COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review Country Report - LATVIA Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions The EU Environmental Implementation Review: Common Challenges and how to combine efforts to deliver better results

1.

Kerngegevens

Document­datum 06-02-2017
Publicatie­datum 07-02-2017
Kenmerk 5967/17 ADD 19
Van Secretary-General of the European Commission, signed by Mr Jordi AYET PUIGARNAU, Director
Externe link origineel bericht
Originele document in PDF

2.

Tekst

Council of the European Union

Brussels, 6 February 2017 (OR. en)

5967/17 ADD 19

ENV 103 ECOFIN 70 SOC 68 COMPET 74 POLGEN 9 CONSOM 37

COVER NOTE

From: Secretary-General of the European Commission, signed by Mr Jordi AYET PUIGARNAU, Director

date of receipt: 6 February 2017

To: Mr Jeppe TRANHOLM-MIKKELSEN, Secretary-General of the Council of the European Union

No. Cion doc.: SWD(2017) 50 final

Subject: COMMISSION STAFF WORKING DOCUMENT

The EU Environmental Implementation Review

Country Report - LATVIA

Accompanying the document

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions

The EU Environmental Implementation Review: Common Challenges and

how to combine efforts to deliver better results

Delegations will find attached document SWD(2017) 50 final.

Encl.: SWD(2017) 50 final

EUROPEAN COMMISSION

Brussels, 3.2.2017 SWD(2017) 50 final

COMMISSION STAFF WORKING DOCUMENT

The EU Environmental Implementation Review

Country Report - LATVIA

Accompanying the document

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions

The EU Environmental Implementation Review: Common Challenges and how to

combine efforts to deliver better results

{COM(2017) 63 final i} {SWD(2017) 33 - 49 final} {SWD(2017) 51 - 60 final}

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This report has been written by the staff of the Directorate-General for Environment, European

Commission. Any comments are welcome to the following e-mail address: ENV-EIR@ec.europa.eu

More information on the European Union is available on the internet (http://europa.eu).

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Photographs: p.11 – ©gorsh13/iStock; p.16 – ©LIFE08 ENV/LV/000451; p.17 – © f9photos/iStock; p.22 – ©Giuseppe Di Paolo/iStock

For reproduction or use of these photos, permission must be sought directly from the copyright holder.

©European Union, 2017

Reproduction is authorised provided the source is acknowledged.

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Table of Content

EXECUTIVE SUMMARY .................................................................................................................................... 4

PART I: THEMATIC AREAS ............................................................................................................................... 5

  • 1. 
    TURNING THE EU INTO A CIRCULAR, RESOURCE-EFFICIENT, GREEN AND COMPETITIVE LOW-

    CARBON ECONOMY ............................................................................................................................... 5

    Developing a circular economy and improving resource efficiency ..................................................... 5

    Waste management .............................................................................................................................. 7

  • 2. 
    PROTECTING, CONSERVING AND ENHANCING NATURAL CAPITAL ....................................................... 9

    Nature and Biodiversity ......................................................................................................................... 9

    Green Infrastructure ........................................................................................................................... 11

    Soil protection ..................................................................................................................................... 11

    Marine protection ............................................................................................................................... 12

  • 3. 
    ENSURING CITIZENS' HEALTH AND QUALITY OF LIFE .......................................................................... 14

    Air quality ............................................................................................................................................ 14

    Noise ................................................................................................................................................. 15

    Water quality and management ......................................................................................................... 15

    Enhancing the sustainability of cities .................................................................................................. 17

    International agreements ................................................................................................................... 18

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ..................................................................... 19

  • 4. 
    MARKET BASED INSTRUMENTS AND INVESTMENT ............................................................................ 19

    Green taxation and environmentally harmful subsidies ..................................................................... 19

    Green Public Procurement .................................................................................................................. 20

    Investments: the contribution of EU funds ......................................................................................... 20

  • 5. 
    EFFECTIVE GOVERNANCE AND KNOWLEDGE ...................................................................................... 22

    Effective governance within central, regional and local government ................................................. 22

    Public participation and access to justice ........................................................................................... 24

    Access to information, knowledge and evidence ................................................................................ 24

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Executive summary

About the Environmental Implementation Review a good level of environmental protection and, generally

In May 2016, the Commission launched the high air and water quality. It has a relatively high variety

Environmental Implementation Review (EIR), a two-year of different ecosystems and natural areas and is one of cycle of analysis, dialogue and collaboration to improve the countries in Europe with the richest biodiversity and the implementation of existing EU environmental policy established nature conservation traditions. and legislation1. As a first step, the Commission drafted Environmental implementation in Latvia is good with low 28 reports describing the main challenges and numbers of complaints and infringements. However, opportunities on environmental implementation for each waste management and particularly recycling, remains Member State. These reports are meant to stimulate a amongst the challenges for Latvia requiring strong efforts positive debate both on shared environmental challenges in order to reach the 2020 recycling target of 50%. for the EU, as well as on the most effective ways to There is also further room for improvement in addressing address the key implementation gaps. The reports rely on resource intensity issues. Latvia could benefit from the detailed sectoral implementation reports collected or a more structured approach and political support to issued by the Commission under specific environmental the circular economy, as well as from targeted ecolegislation as well as the 2015 State of the Environment innovation policy.

Report and other reports by the European Environment Main Challenges

Agency. These reports will not replace the specific

instruments to ensure compliance with the EU legal The main challenges with regards to the implementation obligations. of EU environmental policy and law in Latvia are: The reports will broadly follow the outline of the 7th  Improving waste management, particularly Environmental Action Programme 2 and refer to the 2030 increasing recycling, rolling-out separate collection Agenda for Sustainable development and related and reducing landfilling; Sustainable Development Goals (SDGs) 3 to the extent to  Reducing resource intensity which would lessen which they reflect the existing obligations and policy the exposure of Latvian businesses to rising resource objectives of EU environmental law4. costs.

The main challenges have been selected by taking into Main Opportunities

account factors such as the importance or the gravity of

the environmental implementation issue in the light of Latvia could perform better on topics where there is the impact on the quality of life of the citizens, the already a good knowledge base and good practices. This distance to target, and financial implications. applies in particular to:

The reports accompany the Communication "The EU  Use of the opportunities provided by EIB loans and

Environmental Implementation Review 2016: Common EFSI support to further promote environmental challenges and how to combine efforts to deliver better projects;

results", which identifies challenges that are common to  Use of market based instruments to encourage several Member States, provides preliminary conclusions resource efficiency, particularly in waste on possible root causes of implementation gaps and management and in water resources management; proposes joint actions to deliver better results. It also  High potential for Green Infrastructure development groups in its Annex the actions proposed in each country in order to address flood and erosion risks, while report to improve implementation at national level. improving the connectivity of natural areas.

General profile Points of Excellence

Latvia is a well organised country that benefits from As Latvia is a leader on environmental implementation, innovative approaches could be shared more widely with other countries. Good examples are:

1 European Union, Communication "Delivering the benefits of EU

environmental policies through a regular Environmental  Good compliance record, having a low number of Implementation Review" ( COM/2016/ 316 final ). complaints and infringements.

2 Decision No. 1386/2013/EU of 20 November 2013 on a General Union

Environmental Action Programme to 2020 " Living well, within the limits of our planet ".

3 United Nations, 2015. The Sustainable Development Goals

4 This EIR report does not cover climate change, chemicals and energy.

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Part I: Thematic Areas

  • 1. 
    Turning the EU into a circular, resource-efficient, green and

    competitive low-carbon economy

Developing a circular economy and improving resource efficiency Figure 1: Resource productivity 2003-15 8

The 2015 Circular Economy Package emphasizes the need to move towards a lifecycle-driven ‘circular’ economy, with a cascading use of resources and residual waste that is close to zero. This can be facilitated by the development of, and access to, innovative financial instruments and funding for eco-innovation.

SDG 8 invites countries to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all. SDG 9 highlights the need to build resilient infrastructure, promote inclusive and sustainable industrialization and foster innovation. SDG 12 encourages countries to achieve the sustainable management and efficient use of natural

resources by 2030. In the Sustainable Development Strategy for Latvia until

2030 9 one of the priorities is “Nature as future capital”, Measures towards a circular economy which aims to position Latvia as a leader in protection,

Transforming our economies from linear to circular offers promotion and sustainable use of ecosystem services. an opportunity to reinvent them and make them more In addition, the National Development Plan 2014-2020

10

sustainable and competitive. This will stimulate integrates sustainability concerns into a number of investments and bring both short and long-term benefits priority areas, including economic growth, energy

for the economy, environment and citizens alike. 5 efficiency and energy production, growth-oriented territorial development and sustainable management of

Latvia's resource productivity 6 (how efficiently natural and cultural capital.

the economy uses material resources to produce wealth),

in 2014 in terms of value produced per kg of resources Targeted policy documents for promoting and utilising used is 0.5 EUR/kg, above an EU average of 2 EUR/kg 7 . the principles of circular economy are in the early stages Figure 1 shows that Latvia's resource productivity has of development. The Declaration of the new Government remained relatively stable since 2011. of Latvia adopted in February 2016 highlights waste

management, alternative fuels and bioeconomy as Latvia is gradually moving towards more eco-innovation priorities. but the speed depends largely on availability of financial

resources .There is much scope for work in the area of SMEs and resource efficiency

public awareness and financial planning in order to foster

more favourable conditions for eco-innovation In the Flash Eurobarometer 426 "SMEs, resource development in Latvia. efficiency and green markets"

11 it is shown that 47% of

Latvia's Small and Medium-sized enterprises (SMEs) have

In Latvia responsibility for the policies related to ecoinvested up to 5% of their annual turnover in their innovation and circular economy is split among a range of resource efficiency actions (EU28 average 50%), 17% of institutions, primarily the Ministry of Economy, Ministry them are currently offering green products and services of Education and Science and Ministry of Environmental (EU28 average 26%), 61% took measures to save energy Protection and Regional Development. (EU28 average 59%), 38% to minimise waste

8 Eurostat, Resource productivity , accessed October 2016 5 European Commission, 2015. Proposed Circular Economy Package 9 Sustainable Development Strategy for Latvia until 2030 6 Resource productivity is defined as the ratio between gross domestic 10 National Development Plan 2014-2020

product (GDP) and domestic material consumption (DMC). 11 European Commission, 2015. Flash 426 Eurobarometer "SMEs,

7 Eurostat, Resource productivity , accessed October 2016 resource efficiency and green markets"

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(EU28 average 60%), 41% to save water (EU28 average necessary to substitute rare natural resources 12 .

