Has the environment component of the LIFE programme been effective? Special Report No 15, 2013.
Date: 2014-01-29
Institutions: European Court of Auditors
Subjects: EU Member State, EU environmental policy, EU programme, audit, environmental protection, financing, innovation, project evaluation

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HAS THE ENVIRONMENT COMPONENT 
OF THE LIFE PROGRAMME BEEN 
EFFECTIVE?

EN

 
 
 
 
Special Report No 15 

 2013

HAS THE ENVIRONMENT 
COMPONENT OF THE LIFE 
PROGRAMME BEEN EFFECTIVE?

(pursuant to Article 287(4), second subparagraph, TFEU)

EUROPEAN COURT OF AUDITORS

EUROPEAN COURT OF AUDITORS
12, rue Alcide De Gasperi
1615 Luxembourg
LUXEMBOURG

Tel. +352 4398-1
Fax +352 4398-46410
E-mail: eca-info@eca.europa.eu
Internet: http://eca.europa.eu

Special Report No 15 

 2013

More information on the European Union is available on the Internet (http://europa.eu).

Cataloguing data can be found at the end of this publication.
Luxembourg: Publications Office of the European Union, 2013

ISBN 978-92-9241-497-9
doi:10.2865/75865

© European Union, 2013
Reproduction is authorised provided the source is acknowledged.

Printed in Luxembourg

3

CONTENTS

Paragraph

GLOSSARY AND ABBREVIATIONS

I – V 

EXECUTIVE SUMMARY

1 – 6 

INTRODUCTION

1 – 2 

FUNDING THE ENVIRONMENT IN THE EU

3 – 6 

THE LIFE PROGRAMME

7 – 12 

AUDIT SCOPE AND APPROACH

13 – 63 

OBSERVATIONS

13 – 38 

PART I — DESIGN 

13 – 16 

 THE LARGE NUMBER OF OBJECTIVES OF THE PROGRAMME WAS NOT CONSISTENT WITH THE LIMITED BUDGET 
AVAILABLE

17 – 21 

THE NATIONAL ALLOCATIONS HAMPERED COMPETITION AMONG PROJECT PROPOSALS 

22 – 28 

 THE TEMPLATES USED TO EVALUATE PROJECT PROPOSALS DID NOT REQUIRE ENOUGH JUSTIFICATION OF THE 
EVALUATION RESULTS, WHICH UNDERMINED TRANSPARENCY IN THE SELECTION PROCESS 

29 – 38 

 THE MONITORING FRAMEWORK WAS NOT APPROPRIATE AND THIS HAMPERED EFFICIENT PROGRAMME 
MANAGEMENT

39 – 63 

PART II — IMPLEMENTATION

41 

KEY ASPECTS OF THE PROJECTS WERE NOT ALWAYS APPROPRIATELY ASSESSED DURING PROJECT SELECTION 

42 – 49 

THE COMMISSION’S MONITORING OF PROJECT IMPLEMENTATION WAS INSUFFICIENT IN SOME RESPECTS 

50 – 63 

 LOW DISSEMINATION, SUSTAINABILITY AND REPLICATION OF PROJECTS JEOPARDISED THE ‘CATALYTIC’ ROLE 
EXPECTED FROM THE PROGRAMME 

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

 
4

64 – 72 

CONCLUSIONS AND RECOMMENDATIONS

ANNEX I  —  THE SELECTION PROCESS

ANNEX II  —  ECA ASSESSMENT OF THE SAMPLE OF PROJECTS VISITED

REPLY OF THE COMMISSION

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

 
 
GLOSSARY AND ABBREVIATIONS

5

Catalyst: An agent that stimulates or precipitates a reaction, development or change.

Centralised management by the European Commission:
-  Direct: The budget implementation tasks are performed directly by Commission departments.
- 
Indirect: The Commission entrusts tasks of public authority, and in particular budget implementation, to 
agencies created by the Commission (executive agencies), traditional agencies or joint undertakings, other 
bodies such as the European Investment Bank or the European Investment Fund, national public-sector bodies 
or bodies governed by private law with a public service mission (so-called ‘national agencies’).

DG Environment: Directorate-General for the Environment of the European Commission.

Effectiveness: Achieving the objectives set.

Environment action programmes (EAPs): These are adopted by the European Parliament and the Council 
and set out the EU’s key environmental objectives and priorities. They are multiannual and aim to identify the 
EU’s major environmental challenges, to set objectives and to provide guidelines.

The EU’s first EAP dates back to 1973. The sixth EAP expired in mid-2012. The European Commission has pro-
posed a new EAP (the seventh), entitled ‘Living well, within the limits of our planet’, which will be considered 
through the ordinary legislative procedure by the European Parliament and the Council of the European Union.

EU: European Union.

EU interest: In the context of LIFE ‘Environment’ projects, a synonym for European added value. EU interest 
means contributing to the achievement of the general objectives of EU environmental policy, by targeting 
a problem with significant importance at European level or expecting to generate results that would be widely 
applicable.

Impact: The positive and negative, primary and secondary long-term effect produced by an intervention, 
directly or indirectly, intended or unintended.

Impact assessment: The assessment of the economic, social and environmental consequences of policy and 
legislative proposals. It is a tool to ensure that Commission initiatives and EU legislation are prepared on the 
basis of transparent, comprehensive and balanced evidence.

Indicator: Quantitative or qualitative factor or variable that provides simple and reliable means to measure 
achievement, to reflect the changes connected to an intervention or to help assess the performance. Indicators 
should be relevant, accepted, credible, easy and robust (‘RACER’ criteria).

(a)   Input  indicators:  These  measure  the  quantity,  quality  and  timeliness  of  resources  provided  for  an 

intervention.

(b)   Output indicators: These measure deliverables created or provided by the intervention. They provide infor-

mation to assess the efficient use of inputs.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

6

(c)   Outcomes indicators: Result and impact indicators

- 

- 

 Result indicators: These measure the immediate or short-term results of the implementation of the inter-
vention. They provide key information on the extent to which an intervention achieves its objectives.

 Impact indicators: These measure positive and negative, primary and secondary longer-term effects pro -
duced by an intervention, directly or indirectly, intended or unintended.

Integrated  projects:  Projects  implementing  on  a  large  territorial  scale,  in  par ticular  on  a  regional, 
multi-regional or national scale, environmental or climate strategies or action plans required by specific EU 
environmental or climate legislation, pursuant to other EU acts or developed by Member States’ authorities.

Intervention: Any action or operation carried out by public authorities or other organisations, regardless of 
its nature (policy, programme, measure or project).

LIFE: L’Instrument Financier pour l’Environnement (the financial instrument for the environment).

Monitoring: Regular examination of the resources, outputs and results of interventions.

Output: Something that is produced with the resources allocated to an intervention.

Project replication: The reproduction of the whole project or parts of it.

Project results dissemination: The process of making the results and deliverables of a project available to 
the stakeholders and to the wider audience.

Project sustainability: The continued existence of the project.

Results: The direct effects or changes that arise due to the intervention.

Thematic strategies: The sixth EAP introduced the thematic strategies as an instrument for its implementa-
tion and covered seven thematic areas: soil protection; protection and conservation of the marine environ-
ment; sustainable use of pesticides; air pollution; improving the quality of the urban environment; the sustain-
able use and management of natural resources; and waste prevention and recycling.

These strategies are based on a global approach, by theme, rather than on certain pollutants or types of eco-
nomic activity, as had been the case in the past. They set long-term objectives and provide an opportunity to 
simplify and clarify existing legislation.

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EXECUTIVE SUMMARY

(c)  the quality of the project selection was adverse-
ly influenced by the insufficient justification of 
evalu ation results;

(d)  the  monitoring  framework  of  the  programme 
lacked  appropriate  common  output  and  result 
indicators. This prevented the Commission from 
getting a comprehensive and updated overview 
of the performance of projects, and therefore from 
estimating the operational effectiveness of the 
programme.

IV.
The main implementation problems that hampered 
effectiveness were:

(a)  key aspects of LIFE projects, concerning their in-
novative and demonstrative character, their sus-
tainability  prospects  and  EU  interest,  were  not 
always appropriately assessed during project se-
lection;

(b)  the monitoring of the reasonableness of project 
costs, their sustainability and replication was in-
sufficient;

(c)  the expected role of the component as a catalyst 
for environmental policy was greatly reduced due 
to insufficiently effective dissemination and low 
sustainability and replication of projects.

I.
The EU’s environmental policy is integrated across 
the EU’s main policy areas. The vast majority of EU 
funding for the environment is therefore delivered as 
part of the EU’s main spending policies, such as the 
Structural Funds and the common agricultural policy. 
LIFE (L’Instrument Financier pour l’Environnement) 
is directly managed by the Commission. It is now in 
its fourth programming period and the current LIFE 
programme has an average annual budget of 239 mil-
lion  euro for financing projects  — which represents 
less than 1,5 % of the estimated overall environment-
related expenditure by the EU. This is a modest budget 
for an ambitious objective: to contribute to the devel-
opment, updating and implementation of EU envir-
onmental policy and legislation. Almost 50 % of this 
budget, or 120  million  euro, is devoted to the LIFE 
‘Environment’ component.

II.
The Commission has proposed to increase the budget 
available for the LIFE ‘Environment’ component in the 
next programming period. The Court therefore carried 
out an audit to assess the effectiveness of the LIFE 
‘Environment’ component of the LIFE programme. This 
involved an examination of whether the design and 
implementation of the LIFE ‘Environment’ component 
contributed to programme effectiveness.

III.
The Court found that, overall, the LIFE ‘Environment’ 
component was not operating effectively because it 
was not sufficiently well designed and implemented. 
The main design problems were:

(a)  the lack of a mechanism to target scarce resources 
on pre-selected objectives dissipated the impact 
of the invested funds;

(b)  the indicative national allocations hampered the 
selection of best projects because projects were 
not only selected based on their merit but also on 
their Member State of origin;

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V.
The Court recommends that the Commission imple-
ments the following recommendations.

(4) 

(1) 

(2) 

(3) 

In  the  establishment  of  the  multiannual  work 
programmes  foreseen  in  the  new  LIFE  pro -
gramme, the legislative authorities should en-
able the Commission and the Member States to 
restrict eligible applications to limited strategic 
priorities and to set clear, specific, measurable 
and  achievable  objectives  for  projects  to  be 
funded. A limited number of priorities fixed for 
a number of years would streamline the selec-
tion process, concentrate the efforts on specific 
issues and facilitate the evaluation of the pro-
gramme’s impact.

The Commission’s proposal for the new LIFE pro-
gramme ends the national allocations for tradi-
tional  projects,  but  keeps  a  geographical  bal-
ance for integrated projects. In its application, 
the Commission should ensure that integrated 
projects are selected based on their merit, and 
that geographical balance should not breach the 
principle of equal opportunities for applicants.

The Commission should improve the project se-
lection evaluation forms and require the evalu-
ators to provide separate assessments and scores 
for major project aspects (such as the innovative 
or demonstrative character of the proposal, the 
quality of the dissemination actions planned or 
the  potential  for  the  replication  of  results),  in 
order to improve the quality and transparency of 
the selection process and to ensure that selected 
projects have the potential to contribute most 
towards the achievement of the programme ob-
jectives.

(5) 

(6) 

(7) 

(8) 

The Commission should improve its programme 
management tools and consider introducing ad-
equate common output and result indicators as 
well as follow-up information at project level, 
in order to facilitate an appropriate monitoring 
of the programme. To the extent possible, such 
indicators should be relevant, accepted, credible, 
easy and robust (‘RACER’ criteria).

The  Commission  should  improve  its  assess-
ment of the reasonableness of claimed person-
nel costs, particularly for comparable projects, 
by making better use of information collected 
during the monitoring phase. This could then 
be better used to facilitate the identification of 
excessive costs.

