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greening projects

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									How to green projects within the Structural Funds programmes
Based on the analysis of Regional Development Programmes (Czech Republic, Hungary and Poland)
developed by Expert-Europe Consultants in co-operation with Debrecen University and contributions from
GRDP partners (to be fully acknowledged in the final report)

1. Introduction .................................................................................................................................................................. 2

2. Project identification .................................................................................................................................................... 2

     2.1 Content of calls ........................................................................................................................................................ 2
     2.2 Conclusions .............................................................................................................................................................. 3

3. Information flow ........................................................................................................................................................... 3

     3.1 Personal communication.......................................................................................................................................... 3
     3.2 Information flow of documents................................................................................................................................. 5
     3.3 Conclusions .............................................................................................................................................................. 5

4. Application form ........................................................................................................................................................... 5

     4.1 Format of an application form ................................................................................................................................. 5
     4.2 Conclusions .............................................................................................................................................................. 7

5. Project appraisal ........................................................................................................................................................... 7

     5.1 Project assessment ................................................................................................................................................... 7
     5.2 Conclusions .............................................................................................................................................................. 8

6.       Project approval ...................................................................................................................................................... 8

7.       Monitoring ............................................................................................................................................................... 9

     7.1 Monitoring ............................................................................................................................................................... 9
     7.2 Conclusions .............................................................................................................................................................. 9

8. The compliance of projects with other environmental requirements ...................................................................... 9

     8.1 Sustainability as a horizontal priority ...................................................................................................................... 9
     8.2 NATURA 2000 ....................................................................................................................................................... 10
     8.3 Environmental impact assessment ......................................................................................................................... 10

9. Institutional framework ............................................................................................................................................. 11

10. Recommendations ..................................................................................................................................................... 11

     10.1 Projects identification .......................................................................................................................................... 11
     10.2 Information flow................................................................................................................................................... 12
     10.3 Application form .................................................................................................................................................. 12
     10.4 Project appraisal ................................................................................................................................................. 13
     10.5 Monitoring ........................................................................................................................................................... 13
     10.6 The compliance with other environmental requirements ..................................................................................... 13
     10.7 Institutional framework ........................................................................................................................................ 14
     10.8 Other recommendations ....................................................................................................................................... 14
                                                                                      Draft (26 September 2005)
1. Introduction

The overview on „greening‟ projects supported by the Structural Funds was done on the basis of the analysis
of three regional operational programmes (ROPs) from the Czech Republic, Hungary and Poland1. Expert-
Europe Consultants in co-operation with Debrecen University prepared the original report, covering a wider
range of environmental integration issues, within the GRDP project. This information was supplemented by
contributions from other GRDP partner countries (Italy, Malta, Spain and UK)

In order to examine the opportunities for greening projects within the Structural Funds programmes, the
consultants examined the following issues:
 project identification;
 information flow;
 application forms;
 project approval, evaluation criteria and selection;
 monitoring;
 project environmental compliance;
 institutional framework.

The analysis of these issues resulted in a set of recommendations gathered at the end of this report.

2. Project identification

A variety of methods are in place in EU project development by the national authorities. For
instance the selection of projects suitable for EU funding out of a sample of already approved
national funded projects. Another possibility is the project identification in the case of national
priority –without a selection process at all. For instance the enlargement of the national airport or
some major infrastructure projects (as highways). For these projects the “identification” is done
normally already on the political level and the project development is the main task of the involved
authorities. These examples are very specific and are not subject of further treatment in this guide.
The most common system of project identification is the call for proposals.


2.1 Content of calls

The calls for proposals, organised on a regular basis, initiate the procedure of applying for the funding from
Structural Funds. A managing authority of the ROP sets up, several times per year, dates for such calls. For
each priority, there are as many rounds of calls, during one period, until funding is available.

Calls can be made publicly available via different information sources. Newspapers and web pages of
responsible regional and managing authorities are usually used. They are generally available only in national
languages. A managing authority also ensures that calls are advertised in nation-wide newspapers.

The review of the calls launched within the Czech ROP shows that the content of the call for each priority
and its measures is usually similar, regardless of the priority. It typically includes a number of points as
shown below. Calls are also similar across all operational programmes

.

