Implementation and Integration of EU environmental policies and directives; cutting the Gordian knot This is a preliminary version of the article published in the journal Environmental Policy and Governance Beunen, R., W. van der Knaap & R. Biesbroek, 2009. Implementation and integration of EU directives. Environmental Policy and Governance 19 (1): 57-69 http://onlinelibrary.wiley.com/doi/10.1002/eet.495/abstract Implementation and integration of EU environmental policies and directives; Cutting the Gordian Knot1. Wim van der Knaap & Raoul Beunen Land Use Planning Group, Wageningen University and Research Centre, Wim.vanderKnaap@wur.nl; Raoul.Beunen@wur.nl (+31-317 483849 / + 31-317 482093) Abstract: The EU is gaining importance in the field of sustainable development. More than 200 directives have been adopted by the European Union in the area of environmental policy as well as hundreds of other measures (Barnes & Barnes, 1999). Many environmental directives have been formulated to promote environmental issues embedded in planning and decision making processes. Examples are the Water Framework Directive, Birds and Habitats Directive, Ambient Air Quality Directive, Floods Directive, or several Environmental Impact Assessment Directives. There is a growing awareness about these directives and their importance for planning and decision making, but not much is know about their combined impact on the environment. In our paper we will discuss the implementation of the Water Framework Directive and the Birds and Habitats Directive in the Netherlands. Although these directives aim to strengthen each other, there are also practices in which they are conflicting. Studies show that the focus of practices is much more on legal and procedural aspects of planning and decision making and that environmental goals are fading into the background. We will discuss how different actors deal with the directives and how actions of different actors are often counterproductive for the region. The different ways in which actors frame the environmental issues are important explanations for the gap between the environmental goals of the directives and the ways in which these directives are implemented in practice. We argue that responsible actors must dare to make the necessary decisions in order to achieve a coherent regional sustainable development. Keywords: Spatial Planning; Sustainable conservation; EU environmental policies; Water Framework Directive; Birds and Habitat Directive 1. Introduction The European Union is becoming an important policy actor in the field of sustainable development. More than 200 directives have been adopted by the European Union in the area of environmental policy as well as hundreds of other measures (Barnes & Barnes, 1999). Many environmental directives have been formulated to promote environmental issues in planning and decision making processes. Examples of such directives are the Water Framework Directive, Birds and Habitats Directive, Ambient Air Quality Directive, Flood Management Directive or several Environmental Impact Assessment Directives. Directives have become an important tool for the implementation of European Union’s policies (Levi-Faur, 2006; Radaelli, 2003; Majone, 1994). Every year 100ths of legislation papers pass the EU (Hix, 2005). Majone (1997) explains this emphasis on legislation because EU possibilities to tax and spend are greatly constrained. Barnes and Barnes (1999) emphasise that European legislation is necessary to counterbalance the disadvantages of other economic instruments, like subsidies, 1 For those who don't know, a "Gordian knot" is a historical legend (or truth?) of a knot tied by Gordius, king of Phrygia, held to be capable of being untied only by the future ruler of Asia, and cut by Alexander the Great with his sword. The term has come to refer to an intricate problem, especially a problem insoluble in its own terms; a question that keeps leading you endlessly in loops, circling back around to the origin. If there was a solution to the original knot-that-could-not-be-untied, it was a mystery...and since Alexander cut the knot, it's a mystery that will never be solved. Wim van der Knaap & Raoul Beunen 1 Implementation and Integration of EU environmental policies and directives; cutting the Gordian knot taxes, or voluntary agreements. Because there is also uncertainty and mistrust involved in these processes it is almost a requirement to define explicit rules and legislation. Despite positive results in some policy fields, the concerns about the problematic implementation and enforcement of EU environmental policies remain (Barnes & Barnes, 1999). One of the main reasons is the lack of political will to deal with environmental issues, especially if measures have financial implication or threaten national political interests. These problems show that implementation is not just a rational-follow up but a process in which different actors compete over the meaning and the consequences of a policy. Implementation is the continuation of politics by other means (Pressman & Wildavsky, 1973). The struggle over ideas that characterises policy formulation does not stop once a policy is drawn, but continues during the implementation phase. Hix (2005) describes the outcomes of political processes as the sum of personal wants and desires of actors (preferences) and the formal and informal rules that determine how collective decisions are made (institutions). Policy reviews, evaluation or implementation studies, and monitoring programmes are necessary to identify the problems that occur in the implementation process. The lack of success is not the only reason for concern. There is also a lot of criticism about European directives. People dislike the top-down approach, the technocratic nature, and the uncertainties that these directives cause in planning and decision making practices. Implementation studies can provide further insights in such matters, for example how they affect the context of decision making. Policy analysis is therefore not only useful because it gives better insights in the implementation process, but also