Rating is apparently all the hype in Big Environment these days. When I was looking around on the McPlanet (de) a forthnight ago, the panel on the EU's reaction to climate change started with the moderator (from Greenpeace) asking the panellists to make an opening statement by grading the EU's policy on a scale from 1 to 10.

Quite what this schoolmastery is supposed to accomplish, I don't know. But that's a point of presentation, and I suppose the content is more interesting. Fortunately there is still quite some of that in the mid-term report.

The mid-term report notes in its introduction that the Commission got off to a bad start on the environment, but has recently shown some signs that it has turned around. The Stern review is given credit for starting this movement.

This seems largely correct to me. Along with Gore's documentary and travelling presentation 'An Inconvenient Truth', the Stern Review can certainly be credited to some degree with the greater prominence of the topic of climate change, which has been pushed further by the IPCC reports this year. Not even necessarily much of the content of the latter, but the fact that they're all coming out this year and bring the topic to the foreground.

At the same time, the climate issue tends to drown other issues out and blind people to the real nature of the problem. The climate issue can't be dealt with in isolation, because it is fundamentally an issue of sustainability. It has to be dealt with in the larger picture of developing a sustainable economy and technological structure, otherwise we will only shift the problem from one area to the next.

At the present time, the Commission's overall strategy is to some degree carbon blind. This analysis is reflected in the mid-term review, which rates the Commission's policy on climate change higher than any other.

Arguably, the Commission has been quite good on climate change recently. Most importantly, it has been strong on the national 'allocation' of emission rights under its emissions trading scheme. The ETS covers almost half of the carbon dioxide emissions of the Union, and has just been through what you could describe as a three-year test phase. The emission 'allocations' the national states made to individual businesses in this test phase were too high and, partially as a result, partially due to other causes, the scheme hasn't functioned. In the second phase, which corresponds to the first Kyoto 'commitment period', the national states were again attempting to get lame plans through but the Commission has consequently slashed them down. After Germany and France swallowed some, the big three Member States have now accepted the lower targets, which in practical terms means that all Member States that have not yet accepted them will now have to do so.

This part of the climate change strategy is now pretty much fully designed, what remains is focusing on implementation, enlarging the scheme, using it as a wedge in foreign policy, tying it more clearly to the EU's long-term goals and looking at building a consensus on auctioning the emissions rights instead of handing them out for free.

At the Spring Council (pdf), the Union agreed on three long-term goals for the EU's climate and energy policy. They're easy to remember as they're all 20s and have to be met in 2020. I know, it's very cute, but the goals have different worths. The 20% renewable energy target is very ambitious, where the 20% CO2 reduction target is too low and only palatable because the Union offers 30% in case other countries will also commit to big emission reductions. The goal of a 20% energy efficiency increase is completely inadequate, because the EU's growth and energy consumption may well increase by more than 20%. So it does not accomplish an absolute decoupling between energy use and growth.

Worse, as noted, is the lack of clear linkages and integral (or joined up) policy-making. This is clearest in the Commission's policy on nature protection. One of the few new insights I took away from the McPlanet was a note by an environmental ethics professor that nature protection should be seen as a crucial part of any adaptation strategy. This is obvious when you think of it. Not only does climate change multiply the existing pressures on the natural environment, leading to a greater need for nature protection, but having plentiful nature will decrease the local threat of floods, droughts, etcetera. Nature also tends to function as a carbon sink. This is an area where the costs of non-action have an exponential function and the benefits of action count triple. This is not a lone case. When you engage with environmental problems, you see it over and over again.

As the problems are all interrelated in manifold ways, there is a need for an integrated strategy. The EU, up until now, is working mainly with sectoral ('thematic') strategies which are insufficiently tied up with its sustainable development strategy. Formally, the linkages and referrals are all there, but in actual content there are often incomplete ideas, lacking commitments and mismatches. This is in part due to the bureaucratic structure of the Commission, which needs to be reformed, and in part due to the lobbying and politicking that inevitably accompanies sectoral strategies. They are released through independent procedures and so the political forces and industry lobbies gather anew around each policy. It is the Commission's role to keep the big picture in mind and defy the political interests and forces of the day, but it is not strong and visionary enough to do so.

