2.9.2011   

EN

Official Journal of the European Union

C 259/54


Opinion of the Committee of the Regions on ‘The EU LIFE programme — the way forward’

2011/C 259/10

THE COMMITTEE OF THE REGIONS

confirms that the LIFE programme has proved its worth many times over and should therefore be extended to the next financing period, with particular emphasis on the ‘biodiversity’ component;

requests to simplify the administration modalities, to increase the maximum co-financing rate, to make costs of a successful project preparation eligible for LIFE funding, and to allow that local and regional authorities once again can count their personnel costs in full as own resources;

calls for the future LIFE Biodiversity component to cover a wider concept of biodiversity. In order to play a significant role in financing Natura 2000, it should allow funding of recurring site management activities;

proposes that the future LIFE Environment component continues to be a decisive incentive for local and regional authorities for compliance promotion upstream of EU environmental legislation entering into force, as well as for going beyond legislative requirements and applying innovative environmental solutions, with the projects having a high replication potential for public-sector oriented eco-innovation;

supports, in order to increase the effectiveness of LIFE, the Commission proposal of larger-scale ‘Integrated LIFE Projects’, which provide an effective way to make the most of LIFE's catalytic value by establishing a structured relationship with other EU funds;

stresses that the new LIFE programme continues to support communication and information projects, with an increased focus on education and promoting projects which involve local and regional authorities and have significant impact at EU level.

Rapporteur

Daiva MATONIENĖ (LT/EA) Member of Šiauliai City Council

Reference document

Communication from the Commission on the Mid-term review of the LIFE+ Regulation — COM(2010) 516 final

I.   POLICY RECOMMENDATIONS

THE COMMITTEE OF THE REGIONS

A.   General

1.

believes that protecting the environment and preserving biodiversity is an essential prerequisite for quality of life in Europe and is therefore not just a responsibility for national governments, local and regional authorities (hereinafter LRAs) or EU institutions, but also be a matter of concern for every European;

2.

underlines that one of the objectives of the European Union is to promote sustainable, non-inflationary growth while taking environmental objectives into account and that bio-diversity loss may have an adverse impact on this; the EU itself, however, has growing competences in the field of environmental protection, what is reflected in the Article 192 TFEU, which establishes the EU competence on environment;

3.

recognises that the LIFE programme, introduced by Regulation (EEC) No 1973/92 and subsequently updated, as the EU's specific environmental funding instrument, so far provided EUR 2.2 billion of funding for 3 115 environmental projects (1), and therefore constitutes an important instrument in helping fund local and regional environmental policies and projects with a European added value (2);

4.

warns against overestimating the possibilities of the LIFE programme, while recognising and appreciating what it does. The EUR 340 million or so which is available each year under the LIFE programme can indeed support a range of projects, many of which offer great potential for being good examples and stimuli for positive approaches to environmental policy. However, this sum, which corresponds to roughly 0.2 % of the EU's annual budget, is not sufficient to solve all the problems caused by underfunding for other environmental programmes or EU funds;

5.

acknowledges that the LIFE+ programme has substantially contributed to adopting and implementing environmental management plans, restoring valuable habitats, enabling populations of important species to recover and developing the Natura 2000 network. LIFE+ has also helped to create partnerships, thus strengthening cooperation structures and facilitating the exchange of experience and information between stakeholders and political decision-makers;

6.

calls for the development of local partnerships which are best placed to combine the resources of LIFE with other sources of domestic and EU funds;

7.

stresses that new environmental challenges, continuing biodiversity loss and the EU's development are presenting European environmental protection with new challenges, for which an effective solution must be found as soon as possible and implemented in the context of the new financial perspective;

8.

believes that the European LRAs have an indispensable role to play in implementing EU environmental legislation and making eco-innovations and best practices better known to a wider audience;

9.

recommends that preserving biodiversity should be given top priority in all fields of EU environmental policy. As the protection of biodiversity is a cross-cutting issue, steps must also be taken to ensure that it is taken into account in all key policy areas;

10.

urges the EU's environmental policy to address the new challenges linked to rapid GMO development and its impact on native species, which has not been researched in-depth;

11.

sees that under certain conditions a conflict can arise between the objectives of biodiversity policy and those of other elements of sustainable development. Therefore in view of such possibly conflicting objectives, it is very important to ensure more flexible coordination between differing environmental objectives of sustainable development and ensure coherence between all measures taken so that rules and measures in one area do not lead to deterioration in another area or even poorer solutions across-the-board;