because these studies give insights the political implication of the European directives (Fischer, 2003). Democracy is not only an issue when a policy is formulated, but also when policies affect people during the implementation phase. Studies towards the implementation of the Water Framework Directive and the Birds and Habitats directive in the Netherlands show that the focus of practices is much more on legal and procedural aspects of planning and decision making and that environmental goals are fading into the background (Beunen, 2006; Verschuuren & Van Wijmen, 2002; CEC, 2006; CEC, 2007). Although these directives aim to strengthen each other, there are also practices in which they are conflicting (Grimeaud, 2004). In this paper we will discuss both implementation processes and their interactions. This exercise gives more insight in the (im)possibilities of European environmental directives and the consequences these directives have for planning and decision making practices in the member states. The aim of this paper is to provide further insights in the implementations processes and to use the experiences in the Netherlands to formulate recommendations for the implementation of European environmental directives. In the next paragraph we present a theoretical framework which is used to study the implementation of the Water Frame Directive and the Birds and Habitats directive in the Netherlands. The results of these studies are presented in paragraph 3. In paragraph 4 the different implementation processes are compared and used to generate more general principles. These are discussed in paragraph 5 and we will end the paper with conclusions and some recommendations. 2. Theoretical framework There is an ongoing debate about the European directives. For all actors it is important to know how European directives affect planning and decision making and how they affect the environment. Such studies cannot be limited to outcomes and results. It is important to take account of the whole implementation process. In planning literature this is described as the performance principle (Faludi, 2000; Hopkins, 2001). Are plans and policies used in decision making and do they affect actions? Only if more is known about the performance of European environmental directives is it possible to discuss whether or not their objectives have been achieved. From formulation to implementation, the legislation process is lengthy and involves a great many actors. European environmental directives thus forms networks of actors, all somehow involved in the designation and implementation of these directives (Liefferink et al., 2002). Implementation literature, with roots going back to the late 1970s, emphasizes the importance of the process, the institutions and actors involved, and their interactions (Mazmanian & Sabatier, 1983; Schofield, 2001; Barrett, 2004). Insight in the interplay between preferences and institutions gives insight in how the European Union works. The way the directive is applied also causes differences in implementation (the conformance aspect). People who use the directive as a guideline will interpret and use the texts of the legislation in a different way than people who cling to the letter of the law. Styles of regulation differ between Member States and between organisations involved in the implementation of the environmental directives (Terpstra & Havinga, 2001; CEC, 2007). Wim van der Knaap & Raoul Beunen 2 Implementation and Integration of EU environmental policies and directives; cutting the Gordian knot 3. Case the Netherlands 3.1 Water Framework Directive The overall objective of the Water Framework Directive (WFD, 2000/60/EC) is to achieve a good ecological status for all rivers, lakes, estuaries, coastal waters and groundwater in 2015, by a progressive reduction of emissions of hazardous substances to water. This has been formulated as an objective for all EU member states. The WFD proposed common principles to coordinate the protection of Community waters in terms of quantity and quality, to promote sustainable water use, to contribute to the control of transboundary water problems, to protect aquatic ecosystems, and terrestrial ecosystems and wetlands directly depending on them, and to safeguard and develop the potential uses of Community waters’ (CEC, 2000, (art 22-23) p.3). Each Member State is obliged to construct programme measures before December 2009, made operational by 2012 to adhere to these pressures. By 2015, the environmental objective of the directive must be achieved (CEC, 2006). The first stage of the implementation process has been reported in March 2007 (CEC, 2007) and it also made recommendations for the next important milestone, the river basin management plans (due in December 2009). The overall comments, based on this first progress report are that member states must do more to achieve the directive’s objective; the current status of EU waters is worse than expected (CEC, 2007). One of the indicated shortcomings is the inappropriate transposition of the directive into national law (CEC, 2007). Another shortcoming is the considerable lag by a number of member states in incorporating economic instruments into water managements systems. The Netherlands have identified 95% of their waters as artificial (not natural) water bodies for which the WFD should be implemented and is one of the three spots with such a high percentage. The Dutch government estimates that about 98% of the water bodies will be at risk not to meet the EU-requirements in 2015. Studies on the Dutch situation and the implementation progress mention several shortcomings (e.g. Elbersen et al., 2006; Leenders et al, 2006; Hommes-Folkerts, 2006). Although in the CEC-report of 2007 the Dutch situation is not that worse, the Netherlands still need to make an extra effort. In 2009 all the 110 identified river basin areas in the EU should have a definite management plan. In the study by Hommes-Folkerts (2006) about the implementation process in a sub river basin area “Rijn-Oost” she concluded that water managers cannot integrally approach the water system any more due to