Opinion of the EuropeanCommittee of the Regions on ‘Towards an eighth Environment Action Programme (EAP)’
Date: 2019-02-07
Institutions: Commission for the Environment, Climate Change and Energy, European Committee of the Regions
Subjects: Community acquis, EU environmental policy, EU programme, action programme, circular economy, climate change policy, environmental protection, innovation, multi-level governance, town planning








C_2019168EN.01002701.xml










16.5.2019   


EN


Official Journal of the European Union


C 168/27






Opinion of the European Committee of the Regions on ‘Towards an eighth Environment Action Programme (EAP)’
(2019/C 168/06)






Rapporteur:


Cor LAMERS (NL/EPP), Mayor of Schiedam




Reference document:


Own-initiative opinion





POLICY RECOMMENDATIONS

THE EUROPEAN COMMITTEE OF THE REGIONS
A.   
Introductory comments










1.


Points out that the EU must show a higher ambition in all relevant policy domains, especially on climate, biodiversity and environment, to achieve the aims of the Paris Agreement and the UN Sustainable Development Goals (SDGs);












2.


Notes that insufficient implementation of EU environment, biodiversity and climate policies and legislation constitutes a risk to the long-term sustainability of our way of life, poses severe health threats and reduces the quality of life of EU citizens;












3.


Points out that a growing world population demands more food, energy and resources. The consequences – climate change, large-scale loss of nature reserves and decreasing biodiversity –are often disastrous;












4.


In this context it strongly believes the EU Environment Action Programmes (EAPs) provides strategic guidance, long-term visions and opportunities for ensuring consistency between environment and climate objectives, thereby providing added value;












5.


Underlines that much has been achieved under the EAPs as pollution in general has slowly started to decrease, nature is being better protected and the transfer to a low-carbon and circular economy has increased, but much more remains to be done;












6.


Points out that although the 7th EAP has identified better implementation as a key priority, insufficient implementation of environment policies and legislation – due to weak policy integration for example – remains a significant problem;












7.


Calls therefore on the European Commission, the Council and the Parliament to develop an 8th EAP in line with the objectives set out in this opinion;




B.   
Assessment of the 7th EAP










8.


Supports the conclusions of the European Parliament’s ‘Implementation of the 7th EAP report’ of 17 April 2018 (1), and the findings of the European Parliamentary Research Service study of November 2017 (2), and reiterates – based on the previous CoR opinions (3) – challenges such as the lack of policy integration, available funding and information about good practices;












9.


Notes nevertheless that the results on the core themes of the 7th EAP are uneven and insufficient:






a)


the objectives of priority 1 (protection of natural capital) will not be met by 2020;










b)


progress has been made on various sub-targets of priority 2 (low-carbon economy and resource efficiency), in particular on climate- and energy-related targets but also to some extent on waste/circular economy goals;










c)


it is uncertain to what extent goals under priority objective 3, linked to environment-related pressures and risks to human health, will be achieved;










d)


progress towards goals under objective 8 (sustainable cities) shows an uneven picture for energy efficiency, sustainable transport and mobility, sustainable urban planning and urban design, urban biodiversity and sustainable buildings;
















10.


Identifies four main causes for the shortcomings in implementation:






a)


a lack of integration of environmental concerns into other policy areas, especially the common agricultural policy (CAP), the common fisheries policy (CFP), and cohesion policy;










b)


insufficient funding and insufficiently tailor-made funding schemes: while a number of EU-funded projects have delivered improvements, not all EU funds have clearly defined sustainability criteria. Also, within the Member States there are insufficient funds available in this respect;










c)


insufficient knowledge-sharing: while there is sufficient expert knowledge available, this does not always find its way to the policymakers;










d)


poor involvement and engagement of local communities and stakeholders (4);
















11.


Concludes that the 7th EAP has demonstrated its added value and has had a positive influence on EU environmental policy, citizens, the environment and the economy. Its long-term vision is key in providing a stable environment for sustainable investment and growth, within the planet’s ecological limits;












12.


Highlights that the 7th EAP was comprehensive and very complex, with many sub-targets and detailed descriptions. Also, as the 7th EAP set targets for a given period (rather static), it was not easy to respond to new technology developments, changing circumstances and new international strategies;












13.


