Blog entry

How shared mobility can curb the hidden costs of reducing carbon emission with electric cars

On its path to meet its climate neutrality scenario, the EU is set to secure its supply of key raw materials underpinning its digital revolution and clean up the industry’s supply chains by 2025. The picture is all the more impressive when you consider that, by 2030, its demand for lithium is estimated to grow 18 times and for cobalt 5 times, compared to the current supply. By 2050, the figures for lithium approach almost 60 times more lithium and 15 times for cobalt.

The EU’s plan to deal with the slew of issues in the supply chain can’t come soon enough. Little has been done in terms of the lack of transparency and the high impact of the supply chain of ICT-related raw materials, starting with material mines, and stretching to smelters and complicated manufacturing networks.

A look at the lack of safeguards in Europe’s green transformation scenario shows that Commissions’ approach to hastily open mining projects in the EU and its neighborhood may amplify existing exploitative and corrupt practices that harm the nearby environment and livelihoods.

In Serbia, a planned lithium mine has illegal government support to the Rio Tinto corporation, lack of public participation, and secrecy surrounding the proceedings of the project.

Meanwhile, nearly two-thirds of the world’s storage of Cobalt is found in the Democratic Republic of the Congo (DRC) and about 10 per cent is excavated in small-scale mines associated with human rights allegations and reports of child labor.

The transportation question

For Dr. Harald Buschbacher, an e-mobility expert from Vienna, one way to address the impacts stemming from the green agenda’s push for resource extraction is found in improving public transportation and shared mobility. How shared fleets can become a driving factor in reducing resource consumption is a story of down-scaling range and passenger capacity of electric vehicles (EV).

“If everyone owns their individual vehicle, this means that not only a larger number will be used less than an hour per day, but also passenger vehicles have to come with five seats, high-speed, high crashworthiness and long-range,” he says.

A recent study has revealed just how redundant private ownership of passenger vehicles is in wealthy countries with good transport systems, showing that the European countries average 1.7 passengers in vehicles. This raises Buschbacher’s hopes for the wide-scale introduction of smaller and slower EVs such as these prototypes; a 2-user EV or an automated EV fleet.

“If people could take a shared vehicle for every trip, both the necessary number of vehicles and the required battery capacity of every single vehicle could be reduced,” says the expert. The battery capacity is the energy storage over a specific time and is driven by fuel economy, range, and powertrain configurations.

In terms of e-mobility management, the key is to integrate EVs into public transportation systems for a short to medium range such as their last leg of the journey between a rail station and one’s home in rural and suburban areas that lay beyond the coverage of commercial services.

Dr. Buschbacher suggests that “it seems realistic that shared cars would operate 25% of their lifetime, leading to maximally 50% of the vehicles in motion at the same time.” In cities with advanced public transport networks, “the number might be even lower because public transport tends to cover the greater bulk of the user mobility during peak hour rather than off-peak.” In the long run, he predicts the demand for vehicles to drop to a fifth, compared to a scenario with individual ownership.

The takeaway for reduced resource consumption is this: we need electric cars with lesser battery capacity because “the demand for key raw materials is proportional to the total demand of battery capacity in kilowatt-hour (kWh) and inversely proportional to battery’s lifetime, while the charging and discharging speed of batteries also factors into the battery capacity,” says Buschbacher.

If we want batteries “with less demand for some raw materials, then we should rather downsize the vehicles to meet the requirements of mostly short trips for one or two person, instead of upsizing electric vehicles to equal the driving range of those driven by fossil fuels,” which makes him endorse the mainstreaming of fleets of short-ranged and 2-user EVs in existing transportation networks.

And yet challenges remain around the energy density of batteries since charging smaller batteries takes longer, according to Buschbacher. But there is an array of alternatives under development, if not already on the market, that aim for higher energy density with different battery chemistries.

Driving ahead

Even if a varied choice of batteries gains traction on the market, the Commission needs to take clear policy action and allocate funds to meet its long-term goals of achieving a circular economy, reducing resource consumption, and making supply chains of raw materials fair and sustainable.

For Buschbacher, besides earmarking European funds for pilot projects to make carsharing systems more competitive and reduce individual car ownership, perhaps the most important measures are “stricter national and EU level legislation or financial motivators on non-sustainable sourced material” to curb the hidden cost of reducing carbon emission with electric cars.

