase the EU added value, through stronger priority setting and 
related targeting, and through increase in the leverage and multiplier effects.  

29 
30 

31 

See Annex 11 for more detailed analysis of Integrated Projects.  
The  larger  size  of  Integrated  Projects  responds  to  the  call  for  larger  projects  made  in  the  ex-post 
assessment of the LIFE III programme. 
Noted as a benefit of Integrated Projects by the Committee of the Regions (2011) DRAFT OPINION of the 
Commission for the Environment, Climate Change and Energy on THE EU LIFE PROGRAMME.THE WAY FORWARD. 

43 

 
 
                                                 
The  scale  of  this  improvement  is  difficult  to  quantify;  it  depends  on  how  much  of  the  best 
practice  currently  achieved  for  most  performing  sectors  could  be  expanded  and  used  to 
replace less effective activity. On the assumption that there could be a 50% improvement in 
the least effective part of the Programme (say the bottom-up quartile of activity), and a 25% 
improvement  in  the  second  least  effective  quartile,  this  would  represent  an  overall 
improvement of 19% (say 20%). 

Taking the minimum value of the environmental benefits expected to be achieved, i.e., €750 
million  a  year,  and  excluding  the  substantial  social  and  economic  benefits,  this  would 
represent  an  increase  of  €150  million  of  environmen tal  benefits  per  year  attributed  to  this 
option. Taken the maximum level and increase of €210 million of environmental benefits per 
year could be obtained through this option.  

Other considerations:  

A  more  strategic  focus  will  also  increase  the  capacity  to  create  critical  mass  for  specific 
sectors, and multipliers. Under the current LIFE+ Regulation, there are significant examples 
of  projects  that  have  demonstrated  environmental  benefits,  which  have  subsequently  been 
disseminated  and  have  catalysed  subsequent  take-up,  thereby  increasing  environmental 
benefits.  

Box 8: The following projects serve to illustrate examples of projects which have had ’multiplier’ effects. 

Given the need for elapsed time, these exemplars are taken from the LIFE III Programme 

The catalytic role of LIFE – NATURE: IBA MARINAS - Important Bird Areas for Seabirds (Marine Ibas) in Spain  
(LIFE04 NAT/ES/000049) 
The  project  aimed  to  prepare  a  detailed  inventory,  using  objective  methodological  criteria,  to  determine  marine  IBAs  for 
seabird species listed in Annex I of the Birds Directive that live in Spanish marine waters. The project worked closely in co-
ordination with a similar LIFE project covering Portuguese territorial waters. The project developed a model methodology 
for  defining  future  marine  IBAs.  This  approach  has  now  been  adopted  by  members  of  BirdLife  International  as  part  of  a 
global standard (in Greece, Malta, the Baltic Countries, Argentina, Peru, USA, South Africa and New Zealand). 

The catalytic role of LIFE – EPG: Reducing Emissions of Greenhouse Gases in Rome (LIFE04 ENV/IT/000453) 

The project funded a local action plan in Rome to reduce GHG emissions by 6.5% by 2012 (compared to 1990), in line with 
the Kyoto target for Italy. The project included eight small pilot projects to test actions that might be included in the plan. 
These pilot actions proved successful and were consequently models for demonstration and replication. The pilot on local 
traffic planning gave important inputs that have now been adopted in the new Strategic Mobility Plan for Rome.  An Action 
Plan for the Reduction of GHGs in Rome was drawn up and approved by the municipal council in March 2009, building on 
the results of the pilot projects.  

The  added  value  of  LIFE  is  increased  by  concentrating  the  resources  of  the  Environment 
strand  on  environmental  policy  improvements,  which  relates  largely  to  the  development  of 
action  plans,  management  plans  and  strategies  at  the  level  of  a  competent  authority  or 
municipality;  and  on  funding  environmental  solutions  that  can  help  integration  directly  and 
through being mainstreamed in the major funding instruments. 

More significant impacts in terms of awareness raising and dissemination of lessons learned 
are  expected.  The  system  would  allow  for  targeting  specific  sectors  which  may  lead  to 
quantifiable changes in attitude towards an environmental challenge. The examples included 
in  Box  2  (at  section  2.2.2(a)1)  illustrate  how  the  new  system  could  help  designing  call  for 
proposals  to  complement  EU  campaigns  and  targeting  resources  in  specific  policy  areas, 
thereby increasing impact. 

The 2-3 years rolling plans would also be adaptable so that adjustments can be done based on 
the  evolution  in  achieving  targets.  For  example,  if  sufficient  Integrated  Projects  have  been 
financed in the nature sector as to provide enough examples for the different Member States 
and bio-geographic regions, the rolling plan will allow targeting other sectors. However, the 

44 

 
 
system could be too rigid and discourage potential applicants, especially as Integrated Projects 
may take up almost all annual resources in the second half of the programming period.  

As to subsidiarity considerations, Member States will participate in the preparation of the 2-3 
years work plans and the elaboration of the selection criteria, thereby ensuring that Member 
States needs are also reflected in the programming. On the other hand, this participation could 
lead to lengthy negotiations hampering the endorsement of the rolling plans. Participation in 
an advisory capacity could diminish this risk. 

•  Option  A3:  An  approach  combining  the  top-down  approach  for  Integrated  Projects 

and bottom-up approach for all other types of interventions 

Increased environmental impacts compared to option A1 will be those linked to the capacity 
to focus Integrated Projects on specific sectors that require specific EU intervention.  

For traditional projects, however, there would be no possibility for creating priority sectors or 
specify  needs  linked  to  concrete  Directives  within  one  sector.  This  could  lead  again  to  a 
myriad of projects will little links to policy development and implementation. No possibility 
for adjustments during the programming period, not even after a mid-term evaluation, because 
there  would  be  no  formal  planning  system  to  reallocate  resources,  if  needed.  This  could  be 
done  only  for  Integrated  Projects  in  an  informal  basis  and  depending  on  the  geographical 
distribution system adopted.  

However,  the  system  could  be  considered  more  flexible,  especially  by  the  end  of  the 
programming  period  where  only  a  limited  number  of  traditional  projects  is  expected  to  be 
financed.  

B.  Options for thematic concentration of Integrated Projects 

Box 9: What do stakeholders think? 

Respondents to the Committee of Regions survey suggested that Integrated Projects could most realistically and 
effectively  be  used  to  address  a  wide  variety  of  environmental  problems/challenges  met  within  their 
region/municipality, notably: ‘freshwater management’ (21.5% of responses); ‘nature and biodiversity’ (18% of 
responses);  ‘resource  use  and  waste’  (14%  of  responses);  as  well  as  ‘urban  environment’,  ‘air  pollution’  and 
‘land use’ (each counting for 9% of responses). In addition, a total of 14% of the related responses concerned 
climate change issues (either adaptation or mitigation). Almost 55% of respondents to YVIE survey supported 
Integrated Projects with 42% supporting the approach for Natura2000 (only 16% of respondents were opposed), 
50% for other sectors such as water, marine and waste. 

A mode detailed assessment of benefits of Integrated Projects is provided in Annex 11. 

•  Option B1: Baseline: No thematic concentration of Integrated Projects 

Given  the  resources  allocated  to  the  Environment  sub-programme  of  the  future  LIFE,  an 
analysis of ‘what will it take’ to produce a step change in the impact of the Programme has 
been  made.  The  number  of  Integrated  Projects  required  relates  to  the  relevant  territorial 
‘units’  for  each  environmental  theme  identified  as  having  a  potential  for  integrated 
approaches. A statistical relevance of 15-20% of the relevant territorial unit has been used to 
determine  the  number  of  projects  required  in  a  specific  sector  to  have  enough  examples 
applicable to different administrative and regional characteristics (including levels of capacity 
development) so that different experiences can be widely disseminated among Member States 
and regions. Applying the statistical relevance it is possible to identify how many Integrated 
Projects would be required to have critical mass in the sector concerned.  

Integrated  Projects  in  Nature  –  The  relevant  unit  is  the  NUTS  2  region,  given  than  regions 
tend to be responsible for the management of Natura2000. This also has the merit of linking 

45 

 
directly to possible regional funding. There are 271 NUTS 2 regions in the EU. Assuming the 
minimum  level  of  action  required,  one  Integrated  Project  for  nature  conservation,  in  say 
between  15-25%  of  the  regions  over  a  7-year  Programme  period  would  be  needed.  This 
means between 6 and 10 Nature Integrated Projects in average per year.32 

Integrated  Projects  in  Environment  –  In  this  case  the  relevant  unit  depends  on  the 
environmental theme.  

•  Waste management – the appropriate unit is also probably the NUTS 2 region, given 
the nature of regional waste management plans. 15% Integrated Project activity over 
the  Programme  would  provide  a  minimum  level  of  catalytic  effect  –  say  an  average 
minimum of 6-10 projects a year; 

•  Water management – the appropriate unit is the river basin district of which there are 
110  river  basin  districts  and  176  national  branches.  Given  the  important  issues 
associated  with  transposition  and  implementation  of  the  Water  Framework  Directive 
(WFD), and the interest in ensuring cross-compliance with the WFD as a condition of 
regional  funding,  then  a  greater  share  of  ‘units’  should  be  covered  –  15-25%.  This 
would require an average minimum of 3-4 projects a year; 

•  Air  quality  management  –  activity  in  large  cities  to  combat  urban  air  pollution  (e.g. 
particulates, low level ozone and nitrogen dioxide) would also benefit from the use of 
Integrated Projects. Building on the 2013 European ‘Year of Air’, 3 IP projects a year 
would allow action in 20 of the most polluted EU cities. This could be combined with 
other urban elements; 

•  Marine environment – probably 1-2 Integrated Projects per sea basin (3-5 projects per 

year in average).    

The  Environment  strand  would  therefore  require  a  minimum  of  13-19  Integrated  Projects  a 
year, if the use of these projects was to really tackle the institutional weaknesses that underpin 
the  lack  of  adequate  policy  implementation  and  effective  policy  integration  in  the  entire 
acquis. 

Given  that  these  projects  are  larger  in  size  (EU  contribution  €10  million  per  project),  the 
current  allocation  would  probably  be  not  sufficient  to  achieve  all  abovementioned  targets, 
thereby undermining the Programme’s capacity to achieve critical mass of projects in specific 
sectors.  This  would  imply  not  addressing  the  main  criticism  related  to  lack  of  prioritisation 
and focus. The possibility to reach concrete results and provide enough examples for different 
administrative  organisations  and  sectors  may  not  be  possible.  On  the  other  hand,  a  large 
thematic scope will allow testing the approach in a bigger number of sectors.  

