COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Improving the delivery of benefits from EU environment measures: building confidence through better knowledge and responsiveness
Date: 2012-03-07
Institutions: European Commission
Subjects: administrative sanction, application of EU law, application of the law, dissemination of EU information, environmental law, environmental statistics

EUROPEAN COMMISSION 

Brussels, 7.3.2012  
COM(2012) 95 final 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

Improving the delivery of benefits from EU environment measures: building confidence 
through better knowledge and responsiveness 

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   EN 

 
 
 
 
  
 
COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

Improving the delivery of benefits from EU environment measures: building confidence 
through better knowledge and responsiveness 

Introduction 

The ideas set out in this Communication respond to the December 2010 Environment Council 
request  that  the  Member  States  and  Commission  enhance  and  improve  the  implementation 
and  enforcement  of  EU  environment  legislation  in  order  to  improve  the  state  of  the 
environment and ensure a level playing field.  

The 2008 and 2011 Eurobarometer opinion poll on attitudes of European citizens towards the 
environment confirmed that for most citizens a healthy environment is as important to their 
quality of life as the state of the economy and social factors. 

However, the 2010 European Environment State and Outlook of the European Environment 
Agency  (EEA),  confirms  that  "the  EU  appears  to  be  locked  in  a  number  of  status-quo  and 
downward trends which are moving away from, rather than toward, sustainability".  

How  can  we  begin  to  reverse  these  trends?  With  the  exception  of  soil,  our  environment  is 
already the subject of extensive EU environment legislation, much of it long-established, so 
the main challenge is now one of effective implementation.  

Two issues stand out: the extent of our knowledge about the state of the environment and how 
it is safeguarded; and effective ways of dealing with problems on the ground.  

Knowledge  is  already  extensive  on  matters  such  as  urban  air  pollution  levels  and  bathing 
water quality. In others, such as biodiversity and land-use, it is patchier. Moreover, the picture 
is  difficult  to  fill  in  if  we  want  to  know  precisely  how  implementation  is  undertaken  in  a 
region, city or village. While often helpful, complaints sent to the Commission and petitions 
submitted to the European Parliament are an incomplete source of information.  

Analysis  and  consultation  conducted  in  the  framework  of  the  preparations  for  a  7th 
improving 
Environmental  Action  Programme  clearly 
implementation  can  be  considered  a  priority  objective  of  European  environment  policy  in 
itself.  The  ambition  of  this  communication  is  to  examine  means  of  helping  Member  States 
achieve  a  fully  systematic  approach  in  knowledge  collection  and  dissemination  and  greater 
responsiveness  to  problems  on  the  ground.  Effective  access  to  justice  is  necessary  but  not 
sufficient,  so  it  is  proposed  to  also  look  at  inspections  and  surveillance,  complaint 
mechanisms and formalising partnerships to ensure implementation.  

that  enhancing  and 

show 

The  ideas  presented  aim  at  complementing  the  content  of  a  2008  communication  on  the 
subject1  and,  while  focused  on  the  specificities  of  environment  law  as  underlined  by  the 

1 

COM(2008) 773 final 

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Aarhus  Convention2,  draw  inspiration  from  the  2007  Communication,  "A  Europe  of 
Results"3, which stresses the importance of increased transparency at EU level and observes 
that  "complainants  could  in  some  cases  enforce  their  rights  directly  at  national  level  in  a 
more efficient way." 4 

The  response  to  the  present  Communication  will  feed  into  the  preparations  for  the  7th 
Environmental Action Programme. It may also lead to specific measures being proposed by 
the Commission underpinned by impact assessments where necessary. When legislation aims 
at  other  objectives  in  addition  to  the  environmental  ones  (e.g.  energy  legislation),  the 
proposals set out here might need to be supplemented by specific provisions, in particular on 
relations with certain stakeholders.  

Why good implementation matters 

Delayed or inadequate implementation has many negative consequences. It ultimately harms 
the environment and human health, generates regulatory uncertainty for industry and puts in 
question the level playing field of the Single Market. The long-term remediation costs – for 
example for clean-up of illegal waste sites and restoration of damaged habitats – can be much 
higher than the costs of prevention. 