The Commission should require the monitoring 
team to include in its assessments a critical anal-
ysis of the dissemination, sustainability and rep-
lication measures proposed by the beneficiary 
and of the potential barriers that might hinder 
them, both in its evaluation reports during the 
project implementation as well as in its ex post 
visit reports.

The Commission should consider how to better 
encourage the dissemination and replication of 
project results by private beneficiaries who wish 
to protect their commercial interests.

The Commission should consider how to require 
the beneficiaries to electronically submit simple 
and updated information after the project com-
pletion (i.e. whether the project remains opera-
tional, whether the project is replicated, and if 
yes, how many times, etc.). This would enable 
the Commission to efficiently improve its ex post 
information on programme effectiveness.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

INTRODUCTION

9

1. 

2. 

FUNDING THE ENVIRONMENT IN THE EU

The environment is an increasingly important policy area for the Euro-
pean Union. With the Treaty of Amsterdam (1999), the Union recognised 
that the environment needed to be integrated, in terms of both defini-
tion and implementation, into all its other policies (e.g. transport, en-
terprise, research and enlargement). Due to the cross- cutting nature of 
environmental issues, the main EU expenditure programmes (in particu-
lar the Structural Funds, the Cohesion Fund and agricultural expenditure, 
as well as other assistance programmes implemented outside the EU) 
include aspects related to environmental policy.

Figure 1  shows the estimated environment-related expenditure for the 
period 2007  to  2013 by expenditure programme. The LIFE programme, 
with  a  budget  of  2,1  billion  euro,  represents  less  than  1,5  %  of  total 
environment-related expenditure.

FIGURE 1

ESTIMATED ENVIRONMENTAL EXPENDITURE (BILLION EURO), 2007–13

105,0

1,9

3,9

5,0

LIFE

European Regional Development Fund/
European Social Fund/Cohesion Fund

Framework programme

European neighbourhood policy
instrument

Other programmes

Common agricultural policy

35,4

2,1

LIFE represents 1,37 % of total

Source: Combined impact assessment and ex ante evaluation of the review of the LIFE+ regulation: options development.

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1  The so called ‘LIFE+’ 
programme is governed by 
Regulation (EC) No 614/2007 
of the European Parliament 
and of the Council of 
23 May 2007 concerning 
the financial instrument for 
the environment (LIFE+) 
(OJ L 149, 9.6.2007, p. 1). It 
is the successor to the LIFE 
I (1992–95), LIFE II (1996–99) 
and LIFE III (2000–06) 
programmes from previous 
periods.
The Commission has 
prepared a proposal for 
the new LIFE programme 
(2014–20) that is currently 
under negotiation in the 
European Parliament and the 
Council of the EU.

2  Management by the 
European Commission (DG 
Environment) on a centralised 
basis.

THE LIFE PROGRAMME

3. 

The current LIFE programme1 covers the period from 2007 to 2013 and 
has three components.

(a) 

LIFE ‘Nature and biodiversity’, which co-finances best practice or 
demonstration projects that contribute to the implementation of 
the birds and habitats directives, the Natura 2000 network. In addi-
tion, it co-finances innovative or demonstration projects that con-
tribute to the implementation of the objectives of the Commission’s 
communication on ‘Halting the loss of biodiversity by 2010 — and 
beyond’.

(b)  LIFE ‘Environmental policy and governance’ (hereafter LIFE ‘Envi-
ronment’), which co-finances innovative or demonstrative projects 
related to climate change, water, air, soil, urban environment, noise, 
chemicals, environment and health, natural resources and waste, 
forests and innovation.

(c) 

LIFE ‘Information and communication,’ which supports projects that 
disseminate environmental information, such as information about 
climate change or nature conservation, networking or best-practice 
platforms.

LIFE is directly managed by the Commission 2. Given that most of the 
EU  environmental  expenditure  is  integrated  into  other  expenditure 
programmes, LIFE stands as the environmental backbone of the EU. Its 
overall objective is to contribute to the development, updating and im-
plementation of EU environmental policy and legislation, including the 
integration of the environment into other policies. It should therefore 
serve as a platform for developing and exchanging best practices and for 
sharing knowledge, to catalyse and accelerate change on environmental 
and climate issues. In practice, LIFE supports the general (political) envir-
onmental priorities set by the Council and the European Parliament in 
the environment action programmes (EAPs). LIFE ‘Environment’ projects 
cover a very wide range of sectors, including climate change, chemicals, 
water and natural resources, as outlined in Box 1 .

The current LIFE ‘Environment’ component has an average annual budget 
of some 119,5 million euro. From 1996  until 2012, this component pro-
vided 1,3 billion euro to 1 730 projects (see Table 1 ). The LIFE ‘Environ-
ment’ component is presented in Figure 2 . It shows the intervention 
logic underlying the component and the interplay between its main 
elements: ‘policy setting and evaluation’, ‘project implementation’ and 
‘results and impact’.

4. 

5. 

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PROGRAMME EVALUATION
Ex-ante, mid-term and ex-post evaluations
are performed, which can lead to
reconsideration of programme objectives
and processes.

CATALYTIC EFFECT
Accelerate change on environmental
and climate issues.

REPLICATION
Reproduction of the project outcomes, 
ideally across the EU.

DISSEMINATION OF RESULTS
Dissemination by the Commission 
and the beneﬁciaries of project
objectives and results.

FIGURE 2

THE LIFE ‘ENVIRONMENT’ COMPONENT

LIFE ENVIRONMENT COMPONENT OBJECTIVES
Contribute to the development and update of environmental
and climate change policy through co-ﬁnancing innovative 
or pilot projects.

CALL FOR PROPOSALS
Publication of the call in the Oﬃcial Journal.

The proposals are sent to the European Commission via the 
Member State authorities.

PROJECT SELECTION
Evaluation and selection of the proposals.

Grant agreement signed with beneﬁciary.

PROJECT IMPLEMENTATION
Implementation of agreed actions and communication
of project progress and results to the Commission by 
the beneﬁciary.

Monitoring and assessment of project progress and 
completion by the Commission.

Payment of eligible actions by LIFE Environment funds.

PROJECT RESULTS
Completion of sustainable innovative or pilot projects.

FOLLOW UP
Ex-post audits and ex-post visits to projects.

POLICY SETTING AND 
EVALUATION

PROJECT 
IMPLEMENTATION

RESULTS AND IMPACT

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12

6. 

As  a  result  of  the  relatively  limited  budget  of  the  LIFE ‘Environment’ 
component, both compared with its extensive objectives and overall 
EU environmental spending, its effectiveness is strongly determined by 
whether funded projects serve as catalysts for environmental change. 
This means that the successful completion of a project is not in itself 
enough to ensure the overall effectiveness of the programme. Indeed, 
if the projects do not address problems with significant importance at 
European level and their results are not adequately monitored, dissemi-
nated, sustained and replicated, the overall objective of contributing to 
environmental policy is unlikely to be achieved.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

AUDIT SCOPE AND APPROACH

13

The Court identified a number of risks to the effectiveness of the LIFE 
‘Environment’ component of the programme in achieving its objectives, 
in particular the risks that the combination of a high number of prior-
ity actions and the relatively low budget could lead to a lack of focus 
and inconclusive results, the weaknesses in the project monitoring and 
evaluation systems for drawing conclusions about the programme and 
the lack of a multiplier effect due to the insufficient dissemination of 
project results. Given the Commission’s intention to significantly increase 
the programme’s budget for the next programming period 2014–20, the 
Court decided to carry out an audit in order to assess these risks in more 
detail.

3  The ‘Nature and 
biodiversity’ component was 
the subject of the Court’s 
Special Report No 11/2009 
on ‘The sustainability and the 
Commission’s management 
of the LIFE-Nature projects’.

The objective of the audit was to answer the question: ‘Does the LIFE 
“Environment” component of the LIFE programme3 operate effectively?’ 
This was done by addressing the following audit sub-questions.

 — ‘Was the LIFE “Environment” programme well designed in order to 
facilitate effective results?’ In order to answer this question, the 
Court examined the consistency of objectives with the available 
budget, how the budget was allocated and the design of the pro-
ject selection and monitoring processes.

 — ‘Was the LIFE ”Environment” programme well implemented in order 
to obtain effective results?’ In order to answer this question, the 
Court examined the application of the selection criteria and the 
monitoring, dissemination, sustainability and replication of projects.

The above questions consider the criteria necessary to achieve the cata-
lytic effect and thus the overall effectiveness of the ‘Environment’ com-
ponent of the programme.

The audit focused on the projects funded between 2005 and 2010. The 
Court visited the Commission’s relevant services and five Member States 
from among the largest beneficiaries of LIFE (Germany, Spain, France, 
Italy and the United Kingdom), representing 55 % of the LIFE budget and 
15 % of its projects.

7. 

8. 

9. 

10. 

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14

11. 

12. 

In total, 25 projects were visited on the spot in the five Member States4. 
Relevant documents were examined to check the purpose, eligibility, 
existence, sustainability and potential replication of the projects and to 
verify whether best practices and lessons learned were appropriately 
disseminated by the Commission. In addition, relevant information re-
lated to project selection and monitoring, as well as information on the 
project websites, was analysed for a sample of 70 projects.

Interviews were carried out with representatives of the Commission, 
the evaluation team, the monitoring team5 and representatives of the 
national or regional authorities acting as national or regional contact 
points (NCPs).

4 

Including 23 completed 
projects, of which 22 were 
selected in 2005 and 2006 
and only three in 2007. It 
should be noted that some 
rules, for example those 
concerning the dissemination 
of project results, were made 
more stringent since 2007.

5  The Commission is assisted 
in the project selection 
procedure by external 
evaluators and in project 
monitoring by an external 
monitoring team.

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OBSERVATIONS

15

13. 

14. 

PART I — DESIGN

THE LARGE NUMBER OF OBJECTIVES OF THE PROGRAMME WAS NOT 
CONSISTENT WITH THE LIMITED BUDGET AVAILABLE

In order to be effective, programmes should not only define clear and 
specific objectives, but these should be realistic and consistent with the 
allocated budget. More concretely, programmes should include a limit-
ed number of defined specific priorities in order to target available re-
sources on attaining the objectives set. This is particularly important for 
LIFE, given its expected catalytic role to promote developments in EU 
environmental policy and its relatively limited budget.

The LIFE regulation sets many eligible objectives for LIFE ‘Environment’ 
component projects (see Box 1 ). From 2008, the Commission narrowed 
down these objectives in its annual call for proposals into ‘indicative 
priority areas’. However, in practice this did not result in a much greater 
targeting of specific priorities because proposals outside these priorities 
are eligible for funding, as long as they relate to any of the many objec-
tives under the regulation. Therefore, despite its modest budget, LIFE 
‘Environment’ funds projects across 12 different policy areas and involv-
ing very different issues and interests. Even if good projects are being 
financed, this inevitably translates into a lack of critical mass of projects 
to promote meaningful developments in EU environmental policy and 
prevents any real impact on policy areas.

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BOX 1

LIFE ‘ENVIRONMENT’: A SMALL BUDGET  …

The LIFE ‘Environment’ component represents around 0,5 % of the estimated EU environmental expenditure 
for the period 2007–13.

But with many ambitious objectives (listed in Annex II of the LIFE+ regulation).

(a)  Climate change: to stabilise greenhouse gas concentration at a level that prevents global warming above 

2 °C.

(b)  Water: to contribute to enhanced water quality by developing cost-effective measures to achieve a good eco-
logical status in view of developing the first river basin management plan under Directive 2000/60/EC6 by 2009.

(c)  Air: to achieve levels of air quality that do not give rise to significant negative impacts on and risks to human  

health and the environment.

(d)  Soil: to protect and to ensure the sustainable use of soil by preserving soil functions, preventing threats to 

soil, mitigating their effects and restoring degraded soils.