A large thematic scope for Integrated Projects would also imply that if the Programme wants 
to  have  any  chance  of  reaching  targets  in  some  sectors,  traditional  projects  could  not  be 
financed.  These  traditional  projects  cannot  be  completely  phased  out  (as  recognised  by  the 
MFF  Communication).  Firstly,  these  projects  address  the  needs  of  stakeholders  that  are  not 
necessarily  public  authorities,  such  as  SME.  In  addition,  not  all  environmental  activities 
require a planned and large territorial scale action. Finally, not all public authorities would be 
ready  at  the  beginning  of  the  programming  period  to  submit  an  Integrated  Project  in  some 
cases due to lack of capacity.   

32 25% of 271, divided by 7. 

46 

 
                                                 
Based  on  the  experience  under  LIFE+,  between  8-10  traditional  project  per  environmental 
sector  would  be  required  to  achieve  critical  mass  and  create  multipliers.  If  environmental 
sectors are grouped in 6 sectors (biodiversity, water, natural resources and waste, environment 
health,  which  would  include  noise  and  chemicals,  emissions,  which  would  include  air  and 
IPPC,  and  green  economy)  around  56  to  60  traditional  projects  per  year  are  required  in 
addition to information projects. 

Integrated  Projects  would  gradually  be  introduced  in  the  Climate  Action  sub-programme  in 
the area of mitigation and adaptation, in order to allow time build up capacity needed for such 
projects. 

•  Option B2: Thematic concentration of Integrated Projects 

Given  above  considerations,  it  would  seem  that  some  thematic  concentration  for  the 
Environment sub-programme may be required. Integrated Projects could concentrate on:  

(1) Sectors where implementation or integration problems are more significant 

As to implementation problems, a good indicator is infringement cases. Nature conservation, 
waste  and  water  legislation  accounts  for  59%  of  the  infringement  case  load  for  the 
environment sector, with the sectors "impact assessment" and air contributing the bulk of the 
remainder (27%). Other sectors, such as Marine, are still in a development phase.33  The last 
few years have seen a marked increase in cases in the air sector.  

Implementation  problems  often  reflect  integration  problems.  For  example,  the  high 
percentage of cases concerning nature protection legislation can be explained by the fact that 
many  infrastructure  developments  proposed  in  Member  States  that  lead  to  complaints  are 
those affecting in some way Natura 2000 sites or EU protected species. As shown above when 
analysing consistency with other EU funds and the Zero option, Nature conservation also has 
problem of absorption capacity in other EU programmes, partially because authorities do not 
always perceive the socio-economic benefit of nature conservation.  

The overall percentage share of waste and water cases reflects the fact that they have entered 
crucial implementation phases. The waste sector also has problems of absorption capacity in 
other  EU  programmes.  As  in  the  case  of  Nature,  the  capacity  to  develop  and  prepare 
investments,  and  to  channel  large  amounts  of  EU  funding,  is  still  lacking  in  some  Member 
States. There is a risk that some funds from the 2007-2013 programming period will not be 
spent in time. 

Nature,  water  and  waste  are  entering  crucial  implementation  phases.  In  the  near  future,  the 
Habitats  Directive  will  move  from  designation  to  active  management  and  restoration; 
similarly,  under  the  Water  Framework  Directive  (WFD),  the  river  basin  management  plans 
will  need  implementation  to  achieve  the  objective  of  good  environmental  status.  Air 
legislation will be revised in 2013, which implies that in the period 2014-2020 will also enter 
its  crucial  implementation  phase.  The  Marine  legislation  will  enter  as  well  the  crucial 
implementation phase, since by 2020 Member States should have achieved or maintain a good 
environmental status. 

Management  and  implementation  costs  for  Natura2000,  water  and  waste  are  very  high  i.e., 
€5.8 billion per year for Natura2000,  €30 billion per year for water,  €7-12 billion per year for 
municipal waste compared to Air which requires about €1 billion per  year (see Annex 5).  

(2)  Sectors  that  are  more  linked  to  achieving  Europe  2020  resource  efficiency  targets  and 

33 http://ec.europa.eu/environment/legal/law/statistics.htm. 

47 

 
 
                                                 
direct environmental benefits  

The  Resource  efficiency  roadmap  indentifies  biodiversity,  water,  waste,  air  and  soil  as  the 
main  environmental  sectors  that  are  essential  to  shift  towards  a  more  resource  efficient 
economy. Of these, biodiversity, water, waste and air are suitable for Integrated Projects. 

As to direct environmental benefits, as shown in section 2.2.2(a) and Annex 7, Nature, water 
and  waste  are  the  sectors  with  more  direct  environmental  benefits.  In  addition,  air  provides 
many socio-economic benefits linked to health. Not enough information about marine projects 
exists as to determine the environmental benefits generated.  

(3) Sectors that have more possibility to link to, and therefore mobilise, other EU funds.  

Mainstreaming of nature, water and waste is much consolidated and has been improved under 
the  MFF  Communication  proposals  thereby  providing  more  opportunities  for  generating 
examples  for  integrated  funding  to  solve  the  significant  absorption  capacity  problems 
identified.  Air  has  also  improved  mainstreaming  due  to  its  health  impacts,  and  many  links 
with  climate  change  (especially  in  urban  areas).  The  new  European  Maritime  and  Fisheries 
policy  has  also  improved  the  integration  of  Nature  Directives  and  the  Marine  Strategy 
Framework Directive.  

Additional criteria: 

(4) The maturity of the sector (i.e., the development of plans and programmes is required by 
the legislation and they are already in place), including the success of environmental sectors 
in LIFE. 

Nature,  water  and  waste  are  probably  the  most  mature  environmental  sectors  in  terms  of 
planning  and  programming.  Management  plans  for  Natura2000,  River  Basin  Management 
Plans and Waste management plans have already been developed. The Habitats Directive will 
require  a  programme  approach  applied  to  the  network  (and  not  only  to  a  site)  through 
Prioritised Action Frameworks. The Water Framework Directive’s River Basin Management 
Plans already foresees an integrated approach, and there is an increasing call for overreaching 
waste strategies.  

As to the consolidation of the sectors in LIFE, Nature, water and waste are the traditionally 
successful sectors: 50% of resources are allocated to Nature, and water and waste applications 
amount  to  almost  70%  of  all  LIFE  Environment  applications,  with  an  average  of  50-60 
applications  for  water  and  80-100  for  waste  compare  with  12  applications  for  air.  Marine 
applications tend to be done in the context of the Habitats Directive.  

(5)  The  stakeholders’  opinion  could  also  be  used  to  discriminate  between  one  or  another 
sector.    As  seen  in  Box  9  above,  nature,  water  and  waste  are  the  sectors  signalled  by 
stakeholders. Air is also mentioned but to a lesser extent. 

o  Sub-option B2a: Thematic concentration on 3 sectors: Natura2000, water, waste 

Natura2000, water and waste rate first in almost all the criteria mentioned above. Although 
it is difficult to quantify the environment and socio-economic benefits of LIFE projects (see 
some examples in Annex 11), the more targeted approach for Integrated Projects will allow 
covering at least 15% of the Natura2000 network (doubling the coverage under the 2007-2013 
period), 10-15% of the river basin districts and up to 15% of regions for waste management. 
Only for the Natura 2000 network, this could represent a 30-40% increase of environmental 
benefits compared to the baseline. In addition it will be possible to create synergies between 
Natura2000 and Water Framework Directive.  

48 

 
  
 
Since  nature,  water  and  waste  are  very  consolidated  sectors  under  LIFE  funding,  risks  of 
failure of the approach (e.g., lack of demand) would be reduced. This is especially important 
for water and waste (so far covered by the LIFE Environment component) which had mostly 
focused  on  innovation  and  demonstration  of  technologies  and  now  will  shift  focus  towards 
implementation.  

The Marine Strategy Directive could be partially covered by either Natura2000 (marine and 
coastal  habitats  and  species)  or  the  Water  Framework  Directive  (coastal  and  transitional 
waters).  Air  legislation  could  be  partially  covered  by  Climate  adaption  and  mitigation 
Integrated Projects. However, it would mean excluding the sector that provides more health 
benefits and which has been identified by the Commission as a priority for the coming years, 
also in relation to the Resource Effiency Roadmap. 

o  Sub-option  B2b:  Thematic  concentration  on  4  sectors:  Natura2000,  water,  waste 

and air 

This option will increase the potential of the Programme to provide direct benefits, especially 
in  relation  to  health.  As  shown  in  section  5.1,  the  current  LIFE+  Regulation,  with  only  an 
average of 2-6 air projects per year, will be able to improve the quality of air of 12 million 
citizens. Air projects covering the 40 most polluted cities through 20 twinning projects could 
imply  reaching  about  10%  of  the  EU’s  population.  Air  is,  however,  a  sector  with  a  low 
application rate for LIFE funding. Therefore, there might be demand problems. On the other 
hand, one of the Integrated Projects precursors was an air project.  

Given the limited resources under the Environment sub-programme, the number of traditional 
projects per  year may go below the threshold. It  might  also  require  lowering  targets  for  the 
water and waste sector thereby reducing the focus and overall demonstrative relevance of the 
Programme.  One  possibility  to  overcome  this  risk  is  by  lowering  the  expected  EU  co-
financing  rate  for  Air  Integrated  Projects.  As  shown  above,  management  costs  for  Air  are 
significantly lower than for other environmental sectors. This suggests that Integrated Projects 
may  also  be  smaller  (e.g.,  let’s  say  about  €7,5  million  co-financing).  However,  the  size  of 
Integrated Projects is only assumed based on examples of projects financed under LIFE+. 

For both sub-options, Integrated Projects would gradually be introduced in the Climate Action 
sub-programme in the area of mitigation and adaptation, in order to allow time to build up the 
capacity needed for such projects. 

C.  Options for allocation of resources between different priority areas 

•  Option C1: Baseline- MFF Communication allocation  

Under this option, better targeting for climate change will be achieved (thus solving one of the 
problematic aspects highlighted under Problem 1 in section 2.2.2(b). This will increase direct 
benefit  at  least  associated  to  climate  impacts  (Concentration  on  climate  may  increase 
environmental benefits by 50% from €135 millio n a year to €270 million- see section 5.1). 

However,  the  Environment  sub-programme,  and  more  precisely,  the  Nature  &  Biodiversity 
component  would  lose  the  feature  that  has  been  partially  responsible  for  the  success  and 
strategic focus of the component. Therefore, instead of solving Problem 1, the option would 
increase risks of further dilution of thematic focus for the Environment sub-programme.  

This  will  also  impact  the  capacity  of  the  Programme  to  provide  direct  benefits.  As  shown 
above (sections 2.2.2(a) and section 5.1), Nature is responsible for the highest and most cot-
effective  environmental  benefits  for  the  Programme.  Similarly,  implementation  problems 
(driver 1) and integration deficiencies on the ground (driver 2) are especially significant for 
nature. In many cases, LIFE is the only Fund available for specific Natura2000 management 

49 

 
measures.  If  resources  are  no  earmarked,  and  given  the  more  complex  characteristics  of 
developing a nature project, the higher demand in projects in the environmental sector could 
significantly reduce the chances for nature and biodiversity projects to be funded. In fact, this 
higher demand derives from the large spectrum of sectors covered. 

