Specific concerns about the spending

Delayed programming threatens quality spending

The Croatian government has yet to develop its Operational Programmes and if the delay continues, it risks losing much-needed EU funds in the near future. In particular the strategic environmental assessment procedure may last up to six months. So in order for the Operational Programmes to be steered by this assessment, the start of the new funding period will therefore be significantly delayed. And thus begins the vicious circle: without the programme documents or strategies, local authorities are unable to plan regional development strategies, and no programmes or calls for project proposals can be developed to support the needed absorption capacities.

No funds yet planned for reduce, reuse and recycle

The draft Operational Programme does not include proper analyses in line with the EU’s Waste Landfill Directive and Croatian Accession Treaty, and the goals of the Waste Framework Directive – to prioritise the reduction, reuse and recycling of waste – are not included. Without consideration of the Waste Framework Directive with respect to the preparation of prevention plans, reuse and recycling will be modest – 50% of waste recycled by 2020 – contrary to many recent EU-initiatives like the Resource Efficiency Flagship.

Specific concerns about the spending

Zero support for renewable energy projects in cities, communities or non-profits

Two Operational Programmes are the most relevant for the transition to a low-carbon economy in the Czech Republic: Environment and Enterprise and Innovation for Competitiveness. Environment supports mainly energy efficiency in public buildings, with small scale renewables including solar water heaters and biomass boilers counted as efficiency measures. Renewables-based electricity production is only supported via Enterprise and Innovation for Competitiveness, meaning only small hydropower generation, biomass for heat and power and biogas are included. This means that only companies, including the largest, will benefit, while cities, communities and non-profit organizations who want to run their own renewables projects left in the dust. To offset the lack of support for solar and wind power, Czechs will mask investments into gas as a low-carbon measure, promoting energy security with yet more imports.

Waste incineration replacing material efficiency again

The recycling rates for biodegradable waste are far from the target necessary to be used in the most effective way. A genuine strategy for the waste sector is missing, and the reality is that the country has a clear agenda both in the current and future programming periods to increase waste incineration. This is evidenced by a recent law on energy sources that offers feed-in tariffs for combined heat and power produced from biomass, meaning waste incinerators that burn biodegradable waste together with the rest of mixed municipal waste. The current Operational Programme Environment sets no hierarchy for waste prevention, recycling or incineration, and experience from the current period shows that this lack of prioritisation has led to exaggerated levels of waste incineration, leaving many local biomass recycling projects waiting in vain.

More cars in Prague’s historic city centre

The transport sector strategy lacks any assessment of the sector’s impact on the climate, nor does it offer solutions to reduce emissions. While assessing impacts of Prague’s ring road, noise and emissions scenarios for Prague’s outskirts have been included, the impacts to the city centre are ignored, meaning that the strategy will promote the more harmful variant that brings transit traffic into the centre. Moreover the traffic intensity model used for transport planning in Prague and its surroundings assumes there will be less traffic in 2040 – good news, if it were based on reality and not an incorrect methodology. If not sorted during the strategic environmental assessment process, EU funding for transport might once again pave over the environment in Prague and quality of life for its residents.

Specific concerns about the spending

Green versus grey, or the question of climate adaptation on water resources

The draft Operational Programme Quality of Environment includes one big conflict on two very different approaches to combat the effects of climate change on water resources. Slovakia regularly faces both droughts and - after downpours - floods. As the development of water management techniques has progressed, the EU has pursued ecosystems-based adaptation measures that improve an ecosystem’s ability to stabilise water levels and flows. Although thanks to public pressure the European Commission has ruled out the financing of dams, the regulation of riverbeds through grey infrastructure remains a priority. This involves removing more rapidly than ever the natural vegetation that grows on riverbeds, as the development and construction phases do not take environmental issues into consideration. The active control of water still remains top of the agenda for water management in Slovakia as industrial and agricultural consumption of water steadily exceeds the available volumes. The efficacy of these measures for stabilising water regimes is questionable. Furthermore the adaptation axis set up neglects the second water related effect of climate change – decreasing water levels and droughts. Although drought does not have the character of a visible natural disaster, its effects are even more far reaching and destructive than those from floods. It is necessary, therefore, to bring the focus back to climate adaptation and prevent a set up that tackles only the end effects of an unstable water regime, and create potential to combat water regime instability where it makes most sense.