The costs of not implementing current legislation are broadly estimated at around €50 billion 
a year5. These relate not just to environmental but also to human health impacts. For example, 
20  %  -  50  %  of  the  European  population  lives  in  areas  where  the  air  quality  breaches 
European limit values and the estimated annual costs in terms of health expenditure or days of 
work lost run to billions of Euros.  

In  terms  of  benefits,  the  Europe  2020  strategy  observes  that  new  sources  of  growth  depend 
critically  on  investing  in  knowledge  and  innovation.  As  the  EU  environment  industry  is 
estimated  to  have  an  annual  turnover  in  excess  of  €300  billio n,  uncertainty  about 
implementation possibilities, pathways and time-frames may carry significant costs in terms 
of missed opportunities6.  

More  specifically,  full  implementation  of  EU  waste  legislation  is  estimated  to  generate 
400,000 jobs and have net costs that are €72 billi on per year lower than under the alternative 
scenario of non-implementation7.  

At  the  same  time,  innovative  or  improved  implementation  methods  offer  the  prospect  of 
reduced  administrative  burden  and  a  more  level  playing  field  by  making  decision-making 
better informed as well as more rigorous, predictable and coherent. 

Why the EU needs to improve knowledge on implementation  

2 

3 
4 

5 
6 
7 

Convention on  access  to  information,  public  participation  in  decision-making  and  access  to  justice  in 
environmental matters 
COM(2007) 502, final 
These ideas will be shared with the enlargement countries so that they can make use of them to plan for 
and improve implementation from the start of alignment with the environment acquis 
"The costs of not implementing the environmental acquis", COWI, 2011.  
Ibid.  
"Implementing EU Waste Legislation for Green Growth", Bio Intelligence Service, 2011 

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Knowledge about implementation covers, on the one hand, the state of the environment and, 
on  the  other,  all  the  required  administrative  and  other  measures  intended  to  protect  and 
improve it.  

EU  environment  laws  contain  rules  that  generate  information,  for  example  air  quality 
monitoring requirements, as well as rules that require information to be made available to the 
wider public.  

During  the  past  ten  years  the  way  in  which  knowledge  is  structured  and  used  has  been 
strengthened, thanks in part to a revision of the Access to Information Directive8, the adoption 
of the INSPIRE Directive9, work pursuant to the 2008 Commission Communication Towards 
a  Shared  Environmental  Information  System  (SEIS)10  and  increased  use  of  information  and 
communication  technologies  (ICT)  at  EU  and  national  levels.  However,  knowledge  about 
implementation remains problematical.  

For  example,  it  is  not  always  simple  to  identify  quickly  the  provisions  of  national  law  that 
correspond to a given provision of a directive. Monitoring efforts are uneven across Europe 
and the information generated is patchy and often out-of-date. Environmental information is 
available through individual requests rather than systematically published.  

Better information at national, regional and local level would allow identification of the main 
problems and the most appropriate and efficient ways to address them. Greater application of 
the SEIS principle of "report once, use often" would help streamline information demands.  

Improving knowledge on implementation 

The chief responsibility for implementation lies within Member States and this is where the 
greatest  environmental  information  needs  and  expectations  of  citizens,  administrations  and 
businesses arise. Meeting these requires information systems to be set up by Member States 
that  generate,  manage  and  communicate  information  that  shows  how  EU  laws  are 
implemented  and  complied  with  in  practice11.  The  information  concerned  must  cover  the 
physical state of the environment as well as administrative measures, stable elements12 as well 
as  dynamic  ones13.  It  needs  to  serve  different  end-users,  helping  competent  authorities  to 
manage their tasks, monitoring bodies to verify compliance and the public to understand how 
they  and  their  environment  are  protected.  This  only  works  if  there  is  close  collaboration 
between  environmental  scientists,  statisticians,  ICT  experts  and  administrators  in  order  to 
deliver information that is, on the one hand, scientifically and legally robust and, on the other, 
meaningful to the general public, experts and policy-makers. Finally, the Aarhus Convention 
envisages progressive improvement in online environmental information.  

8 

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10 
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12 
13 

Directive  2003/4/EC  on  public  access  to  environmental  information  and  repealing  Council  Directive 
90/313/EEC, OJL 41, 14.2.2003 
Directive 2007/2/EC establishing an Infrastructure for Spatial Information in the European Community 
(INSPIRE), OJL 108, 25.4.2007 
COM(2008)46 final, 1.2.2008 
With  regard  to  the  transposition  of  directives  into  national  law  see  Joint  Political  Declaration  of  27 
October 2011 of the European Parliament, the Council and the Commission on explanatory documents, 
OJC 369, 17.12.2011. 
Such as the location of designated areas. 
Such as monitoring data. 