A typical content of a call is:

1
 In all countries in our comparison, the English name of this Operational Programme is slightly different: the Czech
Republic - Joint Regional Operational Programme, Poland - Integrated Regional Operational Programme, Hungary –
Operational Programme for Regional Development. This report refers to these programmes as Czech Regional
Operational Programme (Czech ROP), Hungarian Regional Operational Programme (Hungarian ROP) and Polish
Regional Operational Programme (Polish ROP)

                                                                                                                       2
                                                                                   Draft (26 September 2005)

Description of the relevant priority and measure (sub-measure)
Major priority/measure objectives
 List and description of projects eligible for financing
 List of possible final beneficiaries eligible for proposing and implementing the project
 Recommended structure of financing
 Minimum and maximum funding per project
 Location of the project (in the relevant NUTS II region)
 Duration of the project
 Other information - selection criteria, additional requirements, links to useful materials and other
   relevant information.

The calls are the first information available to potential applicants and they provide a basic description on the
types of projects to be submitted.

2.2 Conclusions

   Environmental issues were not included
   The calls includes a list of eligible proposals but they are missing a list of non-eligible
    proposals/projects/measures and environmental constraints
   Good examples from calls in “Old“ Member States
   Project selection criteria are included
   (General or environmental?) Instructions for proposals preparing are available
   Methods listed – (explain, what’s there relevance to environment?)
   More detailed environmental information is maybe not necessary at this stage if selection criteria
    (including environmental criteria) are listed

3. Information flow

3.1 Personal communication

Between responsible authorities and applicants

The next logical and critical step in the application process is the information flow between applicants and
responsible authorities. After the applicants‟ interest is initiated for instance by the calls, all kinds of
questions have to be answered by relevant authorities as „Regional development offices‟ or ”Centres for
regional development”. Employees of these offices are expected to give recommendations concerning the
formal side of an application and also suggest the appropriate orientation of the intended project within ROP.
The main principle is that all potential applicants and interested parties should have equal access to
information with regard to the authorities criteria, rules and procedures.

In this context, the relevant authority should develop a clear information policy that sends clear messages on
the philosophy of its mission, objectives and priorities as well as the criteria for appraisal of projects and the
terms of financing it offers. Such an information policy helps to build predictability in the system and it will
be perceived as fair and transparent by applicants and will not raise wrong expectations. In addition, it will
set clear rules of the game and the lottery element will be reduced to a minimum.

The contacts between the authorities staff and applicants during project preparation should not be limited to
information exchanges and correspondence between the two only. Rather, these contacts should also offer an
opportunity for exchange of opinions authorities requirements. The authority could use all possible channels
to distribute relevant information to potential participants and interested parties, ranging from preparing
project application documentation on paper, to distributing it in an electronic form to posting information on
the Internet. Distributing widely standard application forms, instructions to applicants, example materials and
software and diskettes could significantly improve applicants‟ understanding of the authorities requirements.


                                                                                                                3
                                                                                  Draft (26 September 2005)
In addition, getting in direct contact with potential applicants is another way to disseminate information and
provide explanations. Such direct contacts could include open seminars, trainings, workshops. The main
principle is that such events should be open to everybody and no group of beneficiaries should get
preferential treatment or more information than others. Such group meetings rather than contacts with
individual applicants are advisable and should be the practice as they limit the scope for corruption on the
part of the authority. Such an open policy could help increase the authorities credibility and is a guarantee for
developing good and honest working relations between applicants and the regional authority from the outset.

The assistance extended to applicants has its limits too. The number of meetings and discussions on a given
project should not exceed a level justified by substantive requirements. The staff is not in a position to
educate everybody. The authority cannot take responsibility for the fate of a project. Excessive involvement
would mean that the authorship of a project development is assigned to the authority, which is then supposed
to conduct an objective assessment of this same project. Clearly, this is not possible, if the authority has
participated in project definition. There should, thus, be a binding principle regarding the separation of the
authorities role in providing assistance to applicants and in conducting appraisal, ranking and selection of
projects.

It may happen though that meetings on an individual basis with applicants are sometimes necessary but these
should be very limited. Such meetings could only be justified, if it is obvious from the project‟s idea that it
could be a valuable project to support but the applicant needs special consultation to develop the project
properly. The major question in such situations is how the authority could keep arm-length relations with
applicants while providing them with effective advice on for example changing or modifying the scope of
the project in order to improve the project‟s chances of financing. In principle, such interventions should
only be allowed if the technology proposed by the applicant is obsolete or causing more environmental
problems than resolving.