In the end, city planners are part of this quest because the individual’s choice between car sharing and car ownership depends on whether spatial planning and public transport systems match their mobility needs. According to Dr. Buschbacher “in order to reduce the absolute resource consumptions, public transport should be improved, otherwise people will not have the possibility to choose vehicles with less range, and completed by carsharing.”

The cracks of Shuakhevi

When it rains, Mamuka Tsetskhladze and his family don’t stay at home. Not because they love to be outside during heavy rains in the mountains of Shuakhevi, located in Adjara, Georgia. But because there is a large piece of land next to their house that could slide any time and bury the Tsetskhladzes’ house.

It almost happened on 22 March 2021, when there was a landslide near the tunnel of Georgia’s controversial Shuakhevi hydropower plant. The tunnel lies under the village Nigazeuli, near the Tsetskhladze’s house.

‘We did not sleep all night. In the morning, all of this land had slid. If it rains, we can’t sleep at night. We go to our neighbours’ or cousins’ houses… And if this big mass of land moves, and it is expected that it will, we will be under a big threat’, Tsetskhladze said.

Some locals, including Mamuka Tsetskhladze, say that the construction of the tunnel for the power plant could be among the reasons for the landslide, because the cracks in the ground appeared in 2015 after explosions in the area due to the tunnel’s construction.

His neighbours, Vazha Tsetskhladze and Elguja Khimshiashvili, have no doubt that it’s because of the Shuakhevi power plant’s tunnel that 70 per cent of the water in their village disappeared. The water had never stopped before, they said in an interview.

Shuakhevi is one of Georgia’s biggest and most controversial hydropower plants, which is mostly famous for its failure: in 2017, two months after becoming operational, its tunnels collapsed at eight spots.

The 178 MW hydropower plant project also stands out in the region for the huge financial support it has received from international institutions: the Asian Development Bank (ADB), European Bank for Reconstruction and Development (EBRD), and International Financial Corporation (IFC) are among the funders of the project.

Since the construction of Shuakhevi commenced in 2013, local communities have been complaining about their cracked houses, decreased crops, disappeared drinking water and water leakages. They complain that these are the direct consequences of the construction.

In 2020, new problems came to light: one month after the newly repaired Shuakhevi power plant started operations, Georgian online media outlet Batumelebi published footage that showed water leaking out of Shuakhevi’s dam. The company financing the project said that these leaks were an ‘expected’ occurrence after the plant first became operational and that they were repairing the flaws with special ‘cementation’ measures.

But the cracks on the dam came back, and in more than one spot.

Adjaristsqali Georgia LLC (AGL) is the company behind Shuakhevi’s construction and operations. It is owned by Norway’s Clean Energy Invest AS, India’s Tata Power and IFC Infraventures. Norway’s Clean Energy is also associated with the construction of another controversial large dam in Georgia, Namakhvani, which has caused a wave of protest across the country. Thousands are still marching against its construction.

As a response to another round of problems with the Shuakhevi project this year, AGL told the media that the cracks on a 52-metre-high concrete dam are absolutely ‘normal’. AGL also said that neither the disappearance of water in the village of Nigazeuli nor the landslide risk for the locals is related to the construction of Shuakhevi hydropower plant and its tunnels. The company added that the monitoring process conducted in 2016 found that the tunnel would not cause water loss in the surrounding areas.

The locals recall that the company representatives explained the disappearance of water to them as the consequences of ‘weather changes’.

‘We were told it happened because of the heat and drought’, Vazha Tsetskhladze from Nigazeuli said, recalling his conversation with the Shuakhevi plant’s promoters. He added: ‘We have had droughts since the 1800s. I have witnessed everything in the last 63 years, but this water never even lessened. It is directly their fault that our water is lost…

“It’s painful that we don’t have much to say.”

The blog was prepared based on reporting by Batumelebi.

Pathway to Paris: Can the ADB help Uzbekistan reach carbon neutrality?

This story was originally published by Eurasianet.

Over the last decade, the Asian Development Bank has invested $3.6 billion in Uzbekistan’s energy sector, mainly for the development of gas infrastructure. This is not compatible with the ADB’s vision of a greener planet, or Uzbekistan’s pledge to become carbon neutral by 2050.

