European Environment Eur. Env.

10, 109 120 (2000)

GREENING THE EUROPEAN UNION: WHAT CAN BE LEARNED FROM THE LEADERS OF EU ENVIRONMENTAL POLICY?
Andrew Jordan1,* and Andrea Lenschow2
1 2

University of East Anglia, Norwich, UK University of Salzburg, Austria

contemporary European environmental policy. Copyright 2000 John Wiley & Sons, Ltd and ERP Environment. INTRODUCTION
chieving environmental policy integration (EPI) is arguably the critical challenge confronting European environmental policy makers at the dawn of the new millennium. EPI means moving beyond end-of-pipe environmental regulation to address the root causes of environmental damage. However, as politicians are now beginning to discover, EPI is very different to traditional systems of pollution control, requiring a much more anticipatory and multisectoral approach to protecting the environment than that currently in place anywhere in the industrialized world. For a long time, these differences were not fully appreciated by those politicians who freely counselled greater integration as a means to solve Europes environmental ills. Of course environmentalists made the intellectually convincing case for the systematic application of EPI at the European level when European Union (EU) environmental policy was first founded in the early 1970s, but it is only now, some 30 years later, that their arguments are being seriously addressed by the Commission and the Council of Ministers

The European Union (EU) has undoubtedly made enormous strides in developing a progressive environmental policy, but many of its own policies actively undermine the pursuit of sustainable development. In the aftermath of the 1999 Amsterdam Treaty, the EU is finally beginning to confront the thorny problem of how to green itself. The vehicle selected to reach this goal is the so-called Cardiff process of review and reporting, which is currently exploring the opportunities to achieve environmental policy integration (EPI) at the European level. However, it is argued that in order to green the EU, member states must also take complementary steps to green themselves by implementing EPI at national and sub-national levels. The progress hitherto made by four of the greenest states of the EU, namely Denmark, the Netherlands, Germany and the UK, is examined in order to investigate the opportunities for cross-national learning in this politically and ecologically important area of
* Correspondence to: Dr. Andrew Jordan, School of Environmental Science, University of East Anglia, Norwich NR4 7TJ, UK. E-mail: a.jordan@uea.ac.uk
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A. JORDAN AND A. LENSCHOW (CoM). Currently, the so-called Cardiff process of reporting is primarily concerned with the challenge of implementing EPI at the European level. However, there are important reasons why policy makers must consider EPI as being as much a multi-level as a multi-sectoral challenge. In this paper we argue that EPI cannot be pursued solely at the European level through the institutional mechanism of the CoM and the Cardiff process of reporting. Crucially, in order to ensure that the overall effort is coordinated and comprehensive in its coverage, complementary actions will have to be taken by member states who, in accordance with the principle of subsidiarity, need to comprehensively green their own national policies in pursuit of sustainable development. The remainder of this article draws upon the findings of a comparative analysis of the implementation of EPI by the greenest member states and the institutions of the EU (Lenschow, in press), as well as recent evidence collected by the OECD (1993, 1994, 1999). It examines how well four front-runner states of the EU, namely Germany, the Netherlands, Denmark and the UK, are responding to the political demands generated by the principle of EPI. These four states represent an interesting test case of how far EPI is progressing in Europe, and a potentially rich source of experience for the less progressive member states and the new entrants in the former Eastern Bloc. The picture that emerges from our analysis suggests that EPI represents a far stiffer challenge to the policy status quo in Europe and nationally in the member states than even the most environmentally progressive front-runner states of the EU currently seem capable of overcoming. Having identified the main gaps and overlaps with and between actions currently being undertaken at all the main levels of environmental governance in the EU, we try to identify the opportunities for cross-national learning and lesson drawing in this important area of contemporary EU environmental policy.
Copyright 2000 John Wiley & Sons, Ltd and ERP Environment