Following the findings of the study, it was concluded that the information flow could be critical from the
environmental point of view. Most of these offices are facing problems with professional staff shortages.
Regional development offices have between two and five employees who are dealing with project proposals
and related activities. These regional offices with responsibilities for calls, project advisory services,
evaluation and many other related activities, can hardly co-operate very closely with applicants to propose
high quality projects, which is especially relevant for the horizontal environmental integration. But already at
this early stage, it is highly important to bring a lot of creativity and new ideas. Environmental issues on this
level are rather understood as a constraint to some activities than an opportunity.

Many countries state that the personal communication has been the most effective tool in promoting
environmental integration at the project level. For example, in Malt (Single Programming
Document) the training workshops on horizontal policy requirements and personal meetings between
individual applicants and the environmental agency (MEPA) were particularly effective. A one-stop-shop set
up by MEPA to provide applicants with the guidance on environmental and development planning
requirements worked well to ensure compliance with the national policy.


Advisory Organisations

Two kinds of advisory organisation can appear at that stage of the process. One is the advisory company
type, charged to help applicants to develop high quality project proposals for free or for money depending on
the type of organisation (company, NGO, etc). In general, they do not have much knowledge about these
horizontal sustainability issues. The situation is even worse if we consider the multiplicator organisations
(for example in Hungary), which are supposed to train these advisory organisations since even they do not
have a detailed or sufficient information on this subject.

On the other hand, some advisory organisations of experts in the field of environment can very much help to
develop high quality project. They recognise that considering environmental issues can offer competitive
advantages and they support global, EU and national goals of sustainable development. These experts can
also explain more specifically the whole concept of sustainable development and help to find ways how to


                                                                                                               4
                                                                                 Draft (26 September 2005)
integrate into specific projects but are very expensive and therefore a risk for the applicant as long as he is
the phase of project development. (see chapter below).

3.2 Information flow of documents

The problematic point of the documentation is how to find relevant information related to the
specific measure, especially relevant guidelines. In most of the cases, the difficulty lays in the
availability of the documents. It is not easy to find them on the Internet and applicants won‟t search
too long for guidelines and other complement documents. This is the case in Hungary of the
horizontal environmental sustainability guidelines for group of measures. They exist but applicants
in general are not aware of that and they don‟t consult them because they find it difficult to search
for them.

3.3 Conclusions

   Proper information is a critical point of the application process.
   There are usually not many practical suggestions (explain more)
   Generally low “pro-activity“ on both sides (officials and applicants).
   Very problem oriented (on both sides) and horizontal themes play only a minor role.
   It is important to understand and maintain environmental awareness from this early stage.
   Personal communication:
    Between authorities and applicants
    – environmentally trained and available officials are needed;
    – there is a need of raise the perception of environmental issues and sustainable development.
   Advisory organisations
    – should be involved more in project preparation
    – service should be available for free
    – NGOs, including environmental NGOs should be included.
   Multipilcator trainings: more comprehensive explanation is needed for them since they will train the
    advisors (multiplying effect).
   Information flow of documents:
    - info-packages with all documents should be made available on internet and paper;
    - searching for guidelines (general) and using them is problematic;
    - searching for guidelines (environment and sustainable development as a horizontal priority) is
         problematic (they are completely missing in the Czech Republic, Hungary and Poland);
    - make guidelines easier to find (e.g. links in application forms);
    – should be shorter;
    – should be more practical (e.g. list of ideas for environmental integration, best examples);
    - should be more specific to measures – type of projects.
   Information is needed about selection criteria (especially in Hungary and Poland).

4. Application form

Preformulated application forms are an useful tool of Managing Authority to channel the relevant
information by the applicants. Normally there are administrational, technical and financial forms.

4.1 Format of an application form

The application process itself is based on filling in an application form which has to be processed in a
standardised format (e.g. an electronic standard „Elza‟ form in the Czech Republic, relevant to all priorities
of ROP and also the same for some other Community Initiatives, such as INTERREG). Such forms are also
used in Poland. In Hungary, forms are not standardised and there is no electronic version, which makes the
whole process very complicated and diminish the transparency of the system.