An ADB evaluation of its lending between 2009 and 2019 found that Uzbekistan was its second-largest borrower in the energy sector. This week, from May 3-5, the ADB’s Board of Governors will meet to discuss ways to ensure a resilient and green recovery from the pandemic. If they are sincere, they must help Uzbekistan ditch fossil fuels and tap into its tremendous renewable potential.

Fossil fuels remain the primary source of energy production in Uzbekistan, with natural gas accounting for 85 percent of the total. The national targets for renewable energy development, set in the government’s green transition strategy document, remain relatively modest at just 25 percent of electricity generation by 2030.

But if Uzbekistan is to have any chance of reaching its commitment under the 2015 Paris Agreement to be carbon neutral by 2050, then no more fossil-fuel infrastructure can be built. Recent estimates suggest that gas combustion saves only 30 percent of the greenhouse emissions compared to burning coal, the dirtiest of fossil fuels. So the idea that fossil gas is somehow compatible with the legally binding international treaty is false. Given the significant economic lifespan of gas infrastructure – 30 to 50 years – such projects are clearly incompatible with Paris.

Moreover, Uzbekistan expects to be particularly affected by climate breakdown. In the government’s proposal outlining how it will reach its Paris commitments, Tashkent warns of average air temperature increases in Uzbekistan two times higher than current rates of global warming.

Without additional resource-savings measures by every country, Uzbekistan may face a lack of water, more desertification and land degradation, and increasingly frequent droughts leading to the instability of agricultural production, thus threatening the country’s food security.

The way forward is clear: Development banks must support Uzbekistan’s drive towards carbon neutrality. This year the European Bank for Reconstruction and Development, another multilateral lender active in the country, concluded that if Uzbekistan is to reach carbon neutrality by 2050, it must halt the construction of new fossil gas plants and intensively develop renewable sources of energy.

Yet ADB investments in renewables, particularly solar power, remain low. Renewables account for just 12 percent of the bank’s total energy portfolio in Uzbekistan, at $400 million, despite the overall potential for renewables at an astonishing 4,000 gigawatts. Instead, according to our estimates, the bank has spent over $1.4 billion on new generation facilities in the past decade: five combined-cycle gas turbines with a total capacity of 2,210 megawatts.

The ADB is currently revising its energy policy and has declared its intention to align with the goals set in Paris. Such an approach is welcome. In Uzbekistan, this would mean halting investments in fossil gas and instead prioritizing sustainable decarbonization and energy savings.

Such an approach is the only realistic way for Uzbekistan to achieve carbon neutrality and for the world to chart a path toward Paris.

Read the full briefing “ADB energy investments in Uzbekistan: where to go?”.

The article was updated due to discovered miscalculations.

Left jobless after eviction from Vinca landfill, Roma begin negotiations with Belgrade after complaint to the EBRD

The Vinča landfill on the Danube has been piling up over more than 40 years with no lining or collection of the water leaching out underneath. More than 80 people were living in informal accommodation and trying to eke out a living from discarded waste at the site, part of the 12 000 people estimated to be involved in waste collection throughout the city.

In 2019 the EBRD provided EUR 70 million to ‘Beo Cista Energija d.o.o Beograd’ for the construction of a solid waste incinerator and the remediation of this old landfill in the Serbian capital. The IFC and the Austrian Development Bank are also financing the project. The European Commission and the EIB were as well considering funding before pulling out in October 2019, citing its incompatibility with EU waste prevention and recycling targets. However, the EBRD didn’t find any non-compliance, which was confirmed by the IPAM’s superficial assessment released in December 2020.

Problems begin

In late 2018 some residents of the informal settlement were relocated to social housing units, while a number of individuals were left without any alternative form of housing. This resettlement was said to violate Serbian law and the International Covenant on Economic, Social and Cultural Rights because the housing that was allocated was not affordable for its users.

International human rights standards define the affordability of housing at a cost to an individual or household at a level that does not jeopardize the fulfilment of other basic needs. However, the majority of relocated households were already burdened with the costs of rent and utility services.

Also, only residents of the informal settlement that were there as of 8 June 2016 were offered relocation. As a result, some families who arrived after this census date were left without any alternative accommodation.

Moreover, many waste pickers have lost their main source of income because of the unilateral termination of their contracts with the public utility ‘Gradska Čistoća’. Despite the obligation of the city of Belgrade to ensure economic opportunities for income generation, a few people were offered only short term seasonal jobs, which were poorly compensated. At the same time, picking of recyclables from the streets of Belgrade has been prohibited, and thus their livelihood criminalised. Again, the rights of waste pickers are ignored by the lenders and local government as the new solid waste PPP project is being set up.