12.

stresses that, while LIFE projects have clearly an environment objective, they all have a potential to deliver socio-economic benefits to local communities, including ecosystem services of LIFE Nature & Biodiversity projects. The CoR welcomes the description of such potential benefits in the application forms for LIFE projects, as started already this year. This should result in reporting by the European Commission on a comprehensive set of socio-economic result indicators for the whole LIFE programme;

13.

believes that the ‘Nature & Biodiversity’ component of the LIFE+ programme has significantly contributed to implementing the Birds and Habitats Directives, and at least some of the objectives set out in the Communication on ‘Halting the loss of biodiversity by 2010’ have been achieved. However, LIFE+ only covers some of the measures provided for in the Birds and Habitats Directives, and biodiversity loss remains one area in need of particular attention;

14.

requests that for this reason, the LIFE+ programme must remain a key part of EU environmental policy, with particular emphasis on the ‘biodiversity’ component, and all possible efforts made to achieve the objectives on halting biodiversity loss set for the period till 2020;

15.

draws attention to the specific situation of the outermost regions, which are the largest net contributors to biodiversity in the whole EU, with over 200 sites of Community importance in the Natura 2000 network: these regions are vital for the objective of halting biodiversity loss;

16.

welcomes the Commission proposal to introduce ‘Natura 2000 Prioritised Action Frameworks’ (PAFs) for financing Natura 2000, as the macro management plans at regional or national level, providing a clear and binding framework for other EU funds and national contributions to finance the conservation of Natura 2000 sites and priority species in a defined territory (3);

B.   Recommendations for the mid-term review of the LIFE+ programme

17.

stresses that recent economic and financial crisis has also caused multiple challenges for local and regional authorities' plans in the field of providing co-financing various initiatives, including those of biodiversity preservation. In this regard the CoR invites national authorities and EU institutions to share and implement best practices in the field, e.g. the Polish model of good practice, where the national government has created a national fund that guarantees match funding to successful LIFE project applications (4);

18.

welcomes the introduction of indicative national allocations introduced in LIFE+, especially if this measure will be used as on a temporary basis, aimed to increase the number of approved applications from the new EU member states. At the same time, it expresses the need to clearly indicate the temporary nature of this measure and urges the European Commission to continue its efforts to provide training support to National Contact Points and Member States with lower uptake, as well as call upon these Member States, to increase the capacity of their National and Regional Contact Points for active support for their applicants;

19.

stresses the need to assure sufficient attention to the interests of local and regional authorities, to be affected by this regulation as well as to retain sufficient flexibility in prioritisation of PAFs as well as providing the possibility for regional authorities to be in charge of PAFs programmes and thereby become beneficiaries of this new measure;

20.

calls upon the European Commission to continue on improving the contribution of the LIFE+ Environment policy & governance component to fund compliance promotion projects, which identify, upstream of legislative process, the resources required to implement new EU legislation, green procurement pilot projects, which test the feasibility for large scale green public procurement programmes in towns or regions, as well as demonstration projects for resource efficiency, green growth and sustainable production;

21.

underlines that additional possibilities should be created for funding NGO environmental initiatives, thus enabling effective civil society involvement in implementing EU environmental law, raising public awareness of environmental protection through closer involvement in the setting of new objectives, and gathering best practices and know-how;

22.

draws attention to the fact that so far many of the initiatives, supported by the ‘Nature’ component have focused solely on species at risk of extinction, with extensive media coverage - e.g. brown bears (Ursus arctos), the fire-bellied toad (Bombina bombina) and the marsh fritillary (Euphydryas aurinia). On the other hand, many other endangered species have been entirely overlooked. Improvements to LIFE+ should also look at ways of using the programme to protect other, less visible species;

23.

reminds that current requirements require projects under the ‘Nature’ component to be exemplary and/or innovative. However in many cases protecting biodiversity is not about innovation but about continuing work that has already begun as well as collecting and disseminating accumulated good experience. For projects coming under this component it is therefore very important to have the option of placing less emphasis on having an exemplary and innovative character and more focus on particular needs of Natura 2000 areas and the issues of biodiversity preservation in a certain geographical area. It should be enough for projects to operate on the basis of exemplary procedures which can be applied to other regions;

24.

underlines that in view of the challenges facing LRAs and societies in the new Member States in adapting to the conditions of EU membership, it is vital to provide more active support for the implementation of the LIFE+ programme and other specific programmes in these countries;