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The objectives described below aim at examining how to engage more actively with Member 
States  so  that  they  put  in  place  effective  information  systems;  providing  better  aggregated 
information  at  EU  level;  ensuring  confidence  in  the  information  generated  as  a  whole;  and 
helping Member States to address data gaps and more effectively monitor land-cover changes.  

Objective: Engaging with Member States to put in place more effective information systems 
on implementation 

For  all  key  EU  obligations  in  the  environmental  field,  an  information  system  should  be  in 
place  that  would  allow  implementation  to  be  tracked  in  the  most  efficient  and  timely  way 
possible, in line with the Aarhus Convention.  

By  way  of  illustration,  for  the  many  thousands  of  industrial  and  other  installations  across 
Europe  subject  to  specific  controls,  it  would  be  appropriate  to  have  information  online 
relating  to  the  key  environmental  provisions  applicable.  For  example,  this  would  allow  all 
categories  of  user  to  check  easily  via  an  internet  portal  and  an  interactive  map  whether  a 
specific facility has an authorisation and whether any problems identified by monitoring data 
or otherwise are being addressed.  

The  Access  to  Information  Directive  already  contains  minimum  requirements  on  active  and 
systematic dissemination of information as well as a general duty to ensure that information is 
up-to-date,  accurate  and  comparable14.  However,  until  now,  these  provisions  have  not  been 
systematically linked to information on implementation of and compliance with individual EU 
environment laws.  

The Commission will assess 

• 

• 

• 

How  the  effectiveness  of  the  Access  to  Information  Directive  could  be  enhanced. 
Options 
include  development  of  best-practice  guidance  and/or  proposed 
strengthening of the existing provisions.  

The  feasibility  for  Member  States,  with  support  from  the  Commission,  to  develop 
structured  implementation  and  information  frameworks  (SIIFs)  for  all  key  EU 
environment  laws.  These  would  be  designed  to  clarify  the  main  provisions  of  a 
directive as well as identify the types of information needed to demonstrate how EU 
law is being implemented on the ground. SIIFs would be aimed at existing legislation 
and, together with initiatives under SEIS, would guide the development by Member 
States of information systems that track implementation on the ground on a constant 
basis. 

How  EU  funding  could  be  used  for  the  development,  upgrading  and  deployment 
within  Member  States  of  relevant  interoperable  information  systems  and  related 
training.  

Objective: Improve EU-level information 

Improved  information  systems  within  Member  States  would  need  to  be  complemented  by 
better  EU-wide  overviews  to  demonstrate  a  level  playing  field.  The  EEA  has  developed, 

14 

Articles 7 and 8  

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together with the statistical office of the European Union (Eurostat) and Joint Research Centre 
(JRC), an increasing role in processing monitoring and other data reported by Member States 
to  the  Commission.  For  example,  the  Commission's  annual  bathing  water  quality  report, 
which  is  prepared  with  the  support  of  the  EEA,  provides  a  comprehensive  overview  using 
geo-referenced  data  for  more  than  21,000  bathing  waters  across  Europe.  An  internet  site 
allows users to download data and check interactive maps, from the European level down to 
individual places. Pilot exercises involving the EEA are under development on air quality and 
waste to enhance overall implementation.  

The Commission will examine 

• 

• 

How the public could be provided with systematic and improved online information 
on  implementation,  including  through  the  use  of  transparent  monitoring  tools  and 
benchmarks.  

How  to  continue  the  work  with  Member  States  to  extend  the  approach  used  in  the 
Bathing  Water  Directive  across  all  relevant  EU  environment  laws  and  in 
collaboration with the EEA where appropriate.  

Objective:  Help  ensure  confidence  in  the  information  generated  at  national,  regional  and 
local levels 

Confidence  in  EU  environment  legislation  depends  on  an  equivalence  of  effort  across 
Member States in the extent and reliability of state-of-the-environment monitoring and other 
exercises that generate information. Given its evolving role in environmental data processing 
and validation, the EEA is well placed to help. 