procedural requirements from the EU directives. Each WFD goal is now leading to separation based on old structures, such as groundwater should be monitored and managed by provinces, while physical and ecological aspects are the responsibility of the water boards. Furthermore she noticed that only water boards were occupied at that moment with the WFD implementation. No connection and integration with other policy areas like the habitat directive occurred and there was little or no interaction with the community. Also the cooperation between several governments is not leading to the desired result. There are too many participants, each with there own interests and there own decision process. Little to none direction and central guidance is received from the national level. The way the Dutch water management is organised creates complex situations that slow down and blur the process to a great extent. A lot of the implementation has to be done by the responsible water managers, but they are uncertain about what should be done. This uncertainty also paralyses the implementation process. Next to water quality also financial and stakeholder participation were important driving factors in the Rijn-Oost area. Because of tight regulations from the WFD and the blurred process, the water managers reviewed the implementation process as not flexible and adaptive. As a result they focussed more on the process and the required legal steps instead of the quality of the implementation and integration with other spatially related fields. This made an integral water management approach not directly matching with the WFD regulations. One of the observations, made by Hidding (2006) concerns the way the Dutch planning culture has to cope with EU directives. A common practice in the Dutch planning is that in the national, regional and local plans there is more liberty for negotiations (the famous Dutch approach of “polderen”). With the EU directives this room for discussion and adaptation to local situations will disappear. The way the Dutch approaches spatial developments (for instance by allowing more and more stakeholders to participate) seems in contradiction with the way directives have to be more strictly implemented. Furthermore, the EU-directives are becoming “sticks” for some actors to pursue legal actions against other actors, including governments. 3.2 Birds and Habitats directive The main objective of the European Birds Directive (79/409/EEC) and the European Habitats Directive (92/43/EEC) is to protect natural habitats and the wild flora and fauna in the member states of the EU. Member States have to designate Special Protection areas under the Birds Directive and Special Areas of Conservation under the Habitats directive. Together these areas form an European network of protected areas that is called Wim van der Knaap & Raoul Beunen 3 Implementation and Integration of EU environmental policies and directives; cutting the Gordian knot Natura 2000. Member States also have to transpose the legislation of both directives into their own laws. These laws form a framework for planning and decision making about activities that affect protected areas or protected species. All activities that might have significant effects on protected nature values need to be carefully assessed and may only be allow if there are no alternative solutions and in case of overriding public interest. The European Birds and Habitats directive received quite some attention in the Netherlands after a nature conservation organisation successfully appealed to these directives during a lawsuit against the construction of a business park, (Van der Zouwen & Van Tatenhove, 2002; Verschuurer & Van Wijmen, 2002). This event made clear that European directives need to be taken into account in decision making even if they have not formally been transposed into the national laws. With this knowledge in mind, other people too started to appeal to European directives to protest against all kinds of plans and projects. The number of law suits in which the Birds and Habitats directive played a part, increased from zero to about one hundred per year – and these law suits are just the tip of the iceberg. In many other planning and decision making processes, the Birds and Habitats directive and their possible consequences for the decision making process were discussed among the participants engaging in the process. A review of the law suits in which the Birds and Habitats directive played a role showed that many plans and project have been delayed but that most of them nonetheless proceeded in the long run (c.f. Kistenkas and Kuindersma, 2005). Interviews with decision makers at national and provincial level made clear that only a very small part of the licence requests were denied because they were in conflict with European nature conservation laws. Although the Birds and Habitats directive gained a lot of attention, their actual effect on land use is limited. What has changed are the procedures of decision making. Strict legal interpretations put more emphasis on the procedural aspects of decision making, like for example the presence of ecological reports. Such reports were not used to promote nature conservation objectives, but to sustain decisions already taken. The necessity of such reports was observed at court cases leading to projects and plans being cancelled. Courts have judged decisions mainly by looking at whether the necessary reports were conducted, and not how these were conducted, or what was done with the results. Most decisions that were cancelled in court simply lacked awareness of the requirements of the Birds and Habitats directive. This does not surprise because most actors simply did not know about the European directives or did not know how to apply them – owing to a lack of attention, knowledge or awareness. The court cases led to a growing awareness of the directives and many people learnt “how to deal with them”. They learned how to meet procedural requirements and what actions are necessary in order to avoid juridical problems that might delay or stop plans and projects. Most projects could go on in the long run and the number of law suits due to the Birds and Habitats directive decreased. Although there is indeed a growing awareness of the Birds and Habitats directive, this does not necessarily lead to a better protection of species and their habitats. Instead, there has been a shift to more conflicts, more decision making through lawsuits and an increase of the cost of decision making because of the many reports that need to be made to sustain decisions. Decision making about nature conservation issues has thus become more bureaucratic and more legalistic. 