•  Option  C2:  MFF  Communication  allocation  and  allocation  of  50%  of  resources  to 

biodiversity 

This option will continue the positive impacts already identified under the current Regulation 
and will increase them. This is because there is an increase in funds dedicated to nature and a 
more targeted and integrated approach increasing projects size and thus territorial impact (A 
minimum  of  additional  €450-500  million  environmental  benefits  could  be  expected  -  see 
section 5.1). Such option is in line with stakeholders' expectation in particular concerning the 
financial support expected for Natura 2000 under the Biodiversity strand. It is also consistent 
with the findings of LIFE mid term evaluation. These confirm that implementation gaps and 
integration problems are more significant for Nature and Biodiversity.   

The con of this option is that it may impact the ability to finance standard action grants and/or 
Integrated Projects if too many sectors are included in the Environment component. 

D.  Options for geographical distributional impacts (national allocations) 

Box 10: What do stakeholders think? 

As to national allocations, these were only discussed with the Member States in the Committee meeting. The positions were 
divided between those Member States opposing all kind of pre-allocation of funds and others supporting the current system. 
The EESC is clearly opposed to national allocations.  

•  Option D1: Baseline - All projects selected on merit  

Under  this  option,  the  risk  is  that  Italy  and  Spain  will  continue  to  be  main  beneficiaries,  as 
under  the  LIFE+  Programme.  Figure  3  shows  the  impact  of  national  allocations  on  current 
selection.  If  the  selection  had  been  based  on  merit  only  (highest  points  on  the  main  four 
evaluation criteria, i.e., their technical and financial quality, and demonstrative value for the 
EU),  some  Member  States  would  have  received  additional  projects  and  others  fewer.  For 
example,  Austria  would  have  received  two  additional  projects  (one  under  the  environment 
strand  and  another  under  the  information  and  communication  strand)  whereas  others  would 
have  received  fewer  projects.  Because  of  the  national  allocation,  proposals  from  a  Member 
State  that  pass  the  minimum  quality  criteria  but  with  fewer  points  than  those  submitted  by 
other Member States get funded.  

However,  as  shown  below,  it  is  impossible  to  identify  a  clear  trend,  such  as  a  general 
advantage to those with less experience in the Programme or those with fewer resources. In 
one case (Italy), the effect of the current system is simply a re-allocation of funds, within the 
same Member State, between different strands of the Programme. 

If the projects were selected on merit only, this would mostly favour Spain and to a certain 
extent  Italy,  which  are  the  Member  States  already  receiving  most  funding,  whereas  other 
Member  States,  like  Latvia,  Romania  or  the  UK  (which  already  do  not  use  their  national 
allocation) may obtain fewer projects. To summarise, merit only will - with some exceptions - 
favour again the current winners.   

50 

 
 
Figure 4: Impact of National allocations under the current system 

AT BE BG CY CZ DE DK EE ES FI FR GR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK

ENV
INF
NAT

4

3

2

1

0

-1

-2

-3

-4

-5

-6

On  the  other  hand,  the  system  will  lose  part  of  the  solidarity  rationale  and  justification  for 
burden  sharing,  especially  regarding  nature  conservation,  since  natural  assets  are  unevenly 
distributed among Member States.  

•  Option  D2:  All  projects  selected  on  merit  but  ensuring  geographical  balance  for 

Integrated Projects  

Traditional projects have historically been financed mainly in Italy, Spain and Germany. It is 
expected  that  some  Member  States  would  increase  the  number  of  traditional  projects  (as 
shown  above  probably  Austria,  Belgium  and  Greece)  should  the  evaluation  be  based 
exclusively on the quality and demonstrative value for the EU. 

Integrated Projects are linked to the development of regional strategies, implementation and 
capacity  building.  Therefore  a  geographical  balance  is  desirable  to  ensure  that  all  Member 
States  obtain  at  least  one  Integrated  Project  (subject  to  other  concerns).  For  example,  the 
Commission  would  ensure  at  least  one  Integrated  Project  per  Member  State  in  waste  and 
nature  sectors  and  at  least  one  Integrated  Project  per  transboundary  river  basin  district 
(Danube,  Rhine,  etc),  and  at  least  two  projects  per  bio-geographical  region.  Member  States 
with more capacity deficiencies, Member States with high nature assets (e.g., Bulgaria, Spain 
or Slovenia) and Member States hosting transboundary river basin districts (France, Hungary, 
Germany or Austria) would probably be favoured.  

Priority  to  transboundary  projects,  especially  under  the  water  sector  and  to  create  synergies 
between water and Natura2000 (e.g., in the Danube). This option is also flexible and allows 
Member  States  that  are  ready  to  submit  proposals  during  the  first  half  of  the  programming 
period to do so, and it gives time to other Member States to learn from the first experiences 
and  submit  proposals  later.  This  option  would  work  better  with  Strategic  programming 
(option  A2)  because  it  would  allow  adjustments  if  one  Member  State  has  not  received  any 
Integrated Project.   

•  Option  D3:  Standard/traditional  projects  selected  on  merit  only  and  national 
allocations (specific amounts per Member State) for Integrated Projects for the whole 
programming period 

Same as D2 but indicative allocations will be created ex-ante based on environmental needs 
agreed with the Member States. These indicative allocations would be calculated and applied 
for the entire programming period instead of annually as today to allow more flexibility in the 
selection procedure (e.g., one Member State could fulfil its national allocation the first years 
whereas another could need more time and would only submit proposals in the second half).  
This  option  would  also  work  better  with  the  strategic  programming  (option  A2)  because  it 
would allow adjustments.  

51 

 
 
 
For  the  nature  sector,  if  the  current  system  (population  and  %  of  territory  designated  as 
Natura2000)  applies,  the  biggest  financial  envelops  would  be  for  Germany,  France,  Spain, 
Italy  and  the  UK,  which  is  also  largely  in  line  with  the  management  costs  as  reported  by 
Member  States  (costs  tend  to  be  greatest  in  areas  which  require  the  highest  levels  of 
intervention and management such as agricultural areas in North-Western Europe and which 
face  greater  pressure  from  development  and  disturbance  such  as  islands  and  in  Southern 
Europe).  If  the  criteria  were  only  based  on  the  percentage  of  territory  designated  as 
Natura2000,  Slovenia,  Bulgaria,  Slovakia,  Cyprus,  Spain,  and  Greece  will  probably  have 
larger allocations as well as UK, Germany and France (for marine).  This does not imply that 
smaller  Member  States  would  be  overrepresented,  since  currently  the  smaller  annual 
allocation  is  about  €2.5  million  which  implies 
that,  for  a  7  year  programming  period,  the 
minimum allocation could be around €18 million, i.e., two Integrated Projects.  

For  the  water  sector,  given  the  significance  of  transboundary  river  basin  districts  and  the 
pressures  on  them,  priority  could  be  given  to  those.  Probably  France,  Germany,  Austria, 
Hungary or Romania would have larger allocations. If the criteria used were the km2 (ha) of 
river  basin  districts  compared  to  the  national  territory,  again,  the  abovementioned  countries 
and  probably  Spain  and  Italy  would  have  larger  allocations,  whereas  others,  such  as  Malta, 
would hardly have.  

For the waste sector, capacity needs would probably concentrate on new Member States.  

This option might be more acceptable for Member States, especially if strategic programming 
(option A2) is adopted but could increase rigidity and problems in agreement of criteria (as 
per  the  experience  with  current  LIFE+  Regulation)  and  complicate  the  selection  procedure 
(different steps are required to ensure the allocations are fulfilled). There is also the risk that 
the envelops are reserved and not used by the Member State (as per current experience) and 
targets  not  achieved,  in  which  case  a  mechanism  for  allocation  of  unused  funds  will  be 
needed.   

Box 11: Main assumptions in assessing geographical balance 

 -  Environmental  needs,  especially  in  relation  to  institutional  and  capacity  weakness,  and  management  costs  needs  remain 
largely the same during 2014-2020 (the analysis of evolution and scale of environmental problems in Annex 5 so seem to 
confirm).  For  Nature,  data  used  is  information  available  regarding  management  costs  for  Member  States  reported  by 
themselves as well as the number and share of Natura2000 network in relation to the territory, since this is a good indication 
of  burden  and  effort  sharing  (Member  States  with  a  larger  proportion  of  their  territory  designated  should  have  a  greater 
responsibility in conserving, preserving and restoring those habitats and species which are considered of EU interest). The 
assessment assumes that there would not be dramatic changes in designation in the next years, especially since the terrestrial 
N2000 network is considered largely complete. A similar logic and assumption was followed for water.  

-  Level  of  demand  in  all  Member  State  remain  similar  to  current  levels.  The  crisis  has  not  prevented  vulnerable  Member 
States (such as Italy, Spain or even Greece) from increasing the number of proposals submitted in 2011. It would seem fair to 
assume that the situation will remain the same in the coming years.  

-  A minimum number of Member States are ready to submit Integrated Projects at the beginning of the programming period. 
In  this  sense,  the  assumption  is  that  Member  States  with  more  experience  in  managing  larger  projects  or  precursors  of 
Integrated  Projects  (e.g.,  Belgium,  Spain,  Italy,  Slovenia,  the  Netherlands,  or  Finland)  will  be  ready  to  submit  Integrated 
Projects at the beginning of the Programming period, whereas new Member States, such as Romania or Bulgaria, will have 
more  difficulties.  Risks  mitigation  measures  in  relation  to  demand  have  been  developed.  Already  LIFE+  is  financing 
necessary  strategic  frameworks  required  under  the  specific  Directives  and  actively  promoting  Integrated  Projects,  so  some 
examples may already exist at the moment of entry into force of the new Regulation.  

52 

 
 
E.  Options for funding activities under Governance and Awareness raising 

•  Option  E1:  Baseline  -  NGO  funding,  Commission  communication  activities  and 

reinforced communication/dissemination obligations for projects  

Impacts  are  difficult  to  quantify  but  they  could  be  assessed  qualitatively  based  on  the  mid-
term evaluation and efficiency/effectiveness gains. As noted above, NGO contribute to civil 
society  participation  in  policy  development,  promoting  implementation,  strengthening  the 
knowledge base and raising awareness.  

Given  the  relatively  small  size  of  the  Information  &  Communication  component  (for  the 
2007-2009  calls,  the  INF  component  accounted  for  only  4%  of  the  EC’s  contribution  in 
LIFE+),  more  strategic  value  can  be  gained  from  strengthening  the  mandatory  information 
and communication activity in projects. As shown in section 2.2, the close links between the 
projects and the local populations place them in a unique position to influence behaviour and 
empower citizens. One could expect these impacts to increase by adopting a stronger focus on 
the generation of multiplier effects, which is translated into greater responsibility on project 
co-ordinators  for  identifying  and  communicating  findings  with  target  users  and  providing 
training. In particular, networks of similar projects around priority themes could be promoted. 