The Commission plans to continue working with the EEA, in line with its statutory remit, so 
that the Agency can  

• 

• 

the  Commission 

the  quality  of  state-of-the-environment 
Assist 
monitoring arrangements at national level, examining monitoring systems to ensure 
that  they  are  broadly  comparable,  fit-for-purpose  and  adequately  focused  on  the 
greatest risks.  

in  assuring 

Carry  out  other  tasks  related  to  providing  information  on  implementation  of  EU 
environment measures.  

Objective: Close important information gaps on compliance promotion and enforcement, and 
land-cover monitoring  

There is a lack of data on the compliance and enforcement work being undertaken at national 
level  by  inspectors,  prosecutors  and  courts.  This  means  that  choices  between  different 
approaches  to  compliance,  including  potentially  promising  complementary  ones  involving 
incentives, are not facilitated.  

Monitoring  and  responding  to  land-cover  changes  is  central  to  the  success  of  much  EU 
environment  legislation  such  as  the  control  of  illegal  waste  operations  and  management  of 
rare  habitats.  Technological  advances,  as 
techniques,  provide 
opportunities,  including  o  in  terms  of  reduced  monitoring  costs  that  are  not  yet  being 
systematically exploited.  

in  earth-observation 

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The Commission considers that improvements could be achieved through:  

• 

• 

Working  with  Member  States  and  opening  a  dialogue  with  key  networks  of 
inspectors,  prosecutors  and  judges  in  order  to  identify  the  crucial  categories  of 
information and best means of collecting and collating data. 

An initiative on the use by Member States of earth observation techniques to extend 
the effectiveness of implementation monitoring on the ground. 

Why the EU needs to improve responsiveness at national, regional and local levels 

Improved knowledge will contribute to better delivery but it is not enough on its own. A key 
responsibility  is  implementation  monitoring  provided  through  bodies  and  persons  who  have 
duties  and/or  powers  and  rights  to  enquire  into,  oversee,  verify,  advise  or  ensure 
accountability  in  respect  of  compliance  obligations.  These  include  national  inspectors, 
ombudsmen,  prosecutors,  courts,  auditors  and  NGOs  and  citizens  exercising  participatory 
rights  and  submitting  representations.  At  EU  level,  the  Commission,  Parliament,  Court  of 
Justice, European Ombudsman and EEA all exercise relevant roles.  

As  guardian  of  the  Treaties,  the  Commission  uses  its  enforcement  powers  to  address  an 
absence of required end-results. However, the high number of infringements, complaints and 
petitions  related  to  EU  environment  legislation  points  to  a  need  generally  to  reinforce 
implementation monitoring within Member States.  

Improving responsiveness at national, regional and local levels 

The  Commission  proposes  to  examine  a  suite  of  initiatives  which  could  address  this 
challenge.  Although  the  initiatives  can  stand  individually  on  their  own  merits,  they  are 
complementary and will be more effective in combination. For example, improved access to 
justice without improved complaint-handling may leave citizens frustrated in situations where 
they do not wish to go to court.  

Objective: Improve the inspections and surveillance applying to EU legislation  

that 

includes 

framework 

Inspections  and  surveillance  at  national  level  are  important  in  ensuring  trust  in  the 
requirements of EU environment legislation. Inspections of industrial facilities already benefit 
from  a 
in 
the  minimum 
Recommendation  2001/331/EC15  and  binding  sectoral  provisions.  However,  beyond  the 
domain of industrial facilities, the full range of activities having a potential significant adverse 
impact  on  the  environment  –  from  groundwater  abstraction  to  trade  in  protected  species  – 
would benefit from additional provisions on inspections and surveillance, to make these more 
streamlined  and  risk-based,  for  instance.  Given  the  cross-cutting  nature  of  EU  environment 
law – for example, as between water and nature legislation – such an approach should include 
full coherence and coordination amongst competent national authorities. 

inspection  criteria  contained 

The  context  for  addressing  inspections  and  surveillance  at  national  level  also  includes 
demands  to  secure  a  level  playing  field  and  the  necessary  degree  of  cooperation  and 

15 

Recommendation  2001/331/EC  providing  for  minimum  criteria  for  environmental  inspections  in 
Member States, OJL 118, 27.4.2001 

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consistency on issues having a trans-frontier character with a view to improving mutual trust 
between Member States.  

