life.lifevideos.eu · 4 CONTENTS A ANNEX A: SUMMARY OF THE INTERVENTION LOGIC FOR LIFE+ .......................................... 5 B ANNEX B: SUMMARY OF THE CONCLUSIONS OF THE EX-POST

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Mid-Term Evaluation of the Implementation of the LIFE+ Regulation

Final Report Annexes

In association with Arcadis and VITO

March 2010

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Document Control

Document Draft Final Report Annexes - Mid-term evaluation of LIFE+

Job No. 30257084

Prepared by James Medhurst, Laurent Franckx, Arcadis, Karla Schoeters, VITO

Checked by Vanessa Foo, Charlotte Slater

Date 2nd March 2010

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CONTENTS

A ANNEX A: SUMMARY OF THE INTERVENTION LOGIC FOR LIFE+ .......................................... 5

B ANNEX B: SUMMARY OF THE CONCLUSIONS OF THE EX-POST EVALUATION ................... 8

C ANNEX C: OVERVIEW OF EU PROJECTS REVIEWED IN DESK STUDY ................................ 12

D ANNEX D: OVERVIEW OF THIRD COUNTRY ACTIVITY IN LIFE AND OTHER PROGRAMMES 23

E ANNEX E: REVIEW OF FOREST FOCUS ACTIVITIES ............................................................... 34

F ANNEX F: REVIEW OF THE CO-OPERATION FRAMEWORK FOR SUSTAINABLE URBAN DEVELOMENT (SUD) .......................................................................................................................... 45

G ANNEX G: REVIEW OF NATIONAL ALLOCATIONS .................................................................. 53

H ANNEX H: REVIEW OF NATIONAL PRIORITIES ........................................................................ 59

I ANNEX I: REVIEW OF THE APPLICATION PROCESS ................................................................ 63

J ANNEX J: REVIEW OF THE APPRAISAL AND SELECTION PROCESS ................................... 66

K ANNEX K: REVIEW OF ENRTP APPLICATION PROCESS ....................................................... 76

L ANNEX L: REVIEW OF PROJECT MONITORING ....................................................................... 81

M ANNEX M: REVIEW OF COMPLEMENTARITY........................................................................... 87

N ANNEX N: OVERVIEW AND SELECTION OF NGOS ................................................................. 99

O ANNEX O: DETAILED ANALYSIS OF NGO OPERATING GRANTS ....................................... 111

P ANNEX P: QUANTITATIVE OUTCOME ANALYSIS OF NGO OPERATING GRANTS ............ 150

Q ANNEX Q: OVERVIEW OF THE LEGAL AND POLICY CONTEXT FOR THE NGO PROGRAMME .................................................................................................................................... 177

R ANNEX R: IDEA FOR INCREASING EU VALUE ADDED THROUGH MUTUAL LEARNING . 196

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A ANNEX A: SUMMARY OF THE INTERVENTION LOGIC FOR LIFE+

Objectives Main objectives include:

Contribution to implementation, updating and development of Community environmental policy and legislation

Integration of environmental issues into other policies

Contribution to sustainable development

Support the implementation of the 6th Environmental Action Programme (6th EAP)

Financing measures and projects with a European added value

Specific objectives set out under each of the 3 LIFE+ components: Nature & Biodiversity; Environmental Policy & Governance and Information & Communication, help to achieve the needs of target groups

Context and Evolution

Operation of LIFE+ at a European level:

Centrally managed by the Commission.

Commission is responsible for commissioning the annual call for proposals and selecting, revising and monitoring projects with the help of external experts.

At a national level:

Member States forward project proposals (prepared by the applicants) to the Commission, set national objectives/priorities, prepare comments on proposals (especially in relation to national annual priorities).

Evolution of LIFE+ from previous programmes is characterised by:

Greater involvement of MS in definition of priorities to enable proposed projects to respond to various national and regional environmental needs.

New provision to ensure proportionate distribution of projects by establishing indicative national allocations based on set of criteria (population size, nature and biodiversity).

At least 15% of budget to be dedicated to project action grants allocated to transnational projects.

Broader application that includes theme relating to biodiversity loss, forest fire prevention and awareness raising, NGO and policy support.

Significant proportion of funding for nature and biodiversity, especially nature conservation – 50% (or €836 million) of the budgetary resources for LIFE+ dedicated to action grants for projects have been ring-fenced for measures to support conservation of nature and biodiversity.

Absorption of other programmes – replaces the current LIFE programme, the Forest Focus and Urban programmes, DG Environment's funding programme for environmental non-governmental organisations (NGOs), and a general fund for policy development and implementation.

Activities and Rationale

The following types of activities will be supported to address objectives of the LIFE+ programme:

demonstration of innovative policy approaches, technologies, methods and instruments;

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specifically for nature and biodiversity component - preparatory actions (such as developing biodiversity action plans, preparatory inventories, technical planning etc) and conservation actions (such as implementation of biodiversity action plans, site related conservation actions etc);

information and communication actions including awareness-raising campaigns;

operational activities of NGOs involved in development and implementation of Community policy and legislation;

developing and maintaining networks, databases and computer systems directly linked to the implementation of community environmental policy and legislation;

studies, surveys, modelling and scenario-building;

capacity building assistance;

monitoring (including the monitoring of forests);

training, workshops and meetings; and

networking and best practice platforms

Results and Impacts

More immediate results:

greater innovation and demonstration

improved awareness, learning and capacity

greater knowledge base

better dissemination of good practice throughout Europe

broadening stakeholder involvement in development and implementation of environment policy and legislation

development and effective implementation of Community environmental policy

improved governance of environmental legislation

LIFE+ programme will contribute to the achievement of following longer-term impacts:

Nature & Biodiversity – halting the loss of biodiversity within the EU by 2010

Climate Change - stabilisation of greenhouse gas concentration at a level that prevents global warming above 20C

Water - enhanced water quality

Air – levels of air quality that do not give rise to significant negative impacts on and risks to human health

Soil – protection of soil and soil biodiversity

Urban environment – improvement in environmental performance of Europe’s urban areas

Noise – reduction in noise levels

Chemicals – protection of the environment and health from risks posed by chemicals by 2020

Environment and Health – improved health and environment

Natural resources and waste – sustainable management and use of natural resources and waste

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Forests – protection of forests against fire

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B ANNEX B: SUMMARY OF THE CONCLUSIONS OF THE EX-POST EVALUATION

B.1 Summary of Recommendations from the Ex-post Evaluation of the LIFE III Programme (COWI, 2009)

The following is a summary of recommendations from the ex-post evaluation of projects and activities financed under the LIFE Programme.

Strategic management and programming:

1. Clarify the role and objectives of the LIFE Programme in relation to implementation of EU environmental policy and creation of European added value

Set targets and indicators for the Programme to determine the degree of success. The Life Unit should increase co-ordination with Policy Units e.g. through a steering committee for the LIFE programme. The LIFE Unit could also be reorganised into thematic desks. The role of the Life programme is unclear and having a unit dedicated to project management has improved streamlining and efficiency but it has become removed from the policy development function.

A review of the Environmental Action Plans shows that the 6th EAP mentioned the LIFE programme which indicates increased formal connection between the policy and the programme. This link seems weak as the reference was focused on the subject of product innovation and the 6th EAP did not contain any consideration of how the LIFE instrument was to be used in relation to the overall environmental priorities identified in Art. 1.

Interviews with officers from the policy units in DG Environment who have interacted with the LIFE programme show there is limited coordination between policy units and the LIFE unit. European added value is not mentioned in the objectives of the LIFE Programme in any of the Regulations covered by the evaluation period. The LIFE Nature components had a stronger link to policy objectives than LIFE Environment, whereas the latter was more focused on European value added than was the case for LIFE Nature.

2. Implement regular monitoring and reporting on the performance at programme level

Systems for regular monitoring and performance should be developed on the basis of objectives and indicators. A uniform set of indicators should be applied across all projects and a regular annual status report on programme performance could be produced. Current monitoring and reporting systems are focused on the project level - monitoring of programme performance is irregular (external evaluations) and lack of knowledge exists about programme performance against objectives.

Very little was done in terms of developing indicators to measure the performance of the programme and a review of the BUTLER tool shows it was not developed in this direction either. Even basic thematic categorisation of the LIFE projects in BUTLER was somewhat ad-hoc and did not facilitate a thematic analysis of the project portfolio.

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3. Develop support systems to improve the basis for strategic management, i.e. database on Nature projects linked to database on Natura 2000

The systems containing the project level information should be developed to provide information on project objectives and achievements in line with the indicators for the Programme. For LIFE Nature it is recommended that a geographical database is developed, comparable with the Natura 2000 database to see how far LIFE projects are supporting the implementation of Natura 2000. The organisation of the LIFE Unit as a functional, project management secretariat was not effective concerning the strategic management of the programme as little interest was shown on the part of the LIFE Unit and DG Environment to further target the programme to specific policies.

In the course of this evaluation, a LEAN-inspired analysis was carried out through a workshop with participants from the LIFE Unit focusing on key work flows in relation to monitoring. the LEAN perspective can be seen as a way for releasing resources in order to reallocate them to tasks where performance could be improved

Co-ordination, dissemination, partnerships

4. Promote active knowledge sharing at European level, e.g. through thematic workshops and seminars

Organise thematic conferences for knowledge sharing and to involve increased numbers of stakeholders to promote general awareness of LIFE. Co-ordinate events with policy units to create synergy. The ex-post evaluation discovered a need to focus more on dissemination and knowledge sharing to exploit the learning and replication potential of the LIFE projects.

Interviews with LIFE Unit staff, the monitoring team and the EACEA comparative study suggested more focus on thematic conferences and workshops bringing together a number of projects

5. Target dissemination efforts to reach the right audience through a strategic communicative effort in individual projects and at programme level

Ensure considerations of key messages, target groups and communication channels are high by urging beneficiaries to think along the lines of communication strategy. Projects which found appropriate communication channels to reach target group saw the most positive results in regards to dissemination and replication.

Actions and resource allocation according to Unit Management Plan 2006 states to enhance the EU added value of LIFE projects by successful communication and the spreading of best practices

6. Build capacities of potential LIFE beneficiaries to increase number and quality of applications

Broaden the client-base of the LIFE Programme to ensure a sufficient number and quality of applications. Consider less experience organisations for LIFE Nature to increase number of organisations capable of managing conservation actions. The LIFE Unit should be proactive in building relations through national focal point and arrange information meetings, training seminars etc

Data on number of applications received and funded indicate that the success rate for obtaining Environment projects is considerably higher in the Old Member States. In

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2006, the New Member States had a success rate of 0%, whereas it was 12% for the Old Member States.

7. Involve the Member States in dissemination and capacity building activities

The Unit should be more proactive in engaging the national focal points to play a key role as access points to potential beneficiaries, marketing the LIFE Programme and providing guidance to applicants. This would contribute to a more uniform approach among the Member States to guiding potential applicants.

Several national focal points (especially LIFE Environment) state that they know very little about project results and impacts and the LIFE Unit should do more to inform and thus create interest. Interviews with the national focal points also point to great differences in the degree to which the national focal points provide the applicants with information and assistance during the application process.

Procedures for selection and monitoring

8. Further improve application guidance and application forms, e.g. by simplifying and digitalising application forms

The guidance to applicants should be improved and application forms simplified and digitalised. This will also minimise the time required for assessing the applications. Eliminating the approval procedure of final projects by Member States (the LIFE Committee) would reduce the length of the selection period.

An issue raised by many national focal points is that the requirements to applications are very complex and demanding. There is a perception that this is possibly deterring new applicants from applying. A lengthy and time consuming application process is noted. Data from the e-survey shows that beneficiaries spend 30-90 work days (49%) or more than 90 work days (29%) on preparing their application46, and 50% of the respondents regarded the time required as somewhat excessive.

9. Outsource the receipt, eligibility check, selection and award phases of the selection procedure

Outsource the entire process from receipt of applications to the award phase. The calculation of administrative costs compared to commitments made indicate a slight annual increase in the period 2002-2006.

A LEAN inspired analysis showed further efficiency gains could be obtained in complete outsourcing of the selection activities and by improving the coordination with the monitoring team......The argument used for outsourcing is that the task of selection should not be performed by the same officials who are responsible for the monitoring of the implementation of the projects. Also interviews in the LIFE Unit indicate that the TDOs experienced a number of "cold starts" and spent resources on refreshing the content of the applications in question

10. Further clarify criteria for selection and scoring system

The evaluation guide should be clarified with regard to the evaluation of the award criteria in order to ensure equal treatment of the applications. Ambiguities have been identified in the definition of criteria, e.g. guides to applicants mentioned priorities which were not reflected in the criteria, there is a lack of clarity in how the subcriteria/questions mentioned under each criteria are to be weighted

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Some national focal points have stated that they found the background for the scores given unclear and have indicated that the rationale for project selection has been inconsistent.

11. Further clarify tasks of the monitoring team

A broader dialogue with the monitoring team should be initiated e.g. focus more on common training seminars, conferences, etc. This dialogue should clarify tasks and quality criteria for the evaluation of project reports to avoid duplication of tasks. It has been noted that dialogue is to a large extent decentralised to the individual TDO/FDO and monitoring expert in connection with specific countries.

The Lean analysis revealed that the workshop participants believed that the beneficiaries, despite the support from monitors, lack knowledge about the procedures and requirements as a LIFE beneficiary, particularly with regard to requirements on the financial management of the projects.

12. Apply a prioritised approach to individual project monitoring based on risk assessment

A more strategic approach focusing on visits to high-risk projects and replacing some visits with cross-project (thematic) conferences/workshops to reach a larger number of projects and still achieve similar benefits for each project. Visits to projects and face-to-face contact with beneficiaries were found to be important parts of the effective monitoring system in place.

A risk assessment tool has been developed to focus monitoring visits on the projects more in need for close follow-up. However, according to interviews in the LIFE Unit the tool is applied in a somewhat ad hoc manner.

13. Optimise document flow and clarify the role of the verifier in the Unit

Prepare the signataire when receiving the evaluation from the beneficiaries. The system for verification should also be clarified so that unnecessary time used on verification can be eliminated.

The LEAN workshop found that by merging two steps and preparing the signataire when receiving the evaluation from the beneficiaries, up to five days of sending papers back and forth between staff can be saved

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C ANNEX C: OVERVIEW OF EU PROJECTS REVIEWED IN DESK STUDY

C.1 Summary of the first two calls

C.1.1 Number and type of partners

An overview of 141 LIFE+ projects across all 3 components that were funded following the 2007 call1 and 195 projects funded following the 2008 call showed that 70% of the projects involved collaborations of between 1 and 5 partners (see Table C-1Table C-1). Approximately 18% of the projects did not involve any collaboration, and only 12% of all analysed projects involved more than 5 partners.

Table C-1: Breakdown of funded projects based on the number of partners showed that the majority of 2007 and 2008 LIFE+ projects involved between 1 and 5 partners2

LIFE+ call

Number of partners

0 1-5 6-10 >10

2007 29 92 16 4

2008 31 141 17 2

Total 60 233 33 6

An analysis of all lead beneficiaries of selected projects showed that in 2007 and 2008, public authorities and development agencies constituted the most abundant group of beneficiaries (see Figure C-1). Professional organisations (e.g. Regional Fisheries Board) constitute the smallest group of beneficiaries.

1 GHK analysis was based on data from the LIFE+ project database: http://ec.europa.eu/environment/life/project/Projects/index.cfm 2 By ‘0’ partners this means we interpret there to be only one single contract holder (who has no other project partners)

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Figure C-1: Public authorities, development agencies and NGOs accounted for more than half of lead partners for LIFE+ projects funded in 2007 and 20083

42%

22%

19%

12%5%

Public authorities and development agencies

Universities/Research institutions

NGO-foundations

Enterprises (including public enterprises)

Professional organisations (e.g. The Shannon Regional Fisheries Board)

In terms of types of beneficiaries, under the Nature and Biodiversity component, the majority of lead beneficiaries were public authorities and NGOs. In contrast, there was a fairly even breakdown between universities, enterprises and public authorities under the Environment Policy and Governance component. NGOs were also active in running Information and Communication projects (see Figure C-2).

3 GHK analysis was based on data from the LIFE UNIT (DG ENV)

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Figure C-2: Public authorities and development agencies were the most active group of beneficiaries across all 3 LIFE+ components (2007-2008)4

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5811

4

361

14

52

7

45

13

8

312 1

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Nature and Biodiversity

Environment Policy and

Governance

Information and Communication

Professional organisations

NGO-foundations

Universities/Research institutions

Enterprises

Public authorities and development agencies

Number of projects financed

In terms of the number of projects funded in each component, in both 2007 and 2008, at least half of the projects were under the LIFE+ Environment Policy and Governance component (see Figure C-3). The second largest group of projects (approximately 40% of the total number of projects) fell under the Nature and Biodiversity component. Within this component, the majority were LIFE+ Nature projects.

4 GHK analysis was based on data from the LIFE UNIT (DG ENV)

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Figure C-3: Of 143 projects financed following the 2007 call and 196 projects financed following the 2008 call, projects from two LIFE+ components (LIFE+ Nature and Biodiversity and LIFE+ Environment Policy and Governance) accounted for over 90% of total funded LIFE+ projects5

5438%

43%

7452%

117%

7237%

84%

9950%

179%

Nature

Biodiversity

Environment policy & governance


In terms of funding, projects under the LIFE+ Nature and Biodiversity component accounted for almost half of the total amount (see Figure C-4). This was in line with the conditions set out in the LIFE+ Regulation, whereby “at least 50% of the budgetary resources for LIFE+ dedicated to project action grants shall be allocated to support the conservation of nature and biodiversity” (Article 11). Of the remaining budgetary resources, Environment Policy and Governance accounted for most of the budget for action grants. LIFE+ Biodiversity and Information and Communication which were newly introduced aspects to LIFE+, accounted for between 3 to 9% of the budget. Combined with the project number breakdown, the analysis showed that on average, LIFE+ Nature projects received the most amount of funding per project.

Figure C-4: The total funding for LIFE+ Nature and Biodiversity projects accounted for half of the total LIFE+ budget in 2007 and 20086

8248%

32%

7746%

64%

10049%

73%

9043%

105% Nature

Biodiversity

Environment policy & governance


On the whole, the number of projects financed increased across most policy areas between 2007 and 2008 (see Figure C-5). The biggest increase was observed in the LIFE+ Nature and Biodiversity component.

5 GHK analysis was based on data from the LIFE+ project database: http://ec.europa.eu/environment/life/project/Projects/index.cfm

6 GHK analysis was based on data from the LIFE+ project database: http://ec.europa.eu/environment/life/project/Projects/index.cfm

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Across policy areas in the Environment Policy and Governance component, the majority of financed projects appeared to focus on waste/natural resources and climate change. Fewer projects were financed under other policy areas, which included ‘new’ policy areas such as noise and environment and health.

Within the Information and Communication component, a more even distribution of projects across policy areas was observed in 2008. In particular, the number of projects with the focus on forest fires was increased from 0 to 4. This new policy area of raising awareness on forest fires/training for forest fire agents (4 projects) accounted for 24% of total projects funded under this Information and Communication component (17 projects).

Figure C-5: Number of projects financed under different policy areas varied across all 3 LIFE+ components in 2007 and 20087

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72

2

2

2

3

3

3

5

6

7

14

26

27

4

5

8

4

54

1

1

1

2

2

1

1

4

3

8

21

27

0

2

9

0 20 40 60 80

Biodiversity

Nature

Noise

Environment and Health

Air

Urban Environment

Soil

Forests

Chemicals

Strategic Approaches

Innovation

Water

Climate Change

Waste and Natural resources

Prevention of forest fires & training for forest fire agents

Nature protection or Biodiversity matters

EU environmental policy and legislation

Number of projects financed

2007

2008

7 GHK analysis was based on data from the LIFE Unit (DG ENV)

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In terms of project distribution across Member States, a similar distribution was observed in both 2007 and 2008 (see Figure C-6). In general, an increase in projects funded by LIFE+ was observed in most Member States. Italy, Spain and Germany continued to be leading Member States in terms of highest number of projects funded by LIFE+. In contrast, four Member States - Luxembourg, Lithuania, Ireland and Malta - did not appear to receive funding following the 2008 call, although this was probably due to the low number of applications submitted from these Member States8.

Figure C-6: Number of projects financed under LIFE+ varied between different Member States in 2007 and 20089

0 10 20 30 40 50

Czech Republic

Bulgaria

Cyprus

Latvia

Malta

Poland

Slovakia

Denmark

Estonia

Ireland

Lithuania

Luxembourg

Slovenia

The Netherlands

Austria

Hungary

Romania

Finland

Portugal

United Kingdom

Belgium

France

Sweden

Greece

Germany

Spain

Italy

2007

2008

8 Ireland submitted 1 application, Latvia 3, Lithuania 3 and Malta 4. 9 GHK analysis was based on data from the LIFE Unit (DG ENV)

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Funding awarded to Member States for action grants

In terms of funding awarded to action grants, most Member States appeared to receive more funding in 2008 (see Figure C-7). Germany, Spain and Italy continued to receive the highest amounts of funding. In fact, the total amounts awarded to these 3 Member States totalled €98 million in 2008, accounting for almost half of the total LIFE+ budgetary resources (€205 million).

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Figure C-7: Amounts of funding awarded to action grants increased in most Member States in 200810

0 10 20 30 40 50

Czech Republic

Malta

Poland

Latvia

Cyprus

Estonia

Bulgaria

Ireland

Slovenia

The Netherlands

Lithuania

Romania

Slovakia

Luxembourg

Denmark

Portugal

Hungary

United Kingdom

Finland

France

Austria

Greece

Belgium

Sweden

Italy

Spain

Germany

Amounts awarded (€ million)

2007

2008

In general, in 2008, the actual amounts awarded to Member States appeared to match the indicative national financial allocations (see Figure C-8). Italy, Spain and Germany were found to have the highest amounts of funding beyond the indicative national allocations. In fact, the amount awarded to Italy (€36 million) was found to be twice as much as their corresponding indicative national allocation (€18 million). With Member States that received less funding than the indicative national allocations, the differences between the actual amounts and the indicative allocations were more subtle, with the biggest gap being in the UK (approximately €5 million).


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Figure C-8: The amounts awarded to action grants in Member States in 2008 appeared to match the indicative national financial allocations in most Member States11

0

5

10

15

20

25

30

35

40

DE ES IT FR UK PL RO SE FI GR NL PT HU DK SI BG BE CZ AT EE IE SK LT LV MT LU CY

€M

illio

ns

Indicative national allocations

Budget allocations

In terms of application numbers, on the whole, the number of applications received in Member States correlated with the indicative national allocations, except for Spain, Italy, Greece and Belgium (see Figure C-9).


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Figure C-9: The number of received applications correlated with the indicative national allocations in most Member States in 200812

0

20

40

60

80

100

120

140

160

0

5

10

15

20

25

30

DE ES IT FR UK PL RO SE FI GR NL PT HUDK SI BG BE CZ AT EE IE SK LT LV MT LU CY

€m

Indicative national allocations

Number of applications

Success rate The number of applications also appeared to be correlated with the number of projects selected (see Figure C-10). Amongst the 4 Member States with the highest number of projects financed, Germany was found to have the highest success rate, compared to Italy, Spain and Greece.

Figure C-10: Italy, Spain, Greece and Germany received the highest number of applications and had the highest number of projects financed under LIFE+ in 200813

0

20

40

60

80

100

120

140

160

IT ESGR DE FR PT BE FI PL UK SE BG CY HURO SI NL AT DK SK CZ EE LU MT IE LV LT

Applications

Selected projects

12 GHK analysis was based on data from the LIFE Unit (DG ENV) 13 GHK analysis was based on data from the LIFE Unit (DG ENV)

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Across the three LIFE+ components, the success rate was found to increase between 2007 and 2008 (see Table C-2). In 2008, although the number of proposals decreased in all 3 components, a higher number of projects was selected. Applications under the Nature and Biodiversity component appeared to have similar success rates compared to applications under the Environment Policy and Governance component. In both years, these success rates were at least twice as high compared to the success rate for applications under the Information and Communication component (see Figure 11).

Table C-2: The number of proposals and selected projects varied across 3 LIFE+ components in 2007 and 200814

2007 call 2008 call

Number of proposals

Number of selected projects

Average success rate (%)

Number of proposals

Number of selected projects

Average success rate (%)

Nature and Biodiversity 264 57 21.59 227 80 35.24Environment Policy and Governance 325 72 22.15 288 99 34.38Information and Communication 118 11 9.32 98 17 17.35

Total 707 140 19.80 613 196 31.97

Figure C-11: Average success rate (%) increased across all 3 LIFE+ components between 2007 and 200815

0

10

20

30

40

2007 call 2008 call

Nature and Biodiversity

Environment Policy and Governance


14 GHK analysis was based on data from the LIFE Unit (DG ENV) 15 GHK analysis was based on data from the LIFE Unit (DG ENV)

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D ANNEX D: OVERVIEW OF THIRD COUNTRY ACTIVITY IN LIFE AND OTHER PROGRAMMES

D.1 Summary of Previous LIFE TCY Projects

Table D.1 below provides a summary of previous TCY projects

D.2 Review of TCY Alternative Instruments

D.2.1 The EU’s Thematic Programme for Environment and Sustainable Management of Natural Resources including Energy (ENRTP)

Under the Development Co-operation Instrument (DCI), ENRTP was adopted in 2006, managed by DG AIDCO, to support projects highlighting the importance of managing natural resources and having a healthy environment to maintain lasting poverty reduction. The total budget of the programme is € 889.5m for the period between 2007 and 2013 and provides funding under the following:

Regulations (EC) No 2493/2000 and (EC) No 2494/2000 on the Environment in Developing Countries and Tropical Forests and Other Forests in Developing Countries

The Life-Third countries part of Regulation (EC) No 1682/2004 and the International Environment budget line 07 02 01

Budget Lines 06.04.02 and 06.01.04.09 “COOPENER

An AIDCO representative suggested that the focus of ENRTP projects is to promote implementation of EU initiatives and internationally agreed commitments in relation to environment and sustainable management of natural resources including energy.

The four-year strategy addresses the following challenges:

Assisting developing countries to make better progress on integrating environmental sustainability in decision making and thus underpin achievement of all the Millennium Development Goals by building capacity, supporting the involvement of civil society and developing innovative approaches;

Promoting implementation of Community initiatives and agreed commitments (including those under Multilateral Environmental Agreements) on environment and sustainable management of natural resources, including resource efficiency, energy at international and regional level and across national boundaries;

Improving environmental integration and promoting coherence in EU policies affecting third countries through methodological work and enhancing expertise;

Promoting EU environmental policies abroad by strengthening international environmental governance, negotiation and monitoring, assisting the operation of MEAs and other processes, supporting coherent international policy development across the three pillars of sustainable development and

Promoting EU energy policies abroad, in particular sustainable energy options in partner countries and regions by support for policy development and through innovative funding mechanisms.

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Table D-1: TCY Projects – A Summary and Instances16

Title of project

Beneficiary Countries

Type of beneficiary

TCY Contribution (€)

Background Objectives Anticipated / Actual Outcomes

Promoting Climate Change Policies in Turkey

Turkey (TR)

Intergovernmental body

259,413

Given its candidature for EU membership, climate change policies have progressively become more significant in Turkey in the last years, the main milestone being Turkey's ratification of the UN Framework Convention on Climate Change (UNFCCC). However, civil organisations, industry and public institutions require training and networking activities to tackle climate change related issues on a wider scale.

Main objective: to assist Turkey in developing tools to reduce greenhouse gas emissions and fulfil its obligations towards the UNFCCC. To this end, the project strives to build capacities related to climate change within national administration and civil society groups; promote intra-governmental Co-operation; and increase the awareness of stakeholder groups and strengthen their role in climate change debate.

The project will directly support the development of climate change policies for priority sectors and will enhance public participation and access to environmental information.

Flash Floods in Egypt: Protection and Management

Egypt (ET)

Research institutions

540,000

Flash floods can cause severe damage and loss of life in desert areas such as the Sinai Peninsula. They also represent a constraint to regional development and a major source of erosion and pollution. On the other hand, however, floodwater can be an important source of water replenishment in arid regions. The wise use of floodwater in these areas is therefore important for the sustainable management of water resources.

Overall: to achieve a sustainable management of water resources in the Sinai Peninsula. Specifically: to develop and implement an integrated flash-flood management strategy for the Wadi Watier, which flows into the Gulf of Aqaba near Nuweiba City (South Sinai).

The establishment of an early-warning system, including response chains and strategies; the adaptation of land-use and implementation of protection measures appropriate to local levels of risk and vulnerability; the improvement of water-storage options and facilities.

Protecting Trans-Boundary Groundwater Sources from Pollution: Research, Training

Gaza strip West Bank (GA), Israel (IL)

NGO-Foundation

279,342

One of the most significant water resources for Palestinians and Israelis alike is the shared groundwater systems of the coastal and mountain aquifers. The Coastal Aquifer has been subject to industrial pollution, leading to closure of some wells in Israel. Regarding the Mountain Aquifer, pollution by sewage has rendered hte water of many

Overall: to reduce groundwater pollution in Israeli and Palestinian municipalities. Specifically: to research sources of groundwater pollution from anthropogenic activity in Israeli and Palestinian municipalities; to establish guidelines for monitoring, managing, and reducing sources of groundwater pollution; to strengthen technical know-how and build a network of

The project succeeded in developing capacity and enthusiasm for implementing improved water management in demonstration municipalities in both Israel and Palestine. Research was carried out into the sources of groundwater pollution in both Israel and Palestine through case studies of two municipalities, one in each area. Anthropogenic activities were examined, a

16 http://ec.europa.eu/environment/life/publications/lifepublications/lifefocus/documents/TCY_lr.pdf

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and Guidelines for Israeli and Palestinian Companies

natural springs undrinkable.

Israeli and Palestinian water practitioners at municipal level; to plan and conduct joint study tours for Israeli and Palestinian water practitioners; to create commitment to improve environmental performance.

wide and comprehensive set of new hydrological data was produced and institutional and infrastructural factors that could help or impede groundwater resources were also considered.

Wastewater Treatment and Reuse for Irrigation

Morocco (MA)

University

338,151

Irrigation is the largest water consuming activity in Morocco. In countries where rainfall is insufficient to supply those needs, reuse of domestic and industrial waters is needed. However, regulations for the reuse of wastewater for irrigation are not yet in place in Morocco.

Aim: to demonstrate the use of best available technologies for wastewater treatment, pollution reduction, and water reuse in irrigation and to build administrative capacity for the management of the entire water cycle, in particular in the Settat province.

The results will be used to support environmental legislation, improve environmental management, and promote strategies for sustainable development of agriculture and water resources management.

Kaliningrad Air Pollution Induced by Traffic: Modeling System Design, Installation and Validation

Russia (ROS)

Local authority

283,950

The City of Kaliningrad's authorities are seriously concerned by the city's growing air traffic, which is leading to continuously higher air pollution. The main urban pollutants involved are nitrogen oxides (NOx), dust (PM) and hydrocarbons, especially benzene.

Objective: to build a modelling tool to be used by the municipal institution ECAT-Kaliningrad (ECAT) to study the patterns of air pollution induced by traffic in Kaliningrad. Through the application of optimised emission-reduction strategies, the project will seek to reduce air pollution caused by traffic in the city's 'hot spots'. The initiative will also support the effective control and monitoring of the transport sector's impact on the environment.

The key results of the project should be the definition of emission-reduction scenarios and an air-pollution abatement strategy, which will be used by the municipality to prioritise and enforce emission-reduction policies.

Network for Water Quality Monitoring

Tunisia (TN)

National authority

448,620

The protection of water resources is a national priority in Tunisia. Water quality is degrading due to discharges of untreated urban and industrial wastewater in lakes, rivers and 'oueds', diffuse pollution due to the agricultural use of pesticides and fertilisers, and contamination by solid waste. However, there is no inventory or assessment of the pollution sources. Tunisian authorities also lack the required monitoring and institutional capacity to fully enforce laws and regulations.

Objective: to reinforce the capacity of the National Environment Protection Agency to monitor and control water pollution; the project aims to support the institutional strengthening of ANPE to improve water pollution control, promote coordination between stakeholders in charge of water monitoring, and upgrade the local monitoring equipment.

Activities will include the development of a manual of procedures, training of staff, and purchase of mobile laboratories and equipment.

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Central Posavina - Wading Toward Integrated Basin Management

Croatia (CRO)

Park-Reserve authority

496,845

Lonjsko Polje Nature Park represents the largest maintained inundation area in the Danube river catchment. It is a key component of the flood control system formed by the Sava River basin, affecting Bosnia Herzegovina, Serbia and Montenegro. The Park has been identified by IUCN - the World Conservation Union as a showcase of Best Practices of Conservation Planning and is home to seven important habitats and 89 species mentioned in the EU Habitats Directive (92/43/EEC).

Aims: to maintain and protect the biological and landscape diversity of the Lonjsko Polje Nature Park; to improve benefits for local people; to raise public awareness about the values of the site; and to ensure effective flood control on a multilateral basin scale.

The project will develop consultative processes on a basin scale involving relevant stakeholders and develop a management planning process to ensure that the management requirements of the wetlands are recognised. Furthermore, activities will be implemented to improve benefits for local people; develop a sustainable visitor management system; and train rangers in communication and ecological monitoring.

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Under the ENRTP initiative, funding was extended to institutes and authorities in countries all over the world – in the Middle East, Africa, Latin America and Asia – as well as to international institutes such as Transparency International and Internews Europe. Adopted in 2006 by the European Commission, the initiative sought to support projects relating to the environment and the sustainable management of natural resources. On a broad level, themes addressed by beneficiary projects included:

promotion of innovative renewable energy sources;

land and biodiversity conservation;

forest resource management;

waste management.

Beneficiary organisations included non-state actors (NSAs), research institutes / universities and international bodies.

Several projects sought to engage local communities and populations in their conservation / innovation initiatives – as in the case of the Georgian forest management project and the programme encouraging usage of bamboo for clean energy generation in Ethiopia and Ghana.

While some projects – such as the Palestinian wind-energy system project and the Indonesian carbon-monitoring initiative – promoted innovation, others sought to revive and conserve traditional environment-friendly practices, as in the case of the rainwater-harvesting project undertaken in South India.

Details of ENTRP Projects are summarised in Table D.2 below.

D.2.2 ENPI - Cross-border Co-operation (CBC)

Cross-border co-operation on the external borders of the EU is a key priority both in the European Neighbourhood Policy and in the EU’s Strategic Partnership with Russia. The adoption of the European Neighbourhood and Partnership Instrument (ENPI) has considerably enhanced the scope for cross-border co-operation17. Cross-border Co-operation covers the countries of Eastern Europe, the Southern Caucasus, and the Southern Mediterranean, those regions which directly share a land or maritime border with the EU, and their counterparts on the EU side of the border. In line with Interreg practice, the regions eligible to participate in the programmes will be those departments or provinces directly sharing the border on both sides.

The total EC funding provided for in this Indicative Programme, for the period 2007-10, amounts to €583.28 million to:

promote economic and social development in regions on both sides of common borders;

address common challenges, in fields such as environment, public health and the prevention of and fight against organised crime;

ensure efficient and secure borders;

promote local cross-border “people-to-people” actions.

17 European Neighbourhood & Partnership Instrument (2007), Cross-Border Co-operation Strategy Paper 2007-2013, Indicative Programme 2007-2010

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Table D-2: Examples of ENRTP Projects

Title of project

Region Country EC Contribution (€)

Background Objectives Expected results

Integrated Wind Energy Production System for Al-Ahli Hospital

ENPI-EAST Palestine 1,309,440

Funding has been secured through the European Union's Environment budget line, which helps developing countries and partner organisations to manage environment and natural resources, to fulfill their obligations under multilateral agreements and to participate fully in developing international policies in a variety of areas. (http://gazaeconomy.blogspot.com/2009/11/integrated-wind-energy-production.html)

To help finance a cutting-edge wind energy production system named “Integrated Wind Energy Production System for Al-Ahli Hospital “ that can provide over 40% of the hospital's energy needs - will help install a wind turbine capable of producing up to 700 KW of energy. "Specific objectives include energy consumption decrease by approximately 30-40 % per year, increased reliability, reduction of 800 tonnes of CO2 emissions/year, technical workshops and capacity building in wind energy management."

First instance of wind-generated electricity in Palestine, it is hoped this would serve as a model. A study also planned to assess potential for wind energy projects in the West Bank. The biggest health facility in the area will get a substantial portion (>40%) of its energy from a green source.

Conserving Georgia’s unique biodiversity: Delivering capacity to protected areas and engaging traditional pastoral communities

ENPI-EAST Georgia 1,827,728

Forest management and forest preservation infrastructure development needs in the mountainous Caucasus regions

Fostering a programme of community policy vis-a-vis forest management to address issues relating mainly to deforestation and climate change, but also others: http://www.rec-caucasus.org/recc/index.php?f=12&su=12060010012&t=index

"The project will be focused on development of new institutional, legal and technical set-up for community forest management and in particular will support securing land tenure and forest rights of local communities, implementation of institutional arrangements and land use policies for forest conservation and sustainable use. In addition immediate reforestation measures under the project can solve such problems as land-slides, mudflows, avalanches and consequently protect populated areas from natural disasters."

Across the River – a transboundary peace park for Sierra Leone and Liberia

ACP-AFRICA Sierra Leone

2,447,286

This project, along with "The Gola Forest: A new, practical model for achieving sustainable protected areas in post-conflict Sierra Leone, a Least Developed Country" aims at preserving what remains of the vast Upper Guinean Rainforest. These rainforests are classified as a biodiversity hotspot of global value.(http://europa.eu/rapid/pressReleasesAc

To unite the Gola Forest Reserve (Sierra Leone) and the Lofa and Foya Reserves (Liberia) with a view to promote regional peace and stability as well as foster collaboration on the critical issues of climate change and forest resource management.

The project envisages uniting isolated patches of forest across the two borders. This will promote better forest resource management and conservation, as also promote regional stability and peace efforts. "The establishment of the Peace Park will ensure that the long-term conservation of the forests, their biodiversity and global carbon storage benefits is secured

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tion.do?reference=IP/09/799&format=HTML&aged=0&language=EN&guiLanguage=en)

through national and international partnerships for improved forest governance across the Sierra Leone–Liberia border." (http://www.birdlife.org/news/pr/2009/05/peace_park_west_africa_pr.html)

Bamboo as sustainable biomass energy: A suitable alternative for firewood and charcoal production in Africa

ACP-AFRICA Ethiopia 1,330,000

Due to its extremely fast growing properties, woody nature, high-tensile strength, and carbon sequestration rates, bamboo is an ideal sustainable alternative biomass fuel. Bamboo can serve as a viable alternative biomass for firewood and charcoal at the household level in Africa. This project will promote bamboo as a renewable energy biomass and will address specific environmental problems in Ethiopia and Ghana.

• To increase the use of bamboo as a source of energy for the poor of Ethiopia and Ghana. • To develop over a four year period the bamboo resource base in Ethiopia and Ghana

• To develop over a four year period a small-scale private bamboo firewood and charcoal sector to ensure appropriate supply • To put into place the institutional support needed.

(http://www.inbar.int/publication/TXT/Texto%20Programa%20Informativo1.doc)

• By the end of the project period a sustainable local resource base for bamboo will be in place in both Ethiopia and Ghana, sufficient to supply households and small enterprises to substitute bamboo for firewood and charcoal. • At least 30,000 households will be using bamboo as their energy source, and at least 1,000 micro and small enterprises (MSEs) producing bamboo charcoal. • By the end of the project, both governments will have issued policy recommendations, and at least one national level MSE association in each country will be in place.

(http://www.inbar.int/publication/TXT/Texto%20Programa%20Informativo1.doc)

Sustainable Utilisation of Nigeria’s Gas and Renewable Energy Resources

ACP-AFRICA Nigeria 2,297,752

In spite of its abundant conventional fuel resources and renewables potential, Nigeria faces an energy crisis which is crippling its ability to mitigate poverty and attain Millenium Development Goals (MDG) targets. The SUNGAS project seeks to facilitate access to modern energy services in the Niger Delta area in Nigeria.

"To catalyse the development of natural gas and renewable energy markets and sustainable community-based energy facilities within and beyond target communities and the target states, through policy reform and by demonstrating that alternative community-based energy facilities can provide sufficient power for meeting rural and urban community needs."

(a) Reformed policy framework and more favourable investment climate

(b) One community-based demonstration project for utilisation of flared gas to generate electricity for household and enterprise consumption (c) Up to five community-based renewable energy facilities based on scaling up or replication of successful pilot initiatives.

(d) Institutions to enable work to continue beyond the life of the project .

(http://www.iied.org/pubs/pdfs/G02477.pdf)

Conserving Georgia’s unique

ENPI-EAST Georgia 890,488 NACRES is a non-governmental, not-for-profit organization, founded in 1989. Its mission is to safeguard the biodiversity of Georgia and the

Overall Objective: To conserve the biodiversity of the semi-arid landscape in Georgia by drawing on indigenous and international

Increased and improved conservation of important ecosystems and species as a result of effective capacity support to selected Protected

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biodiversity: Delivering capacity to protected areas and engaging traditional pastoral communities

South Caucasus, through conservation activities at national and local levels. In 2004, NACRES requested assistance from Fauna & Flora International to train its staff and support their institutional development.

expertise. Aim: to develop effective mechanisms and capacity and enhanced advocacy to improve the conservation status of large carnivores in and around the Protected Areas of the semi-arid landscape (Georgia).

(http://www.nacres.org/carnivore_conservation.html)

Areas; successful human-wildlife conflict mitigation measures developed and implemented in partnership with key stakeholder groups; rural livelihoods enhanced in ways which offer sustainability and enhanced conservation of ecosystems and species; improved attitudes and perceptions amongst target groups for biodiversity, carnivores and conservation; national policy and local practices positively influenced by lessons captured from Action

Protección de la biodiversidad nativa de las islas Galápagos (Protection of native biodiversity in the Galapagos Islands)

LATIN AMERICA

Ecuador 960,000 There are many causes that cause the accelerated loss of biodiversity in the Galapagos, but in this proposal we have concentrated on those factors that can more quickly reverse the loss of biodiversity. When referring to the word "protect" we are talking about "preserve through the action of people" is why the project works with people to solve the environmental problem.

Overall objective: the comprehensive protection of the biodiversity of the Galapagos Islands, which is being threatened by alien species. Specific goals: To strengthen and integrated public institutions addressing the entry and control of alien species; to the impact of introduced species on native and endemic biodiversity while promoting the restoration of degraded ecosystems; to increase the active participation and empowerment of local communities in conservation activities.

Eradication of invasive species, better nature tourism, improvement in living conditions of locals (http://www.fundargalapagos.org/portalj/index.php?option=com_content&task=view&id=94&Itemid=84&lang=en)

Accountability and Local Level Initiative to Reduce Emission from Deforestation and Degradation in Indonesia (ALLREDDI)

ASIA Indonesia 886,769 Indonesia is at the centre of interest of the current debate on reducing greenhouse gas emissions from deforestation and degradation because it has, over the past decade, regarded as the country with the third highest emissions. Currently, the Government of Indonesia lacks necessary skills and know-how to independently develop and implement credible carbon accounting system that can be used in the negotiation for REDD incentives at an international level.