25.

stresses that in order to achieve maximum synergy, efforts should be made in already this financing period to coordinate the LIFE+ programme wherever possible with other EU programmes directly or indirectly linked with environmental protection, for example the Seventh Research Framework Programme, the Competitiveness and Innovation Framework Programme, the European Agricultural Fund for Rural Development, Structural and Cohesion Funds;

26.

notes the benefits of promoting private sector involvement in biodiversity initiatives and of supporting the view that the objectives of the LIFE+ programme promote sustainable and socially responsible economic development;

27.

notes the benefits of higher involvement of academia in LIFE activities and would encourage its cooperation with the principal beneficiaries of the Programme, with scientists contributing the latest scientific findings and providing new perspective to common challenges;

C.   The LIFE programme in the new financing period

28.

stresses the importance of appropriate funding in the new financing period for environmental initiatives in Europe in order to protect biodiversity while providing ordinary Europeans with a high-quality environment and raising the environmental awareness of people world-wide;

29.

reminds that practise shows the unlimited number of environmental challenges and usual scarcity of resources to address them. For this reason, measures aimed at protecting the environment and biodiversity need to be particularly efficient. One of the main conditions for an efficient Europe, which lives up to the idea of ‘unity in diversity’, is the flexible use of resources, enabling stakeholders in various European countries and regions to get the greatest added value from EU funding, taking into account local conditions;

30.

reassures that local and regional authorities have, and will continue to play a key role to play in ensuring that Europeans can live in a high-quality environment rich in biodiversity. Priority must therefore be given to ensuring that LRAs can also make use of the various instruments for environment protection, with maximum involvement in shaping and improving them;

31.

confirms that the LIFE programme, introduced in 1992, has proved its worth many times over. It should therefore be extended to the next financing period, while making maximum use of the positive and negative experiences of the current financing period;

Priorities in the development of new LIFE programme

32.

takes note of the results of the impact assessment consultation on the future of the LIFE programme (5), which indicates that LRAs have identified raising awareness of the environmental problems and the need for solutions amongst different actors, as well as promoting innovation in techniques that enable improved environmental management, especially by competent authorities, as the two most effective ways of improving local environmental policy and its implementation; therefore urges the Commission to maintain the strengthening of LRAs administrative capacities and raising public awareness as the key priorities in any reforms of LIFE;

33.

expresses firm belief that the LIFE programme shall remain the key financial instrument for the protection of nature and biodiversity also during the new programming period, characterized by cost-effectiveness as well as a high quality of projects and programmes. Therefore any development of the programme should focus on simplifying application and administration procedures and opening it to a wide range of eligible applicants;

34.

asks that local and regional authorities and other public-law organisations be allowed once again to count their personnel costs in full as own resources in the new LIFE+ funding period, so that they can make even better use of the LIFE programme;

35.

underlines, that the full achievement of the goals of LIFE programme has possibly also been halted by slow administrative procedures and low co-financing rate (usually 50 % with possible exceptions for LIFE+ Nature). Therefore the programme shall see ways how to simplify the administration modalities (application, implementation, eligibility of smaller projects) as well as increasing maximum co-financing rate;

36.

notes the still remaining differences in information levels and financial capacities between the old and new Member States and therefore, in order to ensure the availability of the programme, recommends to develop special respective mechanisms to support applicants and beneficiaries from the newer Member States. This assistance shall aim towards project proposal development and administration issues and could be organized by strengthening the system of National Contact Points or by setting up regional contact points where these do not yet exist;

37.

proposes that the procedures of application shall take into account the concerns of sustainability and to exploit available IT possibilities. Namely online-based project application, evaluation, management body-applicants communication procedures shall be developed, including online applicants' registration and data provision system;

38.

calls for essential attention to be paid to the assessment process of project applications, which currently takes about one year and a half from the call for proposals and the start of a project. In this regard best management examples could be used from best-performing territorial cooperation programmes' Joint technical secretariats;

39.

indicates that while facilitating the application procedures and following the practices of territorial cooperation programmes, the costs of project preparation shall be made eligible for LIFE funding, or compensated through a lump sum (e.g. depending of total project budget), in case the project is approved;

40.

notes that the new LIFE implementation procedures should be simplified as far as possible to ensure that projects funded by the programme can focus primarily not on accountancy but on targeted environmental protection and information activity;

41.

