by Flore Perroquin
Bachelor of Arts of Politics and International Studies, University of Warwick (UK). She performed her summer internship at the CSDS

By asserting that “climate change has direct and indirect implications for international security and stability”[1], the European Union (EU) recognizes climate change as a security challenge which should thus be commonly tackled. The EU promotes and implements policies to counter the effects both on national and EU soils. According to the EU law, the EU lets its Member States choose and implement their own policies regarding environment and energy. Yet, a common policy should be enforced to counter the climate change effects on the environment and the people and deliver meaningful results on the long run. In that view, tackling climate change can become a challenge for the EU as each state must create its own regulation according to the EU policies while considering their national issues.

This essay shall assess how the EU is prepared to tackle climate change as a security issue. It shall proceed as follow. The first section will focus on the EU’s three priority areas and what policies it recommends. This is important because it shows how the EU wants to tackle climate change and how these priority areas represent a security concern for the EU, the Member States and the citizens. The second section will examine how the Member States implement the EU recommendations and how the EU assist them, which helps understand how the EU support and implement its Member States. The third section closely examines the EU’s areas of improvement. Finally, the last section will summarize the key argument and findings of the essay and will discuss how the central argument – how the EU is prepared to tackle climate change as a security challenge – is important for broader debates in the study of EU policy-making regarding climate change.

 

The EU’s three priority areas: Renewables, greenhouse gas emissions and energy efficiency

To tackle climate change, the EU has defined three main priority areas which are promoting and using renewables, reducing greenhouse gas (GHG) emissions and enhancing EU energy efficiency. By dealing with these three main issues, the EU aims at preserving the life of its citizens from the consequences of climate change. The main goal is the “maintenance of stable climatic conditions”[2] which explains why the EU prioritizes these three areas. To undertake this challenge, the EU has recommended policies for each of these three issues through common regulations and directives so each of the Members can implement these recommendations according to their own national legislation. The EU relies on “fairness, cost-effectiveness and environmental integrity”[3] to carry out a sustainable transition towards a greener Europe and to preserve its security from climate change-related risks.

One of the main challenges is the development of renewables which “enhances the energy security and environmental protection”[4] of the Union. On one hand, energy security is crucial for the security of European citizens and the functioning of the Member States, as renewables reduce importations and assure supply stability while strengthening energy independence of the EU[5]. On the other, renewables “provide an exceptional opportunity for mitigation of greenhouse gas emission and reducing global warming”[6]. To carry out this transition, the EU proposed in 2018 an upgraded Renewable Energy Directive which targets that 32% of renewable energy must be part of EU gross final energy consumption by 2030. Renewables play a key role in the EU’s energy security as the energy importation of the Union will fall from 55% in 2019 to 20% in 2050. To meet this threshold, the EU and the Members States share “statistical transfers, joint projects and joint support schemes”[7] which allow surplus transfers between Members to meet the common target by 2020. These actions have shown that the EU is currently on track to meet the 2020 renewables target. Yet, eleven Members’ policies seem insufficient to meet their 2020 threshold. The Commission has thus assessed each national contributions and issue recommendations to meet the common goal and sustain it during the next decade. The EU encourages its members to step up their efforts while reducing their energy consumption. It also facilitates surplus transfers between states through the reduction of administrative procedures[8][9], fosters the cooperation between states and the major actors of the industrial sector through strategies such as the Clean Energy Industrial Forum or the Renewables or the Strategic Energy Technology (SET) Plan which intend at coordinating research and development between Members, companies, research institutions and the EU[10]. As renewables “reduce greenhouse gases which mitigates climate change, reduce environmental and health complications”[11], the EU through its policies, sees this technology as one of the best ways to tackle climate change and preserve its environmental security.

In line with renewables policy, the EU sees GHG emissions as a serious threat to its citizens and its environment and one of the causes of climate change[12]. In that view, the Parliament adopted in 2018 the Effort-Sharing Regulation (ESR) regarding GHG emissions which aims at reducing EU emissions by least 40 % by 2030 and to a net-zero GHG emission economy in 2050. If this legislation has been adopted, it is up to the Member States to implement national policies to meet this threshold. The EU wants each Member States to reach this progressive reduction between 2021 and 2030 and acknowledges each “Member States’ ability to take action […] and set differentiated national targets”[13] according to its principle of fairness and cost-effectiveness. Indeed, the ESD bases national targets on Gross Domestic Product (GDP) per capita by taking into consideration each Member’s ability. It also formulates national energy and climate plans including their approach to reach their national goals and what policies they will implement. The Union views technological innovations in energy, transport or industry as the key motor of the transition and stresses that cooperation between states is crucial to “maximise synergies by pooling resources and knowledge together”[14]. The EU points out that the different options towards a low carbon economy are emerging or already exist, which will ensure that this transition is attainable by 2050 and will limit GHG emissions for the second part of the century.