(http://www.worldagroforestrycentre.org/sea/ALLREDDI)

Overall objective: to assist Indonesia in accounting for land-use based greenhouse gas emissions and to be ready to use international economic ‘REDD' incentives for emission reduction in its decision-making at the local and national levels. Specific aims: Developing national carbon accounting systems that comply with Tier 3 of the IPCC guidelines for AFOLU, complementing and maximizing existing efforts; developing and strengthening national and sub-national capacity in carbon accounting and monitoring; designing operational REDD mechanisms in five pilot areas spread geographically, socio-economically and culturally across Indonesia based on local constraints and opportunities and in conjunction with local development planning

Expected outputs of the project include: An accounting and monitoring system that relates local level action to national emission data towards international agreements; Credible estimates of the dynamics of carbon stocks at the national level over the past 20 years that complies with Tier 3 reporting guidelines of the IPCC; REDD designs for five pilot areas, including baselines nested within national policy, providing efficient & fair payment distribution; Operational guidelines for REDD for approval by the designated national authority in Indonesia

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Increased water harvesting and diminished desertification in Tamilnadu, India

ASIA India 841,099 The food security in southern India mainly depends upon the performance of the village level tanks and farm level ponds. The communities used to manage the tanks for collecting and distributing water throughout the year. Due to poor investments and breakdown of communal management the performance of these water bodies became dysfunctional and this leads to break down of land use and agriculture. All the actions through the project will rehabilitate and restore the water holding capacity of tanks thereby increasing the food security of poor and marginal farming families.

This action–oriented project aims at contributing to increased food and environmental security in drought prone coastal areas of southern India, through conservation of traditional water bodies like tank and farm level ponds. The targeted groups of the action are marginalized small farmers’ and landless families.

(http://www.dhan.org/projects/water_harvesting.php)

•Traditional water harvesting structures in the five selected districts will be revived, conserved and developed •Community based tank management associations will be established that effectively manage the water harvesting structures •Increased income for small land holders in the five selected districts from better agriculture land use and additional income generating activities •Lessons learned and good practices will be documented and disseminated to other stakeholders/interested practitioners working on tanks in South India and South Asia

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D.2.3 Instrument for Pre-Accession Assistance (IPA)

IPA replaces a number of instruments, and was set up to assist candidate countries (Turkey, Croatia and FYROM) and potential candidate countries (Serbia, Montenegro, Bosnia-Herzegovina and Albania) towards progressive alignment with EU standards and policies. The main impacts of the instrument are likely to be more coherence and coordination of assistance for all beneficiary countries and better preparation for Structural, Cohesion and Rural Development Funds through greater familiarisation of necessary structures and programming documents.

As of 1 January 2007, pre-accession funds underwent a significant policy reform, namely the replacement of several EU programmes and financial instruments with a single instrument and legal framework18 – the Instrument for the Pre-Accession Assistance (IPA).

Financing under this single umbrella is provided through five components, which differ in terms of who is eligible for funding and which DG is responsible for disbursing the funds:

Component Nature of component DG responsible for provision of funding

Countries eligible for funding

1- Transition Assistance and Institution Building

financing capacity-building and institution-building

Enlargement All beneficiary countries: both current Candidate Countries and potential Candidate Countries

2- Cross-border co-operation

With EU MS and other countries eligible for IPA

Regional Policy All beneficiary countries: both current Candidate Countries and potential Candidate Countries

3- Regional Development

Providing support to transport, environment infrastructure and enhancing competitiveness and reducing regional disparities

Regional Policy Candidate Countries only

4- Human Resources Development

Strengthening human capital and combating exclusion

Employment and Social Affairs

Candidate Countries only

5- Rural Development

preparation for the common agricultural policy and related policies and for the European Agricultural Fund for Rural Development (EAFRD)

Agriculture Candidate Countries only

Source: IPA website

An example of an IPA funded project that is worth mentioning in this context is the “Environment Forum” project. The overall objective is to build and strengthen civil society active in the environment field in candidate countries and potential candidates. The specific purpose of this project is to develop the dialogue between environmental NGOs and the

18 Established under Council Regulation (EC) 1085/2006 of 17 July 2006 and its implementation provisions in Commission Regulation (EC) 718/2007

33

European Commission on developments in the EU’s environmental and horizontal policies and their implications in the context of the enlargement process. The activities included:

The design, implementation and maintenance of an e-mail forum and database/website, which serves as a platform for the diffusion of information and discussion between the NGOs and the European Commission

The organisation and animation of 1 annual meeting of a group of selected NGOs

Ensure the reporting and the production of targeted publications

Although this project does, up to a point, mirror the objectives and approach of the NGO programme under Life+, its potential beneficiaries are different, as the project only involves NGOs from the candidates and potential candidates: Albania, Bosnia and Herzegovina, Croatia, fyRoM, Kosovo, Montenegro, Serbia and Turkey (the beneficiary countries).

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E ANNEX E: REVIEW OF FOREST FOCUS ACTIVITIES

The LIFE+ Regulation 614/2007 repealed the Forest Focus Regulation 2152/2003, but does not appear to be able to substitute the latter. Although their scopes and intended purposes bear similarities, the regulations differ to a large extent.

E.1 Differences in the Forest Focus and LIFE+ Regulations

The Forest Focus Regulation concerning monitoring of forests and environmental interactions in the Community for the 2003-2006 period, and its implementing regulation 1737/2006, were the last instalment of 20 years of continuous mandatory forest monitoring in the EU (regarding fire since regulation 2158/92 and air pollution since regulation 3528/86). Under Forest Focus, such as in previous regulations, Member States had to conduct coordinated forest monitoring harmonised at the EU level. Data was then sent to databases kept by the Commission's Joint Research Center (JRC)19.

LIFE+, on the other hand, establishes forests as a "principal objective:"

"To provide, (…) relevant information on forests in relation to climate change (…), biodiversity (…), forest fires, forest conditions and the protective functions of forests (…) as well as contributing to the protection of forests against fires."

and sets 5 priority areas of action including:

"promoting harmonisation and effectiveness of forest monitoring activities and data collection systems and making use of synergies by creating links between monitoring mechanisms established at regional, national, Community and global levels".

In addition, recital 8 of the LIFE+ Regulation notes that "Projects for the development and implementation of Community objectives relating to the broad-based, harmonised, comprehensive and long-term monitoring of forests and environmental interactions should be eligible for Community financing under LIFE+, except where they are eligible for funding under other Community financial instruments.” LIFE+ defines a certain number of actions that could be eligible for support and sets priorities that are consistent with full and harmonised monitoring, but it does not guarantee continuity and concrete proposals are left to the goodwill of Member States and interested organisations20.

E.1.1 Geographical coverage and relevance of forest monitoring networks A consequence of the change from Forest Focus to LIFE+ for forest monitoring has been that some MS did not join, or later withdrew from the FUTMON project that was chiefly proposed under LIFE+ as a continuation of Forest Focus21. The EU-wide spatial coverage is therefore seemingly lost and retro-compatibility with the time series already stored in JRC is not guaranteed.

19 Information provided by officer formerly in charge of the technical implementation of the Forest Focus Regulation (EC, DG Environment, Unit B.1)

20 Information provided by officer formerly in charge of the technical implementation of the Forest Focus Regulation (EC, DG Environment, Unit B.1) 21 Information provided by officer formerly in charge of the technical implementation of the Forest Focus Regulation (EC, DG Environment, Unit B.1)

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The design of Forest Focus, following the tradition of the International Co-operative Programme on Assessment and Monitoring of Air Pollution (ICP) was based on two networks of data collection sites: the low intensity “level 1” representative and systematic network

the “level 2” intensive monitoring and research sites.

The monitoring and research communities expected that they would be able to upscale the scientific results obtained on level 2 to gain additional representative insight based on the cheap but broadbased level 1 data. This approach failed and provided little policy relevant information. Forest Focus’ level 2 proved extremely costly and of little predictive or representative value. FUTMON continued even further in this research driven agenda and created an even more intensive and less representative level 3 network. As determining the scientific purpose and relevance of levels 2 and 3 networks is up to the scientific community, its financing could as well rely on the research budget22.

E.1.2 Ownership of data and existing information systems

There is no concrete provision in LIFE+ to contribute to update the Forest Focus database or to continue comparing the soil and biodiversity results to the Biosoil baselines set up within the Forest Focus scheme. Additionally, the JRC cannot provide past data to the FUTMON consortium due to objections from some former national Forest Focus competent bodies outside of FUTMON. As the result, the EU ends up with two databases that cannot be merged for both legal and technical reasons.

The European Forest Fires Information System (EFFIS) also supported and legally anchored by Forest Focus, lost its legal basis with the repeal of its Regulation. EFFIS and the Commission's expert group on forest fires are unique and recognised and appreciated within and outside EU. EFFIS includes information from all Member States and some Mediterranean third countries facing significant fire risks. It is a strategic tool (for preventing forest fires or triggering help from the EU Solidarity Fund, for instance) and serves as a core element of forest fire monitoring under Forest Focus and beyond. Following the termination of Forest Focus, the support to EFFIS provided by Forest Focus was not transferred to the LIFE+ instrument. However, the work of EFFIS that was previously supported under Forest Focus has been assured till the end of 2010 by means of a grant of the European Parliament on forest protection on conservation. One remaining important question will be on which legal basis EFFIS and its activities will be maintained after this grant funding ceases.

E.1.3 Scope and duration of support measures

Under Forest Focus, feasibility studies and demonstration projects on monitoring forest genetics, carbon storage, or effects of climate change were performed in accordance with Member States priorities. Practical measures (such as structural fire prevention) were also co-financed.

Based on national agreements with all 25 MS, Forest Focus covered:

Monitoring the effects of atmospheric pollution on forests;

Prevention of forest fires and the study of their causes and effects;

Development of the European Forest Fire Information System;

Biodiversity, climate change, carbon sequestration, soils and protective functions of forests;


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Continuous evaluation of monitoring activities

More specifically, the Forest Focus instrument provided measures to:

Promote harmonised collection, handling and assessment of data at EU level;

Enhance the understanding of forests and, in particular, the impact of natural and anthropogenic stresses;

Study the dynamics of forest fires and their causes and impacts on forests;

Develop indicators and methodologies for the assessment of new forest parameters, broadening the scope of the previous forest monitoring (so far limited to atmospheric pollution and forest fires).

LIFE+ makes some measures previously supported under Forest Focus eligible for funding:

developing and maintaining networks, databases and computer systems directly linked to the implementation of Community environmental policy and legislation,

studies, surveys, modelling and scenario building;

monitoring, including the monitoring of forests;

capacity building assistance;

training, workshops and meetings, including the training of agents involved in forest fire prevention initiatives;

information and communication actions, including awareness-raising campaigns and, in particular, public awareness campaigns on forest fires;

E.1.4 Administrative process

Under the Forest Focus scheme, all 25 Member States (except for Malta) drew up two-year national programmes for 2003/2004 and 2005/2006 (split in two phases, 2005 and 2006). These programmes were submitted to the Commission for approval and were also subject to ex-ante evaluations. Each MS was to designate a competent authority to manage its national programme (with the exception of Belgium, Germany and Portugal which designated more than one competent authority)23. The Commission was responsible for coordinating, monitoring and developing the scheme. Decisions on the designation of the competent bodies carrying out the scheme, the national programmes and their budget were notified to each of the Member States. Subsequently, the Commission concluded agreements for each of the national programme periods with the national competent bodies. The Commission established a scientific coordination at its Joint Research Centre and concluded a major grant agreement with BFH/ICP-Forests for coordinating the programmes.

Under the current “annual call approach” of LIFE+, the Commission’s role is limited to accept/reject short term grant proposals. There is a limited extent to which interested Commission services can steer sustained effort and involve countries with few or none proposals, and define ex-ante new policy relevant questions that need answering24.

To remain eligible according to the LIFE+ regulation, recurring but atypical forest monitoring grants (costing the LIFE+ budget €20 million for a 2-year period) should support

23 COM (2008) Report from the Commission to the council and the European Parliament on the implementation of the FF scheme according to Regulation (EC) No 2152/2003 of the European Parliament and of the Council of 17 November 2003 concerning monitoring of forests and environmental interactions in the Community (FF)


37

“development and implementation of Community objectives relating to the broad-based, harmonised, comprehensive and long-term monitoring of forests”. This means the Commission provides initial “investment support” but in the long run, only interested Member States bear the “sustained financing of operational costs” and overall responsibility. These projects consume a significant share of what could be spent on other forest actions25. One could argue whether they could be revaluated against other priorities26.

E.2 Measures actually financed

E.2.1 The Forest Focus scheme (2003-2006)

The types of activities co-funded under the Forest Focus scheme can be divided into:

A activities - concerning project coordination and management

B1 activities - concerning the systematic or level I monitoring network

B2 activities - concerning level II plots involving intensive monitoring

B3 activities - concerning forest fire prevention, including the establishment of firebreaks, maintenance and further development of the European Forest Fire Information System (EFFIS), and awareness raising campaigns

C activities - concerning studies and demonstration projects to broaden and further develop the scheme: biodiversity, soils, carbon stocks, etc.

In terms of financial contribution, the EU contributed between 50% and 75% of the total costs, depending on the type of activity included in the national programmes. The total budget committed for Forest Focus between 2003 and 2006 was €65 million, including €9 million for fire prevention measures. A large proportion of the budget was committed for Level II intensive monitoring plots and for studies and demonstration projects (including €10 million for developing a forest soil and biodiversity monitoring system (see Figure E-1).

25 such as EFFIS, the dissemination of policy-relevant information concerning forests and environmental interactions, synergies between specific forest-related issues and environmental initiatives and other legislation (e.g. Thematic Strategy for soil protection, Natura 2000, Directive 2000/60/EC, Water Framework Directive, RES and RDR directives), contributing to sustainable forest management...


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Figure E-1: Breakdown of FF budget allocation per activity between 2003 and 200627

€ 3,890,7877%

€ 4,682,8978%

€ 21,526,69938%

€ 9,364,28317%

€ 17,003,55930%

A Activities

B1 Activities

B2 Activities

B3 Activities

C Activities

The number of Member States participating in Forest Focus in 2003 was 15, and this was increased to 24 in 2004 following the inclusion of 9 new Member States (excluding Malta, which did not participate in the programme)28. The size of EC allocation used for co-funding from 2004 was therefore higher than that in 2003 (see Figure E-2 below).

Figure E-2: Budget allocation by type of activity from 2003 to 2006 under Forest Focus29

0

2

4

6

8

10

12

14

16

18

20

2003 2004 2005 2006

Millions (EUR)

C activities

B3 activities

B2 activities

B1 activities

A activities

27 Chart generated based on data presented in the COM (2008) 6 final paper

28 METLA (2004) Final Report for EU contract concerning: Development and review concerning FF.

29 Chart generated based on data presented in the COM (2008) 6 final paper

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An evaluation of the Forest Focus programme provided the following recommendations30:

1. The management of the programmes was cost effective but in MS with more than one competent authority, the administrative burden was increased

2. Monitoring activities (both the intensive and the systematic networks) should focus more widely than on forest health condition related to air pollution. They should include parameters related to climate change, biodiversity and the protective functions of forests

3. Data from national forest inventories should be taken into account when forest monitoring takes place

4. The continuation of the monitoring scheme should be assured

The ending of the Forest Focus Regulation removes the obligation from the MS to conduct coordinated EU-level forest monitoring, and in order to avoid uncoordinated activities, in the future, it would be necessary to develop an EU-wide framework which allows for efficient management, data recording, analysis, quality control and reporting.

E.2.2 Environment projects with a focus on forests under the LIFE programme (1996-2006)

During the 1996-2006 period, the LIFE Programme (LIFE II–LIFE III extension) co-financed 15 projects which were categorised as forest projects. This was less than 2 percent of all LIFE Environment projects. The total budget was €14.1 million, of which the Commission contributed €6.1 million (equivalent to 43% of the total budget). The breakdown of projects related to forests is presented in Table E-1.

30 Report from the Commission to the Council and the European Parliament - Report from the Commission to the Council and the European Parliament on the implementation of the Forest Focus scheme according to Regulation (EC) No 2152/2003 of the European Parliament and of the Council of 17 November 2003 concerning monitoring of forests and environmental interactions in the Community (Forest Focus)

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Table E-1: Overview of LIFE projects (LIFE II- LIFE III extension, 1996-2006) categorised as forest projects31

There is no concrete mention of forests in the outline of objectives of LIFE II and LIFE III (1996-2006). In addition, LIFE III does not specify any particular measures, which in relation to forests, could be eligible for funding. However, the general objective of LIFE is to “contribute to the implementation, updating and development of... sustainable development in the Community” (Article 1) and sustainability was one of the most important guidelines for eligibility of forest projects under LIFE III.

A substantial number of LIFE projects dealt with forests from a nature/habitat/biodiversity point of view and were categorised as LIFE Nature and LIFE Environment projects. On the whole32:

In financial terms, an average total budget for a project ranged from €0.6 to €1.5 million, and LIFE contributed from €0.22 to €0.64 million (corresponding to between 30-50% of the budget);

The majority of projects started in 1998 and 1999, and no new forest projects were registered under LIFE Environment from 2002-2006. It was suggested that this was due to the emergence of the Forest Focus programme in 2004, which had a budget worth €65 million.

The projects were carried out in only 5 countries, and Spain was found to carry out the highest number of projects (6 out of 15) (see Table E-2).

31 COWI (2009) Ex-post evaluation of projects and activities financed under the LIFE Programme. Report contracted by the Directorate General Environment, European Commission.


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Table E-2: List of Forest projects within the LIFE Environment component (LIFE II- LIFE III extension, 1996-2006)33

In terms of types of projects:

Most of the projects (67%) focused on forest management.

o Some of these projects combined project management with awareness raising and communication and one involved elements of monitoring (testing of indicators).

o Other projects involved the preservation of bio-cultural heritage in forests or revitalisation of overexploited forest areas, which are typical of the Mediterranean region.

Of the remaining projects, some projects focused on technical aspects.

o Many projects aimed to introduce better techniques and management methods to achieve sustainability of the targeted forest systems (often in mountainous areas) for the benefit of the rural communities in the longer term.

E.2.3 Forest projects under LIFE+ (2007-2008)

Under LIFE+, four projects were funded under the Environment Policy and Governance component (see Table E-3) and four projects regarding information and awareness-raising campaigns in relation to forest fires were funded under the Information and Communication component (see Table E-4). The total budget of all 8 projects was €43 million, of which the EC contributed €20 million, including more than €16 million spent on the FUTMON project.


42

In 2008, three grants were awarded, all to Greek entities, significantly smaller in amount than the 2007 grant. Two of the three projects, one undertaken by an intergovernmental body and the other by a university, dealt with the problem of forest fires. The third – also taken up by a university – sought to set up a national-level data facility to improve policy responses to climate change and other adverse environmental impacts on forests.

Table E-3: List of LIFE+ Environmental Policy and Governance projects categorised in the Forest theme34

Project ID Project name MS Beneficiary Size of project (€) EC contribution (€)

Aim

LIFE07 ENV/D/000218

Further Development and Implementation of an EU-level Forest Monitoring System

DE Research institution

34,443,390 16,139,278

Create a pan-European forest monitoring system that can serve as a basis for the provision of policy-relevant information on forests in the European Union.

LIFE08 ENV/GR/000553

Local Authorities Alliance for Forest Fire Prevention

EL Intergovern-mental body

698,323 341,419

Develop a network of Greek local authorities (LAs), to analyse existing forest fire prevention measures, and to develop a local action plan and a guide for forest fire prevention.


Development of an integrated analysis system for the effective fire conservancy of forests

EL University 2,340,839 1,158,803

Improve the knowledge and skills of civil protection professionals/services on effective temporal and spatial planning of resources; improve the knowledge and skills of decision-makers on evacuation planning; and increase the effectiveness and readiness of fire brigades, civil protection, local communities and any other stakeholders to deal with forest fire threats.


Building a structured, indicator based knowledge system for sustainable forest policy and management

EL University 1,139,495 567,247

Establish a knowledge base for national forest policy development and implementation, based on MCPFE criteria and indicator estimates, including impact assessments on forests related to climate change.

Table E-4: List of Information and Communication projects relating to Forests35

Project ID Project name MS Beneficiary Size of project (€) EC contribution (€)

Aim

LIFE08 INF/EE/000260

Raising awareness for forest fires and training of forest fire agents and volunteers in

EE NGO 300,432 150,178

Raise awareness of how to protect against forest fires and to provide training to improve

34 GHK analysis based on data from http://ec.europa.eu/environment/life/funding/lifeplus.htm

35 GHK analysis based on data from http://ec.europa.eu/environment/life/funding/lifeplus.htm

43

Estonia the implementation of preventative measures

LIFE08 INF/E/000179

Our forest – Live it and let it live!

E Regional Authority

689,535 344,467

Develop and implement an awareness-raising an educational campaign on forest fire prevention, focussing on the safe use of fire and the value of forests.

LIFE08 INF/P/000220

Efficiency and Effectiveness of Awareness Campaigns in the EU Forests

PT Local Authority

975,825 295,913

Help support the work of national and regional forest authorities in the Mediterranean region. It will include an international seminar.

LIFE08 INF/PL/000523

Forest fires and nature – raising the awareness of rural communities concerning forest fire prevention

DE National authority

1,987,381 889,544

Raise awareness of forest fire prevention among rural residents and people using forests for recreational purposes

With regard to the amounts each programme spent on forest projects:

A significant increase in spending on forest projects was observed following the transition from LIFE III to LIFE+ (see Figure E-3). However, compared to the budget spend under Forest Focus, only half of this amount is currently spent under LIFE+.

The amount of LIFE+ contribution towards monitoring of forests is similar to that in Forest Focus, but the value of the results are not comparable as regards the long-term approach of monitoring activities.

In addition, compared to Forest Focus, there is a significantly lower amount of spending on studies and demonstration projects, forest fire prevention and project coordination in LIFE+ (see Figure E-3).

44

Figure E-3: Average amounts contributed by the EC to forest projects under different programmes36

0

2

4

6

8

10

12

14

16

18

20

Forest Focus (2003-2006)

LIFEII-LIFEIII (1996-2006)

LIFE+ (2007-2008)

Ave

rag

e E

C c

on

trib

uti

on

(€

mil

lio

n p

er y

ear)

Studies/demonstration projects

Project coordination

Forest f ire prevention (training/raising awareness)

Establishing knowledge base

Monitoring

E.3 Results of the consultation

Interviews with a representative of the Forest Focus programme37 suggest that the level of monitoring has changed. Under Forest Focus, Member States were obliged to conduct coordinated EU-level forest monitoring, whereas under LIFE+, this is voluntary38. In addition, the consultee felt that LIFE+ guidance is vague in describing monitoring, and lacks a description of specific monitoring parameters (such as monitoring decolouration of leaves or monitoring defoliation).

Furthermore, a number of NCPs have suggested that the inclusion of Forest Focus under LIFE+ has not resulted in positive outcomes. One NCP suggested that the administrative effort (e.g. application, in-between-payment procedures etc) is now higher in comparison with Forest Focus39. Other NCPs suggested that long-term monitoring of forests no longer occurs because of the LIFE+ focus on non-recurring activities40. This is particularly detrimental for certain NCPs where a large proportion of the area is covered by forests. One NCP suggested that if the EU want a coordinated forest monitoring process it is not viable to subject these projects to further competition’.

36 GHK analysis based on data presented in the COM (2008) 6 final paper and data provided by the LIFE UNIT (DG ENV)

37 Telephone interview with officer formerly in charge of the technical implementation of the Forest Focus Regulation (EC, DG Environment, Unit B.1) 38 A Commission report predicted that given that LIFE+ is based on voluntary participation, monitoring under LIFE+ would be more policy specific driven and include parameters such as climate change, biodiversity and the protective function of forests – rather than a simple continuation of observations based on traditional parameters (as was the case under the “Forest Focus” scheme). COD/2004/0218, http://www.europarl.europa.eu/oeil/resume.jsp?id=5204532&eventId=1022540&backToCaller=NO&language=en 39 Telephone interview with NCP, February 2010

40 Telephone interview with NCPs, February 2010

45

F ANNEX F: REVIEW OF THE CO-OPERATION FRAMEWORK FOR SUSTAINABLE URBAN DEVELOMENT (SUD)

F.1 Objectives

Under the Co-operation Framework, projects and activities could be funded under one of three parts. The indicative breakdown of financial support for projects and activities was as follows:

Part A projects: Exchanges of information among areas where environmental problems occur alongside socio-economic problems (40%)

Part B projects: Co-operation between European level partners (40%)

Part C activities: Accompanying measures: reports, analytical reviews, monitoring etc. (20%)

The Co-operation Framework instrument covered the period from 2001 to 2004 with the intention that it would legitimise, consolidate and extend EU activities in relation to the urban environment. Between 2001 and 2003, 9 projects were approved for funding, up until the end of 2003, under parts A and B of the framework (see Box F.1). The total budget for the 9 projects was €6.3m, of which €5.1m (81% of the total budget) was contributed by the EC. In addition, a number of reports and support including support for the Urban Thematic Strategy working groups were completed under Part C (see Table F.1).

Box F.1: Summarising the projects funded under parts A and B by the Co-operation Framework programme41

CAMPAIGN (Year: 2001, Total Budget: €1,364,398; EU grant: €1,262,398)

Led by Eurocities with ten of the major European networks as partners. The objective was to provide support to actors and towns to implement local Agenda 21, facilitation of information exchange, networking and awareness rising. Activities included newsletters, meetings, web sites and presentations.

RESOURCITIES (Year: 2001, Total Budget: €459,240; EU grant: €359,240)

Led by Association of Cities and Regions for Recycling. The objective was to raise awareness of local and regional authorities, and through them, of the general public, on the relations between current ways of life and the consumption of natural resources beyond the growing urban waste production. Activities included touring exhibitions, web sites, events, guidance and awards for good practice.

PHASE (Year: 2002, Total Budget: €512,255; EU grant: €480,298)

Led by the World Health Organisation. The objective was to integrate health and social aspects into sustainable development in European cities and towns and to mobilise networks of healthy cities. Activities included meetings, the development of a Health Impact Assessment toolkit and resource pack.

DISPLAY (Year: 2002, Total Budget: €438,379; EU grant: €394,541)

41 IEEP (2005) Mid-term assessment of the Community Framework for Co-operation to promote sustainable urban development’

46

Led by Energie Cités. The objective was to launch and co-ordinate a Campaign directed at European cities to stimulate them to display the CO2 emissions and energy consumption performance in public buildings. Activities included the creation of a display label of CO2

emissions/energy consumption and to improve the information system of European municipalities so they could be used for the assessment of energy/climate policy.

MIRIAD 21 (Year: 2002, Total Budget: €795,700; EU grant: €692,259)

Led by Association Les Eco Maires. The objective was to use sustainable development as a platform to prevent major industrial risks. Activities included web sites, awareness raising, campaigns, meetings and the development of urban management systems.

SIPTRAM (Year: 2002, Total Budget: €602,676; EU grant: €497,134)

Led by the International Council for Local Environmental Initiatives (ICLEI). The objective was to promote competitive tendering in public urban transport as a chance, rather than a threat or an obligation, to improve environmental and social standards. Activities included the production of a Good Practice Guide, creation of networks and signing of commitment documents.

EMAS (Year: 2002, Total Budget: €590,058; EU grant: €535,768)

Led by the Union of the Baltic Cities (UBC). The objective of the project was to encourage municipalities across Europe, especially in the new Member States, to use and develop EMAS. The activities included a step-by-step guide to EMAS, peer reviews by friendly visits conducted by other cities, newsletters and workshops.

AALBORG +10 (Year: 2003, Total Budget: €1,037,274; EU grant: €450,270)

Led by the Council of European Municipalities and Regions (CEMR). The objective was to encourage cities and towns to start local, sustainable actions and to assess the experience gained since the Aalborg charter. The activities included the organisation of the Aalborg +10 conference and the preparation of new Aalborg +10 commitments.

QUICKSTART (Year: 2003, Total Budget: €459,875; EU grant: €390,296)

Led by Klima-Bündnis (Climate Alliance of European Cities with Indigenous Rainforest People). The objective was to offer a methodology for local authorities to work out an immediate climate policy action programme in a very short time. Activities included the development of the QUICKSTART methodology, training programmes and the involvement of pilot cities.

Table F-1: Summary and assessment of activities funded under Part C of the Co-operation Framework42

Number/Title Description Objective Lead organisation (plus partners)

Budget (€)

Activities funded in 2001

42 IEEP (2005) ‘Mid-term assessment of the Community Framework for Co-operation to promote sustainable urban development’.

47

1. Conference on Sustainable Urban Development, held in Barcelona

Reimbursement of experts To bring together potential beneficiaries of the Co-operation Framework to provide an opportunity to discuss their potential contribution, how to respond to the opportunities it offers and to help forge partnerships etc.

The City of Barcelona and the Province of Catalonia.

14,927

2. European Common Indicators (ECI)

Fund the translation of the ECI methodology into all EU(-15) languages

To translate the ECI methodology sheets into the EU languages

Different small contracts with different contractors

24,014


3. Ecological Footprint

Development of the 11th ECI – Ecological Footprint and preparing a test phase

To finalise the Ecological Footprint as an indicator for local sustainability

Contract with Best Foot Forward, also involved:

21,850

4. Urban legal base- Bureau de liaison Bruxelles- Europe

Meeting with Eurocities and the Bureau Liaison Bruxelles, on 12 June 2002

No information Eurocities and the Bureau Liaison Bruxelles

710

5. Sustainable Cities & Towns Campaign at Johannesburg

Project to promote regional variations of the European Sustainable Cities and Towns Campaign.

To share the experiences of regional Agenda 21in Europe to the rest of the world.

Contract with City of Hannover

87,225


6. Working Group on Sustainable Urban Construction

Project to manage working group and support chair, prepare reports of meetings and minutes, to reimburse attendance of experts

To contribute to the development of the Commission’s Thematic Strategy on the Urban environment, in particular the aspects of urban construction.

Contract with Architects Council of Europe

44,300

7. Working Group on Sustainable Urban Transport

To manage working group and support chair, to prepare reports of meetings and minutes.

To contribute to the development of the Commission’s Thematic Strategy on the Urban environment, in particular looking at the following topics:

Contract with RAND Europe

31,890

8. Working Group on Sustainable Urban Management

To manage working group and support chair, to prepare reports of meetings and minutes, to reimburse attendance of experts

To gain independent and expert input into the development of the Thematic Strategy on the Urban Environment.

Administrative Arrangement with JRC

30,000

9. Stakeholder Platform Coordinator – NGO Sector

To undertake consultation exercise and workshop to collect views of NGOs for Thematic Strategy.

To ensure representative views from the NGO sector across Europe are included in the development of the Thematic Strategy on the Urban Environment.

Contract with European Environment Bureau

13,500

10. U.W.E.- Assisting the expert working group on sustainable urban transport

To undertake consultation exercise and workshop to collect views of academic community NGOs for Thematic Strategy

To gain a representative view of academic community to ensure their views are included in the development of the Thematic Strategy on the Urban Environment.

Contract with European Urban Research Association (via UWE)

13,293

11. Stakeholder Platform Coordinator – Business Sector

To undertake consultation exercise and workshop to collect views of business community for Thematic Strategy

To collect representative views from the business sector and insure they are included in the development of the Thematic Strategy on the Urban Environment

Contract with Eurochambres

13,500

12. Stakeholder Platform at Metropole Hotel – Event Organisation

To prepare 4 position papers from different stakeholder groups, organise and run the 2 day event and workshops

To inform and facilitate the preparation of the Thematic Strategy on the Urban Environment through four priority areas for improvement

Contract with Land Use Consultants

61,573

13. Candidate Country Study

To ensure that the Thematic Strategy properly reflects the situation in the Candidate Countries.

To prepare a study on the situation in the Candidate Countries with regard to the 4 priority themes of the Thematic Strategy, to collect good practice examples from the Candidate Countries.

Contract with European Academy of the Urban Environment

44,675

14. Commitment for meetings

To reimburse attendance of experts

Consultation events on the development of the Thematic Strategy on the Urban Environment

Opinion from ENVAC

144,093

48

15. Fedenature Contract

Small ad hoc research project

To make a table of values for peri-urban natural spaces and classify their typology.

Contract with Fedenature

12,820

There was a clear distinction between the type, and number, of part C activities funded in the first few years compared to those funded in 2003. In 2001 and 2003, only five activities were funded, compared to ten activities funded in 2003. Activities funded in 2001 and 2002 focused on reimbursement of expenses incurred by experts in attending relevant meetings and conferences, dissemination of information, development of the European Common and Indicators project. Activities in 2003, however, were linked directly to the Thematic Strategy on the Urban Environment. The difference in focus was accounted for by the fact that when the Co-operation Framework was first agreed, the thematic strategy had not yet been initiated, whereas by 2003, it had become a focus for the development of policy relating to the urban environment at the EU level. This suggested that the emergence of the thematic strategy provided a focus for part C activities in 200343.

Funded projects focused on raising awareness, the production and dissemination of good practice and the implementation of specific practices, which aim to deliver environmental improvements in the longer-term. The focus of funded projects was suggested to be relevant, as all local authorities are facing the same problems in relation to sustainable development and therefore need information on how they might address this:44

The focus on networks is a good means of enabling towns and cities to work jointly and to exchange views and experiences in relation to the implementation of urban sustainable development. The Co-operation Framework programme has been a contributing factor to some political decisions resulting in changes at the local level. The programme appeared to have provided a district funding stream as no other funding mechanism has focused exclusively on funding networks to promote urban sustainable development.

The focus on pan-European networks seemed to have brought added value and provided a means through which its network members including local authorities, could share experience and have a more effective voice at the European level.

In addition, the Co-operation Framework programme was found to complement other Commission funding mechanisms which broadly focus on delivering concrete actions or disseminating practices relating to specific funding mechanisms.

The level of co-financing under the Co-operation Framework was high compared to other Commission funding mechanisms.

The IEEP report however, recognised that there was a degree of mistrust and misunderstanding between the Commission and the networks. Although it was not possible to identify the source of this, the IEEP report acknowledged uncertainty facing the networks in light of the integration of the Co-operation Framework into LIFE+.

F.2 Environment projects with a focus on urban under the LIFE programme (1996-2006)

Prior to the consolidation of the Co-operation Framework programme into LIFE+, during the 1996-2006 period, the LIFE Programme (LIFE II–LIFE III extension) co-financed 69 projects which were categorised as urban projects. The total budget was €82.8m, of which the Commission contributed €35.4m (equivalent to 43% of the total budget). The breakdown of projects related to urban environment is presented in Table F.2



49

Table F-2: Overview of LIFE projects (LIFE II- LIFE III extension, 1996-2006) categorised as urban projects45

Generation

Year Number of projects

Total budget (€m)

Total LIFE co-financing budget (€m)

Average duration (years)

LIFE II 1996 5 6.0 2.7 3.6

1997 16 21.1 7.1 3.0

1998 9 7.3 3.2 3.6

1999 14 12.3 5.6 3.5

Total 44 46.7 18.6 3.4

LIFE III 2000 7 11.2 5.4 3.1

2002 7 8.7 4.1 3.3

2003 2 2.2 1.0 3.5

2004 3 2.3 0.7 3.7

Total 19 24.3 11.3 3.4

LIFE III extension

2005 5 9.6 4.5 3.6

2006 1 2.2 1.0 3.0

Total 6 11.8 5.4 3.3

Grand total 69 82.8 35.4 3.4

Comparative figures for all ENV projects

1,076 1,947.7 615.9 3.4

The majority of urban environment projects, 69%, were carried out by authorities, mainly at local level (55% of total urban projects), whilst NGOs accounted for 11% of urban projects. In terms of focus of projects:

The majority of projects concerned urban environment/sustainable management (70%);

A small proportion of projects concerned development of supporting tools/methods for evaluation and monitoring purposes (14%) and awareness raising and public participation (10%)

A large proportion of management projects are restricted to the project site, which in most cases is very local. Many projects are found to deal with development or implementation of integrated strategies, plans and systems for better environmental or sustainability management in larger or smaller urban areas. Therefore, urban environment projects do not in themselves necessarily lead directly to tangible and quantifiable environmental results and benefits but mostly provide the framework through which such results and impacts can be derived in the future. Awareness raising activities appear to have been quite successful at the local level.


50

F.3 Urban projects under LIFE+ (2007-2008)

Under LIFE+, five projects were funded under Urban Environment theme in the Environment Policy and Governance component (see Table F.3). The total budget of all 6 projects was €8.5m, of which the EC contributed €4m (equivalent to 47% of the total budget). Two Urban awards were made in 2007, and three in 2008.

Table F-3: List of Environment Policy and Governance projects under the Urban theme

Project ID Project name MS Beneficiary Size of project (€)

EC contribution (€)

Aim

LIFE07 ENV/D/000224

Promoting the Protection of Natura and Biodiversity in Urban Areas: Award European Capital of Nature and Biodiversity

DE NGO-Foundation

569,842 844,065

To build the capacity of local authorities to protect nature and biodiversity in urban areas and to support and motivate new initiatives in this field by promoting “Capital of Nature and Biodiversity” competitions.

LIFE07 ENV/FIN/000138

Climate Change Response through Managing Urban Europe-27 Platform

FI Local authority

2,033,033 1,014,841

To establish an Integrated Management Systems (IMS) competence development package to enable the local level to contribute to EU environmental and climate change commitments;

LIFE08 ENV/E/000097

Innovative management model of urban trees in the city of Jerez de la Frontera

ES Local authority

656,938 317,554

To create a new management model of urban green areas that will integrate: (1) management and maintenance processes and tools; (2) the use of environmentally-friendly treatments and tree regeneration techniques for endangered species; and (3) participation and information processes to raise awareness of the importance of urban green areas as part of as a city’s heritage.

LIFE08 ENV/E/000107

Pervasive Air-quality Sensors Network for an Environmental Friendly Urban Traffic Managemen

ES NGO-Foundation

2,508,075 1,201,537

To produce pollution predictions in real time; to calculate the effects of various traffic regulation scenarios; and to compare their impact at pollution “hotspots” with new data collected by the same measurement instruments.

LIFE08 ENV/E/000123

Renewable energy production park in the landfills of Huesca

ES Local authority

2,690,940 569,842 To make the Huesca solid urban waste landfill facility energy self-sufficient.

Source: GHK analysis based on data from http://ec.europa.eu/environment/life/funding/lifeplus.htm

In general, grants address urban design relating to quality of life and transport planning with the exception of one grant which concerned municipal waste (including household and commercial). The schemes aim to support initiatives promoting green practices and standards with an urban focus, addressing key issues such as mitigation of air pollution levels, waste management and green-area management. Thus far, three local authorities and two NGOs have been granted awards under this category.

51

F.4 A comparison of Urban projects under LIFE+ and projects funded under the Co-operation Framework

A review of projects showed that the focus of urban projects has not changed following the transition from LIFE III to LIFE+, with projects mainly concerning management at the local level. Compared to projects under the Co-operation Framework:

There is less involvement of networking between local authorities

There is a lack of funding for activities (as previously funded under Part C in the Co-operation Framework).

Consultation with the former Head of the Co-operation Framework programme46 advised that an internal audit of this financial instrument identified problems - notably on double funding of networks of cities. This main concern was therefore addressed in LIFE+ through a reduction in the number of projects involving networks of cities.

In addition, with regard to the effectiveness of the Co-operation Framework programme, the consultee felt that the level of success of the programme was rated as ‘medium’, and felt that the programme only helped to develop plans and these plans still needed to be translated into actions. It was estimated that about 1.5 persons were involved to run the Co-operation Framework each year.

The number of projects funded under LIFE+ is similar to that funded under the Co-operation Framework programme (approximately 3 projects per year). This is, however, lower than the average number of projects funded under LIFE II- LIFE III extension (approximately 7 projects per year).

With regard to the scale of projects, the mid-term evaluation of the Co-operation Framework instrument raised concerns that the complicated nature of applying for funding helped predominantly the larger cities, or those with established political backing, necessary resources and knowledge of what ‘buzz words’ to include. It was suggested that the more ‘experienced’ local authorities are successful in obtaining funds, whereas the majority of local authorities remain disconnected from the ‘networks’.

It is important to recognise that local authorities who have been actively involved in networks for a number of years should not now have a high demand for awareness raising, whereas local authorities, for example in southern and eastern Member States, which are still not as aware of the urban environmental policies or engaged in the EU processes should be the prime targets47.

This suggests urban programmes including LIFE+ should therefore, seek to engage local authorities that are not yet politically committed to urban sustainable development and which do not currently access EU funds.

In order to assist urban projects in delivering the Thematic Strategy on the Urban Environment, it was suggested that LIFE+ should include a pro-active dissemination strategy, possibly including a network and provisions for translation the project’s outputs.

46 Former officer in charge of SUD, DG ENV


52

53

G ANNEX G: REVIEW OF NATIONAL ALLOCATIONS

G.1 Approach to Defining National Allocations

The proportionate distribution of projects is to be calculated on the following criteria:

(a) Population:

(i) The total population of each Member State (a weighting of 50 % shall be applied to this criterion) and

(ii) The population density of each Member State, up to a limit of twice the EU’s average population density (a weighting of 5 % shall be applied to this criterion) ;

(b) Nature and biodiversity:

(i) The total area of sites of Community importance for each Member State, expressed as a proportion of the total area of sites of Community importance (a weighting of 25 % shall be applied to this criterion) and

(ii) the proportion of a Member State’s territory covered by sites of Community importance in relation to the proportion of Community territory covered by sites of Community importance (a weighting of 20 % shall be applied to this criterion).

The selection of proposals takes into account indicative national allocations, whereby priorities are given to proposals that fit within the LIFE+ budget as well as the indicative national allocation (see Figure G.1 and Box G.1).

54

Figure G-1: Schematic diagram of the proposal selection process following the revision phase48

Box G.1: The preliminary long list of proposals to be retained for LIFE+ funding will be set up according to the following procedure:

STEP 1: the highest-scored NAT/BDV proposals that fit into any of the 27 national allocations will be retained for funding until the 50% threshold for "Nature and Biodiversity proposals" is achieved;

STEP 2: if the proposals retained in step 1 are insufficient to cover the 50% budget threshold for nature and biodiversity, additional NAT/BDV proposals will be retained for funding outside of the limits of the national allocations, either until (1) the 50% threshold is achieved or, alternatively, until (2) there is no further NAT/BDV project left for funding (again, priority will be given to the highest-scored proposals).

STEP 3: starting with the highest-scored proposal, the remaining proposals are allocated to the remaining budgets within the national allocations, either until (1) there is no funding left for retaining a further proposal in any of the national allocations, or until (2) there are no further projects left for funding after the award phase.

