- E Rehbinder, “Regulatory federalism: environmental protection in the European Community”, Conference Paper, Florence, 1990.
- Quantitative restrictions on exports, and all measures having equivalent effect, are prohibited under Article 34 of the EEC Treaty.
- D Wyatt and A Dashwood, Wyall and Dashwood's European Community Law (3rd ed, 1993), p 208. Weatherill and Beaumont observe that “[t]he vigour of Article 30 lies in its remarkable scope.” EC Law (Penguin, 1993), p 370.
- Case 8/74, Dassonville [1974] ECR 837 at 852, para 5.
- Article 36 EEC.
- [1981] ECR 1625.
- Case 72/83, [1984] ECR 1299. This case is discussed further in Section II, infra.
- Case 120/78 Rewe-Zentral v Bundesmonopolverwaltung für Branntwein [1976] ECR 649.
- Ibid, at para 9.
- In Case 240/83, Bruleurs d'Huiles Usagees [1985] ECR 532, discussed further below at n 17.
- EC Doc SEC(71) 2616 def of 22 July 1971.
- The first action programme covered the period 1973–76; the second encompassed 1977–81; the third covered 1982–1986; and the fourth expired in 1992.
- For a general summary see L Kramer, EEC Treaty and Environmental Protection (1990), at pp 3–18. For a recent compilation of environmental legislation see The Commission and DGXI, European Community Environment Legislation (1992), in eight volumes.
- For a summary of the energy-related legislation adopted under the Community's first four action programmes, see Hancher, (1989) Common Market Law Review at pp 478–482.
- Article 100: The Council shall, acting unanimously on a proposal from the Commission, issue directives for the approximation of such provisions laid down by law, regulation or administrative action in Member States as directly aifect the establishment or functioning of the common market.
- The Assembly and the Economic and Social Committee shall be consulted in the case of directives whose implementation would, in one or more Member States, involve the amendment of legislation.
- Article 235: If action by the Community should prove necessary to attain, in the course of the operation of the common market, one of the objectives of the Community and this treaty has not provided the necessary powers, the Council shall, acting unanimously on a proposal from the Commission and after consulting the Assembly, take the appropriate measures.
- Environmental measures might be taken in the context of other policies or measures, reflected in a legal base of, for example, Article 84 (transport policy) or Article 99 (fiscal measures). See further Kramer, (1993) Common Market Law Review, p 112.
- In fact, the matter was simply not challenged, no doubt in part because each Member State had a veto over proposed measures under Articles 100 and 235 through the requirement of unanimity.
- Case 240/83, [1985] ECR 531.
- Ibid, at p 549. pp
- Davidson, “The Single European Act and the Environment” (1987) 2:4 IJECL 259.
- Title VII of the SEA provides as follows:
- ‘!Article 130R: (1) Action by the Community relating to the environment shall have the following objectives:
- - to preserve, protect and improve the quality of the environment;
- -to contribute towards protecting public health;
- -to ensure a prudent and rational utilization of natural resources.
- Action by the Community relating to the environment shall be based on the principles that preventive action should be taken, that environmental damage should be rectified at source, and that the polluter should pay. Environmental protection requirements shall be a component of the Community's other policies.
- In preparing its action relating to the environment, the Community shall take account of: available scientific and technical data;
- - environmental conditions in the various regions of the Community;
- -the potential benefits and costs of action or of lack of action;
- -the economic and social development of the Community as a whole and the balanced development of its regions.
- The Community shall take action relating to the environment to the extent to which the objectives referred to in paragraph 1 can be attained better at Community level than at the level of the individual Member States. Without prejudice to certain measures of the Community nature, the Member States shall finance and implement the other measures.
- Within their respective spheres of competence, the Community and the Member States shall co-operate with third countries and with the relevant international organisations. The arrangements for Community co-operation may be the subject of agreements between the Community and the third parties concerned, which shall be negotiated and concluded in accordance with Article 228.
- The previous paragraph shall be without prejudice to Member States’ competence to negotiate in international bodies and to conclude international agreements.
- Article 130S: The Council, acting unanimously on a proposal from the Commission and after consulting the European Parliment and the Economic and Social Committee, shall decide what action is to be taken by the Community.
- The Council shall, under the conditions laid down in the preceding subparagraph, define those matters on which decisions are to be taken by a qualified majority.