4. Implementation and integration of European environmental policies Implementation The studies showed that actors struggle about responsibilities and about the meaning of legislation. They also use legislation while they compete over space. Legislation is only one of the many aspects influencing planning practices. The European environmental directives have been used by different actors to achieve their own objectives. In (local) planning practices the directives have become new means that are used by competing actors. In these practices actors not only “use” law as a stick, but they also compete about the way the law has to be interpret and applied. Research should thus include insights about how laws affect outcomes but also how they affect the context of decision making. The approach of the Water Framework Directive and the guidance documents raise the issue of uncertainty in different ways and offer different approaches to deal with it. This normative and informational uncertainty lead to formal compliance with the directives in stead of focussing on what is necessary on a local or regional level to facilitate required developments. Furthermore, high costs involved for the implementation of the Bird and HabiWim van der Knaap & Raoul Beunen 4 Implementation and Integration of EU environmental policies and directives; cutting the Gordian knot tat Directive are a second hindrance that influences the smoothness of implementation. These costs are related to administration, monitoring and intervention actions. (Kallis & Butler, 2001). The costs related to the Water Framework implementation are not yet visible but might be substantial as well. Based on the division of responsibilities related to the water management over many governmental organisations, the division of these costs will be a future point of discussions. Integration Many actors are involved in the implementation of European environmental directives. The studies towards the implementation of the Water Framework Directive and the Birds and Habitats directive show that they are implemented separately and without integration. This is due to different time schedules (the Birds and Habitats directives are much older) and due to a sectoral approach of the implementation. While the Bird and Habitat Directive simply defines goals in order to sustain endangered species, the Water Framework asks to set the goals. This in itself creates a tension with the responsible people and between different actors involved, and will no be in support of a more smooth integrated process (Bijnsdorp, 2007). Water management and nature conservation are dealt with by different governmental organisations, or by different departments within the same organisation. Both implementation processes are thus largely autonomous and independent. This often implies that problems are created or not solved when specific measures have to be taken in an area. In this phase it becomes visible that the objectives of both directives can be conflicting in specific situation. For example, when measures are necessary to improve the quality of the water these can have negative effects on the population of specific species that are protected by the Birds and Habitats directive. A decrease of nutrients in the water, such as lower N and P concentrations, leads to less available food for birds .and thus it will have a negative effect on the population. An other example are changes in the (ground)water level that are likely to effect the current vegetation that is strictly protected by the Habitats directive. Many of the measures that water managers need to take need are subject to an extensive impacts assessment and require an official license, because such measures are likely to have significant effects on the habitats or on the population of protected species. This shows that although most directives aim at the same general objective of improving environmental quality, the specific interpretation of this objective in the different directives is different and even contradictory. In the WFD targets have to be drawn up for specific areas and water bodies. If however upstream influence is great, these goals will not be reached. This roll down effect of upstream areas should be anticipated. Especially the Netherlands is at the end of several great river basins and therefore sensitive for this roll down effect. Leenders et al. (2006) suggest taking measures in all upstream areas and water bodies in the same amount as downstream. For example, if the inflow target in a downstream area should be halved, the reduction target for all upstream areas should be doubled, thus reducing the downstream target. In this way in all water bodies the targets are met. Of course one has to consider regional differences. In a case study area of the Dinkel (a sub river basin area in the north eastern part of the Netherlands) the influence of N and P from Germany is high. To prohibit this roll down effect international cooperation is necessary. In this same sub river basin area Leenders et al (2006) also took into account the effect of the Birds and Habitat Directive. They concluded that implementing this Bird and Habitat directive greatly enlarges the WFD-targets. This also enlarges the roll down effect and increases the upstream targets even more. The consequences of many ambitions related to nature development and conservation are directly linked to the required water quality targets to protect nature areas and control nutrients in surface water. The upstream impact on downstream areas is great for nature