Memorandum by the Department for International
This memorandum has been prepared by the Department
for International Development (DFID) with assistance from the
Department of Environment, Transport and the Regions (DETR), in
response to a request from the European Communities Committee,
Sub-Committee C (Environment, Public Health and Consumer Protection),
which is conducting an enquiry into environmental aspects of the
1. Nature and scale of environmental problems
in the NIS
1.1 The Newly Independent States of the former
Soviet Union face immense environmental problems. These are largely
the legacy of the Soviet period. The size of the NIS coupled with
the wide variations in climate and levels of industrialisation
contributes to the diversity of environmental problems. The Western
NIS countries have large urban populations, heavy industry, high
levels of ambient air pollution, water pollution and large volumes
of municipal and industrial waste. The Central Asian Republics
are less densely populated with economies driven by the extraction
of natural resources and irrigated agriculture.
1.2 Economic decline has brought about a reduction
in air and water pollution but now measures are needed to ensure
that economic recovery will be developed in an environmentally
sustainable manner. Priorities are the reduction of health risks
(in particular, by improving access to safe drinking water and
tackling the most severe cases of industrial pollution and hazardous
waste), and institutional improvements in order to integrate environmental
considerations into policy in other sectors. It is also important
to improve monitoring procedures, streamline regulations, strengthen
enforcement mechanisms, and to improve environmental awareness
amongst the public. A note on specific issues is at Annex A.
1.3 In the Russian Federation, the Action Plans
of the Government for 1994-95 and 1996-97 were the first attempt
to formulate a new national policy in the field of environmental
protection. Building on this experience, the State Committee for
Environmental Protection is currently preparing a National Environmental
Action Plan (NEAP) for 1998-20 (expected to be approved in summer
1998). In Ukraine, Main Directions of State Environmental Policy
were prepared in 1995 and approved by the Cabinet in 1997. They
are expected to be adopted by Parliament in 1998. The National
Environmental Programme of Belarus for 1996-20 was approved in
1996. Kyrgyzstan and Moldova approved NEAPs in 1995. Kazakhstan,
Uzbekistan, Armenia, Azerbaijan and Georgia are preparing NEAPs
for approval in 1998.
1.4 The willingness and ability of polluters
to pay for investments to resolve environmental problems is very
low and, in some cases, non-existent in the NIS. In many NIS,
state and municipal budget allocations for the environment have
fallen significantly. The capacity and effectiveness of environmental
funds, capitalised by environmental charges and taxes, is weak.
Foreign direct investment is low.
1.5 The Environment for Europe process, launched
at the Dobris Castle Conference in 1991, provides an effective
political framework for environmental co-operation in the UN European
region, including all the NIS countries. Policy reform, institution
building and priority investments are promoted in line with the
Environmental Action Programme for Central and Eastern Europe
(1993), although progress has been greater in Central Europe than
the NIS countries. The next Environment for Europe Ministerial
conference will be held in Aarhus, Denmark, in June and is expected
to call for a greater focus on the problems of the NIS countries,
including more emphasis on the environment in the TACIS programme.
2. Priorities for action under the TACIS programme
2.1 The EU began supporting reforms in the Soviet
Union in 1990. This led to the creation of the TACIS programme
of technical assistance to 12 of the successor independent States
(i.e., excluding the three Baltic States), plus Mongolia, with
the aim of supporting the transition to a market economy and reinforcing
democracy. It is the largest single provider of technical assistance
to the region with 2,268 mecu committed so far.
2.2 The current TACIS Regulation, adopted in
1996, provides the legal base for the programme for the four-year
period to 2000. The Regulation sets a "financial reference
amount", or allocation, of 2,224 mecu for the programme,
and actual budgets are then approved annually by the European
Council and Parliament.
2.3 The Regulation identifies six priority areas
human resources development;
enterprise restructuring and development;
energy, including nuclear safety;
food production, processing and distribution;
the environment, with particular
reference to institutional strengthening, legislation and training.
2.4 Environment was added in 1996 as a priority
area, largely at the instigation of the UK and one or two other
Member States. In addition, the Regulation stresses the importance
of taking account of environmental considerations in the design
and implementation of the programme as a whole. A full list of
TACIS environment projects is at Annex B.