44%), and 58% to save materials (EU28 average 54%).

From a circular economy perspective, 16% took measures The overall position of Latvia in the Eco Innovation

to recycle by reusing material or waste within th Scoreboard (Eco-IS) has improved from 24 place in 2013

the company (EU28 average 40%), 19% to design (55 points) to 20th place in 2015 (74.9 points) as shown products that are easier to maintain, repair or reuse in Figure 2.

(EU28 average 22%) and 17% were able to sell their scrap

material to another company (EU28 average 25%). Figure 2: Eco-Innovation Index 2015 (EU=100)

13

According to the Flash Eurobarometer426, resource efficiency actions allowed the reduction of production costs in 44% of Latvian SMEs (EU28 average 45%).

The Flash Eurobarometer 426 "SMEs, resource efficiency and green markets" shows that 47% of the SMEs in Latvia have one or more full time employee working in a green job at least some of the time (EU28 average 35%).

Latvia has an average number of 2.1 full time green employees per SME (EU28 average 1.7%).

Eco-Innovation

The key eco-innovation areas in Latvia have not changed markedly in recent years. Sectors that continue to develop include renewable energy and energy efficiency in residential buildings, forest-based industries and ecocosmetics. In addition, service sectors that use Latvia’s

‘green image’ as a key selling point – e.g. tourism, leisure and recreation and organic agriculture – maintain their activities.

Among the developing eco-innovation areas in Latvia one can highlight electromobility. In 2014 the Ministry of

Transport elaborated the Electromobility Development

Plan of Latvia 2014-2016. The plan has been prepared with a long-term view to fully integrate this area into transport policy as a way to decrease the use of fossil fuels, CO2 emissions and noise levels. This includes the The main drivers for eco-innovation in Latvia are certainly support to new means of electromobility and the the energy and resource efficiency targets of the EU’s establishment of their charging infrastructure. Europe 2020 strategy, which have been integrated in

Through the Climate Change Financial Instrument, the national policy documents and corresponding funding Ministry of the Environmental Protection and Regional lines, most notably the EU Structural Funds envelope. Development has provided financial support for the Together with national co-financing Latvia plans to invest implementation of 102 Projects where electrical vehicles around EUR 550 million in research, development and were purchased and public charging infrastructure was innovation (RDI), EUR 565 million in transition to lowinstalled.

carbon economy and EUR 733 million in environmental protection and resource efficiency by 2020 (Ministry of

In terms of recent actions by established cleantech Finance, 2014). The Latvian Smart Specialisation Strategy companies in Latvia, a stronger focus on water emphasises the focus on developing bioeconomy, smart management and purification can be observed, as well as materials and sustainable energy solutions as three out on technologies related to water infrastructure of five key areas for RDI investment. This ensures a development and monitoring. sustained political and financial commitment for

the development of the green economy – an area that The green technology start-up scene in Latvia sees new previously has not been high on the political agenda in ideas and enterprises incubated in a wide range of Latvia. sectors, including electromobility, wind energy, ecodesign, eco-innovative solutions in construction, LED lightning applications, composite materials and

metalworking to develop material characteristics that are 12 Neimanis, M., 2016, Interview. 13 Eco-innovation Observatory : Eco-Innovation scoreboard 2015

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Equally important is the increasing support to ecoto the knowledge-based bio-economy, smart materials innovation from other international funding and smart energy. Green growth and circular economy programmes, such as the Norwegian Financial vocabulary is being adopted gradually from EU directives, Mechanism. In 2014, with the support of the Norwegian but their implications in the context of the national Financial Mechanism’s programme, “Green Industry economy have to be still assessed to find the best Innovation”, the Green technology incubator was solutions. Though, overreliance on the EU and EEA launched in Latvia, which was the first innovation support financial mechanisms create a fragmented support instrument specifically dedicated to the development of landscape that is not favourable to long-term green eco-innovative companies and eco-innovative industry development. entrepreneurship in the country.

Waste management

The richness of natural capital such as forests, soil and

water can also be identified as drivers of eco-innovation. Turning waste into a resource requires:

Almost half of Latvia’s territory is made up of natural − Full implementation of Union waste legislation, ecosystems. Low population density and relatively low which includes the waste hierarchy; the need to levels of industrial pollution highlight the “green image” ensure separate collection of waste; the landfill of the country, making it a good destination for ecodiversion targets etc. tourism and travel. Consequently, it also promotes a − Reducing per capita waste generation and waste wide range of eco-innovation businesses and related generation in absolute terms. activities. − Limiting energy recovery to non-recyclable materials

and phasing out landfilling of recyclable or

The main barriers to eco-innovation development and recoverable waste. diffusion in Latvia are related to the small number and SDG 12 invites countries to substantially reduce waste size of companies active in environmental technology generation through prevention, reduction, recycling and fields and the low innovative capacity of companies in reuse, by 2030.

general, especially in the medium and high-tech fields.

In addition, the very limited number of large companies The EU's approach to waste management is based on the that have resources to divert to RDI and new technology "waste hierarchy" which sets out an order of priority adoption, and the low level of early-stage investments when shaping waste policy and managing waste at that are available for green technology development, are the operational level: prevention, (preparing for) reuse, important hampering factors 14 . recycling, recovery and, as the least preferred option,

disposal (which includes landfilling and incineration

NGOs have been active in initiating cultural change and without energy recovery). The progress towards reaching positive influence from forerunner countries on societal recycling targets and the adoption of adequate

and entrepreneurial awareness should not be WMP/WPP 15 should be the key items to measure the

underestimated. While the demand for eco-innovation performance of Member States. This section focuses on

products has been increasing in recent years, price is still management of municipal waste 16 for which EU law sets

a dominant factor in consumer and producer choice, mandatory recycling targets.

which limits incentives for entrepreneurs to engage in

eco-innovative activities. The amount of municipal waste generated in Latvia amounted to 325 kg/y/inhabitant in 2014 (well below the

Latvia does not have a specific green growth policy. But EU average of 475 kg/y/inhabitant).

17

Sustainable Development Strategy of Latvia until 2030 Figure 3 depicts the municipal waste by treatment in has a special chapter on Innovative and eco-efficient Latvia in terms of kg per capita, which shows a decrease economy. Besides, elements of eco-innovations are in in recycling and an increase in landfilling. chapter on Nature as capital for future, where several The main treatment option of municipal waste remains instruments and initiatives are suggested to maintain disposal in landfills. In 2014, Latvia landfilled a big share natural capital, for example, green budget reform, of municipal waste (79% in 2014, a slight drop from 83% market instruments, support to firms and technologies in 2013) against the EU average of 26%. Composting is that are eco-innovative. The Smart Specialisation broadly stable at only 4% in 2014 (EU average 28% in Strategy aims to promote innovation capacity and the 2014).

creation of a system that fosters and technological

progress. Its priorities, amongst others, include support 15 Waste Management Plans/Waste Prevention Programmes

16 Municipal waste consists of waste collected by or on behalf of municipal authorities, or directly by the private sector (business or

14 Brieze, I., 2013, Latvia is the second most green country in Europe. A private non-profit institutions) not on behalf of municipalities. myth or reality? Interview with the manager of the INTERREG project 17 Eurostat, Municipal waste and treatment, by type of treatment Global method, accessed October 2016

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Figure 3: Municipal waste by treatment in Latvia 2007- The national Waste Management Plan 2013-2020 will be

14 18 subject to a midterm review in 2016. The plan also

includes Latvia's Waste Prevention Programme.

Although Latvia has achieved some progress in municipal waste management over the past couple years, significant investments are still required. These include: − putting in place infrastructure to improve separate waste collection and increase waste recycling capacity (packaging and biodegradable waste), − making improvements in market instruments (taxation of polluting products, extended producer responsibility), and − adapting administrative and regulatory measures to facilitate recovery, including composting.

In order to make recycling economically viable, an incineration and MBT tax (mechanical biological treatment), whilst keeping the landfill tax higher than taxes for incineration and MBT, would be effective. In order to help bridging the implementation gap in

Latvia, the Commission has delivered a roadmap 21 for

compliance in which economic instruments play a crucial

As shown in Figure 4, recycling of municipal waste role. Revenues from a landfill tax in conjunction with increased only slightly from 17% in 2013 to 21% in 2014 further refinement of the allocation of the CF (allocations (EU average was 44% in 2014), while composting of should be prioritised to the first steps of the waste municipal waste in Latvia dropped from 6% in 2013 to 4% hierarchy) could contribute to building and operating in 2014 (EU average being 16% in 2014). This means that the infrastructure required to meet EU targets.