- Article 130T: The protective measures adopted in common pursuant to Article 130S shall not prevent any Member State from maintaining or introducing more stringent protective measures compatible with this Treaty.
- On the issue whether Declarations appended to the Single European Act are in fact legally binding, see A G Toth, “The legal status of the declarations annexed to the Single European Act” [1986] 26 C M L Rev 803. Such a conclusion appears to conflict with the Article 31 of the Vienna Convention on the Law of Treaties; see further Hancher, (1989) Common Market Law Review, at p 486, and Vandermeersch, “The Single European Act and the Environmental Policy of the EEC” (1987) E L Rev 407 at p 415. Budlong notes that, irrespective of its legal effect, “the mere existence of such a reservation [sic] suggests less than full political commitment among Member States of the goal of environmental protection on a Community scale”. S C Budlong, “Article 130r(2) and the Permissibility of State Aids for Environmental Compliance in the EC” (1992) 30(2) Columbia Journal of Transnational Law 431, at p 443, n 41.
- For possible incompatibility between state aids for environmental compliance and the polluter pays principle, see Budlong, Supra, n 20, at p 455 et seq.
- Environmental policy is unique in this connection as no other policy is required to be so integrated: cf Kramer, Supra p 15, at p 123. On the integration of environment and energy policy, see Part III below.
- For discussion of joint meetings of Environmental and Energy Councils, see further below, Part III.
- This provision was sought by Member States like Denmark with strong national environmental policies who feared the erosioin of national environmental standards—a lowest common denominator for environmental policy. However, Article 130T makes clear that higher standards may only be enacted or retained where consistent with the EEC Treaty.
- This suggests that environmental quality objectives, rather than uniform emission standards, may be the preferred mechanism for reconciling environmental protection and regional development. Hancher suggests that this may render Article 130R more flexible in application than Article 100A, which requires the approximation (harmonisation) of laws (cf Hancher, Supra, p 14, at p 503), though in practice approximation may leave considerable scope for national variations.
- Supra, note 19, at p 262.
- Cf Vandermeersch, Supra, note 20, at p 422.
- In Article 3b. In the context of energy and environmental policy, “given the established role of the Community in regulating energy-related pollution, much of which has transfrontier implications, [the] relevance [of the subsidiary principle] as a constraint on internal Community action appears limited.” Hancher, Ibid, p 14, at p 503. Both Hancher and Kramer view the subsidiary principle as performing a largely political function: Hancher, Ibid, p 502, p 122; Kramer; Supra, p 15, at p 681. Weatherill and Beaumont remain sceptical as to whether Article 3b will “permit challenges to Community initiatives by states on the basis that they intrude on matters more efficiently dealt with at national level. At present, Article 3b EC, although doubtless a focus for political debate, seems scarcely justifiable”. Supra, p 3, at p 424 (footnotes omitted).
- Defined in Article 8A (added by the SEA) as “an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured in accordance with the provisions of this Treaty”.
- In Article 149.
- Steiner, Textbook on EEC Law (Blackstone Press, 3rd ed, 1992), at p 11.
- Thus removing one of the possible grounds for the ECJ's decision in Case C-300/89, the Titanium Dioxide case where it rejected the use of Articles 100A and 130S in tandem. It is submitted that the differences which still exist between Articles 100A(4) and Article 130 R-T, particularly in respect of the scope of derogations under 100A(4) and 130T, make it unlikely that utilisation of a dual legal base would pass unchallenged.
- An additional objective of Community policy on the environment is added to Article 130r(1), namely, “promoting measures at international level to deal with regional or worldwide environmental problems”. The reference to subsidiarity in Article 130r(4) is removed, in recognition of the inclusion of the principle in Article 3b.
- Emphasis added. This approach may provide a precedent for global attempts to reconcile trade and environmental protection, particular in the GATT. See J Cameron, p Mholo- Thamage and J Robinson, “Relationship Between Environmental Agreements And Instruments Related To Trade And Development” in UNCED, The Effectiveness of International Agreements (1992)475, at p 498.
- Kramer has repeatedly doubted whether the rules on free movement of goods have any “fundamental status”: cf Supra, n 15. Nonetheless, frequent reference to the free movement principles—goods, persons, capital and services—as the cornerstones of the EEC Treaty has a pervasive influence. Indeed, notwithstanding the lack of hierarchy in the objectives of the Community stated in Article 3 of the Treaty on European Union, the culture of dominance of free trade principles coupled with the milder wording used in respect of other policies (Article 3(k) being a case in point) suggests that the former may well prevail in practice. One reason for this is that the free movement principles depend in part for their enforcement upon individual persons and traders, whereas environmental provisions are primarily dependent upon public action at member State level.