Seeking redress

On 13 January 2021, the EBRD’s Independent Accountability Mechanism registered a complaint filed by the A11 Initiative and six displaced people asking that the bank ensure adequate alternative accommodation and a realistic possibility for livelihood restoration for the resettled individuals. On 20 April 2021, the IPAM published an Assessment Report confirming that the case will proceed to problem solving. It aims to facilitate dialogue between the affected Roma people and the city of Belgrade to pursue resolution for the raised problems through information gathering, joint fact-finding and mediation meetings. The same day, A11 Initiative contacted the Executive Directors of the International Finance Corporation’s Board to inform IFC directors about the breaches of the bank’s Performance Standards during the project implementation.

This problem-solving initiative is a great opportunity for the City of Belgrade and the project promoter to demonstrate good faith and restore the human rights for Roma.

Scientific studies reveal river ‘sickness’ from small hydropower plants in Serbia

As millions of people around the world celebrate Earth Day, a new case study by Bankwatch and WWF Adria shows that we are still not going in the right direction. The theme of Earth Day 2021 is Restore Our Earth, but the Beli Kamen and Komalj hydropower plants in Serbia show we haven’t even stopped destroying ‘protected’ areas.

Built on the Crni Rzav and Ribnica Rivers in Zlatibor Nature Park, which is also an Emerald site, both plants were financed by the European Investment Bank (EIB) via loans to the financial intermediaries Banca Intesa Beograd and Crédit Agricole Srbija. A further plant, Peta, is also planned as part of the same hydropower complex, but has not been built yet. The EIB, which likes to model itself as the EU’s climate bank, has largely withdrawn from direct financing of destructive dams. But the lack of transparency over investments by intermediary banks has enabled the destruction of many rivers, for example by the Blagoevgradska Bistritsa cascade in Bulgaria and the Ilovac hydropower plant in Croatia.

How do we know if a river is ‘unwell’?

Assessing the impacts of the Beli Kamen and Komalj plants is difficult not only because of the lack of transparency about the projects and the remoteness of the area, but also because many of the problems hydropower plants cause are underwater. In 2020, WWF Adria organised hydrobiological studies of eight rivers in Serbia with the goal of assessing the environmental impacts of planned or already built hydropower plants. The studies were carried out in line with the EU’s Water Framework Directive, according to which the physical-chemical parameters of water, some very small plants and animals (phytoplankton, phytobenthos, macrophytes, macrozoobenthos) and fish are used to assess water status and quality.

Poor ecological status of parts of the Crni Rzav River after building the plants

The Beli Kamen plant (1.68 MW) was put into operation in 2016 and the Komalj plant (0.6 MW) in 2018. Beli Kamen has two intakes and two pipelines – one on the Crni Rzav (4.3 kilometres upstream from the powerhouse) and one on Ribnica (2.5 kilometres upstream from the river confluence). Komalj has no separate intakes, but the water used by Beli Kamen goes directly into Komalj’s pipelines, bypassing the Crni Rzav River for an additional 2.4 kilometres. Therefore, a total of 9.2 kilometres of river are seriously impacted. Hydrobiological studies were carried out by WWF Adria in 3 locations:

Location 1, in a stretch not impacted by hydropower, higher than the intakes
Location 2, above the Komalj powerhouse
Location 3, below the Komalj powerhouse

Hydrobiological research on Serbian rivers. Photo: Nataša Milivojević

The results proved not only impacts between the intakes and Komalj powerhouse, but also downstream. In total, more than 10 kilometres were destroyed. Location 2 had much higher temperature and higher values of oxygen concentration and saturation, which is a consequence of low water levels and algal bloom. During times of rapid photosynthesis of algae during the day, the water quickly becomes saturated with oxygen. The surplus oxygen just bubbles out of the water. That leaves no reserve for the system at night when the water organisms need oxygen. After algae die their decomposition leads to poor water quality.

