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					Commentary on the Communication of the Commission
Towards a Thematic Strategy on the Urban Environment

The European Commission issued a Communication, prepared by its Environment Directorate General (DG
ENV), dated the 11th February 2004 entitled “Communication from the Commission to the Council, the
European Parliament, the European Economic and Social Committee and the Committee of the Regions –
Towards a thematic strategy on the urban environment”. The Communication contained, on page 41, under
item 6, an invitation to stakeholders to submit comments on the Communication.

The Architects’ Council of Europe1, who co-ordinated the work of one of the Expert Groups that prepared a
report for the Commission in the preparatory phase of the work that has led to this Communication, has
studied the content of the document and it hereby submits the following comments on the Communication
for the consideration of the Commission. The comments are a mix of specific and general remarks that the
ACE believes will assist the Commission in the next phase of its work on this important initiative. Where
page references are given, they relate to the English language version of the Communication.

Page 3
The first sentence states “Some 80% of Europe’s citizens live in urban areas…”. The ACE suggests that
this comment should be elaborated so as to point out that the citizens of the EU spend, as a general rule,
90% of their time in buildings. This would immediately bring the specific aspects of the indoors – buildings -
into the Communication right from the start and thereby highlight the fact that the effects of many
environmental problems are felt most strongly when indoors.

In the introduction and overview it is essential that the Communication highlights the fact that most (the ACE
does not have an estimate of the exact percentage) of all production from all sectors (energy, food, goods,
services etc.) flows into urban areas, making these responsible for most of the environmental problems

  The Architects’ Council of Europe (ACE) is an organisation, based in Brussels, whose Membership is drawn from representative
national registration and professional architectural organisations of all twenty-five European Union (EU) Member States and most
Candidate Countries as well as Switzerland and Norway. As such, it is an Organisation that represents about 450,000 European
architects. The ACE was founded in 1990 and its principal function is to monitor and influence developments at EU level highlighting
those areas of EU Policy that have a direct impact on architecture, architectural practice, policy and the built environment.
For further information see: or e-mail:

Commentary of the ACE on the Communication of the Commission “Towards a Thematic Strategy on the Urban Environment”               1
experienced in those areas. It is also important to note that the environmental impacts are related to all
phases of the production and delivery of these items.

Balance Between the Thematic Areas and the Overall Message

The Thematic Strategy for the Urban Environment clearly identifies Transport/Mobility as the most relevant
of the areas in which to intervene. It does this by the extent to which the issue is discussed and elaborated
upon in the Communication. This may be the case because of the fact that the number of stakeholders that
are required to co-operate in order to achieve environmental improvements are fewer and easier to reach
consensus with, than the large number of stakeholders identified in the other areas – especially sustainable
construction. Many of the improvements identified can probably be achieved with one approach - political
negotiations with the main stakeholders - the main car manufacturers and the public transport networks.

The fact that transport/mobility has a very obvious link to the environment in peoples’ perception arises from
the fact that they can actually see the fumes coming out of vehicles and they are victims of the ever-present
traffic jams.   These obvious factors facilitate the development of clear strategies that result in speedy
positive impacts following the implementation of any improvements. The dramatic dimension of mobility -
cursing the traffic on many occasion’s in day to day life - and the individual’s powerlessness to resolve the
problems further favour the theme’s marketability.

Nonetheless, the importance given to transport/mobility distracts, as already signalled by the ACE at the first
meeting of the Advisory Panel on the 7th April 2004, from the real cause: it is the built environment that
determines the need for mobility. A well-designed built environment will have much less mobility related
environmental problems than a badly designed one. The ACE therefore suggests that the mobility theme
should be addressed within the framework of the Sustainable Urban Design theme and its recommendations
should step over into that theme, or at least be fully taken into account so as to ensure adequate co-
ordination of the two themes.

Nevertheless, the ACE wishes to record that it believes that all the actions proposed in the Communication
on the theme of transport/mobility are relevant and it supports the direction being suggested by the

Still on the subject of balance, the weight of the Urban Design chapter seems to be too light in contrast with
the other themes. The model of the compact city is unequivocally proposed in the Communication, so much
so, that the traditional approach to density in urban areas is revolutionised. It its proposed actions, minimum

Commentary of the ACE on the Communication of the Commission “Towards a Thematic Strategy on the Urban Environment”   2
rather than maximum densities should be set do as to limit urban sprawl. However, although this proposal is
very powerful, it will require further detailed consideration, as the quality of life of citizens in higher density
built environments relies on environmental indicators (that are quantifiable and less quantifiable), for which
the culture is not yet common. It is the view of the ACE that it is essential to follow such a statement with a
direct link to the need to use the framework of these indicators to evaluate the impact of the proposed higher
densities. These indicators are addressed within the Sustainable Construction report, and a reference can
be made to link the two themes.