•  Option  E2:  NGO 

and 
communication/dissemination  obligations  for  projects,  and  specific  Communication 
campaigns financed through grants.  

funding,  Commission 

communication 

activities 

The  positive  impacts  of  option  C1  are  expected  to  increase  by  complementing  all  the 
abovementioned  activities  with  specific  information  and  communication  projects  financed 
through  grants  that  will  target  a  particular  sector  or  stakeholder  group  as  defined  by  the 
Commission. These projects could also be initiated to take on the synthesis and dissemination 
activity of results from the traditional projects under selected themes. This would allow these 
campaigns to be better focused: the strand has been hampered to date by its attempt to cover a 
broad  range  of  themes  and  by  the  fact  that  only  a  small  number  of  projects  have  been 
successfully funded so far (38 selected for funding from 329 proposals for the first 3 calls). 
This has affected its strategic impact (‘spread too thinly’) and its ability to concentrate on the 
issues  of  greatest  priority.  In  addition,  these  more  specific  projects  could  complement  DG 
ENV and DG CLIMA own communication and governance efforts increasing the multiplier 
effect  of  the  campaign  and  the  sense  of  ownership  regarding  results.  Indeed,  since  these 
projects will be carried out by national stakeholders, it would be easier to adapt the specific 
characteristics  of  a  particular  Member  State.  This  option  works  better  with  a  strategic 
the  priority  communication  and  dissemination 
programming  approach 
campaigns to be financed for 2-3 years. 

to  determine 

F.  Options for simplification 

•  Option F1: Baseline: On-line tools and larger projects 

On-line  tools:  It  is  difficult  to  assess  administrative  gain  regarding  the  use  of  on-line  tools. 
Current bidding costs are about €3.4 million. On-line tools will mostly simplify the procedure 
for submission of proposals which  accounts for around 20% of the bidding costs (including 
technical  and  administrative  staff  costs).  Applying  an  increase  in  efficiency  of  50%  for 
administrative staff costs and 10% for technical staff would lead to 7% savings. If applying 
50% gains in efficiency for both, 12% increase in savings would be expected.  

53 

 
 
Larger  projects  and  Integrated  projects:  Regarding  the  selection,  it  is  difficult  to  quantify, 
but  moving  to  larger  projects  imply  bidding  savings  for  the  beneficiary  for  the  entire 
programming  period,  since  instead  of  submitting  3  or  4  projects  in  a  10-year  period,  ,  only 
one project will be submitted. In addition, risks associated to multiple bidding, and therefore 
that  one  of  the  projects  may  not  be  selected  because  of  competition,  will  be  reduced.  The 
example below illustrates these gains.  

Box 12:  Potential LIFE Integrated Project-PM10 control in urban areas 

Four Austrian LIFE projects are interconnected and all have PM10 control in urban areas as a main objective. Each project 
has been used as a further step in developing a more holistic approach and contributing to a long term plan. The four projects 
could theoretically have been combined into a single integrated project, which drew on several funding sources. Even if the 
resources to prepare a proposal for an Integrated Project would increase as compared to smaller projects, they would still be 
fewer than the resources needed to prepare 4 different applications and go through 4 different negotiation procedures.  

As to management costs savings, see Options G. 

•  Option  F2:  Selection  procedures:    2  stage  procedure  and  simplified  reporting  for 

Integrated Projects - moving to larger projects 

Integrated  Projects:  The  simplification  in  the  reporting  cycle  will  imply  for  the  projects 
beneficiaries a reduction by 25% in reporting costs (a 2-year reporting cycle - instead of 18 
months - would imply, for a 6-year project, 3 reports instead of 4). Given that administrative 
costs  are  around  €1.7  million  a  year  and  that  re porting  costs  represent  between  60-75%  of 
administrative  costs  for  projects  and  that  Integrated  Projects  will  represent  between  20  and 
40% of projects financed every year, it could mean reporting savings between €178,500 and 
€357,000 a year. In addition, in terms of manage ment costs for the Commission, for a 6-year 
project, 2 amendments and 4 payments will be done. Considering that an Integrated Project 
could correspond to at least 5 traditional projects for which 15-20 reports, 15 payments and 3-
5  amendments  would  be  necessary,  this  represents  a  reduction  of  70%  in  the  number  of 
transactions. 

Multiannual selection for NGOs: This will ease the administrative burden of yearly selection 
procedures  (reducing  by  at  least  by  50%  cost).  One  disadvantage  identified  is  the  loss  of 
flexibility  as  compared  to  the  yearly  selections,  but  this  would  be  outweighed  by  improved 
stability and coherence of strategy and planning for NGOs, as well as reduced administrative 
burden. The periodicity preferred by stakeholders is 2 or 3 years. 

•  Option F3: Outputs and results payments vs lump-sums, ineligibility of certain costs 

An option of payment based on outputs could be examined.  However, it would take time to 
develop  a  methodology  to  calculate  cost/ha  and  type  of  habitats  for  restoration  and 
management activities.  

The  use  of  lump  sums  will  be  a  better  option  since  it  simplifies  reporting  costs  for  the 
beneficiary.  For  example,  by  introducing  standards  staff  costs,  obligations  regarding  time 
sheets  could  be  eliminated  to  a  large  extent  without  restraining  beneficiaries  to  only  recruit 
new people.  

Ineligibility of certain costs: Considering VAT cost non-eligible will simplify reporting since 
beneficiaries, especially some categories, have to go through complicated systems to obtain a 
certification that shows they are not eligible to obtain a refund. As to personnel costs, limiting 
eligible costs to only additional staff recruited specifically for the project will have significant 
impacts  on  simplification  in  terms  of  financial  reporting  and  monitoring  for  the  project 
beneficiary. Specific timesheets tend to duplicate the system in place by the beneficiary. Most 

54 

 
 
cases of recoveries are currently associated to personnel costs. Such a limitation would also 
make it easier for the Commission to monitor job creation for the project.  

Considering ineligible above costs would imply a reduction in the total real costs of about 5-
10% for VAT and 20-40% for personnel, which could discourage potential applicants. If the 
EU  intervention  (i.e.,  50%  of  eligible  costs)  is  to  remain  at  the  same  level  as  today  for  the 
project as a whole, the current co-financing rate will need to increase up to 70% for projects 
which currently have a co-financing rate of 50% and up to 80% for projects which currently 
have a co-financing rate of 75%.   

G.  Options for externalisation  

Options for externalisation should be considered within the context of the overall Commission 
intention to reduce management costs for the funding programmes.  

As  mentioned  in  section  1,  the  management  costs  of  the  LIFE  Programme  are  around  6%. 
LIFE  compares  well  to  other  EU  funding  programmes.  The  ex-post  evaluation  compared 
LIFE with EACEA as per its interim evaluation. The average ratio of administrative costs as 
% of total commitments was 9% in 2007. However, this covers large differences between the 
various programmes that EACEA manages. The ratio changes between 8.3% and 13.6% (five 
components),  2%  (for  one  large  component)  and  20.6%  (one  small  component).  The 
administrative costs as share of the total budget for EACEA represented 8.7% in 2007, 7.6% 
in 2008 and 11.8% in 2009. 

The ex-post evaluation concluded that the LIFE Programme seems within the same range and 
in  some  cases  below  the  range  of  other  similar  programmes.  However  the  basis  for 
comparison  is  limited.  Given  that  EACEA  is  an  executive  agency  where  the  potential 
efficiency  gains  from  externalising  the  tasks  should  have  been  achieved,  the  similarity  in 
range  points  in  the  direction  of  a  high  degree  of  efficiency  of  the  LIFE  Programme  most 
probably explained by the fact that main tasks linked to selection and monitoring have been 
already  outsourced.  In  fact  from  LIFEIII  to  LIFE+,  costs  passed  from  8%  to  6%  thanks  to 
further outsourcing at the consolidation of different programmes (Forest focus, Urban, NGOs 
operating grants) into one programme, saving 4 full-time posts.34  

The decision of the MFF Communication to move towards larger projects is a further attempt 
to reduce management costs. Moving to larger projects also implies a reduction in the number 
of  projects  and  thus  on  the  staff  required  to  manage  them.  As  seen  above,  further 
simplification measures related to reporting and eligibility of costs could further reduce these 
costs. Externalisation to an existing Executive Agency is also part of the efforts to continue 
this trend.  

It is difficult to compare the costs of direct centralised management by the Commission with 
the  costs  of  management  by  an  Executive  Agency  (hereafter,  called  'Agency').  Doing  so 
requires  assumptions  to  be  made,  in  particular,  on  the  performance  by  any  Agency  and  on 
'efficiency gains'. Many of these assumptions will be tested when negotiating a contract with 
an  Executive  Agency,  but  even  the  benefits  of  any  improved  performance  will  not  be  seen 
until later.  

It should be noted that at the time of any delegation the Commission will publish a fuller cost 
benefit  analysis  going  into  further  detail,  and  informed  by  negotiations  with  the  Executive 
Agency. Therefore, the estimation of resources for both the Agency and the Commission, the 

34  

As  to  EACI  the  Interim  evaluation  indicates  that  EACI  has  a  ratio  of  administrative  staff  (defined 
differently to “administrative support”) significantly below the average (10.2% for EACI in 2010, while 
the average of all EAs was 14.4%) but no more details are provided regarding the costs of the overheads 
costs compared to the budget managed. 

55 

 
                                                 
cumulative  impacts  across  the  entire  programming  period  as  well  as  the  impacts  of  the 
transitional arrangements35 will  need  to be  a carefully  developed,  reviewed  and validated at 
the time of preparing the detailed cost/benefit analysis. 
The Court of Auditors36 has already highlighted some of the problems with past analyses of 
an Agency option: 

•  emphasis is placed mainly on savings from the use of cheaper contract staff rather than 
permanent staff but  aspects  of improved performance and efficiency gains are rarely 
considered;  

•  costs  of  additional  staff  needed  in  the  Commission  to  supervise  agencies  and  at  the 
agencies for horizontal functions, are not accurately included or not included at all; 

•  comparison is often made using the single average unit cost for the various categories 
of contract staff but in practice they vary in grade and therefore cost. Analysis shows 
the  composition  of  the  Commission  consists  largely  of  lower  grades  compared  to 
specialised personnel so this would lead to an overestimation of Commission costs in 
cost comparisons. 

In  this  analysis,  the  costs  of  additional  staff  to  supervise  agencies  has  been  estimated,  but 
potential  performance  and  efficiency  gains  from  implementing  a  larger  programme  in  one 
Agency  have  only  been  partially  considered,  which  may  leave  the  Agency  option  in  a  less 
favourable light. 