Location	Temp. (°C)	pH	Electrical conductivity (μS/cm³)	Water hardness (mg/l)	Oxygen concentration (mg/l)	Oxygen saturation (%)
1	17.8	7.9	260	130	9.74	114.8
2	23.8	8.65	350	170	12.03	151.3
3	18.3	8.61	370	180	9.78	111

The hydropower cascade very seriously altered the river habitats, as proven by the changes in algae compared to the river stretch not impacted by hydropower (Location 1). The lack of any algae at Location 3 means lack of food and shelter for many aquatic animals. The overgrowth of algae at Location 2 and the change in species composition indicate a totally modified river stretch with stagnant water. Below the two hydropower plants (Location 3), the status based on macroinvertebrates was poor, and according to some indices even bad. Between the two plants (Location 2), it was moderate. The river stretch not impacted by hydropower (Location 1) had good status, and according to some indices, even high.

	Location 1	Location 2	Location 3
Ecological status class	II	III	IV
Ecological status assessment	Good	Moderate	Poor

A very important indicator of the impact of hydropower was the disappearance of the stone crayfish (Austropotamobius torrentium). It was found on Crni Rzav in 2018, but not in 2020 when the Komalj plant started operation. The stone crayfish is a priority species for conservation in the EU Habitats Directive and the Bern Convention. It is an indicator of the good status of mountain rivers and is threatened all around Europe by hydropower projects.

Stone crayfish from Veliki Rzav River. The species disappeared from the Crni Rzav after building the hydropower plants. Photo: Nataša Milivojević

The studies on fish showed that there has been a drastic decline in biomass of fish recorded at Location 3. Below the hydropower plants there were 17 times fewer fish than above. The most significant decline was in the population of Danube barbel (Barbus balcanicus), another protected species by the Habitats Directive and Bern Convention. The decline is a consequence of habitat fragmentation, changes in the hydromorphological characteristics of the river flow, construction of inadequate fish passes that prevent spawning upstream and variable water levels. The impacts on fish will also have serious consequences on other species that prey on them and are protected in the Zlatibor Nature Park and Emerald site – the otter (Lutra lutra), black stork (Ciconia nigra) and kingfisher (Alcedo atthis).

European chub (Squalius cephalus) from a river stretch not impacted by hydropower. Photo: Nataša Milivojević

Is restoration possible?

Coming back to Earth Day 2021, it is still possible to ‘restore the Earth’. There is a growing movement, Dam Removal Europe, whose goal is to restore rivers in Europe with natural or cultural importance. It will take time until the Serbian government understands that restoring 10 kilometres of Crni Rzav and Ribnica will bring more benefits than only 2 MW of hydropower. But until then, some urgent action is needed.

EIB policy improvements needed

The EIB needs to make its lending through financial intermediaries fully transparent, at least for projects which may have significant negative impacts on the environment, such as hydropower plants.
For higher-risk projects, such as those from Annex I or II of the EIA Directive, or any projects situated in sensitive areas, such as Emerald sites, the EIB needs to require that the projects be referred to the EIB for environmental and social appraisal, and the Bank needs to be included in project monitoring. Based on data from the hydrobiological studies, it can be clearly concluded that the negative impacts of small hydropower plants on river biodiversity are extremely high, compared to the very small amount of electricity produced (in this case study – 10 kilometres of rivers were destroyed for around 2 MW capacity). The EIB should stop financing such projects.
The EIB needs to make clearer the relationship between its Environmental and Social Standards and its Hydropower Guidelines and ensure that the provisions for financial intermediaries set in the Guidelines are included in loan contracts.

Project-level remediation of damage needed

The EIB must engage with all stakeholders to investigate the reasons for the poor to moderate environmental status of the river impacted by the plants and carry out additional assessments in more locations where plants financed by the Bank are situated using the same methodology as in the WWF-Adria study.
The EIB must engage with the final beneficiary of the loan to remedy the situation accordingly and with the Institute of Nature Protection of Serbia to set the necessary nature conditions in order to improve the ecological status of the Crni Rzav and Ribnica Rivers (leave more water in the river, modify the energy production regime, etc.).
The EIB needs to investigate how its clients Banca Intesa Beograd and Crédit Agricole Srbija performed their due-diligence duties and publish its findings.
The EIB must oblige its client to engage with the final beneficiary, the relevant authorities and interested stakeholders to reach an agreement not to build the third planned plant, Peta, because of the negative impact of the other two plants on the river ecosystem.

This publication was produced in collaboration with EuroNatur in the frame of the joint research and advocacy work on hydropower finance and subsidies.

This publication was updated following a reply by the EIB to Bankwatch on 14 March 2022.

