Opinion of the European Committee of the Regions — 8th Environment Action Programme
Date: 2021-02-05
Institutions: Commission for the Environment, Climate Change and Energy, European Committee of the Regions
Subjects: EU environmental policy, EU programme, biodiversity, circular economy, climate change, environmental cooperation, environmental protection, green economy, reduction of gas emissions, regional and local authorities




C_2021106EN.01004401.xml










26.3.2021   


EN


Official Journal of the European Union


C 106/44






Opinion of the European Committee of the Regions — 8th Environment Action Programme
(2021/C 106/09)












Rapporteur-General:



Dimitrios KARNAVOS (EL/EPP), Mayor of Kallithea





Reference document:



Proposal for a Decision of the European Parliament and of the Council on a General Union Environment Action Programme to 2030, Brussels, 14.10.2020
COM(2020) 652 final, 2020/0300 (COD)








I.   RECOMMENDATIONS FOR AMENDMENTS


Amendment 1

Recital 9






Text proposed by the European Commission


CoR amendment




The 8th EAP should accelerate the transition to 
a regenerative
 economy that gives back to the planet more than it takes. A 
regenerative
 growth model recognises that the wellbeing and prosperity of our societies depend on a stable climate, a healthy environment and thriving ecosystems, which provide a safe operating space for our economies. As the global population and the demand for natural resources continues to grow, economic activity should develop in a way that does no harm but, on the contrary, reverses climate change and environmental degradation, minimises pollution and results in maintaining and enriching natural capital, therefore ensuring the abundance of renewable and non-renewable resources. Through continuous innovation, adaptation to new challenges and co-creation, the 
regenerative
 economy strengthens resilience and protects present and future generations’ wellbeing.


The 8th EAP should accelerate the transition to 
an
 economy that gives back to the planet more than it takes. A 
sustainable
 growth model recognises that the wellbeing and prosperity of our societies depend on a stable climate, a healthy environment and thriving ecosystems, which provide a safe operating space for our economies. As the global population and the demand for natural resources continues to grow, economic activity should develop in a 
sustainable
 way that does no harm but, on the contrary, reverses climate change and environmental degradation 
with mitigation or compensatory measures


and contributory benefits for local environment and communities
, 
follows up on the impacts on environment on a permanent basis
, minimises pollution and results in maintaining and enriching natural capital, therefore ensuring the abundance of renewable and non-renewable resources. Through continuous innovation, adaptation to new challenges and co-creation, the 
sustainable
 economy strengthens resilience and protects present and future generations’ wellbeing.






Reason








i)


Economic activities should be sustainable and continue to grow ensuring the protection of environment and the sustainable growth of local environment and communities, with dedicated measures and a monitoring mechanism or tools, such as Environmental and Social Management Plans (ESMP), etc. ii) The concept of the ‘regenerative economy’ enables the risk implying that nature and our environment can easily be regenerated. As an alternative, it is suggested the term ‘sustainable growth model’.





Amendment 2

Article 2.1






Text proposed by the European Commission


CoR amendment




The 8th EAP has the long-term priority objective for 2050 that citizens live well, within the planetary boundaries in a 
regenerative
 economy where nothing is wasted, no net emissions of greenhouse gases are produced and economic growth is decoupled from resource use and environmental degradation. A healthy environment underpins the well — being of citizens, biodiversity thrives and natural capital is protected, restored and valued in ways that enhance resilience to climate change and other environmental risks. The Union sets the pace for ensuring the prosperity of present and future generations globally.


The 8th EAP has the long-term priority objective for 2050 that citizens 
and their local communities live well, within the planetary boundaries in a 
sustainable
 economy where nothing is wasted, no net emissions of greenhouse gases are produced and economic growth is decoupled from resource use and environmental degradation. A healthy environment underpins the well-being 
and the health
 of citizens, 
upgrades ecosystem services, biodiversity thrives and natural capital is protected, restored and valued in ways that enhance resilience to climate change and other environmental risks. 
The 8th EAP aims to increase the connection between environment policy and health. A healthy living approach needs to be at the basis of all EU policies promoting human health, a healthy planet, a healthy economy and a healthy society with opportunities for all.
 The Union sets the pace for ensuring the prosperity of present and future generations globally.






Reason








i)


Multiple environmental policies are dealt with not just by individual citizens but also by local communities. ii) Considering the situation created by the COVID-19 pandemic, the health aspect should be further highlighted. The link between health and environment should also be highlighted, because of its fundamental importance. Local and regional authorities can see in their communities the impacts of environment policies on health and well-being. iii) The concept of ecosystem services is also connected with the healthy environment.