Current  cost  of  Programme  Management  as  a  percentage  of  Programme  value:  The 
number  of  full-time  equivalent  posts  to  manage  all  aspects  of  the  Programme,  including 
external  contractors  and  EU  officials  is  approximately  125  full-time  equivalent  posts.  The 
represents 
total  administrative  cost  is  just  over  €15  million  (€15,084,000).  This  currently 
6.2% of the total annual Programme budget.37  

•  Option G1: Baseline- Externalisation 

In  the  MFF  Communication,  the  Commission  considers  that  the  future  Programme  should 
remain centrally managed, but that management tasks could to a large extent be delegated to 
an existing executive agency. 

o  Sub-option G1.a: Externalisation without replacing technical assistance 

In  terms  of  costs,  based  on  the  experience  gained  with  the  externalisation  of  the  eco-
innovation  part  of  the  CIP  Programme,  the  same  number  of  staff  currently  managing  the 
LIFE+  Programme  within  the  Commission  (44  posts)  could  be  needed  in  the  Agency  (of 
whom 9 would be officials seconded from the parent DGs to the Agency).38 In addition, some 

35 

36 

37 

38 

There are projects currently financed that will last until 2018. Around 200- 230 projects are selected in 
average in the last call for proposals. Assuming that only projects that were financed in the second half 
of the Programme will likely still be active when the new Programme starts that gives around 600-700 
projects from LIFE+ still alive when the new LIFE Regulation enters into force.  
European  Court  of  Auditors  Special  Report  No.  13,  ‘Delegating  implementing  tasks  to  Executive 
Agencies: a successful option?’ (2009). 
Estimated  to  be  €244  million  (annual  EC  contribution  to  action  grants  and  expenditure  on  technical 
assistance). 
Based on experience and conversations with EACI, a minimum of 6 staff need to be seconded to the 
Agency when transfer occurs. According to figures for existing agencies like EACI, the percentage used 
for  seconded  staff  is  24%  of  the  staff  used  in  the  parent  DG.  A  20%  level  is  used  here  since  it  is 
expected  that  the  number  of projects  financed  will  decrease  as  well  as  overall  Commission  staff  (5% 
target).   

56 

 
                                                 
staff would need to remain in the parent DGs to take up coordination and control tasks (for 
governance,  supervision  and  monitoring  of  the  Programme,  including  establishing  links 
between the parent DGs, other DGs and the Agency).  

In  addition,  there  will  be  an  additional  staff  requirement  related  to  supplying  additional 
administrative  services  (human  resources  etc)  to  the  new  Agency  staff.39  There  are  also 
additional overhead costs (e.g., office costs) associated with the posts and contractual agents 
to  be  transferred  to  the  Agency.  The  total  cost  of  this  option,  represents  6.3%  of  the 
Programme budget.40  

As for aspects related to policy links, the overall programming and design will remain within 
the  parent  DGs  ensuring  a  link  between  traditional  projects  and  policy  priorities.  Adequate 
feedback  mechanisms  between  the  Agency  and  the  parent  DG  will  be  established  to  ensure 
project results feed into policy making.  

Since  most day-to-day   tasks  (e.g.,  visiting  projects  every  year,  answering  project  queries) 
will  be  implemented  through  technical  assistance,  the  Agency  staff  could  concentrate  on 
ensuring  information  flow  towards  the  parent  DGs,  and  on  financial  management  and 
control,  including  gathering  of  project  data.    Staff  in  the  parent  DG  will  concentrate  on 
ensuring  that  results  of  the  projects  are  duly  integrated  in  the  policy  definition  and 
implementation  and  on  transferring  information  to  other  DGs.  Promotion  of  Integrated 
Projects and networking could be done either by the Agency or by the parent DGs.  

However,  there  might  be  some  risks  that  an  additional  layer  of  communication  between 
projects and the parent DGs reduces the information flow and thus the capacity to use project 
results into decision making.   

o  Sub-option G1.b: Externalisation replacing technical assistance 

Most  probably,  the  Agency  staff  can  provide  the  services  undertaken  by  the  technical 
assistance external contractors at the same level of effectiveness and efficiency. At an annual 
staff  cost  of  €64,000,  the  additional  80  fulltime  e quivalent  contract  posts  would  cost  €5.1 
million.  There  is  also  a  requirement  for  additional  administrative  posts,  adding  a  further  16 
 In addition, there would be overhead costs 
posts. The total staff cost would be €6.1 million.
and  since  the  staff  would  be  based  in  Brussels,  there  would  be  the  additional  mission  costs 
currently avoided by using contractor staff based in the Member States. The total cost of this 
option,  with  the  replacement  of  external  assistance,  would  be  €14.6  million,  representing 
6.0% of the Programme budget; a saving of €0.5 million (3.0%) on the centrally managed 
option.  

On the other hand, there would also be cost savings if the work is brought in-house rather than 
the parent DG (or Agency) having to manage and supervise the contracting and undertaking 
of  this  technical  assistance  externally.  In  addition,  the  Agency  staff  would  have  a  constant 
direct  contact  with  the  projects  through  the  close  technical  and  financial  monitoring,  and 
annual visits which will help early detection of problems and if needed rapid contact with the 
parent DGs. However, arguably, the workload of the Agency staff would increase. 

39 

40 

Additional  staff  for  horizontal  (administrative)  tasks  is  based  on  current  demand  from  EACI  that 
estimates a need of 20%. 
Applied  to  current  programme  budget  assuming  that  for  some  years  the  transitional  costs  will  be 
standing still. 

57 

 
 
 
 
                                                 
Box 13 – Summary of advantages and disadvantages of the full externalisation option 

Advantages  

•  The majority of the staff in the Agency (up to 75%) can be contract posts that are significantly cheaper. 

•  The recruitment of such contract staff will be of a high quality and tailored technical expertise.41 The Agency employees 
could therefore undertake the bulk of work that is currently undertaken by the LIFE Unit staff and external contractors 
(under the option that includes technical assistance): 

-  Management  tasks  –  specific tasks  relating  to Programme  management  such  as  financial and  technical  management 
e.g. payment processing (and finding ways to improve the processing)42; 
- Programme implementation e.g., ensuring reports processed within deadlines and selection of projects takes place on 
time; 
- Communication and dissemination activities. 

•  The recruitment of staff with a specific technical profile could also increase the effectiveness of technical monitoring and 
improve the communication of lessons learned to the parent DGs (provided the organisational arrangements are based on 
thematic expertise rather than geographical or a mixture of both).  

•  The use of contract posts in the Agency also ‘frees up’ the Commission’s human resources in terms of ‘saving’ permanent 
posts and allowing for the re-allocation of them to core policy tasks, which in itself reduces the need for contract posts. In 
  of  which  two  thirds  would  be  AST  posts  and  one  third  AD  posts. 
fact,  the  Agency  option  could  free  up  19  posts;
However, this would materialise only after a number of years and only if all ongoing projects would be transferred. 

43

Disadvantages  

•  Integrated Projects are to act as a catalyst for effective mainstreaming into the other EU financial instruments. This will 

require careful design and cooperation with the policy units in the parent DGs and other DGs to ensure their success. 

•  Integrated  Projects  are  also  to  provide  examples  of  how  integration  is  possible  in  practice.  Therefore  it  is  important  to 
know whether this approach works and to identify at an early stage problems and to react rapidly. Close monitoring by the 
Commission and contact with the beneficiaries is needed to ensure this early detection and quick solution finding.  

•  The preferred option for the Programme is one which concentrates on strategic sectors, requiring enhanced cooperation 
and  management  to  effectively  contribute  to  policy  design  and  implementation  and  high  quality  technical  support  to 
ensure replication of results is achieved. As a result, there is a risk that the Agency option would decrease the ability of 
this option to deliver the expected added value. For example, Integrated Projects for Nature will test the development and 
implementation  of  the  Prioritised  Action  framework  (PAFs)  required  by  the  Habitats  Directive.  It  is  essential  that  the 
Commission closely follows how these new frameworks are developed in different Member States and is able to quickly 
react to demands for advice. This is more effectively done if the monitoring and management of the project remain within 
the Commission.  

•  There is also a clear link between Integrated Projects and implementation and compliance of some of the most demanding 
legislation  (Water  Framework  Directive  or  the  Waste  Framework  Directive).  In  the  case  of  the  Water  Framework 
Directive, the projects will be implementing plans that are directly assessed by the Commission to determine whether a 
Member States is meeting its obligations under the Directive. In addition, based on the experience with Nature projects, 
this type of project provides technical information that can be used for infringement cases or pilot cases. Therefore, strong 
policy  link  with  thematic  units  during  design  and  implementation  of  these projects  is  necessary,  and  could  not  be done 
efficiently by an Agency.  

•  If the level of the Programme remains similar to current levels, or if the budget increase is associated with a similar or 
fewer  numbers  of  projects  but  with  a  larger  average  size,  and  especially  if  technical  assistance  is  used  because  of  the 
importance of maintaining the current networks, the Agency option becomes less attractive on cost saving grounds. 

41 

42 

43 

See Technopolis (2006), ‘Cost Benefit Analysis of the externalisation of the certain tasks regarding the 
implementation of the Competitiveness and Innovation Framework Programme (2007-2013) through an 
executive Agency’. 
According to the European Court of Auditors Special Report No. 13, ‘Delegating implementing tasks to 
Executive  Agencies:  a  successful  option?’  (2009),  the  contracting  time  for  the  ‘Public  health’ 
programme  dropped  from  345  days  to  219  when  managed  by  an  Agency;  payment  period  shortened 
from 503 to 91 days and approval time for technical/financial reports dropped from 90 to 42 days. 
36 post minus 9 seconded and less 8 staff used in parent DGs for governance. 

58 

 
 
                                                 
•  G2:  Hybrid  solution:  externalisation  of  traditional  projects  -  keeping  Integrated 

Projects for the Environment sub-programme within the Commission  

Given the need to ensure that Integrated Projects feed back into policy design, provide more 
effective information for policy implementation and maximise their demonstration value, one 
option which would address these objectives in an efficient way would be to keep Integrated 
Projects for the Environment sub-programme under direct central management.   

In terms of costs, the option remain more or less at the same level as option G1 (around 6- 
6.3% of the Programme budget). As a form of sensitivity analysis, the calculations used for 
externalisation costs can be tested to see if they change with the change in number of projects 
that is likely to occur with the introduction of Integrated Projects and thus an approximation 
to calculating costs for the Hybrid solution. This is done comparing central management with 
the Agency option of Agency where technical assistance is not replaced.  

The  average  number  of  projects  managed  under  the  current  Programme  is  600  projects  per 
year.  The  total  number  of  projects  will  decrease  in  absolute  and  relative  terms  as  a 
consequence  of  the  phasing-in  of  Integrated  Projects  (which  are  larger  in  size).  Applying  a 
complexity factor of "2" to Integrated Projects, it would mean that on average the equivalent 
of 155 traditional projects would start each year, and over time the equivalent of around 400 
projects would be running at any one time.  

