Opinion of the Regulatory Scrutiny Board
Date: 2024-06-06
Institutions: European Commission, Regulatory Scrutiny Board
Subjects: EU environmental policy, EU strategy, European Environment Agency, carbon neutrality, environmental monitoring, evaluation method, management techniques

EUROPEAN COMMISSION 

Brussels, 6.6.2024 
SEC(2024) 218 final 

REGULATORY SCRUTINY BOARD OPINION 

Commission Staff Working Document - Evaluation of the European 
Environment Agency (EEA) and its European Environment Information and 
Observation Network (EIONET) for the period 2017-2021 

{SWD(2024) 204 final} 
{SWD(2024) 205 final} 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Regulatory Scrutiny Board 

Brussels,  
Ares(2024) 

Opinion 

Title: Five-year evaluation of the European Environment Agency (EEA)  

Overall 2nd opinion: POSITIVE WITH RESERVATIONS 

(A) Policy context 

This  is  the  five-year  evaluation  of  the  European  Environment  Agency  (EEA)  and  the 
European  Environment  Information  and  Observation  Network  (EIONET)  covering  the 
period 2017-2021.  

The purpose of the evaluation is to assess whether the 1990 Founding Regulation is still fit 
for purpose in view of the changed EU policy priorities, including the European Green Deal. 

(B) Key issues 

The Board notes the improvements to the text responding to the Board's first opinion. 

However, the report still contains significant shortcomings. The Board gives a positive 
opinion with reservations because it expects the lead Service to rectify the following 
aspects:   

(1)  The  factual  evidence  base  is  too narrow  and  the  stakeholder  consultation  is  too 
limited. The adequacy and suitability of the monitoring system for the management 
and evaluation of the agency’s activities is not sufficiently assessed. 

(2) The conclusions and lessons learned section do not fully reflect all the findings of 
the analysis. 

(3) The potential for efficiency gains and for digitalisation in reducing operating costs 
is not sufficiently explored.  

(C) What to improve 

(1)  The evaluation predominantly relies on opinion-based evidence from a limited number 
of stakeholders, the majority of whom are the Agency’s staff. The report should be more 
transparent  about  this  limitation  throughout  the  analysis  avoiding  general  reference  to 
“(some)  stakeholders”  or  “(some)  interviewees”.  The  report  should  clearly  indicate  how 
much relative weight is given to factual evidence collected and which groups of stakeholders 
support which statement. Consequently, the conclusions on the effectiveness, coherence and 
relevance should be more nuanced as currently not sufficiently based on robust evidence. 

  ________________________________   
This opinion concerns a draft evaluation which may differ from the final version. 

Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 08/010. E-mail: regulatory-scrutiny-board@ec.europa.eu 

 
 
 
 
 
 
(2)  The report should assess in  greater  depth the adequacy  and suitability of the existing 
monitoring  system  for  the  management  of  its  activities  and  evaluating  the  Agency’s 
functioning. Whereas the revised report has made better use of the available evidence, it does 
not investigate it more thoroughly.  
(3)  The  report  should  better  reflect  in  its  conclusion  and  lessons  learned  section  all  the 
findings  of  the  analysis  section,  in  particular  the  need  (i)  to  develop  a  comprehensive 
monitoring  system  which  would  provide  robust  data  base  for  evaluation  of  effectiveness, 
efficiency and relevance, and not only for the KPIs, (ii) to improve the prioritisation process, 
and (iii) to measure resource allocation. 
(4)  The report should make a further effort to uncover what the critical issues are – apart 
from staff shortage – that impacted the Agency’s performance in the period under evaluation. 
It should better develop the potential for further efficiency gains, in particular the potential 
to reduce operating costs through digitalisation. It should also better distinguish the roles and 
responsibilities of the Agency and the JRC and EUROSTAT to avoid overlaps and maximise 
synergies, among other things, also in data interoperability and management. 
(5)  The report should be more specific on what data and evidence was used, and how, in the 
efficiency and effectiveness analysis. It should further apply the value for money concept 
and present in more structured way outputs and resources allocated.  

Some more technical comments have been sent directly to the author DG. 

(D) Conclusion 

The lead Service should revise the report before launching the interservice consultation. 

Full title 

Evaluation of the European Environment Agency (EEA) and the 
European  Environment  Information  and  Observation  Network 
(EIONET) for the period 2017-2021 

Reference number 

PLAN/2021/13163 

Submitted to RSB on 

21 May 2024 

Date of RSB meeting 

Written procedure 

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EUROPEAN COMMISSION 
Regulatory Scrutiny Board 

Brussels,  
Ares(2023) 

Opinion 

Title: Five-year evaluation of the European Environment Agency (EEA) 

Overall opinion: NEGATIVE 

(A) Policy context 

This  is  the  five-year  evaluation  of  the  European  Environment  Agency  (EEA)  and  the 
European  Environment  Information  and  Observation  Network  (EIONET)  covering  the 
period 2017-2021.  

