2.1.5. Greening formulation
Background
The action document should concretely and explicitly integrate environment, climate change and DRR into the action design, in particular in the definition of the objectives, outcomes, outputs, activities and/or indicators.
Entry points for formulation
➡️ Build on the greening steps from identification
✅ Seek further opportunities to maximise positive contributions to environmental sustainability, biodiversity, climate resilience and low carbon development. The Quick Tips for the integration of environment and climate change can be used as inspiration to identify options to enhance positive contributions.
✅ Ensure climate proofing of the project and integrate measures to address its vulnerability to environmental degradation processes that can affect its effectiveness and sustainability.
✅ Avoid excluded activities under Article 29 of the NDICI-Global Europe Regulation (see section above on Identification) and ensure compliance with the national environmental and climate legislation.
✅ Wherever relevant, integrate environment and climate change concerns and objectives in the definition of the objectives, outcomes, outputs, activities and/or indicators; and ensure that the proposed implementation modalities/implementers will be conducive to their implementation.
✅ Ensure that formulation of the action is informed by meaningful consultations with key environment and climate stakeholders.
✅ Mobilise specific expertise to address environment and climate change opportunities and risks and foresee specific attention to these matters during milestones of the design process.
✅ Ensure that the design of the action respects the DNH principle. Refer to the corresponding section under Identification for more details.
✅ Involve the thematic units on environment and climate change in DG INTPA or DG NEAR as part of the co-creation process[15].
➡️ Finalise the screening process
The results of the environment & climate risk screening must be summarised in the mainstreaming section of the action document and annex f3 to the action document[16] must provide the rationale for the risk category and for whether or not an SEA, an EIA and/or a CRA is required. The questionnaire in Annex f3 must also indicate the opportunities to minimise environment and climate risks, and maximise opportunities to contribute to environmental sustainability, climate resilience and low-carbon development, even in the case that an SEA, EIA and/or a CRA is not required.
For actions with a potentially high environment- or climate- risk[17], it is recommended to engage partners and key stakeholders in the screening process. Annex 5 on Sources to understand the environment and climate change context can be useful to apply the screening.
✅ If the screening indicates that an EIA, SEA or CRA is necessary, ensure sufficient financial resources are available for their preparation. These can be from the action’s budget or from other sources such as ‘Support Measures’ or a ‘Cooperation Facility’ potentially available at EUD level.
➡️ (If relevant) finalise any required environmental or climate assessments
Ideally, the environment & climate risk screening should be undertaken during identification, or even programming, in which case it is good practice to complete any required assessments in time to inform the formulation of the action. However, these assessments can take time to complete and there is a possibility that they may not be ready by the time the funds have to be committed.
If an EIA is required for a particular project/activity under national legislation, its completion will be mandatory before development consent can be given.
Early completion is also particularly relevant for SEA, which should inform the design of a budget support programme. The SEA approach should be adapted to the stage at which the formulation of the national/ sector strategy in question is at. Ideally SEAs should be an integral component of the policy making/ planning process, although often they will be prepared on the basis of an already advanced or even a final version. This is why it is encouraged to identify the need for an SEA as early as possible, even from the programming phase.
➡️ Develop specific green measures and indicators
✅ Identify options to minimise the action’s adverse impacts on the environment and climate, which should be integrated into the design of the action independently on whether an SEA, EIA and/or CRA are required. The Quick Tips provide concrete ideas.
✅ Identify climate-proofing measures and other measures necessary to address the potential impact of environmental degradation processes on the project.
✅ Identify indicators to measure progress on the achievement of positive environmental and climate objectives, and ensure the effectiveness of adverse impact mitigation measures. In the latter case, and for high-risk activities, these indicators will be provided by the Environmental Management Plan (EMP) and/or the Climate Risk Management Plan (CRMP).
➡️ Score policy and Rio markers
✅ Score the policy markers for aid to environment and DRR, as well as the Rio markers as either ‘principal objective’, ‘significant objective’ or ‘not targeted’. Refer to the OECD DAC eligibility criteria and guidance available to ensure the correct use of the markers. A compilation of guidance material on the relevant markers can be found here.
✅ Remember to consult the thematic units dealing with environment and climate change early in the design and at the latest as part of the quality review processes.
➡️ Ensure partners’ processes are aligned
When it comes to the environment & climate risk screening and ensuring the adherence to do the DNH principle, partner organisations can apply their own processes and safeguards, as long as they are not less stringent than the EU’s screening procedure described in this toolbox. Please keep in mind that partner organisations are not pillar-assessed for their environmental and climate safeguards and standards.
✅ Enquire about the environmental policies and safeguards used by the selected implementing partners to ensure alignment with the minimum requirements defined in this toolbox. Assistance can be obtained from the thematic units and their support facilities to this effect.
References
[15] INTPA: units F1 and F2 (notably via the CCT/RCT/TCT), NEAR: unit A3
[16] As per the INTPA Companion to financial and contractual procedures applicable to external actions financed from the general budget of the EU and from the 11th EDF.
[17] Sectors with potentially high environment and climate risk include: agriculture and land use change, energy, transport, water, private sector development, urban development and tourism.