Latvia is under an increasing risk of not meeting 50%

recycling target by 2020 19 , and the 2020 landfill diversion Full implementation of the existing legislation could

targets for biodegradable waste (75%). create more than 2.800 jobs in Latvia and increase the

Figure 4: Recycling rate of municipal waste 2007-14 20 annual turnover of the waste sector by over EUR 304 million. Moving towards the targets of the

Roadmap on resource efficiency could create over 3300 additional jobs and increase the annual turnover of the

waste sector by over EUR 350 million. 22

Suggested action

• Introduce and gradually increase landfill taxes to phase-out landfilling of recyclable and recoverable waste. Use the revenues to support the separate collection and alternative infrastructure in conjunction with a better allocation of the cohesion policy funds to the first steps of waste hierarchy. Avoid building excessive infrastructure for the treatment of residual waste.

• Focus on implementation of the effective separate collection scheme to increase recycling rates. Once this is in place consider introducing PAYT (Pay As You Throw) schemes.

18 Eurostat, Municipal waste and treatment, by type of treatment 21 European Commission, Support to Member States in improving method, accessed October 2016 waste management based on assessment of Member States’

19 Member States may choose a different method than the one used by performance. Roadmap for Latvia

ESTAT (and referred to in this report) to calculate their recycling rates 22 Bio Intelligence service, 2011. Implementing EU Waste legislation for and track compliance with the 2020 target of 50% recycling of Green Growth , study for European Commission. The breakdown per municipal waste. country on job creation was made by the consultant on Commission 20 Eurostat, Recycling rate of municipal waste , accessed October 2016 demand but was not included in the published document.

Latvia 9

  • 2. 
    Protecting, conserving and enhancing natural capital

Nature and Biodiversity designated 102 sites covering 6609.6 km

2 , from which 6183.9 correspond to terrestrial sites (97) and 425.7 km 2 The EU Biodiversity Strategy aims to halt the loss of to marine sites.

biodiversity in the EU by 2020, restore ecosystems and

their services in so far as feasible, and step up efforts to The latest assessment

24 of the SCIs part of the Natura

avert global biodiversity loss. The EU Birds and Habitats 2000 network shows that there are insufficiencies in Directives aim at achieving favourable conservation designation (see Figure 5

25 ).

status of protected species and habitats. Figure 5: Sufficiency assessment of SCI networks in

SDG 14 requires countries to conserve and sustainably Latvia based on the situation until December 2013 (%)

26

use the oceans, seas and marine resources, while SDG 15 requires countries to protect, restore and promote the sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and reverse land degradation and halt biodiversity loss.

The 1992 EU Habitats Directive and the 1979 Birds

Directive are the cornerstone of the European legislation aimed at the conservation of the EU's wildlife. Natura

2000, the largest coordinated network of protected areas in the world, is the key instrument to achieve and implement the Directives' objectives to ensure the longterm protection, conservation and survival of Europe's most valuable and threatened species and habitats and the ecosystems they underpin.

The adequate designation of protected sites as Special

Ares of Conservation (SAC) under the Habitats Directive and as Special Protection Areas (SPA) under the Birds

Directive is a key milestone towards meeting the Even though Latvia is progressing towards establishing objectives of the Directives. The results of Habitats comprehensive management plans for its sites (already Directive Article 17 and Birds Directive Article 12 reports completed for about 60 SACs), both the scientific basis and the progress towards adequate Sites of Community over which the network was developed as well as

Importance (SCI)-SPA and SAC designation 23 both in land the actual conservation status 27 of some of the protected

and at sea, should be the key items to measure the species and habitats is currently under review. performance of Member States.

11.53% of the national land area of Latvia is covered by 24 For each Member State, the Commission assesses whether the

Natura 2000 (EU average 18.1%), with Birds Directive species and habitat types on Annexes I and II of the Habitats SPAs covering 10.23% (EU average 12.3%). Latvia has Directive, are sufficiently represented by the sites designated to

designated 332 Special Areas of Conservation (SACs) date. This is expressed as a percentage of species and habitats for which further areas need to be designated in order to complete the

covering an area of 12241,37 km 2 , from which 7877.3 network in that country. The current data , which were assessed in

km 2 correspond to the terrestrial part of the country's 2014-2015, reflect the situation up until December 2013.

share of the Natura 2000 network, and 4364.07 km 2 to 25 The percentages in Figure 5 refer to percentages of the total number marine sites. Regarding Special Protection Areas (SPAs) of assessments (one assessment covering 1 species or 1 habitat in a

for birds designated under the Birds Directive, Latvia has given biographical region with the Member State); if a habitat type or a species occurs in more than 1 Biogeographic region within a given

Member State, there will be as many individual assessments as there are Biogeographic regions with an occurrence of that species or

23 Sites of Community Importance (SCIs) are designated pursuant to habitat in this Member State. the Habitats Directive whereas Special Areas of Protection (SPAs) are 26 European Commission, internal assessment. designated pursuant to the Birds Directive; figures of coverage do 27 Conservation status is assessed using a standard methodology as not add up due to the fact that some SCIs and SPAs overlap. Special being either ‘favourable’, ‘unfavourable-inadequate’ and Areas of Conservation (SACs) means a SCI designated by the Member ‘unfavourable-bad’, based on four parameters as defined in Article 1 States. of the Habitats Directive.

Latvia 10

The acknowledged presence of significant gaps in the Furthermore, 35% are considered to be unfavourable– knowledge base required for a sound science based inadequate (EU27: 47%) and 51% are unfavourable – bad implementation of the Habitats and Birds Directives, (EU27: 30%). As for the species, 28.83% of the starting from the designations carried out in 2004, is a assessments were favourable in 2013, 39% at recognized shortcoming that undermines any attempt of unfavourable-inadequate (EU27: 42%) and 21% a more factual assessment of the actual state of the unfavourable-bad status (EU27: 18%). This is depicted in

species and habitats requiring protection in the Latvian Figure 6 30 .

territory. The Latvian authorities are currently producing

an updated survey of the spatial distribution of habitats Only 2% and 4.5% of the unfavourable assessments and species that should help to clarify the situation and respectively for habitats and species were showing a to overcome current shortages. positive trend in 2013.

From the available information it is evident that those As shown in Figure 7, as far as birds are concerned, 41% assets located in areas shared with agriculture or of the breeding species showed short-term increasing or commercial forestry activities are under most pressure. stable population trends (for wintering species this figure This unfavorable situation is particularly evident in the was 67%).

case of the habitats based on grasslands. The current Figure 7: Short-term population trend of breeding and

provisions for the funding of nature conservation would wintering bird species in Latvia in 2012 (%) 31

need to be adapted so as to make the management of the land for nature conservation objectives economically viable for commercial farmers, or foresters.

Figure 6: Conservation status of habitats and species in

Latvia in 2007/2013 (%) 28

So far, there is no involvement of Latvia in the EU initiative on Mapping and Assessment of Ecosystems and

their Services (MAES). 32 However, several LIFE + projects

for pilot assessment of the ecosystem services can be

noted. 33

Suggested action

• Complete the SAC designation process and put in place clearly defined conservation objectives and the necessary conservation measures for the sites and provide adequate resources for their implementation

According to the latest report on the conservation status of habitats and species covered by the Habitats

Directive 29 , 10.53% of the habitats biogeographic 30 Please note that a direct comparison between 2007 and 2013 data is

assessments were favourable in 2013 (EU 27: 16%). complicated by the fact that Bulgaria and Romania were not covered by the 2007 reporting cycle, that the ‘unknown’ assessments have

strongly diminished particularly for species, and that some reported changes are not genuine as they result from improved data /

28 These figures show the percentage of biogeographical assessments monitoring methods. in each category of conservation status for habitats and species (one 31 Article 12 of the Birds Directive reporting - national summary of assessment covering 1 species or 1 habitat in a given biographical Latvia

region with the Member State), respectively. The information is 32 Ecosystem services are benefits provided by nature such as food, based on Article 17 of the Habitats Directive reporting - national clean water and pollination on which human society depends. summary of Latvia 33 LIFE13 ENV/LV/000839 " Assessment of ecosystems and their

29 Article 17 requires a report to be sent to the European Commission services for nature biodiversity conservation and management "; every 6 years following an agreed format. The core of the ‘Article 17’ LIFE12 BIO/LV/001130 LIFE GRASSSERVICE - Alternative use of report is assessment of conservation status of the habitats and biomass for maintenance of grassland biodiversity and ecosystem species targeted by the Habitats Directive. services

Latvia 11

in order to maintain/restore species and habitats of The operational programme "Growth and Employment"

community interest to a favourable conservation status envisages the green infrastructure solutions as a priority

across their natural range. where they are technically and economically possible and

• Improve the incentives for foresters and farmers to efficient, including eco-system based approaches' for the

better protect forest and grassland habitat. activities reducing flood and erosion risks in affected

• Initiate and provide government support for the work ecosystems - grasslands, wetlands, dunes and forests.

on mapping and assessment of ecosystems and their Priorities for restoration will be set within the framework

services, valuation and development of natural capital of a LIFE+ funded project 36 .

accounting systems. Soil protection

Green Infrastructure The EU Soil Thematic Strategy highlights the need to

The EU strategy on green infrastructure 34 promotes the ensure a sustainable use of soils. This requires the incorporation of green infrastructure into related plans prevention of further soil degradation and the and programmes to help overcome fragmentation of preservation of its functions, as well as the restoration of habitats and preserve or restore ecological connectivity, degraded soils. The 2011 Road Map for Resourceenhance ecosystem resilience and thereby ensure the Efficient Europe, part of Europe 2020 Strategy provides continued provision of ecosystem services. that by 2020, EU policies take into account their direct

Green Infrastructure provides ecological, economic and and indirect impact on land use in the EU and globally, social benefits through natural solutions. It helps to and the rate of land take is on track with an aim to understand the value of the benefits that nature provides achieve no net land take by 2050.

to human society and to mobilise investments to sustain SDG 15 requires countries to combat desertification, and enhance them. restore degraded land and soil, including land affected by

desertification, drought and floods, and strive to achieve Latvia has a relatively high density of natural areas a land-degradation-neutral world by 2030. compared to many other EU Member States.