Amendment 3

Article 2.2






Text proposed by the European Commission


CoR amendment




The 8th EAP has the following six thematic priority objectives:


The 8th EAP has the following six thematic priority objectives:










(a)




irreversible
 and gradual reduction of greenhouse gas emissions and enhancement of removals by natural and other sinks 
in the Union
 to attain the 2030 greenhouse gas emission reduction target and achieve climate neutrality by 2050 as laid down in Regulation (EU) …/…32;












(a)




continuous
 and gradual reduction of greenhouse gas emissions and enhancement of removals by natural and other sinks 
or green investments


contributing to the reduction of CO2 emissions at Union, national, regional and local level
 to attain the 2030 greenhouse gas emission reduction target and achieve climate neutrality by 2050 as laid down in Regulation (EU) …/…32;














(b)




continuous
 progress in enhancing adaptive capacity, strengthening resilience and reducing vulnerability to climate change;












(b)




constant need for
 progress, 
especially in vulnerable regions and local areas,
 in enhancing adaptive capacity, strengthening resilience and reducing vulnerability to climate change;














(c)


advancing towards 
a regenerative
 growth model that gives back to the planet more than it takes, decoupling economic growth from resource use and environmental degradation, and accelerating the transition to a circular economy;












(c)


advancing towards 
a sustainable
 growth model that gives back to the planet more than it takes, decoupling economic growth from resource use and environmental degradation, and accelerating the transition to a circular economy;














(d)


pursuing a zero-pollution ambition for a toxic free-environment, including for air, water and soil, and protecting the health and well-being of citizens from environment-related risks and impacts;












(d)


pursuing a zero-pollution ambition for a toxic free-environment, including for air, water and soil, and protecting the health and well-being of citizens from environment-related risks and impacts;














(e)


protecting, preserving and restoring biodiversity and enhancing natural capital, notably air, water, soil, and forest, freshwater, wetland and marine ecosystems;












(e)


protecting, preserving and restoring biodiversity 
and ecosystem services


inside and outside protected areas,
 and enhancing natural capital, notably air, water, soil, and forest, freshwater, wetland and marine ecosystems;














(f)


promoting environmental sustainability and reducing key environmental and climate pressures related to production and consumption, in particular in the areas of energy, industrial development, buildings and infrastructure, mobility and the food system.












(f)


promoting environmental sustainability and reducing key environmental and climate pressures related to production and consumption, 
by


using tools such as e.g. environmental impact assessments and appropriate assessments and developing methods and instruments for continuous cross-cutting impact monitoring and continuous improvement of environmental performance, in particular in the areas of energy, industrial development, buildings and infrastructure, mobility and the food system.










Reason








i)


The reduction of air emissions could be achieved not only by natural and other sinks, but also with green and sustainable investments, ii) Enhancing adaptive capacity and strengthening resilience to climate change concerns more vulnerable areas, such as coastal areas, etc. Therefore, it could be said that it is mainly a regional and local issue. iii) Most of the areas (e.g. energy, industry, infrastructure, etc.) mentioned in point (f) require the environmental licensing process to be followed. This process can to some extent ensure their construction and operation in a sustainable way. It is therefore crucial to have a mechanism for permanent monitoring and continuous improvement of their environmental performance.





Amendment 4

Article 3.1(b)






Text proposed by the European Commission


CoR amendment





1.   Achieving the priority objectives of the 8th EAP will require:




1.   Achieving the priority objectives of the 8th EAP will require:











(a)


… …












(a)


… …














(b)


strengthening the integrated approach to policy development and implementation, in particular by:












(b)


strengthening the integrated approach to policy development and implementation, in particular by:














 








—


mainstreaming the priority objectives set out in Article 2 in all relevant strategies, legislative and non-legislative initiatives, programmes, investments and projects at Union, national, regional and local levels so that they and their implementation do no harm to any of the priority objectives set out in Article 2;
















 








—


mainstreaming the priority objectives set out in Article 2 in all relevant strategies, legislative and non-legislative initiatives, programmes, investments and projects at Union, national, regional and local levels so that they and their implementation do no harm to any of the priority objectives set out in Article 2;












 








 








—




developing practices and carrying out activities that support local and regional authorities in meeting their objectives;














 








 








—




strengthening the cooperation between the European Commission and the Committee of the Regions, in the framework of the Technical Platform for Cooperation on the Environment and exploring how to improve dialogue and information pooling;




