The Commission considers that improvements may be appropriate by 

• 

• 

• 

Upgrading the existing framework for inspections and surveillance  

Assessing,  for  all  new  legislation,  the  value  of  including  specific  inspection  and 
surveillance  provisions,  taking  into  account  the  experience  with  existing  binding 
provisions; 

Assessing  options  for  complementing  national  inspections  and  surveillance  in  a 
targeted way at EU level, including  

• 

• 

An EU-level inspection and surveillance capacity;  

Limited  inspection  role  for  the  Commission  that  respect  Member  States' 
administrative autonomy, the Ozone Regulation16 offering a possible model, or 
powers  to  audit  Member  State  inspections  as  provided  for  in  the  Animal 
Experiments Directive17;  

•  More systematic use of peer-review inspections, drawing on existing initiatives 

of IMPEL (the network of national inspectors); 

• 

Arrangements  for  independent  expert  input  on  an  ad  hoc  basis  to  address 
situations that present very particular implementation challenges. 

Objective: Better complaint-handling and mediation at national level  

There  is  currently  no  general  framework  on  how  competent  authorities  should  respond  to 
complaints at national level. A dual approach addressing direct and review-stage complaint-
handling  would  make  it  more  likely  that  concerns  and  grievances  will  be  dealt  with  in  a 
consistent way and sooner rather than later.  

Complaint-handling systems can improve the inter-action between citizens and authorities but 
there  may  be  situations  in  which  mediation  or  other  similar  dispute  resolution  mechanisms 
will add a further useful dimension.  

Improvements  in  complaint-handling  at  national  level  would  in  no  way  affect  the  right  to 
complain to the Commission but should reduce the citizen frustration that can arise when EU 
institutions are asked to make up for a lack of national remedies. Such improvements would 
also be consistent with a recent trend in other EU policies, notably consumer legislation18, to 
make specific provision for grievance and dispute settlement at national level. 

16 
17 

18 

Regulation (EC) 1005/2009 on substances that deplete the ozone layer, OJL 286, 31.10.2009 
Directive  2010/63/EU  on  the  protection  of  animals  used  for  experimental  purposes,  OJL  276, 
20.10.2010 
Directive  2009/72/EC  of  the  European  Parliament  and  of  the  Council  of  13  July  2009  concerning 
common  rules  for  the  internal  market  in  electricity  and  repealing  Directive  2003/54/EC,  OJL  211, 
14.8.2009  

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The  Commission  considers  it  worthwhile  to  explore  an  initiative  designed  to  improve  the 
handling by Member States of complaints. This initiative might involve, for example, binding 
general  criteria  or  non-binding  general  criteria  complemented  by  sector-specific  binding 
provisions and would cover:  

Complaints focusing on the need for competent authority intervention. EU complaint-handling 
criteria  would  aim  at  a  level  playing  field  in  terms  of  the  responsiveness  by  competent 
authorities and provide general safeguards on matters such as confidentiality, record-keeping 
and timeliness.  

Complaints  focusing  on  claims  of  administrative  inaction  or  inadequacy.  EU  complaint-
handling criteria would aim to provide citizens with a means of bringing their dissatisfaction 
to  the  attention  of  an  independent  national  administrative  review  body  such  as  an 
ombudsman.  

Complaints for which mediation or some other similar dispute resolution mechanism may be 
appropriate.  EU  criteria  would  make  provision  for  such  a  mechanism  to  cover  situations 
where the parties see mutual advantage in an amicable resolution.  

Objective: Improve access to justice.  

Specific provisions aimed at ensuring reasonable access to justice are currently restricted to a 
few areas of EU environment law. A 2003 Commission proposal19 aimed at facilitating wider 
access has not progressed but the wider context has changed, in particular the Court of Justice 
has  confirmed  recently  that  national  courts  must  interpret  access  to  justice  rules  in  a  way 
which  is  compliant  with  the  Aarhus  Convention20.  National  courts  and  economic  as  well  as 
environmental interests face uncertainty in addressing this challenge.  

The Commission considers it appropriate to explore how greater certainty could be provided 
for national courts and economic and environmental interests. Possibilities include: 

• 

• 

Developing guidance to take account of a significant recent body of case-law in order 
to improve implementation of existing access to justice provisions21 as well as 

Defining  at  EU  level  the  conditions  for  efficient  as  well  as  effective  access  to 
national courts in respect of all areas of EU environment law.  

