28.9.2004   

EN

Official Journal of the European Union

C 241/44

1.1

This communication is one in a long line of non-legislative Commission texts which take stock of past initiatives and future options in a particular sector. It forms a sort of general framework for Commission thinking on environmental technologies.

1.2

From the very start, the communication is set in the context of the EU sustainable development strategy and the Lisbon strategy, pointing out — in the words of the now familiar refrain — that the aim is to make the EU ‘the most competitive and dynamic knowledge-based economy in the world, capable of sustainable economic growth with more and better jobs and greater social cohesion’.

1.3

But after this now ritual reminder, the real question is raised, namely what are the aims of this environmental technologies action plan (ETAP)?

The Commission lists three:

with the ultimate aim being to reduce pressures on our natural resources, improve the quality of life for Europe's population and promote economic growth.

1.4

The Commission thinks that politically the time is right for launching this action plan, but the question is how is this to be done and what concrete actions are to be taken. It is the responses to these two questions which structure the text.

2.1.1

The Commission starts by noting a number of points which are to underpin the action plan:

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Getting from research to markets,

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Improving market conditions,

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Acting globally.

2.2.1.1

The Commission is advocating that funds from, inter alia, the EIB and the EBRD be used to increase and focus research, the aim being to develop commercial applications.

2.2.1.2

The Commission plans to promote technology platforms for promising environmental technologies, the main aim of which would be to improve the effectiveness of research, mobilise resources, provide for the development of public-private partnerships, and improve technology transfer to developing countries.

2.2.1.3

Finally, the Commission wishes to improve testing and standardisation in relation to environmental technologies.

2.2.2.1

The Commission describes how to bring about this improvement in the market in terms of investment, removing economic barriers, influencing the economic weight of public procurement and mobilising civil society.

2.2.3.1

Europe's ambitions with regard to environmental technologies are not confined to the old continent. The Commission thinks that the European Union has a duty to act resolutely in promoting sustainable development worldwide.

2.2.3.2

The Commission plans to develop partnerships with developing countries and to get closely involved in the initiatives taken at the Johannesburg summit with regard to environmental technologies.

3.1

The drawing-up of an action plan supposes that its implementation will be monitored. The Commission makes provision for various instruments to that effect: two-yearly report, European panel on environmental technologies, coordination, information on best practice, etc.

4.1

The Committee's comments also take account of the remarks and suggestions of the Consultative Commission on Industrial Change (rapporteur: Mrs Sirkeinen, co-rapporteur: Mr Reichel).

4.2

Environmental technologies, by definition, cover a very wide field. Their purpose can be to use natural resources in a sustainable manner, avoid or reduce damage to the environment, develop alternative energy sources, or be a part of integrated products policy, etc. As the EESC has already pointed out (1), it is very important for the definition of environmental technologies not to be limited to ‘clean’ technologies. The ongoing improvement of processes and service provision methods in order to reduce the negative impact on the environment, research, innovative know-how and development with a view to upgrading traditional technologies and incorporating an environmental dimension therein is also one way of developing environmental technologies and must be encouraged. The effectiveness of an environmental technique is gauged in the light of its favourable impact on the environment and not on the basis of a predetermined definition of environmentally ‘virtuous’ technologies.

4.3

There is the danger of a very broad action plan being too wide-ranging and hence its resources being scattered too widely. One of the major challenges for such a plan's success is probably the ability to define priorities and establish a hierarchy and hence to assess not only the effectiveness of environmental technologies but also their economic viability. This idea hardly comes across at all in the Commission document, but it is of major practical importance. However, it must also not be forgotten that the sustainable development concept rests on three pillars — economic development, protection of the environment and natural resources, and personal self-fulfilment within society.

4.4

Environmental technologies are always used when their use is either of direct benefit to the user or a legal requirement. Since the free market alone does not fulfil all the socially accepted ethical, social and environmental goals, the legislator has always had to step in to create the appropriate legal framework. Whilst such legislation may result in higher costs at a microeconomic level, these costs may prove to be worthwhile in macroeconomic terms. When establishing the legal framework, the legislator should take into account the innovative strength of the economy and of science, by setting targets without specifying the steps or technologies that are needed to achieve those targets. The increasing awareness that fulfilling additional social and environmental criteria may bring opportunities for increasing sales is an important driving force for the action plan and for strengthening the competitiveness of the European economy.