reserve areas. Defining the WFDtargets for surface water bodies thus sets conditions for upstream areas (external spatial impact). The sub river basin of the Dinkel for example sets limitations for all upstream-related sources, such as agriculture. Also the protection of specific habitats or species sets limits to the use of the surrounding areas. These interdependencies between areas and uses require co-ordination between the different actors that are linked with different land uses. In a study by Elbersen et al. (2006) about tuning the implementation of different directives around 30 knowledge gaps were identified that could possible lead to potential obstacles. Themes identified were methodological coordination, monitoring, flexibility of implementation and governmental and legal aspects. Many topics are related to the regional level, especially when boundaries and aims do not coincide with management purposes. They state that if policies are not too much top-down orchestrated, there are opportunities for coordination (using flexibility) between several directives. A central approach on main principles with regional flexible implementation should lead to positive results. However, the optimal path for this intertwinement and integrated implementation process requires more research. For example, boundaries of River Basin Plans and Natura 2000 areas often do not coincide, but impact of both directives will mutually have effect directly and indirectly. One of the issues should be how to deal with these boundaries. But not only the physical side of the implementation of directives should be approached more integrated, also governmental, legal and communication aspects should be taken into account. Furthermore, one has to bear in mind that EU directives with an effect on the environment come at a higher speed as ten years ago. In an interview of Bijnsdorp (2007) with the directors of the WFD implementation Wim van der Knaap & Raoul Beunen 5 Implementation and Integration of EU environmental policies and directives; cutting the Gordian knot process in the Netherlands the importance of coordination and tuning between several directives is underlined. How can you combine processes in a region and prohibit that on day one you’re focussing on the WFD and the next day on the BHD. This divergence in implementation would only increase reluctance to cooperate and diminish the success rate. 5. Discussion and Conclusions Implementation and enforcement problems are inherent to policies. There are so many actors involved in the implementation of European policies that divergence of the original policy goals and procedures in inevitable. Implementation is and will always be a political process. Many actors involved in this process are likely to have different opinions about both the ends and the means of the environmental policy. Unfortunately many studies and recommendations ignore this political dimension. Barnes and Barnes (1999, p 107) for example argue that “The introduction of the use of framework directives may help to overcome some of the problems outlined above. In this legislative form general principles and requirements for the legislation in the different sectors are set out which give more flexibility to the national authorities. … However, framework legislation will only achieve its objectives if it is part of an overall holistic approach to the implementation and enforcement of environmental policy and if more emphasis is placed on monitoring and management of the actions of national governments”. However, such an overall holistic approach is impossible as the current implementation of EU environmental directives in the different member states shows. In the monitoring of the implementation process, a lack of contextual knowledge can be encountered; each environment is different. It can not be sufficient to have one scientific approach for all places and regions. Fischer (1990) already identified problems with technocratic ways of decision making, especially when this process is only based on scientific knowledge. Environmental issues are only one element in the planning and decision making processes. At a lower level, environmental objectives can be related to other objectives. Studies show that local and regional actors are actively looking for ways to deal with the different European directives; the commitment is high. Such initiatives should be promoted and supported. Frustration among actors involved is growing because the way they have to implement European directives conflicts with current practices. Not the environmental objectives but the way these objectives need to be achieved and monitored seems to be the reason for problems. These actors criticise the emphasis that is put on legal and procedural compliance and on formal output. There is a difference between political commitment and commitment by different stakeholders. This can be noticed especially during negotiation processes. The relational perspective, the social co-ordination mechanisms such as trust and reputation, are more important than instrumental perspectives (Van Ark, 2005). Without recognising the relational aspects of collaborative planning and especially the role of trust therein, it is hardly possible to reach agreements and to co-operate successfully. Because of the enormous distance between the European government and local actors, agreement can only be reached on local and regional level. National governments (and in larger countries) should not try to control these practices but support initiatives and collaborate and negotiate with the actors. Commitment can not be forced through control; actors will always find ways around the directives. Political pressure from the European Union, other member states, NGO’s or the public are likely to sort more effect. Of course it has to be noted that the EU faces a great dilemma: on the one hand they must safeguard equality of rights for all member states and prevent distortion of trade but on the other hand there are many differences between member states and environmental issues. The fragmentation of European directives deserves attention