A new framework for policy making should be based on clearer fundamental principles than hitherto, Unice argues. They should include the principles of subsidiarity and proportionality as well as the precautionary principle, which the association says should be applied consistently "recognising a shared responsibility of all stakeholders in the life cycle of environmental impacts".
Clearer definitions are also needed, according to the association. It picks out waste management as an area where the EU's broadening of the definition of wastes to include those destined for recovery "has resulted in a great deal of problems". "It is time to reconsider the fundamental basis of EU waste management policy," Unice says. The association proposes "integrated resource and waste management" as a new guiding principle, which it says could give waste generators and processors the flexibility to choose options with the lowest overall environmental impact.
The potential role of the "full range" of environmental policy instruments should be clarified, the memorandum says, including voluntary initiatives and market mechanisms. Unice adds that all instruments should be evaluated for their environmental efficiency, ease of administration, flexibility, appropriateness and consistency with the EU's single market.
A fourth ambition set by Unice is for clearer definition of the role of different stakeholders in the formulation and implementation of environmental policies. The positive potential role of broader stakeholder involvement has now become of "key importance," Unice's Daniel Cloquet told ENDS Daily. The association held its first stakeholder seminar with environmental NGOs as well as policy makers this summer, he said, and wanted to get involved in more such discussions.
Unice suggests air quality, climate change and waste management as issues on which focused efforts should be made to increase the level of multi-stakeholder dialogue. The association is concerned that existing legislative instruments aiming at cleaner air "are running into the problem of diminishing returns". It is particularly worried about the potential costs involved in implementing the European Commission's new proposals to set strict national ceilings on emissions of four key air pollutants. Though not mentioned in the memorandum itself, Unice also believes that multi-stakeholder dialogue is needed to address transport issues, according to Mr Cloquet.
Unice, tel: +32 2 237 6511. References: "Unice Agenda for Promoting Sustainability: Memorandum to the European Institutions". (posted on the web site).
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