4.5

Another determining factor for the success of the environmental technologies plan is market access and conditions. There is no point in hoping that environmental technologies will take off if they cannot find a buoyant and competitive market. Partly because of non-internalised environmental costs, but also partly because they have not been developed or penetrated the market to such a degree that economies of scale can be made to reduce costs, effective environmental technologies often cannot be produced as cheaply as less environment-friendly technologies. The challenge is therefore to define ways and means (loans, subsidies, tax incentives) of promoting the development of environmentally desirable and proven processes and corresponding environmental technologies, in order to encourage and facilitate market access, or even market creation. The EESC would stress that if incentives are to form a coherent whole and be put to good use, it will be necessary to establish some sort of classification or hierarchy: risk capital for launches, more traditional loans during the development phase, tax incentives to consolidate the market, and possibly taxes which internalise the environmental costs of less environmentally-friendly technologies.

4.6

In this respect, incentives or deterrents — in the form of legal and regulatory provisions — are necessary but cannot treat economic and social realities with disdain. Nor can they result in the unfair distortion of competition. Environmental technologies must not be an unattainable luxury or result in the distortion of competition, brought about by the acceptance of products and services from economic areas which have not imposed similar rules. The Commission text makes a point of this vital fact. The briefing and mobilisation of civil society and public opinion in support of environmental technologies will be futile if reality and economic feasibility are overlooked. One factor in gaining the support of public opinion is that it must not be forgotten that citizens and consumers are also working men and women. Therefore, if old technologies have to be abandoned because of sustainable development requirements, it is necessary to foresee the need for retraining and the cost thereof.

4.7

Finally, it should be pointed out that it is necessary for the EU's various policies to be generally consistent so that there is no policy clash. For example, it would be pointless to formulate a sustainable development policy that is in conflict with the policy pursued by the EU in the context of the WTO or in connection with market liberalisation. In this regard, there is a vital need for both a serious debate on this issue within the WTO and a resolute stance against the acceptance of products and services — irrespective of their origins — which do not confine the impact of technologies and processes to the minimum.

5.1.1

The EESC endorses the action plan's objectives and in particular the desire to exploit environmental technologies' potential to the full in order to improve the state of the environment while at the same time boosting competitiveness and economic growth. This point has already been made in an earlier opinion (see footnote 1).

5.2.1

The Committee stresses the importance of incentives for developing environmental technologies, but it would point out that these incentives must not lead to artificial support for technologies which will never be able to find a real market. Above all, the market should, however, be geared, through the use of a properly targeted mix of taxation, subsidy, licence and regulatory instruments, in such a way as to ensure that the external costs of various alternative technologies are taken into account.

5.2.2

Efforts must also focus on improving more traditional technologies so that they comply increasingly with sustainable development requirements. In practice, the modernisation and adaptation of equipment and advances made in technology and manufacturing or service provision methods have already led to the application of certain environmental technologies. This is one way of developing environmental technologies which may go unnoticed but which is very real.

5.3.1

One of the major challenges is finding concrete applications for research into environmental technologies. Research funds should therefore also be earmarked for applied research and provision made for the large-scale involvement of enterprises — and particularly SMEs. It must also be pointed out that certain SMEs play a locomotive role in the development and perfection of environmental technologies.

5.4.1

The EESC thinks that the idea of establishing technology platforms for promising environmental technologies is interesting. Bringing together interested stakeholders with real expertise to focus on a given technology, technologies serving a given sector or the implementation of technologies suitable for solving a specific environmental problem is an interesting move. Intellectual property, patent and trade mark issues will be governed by the research framework programme's rules and intellectual property law without giving rise to any particular problems. The EESC thinks that if the secretariat is provided by the Commission at the outset, a form of public-private partnership should be able to develop insofar as these technology platforms meet a real need and are of real interest.

5.5.1

The spread of environmental technologies is based on economic considerations but also on their technical effectiveness. A validation mechanism and networking system for data on certain key technologies — as advocated by the Commission — would be very useful for both enterprises and the public authorities, especially if there is a wish to include some form of ‘best environmental value’ in public procurement. In this context, the EESC would draw attention to the call which it has made for the establishment of a European database. The European Environment Agency could be involved in the setting-up and maintenance of this database, which would list proven, cost-effective/appropriate environmental technologies and thus provide them with a form of ‘quality label’ (2).

5.6.1

The Commission stresses that these targets must be based on best environmental performance while being realistic from an economic and social efficiency point of view. The EESC can only endorse this point and would underline that real sustainable development takes account of not only environmental concerns but also economic competitiveness, the creation of more and better jobs, and social cohesion.

5.7.1

The use of existing financial instruments and creation of new ones to share the risk of investing in environmental technology projects and companies, notably through risk capital funds, requires skilled analysts who can assess the projects' technical and economic feasibility. Otherwise there would be a risk of wasting loans, which could be useful elsewhere. Projects must be assessed on the basis of sound and objective scientific and technical facts and not on the basis of preconceived ideas. The application of new financial instruments could provide an opportunity to involve local authorities in the development of environmental technologies and to devise public-private partnerships.