 








—


maximising the benefits from implementing the Directives 2014/52/EU and 2001/42/EC of the European Parliament and of the Council;
















 








—


maximising the benefits from implementing the Directives 2014/52/EU and 2001/42/EC of the European Parliament and of the Council;


















 








—


paying careful attention to synergies and potential trade-offs between economic, environmental and social objectives so as to ensure that citizens’ needs for nutrition, housing and mobility are met in a sustainable way that leaves no-one behind;
















 








—


paying careful attention to synergies and potential trade-offs between economic, environmental and social objectives so as to ensure that citizens’ needs for nutrition, housing and mobility are met in a sustainable way that leaves no-one behind;












 








 








—




ensuring that reaching the long-term priority objective for 2050 as set out in Article 2.1 will not come at the cost of higher taxes, higher energy prices, and/or elevated regulatory burden for European consumers and businesses;




















 








—


regularly evaluating existing policies and preparing impact assessments for new initiatives, which are based on wide consultations following procedures that are accountable, inclusive, informed and simple to implement, and which pay due regard to projected impacts on environment and climate;
















 








—


regularly evaluating existing policies and preparing impact assessments for new initiatives, which are based on wide consultations following procedures that are accountable, inclusive, informed and simple to implement, and which pay due regard to projected impacts on environment and climate;












 








 








—




promoting communication activities at the EU, national, regional and local level, aimed at raising awareness, especially among young people, about the importance and benefits of a sound implementation of environment policy, as well as about its added value to the citizens, businesses and the planet, in order to increase a sense of ownership and the participation of all the relevant stakeholders in the implementation efforts;
















Reason








i)


The Technical Platform for Cooperation on the Environment was created in 2012 and subsequently included in the 7th EAP. As indicated by the webpage of the platform, its inclusion in the 7th EAP places it on a sound and long-term basis. Considering the positive experience of cooperation, the inclusion in the 8th EAP would be a natural step that would ensure continuing support this forum. ii) Communication needs further improvement and LRAs can play an important role on that.





Amendment 5

Article 3.1(d)






Text proposed by the European Commission


CoR amendment




mobilising sustainable investments from public and private sources, including of funds and instruments available under the Union budget, via the European Investment Bank and at national level;


mobilising sustainable investments from public and private sources, including of funds and instruments available under the Union budget, via the European Investment Bank and at national level
, ensuring the right synergies, while making sure that sufficient investment can be allocated at the level where it is most needed and most effectively employed, ensuring that local and regional communities have adequate resources for implementation on the ground
;






Reason


In many cases, environmental policies are implemented with the strong involvement of local and regional authorities. It is essential to ensure that adequate resources are available to local and regional communities. Even when national authorities have responsibility for executing policies, often the direct and indirect impacts of policies on the ground are managed at local and regional level.

Amendment 6

Article 3.1(e)






Text proposed by the European Commission


CoR amendment




phasing out environmentally harmful subsidies at Union and national level, making the best use of market-based instruments and green budgeting tools
, including those required to ensure a socially fair transition,
 and supporting businesses and other stakeholders in developing standardised natural capital accounting practices;


phasing out environmentally harmful subsidies at Union and national level, making the best use of market-based instruments and green budgeting tools and supporting businesses and other stakeholders in developing standardised natural capital accounting practices 
while ensuring socially fair transition for all regions, cities and municipalities
;






Reason


Socially fair transition should apply to all the instruments, not only green budgeting tools, and concern all the regions, cities and municipalities across the EU.

Amendment 7

Article 3.1(f)






Text proposed by the European Commission


CoR amendment




ensuring that environmental policies and action are based on the best available scientific knowledge and strengthening the environmental knowledge base and its uptake, including by research, innovation, fostering green skills, and further building up environmental and ecosystem accounting;


ensuring that environmental policies and action, 
at the Union, national, regional and local levels,
 are based on the best available scientific knowledge and strengthening the environmental knowledge base and its uptake, including by research, innovation, fostering green skills, and further building up environmental and ecosystem accounting
, as well as fostering the continuous improvement of scientific knowledge on the basis of indicators comparable at regional level as well, in order to inform decision-making
;






Reason


The proposed amendment highlights the critical role of all levels, and seeks to strengthen the capacity to assess progress towards the overall aims of the 8th EAP at all levels, including indicators at regional level.

Amendment 8

Article 3.1 — add a new point (h) after point (g)






Text proposed by the European Commission


CoR amendment




—










(h)






ensuring the full participation of, and cooperation with, local and regional authorities across all dimensions of environmental policy-making through a collaborative and multi-level governance approach;












Reason


The proposed amendment is expected to contribute in strengthening of policy development and implementation.