- Cameron, et al, Supra, n 34, p 475.
- Case 302/86, Commission p Denmark [1988] ECR 4607; [1989] 1 CMLR 619. For comment see Kromarek, “Environmental Protection and Free Movement of Goods: The Danish Bottles Case” (1990) 2:1 Journal of Environmental Law 89; Gormley, (1990) 27 Common Market Law Review 825, 844; Sexton, (1991) 24 Cornell International Law Journal 563–593; Kramer, Supra, p 15, at pp 120–123 (1993 CMLR); and Weatherill and Beaumont, Supra, p 3, at pp 452–454.
- 30 ILM. 1594(1991).
- Opinion of the Advocate General (Sir Gordon Slynn), [1989] 1 CMLR 621.
- Ibid, at p 622.
- Either because the container was not technically adapted to the system of return, or the system of return established with respect to a particular new type of container will not ensure actual re-use of a sufficient proportion of containers, or an approved container of equal capacity is already available and appropriate for the intended use: Ibid, Judgment of the Court, para 2.
- A limit of 3000 hl per producer per year was imposed by Order 95 of 16 March 1984 on Danish producers and importers alike. There was also a test market derogation, permitting producers from other member States to test the Danish market with a beverage marketed in a bottle normally used for that beverage in the country of production. Further restrictions included a prohibition on the use of metal containers and the requirement that a return and deposit20scheme be established. The legislation is fully described in the Opinion of the Advocate General, at pp 622–623.
- Judgment, Ibid, para 6.
- Ibid, paras 8–9. The Court relied on the ABDU case (discussed Supra, p 17) and Title VII of the SEA.
- Ibid, para 22.
- In distinction to the Advocate-General who had considered both aspects of the scheme incompatible with Community law.
- Weatherill and Beaumont, Supra, p 3, p 453.
- Ibid.
- Case C-2/90 Commission p Belgium [1993] CMLR 365. For comment see Wybe Th Douma, “Walloon Waste Import Ban” (1993) 4:2 European Business Law Review 32; Hancher and Sevenster, (1993) CMLRev 351; Geradin, (1993) 18 ELRev 144.
- Hancher and Sevenster, Ibid, at p 358.
- Ibid, p 379 (Advocate General's First Opinion).
- It was also alleged that the decree was incompatible with two directives on waste. The argument failed with respect to Directive 75/442 as both the Advocate General and the Court held that this directive did not address intra-Community movement of waste. With respect to the second, the Court held that the Walloon decree was incompatible with the Directive which sought extensively to regulate intra-Community hazardous movements without scope for Member States to impose general prohibitions such as those contained in the decree. Ibid, p 395, paras 20, 21. This left the Court with the task of determining the compatibility with Article 30 of the Walloon decree in respect of non-hazardous waste.
- Ibid, p 396, para 26. See also the Second Opinion of the Advocate General (Jacobs), at p 383, which addresses the Belgian contention that the disposal operations amount to the provision of a service and as such should be judged against the provisions of the Treaty relating to free movement of services, not goods.
- Ibid, p 396, para 27.
- Ibid, p 396, para 29.
- Protection of human health is one of the exceptions found in Article 36, which was considered in the First Opinion of the Advocate General who “did not think it possible to adopt a wide interpretation of the ‘human health’ exception so as to permit restrictions on substances which do not threaten health or life but at most ‘the quality of life’”. Ibid, p 381. It should be recalled that the provisions of the decree subject to Article 30 at issue here are those concerning non-dangerous waste since the Advocate General (and the Court) considered the provisions of the decree pertaining to dangerous waste to be incompatible with Directive 84/631. Protective measures could only be adopted within the framework of this harmonising directive with recourse to the provisions of Article 36 precluded. It is clear that this must be a necessary consequence of a directive which seeks to harmonise measures for the protection of animal and human health and establish Community procedures to ensure observance of such measures, else the purpose of such harmonising measures would be subverted.