If Integrated Projects are kept within the parent DG, the cost will be similar to externalisation 
but the policy links will be ensured. The parent DGs have direct access to Integrated Projects 
making  it  easier  to  transfer  information  about  the  project  results  and  identification  of  the 
funds mobilised under other EU instruments as well as to provide inputs to Common Strategic 
Framework and Investment partnership contracts. This would be mainly done through regular 
contacts  with  beneficiaries,  including  on-site  visits  and  close  technical  monitoring  of  the 
achievement of outputs and targets. However, in the second half of the programming period, it 
could be that the parent DGs managed almost all projects (due to the progressive phase-in of 
Integrated  Projects),  making  the  externalisation  option  ineffective  for  traditional  projects 
under  the  environmental  sub-programme.  The  mid  term  evaluation  of  the  new  Programme 
will  need  to  revisit  the  analysis  to  assess  whether  Integrated  Projects  should  be  managed 
directly or by an Agency. 

6. 

COMPARING THE OPTIONS 

6.1. 

Summary of the assessments  

The  different  options  assessments  as  scored  in  the  previous  section  are  summarised  in  the 
assessment grid (Table next page) 

59 

 
(down) 

largely  bottom-up 

Effectiveness 
1.  Better  alignment  with  EU  policy 
priorities including climate action 

Top-down 
A.2 
all 
for 
approach 
of  projects 
types 
(flexible 
for 
traditional  projects 
and rigid for IP) 

/ 
Options 
Specific  Objectives 
(across) 
A. Options for strategic planning: top down versus bottom up 
A1. – Limited 
A. 1- Baseline  
-  Better  focused  on  Biodiversity  and 
Climate due to pre-allocation of resources: 
25%  of  LIFE  for  Climate  Action  sub-
programme. However within sectors, great 
diversity of projects financed. 
-  Very 
flexible: 
approach for projects, including IP.  
- Impacts: €750-1,000 million/year.  
A2. – Excellent 
-  Specific  constant  priorities,  Biodiversity 
and Climate Action.  
-  Possibility  to  establish  more  precise 
priorities  for  action  within  rolling  plan 
translated into the annual calls. 
- IP focused on three sectors: nature, water 
and  waste  in  line  with  biodiversity  and 
resources efficiency targets. 
-  Impacts:  20%  increased  compared  to  A1 
(between €900 and 1,210 million/year). 
A3. - Good 
- Better focus on Biodiversity and Climate 
due  to  pre-allocation  of  resources:  50%  of 
to 
Environment 
Biodiversity.  25%  of  LIFE  for  Climate 
Action  sub-programme.  However  within 
sectors,  great  diversity  of  projects 
financed. 
- IP focused on three sectors: nature, water 
and  waste  in  line  with  biodiversity  and 
resources efficiency targets. 
-  Flexible:  largely  bottom-up  approach  for 
projects. 

A.3. 
Top-down 
approach  for  IP  and 
bottom-up  for  other 
interventions 

sub-programme 

2.  Promote  the  funding  of  IP 
and 
in  LIFE 
project funded 

their  share 

Coherence 
and 
3.  Develop 
complementarity  with  other  EU 
funds 

synergies 

Efficiency 
4.  Align  selection  criteria  with  EU 
added  value 
  and  solidarity/effort 
sharing 

Simplify  and  streamline  the  LIFE 
Programme 

A1. – Neutral:  
No  specific  selection  criteria  attached  to 
priorities. 

A1. – Neutral:  
No change compared with business as 
usual. 

A2. -  Excellent:   
Selection  criteria  will  be  adapted 
priorities. 

to 

A2. -  Excellent:   
Mechanism  for  increased  focus  will 
simplify 
the  Programme 
works. 

the  way 

A2. -  Good:   
Selection  criteria  will  be  adapted 
priorities, but only for IP. 

to 

A2. -  Good:   
Mechanism  for  increased  focus  will 
simplify 
the  Programme 
works. 

the  way 

A1. – Neutral:  
Progressive  phase-in  of  larger 
IP in all sectors. 

A2. - Excellent:  
Progressive  phase-in  of  larger 
IP 
sectors. 
priority 
Possibilities for adjustment. 

in 

A3. – Excellent 
As  above.  Progressive  phase-in 
of  larger  Integrated  Projects  in 
priority  sectors  (water,  waste 
and  nature).  But  more  limited 
possibility for adjustment. 

A1. - Excellent:   
Structured  cooperation  with  other 
EU 
positive 
complementarity  enhanced  through 
integrated projects. 

funds 

and 

A2. -  Excellent:   
Structured  cooperation  with  other 
EU 
positive 
complementarity  enhanced  through 
integrated projects. 

funds 

and 

A3. -  Excellent:   
Structured  cooperation  with  other 
EU 
positive 
complementarity  enhanced  through 
integrated projects. 

funds 

and 

60 

 
 
  
 
 
 
 
 
 
 
(down) 

Effectiveness 
1.  Better  alignment  with  EU  policy 
priorities including climate action 

/ 
Options 
Specific  Objectives 
(across) 
B. Options for thematic concentration of Integrated Projects 
B1. Baseline 

B1. – Neutral:  
The  broad  scope  for  the  projects  will  not 
allow  financing  a  critical  mass  of  IP  to 
have a better alignment with EU policies. 
B2a – Good 
Concentration on limited sectors will allow 
a better alignment with EU priorities 

B2b – Excellent 
Concentration on limited sectors will allow 
a good alignment with EU priorities 

Thematic 
concentration of IP 
B2a.  Concentration 
on 3 sectors 

Thematic 
concentration of IP 
B2b.    Concentration 
on 4 sectors 

2.  Promote  the  funding  of  IP 
and 
in  LIFE 
project funded 

their  share 

Coherence 
and 
3.  Develop 
complementarity  with  other  EU 
funds 

synergies 

Efficiency 
4.  Align  selection  criteria  with  EU 
added  value 
  and  solidarity/effort 
sharing 

Simplify  and  streamline  the  LIFE 
Programme 

B1. – Good 
A  wide  scope  of  sectors  to  be 
covered 
encourage 
will 
submission of IP. 
B2a – Excellent 
IP  will  be 
Submission  of 
encouraged in few concentrated 
sectors 

B2b – Good 
Submission  of 
IP  will  be 
encouraged  but  increased  risks 
for  achieving  targets  in  a  less 
successful sector. 

B1. – Good 
Synergy  and  complementary  with 
other funds will be developed. 

B1. – Neutral 
Thematic  concentration  has  no  specific 
impact. 

B2a - Good 
Synergy  and  complementary  with 
other funds will be developed. 

B2a – Neutral 
No specific impact 

B2b – Good + 
Synergy  and  complementary  with 
other funds will be developed for 4 
sectors. 

B2b – Neutral 
No specific impact. 

is 

but 

B1. – Neutral 
Funding  of  larger  projects  is  part  of 
simplification, 
thematic 
concentration has no specific impact. 
B2a – Excellent 
of 
part 
Concentration 
simplification.  Focusing  on 
three 
sectors  will  only  require  specific 
criteria for three sectors.  
B2b – Good 
of 
Concentration 
part 
simplification.  Focusing  on 
four 
sectors  will  only  require  specific 
criteria for four sectors. 

is 

C. Options for allocation of resources between different priority areas 
C1. Baseline 

C1. – Limited 
The alignment with EU priorities will only 
be limited (for Climate Action). 

C1. Neutral 
No specific impact.  

C2. – Good 
Projects would better address EU priorities. 

C2.  Allocation  of 
25% 
the 
of 
Programme  funds  to 
climate  action  and 
50% to biodiversity 
D. Options for geographical distributional impacts (national allocations) 
D1. Baseline 

C2.- Good 
IP  will  be  promoted 
Biodiversity. 

D1. – Neutral 
Distribution  of  all  projects  based  only  on 
the  quality  of  the  application  and  their 
demonstration  value  (capacity  to  develop 
multipliers). No geographical key.  

D1. - Limited 
Small  and  less  developed  MS 
may  be  not  prepared  to  submit 
IP  and  be  discouraged  by  a 
purely merit based approach.  

C1. – Neutral 
No specific impact. 

C1. - Neutral 
No specific impact. 

C1. - Neutral 
No specific impact. 

C2.- Neutral 
No specific impact. 

in 

C2. – Good 
- Better EU added value and solidarity. 
-  New  Member  States  with  high  nature 
assets  (e.g.,  ES,  SL,  BG)  would  probably 
be favoured.  

C2. - Neutral or slightly negative 
No  specific  impact.  Ensuring  50% 
nature  may 
additional 
add 
complication to the selection. 

an 

D1. – Limited 
Based  on  quality  only.  Therefore, 
no  possibility  to  take  into  account 
the  fact  that  some  MS  will  have 
limited choice in obtaining funding 
from other EU funds.  

the  application  and 

D1. - Neutral 
-  Distribution  all  projects  based  on  the 
their 
quality  of 
capacity to develop multipliers.  
-  Prioritisation  of  transboundary  project, 
however,  no  consideration  of  solidarity 
and  effort  sharing.  Probably  IT,  ES,  DE 
will continue being most successful. 
D2. – Good 
- Traditional projects to be selected based 

D1. - Excellent 
Criteria based on EU added value will 
selection 
steps 
reduce 
procedure. 

the 

in 

D2. - Neutral or slightly negative 
Geographical  balance  may  add  an 

D2. 
Traditional 
projects  merit  only, 

D2. – Good 
Distribution  of 

integrated  projects 

to 

D2.- Good 
- Discretion by the Commission 

D2.- Good 
Discretion  by  the  Commission  to 

61 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
(down) 

/ 
Options 
Specific  Objectives 
(across) 
ensuring 
geographical  balance 
for IP 

Effectiveness 
1.  Better  alignment  with  EU  policy 
priorities including climate action 

ensure  geographical  balance  to  allow  for 
some  reflection  of  solidarity  and  effort 
sharing. Priority to transboundary projects.  

their  share 

2.  Promote  the  funding  of  IP 
and 
in  LIFE 
project funded 
to  ensure  geographical  balance 
may  encourage  small  and  less 
developed  MS  to  apply  with 
quality proposals.  
-  Flexible  and  allows 
adjustments. 

for 

synergies 

Coherence 
and 
3.  Develop 
complementarity  with  other  EU 
funds 
ensure  geographical  balance  may 
that  certain 
take 
MS/regions  cannot  obtain  funding 
from other EU funds. 

into  account 

Traditional 
D3. 
projects  merit  only 
and 
national 
allocations for IP 

based 

agreed  with  MS 

D3. – Good 
-  Distributional  allocation  pre-established 
and 
on 
environmental  needs  per  each  sector  for 
Integrated Projects.  
-  Fixed  allocations  for  the  programming 
period  may  imply  selecting  projects  that 
are  of  less  quality  than  projects  submitted 
by other MS. 