Nevertheless, further efforts to increase connectivity Soil is an important resource for life and the economy. It

between habitats would be useful 35 . provides key ecosystem services including the provision

of food, fibre and biomass for renewable energy, carbon sequestration, water purification and flood regulation, the provision of raw and building material. Soil is a finite and extremely fragile resource and increasingly degrading in the EU. Land taken by urban development and infrastructure is highly unlikely to be reverted to its natural state; it consumes mostly agricultural land and increases fragmentation of habitats. Soil protection is indirectly addressed in existing EU policies in areas such as agriculture, water, waste, chemicals, and prevention of industrial pollution.

Artificial land cover is used for settlements, production

Challenges relate e.g. to the lack of general strategic systems and infrastructure. It may itself be split between policy framework for Green Infrastructure development; built-up areas (buildings) and non-built-up areas (such as lack of know-how and awareness (especially at linear transport networks and associated areas).

the municipal level) and lack of public participation. The annual land take rate (growth of artificial areas) as

provided by CORINE Land Cover was 0.38% in Latvia over

Nine border municipalities in Latvia and Lithuania are the period 2006-12, below the EU average (0.41%). It cooperating under the motto “Let’s make our cities represented 475 hectares per year and was mainly driven greener” in order to restore urban parks and green by housing, services and recreation as well as industrial infrastructure; improve the wellbeing, awareness and and commercial sites 37 . The percentage of built up land

engagement of citizens to maintain green areas in their neighbourhood; and enable city planners to integrate green infrastructure in urban space.

36 LIFE, NAT-PROGRAMME - National Conservation and Management 34 European Union, Green Infrastructure — Enhancing Europe’s Natural Programme for Natura 2000 Sites in Latvia

Capital, COM/2013/0249 37 European Environment Agency Draft results of CORINE Land Cover

35 Service Contract " Supporting the implementation of Green (CLC) inventory 2012; mean annual land take 2006-12 as a % of 2006

Infrastructure (2015), Green Infrastructure in Latvia Factsheet artificial land.

Latvia 12

in 2009 was 1.11%, well below the EU average (3.23%) 38 . marine waters by 2020 by providing an ecosystem

approach to the management of human activities with

The soil water erosion rate in 2010 was 0.32 tonnes per impact on the marine environment. The Directive

ha per year, well below EU28 average (2.46 tonnes) 39 . requires Member States to develop and implement

Figure 8 shows the different land cover types in Latvia in a marine strategy for their marine waters, and cooperate

2012. with Member States sharing the same marine region or subregion.

Figure 8: Land Cover types in Latvia in 2012 40

As part of their marine strategies, Member States had to make an initial assessment of their marine waters,

determine GES 42 and establish environmental targets by

July 2012. They also had to establish monitoring programmes for the on-going assessment of their marine waters by July 2014. The next element of their marine strategy is to establish a Programme of Measures (2016). The Commission assesses whether these elements constitute an appropriate framework to meet the requirements of the MSFD.

Latvian marine waters are part of the Baltic Sea and Latvia is a party to the Convention on the Protection of the Marine Environment of the Baltic Sea (HELCOM). In the Baltic Sea, main risks for biodiversity relate to eutrophication, overfishing and bycatch, pollution by contaminants and oil and introduction of non-indigenous

species 43 .

In its implementation of the Marine Strategy Framework Directive (MSFD), Latvia did not determine good

environmental status for all the 11 MSFD descriptors. 44

Latvia also reported that the current level of impacts is

There are still no EU-wide datasets enabling the provision 'good' when assessing the state of its marine waters. of benchmark indicators for soil organic matter decline, It however provided no justification for this assessment.

contaminated sites, pressures on soil biology and diffuse

pollution. An updated inventory and assessment of soil It is therefore too early to say whether Latvian waters are protection policy instruments in Latvia and other EU in good status as there were weaknesses in identifying Member States is being performed by the EU Expert what a good environmental status is in the first place.

Group on Soil Protection.

Latvia established a monitoring programme of its marine

Marine protection waters in 2014. However, its monitoring programmes for all descriptors need further refinement and development

The EU Coastal and Marine Policy and legislation require to constitute an appropriate framework to monitor that by 2020 the impact of pressures on marine waters is progress towards achieving Good Environmental Status, reduced to achieve or maintain good environmental especially since gaps are still prevalent and the status and coastal zones are managed sustainably. monitoring programmes will not be in place before 2018

SDG 14 requires countries to conserve and sustainably for most descriptors, when the next assessment of use the oceans, seas and marine resources for marine waters is due

45 .

sustainable development.

The Marine Strategy Framework Directive (MSFD) 41 aims 42 The MSFD defines Good Environmental Status (GES) in Article 3 as:

to achieve Good Environmental Status (GES) of the EU's “The environmental status of marine waters where these provide ecologically diverse and dynamic oceans and seas which are clean,

healthy and productive” 43 European Environment, 2016, The Baltic Sea 38 European Environment Agency, 2016. Imperviousness and 44 Report from the Commission "The first phase of implementation of

imperviousness change the Marine Strategy Framework Directive (2008/56/EC) - The

39 Eurostat, Soil water erosion rate , accessed June 2016 European Commission's assessment and guidance" COM(2014)097

40 European Environment Agency, Land cover 2012 and changes 45 Commission Staff Working Document Accompanying the country analysis [publication forthcoming] Commission Report assessing Member States' monitoring

41 European Union, Marine Strategy Framework Directive 2008/56/EC programmes under the Marine Strategy Framework Directive

Latvia 13

In 2012, Latvian marine protected areas covered

4382,8 square kilometers of its marine waters in the

Baltic Sea 46 .

Suggested action

• Continue work to improve the definitions of GES in particular for biodiversity descriptors, including through regional cooperation by using the work of the relevant Regional Sea Convention.

• Identify and address knowledge gaps.

• Further develop approaches assessing (and quantifying) impacts from the main pressures in order

to lead to improved and more conclusive assessment results for 2018 reporting.

• Continue integrating monitoring programmes already existing under relevant EU legislation and to implement, where they exist, joint monitoring programmes developed at (sub)regional level, for instance by HELCOM.

• Enhance comparability and consistency of monitoring methods within the country's marine region.

• Ensure that its monitoring programme is implemented without delay, addresses all descriptors and is appropriate to monitor progress towards its GES.

(COM(2017)3 i and SWD(2017)1 final)

46 2012 Data provided by the European Environmental Agency to the

European Commission– Not published

Latvia 14

  • 3. 
    Ensuring citizens' health and quality of life

Air quality 2014 for sulphur oxides (-96%), nitrogen oxides (-63%), ammonia (-61%) as well as volatile organic compounds

The EU Clean Air Policy and legislation require that air (-46%) ensure air emissions for these pollutants are quality in the Union is significantly improved, moving within the currently applicable national emission

closer to the WHO recommended levels. Air pollution ceilings 50 .

and its impacts on ecosystems and biodiversity should be

further reduced with the long-term aim of not exceeding Air quality in Latvia is reported to be generally good, with critical loads and levels. This requires strengthening exceptions. Nevertheless, for the year 2013, efforts to reach full compliance with Union air quality the European Environment Agency estimated that about legislation and defining strategic targets and actions 2 080 premature deaths were attributable to fine

beyond 2020. particulate matter 51 concentrations, 60 to ozone

The EU has developed a comprehensive suite of air concentration

52 and over 110 to nitrogen dioxide 53 concentrations 54 . This is due also to exceedances above

quality legislation 48 , which establishes health-based the EU air quality standards such as shown in Figure 9 55 .

standards and objectives for a number of air pollutants.

As part of this, Member States are also required to

Figure 9: Attainment situation for PM10, NO2 and O3 in 2014 47

50 The current national emission ceilings apply since 2010 ( Directive

ensure that up-to-date information on ambient 2001/81/EC ); revised ceilings for 2020 and 2030 have been set by

concentrations of different air pollutants is routinely Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants, amending Directive 2003/35/EC i and

made available to the public. In addition, the National repealing Directive 2001/81/EC i.

Emission Ceilings Directive provides for emission 51 Particulate matter (PM) is a mixture of aerosol particles (solid and

reductions at national level that should be achieved for liquid) covering a wide range of sizes and chemical compositions.

main pollutants. PM10 (PM2.5) refers to particles with a diameter of 10 (2.5) micrometres or less. PM is emitted from many anthropogenic

sources, including combustion.