Estonia’s EU recovery fund measures are promising yet potentially obstructive

Unlike many other countries, as of mid-April, Estonia had only published brief documents outlining the proposed measures and budget allocation for the Recovery and Resilience Facility (RRF). It also organised weeklong consultations for selected measures, but these did not provide many further details.

While the lack of access to a full draft does not allow for a thorough review of the recovery plan itself, a general assessment of provided documents shows that the measures included in the Estonian recovery plan are mostly aligned with the European Green Deal.

However, as the devil is in the details, many measures could also jeopardise the green transition, there is a need to ensure that the detailed eligibility and implementation criteria planned for proposed measures is aligned with the Green Deal.

The estimated EUR 0.9 to 1.1 billion allocated to Estonia under the RRF will be channeled towards five areas: healthcare and social protection (EUR 446 million), business (EUR 337 million), e-governance (EUR 135 million), energy and energy efficiency (EUR 92 million) and transportation (EUR 96 million).

Mixed signals from the recovery measures

Proposed measures with a likely positive effect on climate goals take EUR 322 million, or 29 per cent, of the estimated total. These include much needed investments in the energy grid, energy storage and renewables (EUR 45 million), increasing the energy efficiency of buildings (EUR 47 million) and a green fund for investing in enterprises’ green transition (EUR 100 million). A further EUR 50 million is planned for introducing integrated renewables-based hydrogen technologies, but the measure’s design could be based on overly optimistic expectations and lead to implementation issues.

Measures that will positively contribute to the decarbonisation of the transportation sector and hence the climate goals include constructing an additional tram line in Tallinn (EUR 26 million), restoring a section of a former railroad line in Northern Estonia (EUR 34 million) and municipal investments in cycling paths (EUR 5 million).

Most other measures can be potentially harmful and could undermine the Green Deal. Due to the low level of detail provided, many of the proposed measures could be used to support the growth and longevity of harmful companies and sectors that significantly reinforce climate change, such as extracting and processing mineral resources and fossil fuels. Such measures include, for instance, supporting firms’ export capacity (EUR 33 million), adopting innovative and resource-efficient technologies (EUR 23 million), and digitisation and automation of enterprises (EUR 73 million).

There is also uncertainty around the impact of measures like advancing bioresources (EUR 24 million) and constructing a joint transport terminal of Rail Baltic (EUR 31 million). For the former, it is unclear whether the measure will fuel increasing logging intensity that carries the risk of adverse environmental and climatic impacts. The latter could support the decarbonisation of the transportation sector, but it encourages developing Rail Baltic, which likely negatively affects biodiversity as it can involve clearing bogs and forests of high conservation value to make way for the railroad.

Biodiversity neglected

The European Commission has highlighted the need to allocate a larger proportion of EU funds for protecting and restoring biodiversity in both the Technical Guidance for the RRF and the EU Biodiversity Strategy. Such investments would also contribute to the requirement to invest 37 per cent of the recovery fund in green transition. Despite all this and the central role of preserving biodiversity and ecosystems in climate change mitigation and adaptation, Estonia has not proposed any measures on these.

From the view of conservation, for instance, the status of most forest habitat types of the Habitats’ Directive in Estonia is either inadequate or bad, suggesting that the state has not fulfilled its duty to ensure and restore the favourable status of these. Also, 49 per cent of the forest area within the Natura 2000 network in Estonia is not covered by the Habitats’ Directive forest habitat inventory, indicating that forests with potentially high conservation value may not be adequately protected from intense logging.

Using the RRF to invest in improving the status of forests and other habitats and in taking inventory of the land within the Natura 2000 network would help to capture and store carbon and ensure that ecosystems needed to adapt to climate change would be preserved. It would also contribute to the climate goals required by the facility.

Missing pieces

To realise the good intentions behind Estonia’s proposals, further scrutiny is needed to ensure that the measures effectively contribute to the Green Deal.

This requires, first, a comprehensive application of the ‘do no significant harm’ principle across all measures as well as applying the EU Taxonomy for sustainable activities criteria on measures classified as ‘green’. Second, it must have a stronger focus on investing in biodiversity and preserving and restoring the favourable condition of different ecosystems. Third, Estonia must have a public recovery plan that defines a strategic and operational framework specific to the RRF. Without this, the measures are likely to be ineffective in the long run.

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