Objective:  Deliver  improvements  in  environmental  outcomes  through  capacity-building  and 
implementation agreements that engage Member States  

At  European  level,  networks  have  been  created  by  ombudsmen,  environment  agencies, 
inspectors,  lawyers  working  with  governments,  judges  and  prosecutors.  However,  despite  a 
number  of  initiatives,  the  potential  of  cooperation  has  not  been  fully  realised  across  all 
networks. Challenges include ensuring that networks have the necessary secretariat stability to 
function effectively over extended time-periods and identifying and undertaking projects and 
initiatives that help network members and facilitate implementation.  

19 
20 
21 

COM(2003)624 final 
Case C-240/09  
Directive 2003/35/EC 

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Networks  may  be  useful  within  Member  States,  too,  for  example  to  better  involve  regional 
and local government in implementation. Linking national inspectors or prosecutors can also 
make a significant contribution22.  

Where problems emerge, there is a need for clear commitments from Member States to put in 
place  measures,  with  benchmarks  and  timelines,  to  deliver  the  required  results.  These 
commitments  need  to  be  formalised  and  publicly  available,  so  that  Member  States,  the 
European  Parliament,  businesses  and  citizens  can  have  confidence  that  their  concerns  are 
being  addressed  within  a  structured  framework.  This  challenge  could  be  addressed  through 
partnership  implementation  agreements  designed  to  help  deliver  improved  environmental 
outcomes. 

The Commission considers that improvements could be achieved through  

• 

• 

• 

Active cooperation with EU networks, focusing on their distinct roles and strengths 
avoiding  duplication  and  facilitating  trans-network  communication.  The  outputs  of 
cooperation  will  respect  the  autonomous  roles  of  both  the  Commission  and  the 
networks. They might cover support for training of prosecutors and investigators as 
well as judges. Possible new outputs of such networks include : 

• 

• 

• 

• 

• 

information  on  successful  complementary  approaches  to  compliance  and 
enforcement;  

advice or other forms of assistance to national ombudsmen on investigation of 
complaints related to EU environment law;  

suggested  criteria  for  employing  administrative  and  criminal  sanctions  in  the 
case of prosecutors;  

advice  on  how  to  close  data  gaps  on  compliance  promotion  and  enforcement 
work at national level;  

general advice on the implementability and enforceability of EU environment 
proposals.  

Co-organisation of events and conferences on implementation with the Committee of 
the Regions and creation of a technical platform for co-operation on the environment 
along the lines of the platform already established on health 

Implementation  agreements  that  commit,  without  prejudice  to  the  provisions  of  the 
Treaties  and  the  Commission's  role  as  guardian  of  the  Treaties,  Member  States  to 
actions  having  either  the  preventive  aim  of  strengthening  the  capacity  to  deliver 
effective  implementation  or,  where  appropriate,  the  remedial  aim  of  resolving 
specific  problems  through  targeted  action.  Partnership  implementation  agreements 
could proactively direct EU assistance towards improved implementation structures 
within Member States and might be linked to other initiatives in this Communication, 
such  as  effective 
information  systems,  complaint-handling  mechanisms  and 
inspections.  They  could  also,  on  a  case  by  case  basis,  endorse  Member  State 

22 

Examples from Ireland and the Flemish Region of Belgium may be cited. 

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remedial  plans  to  resolve  specific  problems  through  targeted  and  adequately-
resourced programmes of work featuring milestones, guarantees of transparency and 
other safeguards.  

Conclusion  

This communication supplements the previously mentioned 2007 and 2008 communications 
by  developing  ideas  primarily  aimed  at  providing  Member  States  with  better  tools  for 
improving implementation on the ground.  

Knowledge and responsiveness are complementary facets of implementation. To give just one 
example, better knowledge can enable customs authorities to deploy better control strategies 
for illegal trade in waste and endangered species  

Implementation has a cost. But the cost of non-implementation is very often much higher, and 
therefore taking the steps proposed in this communication represents a sound investment not 
only for the future but also for the present.  

This Communication is addressed to the European Parliament, Member States, their citizens 
and  all  actors  in  the  area  of  implementation  and  enforcement  of  environment  law.  The  7th 
Environmental  Action  Programme  should  ensure  a  proper  follow  up  and  specific  measures 
will be subject to impact assessment. 

EN 

11 

   EN