reminds that civil society organisations will continue to play a no less important role in initiatives to protect the environment and biodiversity. The new LIFE programme should therefore include a strong component geared to non-governmental organisations and public information. At the same time, it is important to ensure that small local NGOs and scientists can also benefit from the programme;

42.

stresses the importance that any changes in the LIFE+ programme should also take into consideration the major contradiction between biodiversity protection measures on the one hand, and the tangible results on the other: projects are often short-term whereas results only become apparent after a longer period. Appropriate evaluation methods must therefore be used;

43.

calls on LIFE+ to be defined according to more identifiable and attainable targets. This requires more emphasis on outcomes rather than on assessing success on the basis of regularity of expenditure;

44.

proposes that as the programme is oriented towards long-term goals, the applicants shall be encouraged to implement and/or finance the activities, necessary for ensuring the effective follow-up after the termination of the project, which includes monitoring of the long-term effects of the project. Such encouragement could be foreseen as additional evaluation scores for those applicants, foreseeing the system of follow-up in their applications and committing to support it with own resources;

45.

indicates that the new LIFE+ programme must also include identification of projects which are in line with the objectives of regional strategies such as the Baltic Sea Strategy;

46.

based on practical experience, is convinced that project funding (action grants) are the most effective mechanisms and should remain the main instrument of LIFE support to assist local and regional authorities in their environmental activities and investments. The use of innovative financial instruments could also be considered, especially in the environmental area of the LIFE programme, but these tools should only be used, if at all, in addition to, and not in place of, direct project financing;

Management of the programme

47.

considers that current centralized management of LIFE programme has proved its efficiency, characterized by relatively low share of programme funds being attributed to administration, therefore the CoR, repeating its already expressed opposition to ‘renationalisation’ of the instrument (6), recommends to continue the future LIFE programme with a centralised management system run by the European Commission;

48.

indicates that in view of the fact that during project implementation it can be very difficult to achieve specific results in relation to an ecosystem, in the new EU financing period, project evaluation under the LIFE+ programme should also be carried out taking this into account. However, attention should focus on measures envisaged by projects, their extent and possible long-term impact, rather than the results achieved in the course of the reporting period;

49.

calls for the new LIFE programme to be made sufficiently flexible and be coordinated with other support instruments which have environmental components, even if they are not necessarily directly linked to environmental protection;

50.

considers that there is a need to promote a common, coherent strategy incorporating both nature conservation and rural development, especially for the regions covered by the Natura 2000 network which have a significant agricultural and livestock land-use component, and highlights the need to ensure effective coordination with the future instruments of the CAP, which is likely to target environmental competitiveness;

51.

welcomes the idea of regional authorities being in charge of Natura 2000 Prioritised Action Frameworks (PAFs) as well as stresses the need to assure sufficient space for latter changes in the priorities of the PAFs;

Structure of the new LIFE programme

52.

supports the Council, which has highlighted the need for all its components and the importance of reflecting LIFE in the future EU financial framework, bearing in mind the synergies with other EU financial instruments that contribute to achieving the EU environmental objectives  (7);

53.

calls on LIFE to be, as a minimum, formally linked with the new Common Strategic Framework;

54.

suggests the future LIFE programme to retain the structure similar to the present one, which would consist of three components: LIFE Biodiversity (including the current LIFE+ Nature & Biodiversity strand), LIFE Environment, and LIFE Governance (including the current LIFE+ Information & Communication strand);

LIFE Biodiversity

55.

calls the future LIFE Biodiversity strand not be limited only to Natura 2000, but to cover a wider concept of biodiversity. Biodiversity has become a wide concept, covering aspects like ecosystem services, green infrastructures, invasive alien species, etc. Though many of these aspects can be addressed under Natura 2000, which shall remain the core concept, there are aspects that are only partially covered or not at all, thus indicating a need of employment of wider concept of biodiversity;

56.

indicates that in order to play a significant role in financing Natura 2000, the LIFE should also allow funding of recurring site management activities, not only limiting to best practice or innovative projects as indicated in Article 3 of the LIFE+ regulation; however, in the interests of maintaining a high level of quality for the projects and activities receiving support, the LIFE programme should include minimum standards for proposed projects, arrangements for monitoring them and a requirement that results be communicated to the public;

LIFE Environment

57.

proposes that Environment component of the new LIFE programme should continue to be a decisive incentive for local and regional authorities, wishing to go beyond legislative requirements and applying innovative technologies and environmental solutions. This component could cover the upfront investment, thus opening the way to long-run benefits (8);