D3. – Good 
-  Existence  of  allocations  may 
encourage  all  MS  to  apply  but 
allocations may remain unused. 
- Not flexible. 

D3.- Good 
Fixed  national  allocations  may 
reflect  the  fact  that  certain  MS 
cannot  obtain  funding  from  other 
EU  funds.  However,  it  will  be 
difficult  for  MS  where  only  some 
regions are excluded. 

Simplify  and  streamline  the  LIFE 
Programme 

additional  sub-step  in  the  selection 
process. 

D3. - Negative 
Fixed  allocation  largely  increase  the 
number  of  sub-steps  in  the  selection 
process complicating and lengthening 
the selection process. 

to 

Efficiency 
4.  Align  selection  criteria  with  EU 
added  value 
  and  solidarity/effort 
sharing 
on  their  demonstration  and  replication 
transboundary 
potential.  Priority 
projects.  
- Distribution of IP to ensure geographical 
balance:  at  least  one  IP  per  MS  in  waste 
and  nature  sectors  and  at  least  one  IP  per 
transboundary RBD (Danube, Rhine, etc). 
At least two projects per bio-geographical 
region.  
-  New  Member  States  with  big  capacity 
deficiencies,  MS  with  high  nature  assets 
(e.g.,  ES,  SL,  BG)  and  MS  hosting  big 
transboundary  RBD  (FR,  HU,  DE,  AT, 
RO) would probably be favoured.  
- Flexible and allows for adjustments. 
D3. - Good 
-  Traditional  projects  selected  as  above. 
Distributional  allocation  pre-established 
and 
on 
environmental  needs  per  each  sector  for 
Integrated  Projects.  Will 
encourage 
smaller or less developed MS to apply for 
an IP.  
-  Fixed  allocations  for  the  programming 
period  may  imply  selecting  projects  that 
are of less quality than projects submitted 
by other MS.  
-Will reduce flexibility. 
-Allocation may remain unused.   

agreed  with  MS 

based 

Baseline 
NGOs, 

E. Options for funding activities under Governance and Awareness 
E1. 
Enhanced 
Commission 
communication  and 
communication 
obligations 
projects 

E1. – Neutral 
Possibility  to  carry  out  tailored  campaigns 
and  enhanced  obligations  for  NGOs  and 
communication  activities  on  projects  not 
much dependent on planning. 

in 

activities 

E1. – Good 
Possibility  to  carry  out  some 
dissemination 
to 
promote  IP  through  enhanced 
Commission 
communication 
activities  and  communication 
obligations in projects. 

E1.- Good 
Possibility to carry out disseminate 
project  results  for  mainstreaming 
under  other  EU  Funds  through 
Commission 
enhanced 
and 
communication 
in 
communication 

activities 
obligations 

62 

E1.-Good: Selection criteria for NGOs to 
favour  newly  created  and  most  active 
NGOs. 

E1 - Neutral 

 
 
  
 
 
 
 
 
 
 
(down) 

/ 
Options 
Specific  Objectives 
(across) 

Effectiveness 
1.  Better  alignment  with  EU  policy 
priorities including climate action 

E2.- Excellent 
Activities 
disseminate 
specific projects. 

specifically 
lessons 

designed 

to 
including 

learned, 

E2. Enhanced NGOs, 
Commission 
communication  and 
communication 
obligations 
in 
projects,  and  specific 
grants  projects  for 
information 
and 
communication 
F. Options for simplification 
F1. Baseline  

F1.-Good 
Package  of  measures  aligns  with  EU 
priority  of 
funding 
instruments. 

simplifying  EU 

F2 
+ 
Baseline 
Selection procedures 

F2.-Excellent 
Through  2-step  approach  the  Commission 
will  ensure  that  only  most  relevant  IP  are 
admitted to the second stage. 

2.  Promote  the  funding  of  IP 
and 
in  LIFE 
project funded 

their  share 

E2.- Excellent 
Activities  specifically  designed 
to  disseminate  lessons  learned, 
including IP examples. 

synergies 

Coherence 
and 
3.  Develop 
complementarity  with  other  EU 
funds 
projects. 
E2.- Excellent 
Activities 
projects) 
(e.g., 
specifically designed to disseminate 
lessons learned for mainstreaming. 

Efficiency 
4.  Align  selection  criteria  with  EU 
added  value 
  and  solidarity/effort 
sharing 

Simplify  and  streamline  the  LIFE 
Programme 

E2.-Good:  
Selection  criteria  for  NGOs  to  favour 
newly created and most active NGOs. 

E1.- Neutral 

F1.-Good 
Larger  projects  and  IP  part  of 
the  simplification  measures  to 
be included.  

F1.-Neutral 
No particular impact 

F1.-Neutral 
No particular impact. 

IP. 

and  promote 

F2.-Excellent 
-  2-step  approach  designed  to 
the 
facilitate 
submission 
5-page 
of 
concept  paper  instead  of  100-
200 pages proposal. Proposal in 
the  second  stage  only  focused 
on  first  2  years  and  measures 
included in the already prepared 
environmental 
plan 
(significantly  less  than  current 
proposals for 4-5 years).  
in  reporting 
-  Simplification 
also  designed 
to  promote 
submission  of  IP  (2  year  cycle 
reporting  -25%  less  than  for 
traditional  projects),  at  least  4 
payments instead of 3. 

action 

F2.-Good 
Those  IP  submitting  a  concept 
paper  where  high  synergies  with 
other EU funds are ensured will be 
admitted to the next stage.  

F2.-Good 
Through 2-step approach the Commission 
will ensure that only  most relevant  IP are 
admitted to the second stage. 

63 

F1.-Good 
-  Simplification  of  the  application 
procedure  through  ensuring  paperless 
and  more  effective  submission  and 
avoiding mistakes. 
- Funding of larger projects is part of 
simplification. 
F2.-Good+ 
-  Multiprogramming  for  NGOs  to 
limit the number of call for proposals 
and thus bidding costs.  
IT  tools  to  reduce  bidding  costs 
between 7-12% . 
Reporting obligations for IP to reduce 
reporting  obligations  by  25%  with  a 
proportional  reduction  of  reporting 
costs. 
-  2-step  approach  to  reduce  bidding 
costs  for  unsuccessful  applicants.  For 
successful applicants, savings may be 
outweighed  by 
increase  costs  for 
negotiation  with  large  number  of 
associated beneficiaries. 

 
 
  
 
 
 
 
(down) 

/ 
Options 
Specific  Objectives 
(across) 

Effectiveness 
1.  Better  alignment  with  EU  policy 
priorities including climate action 

F3- 
Payments 

Baseline+ 

F1.-Good 
No  particular  impact  compared  to  the 
baseline. 

their  share 

2.  Promote  the  funding  of  IP 
and 
in  LIFE 
project funded 
-  Ineligibility  of  certain  costs 
increased  co-
together  with 
financing  rate  designed  to  easy 
reporting  and  reduce  error  rate 
especially  in  large  projects  (as 
is the case with IP). 
F3.-Excellent 
Simplification 
reporting 
costs  because  of  reduction  of 
eligible  costs  and increased  use 
of  lump  sums  may  encourage 
submission  of 
IP.  Possible 
negative  impact  of  ineligibility 
of certain personnel costs would 
be  compensated  with  increased 
co-financing rate.  

of 

Coherence 
and 
3.  Develop 
complementarity  with  other  EU 
funds 

synergies 

Efficiency 
4.  Align  selection  criteria  with  EU 
added  value 
  and  solidarity/effort 
sharing 

Simplify  and  streamline  the  LIFE 
Programme 

F1.-Neutral 
No particular impact. 

F1.-Neutral 
No particular impact. 

F3.-Excellent 
Simplification  of 
reporting  costs 
because  of  reduction  of  eligible  costs 
and  increased  use  of  lump  sums  and 
reduction of error rate. 

The  three  options  in  economic  terms 
are rather neutral with: 
- Option 1a representing around 6.2% 
of the Programme. 
- Option 1b represents around 6.0%. 
- Hybrid will remain in between. 

G. Options for externalisation 
G1 Baseline 
G1a 
without TA 

Agency 

– 

G.1b-  Agency  with 
TA 

G1a & G1b-Neutral  
-  Programming    within  the  parent  DG 
ensuring  a  link  between  the  projects  and 
policy priorities. 
-  Solid  feedback  mechanisms  to  ensure 
project  results  feed  into  policy  making. 
Technical expertise of recruited staff make 
improve effective management and transfer 
of results and lessons learned. However, if 
also carrying out tasks normally performed 
by 
increase 
workload. 
-  Risks 
layer  of 
that  an  additional 
communication  between  projects  and  the 
parent  DGs 
transfer  of 
information  and  therefore  the  policy  link  
This  would  be  particularly  significant  for 
to  MS 
IP 
closely 
implementation  obligations  under 
the 
specific  Directives  and  require  to  close 

technical  assistance  will 

reduces 

link 

that 

the 

are 

G1.- Neutral 

IP 

G1a & G1b - Neutral 
- 
through 
promoted 
communication activities. In E1 
those  communication  activities 
will be managed by the Agency 
as per Commission guidelines. 
- However, the LIFE units have 
relationship 
expertise  based 
with the MS, which may be lost 
if  IP  were  to  be  managed  as 
well by the Agency. 

G1 - Limited or Neutral 
- The parent DG and the Agency to 
retain relation with the other funds. 
However  no  direct 
information 
from the projects.  
- If there are defaults in the transfer 
of  knowledge  between  the  Agency 
and  the  parent  DG,  the  chances  of 
building  synergies  with  the  other 
funds may be reduced. 
-  In  addition,  increased  risks  if  not 
timely spotting projects that may be 
compensatory 
to 
infrastructure  projects  that  should 
be  financed  by  the  MS  or  the 
private operator.   

measures 

64 

 
 
  
 
 
 
 
 
(down) 

/ 
Options 
Specific  Objectives 
(across) 

Effectiveness 
1.  Better  alignment  with  EU  policy 
priorities including climate action 

2.  Promote  the  funding  of  IP 
and 
in  LIFE 
project funded 

their  share 

Coherence 
and 
3.  Develop 
complementarity  with  other  EU 
funds 

synergies 

Efficiency 
4.  Align  selection  criteria  with  EU 
added  value 
  and  solidarity/effort 
sharing 

Simplify  and  streamline  the  LIFE 
Programme 

G2. Hybrid 

monitoring by the thematic units in relation 
to the achievement of policy targets, policy 
development and drawing lessons. 
G2 - Good 
As  above,  but  risks  of  loss  of  policy  link 
between the IP and policy priorities will be 
reduced.  

