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EU pre-accession funds have not always been a success story for reasons 
      that range from misunderstanding of the local circumstances and differences 
      on the part of the EU to bad management and lack of ownership on the part 
      of local governments.
      CEE Bankwatch Network and Friends of the Earth have been monitoring the 
      use of EU pre-accession funds in the Central and Eastern European candidate 
      countries since 2000. Pre-accession aid  ISPA (environment, transport), 
      SAPARD (agriculture, rural development) and Phare (institution building, 
      economic and social cohesion)  will cause profound changes in the 
      economies of Central and Eastern European countries and will have an enormous 
      impact on the environment through new strategies and projects in infrastructure, 
      energy, nature conservation, and agriculture. Moreover, the funds will attract 
      funding from other sources such as international financial institutions 
      (especially the European Investment Bank). 
      To bring the expected benefit to the countries that are still transforming 
      into market economies, these financial instruments should be implemented 
      in accordance with the principles of sustainable development and should 
      be managed in a transparent way that implies public involvement. Unfortunately, 
      experience has shown that this has not always been the case. Although the 
      EU has called for the integration of environmental principles into all areas 
      of work, to what extent this has happened in practice remains to be seen. 
      The EUs environmental regulations are not always enforced in EU-funded 
      projects and the funds structure often encourages unnecessarily large 
      projects and favours end-of-the-pipe solutions such as landfills 
      over more proactive approaches such as recycling and waste reduction.
Some examples from Bulgaria
      In Bulgaria, for example, most of the wastewater plants that have been proposed 
      for EU pre-accession aid are oversized. They were designed 10-15 years ago, 
      during the communist regime, when environmental principles did not play 
      the role they play today. Furthermore, data describing the existing situation 
      have not been systematically collected, which makes it difficult to develop 
      new projects. This is a critical issue, since wastewater plants need to 
      be the right size to work properly, otherwise their effectiveness and cleaning 
      technology are undermined. A fragile cleaning technology is closely connected 
      with the price that citizens will have to pay in the future for maintenance. 
      
      Many problems related to wastewater treatment still remain to be solved. 
      For example, industrial and household wastewater is not separated before 
      treatment, which automatically makes all the sludge a hazardous waste. If 
      separation was carried out, household sludge could be used for agriculture. 
      Very often, the wastewater collection system is not completed and settled 
      areas are not connected to the wastewater plants. At the same time, the 
      plant is designed to serve the whole city, which also creates problems in 
      terms of the size and effectiveness. Such an example can be found in Stara 
      Zagora, Bulgaria, financed by ISPA, where 40% of the city wastewater system 
      is not directed into the main collector. 
      The major problem, however, is that big cities lack a strategy and planning 
      for wastewater collection and treatment. Therefore, projects financed by 
      the International Financial Institutions and ISPA funds are isolated and 
      lack a holistic, sustainable approach. The EU has tried to improve the situation 
      by introducing conditions for sustainability, but as these measures were 
      not integrated they are seen as an extra burden on the municipalities which, 
      to make things worse, are expected to fund them from their own resources. 
      
      Apart from insufficient capacity in the pre-accession countries, external 
      pressures driven by macroeconomic success and political cohesion among member 
      states push environmental needs low down on the agenda. This trend can be 
      very easily observed in the drive to complete the "Trans-European Network 
      of Motorways at the expense of more environmentally sound modes of 
      transportation. On the one hand, ISPA supports environmental projects and 
      on the other hand the same fund is used to finance one of the most environmentally 
      harmful modes of transport. Combined with SAPARD, which encourages intensive 
      agriculture rather than organic farming, the EU funds and EU concerns for 
      the environment suffer from a lack of coordination and a lack of integration 
      of environmental principles in the actual policies and programmes. 
How EU funds could be improved
      Environmental principles should be integrated in all areas of pre-accession 
      activities to increase public participation, significantly increase the 
      consistency and quality of administering pre-accession assistance and build 
      a proper legal and institutional basis for the future management of structural 
      funds.
      National sectoral policies, as well as national and regional strategies 
      and plans should be subject to strategic environmental assessment. In keeping 
      with the EU Directive on Strategic Environmental Assessments (SEAs), the 
      same applies to the newly prepared national development plans, single programming 
      documents or operational programmes. During the midterm review, guidelines 
      for pre-accession funds should be revised in the spirit of the EU Strategy 
      on Sustainable Development. 
      Transparency and public participation in decision-making should be among 
      the key requirements for funding. The public participation process should 
      not be treated as an obstacle to a smooth realisation of projects nor should 
      it be treated as a mere formality - as yet another box to tick off in the 
      funding process. Co-financing institutions such as the European Investment 
      Bank should also be required to show increased openness and transparency.
      A transfer of know-how is needed, combined with resources dedicated to better 
      preparation of projects and more efficient use of EU funding. Technical 
      assistance and capacity building at all administrative levels is needed 
      just as much as - if not more than - investments in new highways, especially 
      if the accession countries are to use the structural funds wisely in the 
      future.
      Western consultancy companies helping to prepare activities within the scope 
      of pre-accession funds must be closely scrutinised for their capacity, quality 
      of work and credibility to avoid inefficient use of resources. Bearing in 
      mind the importance of creating sufficient capacity in the accession countries 
      to enable them to use future use of structural funds, priority should be 
      given to involving local consultants and developing high-quality local consultancies.
      Also needed are resources for increasing NGOs abilities to become 
      a strong part of the process as both contributors and watchdogs. Both the 
      European Commission and the governments of the accession countries must 
      involve the public and NGOs in the process of preparing the countries to 
      use the structural and cohesion funds in a timely and proactive manner.