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Friends of the Earth Europe, Greenpeace, Justice and Environment and European Environmental Bureau position paper regarding the Review of the Environmental Impact Assessment (EIA) Directive

We welcome efforts by the European Commission to review the functioning of the Environmental Impact Assessment (EIA) Directive and to identify areas which need improvement. We also appreciate that the Commission has facilitated public consultations through web-based questionnaires. However, the questionnaire provided does not allow respondents to express opinions on all the important aspects of the Directive, and specifically on its functioning in practice. It also does not allow respondents to provide examples to support their arguments, nor does it provide space for additional comments | O Friends of the Earth Europe GMeNWAcs European Network of Environmental Law Organizations EUROPEAN ENVIRONMENTAL BUREAU Friends of the Earth Europe Greenpeace Justice and Environment and European Environmental Bureau position paper regarding the Review of the Environmental Impact Assessment EIA Directive1 Based on legal expertise provided by the Environmental Law Service Czech Republic Introduction We welcome efforts by the European Commission to review the functioning of the Environmental Impact Assessment EIA Directive and to identify areas which need improvement. We also appreciate that the Commission has facilitated public consultations through web-based questionnaires. However the questionnaire provided does not allow respondents to express opinions on all the important aspects of the Directive and specifically on its functioning in practice. It also does not allow respondents to provide examples to support their arguments nor does it provide space for additional comments. For these reasons we are submitting this paper to highlight what we consider to be the most pressing and important areas for improvement in the EIA Directive and in standards of environmental assessment and decision-making in general. The document includes short examples illustrating our main points. General evaluation of the EIA Directive Despite important problems and deficits concerning the current content of the Directive and namely of its implementation in practice which are detailed below the institutes and requirements established by the Directive can be considered as some of the most efficient horizontal measures of environmental protection in existence in Europe. The EIA procedure is in keeping with the polluter pays principle and aims to reduce pressure on the environment. This leads ultimately to social and economic costs for society being reduced. 1 This material reflects common experiences of our member organisations and is based on previously published NGO materials among .