Finally, the new Energy Efficiency Directive (EED) adopted in December 2018 updates the energy policy framework in view of the 2030 target which sets an energy efficiency at 32.5% across the EU. This transition will “increase the security of energy supply and improve the overall resilience of the EU’s energy system”[15]. If the EU maintains “a regular energy dialogue”[16] with its partners, it remains vital to have an effective energy security both for security and environmental reasons. Yet, in September 2018, Member States recognised that the EU was not on track for achieving the 2020 objectives for energy efficiency. The EU has thus asked for additional measures and efforts from all Member States while the Commission has fostered information sharing, awareness-raising and supporting and monitoring national policies every two years [17]. This new form of monitoring has produced the Member States’ Task Force which focuses on “better understanding the causes behind the increased consumption trends and identify concrete solutions and responses to address the challenge”[18] through the analysis of the causes of the Members that are not on track for the 2020 target and the proposition of new national actions. It also aims to revaluate the different measure taken by the Commission to support the Members[19]. The EU will also increase its liaison between the Members States and stakeholders to provide the necessary support[20]. The EU reminds the importance of “cross-border interconnections, and common arrangements” between Member States to increase “the security of energy supply and improved the overall resilience of the EU’s energy system to external energy shocks”[21].

 

 

 

EU’s policies recommendation

To implement its policies, the EU has developed different tools to support, monitor and review Member States’ actions and application of its legislations. The aim if for each Member States to achieve its own objective through “a structured, iterative process” and a “system of regional consultations and Commission recommendations” while “ensur[ing] better synergies between national efforts”[22]. The Effort Sharing Directive (ESD), for example, trough differentiated energy targets according to the Member’s capacity to achieve it, promotes burden-sharing to ensure cooperation between states[23]. The ESD implementation has proven its usefulness as all Members States have complied with the EU target in 2013-2015 and have become more aware of the many possible measures to reduce their GHG emissions[24]. If each uses their own national legislation to meet the EU regulation of GHG emissions, partnerships and agreements between states foster regional cohesion and ensure that the ESD is respected. “For the EU, ambition is not only about reducing GHG emissions, but also about adapting to the effects of climate change and addressing its impacts on human and state security.” (European External Action Service 2019, 1)

“The regulation [that] allows individual countries sufficient flexibility to adapt to their national conditions and needs”[25] is essential to attain and maintain EU and national objectives as emissions, renewables energy creation and energy efficiency are uncertain. In that view, the EU accords to each Member a limited number of Emissions Trading System (ETS) allowances that permits to meet the common goals. For example, Malta exceeded its Annual Emissions Allocations (AEAs) in 2013-2015 but bought Bulgaria’s AEA, ensuring that the EU’s AEAs will reduce to meet the legislation. On the other side, Sweden whose AEAs were under its maximal threshold prevent any purchase from other Members to improve the environmental GHG emissions of the EU as a whole[26]. Experts point out the effectiveness of annual monitoring plans and evaluation. In that sense, any Member deviating from its national goals is obliged to submit to the Commission new action plans and policies to meet its objectives. This tracking system provides Members “early warnings in case Member States are lagging behind with their obligations and provides encouragement to take the necessary actions”[27].

The European Parliament and the Commission adopted in June 2018 the Energy Union governance regulation which ensures that the EU will meet the 2030 energy and climate objectives. This new legislation aims at reaching EU’s energy goals while fostering partnership between Member States and between Members and the EU by ensuring that “the range of actions proposed constitute a coherent and coordinated approach”[28] and that “the targets are set according to the principle of fairness, which was important to gain political acceptability”[29]. The 2019 National Energy and Climate Plans of each Member aims at integrating energy efficiency policy into their national policies. These Plans that record each states’ results will “promotes mutual learning and maximises the opportunities for regional cooperation”[30] so the common goal will be reached. The EU reminds that it imports 53% of the energy it needs and this reliance, particularly on Russia, weakens the “capacity of the EU as a whole to deal with supply shocks and respond to energy security threats.”[31]