STEP 4: if the projects retained in step 1-3 are insufficient to cover 100% of the LIFE funding available for project co-financing and if there are still project proposals left for funding, the highest-scored remaining proposals will be retained for funding, until there is no further funding available for additional proposal.

48 GHK analysis based on the Guide for the evaluation of LIFE+ project proposals 2009 (LIFE UNIT)

55

STEP 5: two reserve lists will be set up, one for NAT/BDV and one for ENV/INF proposals. In case there are still enough proposals available, these lists will each cover proposal for an amount equivalent to up to 20% of the total available LIFE+ funding.

Source: Guide for the evaluation of LIFE+ project proposals 2007

The Commission may also make additional allocations to land-locked Member States. The total amount of such allocations shall not exceed 3 % of the total budgetary resources dedicated to action grants for projects. However, the Commission shall ensure that no Member State’s allocation is less than an appropriate minimum allocation of between EUR 1 and 3 million per year, taking into account population density, environmental expenditure, environmental need and absorption capacity. The indicative national allocations assigned by the EC for the 2009 call was as follows (Table G.1):

Table G-1: The indicative national financial allocations (€m) assigned by the EC in 200849

Member State Indicative national financial

allocations for 2008

Member State Indicative national financial

allocations for 2008

Germany 24.2 Denmark 5.1

Spain 22.2 Slovenia 4.5

Italy 18.3 Bulgaria 4.5

France 18.2 Belgium 4.3

United Kingdom 16.5 Czech Republic 4.1

Poland 9.8 Austria 3.9

Romania 9.0 Estonia 3.4

Sweden 8.5 Ireland 3.3

Finland 7.4 Slovakia 3.2

Greece 7.1 Lithuania 2.9

The Netherlands 6.7 Latvia 2.9

Portugal 5.8 Malta 2.4

Hungary 5.2 Luxembourg 2.3

Cyprus 2.2

Of the €207m budget that LIFE+ dedicated to Action grants in 2008, almost a third (€64.6m) was expected to be allocated to three Member States: Germany, Spain and Italy.

When comparing the indicative national allocations and the actual amounts awarded to Member States, it was found that on the whole, the majority of Member States were awarded amounts similar to the indicative national allocations (see Figure G.2). Italy, Spain and Germany were found to have the highest amounts of funding in excess of the indicative national allocations. In fact, the amount awarded to Italy (€36 million) was twice the indicative national allocation (€18 million).

For Member States that received less funding than the indicative national allocations, the differences between the actual amounts and the indicative allocations were smaller, with the biggest deficit in the UK of approximately €5 million. Ireland, Lithuania, Latvia and Malta did not receive any funding.

49 GHK analysis based on information provided by the LIFE Unit

56

Figure G-2: Comparison of the indicative and actual financial allocations for LIFE+ Action Grants, 2008

0

5

10

15

20

25

30

35

40

DE ES IT FR UK PL RO SE FI GR NL PT HU DK SI BG BE CZ AT EE IE SK LT LV MT LU CY

€Millions

Ind icative national allocations

Budget allocations

Source: GHK analysis based on information provided by the LIFE Unit

G.2 Assessment of the Contribution of the National Allocations to the Performance of the LIFE+ Programme

G.2.1 Reflection of Needs

Respondents from the LIFE Units felt that the weighting applied to the criteria for defining national allocations was generally correct (ranging from 62-71% of respondents, Figure G.3).

Figure G-3: Do you think the weighting attached to each of the criteria is correct and adequately reflects needs?

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Total population of each MS (50%)

Population density of each MS (5%)

Total area of SCI for each MS as a proportion of the total area of SCI (25%)

Proportion of MS territory covered by SCI in relation to the proportion of Community territory covered by SCI (20%)

Yes

No

Source GHK LIFE Unit E-survey (7/8 responses)

57

Over 75% of NCPs interviewed felt the criteria and weighting were set correctly to adequately reflects needs. Those NCPs that did not agree with the weighting comments appeared mainly to be the smaller countries50 with small allocations and fewer projects. One NCP suggested that countries with a small area of SCI are at a disadvantage and another stated that for their country, the national allocation is low and unfairly distributed compared to others as a large proportion of its territory is designated as Natura 2000.

G.2.2 Improved Geographical Spread and Impacts on the Quality of Project Applications

NCPs were also asked for their view on whether the newly introduced national indicative allocations would impact the quality of the project proposal applications and geographical spread of applications received. The results are shown below in Figure G.4.

Figure G-4: How do you think that the newly introduced national indicative allocations have impacted the quality of the project proposal applications and geographical spread of applications received?

improved geographical spread but same quality as before

improved geographical spread but decrease in quality of applications received

no change in geographical spread of applications but an overall increase in quality of applications

no change in geographical spread of applications but an overall decrease in quality of applications

no change in either

Source: NCPs (17 respondents)

41% of respondents suggested it provided for an improved geographical spread but had not changed the quality of projects compared with before, and 18% cited an improved geographical spread but a decrease in the quality of applications received. Some countries emphasised that the introduction had not affected them as so few proposals had been received.

Respondents to the ASTRALE e-survey felt that the newly introduced national indicative allocations had affected neither the quality of project applications nor the geographical spread of applications received (54%). Just fewer than 20% felt that the geographical spread had been improved with the same quality of applications received and 15% felt that whilst the geographical spread had improved, the quality of applications had decreased. 10% felt that national indicative allocations had not changed the geographical spread of applications but had led to a decrease in application quality (Figure G.3).

50 One NCP suggests Special Protection Areas should be taken into consideration as a criterion and is as important as SCI, because it reflects the needs of financing nature conservation. The total population criterion weighting of 50% is seen as disproportionately high.

58

Figure G-5: How do you think that the newly introduced national indicative allocations have affected the quality of the project applications and geographical spread of applications received?

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

improved geographical spread but decrease in quality of applications received

improved geographical spread but same quality as before

no change in either

no change in geographical spread of applications but an overall decrease in quality of applications

no change in geographical spread of applications but an overall increase in quality of applications

Source: GHK Astrale monitors e-survey (43 responses)

59

H ANNEX H: REVIEW OF NATIONAL PRIORITIES

H.1 Review of the Application of the National Priorities

Table H.1 illustrates (in the example of the Forests theme) how Member States vary in describing their national objectives to achieve a common priority set out in Annex II of the LIFE+ Regulation.

Member States that submit national priorities also tend to be more active in sending comments on applications to the Commission in support of applications, emphasising the importance of proposed actions to the Member States and how major problems could be solved by having these actions in place (see Box H.1).

60

Table H-1: National annual priorities submitted by Estonia, Romania and the Netherlands for the priority of action regarding Forests following the LIFE+ call in 200951

Forests: Providing, especially through an EU coordination network, a concise and comprehensive basis for policy relevant information on forest in relation to climate change (impact on forest ecosystems, mitigation, substitution effects), biodiversity (baseline information and protected forest areas), forest fires, forest condition and the protective functions of forests (water, soil and infrastructure) as well as contributing to protect forests against fires.

Principal objectives and priorities

as set out in Annex II of the LIFE+ Regulation

Estonia Romania The Netherlands

Area chosen as national

annual priority:(Tick if

appropriate)

Types of projects as set

out in Article 3(2) of

the LIFE+

Regulation

Specific national objective (Please include reference to

more information)

Area chosen as national annual priority: (Tick if

appropriate)

Types of projects as

set out in Article

3(2) of theLIFE+

Regulation

Specific national objective (Please include reference to more information)

Area chosen as national annual priority: (Tick if

appropriate)

Types of projects

as set out in Article

3(2) of the LIFE+

Regulation

Specific national objective (Please include

reference to more

information)

Priority areas

of action

a) promoting the collection, analysis and dissemination of policy-relevant information concerning forests and interactions between forests and the environment;

x

As specified in LIFE+

Regulation

National Strategy for Sustainable Development http://www.mmediu.ro.dezvoltare_durabila/sndd.htm

x


Regulation

-

b) promoting the harmonisation and effectiveness of forest monitoring activities and data collection systems and making use of synergies by creating links between monitoring mechanisms established at regional, national, European and global level;

x


Regulation


x


Regulation

-

51 Information provided by the LIFE Unit

61

c) stimulating synergies between specific forests related issues and environmental initiatives and legislation (e.g. EU soil strategy, Natura 2000, Water Framework Directive, etc.);

X

Projects for thedevelopment

and implementation

of Community objectives

relating to the broadbased, harmonised,

comprehensive and longterm monitoring of

forests and

environmental interactions

1. Estonian Environmental strategy until 203044 (Priority 5.1.4 Forest, objective: Balanced

satisfaction of ecological, social, cultural and

economic needs in the course of utilisation of forests in a very long

perspective (longer than the period of 25 years

discussed in the Strategy).2. Environmental Action Plan 2007-201345 (1.4

Forest) 3. Development Strategy of the Ministry of Environment

2010-201346 (Area of activity: protection and

sustainable usage of nature including forestry and fisheries; measure:

ensuring sustainable forest management)

4. Forest Act47(regulates the forest management and its development in Estonia).

x


Regulation


x


Regulation

-

d) contributing to sustainable forest management in particular by collecting data related to the improved Pan-European Indicators for Sustainable Forest Management as adopted by the MCPFE Expert Level Meeting 7-8 October 2002, Vienna, Austria; and

x


Regulation


x


Regulation

-

e) building capacities at national and Community level to allow for coordination and guidance on forest monitoring.

x


Regulation


x


Regulation

-

62

63

I ANNEX I: REVIEW OF THE APPLICATION PROCESS

I.1 LIFE+ Application procedures

An e-survey of the external evaluators52, AGRECO, found that 56% of AGRECO respondents suggested that a low number of project applications have been successful in gaining funding under the new components and themes of LIFE+ because ‘potential applications are still unsure about the differences between the new areas and what types of projects would be funded under them, which is affecting the quality of applications’. 41% felt that ‘EC guidance on demarcation between the different areas is still insufficient and needs to be improved’. Other reasons put forward to explain the low number of project applications successful in gaining funding under the new components and themes of LIFE+ include a ‘lack of good and challenging ideas’ and a ‘low quality of technical coherence’.

Of the 170 project co-ordinators who responded to the GHK e-survey, 42% had experience of managing a previous LIFE project. Table I-1 shows how project co-ordinators were made aware of the LIFE+ funding instrument and suggests that information from previous LIFE beneficiaries is the most effective tool in creating awareness and encouraging potential beneficiaries to apply. 15% chose the option ‘Other’ and their responses indicated that a variety of other sources were involved including colleagues of project co-ordinators, information received via e-mail and external consultants.

Table I-1: How were you made aware of the LIFE+ funding instrument?

Medium %

National contact points 28%

LIFE+ website 29% LIFE+ workshops and visits to the Member State made by LIFE Unit 8%

Previous project partners from other projects 35%

Total 100.00%

Source: GHK Project coordinators e-survey (154 respondents)

When asked how clear guidance had been from the EC on eligibility and application for funding, 94% of project co-ordinators respondents said that it had been either ‘very clear’ or ‘quite clear’. Only 5% stated that guidance had not been useful. 28% of the respondents with experience from LIFE III suggested that guidelines were now much better and clearer with 47% stating ‘a little better’ and 25% citing no change in clarity.

When asked what the rationale was for the project proposal, Figure I-1 shows a fairly even spread of responses with the most common response being that it was based on national priorities (18%). Project co-ordinators were asked whether or not it was clear where within the LIFE+ Programme the project best fitted. Here, 84% of respondents suggested that it was ‘very clear’ with 16% stating it was ‘fairly clear’. When asked whether LIFE+ provides opportunities for interesting projects to be started, 60% stated ‘Yes – more so than other instruments’ whilst 30% thought it was as good as other instruments.

52 GHK e-survey of AGRECO evaluators

64

Figure I-1: What was the rationale for the project proposal?53

0% 20% 40% 60% 80% 100%

It is a follow‐up / based on previous projects you have done

It is based on new research

A chance to collaborate with others

A chance to collaborate with international partners in particular

It is based on national priorities

A response to a new policy

It is based on demands from end users

It is a response to a particular challenge

Source: GHK Project Coordinators E-Survey (169 respondents)

Project co-ordinators were asked what action they would have taken in the absence of the LIFE+ Programme. Figure I-2 displays all responses and shows that 37% would have delayed the project until sufficient funds were available and 30% would have abandoned the project idea. 27% of respondents said they would have applied to an alternative EU or national funding programme, examples including FP7, INTERREG, CIP, IEE and MED Programme. Examples of national funding alternatives included ministry funding, national innovation funding programmes and R&D funding programmes.

Figure I-2: In the absence of the LIFE+ Programme, indicate which of the following course of action would have been followed54

53 Respondents were given the option of selecting more than one answer

54 More than one option was chosen by several respondents

65

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

We would have applied and expected to receive similar levels of funding from another EU Programme

We would have applied and expected to receive similar levels of funding from another MS Programme

We would have scaled back the project and funded it from our own/partner funds

We would have delayed the project until we had sufficient funds available from our own/partner resources to proceed on our own

We would have abandoned the project idea


66

J ANNEX J: REVIEW OF THE APPRAISAL AND SELECTION PROCESS

67

Figure J-1: Comparison between LIFE III and LIFE+ selection guidelines

LIFE III LIFE +

EVALUATION OF ELIGIBILITY

CHECK IF FORMS WERE COMPLETED

EVALUATION OF ADMISSIBILITY, EXCLUSION AND ELIGIBILITY

CHECK IF FORMS WERE COMPLETED

CHECK IF PROJECTS FALL WITHIN THE SCOPE OF LIFE+

SELECTION PHASE

1. TECHNICAL AND FINANCIAL SOUNDNESS

TECHNICAL RELIABILITY OF APPLICANTS

FINANCIAL RELIABILITY OF APPLICANTS

2.

ENV

Compliance with the current LIFE regulation

Check if proposals are related to any of the topics set out in the Regulation

SELECTION PHASE

1. TECHNICAL SELECTION COHERENCE

TECHNICAL RELIABILITY OF APPLICANTS

SCOPE OF PROPOSALS

SPECIFIC QUESTIONS

NAT/BIO ENV INF

At least 25% of the proposed budget allocated to concrete conservation actions Actions are innovative or demonstration, or relate to forest monitoring Actions are awareness raising campaigns on environmental nature protection, biodiversity conservation issues or the prevention of forest fires and/or training activities for forest-fire agents

NAT BIO

Actions aimed at implementing the objectives of the EU Birds and Habitats Directives and contain conservation measures for species & habitat types covered in the relevant annexes of the Directive

Actions are demonstration or best practice Actions relate to the objectives of the “Halting the loss of biodiversity by 2010-and beyond” paper

Actions are innovative or demonstration

2. FINANCIAL SELECTION COHERENCE

CHECK IF APPLICANTS HAVE STABLE AND SUFFICIENT SOURCES OF FUNDING TO MAINTAIN ACTIVITIES THROUGHOUT THE PERIOD DURING WHICH THE ACTION IS CARRIED OUT

68

AWARD PHASE

NAT ENV

1. Technical coherence an quality of the proposal

Check if proposed actions are clear, coherent and contribute to the achievement of project objectives

2. Financial coherence and quality of the proposal

Evaluate the compliance of the proposal with the financial rules as defined by the Common Provisions

3. Conservation benefit

Project actions should make a significant contribution to the conservation of important habitats and species, in particular habitats and species in the Natura 2000 network.

Highest priority: targeting significant expanses of priority habitats or significant populations of priority species.

2nd order priority: projects of strategic importance for non-priority habitat/species

3rd order of priority: projects on sites of EU0importance for the habitats/species targeted

Projects may be given hider score depending on the relative importance of the actions proposed or if they fit into EU-wide conservation strategies or if the proposed actions are expected to have long lasting, sustainable positive impact.

4. Socio-economic and operational context

Any social, economic, political or cultural aspect of the proposal that is likely to improve the chance of a successful project implementation may lead to a high score.

Projects integrating the experience of similar past and current projects may be considered for a higher score

Priority may be given to projects based on a multinational approach, when this is likely to have more effective results.

AWARD PHASE

1. TECHNICAL COHERENCE AND QUALITY

CHECK IF PROPOSED ACTIONS ARE CLEAR, COHERENT AND CONTRIBUTE TO THE ACHIEVEMENT OF PROJECT OBJECTIVES

PASS SCORE: 8/15

2. FINANCIAL COHERENCE AND QUALITY

CHECK IF PROPOSED BUDGET IS CONSISTENT WITH PROPOSED ACTIONS

CHECK IF BUDGET IS TRANSPARENT, COST-EFFICIENT AND OFFERS BEST VALUE FOR MONEY

PASS SCORE: 8/15

3. CONTRIBUTION TO THE GENERAL OBJECTIVES OF LIFE+

HIGHER SCORING IS GIVEN TO PROPOSALS IF:

PROBLEMS TARGETED ARE RELATIVELY IMPORTANT AT THE EU LEVEL

PROPOSALS CONTRIBUTE TO THE UPDATING OR DEVELOPMENT OF COMMUNITY ENVIRONMENTAL LEGISLATION OR POLICIES

LIFE+ NAT/BIO PROPOSALS INVOLVE BUSINESS-SECTOR CO-FINANCING

PASS SCORE: 12/25

4. EUROPEAN ADDED VALUE AND COMPLEMENTARITY AND OPTIMAL USE OF THE EU FUNDING

UNDER LIFE+ NATURE, BEST PRACTICE/DEMONSTRATION ACTIONS MUST BE PROPOSED

UNDER LIFE+ BIODIVERSITY, EPG AND INF, DEMONSTRATION AND INNOVATIVE ACTIONS MUST BE PROPOSED, EXCEPT FOR:

O PROJECTS FOR AWARENESS-RAISING CAMPAIGNS (INF)

O PROJECTS FOR THE TRAINING OF THE TRAINING OF FOREST FIRE AGENTS (INF)

69

Pass score for each criterion: 5/10

Final score:

= (Technical coherence)*1+ (Financial coherence)*0.3 + (Conservation benefit)*2+ (Socio-economic and operational context)*1 First phase:

1. Innovative nature and progress. Technical feasibility

Ideally LIFE projects should have conducted a certain amount of previous research work before embarking into the proposed project.

Indicate how progress will be measured

Identify the risks of the project failing due to technical uncertainties, differences of scale.

2. Transferability of results. Demonstration character of the project and dissemination

Understand the potential for the “know-how”, practices, technology or products developed by the projects to be transferred.

Demonstrate that the necessary steps have been taken to ensure that the foundations of the underlying hypotheses have been appropriately secured

Outline a dissemination strategy detailing target groups, methods, detailed actions and ways to assess the impact of the strategy


Bonus criteria

Multinational approach

Maximum of 4 points given to proposals, depending on the level of involvement of partners from all the relevant countries

Job creation and SME

Maximum of 2 points

Second phase:

3. Coherence and quality, integration

O PROJECTS FOR THE LONG-TERM MONITORING OF FORESTS (EPG)

SHOULD FORESEE THE DEVELOPMENT AND DISSEMINATION OF LESSONS LEARNT

MONITORING, ASSESSMENT, EVALUATION, COMMUNICATION, NETWORKING AND DISSEMINATION ACTIVITIES MUST BE FORESEEN

THE INVOLVEMENT OR CONSULTATION OF STAKEHOLDERS IN THE PROJECT IMPLEMENTATION PROCESS WILL BE POSITIVELY CONSIDERED

A PROPOSAL MAY BE CONSIDERED NEGATIVELY REGARDING COMPLEMENTARITY AND OPTIMAL USE OF THE EU FUNDING IF:

O LIFE+ IS NOT THE MOST SUITABLE PROGRAMME FOR FINANCING THE PROPOSED ACTIONS

O PROPOSALS INCLUDE RECURRING ACTIVITIES

O THE PROPOSALS INCLUDE COMPENSATION MEASURES WHICH ARE OBLIGATORY ACCORDING TO NATIONAL LEGISLATION AND/OR THE FINANCIAL CONTRIBUTIONS TO THE PROPOSAL BUDGET INCLUDE A SUBSTANTIAL SHARE OF FUNDS EARMARKED FOR COMPENSATION MEASURES.

O A SUBSTANTIAL SHARE OF THE PROJECT BUDGET IS EARMARKED FOR ACTIONS THAT ARE FINANCIALLY SECURE WITHOUT LIFE+ FUNDING

PASS SCORE: 15/30

5. TRANSNATIONAL CHARACTER

TRANSNATIONAL PROPOSALS SHALL BE FAVOURED WHEN THE TRANSNATIONAL CO-OPERATION IS ESSENTIAL TO GUARANTEE THE ACHIEVEMENT OF THE PROJECT OBJECTIVES

MAX SCORE: 5; NO PASS SCORE.

6. COMPLIANCE WITH NATIONAL ANNUAL PRIORITIES AND NATIONAL ADDED VALUE ACCORDING TO THE LIFE+ NATIONAL AUTHORITY

NATIONAL ANNUAL PRIORITIES

O PROPOSALS WITH ACTIONS IN 1 MS MAY RECEIVE BETWEEN 0 AND 5 POINTS REGARDING COMPLIANCE WITH THE NATIONAL ANNUAL PRIORITIES DEPENDING ON WHETHER IT FALLS INTO ANY OF THE

70

Coherence between problems addressed, objectives sought and actions implemented

Realistic timing

Assess whether the organisational arrangements proposed are clearly described and appropriate for the type of project proposed

Sustainability: integration of the social and economic dimensions

Value for money

4. Financial coherence and quality

Check if proposed budget is consistent with proposed actions

5. Community interest and environmental problem

Contribution to the general objective of the Community Environmental policy must be clearly defined

Provide solutions to a problem which arises very often in the Community, or is of great concern to some MSs.


PRIORITY AREAS PUBLISHED FOR THE MS IN THE YEAR CONCERNED

NATIONAL ADDED VALUE

O PROPOSALS MAY BE GIVEN A HIGHER SCORE (OUT OF A MAXIMUM OF 5 POINTS) IF THE MS COMMENTS PROVIDE ADDITIONAL POSITIVE ELEMENTS THAT HAVE NOT BEEN CONSIDERED SO FAR IN THE ANY OF THE OTHER AWARD CRITERIA

ANY PROPOSAL THAT RECEIVES A FINAL SCORE BELOW THE PASS SCORE FOR ANY OF THE AWARD CRITERIA 1 TO 4 WILL BE DECLARED REJECTED

REVISION PHASE

AIM TO CLARIFY, PRIOR TO THE SIGNATURE OF THE INDIVIDUAL GRANT AGREEMENTS, ALL OPEN QUESTIONS REGARDING FEASIBILITY, COST-EFFECTIVENESS AND ELIGIBILITY OF INDIVIDUAL ACTIONS, COMPLIANCE WITH THE LIFE REGULATION AND COMMON PROVISIONS.

APPLICATIONS CAN BE ASKED TO PROVIDE FURTHER DETAILS/INTRODUCE MODIFICATIONS/IMPROVEMENTS TO THE ORIGINAL PROPOSALS.

71

Figure J-2: Process of Action Grant Selection and Award

Receipt of proposals:

Applicants send proposals to their national contact point who will review and ensure that it is eligible. The proposal is then sent to the LIFE unit who will upload the information into ESAP.

Technical & Financial Selection:

Proposals that pass the Admissibility Phase are sent to AGRECO for technical selection. AGRECO will designate a "lead evaluator" to evaluates the compliance of the proposal with the technical selection criteria and enter evaluation comments into ESAP.

For LIFE+ Nature projects, the technical selection phase will also include an assessment of the compliance of the Natura 2000 information (site boundaries and species/habitat types).

A financial evaluator from AGRECO will check that the proposal meets financial selection criteria. The selection evaluation is considered "final" once it has been approved by the Commission.

Panel meeting sessions

There is a panel meeting for each intervention where AGRECO evaluators and TDOs meet to discuss the scores given to proposals. Discussions focus on proposals originating from countries who submitted only few proposals as well as borderline cases. Changes may be made to scores and the final list of projects then pass onto the revision phases.

Award Phase

Two AGRECO evaluators independently score the proposals on the basis of the award criteria and detailed questions. A third evaluators checks these evaluations and if divergences are noted completes a third evaluation.

Purpose: The award phase comments in ESAP have a triple role:

1. to provide a justification as regards the score proposed.

2. to allow AGRECO to verify the quality of the assessment undertaken by the evaluator

3. in case of a negative score, the full comment under "against" will be included into the letter that the Commission will send to the beneficiary to justify the rejection of the project.

Proposals are then distributed to TDOs on the basis of technical skills who review the AGRECO evaluations and identify borderline cases for discussions in the panel meeting sessions.

6 weeks

Admissibility check:

Proposals are divided amongst the TDOs (Technical Desk Officers) for admissibility check (whether correct forms are included in the requested format etc). If documentation is missing applicants are informed and have 5 days to provide this information.

1-2 weeks

4 weeks

ENV & INF 6 weeks

NAT 8 weeks

2 days

72

The figure below illustrates the full evaluation and selection procedure respect to the 2008 call for proposals in LIFE+:

Figure J-3: The selection process for proposals received following the 2008 call55

Common problems:

• Incomplete application form • Missing mandatory annexes• Supporting documents not provided

Common problems:

564 remaining proposals

• Project fails to propose innovative actions or demonstration measures related to any of the priority areas

• Lack of financial capacity, co-financing not assured, risk of bankruptcy, lack of proof of public body status


Common problem:

Below the threshold for at least 1 of the Award Criteria 1-4


Common problems:

• A reduction in co-financing rate as suggested by the EC would compromise the quality of the project• Lack of satisfactory answers from applicants

ApprovalTotal: 196 proposals

Receipt of proposals(Total: 613 proposals)

Eligibility check

Technical and financial selection

Award phase

Rejected 49 applications




49 days

70 days

Revision

24 days

31 days

Figure J-3 illustrates the importance attributed by LIFE Unit respondents to each award criteria. The most important criteria is ‘technical coherence and quality’, rated ‘1’ by 38% of respondents, ‘transnational character’ was awarded the least number of ‘1’s (13%) and most number of ‘5’s (38%) suggesting its relative unimportance.

Primarily, LIFE Unit respondents were positive about the guidance provided to them in scoring each of the criteria during the awarding phase. 43% of respondents stated that the guidance was ‘very helpful- I understand exactly how to score each criteria’ whilst another 43% stated that it was ‘adequate - provides me with some guidance but still quite vague’. 10% felt it was ‘not helpful - needs a lot of improvement and more direction on how to score’.

55 GHK analysis was based on data provided by the LIFE Unit- DG ENV

73

Figure J-4: How important do you think each of the award criteria are? (where 1=most important)

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%100%

Technical coherence and quality

Financial coherence and quality

Contribution to the general objectives of LIFE+

European added value and complementarity and optimal use of the EU funding

Transnational character

Compliance with national annual priorities and national added value according to the LIFE+ national

authority

1 (most important)

2

3

4

5 (least important)

Source GHK LIFE Unit E-survey (7/8 responses)

Project co-ordinators were asked their opinion on the length of time taken by the Commission in deciding whether a project should receive funding. 45% stated it takes too long, whilst 54% suggested it was ‘just right’. In addition, just over 90% of project beneficiaries stated that the funding decision was followed quickly by access to funds.

In terms of assistance provided by NCPs to project applicants, 88% responded that they provided ‘just the right amount of assistance’ of written comments. Most of the NCPs that have not set national priorities (18 in total) stated this was because they generally had few applications and “did not want to limit applications or limit the chance of projects receiving funding”. In addition, several NCPs stated that they do not provide comments as they “no longer believe they are helpful or taken into account”. However there remain some NCPs who do take a more proactive role in terms of providing comments and assistance, including one in particular, which has contracted out the NCP role for LIFE issues. As a result, a more dedicated service is available to potential applicants, including the provision of advice (e.g. through a Helpline), and an early screening service to check proposals for eligibility and content (but not on the specific technical issues of a proposal).

Proposed Changes to the Appraisal and Selection Process

We summarise below proposed changes to the appraisal and selection process.

Figure J-5: Proposed changes to the evaluation and selection procedure56

Phase 1: Eligibility

Admissibility/Eligibility – responsibility to be transferred to NCPs

NCPs to check for compliance with all admissibility and exclusion criteria (i.e. submitted by deadline in the correct format with all relevant applications forms

56 Red borders to each box indicate a change to that particular phase of selection

74

present and checking that the beneficiaries are all legally registered in the EU etc)

The proposals will also be checked for compliance with eligibility criterion – ensuring projects fall within the scope of LIFE+

Technical and Financial Selection (AGRECO and TDOs)

Technical selection

1. Technical reliability of applicants (check if applicants are unreliable managers)

Financial selection

1. Check if applicants have stable and sufficient sources of funding to maintain activities throughout the period during which the action is carried out

Additional criteria: Include an initial assessment of EU added value

1. Are Nature (NAT) projects contributing to the Birds and Habitats Directive?

2. Are NAT projects demonstrative/best practice?

3. Are BIO projects contributing to the objectives of the “Halting the loss of biodiversity by 2010-and beyond” paper

4. Is at least 25% of the proposed project budget (for NAT/BIO proposals) allocated to concrete conservation actions?

5. Are EPG/INF/BIO projects innovative/demonstrative?

Phase 2: Selection Phase (AGRECO + TDOs) – Projects with a de minimis level of EU Added Value

Technical coherence

- Check if proposed actions are clear, coherent and contribute to the achievement of project objectives

Financial coherence

Check if proposed budget is consistent with proposed actions

Check if budget is transparent, cost-efficient and offers best value for money

Phase 3: Award Phase: Enhanced EU Added Value / Bonus Points (AGRECO + TDOs)

75

NAT/BIO EPG INF

Action required: LIFE Unit to define EU added value in specific relation to NAT & BIO stating order of priorities

A series of questions to determine if projects address priorities as defined by the LIFE Unit (and/or policy units)

- A series of specific Nat&Bio questions to assess the extent to which projects fulfil the objectives of LIFE+

- Assessment of how far projects plan to disseminate / communicate results?

- Is it transnational in character?

- Does it comply with national priorities?

- Does it contribute to national added value?

- Complementarity issue

Action required: LIFE Unit to define EU added value in specific relation to EPG stating order of priorities


- A series of specific EPG questions to assess the extent to which projects fulfil the objectives of LIFE+






Action required: LIFE Unit to define EU added value in specific relation to INF stating order of priorities


- A series of specific INF questions to assess the extent to which projects fulfil the objectives of LIFE+






Assumptions:

Awarding of scores in Phase 3 is based on following assumptions:

National priorities ought to be stated by all Member States

All projects which pass Phase 2 are feasible projects and could be funded but those which accumulate the highest score (by getting the bonus points in Phase 3) should be ‘top of the selected projects’. The number of projects which pass Phase 2 but do not get many additional points that end up being funded will be a function of the number of total applications received in that Call.

76

K ANNEX K: REVIEW OF ENRTP APPLICATION PROCESS

K.1 Application process:

Since 2007, ENRTP has launched 2 calls for proposals, the first call has completed and the second call is on-going. Different from LIFE+, ENRTP employs a two-stage approach whereby:

‘In the first instance, only Concept Notes must be submitted for evaluation. Thereafter, applicants whose Concept Notes have been pre-selected will be invited to submit a Full Application Form. Further to the evaluation of the Full Applications, an eligibility check will be performed for those which are provisionally selected. This check will be undertaken on the basis of the supporting documents requested by the Contracting Authority, the signed "Declaration by the Applicant" sent together with the Concept Note and the second Declaration sent together with the Full Application.‘57

Following the first call for proposals, ENRTP attracted 987 concept notes, mainly from Europe, Africa, Asia and South America (see figure 1). Despite having a smaller budget compared to LIFE, ENRTP appeared to attract a larger number of applications, suggesting that the two-stage approach encourages applicants to apply for funding. A summary of the top countries with the highest number of concept notes was presented in Table 1.

Figure K-1: Origin of concept notes received following the 1st ENRTP call58

European Union42,3%

Other Europe0,9%

Africa21,3%North America

2,3%

Central America & Caribbean

5,8%

South America13,3%

Asia12,3%

Pacif ic1,8%

Table K-1: List of countries with the highest number of concept notes

Country Number of concept notes

Italy 89United Kingdom 76

57 Guideline for grant applicants

58 GHK analysis was performed based on data provided by DG AIDCO

77

France 50Netherlands 50Germany 40Colombia 38Spain 29Brazil 28Peru 25Mexico 23USA 22Kenya 21

Table K-2: Success rates of concept notes and full applications following the first ENRTP call59

Number of

concept notes Number of full applications

Percentage of concept notes

passed the first selection stage

Number of projects selected

Percentage of full applications

selected for funding

European Union 417 132 32 31 23

Africa 210 20 10 2 10

South America 131 29 22 3 10

Asia 122 19 16 5 26

Central America & Caribbean 57 4 7 0 0

North America 23 3 13 0 0

Pacific 18 1 6 0 0

Other Europe 9 4 44 1 25

Total 987 212 21 42 20


78

Figure K-2: The selection of concept notes and full applications following the first ENRTP call60

0

50

100

150

200

250

300

350

400

450

Selected Full Applications Concept Notes

Following the receipt of concept notes, approximately 21% of concept notes were selected and applicants were invited to send full applications (see Table 3 and Figure 3). During the second stage of the process, full applicants were evaluated and approximately 20% of full applicants, totalling 48 projects, were selected for funding.

K.2 Application process

Since 2007, ENRTP has launched 2 calls for proposals, the first call has completed and the second call is on-going. Different from LIFE+, ENRTP employs a two-stage approach whereby:

‘In the first instance, only Concept Notes must be submitted for evaluation. Thereafter, applicants whose Concept Notes have been pre-selected will be invited to submit a Full Application Form. Further to the evaluation of the Full Applications, an eligibility check will be performed for those which are provisionally selected. This check will be undertaken on the basis of the supporting documents requested by the Contracting Authority, the signed "Declaration by the Applicant" sent together with the Concept Note and the second Declaration sent together with the Full Application.‘61

Following the first call for proposals, ENRTP attracted 987 concept notes, mainly from Europe, Africa, Asia and South America (see figure 1). Despite having a smaller budget compared to LIFE, ENRTP appeared to attract a larger number of applications, suggesting that the two-stage approach encourages applicants to apply for funding. A summary of the top countries with the highest number of concept notes was presented in Table 1.

60 GHK analysis was performed based on data provided by DG AIDCO 61 Guideline for grant applicants

79

Figure K-3: Origin of concept notes received following the 1st ENRTP call62

European Union42,3%

Other Europe0,9%

Africa21,3%North America

2,3%

Central America & Caribbean

5,8%

South America13,3%

Asia12,3%

Pacif ic1,8%

Table K-3: List of countries with the highest number of concept notes

Country Number of concept notes

Italy 89United Kingdom 76France 50Netherlands 50Germany 40Colombia 38Spain 29Brazil 28Peru 25Mexico 23USA 22Kenya 21

Table K-4: Success rates of concept notes and full applications following the first ENRTP call63

Number of

concept notes Number of full applications

Percentage of concept notes

passed the first selection stage

Number of projects selected

Percentage of full applications

selected for funding

European 417 132 32 31 23

62 GHK analysis was performed based on data provided by DG AIDCO 63 GHK analysis was performed based on data provided by DG AIDCO

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Union

Africa 210 20 10 2 10

South America 131 29 22 3 10

Asia 122 19 16 5 26

Central America & Caribbean 57 4 7 0 0

North America 23 3 13 0 0

Pacific 18 1 6 0 0

Other Europe 9 4 44 1 25

Total 987 212 21 42 20

Figure K-4: The selection of concept notes and full applications following the first ENRTP call64

0

50

100

150

200

250

300

350

400

450

Selected Full Applications Concept Notes

Following the receipt of concept notes, approximately 21% of concept notes were selected and applicants were invited to send full applications (see Table K-4). During the second stage of the process, full applicants were evaluated and approximately 20% of full applicants, totalling 48 projects, were selected for funding.


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L ANNEX L: REVIEW OF PROJECT MONITORING

L.1 The Performance of the Project Monitoring Procedures

It was stated that disagreements on project progress between LIFE Unit and ASTRALE happen on occasion. Often perspectives differ largely because Astrale may have visited a project, but LIFE Unit may not have. However, ASTRALE points out that even though the assessment may differ, the decision on how to deal with the problem rests with the TDO.

83% of LIFE Unit respondents felt that the most important gain from projects being thematically assigned would be the ‘better communication about projects between thematic units and stakeholders because of greater familiarity with the topic’.

Figure L-1 illustrates that almost 50% of ASTRALE respondents felt that if projects were assigned to TDOs thematically, the most significant issue would be the dilution of working collaborations due to working with higher number of Astrale monitors. Over 30% felt that language barriers may also be an issue, leading to a breakdown in the relationship between TDOs and NCPs.

Figure L-1: If projects were assigned to TDOS thematically (to thematic desks in LIFE) rather than by country, what do you think would be the most significant issue?

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

language barriers may cause a breakdown in the relationship between TDOs and national contact points

missions would take longer and cost more because projects would be dispersed geographically

this would result in having to work with a larger number of Astrale monitors, which would dilute working

collaborations

Source: GHK Astrale Monitors survey (48 responses)

ASTRALE respondents suggested that the most important gain from projects being thematically assigned would be a greater knowledge of technical context, allowing the more effective monitoring of projects (44% of responses); 20% felt that the most important gain would be an improved establishment of contacts between thematic desks and projects.

40% of ASTRALE monitors felt that the area most requiring more resources or having room for improvement related to ‘field visits’. 38% felt that there should be better ‘assistance for beneficiaries to understand the LIFE+ Regulation’, with a further 35% feeling that more assistance was needed in implementing good practices in reporting and project

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communications. Around one in five felt that contact with project beneficiaries could be improved; with a similar proportion stating that following up project deliverables and major project milestones could be improved. Primarily, more resources were required to support projects with report writing due to the variance in the quality of submissions, with a suggestion that this could also improve communication and dissemination of project activity. 86% of respondents felt that the benefits of additional resources would outweigh extra costs due to the improved report writing, better implementation of project activity and a reduced risk of project failure i.e. ‘less time spent on fire fighting’.

75% of respondents felt that it was ‘fairly straightforward’ to assess whether projects are on target to meet their objectives before projects are completed. An additional 15% felt that it was ‘very straightforward’ however 10% felt that it was ‘not so straightforward’.

Regarding the dissemination of results, half of ASTRALE respondents felt it would be ‘OK’ for projects to disseminate results. 20% felt that it would be ‘relatively easy’ with an additional 4% stating it would be ‘extremely easy’. 25% felt it would be ‘difficult’ for projects to share results, but no respondents stated that it would be ‘extremely difficult’. For those who stated it would be ‘difficult’, one respondent suggested that the LIFE dissemination requirements of projects are ‘very formal’, with further suggestion from respondents that the dissemination should be considered from the project proposal stage and actively take place from the start of the project to allow it to be integrated from the outset.

The majority of respondents (64%) felt it was ‘OK’ to assess the eligibility of the beneficiary and partners’ expenditure. 20% felt that it was ‘difficult’ to assess with one in ten stating that is was ‘easy’. No respondents felt that it was ‘extremely difficult’.

Figure L-2: How would you rate your performance in assessing whether project funds are being appropriately used and reported to the Commission?

very good

good

ok

Not effective


88% of ASTRALE respondents felt that they receive adequate information, advice and guidance from the LIFE Units during the monitoring process, although there was some suggestion that further information on financial monitoring and evaluation may be beneficial.

30% of respondents could not name anything onerous regarding the LIFE+ monitoring process. The assessment of financial documents was onerous for at least 10% respondents with others suggesting that different interpretations of LIFE/ EC regulations led to difficulties in some cases.

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Project co-ordinators were asked what their opinion was of the performance of the monitoring team (ASTRALE). Figure L-3 shows that the majority (66%) felt that they were ‘thorough, professional and helpful’, only 4% felt they could improve in their performance.

Figure L-3: What is your opinion of the performance of the external monitoring team (Astrale)

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

They are thorough, professional and helpful They provide a little assistance to beneficiaries but not much

They could improve in their performance They are unhelpful and significantly need to improve

None of the above

Source: GHK NCP Coordinators E-Survey (153 respondents)

Box L-1: Sustainability – what happens to the project after LIFE+ stops the funding?

Follow-up of projects by the Commission after their completion is seen as crucial to encouraging sustainability. This is particularly the case for Nature and Biodiversity projects due to the inherent nature of conservation measures, where results are very often only attained and visible after a certain lapse of time. For example, it takes time to restore plant species and habitats after performing extensive intervention measures such as, for example, the logging of trees and bushes in order to turn a monocultural coniferous forest back into the nutrient-poor moor lands it used to be65.

However, after the final payment the Commission’s services do not necessarily remain in contact with the beneficiaries or monitor the projects and, as a result, the Commission does not know the results and long-term impact of conservation measures funded by LIFE-Nature. In 2005, the Commission introduced an 'after-LIFE conservation plan' as a contractual obligation for all new LIFE-Nature projects in which the beneficiary has to outline further objectives and, above all, detail its plans for securing further sources of funding for sustaining the management of the project beyond LIFE funding. This does allow the sustainability of project results for Nature and Biodiversity projects to be checked, but for those projects under the Environment Policy and Governance component, it is considerably more difficult to monitor sustainability. Some projects with ‘strong ideas’ have been difficult to implement due to ‘recessionary constraints’ and smaller beneficiaries (e.g. NGOs, SMEs) find it more difficult to make long-term plans given their financial instability. An interview with the Astrale central team suggests that sustainability has to be considered

65 European Court of Auditors (2009), ‘The Sustainability and the Commission’s Management of the LIFE-Nature Projects’

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on a case-by-case basis and there is a “limit to how much sustainability the Commission can insist on given that funding ceases”66.

It must be mentioned that some projects are selected for ex-post monitoring visits several years after they have finished.

LIFE desk officers can usually visit between one and four projects within one mission, with 44% stating it was usually two or three. Missions last for between one and five days. If the TDO or external monitor was unable to speak the language of the project beneficiary, there was general belief amongst LIFE Unit respondents that this would lead to an increase in time (2-3 hours) and cost (approximately €250 per day).

Generally, LIFE Unit respondents felt that monitors were effective in assessing whether project funds are being appropriately used; 44% stated they were ‘very good’, 33% ‘good’ and 22% ‘ok’. 56% of respondents felt that it was ‘ok’ to assess the eligibility of the beneficiary and partners’ expenditure. A further 20% felt it was ‘easy’ with 11% stating it was ‘very easy’. Only one respondent (11%) felt that it was ‘difficult’.

TDOs suggested that organising a visit before the final report was an effective preparatory measure in dealing with any issues that would affect the final payment. However, visiting before certain deliverables cannot be guaranteed due to availability and resources. For Astrale, it would be difficult to plan the timing of missions to fall near certain deliverables e.g. inception, as this would require completing a huge amount of visits in a short space of time, and planning visits according to availability, logistics and geography. Previously, attempts were made to stagger the start of projects to ensure that visits could be spaced across time, but in reality this was not effective and 80-90% of projects still started at the same time.