THE PRINCIPLE OF EPI

The thinking that lies behind the concept of EPI is neither sophisticated nor especially novel (Haigh, 1998). In some respects it is one of the guiding tenets of green political thought. However, it only really began to achieve wider political currency with the publication of the 1987 United Nations (Brundtland) Report entitled Our Common Future (WCED, 1987). Brundtland identified EPI as a necessary but insufficient condition for achieving sustainable development, which, following the ratification of the 1999 Amsterdam Treaty (Jordan, 1998), is now one of the overarching legal goals of the EU. Brundtland identified the fundamental mismatch between the integrated operation of ecosystems and the sectorized structures and operational procedures of those administrative bodies to manage it as one of the root causes of unsustainable development: Those responsible for managing natural resources and protecting the environment are institutionally separated from those responsible for managing the economy. The real world of interlocked economic and ecological systems will not change; the policies and institutions concerned must (WCED, 1987, p 9). The EUs failure to attain this administrative ideal is amply demonstrated by the deeply sectorized structure of both the Commission and the CoM. Brundtlands intellectual solution to this and other institutional mismatches was and remains exceedingly simple: the major central economic and sectoral agencies of governments should now be made directly responsible and fully accountable for ensuring that their policies, programmes, and budget support development that is ecologically as well as economically sustainable (WCED, 1987, p 314). In practice, EPI requires nothing less than a political revolution in European political
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GREENING THE EUROPEAN UNION governance: environmental agencies need to colonize the key centres of power at all the main administrative levels of the EU, by winning over more powerful sectoral agencies to their way of thinking. Given the historically lowly political status of most environmental directorates, departments and agencies at all levels of governance, and the deeply entrenched barriers to horizontally co-ordinated activity (joined-up-policy making) in all organizational systems, the political difficulty of achieving such a transformation even in the medium to long term should not be underestimated. So what exactly does EPI involve? Unfortunately, EPI is a general principle of environmental policy making, not a well developed plan of action. Arild Underdal suggests that a policy is integrated when the consequences for that policy are recognized as decision premises, aggregated into an overall evaluation and incorporated at all policy levels and into all government agencies involved in its execution (in Weale and Williams, 1992, p 46). We would argue that policies are environmentally integrated when policy makers in non- environmental sectors recognize the environmental repercussions of their decisions and adjust them by appropriate amounts when they undermine sustainable development. According to the European Environment Agency (EEA), EPI is a process of adjusting the focus of environmental policy away from the environmental problems themselves to their causes . . . [and] [f]rom end-of-pipe environment ministries to driving force sector ministries (EEA, 1998, p 283). ropean level is, of course, hugely important because many, if not most, aspects of national environmental policy are now decided there, but it is also vitally important to remember that EPI is (and always will be) a multi-level challenge, which bears upon and requires coordinated responses from all levels of government in the EU European, national, regional and local. National governments perform a particularly important role in this respect because the most significant driving force sectors of environmental damage are not nearly as communitized (i.e. EU led) as EU environmental policy. Consequently, the EUs ability to steer them in a more sustainable direction is relatively weak. Responsibility for achieving EPI therefore has to rest equally with member states, who, in accordance with the principle of subsidiarity, need to make appropriate adjustments to their own national policies in areas such as transport and energy to achieve sustainable development. For example, local land use planning1 is a potentially important tool for managing the demand for transport, but is mainly, though not exclusively, under state control. Similarly, alterations in national energy policies have a significant impact upon total European emissions of various pollutants, but they too are mainly state controlled. The same also can be said of structural (regional) development policies: funds are made available by the EU for infrastructure projects, but most of the planning and decision making i.e. the key points where EPI must bite if it is to be effective is undertaken by the member states. EU legislation provides a legal framework for achieving EPI at these lower (i.e. national and sub-national) levels of governance (i.e. the environmental impact assessment (EIA) directive), but it applies too late in the decision-making chain to have any significant effect on environmental outcomes, and, crucially, the primary responsibility for undertaking EIAs and other forms of policy appraisal currently rests with national or regional-level authorities.
1 Town and country planning and energy supply issues are two of three policy areas exempted from qualified majority voting by the 1993 Maastricht Treaty, a decision subsequently confirmed by the 1999 Amsterdam Treaty. For details see Wilkinson (1992, p 228).