Many Member States ask for “further action at EU level”[32] to increase results on energy efficiency or the reduction of GHG emissions. These measures include the creation committees, meetings and workshop at the demand of the Commission or the Members themselves to facilitate the implementation or creation of policies[33]. In that view, the creation of the Environment Action Programme (EAP) “has helped Europe speak with one voice” both to European states, regional players, private stakeholders, and citizens as well as international actors[34]. It has enhanced greater coherence and commitment from the Member States to reach their different national targets on GHG emissions, energy efficiency, renewables or other climate change challenges. Moreover, monitoring and evaluating Members’ policies and strategies is crucial to guarantee effectiveness. The Commission has developed tools and indicators to evaluate national strategies[35]. Such tool is the creation in 2016 of the Environmental Implementation Review (EIR) whose aim is to “improve the implementation of European environmental policy and commonly agreed rules in all EU Member States[36]”. This review assesses national environmental implementations while highlighting priorities and implementation gaps. It proposes national reviews as well as common EU trends in climate change actions, underlines the good results such as the climate and renewable energy 2020 and 2030 targets while pointing at the need for more efforts on energy efficiency.[37]

Finally, the EU is also entitled to use sanctions against any Member State [38] if it fails to enforce EU law. This infringement procedure aims to deter Members to break EU environmental and energy policies through the use of economic sanctions or the temporary removal of votes in Parliament. This procedure starts with a “formal letter”, followed with a “reasoned opinion” and can eventually end up before the Court of Justice of the EU[39] if the State does not provide answers and a change in its implementation of the EU law. In 2018, the Commission launched infringement procedures against fifteen Members for not complying with the EU policy on energy efficiency[40]. Penalties for infringement must be “effective, proportionate and dissuasive[41]” in order to fulfil their role of compelling Member to implement EU regulation on climate change. Such infringement decisions were applied towards Austria, Germany, Slovakia, Spain, Sweden, and the United Kingdom which failed to transpose the EU energy efficiency rules under the Energy Efficiency Directive into their national law. Indeed, such failure was compromising the energy efficiency target of 2020.

 

EU’s areas of improvement

If experts point out that each of the 25 Members States have integrated a national strategy for climate change and that climate action is now fully integrated into the EU budget, they argue that the Commission needs to better “implement and monitor national strategies; complete mainstreaming in EU policy, address territorial and social differences in vulnerability to climate change”[42]. “Lack of resources, insufficient capacity in the organisations responsible for environmental regulation and enforcement, and inadequate sanctions and low level of fines for those that breach the law” [43] are the main failures of the EU environmental legislation and implementation. Indeed, Members’ compliance with EU climate change policy is frequently criticized as this policy area has the second-highest numbers of violations[44]. Effective implementation starts with simplified laws and regulations that allow the Member States to enforce them according to their national legislations. “The implementation chain, including [actors] responsible for environmental planning, permitting, monitoring, compliance promotion and assessment, enforcement, prosecution, and the judiciary”[45] should be simplified. In that same view, many argue that effective “implementation involves bargaining and negotiation, not rigid, top-down control.”[46]

If many suggest that the implementation gap is because of the Members, only a few looks at the EU level. They argue that non-compliance can result in the difficulty for Members to implement EU law into their national legislation rather than the unwillingness to do so. Experts claim that the EU should help States in their implementation by “easing the burden and by strengthening their legal and administrative capacities”.[47] A simpler legislation would allow Members to implement more rapidly the EU legislation into their national and prevent environmental offences as time can be a crucial factor in tackling climate change. Two dominant theories explain the implementation gap. For the enforcement approach, the gap can be dealt if monitoring and sanctioning are better adapted to Members’ national laws. On the other side, the management theory argues that the European Commission should be better effective at helping States to implement EU law in the first place. The EU should thus simplify its environmental regulations to better match with national legalisations which could only help better and faster implementation and enforcement[48] as studies as shown that national administrative structures are one of the main factors that prevent effective implementation[49].

The infringement procedure is mainly criticized because of its duration which can last up to 50 months. In the meantime, the process does not have a suspensive effect, which allows Members to continue their harmful actions[50]. The lack of instruments to stop such activities must be tackled as environmental offences are usually irreversible. In that view, the Commission’s new infringement policy aims at ensuring compliance with the Member States through better partnership and dialogue between the actors includes national policy considerations which will help States better enforce the EU legislation[51]. Drifting apart from infringement procedures towards the improvement of information sharing between Members or the creation of new agencies and networks[52][53] would “improve communication and cooperation between different actors involved in compliance and enforcement”[54].