58.

reminds that as funding is limited, LIFE support may continue only in limited number of LRAs only, whereas the challenge of implementing the acquis concerns a majority of municipalities and regions. Thus, future LIFE projects should have a high replication potential for public-sector oriented eco-innovation (9), whereas the increase of visibility of the LIFE Environment component shall be also among the priorities;

59.

underlines, that the future LIFE Environment component should focus on more than just a few thematic issues (10), thus being open to the unique challenges and opportunities of the places it covers. Awarding criteria should be based on a mixed recognition of the programme's strategic objectives, and local priorities of potential beneficiaries. In order to remain sustainable LIFE could set for each theme biennial priorities, linked to those of EU's;

60.

calls for LIFE Environment to support projects on integrated environmental management by local and regional authorities, also for compliance promotion upstream of EU environmental legislation entering into force;

61.

notes the ongoing debate about the effectiveness of retaining two separate instruments to finance eco-innovation (11), both of which are managed by DG Environment. It therefore calls the European Commission to assess this aspect in its impact assessment for the future LIFE programme, taking into consideration that both instruments currently serve different purposes and reach different beneficiaries (12). Therefore, any decision, taken in this debate shall ensure that LRAs will remain among the beneficiaries, as those who play an indispensable role in bringing environmental best practices to a wider audience, being in close contact with the public, thus being able to raise awareness and encourage changes in behaviour;

LIFE Governance

62.

calls for a future LIFE Governance component to include the promotion of knowledge sharing on the implementation and enforcement of EU environmental law by supporting networks, training, and best practice sharing projects at European level, such as IMPEL or the LIFE+ European Capitals of Biodiversity project (13);

63.

calls for a review of the funding for environmental NGOs under LIFE Governance component, to more effectively support their role in contributing to a balanced stakeholder involvement in the EU policy process. This includes the change from annual to multiannual operating grants, as well as an increase in the number of Member States, covered by the partnership of particular project, thus providing necessary networking and field experience;

64.

reiterates its call upon the European Commission ‘to examine whether the concept of the Covenant of Mayors could be extended to other key EU environmental policy areas such as biodiversity, waste and water, noise and air pollution and land use’ (14), namely by the future LIFE programme financing of the extension of the concept of the Covenant of Mayors from energy efficient to resource efficient and environment-friendly cities;

Larger scale programmes

65.

supports, in order to increase the effectiveness of LIFE, and to reduce administrative costs, the Commission proposal on the possibility of larger-scale ‘Integrated LIFE Projects’ or ‘LIFE Action Programmes’, as a new category of LIFE projects. Projects of this type could be used to address a wide variety of problems, notably in the fields of freshwater management, nature and biodiversity conservation as well as sustainable resource use and waste management (15). However, traditional standalone LIFE Projectsshould be maintained, as they enable smaller local NGOs, stakeholders and authorities to become beneficiaries;

66.

considers that the Integrated Projects could foresee the possibility of support for a specific theme, or a large portion of the territory of a region or a Member State (e.g. wetland restoration projects in a river basin, activities for a threatened species along its migration route, development of sites management plans and their implementation, for all or similar Natura 2000 sites in a region, within a Natura 2000 Prioritised Action Framework);

67.

proposes that the Integrated Projects could include the framework and guidance for development of individual LIFE and of other projects, including a plan explaining how other EU, national, regional, local and private funding is combined to finance the activities proposed; these projects could also establish permanent working groups involving teams from different countries to review medium- and long-term results on similar experiences with LIFE projects which have already been implemented, by setting up networks using meetings, conferences, online platforms and other forms of communication;

68.

calls for public authorities, NGOs and stakeholders working at a regional or national level, and partnerships between these groups, to be eligible as beneficiaries of Integrated Projects. These projects should also be of a longer duration (e.g. 5-10 years), during which individual related LIFE projects can be developed and implemented;

69.

notes the added value of such integrated projects in particular in the major role they give to regional authorities as potential lead beneficiaries, which are also often the competent authorities in charge of Rural Development Funding, the Operational Programmes for Structural Funds, and the future Natura 2000 Prioritised Action Frameworks. Moreover, such projects provide an effective way to promote complementarities, and to make the most of LIFE's catalytic value: they establish a structured relationship with and develop project pipelines for the other EU funds, thereby promoting the mobilisation of their much larger contributions made for meeting environmental objectives. This could also help to address the current underspending by the EU Structural Funds in the fields of biodiversity and environment, a problem which the CoR addressed in earlier Opinions (16);