(e)  Urban environment: to contribute to improving the environmental performance of Europe’s urban areas.

(f )  Noise: to contribute to policy development and implementation on environmental noise.

(g)  Chemicals: to improve the protection of the environment and health from risks posed by chemicals by 2020 

by implementing chemicals legislation.

(h)  Environment and health: to develop the information base for policy on the environment and health (the 

environment and health action plan 2004–10).

(i)  Natural resources and waste: (a) to develop and implement policies designed to ensure sustainable manage-
ment and use of natural resources and waste, and to improve the environmental performance of products, 
sustainable production and consumption patterns, waste prevention, recovery and recycling; (b) to con-
tribute to the effective implementation of the thematic strategy on the prevention and recycling of waste.

( j)  Forests: to provide, especially through an EU coordination network, a concise and comprehensive basis for 
policy-relevant information on forests in relation to climate change (impact on forest ecosystems, mitiga-
tion, substitution effects), biodiversity (baseline information and protected forest areas), forest fires, forest 
conditions and the protective functions of forests (water, soil and infrastructure) as well as contributing to 
the protection of forests against fires.

(k)  Innovation: to contribute to developing and demonstrating innovative policy approaches, technologies, 
methods and instruments to assist in the implementation of the environmental technologies action plan 
(ETAP).

6  Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community 
action in the field of water policy (OJ L 327, 22.12.2000, p. 1).

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17

Table 1  shows the amounts that LIFE ‘Environment’ spent by priority area 
in the years 1996  to  2012. Even within the priority areas, the projects 
cover  a  wide  range  of  sectors  and  the  total  amount  involved  repre -
sents around 0,5 % of the total EU environment-related expenditure (see 
paragraph 5).

Consequently, the fact that the LIFE programme does not have a mecha-
nism to allocate its limited resources to the indicative favoured actions 
prevents the Commission from focusing project applications on a limited 
number of specific priorities, which means that LIFE does not neces-
sarily focus on pre-selected policy areas, but funds the policy areas of 
the selected projects. In the Court’s view, this is not consistent with the 
catalytic role expected from the programme.

15. 

16. 

TABLE 1

LIFE ‘ENVIRONMENT’ (1996–2012): NUMBER OF PROJECTS AND AMOUNT FUNDED BY 
PRIORITY AREA

Themes 1996–
2006

Policy areas

Air

Chemicals

Climate change

Forests

Soil

Strategic approaches

Urban environment 

Waste and natural resources

Water

Environment and health 

New themes

Innovation

Noise

Total

2007–12

1996–2006

Number of 
projects

EU contribution 
(million euro)

Number of 
projects

EU contribution 
(million euro)

20

32

144

15

27

37

33

191

92

18

35

10

654

21

21

168

17

29

28

7

30

37

29

195

84

666

93

17

39

15

92

189

69

312

250

52

10

33

6

49

103

35

184

145

1 076

617

Source: ‘Mid-term evaluation of the implementation of the LIFE+ regulation’, GHK and Commission services, April 2010.

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18

THE NATIONAL ALLOCATIONS HAMPERED COMPETITION AMONG 
PROJECT PROPOSALS

LIFE funds cover a wide range of areas in the whole territory of the EU. In 
order to fund the best possible projects, applications should go through 
a competitive selection process whereby the best projects are selected 
for funding.

7  The national allocations 
‘not used’ are reallocated and 
used to co-finance projects 
submitted by other Member 
States.

Since 2007, the LIFE programme has been designed to provide a propor-
tionate distribution of projects among the Member States. Article 6(2) of 
the LIFE+ regulation establishes indicative national allocations7, based on 
population and on the percentage of the national territory designated 
as a Natura 2000 area.

The indicative national allocations intend to secure funding for smaller 
Member States by ‘blocking’ a part of the budget for them. But, as high-
lighted in the impact assessment supporting the Commission’s proposal 
for the new LIFE regulation, their allocations are by definition small and 
this reduces their interest and commitment to the programme. As a re-
sult, the system did not stimulate more applications from these Member 
States.

Furthermore, the Court found that the national allocations distort the 
results of the evaluation criteria used for the selection process and can 
result in projects, depending on their Member State of origin, being 
selected with lower evaluation scores than rejected projects from other 
Member States. For example, in 2009, three projects from Italy, Poland 
and Finland with a final score of 55 points were refused for co-financing 
while one French project with only 46 points and two British projects 
with 50 points were retained.

17. 

18. 

19. 

20. 

21. 

The system magnifies competition between projects in the same coun-
try, rather than ensuring that the best projects are selected at European 
level. The European added value of the programme is therefore reduced.

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8  Under the current 
programme, the template 
for the award criterion on 
the European added value 
of the proposals includes 
inter alia the assessment of 
some aspects such as the 
innovative and demonstrative 
character of the project and 
that of the proposed action 
for dissemination of the 
results.

22. 

23. 

24. 

25. 

THE TEMPLATES USED TO EVALUATE PROJECT PROPOSALS DID NOT 
REQUIRE ENOUGH JUSTIFICATION OF THE EVALUATION RESULTS, 
WHICH UNDERMINED TRANSPARENCY IN THE SELECTION PROCESS

The project selection process is a cornerstone for the quality of spend-
ing programmes and a necessary condition for their effectiveness. This 
process should ensure transparency and equal opportunities for all ap-
plicants, be based on objective criteria and target projects that con-
tribute most towards the achievement of the programme objectives. 
A transparent and effective selection process requires evaluation forms 
that reveal the score given to each of the criteria and their justification.

LIFE projects are selected on the basis of a call for proposals launched 
every year by the Commission. While the Commission receives assistance 
from a consortium of external evaluators to evaluate project proposals, 
it remains responsible for the selection process.

The overall selection process of LIFE ‘Environment’ proposals takes place 
in four phases: eligibility, selection, award and revision. The process is 
outlined in Annex I . For the two first phases of the evaluation process — 
eligibility and selection — each proposal is examined by one evaluator. 
In the award phase, the proposals have to be assessed independently 
by two expert evaluators. In case of significant divergence, a third as-
sessment of the proposal is required. The final decision on the score 
to be given to each proposal is taken during a meeting chaired by the 
Commission’s services and attended by the evaluators.

The evaluators use standard templates, prepared by the Commission, to 
appraise project proposals on the basis of pre-defined selection criteria. 
Each of these criteria is further developed into a series of more specific 
aspects to be considered8. While for the award phase the templates re-
quire the evaluators to score and give opinions in favour of and against 
each major criterion, there is no requirement to justify the assessment 
or to score the different aspects included in each major criterion.

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26. 

27. 

28. 

The audit found that key aspects for the effectiveness of the programme, 
such as the innovative or demonstrative character of the proposal, the 
quality of the dissemination actions planned or the potential for the 
replication of results, were not considered as standalone evaluation cri-
teria, but as one among the several aspects inside the evaluation criteria. 
In practice, this meant that the evaluators were not required to score 
and justify their assessment of these key aspects of LIFE ‘Environment’ 
projects. In the Court’s view, this represents a weakness in the design of 
the project selection system9.

9  The ex post evaluation 
of LIFE III (COWI 2009) and 
the Court’s Special Report 
No 11/2009 have already 
identified the need for further 
clarification of the scoring 
system.

In fact, the Court found that the aggregation of different key aspects 
under the same evaluation criterion, without requiring the evaluator 
to  give  an  individual  score,  led  to  situations  where  the  scores  given 
were not sufficiently justified in the evaluation templates (see Box 2) 
or where important aspects were not appropriately assessed (see Box 3 
and paragraph 41).

Furthermore, providing an overall score to an evaluation criterion with-
out scoring the underlying aspects prevents an objective and thorough 
reperformance of the evaluation work carried out. This undermines the 
transparency of the programme’s selection system.

BOX 2

EVALUATION SCORE NOT SUFFICIENTLY JUSTIFIED

A German proposal received predominantly negative comments concerning the evaluation criterion 1. Under 
this criterion, the evaluators should assess the innovative nature of the proposal, the significance of the expected 
environmental progress and its technical feasibility.

The evaluator noted in the evaluation form that the only innovative character resided in the process, not in the 
methods and concepts.

The evaluator scored this criterion with 6 points out of a maximum of 10. In the Court’s view, the negative nar-
rative assessment provided in the evaluation form does not justify this score.

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29. 

30. 

31. 

THE MONITORING FRAMEWORK WAS NOT APPROPRIATE AND THIS 
HAMPERED EFFICIENT PROGRAMME MANAGEMENT

The appropriate management of any kind of programme requires a regu-
lar examination of inputs, outputs and results, in order to obtain up-to-
date information on whether the programme is progressing as intended, 
in other words, a monitoring framework. Monitoring informs managers 
during programme implementation about the achievement of opera-
tional objectives, so that problems can be identified and corrected in 
a timely manner. A sound monitoring framework should contain, for 
example, a set of common input, output and result indicators. These 
should allow data at project level to be aggregated at programme level 
and to be compared against pre-defined objectives and targets.

Monitoring should not stop when projects are completed. In the LIFE 
programme, ex post monitoring would be useful to determine whether 
or not the outputs and expected results continue to be generated, to 
check that there are no sustainability-related problems or the extent to 
which project results have been transferred or replicated elsewhere.

The Commission monitors project implementation, assisted by a consor-
tium of experts acting as an external monitoring team. The team makes 
annual site visits to inspect project progress, either alone or with a desk 
officer from the Commission. The monitoring team assesses the regular 
reports on project implementation, which the beneficiary submits to the 
Commission.

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32. 

33. 

34. 

During their project visits, the monitoring team assesses the delivery 
of outputs and the achievement of results as stated in the project pro-
posals and assesses the technical and financial eligibility of the costs 
declared. At the end of the project, the monitoring experts complete 
an overall evaluation of the project’s results, including a final ‘score’. 
However, these monitoring arrangements focused at project level are of 
little use to draw lessons on the performance of the programme. This is 
because the programme’s performance monitoring framework does not 
have adequate common output and result indicators. In particular, the 
set of common output indicators introduced in 2007 is largely limited 
to communication and dissemination actions such as workshops, semi-
nars, conferences and publications. Furthermore, the Commission has 
not defined any result indicator. Consequently, the current framework 
does not allow the information from individual project results to be ag-
gregated in a meaningful way. This prevents the regular monitoring of 
the programme’s effectiveness and the timely identification of problems 
affecting its performance.

10  Other projects are visited 
in the framework of DG 
Environment’s annual audit 
plan. The audit visits are 
conducted just after the 
final payment, as the sample 
is drawn from projects for 
which the final payment 
was made the previous 
year, and shortly after the 
project conclusion. They are 
focused on financial aspects 
of the projects and are not 
considered to be a part of the 
follow-up activities.

The overall objective of the programme is to contribute to the develop-
ment, updating and implementation of EU environmental policy and 
legislation. That requires that successful projects are sustained, and their 
results disseminated and ultimately replicated. However, once the pro-
jects are closed, the Commission considers that its available resources 
do  not  allow  it  to  per form  systematic  ex post  visits  to  follow-up  the 
‘after-LIFE’ evolution of the projects.

Aware of these weaknesses, the Commission has, since 2009, included 
in the contract between the European Commission and the monitoring 
team a requirement for 10 ex post visits per year to examine sustainability 
and other issues10. By December 2012, 30 LIFE ‘Environment’ projects had 
been visited. Although this represents an improvement, it represents 
only 5 % of closed projects.

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35. 

36. 

37. 

38. 

When evaluating the final project report, the monitoring team estab-
lishes a set of long-term monitoring indicators to be used during ex post 
visits. However, the audit has not found any evidence that these indica-
tors are assessed in subsequent ex post visits. Moreover, the proposed 
long-term indicators are unique to each project, which would limit their 
usefulness, even if a value would be available, at programme level. A fur-
ther weakness in the recently introduced ex post checks is that, even 
if a project’s sustainability is comprehensively analysed by the ex post 
evaluations, the monitoring team is not asked to analyse the project’s 
replication, which is fundamental to achieving the catalytic effect of the 
programme.