Amendment 9

Article 3.1 — add a new point (j) after point (i)






Text proposed by the European Commission


CoR amendment




—










(j)






promoting the benefits of the 8th EAP at local and regional level as an essential part of the effective and efficient implementation of EU environment policy, as set out in the Environmental Implementation Review (EIR);












Reason


It is important to communicate and promote the benefits of the 8th EAP in order to increase the implementation rate of environmental policies.

Amendment 10

Article 3.2






Text proposed by the European Commission


CoR amendment




Reaching the 8th EAP’s priority objectives will require mobilising broad support by involving citizens, social partners and other stakeholders, and encouraging cooperation in the development and implementation of strategies, policies or legislation related to the 8th EAP amongst national, regional and local authorities
, in urban and rural areas
.


Reaching the 8th EAP’s priority objectives will require mobilising broad support by involving citizens, social partners and other stakeholders, and encouraging cooperation in the development and implementation of strategies, policies or legislation related to the 8th EAP amongst national, regional and local authorities. 
The EU will promote a holistic place-based and area-oriented approach taking into account the specific challenges and strengths of all typologies of communities such as urban and rural, but also coastal, mountain, island, archipelagic and outermost areas. This approach will consider the interactions between communities and their surrounding areas, in particular hinterlands of urban areas.








Reason


Local and regional authorities in the EU are of multiple typologies, each with its own challenges and strengths. Environmental policies have often a strong territorial component that needs to be adapted to the specific situation on the ground. The 7th EAP focuses mainly on the urban dimension. The proposal for an 8th EAP only mentions urban and rural areas. The rich complexity of EU communities needs to be central for an effective implementation of EU environmental policies.

Amendment 11

Article 4






Text proposed by the European Commission


CoR amendment





1.   The Commission, supported by the European Environment Agency and the European Chemicals Agency, shall assess and report on the progress of the Union and the Member States with regard to achieving the priority objectives laid down in Article 2 on a regular basis, taking into consideration the enabling conditions laid down in Article 3.




1.   The Commission, supported by the European Environment Agency and the European Chemicals Agency, shall assess and report on the progress of the Union and the Member States with regard to achieving the priority objectives laid down in Article 2 on a regular basis, taking into consideration the enabling conditions laid down in Article 3.






2.   The assessment referred to in paragraph 1 shall reflect the latest developments as regards the availability and relevance of data and indicators, building on data available in the Member States and at the Union level, in particular those operated by the European Environment Agency and the European Statistical System. This assessment shall be without prejudice to existing monitoring, reporting and governance frameworks and exercises covering environment and climate policy.




2.   The assessment referred to in paragraph 1 shall reflect the latest developments as regards the availability and relevance of data and indicators, building on data available in the Member States and at the Union level, in particular those operated by the European Environment Agency and the European Statistical System. This assessment shall be without prejudice to existing monitoring, reporting and governance frameworks and exercises covering environment and climate policy.






3.   The European Environment Agency and the European Chemicals Agency shall support the Commission in improving the availability and relevance of data and knowledge, in particular by carrying out the following:




3.   The European Environment Agency and the European Chemicals Agency shall support the Commission in improving the availability and relevance of data and knowledge, in particular by carrying out the following:











(a)


gathering, processing and reporting evidence and data with modern digital tools;












(a)


gathering, processing and reporting evidence and data with modern digital tools;














(b)


working towards closing the relevant monitoring data gaps;












(b)


working towards closing the relevant monitoring data gaps;














(c)


delivering policy-relevant and systemic analyses, and contributing to implementing policy objectives at Union 
and
 national level;












(c)


delivering policy-relevant and systemic analyses, and contributing to implementing policy objectives at Union, national, regional


and


local
 level;














(d)


integrating data on environmental, social and economic impacts, and exploiting fully other available data, such as those delivered by Copernicus;












(d)


integrating data on environmental, social and economic impacts, and exploiting fully other available data, such as those delivered by Copernicus;














(e)


further improving access to data through Union programmes;












(e)


further improving access to data through Union programmes;















(f)



ensuring transparency and accountability;














(f)






improve the availability and interoperability of data at local and regional levels;

















(g)



helping civil society, public authorities, citizens, social partners and the private sector identify climate and environmental risks and take action to prevent, mitigate and adapt to them, and fostering their engagement in closing knowledge gaps.