In general, an applicant has to specify in several sets of folders, the following information which provide also
information which are subject of the monitoring system:
                                                                                                                 5
                                                                                 Draft (26 September 2005)

Information in the administrative forms is:

   Applicable priority, measure and sub-measure;
   Exact location of the proposed project (place of implementation)
   Details concerning the applicant and his partners
      - local authority, county authority, private enterprise, NGOs;
      - applicants economic performance in the last period;
      - experiences in project management.
   Monitoring indicators; (Normally these are not separated indicators but already collected information)
Technical administration forms include:
   Name and detailed description of the project;
    - state of the art;
    - reasons for the project;
    - general and specific goals of the project;
    - activities involved within project implementation;
    - preparedness for implementation;
    - possible threats and risks involved;
    - linkages to other projects;
   Horizontal priorities – including sustainable development, impact on especially protected areas;
   Project publicity – expected means of project publicity (advertisement leaflets and brochures,
    newspapers, billboards, markers etc.).
Financial forms include at least:
   Project timetable (stages etc.);
   Financial background, expected sources of co-financing, received financial support from other sources in
    the previous period (from the state, county or local authorities budgets or form EU funds);
   Project sustainability (not the same as sustainable development!!!) - perspective of sustaining the project
    results after implementation finished;
Looking at the environmental aspects of an application, monitoring indicators and horizontal priorities are
the most important parts of application forms as these are the only places where environmental issues are
directly mentioned. Other parts of forms are related to economic and administrative matters. Thus, closer
attention will be paid at these two elements, namely, monitoring indicators and horizontal priorities.

In the context of monitoring indicators, in some programmes, it is necessary for applicants to develop sets of
these indicators in relation to the project goals – with the specified measure.

In general, guidelines are assisting applicants in the development of project-specific indicators, as it is the
case in Hungary. In the Czech Republic, after the applicant selects target measure within the ROP, a detailed
list of possible indicators is generated automatically. For example in the measures dealing with tourism,
monitoring indicators are: number of beds created, number of new tourist facilities, number of tourism
products created, length of new cyclist and walking paths constructed, number of cultural and natural sites
re-constructed, lastly also number of working places created.

Sometimes applicants can choose from several sets of indicators or develop their own indicators to show in
advance what is the expected target goal of the project. These indicators later become part of the contract and
their fulfilment is monitored and enforced. In the most cases the criteria and indicators are required by the
administration unit in order to compare projects and develop benchmarks and aggregate the effects.




                                                                                                             6
                                                                                          Draft (26 September 2005)
The main problem that we see in the context of environmental horizontal priority, especially in Polish and
Hungarian application forms, is a fact that there is no room for deeper or detailed explanation of
environmental sustainability of the overall project. In these countries, only 4 000 characters are available to
explain this issue. It is not only too short but it also limits the motivation of applicants to think the question
over.

However, it has to be mentioned that not all indicators and criteria can be provided by all projects. The
amount of data has to correspond with the size of the project and has to be in reasonable relationship with the
subsidy.

From Maltese experience in the current programming period, the application process (form) was considered
as one of two approaches (next to the information flow) that worked best to contribute to the “greening” of
projects.

Application forms have also been designed with a view of extracting information that could be relevant to
evaluate the potential environmental impact of proposed projects. Mandatory annexes to the application
forms also facilitated the communication between Malta Environment and Planning Authority (MEPA) and
the applicants, who were required to set up personal appointments with the agency to complete the forms.

4.2 Conclusions

   Clarification of sustainable development concept is needed.
   Clarification of definition of project sustainability (sustainable development versus durability) is needed.
   Clear distinction between sustainable development and pure environmental issues is required.
   Enough space to explain the sustainable development aspect of the overall project is needed. Very
    specific poblem.
   Anonymisized example/s of good application forms should be available to applicants.
   Definition of some specific and general sustainable development indicators for each measure is needed.
   Distinction between big and small projects with different requirements

5. Project appraisal

5.1 Project assessment

After an applicant fills in all data, he/she has to deliver several printed originals and/or copies2 on time to a
submission unit (for instance a Regional development office or national/regional fund) where a proposal is
checked whether it satisfies with formal requirements. Next, general acceptability and compliance with
programme‟s goals, national legislation, money allocation, etc. are assessed. Projects that successfully pass
this stage are subject to the selection process.

In case of individual projects3, the evaluation process is based on principle of competition among proposed
projects. This means that these projects get either EU funding or no funding at all. Other countries as Austria
elaborated completely different selection procedures where EU projects are selected out of a sample of
preselected national financed projects.

Those projects are selected which received the highest score in the evaluation. The maximum number of
projects per one measure is – in most programmes - limited by the money allocation for this measure in the
region. Other possibilities can be also technical criteria (as the number of projects or the fulfilment of the
economic or environmental goals). Table 1 provides groups of criteria and their weight in the evaluation for
the Czech ROP.