The distribution of projects to monitors on the basis of technical experience or language has been widely debated within the Commission and the consensus is that projects should not be split on a thematic basis. Language is essential for building a working relationship and understanding of the projects. FDOs require language to be able to discuss financial issues and for the external monitoring team, it would not be feasible to organise by theme as monitors would be required to travel great distances over a short period of time. Participants to the Monitoring workshop in December 2009 suggested that technical knowledge would not improve the project management process, and that language and rapport would have a greater impact. Furthermore, only a small number of projects have been deemed to be technically difficult in the past, and in these cases information can be sought from the external team.

80% of LIFE Unit respondents felt that the distribution of projects according to language/country responsibility lines was the optimal form of allocating project management responsibilities. If projects were assigned to TDOs thematically rather than by country, the main barriers were thought to be that ‘language barriers may cause a breakdown in the relationship between TDOs and national contact points’ (43%) and that ‘missions would take longer and cost more because projects would be dispersed geographically’ (43%). The remaining 14% felt that it ‘would result in having to work with a larger number of Astrale monitors, which would dilute working collaborations’.

83% of LIFE Unit respondents felt that the most important gain from projects being thematically assigned would be the ‘better communication about projects between thematic units and stakeholders because of greater familiarity with the topic’.

66 Face-to-face interview with the Astrale central team, February 2010

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Figure L-4 illustrates that almost 50% of ASTRALE respondents felt that if projects were assigned to TDOs thematically, the most significant issue would be the dilution of working collaborations due to working with higher number of Astrale monitors. Over 30% felt that language barriers may also be an issue, leading to a breakdown in the relationship between TDOs and NCPs.

Figure L-4: If projects were assigned to TDOS thematically (to thematic desks in LIFE) rather than by country, what do you think would be the most significant issue?

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

language barriers may cause a breakdown in the relationship between TDOs and national contact points

missions would take longer and cost more because projects would be dispersed geographically

this would result in having to work with a larger number of Astrale monitors, which would dilute working collaborations


40% of ASTRALE monitors felt that the area most requiring more resources or having room for improvement related to ‘field visits’. 38% felt that there should be better ‘assistance for beneficiaries to understand the LIFE+ Regulation’, with a further 35% feeling that more assistance was needed in implementing good practices in reporting and project communications. Around one in five felt that contact with project beneficiaries could be improved; with a similar proportion stating that following up project deliverables and major project milestones could be improved. Primarily, more resources were required to support projects with report writing due to the variance in the quality of submissions, with a suggestion that this could also improve communication and dissemination of project activity. 86% of respondents felt that the benefits of additional resources would outweigh extra costs due to the improved report writing, better implementation of project activity and a reduced risk of project failure i.e. ‘less time spent on fire fighting’.

75% of respondents felt that it was ‘fairly straightforward’ to assess whether projects are on target to meet their objectives before projects are completed. An additional 15% felt that it was ‘very straightforward’ however 10% felt that it was ‘not so straightforward’.

Regarding the dissemination of results, half of ASTRALE respondents felt it would be ‘OK’ for projects to disseminate results. 20% felt that it would be ‘relatively easy’ with an additional 4% stating it would be ‘extremely easy’. 25% felt it would be ‘difficult’ for projects to share results, but no respondents stated that it would be ‘extremely difficult’. For those who stated it would be ‘difficult’, one respondent suggested that the LIFE dissemination requirements of projects are ‘very formal’, with further suggestion from respondents that the

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dissemination should be considered from the project proposal stage and actively take place from the start of the project to allow it to be integrated from the outset.

The majority of respondents (64%) felt it was ‘OK’ to assess the eligibility of the beneficiary and partners’ expenditure. 20% felt that it was ‘difficult’ to assess with one in ten stating that is was ‘easy’. No respondents felt that it was ‘extremely difficult’.

Figure L-5: How would you rate your performance in assessing whether project funds are being appropriately used and reported to the Commission?

very good

good

ok

Not effective


88% of ASTRALE respondents felt that they receive adequate information, advice and guidance from the LIFE Units during the monitoring process, although there was some suggestion that further information on financial monitoring and evaluation may be beneficial.

64% of ASTRALE respondents felt that NCP support during the lifetime of the project could be improved. When asked how it could be improved, it was suggested that the level of involvement was relatively low although variable from country-to-country. This is exemplified by one respondent who stated that his NCP is too focused on the environment projects with another commenting that in his country there is not enough support with relation to the environment. Further comment is made that the visibility of NCPs should be improved with more regular contact.

25% of ASTRALE respondents felt that the Inception Report was very useful with a further 19% stating that it was useful; some specifically mentioning that ‘it should not be removed’. For the progress or interim report, it was felt that importance depended on the project, but generally useful and should not be removed. The midterm report was described as ‘a necessity as it triggers payment’ and therefore is important from a financial accountability point of view; no negative comments were made. The final report was also seen as ‘vital’, and by many the ‘most important’ report produced.

30% of respondents could not name anything onerous regarding the LIFE+ monitoring process. The assessment of financial documents was onerous for at least 10% respondents with others suggesting that different interpretations of LIFE/ EC regulations led to difficulties in some cases.

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M ANNEX M: REVIEW OF COMPLEMENTARITY

M.1 Review of Feedback on Guidance for Complementarity

Stakeholders were asked to consider whether there was sufficient guidance on complementarity.

Figure M-1: Is your Member State providing sufficiently clear guidance to potential project beneficiaries about potentially complementary financial instruments?

Very clear guidance

Relatively clear guidance

Satisfactory

Not sufficiently clear and needs improvement

Hardly any guidance provided at all / none


NCPs were asked whether the Commission was providing them with a sufficient level and detail of guidance on complementarity. There was a 50/50 split in responses. One NCP suggested that the Commission does not seem too familiar with this problem, particularly as the problem of complementarity is different in each Member State and therefore the Commission is not familiar with all issues. Another NCP suggested that the Commission could have better explained the concept of complementarity and another NCP pointed out that there is such a high number of EU funding programmes that it is an extremely time consuming and difficult issue for applicants to look at.

NCPs were also asked whether it was clear how LIFE+ and other funding instruments differ from one another and what projects are eligible for funding under the various instruments. 57% stated that they ‘just about understand’ perhaps highlighting a need for additional training. One NCP suggest that they would not be able to cite difference between funds and would like more information on the different funds if possible.

NCPs were asked to rank which programmes shared the most overlap with LIFE+ and the results are in Figure M-2 below: 5 interviewees stated that EAFRD shared the biggest overlap with LIFE+, 4 stated ERDF, and 3 stated CIP.

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Figure M-2: Please rank which programmes you feel share the most overlap with LIFE+ (where 1 is ‘most overlap’)

Rank CIP FP7 ERDF ESF Cohesion Fund

EAFRD European Fisheries Fund

1 3 0 4 0 0 5 0

2 1 1 2 0 1 0 0

3 0 2 0 0 1 1 0

4 1 0 1 0 1 1 2

5 0 1 0 2 0 0 0

6 0 1 0 1 1 0 0

7 1 0 0 1 0 0 2

X 5 0 3 2 0 2 1

Source: GHK NCP Interview results (different numbers of respondents to each component)

M.2 A description of EAFRD – a complementary instrument

M.2.1 Structure of EAFRD

European Agricultural Fund for Rural Development (EAFRD) constitutes a major support for the protection of the natural terrestrial environment. Its overarching aim is to achieve Sustainable rural development throughout the Community, in part through the restructuring of the agricultural sector The EAFRD has been the single instrument to finance rural development policy since January 2007. The EARDF has been allocated a budget of EUR 96.3 billion for the period 2007-201367.

Implementing the national strategic plans is carried out through rural development programmes containing a package of measures grouped around 4 axes:

Axis 1: Improving the competitiveness of the agricultural and forestry sector

A minimum of 15 per cent of allocated funds must be spent here. The aim is to support measures designed to improve the competitiveness of the agriculture and forestry industries (e.g. restructuring holdings and improving human capital and product quality)

Axis 2: improving the environment and the countryside

A minimum of 25 per cent of allocated funds must be spent here. The aim is to support land management measures designed to enhance the environment and the countryside (e.g. agri-environment schemes and animal welfare commitments). In terms of Biodiversity EAFRD focuses on conserving biodiversity in rural areas and more specifically co-financing measures carried out by farmers or foresters.

Eligible measures include:

67 http://europa.eu/legislation_summaries/agriculture/general_framework/l60032_en.htm

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- Payments to farmers to compensate for the costs incurred and income forgone in managing Natura 2000 sites on their land;

- Agri-environment payments to farmers and other land managers for commitments going beyond standard good agricultural practice;

- Support to private forest owners or forestry associations to cover the costs and income foregone resulting from restrictions aimed at safeguarding Natura 2000 sites;

- Forest-environment payments for voluntary commitments going beyond minimum mandatory requirements.

Axis 3: quality of life in rural areas and diversification of the rural economy

A minimum of 15 per cent of allocated funds must be spent—aims to support policies that target improvements in the quality of life in rural areas (e.g. basic services provision, rural heritage conservation) and promote economic diversification towards non-agricultural activities (e.g. tourism).

Eligible measures include:

- the development of management plans relating to Natura 2000 sites and other places of high nature value

- Measures to raise environmental awareness

- Investments associated with the maintenance, restoration and upgrading of the natural heritage

- Studies and investments associated with the maintenance, restoration and upgrading of the cultural features of villages and the rural landscape.

- Training, skills acquisition, and the animation of local people to participate in local development strategies.

Axis 4: LEADER

A minimum of 5 per cent of EAFRD funds are specifically for LEADER initiatives across the three axes. Under the LEADER approach, local action groups can secure funding for local development projects.

M.2.2 Potential overlap between LIFE+ and EAFRD

EAFRD does fund actions that are quite similar to LIFE Nature and although there is potential for overlap here, LIFE+ remains a unique instrument for certain types of projects that lack other funding options and is also the only instrument with an exclusive focus on nature and environmental issues it can therefore be deemed more focused.

As a CAP funding programme EAFRD is terrestrial focused and much of the funds are allocated to farmers under agri-environment programmes. In addition the alternative axes can fund a range of other projects (including management plans, visitor infrastructure, monitoring etc), however there are many competing priorities for these. EAFRD does not provide opportunity for the funding of Information and Communication activities or Implementation and Governance of environmental policy. In addition it does little towards the aquatic and marine environment. Furthermore the majority of the beneficiaries are farmers and to a lesser extent foresters. Although there is potential for overlap with

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activities described in the table above, LIFE+ remains a unique instrument for certain types of projects that lack other funding options and is also the only instrument with an exclusive focus on nature and environmental issues.

The main issue with funding for nature conservation is the fact that EU is committed to co-fund the Natura 2000 network which will cost 5-6 billion Euros annually, however there is little dedicated funding. Discussions on options in 2002-04 identified possibility for new, dedicated “Super LIFE” programme but it was deemed too expensive and the additional resources could not be found. Therefore the decision was taken to use existing funds e.g. Structural funds, EAFRD and LIFE. The issue is that there are competing priorities and Structural Funds and EAFRD are not sufficiently focused. LIFE is more flexible but limited in scale relative to need. Hence the network is under-funded. In theory most projects can be funded using one instrument or another, but there are no guarantees, there are conflicts, the funding may not match the timetable and it may be difficult to bend the project scope to meet other objectives therefore there remains funding gaps.

M.2.3 Management of EAFRD and LIFE+

LIFE+ is a centrally managed programme and unique in the fact that projects on the ground can influence decision making and policy and together they aim to have an overall impact on EU added value. In contrast, EAFRD can only fund activities or programmes that are implemented by Member States and Regions therefore spend depends on their priorities. The Member States have the greatest influence on the result of the programming process. The Commission’s influence is limited

Under the principle of shared management between the Commission and the Member States, the Member States must appoint, for each rural development programme: a management authority, a paying agency and a certification body. They are also tasked with providing information and publicity on co-financed schemes. Each Member State must also set up a monitoring committee to ensure the programme is implemented effectively. In addition, the management authority for each programme must send an annual report to the Commission on the implementation of the programme.

M.3 Lessons for the Management of Eco-Innovation based on Review of EACI

M.3.1 What have been the benefits of the delegation of management of the eco-innovation initiative to EACI?

Beneficiaries appear to be grateful that they are dealing with specialists in the different areas, and the ‘general service approach’ seems to be appreciated by most beneficiaries. The agency also operates a ‘no wrong door’ policy – which means that they devote full efforts to each potential beneficiary in helping them understand which elements would be accepted for funding under CIP eco-innovation and where applicants should look at other instruments. They provide their contact details. In general, potential applicants have been very positive about EACI’s response time for any questions or feedback68.

In addition, the project monitoring means that the Agency receives feedback directly ‘from the ground’ and can make alterations to the process as necessary – for example, they had to recognise that innovation has been developed in different countries at differing rates and some countries are more advanced than others. This finding has been made more explicit in subsequent calls, when referring to different kinds of innovation.

What has been particularly important is staying in touch with the Parent DG - meetings are organised with DG Environment, but also with DG Research (e.g. regarding food and drink

68 Refer to the recent Court of Auditors report for more detail on the performance of the Agency as a whole http://eca.europa.eu/portal/pls/portal/docs/1/3384294.PDF

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projects). It is important to feedback results and suggestions to the Parent DG. EACI depend on the DG for input and direction when defining new calls, so it is important to maintain a close working relationship.

The selection process from the call closure to the signing of the contract was 9 months.

M.3.2 What steps have you taken to increase the visibility of the Programme and to reach out to a wider audience of potential beneficiaries?

To reach potential applicants in the first run, several databases were used (including that of LIFE+) to promote the CIP eco-innovation initiative. An e-mail was sent to all potential beneficiaries to ask them to register if interested in CIP eco-innovation and this generated over 1000 responses69 from the LIFE database alone.

Events were held, business cards were collected and a corporate design and logo was developed and translated into all languages. This was all done in close participation with DG ENV. A comprehensive website was developed which offered a web enquiry address. The website also offered a support service – where applicants could send a 2-page summary of their project and would receive feedback on whether it was eligible. Applicants consider this helpful as it limits wasted effort on long proposals.

In addition, a European Information day is organised to coincide with the annual calls and national information days are organised in national languages. Holding events can be difficult as the unit is small and so often they try to link events or with other units, for example with ETAP group and Green Week. They also use the European Enterprise network for contacts and use their database as they also target SMEs. Press releases are published but this happens less frequently and should be increased.

As a result of all the efforts 134 applications were received in the first call (as more or less expected). In the second this rose to 202.

(The dissemination of project results has not yet begun as 2008 was the first call and projects started last year. Therefore at this stage there are not many results to share).

M.3.3 What role do the NCPs play in the CIP instrument and how can responsibilities be enhanced / role be widened?

CIP eco-innovation belongs to the EIP programme. Therefore, informal NCPs were set up to focus on eco-innovation.

Some NCPs were created after a response to an initial request to the EIP committee. It was then extended to ETAP members to increase numbers. Further NCPs were organisations volunteering, approaching EACI directly and offering their services. Any NCPs had to be organisations that would not have an interest in applying to the initiative themselves.

The role of the NCPs is to take some of the burden off EACI in terms of disseminating information and responding to queries. The level of commitment and involvement is variable dependent on each individual NCP. EACI also appreciate feedback from the NCPs concerning administrational issues and content aspects of Calls.

M.3.4 Are you there any potential overlaps between the CIP programme and LIFE+?

CIP and LIFE try to avoid overlaps by making clear the distinction. The main difference are:

69 This figure was to be confirmed by the interviewee but no confirmation was made before submission of the Report

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CIP looks for market uptake and has a clear market focus where replication is crucial during the project or just after completion.

A strong SME focus – 70% of beneficiaries are SMEs and the private sector, in particular SMEs are prioritised.

Demands an integrated approach across environmental themes (cannot just focus on one theme, e.g. water) – life-cycle approach.

CIP Eco-innovation bridges the gap between the research and commercialisation phase. While the technology demonstration phase could be part of LIFE projects, under CIP eco-innovation this phase has to be completed beforehand.

Figure M-3: Comparison of Key Features of the CIP and LIFE+ Projects

Eco-innovation LIFE +

Priority on private sector, businesses

CIP umbrella

Market competitiveness and market uptake

Replication is crucial

Integrated environmental impacts (e.g. water only one aspect)

Mainly public sector

Policy development and Implementation of legislation

Dissemination, awareness raising, capacity building

Land-use, urban planning, water management, waste management, chemicals, noise and many other environmental themes

Environmental solutions but market uptake is not vital

M.3.5 Are you responsible for the management of results and outcomes?

Yes – they are responsible for monitoring projects - there are 3 project officers running 44 projects with another 45 projects starting this year. (2 more project officers next month).

In the application phase projects have to provide indicators to measure results under 3 categories: improved environmental performance, better use of natural resources,

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economic performance/market replication and these indicators are updated with the interim and final reports by applicants in order to monitor impacts.

Attempts are made to avoid overlaps with other programmes such as IEE – but here the focus is on energy and for CIP eco-innovation it has to be across themes so relatively easy to distinguish. Furthermore the types of projects differ with an emphasis on Promotion and dissemination by IEE.

M.4 Overview of the CIP Programme

Two factors help explain the high demand for CIP:

Focus on commercialisation and SMEs being a key constituency (universities and limited number of public authorities also participate but to a very limited extent). Businesses have to innovate to survive whereas there is arguably less incentive for public authorities to (eco)innovate and the opportunities for achieving real breakthroughs with the modest funds available is debateable.

EACI through the Enterprise Europe Network has been instrumental in effectively engaging with target groups and creating demand for the programme.

Figure M-4: Overview of Support Earmarked for Eco-innovation

EIP Market Replication Projects

EUR 195 million has been earmarked for market replication projects over 2007-2013.

So far c. EUR 95 million has been committed/ budgeted as follows:

Table M-1: Overview of Calls for Proposals

2008 2009 2010

Budget committed – calls for proposals (EUR) 27,850,000 32,003,000 35,020,000

Budget committed – calls for tenders (EUR) - 150,000

220,000

EACI – operating expenses (EUR)* 911,020

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2008 2009 2010

Call for proposals - Timetable

Publication of call Apr 2008 Apr 2009 Q2 2010

Call closing date Sep 2008 Sep 2009

Complete evaluation of proposals by Jan/ Feb 2009 Jan 2010

Implementation of projects Spring 2009 Mar 2010

Call Results

No. of proposals submitted 134 202

No. of participants 444 614

Requested Funds 110,000,000 150,000,000

Average funds requested 830,000 770,000

% SME participants 74% 70%

*EACI revenue Structure - 2008

Source: 2008 Final Accounts http://ec.europa.eu/eaci/docs/agency_accounts2008.pdf

M.4.1 EIP Financial Instruments

Specific support to eco-innovation oriented VC funds (EUR 228 million). By the end of 2009 four investments made into eco-innovation. Under CIP, the management fees payable to EIF amount to 6 per cent of the signed amounts

M.4.2 Networks

EUR 10 million was earmarked for eco-innovation. Europe INNOVA and PRO INNO Europe contribute to eco-innovation through the establishment of networks and partnerships.

Within the Europe INNOVA initiative:

The establishment of European Innovation Platform relevant for eco-innovative sectors of high political priority, to test innovative tools through public-private partnerships with the perspective to leverage their broader deployment.

Support projects to the Platform, such as the Eco-innovation Observatory:

http://www.europe-innova.eu/web/guest/eco-innovation-observatory/overview

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Within the PRO INNO Europe initiative: Championing eco-innovation through the establishment of an open platform for eco-innovation policy learning and development.

M.4.3 IEE – European Local ENergy Assistance (ELENA)

Technical assistance facility established by the European Commission and managed by the European Investment Bank. Launched December 2009. ELENA facility is endowed with a fund of EUR 15 million from the IEE 2009 budget. ELENA support covers a share of the cost for technical support that is necessary to prepare, implement and finance the investment programme, such as feasibility and market studies, structuring of programmes, business plans, energy audits, preparation for tendering procedures - in short, everything necessary to make cities' and regions' sustainable energy projects ready for EIB funding.

CIP Arrangements for Appraisal and Selection

The average ‘delai de contrat’ for eco-innovation call in 2008 was 283 days: Call closure was 11 September 2008. Evaluation Committee was held 20/26 January 2009. The contract preparations started in February and a first award decision was signed on 8th April for 10 proposals. Two more decisions were signed in May (11 proposals on the 6 May and 9 proposals on the 20 of May). 30 proposals were in total awarded by the month of May.

Last award decision was on 22.7.2009. All 44 contracts were signed by the EACI by the end of August 2009.

The HoU, HoS and a representative from DG ENV moderated panel discussions themselves.

Key points for the fast Eco-innovation contract preparation:

Already during the evaluation phase, experts elaborate points to be taken into consideration during the contract preparation phase.

Work on word files with track changes with late downloading to RIVET.

Simplified formats for:

Common template for contract preparation regarding technical, financial and administrative points where input from the evaluation and further PO/FO is included.

Report on contract preparation (limited to 1 page compared to the ~6 pages used at EACI)

SME declarations accepted for the award decision. SME detailed checking done after the signature.

Flexible batches for signature of authorising officer: Firstly batches are established. Secondly and whenever a decent amount of proposals has passed the contract preparation phase, a batch is created.

Communicate only the absolute amount of EC funding in €, not a %.

Flexibility for amendments is 20% for budget shifts.

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M.5 Feasibility funding to help increased demand for the LIFE+ programme for eco-innovation

The LIFE+ Regulation specifies that 78% of the budget should be allocated through calls for applications for Action Grants. Up to €2m of funding is provided per project with 50% match funding from the Commission.

One idea to promote eco-innovation applications under LIFE+ is to provide an element of feasibility funding for upfront development. This can help to bring partners together to explore the feasibility of a project. This has the huge benefit of allowing some preliminary work to be undertaken at little cost to partners, whilst providing an indication of how a larger project might be tackled and the type of initial challenge that could be expected. LIFE+ benefits by broadening the applicant base and raising the quality of successful bids. There is already a good model for this being used by the UK’s Technology Strategy Board (see box below) which could be replicated for certain types of project under LIFE+.

The UK’s Technology Strategy Board (TSB) aims to stimulate innovation across its core technology areas to help ensure that UK businesses are well-equipped to respond to the challenges presented by the current downturn. To increase engagement and participation in many of its technology competitions, the TSB provides funding for feasibility studies that are the first stage in a larger funding round. For example, under its September 2009 competition for ‘technology-inspired innovation’70, it has allocated up to £1m for feasibility studies lasting up to three months and each costing no more than £33,000 in total. It will fund 75% of the project cost (up to around £25,000). The output of each study typically comprises a short report and presentation which are then judged by a panel with the best going to full project bid stage.

M.5.1 Increased funding from member states

The LIFE+ Regulation specifies that 22% is available to be used to fund procurement of service contracts (of which 3% for NGOs). Compared to the Structural Funds and ERDF, LIFE+ is able to invest together with local and regional authorities without national funds having to invest. However, making member state funding compulsory could enhance the programme leverage as well as aligning the eco-innovation objectives better with member states.

M.5.2 Direct investment into projects

EIB could co-invest in a risk-sharing finance facility to support, for example, Energy Service Company (ESCO) activities (or else help create a public-private ESCO). This would in turn draw on LIFE+ funding to help refine an innovative management and business method which could potentially be deployed through numerous ESCOs – for example, to support climate change mitigation strategies by European cities.

M.5.3 Investment funding to lever private sector funds

Assuming that the scope of eco-innovation within LIFE+ would allow SMEs to help drive forward projects, rather than public sector bodies per se, there might be an opportunity to lever in private sector funding from venture funds (through EIB), as is done under CIP. The beneficiaries of such funds could then link LIFE+ project funding with their own growth and commercialisation plans – for example, where a particular innovation being developed by an SME has wide applicability to the public sector etc.

One aim of CIP is to improve access to finance for the start-up and growth of SMEs as well as to enhance investment in innovation activities. Around half of the €1.1 billion CIP

70 www.innovateuk.org/_assets/pdf/TechnologyInspiredInnovCompFlyerSept09.pdf

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resources allocated to financial instruments for 2007 to 2013 are budgeted for the CIP High Growth and Innovative SME Facility (GIF) – see diagram below which illustrates where GIF sits in the growth stages of business71. There are two GIF windows: one aimed at risk-capital funds targeting investments in SMEs that are in seed and start-up stage (GIF 1); the other for funds targeting expansion-stage SME investments (GIF 2). For risk-capital funds focused on eco-innovative SMEs, higher investment rates are allowed under GIF. In GIF 1, EU investment may represent up to 50% of fund size compared with 25% for funds investing in more traditional industrial sectors. With GIF 2, the financing caps are 25% for eco-innovation and 15% in other cases.

Under GIF, a specific ‘envelope’ of over €200 million is dedicated to venture-capital funds with an eco-innovation focus. To date, EIF has committed more than €50 million in four deals with eco-innovative funds72 (see box below). Each investment has comprised between €15-25m, representing between 15% and 20% of the private investment funds, hence leveraging between 5 and 6.5x the initial investment from private sector investment.

High Growth and Innovative SME funding facility (GIF) levers in private investment

CAPRICORN (June 2008) - €112 million fund is investing in early to mid-stage ventures across cleantech and eco-innovation SMEs.

WHEB (January 2009) - will invest in innovative young companies with high growth potential.

PINOVA Fund 1 (January 2009) - focuses on lower mid-market and expansion stage phases of SMEs in Germany and Austria, helping engineering, services and environmental businesses to become international players.

DEMETER 2 Fund (May 2009) - provides €200 million for expansion and venture capital to companies in the sustainable energy and eco-industry sectors in France, Spain, Germany and the rest of Europe.

71 www.lisboncouncil.net/component/downloads/?id=289 72 http://ec.europa.eu/environment/etap/inaction/showcases/eu/418_en.html

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M.5.4 Loan guarantees

It is uncertain how loan guarantees might work in the context of LIFE+ but it might be worth exploring how a mechanism similar to that employed through EIF (below) might work in practice for some of the projects undertaken through LIFE+.

Through the EIF, the EU partly guarantees loans or other debt finance granted by local institutions to SMEs. The risk-sharing arrangements established between EIF and each of its local partners, known as “Intermediaries”, aim to stimulate the provision of debt finance to SMEs at local level.73 Depending on the type of Intermediary and its activity, EIF may issue:

Direct guarantees to Intermediaries that provide finance directly to SMEs. EU Loan Guarantees partially cover portfolios of loans, lease agreements or other types of debt finance.

Counter-guarantees to Intermediaries that issue guarantees for the benefit of lending institutions. EU Loan Guarantees partially cover portfolios of guarantees covering debt finance extended to SMEs.

73 http://www.eif.org/guarantees/cip_portfolio_guarantees/loan_guarantees/index.htm

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N ANNEX N: OVERVIEW AND SELECTION OF NGOS

N.1 Overview of the NGO population

The table below presents the overview of all NGOs being funded in 2006 (the last year before the new LIFE+ framework entered into force), 2007 and 2008 (the target years of this study), and 2009 (the current year).

2006 2007 2008 2009

1 AGREE.NET association Czech Republic

X X X

2 AIFM Association internationale forêts méditerranéennes

France X X X

3 ANPED The Netherlands

X

4 Aquanet Europe foundation The Netherlands

X

5 Avalon foundation The Netherlands

X X

6 BEF Baltijas vides forum Latvia X X X

7 Birdlife Europe The Netherlands

X X X X

8 CEE bankwatch network Czech Republic

X X X X

9 CEEWEB Central and eastern European working group for enhancement of biodiversity

Hungary X X X

10 Climate action network Europe Brussels X X X X

11 Coalition clean Baltic Sweden X X X X

12 DEF Danube environmental forum Slovakia / Hungary

X X X X

13 ECOS European environmental citizens organisation for standardisation

Brussels X X X

14 EEB European environmental bureau

Brussels X X X X

15 EFNCP European forum on nature conservation and pastoralism

UK X X X

16 ELO European landowners organisation

Brussels X X X

17 Environmental partnership for sustainable development

Czech Republic

X X

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2006 2007 2008 2009

association

18 EUCC European Union for coastal conservation – the coastal union

The Netherlands

X X X X

19 EUROPARC federation Germany X X X X

20 European cyclists federation Brussels X

21 European federation for transport and environment

Brussels X X X X

22 Eurosite Association France / The Netherlands

X X X

23 EWA European Water association Germany X X X

24 EWLA Eurogroup for wildlife & laboratory animals

Brussels X X X

25 FACE federation of associations for hunting and conservation of the EU

Brussels X

26 FERN The Netherlands

X X X X

27 Friends of the Earth Europe Brussels X X X X

28 Global ecovillage network of Europe

Germany X

29 Groupe de recherche en agriculture biologique

France X

30 HEAL Health & environment alliance, former EPHA European public health alliance environment network

Brussels X X X X

31 Health care without harm Europe The Netherlands

X X

32 IFN/NFI Naturfreunde international Austria X X X X

33 IFOAM international federation of organic agriculture movements EU group

Brussels X

34 INFORSE International network for sustainable energy

Denmark X X X X

35 Iniciativa karpatskeho eckoregionu Slovakia X

36 Institut fur Weiterbildung und Beratung in Umweltschutz

Germany X

37 International solar energy society Germany X

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2006 2007 2008 2009

38 ISWA International solid waste association

Denmark X

39 Justice & environment – European network of environmental law organisations

The Netherlands

X X X X

40 Mediterranean information office for environment, culture and sustainable development MIO ECSDE

Greece X X X X

41 PAN-E Pesticide action network Europe

UK X X X X

42 Panparks The Netherlands

X

43 Platform on shipbreaking Brussels X

44 RREUSE re-use and recycling European Union social enterprices

Brussels X X X X

45 SAR Seas at Risk federation The Netherlands

X X X

46 Sea alarm Brussels X

47 Taiga rescue network Sweden X

48 WECF Women in Europe for a common future

The Netherlands

X X X

49 WWF European policy programme (WWF-EPO)

Brussels X X X X

50 WWF international Danube Carpathian programme (WWF-DCP)

Austria X X X X

51 YEE youth and environment Europe

Czech Republic

X

TOTAL 43 30 33 32

new 3 4 6

stopped 16 1 7

The total number of different NGO’s that were funded in 2007 and/or 2008 is 34. The total number of NGOs having experience with the LIFE+ programme is 40.

N.2 Selection of NGOs for further analysis

N.2.1 Number of NGOs

In accordance with the proposal, 25% of the awarded NGOs will be visited for a face-to-face interview. In the KO meeting with the Commission services at September 30th 2009, it was agreed

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to visit 11 NGOs of which 6 are based in Brussels, and to add 11 supplementary NGOs for a telephone interview.

N.2.2 Selection criteria

The selection of NGOs should be representative for the total population. The following criteria should be reflected in the choice of the NGOs:

Experience with the previous funding system ––– only experience with LIFE+

Continuously rewarded ––– rewarding stopped

EU wide action domain ––– regional action domain

Broad policy approach, multi thematic ––– specific thematic approach

Policy development ––– policy implementation ––– education and awareness raising

Brussels based ––– EU spread (north – south, EU15 – EU12)

Large amounts awarded (absolute terms) ––– smaller amounts awarded (absolute terms)

Large amounts awarded (%) ––– smaller amounts awarded (%)

The split up of the NGOs over the above categories is illustrated in the following sections. The NGOs selected are marked in bold.

The NGOs are selected from the population of 34 being funded in 2007 and/or 2008.

N.3 Experience with the previous funding system ––– only experience with LIFE+

Experience with the previous funding system: AGREE.NET association; AIFM Association internationale forêts méditerranéennes; BEF Baltijas vides forum; Birdlife Europe; CEE bankwatch network; CEEWEB Central and eastern European working group for enhancement of biodiversity; Climate action network Europe; Coalition clean Baltic; DEF Danube environmental forum; ECOS European environmental citizens organisation for standardisation; EEB European environmental bureau; EFNCP European forum on nature conservation and pastoralism; Environmental partnership for sustainable development association; EUCC European Union for coastal conservation – the coastal union; EUROPARC federation; European federation for transport and environment; Eurosite Association; EWA European Water association; FERN; Friends of the Earth Europe; HEAL Health & environment alliance; Health care without harm Europe; IFN/NFI Naturfreunde international; INFORSE International network for sustainable energy; Justice & environment – European network of environmental law organisations; Mediterranean information office for environment, culture and sustainable development MIO ECSDE; PAN-E Pesticide action network Europe; RREUSE re-use and recycling European Union social enterprises; SAR Seas at Risk federation; WWF European policy programme (WWF-EPO); WWF international Danube Carpathian programme (WWF-DCP)

Only experience with LIFE+: ELO European landowners organisation; EWLA Eurogroup for wildlife & laboratory animals; WECF Women in Europe for a common future

Continuously rewarded ––– rewarding stopped

Continuously rewarded : NGO’s that are rewarded in 2006, 2007, 2008, 2009: Birdlife Europe; CEE bankwatch network; Climate action network Europe; Coalition clean Baltic; DEF Danube environmental forum; EEB European environmental bureau; EUCC European Union for coastal conservation – the coastal union; EUROPARC federation; European federation for transport

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and environment; FERN; Friends of the Earth Europe; HEAL Health & environment alliance; IFN/NFI Naturfreunde international; INFORSE International network for sustainable energy; Justice & environment – European network of environmental law organisations; Mediterranean information office for environment, culture and sustainable development MIO ECSDE; PAN-E Pesticide action network Europe; RREUSE re-use and recycling European Union social enterprises; WWF European policy programme (WWF-EPO); WWF international Danube Carpathian programme (WWF-DCP).

Rewarding stopped : NGOs for which the funding stopped during 2007 or 2008: ECOS European environmental citizens organisation for standardisation; Environmental partnership for sustainable development association; EWA European Water association; Health care without harm Europe; SAR Seas at Risk federation.

EU wide action domain ––– regional action domain

EU wide action domain : Birdlife Europe; Climate action network Europe; ECOS European environmental citizens organisation for standardisation; EEB European environmental bureau; EFNCP European forum on nature conservation and pastoralism; EUCC European Union for coastal conservation – the coastal union; EUROPARC federation; European federation for transport and environment; Eurosite Association; EWA European Water association; FERN; Friends of the Earth Europe; HEAL Health & environment alliance; Health care without harm Europe; IFN/NFI Naturfreunde international; INFORSE International network for sustainable energy; Justice & environment – European network of environmental law organisations; PAN-E Pesticide action network Europe; RREUSE re-use and recycling European Union social enterprises; SAR Seas at Risk federation; WWF European policy programme (WWF-EPO); ELO European landowners organisation; EWLA Eurogroup for wildlife & laboratory animals; WECF Women in Europe for a common future

Regional action domain : AGREE.NET association; AIFM Association internationale forêts méditerranéennes ; BEF Baltijas vides forum; CEE bankwatch network; CEEWEB Central and eastern European working group for enhancement of biodiversity;Coalition clean Baltic; DEF Danube environmental forum; Environmental partnership for sustainable development association; Mediterranean information office for environment, culture and sustainable development MIO ECSDE; WWF international Danube Carpathian programme (WWF-DCP)

Broad policy approach, multi thematic ––– specific thematic approach

Multi thematic: EEB European environmental bureau; Friends of the Earth Europe; BEF Baltijas vides forum; Environmental partnership for sustainable development association; Mediterranean information office for environment, culture and sustainable development MIO ECSDE

Specific thematic approach: AGREE.NET association; AIFM Association internationale forêts méditerranéennes; Birdlife Europe; CEE bankwatch network; CEEWEB Central and eastern European working group for enhancement of biodiversity; Climate action network Europe; Coalition clean Baltic; DEF Danube environmental forum; ECOS European environmental citizens organisation for standardisation; EFNCP European forum on nature conservation and pastoralism; ELO European landowners organisation; EUCC European Union for coastal conservation – the coastal union; EUROPARC federation; European federation for transport and environment; Eurosite Association; EWA European Water association; EWLA Eurogroup for wildlife & laboratory animals; FERN; HEAL Health & environment alliance; Health care without harm Europe; IFN/NFI Naturfreunde international; INFORSE International network for sustainable energy; Justice & environment – European network of environmental law organisations; PAN-E Pesticide action network Europe; RREUSE re-use and recycling European Union social enterprises; SAR Seas at Risk federation; WECF Women in Europe for a common future; WWF

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European policy programme (WWF-EPO); WWF international Danube Carpathian programme (WWF-DCP)

Policy development ––– policy implementation ––– education and awareness raising

Mainly policy development: Climate action network Europe; Coalition clean Baltic; ECOS European environmental citizens organisation for standardisation; EEB European environmental bureau; ELO European landowners organisation; European federation for transport and environment; EWA European Water association; EWLA Eurogroup for wildlife & laboratory animals; FERN; Friends of the Earth Europe; HEAL Health & environment alliance; Health care without harm Europe; Mediterranean information office for environment, culture and sustainable development MIO ECSDE; RREUSE re-use and recycling European Union social enterprises

Mainly policy implementation: BEF Baltijas vides forum; DEF Danube environmental forum; EFNCP European forum on nature conservation and pastoralism; Environmental partnership for sustainable development association; EUROPARC federation; Eurosite Association; IFN/NFI Naturfreunde international; Justice & environment – European network of environmental law organisations;

Mainly education and awareness raising: most of the NGOs combine their other activities with awareness raising.

Multiple fields of action: many NGOs announce that they are active in policy development, policy implementation and awareness raising; The NGOs mentioned here are combining two or all three approaches without one approach being prominently more important than the other approaches: AGREE.NET association; AIFM Association internationale forêts méditerranéennes; Birdlife Europe; CEE bankwatch network; CEEWEB Central and eastern European working group for enhancement of biodiversity; EUCC European Union for coastal conservation – the coastal union; INFORSE International network for sustainable energy; PAN-E Pesticide action network Europe; SAR Seas at Risk federation; WECF Women in Europe for a common future; WWF European policy programme (WWF-EPO); WWF international Danube Carpathian programme (WWF-DCP)

Brussels based ––– EU spread (north – south, EU15 – EU12)

Brussels based: Climate action network Europe; ECOS European environmental citizens organisation for standardisation; EEB European environmental bureau; ELO European landowners organisation; European federation for transport and environment; EWLA Eurogroup for wildlife & laboratory animals; Friends of the Earth Europe; HEAL Health & environment alliance; RREUSE re-use and recycling European Union social enterprises; WWF European policy programme (WWF-EPO)

Northern Europe EU-15:

Birdlife Europe; Coalition clean Baltic; EFNCP European forum on nature conservation and pastoralism; EUCC European Union for coastal conservation – the coastal union; EUROPARC federation; Eurosite Association; EWA European Water association; FERN; Health care without harm Europe (moved to Brussels); IFN/NFI Naturfreunde international; INFORSE International network for sustainable energy; Justice & environment – European network of environmental law organisations; PAN-E Pesticide action network Europe; SAR Seas at Risk federation; WECF Women in Europe for a common future; WWF international Danube Carpathian programme (WWF-DCP)

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Southern Europe EU-15: AIFM Association internationale forêts méditerranéennes; Mediterranean information office for environment, culture and sustainable development MIO ECSDE

EU-12: AGREE.NET association ; BEF Baltijas vides forum; CEE bankwatch network; CEEWEB Central and eastern European working group for enhancement of biodiversity; DEF Danube environmental forum; Environmental partnership for sustainable development association

Large amounts awarded (absolute terms) ––– smaller amounts awarded (absolute terms)

Large amounts awarded: NGO’s being funded for > € 300.000 in 2007 or 2008: BEF Baltijas vides forum; Birdlife Europe; CEE bankwatch network; Coalition clean Baltic; EEB European environmental bureau; Eurosite Association; Friends of the Earth Europe; HEAL Health & environment alliance; IFN/NFI Naturfreunde international; Mediterranean information office for environment, culture and sustainable development MIO ECSDE; WECF Women in Europe for a common future; WWF European policy programme (WWF-EPO)

Small amounts awarded: NGO’s being funded for < € 100.000 in 2007 or 2008: AIFM Association internationale forêts méditerranéennes; DEF Danube environmental forum; Environmental partnership for sustainable development association; EUROPARC federation; INFORSE International network for sustainable energy; PAN-E Pesticide action network Europe; RREUSE re-use and recycling European Union social enterprises; SAR Seas at Risk federation

Large amounts awarded (%) ––– smaller amounts awarded (%)

Large amounts awarded: NGO’s benefiting from +60% EU contribution in 2007 or 2008: AGREE.NET association; AIFM Association internationale forêts méditerranéennes ; CEE bankwatch network; CEEWEB Central and eastern European working group for enhancement of biodiversity; Coalition clean Baltic; DEF Danube environmental forum; ECOS European environmental citizens organisation for standardisation; EFNCP European forum on nature conservation and pastoralism; Environmental partnership for sustainable development association; HEAL Health & environment alliance; INFORSE International network for sustainable energy; Justice & environment – European network of environmental law organisations; Mediterranean information office for environment, culture and sustainable development MIO ECSDE; PAN-E Pesticide action network Europe; RREUSE re-use and recycling European Union social enterprises

Small amounts awarded: NGO’s benefiting from -35% EU contribution in 2007 or 2008: ELO European landowners organisation; WECF Women in Europe for a common future; WWF European policy programme (WWF-EPO); WWF international Danube Carpathian programme (WWF-DCP); Birdlife Europe; EUROPARC federation; European federation for transport and environment; FERN.

11 NGOs have been selected out of the total of 34, using the above selection criteria. These NGOs are summarised below. The selection focussed on 6 Brussels-based and 5 non-Brussels based NGOs. However, the NGO Health Care Without Waste that was funded in 2007 used to be established in Rijswijk – The Netherlands, but has since shifted offices and is now established in Brussels.

1. BEF, Baltijas vides forum

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The Baltic Environmental forum was founded by the Baltic Ministries of Environment, Germany and the European Commission as a technical assistance project aiming at strengthening the co-operation among the Baltic environmental authorities. With EU accession the technical assistance projects ended. However, to keep the networks active and to implement more projects in the Baltic Sea Region the BEF team has founded in 2003 NGOs in Latvia, Estonia, Lithuania and Germany. Action domains are nature conservation, climate change and energy, pollution control, chemicals safety, water, waste, strengthening partnerships.

The Baltic Environmental forum can be classified as follows:

Experienced with the previous funding system and with LIFE+

Funded in 2006, 2007, 2008

Regional action domain; balticum

Multi thematic

Focus on implementation of EU legislation

Based in EU-12 : Riga - Latvia

Funded above €300.000

2. CEE Bankwatch

Bankwatch’s mission is to prevent the environmentally and socially harmful impacts of international development finance, and to promote alternative solutions and public participation. The overall objective of CEE Bankwatch Network's work is to ensure that public money distributed via the EU funds or the International Financial institutions is used in environmentally and socially sustainable ways and that it serves the public good.