The emission of several air pollutants has decreased 52 Low level ozone is produced by photochemical action on pollution

significantly in Latvia 49 . Reductions between 1990 and and it is also a greenhouse gas 53 NOx is emitted during fuel combustion e.g. from industrial facilities

and the road transport sector. NOx is a group of gases comprising nitrogen monoxide (NO) and nitrogen dioxide (NO2).

47 European Environment Agency, Attainment situation for PM10, NOx 54 European Environment Agency, 2016. Air Quality in Europe – 2016 and O3 in 2014 [publication forthcoming] Report, (Table 10.2, please see details in this report as regards the

48 European Commission, 2016. Air Quality Standards underpinning methodology)

49 See EIONET Central Data Repository and Air pollutant emissions data 55 Based on European Environment Agency, 2016. Air Quality in Europe viewer (NEC Directive) – 2016 Report . (Figures 4.1, 5.1 and 6.1)

Latvia 15

Until 2013, Latvia reported exceedances of particulate Latvia's implementation of the Environmental Noise

matter (PM10) in one air quality zone (Riga); however, Directive 59 is delayed. The noise mapping for the most

for 2014 compliance has been reported. For 2014, recent reporting round, for the reference year 2011, is exceedances above the EU air quality standards have complete for agglomerations, major airports and major been only been registered related to the long-term roads, but incomplete major railways. Action plans for objectives regarding ozone concentration in two air noise management in the current period have been

quality zones 56 . adopted for agglomerations, major roads and airports,

but not for major railways. The persistent breaches of air quality requirements (for

PM Suggested action 10 ), which have severe negative effects on health and

environment, are being followed up by the European • Complete noise mapping and action plans for noise

Commission through infringement procedures covering management. all the Member States concerned, including Latvia. The

aim is that adequate measures are put in place to bring Water quality and management

all zones into compliance. The EU water policy and legislation require that the

impact of pressures on transitional, coastal and fresh It is estimated that the health-related external costs from waters (including surface and ground waters) is air pollution in Latvia are above EUR 748 million/year significantly reduced to achieve, maintain or enhance (income adjusted, 2010), which include not only good status of water bodies, as defined by the Water the intrinsic value of living a full health life but also direct Framework Directive; that citizens throughout the Union costs to the economy. These direct economic costs relate benefit from high standards for safe drinking and bathing to 325 thousand workdays lost each year due to sickness water; and that the nutrient cycle (nitrogen and related to air pollution, with associated costs for phosphorus) is managed in a more sustainable and employers of EUR 22 million/year (income adjusted, resource-efficient way.

2010), for healthcare of above EUR 2 million/year

(income adjusted, 2010), and for agriculture (crop losses) SDG 6 encourages countries to ensure availability and of EUR 11 million/year (2010) 57 . sustainable management of water and sanitation for all.

The main overall objective of EU water policy and

Suggested action legislation is to ensure access to good quality water in

• Reduce PM sufficient quantity for all Europeans. The EU water 10 emission and concentration, inter alia, by reducing emissions related to energy and heat acquis

60 seeks to ensure good status of all water bodies

generation using solid fuels, to transport and to across Europe by addressing pollution sources (from e.g.

agriculture. agriculture, urban areas and industrial activities), physical and hydrological modifications to water bodies) and the

Noise management of risks of flooding.

The Environmental Noise Directive provides for a River Basin Management Plans (RBMPs) are a common approach for the avoidance, prevention and requirement of the Water Framework Directive and a reduction of harmful effects due to exposure to means of achieving the protection, improvement and environmental noise. sustainable use of the water environment across Europe.

Excessive noise is one of the main causes of health This includes surface freshwaters such as lakes and rivers, issues 58 . To alleviate this, the EU acquis sets out several groundwater, estuaries and coastal waters up to one requirements, including assessing the exposure to nautical mile.

environmental noise through noise mapping, ensuring Latvia has provided information to the Commission from that information on environmental noise and its effects is its second generation of RBMPs. However, as the made available to the public, and adopting action plans Commission has not yet been able to validate this with a view to preventing and reducing environmental information for all Member States, it is not reported

noise where necessary and to preserving the acoustic environment quality where it is good.

59 The Noise Directive requires Member States to prepare and publish, every 5 years, noise maps and noise management action plans for agglomerations with more than 100,000 inhabitants, and for major

56 See The EEA/Eionet Air Quality Portal and the related Central Data roads, railways and airports.

Repository 60 This includes the Bathing Waters Directive (2006/7/EC); the Urban

57These figures are based on the Impact Assessment for the European Waste Water Treatment Directive (91/271/EEC) concerning

Commission Integrated Clean Air Package (2013) discharges of municipal and some industrial waste waters; the

58 WHO/JRC, 2011, Burden of disease from environmental noise, Drinking Water Directive (98/83/EC) concerning potable water

Fritschi, L., Brown, A.L., Kim, R., Schwela, D., Kephalopoulos, S. (eds), quality; the Water Framework Directive (2000/60/EC) concerning World Health Organization, Regional Office for Europe , Copenhagen, water resources management; the Nitrates Directive (91/676/EEC) Denmark and the Floods Directive (2007/60/EC)

Latvia 16

here. a reduction in the number of animals. Following an infringement procedure on the implementation of the

In its first generation of RBMPs Latvia reported 53% of nitrates directive, Latvia has improved its action surface water bodies and almost all groundwater bodies programme measures. classified as having good or high ecological status 61 and all groundwater bodies 62 classified as having good As regards drinking water, Latvia reaches very high groundwater status. compliance rates of 99-100% for microbiological and

chemical parameters, and also shows a 98.7%

The main pressures are point sources from urban (and to compliance rate with indicator parameters laid down in a lesser extent industrial) wastewater, diffuse sources the Drinking Water Directive 64 .

from agriculture and hydromorphological alterations.

As shown in Figure 10, in 2015, in Latvia out of 55 bathing

There are certain deficiencies in RBMPs. In particular waters, 67.3% were of excellent quality, 18.2% of good the methods to assess the status of water bodies are not quality while it was not possible to assess the remaining fully developed. A high number of exemptions were 8 bathing waters as they were just recently identified and applied. The Programmes of Measures are expected to did not have data about 4 last bathing seasons, necessary result in improvement of the ecological and chemical for the assessment 65 . status 63 of natural surface water bodies by 24% and 5%

respectively. The planned measures are expected to Figure 10: Bathing water quality 2012–15

66

result in improvement of ecological potential of artificial and heavily modified water bodies by 17% and chemical status of these bodies by 8%.

With regard to the implementation of the Urban Waste Water Treatment Directive, Latvia reaches overall high compliance rates: 100% of its waste water load is collected, and 98.7% is submitted to secondary

treatment 67 . The final deadline to fully comply with the

Urban Waste Water Treatment Directive (UWWTD) in

As regards water pollution from agricultural sources, Latvia was the end of 2015. All the Latvian territory is nitrate levels have been slightly decreasing in the period considered as sensitive area, meaning that all 2008-2011. However, eutrophication of the Baltic Sea agglomerations whose size is above 10,000 p.e. should be remains an issue. In 2008-2011, a slight expansion of subject to more stringent treatment. Commission's latest the agricultural area took place and mineral fertilizer use report on the implementation of the Urban Waste Water

increased as compared to the period 2004-2007. At the

same time, the pressure from livestock decreased, due to 64 Commission's Synthesis Report on the Quality of Drinking Water in

the Union examining Member States' reports for the 2011-2013 period, foreseen under Article 13(5) of Directive 98/83/EC i;

61 Good ecological status is defined in the Water Framework Directive COM(2016)666 i referring to the quality of the biological community, the hydrological 65 European Environment Agency, 2016. European bathing water characteristics and the chemical characteristics. quality in 2015 , p. 26

62 For groundwater, a precautionary approach has been taken that 66 European Environment Agency, State of bathing water , 2016 comprises a prohibition on direct discharges to groundwater, and a 67 Eighth Report on the Implementation Status and the Programmes requirement to monitor groundwater bodies. for Implementation (as required by Article 17) of Council Directive

63 Good chemical status is defined in the Water Framework Directive 91/271/EEC i concerning Urban Waste Water treatment Directive referring to compliance with all the quality standards established for (COM (2016)105 final) and Commission Staff Working Document chemical substances at European level. accompanying the report (SWD(2016)45 final ).

Latvia 17

Treatment Directive indicates that, in 2012, 0% of the these issues in a comprehensive way, including their waste water load collected was subject to more stringent connections with social and economic challenges. At the treatment in accordance with Article 5 of the WWTD. heart of this Urban Agenda will be the development of However, Latvia has since then explained that this was twelve partnerships on the identified urban challenges,

due to a reporting mistake and only 3 agglomerations including air quality and housing 70 .

remain, overall, non-compliant with the Urban Waste

Water Treatment Directive. Despite these overall good The European Commission will launch a new EU results, it should be noted that 10.9% of the waste water benchmark system in 2017.

71

load in Latvia is addressed via individual or other systems The EU stimulates green cities through awards and whose appropriateness to protect the environment funding, such as the EU Green Capital Award aimed at might be questionable. cities with more than 100,000 inhabitants and the

Finally, it is necessary to improve the situation of the EU Green Leaf initiative aimed at cities and towns, with physical connections to the waste water collection between 20,000 and 100,000 inhabitants.

systems.

The estimated investment needs (reported by Latvia under Article 17 of the Urban Waste Water Treatment

Directive) to reach full compliance with the Directive are

of EUR 107 million 68 .