2
  Three printed versions are required in the Czech Republic and Poland. One original and four printed copies plus some
part electronically (application form and the budget) are required in Hungary. Electronic application is possible but not
widely used in Europe.
3
  Besides individual projects, which are the core of this study, there are also grant schemes available (in hands of county
authorities).
                                                                                                                         7
                                                                                 Draft (26 September 2005)
Table 1: Projects evaluation criteria
GROUPS AND CRITERIA                                                                        WEIGHT
1. Capabilities and experiences of the applicant (as experience with other projects,            10 %
Management and organisational structure of the project, Financial performance


2. Need and project relevance (as need for the project, relevance with development              30 %
objectives, linkages to other programmes, partnership)
        Need of the project (based on analysis and marketing studies)
        Relevance of the project with development strategies (national, regional,
         local)
        Linkages to other programmes
        Partnership (reality and applicability of partners)
3. Quality of the proposed project (as risk identification and means of their                   40 %
mitigating, economical effectiveness, budget evaluation, benefits of the project,
connection to indicators, transparency of the proposal, project sustainability)
4. Horizontal criteria (as how does the project complies with relevant horizontal               20 %
priorities)

The scores given to environmental criteria vary among the countries. For example, in the Hungarian ROP
and it accounts for 10% of the total score, in Polish ROP, for 14%. The cross cutting themes account for 30%
of the project score (so 10% for environmental) in the Cornwall Objective Two programme. However there
are environmental criteria at Programme level ("protect and enhance the environmental assets of the region"
and "deliver integrated economic, social and environmental benefits") so the environmental proportion of the
score is slightly more than this.

In some cases, for example in Malta, environmental horizontal criteria constitutes a part of „horizontal
criteria‟ and 10% of the total score is allocated to three horizontal priorities: environment, equal
opportunities and information society. No specific marks were allocated to each of the horizontal priorities.

Alternative to the scoring system compliance with environmental criteria be decided also on a YES - NO
basis. In the Czech Republic ROP assessed horizontal priorities vary depending on the priorities for which
the project is applicable, usually three-four of them.

5.2 Conclusions

   Higher consideration of environmental/sustainable development aspects, rewarded by extra points.
   Possibility for more consultation in case of low quality in environmental issues.
   Inclusion of environmental experts in selection committees.
   If a project has environmentally/sustainable development positive impact - get positive
    discrimination!

6. Project approval

A crucial point of the selection of projects for financing by the Structural Funds is an advisory
group/committee, sometimes also entitled as selection committee. This committee will decide or suggest to
the Approval Authority (Minister) if a project is fulfilling the national, EU and Structural Funds criteria, and
is among the best that should be implemented. That is why the participation of environmental experts is so
important in such a committee. In Hungary, environmental experts from an NGO side and also from the
Ministry of Environment participate in the decision making process within such an advisory committee.




                                                                                                              8
                                                                                        Draft (26 September 2005)
7. Monitoring

7.1 Monitoring

There are key indicators provided by the EC and there are additional environmental indicators possible on
national and programme level.

However, there is not enough evidence to assess the monitoring of the implementation from
environmental/sustainable development perspective, taking into account that the implementation of projects
in the current period 2004 - 2006 has just started. However, environmental partners (environmental NGOs
and Environmental Authorities) have opportunities to participate in the Monitoring Committees. However,
their involvement should be further facilitated.

Concerning the monitoring visits to specific projects, they can fulfil two goals. The monitoring visits are
more to provide hands on support and guidance to projects that are not used to integrating environmental
considerations into economic development projects than to check that they are delivering what they
committed to (UK).

7.2 Conclusions

   General conclusions because of limited experience.
   Monitoring the defined indicators. Expain more clearly
   Inclusion of environmental experts in monitoring committee.
   The monitoring process s often driven by the technical specifications of he national monitoring system.

8. The compliance of projects with other environmental requirements

The following chapter reviews other environment-related requirements valid for all proposed projects within
ROPs. It looks specifically at environment/sustainable development horizontal priority4, compliance with
NATURA 2000 requirements and environmental impact assessment applicability.

8.1 Sustainability as a horizontal priority

Several horizontal priorities are monitored across all prioritises and measures in ROPs. According to the
guidelines for applicants in the Czech ROP5 sustainable development represents political priority of
implementing environmental protection and nature conservation into the project preparation and
implementation. In principle, in the three new Member States, all projects must be evaluated from the point
of possible impacts on the environment and their linkages to sustainable development. In this case,
sustainable development concept is interpreted via addressing the following principles/elements:
 Decrease in amount of waste and wastewater produced.
 Decrease in energy usage and increase of renewable energy sources use.
 Taking advantage of new business opportunities in environmental management.
 Encouraging environmental innovation, research and development (R&D).
 Support towards public transport, cycling and walking.
 Support of environmental initiatives taken on administrative level (energy efficiency, etc.).
 Support of local authorities to take advantage of the quality of their environment as a key economical
    factor.
These elements often are identical with the environmental key monitoring indicators.