CEE Bankwatch can be classified as follows:


Funded in 2006, 2007, 2008, 2009

Regional action domain : Eastern European countries

Specific thematic approach : international finance

Focus on multiple approaches; policy development, policy implementation, communication

Based in EU-12 : Prague – Czech Republic

Funded above €300.000 and above 60%

3. EEB European Environmental Bureau

The EEB is a federation of, currently, 147, mainly EU based, environmental civil society organizations. Its mission is to protect and improve the environment of Europe and to promote understanding of EU environmental and sustainable development policies among EU environmental citizens organisations informing them of their rights and possibilities in playing an active part. The activities of the European Environmental Bureau cover a wide range of environmental issues, both in their policy development and implementation stages. It also works on agriculture, sustainable development and environmental governance issues. It focuses on policies directly and on capacity building in the European environmental movement.

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EEB can be classified as follows:


Funded in 2006, 2007, 2008, 2009

EU-wide action domain

Multi thematic

Focus mainly on policy development

Based in Brussels


4. EWLA Eurogroup for wildlife and laboratory animals

Eurogroup for Animals represents a united voice for animal welfare organisations in Europe. For more than 25 years, it has been working to improve the way animals are treated and kept throughout the European Union. The long-standing relationship it has established with the EU institutions allows Eurogroup to be recognised as a credible partner for all the policy issues that affect animals. On the topics “animals used in research” and “wild animals” Eurogroup for Animals works through its sister organisation EWLA (Eurogroup for Wildlife and Laboratory Animals).

EWLA can be classified as follows:

Experienced with the LIFE+ funding system only

Funded in 2007, 2008, 2009


Specific thematic approach : animal welfare

Focus on policy development

Based in Brussels

5. FoEE, Friends of the Earth Europe

Friends of the Earth Europe is the largest grassroots environment organisation in Europe with 31 national member groups campaigning for sustainable communities and environmental justice. FoEE influences the EU policy process to achieve strong environmental policies in four key areas: climate change and energy, food and biodiversity, economic justice (corporate/trade/EU funds) waste and resource use.

FOEE can be classified as follows:


Funded in 2006, 2007, 2008, 2009


Multi thematic


Based in Brussels


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6. HEAL Health and Environment Alliance

The Health and Environment Alliance aims to raise awareness of how environmental protection and sustainability improve people’s health, and to empower the health community to contribute their expertise to policy making. HEAL’s membership includes citizens’, patients’, community, women’s, health professionals’ and environmental organizations as well as research and public health institutes across Europe. HEAL's focus is on advocating for the needs of the most vulnerable to be considered in EU policy formulation and implementation. Its strategy is to provide expert input and a health perspective into environmental policies, and build coordinated efforts with vulnerable and health-affected groups, such as youth organisations and patients with asthma, cancer and Parkinson's disease, and with health professionals, who represent highly-respected voices in European debates.

HEAL can be classified as follows:


Funded in 2006, 2007, 2008, 2009


Specific thematic approach: health and environment


Based in Brussels


7. Healthcare Without Harm Europe

Health Care Without Harm is an international coalition of hospitals and health care systems, medical professionals, community groups, health-affected constituencies, labour unions, environmental and environmental health organizations and religious groups. Together with its partners around the world, Health Care Without Harm shares a vision of a health care sector that does no harm, and instead promotes the health of people and the environment. To that end, they are working to implement ecologically sound and healthy alternatives to health care practices that pollute the environment and contribute to disease. Health Care Without Harm is at the centre of the work to transform the health care sector worldwide, without compromising patient safety or care, so that it is ecologically sustainable and no longer a source of harm to public health and the environment.

Health Care without Harm can be classified as follows:


Funded in 2006, 2007. experienced with the effect of the ending of funding


Specific thematic approach: health and environment


Based in Brussels, formerly Northern Europe: Rijswijk - The Netherlands

8. INFORSE Europe

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INFORSE-Europe, the International Network for Sustainable Energy, is a network of 70 NGOs from 34 European Countries. The network is active on environmental policy since 1992 and promotes sustainable energy (renewable energy and energy efficiency) to defend environment i.e., mitigate climate change, to decrease air pollution, waste and resources through EU Policy influence, awareness raising, education, NGO seminars, quarterly newsletter, website, large database.

INFORSE Europe can be classified as follows:


Funded in 2006, 2007, 2008, 2009


Specific thematic approach : sustainable energy


Based in Northern Europe: Hjortshoj – Denmark

Funded below €100.000

9. Mediterranean information office for Environment, Culture and Sustainable Development MIO-ECSDE

MIO-ECSDE is a Federation of Mediterranean Non-Governmental Organisations (NGOs) active in environment and development issues. It functions as a technical and political platform and umbrella for NGO intervention in the Mediterranean scene. The ultimate goal of MIO-ECSDE is to promote Sustainable Development in a peaceful Mediterranean. MIO-ECSDE’s main activities are networking, capacity building, drafting, promoting and presenting common NGO policies and positions, promoting partnerships, raising public awareness, participation and consensus building, education for sustainable development (ESD), promoting the cultural dimension of sustainable development, facilitation of Mediterranean stakeholder networks, publications, etc.

MIO-ECSDE can be classified as follows:


Funded in 2006, 2007, 2008, 2009

Regional action domain : Mediterranean

Multi thematic


Based in Southern Europe: Athens – Greece


10. RREUSE Reuse and Recycling European Union Social Enterprises Network

The Reuse and Recycling European Union Social Enterprises Network was founded in 2001 by 10 national social economy federations with the objective to promote reuse and recycling activities as a way to preserve energy and resources and to promote social and economic integration. The RREUSE work programme is focused on the following issues: revision of the WEEE (Waste Electrical and Electronic Equipment) directive, the implementation of the Waste Framework Directive (WFD), the

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implementation of the Energy using Products (EuP)directive, the Action Plans on Sustainable Production and Consumption and Sustainable Industrial Policy (SCP – SIP), the VAT revision for environmental services and biowaste.

RREUSE can be classified as follows:


Funded in 2006, 2007, 2008, 2009


Specific thematic approach: reuse and recycling in social economy

Focus on policy development

Brussels based

Funded below €100.000 and below 35%

11. EUROPARC Federation

EUROPARC represents and unites national parks, regional parks, nature parks and biosphere reserves across the continent, with the common aim of protecting Europe’s unique variety of wildlife, habitats and landscapes. The EUROPARC Federation seeks to support and enhance the management of Europe's natural habitats and cultural landscapes through an ambitious work programme. Rooted in international co-operation, networking and skill sharing, the Federation looks to strengthen its mandate through strategic partnerships, greater collaboration and an important lobbying presence with European institutions. Further project development will seek to ensure the organisation and its members are fit for purpose in a challenging and changing natural, political and economic environment.

EUROPARC and T&E can be classified as follows:

EUROPARC T&E Experienced with the previous funding system and with LIFE+

Funded in 2006, 2007, 2008, 2009 EU-wide action domain

Specific thematic approach : nature parks Specific thematic approach: transport Focus on policy development

Northern Europe based : Grafenau -Germany

Brussels based

awarded less than €100.000 and less than 35%

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O ANNEX O: DETAILED ANALYSIS OF NGO OPERATING GRANTS

O.1 General Aspects of the LIFE+ Operational Grants Intervention

O.1.1 Programme Effectiveness

Results of the NGO consultation

The operational grants of 2007 and 2008 have been used mainly for policy implementation and policy development. In Table O-1 the budget distribution for the whole of the NGOs is presented.

Table O-1: Budget Distribution of the Operation Grants

Allocation of the operational grants %

Environment policy development – giving policy advice to the Commission through position papers, participation in public consultations and/or participation at official meetings.

27.1

Implementation of environment policy and legislation - Production of position papers on analysis of the EU legislation and its implementation at national or local level and of the environmental situation in the EU, participation in expert groups on implementation or policy review groups.

28,2

(External) capacity building of members (local or national organisations) and partners (small regional or local associations). External capacity building work ranges from targeted outreach work, networking and information sharing, and increasing familiarity of targeted NGOs/partners with implementation of regulations and solutions in specific / local context. Activities relating to training have been grouped as a separate category (environmental education) reflecting the specific award criteria.

16.8

Environmental Education - training experts and decision makers from administration, industry and network members on environmental issues, awareness raising campaigns and knowledge enhancement activities.

9.8

Enlargement and Third Countries – specific activities carried out in candidate countries and third countries.

7.9

Internal Capacity Building - all of the capacities that are associated with the internal functioning of the organization. This could relate to organisational structure, staffing, strategic approach, financial management, evaluation and reporting, technical competence.

10.2

Results of the interviews with Commission stakeholders

We have received very limited inputs from Commission staff to this specific issue. This is probably mainly due to the fact that the vast majority of the officials that were interviewed have not actively worked with NGOs in the recent past (although most of them were involved in the selection process).

One of the interviewed stakeholders explicitly stated that the contribution of the NGOs to policy should be discussed with the policy units instead. The general impression of this official is that the NGOs have a contribution to make but that it would be very difficult to evaluate what this contribution would have been in the absence of EU funding - he cannot confirm that this funding is really essential.

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He has also pointed to three important roles the NGOs can play:

Some NGOs have a specific scientific expertise. For instance, Birdlife has thousands of observers around the world, and provides important data on bird migration. In their field, they are world leaders on facts, not just opinions.

In general, DG ENV has a good working relationship with NGOs, partly because DG ENV and the NGOs share some objectives. The NGOs provide useful inputs to DG ENV in its discussions with other DGs of the Commission.

The main rationale behind the setting up of the programme was the big discrepancy between the lobbying resources of industry on the one hand and of the groups representing environmental interests on the other hand.

One respondent has formulated the last point as follows: the NGO programme can be seen as using community money to make sure that all voices of society, all interested parties, and all viewing points can be heard.

Another official referred to her experiences with the NGOs she usually works with. She considers these NGOs to be very constructive (even if she does not always agree with their positions), especially in the field of awareness raising. Their monthly newsletters and some campaigns have helped to raise the profile of the issues they work on. These NGOs also provide a counterbalance to industry, provide comments on draft policy papers, attend expert groups and committee, are actively involved in the follow-up of some Commission Action Plans and undertake some research and studies. They also provided support through data provision and information. The NGOs’ efforts to participate in events and meetings are very high. Their membership is wide and they provide a good channel for information. In her view, they sufficiently support policy development and implementation.

In the view of this stakeholder, these NGOs are thus useful and they need the funding.

However, this interviewee also admits that the results are not measured and that the final impact of the NGOs activities is not well known – she thinks a complete cost-benefit analysis of NGO involvement is not possible. She also thinks that it is important to relate the funding of the NGOs to the themes of the 6th EAP. However, the themes of the 6th EAP are very broad, and there is scope for higher detail and better focus.

This official cannot think immediately of other than financial measures that could be used to strengthen the participation of NGOs in the dialogue process in environmental policy making and implementation.

Concerning the specific issue of NGOs working on standardisation, one stakeholder has pointed out that, historically, this process was completely dominated by industry. However, this process is more and more integrated into environmental policy (carbon footprinting, energy efficiency of buildings, environmental labelling). 2 stakeholders reported that there is only one NGO with the necessary capabilities to work in this field. Standardisation is very technical, unglamorous work, and it is very difficult for this NGO to receive any sort of funding from other sources than Life+. This raises the question whether NGOs working on standardisation should not be taken out of the general funding, and become subject to a dedicated support mechanism.

With respect to the EU added value of Community Funding, our respondents have pointed out that this follows naturally from two elements:

the Member States will not help the NGOs to develop EU Policy

no national NGOs are funded by Life+.

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O.1.2 Effects of the simplification exercise

Since 2007, the structural funding for NGOs has been incorporated in LIFE+, replacing the funding mechanism from Decision 466/2002/EC of the European Parliament and of the Council laying down a Community action programme promoting non-governmental organisations primarily active in the field of environmental protection.


For the majority (62%) of NGOs, the new system had no significant effects on the effectiveness of the NGO. However, it decreased the effectiveness for 20% of the NGOs, because the work outside Europe cannot be included anymore: e.g. the cooperation with countries like Turkey or Russia had to be stopped because no other funding was available. Also in Croatia activities diminished.

Not all NGOs agree that the simplification of the regulation has decreased the administrative burden: for merely 26% the burden decreased. The decrease is attributed to the removal of the requirement for mid-term reporting.

However, for about 35% the administrative burden remained the same and for 38% it even increased. Many NGOs emphasise that the administrative effort needed from them is still too high, because, in their view:

The new and extra requirements for the auditing cost more and also demand extra labour internally. One NGO reported that these costs have increased to 5.000-10.000 € from approximately 2.000 € in the past. A better combination of regular auditing (NGOs have their national auditor that approves the accounts every year anyway) and the extensive audit visits could save costs both for the programme and for the beneficiary74.

NGOs are very frequently audited, and the programme is very frequently evaluated. Some respondents consider the individual audits as a useful idea, but would prefer auditing during the funded period and not afterwards. I.e. not as an evaluation tool but as a supportive action leading to recommendations.

Because national members are no longer eligible, less centralised NGOs that distribute more EU activities to their members had to restructure in order to make costs of member staff eligible, or they have to follow subcontracting rules.

Each year all the official and financial documents must be provided. A suggestion to simplify this was to put administrative documents online once or for a certain period. For instance, at DG Research’s Framework Programme, it is possible to have a ‘period of validity’ for a number of years. To receive a PIN code, the NGO has to send in statues, audited reports, etc. Once approved, the NGO only has to enter their PIN code and can focus on the content of its proposal.

NGOs have the impression that they are constrained to score on each of the 5 criteria (policy formulation, implementation, integration, awareness raising and international aspects) while they feel that they should be able to focus on a selection of these criteria, and not be forced to spread their resources too thinly over a wide range of activities. For instance, awareness raising was considered less relevant for this programme by some NGOs. If activities could be focused and targeted towards achieving specific objectives, the impact of the work of NGOs, and hence of the grants, would be enhanced.

Especially for smaller NGOs, a substantial part of the budget is still needed to complete the requested forms, time sheets, designate budget towards topics, etc. (some mention 0,5 FTE). The

74 An important issue to consider is that the scope of the audits is not always the same: the yearly account audits cover all NGO expenses, while the LIFE+ audits focus on the eligible costs.

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above mentioned extra administrative costs are (logically) not considered a proper way of spending the money.

The majority of the NGOs think the new procedure does not offer more legal certainty or a higher predictability. The fact that the budget is limited to the amount received in the previous year has increased predictability, however, this measure is mostly not supported by the NGOs. On the other hand, the predictability decreases the later the decision is communicated. Most NGOs (53%) do not experience any significant difference regarding predictability between the old and the new procedure.


Most interviewed stakeholders have not been consulted in the drafting process of the LIFE+ Regulation, and could therefore not comment on the results which were expected when the NGO programme was integrated into the LIFE+ Regulation.

One of the Commission officials explained that, compared to the previous Regulation covering NGO funding, more flexibility was introduced in the Regulation. This allows DG ENV to change the implementation from year to year based on past experience.

Another Commission official pointed out that the concept of LIFE+ was not really about simplification. The changes in the administrative system compared to the previous programme do not follow from the changes in the LIFE Regulation. Indeed, the financial issues and the implementation rules are determined in the Financial Regulation, which has recently been amended. LIFE+ is not very specific on the financial aspects.

The same official recognized that the current administrative burdens could be reduced. However, some guarantee is needed that the public money involved goes to reliable organisations and this guarantee is provided by the reporting and administrative documents. In order to reduce the burdens for NGOs, the Financial Unit already has produced a standardised document. For the NGOs that apply each year, this respondent claims that it is relatively easy to produce the required documents. Some NGOs (especially first-time applicants) face indeed problems with the complexity of the system, but if they have questions, they can communicate with the Financial Unit. However, according to this interviewee, there is no possibility to reduce the required documentation.

Another Commission official reported that some NGOs have changed their administrative procedures (including full accounting systems) thanks to the advice they have received from their auditors. In this sense, LIFE+ has provided an incentive for them to become more professional. The audits have led to a clear view on eligible and non-eligible spending, and the managerial structures in the organisations are stronger and more stable.

Another respondent emphasised that the yearly audit makes NGOs more transparent, and thus more acceptable for the public opinion.

Finally, concerning the programme length, which evolved from 3 over 5 to 7 years, one stakeholder pointed out that if some problems are not clarified (such as the “costs outside the EU”), problems remain blocked for a longer period.

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O.1.3 Effects of the consolidation exercise

Activities outside the EU

The consolidation of the NGO operating grants with the other elements of the LIFE+ regulation had an impact on the eligible costs: costs occurred for activities outside the EU are no longer eligible for funding.


This creates problems for a large number of NGOs, only 15% of the NGOs consider this fair enough

Most beneficiaries report to have members in non EU countries or links with international networks with which co-operation is required. For them, the financial limitation regarding the exclusion of expenditure incurred outside the EU causes administrative problems and reduces flexibility in how the operating grant is used. Only organisations that are not highly dependent on the LIFE+ funding are able to manage this restriction. However, it causes a high administrative burden and reduces the organisation's ability to use the grant flexibly.

For some NGOs funding for extra EU-activities is not always readily available, particularly for policy work, it depends very much on the specific issue. NGOs are for many other grant schemes not eligible or the country is not eligible.

According to one third of the NGOs this criterion has led to more administrative burden, and for almost half of the NGOs it even reduced the efficiency of the activities.

The negative impact is especially relevant in case of policy implementation issues: these activities become more efficient if a larger target group can be reached, including non EU countries as well. A lot of EU environmental policy is connected to, influenced by or has a bearing on a multilateral context outside of the EU - it features in many relationships of the EU with third countries and in UN negotiations the EU engages in. Following through on EU policy development cannot be entirely disconnected from activities outside the EU, so a change in activity for the NGOs is not possible.

This measure does not seem to reflect the objective of the grant scheme to support enlargement. The grants still aim, in part, to support work outside the EU, as reflected in the evaluation criteria, where an NGO is asked to list the activities outside the EU. However the regulation makes these activities ineligible. This does present an inconsistency.

In particular, the following negative impacts were mentioned:

If an NGO has the mission of sharing best practices, it wants to do this as widely as possible. It also needs to be considered that certain aspects like air pollution by the disposal of chemicals in non-EU countries can have an effect on the EU member states: there is a need for knowledge and support to non EU member states as well.

Some NGOs have to participate more and more in international activities (ISO, IEC, UNFCCC), in which the EU has a direct influence. To do so, the NGO now is not able to use e.g. a US-expert for an ISO-meeting taking place in the US. That strips the NGO from opportunities to substantially reduce costs (travel, per diems) and travel carbon. Other sources could be used for funding that, but that reduces the funding available as matching funds for the DG ENV grant.

NGOs must undertake unnecessary efforts to make costs eligible: rather than directly going ahead with activities, they have to be done through EU-based agencies or organisations - e.g. employing people in a EU 27 country and having social tax problems or paying extra fees for EU 27 travel agencies. This is one of the examples, in which the

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rule defeats the cost-effectiveness principle which underlies EU grant-making, because the use of EU 27 intermediaries incurs additional expense - and offers less variety of choice and less activities in the end.

NGOs working in EU and Non-EU countries as 1 networked organisation of equal groups now can not directly allocate funds for the non-EU countries for their local jobs any more. They can not “act as one”. For the non-EU members the NGOs can pay only some direct international expenses, otherwise they have to look for other funding schemes and sources.

The environmental action program now needs to be split up for the EU members and non-EU members (not only in terms of place of the activities, but also participants, communication work, etc.) Also for matching funding the NGO has to to distinguish between EU and non EU work.

It was suggested by some NGOs that a certain (limited) percentage of the costs for non-EU activities would be eligible, when they are clearly linked to the objectives of the work programme. In general, 5% is already considered a good compromise. The 5% could be used for translation and seminars to create a dialogue between the stakeholders / government and networking.

Another suggestion was to make costs incurred in neighbouring countries, with a transboundary environmental impact on the European environment, eligible. Especially for policy implementation, NGOs would be happy to involve enlargement or candidate countries. These countries are already internally implementing EU legislation and want assistance. For instance Turkey is working on a better building regulation (EPBD) and on ecodesign. Ukraine is also interested.


One of the interviewed Commission officials explained that the principle of territorial limitations was introduced because Life+ is an internal instrument to the EU. This was not at first understood by the NGOs. Therefore, a flexibility rule was introduced: costs are eligible as long as they are incurred in the EU (for instance, a plane ticket bought in the EU). However, this can have perverse effects. For instance, in order to fund a project in Russia, an NGO may pay a consultant in the EU in order to make the costs eligible.

However, this respondent thinks that more opportunities for international work should exist: environmental issues are by their nature cross border problems where NGOs can play an important role. NGOs contribute to the promotion of EU legislation in third countries (for instance, through the exchange of good practices). In this view, it would be better if, once an NGO has been found to be “mainly European”, all their activities (including the international ones), were eligible for funding. The difficulty would then lie in where to draw the line between (a) European NGOs with a lot of international members on the one hand (b) international NGOs with a European focus on the other hand. 5 to 10 applications per year are in this grey zone. In the current situation, if an NGO has a lot of international activities, it has to keep them all out of their work programme because these are ineligible expenses.

One of the respondents pointed out that the fact that activities outside the EU are not eligible is actually in contradiction with one of the assessment criteria e.g. working in neighbouring countries or accession countries. He therefore thinks that these costs should become eligible.

One stakeholder pointed out that the interpretation of what constitute “costs outside the EU” is not clear in Life+. None of the interviewed stakeholders has commented on the potential use of the Instrument for Pre-Accession Assistance (IPA – see Section D.2.3) to alleviate funding problems related to network capacity building for organisations with members in non-EU countries.

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Awareness raising

The awareness raising activities are positively appreciated by most NGOs (85%) as complementary to the communication efforts of the NGOs and/or as an opportunity for the NGOs to frame their own communication efforts in a larger picture. None of the NGOs have experienced the awareness raising activities organised by the Commission as substantially contradictory to the message communicated by the NGOs.

However, one third of the NGOs think the funds would be better spent on communication initiatives by the NGOs themselves. It was mentioned that the Green week formula is overworked and tired, and it needs refreshing. Events such as Green Week are, in principle, considered worthy, but are by some NGOs also considered as falling short of the aim. They do not offer sufficient outreach opportunities, speaking only to the 'converted'. It was mentioned that members are generally not attracted to participate and do not see participation as an advantage. The current participants are considered a very small part of EU civil society, and mainly from inner circles. Using that money to support NGOs in their outreach work on EU environmental policies, including organising public debates at the national level, would have more impact according to some NGOs. On the other hand, NGO communication initiatives could be done more in partnership with EC.

None of the interviewed Commission officials has provided any comment on this specific issue.

O.1.4 Eligibility criteria regarding member organisations activities

As from 2008, changes related to the incorporation of the programme in LIFE+ have limited the scope for beneficiaries to involve their national member organisations in carrying out the activities of the work programme since the Financial Regulation, as interpreted by DG Budget, does not allow transfers of funds in the case of operating grants.


On the one hand, activities in at least 3 EU members states are required, but eligible costs are limited to the applicant NGO. Only 24% of the NGOs appreciate this as fair enough, and consider that under application of the subsidiary principle, sufficient subsidies can be obtained from the national authorities.

However, 82% of the NGOs also mention a negative impact of this change. Almost 40% of the NGOs consider it has negative impacts on their efficiency, of which 30% mention it has lead to less funding for the total of the NGO and its members. For 70% of them, this has lead to more administrative burden.

The following reasons for reduced efficiency and effectiveness were given:

Some activities need the support of member organisations, especially when they are aimed at or connected to the implementation of EU legislation at national level. Additionally, a proper advocacy campaign on European policy formulation also requires the support of members at national level, since contacts must be established with national representatives of the EU Council and members of the EU Parliament. Member organisations often have a better knowledge of who these people are, what is their individual background and how to convince them.

This has led some NGOs to exclude some activities from the budget and the work-plan of the NGO grant. It would be preferable to be able to offer support to member organisations (e.g. to attend meetings etc.) and to occasionally engage them to deliver or participate in some activities (e.g. developing case studies or providing expertise). The requirement to engage them as subcontractors through a formal process is cumbersome and not always appropriate.

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The change has reduced the ability of the NGO to function as a network and to implement activities at national level. In some CEE countries subsidies are not available from national authorities, and EU funding opportunities at national level are difficult if not impossible to tap for most NGOs.

By some NGOs it is considered more an identity issue, whether NGOs define themselves as a (franchise) Network or Association. Most of the Green 10 and also Justice & Environment started bottom up, grouped and affiliated as an issue network from already existing strong national groups. The members of FoE, EEB, Birdlife and also J&E have a “dual identity”: their own national identity and at the same time the holders of a strong EU-level brand. (NB the EU and the Member States also act this way.) On the contrary, the present Operational Grant logic expects a top-down structure, a central office and national branches with small national identity, one single central bank account, etc. Administratively it’s feasible, but it caused some identity issues, and meant more administrative burden than benefit.

Large international, centralized organizations are now advantaged. This enables them to expand into new regions like multi-national corporations at the expense to indigenous NGOs.

As a general conclusion, many NGOs (especially the ones with a rather small secretariat) claim that the involvement of members is crucial to their work, including policy formulation and implementation that are both based on experience from as many countries as possible. To get inputs from the members, it is important to be able to pay them for continued EU policy level activities that they cannot afford themselves.

Although members are no longer eligible, the possibility has been created that they act as a subcontractor.

There are no detailed legally binding rules on subcontracting but certain thresholds have been suggested for guidance purposes75:

NGOs are allowed to follow their own procedures, as long as the general principles are respected. However, a clear guideline on the above procedures has been requested by some NGOs.

Some NGOs now involve their members as subcontractors, however with a loss of efficiency. Without the need for subcontracting, larger national events would have been organised and more NGOs could have been involved in policy development and implementation. According to the NGOs, a clear difference exists between subcontracting (in the true sense, open tenders etc....) and other relationships between partners, such as between a networking NGO and its member organisations, or between leads in a project and otherwise equal partners. Other NGOs have restructured their organisation and included some members as own staff, which increased their administrative costs.


Most Commission stakeholders we have interviewed did not have a clear cut opinion on this specific issue, or felt they were not well placed to answer this question.

One official acknowledged that national member organizations stand closer to the citizens and are needed to increase the success rate of the program.

One single official emphasized that the purpose of the NGO programme is to support NGOs if they contribute to policy making. In the current situation, individual members indeed receive fewer benefits because the focus is on the activity of the “holding” NGO. According to this official, the

75 http://ec.europa.eu/environment/funding/pdf/tendering_guidelines.pdf

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impact on the efficiency of the activity of the NGOs is not clear however. In this view, the NGOs that contribute to real implementation should receive their money through other Life+ funding such as Life Nature. However, as the survey has shown that NGOs also involve their national members actively in policy development, it is not clear to what extent this would solve all problems that have been raised by the NGOs.

Another official pointed out that the reimbursement of costs of partners and member organisations is not in line with the Financial Regulation. NGOs can still distribute money to their members through subcontracting, but then they need to respect the rules for competition required by the Financial Regulation (Article 120 of the Financial Regulation and Article 184 of the Implementation Rules). The underlying rationale for this restriction is that the Commission does not have the instruments to audit the books of members and partners: it can only ask the books of the beneficiaries.

O.1.5 Eligibility of the NGO structure


72% of the NGOs agree with the provision that NGOs that only have individual members are ineligible, because this is necessary to select NGOs with a European, non strictly national vocation.

Almost 10% of the NGOs however consider this is not correct because NGOs with individual members can also work with European themes, and 12% of the NGOs considered this requirement deprives NGOs from funding where the national funding mechanisms are sometimes inadequate. While this program is rightly focusing on EU wide activities, national groups play an important role in EU policy development and certainly in implementation. An additional instrument may be needed to allow national organisations access to EU support where it is hard to come by at the national level.

Some NGOs express their concern that member organisations of a network should be genuine organisations that represent something. Some NGOs take care to evaluate their network members thoroughly, because it is sometimes too easy to become ‘member’ of a network. A wide and collective approach should be created to influence policies. A critical mass of people is necessary to establish a network. The degree of internal democracy could be a good indicator to evaluate NGOs to be funded. One NGO proposes to include independent NGO insiders in the Selection Committee to give expert opinion on the nature of the NGOs.


There was a clear consensus amongst the interviewed Commission stakeholders that this criterion should be maintained. The following reasons were given:

If this criterion was not added, it would be sufficient to have three people from three different countries to have an international NGO. Therefore, this criterion is necessary to include only broad-based and representative NGOs.

If you would allow "individual membership" organisations, there is a risk you will end up with national or regional NGOs. However, the objective is to add value to the European dimension of their activities

If you want NGOs that can communicate messages from and to civil society, an NGO that would only allow individual members would not meet the quality criteria.

One stakeholder has also pointed out that, in the initial concept of the instrument, the target group were grassroots organisations. Things have changed since. There is an increasing, if limited, number of applications coming from groups that are formally NGOs, but whose membership more resembles that of professional sector organisations (landowners, hunters, water professionals,

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social economy). This is very different from what the programme was intended for. In his view, such organisations can provide valuable insights and that they can be useful for the technical Units. However, for this type of organisation, EU money is not an issue of survival: it is rather an instrument that gives them a higher legitimacy and green credentials. Several NGOs have questioned whether this type of organisation should be beneficiaries.

O.1.6 Eligibility of NGOs active in at least 3 MS


Half of the NGOs consider 3 Member States is not enough to assure a sufficient EU coverage. Less than 20% of the NGOs considers it is sufficient, and for another 16% it doesn’t matter in how many Member States an NGO is active, as long as he tackles European wide topics or problems.

It was suggested an NGO should be active in at least 5 to 10 member states because:

With the increasing number of NGOs and of EU countries, three countries (representing just over 10%) is not an adequate criterion to ensure the necessary networking. For effective monitoring and implementation of EU policies, strategies and legislation it is necessary for an NGO to be truly representative and present in the majority (if not all) of the countries in the region, where it is active. Three is not enough to have a well functioning network.

Policy formulation and implementation activities must be fed by field experience and difficulties. There are strong discrepancies across EU Member States and there is a need to be present in a variety of Member States to benefit from a panoramic view. Geographical coverage is of utmost importance for policy activities to succeed. NGOs should be able to work (and to mobilise organisations) in more countries if they want to be effective in what they are doing.

On the other hand, the criterion should also not be too high, because then NGOs working on specific or regional issues such the Baltic sea, coastal issues, specific landscapes such as mountain issues or river issues would be excluded. These are cross-boarder issues but they don’t cover that many countries. According to some NGOs it should be acceptable for an NGO in this programme to have e.g. a regional focus if this tackles EU wide topics. They state it is more important to show the European wide impact of the work-plan rather than to impose an arbitrary minimum on the number of countries.


There was a broad consensus amongst the interviewed Commission stakeholders that being active in three Member States is the minimum requirement.

While at least one official expressed the view that this condition should be more demanding, another one reckoned that three member states is a good compromise. If the threshold was put at, say ten Member States, the proposals could become too general. It is unlikely that Austria for instance would be interested in working on environmental problems linked to the Baltic Sea.

One official also thinks that this criterion has led to artificial temporary unions of NGOs that work on completely unrelated topics, which has hampered the quality of their proposal. Another interviewee has confirmed that some new NGOs have been created as networks of national NGOs with the main purpose of becoming eligible for funding. However, he does not think this is negative, because it has created an incentive for NGOs to become more efficient and has lead to better networking. If the grouping is really artificial, this will become apparent in the quality of the application.

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O.1.7 Eligibility of European NGOs


The majority (almost 60 %) of the NGOs agree that it is good that international NGOs are not eligible:

to prevent that European funds are being spent on non-European issues as well.

this is necessary because making a distinction between eligible European and non eligible non European or international issues is too difficult to make.

About 19% of the NGOs consider that if a distinction can be made between European and non European activities, there is no reason to exclude the international NGOs.

One NGO considers it depends on the topic: some topics have worldwide impacts including on the European territory. In these cases funding international NGOs would be beneficial, even if some of the activities are not strictly linked to European policy.

However, the exact definition of an international NGO is still not clear, and NGOs are evaluated against this criterion on a case by case basis.


An important practical problem with this criterion is the lack of operational definition of what constitutes a “European NGO”. In some subjects (such as climate change), NGOs have a very international scope, and the concept of “European NGO” should be better defined.

The interviews with the Commission stakeholders have revealed the following rationales for this criterion:

As the funding is paid for by European taxpayers, this should only benefit NGOs whose principal activity is in Europe.

This condition has been added in order to avoid financing foreign NGOs that have their own agenda and who could lead counterproductive activities behind the scenes – this could be the case in fields such as fisheries, GMOs and authorisation for chemicals.

This criterion helps to narrow down the number of applications.

However, there is no consensus amongst the interviewed Commission officials that this argument should be maintained. The interviews have revealed the following counterarguments:

Any NGO that covers at least three countries of the EU during at least two years could be useful to the Commission.

It is true that some international NGOs may have hidden agendas such as protecting specific industrial interests in their home countries. However, one never really knows the actual agenda of an NGO. They can nevertheless still provide a useful input to environmental policies.

A more specific problem is whether NGOs legally established in EFTA States participating in the EEA, candidate members, Western Baltic countries included in the Stabilisation and Association Process should be included or excluded from the NGO funding. The opinions expressed by the Commission officials were very diverse:

One official responded that this is a political evaluation that needs to be made and that therefore this question should not be addressed to Commission officials. This official also pointed out that EFTA states can already choose to participate in environmental programmes. If they do not participate in Life+, this question is not relevant.

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A second official reminded that the funds are already very scarce, and that he did not see any advantage that would be obtained from such an extension (without prejudice regarding the quality of the NGOs in these countries)

This stand in contrast with the position of a third interviewee, who stated that if a higher budget would be available, his answer would be yes. The NGOs in these countries need to be prepared for possible future membership of the countries. The NGO involvement in Life+ is a good tool to make EC policy understandable. However, in reality, there are budget constraints. A well established NGO from Western Europe will always perform better than an NGO from a candidate member. If you put them on equal footing in the selection procedure, a lot of proposals coming from accession countries will not stand a chance. In this official’s view, it could be interesting to get NGOs from these countries involved in the activities of existing NGOs. This tool can be used to work together with accession countries and to transfer knowledge in order to avoid reinventing the wheel. The main problem is how to include the accession countries in the process so that they can profit from the experience of well-established NGOs76.

A fourth stakeholder also expressed the opinion that it would be better if the instrument would include some work outside the EU. This is especially the case for work done in neighbourhood or pre-accession countries if the NGOs help the applicant country to implement the EU acquis. It is less clear whether beneficiaries outside the EU should be allowed.

O.1.8 Eligibility of NGOs that are active for more than 2 years


The large majority of the NGOs (94%) agree on the provision that an NGO should be legally constituted for more than 2 years unless derogation is obtained.

In general, it is agreed the 2 years are needed

Because the evaluation depends partly on the performance of an NGO in previous years (63%)

To be sure that the NGO will be stable enough to guarantee that the funds are well used (59%)

One NGO confirms that in practice the derogation is used, allowing fair opportunities for new initiatives. It is mentioned that it is particularly crucial that the members are stable.

However, 6% of the NGOs think this is too large a barrier for new NGOs and only protects the funding of existing NGOs.

One NGO states that supporting new NGOs is a good thing, but that other instruments should be designed for this purpose, above the existing operational funding programme.


There was a clear consensus amongst the interviewed Commission officials that 2 years is the absolute minimum - this criterion ensures that applications are proposed by people with experience. It was remarked that Life+ is not a financial instrument for start-ups! Indeed, an essential objective is to contribute to EU policy, and it is not clear how one can contribute to policy if one has no experience with it. Nevertheless, a young NGO can score better on the potential for organisational development (which counts for about 15% of the points in the evaluation procedure).

76 Actually, such a tool already exists – see the Environment Forum discussed in Section D.2.3.

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One official concluded that, if the objective is to help new NGOs, a separate instrument is needed.

O.1.9 Need for other eligibility criteria

During the interviews with the Commission stakeholders, the question was also raised whether other criteria were needed to prove the “primarily European” nature or the European added value of the eliged NGOs.

One of the interviewed stakeholders thinks that field experience of the member organisations is also an important criterion. The purpose of the instrument is indeed two-fold: (a) to provide the Commission with information from the field concerning the topics that are dear to the Commission (b) to provide the field players with information coming from the European level. It is through this combination of top-down and bottom-up communication that NGOs can be influential.

Another stakeholder proposed to include the Commission’s working experience with the NGO as a criterion. He explained that, according to the guidelines, an evaluator is only allowed to judge only the quality of the current proposals. This can cause problems if the evaluator knows from past experience that some NGOs present brilliant proposals but then do nothing productive with the money they receive. This official thinks the results of past grants should be taken into account in the selection of the proposals.

O.1.10 Efficiency of yearly grants and timing

The LIFE+ instrument provides yearly grants. This means every year a new application has to be submitted, which requires a yearly administrative effort and every year a period of financial uncertainty is created. On the other hand, if an NGO is not successful, it has the possibility to re-enter the programme the following year.


Only about 12% of the NGOs (4 NGOs representing about 8 % of the funding budget of 2007/2008 and 3% in 2009) would maintain the yearly grants (of those, 4, 3 did not receive funding in 2009, and 1 is now going to be closed down due to significant financial problems).

The NGOs defending the yearly grants argue that

the insecurity of annual funding is off-set by the ability to apply again after one year with a new budget.

there is already a bias towards Brussels based NGOs, and multi-year funding would only solidify the strangle hold that certain NGOs already have on Commission funding.

yearly grants allow also a large degree of flexibility for organisations with small financial or organisational capacity, i.e. to be able to develop without having to commit at the start for several years.

Most NGOs (85%) however plead for a periodicity of 2, 3 or 5 years: more than 24% opted for 2 years, 57% NGOs opted for 3 years (representing more than 60% of the budget of 2007 and of 2008), and 6% (2 NGOs) opted for 5 years (representing 10 tot 12% of the budget of 2007 and of 2008).

Yearly grants are judged not efficient by the large majority of the NGOs because of the following reasons:

They create a yearly administrative effort (76%)

They create a yearly period of financial uncertainty (76%), which may

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affect recruiting and retaining high quality staff : the uncertainty of how to work from year to year adds stress to the staff and is experienced as one reason why staff look for jobs elsewhere

affect the continuity of the work programme: for some NGOs the work programme is put ‘on hold’ until they have confirmation that they will receive a grant.

They are not in line with the objectives of the LIFE+ grants to provide for core funding of long term activities.

The policy development is multi-annual, and so is the planning of the NGO work. Cutting the grants after 1 year would mean cutting something that has an organic lifespan of more than 1 year. This would seriously decrease the efficiency of the grants: the outcome would be lost.

The NGO activities depend on each other or are the continuation of one other. Therefore, if the funding is not granted for a certain year, it has not only financial, organizational, but also professional consequences on the NGOs.

Policy aspects of the NGO work are inherently focused on long term objectives which are obviously difficult to assess in a year’s frame. A multi-annual framework agreement like the ones adopted by other DGs could be an advantage, since it would give NGOs more certainty about their future.

The short-term nature of the funding is restrictive and prevents any real planning for the longer term: members activities need support, build up and planning over a longer term generally, which means the NGOs are unable to support in any practical terms. Also, because NGOs often rely heavily on the grant to survive, the uncertainty and degree of speculation involved is experienced as counter-productive and damaging.

They do not allow for a clear visibility of the sustainability of results

One NGO suggested a sort of multi-annual funding scheme, or possibly an overlapping “one window” reporting and submission method, which might serve better the needs of the NGOs. The present operational grant covers ongoing, continuous work, the very mission of the supported NGO, but is somewhat mixed with a project-funding approach.

In an overlapping method the report and description of the continued activities in the next year’s work plan could be evaluated in one step and also followed better and more transparently. A 2 year, or 20 month scheme, with a calendar year work-plan in the middle and 4-4 months on the "edges" would be suitable, calculable and budgetable.

On the other hand, it was mentioned by more than 27% of the NGOs that the scheme should still allow for some flexibility and give the possibility to newcomers to get into the funding scheme. The system should also avoid that an organisation which was refused the grant one year would be excluded in subsequent years.

Most NGOs (about 60%) do not experience any significant difference in time before a decision by the Commission is communicated. However, more than 23% think that the time for decision taking has increased under the new Regulation, and less than 18% think it has decreased.

The timeframe in which an NGO knows whether is will receive the operational grant or not is in general very important to all NGOs, impacting their planning and their liquidity and cash flow. It is preferable to all NGOs that the decision is communicated in January. Now this is usually only in (the end of) March, forcing some NGOs to postpone certain activities that depend on the LIFE+

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funding, or seek for matching funds until later in the year. Also decisions on staff and budget depend on this, and are a high risk for smaller organisations.

Most NGOs would be willing to submit the application earlier in order to get the decision earlier.

The liquidity problem is a big issue for NGOs. If a continuously operating NGO is considered, working on a multi-annual programme, they have to pre-finance almost the total funding amount before they get the final payment:

Decision: March

Contract: May/April

First payment: June (60%)

Financial report: March year after

Final payment: June year after: this means that on 31/06 the NGO has pre-funded 90% of the budget:

40% of the previous year

50% of the current year (6 months)

The rate of 90% is too high, and should be brought back to at least 70%. This could be achieved by:

Increasing the first payment to 80% instead of 60% >> 20% of previous year

Realising the final payment earlier, e.g. on 01/05 (which implies earlier decision taking: January in stead of March) >> 33 % of the current year (4 months)

Realizing a 2-month shift in the deadlines for application, decision communication, contract and payment hence would have several beneficial effects. Not only it would fit better into the NGO budget planning, but also it would allow for less liquidity problems (pre-financing of 73% to even 53% in stead of the current 90%).

Another way of addressing the liquidity problems would be to provide for multi-annual funding: see below for a discussion of multi-annual partnership framework agreements.


One of the interviewed stakeholders referred to the Financial Regulation, which includes provisions on multi-annual partnership framework agreements (see Annex Q, Section 7.20). The possibility to include this type of agreements in the Life+ Regulation has been discussed when the new Programme was conceived. However, during the evaluation of the previous programme, the views were split and the overall weight was negative. There were two main reasons why, at that time, NGOs were not interested in this option. First, in a multi-annual framework, if an NGO misses the train, it will miss it for several years in a row. Second, in such a framework, NGOs would have to sign a declaration that they had common objectives with DG ENV. Some NGOs though this would affect their independence.

Concerning the specific issue of independence, this official pointed out that the concept behind the NGO funding under Life+ is that the Commission creates financial dependence so that the NGOs can be operationally independent. This allows NGOs to be part of the policy process. The official also admitted that annual funding can create a lot of uncertainty and specific cash flow problems for very small NGOs. He also understands that job security for NGO staff is an issue and that NGOs need to be able to offer good working conditions in order to recruit and keep qualified staff.

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One specific drawback of multi-annual funding that was mentioned was that it could make life “too easy” for the NGO who obtain the funding. It was also pointed out that the current system does not impose an excessive administrative burden on the Commission services.