- Unlike the Danish bottle case, the Commission had not put forward any proposals for measures less restrictive upon intra-Community trade which would accomplish this objective. See Douma, Supra, p 49, p 34. In any event, the reasoning of the Court avoids the application of the rule of reason by focussing on Article 130R(2) and principles drawn from the Basle Convention: Hancher and Sevenster, Supra, p 50, at p 362.
- Ibid, p 397, para 36.
- The converse of the “nimby”—not in my back yard—syndrome.
- These principles are derived from the 1989 Basel Convention on the Control of Transborder Movements of Harzardous Waste, to which the EC is a party.
- Paraphrasing paragraph 33 of the Judgment wherein this competing view is set forth.
- Case C-155/91 Commission v Council judgment of 17 March 1993. The Commission had proposed Article 100A as the legal base for Directives 91/156 and 91/689, both initiatives in the waste field, but the base was changed to Article 130S by Council. See Hancher and Sevenster, Supra, p 50, p 365.
- See Weatherill and Micklitz, “Consumer Policy in the European Community Before and After Maastricht” (1993) Journal of Consumer Policy (forthcoming, text accompanying notes 56–57).
- Ibid.
- See in particular, G White, “Energy Policy” in EC Commission, Thirty Years of Community Law (1983), Ch VI; Daintith and Hancher, “The Management of Diversity: Community Law as an Instrument of Energy and Other Sectoral Policies” (1984) 4 YEL 123 and ibid, Energy Strategy in Europe: The Legal Framework (1986); and C J Audland, “European Community Energy Strategy and its Legislative Implications” (1983) JENRL 9.
- The following discussion will be largely confined to the application of the EEC Treaty to the energy sphere.
- For further discussion of this point see the Campus Oil case infra, n 77.
- A V Lowe, “Legal Issues of the European Charter” (1991) 2:4 Utilities Law Review 155, at p 156. This is expressed in a 1962 UN General Assembly Resolution on Permanent Sovereignty over Natural Resources (UNGA Res 1803 (XVII)) which declares that “[t]he exploration, development and distribution of such resources… should be in conformity with the rules and conditions which the peoples and nations freely consider to be necessary or desirable with regard to the authorisation, restriction or prohibition of such activities.”
- George, Politics and Policy in the European Community (2nd ed, 1991) p 126; F McGowan, “EC Energy Policy” in A M El-Agraa (ed), The Economics of the European Community (3rd ed, 1990), p 246.
- See J G van der Linde and R Lefeber, “International Energy Agency Captures the Development of European Community Law” (1988) 22:5 Journal of World Trade 5, wherein they conclude that the establishment of the IEA created new institutional fragmentation in the energy sector and an impediment to the development of a Community energy policy (at pp 24–25). George describes the energy sector “as the most spectacular failure of the process of integration.” Ibid, p 116.
- The Spaak memorandums, on the basis of which the treaties of Rome were negotiated, assumed that the choice for Europe was between continued dependence on high-cost coal and movement to low-cost nuclear energy. Oil was not mentioned at all. This neglect, according to George, was “disastrous” in the context of the development of a common energy policy: S George, Politics and Policy in the European Community (2nd ed, 1991, OUP), at p 122.
- Kramer, EEC Treaty and Environmental Protection, p 22, para 1.50.
- McGowan, Supra, n 69, p 244.
- This reflected the same aims as the ESCS's “Protocol of Agreement on energy policy” adopted in 1964. See D Swann, The Economics of the Common Market (7th ed, 1992, Penguin), at p 266.
- Notification of investment projects had existed in respect of coal and steel projects since the Paris Treaty.
- McGowan, Supra, n 69, p 246.
- Case 72/83 [1984] ECR 2727, an Article 177 reference. For comment, see Weatherill and Beaumont, Supra, p 3, pp 402–404; Oliver, (1985) 22 Common Market Law Review 307; and Minor, (1984) 9 European Law Review 340.
- Ireland had no crude oil resources of its own and only one oil refinery which had previously been operated by several major oil companies. The measures in question arose as a consequence of the threatened closure of the refinery, which led to its compulsory acquisition by the Irish Government and the regulations at issue in the case.
- The argument that free movement of goods would jeopardise national security is infrequently advanced: for discussion see Weatherill and Beaumont, Supra, p 3, p 402.
- Ibid.
- One of the arguments made against the Irish measure was that it could not achieve its objective of maintaining security of supply since refining capacity could be of no assistance in a crude oil crisis. Clearly the Court did not accept this argument.