Moreover, inspection constitutes a vital element in implementation. Yet, for a few years, the inspection system has failed to deliver a homogeneous application of climate change-related EU legislation, which compromised the achievement of the common goals. As a response, the Seventh Environment Action Programme 2013-2020 has placed inspections into the political foreground and the Recommendation 2001/331 on Minimum Criteria for Environmental Inspections (RMCEI) was created to improve the effectiveness of such inspections. Crucial areas such as GHG emissions are now distinctly inspected to ensure Members’ compliance and prevent any fraud or abuse regarding the ETS system. [55] Monitoring, reviewing and cooperation between all the actors involved, whether the EU institutions, the States or the private actors are is the basis to implement an effective policy that tackles climate change.

 

This essay has assessed how the EU is prepared to tackle climate change as a security challenge. Its three main priorities are each inherently linked to climate change, which explains the EU legislation and regulations on these matters. The many regulations, laws and plans as well as the EU’s way to implement them show that the EU seems prepared to tackle it. However, the nature of the EU law in the implantation of legislations in its States Members can limit its purpose. In that view, simplification and support should be the priorities if the EU wants to secure its citizens and Members form climate change risks.

 

 

 

 

 

 

 

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[1] Council of the European Union, Council Conclusions on Climate Diplomacy, 26 February 2018, http://www.consilium.europa.eu//media/32953/st06125-en18.pdf.

[2]  Trombetta. M. J. 2008. Environmental security and climate change: Analysing the discourse, Cambridge Review of International Affairs. 21:4, 585-602. https://www.tandfonline.com/doi/full/10.1080/09557570802452920#aHR0cHM6Ly93d3cudGFuZGZvbmxpbmUuY29tL2RvaS9wZGYvMTAuMTA4MC8wOTU1NzU3MDgwMjQ1MjkyMD9uZWVkQWNjZXNzPXRydWVAQEAw

[3] European Commission. 2018. “EU and The Paris Climate Agreement: Taking Stock of Progress at Katowice COP”. Report from The Commission to The European Parliament and The Council. Brussels: European Commission. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018DC0716&qid=1564824450589&from=EN

[4] Gökgöz. F., Güvercin. M. T. (2018) Energy security and renewable energy efficiency in EU. Renewable and Sustainable Energy Reviews. 96. 226–239 https://reader.elsevier.com/reader/sd/pii/S1364032118305549?token=30DF0CE2D70170CE767F27250DE5BF09A35C618D73487173688F78E27D9B86F16A7F568997CA5C698A18674F3498BA75

[5] Ibid.

[6] Owusu. P. A., Asumadu-Sarkodie. S. 2016. A review of renewable energy sources, sustainability issues and climate change mitigation. Cogent Engineering. 3: 1167990. https://www.tandfonline.com/doi/full/10.1080/23311916.2016.1167990#aHR0cHM6Ly93d3cudGFuZGZvbmxpbmUuY29tL2RvaS9wZGYvMTAuMTA4MC8yMzMxMTkxNi4yMDE2LjExNjc5OTA/bmVlZEFjY2Vzcz10cnVlQEBAMA==

[7] European Commission. 2019. Report from The Commission to The European Parliament, The Council, The European Economic and Social Committee and The Committee of The Regions: Renewables Energy Progress Report. Brussels: European Commission. https://ec.europa.eu/commission/sites/beta-political/files/report-progress-renewable-energy-april2019_en.pdf

[8] Ibid.

[9] European Commission. 2018. “EU and The Paris Climate Agreement: Taking Stock of Progress at Katowice COP”. Report from The Commission to The European Parliament and The Council. Brussels: European Commission. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018DC0716&qid=1564824450589&from=EN

[10] https://ec.europa.eu/energy/sites/ener/files/documents/1_EN_ACT_part1_v8_0.pdf page 2

[11] Owusu. P. A., Asumadu-Sarkodie. S. 2016. A review of renewable energy sources, sustainability issues and climate change mitigation. Cogent Engineering. 3: 1167990. https://www.tandfonline.com/doi/full/10.1080/23311916.2016.1167990#aHR0cHM6Ly93d3cudGFuZGZvbmxpbmUuY29tL2RvaS9wZGYvMTAuMTA4MC8yMzMxMTkxNi4yMDE2LjExNjc5OTA/bmVlZEFjY2Vzcz10cnVlQEBAMA==

[12] Protocol to the United Nations Framework Convention on Climate Change. 1997. http://unfccc.int/essential_background/kyoto_protocol/items/1678.php