(g)




ensuring transparency and accountability;








 










(h)




helping civil society, public authorities 
at national, regional and local level
, citizens, social partners and the private sector identify climate and environmental risks and take action to prevent, mitigate and adapt to them, and fostering their engagement in closing knowledge gaps.












(i)






fostering positive environmental links between urban, peri-urban and rural areas, in line with SDG 11: Sustainable Cities and Communities.











4.   The Commission shall regularly examine data and knowledge needs at Union and national level, including the capacity of the European Environment Agency and the European Chemicals Agency to carry out the tasks referred to in paragraph 3.




4.   The Commission shall regularly examine data and knowledge needs at Union and national level, 
and, when necessary, at regional and local levels
, including the capacity of the European Environment Agency and the European Chemicals Agency to carry out the tasks referred to in paragraph 3.







Reason


Local and regional authorities have an important role in implementing environment policy on the ground. The creation of the new monitoring framework should take these levels into account and also provide data with the aim of supporting implementation in local and regional communities.
II.   POLICY RECOMMENDATIONS

THE EUROPEAN COMMITTEE OF THE REGIONS








1.


welcomes the 8th EAP, which defines a strategic approach for environment and climate policies to 2030 and keeps a long-term vision for 2050 for living well within the planetary boundaries with a focus on better implementation and monitoring;












2.


calls for the 8th EAP to have a strong complementary role to the European Green Deal and to support the EU’s green recovery, through its long-term orientation and environmental priority objectives;












3.


urges that no precedent be set for future EAPs by the fact that the 8th EAP, unlike previous such programmes, includes no measures; underlines that it is only until 2024 that the Green Deal provides for measures relating to the priority objectives of the 8th EAP, which is valid until 2030; in this connection, calls for clarification in the 8th EAP of how, in the context of its midterm review, new measures to achieve its priority objectives are to be set;












4.


welcomes the fact that the 8th EAP has identified more effective and efficient implementation as a key priority, calls therefore for adequate instruments and resources, as well as innovative approaches that will empower LRAs to provide tailor-made solutions to improve the implementation of environmental policies on the ground;












5.


stresses that implementation problems cannot be solved by more legislation alone. Support mechanisms, new approaches and innovation are also needed to meet target values and standards.












6.


highlights the positive role of the Technical Platform for Cooperation on the Environment between the European Commission and the European Committee of the Regions and that its insertion in the 7th EAP placed it on a sound long-term basis; 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;












7.


calls to strengthen the environmental knowledge base, harnessing the potential of digital and data technologies and increase the use of nature-based solutions and social innovation to improve the implementation;












8.


underlines that the traditional, sectoral environmental policy is largely ineffective, therefore the 8th EAP, in order to strengthen environmental policy, should set up an integrated approach, address the multifaceted nature of environmental challenges, create synergies and avoid mismatches between:






a)


the ambition, timelines, implementation procedures and tools for different environment, energy and climate policies,










b)


the ambition and timelines of limit values of the EU environment legislation and those of source-based policies;
















9.


points out the mismatch between the adoption of the 8th Environment Action Programme and the Multiannual Financial Framework (MFF) 2021-27 and reiterates that the decision — making process of future EAPs should be aligned with the timeframe of the MFF;












10.


notes that effective gathering, processing and exploitation of data on the state of the environment is essential in order to achieve the objectives set. Practices still vary widely, however, and are often rudimentary with too much of the work carried out by humans, especially at local and regional level. The CoR therefore underlines the need for development activities and investments across the whole EU, through which the necessary data processing can be carried out in a uniform manner, emphasising compatibility and making use of automated data flows and open interfaces;












11.


considers that the ‘do not harm’ principle, as well as being a healthy living approach, should guide the recovery and resilience plans to ensure policy integration and coherence;












12.


calls for the full integration of environment and climate policies, and policies that enable a circular economy, into the budgetary, economic and social actions of the EU and reminds that the green recovery efforts should take into consideration territorial disparities and challenges and ensure that no community is left behind;












13.


reiterates its call for a holistic place-based or area-oriented approach as the best way of making healthy living for all a reality in line with the specific features of the place or area in question including biocultural diversity;












14.


welcomes the commitment to a recovery strategy based on the European Green Deal and reiterates its position that environmental, climate and transition challenges require significant green and blue investments and innovation at all levels of governance;












15.