5.7.2

Investments made by enterprises to reduce the adverse impact of their activities on the environment or to make their activities more in tune with sustainable development often represent considerable financial commitments, especially in heavy industry. Tax incentives should be devised to encourage such investments, and inversely the tax system should penalise enterprises that make no effort to improve their activities' environmental impact and thus gain a competitive edge by producing more cheaply.

5.8.1

The idea of using ‘best environmental value’ to promote environmental technologies is not new. It must be assessed in the light of the reliability of environmental technologies and public finance constraints. It can provide an opportunity to develop performance-based invitations to tender. Whatever happens, however, it cannot be a gimmick used merely for the sake of having a clear conscience.

5.9.1

Every generation is accountable for the society it hands down to its children. Our contemporaries are becoming increasingly aware that they are answerable for the environment they are bequeathing to future generations. Promoting environmental technologies requires that people be educated and provided with information which — if it is to be effective — must be realistic, must underline the advantages of such technologies, and must be easy to understand and access. This means organising a real dialogue with stakeholders and the general public and mobilising local authorities, which often have a major responsibility in the environmental field.

5.10.1

The Commission's wish to act globally is commendable. The EESC would point out that in the case of most developing countries the main concerns are economic growth and the fight against poverty. In addition, these countries' financial capabilities are poor. The Committee therefore thinks effective aid must be based more on the transfer of simple and cheap ‘intermediate’ technologies which would already be an improvement on the present situation and need not necessarily be inferior to more complex, more expensive solutions in terms of their performance. It should be pointed out that, in the case of less complex solutions, those receiving the technologies will face lower costs relating to intellectual property rights and patents.

5.10.2

The EESC thinks that it would be interesting for the EU to participate in the action taken under the auspices of UNITAR (3) to promote sustainable urbanisation in developing and transition-economy countries. It notes that in this context research, study and training centres have been opened in Kuala Lumpur (Malaysia), Curitiba (Brazil) and Ouagadougou (Burkina Faso). UNITAR is also planning activities in central Europe. The Committee also draws attention to its recommendation that ‘independent skill centres for appropriate technologies’ be set up in the new Member States (4). Such centres could organise the requisite transfer of expertise and provide advice to both local decision-makers and civil society bodies, and do not necessarily need to be restricted to the new Member States.

5.11.1

The EESC thinks that of the proposed initiatives, the exchanging of information on good practice and the establishment of indicators to compare best practice are the most interesting. If the biennial report for the Council and the European Parliament is not very concrete and compact, it is in danger of becoming just another report. Also, calling the European panel on environmental technologies a committee in some language versions is a bad choice of words, since it is not a committee in the usual sense but rather a forum bringing together scientists, technologists, industrialists, entrepreneurs and NGOs, etc. However, there is also a case for asking whether the tasks assigned to this panel could not be performed by the DG Environment and the DG Research without setting up yet another body, the effectiveness of which may be open to question if it is too large?

5.11.2

In an earlier opinion the EESC, reflecting the wish to ‘move forward’, proposed an ‘environmental ombudsman’, who would be responsible in particular for highlighting the obstacles to the development of environmental technologies created by rules and regulations. This proposal would be more operational than the establishment of a vast forum, which would be in danger of getting lost in generalities.

6.1

The EESC recognises the importance of the Commission's action in drawing up the environmental technologies action plan, which has given rise to wide-ranging consultations. At a general level, the importance of this type of non-legislative document is that it provides an overview within the framework of a flexible procedure and lays down general guidelines.

6.2

The EESC considers that the practical development of environmental technologies inevitably means making choices, establishing a hierarchy for these choices and drawing up a classification for funding, which is limited and must be used wisely. The ability to make pertinent choices will determine the success of the European strategy in this field. It necessitates a realistic and practical approach.

6.3

The EESC would emphasise the importance of a system for validating the effectiveness of environmental technologies and the dissemination of the data available on such technologies. This is one of the prerequisites for the spread of environmental technologies and their application by enterprises and public authorities.

6.4

Ultimately, one must ask whether the whole question does not boil down to determining the environmental technologies which it is advisable to develop in the light of their effectiveness, the conditions on the market, environmental constraints, the employment situation in both quantitative and qualitative terms, living standards and the level of development. It is a matter of scientific, technical, economic and social judgment and competence which the Union has a duty to address if it wishes to promote environmental technologies effectively.