[13] European Commission. 2018. “EU and The Paris Climate Agreement: Taking Stock of Progress at Katowice COP”. Report from The Commission to The European Parliament and The Council. Brussels: European Commission. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018DC0716&qid=1564824450589&from=EN

[14] European Commission. 2018. “A Clean Planet for all A European strategic long-term vision for a prosperous, modern, competitive and climate neutral economy”. Report from The Commission to The European Parliament, the European Council, the Council, the European Economic and Social Committee, the Committee of the Regions and the European Investment Bank. Brussels: European Commission. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018DC0773&from=EN

[15] European Commission. 2019. “Report from the Commission. To the European Parliament, the Council, the European Economic and Social Committee, the Committee of the Regions and the European Investment Bank. Brussels: European Commission. https://ec.europa.eu/commission/sites/beta-political/files/fourth-report-state-of-energy-union-april2019_en_0.pdf

[16] Ibid.

[17] Directorate General for Energy. 2019. “Report of The Work of The Task Force on Mobilising Efforts to Reach The EU Energy Efficiency Targets For 2020”. Brussels: European Commission. https://ec.europa.eu/energy/sites/ener/files/report_of_the_work_of_task_force_mobilising_efforts_to_reach_eu_ee_targets_for_2020.pdf

[18] Ibid.

[19] Ibid.

[20] Ibid.

[21] European Commission. 2019. “Report from the Commission. To the European Parliament, the Council, the European Economic and Social Committee, the Committee of the Regions and the European Investment Bank. Brussels: European Commission. https://ec.europa.eu/commission/sites/beta-political/files/fourth-report-state-of-energy-union-april2019_en_0.pdf

[22] Council of the EU. 2018. “Governance of The Energy Union: Council Confirms Deal Reached With The European Parliament”. Brussels. https://www.consilium.europa.eu/en/press/press-releases/2018/06/29/governance-of-the-energy-union-council-confirms-deal-reached-with-the-european-parliament/pdf

[23] Delbeke, Jos, and Peter Vis. 2015. EU Climate Policy Explained. Brussels: Taylor and Francis.

[24] European Commission. 2016. “Proposal for a Regulation of the European Parliament and the Council on binding annual greenhouse gas emission reductions by Member States from 2021 to 2030 for a resilient Energy Union and to meet commitments under the Paris Agreement and amending Regulation No 525/2013 of the European Parliament and the Council on a mechanism for monitoring and reporting greenhouse gas emissions and other information relevant to climate change”. Brussels : European Commission. https://eur-lex.europa.eu/resource.html?uri=cellar:923ae85f-5018-11e6-89bd-01aa75ed71a1.0002.02/DOC_1&format=PDF

[25] Council of the EU. 2018. “Governance of The Energy Union: Council Confirms Deal Reached With The European Parliament”. Brussels. https://www.consilium.europa.eu/en/press/press-releases/2018/06/29/governance-of-the-energy-union-council-confirms-deal-reached-with-the-european-parliament/pdf

[26] European Commission. 2018. “EU and The Paris Climate Agreement: Taking Stock of Progress at Katowice COP”. Report from The Commission to The European Parliament and The Council. Brussels: European Commission. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018DC0716&qid=1564824450589&from=EN

[27] European Commission. 2016. “Proposal for a Regulation of the European Parliament and the Council on binding annual greenhouse gas emission reductions by Member States from 2021 to 2030 for a resilient Energy Union and to meet commitments under the Paris Agreement and amending Regulation No 525/2013 of the European Parliament and the Council on a mechanism for monitoring and reporting greenhouse gas emissions and other information relevant to climate change”. Brussels: European Commission. https://eur-lex.europa.eu/resource.html?uri=cellar:923ae85f-5018-11e6-89bd-01aa75ed71a1.0002.02/DOC_1&format=PDF

[28] Council of the EU. 2018. “Governance of The Energy Union: Council Confirms Deal Reached With The European Parliament”. Brussels. https://www.consilium.europa.eu/en/press/press-releases/2018/06/29/governance-of-the-energy-union-council-confirms-deal-reached-with-the-european-parliament/pdf

[29] Delbeke, Jos, and Peter Vis. 2015. EU Climate Policy Explained. Brussels: Taylor and Francis.