Suggested action

• The RBMP of Measures should address all relevant pressures and implementation gaps in particular measures addressing agricultural pollution.

• Review and improve its measures to reduce the hydromorphological pressure in its river basins.

• Measures to rationalise water and wastewater management structures and services could also be considered together with incentives for increasing the

level of physical connections to the networks. A number of initiatives are covered under the Union of

the Baltic Cities Sustainable Cities Commission, which is a

Enhancing the sustainability of cities voluntary network of its member cities of the Baltic Sea

The EU Policy on the urban environment encourages Region addressing a number of issues, including cities to implement policies for sustainable urban environmentally sustainable development. This includes planning and design, including innovative approaches for such initiatives as integrated management systems and urban public transport and mobility, sustainable spatial management, urban water management, buildings, energy efficiency and urban biodiversity maritime activities and sustainable urban mobility.

conservation. For example, the project PRESTO, which is aimed at improving quality of local waters and the Baltic Sea by

SDG11 aims at making cities and human settlements reducing nutrient load. inclusive, safe, resilient and sustainable.

Europe is a Union of cities and towns; around 75% of the Under the project PURE, aimed at promote advanced

EU population are living in urban areas. 69 The urban phosphorus removal and sustainable sludge management environment poses particular challenges for the in the Baltic Sea region, phosphorus removal equipment environment and human health, whilst also providing was installed in Riga and Jūrmala waste water treatment opportunities and efficiency gains in the use of resources. plants.

The Member States, European institutions, cities and Furthermore, Riga City Council is amongst the partners of stakeholders have prepared a new Urban Agenda for the the Baltic Urban Lab project, which aims at identifying EU (incorporating the Smart Cities initiative) to tackle and promoting best practices on brown field

68 Latvia reports that according to a survey carried out by MoERDF in 70 http://urbanagendaforthe.eu/

2014, the investment needs for the development of waste water 71 The Commission is developing an Urban Benchmarking and systems incl. waste water treatment plants, extension and Monitoring ('UBaM') tool to be launched in 2017. Best practices renovation of waste water pipelines in agglomerations whose size is emerge and these will be better disseminated via the app featuring above 2,000 p.e. amounts to 445 million EUR the UBaM tool, and increasingly via e.g. EUROCITIES, ICLEI, CEMR,

69 European Environment Agency, Urban environment Committee of the Regions, Covenant of Mayors and others.

Latvia 18

regeneration. signed but not yet ratified the International Convention

for the Regulation of Whaling and the Nagoya Protocol 74 . Under the Covenant of Mayors for Climate and Energy 72

20 Latvian cities have set GHG reduction targets for a period until 2020. Valka has also committed to develop municipality wide adaptation strategy and action plan.

Riga City has implemented a flood management project

"Hydro Climate Strategy Riga" 73 that produced maps,

models and guidance to help Riga City Council plan measures for safeguarding the Latvian capital against the increased risk of flooding predicted by climate change scenarios.

15 municipalities have published their climate related actions in the UNFCCC Non-state Actor Zone for Climate

Action (NAZCA), emphasizing their commitment and climate friendly forward-looking development.

The OP Growth and Employment will provide ESIF support the for revitalisation measures in the city of Riga and for environmentally friendly public transport measures in other major Latvian cities.

International agreements

The EU Treaties require that the Union policy on the environment promotes measures at the international level to deal with regional or worldwide environmental problems.

Most environmental problems have a transboundary nature and often a global scope and they can only be addressed effectively through international co-operation.

International environmental agreements concluded by the Union are binding upon the institutions of the Union and on its Member States. This requires the EU and the

Member States to sign, ratify and effectively implement all relevant multilateral environmental agreements

(MEAs) in a timely manner. This will also be an important contribution towards the achievement of the SDGs, which Member States committed to in 2015 and include many commitments contained already in legally binding agreements.

The fact that some Member States did not sign and/or ratify a number of MEAs compromises environmental implementation, including within the Union, as well as the Union’s credibility in related negotiations and international meetings where supporting the participation of third countries to such agreements is an established EU policy objective. In agreements where voting takes place it has a direct impact on the number of votes to be cast by the EU.

Latvia has signed and ratified almost all MEAs. It has

74 Protocol on Access to Genetic Resources and the Fair and Equitable 72 Covenant of Mayors for Climate and Energy Sharing of Benefits Arising from their Utilization to the Convention on 73 Hydro Climate Strategy Riga Biological Diversity.

Latvia 19

Part II: Enabling Framework: Implementation Tools

  • 4. 
    Market based instruments and investment

Green taxation and environmentally harmful good practice scenario

78 , these taxes could generate an

additional EUR 0.22 billion by 2018, rising to EUR 0.43

subsidies billion by 2030 (both in real 2015 terms). This is

The Circular Economy Action Plan encourages the use of equivalent to an increase by 0.79% and 1.05% of GDP in financial incentives and economic instruments, such as 2018 and 2030, respectively.

taxation to ensure that product prices better reflect Figure 11: Environmental tax revenues as a share of environmental costs. The phasing out of environmentally total revenues from taxes and social contributions harmful subsidies is monitored in the context of the (excluding imputed social contributions) in 2014 79

European Semester and in national reform programmes submitted by Member States.

Taxing pollution and resource use can generate increased revenue and bring important social and environmental benefits.

Environmental taxation has been strengthened but there is further scope for a growth-friendly tax shift.

In 2014, the ratio of tax revenues to GDP in Latvia slightly

exceeded the EU average (2.67% vs 2.46% of GDP) 75 . In

the same year environmental tax revenues accounted for

9.26% of total revenues from taxes and social-security contributions (EU28 average: 6.35%) as shown in Figure

  • 11. 
    Most of the revenue of environmental taxes still comes from energy taxes (74% of environmental taxes in

2014), while the share of transport was 18% of total environmental taxes in 2014. Pollution/resource and transport taxes (excluding transport fuels) have produced smallest revenue streams – 4%. Additional revenue from environment related taxes could therefore alleviate budgetary pressures and provide the necessary source

for funding contributing to the green economy. 76

Further increasing taxes on the use of natural resources and decrease of environmentally harmful subsidies

would contribute to achieving environmental goals; In Latvia, the Natural resource tax since its introduction improve resource and energy efficiency that would lead in 2006 has increased from 0.6 EUR per CO2 tonne to to higher levels of output and employment at the same 3.50 EUR per CO2 tonne in 2015. Possibilities of the time providing room for a shift away from taxation of increase of the Natural resources tax (NRT) rate per labour. tonne of CO2 are being evaluated and to promote

implementation of greenhouse gas emission reduction

A 2016 study shows there is considerable potential for

shifting taxes from labour to environment 77 . Under a suggesting concrete changes as to the level of environmental

taxation. It merely presents the findings of the 2016 study by Eunomia et al on the potential benefits various environmental taxes

75 Eurostat, Environmental tax revenues , accessed June 2016 could bring. It is then for the national authorities to assess this study

76 Taxation trends in the EU (Eurostat, 2014); Tax Reforms in EU and their concrete impacts in the national context. A first step in this

Member States 2014 (TAXUD) respect, already done by a number of Member States, is to set up

77 Eunomia Research and Consulting, IEEP, Aarhus University, ENT, expert groups to assess these and make specific proposals.

2016. Study on Assessing the Environmental Fiscal Reform Potential 78 The good practice scenario means benchmarking to a successful

for the EU28. N.B. National governments are responsible for setting taxation practice in another Member State. tax rates within the EU Single Market rules and this report is not 79 Eurostat, Environmental tax revenues , accessed October 2016

Latvia 20

measures further raise of the CO2 rates is feasible in the to ensure that procurement planned from the state and near future. However, it is to be done in the context of local government budgets to which GP applies in financial the processes taking place in the EU allowances market. terms reaches at least 15% of the total volume of NRT for waste landfill has increased from 1.07 EUR per procurement made by state and local government tonne in 2002 to 12.00 EUR per tonne in 2014. Since the institutions starting from 2015, 20% in 2016, and 30% in NRT rate has not been effective enough for diverting 2017, and that GP and “Green Procurement support plan waste from landfill to recycling, Latvia has plans for 2015-2017” requirements are applied and integrated in further increase in NRT rate for waste landfill. the implementation process of the EU Structural Funds

and of the Cohesion Fund. 85

Green Public Procurement

The EU green public procurement policies encourage There is no data available as regards the uptake of GPP.

Member States to take further steps to reach the target

of applying green procurement criteria to at least 50% of Investments: the contribution of EU funds

public tenders. European Structural and Investment Funds Regulations

Green Public Procurement (GPP) is a process whereby provide that Member States promote environment and public authorities seek to procure goods, services and climate objectives in their funding strategies and works with a reduced environmental impact throughout programmes for economic, social and territorial their life-cycle when compared to goods, services and cohesion, rural development and maritime policy, and works with the same primary function that would reinforce the capacity of implementing bodies to deliver otherwise be procured. cost-effective and sustainable investments in these areas.

The purchasing power of public procurement in the EU Making good use of the European Structural and

equals to approximately 14% of GDP 80 . A substantial part Investment Funds (ESIF) 86 is essential to achieve the

of this money is spent on sectors with high environmental goals and integrate these into other policy environmental impact such as construction or transport, areas. Other instruments such as the Horizon 2020, the

so GPP can help to significantly lower the impact of LIFE programme and the EFSI 87 may also support public spending and foster sustainable innovative implementation and spread of best practice.

businesses. The Commission has proposed EU GPP

criteria 81 . Latvia, through 3 national programmes, benefits the ESIF

funding of EUR 5.6 billion over the period 2014-2020 88 .