Furthermore, as is the case during the implementation of the projects, 
neither the Commission nor the monitoring team have considered pre-
paring a list of common indicators to be used by the monitoring team 
during the ex post visits in order to follow-up the outcomes of the LIFE 
‘Environment’ projects. The combination of the above weaknesses means 
that the Commission lacks information on the number of successfully 
completed projects, the number of projects that are still operational after 
a certain number of years and the number of projects that have been 
replicated. This prevents the opportunity to benefit from lessons learned 
in the past and thereby improve selection and monitoring procedures, 
avoid the repetition of errors and save resources.

Although the Commission organises periodic evaluations of the pro-
gramme,  these  cannot  replace  the  day-to - day  monitoring  of  the 
programme. In fact, both processes are complementary, since evalu-
ations should use, among other sources, the information produced for 
monitoring.

Overall, the audit found that the lack of consolidated information and 
appropriate indicators regarding the outputs and results of LIFE ‘Envir-
onment’ projects prevents the ongoing assessment of the effectiveness 
of the programme and hinders the timely identification of problems 
affecting programme implementation, which in turn hinders learning 
lessons for the future.

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PART II — IMPLEMENTATION

39. 

Taking into account the objectives of the LIFE ‘Environment’ component 
(see paragraph 4 and Box 1), the eligibility criteria defined by the regu-
lation and the Commission’s selection guidelines, the Court considers 
that, to act as catalysts and contribute to an effective programme, LIFE 
‘Environment’ projects should:

(a)  be innovative or demonstrative by focusing on innovative or de-
monstrative solutions to environmental problems by developing 
or disseminating innovative techniques or methods, best practice 
techniques, know-how, etc.;

(b)  be of EU interest and contribute to the achievement of the general 
objectives of EU environmental policy by targeting a problem with 
significant importance at European level or expecting to generate 
results that would be widely applicable;

(c)  have their results disseminated to ensure that innovative technolo-
gies and procedures for protecting the environment are well known 
and widely applied;

(d)  be sustainable as the continued existence of the project is required 

for its successful dissemination and replication;

(e)  be replicated by other entities in order to generate a wider impact. 
Replication may imply the propagation and multiplication of the 
outcomes of the project and the generation of impacts beyond the 
individual project.

40. 

The audit analysed, therefore, how these criteria were met in the differ-
ent implementation phases of LIFE projects.

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41. 

KEY ASPECTS OF THE PROJECTS WERE NOT ALWAYS APPROPRIATELY 
ASSESSED DURING PROJECT SELECTION

The Court reviewed the evaluation forms of the 25 projects visited and 
of 70 additional projects subject to a desk review. More concretely, the 
Court reviewed whether the evaluation of project proposals appropri-
ately covered certain essential aspects for the effectiveness of the pro-
gramme, such as the project’s innovative or demonstrative character, 
potential for sustainability or replication and significance of the envir-
onmental problem addressed (see paragraph 39). The audit revealed 
projects where the evaluation and key criteria scores awarded were not 
sufficiently justified (see paragraph 27), but which were nevertheless 
funded.

(a) 

The assessment of the innovative and demonstrative character 
of  projects  was  not  sufficiently  justified  in  20  %  of  the  projects 
that were the subject of a desk review and in 24 % of the projects 
visited on the spot.

 — The Court’s visit to the 25 projects found cases (see example 
in Box 3 ) where the level of innovation was either overrated 
or insufficiently justified, for example where the evaluators did 
not take into account the existence of similar projects.

BOX 3

SELECTION PROCEDURE: EXAMPLE OF WEAKNESSES IN THE EVALUATION OF 
INNOVATIVE AND DEMONSTRATIVE CHARACTER

In the evaluation of a British project, the innovative character of the project was considered as high, even if 
under other criteria the evaluator stated that ‘the method is not entirely innovative in the Community’.

When evaluating the demonstration character of the project, the evaluator questioned the scale of the project 
as being too large. The beneficiary’s reply was that the technology proposed had already been tested on two 
smaller facilities of the company.

The audit revealed that one of these two facilities was already operating at a production scale, which questions 
the demonstrative character of the LIFE project.

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(b)  The assessment of project sustainability or replication prospects 
was not sufficiently justified in 21 % of the projects that were the 
subject of a desk review and in 12 % of the projects visited on the 
spot.

 — The Court’s visit to the 25 projects found cases (see exam-
ples in Box 4 ) where evaluators did not identify the potential 
economic, financial or legal barriers that could prevent the 
project from being sustained or replicated. Indeed, the audit 
found cases of projects that, while achieving their objectives 
and expected results, could not be sustained or replicated 
because of these barriers 11, which in the Court’s view could 
have already been identified during the selection process. Had 
these barriers been identified by the evaluators, the Commis-
sion could have decided not to fund the project.

11  Typical barriers which were 
not sufficiently addressed 
by the monitoring team 
include: absence of market 
opportunities for the project 
outputs; problems with 
business continuity or access 
to financial resources of the 
beneficiary; and legislative 
barriers.

BOX 4

SELECTION PROCEDURE: EXAMPLES OF WEAKNESSES IN THE EVALUATION OF 
SUSTAINABILITY AND REPLICATION OF THE PROJECT PROPOSALS

Project sustainability prospects

In the evaluation of a Spanish proposal, the evaluators noted that there were no commercial plans to main-
tain the project and therefore they could not assess whether the project would be economically viable after 
completion and receipt of EU funding. However, the evaluators did not request any modifications or additional 
information in the revision of the project to ensure that the project offered the minimum guarantees of sustain-
ability beyond EU funding. The evaluation of sustainability was therefore insufficient.

The auditors’ visit of the project confirmed that the project was not sustained after its completion.

Legal barrier to project replication

Another project in Spain, which was completed in 2008, developed a technique using ozone as an alternative 
environmentally friendly cleaning agent in food-processing plants. The spreading of this technology would 
depend on a new European legislation supporting this technology, which is still not in place.

Economic barriers to project replication

A project in France reduced the environmental impact of glass production. However, the long lifespan of the 
glass furnaces (15–20 years) limits the possibility for replication to within the beneficiary’s group of companies. 
Replication outside the group is not envisaged as the project represents an economic advantage for the group.

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(c) 

The assessment of EU interest was insufficiently justified in 20 % of 
the projects that were the subject of a desk review and in 12 % of 
the projects visited on the spot.

 — The Court’s visit to the 25 projects found cases (see example 
in Box 5 ) where the EU interest was either not assessed or the 
assessment was not justified by the evaluator, for example 
cases where there were doubts that the project results could 
be applied outside the immediate project scope.

THE COMMISSION’S MONITORING OF PROJECT IMPLEMENTATION WAS 
INSUFFICIENT IN SOME RESPECTS

The Court checked whether the monitoring work carried out was compre-
hensive and that the reports produced by the monitoring teams for the 
25 projects visited accurately reflected actual project implementation.

The work of the monitoring team during project implementation is fo-
cused on the delivery of the expected outputs and verifying that the 
claimed  costs  are  technically  justified,  provided  for  in  the  project’s 
budget , realistic and actually incurred in the reporting period. The Court 
found that these checks are carried out regularly. However, the audit 
found problems with monitoring the reasonableness of costs and the 
sustainability and replication of projects.

42. 

43. 

BOX 5

SELECTION PROCEDURE: EXAMPLE OF WEAKNESSES IN THE EVALUATION OF THE EU 
INTEREST OF THE PROJECT PROPOSALS

A British proposal aimed at maintaining urban environments in three sites. In two of these, the proposal did 
not mention environmental issues. The main actions planned, and finally carried out, were related to the social 
environment or to nature protection measures, rather than to address any environmental problem of significant 
importance at EU level as required by the applicable regulation.

Even if referring to one of the priorities defined in the LIFE regulation, the proposal focused on very local prob-
lems and was not of EU interest.

The evaluation forms reviewed by the Court showed no evidence that this aspect had been assessed by the 
evaluator.

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44. 

While the eligibility of claimed costs is checked, there is no comparative 
analysis of the costs among similar projects, not even between projects 
in the same sector and region. The absence of such comparisons may 
lead to the acceptance of excessive costs, especially as the evaluators 
responsible for assessing the project proposals and the beneficiaries’ 
final reports are primarily technical, rather than financial, experts. For 
example, the audit found that the claimed hourly staff cost of project 
managers for the 23 closed projects visited varied between 10,56 euro 
and 164,39 euro.

45. 

The analysis of the final cost structure of the 23 completed projects that 
were visited  — shown in Figure 3  — indicates the importance of staff 
costs, which in the Court’s sample represented between 18,5 % to 83,5 % 
of the total costs of the project.

FIGURE 3

COST STRUCTURE OF THE 23 COMPLETED PROJECTS

100 %

80 %

60 %

40 %

20 %

0 %

UK1 UK2 UK3 UK4 DE1 DE2 DE4 DE5 ES1 ES2 ES3 ES4 ES5 FR1 FR2 FR3 FR4 FR5 IT1

IT2

IT3

IT4

IT5

% External assistance ﬁnal (eligible cost)

% Fixed assets ﬁnal (eligible cost)

% Staﬀ ﬁnal (eligible cost)

Source: European Court of Auditors.

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While there may be good reasons justifying the wide variations found 
in the hourly staff cost charged to LIFE projects, the Court neverthe -
less finds that extreme range variations justify further analysis by the 
Commission.

The Court also found that the monitoring team does not pay sufficient 
attention to the sustainability and replication prospects of projects (see 
examples in Box 6 ).

46. 

47. 

BOX 6

EXAMPLES OF WEAKNESSES IN THE MONITORING OF SUSTAINABILITY AND 
REPLICATION

A project in Spain aimed at reducing groundwater contamination by reducing the use of fertilisers and nitric 
acid in a horticultural sector.

The project received a good assessment from the monitoring team despite the fact that the beneficiary recog-
nised that limited environmental benefits were obtained and that further studies were needed to demonstrate 
environmental benefits. The monitoring team also noted that such studies were necessary to assure the project’s 
sustainability, although the beneficiary had not committed to undertake such studies. Finally, the transferability 
was assessed as ‘high’ by the monitoring team, although the team concluded that ‘this sector was probably not 
ready to introduce technological changes because it has low profits and no investment can be really done by 
the small producers’. This issue was not addressed during the implementation of the project.

At the time of the Court’s visit, only one of the six partners which participated in the project continued using 
the new technology. There is no evidence that the project was replicated.

A project in Italy had an expected duration of 24 months. Five months before its end, the beneficiary requested 
a substantial project modification as none of the 50 potential users that were initially interested in product 
testing were still interested in the new process. Despite the fact that such testing was initially considered as 
fundamental, the beneficiary requested the Commission’s permission to have the test performed by a business 
partner.

The Commission accepted the requested modification of the project. After its completion, the project was not 
sustained nor replicated due to the lack of interest of end-users. Despite the evident risks that the lack of inter-
est from end-users represented for the sustainability of the project, the monitoring team never questioned this 
issue and no corrective action was taken to address it.

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48. 

49. 

Beneficiaries prepare implementation and final reports in which they 
present the project results and achievements. The monitoring teams 
assess these reports. The audit found that the monitoring teams were 
not sufficiently critical of the statements and arguments made in the 
beneficiaries’ implementation and final reports (see Box 7 ). As a result, 
there is a risk that the achievements of the projects, and thus of the 
programme, are overestimated.

In conclusion, the audit detected weaknesses in the assessments by 
the monitoring teams in 18 out of the 25 projects examined. In addi-
tion to the lack of a sufficiently critical assessment of beneficiaries’ own 
assessments, the weaknesses were evenly spread over the assessment 
of the projects’ environmental objectives, sustainability, replication and 
dissemination.