Points out that the 7th EAP outlined actions for improving the sustainability of cities, but neglected other types of communities, such as rural, coastal, mountain, island, archipelagic and outermost areas. While cities are important hubs for achieving the objectives, they do not exist in isolation from their surroundings. More attention should be given to the interrelations between cities and their hinterland;












14.


Supports the conclusion of the European Environment Agency (EEA) report, which flagged six causes for sub-optimal implementation of EU environmental legislation: ineffective coordination among local, regional and national authorities, lack of administrative capacity and insufficient funding, lack of knowledge and data, insufficient compliance assurance mechanisms and lack of policy integration (5);




C.   
The main principles for developing an 8th EAP



The changed context of European environment policy and its regional and local impact









15.


Stresses that unity and diversity are two important characteristics of the EU. These two concepts are fundamental to the very essence of the EU, especially when setting policy targets or developing new legislation;












16.


Points out that the strongest symbol of unity is the acquis. The European Committee of the Regions (CoR) therefore considers it to be the foundation of the 8th EAP. Its legislation, standards and values remain important tools for ensuring the environment is protected, addressing safety and risk issues and guaranteeing quality of life. The acquis also gives European people equal rights and a fair level playing field for trade and industry;












17.


Underlines there is also a clear EU obligation to respect political, social, economic, geographical and biocultural diversity between Member States, regions and cities. The extensive efforts of the EU have not always led to the desired outcome. Since big transitions are emerging, the 8th EAP should move away from top-down and one-size-fits-all solutions and create a bridge between unity and diversity by finding a balance between setting harmonised standards and providing space for the development of tailor-made solutions in line with the local context. It is therefore important that EU as well as national policies and legislation allow enough leeway for a local and regional approach;












18.


Stresses that the 8th EAP should support effective implementation of the current acquis, with the traditional role for the European Commission as guardian of the acquis;












19.


Points out in this regard that although traditional environment policy has been successful for over 40 years, it is no longer sufficient. Even when limit values are achieved, insufficient air quality, soil quality and water quality can still have negative impacts on human health and nature. Also implementation problems cannot be solved by more legislation alone. Support mechanisms, new approaches and innovation (in addition to the acquis) are also needed to meet target values and standards;












20.


In this context, highlights the problem that various Member States have introduced national legislation whereby fines arising from EU infringement procedures may be recovered from municipalities and regions. Such a ‘decentralization’ of the responsibility for complying with EU legislation is problematic because national authorities often focus only on the legal implementation, i.e. transposition into national legislation, but regional and local authorities are not given the necessary instruments to implement the acquis in fact and in practice. It is in most cases the European and national levels of government which have the appropriate financial, legal and administrative resources and should therefore bear the responsibility for paying fines for non-compliance;












21.


Strongly believes the EU should look for new ambition in transitions such as the transition to a circular economy, and transitions to a more sustainable energy, mobility and food production and consumption. It should also encourage Member States, regions and cities, who act as frontrunners, to reach an environmental quality, which goes beyond EU standards. This requires the European Commission to stimulate them into further action;












22.


Calls to recognise the efforts of regions who are pioneers in the circular economy, and also sustainable food production and consumption, as well as the reduction of air, noise and light pollution, and therefore to support them and facilitate the replication of best practices throughout Europe;












23.


Points out that the context in which environment policy was drafted and is now being implemented has changed, requiring a new balance between old and new approaches, including the following reasons:






a)


Today’s policies are more interconnected. In addition to the sectoral division of EU legislation into areas such as air, water, noise and energy, today’s challenges demand further integration of sustainability issues, both in people’s daily behaviour and the day-to-day running of businesses and on the socioeconomic front. Therefore the EU should see its regions as complex economic, social, environmental and biocultural systems;










b)


Innovation and transitions bring about the greatest improvements. Learning from each other is also important, requiring an open mind and awareness of both good and bad examples. Current legislation focuses on standards and limit values, whereas innovation and transitions require space for experimentation. The EU needs both;










c)


The EU follows a linear policy cycle (proposal, decision, implementation, evaluation), but the speed of innovation requires a more circular and flexible approach;
















24.


Stresses that this new context requires a different line of thinking and should focus on the interdependence of all five components of the causal framework as adopted by the EEA, namely drivers, pressures, states, impacts and responses. Classical environment policies focus on states and impacts. However, to tackle present and future pollution, EU and national policies should also focus on drivers and pressures. This is the core of the circular economy and other transitions: to tackle the issue directly at the source;





Policy integration









25.