EPI AS A MULTI-LEVEL PROBLEM

The appearance of Article 6 of the 1999 Amsterdam Treaty marked an important watershed in thinking about EPI in Europe. Currently, however, the so-called Cardiff process of reporting on the environmental impact of different sectoral formations of the CoM (e.g. agriculture, energy, single market etc) is centred upon what needs to be done at the European level to achieve EPI. The EuCopyright 2000 John Wiley & Sons, Ltd and ERP Environment

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A. JORDAN AND A. LENSCHOW All these examples illustrate the complicated interdependencies that exist between different levels of governance in the EU. For many environmentally related issues, it is member states (and their emanations) acting individually within their own territories rather than collectively in the various sectoral formations of the CoM that make (or fail to make) many important integrated decisions. The protracted political battles surrounding the allocation of emission reductions strategies within the EUs climate change bubble provide a sobering reminder of how potentially difficult it can be in practice to achieve co-ordinated action across the various level of the EU in pursuit of a goal agreed jointly at the Ministerial level in the Environment Council.

Do government purchasing strategies take sufficient account of environmental issues? Are there environmental management measures within government and is implementation monitored? To these we would add that there should also be a common set of what the Cardiff process refers to as sector-specific targets, timetables . . . and indicators. These would measure how well EPI measures are performing and, where necessary, flag the need for corrective measures when deviant sectoral policies threaten the attainment of sustainability objectives agreed jointly. In the next section we analyse how well the four front-runner states are performing against these criteria.

NATIONAL APPROACHES TO EPI MEASURING INTEGRATION

If, as we argue, states need to green themselves in order to achieve EPI in Europe, how should their performance be assessed? Ultimately the acid test of how well EPI measures are performing within the greenest EU member states is the extent to which they contribute to or undermine the achievement of sustainable development. Unfortunately, sustainable development is not a sufficiently clear endpoint to employ as an evaluative yardstick. It is, as the Cardiff process now recognizes, more useful to break the term down into a series of more specific targets or benchmarks (see EEB, 1999). The European Environment Agency (EEA, 1998, p 284) has usefully provided a suite of possible indicators expressed in the form of a checklist of questions. These include the following:

The United Kingdom In the past, the UK has often delayed the adoption and implementation of common environmental standards in Europe. However, since the publication of the 1990 White Paper, the UK Government has, through its greening government initiative, made comparatively good progress in implementing EPI at the national level, although critical bottlenecks remain. The initiative tries to build an environmental element into the comparatively strong and centralized system of policy development and coordination that exists in the UK (for a historical overview, see Hill and Jordan, 1993; Jordan, in press a, b). Greening government has the following elements:

Has an environmental impact assessment been undertaken at the planning stage of a new policy (i.e. a strategic environmental assessment (SEA))? Have the potential environmental impacts been identified and, where possible, quantified? Have any environmentally damaging subsidies been withdrawn?
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a Cabinet committee on the environment chaired by the Deputy Prime Minister and environment secretary, John Prescott. The Committee (ENV) is the principal decisionmaking body for government policy on sustainable development; a Committee of Green Ministers from each government department to consider and report on the environmental impact of their own departments policies and to implement green housekeeping issues such as energy efficiency and recycling; and
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GREENING THE EUROPEAN UNION

an appraisal system for assessing the environmental impact of departmental policies, backed up by guidance, training and external reporting.