3. Relationship between TACIS and other forms
of official assistance
3.1 The demands of the NIS region are huge,
and there is scope for all donors to be active. The technical
assistance funded by TACIS and by bilateral donors, including
Germany and the UK, combined with the investment funding of the
World Bank and EBRD should be mutually reinforcing. But the May
1997 TACIS Interim Evaluation reported a lack of co-ordination
3.2 World Bank Consultative Groups offer a formal
forum for donors to exchange views on country programmes (except
Russia), and there are also informal in-country donor co-ordination
meetings, some on specific issues. The Environment for Europe
process is an important framework for co-ordinating environmental
3.3 The scale of TACIS resources should give
it more leverage over beneficiary government policies compared
with the effects of more modest bilateral programmes such as the
UK Know How Fund. We try to influence the shape of the TACIS programme
by sharing examples of best practice and experience of our own
4. Success of Partnership and Co-operation Agreements
in providing a satisfactory framework for environmental programmes
4.1 Partnership and Co-operation Agreements
(PCAs) between the EU and the successor states to the Soviet Union
are intended to replace and enhance the 1989 EC/USSR Trade and
Economic Co-operation Agreement. PCAs have now been signed with
almost all the successor states and those with Russia and Ukraine
have entered into force. Inter alia, the PCAs provide for
co-operation in a wide range of areas, including environment.
4.2 Article 69 of the PCA between the EU and
Russia, for instance, commits the Parties to develop co-operation
on the environment and human health. The inaugural Co-operation
Committee was held in Brussels on 22 April 1998 and accepted the
establishment of a sub-committee which will cover the environment
(along with energy and nuclear issues). The main goal is to combat
the deterioration of the environment in all problem areas, for
which technical assistance is available through TACIS.
4.3 We expect that a similar approach will be
followed as other PCAs come into force; preparation is now under
way for the inaugural Co-operation Council between the EU and
Ukraine in June, where nuclear safety and the protection of the
environment will certainly be on the agenda.
5. New Emphasis on environment in the 1996 TACIS
5.1 Before 1996, support for the environment
was channelled through the interstate programme, rather than individual
country programmes. The Cross-Border Co-operation programmes and
the TACIS Action Plans for Russia in 1997 and Ukraine in 1998
included discrete environmental projects in the country programme
for the first time. Environment projects now account for around
10 per cent of the funding allocated to Russia and Ukraine, and
environmental factors are taken into consideration in all TACIS
5.2 In reporting its activities by sector, TACIS
combines statistics on environment with nuclear safety. The combined
environment/nuclear safety sector received the largest share of
TACIS resources in 1996 (141.5 mecu), but most of it is for nuclear
safety, including the rebuilding of the Chernobyl sarcophagus.
5.3 The TACIS Interim Evaluation reflected the
low priority given to the environment up to that time. It found
that the impact of TACIS in promoting environmental awareness
among its project partners had been low. Our impression is that
TACIS's performance on the environment has improved recently although
it is too early to assess the results.
6. TACIS as a "people-to-people" programme
6.1 In the 1996 TACIS Annual Report Commissioner
Van den Broek suggested that the key characteristic of TACIS was
that it was a "people to people" programme. In the sense
that the programme consists mainly of the transfer of know-how
from European experts to NIS counterparts, the description is
accurate. The Interim Evaluation found that "one main strength
of TACIS lies in [this] approach. Tens of thousands of NIS managers,
experts, administrators (and some politicians) have met their
EU counterparts . . . This joint work gives a wider view, leading
to a better and in depth understanding of the problems."
6.2 The TACIS Country Action Programmes are
constrained by the need to secure partner government approval,
for both sectoral focus and project proposals. They are also frustrated
by complex internal EC procedures, institutional barriers and
long chains of command. But there are some small programmes, such
as the Lien and Partnership and Co-ordination Programmes, which
are open to all NIS countries and which are not subject to the
same procedural requirements as the Country Action Programmes.
Projects under these programmes are proposed by non-governmental
and private organisations in the EU and NIS, and as such, constitute
a "people-to-people" approach.
7. European Commission organisation and the resources
needed for efficient management of the programme
7.1 EC aid has a complex management structure.
Five different Directorates General (DGs) are involved (see Annex
C). Each has different priorities, programmes, and procedures.
7.2 The Commission has decided to form a Common
Services Unit for management of all external assistance, and is
aiming for it to be operational by September 1998. (Phillipe Soubestre
will head the new structure.) This should bring improvements (e.g.,
harmonisation of procedures), but much will depend on the final
division of responsibilities, lines of responsibility, and communication
with the DGs/Delegations. We are concerned that the project cycle
will be split in two (with policy and project identification and
design the responsibility of the DGs; and contracting, monitoring
and evaluation left for the new structure).
7.3 Reorganisation is an internal Commission
activity and there is no formal role for Member States. But Member
States have a legitimate interest in the effectiveness of the
new arrangements. DFID is keeping in close touch with the Commission.