at European level. And it is gaining the EU attention. For example, the recent Flood Management Directive has clear links with the WFD and BHD implementation. It is however a fiction that it is possible to integrate all environmental directives at this policy level. The diversity of European natural environments is enormous. All these environments have specific circumstances and they face different threats. The European Union should thus not try to develop policies and legislation that work in the same way in all contexts. This is simply impossible. Instead they should incorporate and promote flexibility. Actors need to be able to integrate different directives in local planning and decision making practices. This might imply that not all objectives can be reached (choices have to be made) or that the process of planning and decision making is conflicting with one or more procedural requirements from European directives. Procedures and formal compliance are means and not objectives of environmental policies. It is necessary to find ways to monitor the main objective of European environmental objectives, namely improving the quality of natural environments. Actors must be able to account for their approaches and the progress that is booked. Actions and results must be judged together. Performance (on a regional level) must be judged in relation to the outcomes. Flexibility is necessary to apply European directives in specific planning practices. This flexibility is included in the directives but it is necessary that national governments dare to use it. This means that implementation (and its monitoring) must not be limited to legal and procedural compliance but that the whole process, including the outcomes and external spatial impact, is taken into account. Current developments, especially in the monitoring Wim van der Knaap & Raoul Beunen 6 Implementation and Integration of EU environmental policies and directives; cutting the Gordian knot process, show that the emphasis is too much on formal conformance and that this leads to legalistic and bureaucratic forms of decision making. National governments have a great responsibility in the whole process. Too often they use European policies as a ‘scapegoat’ to cover their own lack of political commitment to environmental issues. They should not blame Europe for current problems related to the implementation of European directives but actively look for suitable ways to implement these directives in the planning practices. This should be done in close co-operation with the most important actors in a specific policy domain. European directives offer member states room to implement in their own way. National governments should take this room (for flexibility), defend their policies, and account to the European Union for their specific way to reach environmental objectives. Framework directives can only partly deal with the sometimes conflicting objectives of different European environmental directives. The real integration of different environmental objectives must be done at a local or regional level. And if required there should be international co-operation to meet goals set. The Netherlands has a long tradition of integrative approaches in both water management and nature conservation. These are not a guarantee for success but the experience shows that such an approach leads to more commitment of the different stakeholders. This commitment, in the long run, might prove to be much more valuable than bureaucratic procedures and control mechanisms in order to improve the quality of the European environment. This plea is also not about changing the rules, but about thinking how from practice and insight information from the implementation process we can come up with better results. Not the procedure (with its indicators and progress reports) should be central, but integrated regional development. There is a dichotomy of measuring progress with indicators and reports on the EU level versus results based on integrated regional development. What are the ultimate objectives of the directives? Who in the long run has to be satisfied? We argue that this should be the actors and people in a region and not the EU administration. The current implementation of the Water Framework Directive and the Birds and Habitat Directive (as well as other EU environmental directives) results in a Gordian knot, especially when looking at the local or regional level. This knot is a knot of legal and administrative procedures. Choices about local and regional developments need to be made, but each actor is waiting on someone else and the focus is not directly on what a region needs. Most actors focus on formal compliance to the EU directives and the environmental objectives get out of sight. If one tries to disentangle this knot in order to meet objectives of each separate directive, this will probably end up with very long procedures for each rope and strong sectoral approaches, without co-operation. This Gordian Knot of EU environmental directives shows the shortcomings and limitations of technocratic, science-based, policies. A further emphasis on integration on a European level or on uniform implementation in all member states will only tie this knot much tighter. This forms a strong argument against initiatives for a centrally controlled EU programme on spatial planning in which different objectives should be integrated (territorial cohesion, ESPON). Unfortunately this initiative is sometimes advocated by spatial planners. The only remedy is to cut the knot. This implies that the EU should no longer try to control local and regional development. This does not imply that the EU should not try to improve environmental quality but that they should accept that environmental quality has multiple meanings and that it can be achieved in many different ways. Instead of focusing on uniform objectives and procedures they should create awareness for environmental issues and possible solutions and facilitate the processes of international coordination. Reference list Barnes, P.M. & Barnes, I.G.. 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