The new Labour government supplemented these with a Green Globe task force to inform the Foreign Offices ethical foreign policy, a parliamentary audit committee to chase progress across government departments and a special cross-departmental sustainable development unit located in Prescotts new superministry, the Department of Environment, Transport and the Regions (DETR). The creation of the DETR was warmly received by environmental groups because it addressed a major discontinuity in central government by re-uniting the separate functions performed by the Departments of the Environment (DoE) and Transport (DoT): an example of EPI by institutional re-organization. Comprehensive policy reviews were also ordered in the energy and transport sectors two key drivers of environmental change and extra spending was earmarked for an environmental task force to help the young unemployed back into work. Finally, the Labour government introduced a set of key sustainability indicators to sit along side the headline inflation and GDP figures. In comparison to other European states, the machinery of government in the UK is strong and well organized. However, the new parliamentary audit committee soon discovered a deep seated and continuing reluctance to take environmental protection requirements as seriously as social and economic concerns (HC 517-I, Session 199798, paragraph 4). The failure to attain higher levels of EPI is often put down to a combination of weak political leadership at the centre of government and resistance from other departments, who see little to be gained politically or economically by voluntarily adjusting their policies to reflect environmental requirements. The clear impression given by their Lordships when they investigated the White Paper process in 1995 (HL 72, Session 199495) was that there was no systematic inter-policy co-ordination on environmental matters outside that dictated by EU Directives and political expediency
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generated by controversial events and electoral considerations. The audit committee referred to this very minimalist interpretation of EPI as green proofing. Crucially, this highly truncated form of EPI fails to penetrate that most fundamental of all government activities the setting of a national budget (HC 326, Session 199899, 3; HC 233, Session 1999 2000). In terms of the EEAs evaluative criteria, the UK continues to resist the Commissions attempts to introduce a more systematic process of SEA in the EU, even though most of the main elements are in fact already in place. The subtext of the DETRs evidence to MPs was that other parts of Whitehall were actively opposing its efforts to formalize the current appraisal system: we already carry out SEAs . . . [SEA] is already there in the planning procedures. There are different views in Whitehall, but our general view is that it is not a priority [but] I accept that there is a case for extending it (HC 517-II, session 199798, cols 478). The audit committee has done much to reveal how inconsistently the UK applies its preferred alternative policy appraisal. Estimating the total level of environmentally damaging subsidies in the UK is an extremely difficult task. However, the British Government Panel on Sustainable Developments (1997) conservative estimate of 20000 million p.a. indicates the scale of the change that is theoretically possible. Pressure from the audit committee has been instrumental in encouraging several departments to adopt environmental management systems but there are parts of Whitehall where commitment remains weak. Finally, the UK has a suite of national sustainability indicators, but they will only really support the attainment of EPI if they are tied directly to sectoral policies. Currently, it is still unclear which, if any, policy levers the Government will pull if the indicators begin to move in an unfavourable direction.
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A. JORDAN AND A. LENSCHOW The Netherlands The Netherlands was one of the first countries to recognize and respond to the intercoupling of environmental and sectoral policies, and has been a front-runner with regard to the implementation of EPI ever since. The Dutch National Environmental Policy Plan (NEPP), published in 1989, was the first policy outcome of an emerging awareness among governmental elites that EPI could not be achieved by the state acting alone. The plan was jointly drafted by a number of ministries, but the intention was always to develop a wider social contract with Dutch civic society. The NEPP and its successors (NEPP3 was adopted in 1998) have all adopted a new problem-solving approach to environmental issues, which addresses the attitudes and behaviour of all societal actors. One of the axioms of the so-called verinnerlijking approach is that the internalization of environmental concerns is a vital prerequisite for effective EPI feeding through to alterations in consumption and production patterns. Consequently, at the planning stages of the NEPP process target groups were formed to draw in and engage the most important stakeholders. In detail, the plan reflects Brundtlands emphasis upon long-term planning, wide stakeholder engagement and positive-sum relationships between environment and the economy. The plan has a 25-year time horizon and includes cost figures for environmental measures to achieve long-term targets (e.g. acidification, waste generation). The target groups have remained important in the implementation process of the NEPP (Le Blanch, 1996). Sectoral target groups were asked to define policy objectives for themselves and select appropriate policy instruments. The advocates of consensual policy making believed such an approach would facilitate the recognition of win win situations and prevent conflicting interests from becoming entrenched (Bressers and Plettenburg, 1997, p 124). The environment department acted as the overall coordinator and facilitator for the different target groups looking after the implementation of the NEPP. Within the environment