[30] European Commission. 2019. “Report from the Commission. To the European Parliament, the Council, the European Economic and Social Committee, the Committee of the Regions and the European Investment Bank. Brussels: European Commission. https://ec.europa.eu/commission/sites/beta-political/files/fourth-report-state-of-energy-union-april2019_en_0.pdf

[31] Wilson. A. 2015. European Energy Security Strategy. Brussels: European Parliament. http://www.europarl.europa.eu/EPRS/EPRS-AaG-559474-European-Energy-Security-Strategy-FINAL.pdf

[32] European Commission. 2019. “Report from the Commission. To the European Parliament, the Council, the European Economic and Social Committee, the Committee of the Regions and the European Investment Bank. Brussels: European Commission. https://ec.europa.eu/commission/sites/beta-political/files/fourth-report-state-of-energy-union-april2019_en_0.pdf

[33] Ibid.

[34] European Commission. 2019. “Report from The Commission to The European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on the on the evaluation of the 7th Environment Action Programme”. Brussels: European Commission. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52019DC0233&from=EN

[35] Ibid.

[36] European Commission. 2019. “Environmental Implementation Review: Commission helps Member States to better apply EU environment rules to protect citizens and enhance their quality of life”. Press Release. European Commission. Brussels. https://europa.eu/rapid/press-release_IP-19-1934_en.htm

[37] Ibid.

[38] Official Journal of the European Union. 2019. Consolidated Version of the Treaty on European Union, Title I, Common Provisions, Article 7. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12012M007&from=EN

[39] Ibid.

[40] European Commission. 2019. “Monitoring the Application of Union Law 2018 Annual Report”. Report from the Commission. “Monitoring the application of European Union law 2018 Annual Report”. Brussels. https://ec.europa.eu/info/sites/info/files/report-2018-annual-report-monitoring-application-eu-law.pdf

[41] European Commission. 2019. Infringement Decisions. Jury Infringements Package: Key Decisions. Brussels. https://europa.eu/rapid/press-release_INF-19-4251_EN.htm

[42] European Commission. 2018. “Report from The Commission to The European Parliament and The Council”. EU And the Paris Climate Agreement: Taking Stock of Progress at Katowice COP. Brussels: European Commission. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018DC0716&qid=1564824450589&from=EN

[43] European Union for the Implementation and Enforcement of Environmental Law. 2015. Challenges in the practical implementation of EU environmental law and how IMPEL could help overcome them. Brussels: IMPEL. http://impel.eu/wp-content/uploads/2015/07/Implementation-Challenge-Report-23-March-2015.pdf

[44] Hoffman, A., 2019. Left to interest groups? On the prospects for enforcing environmental law in the European Union. Environmental Politics, 28 (2), 342-364. https://doi.org/10.1080/09644016.2019.1549778

[45] European Union for the Implementation and Enforcement of Environmental Law. 2015. Challenges in the practical implementation of EU environmental law and how IMPEL could help overcome them. Brussels: IMPEL. http://impel.eu/wp-content/uploads/2015/07/Implementation-Challenge-Report-23-March-2015.pdf

 

[46] Jordan. A. 1998. The implementation of EU environmental policy; a policy problem without a political solution? Environment and Planning: Government and Policy. 17. 69-90

[47]  Ibid.

[48] Smith. M. 2018. Challenges in the implementation of EU Law at national level. Briefing requested by the JURI committee. Brussels. European Parliament. http://www.europarl.europa.eu/RegData/etudes/BRIE/2018/608841/IPOL_BRI(2018)608841_EN.pdf

[49] European Union for the Implementation and Enforcement of Environmental Law. 2015. Challenges in the practical implementation of EU environmental law and how IMPEL could help overcome them. Brussels: IMPEL. http://impel.eu/wp-content/uploads/2015/07/Implementation-Challenge-Report-23-March-2015.pdf

[50] Hedemann-Robinson. M. 2010. Enforcement of EU environmental law and the role of interim relief measures. European Energy and Environmental Law Review, 204–229.

[51] European Commission. 2017. Communication from the Commission to The European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions. Completing the Better Regulation Agenda: Better solutions for better results. Strasbourg. European Commission. https://ec.europa.eu/info/sites/info/files/completing-the-better-regulation-agenda-better-solutions-for-better-results_en.pdf

[52] Ibid.

[53] European Union for the Implementation and Enforcement of Environmental Law. 2015. Challenges in the practical implementation of EU environmental law and how IMPEL could help overcome them. Brussels: IMPEL. http://impel.eu/wp-content/uploads/2015/07/Implementation-Challenge-Report-23-March-2015.pdf

 

[54] Ibid.

[55] Hedemann-Robinson. M. 2016. Environmental inspections and the EU: Securing an effective role for a supranational union legal framework. Transnational Environmental Law, 6 (1), 1–28

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