Points Specifically in Relation to Sustainable Construction Content

The main ideas of the Sustainable Construction Methods and Techniques (SCMT) report are clear and
apparent in the Thematic Strategy.              Nonetheless, the strength of the theme also relies on the
recommendations of the expert group and most of these have not found their way into the Communication
on the Thematic Strategy. The Commission will be aware that this point was forceably made by the ACE at
the Advisory Panel meeting that was held on the 7th April 2004.

The fact that the construction sector has so many relevant actors, all of whom need to be involved in a
change of approach, makes it a very complex sector in which to achieve results. Nevertheless, it is the
sector with the largest and the most determining impact on the environment and on the quality of life of
citizens. In the view of the ACE, the construction sector should therefore be addressed in a way that the
specific and most powerful recommendations presented in the SCMT report are transposed to the
Communication on the Thematic Strategy and its proposed actions. The recommendations addressing
those actors that have most power to bring change need to be clearly incorporated in the future Thematic
Strategy, if they are to be taken seriously and implemented on a voluntary basis.

The ACE is ready to take on the role of selecting, from the SCMT report, the most relevant
recommendations that were not included in the Communication in order that they are adequately taken into
account in the ongoing work towards the Thematic Strategy. It is also ready to examine, in conjunction with
the Commission, how best to incorporate them into the future Thematic Strategy in an attempt to enhance
the coherence of all the recommendations, thereby ensuring an integrated and holistic approach.

Additional Information and Commentary

The ACE is supportive of the approach taken in the Communication that highlights, in words, examples of
good practice to illustrate the content of the Communication. This inclusion of best practice examples is

Commentary of the ACE on the Communication of the Commission “Towards a Thematic Strategy on the Urban Environment”   3
very eloquent in assisting non-technical persons to appreciate what can be achieved. However, as a picture
says a thousand words, the ACE strongly believes that these good practice examples should be illustrated
with high quality images. The ACE is ready to assist the Commission to source appropriate projects and
images of them for the future work on the Strategy.

The Commission has announced that it is to set up three Working Groups to assist it in the further
development of the work that will lead to the publication of the Thematic Strategy ion June 2005. Two of
these groups, on the topics of Urban Management and Urban Transport, will be mandated to pursue the
actions set out in the Communication, thus preparing the ground for real progress in these two areas. The
ACE is very concerned that in the areas of Sustainable Constructions and Urban Design, the Work Group
will only be charged with identifying research needs for these two themes.

This approach to the next phase of work seems to be ill-conceived. The splitting of the work into distinct
themes brings with it the risk that the necessary integrated thinking will not be adequately incorporated into
the work.     This risk is accentuated by the fact it is possible (and tempting) to treat the topics of
transport/mobility and management plans as separate tasks with separate outcomes.

The underlying topic for the entire Thematic Strategy is, in fact, the theme of Sustainable Urban Design and
it is therefore essential that this topic be given priority in the work that will lead to the publication of the
Thematic Strategy itself. It is clear that there are important sub-themes, but it is only through coherent,
integrated Sustainable Urban Design strategies that the future of the Urban Environment can be significantly
improved in the way that the Commission foresees. The ACE therefore urges the Commission to alter the
mandate for the third Working Group so that it, too, can prepare the ground for real short-term progress for
the themes of Sustainable Urban Design and Sustainable Construction.                      At the very least, it will be
necessary to ensure that the theme of sustainable construction is fully incorporated into the work on
sustainable urban management and transport plans.

Moreover, the ACE is involved in work, which is underway, to propose a European Technology Platform
(ETP) for the Built Environment. The principle objective of the work will be to set down a “Vision 2030” for
the built environment and to establish a roadmap for its achievement. The work is being guided by a High
Level Group (HLG) consisting of persons drawn from most of the stakeholders in the construction sector
(contractors, material producers, equipment providers, architects, consultants, research institutions, public
authorities, NGO’s, citizens groups etc.) and in close co-operation with the Commission services (DG
Research). It is hoped that the ETP itself ill be launched in late 2004.

Commentary of the ACE on the Communication of the Commission “Towards a Thematic Strategy on the Urban Environment”   4
A principle aim of the work towards an ETP is to identify the Research needs for the sector over the period
to the date of the Vision. The HLG has suggested that the work to build the vision might have several
different focal points and one of these is “Cities”. As such there are clear links and crossovers with the work
on the Thematic Strategy and the ACE urges the Commission to ensure that adequate linkages between
the two actions are created.

Finally, the ACE wishes to reiterate its recommendation, made during the meeting of the Advisory Panel on
the 7th April 2004, that it would be beneficial to devise a procedure for reviewing the various policy
recommendations that have been and will be made in the work on the Thematic Strategy. Such reviews
should be targeted at the achievement of two objectives:

         1.       A comparison of these new recommendations against existing policy that will highlight how
                  the new recommendations can be effectively implemented.
         2.       The development of specific implementation policies that will illustrate and define
                  methodologies and set down ways of monitoring the implementation procedures ensuring
                  adequate understanding of their impact.

The ACE is ready to actively contribute to this work.

End of report
28 April 2004

Commentary of the ACE on the Communication of the Commission “Towards a Thematic Strategy on the Urban Environment”   5

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