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department policy activities flowing from the NEPP process have been divided among the different directorates. A training programme was established, called the Implementation Challenge, to train the 400 or so officials affected by EPI. Other departments soon followed with the development of their own environmental policy plans. They also acted as conveners for various target groups covering issues such as energy saving, agricultural protection and land use planning etc. NEPP3 builds on earlier Plans and stresses the need for continued cooperation with target groups (Liefferink, 1999). The critical question is just how environmentally effective has the Dutch approach been? Glasbergen and Driessen (1994) cite several examples (the Genre Valley, the Green Heart, Schiphol Airport) of relatively successful network management resulting in integrated approaches to major infrastructure projects. However, even with these EPI initiatives the actual environmental performance of the Netherlands is far from perfect. Critics point to enduring sectoral rigidities, especially in the agricultural sector, whose contribution to water pollution has long been recognized (Hajer, 1992; van der Straaten and Ugelow, 1994). Network management has proven to be a complex process requiring good communication skills on the part of the convenors and the facilitators (in order to prevent stakeholders becoming adversaries of the process, for instance) (cf. De Jongh, 1998). In this context two recent developments in the Dutch approach are notable. First, EPI is increasingly being discussed and applied at the regional and sub-regional level where long-term policy plans dealing with spatial policy, water management, economic or social policy are currently being developed. Given the multi-level nature of EPI, it may well be more appropriate to search for consensual solutions to these and other problems at the sub-national level. Second, the NEPP3 also reflects a shift towards another policy tool to achieve integration which is less communication intensive, namely an increased emphasis on economic and, in particular, fiscal instruments. A major ecological tax reform has been proposed for the new millennium.
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GREENING THE EUROPEAN UNION To conclude, the Dutch overwhelmingly interpret EPI as a societal rather than a governmental responsibility. In spite of continuing problems, they have made considerable progress in integrating environmental concerns into sectoral policies at all levels of government. Economic appraisal techniques (including SEA for sectoral plans) have been extensively used to determine policy strategies to reach the targets identified in negotiations with stakeholders. While the highly interactive Dutch planning approach is now being adopted at sub-national levels, the Dutch government is beginning to experiment with new approaches such as fiscal instruments, to internalize externalities. It is ironic that in this respect the Dutch are only now approaching the starting point for recent Danish EPI initiatives: ecological tax reform. the energy sector2, the current Energy 21 Action Plan for sustainable development provides a range of economic and regulatory measures designed to shape energy supply and demand. The agricultural sector is currently undergoing a similar set of reforms with longer-term goals such as the removal of sensitive land from agricultural production and a reduction in the consumption of pesticides3. Finally, major efforts are being made to green spatial planning. Even though most responsibilities lie with regional and subregional government bodies, the Ministry of Environment and Energy draws up a national SEA-style report on spatial planning for submission to parliament that is directed towards ensuring that the overall paths of economic development and environmental protection are compatible. Strong inter-ministerial planning is compensated for by a system of SEA at the governmental planning level. Under a 1993 government circular (Circular 31), all bills presented to parliament that have major environmental effects must include an assessment of their environmental impact. Sectoral ministries use guidelines from the Ministry of Environment and Energy when preparing them. In the parliamentary year 199697, 77% of all proposals were subject to an assessment. The whole system is currently under review. In principle, Circular 31 does apply to the national budget, but as in the UK its overall impact remains unclear. A 1998 evaluation of the environmental impact of the 1998 budget, co-ordinated by the Ministry of Finance following guidelines agreed with the Ministry of Environment and Energy, found a favourable trend over the past eight years. Attempts to achieve EPI only rose to the top of the political agenda in the early 1990s after a change of government in Denmark. Compared to the Netherlands, its approach has not only been more decentralized but has
2 Denmark is the only OECD country that has a single ministry dealing with environmental and energy matters. 3 The OECD suggests that the greening of the agricultural sector is proceeding but far too slowly. Daugbjerg (1998) accounts for the historically powerful position of Danish farmers. However, a recent report on the options for curtailing agricultural use of pesticide may provide the necessary scientific basis to push Denmark to innovative more in this area (EPA, 1999).