One official argued that, while it is true that, with a three year funding, some organisations would be excluded for three years, from the Commission’s point of view, this is not a big disadvantage, as the best NGOs would be selected anyway. It is only at the bottom of the list that there is some discussion on whether the best candidates have been selected.

For the NGOs that are systematically at the top of the list, the situation is ambiguous. On the one hand, a multi-annual programme would allow the NGOs to improve their planning. On the other hand, the “better” NGOs are already fairly sure that they will be selected in the annual round anyway. In this respondent’s view, the main advantage of multi-annual funding is that it would allow them to save on yearly application procedures and that they could offer better contracts to their personnel. Indeed, as an NGO can only be sure of the funding when the final agreement has been signed, some NGOs do no start the recruiting procedures for new personnel until they have received the first instalment (which takes place in the middle of the year). The interviewee also added that this is less of a problem for NGOs that receive enough co-funding.

Another official summarized the issue as follows: the question is whether we want to have some NGOs for many years or whether we should give a chance to other NGOs. Using a mixed system (partly multi-annual, partly annual) would come down to having two programmes running in parallel. This would be complex, but not impossible77, to manage. With an annual system, it is difficult for NGOs to know if they will be accepted next year, but this also provides good incentives for flexibility.

Concerning the cash flow problems some NGOs face, one stakeholder admitted that, although the Financial Unit does it best to have a smooth processing, cash flow can be a problem for some NGOs. However, the NGOs know the calendar, and should be able to plan in advance. If the reports are good and the payment period is not suspended, the payment can be quick. If NGOs have different sources of income, they can also be more independent.

O.2 Selection and monitoring procedures

O.2.1 Objectivity and transparency of the evaluation procedure


Only about 60% of the NGOs think that in general the selection procedure is objective and transparent.

Certain elements however were identified as less transparent or objective, especially relating to the lack of feedback on the scoring or on the link with the size of the grants and co-financing rate. The following comments were given by the NGOs:

The size of the grant: The reasons for granting or not granting funding to (eligible) the organisations are not made clear; there is no access to the ranking given to the organisations, nor the reasons for the ranking. It is not clear why one organisation receives a certain amount of funding, or why some organisations get selected and others get rejected. A scoring is not published, and the applications/reports are not published either. It was suggested that more systematic feedback should be given on the scoring on certain criteria: what is needed to do better?

77 As experience in other DGs has shown – see Annex Q, Section 7.22

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Procedure: It would make the application easier (for both sides) if the procedure is clear: e.g. many activities fall under different headings - if it is clear that one person is evaluating all, one could simply reference to other chapters.

The evaluators: There is no published list of evaluators, therefore conflict of interest cannot be evaluated. It is very difficult to judge who is reading and assessing what, and what they are interested in. There is no insight in or record of the evaluation by the panel at all.

NGOs would prefer to know immediately after the selection the score of the application. Also NGOs think they should be entitled to know who are the experts in charge of the evaluation of the applications, and what is their respective knowledge in relation to the policy areas covered by the application.

To be able to give an objective view on the selection of NGOs it will be important that desk officers at the Commission are all aware which NGOs are selected for a core grant and which topics they say they will work on in their application. In this way they would be able to assess over the year if they are informed by these NGOs on work they are doing. This information can then be shared with the NGO liaison and the selection team as additional information.

Therefore, more interaction between the desk officers and the NGOs would be appreciated by the NGOs. Also the possibility to send the evaluators appropriate information or invite them for discussions would be appreciated.

Almost all NGOs agree that the eligibility criteria are favouring certain types of NGOs. In particular the following types of NGOs were mainly mentioned as being favoured:

NGOs with an EU wide action domain (by 59 %)

Well known NGOs which have a tradition in being attributed an operational grant (by 47 %)

NGOs involved mainly in policy development (by 41 %)

Brussels based NGOs and NGOs with a broad policy approach, working multi thematic (by 34 %)

NGOs that are capable of delivering the maximum European added value (by 28%)

However, 72 % of the NGOs think the selection of NGOs is correct and defendable. Negative comments given by the NGOs were78:

Regarding biodiversity, the biggest international NGO networks have headquarters in Brussels. On one hand, this makes their lobby activities more effective. On the other hand they are farther from those parts of Europe, which still have high natural values, what inevitably decreases the representativeness of the Eastern regions. This provides more support to NGOs of the old Member States while NGOs in the new MS get less support. Therefore, LIFE+ should represent a balance between effective lobbying in Brussels and conserving biodiversity on the spot. LIFE+ should stronger support network organisations that are not based in Brussels but in other regions of the EU.

The selection is not correct because providing support to several small NGOs can be more efficient in terms of EU policy implementation and improvement than one or two "important” NGOs. This could give a diversity of domains of intervention and of approaches.

78 These comments are not always substantiated by the reality of the funding distribution, as presented in Annex P.

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It is appropriate that the NGOs selected are leaders in their fields but this does not mean that they will be known to those outside that field (e.g. biodiversity NGOs not known by waste/resources people & v.v.)

In the application too much emphasis is placed on EU policy formulation. This again favours EU "partner NGOs". EU policy formulation at the NGO level should be done on a tender basis and not on grants basis.

The restriction on existing grantees as to the amount they may request means that funding is based on historical performance rather than the proposed work-plan. This offers some advantages for the Commission and the grantees. However, some way of recognising high scoring proposals would seem fairer.

The process seems, despite assurances, geared to organisations with a multi-topic workplan.

DG Environment seems to sometimes penalise NGOs which focus on environmental issues but work more closely with other DGs.


One of our respondents has explained that, in the past, the selection was based on direct inputs from the technical Units. For instance, a proposal in the climate area was evaluated by climate change experts, nature NGOs were evaluated by nature experts… The advantage of this approach was that the technical experts knew from experience the value of the work of the NGOs they were evaluating. The drawback is that if a policy unit has developed a good working relationship with one NGO, this relationship can become too close, and the selection process then effectively becomes a competition between the technical Units. Moreover, in this system, the evaluation work was spread over a large number of people. This implied that the whole process could be delayed if just one or two people out of 100 were late with their contribution.

Another interviewee pointed to the following drawbacks of that system:

NGOs were evaluated on the basis of a full environmental dossier (covering all environmental policy area’s), while some are specialised in focus areas.

There were no clear guidelines for the evaluators.

All evaluations were done separately so comparison was difficult.

The amount of money distributed was directly linked to the points given by the evaluator. Sometimes NGOs would only get 20% of their request compared to others who would get 95%. The NGOs that had an enormous cut in their budget needed to review their work programme. With as result that the commission financed a work programme that had not been evaluated in first instance.

This respondent concluded that the previous system was neither transparent nor fair. Another drawback of the previous system was that the budget for individual NGOs could fluctuate significantly from year to year.

In the current system, a small committee with clear responsibilities is designated.

The following advantages and drawbacks have been mentioned during the stakeholders’ interviews:

It leads to a more consistent approach. Dossiers can be compared and NGOs can have their specific focus (PAN-European or regional; policy development or policy implementation....)

There is a clear view on the overall evaluation.

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NGOs are listed in relation to their scores; it is possible to draw a line between good scores or not good enough.

The quality of proposal has become more important

The committee system implies a very heavy workload for the committee. The people involved in this committee already have their day-to-day task, and there are real risks that they will skim too quickly through the proposals. One official reported that the range of topics to be covered was too broad for an individual official.

Two of our respondents reckon that both systems discussed above do work and have more or less the same results. For instance, the calls are still annual, and the same eligibility criteria apply.

All interviewed Commission officials agreed that the evaluation and selection process had been objective, transparent, effective and efficient, taking into account the constraints within which it has operated.

The following issues were raised:

One single official thought that efficiency could be improved but did not see how.

If increased transparency would mean that the outside world knows all the details of the internal discussions within the Commission services and knows the position of all individual officials within the selection committee, this could jeopardise the independence of these officials. Indeed, the allocation of grants can be politically sensitive and, in the case of Life Nature projects, it is known that officials have been asked to explain why they have advised against the funding of specific projects in their country of origin. In the view of one official, transparency should only mean that the Unit dealing with the applications provides all applicants with the same information.

In the absence of objective and quantitative selection criteria, there is always a grey zone. The discussion with respect to the evaluation of proposals always took place in a group of 6 people, and this has limited the scope for subjectivity. In case the Committee thought information was lacking, it consulted the technical unit to ask for advice.

A tricky issue is when a personal evaluation has to be translated in quantitative marks: giving a "6 out of 10" can be an excellent mark if given by evaluator A, but very mediocre if given by evaluator B. There is thus a risk of comparing apples and pears when aggregating individual evaluations.

One single official thought that better protocols of the evaluation discussion should be kept and a summary should be made available to the outside world. Another interviewee also voiced the opinion that a minimal justification of the decision should be included.

One stakeholder reported that some evaluators focus too much on the details of the work programme, and not on the overall quality of the organisation. This is often due to a lack of understanding of the purpose of the instrument. The Financial Regulation distinguishes between operating grants and action grants. Operating grants are not used very often, and not many people are aware of the fact that these grants are not given for specific tasks, but for the functioning of the organisation as a whole. The purpose of EC funding is to enable NGOs to pay for general expenses (offices, staff). The main point is to evaluate whether the organisation as a whole is worthwhile being funded; the actual work programme is of secondary importance.

As complaints have been raised concerning the too limited justifications for the choices that were made, a detailed evaluation sheet has been created.

A specific issue is whether the selection and award process should be detailed in annex to the Decision/Regulation. Three officials clearly expressed the view that this should not be the case: the current system leaves more flexibility to the Commission to learn yearly from experience. One

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official also pointed out that, as the calls are published in the Official Journal, the procedure is already quite transparent.

O.2.2 Selection of NGOs and their contribution to EU policy


Most beneficiaries (66%) consider the list of NGOs selected under the programme appropriate to ensure the necessary contribution to EU policy. Broadly speaking, there is a wide range of NGOs active at a European level that represent a vast number of EU citizens and deliver a great deal of expertise.

They cover a wide range of different environmentally related topics: from waste management, to health, climate change, etc. The NGOs agree that most of the fields are covered and this gives DG ENV good allies in most of the policy areas it deals with.

However, the interviews revealed that some NGOs that are currently selected are not even known by many others. There should be an increased visibility of the selected, representative activities of the programme’s beneficiaries.

According to some NGOs, the impact and coherence of the intervention could still be increased by increasing links and exchange between selected NGOs, so that synergies are maximised between the different work programmes.

By developing a regular but flexible guidance process, the Commission could keep an eye on ongoing activities and identify the complementary (and possibly redundant) activities. Support of the same activities by several NGOs would be avoided. Several organisations that are working on the same issues should be expected to co-operate to share expertise. The encouragement of sharing best practises and successes rather than one to one reporting (NGO back to Commission) should be used for the NGOs to learn from one another.

One NGO mentioned that a useful tool for building bridges between the NGOs could be to dedicate a forum to NGOs on the Commission’s website, where projects can be presented, common actions envisaged and partnership or help exchanged between organisations. The Commission could choose to launch a specific consultation to the funded NGOs before a wider consultation on a specific subject to prepare and benefit from an external and practical point of view.


Out of 50 applications, just 30 NGOs have been funded in the last two years. The consulted Commission stakeholder all agreed that the NGOs that were selected deserved to be selected. However, there is a huge range of very diverse NGOs. Whilst it is quite easy to dismiss a low quality application, the budget constraints implied that not all NGOs that deserved to be selected were indeed chosen. However, one of the interviewees emphasized that if there are any problems in the selection, it is only at the margin. If more NGOs were to be selected, this would be at the expense of the budget for each individual selected NGO and it is not sure that this would increase the overall outcome of the programme.

In the case of some selected NGOs, one official also doubts that they are very relevant for environmental policy (however, without questioning the quality of their actual work).

Concerning the regional and topical balance, the following points have been made:

It is desirable that there is an equitable distribution over the regions and the subjects. This is however not inbuilt in the award criteria, but the selection process usually results in a balanced result anyway. The Commission has given priority to NGOs that work on

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subjects that are important for the Commission. Together with the policy relevance, quality is the most important criterion, and for some specific subjects, no NGOs have been identified with the required minimal level of competence.

One official pointed out that there are really two different questions that need to be answered. First, is there a regional and topical bias in the selection procedure? In principle, if 20% of the applications are initiated by Scandinavian NGOs, 20% of the funds should go the Scandinavian NGOs as well. However, for New Member States, there is a learning process: NGOs from these countries need to learn how to reach the Commission, how to present their plans and how to meet the expectations. A specific problem is that several applicants from the New Member States do not understand that this instrument provides financial support for the fixed costs of the organisation, not for the funding of a particular project. A lot of NGOs deal with the protection of specific areas, which are more classical Life Nature issues. As already pointed out above, the topical selection depends on the (evolving) policy priorities of the Commission. This can indirectly also lead to geographical imbalances. The second question is whether there is a regional or topical bias in the applications. A specific difficulty in assessing this criterion is that some NGOs cover the whole of Europe.

Two interviewees think that the southern and eastern countries are clearly underrepresented. NGOs are the most powerful in the Scandinavian countries, the Benelux, Germany and the UK (somewhat less in France). Several possible reasons for regional differences have been discussed. First, because umbrella organisations are mostly based in Brussels, it is not surprising that Belgium is overrepresented. Second, in some New Member States, there is a lack of capacity (although they are catching up quickly). Third, southern countries (Spain, Portugal, Greece, Italy) face specific problems that are not always well reflected in the 6th EAP. For instance, ozone is a much more important problem in southern countries than in the northwest, while animal welfare is hardly a priority in southern countries. If Life+ would not rely on the 6th EAP but on more specific Directives, it would be more likely that NGOs would get involved in the implementation of these specific Directives. Also, this official thinks that a lot of NGOs in southern countries simply do not know the opportunities at the European level and that NGOs in southern countries usually are also less well funded.

Concerning the topics, one correspondent thinks that the menu card is so broad, that NGOs will always find a topic that suits them.

As any official language can be used for applications, regional differences should not (at least in theory) be due to language barriers.

Concerning the issue of synergies between NGOs one of the interviewed Commission officials referred to the use of the LIFE+ website, where reports with achievements are published and where an interactive webpage to find partners brings organisations together. He thinks that existing initiatives under the NGO program such as the Green 10 should be continued and expanded.

O.2.3 Balance funding size and number of NGOs funded


The opinions on the current balance between the number of NGOs funded, the size of the individual grants and the size of the total budget differ. About half of the NGOs appreciate the balance, and the other half have negative comments.

The following positive comments were given:

It is appreciated that the budget is given to both smaller and larger networks.

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A fair amount of groups are currently getting funded: there is a good balance with only 3 major ones, who are also the main NGOs

The current balance is good: big NGOs with a wide range of activity have to receive a fair share, whereas there has to be room for smaller and more sectoral organisations too.

The other half of the NGOs think the distribution of the funding is not correct. In particular the fact that the major organisations get very high funding compared to and at the expense of the smaller NGOs, is subject to some comments:

There seems to be a disparity in the system: big NGOs quite often gain large individual grants. With an average grant of € 200.000 and € 9.000.000 of total yearly NGO grant, it could benefit up to 45 NGOs. For the moment grants range from relatively small amounts (such as 32.700€) to very large amounts (almost 1 million € - or 1/10 of the overall budget). Also, very similar organisations in terms both of staffing and policy work receive extremely different grants, both in absolute value and in terms of percentage. It is unclear and not transparent why some have which co-funding and total grant sums and which activities.

More of the less popular or influential NGOs could get support equal to the support given to already popular and influential NGOs.

Life + funding cannot be the primary source of funding and stability for sustainable organizations. The real goal of Life + funding should be to create sustainable organizations capable of implementing and formulating EU policy. Therefore, Life + should promote the creation of a large field of sustainable NGOs


Concerning the size of the NGOs that were selected, the interviewed officials made the following observations:

Some officials think that there is a logical link between the size of an NGO and the probability that it receives a grant. Indeed, the larger a NGO, the more likely it is to submit a good application (good paper, clear mission, clear description of deliverables). This requires a certain critical size, but also a good understanding of how the Commission works.

The size is also important insofar as the Commission aims at funding representative NGOs who can play a role at the European level. A small NGO will have less influence than a large one with the same level of technical competence.

The link between size is thus also due to the link between the funding of NGOs in Life+ and the 6th EAP. The 6th EAP offers a huge menu card for the next decade. If an NGO is experienced in working with the Commission and is acquainted with the Commission's reasoning and approach, it is easier for some people to write a proposal on such a broad range of topics without having necessarily a deep knowledge of the individual topics. Small NGOs with specialised expertise of specific fields are definitely at a disadvantage here because they cannot rely on professional staff to write broad ranging proposals. If the questions were more specific (for instance, "what can you as an NGO contribute to the implementation of the Water Directive?"), this would be better for smaller NGOs. Since the applicant NGOs are extremely diverse, it is however difficult to formulate specific questions that can apply to all different types of NGOs. Because the current basis is very broad, there is a definite advantage for large NGOs with a broad spectrum of activities.

One single official however disputes that there is a general correlation between the size of an NGOs and the likelihood that it receives funding. Actually, he reckons that some of

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the smallest specialist NGOs receive the highest funding. Although some smaller NGOs do not know very well how to write a good application, this is rather an issue of having experience in working with the Commission – this is reflected in the fact that being based in Brussels increase the chances of receiving funding. Also, in the case of small NGOs, the impact of one key person leaving the organisation can have a dramatic impact on the quality of the application. This is a problem because the Commission has to base its funding decision on the quality of the application, not on its general appreciation of the specific NGO.

According to one of the stakeholders, because the NGOs vary a lot in size, it is not possible to say in general which budget is appropriate.

Another stakeholder does not think there is a need to increase the funding further. Actually, he reckons that the current number of beneficiaries is already too large.

O.2.4 Barriers for new applicants


The main barrier for new applicants that was identified by the NGOs is the administrative burden (highlighted by 59% of the NGOs)

Other important barriers identified by 34% of the NGOs were:

The knowledge of the criteria

The eligibility criteria

The degree of requested co-funding

Other barriers that were mentioned as important were:

Exclusion of non-EU activities

Financial forms: it is very difficult to predict such detailed activities in specific numbers in the budget in the current financial forms. Flexibility would be more helpful in order to be reactive throughout the year.

The procedure: understanding EU funding procedure is not easy and requires a great deal of know-how. And the application phase is only the beginning, because once the funding is secured, it needs to be carefully managed. This can cause even more problems.

The degree of requested co-funding can also pose problems to certain NGOs. A networking NGO is usually set up by a number of existing NGOs, who have experience in co-funding on national level, but less at European level. This national co-funding has become unavailable since national members are not eligible any more.


The interviewed stakeholders have pointed out that new, small NGOs have difficulties competing with established NGOs who know the procedures very well from experience. New applicants will always face difficulties finding their way if they can only rely on the guidelines: there is certain language, a certain way of proceeding that one needs to know. Another important barrier for new applications is that new NGOs are not always aware of what the Commission is looking for and what role they are expected to play when they receive the funding79.

79 As already discussed in Section 0, the Commission does not view this programme as a support

programme for start-ups. In this perspective, this barrier is intrinsic to the objectives of the programme.

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It is not clear what changes in the legislation could help solve this issue. One stakeholder pointed out that these barriers are intrinsic to the system: the budget is limited and experience is one of the relevant criteria. If an NGO works on a purely local issue, there will no bilateral communication, and no European value added. In the view of this stakeholder, there are no other barriers: if some NGOs are not funded, it is because they do not satisfy the criteria.

O.2.5 Reporting and monitoring


The large majority (78%) of the NGOs considers the reporting arrangements and monitoring methods appropriate to assess the performance of the beneficiary NGOs. However, 72% think the reporting arrangements could still be simplified.

The financial part is considered fair and simple, but the technical part is perceived as very heavy and lengthy. The remark is made that the reporting is time consuming and the structure of the report doesn't focus on impact, but on activities. Suggestions for simplifications given by the NGOs are:

The format would certainly gain in readability from a more attractive presentation. Some of the categories in the forms could be taken out or merged (i.e. policy formulation and implementation). For instance, the reporting could be limited to the categories policy formulation and implementation” and “campaigning” (covering internal and external capacity building, and environmental education).

The split of the work programme between the different environmental topics (climate change, biodiversity...) is not always useful. For instance, for NGOs working mainly on a cross-cutting level and on multidisciplinary activities, it is hard to fulfil the blanks without repeating several times the same. It should be clear that "general" environment NGO could fill only the chapter "cross-cutting issues" without discrimination on the mark.

Detailed narrative reporting against all bullet points in the application (under activities and results, respectively) is cumbersome, it takes a lot of time and its benefits are not obvious. It would be much easier if this was only necessary where they have not been fully achieved or implemented (as is the case with the objectives).

It should be enough to rate the outcome instead of rating every objective + activity + outcome.

It should not be necessary to audit every 5th organisation in depth, when organisations are already giving audited accounts as a standard procedure. The combination of reporting and checks from the Commission of websites etc. gives a general overview of activities. The Commission in addition could better visit one annual event of each of the beneficiaries, such as a seminar or exhibition.

The heavy reporting should be proportional to the % of funds received. Those that receive 20% funding should not have the same reporting requirement as those receiving 70%.

The Commission staff and desk officers should know more what the NGOs are doing over the year. There should be more communication between them as well. One NGO was audited 3 times in 1 year and the auditors did not even know from each others’ work.


Monitoring is outsourced to external consultants. The main objective of the desktop reviews of the final reports of each beneficiary is to serve as a basis for the decision on payment. The consultants verify the budget claims, together with the technical report by the NGO. They compare what has been promised in the proposals and what has been carried out, but not results of the work in terms of policy impact which has however been assessed in the selection procedure. Each

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year, 8 NGOs are monitored in depth. This monitoring, together with the desk top reviews, serve as an information source for follow up with individual beneficiaries and adjustments to the programme.

Only one Commission official commented on the issue of the reporting requirements, and considers them to be satisfying.

Another interviewee argued that the interaction between the Commission and NGOs should be more then only reporting. In his view, on the spot visits from commission people together with the “monitors” or presence of policy unit staff on crucial NGO activities can improve the common understanding (while making sure that this interaction does not impact on the full independency of the NGOs ).

O.3 Complementarities between financial instruments

O.3.1 Other EU programmes


Almost all NGOs state that the operational activities of NGOs can not be funded from the other European Programmes (Regional development funds, Social Fund, Cohesion Fund, Agricultural fund for rural development, Competitiveness and innovation framework programme, Fisheries fund and 7th framework programme for research).

The Life+ NGO funding can fund NGOs and international networking. Only CIP and FP7 do that as well. CIP and FP7 however do not support policy work, unless it is closely linked with very specific priorities of the calls within these two frameworks, so they do not allow a permanent focus on EU policies, as the LIFE+ NGO grant does. Life+ seems the only obvious funding source for environmental organisations. The alternative EU funding schemes are generally very difficult to access for NGOs and carry a heavy administrative and financial burden, especially in the new EU member states. Theoretically, they may be accessible, but practically this is often not the case.

The Life+ operational grants are considered irreplaceable by other funding. Most of the other EU programmes are nationally driven, some (RTD) requires an high participation of academic institutions.


None of the interviewed officials felt well placed to provide information or opinions on the complementarity with other instruments.

O.3.2 Other LIFE+ funding


Only 37% of the NGOs consider that the LIFE+ project grants could be considered as a partial alternative funding source for the operational LIFE+ funding for NGOs, however only in a few, special cases, for instance for national implementation of certain EU environmental legislation, but not in general.

The operational grant allows NGO networking on environmental policy issues on a European level, while the LIFE+ projects are more national, and more limited in scope. Moreover, the LIFE+ project funding normally funds mainly big projects which require at least 50% of additional funding in the case of environmental policy projects, which is too much for many smaller NGOs.

Even if project funding would be possible, preference is still given to operational funding. Securing operational funding gives organizations a tremendous advantage in finding project funding.

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Securing project funding on the other hand does not guarantee operational funding. Moreover, costs such as office rent and other overhead costs are mostly not covered by other grants.

For only 1 NGO the LIFE+ public procurement contracts can be an alternative funding source for the operational LIFE+ funding.

In paragraph O.5.1 a calculated remark is given by one NGO on the possibility and sometimes desirability to exchange operational funding for project funding.


No specific information on this issue has been identified during the interviews with EC officials.

O.4 Dependency on the instrument

O.4.1 Financial dependency


All NGOs state that they are very to rather financially dependent on the yearly returning LIFE+ operational funding.

Most (20 NGOs or 65 %) consider themselves as being dependent in the sense that shifts in the current LIFE+ funding would lead to considerable shifts in the working programme. For 60% of the NGOs more than half the funding comes from the LIFE+ funding and a part of the co-funding is linked to the LIFE+ funding in such a way that it would not be available without the LIFE+ funding. If LIFE+ operational funding would stop, staff and activities would have to be cut, because there are no other funding sources for international or cross border cooperation in the EC.

16% (5 NGOs) consider themselves as being rather dependent, in the sense that the NGO would loose efficiency but could find other sources to continue realising its programme if LIFE+ operational funding would be cut.

Another 16% (5 larger NGOs) even state they would not survive without the LIFE+ funding, because:

there are only few core-staff people, who are completely dependent on the LIFE+ funding.

there is very few alternative possibilities for core funding of environmental NGOs on national and international level and such other funds are very small compared to EU funds.

Firstly, most other sponsors focus on specific activities, and usually more “sexy” ones. Certain NGOs would not be able to continue working in areas such as waste, air, product policy. Secondly, the NGOs would lose also their flexibility in response as the EU funding allows for this. As a consequence of both, the NGOs would loose a lot of their high profile with Environmental Ministries, who together are responsible now for a substantial part of the income. Even though ministries often sponsor NGOs for concrete projects, NGOs feel that the reason the ministries do so is because of their appreciation of NGO work as a whole.

In case of decreased LIFE+ operational funding, the NGOs would first decrease their activities in the following order:

1. contribution to the development of Community environmental policy and legislation

2. contribution to the implementation of Community environmental policy and legislation

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3. organisational capacity building,

4. awareness raising activities

5. European focussed activities

Hence, without the funding they would maintain their focus on Europe-related topics, but they would have to decrease their contribution to firstly the development and secondly the implementation of Community environmental policy and legislation.

According to the NGOs a large amount of staff time is dedicated to fundraising, and the NGO operational funding from the Commission is only one among many funding opportunities that NGOs must seize if they wish to avoid being too dependent on one single funder. However, the NGO operational funding is a very burdensome grant, both in terms of the application procedure and in terms of reporting.


According to the interviewed Commission officials, the reliance of NGOs on Life+ varies from one organisation to the other. For instance, there are cases where an NGO receives large grants from the EU but these grants are relatively small compared to other funding sources. Other NGOs however are very dependent on EU funding. Some NGO rely on EU funding up to the maximum amount of 70% of co-funding. According to an interviewed official, it would have a significant impact on NGO activity if the programme was discontinued. However, the Commission has no clear overview of how important this dependency is exactly.

O.4.2 NGO policy independency


32% of the NGOs state that the European funding does not influence their independency in determining the activities or objectives. For 26 % of the NGOs it limits their independency a little bit , and for about 42 % it really influences their work programme in a positive way.

For 35% it does have a small negative impact, in the sense that

The NGO work is limited due to the amount of funding available and administrative barriers rather than any perceived political issues

The NGOs end up adding activities to their work programme which they would otherwise not engage in, due to the criteria for granting funds. This dilutes their resources and does not allow them to focus on their core objectives as much as they would like to, or as much as their members demand.

For 30% it has an average positive impact, in the sense that

EU environmental policy is well formulated and can act as a positive guide for the strategic development of the NGOs

NGOs assess more carefully the policy relevance of the activities, although the objectives themselves are not really influenced.

For 26% it has a high to very high positive impact:

Without the DG ENV grant there would be no NGO activity on standardisation, thus heavy impact on determining the level of activity, whereas regarding the content of the activities there is no impact.

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The funding gives the NGOs the independence to work on European policies based on members that would not be able to fund this as they are NGOs (only larger industries and other stronger actors are able to fund that kind of activities themselves).

The grant, while hard to achieve, comes with no strings for the work done with it in terms of policy positions taken, and so offers a lot of independence for the NGOs, and the size of it allows the NGOs confidence and some independence from other sources.

The grants make the NGOs more independent, because the Commission sponsors their entire programme which they have developed independently. The Commission therewith does not influence which issues the NGOs should focus on and which not, and it also does not use the fact that it is a sponsor to put pressure upon the NGOs.

The grant gives the NGOs flexibility to divert from the work-programme if the circumstances demand that (often influenced by the choices of the Commission itself, for example when it postpones the delivery of draft legislation).

The support from EU gives the NGOs a secure base to act despite different national priorities.


One interviewed official has pointed out that the policy opinions of the NGOs do not influence the Commission’s judgements of the grant requests.

Another respondent emphasized that the Commission and NGOs have a different role to play. Therefore it is important that their activities complement each other.

As already pointed out earlier, the profile of NGOs funded by the instrument has changed over time. One Commission official reported that NGO membership of local governments and companies is acceptable, as long as they have a limited role in the NGO.

O.4.3 Size of the grant: level playing field


The majority of the NGOs (69%) agree that the current budget is not able to create a level playing field to compete with other economic actors. Trade associations and industry representation offices benefit from huge and increasing budgets to carry out lobbying activities in Brussels.

The NGOs mention the following actions that could be taken to improve this situation:

Increase the budget for NGOs, this would:

stabilise the existing NGOs

allow new NGOs to enter the debate

allow NGOs to attract better-trained expert staff and retaining the staff.

strengthen the general technical effort and political impact of NGOs, either in Brussels or towards national decision-makers

compensate for the difficulty of finding other funding for the highly technical and policy focused work conducted by many grantees.

Be selective and target the truly effective NGOs

Create better conditions of stability and long-term planning, i.e. establish multi-annual funding, create a better framework for payments, etc..

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However, NGOs do agree that it can not be expected from the Commission to completely counterweigh the funding of the private organisations.


No clear-cut consensus emerged from the interviews with the Commission stakeholders.

Although some stakeholders think that the size of the grants was not sufficient, the following points were also raised;

A significant increase in the budget already took place with enlargement to meet both the needs of NGOs in the NMS and of the NGOs in the EU15 (who saw an increase in the geographical scope of their work). Governance and stakeholder involvement were also a big issue then. There is no clear need for raising the budget further.

Increasing the budget would come at the expense of other domains. The global envelope for Life+ is already to a large extent in the hands of the Member States, and the amounts allocated to the global envelope are not determined by the Commission.

Whether the size of the grant is sufficient depends on the beneficiaries. For some NGOs the Life+ grants are not the main funding source. For other NGOs, these grants are a conditio sine qua non for their survival.

One official pointed out that, even without EC funding, the Commission would still receive inputs from NGOs. For this official, the really important issue is how to obtain the best possible inputs from the NGOs for a given amount of money. One possible way to deal with this would be to allow NGOs to get themselves organised so that the EU can give one single grant to one single platform. This would simplify the administration, both for the NGOs and for the EU, as the number of beneficiaries would be reduced. According to this official, this approach would be the most efficient, even if it would come at the cost of the work on implementation. Actually, such an approach already exists for social NGOs. Moreover, it could build further upon the existing informal structure of the “green ten”. Such a body would then pretty much cover everybody. It would also be possible to list the beneficiaries in the next legal text.

O.5 Financial provisions

O.5.1 Funding %

The current funding is limited to a maximum of 70% of the total eligible working cost of the NGO.


Most NGOs (77%) agree that the funding limitation of 70% is necessary either to avoid too strong dependency on the grant, or to spread more equally the funding over more candidate NGOs.

In average, the proposed scores rang from 30 to 100, with 70% being supported by the majority (42% of the NGOs). Almost 26% would prefer a funding rate of 80%..

However, 16% of the NGOs think the 70% co-funding is counter-productive and discriminates small NGOs that have no access to other financial sources, and 13% think the cap should not be expressed in percentages but as maximum request / NGO. Also 1 NGO thinks the cap should be expressed in a maximum request per employee.

One NGO presented a calculated example on the possible competition between operational funding, declining other funding opportunities, and using these opportunities which offer sufficient overhead to fund the operational activities. This choice can be made driven by financial evaluation:

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Different project funding systems both at EU and national level have different provisions on allowable overhead costs. These overhead costs are related to direct project costs unlike the NGO operational grant system. This system makes all operational overheads eligible if they are in line with the provisions of the system, no matter if they are related to activity implementation or not. Additionally it also demands that all operational overheads should be attributed to the NGO operational grant system, and could not be entered at other ad hoc grant schemes.

This is justified by the European Commission to avoid double funding. NGO’s are of the opinion that actually double funding cannot take place if all overheads are clearly linked to personnel costs and task implementation.

If overheads, that have previously been attributed to other ad hoc or project grants suddenly are not eligible at these projects, this can cause a distortion in the project budgets. The grants that can be drecieved for a project are usually bound to an agreed proportion of total eligible costs – if less overheads can be entered, the total cost of the project drops, and the total funding drops equally.

This leads to a further problem: The NGO operational funding imposes a maximum grant of 70% requesting co-funding for 30%. This conflicts with other systems where higher rates can be attributed. It means the NGO looses funds when the overheads are shifted from a project with e.g. 75% or 85% EU funding to the operational grant system where only 70% can be granted.

Calculated example on how NGO operational grants could come in conflict with eligible overhead costs of project grants.80

The NGO operational funding includes 70% EC funding for implementation of its work programme. The overheads from other EC grants must be shifted to the NGO grant. This means that the overhead expenses are growing.

The intelligent energy project (IEE) allows for 75% funding for the total project, and for a flat rate of 60% of personnel costs in the project to be allocated to overhead (=operational) costs.

If an NGO has € 50 000 personnel costs in the IEE grant in 2010, consequently it also has € 30 000 or 60% eligible overheads plus € 20 000 other costs – in total € 100 000. The IEE funding scheme would allow € 75 000 share of EC and € 25 000 own financing. A share of this own financing can be acquired by national co-financing for IEE projects.

If now these € 30 000 overheads have to be moved to LIFE+ NGO operational grant this leads to: € 30 000 additional costs at the operational grant, out of which at least € 11 000 must be co-financed under condition that the beneficiary received 70% EC funding, which so far it has not been granted – a non official rule says better to go for 50%. The co-funding sources vanish, as consequently IEE national co-funding does not anymore apply. These overheads cannot be attributed to an eligible activity of the NGO operation grant work programme, as the IEE project activities are not eligible, but they raise unavoidably the total budget of the NGO operational grant – value for money principle is not applying anymore: no action for € 30 000. The remaining IEE project budget being 70 000 EUR out of which EC would fund 75%, means € 52 500, the beneficiary has to co-fund € 17 500.This leads to a co-funding need of € 28 500 in total and a loss of potential national IEE co-funding. The loss in funding respectively the unfavourable own finding share is growing for each ad hoc project and gets even higher if there is a funding scheme with 85% EC funding such as INTERREG or others.

80 Information provided by one of the beneficiary NGOs

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The calculation can be illustrated as follows Table O-2:

An interviewed NGO makes it clear that this kind of balancing has urged them to step uut of the NGO operational funding system. Another NGO replied that the (limited) potential financial benefits of not applying for the operational funding programme do not outweigh the risks of not obtaining the project funds. An NGO can choose for stability or for risk and yield in its funding strategy.

NGOs state that the missing interlink between overheads and activities in the NGO operational grant could lead it to become the garbage bag for all operational expenses that could not be funded from other sources and the described work programme actually a fake.


The requirement for co-funding is determined in the Financial Regulation. One official pointed out that this rule requires the NGOs to look for a diversity of funding sources. No other opinions or information have been provided.

Concerning the possibility to include work or donations in kind, one official has explained that this is not accepted in the budget because it is difficult to make an evaluation of this type of donations. It could be worthwhile to re-open the discussion however, because NGOs rely a lot on volunteers

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and some private companies would like to give equipment away. The main problem lies in the verification.

O.5.2 Funding allocation

For the past 2 years, funding requests from previous beneficiaries have been limited to the amount that they received the year before in order to try to avoid subsequent reductions of proposed budgets.


The majority of the NGOs (68%) experience this as inhibiting their expansion. The general opinion of the NGOs is that they should not be forced to apply for no more than the amount they have received the year before. This makes it difficult if not impossible for them to expand, and it is unfair as some organisations who have done considerable work in policy and organisational terms end up receiving far less than other organisations who once got a large grant and have not significantly improved their operations since.

The preferred alternative allocation system according to NGOs would be that they can themselves decide on the requested amount, and the Commission limits this amount on an individual base, taking into account the quality judgement of the individual files and work programmes to fit in the maximum budgetary limits for the programme.

Another allocation system that is widely supported would be a ceiling for the individually requested amount. This is the preferred system for almost 39% of the NGOs (12 NGOs), representing 27% of the funding budget in 2008, but of which half (6 NGOs) were not re-selected in 2009.

In total 58% of the NGOs (representing 47% of the funding budget in 2008) showed to be in favour of a ceiling, and proposed ceilings ranging from € 250.000 to € 600.000, with an average of about € 450.000. However, this system would be an issue for a few (but certainly important) NGOs. This will limit their scope and work that they can do.


One of the interviewed officials reminded that in the previous legal framework, there was an upper limit to the amount an NGO could bid for. In the first year of Life+, there was no such limit and some NGOs bid for a very high budget. As the budget is now limited to the expenses of the previous year (see Annex Q, Section 7.20.6), this implies that the initial allocation for the NGOs that were selected in the first year is indeed fixed, whilst new applicants can ask any amount they want).

The interviewed Commission stakeholders have pointed to the following issues:

An important advantage of this system is that an NGO can be relatively sure about the amount he will receive if selected - money requested can not be higher then the preceding year and possible cuts are kept to a minimum. This leads to more predictability.

If everything would be questioned again each year, this would lead to an unmanageable amount of complaints concerning the budgetary allocation.

The main problem is how to deal with NGOs that are listed for the first time. One official suggested that newcomers and NGOs who are not used to deal with the Commission need to be given a broad indication of the grant level for the European dimension.

When the evaluation of next year's proposal is made, no ex post evaluation of last year's activities of the NGO has yet taken place. Therefore, in the current system, once an NGO

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has succeeded in obtaining a grant based upon a bloated budget, it is safe for a while. NGOs who requested a more moderate budget can have problems.

One stakeholder suggested that NGOs should be more specific and provide information on what type of action is actually funded by the grant. NGOs should prove what they need the money for (for instance, "recruiting a communication officer" is not specific enough).

In the current system, decisions are based upon what has been done in the previous years. This guarantees at least a minimum level of cost-effectiveness. The drawback of the system is the perpetuation of the existing distribution of funds between the NGOs. However, this lack of flexibility can be compensated (up to a point) by the choice of the NGOs who actually receive the funding.

The Commission officials have also been asked to evaluate alternative distribution system.

In a first alternative, NGOs could themselves decide the height of their request, and the Commission would top of the amount linearly (e.g. everywhere a same percentage) to fit in the maximum budgetary limits for the programme. The interviewed officials have provided the following comments:

This approach was applied in the past to accept more NGOs. At least three officials point out that if NGOs know that the Commission will ask them to reduce the budgets, these NGOs will inflate their demands. The current system obliges NGOs to propose a realistic budget. If they have extra activities, they will have to look for other sources.

Applying a linear correction would be problematic, as this approach would assume that all demands are equally justified.

One official suggested that the Commission should be allowed to reduce the budget by cutting specific lines if these lack policy relevance.

In a second alternative, NGOs could themselves decide the height of their request, and the Commission could top of the amount on an individual base, taking into account the quality of the individual files and work programmes to fit in the maximum budgetary limits for the programme. All interviewed officials have answered that this approach would be unrealistic:

NGOs have different programmes and sizes, and therefore an equal treatment is not possible. It is also very difficult to assess the quality of the activities. Such an approach would lead to a lot of complaints.

With an individual treatment of all applications, one would enter into an infernal system where all individual decisions would need to be justified to everyone. This would lead to a disproportionate bureaucratic burden

In a third alternative, NGOs could themselves decide the height of their request, and the Commission would grant the total requested amount, but top of the number of NGOs funded, based on a ranking of the individual files and work programmes to fit in the available maximum budget for the programme. One official pointed out that if the number of NGOs to be selected were to be decided in advance, this would be politically difficult. Indeed, some stakeholders may raise the question whether the number had been determined with the selection of specific NGOs in mind.

In a fourth alternative, a ceiling for possible requests would be defined at e.g. 500.000 euro or at another level. The interviewed officials have made the following comments:

Such an approach would be at the disadvantage of the organisations with high grants. One official pointed out that in the current system, the same large NGOs are indeed chosen each time, but there are good reasons for that. There is no reason to limit the

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budget allocated to individual NGOs. If a specific NGOs works 100 times more than the other, it is good value for money to spend more.

Two officials reckoned that an upper ceiling would indeed be needed, but they had no clear view on the optimal amount. Possible responses to such a ceiling could be that some NGOs would reduce the number of the topics they cover, and that some larger NGOs may split in several small NGOs to cope with this ceiling.

O.5.3 Miscellaneous

Interviews with Commission officials have also revealed some additional information concerning the budgetary procedures.

Some flexibility in the budget is allowed, up to 20% change between budget categories. It is also possible to request for an amendment to the grant agreement, subject to approval by the Commission. It can be introduced until 2 months before the end of the year. This is in particular required in two cases: (a) if more than 20% of the budget needs to be shifted between the main budget categories (below this amount, the budget can be shifted freely) (b) if there is a major change in the programme. What exactly constitutes a “major change” is a matter of judgement.

It is possible that the final report by the NGO reveals that the work programme has not been performed – one official estimates that only 75 to 80% of the proposed activities are indeed carried out. This implies that each year, some money is decommitted. This can for instance occur if no co-funding has been obtained or because some activities have been cancelled due to changes in priorities. Applicants tend to be overoptimistic on what they can achieve in one year. However, it is not clear to what extent this is a problem. Action on the Commission’s side is only needed if the NGO does less than announced in its work programme but still spends the whole budget, or if an NGO spends systematically less than budgeted (because this money was blocked for the NGO and could not be spent on other NGOs).

O.5.4 Strategic issues

The general evaluation of the Programme by the interviewed Commission officials was positive, and most (with one exception, discussed below) would like the Programme to continue more or less at is. One official concluded that the renewed programme is more transparent and comprehensive than the previous one and that it gives a certain guarantee that if an NGO make a good proposal on relevant EU policy, funding will be given.

One of the interviewed Commission officials emphasized that there is an important difference between monitoring action grants and operating grants. In an action grant, it is easy to verify whether a specific action was performed or not. The technical performance of an NGO under an operating grant is much more difficult to monitor. Within an operating grant you can not expect everything is done exactly as it has been announced, since it is important that the political focus of the EU is followed and this can shift over the year. Other officials confirmed that it is difficult to define success of NGOs. It is hard to evaluate if specific lobby activities have been influential. The major aim of the programme is the balance within democracy.