In Latvia, a national strategy on Green Public

Procurement (GPP) is included in the “Green The biggest share – EUR 2.4 billion (42.6%) of funding is

Procurement support plan for 2015 – 2017” 82 , which was coming from the European Fund for Regional

elaborated by the Ministry of Environmental Protection Development (ERDF).

and Regional Development in cooperation with

stakeholders. The plan has been approved by the Cabinet EUR 1.3 billion (24%) - from the Cohesion Fund (CF). of Ministers on 17th of February 2015. 83

EUR 1.1 billion (19.1%) – from the European Agricultural

GPP criteria have been developed at the national level Fund for Rural Development (EAFRD).

through this plan for 21 products. In addition to the

product groups, the GPP Support Plan for 2015-2017 EUR 639 million (11.3%) - from the European Social Fund defines the GPP targets of 15% for 2015, 20% for 2016, (ESF).

and 30% for 2017 to be met each year for national and

local authorities. 84 EUR 140 million (2.5%) from the European Maritime and

Fisheries Fund (EMFF) in intensification of aquaculture

Green procurement support plan 2015-2017 is intended (43% of pond fish farming activities located in Natura

2000 areas).

80 European Commission, 2015. Public procurement

81 In the Communication “Public procurement for a better 85 European Commission, 2015. Documentation on National GPP environment (COM /2008/400) the Commission recommended the Action Plans

creation of a process for setting common GPP criteria. The basic 86 ESIF comprises five funds – the European Regional Development

concept of GPP relies on having clear, verifiable, justifiable and Funds (ERDF), the Cohesion Fund (CF), the European Social Fund

ambitious environmental criteria for products and services, based on (ESF), the European Agricultural Fund for Rural Development

a life-cycle approach and scientific evidence base. (EAFRD), and the European Maritime and Fisheries Fund (EMFF). The

82 Green Procurement support plan for 2015 – 2017 ERDF, the CF and the ESF together form the Cohesion Policy funds.

83 European Commission, 2015. Documentation on National GPP 87 European Investment Bank, 2016 European Fund for Strategic

Action Plans Investments

84PwC, 2015. Final report Strategic use of public procurement in 88 European Commission: European Structural and Investment Funds

promoting green, social and innovative policies Country Data for Latvia

Latvia 21

In total, EUR 783 million are dedicated to the Thematic total EAFRD (and does not need to present its link to objective (TO)6 Environment Protection and Resource biodiversity conservation). Around 1.5% is allocated to efficiency, EUR 368 though the ERDF, EUR 190 million measure on compensation of the restrictions posed by through the CF, EUR 202 million through the EAFRD Natura 2000. programme, EUR 190 million through the CF, EUR 24.4 million through the EMFF. In addition, EUR 520 million is In the currently proposed modification the sub-measure foreseen for TO4 Low Carbon Economy (ERDF, CF and on high-nature value grassland plans to incorporate some EAFRD) and EUR 268 million for TO5 Climate Change elements from the successful LIFE project, which is Adoption and Risk Prevention (EAFRD and ERDF) (see appreciated.

Figure 12).

Figure 12: European Structural and Investment Funds With regard to the integration of environmental concerns

2014-2020: Budget Latvia by theme, EUR billion 89 into the Common Agricultural Policy (CAP), the two key areas for Latvia (as for all Member States) are, first, using

Rural Development funds to pay for environmental land management and other environmental measures, while avoiding financing measures which could damage the environment; and secondly, ensuring an effective implementation of the first pillar of the CAP with regard to cross compliance and 1st pillar 'greening'. 30% of direct payment envelope (out of total EUR 1.45 billion for

2015-2020 90 ) is allocated to greening practices beneficial

for the environment. An environmentally ambitious implementation of 1st pillar greening would clearly help to improve the environmental situation in areas not covered by rural development, including intensive areas, and if appropriate Latvia could review its implementation of the sectorial policy.

It is too early to draw conclusions as regards the use and results of ESIF funds for the period 2014-2020, as the relevant operational programmes are still in an early stage of their implementation.

Current data suggest that the EU funds for the 2007-2013 period were almost fully spent.

The National Rural Development Program (RDP) of Latvia, its EARDF part, amounts to around EUR 1.1 billion (after

the 1 st modification).

Budget for agri-environmental-climate measure represents 7.05% of the total EAFRD budget.

The measure on natural constraints takes up 18.9% of the

89 European Commission, European Structural and Investment Funds

Data By Country 90 Commission delegated regulation (EU) 2015/851)

Latvia 22

  • 5. 
    Effective governance and knowledge

SDG 16 aims at providing access to justice and building

effective, accountable and inclusive institutions at all Capacity to implement rules

levels. SDG 17 aims at better implementation, improving In the Programming Period 2014-2020 an investment of policy coordination and policy coherence, stimulating EUR 18 million is foreseen in promoting Latvian science, technology and innovation, establishing institutional capacity of public institutions and partnerships and developing measurements of progress. stakeholders and an efficient public administration,

Effective governance of EU environmental legislation and particularly, in professional development of public policies requires having an appropriate institutional administration for development of better legal regulation framework, policy coherence and coordination, applying in the fields of support to small and medium-sized legal and non-legal instruments, engaging with nonenterprises, anti-corruption and mitigation of the shadow governmental stakeholders, and having adequate levels economy, as well as in improving the competence of of knowledge and skills 91 . Successful implementation the staff of courts and law enforcement authorities depends, to a large extent, on central, regional and local promote improvement of business environment.

92

government fulfilling key legislative and administrative In 2011, as part of a reform programme put in place to tasks, notably adoption of sound implementing recover from the financial crisis the Latvian Ministry of legislation, co-ordinated action to meet environmental the Environment merged with the Ministry of Regional objectives and correct decision-making on matters such Development and Local Government. This merger also as industrial permits. Beyond fulfilment of these tasks, resulted in financial cuts (at around 19%). It is essential government must intervene to ensure day-to-day that sufficient capacity and funds for the successful compliance by economic operators, utilities and implementation of environmental legislation as well as individuals ("compliance assurance"). Civil society also the achievement of environmental objectives are has a role to play, including through legal action. To retained. underpin the roles of all actors, it is crucial to collect and

share knowledge and evidence on the state of the Latvia aims to transpose new directives into the national environment and on environmental pressures, drivers legislation respecting the established timelines and the

and impacts. number of non-communication cases opened for noncommunication of national legislation transposing new

Equally, effective governance of EU environmental directives are low.

legislation and policies benefits from a dialogue within

Member States and between Member States and the Latvia has a low number of complaints. Cases often focus

Commission on whether the current EU environmental on transposition of EU law into national law and these legislation is fit for purpose. Legislation can only be are resolved quickly.

properly implemented when it takes into account experiences at Member State level with putting EU commitments into effect. The Make it Work initiative, a

Member State driven project, established in 2014, organizes a discussion on how the clarity, coherence and structure of EU environmental legislation can be improved without lowering existing protection standards.

Effective governance within central, regional and local government

Those involved in implementing environment legislation at Union, national, regional and local levels need to be equipped with the knowledge, tools and capacity to improve the delivery of benefits from that legislation,

and the governance of the enforcement process. Coordination and integration In 2010 Latvia adopted its Sustainable Development

91 The Commission has work ongoing to improve the country-specific knowledge about quality and functioning of the administrative 92 Latvian Operational Programme " Operational programme systems of Member States. “Growth and Employment” for 2014-2020

Latvia 23

Strategy until 2030 93 . (e.g. withdrawal of a permit), use of criminal law 95 and

Implementation is carried out by subordinate action under liability law (e.g. required remediation after administrations and agencies, among those State damage from an accident using liability rules) and Environment Service (compliance enforcement, contractual law (e.g. measures to require compliance licensing), Nature Conservation Agency (competent with nature conservation contracts). Taken together, all nature conservation authority), Latvian Environmental, of these interventions represent "compliance assurance" Geological and Meteorological Agency (management of as shown in Figure 13.

databases, environmental monitoring), Environment Best practice has moved towards a risk-based approach

State Bureau (impact assessment, EMAS, licensing) and at strategic and operational levels in which the best mix the Latvian Institute of Aquatic Ecology (monitoring of of compliance monitoring, promotion and enforcement is aquatic ecology), State Regional Development Agency directed at the most serious problems. Best practice also (structural funds). The 2009 public sector structural recognises the need for coordination and cooperation reforms had a considerable impact on the environmental between different authorities to ensure consistency, authorities. In comparison to 2007, they operate with avoid duplication of work and reduce administrative significant staff and financial cuts that inevitably have burden. Active participation in established pan-European implications on their monitoring, implementation and networks of inspectors, police, prosecutors and judges,

enforcement capacities. such as IMPEL 96 , EUFJE 97 , ENPE 98 and EnviCrimeNet 99 , is a

The Commission encourages the streamlining of the valuable tool for sharing experience and good practices.

environmental assessments to avoid overlaps in Figure 13: Environmental compliance assurance environmental assessments and accelerate decisionmaking, without compromising the quality of the environmental assessment procedure. The Commission

has issued a guidance document in 2016 94 regarding the

setting up of coordinated and/or joint procedures that are simultaneously subject to assessments under the EIA

Directive, Habitats Directive, Water Framework Directive, and the Industrial Emissions Directive.