We are willing to offer any assistance which would be useful.
7.4 The programme is accountable to Member States
which are represented in management committees (see Annex D) and
approve projects and programmes to be financed under the main
budget lines. DFID represents the UK. The Court of Auditors examines
and reports on all Community expenditure. The European Parliament
does not have a formal role in implementation of aid programmes;
but it has a major role in the budget process and the final budget
requires the signature of its President. Member States also participate
in an evaluation working group which has met approximately quarterly
this year to oversee the Commission's work on evaluation of all
its aid programmes.
7.5 The Commission is not uniformly effective.
DGVIII is the best of those involved with aid. There are problems
generally in staffing (there is a lack of professional expertise
in key areas and insufficient support staff), systems and organisational
structure. The Commission's own internal project cycle management
guidance stresses the importance of cross cutting issues (e.g.,
environmental and social issues) in the project cycle. But continuing
efforts are required to ensure this is always fully reflected
in the design and implementation of projects and programmes.
7.6 In order to improve effectiveness, DFID
is providing secondees (detached national experts) to the Commission
in key areas (see Annex E). There is also regular contact between
DFID and Commission staff. We take an active role in management
committees, discussing wider systems and procedures as well as
projects. During our Presidency we have worked on following up
two important resolutions (1993 Poverty Resolution and 1995 Gender
Resolution), reviewing progress and what more needs to be done
to improve effectiveness. Conclusions on these Resolutions were
agreed at the Development Council on 18 May 1998.
8. Criticisms by the European Court of Auditors
and European Parliament; recommendations of the Interim Evaluation
8.1 The Court of Auditors found that complex
procedures and staff shortages in the Commission and the field
have led to some serious delays to both environmental projects
and the nuclear safety programme. The TACIS programme is basically
constrained by the administrative procedures imposed upon it by
the 1977 Financial Regulation covering all EC programmes.
8.2 In its 1996 Annual Report, the Court of
Auditors found that TACIS commitments were loaded heavily towards
the end of the year, owing to the late agreement of the new TACIS
Regulation and Indicative Programmes for the period 1996-99. The
Commission had made commitments totalling about 1500 mecu, but
had failed to enter into contracts. In response, TACIS has cancelled
70 programmes and 559 contracts, totalling 31.3 mecu, which had
never been implemented. Progress was made to improve contracting
performance in 1997, with 700 mecu worth of contracts agreed,
60 per cent more than in 1996, reducing the backlog of uncontracted
commitments to 530 mecu.
8.3 The Commission has accepted many of the
criticisms made by the Court of Auditors, but argues that general
political and sectoral uncertainties are a major constraint to
efficient programme management. TACIS has begun to focus activity
on fewer key areas and to reduce the number of contracts let.
8.4 The Commission has rejected the TACIS Interim
Evaluation recommendations that the demand-driven approach weakens
the programme and should be replaced by a dialogue through the
Partnership and Co-operation Agreements. The Commission's argument
is that the purpose of the Agreements is to govern political relationships
between the EU and partner countries; TACIS is just one of the
instruments which may be used to facilitate the Agreements.
8.5 Project cycle management training has been
introduced, communication strategies are being improved, and financial
procedures have been simplified, but the TACIS and general financial
regulations impose stringent procedures on the Commission which
it cannot escape. In addition, DG1A has been unable to increase
its staff numbers.
9. Obtaining best value from consultants
9.1 TACIS's general approach to the use of consultants
is in line with that of other donor agencies. The NIS is a difficult
part of the world in which to work as counterpart institutions
typically have poor project preparation skills and limited resources.
In consequence it is often difficult to obtain project ownership
and inputs by beneficiaries.
9.2 Two factors affect the value obtained from
services provided by consultants on TACIS funded environment projects:
(a) there is often a considerable delay (typically
1-2 years) between project identification and the start of project
implementation. By then, needs may have changed and beneficiaries
have sometimes lost sight of the original agreements and commitments
they made during project design. This compels consultants to devote
a high proportion of their time and energy to discussing and agreeing
the inputs expected from project beneficiaries. This reduces the
amount of resources that can be allocated by consultants to the
provision of technical inputs.
(b) administrative inflexibility and contractual
delays in DG1A mean that consultants spend a lot of time on contract
management. Any changes in project design which involve a transfer
of funds between budget lines require a contract addendum, which
takes about 2-6 months to process. This makes it difficult for
consultants to respond to the changing needs and demands of the
beneficiaries, and leads to dissatisfaction among all parties.