LOW DISSEMINATION, SUSTAINABILITY AND REPLICATION OF 
PROJECTS JEOPARDISED THE ‘CATALYTIC’ ROLE EXPECTED FROM THE 
PROGRAMME

50. 

One of the LIFE programme’s key objectives is that it should act as a cata-
lyst for developing environmental policy and actions. A necessary con-
dition for this is that projects’ results are appropriately and widely dis-
seminated, sustained and replicated (see paragraph 39).

BOX 7

INSUFFICIENTLY CRITICAL MONITORING OF BENEFICIARIES’ REPORTS

A project in Italy aimed at the reduction of waste in the ceramics sector. The monitoring team’s assessment of 
the beneficiary’s final report substantially reflects the beneficiary’s own statements and is not sufficiently critical 
of the project’s reported sustainability. The project, which was finished in September 2008 (the final payment 
was done in August 2009), was not sustained at the time of the Court’s visit.

A project in Germany aimed at developing cleaner city logistics. The monitoring team’s evaluation of the project’s 
environmental benefits substantially reflects the beneficiary’s own statements, without further assessment.

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51. 

52. 

53. 

54. 

The  sample  of  projects  audited  points  to  problems  with  all  of  these 
elements (see Annex II ). Even when projects achieved positive envi-
ronmental results, the programme failed to effectively disseminate and 
replicate them in order to translate those small-scale results into a more 
meaningful application at EU level. This significantly limits the overall 
effectiveness of the programme.

DISSEMINATION OF RESULTS

As indicated in paragraph 39 and Figure 2, the dissemination of project 
results is required if projects are to serve as catalysts for environmental 
action. Effective dissemination encourages the replication and develop-
ment of project results. It should be well targeted, efficiently delivered 
and monitored. The responsibility for disseminating LIFE project results is 
shared between the Commission and the beneficiaries. The audit found 
problems with both.

The Commission publishes significant LIFE project information on its 
website. This includes summaries of project themes and lessons learned, 
a project database, a ‘LIFE by theme’ tool and project summaries. The-
matic platform meetings are promoted by the Commission, Member 
States or individual beneficiaries and closing conferences are organised 
by a significant number of projects.

However, once projects are completed, no update is made by the Com-
mission to reflect either problems or successes concerning the results, 
sustainability or replication of the projects. Moreover, the partially man-
ual treatment of the information and the lack of Commission resources 
lead to information gaps and errors. For example, 11 out of the 23 closed 
projects visited were not included by the Commission in the ‘LIFE by 
theme’ tool. This means that, despite extensive online information, po-
tential users do not have access to complete and up-to-date project 
information.

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55. 

56. 

57. 

58. 

The LIFE common provisions require the beneficiary, as part of the com-
munication  actions,  to  create  or  use  an  existing  website  for  the  dis-
semination of project activities, progress and results. For LIFE projects 
approved before 2007, there was no mandatory period for keeping the 
site operational. For 16 12 out of 22 of these closed projects that were 
visited by the audit, the website was operational. For LIFE projects ap-
proved from 2007, the website has to be online within 6 months of the 
start of the project and has to be regularly updated and maintained for 
at least 5 years after the end of the project. The projects audited from 
this period complied with this requirement.

12  Only one of the six projects 
without an operational 
website was still functioning.

13  Five projects had been 
abandoned and no website 
existed. One project never 
started.

14  The beneficiary of one 
project withdrew just after 
the selection. It was replaced 
by another project from the 
reserve list.

Although the Commission has made efforts to stimulate improvements 
to project websites (such as posting examples of websites on the LIFE 
website and providing recommendations on how to design LIFE project 
websites given to the selected projects), the audit found weaknesses in 
the websites reviewed.

The audit analysed the content of 63 project websites 13 from the sample 
of 6914 projects. This included 31 LIFE projects approved before 2007 and 
32 LIFE projects approved thereafter. Of the 53 websites that were op-
erational at the time of the audit, 11 had very limited content. The main 
weaknesses were very brief project descriptions and the lack of visual 
aids, reports and presentations. However, there was an improvement in 
the quality of the websites of projects approved from 2007.

In addition to passive communication using the internet or other forms 
of publicity, dissemination activities should be tailored to the specific cir-
cumstances of the project. The audit found cases where, despite projects 
delivering their intended results, dissemination activities were ineffective 
and failed to encourage project replication. Project websites were not 
updated, dissemination was largely in the context of the beneficiaries’ 
commercial advertising campaigns or to direct business partners and 
activities planned as part of agreed ‘after-LIFE’ communication plans 
were not completed.

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For project beneficiaries which are private companies, dissemination 
activities are generally organised in the context of the commercialisa-
tion of the product. This is done to protect know-how as the project is 
often considered as a strategic advantage for the beneficiary companies. 
However, this limits the effectiveness of the dissemination pursued by 
the programme. LIFE results would give the company a competitive ad-
vantage in the industry. Therefore, it may not be in the interest of the 
company to transfer the knowledge and replicate the project out of 
the group to which it belongs. This significantly reduces the eventual 
environmental impact of the project. The question arises as to whether 
the LIFE programme should fund such projects.

In conclusion, the Court found that the dissemination activities under-
taken did not sufficiently encourage the replication of project results. 
Even when beneficiaries completed the dissemination activities required 
under the project agreement, there was a lack of coordinated dissemina-
tion activities between the Commission, beneficiaries and competent na-
tional authorities to effectively encourage replication of project results.

Box 8  gives such an example of a successful project whose potential for 
significant environmental impact was not achieved due to ineffective 
dissemination.

59. 

60. 

61. 

BOX 8

CATALYTIC IMPACT FOR THE CERAMIC SECTOR NOT ACHIEVED

The polishing of ceramic and related materials produces large quantities of waste. One of the projects visited 
in Italy successfully implemented a process to reduce and recycle this waste.

The project, finished in 2008, was still operational at the time of the audit visit in 2012.

Despite the success and sustainability of the project, it has not been replicated. The project’s website has not 
been updated since its completion but the company, considering the project as a very positive marketing as-
pect, includes the LIFE logo on all its promotional items.

An important part of this production is concentrated in a limited number of European regions, in particular the 
ceramic district of Sassuolo in Italy and the Valencia region in Spain.

Although the beneficiary completed the dissemination activities required under the project agreement, there 
has not been a coordinated effort between the Commission, the regional authorities and the business organisa-
tions to disseminate project results and encourage the use of similar techniques elsewhere. The environmental 
impact is therefore significantly reduced.

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62. 

63. 

PROJECT SUSTAINABILITY AND REPLICATION OF RESULTS

As indicated in paragraph 39, the sustainability of LIFE ‘Environment’ 
projects is essential for the programme’s effectiveness, although to some 
extent the innovative and demonstrative character required for LIFE pro-
jects implies a risk of failure. The audit visited 23 completed projects, 
most of them completed between 2007 and  2009. The audit found that 
10 out of these were no longer operational at the time of the visit. For 
two projects, beneficiaries or partners were conducting new develop-
ments. Examples of unsustainable projects are given in Boxes 4  and 6, 
and an example of a sustainable project is given in Box 8 .

The weaknesses in the dissemination of successful project results ex-
plain, at least partially, the low replication of projects. Only eight of the 
23 completed projects visited have been or are likely to be replicated, 
including three that are no longer operational. For two projects out of 
the eight, replication is done within the group of companies to which 
the beneficiary belongs, limiting the replication and EU added value. This 
demonstrates the difference between successful project completion and 
programme effectiveness.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

CONCLUSIONS AND RECOMMENDATIONS

35

64. 

65. 

The  LIFE ‘Environment’  programme  should  serve  as  a  catalyst  for  EU 
environmental policy, essentially through the funding of innovative or 
demonstrative projects with European added value and the subsequent 
dissemination and replication of their results. The audit assessed the ef-
fectiveness of this catalytic effect.

The Court concluded that the LIFE ‘Environment’ component was not op-
erating effectively because it was not sufficiently well designed and im-
plemented. The audit identified design and implementation weaknesses 
which significantly reduced the programme’s fundamental catalytic role 
to boost meaningful developments in EU environmental policy. Without 
this, the overall effectiveness of the programme cannot be achieved.

66. 

The lack of a mechanism to target scarce resources on pre-selected objec-
tives dissipated the impact of the invested funds (paragraphs 13 to 16).

RECOMMENDATION 1

In the establishment of the multiannual work programmes foreseen in 
the new LIFE programme, the legislative authorities should enable the 
Commission and the Member States to restrict eligible applications to 
limited strategic priorities and to set clear, specific, measurable and 
achievable objectives for projects to be funded.

A limited number of priorities fixed for a number of years would stream -
line the selection process, concentrate the efforts on specific issues and 
facilitate the evaluation of the programme’s impact.

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36

67. 

The indicative national allocations hampered the selection of the best 
projects because projects were not only selected based on their merit, 
but also on their Member State of origin (paragraphs 17 to 21).

RECOMMENDATION 2

The Commission’s proposal for the new LIFE programme ends the na-
tional allocations for traditional projects, but keeps a geographical bal -
ance for integrated projects. In its application, the Commission should 
ensure that integrated projects are selected based on their merit and 
that geographical balance should not breach the principle of equal 
opportunities for applicants.

68. 

The quality of the project selection was adversely influenced by the 
inappropriate justification of evaluation results (paragraphs 22 to 28).

RECOMMENDATION 3

The Commission should improve the project selection evaluation forms 
and require the evaluators to provide separate assessments and scores 
for major project aspects (such as the innovative or demonstrative char-
acter of the proposal, the quality of the dissemination actions planned 
or the potential for the replication of results), in order to improve the 
quality and transparency of the selection process and to ensure that 
selected projects have the potential to contribute most towards the 
achievement of the programme’s objectives.

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37

69. 

The monitoring framework of the programme lacked appropriate com-
mon output and result indicators. This prevented the Commission from 
getting a comprehensive and updated overview of the performance of 
projects, and therefore from getting information on the effectiveness of 
the programme (paragraphs 29 to 38).

RECOMMENDATION 4

The Commission should improve its programme management tools and 
consider introducing adequate common output and result indicators 
as well as follow-up information at project level, in order to facilitate 
an appropriate monitoring of the programme. To the extent possible, 
such indicators should be relevant, accepted, credible, easy and robust 
(‘RACER’ criteria).

70. 

71. 

Key aspects of the projects, concerning their innovative and demonstra-
tive character, sustainability and EU interest, were not appropriately as-
sessed during project selection (paragraph 41) (see Recommendation 3 ).

The monitoring of the reasonableness of project costs, their sustainability 
and replication were insufficient (paragraphs 42 to 49).

RECOMMENDATION 5

The  Commission  should  improve  its  assessment  of  the  reasonable-
ness of claimed personnel costs, particularly for comparable projects, 
by making better use of information collected during the monitoring 
phase. This could then be better used to facilitate the identification of 
excessive costs.

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38

72. 

The Court found examples of ineffective dissemination and low sustain-
ability and replication of projects. The potential role of the ‘Environment’ 
component as a catalyst for environmental policy was therefore greatly 
reduced (paragraphs 50 to 63).

RECOMMENDATION 6

The Commission should increase its focus on the dissemination, sustain-
ability and replication of LIFE projects. In particular, the Commission 
should:

(a) 

(b) 

(c) 

require the monitoring team to include in its assessments a criti -
cal analysis of the dissemination, sustainability and replication 
measures proposed by the beneficiary and of the potential barri-
ers that might hinder them, both in its evaluation reports during 
the project implementation as well as in its ex post visit reports;

consider how to better encourage the dissemination and rep-
lication of project results by private beneficiaries who wish to 
protect their commercial interests;

consider how to require the beneficiaries to electronically submit 
simple and updated information after the project completion (i.e. 
whether the project remains operational, whether the project is 
replicated, and if yes, how many times, etc.). This would enable 
the Commission to efficiently improve its ex post information on 
the programme’s effectiveness.