Denmark Denmark has adopted a relatively decentralized approach to implementing EPI (see Skou Andersen, 1997; OECD, 1999). Many sectoral ministries were initially asked to develop strategies for sustainable development, but no inter-ministerial mechanism existed to address sustainable development in the round. The success of the whole initiative has been mixed. The impetus for the process often came from those wishing to water down existing environmental legislation (e.g. in the agricultural sector). Nevertheless, this has had the unintended effect of opening up previously closed sectors to outside political pressure and scrutiny. Denmark now has many sectoral action plans rather than an all-embracing Dutch style NEPP. The plans themselves are often quite explicit with regard to the measures that have to be taken. For instance, the 1993 Traffic 2005 plan establishes the management of transport demand and the need to curb traffic growth as well as several emission targets, as key policy objectives. At the local level, the Danish Environmental Protection Agency has provided direct support to the 73 largest municipalities to establish and implement integrated transport and environment plans. In
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A. JORDAN AND A. LENSCHOW placed more emphasis on fiscal instruments. EPI has been given a great boost by the green tax reforms first adopted in 1993 and now being applied across the full range of economic activities. The aim is to increase proportion of the total tax revenue raised from environmental taxes to 1.2% of GDP by 2000. On the whole, then, the Danes score relatively highly on the EEAs checklist. While scope for removing more environmentally damaging subsidies (which are extensively applied in the agriculture and forestry sectors) and reducing the demand for transport still remains large, Denmark is proving that environmental protection can be reconciled with economic growth. Meanwhile Denmark is fast becoming a progressive force for ecological tax reform in the EU. The Danes are, however, sceptical towards the voluntary agreements, which are such a central feature of the Dutch approach (Skou Andersen, 1997, pp 159160). In terms of providing access to decision making the Danish approach is less corporatist than the Dutch, but the issue of transparency is receiving increasing attention (ENDS Daily, 1999a). Germany Whereas the Dutch have relied upon a partnership approach between state and society to deliver EPI and the Danes are actively exploring the efficacy of economic instruments, the German approach remains largely state centred and implemented via regulatory means. Along with the Netherlands and Denmark, Germany has traditionally been one of the environmental leaders of the EU. It gained this reputation by advocating and adopting strict environmental standards, most notably in the fields of water and air pollution. However, in spite of repeated political commitments to implement precautionary action, the German public discourse overwhelmingly supports technological solutions to pollution control. These achievements are viewed as a sufficient policy response to the contemporary problem of achieving sustainable development through EPI (Beuermann and Burdick, 1997). For instance, in its official submission to the 1992 Rio Summit the German government argued that its advanced pollution conCopyright 2000 John Wiley & Sons, Ltd and ERP Environment