This analysis reveals that the whole concept of sustainable development is not explained clearly. It is based
only on certain elements that should be made towards fulfilling the whole idea. First of all, referring to the

4
  Environment/sustainable development horizontal priority was already referred to in earlier sections of the report,
however, this chapter describes an overall understanding of this concept in the context of projects submitted for funding
from ROPs.
5
  Updated version for third round of calls for proposal.
                                                                                                                        9
                                                                                    Draft (26 September 2005)
principles above mentioned, an applicant is not aware of the main concept of sustainable development -
balance among environment, economy and society in a long-term perspective. The above listed points are
taken out from the sustainable development concept without much relation to other pillars. On the contrary,
suggested points refer more to the practical steps, which could be followed by applicants towards achieving
an environmentally sound project proposal. This can be appreciated by applicants in that way, that they do
not need to study the whole sustainable development concept and they can see some options or possibilities
already in advance, in which way project could be beneficial for sustainable development/environment.

If we also look at the last principle – support of local authorities to take advantage of the quality of their
environment as key economic factor, it sounds very „proactively‟ but any detailed explanation is missing
here.

A number of experts from new member States expressed their thoughts that sustainable development as
horizontal priority has partly failed and one starts to see the real causes of that failure. On one hand, there are
several detailed specific measures and sub-measures, and on the other hand there is unclear and non-
specifically defined horizontal priority of sustainable development. This probably leads to a very problematic
application of this principle into specifically proposed project by applicants. Therefore, we would suggest
here defining sustainable development priorities on a programme level specifically not only for the whole
ROP, but also on the level of priorities and measures. It is quite obvious that most of the emphasis should be
put on priorities having direct impact on environment. It would be applicable for priorities - regional support
of entrepreneurship, development of infrastructure in regions and development of tourism and their
subsequent measures. For the others (development of human resources in regions and technical assistance)
the recent definition should remain as these priorities are quite far from having possible direct impacts and
can be regulated, for example, on the level of calls.

It is important to highlight that there is always room to improve the quality of the environment and be more
proactive (principle of precaution and principle of prevention). It is always possible to be more eco-efficient
(energy/water efficiency, ecological soil use, selected waste collection, etc), or raise the
sustainable/environmental awareness. The positive discrimination of the projects with positive impact on the
environment would motivate the development of that kind of projects.

8.2 NATURA 2000

As it is mentioned in the guidelines for applicants (and also as a part of the compliance strategy with the EU
legislation in the National Development Plans) comprehensive protection of NATURA 2000 sites is a part of
the horizontal principle of sustainable development. In the application form, in the same folder with
horizontal priority of sustainable development, an applicant is asked whether location of the proposed project
is envisioned in the areas of specific nature conservation. All projects with a possible impact on
environmental and landscape have to be a subject to a statement from a responsible authority (department of
environmental protection). This document declares that intended project has no important direct impact on
the NATURA 2000 site, or on some other protected areas declared by the national legislation.

8.3 Environmental impact assessment

The Council Regulation (EC) NO. 1260/1999, laying down general provision of Structural Funds, requires
that all operations financed by the funds shall be in conformity with provisions of the Treaty (Establishing
the European Community), including environmental protection. In this sense, environmental impact
assessment (EIA) is a strong tool to assess possible environmental impacts of proposed projects.

The environmental impact assessment has been transposed into the legislation of Member States. It
obviously applies to all projects no matter what is the financial background (including projects supported
from the Structural Funds).

The compliance with the EIA, including a decision of a relevant authority that a project can be implemented,
is an important part of an application package to ROPs. (Is it required to attach a decision based on the EIA
or just a statement that EIA was conducted (if required)…? Needs clarification


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                                                                                 Draft (26 September 2005)
The Czech Ministry developed specific guidelines on the methodical approach how to co-ordinate EIA with
the projects supported from EU Structural Funds. This defines stakeholders involved in the process –
applicant, authority responsible for EIA process and also sets list of projects when EIA is required and when
not (under different operational programmes).

Concerning the decision issued by the responsible authority we have to be very careful that no political
influences are involved. As there are several examples of cases, where political influence changed
dramatically expected decision in this field. This applies for both EIA and also impact on NATURA 2000
sites and other protected areas. However, it t should be mentioned that EIA is a matter of size and nature of
the development.