Strongly believes the 8th EAP should ensure policy integration;












26.


Underlines that an integrated approach avoids mismatches and connects different aspects, such as:






a)


the ambition, timelines, implementation procedures and tools of different environment and climate policies;










b)


environment and climate policies as well as other policies, such as the CAP, the CFP, economic and social policies;










c)


the ambition and timelines of limit values of EU environment legislation (emissions policy) and those of source-based policies (emissions policies) (6);










d)


EU, national, regional and local policies, in order to align priorities, avoid duplication and minimise contradictory or disconnected processes, as well as to close gaps in existing policy and the ensuing legislation;
















27.


Underlines that the key question is how the EU and other levels of government can efficiently integrate policies, especially how to reconcile environmental, social and economic objectives;












28.


Points out that since policy integration requires another mind-set, the 8th EAP should:






a)


see policy integration as an approach (instead of a priority) of combining and strengthening separate objectives;










b)


encourage EU, national, regional and local authorities to put environment policies at the heart of all other policies (instead of only mainstreaming, environment goals should be at the basis of other polices) and to take environment policies as the main benchmark for implementation of all activities;










c)


take a holistic approach: the 7th EAP initiated a more integrated approach than the previous EAPs; the 8th EAP should go further and look at the environmental, economic and social contexts as a whole;









Funding and investments









29.


Stresses that environmental, climate and transition challenges require significant green and blue investment and innovation;












30.


Stresses that more synergies between various funding sources at the EU, national and regional levels are needed, as well as stronger links between public and private financing to increase the effectiveness of the 8th EAP;












31.


Points out that LRA investment possibilities are limited and under pressure. On the one hand, social issues such as unemployment, population ageing and education are often major cost items on local and regional budgets. On the other transitions, such as the energy transition, require considerable investment. To achieve significant progress in the transitions, a critical mass has to be achieved and LRAs need additional funds for this;












32.


Welcomes the proposal to set up the InvestEU programme and its focus on sustainability, as well as the Commission proposal for the Multiannual Financial Framework (MFF) post 2020, with its focus on sustainable development and integrating environment policy into all the budget headings. However, the CoR would like to see over 30 % of the budget reserved for climate policy mainstreaming. It also calls for a Just Energy Transition Fund at the EU level to address environmental, economic and social challenges of regions undergoing energy transition as well as a sufficient support for waste management and mobility transitions in all regions, that is additional to and compatible with the cohesion funds;












33.


Strongly welcomes the horizontal principles of the Commission proposal for the MFF post 2020: fostering integrated social, economic, cultural and environmental development and security in urban, rural and coastal areas;





A place-based or area-oriented approach









34.


Believes that a tailor-made approach is essential, because regions and local administrations:






a)


are important spatial entities in which people live, work and move around, resulting in a significant amount of emissions;










b)


vary significantly in terms of the type and amount of pollution and emissions;










c)


vary in their implementation of EU legislation;










d)


vary significantly in the economic, social, geographical and environmental opportunities they offer and challenges they present;










e)


vary in their administrative powers, capacity and approach to implementing environment and climate policies;










f)


are in the privileged position of working directly with people and businesses to promote measures such as green public procurement, building and transport policies, education, research and awareness-raising programmes. This allows them to come up with viable solutions and function as living labs for new ideas and knowledge;
















35.


Advocates a holistic place-based or area-oriented approach as the best way of making healthy living a reality in line with the specific features of the place or area in question;












36.


Recommends, with due regard to the principles of subsidiarity and proportionality as well as the government structure and culture of the different Member States, that the 8th EAP develop a number of area-oriented strategies, such as healthy and prosperous urban and metropolitan areas, a healthy vibrant countryside, and safe and attractive coastal, island, archipelagic and outermost areas. The urban strategy could focus on specific urban aspects, such as mobility and urban planning, while the rural strategy could focus on nature, innovation in agriculture and demographic change. The purpose of the recommended strategies would be to support the different transitions while taking into account human health and nature, the economy and the need for a good living environment, in the spirit of the SDGs. In this respect the 8th EAP reflects the horizontal principles of the Commission proposal for the MFF post 2020;





A multi-level approach









37.