Supporting renewables – not all are welcome

Quality of Environment introduces support for renewables in two ways. One is standard support for power plants, the other is small-scale building installations as a part of a more complex energy refurbishment. While the setup appears solid, on closer inspection it is apparent that support for photovoltaics and wind power is missing. Critics argue that photovoltaics received unfair support in the past and nobody wants mirror fields, while no wind potential exists in Slovakia and its instability would make the grid suffer.

However support schemes for photovoltaics have improved, and its future potential should be assessed on a case by case basis, not a national average. At the same time, while Slovakia could focus on support for smart-grid solutions and begin a systematic transformation of the energy sector, it instead continues to upgrade existing and outdated infrastructure. Limiting the type of resource that is supported will affect decisions about how energy is produced, so Quality of Environment should create the conditions for equal access to financing, based on stringent analyses and feasibility studies.

How climate friendly are transport spending plans? Water transport in Integrated Infrastructure

A surprising proposal has appeared in the draft Operational Programme 'Integrated Infrastructure' – a huge water canal project as a priority spending measure. Not only would a mega-project such as the Danube- Oder-Labe canal affect a river basin that supplies a good majority of Slovakia’s population, its economic feasibility is also questionable. With technical complexities that include 20 lock chambers, huge investments needed in the hilly Kysuce region, and existing rail and waterway infrastructure in Slovakia and the Czech Republic, the soundness of investments of this scale is highly dubious. What's more, assessing just the feasibility of such a project would require dolling out large sums of money for studies and project documentation.

Specific concerns about the spending

Stakeholder left out on tackling climate change

The programming for climate change mitigation and adaptation objectives happened without the involvement of partners and stakeholders like NGOs or renewable energy industry representatives. Generally the topic of climate change was not recognised as important during the programming, and no assessment of the investments needed to decarbonise the economy was done.

Strategic Environmental Assessment neglected

While the strategic environmental assessment identified important aspects for Estonia’s sustainable development, its results and conclusions are not reflected in the Operational Programmes. The assessment points out that an analysis is missing of budgetary allocations and whether carbon assessment tools were used to calculate the impacts of climate change on the allocations. Moreover no assessment was made about whether the allocations are complementary to the evaluations and needs assessments outlined in the Partnership Agreement. According to the assessment, many transport investments are in contradiction to environmental targets, and more emphasis should be placed on public transport and green infrastructure, with railways rather than motorways being used to transport goods. However such recommendations are neglected by the programming documents.

Specific concerns about the spending

Low-interest loans are as good as anything

Many regions in Poland plan to exclude financial instruments from their Operational Programmes, claiming that municipalities and other potential beneficiaries are already indebted and if they receive anything but grants they will not be able to absorb the money. When the appropriate national support systems are put in place, renewable energy sources will provide substantial economic benefits, with financing for such projects from the EU funds provided via a reasonable mix of grants and loans to deliver stable and attractive rates of return for the investor while not over-subsidising the investment. Such a system will ensure that EU funds leverage the benefits of energy efficiency and renewable energy sources, while not limiting these to a narrow or privileged group who would then receive an unjustifiable level of public support.

The devil is in the details

While the proposed 'low-carbon economy’ allocation of 10% in the Partnership Agreement is far from satisfactory, regional ambition in this regard seems far better, with places like Lubelskie allocating as much as 24%. This is particularly commendable given that it is one of the poorest regions in Poland. However a closer look at the numbers suggests that in most cases, the highest allocation under this objective goes to ‘low emissions strategies’, which account for improvements for things like public transport, modernisation of heating grids - general municipal investments. For example in the Opolskie region, 55% of Thematic Axis 4 allocations for ‘low emission strategies’ mention items like new buses, while energy efficiency investments in public buildings and housing is only at 4%. This is contrary to the Commission’s recommendations that place priority on energy efficiency and renewable energy measures within this objective.

Specific concerns about the spending

More roads, no alternatives

The Partnership Agreement claims to focus on low-carbon transport through the development of railways, but at the same time it plans to reduce the rail network to a ‘sustainable size’. Meanwhile Bulgaria continues to press for EU funds for any type of road infrastructure – whether or not it is priority under the TEN-T – and argues that motorways are less carbon-intensive than rural roads. Additionally roads that will be funded during the 2014-2020 period have not been presented to participants in the Operational Programme Regions in Growth working group. While funds are necessary in the national budget for the improvement of the road system, EU funds should address EU priorities and in this case sustainable transport that contributes to greenhouse gasses emission reductions.