trol policies were to a large extent identical with the aims and demands of . . . Agenda 21 (cited by Beuermann and Burdick, 1997, p 91). Having an extensive and highly profitable clean technology industry (OECD, 1994, p 207), it is hardly surprising that Germany adopted this particular interpretation of EPI. If anything, re-unification has served to dilute still further Germanys political appetite for the political agenda that is now forming around the concept of sustainability. In issue areas such as nature conservation, biodiversity and land use, the positive sum relationship between growth and environment, which has given the concept of sustainable development rhetorical power, is less convincing and a generic commitment to environmental protection required. Maybe not surprisingly, on these issues economic objectives in Germany have indeed ranked higher than environmental goals, especially in the new Eastern Lan der. This was the gist of the 1993 OECD review of German environmental policy, which praised continuing attempts to decouple growth from pollution flows but criticized the failure to integrate environmental sectoral and environmental decision-making (OECD, 1993, pp 205215). Muller (1999) agrees that the main bottle neck holding up the achievement of EPI in Germany is essentially structural, that is the set-up of political and administrative institutions blocking effective communication and coordination and hence disabling any environmental learning processes across economic sectors. She identifies three such structural bottlenecks: First, EPI has always been something of a one-way street in Germany in that environmental policy makers have always been powerfully constrained by sectoral departments and the Chancellory from taking ambitious measures, whereas the transport, agricultural or economic departments have used normal inter-ministerial mechanisms to achieve their preferred policies. While environmental policy formulation has always had to take other sectoral policy priorities into account at a very early stage, environment only enters policy making in these other domains at a relatively stage when the die of policy is effectively already cast.
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GREENING THE EUROPEAN UNION Second, this pattern of one-way communication continues and gets further cemented in the federal structure of the German government. Permanent Conferences involving state and federal governments are organized to iron out conflicts. However, Federal Ministers are not bound by firm institutional procedures that grant access to environmental representatives. Particularly in the fields of agricultural and transport, Federal Ministers have found they can build a vertical alliance in an early stage of policy formulation, making it difficult for policy makers in subsequent stages of government decision making to inject a strong environmental dimension, let alone stop a particular development from taking place. The environment ministrys second best response is therefore to wait until an invitation to meet is received from the sectoral ministry in question. Only then can the environmental implications of the draft policy be negotiated (Muller, 1999, p 10). Third, the story is made even more complicated by the horizontal distribution of competences in the German federal system. For instance, water pollution is mainly a Lander responsibility, whereas the federal government has a much bigger say over the running of air pollution. In view of this administrative fragmentation, German pollution control policies and laws have traditionally addressed different environmental media (air, water, soil) separately. The assessment of environmental impacts of sectoral policy, however, presupposes an ability to trace pollution across media. Here the structure of the German administrative system has seriously constrained Germanys ability to implement the EU environmental impact directive (Knill and Lenschow, 1998, in press). Similarly, it represents one of the main obstacles to the adoption of an integrated Environmental Statute Book. The Statute Book, which was supposed to enter into force in 2000, will better integrate German legal structures (UBA, 1999). Preparatory work has been ongoing for about 10 years and two expert committees have been involved in the drafting process. The delays are in large part due to the complicated distribution of competences between the federal and the Lander level, especially in the field of water legislation4.
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The desire on the part of environmental policy makers to develop a framework to achieve EPI on the one hand, and the slow progress in actually getting there on the other, is visible in other initiatives. Following UNCED, an inter-ministerial working group assisted by the federal statistical office and the federal environment agency (UBA) was set up to test a suite of sustainability indicators. The report is scheduled to be published in November 1999, but as yet there are no firm plans to implement it. In contrast, the UBA is planning to form another project group to refine the list still further. Not surprisingly, there has been limited progress in developing a methodology of SEAs. Similarly, in 1992 a Parliamentary Enquete Commission was established to give sustainability and EPI a stronger push. After a slow start, the Commission was reinstated in 1995 to develop a national a national ecological action plan. In the Spring of 1998, Environment Minister Merkel presented a first draft, which focused on identifying targets for climate change, resource use, transport, land use and water quality with some environmental indicators attached. However, the bringing together of sectoral targets, indicators and policy strategies remains at a relatively early stage of development and awaits a harmonization of basic legal structures, i.e. the Statute Book. To summarize, EPI initiatives are only slowly being introduced in Germany. The main bottleneck is the lack of effective horizontal coordination at the ministerial level. Judged against the EEAs criteria, Germany still lacks a systematic system of SEA. Crucially, on many critical EPI-related issues the environment ministrys power of veto at the final decision stage is considerably weaker than the finance ministrys. The Federal and Lander governments provide extensive subsi dies to the German coal industry for economic, social and security reasons. Recently, German environmentalists claimed that
4 Gerd Winter, an environmental lawyer who has been involved in the drafting process of the Statute Book, discusses some of the politics responsible for the delay in a recent newspaper interview in Die Tageszeitung, 6 September 1999.