Calls therefore for a well-functioning multi-level governance framework. Radical and lasting lifestyle changes, necessary for creating an equitable, sustainable and low-carbon society, require bottom-up as well as top-down approaches. The CoR therefore believes the 8th EAP should have a clearer link to the strategies and plans developed at the EU, national, regional and local levels;












38.


Calls therefore on all levels of government to do their utmost to encourage cross-administrative cooperation, including cross-vertical government cooperation, interregional, intermunicipal and cross-border cooperation. In the same vein, the 8th EAP should further encourage – with respect to government structures and geographical situation within Member States – cities, municipalities and regional authorities to work with each other and across the EU;












39.


Supports EU initiatives such as the EU Urban Agenda Partnerships. The CoR recommends utilising the existing partnerships for sustainable land use, energy transition, climate adaptation, urban mobility, air quality and circular economy and actively considering setting up new cross-cutting environment and climate partnerships to support implementation of the acquis;












40.


Stresses that translating EU-level targets to concrete local targets is difficult but essential to achieve results and obtain citizens’ trust. Therefore believes that incentives for over-performing should be provided. Award programmes, such as the European Green Capital Award and Green Leaf, should be expanded to smaller towns and villages. Moreover, voluntary actions such as the Covenant of Mayors for Climate and Energy and the Urban Mobility Observatory should be further promoted;












41.


Recommends that Member States work more closely with local and regional authorities and encourage cities and regions to get more involved in developing and implementing national strategies and plans;












42.


Calls therefore on Member States to create appropriate institutional structures or platforms for closer cooperation and continuous consultation, such as vertical cross-governmental teams, whereby experts from different levels of government jointly draw up national plans and strategies;












43.


Stresses that coordination between different levels of government alone is not sufficient for effective governance. The CoR therefore calls on regions and cities to forge close links with civil society, the private sector and knowledge institutes, in and beyond their territories, and to support interregional cooperation in these areas, because such long-term partnerships will contribute to good policy-making;












44.


Points out that this would promote dialogue and discussion among actors with different interests, backgrounds and constraints, resulting in better decision-making;












45.


Encourages EU Member States to define and fund holistic, solution oriented transdisciplinary research projects, within their national research funds;




D.   
A proposal for an 8th EAP



A new approach for the 8th EAP









46.


Points out that in the new context of environment policy the 8th EAP should:






a)


be more strategic and integrated and focus on major themes;










b)


boost innovation;










c)


allow the transfer and scaling up of innovative solutions;










d)


be guided by challenges and solutions, unlike the 7th EAP was guided by limits and problems;










e)


be flexible, to respond to new technological developments and new international strategies, unlike the rather static 7th EAP;










f)


be flexible regarding the social, cultural, economic and environmental contexts of the regions;
















47.


Calls on the UK and EU, in the context of the Withdrawal Agreement and its implementation, to develop joint arrangements that ensure high environmental standards and reciprocity remain, including the high of ambition in the next Environmental Action Programme;












48.


Stresses that future EAPs should be agenda-setting and lead to the integration of sustainability criteria into other EU policies, macroeconomic priorities and financial instruments. Environmental factors are also an indicator of how sustainable our economic development is. The CoR therefore advocates synergy between the 8th EAP, and the MFF and the European Semester;












49.


Regrets in this regard the mismatch between the adoption of an 8th EAP and the MFF post-2020. The decision-making process of future EAPs should be aligned with the timeframe of the MFF so that the proposed MFF reflects well EAP objectives;












50.


Proposes the 8th EAP be the environmental and climate pillar of the new Europe post 2020 Strategy;





Proposed themes for the 8th EAP









51.


Considers the healthy urban and rural living approach a practical and integrated approach. This approach, based on quality of life, integrates the three pillars of sustainable development – economic, environmental and sociocultural aspects – and places human health and nature in the wider context of sustainability. It also ties in with the implementation of the SDGs;












52.


Proposes that the 8th EAP present an EU strategy to promote healthy living for all, bringing together the concepts of:






a)


human health, including a high quality of life;










b)


a healthy planet where resources are used responsibly and efficiently, protecting biodiversity, geodiversity and ecosystems;










c)


a healthy economy based on the circular economy, with sufficient growth, sustainable development, jobs, sustainable investment and a sustainable business environment;










d)


a healthy society with opportunities for all;
















53.