9. Institutional framework

The report shows clearly that the level of knowledge on environmental/sustainable development of officials
was in general low in the new Member States. The related information and knowledge were sometimes
available but the officials had no time to consult and direct applicants about specific issues. Regarding the
overall funding structure from the environmental/sustainable development perspective, the project level is a
crucial step. Guiding and helping applicants to develop sustainable projects, not only avoids damaging the
environment in short term, but also raises awareness of the whole society. That is why the
environmental/sustainable development knowledge in the relevant authorities in all level should be
improved.

There have been also some positive examples how institutional framework can support environmental
integration at the project level. For example, in Italy (Sicily Region) the regional Environmental Authority is
supported by a task force of environmental experts. These technical assistance activities are funded by the
Operational Project “Environment” (OPE) of the National Operational Programme Technical Assistance
2000 – 2006. The major objective is to develop within the public administration an approach oriented to the
sustainable development in all planning, managing, monitoring and evaluating stages. Having regard to the
project level, these experts support the Environmental Authority in
   establishing the necessary compliance with a) EU, national and regional law and policy related to the
    protection of the environment; b) principles and objectives established by programmes in the field of
    sustainable development
   providing eligibility, non eligibility, evaluation and priority criteria
   defining extra points to sustainable projects and imposing environmental constraints
   identifying evaluation methodology
   carrying out the environmental evaluation of projects.

10. Recommendations

10.1 Projects identification

   More detailed explanation of eligibility requirements is needed: it might be useful to point out in advance
    which projects will be not supported (if applicable), including environmental constraints (New member
    States).

   The methods/means of announcing calls: there are certain doubts if all potential final beneficiaries have
    proper access and capabilities to the Internet that is the most common means for announcing calls. In this
    case, it is suggested to announce calls also on public announcement places usually used for other official
    documents (e.g. local authority boards, etc.). To conclude, all kind of media should be used for
    disseminate information about calls (New Member States).

   There is a serious lack of any provisions dealing with environmental issues within calls in some Member
    States. Environmental goals are often included only in the priorities that have a clear impact on
    environment. But they only repeat what has been already expressed in general goals for each priority and
    its measures. It is suggested within calls for relevant priorities to add a detailed list of preconditions
    preventing proposals going directly or indirectly against environmental principles. However, dealing
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    with all ROP calls regardless of their priority (measure) one cannot expect many provisions and
    suggested measures towards environmental issues. Nature of calls is rather a kind of advertisement
    to attract attention of possible applicants, not a comprehensive document stating all criteria and
    conditions. Therefore, we expect deeper inclusion of environmentally related issues in the latter stages of
    application process – through the information flow and within the application form. There is also a
    substantial importance of horizontal priorities to be followed by all project proposals.
    Better clarificatio/re-writing is needed

   It is very important to include environmental, economical and social aspects in the eligibility criteria of
    the projects. In each case, all interventions financed should complying with the environmental regulation
    (La Rioja ROP).

10.2 Information flow

Personal communication

   One-to-one meetings with applicants were considered as one of the most useful approaches in ensuring
    that environmental integration is considered (Malta, UK).

   It is recommended to produce a guidance document for project leaders on how to consider and
    implement environmental integration would improve the environmental integration (Malta).

   We believe that the inclusion of environmental experts in the process is very important from the
    planning phase through the project selection until the monitoring phase. Different solutions could be
    proposed to address this. For example, the assistance could be established within the Regional
    Development Offices. It could include several responsibilities such as assistance with environmental
    issues and sustainable development in the project preparation and later in evaluation. Environmental
    NGOs could be also involved in this process. They usually have many independent experts who can
    bring many proactive ideas and approaches to the discussions proposed projects. NGOs could either
    work totally independently or in close co-operation with Regional development Offices. There has been
    already some good experience in this regard, for example, the involvement of the Friends of the Earth
    (the Czech Republic) or National Society of Conservationists (Hungary).

Information flow of documents

   It is difficult, in many cases, to find relevant information/guidelines, for example, programme guidance
    on horizontal environmental sustainability for specific groups of measures. In some cases, such guidance
    exists but applicants are not aware of this. It is also often not easy to find the documents on the Internet
    and applicants do not search for too long for guidelines and supporting documents (New Member
    States).