9.3 These factors can have a dramatic impact,
as they affect the amount of time that consultants can spend on
the delivery of technical assistance. As a result, management
costs typically comprise a high proportion of the total costs
of TACIS-funded environment projects (particularly those operating
at the Inter-State level).
9.4 A note on TACIS selection procedures is
at Annex F.
10. Strength and influence of environmental NGOs
in the NIS
10.1 The green movement emerged in the Soviet
Union in the mid-eighties and were the first NGOs to be tolerated
by the authorities. Most other so-called NGOs were under the control
of the Communist Party.
10.2 It is not easy to assess the influence
of the NGOs. They are weak in the sense that they have not been
able to mobilise public opinion to force governments to take the
environment more seriously. They are up against enormous oddsthe
basic social needs of large groups of people are not being met
and people have more on their minds than the environment. However,
the groups have strengths. Heavily based on the institutes and
universities, they are intellectually strong and add much to the
debate on the environment. Occasionally this intellectual rigour
has won the argumentin particular in the referendum against
building a nuclear power plant in Kostroma, Russiabut also
for Russia in the success in the courts of groups such as Eco-Juris
and the Centre for Human Rights and Environmental Defence. The
large number of good environmental magazines and bulletins in
Russia is due to the work of the NGOs.
10.3 There are environmental NGOs in Russia
with which western governments and organisations can usefully
work. This is a great improvement on the situation a few years
10.4 In Ukraine, the green movement became much
stronger after the Chernobyl nuclear disaster: many people joined
the movement, which allowed them to participate in a kind of "opposition"
which was safer than human rights or independence movements. In
1989-90, when other political movements and parties began to appear,
the green movement lost more than half of its activists to these
10.5 Green NGOs are still the most numerous
in Ukraine. The most promising area for policy co-operation is
found between NGOs and local authorities. NGOs tend to be seen
as important during election campaigns, and can occasionally influence
decisions by organising rallies and campaigns.
10.6 Regional Environment Centres are being
established with TACIS and other donor support in Moldova, Ukraine,
Russia, Georgia and Kazakhstan to encourage the growth of environmental
10.7 Further details of environmental NGOs in
Russia and Ukraine are in Annex G.
11. Lessons learned from PHARE experience
11.1 The PHARE programme suffered in the past
from a number of problems still experienced by TACIS, namely long
delays between project identification and implementation, administrative
inflexibility and delays in amending contracts. In addition, there
was little active consultation between PHARE project officers
and the intended beneficiaries, with the effect that some projects
did not accurately reflect the needs of these institutions.
11.2 The efficiency and effectiveness of the
PHARE programme has improved considerably over the past 18 months.
In part this is due to pressure from beneficiaries for greater
involvement during project design. It also reflects an increasing
awareness by beneficiaries to identify their requirements more
clearly, and to play a more active role in project development.
11.3 Contracting of consultants by PHARE is
now quicker and more efficient. PHARE has established a framework
contract, in which consultants help in the design, management
and contracting of PHARE environment projects. This eases the
pressure on PHARE staff resources. Tender lists are also more
specific, so that proposals are received from consultants with
more relevant experience. In consequence there is less delay between
project design and the start of project implementation. Projects
more accurately reflect the needs of the beneficiaries, and there
is less need to amend the terms of reference (which can result
in contractual delays).
11.4 The performance of the overall PHARE programme
is currently being evaluated, at the request of the European Parliament.
A draft report on the conclusions is expected later this year.
11.5 There is no evidence that TACIS has actively
incorporated any lessons learned from PHARE experience into its
12. Role of the European Environment Agency
12.1 The main role of the European Environmental
Agency (EEA) is to produce objective, reliable and comparable
information for those concerned with developing European environmental
policy, and for the wider European public. The EEA's programme
of co-operation with the PHARE countries has proved necessary
in order for the Agency to produce a pan-European state of the
environment report, Europe's Environment: The Second Assessment
(known as the Dobris+3 Report), as requested by the Sofia Ministerial
12.2 The EEA is, through the TACIS programme,
working to secure funding for environmental information concerning
countries in Eastern Europe beyond the PHARE countries. Co-operation
is under development in two stages: short term needs for immediate
reporting requirements and a longer term perspective beyond 1998.
The broad objective of the immediate requirements to be implemented
in 1998 is to provide the additional resources and technical assistance
necessary for the NIS and EEA to collaborate in activities linked
with the preparation of the Dobris+3 report.
12.3 The Government considers it is desirable
to build on this work, extending co-operation to TACIS countries
in order to improve the state of reporting on Europe as a whole.
Eastern Europe and Central Asia Department
Department for International Development