Cradle-to-concrete

The Partnership Agreement does not consider the construction waste targets for 2020, in which each Member State is required to recycle 70% of construction waste. Production of concrete is one of the largest culprits of CO2 emissions and causes of environmental harm in Bulgaria.

Who fears the GPP?

Green public procurement is often mentioned in the Partnership Agreement as an instrument to achieve better results and ensure EU funds are a model for public money. But green public procurement has not been adopted as obligatory in any of the Operational Programmes, meaning that climate-friendly opportunities outside of funds already ringfenced will be lost. Despite efforts from civil society to promote rules for green public procurement, programming authorities maintain that they do not want to complicate procurement rules for applicants by introducing green public procurement, irrespective of the fact that they are quite straight forward.

Specific concerns about the spending

‘Business as usual’ investments dressed up as climate-friendly measures

Financing for drainage systems and anti-flood measures have been labelled ‘climate adaptation investments’ in Latvians single OP. However there are next to no indication of how these will address climate change. Rather those investments will be used to maintain and upgrade existing drainage systems. At the same time, there is no comprehensive climate change adaptation strategy and investment priorities in this area are unclear. So official figures suggesting investments for climate adaptation are merely a ruse.

The absence of climate mainstreaming

Neither Partnership Agreements not Operational Programmes consider how investments in transport infrastructure, industry, or even environmental protection will affect greenhouse gas emissions reductions. Previously the Ministry of Environment suggested that each infrastructure investment project should report on the impacts of CO2 – whether providing a net reduction or increase – however the managing authority is set against such measure. No other proper climate mainstreaming measures have been suggested.

No support for renewables

The Operational Programme of Latvia does not support for any type of renewable energy. To a large extent this can be attributed to the government's’ moratorium on renewable energy development, whereby previously-pledged support has either been frozen or withdrawn, and no new support measures are planned. Given the commitments under the EU 2020 initiative to increase the share of renewables to 40 percent – not including support for renewables from the EU funds – Latvia has missed an opportunity that will threaten its ability to meet renewable energy targets, since no other public investments are planned.

Specific concerns about the spending

Environmental concerns on adaptation measures in water management

The draft Partnership Agreement stipulates that the Operational Programme on energy and environment continues to invest into flood management along the Tisza river. The experience of the previous funding period shows that although the original plan included several ecosystems-based solutions, the investments in practice focused mainly on risk management. NGOs are urging the government to assess the implementation of the previous programme and include more aspects of sustainable landscape management.

Groups also criticising the Partnership Agreement for increasing the number of irrigated territories, which can lead to water wastage and soil degradation in the plains. While the Partnership Agreement includes more environmentally-friendly adaptation methods, these should be more focused with an emphasis on an ecosystems-based approach.

No involvement of environmental groups in the working groups on the Operational Programmes

The planning of the Partnership Agreement and Operational Programmes were not inclusive. The Hungarian government submitted a draft of the Partnership Agreement to the European Commission in June, without incorporating comments submitted by several partners. A consultation on the Partnership Agreement was organised in August, yet responses to the comments on the draft have yet to arrive. The development of the Operational Programmes is even less participatory. No environmental NGOs were involved in the programming working groups and have only now been able to comment on the programmes with the start of the public consultation. Requests for clarification about the process sent to the office of the Prime Minister have gone unanswered.

While the draft Partnership Agreement says that environmental NGOs will be involved in the monitoring of the implementation of Operational Programmes, no reference is made about capacity-building and networking support for partners, as is recommended by the draft European Code of Conduct on Partnership. Such shortcomings may prevent Hungarian green groups from integrating environmental and climate change mainstreaming measures with the programmes, as required by EU legislation.

Less allocation for environmental measures

Although the Operational Programmes are not yet published, inside sources suggest that even less money is planned for environmental measures when compared to the previous period. Waste prevention and management, resource use, water quality, nature conservation, green infrastructure and environmental education all may receive much less money. In some respects this can be seen as a backlash against successful public campaigns during the previous period, like awareness-raising about sustainable consumption, which may not be included in the programmes as an environmental issue. Less green infrastructure projects might be implemented, resulting in less biodiversity protection and the reduced quality of ecological corridors and ecosystem services. The programmes may also include very few funding for measures implementing Water Framework Directive, threatening Hungary with non-compliance.