- Ireland still had to satisfy the second sentence of Article 36 which provides that such restrictions shall not constitute a means of arbitrary discrimination or a disguised restriction on trade between member States. Was the refinery unable to obtain the amount of oil necessary to maintain a domestic refining capacity without these compulsory measures? Was the quantity of oil importers were required to purchase no higher than necessary to attain its objectives of security of supply? As the case was an Article 177 reference the application of the principles of proportionality and alternative means was a matter for the national court: Weatherill and Beaumont, Supra, n 3, p 403.
- Case 231/83, Cullet v Centre Leclere [1985] ECR 305. Action must be justified under one of the heads in Article 36; if there is also the incidental achievement of broader economic objectives this does not preclude reliance on Article 36: Case 118/86, Openbaar Ministerie p Nertsvoederfabriek Nederland BV [1987] ECR 3883. In Cullet, France also argued (unsuccessfully) that public policy reasons prevented the removal of statutory controls since this could lead to an all-out price war with social unrest and even violence: cf Weatherill and Beaumont, Supra, n 3, pp 400–401.
- Environmental protection was also conspicuous by its absence.
- “Liberal winds are blowing through European energy” The Times, 12 April 1993, p 34. See, generally, S Padgett, “The Single European Energy Market: The Politics of Realisation” (1992) XXX JCMLS 53; Hancher, “A Single European Market for OU and Gas—The Legal Obstacles” (1990) 8 JERL 77.
- Stimulus for an internal energy market came from developments in other sectors: “The potential for radical action was indicated by a number of moves taken by the competition directorate of the Commission towards other “utility” industries…. In the field of telecommunications it sought open access for equipment and service sales, using powers under Article 90 to do so. These moves not only demonstrated a willingness to act but also a range of mechanisms which could be used in other sectors. The further the policy went in one industry the more likely it would be applied to others.” (McGowan, Supra, p 69, p 249).
- COM(88) 238, pp 9–10.
- The CEN and CENELEC (the European standards bodies) have been assigned the task of establishing an inventory of existing standards in each energy sector and proposing standardisation programmes. However, as Hancher points out there is a dearth of standards to standardise: Supra, p 14, p 509, p 143.
- The first communication on energy and the environment also avoids such discussion, in fact it does so explicitly: see COM (1990) para 10, discussed further in Section III.
- EC Commission Background Report, “European Energy Policy”, ISEC/B31/92, 4 December 1992, p 1. Current policy was set in 1986 for the period 1986–1995: Council Resolution of 16 September 1986, OJ C-241, 25 September 1986. 1995 is also the review year for the Fifth Environment Action Programme.
- It is beyond the scope of this paper to discuss measures designed to complete the single energy market. Three phases of reform were proposed by the Commission to achieve a single energy market, commencing with two utility directives in 1990 to facilitate power exchanges. A further directive sought to improve transparency in pricing through a requirement that gas and electricity utilities supply details of their charges to the Commission. With the goal of competition amongst suppliers of energy to end-users, the consumers of energy, the Commission proposed further directives to “unbundle” vertically organised utilities and to facilitate limited third-party access to transmission systems. The Commission's work programme for 1993–94 expressly encompasses “the establishment of an internal energy market and the need for common rules for electricity and natural gas markets, as well as continued negotiations on the implementation of the European Energy Charter in Central and Eastern Europe.” EC Commission, Background Report “The Commission's Work Programme 1993–94”, ISEC/B8/93, 11 March 1993, at p 4.
- Eg the Energy Charter, which is to include a protocol on environmental concerns. The Charter is described as contributing towards “diversifying sources of supply and integrating the environmental dimension” and is designed “to promote the construction of a larger European energy market taking due account of environmental protection requirements”. See EC Commission, Background Report, Energy Policy in EC,20ISEC/B23/91, 9 August 1991, at p 2.
- What follows is but a brief outline. For further detail, see EC Commission, Background Report, European Energy Policy ISEC/B31/92, 4 December 1992, pp4–6; see also Eurobrief, European Business Law Review, January 1993, at pp 7–10. On both fiscal and non-fiscal measures, see F Yamin, “The Regulation of Energy Efficiency in The European Community—Recent Developments” (1993) 1 ELNI Newsletter 5.
- OJ L185, 17 July 1990.