This  Repor t  was  adopted  by  Chamber  I,  headed  by  Mr  Jan  KINŠT, 
Member  of  the  Cour t  of  Auditors,  in  Luxembourg  at  its  meeting  of 
6 November 2013.

For the Court of Auditors

Vítor Manuel da SILVA CALDEIRA
President

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

39

ANNEX I

THE SELECTION PROCESS

ELIGIBILITY
All proposals submitted for selection are checked for compliance with the admissibility and exclusion criteria (the proposal contains all the required
information, has been prepared using relevant standards and was sent via the national contact points; the beneﬁciary fulﬁls all the required conditions),
as well as  for compliance with the eligibility criterion (projects fall within the scope of one of the components of the programme).

SELECTION
The proposals that have passed the eligibility phase are checked by the evaluator for compliance with the technical (technical reliability
of the project participants; scope of the LIFE+ funding; and innovative or demonstrative character of the proposed actions) and  ﬁnancial
(compliance with the provisions of the Implementation rules of the ﬁnancial regulation) selection criteria.

AWARD
Proposals not rejected after the selection phase are subjected to an in-depth independent evaluation by two evaluators on the basis of six criteria: 
technical and ﬁnancial coherence and quality, contribution to the general objectives of LIFE+, European added value and complementarity
and optimal use of the EU funding, transnational character and compliance with national annual priorities and national added value
according to the LIFE+ national authority.

On the basis of the synthesis reports and scores provided by the contractor, the ﬁnal score to be awarded to each proposal is decided during a meeting
chaired by the Commission services and attended by the contractor’s coordinators and experts.

After the application of budget restrictions and national allocations, the Commission services establish a ‘long’ and ‘reserve list’ of proposals
to be admitted to the revision phase.

REVISION
During the revision phase, the Commission asks the applicant to provide further details about particular aspects of the proposal.
The applicants contacted have 15 calendar days to reply to the questions and/or introduce the requested modiﬁcations or improvements to their proposals.

Based on the replies received, the coordinating beneﬁciary may be asked to introduce modiﬁcations or improvements to the original proposal, to delete
certain actions or to reduce the project budget, the EU ﬁnancial contribution or co-ﬁnancing rate for the project.

Once the revision of proposals has been concluded, a ﬁnal shortlist of LIFE proposals to be funded and a ﬁnal reserve list of proposals are established
by the Commission and submitted to the LIFE committee for approval. They are afterwards subject to the approval of the European Parliament
(since 2012 this step runs in parallel with the approval by the committee and the preparation of the Commission decision).

Applicants are informed by letter about the results of the evaluation of their proposals and, where appropriate, about the reasons for rejection.
Projects on the reserve list may only be retained for co-ﬁnancing if there would be an unexpected withdrawal of a proposal between the date
of the committee meeting and the time when the individual grant agreements are signed.

Once the Commission adopts a decision concerning the list of selected projects, the grant agreements are issued.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

40

ANNEX II

ECA ASSESSMENT OF THE SAMPLE OF PROJECTS VISITED

Member 
State

Policy area

LIFE 
contribution
(1 000 euro)

Does the 
project 
have an 
innovative or 
demonstrative 
character?

Did the 
audit identify 
weakness in 
dissemination?

Is the 
project 
sustained 
(at the 
time of the 
audit)?

Has the 
project 
been 
replicated?

Waste and natural 
resources

GERMANY

Water

Waste

Air, urban development

Water

Soil

Air

SPAIN

Waste

Innovation

Water

Water

Chemicals

FRANCE

Water

Air

Climate change

ITALY

Soil

Waste

Air

Water

Soil

Climate change

UNITED 
KINGDOM

Waste

Water

Waste

N/A1 

414

211

867

959

676

305

434

333

281

1 056

1 904

538

667

3 366

407

214

299

1 775

372

N/A1 

411

407

584

Urban development

1 747

1  Not closed projects. 

Yes

Yes

Yes

No

No

Yes

Yes

Yes

Yes

Yes

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

Yes

Yes

No

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

Yes

Yes

No

Yes

No

No

Yes

Yes

Yes

Yes

Yes

Yes

N/A

Yes

No

Yes

Yes

No

Yes

No

Yes

No (Only 1/6)

No

Yes

Yes

No

Yes

Yes

No

No

Yes

No

N/A

No

Yes

Yes

Yes

N/A

No

No

No

No

No

No

No

Yes

No

No

Yes

Yes

No

Yes

No

Yes

No

No

Yes

N/A

Yes

No

Yes

No

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

41

REPLY OF THE 
COMMISSION

EXECUTIVE SUMMARY

III.
The  Commission  has  in  its  proposal  for  a  new  LIFE  pro-
gramme taken steps in order to improve the design of its 
‘Environment’ component (see specific comments below). 
In addition, the Commission highlights that the final evalu-
ation of LIFE+1 concludes that ‘Virtually all of the external 
stakeholders  inter viewed  and  sur veyed  (beneficiaries, 
national  contact  points,  monitoring  and  coordination 
units) agree that the programme is well designed to meet 
its objectives’ and that ‘in general, the application, moni-
toring and evaluation processes already help to achieve 
the  objectives  of  each  project  and  thus  are  part  of  the 
intervention’s utility’.

III. (a)
The  Commission  agrees  with  the  Cour t ’s  obser vation 
and consequently proposed, in the new LIFE regulation, 
a  mechanism  that  will  allow  it  to  define  project  topics 
for which additional points will be given in the selection 
procedure.

III. (b)
The Commission agrees with the Court that the system of 
indicative national allocations in place in LIFE+ did not ful-
fil its objective to ensure a better geographical distribution 
of the money awarded.

The Commission also agrees with the Court that the indica-
tive national allocations introduced some distortion in the 
competitive process of project selection. The Commission 
therefore proposed the total elimination of allocations in 
the future programme for traditional projects.

However, the text of the new regulation agreed between 
the institutions keeps indicative national allocations for 
traditional projects until 2017 and totally eliminates them 
from 2018 onwards.

III. (c)
The Commission considers that the scores attributed to 
projects were generally adequately justified based on the 
knowledge available at the time. (See also reply to para-
graph 41). 

However,  the  Commission  acknowledges  that  for  major 
selection criteria this justification could be more explicit.

1 

‘Final evaluation of the implementation of the LIFE+ regulation’, Ecorys,  

2012, p. 10.

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42

III. (d)
The Commission notes that the introduction of common 
output indicators since the beginning of LIFE+ represents 
a significant evolution with respect to the situation that 
existed in LIFE III and already allows the consolidation of 
output indicators of all projects, both in terms of proposed 
actions and of actually implemented actions.

IV. (a)
The  Commission  considers  that  the  aspects  in  question 
were appropriately assessed on the basis of the informa-
tion that was available at the time.

IV. (b)
The Commission proposed for the future LIFE regulation 
to eliminate completely the eligibility of staff costs, to be 
compensated through an increase in the rate of co-financ-
ing for the remaining eligible costs. 

The  reasonability  of  project  costs  is  one  of  the  aspects 
which the Commission is assessing before proceeding to 
payments.

The Commission agrees that the sustainability and replica-
tion of projects should be more explicitly assessed from 
the beginning of the project and not only in the evaluation 
of the final reports.

IV. (c)
The  Commission  considers  that  the  new  dissemination 
requirements introduced in 2007 with the LIFE+ regulation 
improved the dissemination of project results. Neverthe-
less, the Commission will, as far as possible, continue to 
improve the dissemination of results. 

The Commission also notes that the rate of sustainability 
and/or replication of LIFE ‘Environment’ projects identified 
by the Court is significantly higher than the ‘normal’ rate 
of success of innovative projects as described in scientific 
literature.

V. (1)
The Commission agrees with the Court’s recommendation, 
and has proposed a more limited number of priorities and 
objectives for the future LIFE regulation. 

V. (2)
The Commission agrees with the Court’s recommendation. 
For the future LIFE regulation, the Commission has pro-
posed to eliminate the national allocations for traditional 
projects while maintaining a system of geographical bal-
ance for integrated projects.

V. (3)
The Commission agrees that the evaluation results of key 
aspects, such as the innovative or demonstrative character 
and the replication potential, could be made more explicit 
and will instruct evaluators accordingly. 

V. (4)
The Commission agrees that, in addition to the project-
specific long-term monitoring indicators that are currently 
defined for each project, a common set of result indica-
tors  could  be  developed.  Both  sets  of  indicators  will  be 
systematically assessed in the ex post visits that are already 
being done to a sample of closed projects and the com-
mon  result  indicators  can  therefore  be  aggregated  at 
programme level. While this exercise will continue to be 
limited  to  a  sample  of  closed  projects,  the  aggregated 
indicators will provide a general overview of longer-term 
programme results.

V. (5)
The Commission agrees with the Court’s recommendation. 
The reasonableness of all costs is assessed by the monitors 
and the Commission desk officers on the basis of all the 
information available. The Commission will examine ways 
to continue to improve this assessment.

Common reply to V. (6) and (7)
The  Commission  considers  that  the  new  dissemination 
requirements introduced in 2007 with the LIFE+ regulation 
improved the dissemination of project results. Neverthe-
less, the Commission will, as far as possible, continue to 
improve the dissemination of results. 

The Commission agrees that the aspects of sustainability 
and replication should be more explicitly assessed from 
the beginning of projects and not only at the time of the 
final reports. The Commission notes, however, that this is 
already the case concerning the dissemination work.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

REPLY OF THE COMMISSIONV. (8)
The  legal  advice  obtained  by  the  Commission  indicates 
that  it  cannot  impose  post-contractual  obligations  on 
bene ficiaries. The Commission agrees that a voluntary sys-
tem could be useful and, in practice, many beneficiaries 
already keep the Commission informed about the continu-
ation of projects. A systematic follow-up of that informa-
tion, however, would require a significant increase of the 
resources available for the management of the programme.

INTRODUCTION

6.
Th e   l i m i te d   s i ze   o f   t h e   p ro gr a m m e   a n d   t h e   l i m i te d 
resources available to the Commission to manage it neces-
sarily limit the direct impact of the programme. Even so, 
the final evaluation of LIFE+ concludes that ‘Virtually all of 
the external stakeholders interviewed and surveyed (bene-
ficiaries, national contact points, monitoring and coordina-
tion units) agree that the programme is well implemented 
and is meeting its objectives’.

43

OBSERVATIONS

14.
The  Commission’s  proposal  for  a  new  regulation  clearly 
targets the ‘Environment and resource efficiency’ part of 
the programme (generally corresponding to ‘Environmen-
tal policy and governance’ in the LIFE+ regulation). This is 
done through the creation of a new type of project (inte-
grated projects) in a small number of thematic areas, but 
also  through  the  introduction  of  multiannual  work  pro-
grammes in which thematic priorities will be specified for 
the period covered.

With the exception of the duration of the multiannual work 
programme, which became 4 + 3 years, these proposals 
from the Commission were endorsed by the Council and 
the Parliament.

16.
The proposal for a new LIFE regulation foresees the attri-
bution of higher scores to the proposals that address one 
of  the  project  topics  identified  in  the  multiannual  work 
programme. This will significantly restrict the possibility 
of funding projects in other topics and, at the same time, 
pass a much stronger message to applicants concerning 
the topics on which funding should be concentrated.

19.
The Commission agrees with the Court that the system of 
indicative national allocations in place in LIFE+ did not ful-
fil its objective to ensure a better geographical distribution 
of the money awarded.

20.
The Commission also agrees with the Court that the indica-
tive national allocations introduced some distortion in the 
competitive process of project selection. The Commission 
therefore proposed the total elimination of allocations in 
the future programme for traditional projects.