Calls on the EU to take the healthy living approach as the basis for all EU policies, its macroeconomic priorities and financial instruments. This approach should also be promoted and implemented at national, regional and local levels. The CoR proposes the EU work more closely with healthy living networks, such as the WHO healthy cities network;












54.


Stresses the 8th EAP should address transition challenges, such as the energy transition, the circular economy, the mobility transition, the transition in food production and consumption and the transition from grey to green and blue infrastructure. Production, consumption and transport practices are key air, water, soil and noise pollution factors. These transitions are in line with source-based policies and therefore will support the implementation of current EU legislation. They are linked to transitions in quality of life: to healthy living in urban areas and better quality of life and vitality in rural areas. The 8th EAP should facilitate these transitions and set out implementation timetables;












55.


Proposes the continuation of the core themes of the 7th EAP – to protect, conserve and enhance the EU’s natural capital, to turn the EU into a resource-efficient, green and competitive carbon-neutral economy, including providing a framework for accessible, sustainable transport of people and goods, ensuring green mobility in urban as well as rural areas; to shield EU citizens from persistent environmental pressures and improve health and wellbeing – as these themes are still very relevant (with possible additional subjects);












56.


Underlines that the 8th EAP should meet the Paris Agreement requirements and incorporate the 17 SDGs. It should be flexible enough to take new international developments and agreements into account;





Proposed structure of the 8th EAP









57.


Proposes a lean clean 8th EAP, with five main chapters: implementation, the transitions, innovation, wider global challenges and communication;












58.


Proposes that these chapters be implemented through EU action agendas with measurable objectives, targeted actions, funding, investments, tools and a clear monitoring mechanism for example via the Environmental Implementation Review process. With these agendas, the EU can create cross-overs between the five chapters of the 8th EAP, develop tailor-made area-oriented solutions and adequately respond to new developments and innovative practices. The EU action agendas in turn can inspire national, regional and local action plans;












59.


Believes that – with due regard to the principles of subsidiarity and proportionality as well as the government structure and culture of the different Member States – the 8th EAP should encourage the adoption of national and/or regional action plans. It is up to the Member States to decide whether to have one national or several regional plans or both, as these decisions are closely linked to national and regional government structures. The next EAP should outline the guiding principles for LRAs to take action and urge the adoption of voluntary local objectives and plans. This would help implement the EAP while allowing some flexibility to take local needs and local capacity, knowledge and expertise into account in solving local problems;












60.


Proposes the first chapter of the 8th EAP consist of the core themes of the 7th EAP. These themes require efficient implementation;












61.


Stresses that the first chapter requires EU implementation action agendas, which include actions outlined in the European Implementation Review (7) and the supporting objectives of the 7th EAP; such as:






a)


better policy integration, more effective source based polices, targeted EU-funding;










b)


research into different implementation challenges;










c)


implementation tools: at the moment environment and climate legislation have their own set of tools and guidance materials. To avoid confusion and ensure greater coherence, the CoR proposes a more unified method with capacity building instruments (e.g. tools and programmes, workshops, webinars, guidance materials, etc.);










d)


collection of knowledge and best practices in a single, publicly accessible and easily searchable database which contains the appropriate features that help identify best practices;










e)


actions to promote, expand and finance existing and new initiatives that support knowledge and best practice sharing by European, national, regional and local networks and city-to-city cooperation such as peer-reviews and mutual learning activities, site visits, green twinning, partner-to-partner mentoring and coaching;










f)


monitoring via the Environmental Implementation Review process;
















62.


Calls on the 8th EAP to further enhance the Technical Platform for Cooperation on the Environment established by the ENVE Commission and DG Environment to foster a dialogue, and gather information on local and regional challenges and solutions in the application of the EU environment law; proposes to establish a network of ambassadors within the Platform to promote the implementation of the environment legislation at all levels of governance, complementing in this way the EIR and TAIEX;












63.


Proposes to focus more on the implementation aspects/challenges in the EU environment policies via CoR opinions as well as the work of the future regional hubs (8) in order to address the gaps and find tailor-made solutions;












64.


Proposes the second chapter address the main transitions (the energy transition, the circular economy, the mobility transition, the transition in food production and consumption and the transition from grey to green and blue infrastructure) and propose the necessary legislative and financial framework to facilitate these transitions in a just way to further stimulate innovation in pioneering regions and support carbon-intensive regions undergoing costly energy transitions;












65.