Territorial scope of the new LIFE programme

70.

calls for LIFE+ programme to take into account the fact that biodiversity challenges often transcend the EU's external borders. Therefore the provisions could be made for extending certain activities to the EU's immediate neighbours;

Information, dissemination and promotion measures

71.

deems satisfactory the results of the mid-term evaluation of LIFE+, where public authorities and development agencies were the most common group of beneficiaries for all three LIFE+ components (42 % of lead beneficiaries in 2007 and 2008, with these indicators rising up to 51 % in Nature and Biodiversity) (17) and further stresses the need to promote active involvement of LRAs in environment protection and biodiversity conservation;

72.

calls for information policies at national level to be improved in order to raise awareness among potential participants of the opportunities offered by the LIFE+ programme. To this end, taking into account the subsidiarity principle and the obvious differences between individual Member States, information policy should be decentralised in such a way as to develop national information centres and in some cases to promote information campaigns on the programme at regional level too;

73.

calls for the future LIFE programme to provide operating grants for networks of local and regional authorities, which engage in the active promotion of the LIFE towards municipalities and regions (18);

74.

stresses that the new LIFE continues to offer support for communication and information projects, with an increased focus on education and promoting projects which involve local and regional authorities and have significant impact at EU level;

75.

notes that in order to achieve additional added value from the communication, the programme should foster stronger focus on targeted and thus more effective ways of communication activities in each LIFE project. In particular, such activities should aim primarily at capacity building and training for, and involvement of, key stakeholders, rather than merely informing the general public through brochures or signposts;

76.

reminds that NGOs initiatives to disseminate information on the LIFE+ programme to date have focused on funding merely European NGOs, based in Brussels. In 2007, 30 NGOs from the whole EU were funded in this way, compared to 33 in 2008 and 32 the year after. Despite the fact that most of these organisations have networked structures, this is clearly not enough. It is therefore very important to provide stronger support for organisations active in the Member States, particularly at local level, as they are usually best aware of local needs;

77.

recommends that in order to ensure by the required effect of NGOs' publicity campaigns, these organisations must be able to focus on their actual environmental and information activities, rather than on funding applications and accountancy. It would also be useful if the Commission agreed to conclude long-term agreements with a duration of at least two to three years;

78.

commits to continue to disseminate the information on the possibilities offered by the LIFE+ programme, to promote the involvement of local applicants in the programme, to gather the views of European LRAs and to provide the Commission with recommendations based on practical experience on how to improve the programme and on the potential for the EU to develop additional instrument for ‘nature and biodiversity’, running in parallel with the new LIFE instrument.

Brussels, 1 July 2011.

The President of the Committee of the Regions

Mercedes BRESSO


(1)  The latest Financial Instrument for the Environment (LIFE+) was established by Regulation (EC) No 614/2007, OJ L 149, 9.6.2007.

(2)  European Commission, DG Environment 2010: LIFE Focus ‘LIFE and local authorities’.

(3)  According to Article 8 of the Habitats Directive. European Commission, LIFEnews feature 2010 ‘LIFE Nature and Biodiversity: what common future?’

(4)  European Commission, LIFEnews feature 2010 ‘LIFE Nature and Biodiversity: what common future?’

(5)  Report ‘Assessment of Territorial Impacts of the EU Life+ instrument’, prepared by the Secretariat of the Committee of the Regions, May 2011.

(6)  CdR 253/2004 fin.

(7)  Environment Council Conclusions of 20 December 2010 on Improving Environmental Policy Instruments (5302/11).

(8)  CdR 164/2010 fin.

(9)  CEMR 02/2011: Response to the consultation on a future EU financial instrument for the environment.

(10)  CdR 253/2004 fin.

(11)  The eco-innovation component of the Competitiveness and Innovation Programme (CIP) and the LIFE+ Environment policy & governance component.

(12)  European Commission, LIFEnews feature 2010 ‘The evolution of LIFE Environment: past, present and future’.

(13)  CdR 164/2010 fin, CdR 112/2010 fin.

(14)  CdR 164/2010 fin.

(15)  Report ‘Assessment of Territorial Impacts of the EU Life+ instrument’, see above.

(16)  CdR 112/2010 fin.

(17)  SEC(2010) 1120 final.

(18)  CEMR 02/2011.