There is quite some vision within the Commission, as this interview with Catherine Day on EurActiv shows. At the same time, it's just not there in the output. This must mean that the big idea goes missing at the political level of the Commissioners, or that the Commission is simply too weak.

Tellingly, on biodiversity, fisheries, and forests, the areas directly related to nature protection, the Commission gets much lower points from the G10 than on climate change. Biodiversity gets 5 points, which is still too high in my opinion. The Commission is lauded here for coming about after wasting some time at the outset with simply not seeing the problem, but the review makes clear that the Commission is losing control over this policy area in the face of rampant non-compliance to its policies. Integration of the policy in other areas, outside the scope of the 'directorate general' on environment, is also found to be minimal. So I suppose that maybe DG Environment could be given a pass for putting up a strategy, although it has to be more clearly integrated in the overall sustainable development strategy. However, as Catherine Day states in the interview with EurActiv (and I have said at the start of this Commission), the Commission's central task is moving from policy formulation to ensuring effective implementation, so since there is a severe deficit here, DG environment can be judged accordingly. The Commission as a whole is simply not performing on the topic.

Lack of policy integration also characterises the European Commission's initiatives on transport. Although the environmental policies of the Commission, notwithstanding the interventions of Verheugen, Merkel and the German car industry, will lead to notable improvements, overall transport policy has become less environmentally friendly. This is because focus of the EU's transport policy has shifted, from accomplishing a 'modal shift' towards more environmentally friendly modes of transport, to accomplishing co-modality. This is all the worse as transport is one of the areas where the EU has large influence and an insufficient but significant amount of funds to spend in the form of the Trans European Networks. Co-modality will lead the EU to fund more useless projects than usual.

The criticism of the G10 on the 6th Environment Action Plan is worth quoting, as it contains some criticism of the general way the Commission is legislating today:

The `Better Regulation' agenda also impedes more ambitious environmental laws. Only in recent months has recognition begun to re-emerge that environmental policies make a necessary and positive contribution to future prosperity. Thematic Strategies are often empty vessels, devoid of targets or postpone or avoid appropriate action (eg Air, Marine, Natural resources, Urban and Waste Thematic Strategies), and in the worst cases result in environmental roll-back (eg Air and particularly Waste). Action taken thus far to protect biodiversity is inadequate to achieve 6EAP's objectives. We question whether the `new' type of legislation, the Framework Directive, which calls for more reporting and process requirements than common targets and deadlines, and builds on delegating regulatory decision-making to comitology and regulation (standardisation), is the right approach. Deploying effective legislation to achieve EU environmental objectives is decreasing. Finally, integrating environmental objectives into other policies, as required by 6EAP and Article 6 of the Treaty, is still poor (particularly in transport and agriculture).

I think that the better regulation agenda and the framework directive approach are basically good ideas, however, they have not worked out in practice. With the better regulation agenda, this is clearly because Barroso, along with Verheugen and McCreevy, has tried to use this agenda to translate better regulation first into less regulation and then into less effective protection. I am all for streamlining regulation and making it more business-friendly, as long as this leads to better enforceability and equal or more effective protection (which it well can). Barroso could have built a consensus around this in the Commission and it could have made great strides in this valuable task. But he didn't and the Commission has been split on the topic as a consequence (with both sides losing some). It may only now be coming back together on the theme. Framework directives with marginal controls are theoretically more effective, but this requires the Commission to use the controls effectively and remain in the driving seat, at which it may not have succeeded.

As we face an increasingly large sustainability problem, the European Commission seems ill-equipped to deal with the task. Its bureaucratic structure is ossified and has shown to be quite incapable of achieving real policy integration. Its power has faded as it has failed to make an effective partnership with the European Parliament to increase the strength of these two supranational organs. Its leaders do not function as the 'guardians of the treaty' and the long-term agenda-setters looking at the European interest that Catherine Day talks about. Instead, they react to short term political pressures in order to keep the favour of the leaders of the Member States.

How do we get on with a Commission that can't perform its assigned role? A first would be the suggested bureaucratic reform. A second, related improvement would be to make the Commission a democratically elected body, in order to give it more independence from the Council and end its split nature of being only half a civil service and only half a political organ. In strategic terms, the Commission needs to move towards more joint policy formulation to better deal with the political and lobbying coalitions that form around its thematic strategies. But if we want it to do that effectively, bureaucratic reform and increased independence are necessary preconditions.