One stakeholder suggested opening the programme to stakeholders from other sides (such as the organisations of land users, whose collaboration is crucial for the implementation of environmental policy). However, this proposal would be controversial -another respondent actually thinks the Commission is already too flexible in its interpretation of what constitutes an environmental NGO.

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One single stakeholder however explained that he does not feel very comfortable with the instrument as it currently exists. The crucial question is what the Commission is expecting as result from this support for NGOs. One possible answer is that the Commission is actually paying NGOs to provide information to the Commission (both “facts” and “arguments”). However, this official doubts that subsidising the overhead costs of NGOs is a good way to spend public money. He would prefer to support projects with clear objectives, timetable and results. He acknowledges that the watchdog role of NGOs is important, but this is mainly played at the local level, and this is precisely the type of activity that is not supported by the current instrument. This stakeholder would find the current approach of supporting NGOs more acceptable if the money was allocated directly by the Parliament instead of the Commission.

None of the stakeholders has suggested further expanding the scope of the Programme.

O.6 Conclusions

O.7 General procedural and eligibility issues

For most NGOs, the simplification exercise has not led to less administrative burden, although the elimination of the mid term report is appreciated. Still a substantial amount of time needs to be spent on application and monitoring. The interviewed Commission officials saw limited scope for further simplification, taking into account that the spending of taxpayers’ money needs to be monitored.

The fact that members’ activities and activities outside the EU are no longer eligible has led to a significant decrease of efficiency and more administrative burden for the large majority of NGOs. More guidelines are needed on the subcontracting possibilities. Commission official have pointed out that the ineligibility of members’ activities follows from the Financial Regulation, not from Life+.

Half of the NGOs consider 3 member states is not enough to assure a sufficient EU coverage. Only 19% considers it is sufficient, for 19% it doesn’t matter. Most interviewed Commission officials agreed that at least three member states should be covered by an NGO, and several suggested making this criterion even more stringent,

The majority of the NGOs (72%) agrees with the requirement that only NGOs constituted by member organisations are eligible. The large majority (94%) of the NGOs agree on the provision that an NGO should be legally constituted for more than 2 years. On these issues, the interviewed Commission officials were broadly in line with the NGOs.

60% of the NGOs agree that it is good that international NGOs are not eligible; to prevent that European funds are being spent on non-European issues as well. There is no clear consensus on this issue amongst the interviewed Commission officials, and the concept of “European NGO” needs clarification.

Some Commission officials have suggested adding the field experience of the member organisations and the Commission’s working experience with the NGO as selection criteria.

Yearly grants are evaluated by the large majority as not efficient: preference is given to a 2 to 3 year grant. In total 85% of the NGOs favour a multi-annual grant, of which about one third on the condition that the option remains to opt-in on a yearly basis. Commission officials have pointed out that this is a significant change of position, and that a yearly opt-in option would be difficult (although not impossible) to manage.

The large majority of the NGOs experiences difficulties with the timing of the decision and the payments: this causes problems in terms of uncertainty, planning and liquidity.

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O.8 Selection and monitoring Although in general the selection procedure is assessed as objective and transparent,

many NGOs had remarks on the transparency of the evaluation: they require more communication on the individual scores (even if successful) and on the evaluation team. Although the interviewed Commission officials accept that a better communication of the scores is possible, the independence of the selection committee can only be guaranteed if the individual members are not disclosed.

Almost all NGOs agreed that the procedure and the criteria are favouring certain types of NGOs. In particular the following types of NGOs were mainly mentioned as being favoured:

NGOs with an EU wide action domain

Well known NGOs which have a tradition in being attributed an operational grant

NGOs involved mainly in policy development

However, 72% of the NGOs think the selection of NGOs is correct and defendable. Most interviewed Commission officials also agreed that, if some types of NGOs (size, region, topic) are better represented than other, this follows naturally from the selection criteria, and not from any partiality.

Most beneficiaries (66%) consider the list of NGOs selected under the programme appropriate to ensure the necessary contribution to EU policy. However, some funded NGOs are not known by many others, there is a need for a better visibility. Impact could be improved by increasing links and exchange between NGOs.

The current balance between the number of NGOs funded, the size of the individual grants and the size of the total budget is appreciated by a third of the NGOs. However, another third of the NGOs assess the distribution of the funding is not correct. In particular the fact that the major organisations get very high funding compared to and at the expense of the smaller NGOs, is subject to comments.

The main barrier for new applicants that was identified by the NGOs was the administrative burden. Other important barriers mentioned were the knowledge of the criteria, the eligibility criteria and the degree of requested co-funding. Similar comments were raised by the interviewed officials.

The large majority (78%) of the NGOs considers the reporting arrangements and monitoring methods appropriate to assess the performance of the beneficiary NGOs. However, 72% of the NGOs also think the reporting arrangements could still be simplified.

O.9 Complementarities between financial instruments Almost all NGOs state that the operational activities of NGOs can not be funded from the

other European Programmes. The Life+ operational grants are considered irreplaceable by other funding. No other funds pay considerable amounts for overhead, which is needed. Most of the other EU programmes are nationally driven, some (RTD) requires a high participation of academic institutions. About one third of the NGOs consider that the LIFE+ project grants could be considered as a partial alternative funding source for the operational LIFE+ funding for NGOs, however only in a few, special cases, for instance for national implementation of certain EU environmental legislation, but not in general.

None of the NGOs consider that the LIFE+ public procurement contracts can be an alternative funding source for the operational LIFE+ funding for NGOs.

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O.10 Dependency on the instrument All NGOs state that they are rather to very financially dependent on the yearly returning

LIFE+ operational funding. Most (65%) consider themselves as being dependent in the sense that shifts in the current LIFE+ funding would lead to considerable shifts in the working programme. For 60% of the NGOs more than half the funding comes from the LIFE+ funding and a part of the co-funding is linked to the LIFE+ funding in such a way so it would not be available without the LIFE+ funding. If LIFE+ operational funding would stop, staff and activities would have to be cut, because there are no other funding sources for international or cross border cooperation in EC. Without the funding they would maintain their focus on Europe-related topics, but they would have to decrease their contribution to the implementation and development of Community environmental policy and legislation. About 5 (larger) NGOs mention that they would not survive without the LIFE+ funding.

About 32% of the NGOs state that the European funding does not influence their independency in determining the activities or objectives, for 26 % of the NGOs it limits their independency a little bit, and for about 42 % it really influences their work programme in a positive way. The Commission officials have confirmed that an NGOs policy opinions do not affect the Commission’s decisions on funding.

The majority of the NGOs agree that the current budget is not able to create a level playing field to compete with other economic actors. This is acknowledged by the Commission officials, who however point out that there are a lot of competing demands for funding.

One official pointed out that, even without EC funding, the Commission would still receive inputs from NGOs. For this official, the really important issue is how to obtain the best possible inputs from the NGOs for a given amount of money. One possible way to deal with this would be to allow NGOs to get themselves organised so that the EU can give one single grant to one single platform. This would simplify the administration, both for the NGOs and for the EU and could build further upon the existing informal structure of the “green ten”. Such a body would then pretty much cover everybody.

O.11 Financial provisions Most NGOs (77%) agree that the funding limitation of 70% is necessary either to avoid

too strong dependency on the grant, or to spread more equally the funding over more candidate NGOs. In average, the proposed scores come down to 67%, ranging from 30 to 80.

The majority of the NGOs (68%) experience the limitation of the funding request to the amount of the previous year as inhibiting their expansion. However, the interviewed Commission officials pointed out that all conceivable alternatives face important drawbacks as well. They suggested that, under the current system, more attention should be paid to guidance for new comers.

Table O-3 Overview main conclusions and recommendations NGO e-survey

Conclusion Recommendation

General aspects - simplification and consolidation

For most NGOs, the simplification exercise has not led to less administrative burden. Still a substantial amount of time needs to be spent on application and monitoring.

Also for the in depth audit considerable resources

Implementation of the regulation:

Reduce the administrative burden by:

Simplification of the application form and reporting :

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need to be made available by the NGO.

The majority of the NGOs think the reporting arrangements could still be simplified.

Relief of the auditing requirements

Within the limits of what is possible without affecting accountability.

The fact that activities outside the EU are no longer eligible has led to a significant decrease of efficiency and more administrative burden for the large majority of NGOs.

LIFE+ Regulation’s provisions:

Include the possibility that a small part of the budget can be allocated to non-EU activities, e.g. 5%

Half of the NGOs and several interviewed Commission stakeholders consider 3 member states is not enough to assure a sufficient EU coverage.

LIFE+ Regulation’s provisions:

Increase the minimum to 7 or 8 member states, without excluding the NGOs working on regional subjects.

The fact that members’ activities are no longer eligible has led to a significant decrease of efficiency and more administrative burden for the large majority of NGOs. More guidelines are needed on the subcontracting possibilities.

Financial Regulation’s provisions:

Evaluate possibilities to work directly with

members again

If it is not possible to amend the Financial Regulation to accommodate this request, create

clearer and less stringent requirements for subcontractors.

Yearly grants are evaluated as not efficient by the large majority of NGOs.


Review the periodicity of the grants: preference

is given to a 2 to 3 year grant with yearly opt-in.

The large majority of the NGOs experiences liquidity problems: the decision is communicated very late in the year, and payments are subsequently also very late. Especially the final payment forces an NGO to pre-finance up to 90% of the year budget.


Earlier decision : January in stead of March (if

necessary, organise the call for proposal earlier)

Earlier payments

Increase the first instalment to 80-85%

Selection and monitoring

The selection procedure is not considered transparent enough by the NGOs.

Communication

Organise more communication and feedback on

the individual scores (even if the NGO was successful)

The impact and coherence of the intervention could be improved by increasing links and exchange between NGOs. Identification of synergies will also avoid double funded activities.

Communication

Create a better visibility of the funded NGOs

Enhance synergies between funded NGOs and knowledge sharing

The impact and coherence of the intervention can be Communication

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improved. Improve synergies and bridges between the NGOs.

Financial dependency

The large majority of the NGOs experience the limitation of the funding request to the amount of the previous year as inhibiting their expansion.

Implementation of the regulation

Do not limit the amount of the funding request to the amount of the previous year. The allocation system preferred by the majority of the NGOs would be based on an individual qualitative score. A ceiling for the individually requested amount is also favoured.

The majority of the NGOs agree that the current budget is not able to create a level playing field to compete with other economic actors.

Implementation of the regulation and LIFE+ Regulation provisions:

Ensure that the size of the budget for NGO

operating grants reflects the evolving environmental agenda

Create better conditions of stability and long-

term planning, i.e. establish multi-annual funding, create a better framework for payments, etc.

150

P ANNEX P: QUANTITATIVE OUTCOME ANALYSIS OF NGO OPERATING GRANTS

Focus of NGO operational funding on specific NGO activity types

NGOs report that operational funding has been applied for followings types of activity:

Environment policy development – giving policy advice to the Commission through position papers, participation in public consultations and/or participation at official meetings.

Implementation of environment policy and legislation - Production of position papers on analysis of the EU legislation and its implementation at national or local level and of the environmental situation in the EU, participation in expert groups on implementation or policy review groups.

(External) capacity building of members (local or national organisations) and partners (small regional or local associations). External capacity building work ranges from targeted outreach work, networking and information sharing, and increasing familiarity of targeted NGOs/partners with implementation of regulations and solutions in specific / local context. Activities relating to training have been grouped as a separate category (environmental education) reflecting the specific award criteria.

Environmental Education - training experts and decision makers from administration, industry and network members on environmental issues, awareness raising campaigns and knowledge enhancement activities.

Enlargement and Third Countries – specific activities carried out in candidate countries and third countries.

Internal Capacity Building - all of the capacities that are associated with the internal functioning of the organization. This could relate to organisational structure, staffing, strategic approach, financial management, evaluation and reporting, technical competence…

All NGOs have given estimates in percentages, except the European Landowners Organization and the Coalition Clean Baltic. For these an expert judgement is made based on the mission statements on their website, and the average reported by the other NGOs for internal capacity building.

Taking into account these estimates in percentages the total amount of funding in 2007 and 2008 can be weighed. This has lead to following distribution table :

Table P-1

Environment policy development 4.519.729 euro 27,1% Implementation 4.704.192 euro 28,2% Capacity building of members and partners

2.810.383 euro 16,8%

Environmental Education 1.639.228 euro 9,8% Enlargement and Third Countries 1.319.172 euro 7,9% Internal Capacity Building 1.703.103 euro 10,2%

151

Figure P-1

operational funding in 2007-2008

27%

28%

17%

10%

8%

10%

Environment policy development Implementation Capacity building of members and partners

Environmental Education Enlargement and Third Countries Internal Capacity Building

This is an equilibrate division of funds over policy implementation, policy development and internal and external capacity building. Education and third countries are smaller fields of activity.

The data confirm that the operational funding scheme reaches its target. No disproportions can be observed.

When taking into account the total budget of the NGOs for 2007 and 2008 and not only the part funded through the operational funding scheme, and assuming that the same distribution over subtasks is applicable, the figures only slightly change. The total budget is more used for implementation, and less for enlargement and third countries.

Table P-2

Environment policy development 12.280.836 euro 27,4% Implementation 13.381.042 euro 29,9% Capacity building of members and partners

7.271.572 euro 16,2%

Environmental Education 4.719.686 euro 10,5% Enlargement and Third Countries 2.801.837 euro 6,3% Internal Capacity Building 4.318.972 euro 9,6%

152

Figure P-2

total NGO budgets in 2007 and 2008

27%

30%

16%

11%

6%

10%

Environment policy development Implementation Capacity building of members and partners

Environmental Education Enlargement and Third Countries Internal Capacity Building

NGOs can be divided in four categories, based on the location of there headquarters: Brussels based, based in another northern European country, based in a southern European country, EU-12 based. The figures for southern European based NGOs are based on a limited set of observations.

Figure P-3

funding for Brussels based NGOs

37%

23%

16%

8%

7%9%

funding for other Northern Eu based NGOs

16%

33%

20%

14%

6%

11%

153

funding for Southern Eu based NGOs

20%

21%

26%

17%

9%7%

funding for EU-12 based NGOs

24%

33%11%

4%

14%

14%

Policy development is clearly more important for Brussels based NGOs, while internal capacity building and enlargement is more important for EU-12 based NGOs. Remarkably education and awareness raising is sub-represented in EU12 based NGOs.

Focus of NGO operational funding on specific NGO policy fields

Data

Based on expert judgement on the websites and the mission statements of the NGOs they can be linked to specific policy topics.

18 topics have been identified:

Agriculture

Wood, forestry

Fishery

Tourism

Nature and biodiversity

Energy and climate

Water

Industrial pollution

Waste

Transport

Chemicals

Sustainable economy, sustainable development

Soil

GMO

Air

Health

Standardisation

Legal issues

Only those themes that are explicitly mentioned in the website or in the mission statement of the NGO have been taken into account. The themes are chosen in a way to avoid overlap, although this is not always possible. Some are focussing on an environmental issue or problem, some on an economic sector, two (legal issues and standardisation) on a specific instrument, and one (sustainable economy, sustainable development) on a broader horizontal scope.

154

For the sake of analysis they can be regrouped:

Nature and open space: agriculture, wood and forestry, fishery, nature and biodiversity

Sustainable economy: tourism, transport, sustainable development, health, standardisation, legal issues

Pollution: water, industrial pollution, waste, chemicals, soil, GMO, air,

Energy and climate.

Of course this is also merely a proxy, as the topic water is larger than pollution, and as agriculture and forestry could also be classified under sustainable economy…

155

Table P-3

156

Analysis

The funds for 2007 and 2008 are counted together per NGO and spread over the topics they serve. We made the assumption that each covered topic is served equally by the NGOs, which is not the case, but which does not affect largely the conclusions drawn.

Table P-4

Topic operational fund 2007-2008 (€)

percentage

Agriculture 1.011.094,68 6,06wood, forestry 651.167,93 3,90Fishery 290.285,15 1,74Tourism 961.389,46 5,76nature and biodiversity 3.107.961,24 18,62energy and climate 2.295.281,04 13,75Water 1.335.164,69 8,00industrial pollution 475.643,17 2,85Waste 726.178,57 4,35Transport 491.624,00 2,94Chemicals 1.090.290,72 6,53sustainable economy sustainable development

2.331.413,01 13,96

Soil 174.372,70 1,04GMO 174.204,22 1,04Air 599.236,26 3,59Health 450.156,17 2,70Standardisation 180.000,00 1,08legal issues 350.344,00 2,10

Figure P-4

distribution of operational funding over policy themes

19%

14%

14%

8%

7%

6%

6%

4%

4%

4%

3%

3%

3%2%

2%

1%

1%

1%nature and biodiversity

sustainable economysustainable developmentenergy and climate

water

chemicals

agriculture

tourism

waste

wood, forestry

air

transport

industrial pollution

health

legal issues

fishery

standardisation

soil

GMO

157

Figure P-5

distribution of operational funding over policy themes (2)

30%

29%

27%

14%

nature and open space sustainable economy pollution energy and climate

Nature, horizontal issues like economy and sustainability, climate and energy, and to a lesser degree water, chemicals, agriculture and tourism are the main topics that are served (indirectly) by the operational funds given to NGOs in 2007 and 2008.

Conclusions, outcome for priority areas

LIFE+ supports the objectives of the 6th EAP, including the priority areas:

Climate change

Environment and health and quality of life

Natural resources and wastes

All topics are covered. The programme succeeds in focussing on climate change, and through its focus on pollution on quality of life. The specific topic health is covered by a few NGOs and a limited percentage (3%), as well as the topic of waste and natural resources (4%). The topic of nature and biodiversity is not mentioned in the 6EAP focuses, but it is one of the major issues covered by the operational funding scheme.

The multi annual strategic programme, annex II of the LIFE+ Regulation, mentions:

Nature and biodiversity

Climate change

Water

Air

158

Soil

Urban environment

Noise

Chemicals

Environment and health

Natural resources and waste

Forests

Innovation

Strategic approaches

Governance

NGO’s

Information and communication

Following topics are well covered by the NGO operational granting : nature and biodiversity, climate change, water, chemicals, and if read as pollution also urban environment. The topic ‘strategic approaches’ and ‘governance’ is covered by the general topic of sustainable economy and sustainable development. And of course the main scope of the operational funding is to promote the topic ‘NGO’ itself. Information and communication has been analysed in another discussed set of indicators, and can eb considered as covered.

Following topic are covered but are not that much prominently present in the activities of the NGOs: air, health (well covered by a limited number specialised NGOs), forests, waste.

The NGO operational funding fails to promote: noise, innovation, soil (very limited attention).

This can be visualised as follows:

Table P-5

Nature and biodiversity Climate change Water Air Soil Urban environment Noise Chemicals Environment and health Natural resources and waste Forests Innovation Strategic approaches Governance Ngo’s Information and communication

159

Geographical focus of NGO operational funding

In order to have an indication of a possible geographical imbalance of the programme, we gathered data for the NGOs that applied for funding in 2009.

As a first step, we looked at the geographical profile of the NGOs that were selected. For each NGO, we verified in which member states they had members81. If an NGO had at least one member organisation in a specific country, that country received a mark “1” - this means that we have not limited ourselves to the country where the selected NGO had its headquarters, as this would very likely have lead to a strong bias in favour of Belgium (due to the proximity to the European institutions). We subsequently summed the marks for each member states and used this sum as an indicator of the extent to which this country is represented in the NGO programme. According to the analysis,

We have obtained that The average mark across the EU27 was 16.41, with a standard deviation of 4.15. Although this standard deviation is rather large, we have to be very careful in its interpretation. The only criterion we have considered is whether or not at least one member organisation operates in a given member states. Some NGOs have more than one member organisation in some member states. However, as these member organisations can differ widely in size and importance, we did not think it would have been meaningful to give different weights according to the number of member organisation per country. Moreover, there is a lot of cross-membership between these member organisations.

If we assume that the marks follow a normal distribution, we obtain that:

The following countries have marks that are higher than the upper limits to the 68.2% confidence interval: Belgium, France, Germany, Hungary, The Netherlands and the United Kingdom.

The following countries have marks that are lower than the lower limits to the 68.2% confidence interval: Cyprus, Luxemburg and Malta. Only Malta also falls outside the 95.4% confidence interval.

The results above immediately suggest that one possible reason why a country may be underrepresented may simply be its demography. We have therefore also calculated the per capita, using Eurostat data on population. This is represented in Table P-6: Approved

NGOs in 2009: countries of membership

Approved NGOs Austria

Belgium

Bulgaria

Cyprus

Czech Republic

Denmark

Estonia

Finland

France

Germany

Greece

Hungary

Ireland

Avalon 1 1 1 1 1 1 Birdlife Europe 1 1 1 1 1 1 1 1 1 1 1 1 1CEE Bankwatch Network 1 1 1 1 CAN 1 1 1 1 1 1 1 1 1 1CCB 1 1 1 1 DEF 1 1 1 1 1 EUCC - The Coastal Union 1 1 1 1 1 1 1 1EWLA 1 1 1 1 1 1 1 1 1 1 1 1EUROPARCe.V. 1 1 1 1 1 1 1 1 1 1 1 1 1EEB 1 1 1 1 1 1 1 1 1 1 1 1 1ECOS 1 1 1 1 1 1 1 Federation T&E 1 1 1 1 1 1 1 1 1

81 We have not considered members that are located outside the EU27, although some of these NGOs have a relatively large membership outside the Union.

160

ELO 1 1 1 1 1 1 1 1 1 1 1 1 1EWA 1 1 1 1 1 1 1 1 1 1 1 1FACE 1 1 1 1 1 1 1 1 1 1 1 1 1FERN 1 1 1 1 FOEE HEAL IFOAM 1 1 1 1 1 1 1 1 1 1 1 1 1International Friends of Nature 1 1 1 1 1 1 1 1 1 1 INFORSE Europe 1 1 1 1 1 1 1 1 1 1 Justice & Environment 1 1 1 1 MIO-ECSDE 1 1 1 NGO Platform on Shipbreaking 1 1 Panparks 1 1 PAN-E 1 1 1 1 1 1 1 1RREUSE 1 1 1 1 1 1 1Sea Alarm SAR 1 1 1 1 1WECF 1 1 1 1 1 1WWF-EPO 1 1 1 1 1 1 1 1 WWF-DCP 1 1 1 1 Total 18 22 17 10 17 17 15 15 22 24 16 21 14

Approved NGOs Italy

Latvia

Lithuania

Luxembourg

Malta

Netherlands

Poland

Portugal

Romania

Slovakia

Slovenia

Spain

Sweden

UK

Avalon 1 1 1 1 1 1 1 1 1Birdlife Europe 1 1 1 1 1 1 1 1 1 1 1 1 1 1CEE Bankwatch Network 1 1 1 1 CAN 1 1 1 1 1 1 1 1 1 1 1CCB 1 1 1 DEF 1 1 1 EUCC - The Coastal Union 1 1 1 1 1 1 1EWLA 1 1 1 1 1 1 1 1 1 1 1 1EUROPARCe.V. 1 1 1 1 0 1 1 1 1 1 1 1 1 1EEB 1 1 1 1 1 1 1 1 1 1 1 1 1 1ECOS 1 1 1 Federation T&E 1 1 1 1 1 1 1 1 1ELO 1 1 1 1 1 1 1 1 1 1 1 1 1 1EWA 1 1 1 1 1 1 1 1 1FACE 1 1 1 1 1 1 1 1 1 1 1 1 1 1FERN 1 1 1 1 1FOEE HEAL IFOAM 1 1 1 1 1 1 1 1 1 1 1International Friends of Nature 1 1 1 1 1 1 1 INFORSE Europe 1 1 1 1 1 1 1 1 1 1 1Justice & 1 1

161

Environment

MIO-ECSDE 1 1 1 1 1 NGO Platform on Shipbreaking 1 Panparks 1 1 1 1 1 PAN-E 1 1 1 1 1 1 1RREUSE 1 1 1Sea Alarm SAR 1 1 1 1 1WECF 1 1 1 1 1 1WWF-EPO 1 1 1 1 1WWF-DCP 1 1 1

Total 18 14 13 9 7 24 17 15 16 14 15 16 1621

Table P-7. We immediately see that, expressed in per capita terms, the scores for Cyprus, Luxemburg and Malta are higher than the average score. This strongly suggests that the lower scores for these countries may mainly be due to their low population.

As a next step, we have also verified the country scores for the eligible NGOs that have not been selected. We have then calculated the ratio between the score for selected NGOs and the total score for all eligible NGOs. We have obtained that the average proportion across the EU27 is 75%, with a standard deviation of 5%.

If we assume that these proportions follow a normal distribution, we obtain that:

The following countries have marks that are higher than the upper limits to the 68.2% confidence interval: Denmark, Estonia, Finland, Greece and Sweden. Only Denmark also falls outside the 95.4% confidence interval.

The following countries have marks that are lower than the lower limits to the 68.2% confidence interval: Czech Republic, Lithuania, Romania and Slovenia.

It is quite remarkable that there is no overlap between the “outliers” using the first criterion and the “outliers” using the second criterion. This suggests that the high scores for Belgium, France, Germany, Hungary, The Netherlands and the United Kingdom are mainly due to the high number of eligible candidate NGOs in these countries, not to any biases in their favour in the selection process. It also remarkable that the countries with very low scores according to the second criterion (the Czech Republic, Lithuania, Romania and Slovenia) all are NMS. This suggests that NGOs in some NMS do indeed face some barriers, maybe due to learning processes. The relatively high score for Hungary (according to the first criterion) and Estonia however show that this needs not be true for all NMS.

162

Table P-6: Approved NGOs in 2009: countries of membership

Approved NGOs Austria

Belgium

Bulgaria

Cyprus

Czech Republic

Denmark

Estonia

Finland

France

Germany

Greece

Hungary

Ireland

Avalon 1 1 1 1 1 1 Birdlife Europe 1 1 1 1 1 1 1 1 1 1 1 1 1 CEE Bankwatch Network 1 1 1 1 CAN 1 1 1 1 1 1 1 1 1 1 CCB 1 1 1 1 DEF 1 1 1 1 1 EUCC - The Coastal Union 1 1 1 1 1 1 1 1 EWLA 1 1 1 1 1 1 1 1 1 1 1 1 EUROPARCe.V. 1 1 1 1 1 1 1 1 1 1 1 1 1 EEB 1 1 1 1 1 1 1 1 1 1 1 1 1 ECOS 1 1 1 1 1 1 1 Federation T&E 1 1 1 1 1 1 1 1 1 ELO 1 1 1 1 1 1 1 1 1 1 1 1 1 EWA 1 1 1 1 1 1 1 1 1 1 1 1 FACE 1 1 1 1 1 1 1 1 1 1 1 1 1 FERN 1 1 1 1 FOEE82 HEAL83 IFOAM 1 1 1 1 1 1 1 1 1 1 1 1 1 International Friends of Nature 1 1 1 1 1 1 1 1 1 1 INFORSE Europe 1 1 1 1 1 1 1 1 1 1 Justice & Environment 1 1 1 1 MIO-ECSDE 1 1 1 NGO Platform on Shipbreaking 1 1 Panparks 1 1 PAN-E 1 1 1 1 1 1 1 1

82 The data for this NGO was not available for aggregation before the submisison of the report 83 As above

163

RREUSE 1 1 1 1 1 1 1 Sea Alarm SAR 1 1 1 1 1 WECF 1 1 1 1 1 1 WWF-EPO 1 1 1 1 1 1 1 1 WWF-DCP 1 1 1 1 Total 18 22 17 10 17 17 15 15 22 24 16 21 14

Approved NGOs Italy

Latvia

Lithuania

Luxembourg

Malta

Netherlands

Poland

Portugal

Romania

Slovakia

Slovenia

Spain

Sweden

UK

Avalon 1 1 1 1 1 1 1 1 1 Birdlife Europe 1 1 1 1 1 1 1 1 1 1 1 1 1 1 CEE Bankwatch Network 1 1 1 1 CAN 1 1 1 1 1 1 1 1 1 1 1 CCB 1 1 1 DEF 1 1 1 EUCC - The Coastal Union 1 1 1 1 1 1 1 EWLA 1 1 1 1 1 1 1 1 1 1 1 1 EUROPARCe.V. 1 1 1 1 0 1 1 1 1 1 1 1 1 1 EEB 1 1 1 1 1 1 1 1 1 1 1 1 1 1 ECOS 1 1 1 Federation T&E 1 1 1 1 1 1 1 1 1 ELO 1 1 1 1 1 1 1 1 1 1 1 1 1 1 EWA 1 1 1 1 1 1 1 1 1 FACE 1 1 1 1 1 1 1 1 1 1 1 1 1 1 FERN 1 1 1 1 1 FOEE84 HEAL85 IFOAM 1 1 1 1 1 1 1 1 1 1 1 International Friends of Nature 1 1 1 1 1 1 1

84 The data for this NGO was not available for aggregation before the submisison of the report 85 As above

164

INFORSE Europe 1 1 1 1 1 1 1 1 1 1 1 Justice & Environment 1 1 MIO-ECSDE 1 1 1 1 1 NGO Platform on Shipbreaking 1 Panparks 1 1 1 1 1 PAN-E 1 1 1 1 1 1 1 RREUSE 1 1 1 Sea Alarm SAR 1 1 1 1 1 WECF 1 1 1 1 1 1 WWF-EPO 1 1 1 1 1 WWF-DCP 1 1 1 Total 18 14 13 9 7 24 17 15 16 14 15 16 16 21

Table P-7: Approved NGOs in 2009: marks per million inhabitants

AU BE BG CY CZ DK EE FI FR DE GR HU IE Marks per million inhabitants 2.154332 2.046512 2.234916 12.54902 1.624068 3.084487 11.19056 2.816206 0.341876 0.292675 1.420908 2.093515 3.146058

IT LV LT LU MT NL PL PT RO SK SI ES SE UK Marks per million inhabitants

0.299775

6.191145

3.880745

18.23708

16.9242

1.455799

0.445774

1.411466

0.744234

6.888537

2.771489

0.34913

1.728544

0.340718

Table P-8: Eligible but not approved NGOs in 2009: countries of membership

Eligible but not selected Austria Belgium Bulgaria Cyprus Czech Republic Denmark Estonia Finland France Germany Greece Hungary Ireland CEE WEB for Biodiversity 1 1 1 1 1 EUROSITE 1 1 1 1 1 1 1 1 1 AGREE.NET 1 1 1 Client Earth 1 1 CERI 1 1

165

Solaris - FZU 1 1 BEF 1 1 AIFM 1 1 1 1 1 1 1 1 GRAB 1 1 EPSD 1 1 1 MedPAN 1 1 1 YEE 1 1 1 1 1 1 1 1 1 ECF 1 1 1 1 1 1 1 1 1 1 1 1 Surfrider Foudation Europe 1 1 1 1 1 EFNCP 1 1 1 1 1 1 1 Total 5 7 6 4 8 3 3 3 8 9 4 9 5

Eligible but not selected Italy Latvia Lithuania Luxembourg Malta Netherlands Poland Portugal Romania Slovakia Slovenia Spain Sweden UK CEE WEB for Biodiversity 1 1 1 1 1 1 EUROSITE 1 1 1 1 1 1 1 1 1 1 1 AGREE.NET 1 1 Client Earth 1 CERI 1 1 1 Solaris - FZU 1 BEF 1 1 AIFM 1 1 1 1 1 1 1 1 1 GRAB 1 1 EPSD 1 1 1 MedPAN 1 1 1 1 YEE 1 1 1 1 1 1 1 1 ECF 1 1 1 1 1 1 1 1 1 1 1 1 1 Surfrider Foudation Europe 1 1 1 1 EFNCP 1 1 1 1 1 1 1 1 1 Total 6 5 6 3 3 7 6 4 8 6 7 7 4 6

166

Analysis of reported outcome indicators

The analysis is based on the indicators reported by the NGOs on the actual application of funds retrieved in the 2008 programme. When incomplete, these data have been assessed using the data on estimated values for the 2009 programme.

167

P.1.1 Indicators on policy development and implementation

Data

Table P-9

168

Figure P-6

Participation in expert groups

0

2

4

6

8

10

12

14

16

0 1 tot 5 6 tot 10 11 tot15

16 tot20

21 tot25

26 tot30

>30

Replies to stakeholder consultations

02468

1012141618

0 1 tot 5 6 tot 10 11 tot15

16 tot20

21 tot25

26 tot30

>30

Participation in stakeholder meetings, public hearings etc,

0

2

4

6

8

10

12

14

16

0 1 tot 5 6 tot 10 11 tot15

16 tot20

21 tot25

26 tot30

>30

Press releases

0123456789

10

0 1 tot 5 6 tot 10 11 tot15

16 tot20

21 tot25

26 tot30

>30

Written submissions to EU institutions

0123456789

10

0 1 tot 5 6 tot 10 11 tot15

16 tot20

21 tot25

26 tot30

>30

Studies undertaken

024

68

1012

141618

0 1 tot 5 6 tot 10 11 tot15

16 tot20

21 tot25

26 tot30

>30

Conference/events organised > 50 participants

02

468

101214

1618

0 1 tot 5 6 tot 10 11 tot15

16 tot20

21 tot25

26 tot30

>30

Conferences/events organised < 50 participants

0

2

4

6

8

10

12

14

0 1 tot 5 6 tot 10 11 tot15

16 tot20

21 tot25

26 tot30

>30

169

Active participation/contributionsto conferences/events > 50 participants

0

2

4

6

8

10

12

0 1 tot 5 6 tot 10 11 tot 15 16 tot 20 21 tot 25 26 tot 30 >30

Active participation/contributionsto conferences/events < 50 participants

0

2

4

6

8

10

12


Other policy areas than environment covered

0

2

4

6

8

10

12

14

16


Actions taken to draw attention to non-compliance with EU policy

0

5

10

15

20

25


Infringement procedures

0

5

10

15

20

25

30


The report and the indicators for Climate action network, Eurosite, WWF European policy office and WWF Danube Carpathian programme are lacking. These values have been filled in with the values for the estimates for 2009, assuming continuity in the working programme and reliability of the estimates. This was not possible for Eurosite.

170

Conclusions: The median of the indicators for each question show the importance of this question,

disregarding outliers. Following medians have been observed:

Table P-10

Participation in expert groups 5 Replies to stakeholder consultations 2 Participation in stakeholder meetings, public hearings etc,

4

Press releases 10 Written submissions to EU institutions 8 Studies undertaken 3 Conference/events organised > 50 participants 3 Conferences/events organised < 50 participants 5 Active participation/contributions to conferences/events > 50 participants

7

Active participation/contributions to conferences/events < 50 participants

6

Other policy areas than environment covered 2 Actions taken to draw attention to non-compliance with EU policy

0

Infringement procedures 0

Press releases, participation in conferences and written submissions to the Commission are the most observed emanations of policy development and implementation.

Attention to non compliance and infringement procedures are the least observed emanations.

A quantitative interpretation of the indicators for policy development and implementation is not easy to make. The spread of the figures and the number of outliers are only to be understood if the nature of the intervention differs. Quality cannot be observed through quantitative figures, which makes it difficult to compare e.g. the number of participations in expert groups or written submissions between NGOs.

Outliers point at a type of specialisation between NGOs, where EEB and ECOS specialise in expert groups, WWF specialises in stakeholder meetings and public hearings, BEF and CEEWEB is studies…

The quantitative indicators as reported by the NGOs are outcome-based. It is an attempt to measure the outcome of the given funding. However, these indicators are designed as if the funds serve to realise a project with a delineated target and an expected end-result. This is however not the case for the operational activities that are funded with this operational funding scheme. NGOs correctly mention in the interviews that a project-approach or project-like indicators are not always applicable on standard operational activities. Operational outcome often cannot be directly measured in the quantity of reports written or expert groups participated in. Operational performance can often only indirectly be observed through witness testimonials from other actors confronted with the operational activities, e.g. the Commissions judgement or appraisal of the quality of the participation in the expert groups, or the appreciation by other NGO insiders on the delivered work, or the degree of staff turnover (limited turnover could indicate higher quality and continuity). Indication on outcome of operational activities is looking at quality, and therefore its indications are often more of an indirect or a qualitative nature.

171

P.1.2 Indicators on education and awareness raising

Data

Table P-11

172

Figure P-7

Communication/education material

0123456789

10

0 1 to 5 6 to 10 11 to 15 16 to 20 21 to 25 26 to 30 >30

Periodicals

0

2

4

6

8

10

12

14

16

0 1 to 5 6 to 10 11 to 15 16 to 20 21 to 25 26 to 30 >30

Educations activities on EU policy implementation and development

0

2

4

6

8

10

0 1 to 5 6 to 10 11 to 15 16 to 20 21 to 25 26 to 30 >30

Subscriptions

0

1

2

3

4

5

6

7

8

0 1 to 500 501 to1000

1001 to1500

1501 to2000

2001 to2500

2501 to3000

>3000

The report and the indicators for Climate action network, WECF, Eurosite, WWF European policy office and WWF Danube Carpathian programme are lacking. These values have been filled in with the values for the estimates for 2009, assuming continuity in the working programme and reliability of the estimates. This was not possible for Eurosite.

Conclusions: The median of the indicators for each question show the importance of this question,

disregarding outliers. Following medians have been observed:

173

Table P-12

Communication/education material 9 Periodicals 6 Subscriptions 1000 Educations activities on EU policy implementation and development

7

All four instruments are used, although some NGOs do not work with subscriptions.

Some NGOs do not focus on education or awareness raising and therefore do not participate in one or more of the possible educational instruments.

o Outliers usually are caused by a non application of a specific instrument, or a mis-interpretation of the requested figure.

o The question on communication material refers to different instruments, and not to the number of e;g. leaflets that have been distributed. This has been misinterpreted by ELO and HEAL.

The question on periodicals refers sometimes to the number of titles or the frequency of emission of a title; weekly, quarterly, monthly…

A quantitative interpretation of the indicators for education and awareness raising makes more sense than on policy development and implementation, because the instruments often are comparable; leaflets, periodicals, subscriptions to electronic newsletters… However a more clear description of the indicator requested could enhance comparability.

Specialisation cannot be observed, except for the distinction between NGOs paying attention to education and awareness raising and NGOs not paying attention to this issue.

174

Indicators on capacity building

Data

Table P-13

175

Figure P-8

Staff training (n° of days)

0

2

4

6

8

10

12

0 1 to 5 6 to 10 11 to 15 16 to 20 21 to 25 26 to 30 >30

Network capacity building

0

2

4

6

8

10

12

14

16

0 1 to 5 6 to 10 11 to 15 16 to 20 21 to 25 26 to 30 >30

Strategic approach development

0

5

10

15

20

25

30

0 1 to 5 6 to 10 11 to 15 16 to 20 21 to 25 26 to 30 >30

Financial management development

0

5

10

15

20

25

30

0 1 to 5 6 to 10 11 to 15 16 to 20 21 to 25 26 to 30 >30

Evaluations

0

5

10

15

20

25

0 1 to 5 6 to 10 11 to 15 16 to 20 21 to 25 26 to 30 >30

Membership development

0

2

4

6

8

10

12

14

16

0 1 to 5 6 to 10 11 to 15 16 to 20 21 to 25 26 to 30 >30

Press coverage

0

2

4

6

8

10

12

14

0 1 to 50 51 to100

101 to150

151 to200

201 to250

251 to300

>300

Web page traffic

0

2

4

6

8

10

12

14

16

0 1 to5000

5001 to10000

10001 to15000

15001 to20000

20001 to25000

25001 to30000

>30000

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The report and the indicators for Climate action network, Eurosite, WWF European policy office and WWF Danube Carpathian programme are lacking. These values have been filled in with the values for the estimates for 2009, assuming continuity in the working programme and reliability of the estimates. This was not possible for Eurosite.

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Conclusions:

The median of the indicators for each question show the importance of this instrument, disregarding outliers. Following medians have been observed:

Table P-14

Staff training (n° of days) 10 Network capacity building 5 Strategic approach development 1 Financial management development 1 Evaluations 3 Membership development 1 Press coverage 20 Web page traffic 24000

Staff training is the major instrument applied for organisational development and capacity building.

Strategic approach development and financial management development are the least mentioned fields for capacity building.

On most indicators a large variation can be observed, this is connected with the accuracy of internal data gathering in the NGOs

o Staff training is difficult to measure when NGOs apply on-the-job training methods.

o Outliers usually are caused by a non application of a specific instrument, lacking data or a mis-interpretation of the requested figure.

Press coverage and web page traffic are not directly connected to capacity building, but more to communication and visibility. Frequently NGOs do not have exact figures on both topics. (In the table above a zero in the second last and last column often means ’no data available’)

On membership development NGOs can be divided in a category that does not grow at all, a category slowly growing in its number of members and a small category growing faster in its number of members.

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Q ANNEX Q: OVERVIEW OF THE LEGAL AND POLICY CONTEXT FOR THE NGO PROGRAMME

Q.1 Content and evolution of the legal and administrative framework

The overview is based upon the former, the intended and the actual legal instruments for NGO funding, completed by the reporting on these instruments, the guiding documents and the evaluation exercises.

Q.1.1 Council Decision 97/872/EC; programme 1998-2001

Council Decision 97/872/EC of 16 December 1997 on a Community action programme promoting non-governmental organizations primarily active in the field of environmental protection.

The Council Decision was initiated to implement the joint Declaration by the European Parliament, the Council and the Commission of 30 June 1982 on various measures to improve the budget procedure. A legal instrument was adopted before appropriations entered in the budget for any new significant Community action could be implemented.

The programme started on 1 January 1998 and ended on 31 December 2001. (three years)

Major eye-catching aspects of this Decision are:

Environmental NGOs are defined as independent and non-profit-making organizations primarily active in the field of environmental protection, with an environmental objective aimed at the public good.

The financial reference amount for the implementation of this programme for the period 1998 to 2001 was ECU 10.6 million or an average of 3.53 million ECU/y.

NGOs have to be active at a European level. The program favours a contribution to a multinational approach, and in particular to cross-border cooperation within the Community and, if appropriate, beyond its frontiers with neighbouring countries.

The rate of overall Community assistance does, in principle, not exceed 50% of the budgeted activities and administrative costs.

Unpaid work or donations in kind may be taken into account to a level of 10% of total eligible costs.

The Commission outlines the priority activities to be financed and details the selection and award criteria and the application and approval procedure

Both ‘running costs’ and activities can be financed: Activities to be financed can be submitted to the Commission by environmental NGOs operating at European level and promoting environmental protection measures of particular interest to the Community. A financial contribution to compensate for administrative costs is considered only for NGOs working at a European level in the context of their general working programme.

The Commission needs to ensure effective monitoring of the implementation of Community-financed activities.

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No later than 31 December 2000, the Commission needed to submit a report to the European Parliament and the Council on the implementation of this programme covering the first three years. Proposals were made for adjustment with a view to continuing the programme. This report, COM(2001) 337 final - Volume I, concluded that the programme should be continued with a number of adjustments.

Q.1.2 Commission report on Council Decision 97/872/EC

Report from the Commission to the Council and the European Parliament on the experience gained in the application of Council Decision 97/872/EC.