However, the text of the new regulation agreed between 
the institutions keeps indicative national allocations for 
traditional projects until 2017 and totally eliminates them 
from 2018 onwards.

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REPLY OF THE COMMISSION44

21.
The Commission would like to note that the effect men-
tioned  by  the  Court  results  from  the  application  of  the 
regulation, but also to highlight the fact that only a small 
number of projects each year were affected by this provi-
sion, by being selected due to the national allocations or 
being rejected for the same reason.

Box 2 
The  Commission  considers  that  the  LIFE  regulation’s 
requirement  for  innovative  character  concerns  not  only 
innovative technologies or methods, but also other aspects 
such as process innovation, by which existing technolo-
gies and methods are put together in a new, more efficient 
and/or more environmentally respectful way.

25.
The  Commission  would  like  to  note  that  there  is  a  deli-
cate balance between having a relatively small number of 
broadly defined award criteria with a global score for each 
and having a long list of questions with a separate score 
for each question.

The  award  criteria  that  the  Commission  currently  uses, 
which are identified in the regulation itself, allow appli-
cants to focus on the aspects which are more relevant for 
their proposals and ignore those that are irrelevant. The 
Commission must also take account of the risks of increas-
ing  the  administrative  burden  and  extending  the  time 
needed to finalise the selection procedure.

26.
The Commission notes that the innovative or demonstra-
tive character of the proposal is, in accordance with the 
LIFE+ regulation, a selection criterion. Projects which do 
not  have  an  innovative  or  demonstrative  character  are, 
therefore, eliminated in the technical selection phase. The 
comments made on innovation or demonstration in the 
award phase therefore concern the degree to which a pro-
posal is innovative or demonstrative, beyond the minimum 
requirement established by the regulation.

27.
The Commission would like to note that transparency and 
equal  opportunities  for  all  applicants  are  fully  ensured 
(apar t  from  the  issue  of  national  allocations  treated  in 
another section) by the fact that a detailed guideline for 
the evaluation of projects is published at the same time 
as the call for projects. Each applicant knows exactly how 
proposals  will  be  evaluated  and  on  the  basis  of  which 
aspects the scores will be attributed. 

However,  the  Commission  agrees  that  the  evaluation 
results of key aspects such as the innovative or demonstra-
tive character and the replication potential are not made 
explicit. 

Box 2 — Third paragraph
Given the innovative character of the project and the com-
ments made on the other aspects covered by the criterion 
in question, the Commission considers that the score of 
6/10 was adequate.

28.
The  evaluation  of  a  proposal  by  an  individual  evaluator 
can never be totally objective. In LIFE, the subjectivity of 
the individual evaluators is significantly reduced through 
the requirement for two or three independent evaluations 
and the discussion of the comments and scores in a panel 
meeting with all evaluators and Commission staff. 

32.
The Commission notes that the introduction of common 
output indicators since the beginning of LIFE+ represents 
a significant evolution with respect to the situation that 
existed in LIFE III and already allows the consolidation of 
output indicators of all projects, both in terms of proposed 
actions and of actually implemented actions.

The Commission agrees that, in addition to the project-
specific long-term monitoring indicators that are currently 
defined for each project, a common set of result indica-
tors  could  be  developed.  Both  sets  of  indicators  will  be 
systematically assessed in the ex post visits that are already 
being done to a sample of closed projects and the com-
mon  result  indicators  can  therefore  be  aggregated  at 
programme level. While this exercise will continue to be 
limited  to  a  sample  of  closed  projects,  the  aggregated 
indicators will provide a general overview of longer-term 
programme results.

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REPLY OF THE COMMISSION45

33.
Most projects actually implement the after-LIFE commu-
nication plans developed during the project. The Court’s 
findings also identify a rate of sustainability that largely 
exceeds the ‘normal’ rate of success for innovative projects, 
which  is  generally  below  50  %,  even  for ‘incrementally 
innovative’ projects2. 

35.
The Commission agrees that the issue of project replica-
tion could be made more visible in the reports from ex post 
visits. It notes, however, that the assessment of this issue 
is the reason for the contacts with other stakeholders not 
involved with the original LIFE project, which the external 
monitors are required to establish in the framework of the 
ex post visits.

36.
See reply to paragraph 32. 

37.
In the Commission’s view, the periodic evaluations of the 
programme allow for a significant sampling of results. The 
frequency of these evaluations is more consistent with the 
duration  of  the  projects  than  an  attempt  at  continuous 
monitoring at programme level.

Common reply to paragraph 39. (d) and (e)
The  Commission  believes  that ‘sustainability ’  and ‘rep-
lication’ are two aspects of the long-term success of the 
project which need to be examined together. A project is 
successful when the work continues, after the end of the 
project, within the same organisation but also if it contin-
ues in other organisations, even if, for economic, social or 
political reasons, the work is not pursued by the entity that 
was a beneficiary of the grant.

41.
The Commission considers that the scores attributed to the 
projects were adequately justified based on the knowledge 
available at the time.

2  See,  for  example, ‘Risks  of  incremental,  differential,  radical,  and 
breakthrough innovation projects’ in InnovationManagement.se.

41. (a) First indent
The Commission notes that the assessment of the inno-
vative or demonstrative character of a proposal was done 
on the basis of the knowledge available at the time of the 
evaluation  by  two  or  three  independent  experts  in  the 
relevant  domain.  Fur thermore,  the  existence  of  similar 
projects does not exclude the possibility that each one of 
them has innovative features that justify the use of LIFE 
funds.

Box 3 
The  Commission  notes  that  the  evaluators  indicated 
explicitly that the innovative character resided in the scale 
of the demonstration.

41. (b) First indent
The  Commission  would  like  to  note  that  the  identifica-
tion of potential barriers and, when possible, of solutions 
is a relevant part of innovative or demonstrative projects. 
The existence of such barriers in itself is not a sufficient 
reason to refuse the funding since finding a solution for 
those barriers is often the most relevant part of a project.

The  Commission  also  notes  that  it  has  no  grounds  to 
believe that barriers that were not identified by experts in 
the relevant domains at the time of the evaluation could or 
should have been identified.

Box 4 
Project sustainability prospects
The  Commission  notes  that  the  relatively  low  score 
obtained by the first Spanish project in the criterion that 
includes an evaluation of sustainability of the project was 
due to what has been considered as insufficient guaran-
tees in terms of sustainability. However, since this was only 
one of the factors being assessed, the resulting score was 
still sufficient for the project to be funded.

Legal barrier to project replication
With respect to the second Spanish project, the Commis-
sion  notes  that  the  legislative  process  is,  in  most  cases, 
longer than the technical demonstration of the viability of 
a certain solution. A project can make a significant contri-
bution to the knowledge basis for decision-makers, but it is 
up to the legislators to draw their own conclusions.

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REPLY OF THE COMMISSION46

Economic barriers to project replication
Concerning the French project, the Commission notes that 
the environmental impact of a project does not necessarily 
have to be immediate. The dominant position in the sector 
of glass production, with plants and offices all over Europe 
and  in  72  countries,  ensured  that,  if  the  project  could 
develop a technically and economically viable solution to 
reduce the environmental impact of glass production, this 
would be implemented gradually in most if not all of their 
plants, reaching a very significant environmental impact.

41. (c) Indent
The  Commission  notes  that  the  evaluation  of  the  EU 
interest  of  a  proposal  was  explicitly  required  from  the 
evaluators. The Commission also considers that the exam-
ple  given  by  the  Cour t  was  correctly  assessed  by  the 
evaluators.

Box 5 
The Commission notes that this application clearly referred 
to one of the priority areas defined in the LIFE III regula-
tion, Article 4(2)(a): ‘integrate considerations on the envir-
onment  and  on  sustainable  development  in  land-use 
development and planning, including in urban and coastal 
areas’.  At  the  same  time,  the  actions  which  the  Cour t 
defines  as ‘nature  protection’  are  covered  by  the  water 
framework directive and were, therefore, also clearly within 
the scope of LIFE ‘Environment’.

Furthermore, Article 4(6)(h) of the LIFE III regulation clearly 
identified ‘promoting integration of environmental consid-
erations into activities whose main aims are economic and 
social’ as one of the criteria on which projects should be 
evaluated. 

43.
The  reasonability  of  costs  is  a  constant  concern  of  the 
financial staff in the LIFE units and the monitors are clearly 
required to indicate when they consider costs not to be 
reasonable.

The  Commission  notes,  however,  that  costs  var y  enor-
mously from one Member State to another and from one 
region to another within the same Member State. Person-
nel costs in particular depend not only on the tasks car-
ried  out,  but  also  on  the  location,  level  of  competence 
required, technical domain, family situation, etc.

Concerning sustainability and replication, the Commission 
agrees that this point is not always explicitly discussed by 
the  monitor  along  the  project  and  is  only  presented  in 
a systematic way in the evaluation of the final report.

44.
The Commission notes that, while the external monitors 
and  evaluators  are  primarily  technical  experts,  the  final 
decisions  concerning  the  eligibility  of  costs  are  taken 
by the Commission also on the basis of its own financial 
experts.

The Commission considers that the reasonability of all pro-
ject costs is part of the evaluation done by the external 
monitors and by the Commission’s desk officers, based on 
their knowledge of the local realities and of the technical 
domains in which projects work and taking into account, 
as far as possible, any specific conditions that may affect 
the costs in question.

See also Commission reply to paragraph 45.

45.
The Commission agrees that staff costs represent a signifi-
cant part of the costs of the projects funded under LIFE+. 
Given the difficulties highlighted by the Court in establish-
ing reasonable costs for different tasks in different loca-
tions, but also the difficulty in monitoring staff costs, as 
well as the difficulty for beneficiaries in keeping track of 
those costs in a verifiable way, the Commission proposed, 
for the future LIFE regulation, to eliminate completely the 
eligibility  of  staff  costs,  compensating  that  through  an 
increase in the rate of co-financing for the remaining eli-
gible costs. 

46.
The Commission notes that a detailed analysis of the vari-
ations in personnel costs would, due to the large number 
of factors that influence those costs, have a very high cost 
that would be difficult to justify with reference to the gains 
that could be obtained.

The Commission also notes that the high rates declared 
in some projects invariably refer to staff in management 
positions. The total amounts involved are, therefore, usu-
ally small.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

REPLY OF THE COMMISSION47

47.
The Commission agrees with the Court that a critical anal-
ysis  of  the  dissemination,  sustainability  and  replication 
measures proposed by the beneficiaries should be a more 
visible part of all assessments by external monitors and by 
the Commission staff, not only at the end of the project 
but throughout its duration.

Box 6 
The Commission notes that the problem of sustainability 
of the Spanish project was identified by the monitor very 
early in the project, leading to a continued insistence from 
the Commission on doing sufficient testing to validate the 
proposed solutions. At the end of the project, the level of 
testing was still considered insufficient, which explains the 
monitor’s comment on the need for further studies.

At the same time, however, a good effort to disseminate 
the  work  of  the  project  did  take  place  and  the  monitor 
considered that, once fully tested, the results of the project 
would be transferable.

Concerning the Italian project, the Commission notes that 
financing innovative or demonstrative projects has inher-
ent risks that cannot be ignored. The fact that potential 
users lose interest in the application of a certain environ-
mental  solution  due  to  modified  economic  conditions, 
changes of legislation or any other reasons are always pos-
sible. The Commission considered, at the time, and taking 
into account the investment already made in the project, 
that the testing of the solution by a business partner of the 
beneficiary was an acceptable solution.

48.
The monitors, as well as the Commission’s desk officers, 
assume responsibility for the statements they make. It is 
normal  that,  in  some  cases,  their  assessment  coincides 
with the assessment of the beneficiary.

Box 7 — Second paragraph
The  Commission  considers  that  the  monitoring  team 
endorsed the assessment done by the beneficiary.