Underlines that the second chapter requires implementation through EU transition agendas with actions and funding to facilitate each transition and the further implementation of innovation on the ground. This involves concrete actions at the regional and local level. The 8th EAP should stimulate the development of national and regional transition agendas. These agendas, which identify challenges, joint actions and appropriate policy responses, could be produced by means of co-creation;












66.


Proposes the third chapter boost green innovation and investment. Further innovation is of the utmost importance, to face environmental and climate challenges. This chapter should give research a more prominent role in formulating appropriate policy response;












67.


Stresses that the third chapter requires implementation through an EU green innovation agenda: an agenda towards healthy living, a sustainable society and a circular economy. The agenda should support research and development. It should be a co-production between policy-makers (EU, national, regional and local), industry and academia and should identify challenges, policy responses and joint problem-solving approaches. Such an agenda would encourage the European Commission, Member States, cities and regions to apply systemic innovative approaches and set up or facilitate partnerships in green innovation projects and address the role of governments as ‘launching facilitators’;












68.


Proposes the fourth chapter address wider global challenges. International developments and strategies, such as the Paris Agreement, the SDGs, the Convention on Biological Diversity and the UN Urban Agenda, heavily influence environment and climate policies. On top of that, many of the priority objectives in the 8th EAP can only be achieved in cooperation with partner countries or as a part of an overall approach, therefore improving the capacity of Regional and Local Governments to be involved in decentralised cooperation can be of significant benefit. Tackling pollution caused by industry, tourism and household activity, and dealing with environmental crime requires international commitment followed by concerted action;












69.


Emphasises that the fourth chapter requires implementation via an international environment and climate agenda for the EU to help the Union address these challenges as well as to play a leading role at the international arena by using economic and trade policies to benefit the global environment and climate;












70.


Proposes that the fifth chapter deals with communication and focuses on raising awareness about the importance and benefits of a sound implementation of the 8th EAP, as well as the added value of the 8th EAP to the citizens, businesses and environment. The implementation of the EAP would be greatly facilitated by an improved understanding among the citizens and the other stakeholders of the EU environmental priorities, actions to be taken, and the concrete results they could bring.





Brussels, 7 February 2019.


The President


of the European Committee of the Regions

Karl-Heinz LAMBERTZ




(1)  ref.: P8_TA(2018)0100

(2)  On the ‘Mid-term review of the implementation of the 7th Environment Action Programme (2014-2020)’.

(3)  The following CoR opinions: ENVE-V-044 (OJ C 271, 19.8.2014, p. 25); ENVE-V-045 (OJ C 271, 19.8.2014, p. 45); ENVE-V-046 (OJ C 415, 20.11.2014, p. 23); ENVE-VI/001 (OJ C 260, 7.8.2015, p. 6); ENVE-VI/005 (OJ C 51, 10.2.2016, p. 48); ENVE-VI/008 (OJ C 240, 1.7.2016, p. 15); ENVE-VI/011 (OJ C 88, 21.3.2017, p. 83); ENVE-VI/013 (OJ C 88, 21.3.2017, p. 43); ENVE-VI/014 (OJ C 207, 30.6.2017, p. 45); ENVE-VI/015 (OJ C 207, 30.6.2017, p. 51); ENVE-VI/021 (OJ C 54, 13.2.2018, p. 21); ENVE-VI-024 (OJ C 54, 13.2.2018, p. 9); ENVE-VI-028 (OJ C 361, 5.10.2018, p. 46); ENVE-VI-029 (OJ C 461, 21.12.2018, p. 30); and ENVE-VI-030 (OJ C 387, 25.10.2018, p. 42).

(4)  CoR study: ‘Towards an 8th Environment Action Programme- Local and regional dimension’.

(5)  EEA, Environmental indicator report 2017. In support of the monitoring of the Seventh Environment Action Programme (EEA report 21/2017); EEA, 2015. The European Environment: State and Outlook 2015: Synthesis report. European Environment Agency, Copenhagen.

(6)  CoR opinion: ENVE-V-046.

(7)  CoR opinion: ENVE-VI/021.

(8)  https://ec.europa.eu/commission/files/report-task-force-subsidiarity-proportionality-and-doing-less-more-efficiently_en