Compliance assurance

EU law generally and specific provisions on inspections, other checks, penalties and environmental liability help lay the basis for the systems Member States need to have in place to secure compliance with EU

environmental rules. Currently, there exist a number of sectoral obligations on

Public authorities help ensure accountability of dutyinspections and the EU directive on environmental holders by monitoring and promoting compliance and by liability (ELD)

  100 provides a means of ensuring that the

taking credible follow-up action (i.e. enforcement) when "polluter-pays principle" is applied when there are breaches occur or liabilities arise. Compliance monitoring accidents and incidents that harm the environment. can be done both on the initiative of authorities There is also publically available information giving themselves and in response to citizen complaints. It can insights into existing strengths and weaknesses in each involve using various kinds of checks, including Member State. inspections for permitted activities, surveillance for For each Member State, the following were therefore possible illegal activities, investigations for crimes and reviewed: use of risk-based compliance assurance; audits for systemic weaknesses. Similarly, there is a range coordination and co-operation between authorities and of means to promote compliance, including awarenessparticipation in pan-European networks; and key aspects raising campaigns and use of guidance documents and of implementation of the ELD based on the Commission's

online information tools. Follow-up to breaches and liabilities can include administrative action

95Directive 2008/99/EC i of The European Parliament and of the Council of 19 November 2008 on the protection of the environment through criminal law.

93 Sustainable Development Strategy for Latvia until 2030 96 European Union Network for the Implementation and Enforcement

94 European Commission, 2016. Commission notice — Commission of Environmental Law guidance document on streamlining environmental assessments 97 European Union Forum of judges for the environment conducted under Article 2(3) of the Environmental Impact 98 The European Network of Prosecutors for the Environment Assessment Directive (D irective 2011/92/EU of the European 99 EnviCrimeNet

Parliament and of the Council, as amended by Directive 2014/52 i/EU). 100 European Union, Environmental Liability Directive 2004/35/CE

Latvia 24

recently published implementation report and REFIT • Improve transparency on organisation and functioning

evaluation 101 . of compliance assurance system and on how significant

risks are addressed, as outlined above.

Latvia has developed some risk assessment tools for • Encourage greater participation of competent inspections of industrial installations. Challenges have authorities in the activities of ENPE, EUFJE and included budget constraints that have led to a decrease EnviCrimeNet.

in the staff of inspection authorities by about 40% 102 . • Step up efforts in the implementation of the

Environmental Liability Directive (ELD) with proactive

Up-to-date information is lacking in relation to the initiatives, in particular by drafting national guidance. following: It should moreover take further steps to ensure an

− data-collection arrangements to track the use and effective system of financial security for environmental effectiveness of different compliance assurance liabilities (so that operators not only have insurance interventions 103 ; cover available to them but actually take it up).

− the extent to which risk-based methods are used to Public participation and access to justice

direct compliance assurance at the strategic level

and in relation to critical activities outside of The Aarhus Convention, related EU legislation on public

industrial installations 104 , participation and environmental impact assessment, and

− how the Latvian authorities ensure a targeted and the case-law of the Court of Justice require that citizens

proportionate response to different types of nonand their associations should be able to participate in

compliant behaviour 105 . decision-making on projects and plans and should enjoy

effective environmental access to justice. In 2011, Latvia hosted an IMPEL IRI but is otherwise not

very active within IMPEL and the other EU level Citizens can more effectively protect the environment if environmental enforcement networks. they can rely on the three "pillars" of the Convention on

Access to Information, Public Participation in Decision

For the period between 2007 and 2013, Latvia reported making and Access to Justice in Environmental Matters thirteen confirmed and three pending instances of ("the Aarhus Convention"). Public participation in environmental damage which were treated under the the administrative decision making process is an Environmental Liability Directive. Evidence points to good important element to ensure that the authority takes its cooperation between the competent authorities and decision on the best possible basis. The Commission stakeholders and NGOs. Latvia has not established intends to examine compliance with mandatory public mandatory financial security (to pay for remediation participation requirements more systematically at a later costs if an operator cannot) and does not intend to do so. stage.

However, it is not evident that the market is offering such Access to justice in environmental matters is a set of security or that there is any take-up. guarantees that allows citizens and their associations to

challenge acts or omissions of the public administration

Suggested action before a court. It is a tool for decentralised

implementation of EU environmental law.

For each Member State, two crucial elements for

101 COM(2016)204 final and COM(2016)121 final of 14.4.2016. This

highlighted the need for better evidence on how the directive is used effective access to justice have been systematically

in practice; for tools to support its implementation, such as guidance, reviewed: the legal standing for the public, including

training and ELD registers; and for financial security to be available in NGOs and the extent to which prohibitive costs represent case events or incidents generate remediation costs. a barrier.

102 Impact Assessment study into possible options for revising

recommendation 2001/331/EC providing for minimum criteria for Latvia grants the public, notably individuals and NGOs, a

environmental inspections (RMCEI), p. 48; IMPEL IRI Latvia, p. 32 and

  • 47. 
    very broad access to justice in environmental cases (actio

103 The Latvian State Environmental Service publishes online monthly popularis). The costs for bringing a case to a court are

reports with some basic statistical data on industrial inspections. also not considered as being prohibitively high.

These include data on numbers of inspections carried-out per region, This guarantees that members of the public are provided

per inspector and per category of installation. See IMPEL IRI Latvia, p. with good conditions for asking for a judicial review in

38-39.

104 According to the IMPEL IRI, the risk-based approach and related environmental matters. However, the court procedures,

data collection for industrial installations do not seem to be applied including environmental cases, in Latvia are rather to the same extent for inspections in other environmental policy long 106 .

areas, see p. 27-29 and 44

105 A national inspector's manual and some guidance are in place which however do not cover important compliance assurance elements, such as for instance criteria for determination of sanctions 106 European Commission, 2012/2013 access to justice in level, see IMPEL IRI Latvia, p. 31-33. environmental matters

Latvia 25

Access to information, knowledge and without procedural obstacles are available and

evidence implemented. Data-sharing in Latvia is implemented through global or bilateral cooperation agreements

The Aarhus Convention and related EU legislation on between public authorities. The cooperation model in access to information and the sharing of spatial data place is not specific to spatial information, but is used for require that the public has access to clear information on all kind of information. The licences used for spatial the environment, including on how Union environmental information are standardized.

law is being implemented.

It is of crucial importance to public authorities, the public Assessments of monitoring reports

113 issued by Latvia

and business that environmental information is shared in and the spatial information that Latvia has published on an efficient and effective way. This covers reporting by the INSPIRE geoportal

114 indicate that not all spatial

businesses and public authorities and active information needed for the evaluation and dissemination to the public, increasingly through implementation of EU environmental law has been made

electronic means. available or is accessible. The larger part of this missing spatial information consists of the environmental data

The Aarhus Convention 107 , the Access to Environmental required to be made available under the existing

Information Directive 108 and the INSPIRE Directive 109 reporting and monitoring regulations of EU

together create a legal foundation for the sharing of environmental law.

environmental information between public authorities

and with the public. They also represent the green part of Suggested action the ongoing EU e-Government Action Plan 110 . The first

two instruments create obligations to provide • Identify and document all spatial data sets required for information to the public, both on request and actively. the implementation of environmental law, and make The INSPIRE Directive is a pioneering instrument for the data and documentation at least accessible 'as is' electronic data-sharing between public authorities who to other public authorities and the public through the can vary in their data-sharing policies, e.g. on whether digital services foreseen in the INSPIRE Directive.

access to data is for free. The INSPIRE Directive sets up a geoportal which indicates the level of shared spatial data in each Member State – i.e. data related to specific locations, such as air quality monitoring data. Amongst other benefits it facilitates the public authorities' reporting obligations.

For each Member State, the accessibility of environmental data (based on what the INSPIRE Directive envisages) as well as data-sharing policies ('open data')

have been systematically reviewed 111 .

Latvia's performance on the implementation of the

INSPIRE Directive as enabling framework to actively disseminate environmental information to the public leaves room for improvement. Latvia has indicated in

the 3-yearly INSPIRE implementation report 112 that

the necessary data-sharing policies allowing access and use of spatial data by national administrations, other

Member States' administrations and EU institutions

107 UNECE, 1998. Convention on Access to Information, Public

Participation in Decision-Making and Access to Justice in Environmental Matters

108 European Union, Directive 2003/4/EC on public access to environmental information

109 European Union, INSPIRE Directive 2007/2/EC

110 European Union, EU eGovernment Action Plan 2016-2020 -

Accelerating the digital transformation of government COM(2016) 179 final

111 Upon request by the Commission, most Member States provided an INSPIRE Action Plan addressing implementation issues. These plans are currently being assessed by the Commission. 113 Inspire indicator trends

112 European Commission, INSPIRE reports 114 Inspire Resources Summary Report


3.

Behandeld document

6 feb
'17
MEDEDELING VAN DE COMMISSIE AAN HET EUROPEES PARLEMENT, DE RAAD, HET EUROPEES ECONOMISCH EN SOCIAAL COMITÉ EN HET COMITÉ VAN DE REGIO'S EU-evaluatie van de tenuitvoerlegging van het milieubeleid: Gemeenschappelijke uitdagingen en hoe inspanningen te bundelen om betere resultaten te realiseren
COVER NOTE
Secretary-General of the European Commission
5967/17
 
 
 
 

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