IP 

promote 

G2 - Neutral or a bit better  
In  both  cases,  the  Commission 
will 
through 
communication activities. In G1 
those  communication  activities 
will be managed by the Agency 
as  per  Commission  guidelines. 
However,  the  LIFE  units  have 
expertise  based 
relationship 
with the MS, which may be lost 
if  IP  were  to  be  managed  as 
well by the Agency. 

G1.- Neutral 

The  three  options  in  economic  terms 
are rather neutral with: 
- Option 1a representing around 6.2% 
of the Programme. 
- Option 1b represents around 6.0%. 
- Hybrid will remain in between. 

the  project 

of 
under 

G2 - Good 
The  parent  DGs  have  direct  access 
to IP and the other DGs so it would 
be  easier  to  transfer  information 
results  and 
about 
funds 
the 
identification 
mobilised 
EU 
other 
instruments  as  well  as  to  provide 
inputs 
to  CSF  and  Investment 
partnership  contracts  to  ensure  IP 
are  included  therein,  and  solve  any 
deadlock  situation  that  may  arise. 
IP  are  supposed  to  bring  greatest 
added  value  in  terms  of  link  with 
policy. 

65 

 
 
  
 
 
6.2. 

Comparisons  

Effectiveness 

Coherence 

Efficiency 

SO1 

SO2 

SO3 

SO4 

SO5 

Option A1: Baseline 

Option A2:  Top-down approach for all types of projects (flexible for 
traditional projects and rigid for IP) 

0 

+++ 

0 

++ 

Option  A3:  Top-down  approach  for  IP  and  bottom-up  for  other 
interventions 

++ 

++ 

Option B1: Baseline 

Option B2a: Concentration on 3 sectors 

Option B2b: Concentration on 4 sectors 

Option C1: Baseline  

Option C2: Allocation to climate action and biodiversity  

Option D1: Baseline 

Option D2 Geographical balance for IP 

Option D3: National allocations (specific amounts per MS) for 
IP  

 Option  E1:  Baseline:  Enhanced  NGOs,  Commission  activities 
and obligations for projects 

Option  E2:  Enhanced  NGOs,  Commission  communication, 
obligation 
information  and 
dissemination projects 

for  projects  AND 

specific 

Option F1: Baseline 

Option  F2:  Baseline  +  Selection  procedures:  comitology,  2 
stage procedure for IP and simplified reporting for IP 

Option F3: Baseline + Payments 

Option  G1a:  externalisation  without 
assistance 

replacing 

technical 

Option G1b: externalisation replacing technical assistance 

Option G2: Hybrid solution: externalisation of standard projects 
- keeping Integrated Projects within the Commission 

6.3. 

Preferred option 

0 

+ 

++ 

0 

++ 

0 

+ 

+ 

0 

++ 

0 

+ 

0 

0 

0 

+ 

0 

+ 

0 

0 

+ 

0 

++ 

++ 

0 

+ 

0 

+ 

+ 

0 

0 

0/+ 

0 

0 

0 

0 

0 

0/+ 

0 

0 

0 

++ 

++ 

0 

+ 

0 

+ 

0 

0 

0 

+ 

0 

++ 

+ 

0 

0 

0 

0 

+ 

0 

+ 

+ 

0 

0 

0 

+ 

0 

0 

0 

0 

0 

++ 

+ 

0 

++ 

+ 

0 

0/- 

0 

0/- 

-- 

0 

0 

0 

+ 

+ 

0 

0 

0 

Based on the above comparison of the different sub-options, the preferred option would be a 
LIFE Programme: 

• 

• 

• 

• 

With  overall  thematic  priorities  for  the  entire  programming  period  inserted  in  the 
Regulation,  a  2-3  year  work  plan  with  non  exhaustive  priorities  defined  by  the 
Commission with the advice of the Member States (Option A2). 

With Integrated Projects focussing primarily on 3 or 4 sectors (Option B2a or B2b). 

With  allocation  of  Programme  funds  to  climate  action  and  other  EU  priorities 
(biodiversity) (Option C2). 

With  a  system  to  select  traditional  projects  based  on  merit  and  a  system  to  select 
Integrated Projects that ensures geographical balance (Option D2). 

66 

 
 
  
 
 
 
• 

• 

• 

That enhances NGOs role in dissemination and different approaches for governance: 
enhanced  Commission  communication  through  public  procurement  and  specific 
dissemination and information projects financed through grants, as well as enhanced 
obligations on projects regarding dissemination and communication (Option E2).   

That uses IT-tool mechanisms for submitting proposals as well as a 2-step approach 
for Integrated Projects with 2-year cycle reporting obligations; and increases the use 
of lump sums, and simplifies eligibility of costs by restricting the eligibility of some 
costs (a combination of Options F). 

With externalisation of the management of traditional projects to an existing agency 
while  keeping  the  governance  of  the  Programme  within  the  parent  DG  (including 
comitology  and  programming)  as  well  as  the  management  of  Integrated  Projects. 
Based on an evaluation to be carried out at the end of the first programming period, 
the management of these projects could be progressively externalised (Option G2). 

The  preferred  option  will  address  efficiently  the  main  recommendations  for  improvement 
from  the  mid-term  evaluation,  in  terms  of  better  thematic  prioritisation  of  the  Programme, 
simplification and good management. Synergies with other EU Funds would be significantly 
developed,  both  from  the  Commission's  and  national  authorities’  points  of  view,  ensuring  a 
better use of available funds for environment and climate policies. 

Finally, this option will generate around €900-1,210  million/year  of environmental benefits, 
and savings of between 7-12% of bidding costs and 25% for reporting obligations.  

7. 

MONITORING AND EVALUATION 

The mid-term evaluation considered current monitoring and evaluation largely effective and 
efficient.  However,  more  focus  on  results  was  desirable.  The  monitoring  framework  thus 
builds on the framework proposed for the current instrument44 but is revised according to both 
the  new  intervention  logic  and  the  changes  made  to  the  baseline  scenario  in  the  preferred 
option.  Since  there  is  no  change  in  the  activities  undertaken  under  the  public  procurement 
budget, the framework does not include these activities. The framework is organised around 
two levels: 
1. Monitoring of outputs, results and impacts, at project and Programme level 

At  project  level,  as  is  the  case  now,  projects  will  have  to  accompany  their  proposals  with 
expected outputs tables. They will be submitted with the proposal and will serve as basis for 
monitoring  of  progress.  Some  of  the  output  indicators  currently  used,  especially  for  the 
environmental part, will be adapted to reflect the new features of the Programme. The updated 
output tables will be submitted with the mid-term and final reports. The after-LIFE plans will 
include a list of expected impacts that will serve as a basis to assess the sustainability of the 
project  results.  Current  practice  of  ex-post  monitoring  visits  for  selected  projects  will 
continue.   

At  programme  level,  thematic  reports  summarising  the  main  achievements  for  a  particular 
sector will be developed periodically (e.g., every two years after the end of the rolling plan). 
They  will  also  serve  as  a  basis  for  disseminating  results  and  feed  them  into  policy 
development and implementation. The practice of organising yearly conference focusing on a 
sector will continue. A mid-term evaluation and an ex-post evaluation of the Programme will 
also be carried out. However, it is important that the mid-term evaluation is carried out when 

44 

Proposed monitoring and evaluation framework for the LIFE+ Regulation, DG Environment, 2007 

67 

 
 
  
 
                                                 
there  are  already  some  project  results.  Annex  10  develops  the  relationship  between  output 
indicators (and other indicators) and the objectives.  

2. Tracking of expenditure at programme level 

In order to provide evidence of the co-benefits that both sub-programmes can bring to specific 
priorities  such  as  climate  action  and  biodiversity,  and  better  illustrate  the  level  of  spending 
available throughout the Programme for these priorities, the monitoring framework will also 
include  the  methodology  for  tracking  of  climate  and  biodiversity-related  expenditure  as 
defined in the June 2011 MFF Communication and derived from the OECD "Rio markers".   

In  relation  to  climate  action,  the  MFF  Communication  stated  that  mainstreaming  of  climate 
action must be visible, robust and accompanied by a clear cross-cutting obligation to identify 
where the Budget promotes climate action or energy efficiency so that the EU is able to set 
out clearly how much of its spending relates to climate action, by using a common tracking 
procedure for climate related expenditure.   

Tracking  of  climate-related  expenditure  will  be  performed  according  to  three  categories, 
based  on  an  established  OECD  methodology  ("Rio  markers"):  expenditure  where  climate  is 
the principal (primary) objective (counted as 100% - climate related only); expenditure where 
climate is significant, but not predominant objective (counted as 40% - significantly climate- 
related);  and  expenditure  not  targeted  to  climate  objectives  (counted  as  0%  -  not  climate 
related).  

As regards biodiversity, the 'Rio markers' established by the OECD and already used by the 
Commission  for  external  instruments  will  be  integrated  in  the  existing  methodology  for 
measuring performance used for EU programmes. They will also help to demonstrate the co-
benefits of climate and biodiversity expenditures, and to highlight the biodiversity co-benefits 
of  climate  spending  on  REDD+  (Reducing  Emissions  from  Deforestation  and  Forest 
Degradation) actions.  

Better  tracking  of  climate  and  biodiversity  expenditure  could  be  possible  by  applying  “Rio 
markers”  for  instance  also  at  project  level.  This  could  be  done  by  continuing  the  current 
practice of including in the call for proposals an option for applicants to indicate whether their 
proposal  could  be  considered  climate  or  biodiversity-related  according  to  the  OECD 
methodology.  This  would  allow  identifying  each  year  the  expenditure  dedicated  to  the  two 
priorities by the entire Programme beside the 50% earmarked resources to biodiversiy under 
the  Environment  sub-programme  and  25%  earmarked  resources  for  Climate  Action  sub-
programme under LIFE.  

68 

 
 
  
 
8. 

(1) 

(2) 

(3) 

(4) 

(5) 

(6) 

(7) 

(8) 

(9) 

ANNEXES 

List of Abbreviations  

The LIFE Programme as per the Communication from the Commission on a Budget 
for Europe 2020, 29th June 2011 

Summary of Stakeholders' consultations  

Summary  of  conclusions  and  recommendations  from  the  Ex-post  evaluation  of  the 
the 
LIFE  Programme  (1996-2006)  and  from 
implementation of the LIFE+ Regulation (2007-2009) 

the  Mid-term  evaluation  of 

Scale  of  the  environmental  problem,  underlying  causes  and  benefits  of  action 
(externalities) 

Examples illustrating the EU added value of the LIFE Programme  

Assessment  of  the  LIFE+  Regulation:  data  used  to  calculate  the  impacts  of  the 
baseline scenario 

Full assessment of the zero option and of the expanded option 

Calculation of externals costs  

(10) 

Objectives and Monitoring framework 

(11) 

Integrated Projects 

(12) 

References 

69