The purpose of the evaluation is to assess whether the Founding Regulation is still fit for 
purpose in view of the changed environmental ambitions of the European Commission for 
the EU to become the first climate neutral continent in the world by 2050. 

(B) Summary of findings 

The  Board  notes  the  additional  information  provided  and  commitments  to  make 
changes to the report. 

However,  the  Board  gives  a  negative  opinion  because  the  report  contains  the 
following significant shortcomings: 

(1)  The intervention logic is not coherent and not specific enough. Its relevance is 
not discussed according to the evolving policy requirements. The underpinning 
factual evidence is lacking while the analysis relies heavily on the few opinions 
collected through an unbalanced stakeholder consultation. 

(2)  The  report  does  not  thoroughly  analyse  the  governance,  the  internal  control 
systems, as well as the resource allocation and the risk of overlap of tasks with 
Commission’s services. 

(3)  The conclusions and lessons learned are not coherent with the main analysis and 

findings hence they do not inform possible future actions.  

The Board considers that in its present form this report does not sufficiently respond 
to the mandate of the evaluation. 

(C) What to improve 

(6)  The  report  should  better  assess  the  continued  relevance  of  the  Agency’s  logic  of 
intervention  in  view  of  the  European  Green  Deal  policy  framework.  As  many  other 
Commission services contribute to its objectives, the intervention logic should include more 
specific objectives, as SMART as possible, for the Agency. The report should specify to what 

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extent the EEA’s objectives and mandate provided for in the Founding Regulation are still 
relevant.  

(7)  The report should better explain what purpose the evaluation serves and what points of 
comparison were used to assess expected outputs and results against actual ones during the 
evaluation period 2017-2021. The report should be more critical on the robustness of its data 
collection supporting the analysis of the actual functioning of the Agency. The report should 
better explain in how far the objectives of EEA and EIONET have been met with the delivery 
of the outputs mentioned, and to what extent these outputs generated the expected results. 

(8)  The evaluation predominantly relies on opinion-based evidence from a limited number 
of stakeholders, the majority of whom are the Agency’s staff. The report should be more 
transparent about data limitations, including the reasons for the limited interest on the part of 
stakeholders to participate. The report should indicate how much relative weight is given to 
factual evidence collected, for example, from the Agency’s own KPI  data,  desk  research, 
workshops, in-depth interviews and case-studies.  

(9)  The report should make a better effort to identify and describe what the critical issues 
are  that  impact  the  Agency’s  performance  in  the  period  under  evaluation.  It  should 
thoroughly evaluate how governance, strategic steering and functioning of the Management 
Board, internal control and monitoring systems and resource allocation of the Agency have 
evolved from the shortcomings identified in the previous evaluation. The report should also 
address issues of potential overlap and duplication of tasks with Commission services and, 
in  particular,  the  JRC.  The  report  should  clarify  to  what  extent  the  projections  of  EEA 
additional  staff  due  to  new  or  upcoming  legislation  are  in  line  with  the  estimates  of  the 
corresponding  financial  fiches.  The  report  should  clarify  how  digitalisation  could  drive 
potential simplification and burden reduction and how this would be taken into consideration 
in a future efficiency analysis. 

(10) The report should indicate more clearly how the evaluation applies the value for money 
concept. It should specify what data and evidence was used, and how, in the efficiency and 
effectiveness  analysis.  The  report  should  define  what  is  meant  by  “direct  benefits”, 
“synergies”,  and  “gains”  and  should  indicate  how  these  are  applied  in  the  cost-benefit 
analysis.  

(11) The  report  should  strengthen  the  validity  of  its  conclusions  and  should  significantly 
strengthen  the  alignment  of  the  conclusions  with  the  evidence,  analyses  and  evaluation 
findings earlier in the report. The report should be more l substantiated in its conclusions on 
the performance of the Agency in the period 2017-2021. The conclusions should also better 
reflect  the  learnings  from  the  preceding  five-year  evaluation  of  the  Agency  covering  the 
period  2012-2016.  The  report  should  draw  a  list  of  lessons  learned  that  should  serve  as 
meaningful inputs to future decisions.  

Some more technical comments have been sent directly to the author DG. 

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(D) Conclusion 

The  Board  advises  the  DG  not  to  launch  the  interservice  consultation  before 
substantially revising the report. 

The lead DG may resubmit to the Board a revised version of this report. 

Full title 

Evaluation of the European Environment Agency (EEA) and 
the European Environment Information and Observation 
Network (EIONET) for the period 2017-2021 

Reference number 

PLAN/2021/13163 

Submitted to RSB on 

15 November 2023 

Date of RSB meeting 

13 December 2023 

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Electronically signed on 06/06/2024 18:16 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121