calls for ambitious investments in key green sectors (e.g. renewable energy projects, circular economy, shift to environmentally friendly transport modes) needed to build resilience and create growth and jobs in a fair, inclusive and sustainable society based on solidarity, and highlights the multiple typologies of benefits created by them for the economy and the health and well-being of people. LRAs can have an important role in recovery and they should be involved in planning and execution of those investments when appropriate;












16.


points out that local and regional governments have a crucial role to play in engaging citizens, businesses, research centres, academia and local stakeholders in designing and implementing environmental policies;












17.


calls for a well-functioning multi-level governance framework and encourages all the levels of governance to promote cross-administrative, interregional, intermunicipal and cross-border cooperation to implement the 8th EAP;












18.


points out that more research, data and knowledge is needed to address specific environmental challenges and seize opportunities in different types of local and regional communities, bearing in mind rural depopulation, population ageing and regional differences, and emphasises the need that these data and knowledge should be publicly available and easily accessible;












19.


points out to the need for more local data, including directly collected from citizens or private bodies that develop green projects (e.g. soil, water, bird watching, habitats, etc.), and calls for a cooperation between the European Commission and LRAs to obtain local data, which is necessary for the better implementation of the EAP;












20.


supports the creation of a new monitoring framework with due regard towards existing frameworks such as the Environmental Implementation Review. Advocates the involvement of the CoR and LRAs in the consultation process to define the key indicators to ensure that the local and regional dimension is adequately taken into account;












21.


calls for ongoing efforts to strengthen environmental monitoring (e.g. biodiversity, zero pollution, toxic-free, a revised Circular Economy), linking it with cross-cutting monitoring tools (e.g. SDGs, Resilience Dashboard, etc.) and setting up headline indicators (e.g. Circular Economy, Climate and Energy, Toxic-free, Biodiversity, Zero Pollution, Pressures, EIR — Implementation indicators, etc.) based on general principles, such as quality assurance, balance, applicability, prioritisation, flexibility, timelines and periodicity;












22.


calls for the new monitoring framework to build as much as possible on existing monitoring tools and indicators used in environmental policy and the Governance of the Energy Union and Climate Action, and for it to bring together technical reporting requirements, so that duplication of work can be avoided wherever possible and the administrative burden limited;












23.


points out that the implementation of the 8th EAP can be accelerated by initiatives such as the Green City Accord or the European Year of Greener Cities in 2022, the urban agenda as well as voluntary actions such as the Covenant of Mayors for Climate and Energy and the Urban Mobility Observatory and that these should, therefore, be further promoted;












24.


supports greater efforts in environmental education and in youth projects to raise environmental awareness;












25.


acknowledges that the full implementation of many environmental policies can be achieved only with the full engagement in day-to-day actions of the citizens;












26.


recognises that more attention should be given to the interrelations between urban areas and rural actors, and to the fact that geographical typologies such as mountain areas, islands, coastal zones, outermost regions, etc. have incredible potential for the development of green investments (e.g. renewable energy projects);












27.


points out to the commitments made by vulnerable regions, including the coal and carbon intensive regions, as well as the outermost regions that aim to achieve decarbonisation by 2040, therefore asks to support the efforts of these regions to accelerate their strategies for global change, allowing them to become laboratories and testbeds for the difficulties that need to be addressed in order for the objectives in this area to be achieved;












28.


agrees with recital 19 of the EAP proposal stating that its objectives cannot be sufficiently achieved by Member States alone. The proposal, as it stands, does not appear to raise any issue regarding its compliance with the principle of subsidiarity. Nor does it raise any issue regarding its compliance with the proportionality principle;












29.


supports strengthening the EU system of access to justice and welcomes the proposed changes of the Aarhus Convention (1) underlines the need to strengthen the EU system on access to information, public participation in decision-making and access to justice in environmental matters; calls on the Commission to promote a dialogue with the CoR and LRAs to ensure that local communities have access to appropriate channels for access to justice and can fully contribute to improvement of implementation of EU environment policy.












30.


proposes to assess the possibility to establish a network of ‘ambassadors’ within the Technical Platform for the Cooperation on Environment to promote the implementation of the environment legislation at all levels of governance, in a form that would be compatible and complementary with existing efforts such as Technical Assistance and Information Exchange instrument (TAIEX) peer-to-peer tool, Environmental Implementation Review (EIR), Green Cities Accord and the Natura 2000 Biogeographical process.





Brussels, 5 February 2021.


The President of the European Committee of the Regions

Apostolos TZITZIKOSTAS




(1)  Texts and further information available in the following press release https://ec.europa.eu/environment/news/commission-proposes-improve-public-scrutiny-eu-acts-related-environment-2020-10-14_en