Following main conclusions have been drafted:

The scope is limited to NGOs primarily active in the field of environmental protection. This is appreciated by the Commission and the stakeholders for following reasons:

o Expanding the scope or eligible organisations is confronted with the limited funds available

o NGOs suffer from increasing difficulties in receiving funds at national and local level

o Social, development, health, consumer and animal welfare groups are eligible for funding under other instruments

There should be a better distribution of resources among the various regions and between small and large NGOs. Although quotas are not recommended, the EC needs to respect diversity and heterogeneity of the NGO community.

The geographical scope of the programme needs to be expanded to candidate countries and the Balkans, as long as the provisions for being active at a European multinational level remains, and as long as the budgets are increased to cover this new geographical scope.

It should be guarded nor to discourage small (but not necessarily incompetent) organisations while favouring highly-professionalised and well-organised competitors, regardless of which has the better ideas.

One of the eligibility criteria is to ‘contribute significantly to the further development and implementation of Community environmental policy and legislation’. In the field of policy development this is often quite difficult to prove. The impact on political processes is not always easy to measure. The results of lobbying activities may come after many years of struggle and at that point, it may not be possible to identify what actors were crucial for what part of the outcome – and what other external and/or synergetic circumstances had an important impact on the final result.

The selection criteria (organisations with a wide geographical scope, a high multiplier effect, with solid and financially feasible activities in line with Community environmental policies) are assessed as not always easy to apply in practice, and especially difficult for applicants that are new to the Commissions evaluators. The selection criteria need to be formulated and used in a more transparent way, not benefitting either experienced NGOs putting at a disadvantage more grassroots

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level organisations, or not influenced by a desire to promote or disseminate the current environmental policy of the European Union. In general the criteria were judged as imprecise and needed to be redefined.

The NGOs request the Commission to urgently address the bureaucratic procedures and rigorous control systems which they find disproportionate to the sums involved. However clear auditing rules would be an advantage, and prevents channelling of funds to other parts or levels of the organisation.

Next to ‘running costs’, activities could be financed. The rule introduced by the Programme co-ordinator not to accept ‘project funding’ applications from those organisations, which are receiving ‘activity funding’ under the Action Programme, has been heavily criticised by some of the NGOs. However by doing so the Commission tries to avoid the risk for overlapping funding.

A programme length of at least four or five year would secure the continuation of NGO activities at the European level by providing sufficient time for the NGOs to plan their medium and – to some extent – long term strategic priorities.

A multi annual funding would save administration work and time for the Commission and the NGOs and would ensure continuity, but it would require too large budget allocations for DG Environment at the first year of implementation.

The available budget was discussed as too small to cover supplementary workload for the NGOs caused by the increasing role they have to play bridging the gap between citizens and the European institutions, the EU enlargement process including new member organisations with limited resources that have to be covered by the coordination NGOs and the increasing integration of environmental issues in the other policy domains.

All NGOs are in favour or raising the ceiling above 50%. The idea of a flexible percentage of up to 100% is discussed, but it could raise questions of integrity and independence.

Voluntary work is the core of all NGO activities, and consulted NGOs are thus in favour of the provision to include unpaid work or donations in kind, if properly documented, up to a level of 10% of total eligible costs, when assessing environmental NGOs’ revenue and costs. It may be increased, especially for small, effective NGOs. According to the financial service of the Programme co-ordinator, unpaid work or donations in kind usually create more problems than they solve, as they are difficult to account for and therefore do not provide a sound basis for eligible costs.

A regular complaint by the beneficiaries of the Action Programme is related to late payments. The evaluation process – covering both activities and the financial side of all completed NGO programmes – is quite time consuming and demands the attention of a number of officials.

On the annex with the definition of areas of eligible costs NGOs displayed an overwhelming call for it to be reconsidered or even deleted. The detailed, quantified description of eligible activities created a difficult framework for the “programme of activities”, as there are numerous overlaps. The annex does not help in drawing up the work programme, and causes problems for the programme co-ordinator to evaluate applications. Eligible activities should be more strictly related to DG Environments ongoing policies and priorities.

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Q.1.3 Decision 466/2002/EC; programme 2002-2006

Decision No 466/2002/EC of the European Parliament and of the Council laying down a Community action programme promoting non-governmental organisations primarily active in the field of environmental protection.

When the Action Programme introduced by Council Decision 97/872/EC came to an end on 31 December 2001, this new Decision was introduced. The Programme has been evaluated by the Commission and present and previous beneficiaries, revealing a strong support for its renewal or revision. The Sixth Environment Action Programme recognised the need for empowering citizens, and proposed an extensive and wide-ranging dialogue with stakeholders in environmental policy-making.

The Programme started on 1 January 2002 and ended on 31 December 2006. (five years, in accordance with the above mentioned evaluation)

Major eye-catching aspects of this Decision are:

The scope of the Decision is double

o to promote NGOs primarily active in the field of environmental protection and enhancement at a European level.

o to promote the systematic involvement of NGOs at all stages of the Community environmental policy-making process, by ensuring relevant representation in stakeholder consultation meetings and public hearings.

Further the NGOs working to apply the acquis communautaire in relation to the environment and sustainable development in their local area are to be strengthened.

In the definition of NGOs that qualify for a grant, the concept of sustainable development is introduced, next to the concept of environmental protection. Priority action fields are defined in the principles of the Sixth Environmental Action Programme:

o limiting climate change;

o nature and bio-diversity — protecting a unique resource;

o health and environment;

o ensuring the sustainable management of natural resources and waste.

NGOs have to be active at a European level, which means that their activities need to cover at least three (or sometimes two) Member States. NGOs established in the Member States were eligible, as well as in the then 12 accessing countries (now EU-12), Turkey, Former Yugoslav Republic of Macedonia, Albania, Serbia, Bosnia-Herzegovina, and Croatia.

The financial reference amount for the implementation of this programme for the period 2002 to 2006 was € 34.3 million or an average 6.86 million €/y.

The rate of overall Community assistance does not exceed 70 %86 of the applicant's average audited annual eligible expenses during the preceding two years nor 80 % of the applicant's eligible expenses for the current year.

86 80% for Balcan countries and candidate Member States

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Contributions in kind are considered uneligible.

The selection and award process is detailed in annex to the Decision.

A beneficiary is free to use the grant to cover its eligible expenses as it deems appropriate, over the grant year. All expenses incurred by the beneficiary during the grant year are considered eligible. Beneficiaries may also disburse funds to partners or member organisations in accordance with details specified in the approved work programme.

An auditing system is implemented to ensure effective monitoring, the amount of the grant shall become final only once the audited financial statement has been accepted by the Commission. In order to ensure the effectiveness of the grants to environmental NGOs, the Commission takes the necessary measures to verify that a selected organisation still satisfies the requirements for being awarded the grant throughout the grant year.

Not later than 31 December 2004, the Commission needed to submit a report to the European Parliament and the Council on the achievement of the objectives of this Programme during the first three years, with, if appropriate, proposals for adjustments to be made with a view to continuing or not continuing the Programme.

Q.1.4 Mid term evaluation on Council Decision 499/2002/EC

Mid-term evaluation of the implementation of the community action programme promoting NGOs primarily active in the field of environmental protection (Decision 466/2002/EC)

The mid-term evaluation report was prepared by Agra CEAS Consulting Ltd., and was submitted on July 2005. The report sets out the general background, objectives and rationale of the Programme, and the objectives, methodology, detailed work plan, findings, conclusions and recommendations of the evaluation. The most important conclusions are:

A review of the rationale behind the intervention has revealed that, while the intervention logic is well established at a general level in terms of overall strategy and general objectives, the formulation of the Programme’s specific objectives is less clear due to the nature of the intervention and in particular the fact that it aims towards qualitative outputs like involvement and contribution to EU policy-making. This observation confirms previous conclusions in the context of the evaluation of the preceding programme. See above.

The Programme is however considered useful as being effective in meeting the objectives set out in its legal base. The lack of detailed objectives should not be seen as a weakness of the Programme and has to be balanced against the main advantages sought by this approach, which are the increased flexibility and independence it offers beneficiaries. The funding enabled European environmental NGOs and their networks to participate more actively and effectively in the stakeholder dialogue in environmental policy-making, in particular within the objectives of the 6th EAP and the Commission’s work programme. The programme has also contributed to correcting issues of imbalance between the representation of the various stakeholders, and in particular of civil society vis-à-vis the interests of business/industry, although it did not solve this imbalance. The Programme was also found to have important multiplier effects in terms of involving and raising awareness of small regional/local associations and increasing the co-ordination of NGO networks on EU policy issues. It also forged greater cooperation and synergy between beneficiaries, and provided a base for fund-raising from other donors. The improved participation of

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beneficiaries in policy-making is confirmed by their increased visibility at DG ENV policy unit level. The Programme is seen as a vital tool for enabling that participation, while environmental NGOs are generally seen as being a ‘voice for the environment’.

In terms of the programme’s overall layout and implementation, there was consensus on the fact that this already represented significant progress compared to its predecessor, and that as a result of a substantial learning curve over the 2002-04 period for all participants involved (applicants/beneficiaries, Programme management, internal DG ENV evaluators), this was now substantially further improved.

Although beneficiaries’ geographical spread has widened during the 2004-04 period, this has taken place through the membership of mainstream established NGOs in Western Europe, while the direct participation in the Programme from organisations in the New Member States and beyond was still very limited.

Beneficiary outputs have been effective in contributing to the achievement of the programme’s objectives. In particular beneficiaries have achieved to increase the volume and quality of their contributions, increase their attendance of meetings/hearings, make a proven difference to the decision-making process, which is often directly acknowledged by the various public bodies involved, and meet the generally widened objectives of their work programme. However, quantitative indicators on these issues need to be interpreted with particular caution. For example, the number of consultation meetings attended is highly dependent on the policy cycle and does not always reflect the real level of political influence that NGOs can exert on policy-making.

Funding appears to be vital for beneficiary involvement at the current level of activity although not necessarily for their existence per se. The sustainability of the Programme’s impacts appears to be relatively short, indicating the need to continue with the funding for any of its positive effects to last after the end of the intervention period. The majority of beneficiaries would need to reduce immediately and substantially their activities if the Programme was discontinued.

Recommended improvements include:

a more standardised and specific structure for the application form (with the addition of some basic measurable performance indicators);

a review of the eligibility phase of the selection process;

the addition of a final ‘calibration’ step at the end of the award process;

the simplification of reporting requirements and a greater coherence so that they can be used more effectively in the review process;

better information and guidance to applicants;

improved resources in terms of the Programme’s management.

Any changes to the current system should only respond to the need to improve the process by making it more user-friendly and accessible, and should not result in increased or unnecessary bureaucracy thereby undermining the Programme’s utility and flexibility.

The majority of respondents (both amongst beneficiaries and within DG ENV) are in favour of the continuing use of operating grants (core-funding) for their advantages of flexibility and political independence. Other recommendations include the clarification of the application of

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the ‘degressivity rule’, and the need to improve the Programme’s targeting to the underrepresented NGOs regarding geographical spread and regarding specific policy fields.

Multi-annual programming is largely perceived to be difficult to implement, higher risk, and potentially increasing beneficiary vulnerability or compromising their independence. Other options of NGO funding, such as service contracts are widely viewed as complementary rather than alternatives.

Q.1.5 LIFE+ programme funding NGOs for 2007-2013

Commission proposal COM 2004/0621 def. Concerning the Financial Instrument for the Environment (LIFE +)

Regulation (EC) No 614/2007 of the European Parliament and of the Council of 23 May 2007 concerning the Financial Instrument for the Environment (LIFE+).

LIFE+ replaces existing financial programmes such as LIFE, "the Urban Programme", Forest Focus, but also the NGO Programme, grouping them under a single set of rules and decision-making procedures and allowing for more consistent targeting. The scope is to make the Community's work more effective.

The approved Regulation differs in some ways from the Commission proposal. Comparing both versions can be useful to discover the major items or topics that have been considered difficult in the decision making process and that are therefore worthwhile to include in a midterm evaluation.

The regulation will cover the period 2007-2013, for 7 years.

Unlike the previous instruments the LIFE+ Regulation is limited in its provision on how the NGO structural funding should be set up. Aspects relevant to GNO funding are:

art 1: The scope of LIFE+, and thus of the NGO funding included in it, is to implement, update and develop both Community environmental policy and legislation, with focus on the implementation of the sixth environmental action program and its thematic strategies: human health and the environment, greenhouse gas, biodiversity, natural resources and waste, environmental governance and awareness raising. Both the Commission proposal and the adopted Directive are on the same line.

Art 1: Measures and projects are to be financed that have European added value in Member States. The limitation to added value within the European borders was not included in this way in the Commissions proposal, which therefore left some space for crossborder activity.

Art 4 includes in its specific objectives on “Environmental Policy and Governance” the provision: to provide support for better environmental governance by broadening stakeholder involvement, including that of NGOs, in policy consultation and implementation. Both the Commission proposal and the adopted Directive are on the same line. This provision is repeated for the objectives on “Nature and Biodiversity”.

Eligible themes and actions are provided in annex I. This annex is indicative in the Commission proposal but limitative in the approved Directive. In annex 1 is mentioned: “operational activities of NGOs that are primarily active in protecting and enhancing the environment at European level and involved in the development and

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implementation of Community policy and legislation.”. Further a set of actions are included among which studies, surveys, monitoring, capacity building assistance, trainings, workshops, meetings, networking, best-practice platforms, communication, awareness raising, innovative policy approaches, technologies, methods and instruments. The Commission proposed to include themes, referring to the sixth EAP, but this has been covered by the provision in article 1. Supplementary to the Commissions proposal an item was introduced on developing systems directly linked to the implementation of the Community environmental policy and legislation which is a clearly executive measure. It focuses on improving public access to environmental information.

Annex II includes as one of the principal objectives of LIFE+ to promote NGOs which are primarily active in the field of environmental protection at European level

o strengthening the participation of NGOs in the dialogue process in environmental policy-making and in its implementation,

o strengthening the participation of NGOs in the European standardisation process in order to ensure balanced stakeholder representation and the systematic integration of environmental aspects.

The Commission proposal did not include a comparable annex but referred to multi annual strategic programmes to be drawn up by the Commission.

Art 5: Types of intervention are described. These include grants, which may take the form of framework partnership agreements, participation in financial mechanisms and funds, or co-funding of operating or action grants. Operating grants to bodies of general European interest shall not be subject to the degressivity provisions of the Financial Regulation (see Section Q.1.7). Only for action grants a maximum rate of co-financing is included in the Directive and in the Commission proposal.

Art 6: For action grants the Directive endeavours to foresee at least 15% of the budgetary resources dedicated to action grants for transnational projects where transnational cooperation is essential to guarantee environmental protection. For operating grants this is not foreseen in the Directive.

Art 8: LIFE+ is open to Member States, EFTA states member of the EEA, accession candidate countries and Western Balkan countries included in the Stabilisation and Association Process. Both the Commission proposal and the adopted Directive are on the same line.

Art 9: Measures cannot be financed if they fall within the eligibility criteria and main scope of other Community financial instruments, or if they receive assistance from these for the same purpose. The Commission should report on steps taken of coordination and complementarity in the context of a.o. the mid term review. Both the Commission proposal and the adopted Directive are on the same line.

Art 10: the total budget for LIFE+ is about € 2.143 million or average 306 million €/y. At least 78% of this is allocated to action grants for projects. The rest (maximum 22%) can be allocated to both operating grants and public procurement contracts. Operating grants do represent 3% of the total LIFE+ Budget87. This means an average of 9.18 million €/y.

Art 14: the implementation decisions that can be taken in comitology procedure are well defined, unlike the Commission proposal.

87 Source?

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Q.1.6 Implementing measures for LIFE+ NGO funding

Application guide NGO operating grants call for proposals 2010

Implementation measures which are no longer included in the legal framework are now included in the detailed information on the call for proposals and the advice on how to prepare applications.

Major eye-catching aspects are:

The indicative budget for 2010 is € 9.000.000, which is less than the above calculated theoretic average, and is pending the approval of the corresponding appropriations by the budgetary authority.

Organisations that can be co-financed must fulfil the following eligibility criteria

o They must be independent and non-profit-making

o They must be primarily active in the field of environmental protection and enhancement with an environmental objective aimed at the public good and with a view to sustainable development

o They must be active at a European level, either singly or in the form of several coordinated associations, and they must cover at least three EU Member States.

o Activities and membership base should primarily be at the European level. The 2008 and 2010 Application Guide excluded explicitly NGOs with activities and membership base primarily at the international level. This was not the case with 2009 Guide.

o They should be legally established in one of the EU Member states (excluding the EFTA, accession or Western Balkan countries mentioned in article 7 of the LIFE+ Directive).

o Its activities must in particular meet the principles underlying the Sixth Environment Action programme.

o They must be legally constituted for more than 2 years, proven by certified accounts. Derogations are possible, such as the creation of a new network by experienced NGOs.

o Its financial resources are not exclusively made up of subsidies from European Union institutions88. Moreover, the budget estimate for the proposed activities must be in balance.

The maximum EU-funding rate is 70 % of the eligible costs of the operating budget of the beneficiary organisation.

No overheads may be charged to other EC supported actions or other funding sources89.

In 2010, the maximum request is limited to the amount awarded in 2009 for organisations that have been awarded an operating grant under the programme for 2009. In 2009, the maximum request was limited to the amount awarded for 2008 plus 3% for organisations that have been awarded an operating grant under this programme for 2008.

88 This requirement follows from Article 109 of the Financial Regulation – see Section Q.1.7 89 This requirement follows from Article 111 of the Financial Regulation – see Section Q.1.7

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The pre-financing payment corresponds to a maximum of 60% of the Commission’s contribution.

The Selection and Award Process shall take place in live successive phases

o Verification of applications against receivability criteria

o Verification of applications against eligibility criteria

o Verification of applications against exclusion criteria

o Verification of applications against selection criteria

o Assessment of applications against award criteria

Receivability criteria include formal administrative characteristics of the file entered, and look at deadlines and completeness.

Eligibility criteria have been listed above (second bullet point).

Exclusion criteria verify that the applicant is in none of, inter alia, the following situations: bankrupt or being wound, convicted, guilty of grave professional misconduct, not fulfilling obligations related to the payment of social security contributions, having been the subject of a judgement for fraud, corruption, involvement in a criminal organisation or any other illegal activities, subject to conflicts of interest, declared to be in serious breach of contract.

Selection criteria include the technical soundness and the financial soundness of the candidates.

Award criteria finally are used to evaluate the overall quality and interest of the complying proposals that have been entered.

o The work programme of the applicant should further the objectives described in the Sixth Environment Action Programme in one or more of the priority areas. The grants will be awarded with a view to the successful completion of those work programmes deemed the most suitable. Priority areas are climate change, nature and biodiversity, environment and health, natural resources and waste, horizontal and cross cutting issues like standardisation. The NGO work programme should demonstrate policy relevance and potential impact of involvement in Community environmental implementation and/or policy-shaping.

o Focus on awareness raising, environmental education, enlargement and third countries in relation to the above mentioned policy areas. Compared to the 2008 Application Guide, the 2009 and 2010 Guide have added the clarification that since LIFE+ is an instrument for support within the EU, the part of the award criteria relating to enlargement and third countries refers to international aspects of work for which costs are incurred within EU-27. The 2010 Application Guide has added a more detailed discussion of the aspects that will be assessed in the fields of policy relevance, potential impact, and awareness raising and international aspects. It clarifies also that international aspects of the NGOs activities should be appropriate in promoting EU policy outside the EU.

o The work programme demonstrates potential for organisational capacity building effects on organisational structure and staffing, strategic approach, financial management, evaluation and reporting, technical competence and visibility.

A point system is applied to evaluate the applications against the award criteria taking into account all three sets of award criteria.

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The selection of an application by the Commission does not constitute an undertaking to award a financial contribution equal to the amount requested by the beneficiary. The Commission reserves the right to reduce the grant requested if the proposal includes elements considered too expensive or not eligible. In addition, since there is a limited overall budget for the funding programme, the Commission reserves the right to propose a level of support Iower than that requested. The awarding of the grant does not establish an entitlement for subsequent years. The Commission may invite applicants to provide a revised budget.

The Commission will calculate its contribution as a percentage of the total eligible costs of the implementation of the work programme. Co-financing implies that part of the running costs of an entity is borne by the beneficiary of a grant, or by contributions other than the Community contribution. Beneficiaries must supply evidence of the co-financing provided.

No double financing is allowed. Beneficiaries of an operating grant may however be awarded one or more grants for an action for one or more specific measures, but overheads through a grant agreement for an action are not allowed.

Eligible costs are: personnel, travel and subsistence, rental, equipment and depreciation, external assistance / subcontracting, overheads / general administration. Non eligible are a.o. contributions in kind, expenses incurred outside EU-27

Only the costs incurred by the beneficiary organisation signing the grant agreement with the Commission can be considered as eligible. Member organisations may participate in the implementation of the work programme, but costs incurred by member organisations are not considered eligible costs. This is a change compared to the 2002-2006 programme.

The beneficiary may be audited on the use made of the grant carried out either directly by its own staff or by any other outside body authorised to do so on its behalf. Such audits may be carried out throughout the period of implementation of the agreement until the balance is paid and for a period of five years from the date of payment of the balance.

Q.1.7 Financial Regulation

The Financial Regulation90 (FR), together with its Implementation Rules (IR), determines the framework of the NGO funding programme.

We discuss here the provisions that are relevant in the context of the current study.

Article 108 of the FR defines grants as direct financial contributions, by way of donation, from the budget in order to finance:

(a) either an action intended to help achieve an objective forming part of a European Union policy;

(b) or the functioning of a body which pursues an aim of general European interest or has an objective forming part of a European Union policy.

Grants are covered either by a written agreement or by a Commission decision notified to the successful applicant.

90 Council Regulation (EC, Euratom) No 1605/2002 as amended by Council Regulation (EC, Euratom) No 1995/2006 and by Council Regulation (EC) No 1525/2007.

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Article 162 of the Implementation Rules (IR) clarifies that a body pursuing an aim of general European interest is:

(a) a European body involved in education, training, information, innovation or research and study on European policies, any activities contributing to the promotion of citizenship or human rights, or a European standards body;

(b) a European network representing non-profit bodies active in the Member States or in the candidate countries and promoting principles and policies consistent with the objectives of the Treaties.

Specific grants may form part of a framework partnership (Article 163 of the IR). A framework partnership may be established as a long-term cooperation mechanism between the Commission and the beneficiaries of grants. It may take the form of an agreement or a decision. The framework partnership agreement or decision shall specify the common objectives, the nature of actions planned on a one-off basis or as part of an approved annual work programme, the procedure for awarding specific grants, in compliance with the principles and procedural rules of the Title covering grants, and the general rights and obligations of each party under the specific agreements or decisions (emphasis added).

The duration of the partnership may not exceed four years, save in exceptional cases. Framework partnership agreements or decisions shall be treated as grants for the purposes of the award procedure.

Article 164 of the IR specifies the minimal contents of a grant agreement. In the case of an operating grant, this includes the work programme approved by that year by the authorising officer.

Grants may take any off the following forms (Article 108a of the FR):

(a) reimbursement of a specified proportion of the eligible costs actually incurred;

(b) lump sums;

(c) flat-rate financing;

(d) a combination of the forms referred to in points (a), (b) and (c).

Flat-rate financing shall cover specific categories of expenditure which are clearly identified in advance either by applying a percentage fixed in advance or by the application of a standard scale-of-unit cost (Article 180a of the IR)91.

According to Article 109 of the FR, grants may not be cumulative or awarded retrospectively and they must involve co-financing (emphasis added). This article also specifies that grants may not have the purpose or effect of producing a profit for the beneficiary. Article 113 adds that the grant may not finance the entire operating expenditure of the beneficiary body.

Co-financing shall require that part of the cost of an action or of the running costs of an entity is borne by the beneficiary of a grant, or by contributions other than the Community contribution (Article 165a of the IR).

91 Examples of flat rate financing of NGO programmes are provided in Section Q.2.

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A beneficiary may be awarded only one operating grant from the budget per financial year, and in no circumstances shall the same costs be financed twice by the budget (Article 111 of the FR).

According to Article 172 of the IR, the authorising officer may accept co-financing in kind, if considered necessary or appropriate (emphasis added).

Chapter 3 of the FR discusses the award procedure. Article 115 requires the award criteria to be such as to make it possible to assess the quality of the proposals submitted in the light of the objectives and priorities set. Article 176 of the IR specifies that the award criteria shall be published in the call for proposals. Article 116 of the FR determines that the proposals shall be evaluated on the basis of pre-announced selection and award criteria, and that the authorising officer draws up the list of beneficiaries and the amounts approved. If the grant request is not awarded, the institution shall give the reasons for the rejection of the application.

The authorising officer responsible shall appoint a committee to evaluate the proposals, unless the Commission decides otherwise in the framework of a specific sectoral programme. Outside experts may assist the committee by decision of the authorising officer responsible (Article 178 of the IR, emphasis added).

Q.2 Other Commission departments' schemes for operating grants to NGOs

In this section, we survey some schemes for NGO operating grants that are managed by other departments of the Commission.

Q.2.1 Youth in Action Programme

Decision 1719/2006/EC of the European Parliament and of the Council established the Youth in Action programme for the period 2007 to 2013. The decision lists the general objectives of the programme:

(a) to promote young people's active citizenship in general and their European citizenship in particular;

(b) to develop solidarity and promote tolerance among young people, in particular in order to reinforce social cohesion in the EU;

(c) to foster mutual understanding between young people in different countries;

(d) to contribute to developing the quality of support systems for youth activities and the capabilities of civil society organisations in the youth field;

(e) to promote European cooperation in the youth field.

The programme supports 5 operational actions. Some of these operational actions are covered by specific calls. For the purposes of this study, only Action 4.1 is relevant.

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Indeed, Action 4.1 of the Programme provides support for the operating costs of bodies active at European level in the field of youth and pursuing an aim which is of general European interest92.

An annual grant may be awarded to help such bodies meet their operating costs. These bodies may be:

a not-for-profit organisation performing its activities on behalf of young people at European level,

a European network representing bodies working on behalf of young people.

The call does not concern organisations which have concluded a Framework Partnership Agreement with the Education, Audiovisual and Culture Executive Agency.

On some points, the eligibility criteria are less strict than under Life+. For instance, with respect to the “minimal age” requirement, it is sufficient that the body is legally registered for one year on the date of submission of applications. The eligible countries also include the EFTA countries in the EEA, the countries applying for membership of the European Union and benefiting from a preaccession strategy, the countries of the Western Balkans and some East European Countries.

The Community financial assistance cannot exceed 80% of the total operating costs. However, contributions in kind (except of the real-estate kind) are considered an eligible source of co-financing.

Moreover, the 2009 call imposes a ceiling of 35 000 EUR on the maximum Community grant for each body.

Applicants can apply under two different systems: budget based or flat rates. In the case of flat based financing, the grant is calculated on the basis of a fixed amount per staff member on the payroll – full and /or part-time – of the organisation up to a maximum. It excludes subcontracting, the voluntary work and the trainees. In the case of budget based financing, the final grant is based on a detailed final financial statement.

Summarizing, the main differences with the Life+ NGO Programme are:

There is no requirement for a membership base constituted by member organisations

Less stringent requirements concerning age

Broader geographical coverage

Ceiling on the maximum Community grants for each body

Contributions in kind (except of the real-estate kind) are an eligible source of co-financing

It is possible to apply for flat rate financing

92 Call for Proposals — EACEA/25/09

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Q.2.2 Citizenship Programme

This programme supports a wide range of activities and organisations involving “active European citizenship”93. It is open to all stakeholders promoting active European citizenship, including NGOs.

It supports two types of grants:

Grants for projects

Grants for the operating budget of a body promoting active European citizenship

The value of voluntary work and other in-kind contributions are not to be formally included as eligible costs.

When a project is approved, the beneficiary receives either a Grant Decision or a Grant Agreement, depending on the specific action/measure and the place where it is legally established.

Where the implementation of the action/project requires subcontracting or the award of a procurement contract, the coordinator and, where applicable, its co-beneficiaries must obtain competitive tenders from potential contractors and award the contract to the bid offering best value for money.

The programme is open to the Member States of the European Union, but can also be opened to other countries, namely the EFTA states which are parties to the EEA Agreement, the candidate countries and countries from the Western Balkans, provided that certain legal and financial obligations are fulfilled. In June 2009, Croatia, the Former Yugoslav Republic of Macedonia and Albania were participating countries94.

For the purposes of this study, we can focus on Action 2 of the Programme, which supports civil society organisations and think tanks, and is composed of three measures:

Structural support for think-tanks (measure 1)

Structural support for civil society organisations at European level (measure 2)

Supports to projects initiated by civil society organisations (measure 3),

The 2009 Specific Call for Proposal (EACEA/11/2009) awards both Annual Operating Grants and Multi-Annual Strategic Partnerships for Action 2, measures 1 and 2.

To be eligible, organisations must:

pursue an aim of general European interest,

be a non-profit making organisation with a legal personality (application by networks may be presented by the member organisation coordinating the network)

operate in the field of European citizenship and correspond to the categories covered by measure 1 or 2

93 Reference: information on the Citizenship Programme on the website of the EACEA. 94 http://eacea.ec.europa.eu/citizenship/programme/who_participate_en.php

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undertake the majority of their activities in eligible countries (emphasis added)

The details of the last requirement depend on whether the grant follows from a multi-annual partnership or from an annual grant.

For multi-annual partnerships, the organisations involved must have been established legally and have had a legal personality for at least four years in an eligible country and cover the following geographical area:

European umbrella organisations and European networks must have members in at least twelve eligible countries;

Organisations performing activities with a wide impact on Europe must be active in at least twelve eligible countries.

Pan-European umbrella organisations must have at least six central organisations among their members, who must be present in the 27 Member States.

To be eligible for an annual grant, the organisations involved must have been established legally and have had a legal personality for at least one year and cover the following geographical area:

European umbrella organisations and European networks must have members in at least eight eligible countries;

Organisations performing activities with a wide impact on Europe must be active in at least eight eligible countries.

Pan-European umbrella organisations may only submit an application within a multi-annual partnership. Individuals and public bodies are not eligible to apply for this call.

The award criteria do not include criteria related to organisational development.

In the call for 2010, it was expected that 85% of the budget would go to grants for multi-annual partnership.


Both Grant Decisions or Grant Agreements are possible

Broader geographical scope than EU27.

No requirement for a membership base constituted by member organisations

Organisations must undertake the majority of their activities in eligible countries

Multi-annual partnerships are possible, and are even required in some cases

More stringent eligibility requirements for minimum age and geographic coverage

Q.2.3 Support for cultural bodies

The Culture programme supports cultural bodies which operate or seek to operate at the European level.

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The Programme Guide for the Culture Programme (2007-2013) explains that the Commission encourages culture in two ways:

Through policies (chiefly cultural policy)

Through financial support primarily via the Culture Programme, but also via other actions such as for example within the framework of regional policy

The Culture Programme supports three types of activities:

Strand 1: Support for cultural projects

Strand 2: Support for organisation active at European level in the field of culture

Strand 3: Support for analyses and for the collection and dissemination of information and for maximising the impact of projects in the field of cultural cooperation

For the purposes of this project, it is mainly Strand 2 that is of interest.

Cultural organisations working, or wanting to work at the European level in the field of culture can receive support for their operating costs (emphasis added).

To be eligible, applicants must have their head office in one of the countries taking part in the Programme:

The Member States of the European Union

The countries of the EEA (Iceland, Liechtenstein and Norway)

The applicant countries of accession to the European Union (Croatia, Turkey, the Former Yugoslav Republic of Macedonia, Serbia and Montenegro)

The countries of the Western Balkans (Albania and Bosnia and Herzegovina) may become eligible in the future, provided they conclude a memorandum of understanding laying down details of their respective participation in the Programme.

The usual financial conditions (co-financing, no double financing, non-retroactivity, no-profit rule) apply. Co-financing is not required for grants awarded at a flat rate.

Grants are calculated either on the basis of a detailed budget or flat-rate financing. In the case of operating grants, flat-rate financing is calculated on the basis of a fixed amount (up to a maximum) per person working for the implementation of the organisation’s work programme.

Under this programme, Grant Decisions are used for literary-translation projects only. Grant agreements can be either annual or multi-annual. In the case of multi-annual agreement, a specific form is the Framework Partnership Agreement. Such an agreement is used for strand 2 and is implemented though specific annual agreements.

Where implementation of the action requires subcontracting or the awarding of procurement or service contracts, the beneficiary and its co-organisers must obtain competitive tenders.

The potential for organisational development is not explicitly part of the award criteria.

Four types of organisations are eligible under Strand 2:

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European Cultural Ambassador

Advocacy networks

Festivals

Organisations actively engaging in a structural dialogue with the European Commission in the framework of the European Cultural Agenda; a further distinction is made between “structured-dialogue platforms” and “policy-analysis groupings”.

The eligibility criteria (minimum number of years during which the organisation must have had legal personality, number of organisations in which the organisation must have member or be active) depends on the type of organisation. For instance, ambassadors must have possessed legal personality for at least two years, whilst the only requirement for “political-analysis groupings” is that they must be legally established or represented by a member organisation that is legally established and duly mandated. “Political-analysis groupings” must comprise members that are legally established in at least three countries taking part in the Programme, while advocacy networks must form a network of members that are legally established in at least 15 countries taking part in the programme.

The degressivity rule of the FR applies to this programme.


The programme is open to organisations who are not yet working at the European level


It is possible to apply for flat rate financing

The eligibility criteria depend on the type of organisation

The degressivity rule applies

Q.2.4 Support to European consumer organisations

The Executive Agency for Health and Consumers may award financial contributions for the activities of European consumer organisations (actions 5 and 6 of Decision N° 1926/2006/EC establishing a programme for Community action in the field of consumer policy).

Financial support may be awarded towards the functioning if two types of European organisations95:

Those which have as their primary objectives and activities the promotion and protection of the health, safety and economic interests of Consumers in the Community (action 5)

Those which have as their primary objectives and activities to represent consumer interests in the standardisation process at Community level (action 6)

In order to be eligible for Action 5, organisations must be, inter alia:

95 EAHC, Funding for European consumers organisations. Call for proposals 2009.

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Non-governmental, non-profit-making, independent of conflicting interests

Have been mandated to represent the interests of consumers at Community level by national consumer organisations in at least half of the Member States that are representative, in accordance with their national rules or practice, of consumers and are active at regional and national level

In order to be eligible for Action 6, organisations must be, inter alia:

Non-governmental, non-profit-making, independent of conflicting interests

Have been mandated in at least two thirds of the Member States to represent the interests of consumers at Community level:

By bodies representative, in accordance with national rules or practice, of national consumer organisations in the Member States

In the absence of such bodies, by national consumer organisations in the Member States that are representative, in accordance with national rules or practice, of consumers and are active at national level.

Only organisations with the necessary operational resources, skills and professional experience may be awarded a grant. There are no formal minimal age requirements.

The maximal co-financing is 50% for Action 5 and 95% for Action 696. The financial contribution may also be given in the form of flat-rate or lump sum financing. Co-financing is then still required, although the percentage limits do not apply.

As regards the participation of third countries, the programme is open:

To EFTA/EEA Countries, in accordance with the conditions established in the EEA Agreement

Third countries, in particular countries to which the European Neighbourhood Policy applies, countries that are applying for, are candidates for, or are acceding to, membership of the European Union, and the western Balkan countries included in the stabilisation and association process, in accordance with the conditions laid down in the respective bilateral or multilateral agreements with those countries establishing the general principles for their participation in Community programmes.



It is possible to apply for flat rate financing or lump sum financing

The requirements concerning the membership base are much more stringent

96 Decision N° 1926/2006/EC, Article 4.

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R ANNEX R: IDEA FOR INCREASING EU VALUE ADDED THROUGH MUTUAL LEARNING

R.1 What is the Problem this Proposal Responds to?

The Action Grant Programme (especially EPG) suffers from a lack of focus in terms of the specific policy needs it is supposed to address, with the result that the projects have a fairly random capacity to provide specific direct policy benefits. Learning and demonstration benefits of projects as a programme are also lost; the benefits are essentially project specific. The lack of focus results from the broad terms of reference provided by the LIFE+ Regulation. The potential for further learning benefits could be realised with a more specific focus on this aspect of the programme with more specific targeted learning with policy makers.

A solution needs to be found to provide a more specific statement of and focus on policy needs and a means to secure greater learning and policy application from the projects.

One Solution Lies in Commissioning an Explicit Learning Programme to Address Explicit Policy Needs, where Learning is informed by Peer Learning Activities Based on Selected Projects

R.2 What is a Peer Learning Activity97?

Peer-learning activity (PLA), sometime referred to as mutual learning, combines elements of peer-review by stimulating in-depth discussion on case studies of approaches and practices being presented without actually engaging in full assessment of approaches presented. This element is addressed through presentation and discussion of several approaches/practices aimed to address a similar issue but using different methods developed and tested in different contexts, leading to a detailed comparison and contrasting of the case study examples.

It is a learning opportunity for the policy makers participating. Therefore the learning content as well as the learning context are crucial. The learning content is not delivered as such but it is created through the exchange among participants, stimulated by carefully selected inputs of research, innovation and demonstration. The learning context is influenced by the set up of the agenda, the composition of the group of policy makers and the facilitation skills of those moderating discussions.

- The typical confusions:

o Peer-learning is not a dissemination activity. It is not about presenting a practice in the perspective of communication. While it is important to present different approaches to tackling a specific policy issue, it is necessary that these present a mixture of approaches - possibly even contrasting. The outcomes/conclusions of a PLA should go beyond the messages presented in the different approaches and practices.

o Peer-learning is not a working group either. It is not about delivering a product at the end of the activity. While it is important that the outcomes of the learning

97 This concept is borrowed from the ENQA-VET policy brief on peer-learning developed in the context of quality assurance of vocational education and training programmes. The link provides a useful explanation of PLA and how is it expected to operate http://www.enqavet.eu/documents/PolicyBriefPLA000.pdf

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process are captured it is not clear at the beginning of the activity what the outcomes will be. In other words the participants are driving the learning process themselves and as part of this exercise they will formulate the messages and the form these should take.

R.3 What are the difficulties of existing peer-learning activities?

o Peer-learning is most effective if the ‘learners’ in this case the policy makers are interested in learning. A typical problem is that in some cases the policy makers were delegated / requested to participate attend which diminishes the chances of spontaneous engagement in learning. Participants need to want to learn!

o Ensure clear discussion on the scope for transferability – examine the conditions for success where approaches are judged to have been effective and whether these conditions can be met in other locations, etc. Facilitators need to ensure that such debates are part of the compare and contrast discussion

o Clear definition of roles in the Learning Process. People with several ‘profiles’ are responsible for a peer-learning activity:

Technical staff with knowledge of the underlying problems and policy needs and an appreciation of possible approaches – responsible for specifying the policy need, and its inclusion in the call for proposals and for advising, with the facilitator, on the selection of projects that would contribute to the PLA

Policy makers wishing to address the particular problem and willing to invest time in both researching and developing responses and to participate in a peer learning exchange – responsible for Action Grant funded projects contracted in response to the call

Facilitators of the learning process – responsible for managing and promoting the exchange, and in the first instance working with the technical staff to ensure calls for proposals reflect the requirements

NCPs in MS where the defined policy needs are of particular interest – responsible for animating interest and promoting the PLA as a means of adding greater value to their participation in the Programme

o Choosing and organising methods for PLA during and after the project research activity. Different types of items can figure on the agenda: presentations, panel discussions, field visits, workshop sessions, small working groups, etc. Each of these types of activities has its own character and requires different considerations for preparation. Some PLAs can take 3 days others can be done in 1.5 days – depending on numbers of approaches and complexities and the methods chosen for the PLA. Early consideration and planning based on the pros and cons of a short event versus a longer one is advisable.

R.4 How might the Process Work for LIFE+ under the Current Regulation?

1. Early planning of the activity will be essential. Two things need to happen prior to the drafting of calls. First the specific policy needs to be addressed by the call need to be defined, based on technical advice from the EC policy units and feedback from the MS

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(perhaps using State of Environment reports as a starter). Second, based on a the statement of policy needs, the relevant actors and networks in the relevant MS need to be alerted to the intended call, advised on the interest in PLA, and allowed time for potential applicants to consider their interest and secure their matched funding in time for the call.

2. The LIFE Unit (or relevant Policy Unit) separately commission a facilitator for the PLA to work with the potential projects during the contracting of projects to ensure requirements and planning for PLA are embedded in work programmes and to manage specific and planned PLA events. The facilitator might also be a resource for relevant applicants during the preparation of proposals.

3. The call for proposals will include a call for projects for peer learning to address the defined policy problem (for example a particular problem in the transposition or enforcement of a particular element of legislation), specified in the first step. In (some / most?) cases the PLA is likely to depend on different experiences across MS in which case the EC would need to have identified common problems across at least a sub-set of MS.

4. Where forward planning was not undertaken or where additional interest needs to be animated. NCPs could be tasked with promoting the PLA as a means of adding value to potential beneficiaries and explaining that PLA is more than just disseminating findings. Since transnational exchange of experience is likely to enrich PLA then NCPs across MS should be encouraged to co-operate

5. Project selection criteria (which in any case need to be revised) would include a specific criterion in relation to planned PLA activity

6. Project contract negotiation would ensure a commitment to the PLA

7. The LIFE Unit disseminate the results of the PLA to the wider policy community.

8. The LIFE Unit collate relevant evidence to inform future impact assessments on reforms of environmental legislation

R.5 Possible Problems with Adoption

The main problem is likely to be a concern that the specification of a particular policy need may be taken to privilege this issue above any others covered in Annex II. However, since the policy need is expected to reflect the importance of the need in at least a sub-set of MS, then, as long as the specification provided evidence of the need with respect to individual MS and confirmed that the specification was consistent with MS priorities there would appear to be no conflict with Article 6 of the Regulation governing programming and project selection. One possibility to make the proposal more acceptable (if required) might be to include it in the call under the INF component, in support of mutual learning (as referenced in Para 9 of the Regulation).

A second potential problem is the scope to encourage NCPs to take a particular interest in and support for the specification and for PLA and especially in support of a transnational response. The solutions relate to the wider issue of the NCP contribution to the LIFE+ Programme and the need for measures to extend their role. Note that because of the specific focus the relevant actors and networks will be far easier to identify and target.

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Another difficulty is the need to revise the project selection criteria to include a specific question on PLA. Since the criteria need revision in any case the inclusion of the question should not be difficult as part of the .broader revision. The change will however allow the specific introduction of the management / regulatory committees to the ideas of PLA.

A final difficulty is to ensure projects are willing and able to engage with the facilitator and projects recognise the required investment of time in the exchange and learning process.

Documents

life.lifevideos.eu · 4 CONTENTS A ANNEX A: SUMMARY OF THE INTERVENTION LOGIC FOR LIFE+ .......................................... 5 B ANNEX B: SUMMARY OF THE CONCLUSIONS OF THE EX-POST