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A. JORDAN AND A. LENSCHOW environmentally damaging subsidies totalled some 15.3 billion p.a. in Germany (ENDS Daily, 1999b). Considering these challenges, Germanys front-runner status is perhaps more of a reflection on its past successes in regulating pollution than in addressing the more diffuse sustainability agenda. complicated institutional arrangement of its governing institutions. The Dutch, the Danes and, to a lesser extent, the British, have been in the vanguard of states in identifying sector-specific targets, timetables . . . and indicators of EPI. However, the acid test is just how concretely are they linked to the performance of sectoral policies in the short and in the long term? In theory, sectoral policies should be re-steered if and when they undermine the pursuit of sustainability objectives, otherwise target setting risks becoming a purely symbolic exercise. In all three countries some coordination problems in sectors such as agriculture and transport persist, for instance. However, in all three there is evidence of innovation in the use of instruments. While the Netherlands is moving in the direction of economic and fiscal instruments, Denmark is increasingly pushing towards transparent decision making. And of course there is the old topdown, regulatory approach to environmental policy making, which remains the preferred approach in Germany. To conclude, EPI is a multi-level challenge requiring simultaneous and coordinated action at more than one level of governance in the EU. There is an obvious danger in expecting too much to emerge from the Cardiff process if states do not take appropriate measures to implement EPI at home. Our analysis of the greenest states reveals how much work remains to be done in this regard. In pursuing EPI in the EU, leaders and laggards alike should be wary of promising more than the EU can deliver. After all, it is potentially inconsistent and counter-productive for states to set targets and timetables for different formations of the CoM, if the dynamics of policy making in the sectors concerned are determined mainly or wholly at the national level. It is, of course, entirely appropriate on subsidiary grounds to tackle EPI at more than one administrative level. However, in order to be strong and enduring, EPI initiatives will need to be co-ordinated both vertically and horizontally with one another. Both politically and institutionally the EU is very different to the states we have examined. However, we would argue that lessons learnt
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CONCLUSIONS
What does our admittedly brief comparison reveal about the prospects for achieving EPI in the EU? Interestingly, though not entirely surprisingly, states have chosen to follow different pathways to achieving EPI that reflect their own cultural and political make-up. Crucially, however, each path or perspective has its shortcomings, which implies that states should be wary of lesson drawing and policy borrowing. Our comparative analysis also clearly reveals that even the most environmentally progressive member states of the EU are still a long way short of achieving what might be considered full or strong EPI. The UK has chosen to try and green its traditionally strong and internally well co-ordinated systems of central government. Compared with other states, this amounts to a relatively top down approach to achieving EPI. However, the performance to date demonstrates unequivocally that EPI requires more than just strong governmental structures and procedures. It also requires strong political backing from the highest levels of government in order to win over more reluctant departments. If the UK is experiencing difficulties then it is safe to assume that states with far weaker structures and coordinating mechanisms (most notably the cohesion member states in the South of the EU 15 and of course the new applicants) have a veritable mountain to climb if they are to achieve anything remotely approaching strong EPI. The German case is instructive because it highlights the political and organizational difficulties of moving beyond pollution regulation to green the driving force sectors of environmental damage. In spite of past successes, on EPI Germany finds itself hamstrung by the
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GREENING THE EUROPEAN UNION at one level can only be fruitfully applied at other levels if the lesson drawing is sensitive to contextual characteristics of the case in question. For instance, member states can learn important lessons from the Cardiff process in terms of how to encourage and engage sectoral agencies in a long-term process of review and target setting. Possibly the greatest lesson that EU policy makers can learn from the unfolding experience of EPI at the national level is the need for strong central coordination to iron out contradictions between sectoral policies. This may take the form of inter-ministerial coordination (UK), SEA at the ministerial level (DK) or government-coordinated target group negotiations (NL). In many crucial respects, the best comparator is Germany. Encumbered by the same multi-level organizational problems as the EU, Germany has suffered the greatest problems in devising an appropriate coordination process. However, absent a basic level of central coordination and political support, all four case studies suggest that EPI will remain an environmental objective pursued solely by environmental agencies. In the EU the most appropriate candidates for the job of brigading sectoral agencies are probably the Commission President and the European Council of European Heads of State. If EPI is to stand any chance of succeeding in the highly sectorized and multi-levelled structures of the EU, it will need the sustained political backing of these, highly prominent actors.
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ACKNOWLEDGEMENTS
An earlier version of this paper was submitted in evidence to a UK House of Commons Environmental Audit Committee study of the Cardiff process of greening the EU. The authors are grateful to Rudi Wurzel and to Tim ORiordan for their perceptive comments. Responsibility for all remaining errors and omissions rests entirely with the authors.

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