- OJ L307, 8 November 1991.
- Directive on the energy efficiency requirements for new hot-water boilers fired with liquid or gaseous fuels, OJ L167, 22 June 1992.
- Directive on the indication by labelling and standard product information of the consumption of energy and other resources by household appliances, OJ L297, 13 October 1992.
- COM(92) 180, 29 June 1992.
- This matter was most recently considered at a joint meeting of the Energy and Environmental Council in April 1993. However, no agreement was reached on the need for a carbon energy tax “despite long and intensive negotiations”: WE/17/93, 29 April 1993. Not only do some Member States, like the United Kingdom, remain unconvinced of the need for an EC-wide tax, but external pressure against the tax is also being exerted. For example, the proposed tax was the main topic of concern in a joint EC-Gulf Cooperation Council meeting in May 1993: WE/19/93, 13 May 1993.
- COM(92) 36, 28 February 1992.
- In its 1990 report on energy and the environment the Commission explicitly acknowledged that “[t]he most direct means of allowing markets to incorporate the risk of environmental stress is to assure that energy prices reflect their full social costs”. (COMB9 (369) final, p 20, para 57). In November 1992 the Commission communicated to Council and the EP a strategy paper on industry and the environment which suggests that priority will be given to policy measures based on the “competitive functioning of markets” with economic instruments “set to play an increasingly important role in the overall approach”—but without a clear proposal of what that role should be. See “EC environment policy to get market dimension” (1992) 214 ENDS Report 39.
- Budlong, Supra, p 20, p 467.
- So described by Sir Leon Brittan, (1992) Public Law 567, at p 574.
- A new title on “Trans-European Networks” is added by the Treaty on European Union pursuant to which the Community shall contribute to the development of trans-european networks in the area of, inter alia, energy infrastructures (Article 129b(1)); the Community shall also take action aimed at promoting the interconnection and interoperability of national networks as well as access to such networks (Article 129b(2)). “[E]ncouragement for the establishment and development of trans-European networks” is also one of the listed activities of the Community under Article 3(n).
- A recent study has concluded that joint Council Meetings offer a suitable approach to the integration of environmental policy into other policies: Baldock et al, The Integration of Environmental Protection Requirements into the Definition and Implementation of other EC Policies (IEEP, 1992). The Report is summarised in the ELNI Newsletter, No 1, 1993, at p 32. Many Directorates General are establishing environment divisions, but they are understaffed and overworked: Ibid.
- 2005 for the UK.
- See EC Commission, Background Report, Energy Policy in EC, ISEC/B23/91, 9 August 1991, at p 3.
- COM89 (369) final.
- Ibid, p 3.
- Ibid, p 18, para 51.
- See Kramer, Focus on European Environmental Law, p 150.
- Ibid, para 41.
- But see, generally, R Carbaugh and D Wassink, “Environmental Standards and International Competitiveness” (1992) 16:1 World Competition 81. They conclude that “trade and relocation have not been greatly affected by the cost of environmental compliance for two reasons: (1) environmental compliance costs, in most countries, are a relatively small fraction of production costs; (2) environmental cost differences, especially among industrial countries, appear minor as countries have moved toward the adoption of similar environmental standards”. (at p 89).
- The Commission cites with approval the Canadian Chemical Industry's commitment entitled “Responsible Care”: Ibid, p 17, para 47.
- Ibid, p 17, para 48.
- Ibid, p 29, para 83.
- COM92 (23) final. The programmes map out the Commission's environmental policy for the next five years or so and provide an indication of the legislative initiatives which may be expected to be taken in the environmental sphere. The Fifth Action Programme is to run from 1993–2000. It was agreed by Council on 15 December 1992, paving the way for implementation of the programme.
- Supra, note 1. Chapter 7 focuses on energy.
- Ibid, p 43.
- This target-and-review based approach is derived from Dutch and UK practice: “Towards sustainable development: A blueprint from Brussels” (1992) 204 ENDS Report 20.
- OJ L206, Vol 35, 22 July 1992. Its objective is to contribute to the development and implementation of EC environmental policy by financing priority environmental actions within the Community, technical assistance measures with third States in the Baltic and Mediterranean regions, and, exceptionally, contribute finance under international agreements. See (1992) 212 ENDS Report 33.
Journal of Energy & Natural Resources Law
Volume 12, 1994 - Issue 1: International Energy Trade