   That is why it is very important to indicate already in the application forms and in other
    possible „places‟, the location of such documents. It would be also helpful to prepare complete
    packages of documents for each measure rather than referring applicants to them. The
    electronic version of the application form would address this problem better because it is very
    easy to include all necessary links, as well as simple software is able to choose and show the
    joint documents if we enter the keyword of the specific measure.
    Better clarification needed

10.3 Application form

   The folder/section of the application form dealing with horizontal priorities provides some potential for
    strengthening the environmental integration. The applicant usually has to answer questions concerning
    impact on equal opportunities, information society and sustainable development, including possible
    impacts on protected areas. It might be worth considering excluding a sustainable development


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    priority/criterion from the horizontal priorities and listing it as separate criterion in order to increase
    sustainable development importance (Hungary).

   The application forms have to be improved. A “template” needs to be developed that helps assessing a
    priori the environmental effects of each intervention (before the implementation) (La Rioja ROP).

10.4 Project appraisal

   It would help to have a specific list of environmental criteria against which to gauge projects before
    selection (Malta).

   Concerning the scoring system, it is important to reflect positive and pro-active attitudes of applicants
    (principle of precaution and principle of prevention). The positive discrimination of the projects with
    positive impacts on the environment would motivate the development of that kind of projects. Therefore,
    it is suggested to design an evaluation system that would support such an approach. For example,
    assigning a number of points according to the total number of positive impacts (New Member States).

   The environmental aspects need to be checked by qualified personal and expert in environmental
    subjects, in the same way that the financial aspects are checked by auditors (gestores) (La Rioja ROP).

   The information included in the application form often does not allow evaluating the impacts on the
    environment since some impacts are addressed at a very general level and some impacts are missed.
    Therefore, it is suggested to add additional impact categories in the application form, and make pollution
    more specific (New Member States).
    Better clarification needed

10.5 Monitoring

   The inclusion of relevant monitoring indicators would offer a potential to greening of projects. For
    example, the indicators on eco-tourism could be useful for the applicants submitting projects in the
    field/priority of tourism. However, further work on how to include eco-tourism ideas into tourism
    activities eligible for structural funds support should be done. It could be suggested that all tourism
    related activities have to be in line with ideas of eco-tourism since this is how sustainable development
    can be put in practice of tourism.

    Similar greening potential can be fulfilled within the competitiveness priority/field. For example, an
    inclusion of an indicator - „Implementation of Environmental Management System (EMS), e.g. ISO
    14001‟ may direct enterprises towards “greening business” activities.

   In order to carry out the monitoring, personal, time and resources are needed. An office similar to the
    financial Intervention office could be created for the environmental aspect (La Rioja ROP).

   Monitoring of projects helps to ensure that any environmental integration planned for is indeed
    implemented (Malta Environment and Planning Authority). After the project is approved, controls “in
    situ” (on site) need to be carried out to check the data and verify that the results comply with what was
    planned originally (La Rioja ROP).

10.6 The compliance with other environmental requirements

   The structure of EIA is very clear and could be useful investors or applicants to think over the
    environmental impacts of any activities. Therefore, a simplified EIA based checklist of possible impacts
    of projects, e.g. „soft projects‟ (not subject to EIA) could be developed. This checklist would help an
    applicant to see better possible impacts and find solutions in advance in consultation with environmental
    experts (precautionary and prevention principles).



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10.7 Institutional framework

   There is a need for environmental experts to be involved in all levels of the structural funding process,
    including project level. To solve the problem of a lack of experts, a network of experts could be set up
    (including environmental NGOs), the positions of sustainable development managers in
    Managing/Implementing/Intermediate Authorities could be created.

   Extend direct assistance of sustainable development managers to applicants.

10.8 Other recommendations

   Strategic Environmental Assessment (SEA) will ensure that the Managing Authorities at least contemplate
    the potential environmental impact of the measures developed in the programme. The Managing
    Authorities may then modify the programme to ensure that environmental impact is minimised (Malta).

   Creating local awareness about the projects selected for funding to help rope in support for the environment
    (Malta).

   The integration of the environment at the level of programming was crucial. If the environment had not
    been taken into account in at the programming stage, it would be much harder to implement it at project
    level (La Rioja ROP).

   From the point of view of sustainable development, the environmental, economical and social aspects
    needs to be ataken into account in a balanced way. If only the environmental aspect was taken into
    account, or if it was the priority over the other aspects, the regional development programme would stay
    very limited, and could evolve towards being an programme for nature conservation (La Rioja ROP).

   The use of State Aid assisstance (e.g. Italy, described in a separate handout) to promote an
    environmental horizontal theme should be furher examined as an approach to improve environmental
    integration at the project level.




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