49.
The Commission would like to highlight that none of the 
weaknesses identified by the Court relate to the actual and 
effective  implementation  of  the  actions  foreseen  in  the 
grant agreements. While the Commission agrees that the 
dissemination and sustainability of the project results is an 
important feature, the actual implementation of the pro-
ject actions cannot be seen as merely accessory.

50.
The  Commission  agrees  with  the  Court’s  point  of  view. 
While the dissemination of results has always been a man-
datory part of every project funded by LIFE, the obligations 
in this sense have been better precised since the begin-
ning of LIFE+. The Commission also published examples 
of good practice for the dissemination of documents and 
increased very significantly its effort to promote the dis-
semination of results, through the publication of thematic 
brochures  and  the  organisation  and/or  participation  in 
thematic ‘platform meetings’.

51.
The  Court’s  obser vation  is  based  on  projects,  the  large 
majority of which were governed by the LIFE III regulation. 
The Commission substantially increased requirements on 
the beneficiaries since 2007 for what concerns the dissemi-
nation of results. 

Furthermore, most of the LIFE III projects audited by the 
Court kept an updated website even if they have no con-
tractual obligation to do so.

52.
See reply to paragraph 51.

54.
The  Commission  notes  that  the ‘LIFE  by  theme’  tool  is 
a rela tively new addition to the LIFE website and that its 
current  weaknesses  are  well  known  to  the  Commission 
and will be addressed as soon as the existing resources will 
allow it. It should also be noted that this tool is just a dif-
ferent way to find information, by theme, while the under-
lying information for each project is, in all cases, that avail-
able through the projects’ database. There is, therefore, no 
link between the incomplete setup of the ‘LIFE by theme’ 
tool and the availability of complete and up-to-date pro-
ject information.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

REPLY OF THE COMMISSION48

56.
The  Commission  notes  that  most  of  the  websites  con-
cerned are for LIFE III projects (before 2007), created before 
the development of the current Commission guidelines.

58.
The Commission notes that almost all the projects visited 
were subject to the rules on the dissemination of results 
for LIFE III projects. With LIFE+, these rules became signifi-
cantly more stringent and the Commission has the pos-
sibility,  which  is  used  often,  to  insist  that  beneficiaries 
improve their communication and dissemination activities.

The Commission also notes that, in most cases, after-LIFE 
communication  plans  are  being  implemented,  even  if 
there is no contractual obligation to do it.

59.
The Commission notes that it was the legislators’ intention, 
by opening the participation in LIFE to all entities, pub-
lic or private, to allow for funding of projects which, while 
possibly creating an advantage to the beneficiaries, also 
show a good potential for addressing significant environ-
mental problems.

60.
The Commission notes that it currently organises thematic 
platform  meetings  to  promote  the  exchange  of  experi-
ences among not only LIFE beneficiaries, but also other 
practitioners in the same domains. Several of these events 
also  had  the  par ticipation  of  DG  Environment ’s  units 
responsible  for  policy  in  the  area  concerned,  therefore 
promoting also the exchange with those responsible for 
policy developments. These events are, in almost all cases, 
organised in collaboration and/or with the participation of 
the LIFE national focal points.

Box 8 — Third paragraph
The  Commission  notes  that  the  website  of  the  project, 
although  it  has  not  been  updated  after  the  end  of  the 
project, included the project’s full technical final report, 
therefore providing a good level of technical detail about 
the conclusions of the project. Furthermore, the benefi-
ciary carried out a wide dissemination of the project and 
its results through participation in the main trade fairs and 
visits to their facilities.

Given the relatively small size of the sector concerned and 
the  reduced  number  of  projects  financed  in  this  sector, 
the Commission did not carry out any additional dissemi-
nation activities (publications and/or thematic platform 
meetings).

62.
The Commission would like to note that the rate of success 
found by the Court is significantly higher than the ‘normal’ 
rate of success of innovative projects, which is generally 
below 50 % even for ‘incrementally innovative’ projects3.

The  Commission  also  considers  that  sustainability  and 
replicability are closely related. The Commission consid-
ers that the same environmental benefits can be delivered 
whether a project is continued by the same organisation 
or by a different one.

63.
See replies to paragraphs 51 and 58. 

3  See,  for  example, ‘Risks  of  incremental,  differential,  radical,  and 
breakthrough innovation projects’ in InnovationManagement.se.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

REPLY OF THE COMMISSION49

The Commission also agrees with the Court that the indica-
tive national allocations introduced some distortion in the 
competitive process of project selection. The Commission 
therefore proposed the total elimination of allocations in 
the future programme for traditional projects.

However, the text of the new regulation agreed between 
the institutions keeps indicative national allocations for 
traditional projects until 2017 and totally eliminates them 
from 2018 onwards.

Recommendation 2
The Commission agrees with the Court’s recommendation. 
For the future LIFE regulation, the Commission has pro-
posed to eliminate the national allocations for traditional 
projects while maintaining a system of geographical bal-
ance for integrated projects. 

68.
The  Commission  considers  that  the  aspects  in  question 
were appropriately assessed on the basis of the informa-
tion that was available at the time.

Recommendation 3
The Commission agrees that the evaluation results of key 
aspects such as the innovative or demonstrative character 
and the replication potential could be made more explicit 
and will instruct evaluators accordingly. 

69.
The Commission notes that the introduction of common 
output indicators since the beginning of LIFE+ represents 
a significant evolution with respect to the situation that 
existed in LIFE III and already allows the consolidation of 
output indicators of all projects, both in terms of proposed 
actions and of actually implemented actions.

CONCLUSIONS AND RECOMMENDATIONS

65.
The  Commission  has  in  its  proposal  for  a  new  LIFE  pro-
gramme taken steps in order to improve the design of its 
‘Environment’ component. 

In addition, the Commission highlights that the final evalu-
ation of LIFE+4 concludes that ‘Virtually all of the external 
stakeholders  inter viewed  and  sur veyed  (beneficiaries, 
national  contact  points,  monitoring  and  coordination 
units) agree that the programme is well designed to meet 
its objectives’ and that ‘in general, the application, moni-
toring and evaluation processes already help to achieve 
the  objectives  of  each  project  and  thus  are  part  of  the 
intervention’s utility’.

66.
The Commission’s proposal for a new regulation is clearly 
targeting the ‘Environment and resource efficiency’ part of 
the programme (generally corresponding to ‘Environmen-
tal policy and governance’ in the LIFE+ regulation). This is 
done through the creation of a new type of project (inte-
grated projects) in a small number of thematic areas, but 
also  through  the  introduction  of  multiannual  work  pro-
grammes in which thematic priorities will be specified for 
the period covered.

With the exception of the duration of the multiannual work 
programme, which became 4 + 3 years, these proposals 
from the Commission were endorsed by the Council and 
the Parliament.

Recommendation 1
The Commission agrees with the Court’s recommendation, 
and has proposed a more limited number of priorities and 
objectives for the future LIFE regulation. 

67.
The Commission agrees with the Court that the system of 
indicative national allocations in place in LIFE+ did not ful-
fil its objective to ensure a better geographical distribution 
of the money awarded.

4 

‘Final evaluation of the implementation of the LIFE+ regulation’ , Ecorys, 

2012, p. 10.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

REPLY OF THE COMMISSION50

Recommendation 4
The Commission agrees that, in addition to the project-
specific long-term monitoring indicators that are currently 
defined for each project, a common set of result indica-
tors  could  be  developed.  Both  sets  of  indicators  will  be 
systematically assessed in the ex post visits that are already 
being done to a sample of closed projects and the com-
mon  result  indicators  can  therefore  be  aggregated  at 
programme level. While this exercise will continue to be 
limited  to  a  sample  of  closed  projects,  the  aggregated 
indicators will provide a general overview of longer-term 
programme results.

70.
The Commission considers that the scores attributed to the 
projects were adequately justified based on the knowledge 
available at the time.

71.
The  reasonability  of  project  costs  is  one  of  the  aspects 
which  the  Commission  assesses  before  proceeding  to 
payments.

Recommendation 6 (a) and (b)
The  Commission  considers  that  the  new  dissemination 
requirements introduced in 2007 with the LIFE+ regulation 
improved the dissemination of project results. Neverthe-
less, the Commission will, as far as possible, continue to 
improve the dissemination of results. 

The Commission agrees that the aspects of sustainability 
and replication should be more explicitly assessed from 
the beginning of projects and not only at the time of the 
final reports. The Commission notes, however, that this is 
already the case concerning the dissemination work.

Recommendation 6 (c)
The  legal  advice  obtained  by  the  Commission  indicates 
that  it  cannot  impose  post-contractual  obligations  on 
bene ficiaries. The Commission agrees that a voluntary sys-
tem could be useful and, in practice, many beneficiaries 
already keep the Commission informed about the continu-
ation of projects. A systematic follow-up of that informa-
tion, however, would require a significant increase of the 
resources available for the management of the programme.

The Commission agrees that the sustainability and replica-
tion of projects should be more explicitly assessed from 
the beginning of the project and not only in the evaluation 
of the final reports.

Recommendation 5
The Commission agrees with the Court’s recommendation. 
The reasonableness of all costs is assessed by the monitors 
and the Commission desk officers on the basis of all the 
information available. The Commission will examine ways 
to continue to improve this assessment.

72.
The  Commission  considers  that  the  new  dissemination 
requirements introduced in 2007 with the LIFE+ regulation 
improved the dissemination of project results. Neverthe-
less, the Commission will, as far as possible, continue to 
improve the dissemination of results. 

The Commission also notes that the rate of sustainability 
and/or replication of LIFE ‘Environment’ projects identified 
by the Court is significantly higher than the ‘normal’ rate 
of success of innovative projects as described in scientific 
literature.

Special Report No 15/2013 – Has the Environment component of the LIFE Programme been effective?

REPLY OF THE COMMISSIONEuropean Court of Auditors

Special Report No 15/2013
Has the Environment component of the LIFE programme been effective?

Luxembourg: Publications Office of the European Union

2013 — 50 pp. — 21 × 29.7 cm

ISBN 978-92-9241-497-9
doi:10.2865/75865

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‘LIFE’ IS THE EU’S LONG-RUNNING PROGRAMME FOR DIRECTLY FUNDING THE ENVIR-

ONMENT. ITS MAIN OBJEC TIVE IS TO CONTRIBUTE TO THE DEVELOPMENT OF EU 

ENVIRONMENTAL POLICY. PART OF THE PROGRAMME CO-FINANCES INNOVATIVE 

OR DEMONSTRATIVE ENVIRONMENTAL PROJECTS AND, WITH A RELATIVELY LIMITED 

BUDGET, EFFEC TIVENESS DEPENDS ON WHETHER FUNDED PROJEC TS SERVE AS 

CATALYSTS  FOR  ENVIRONMENTAL  CHANGE. THE  CURRENT  REPOR T  EXAMINES 

WHE THER THIS  PART  OF THE  LIFE  PROGRAMME WAS  OPERATING  EFFEC TIVELY. 

THE  COURT  FOUND WEAKNESSES WHICH  SIGNIFICANTLY  REDUCED THE  LEVE -

RAGE OF THE PROGRAMME IN DEVELOPING EU ENVIRONMENTAL POLICY: POOR 

TARGETING OF RESOURCES; INSUFFICIENT JUSTIFICATION OF ASSESSMENTS OF 

PROJEC T  SELEC TION  AND  IMPLEMENTATION;  AND  POOR  DISSEMINATION  AND 

MONITORING OF PROJEC T RESULTS. THE REPORT MAKES SPECIFIC RECOMMEN -

DATIONS FOR THE COMMISSION TO IMPROVE THE DESIGN AND IMPLEMENTATION 

OF THE PROGRAMME, IN ORDER TO ACHIEVE ITS FUNDAMENTAL CATALY TIC ROLE 

FOR ENVIRONMENTAL POLICY.

EUROPEAN COURT OF AUDITORS