8th Environment Action Programme proposal - Public consultation

ClientEarth welcomes the 8th Environment Action Programme's goals for a climate-neutral and circular economy but argues that the proposal lacks concrete targets and explicit commitments to phase out fossil fuel subsidies. The organization highlights discrepancies between the EAP's ambitions and existing policies like the Common Agricultural Policy and the European Maritime and Fisheries Fund. It calls for stronger monitoring based on scientific evidence, increased resources for DG Environment, and the integration of the rule of law and access to justice to ensure effective implementation.

• The 8th EAP proposal lacks an explicit statement that public funds should avoid financing fossil fuels, including fossil gas, which creates inconsistencies with the Just Transition Fund and may lead to 'gas lock-in'.
• There is a significant discrepancy between the EAP's stated ambitions and current EU decisions, specifically regarding the Common Agricultural Policy (CAP), the European Maritime and Fisheries Fund for 2021-2027, and the revision of the Aarhus Regulation.
• ClientEarth argues that the EAP should set concrete, meaningful objectives rather than merely referring to other strategies, and suggests a mid-term evaluation in 2024 to complement the 2029 review.
• The document identifies a lack of adequate staffing and resources within DG Environment, which has previously undermined the delivery of environmental strategies.
• EU trade policy is described as being at odds with the principles of consistency and environmental integration, necessitating a shift toward mandatory due diligence to address deforestation and human rights violations.
• The proposal is criticized for omitting references to healthy fish stocks and for failing to explicitly reflect the biodiversity strategy's goal of achieving 30% protected areas in marine and terrestrial environments.
• ClientEarth recommends that the EAP explicitly include the strengthening of the rule of law and the role of civil society in access to justice as requirements for achieving its priorities.

APA

ClientEarth (2020). 8th Environment Action Programme proposal - Public consultation. https://www.clientearth.org/media/bghia2dr/clientearth-input-consultation-8th-eap-docx.pdf

Chicago

ClientEarth. 8th Environment Action Programme proposal - Public consultation. 2020. https://www.clientearth.org/media/bghia2dr/clientearth-input-consultation-8th-eap-docx.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=8th Environment Action Programme proposal - Public consultation |date=December 2020 |url=https://www.clientearth.org/media/bghia2dr/clientearth-input-consultation-8th-eap-docx.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth20208th, author = {{ClientEarth}}, title = {{8th Environment Action Programme proposal - Public consultation}}, publisher = {ClientEarth}, year = {2020}, month = dec, url = {https://www.clientearth.org/media/bghia2dr/clientearth-input-consultation-8th-eap-docx.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }