Context
The European Union’s Recovery and Resilience Fund (RRF) requires all Member States’ plans to comply with the ‘Do No Significant Harm’ (DNSH) principle. This principle ensures that public investments do not negatively impact environmental objectives such as climate change mitigation and biodiversity protection. Spain, a major RRF recipient, faces the challenge of implementing this principle across a vast plan involving numerous public administrations at national, regional and local levels.
The Spanish Ministry for Ecological Transition and the Demographic Challenge (Ministerio para la Transición Ecológica y el Reto Demográfico – MITECO) plays a key role in overseeing the environmental aspects of the plan. A dedicated team, the DNSH Division, was established within MITECO to support other ministries in fulfilling their DNSH responsibilities. This team acts as a centre of expertise, offering guidance and recommendations on integrating environmental considerations into policies and procedures.
Objectives
The DNSH Division’s primary objective is to ensure that public policies implemented under the Recovery and Resilience Plan do not harm the environment. They aim to foster a ‘green skills culture’ within Spanish administrations, enhancing their capacity to design and execute environmentally friendly investments. This focus on environmental integration is crucial for achieving the EU’s green transition goals.
The division recognises the importance of multilevel governance in addressing climate change. They actively promote a better understanding of DNSH principles at local, regional and national levels to ensure coordinated action across all government entities. This collaborative approach is essential for maximising the impact of environmental efforts while addressing staffing shortages related to the climate transition.
Implementation
The DNSH Division, despite its small size of five staff members, acts as a central hub for DNSH knowledge within MITECO. They function as a first point of contact for other ministries, drawing on the expertise of various departments within MITECO when needed. Their activities encompass several key areas.
- Communication: the division continuously reviews legal texts issued by all ministries related to the plan. They offer tailored reports with recommendations on DNSH compliance for each policy measure, fostering informed decision-making.
- Helpdesk service: they provide a dedicated helpdesk service to answer questions from all public entities regarding the design and implementation of actions according to DNSH principles.
- Training and capacity building: the division offers training sessions and webinars to educate public authorities on the environmental requirements of the plan and how to apply them in practice.
While their reports and guidance are not mandatory, audits have recognised their value and recommended their integration into standard legal procedures. This highlights the division’s success in influencing policy and practice despite their lack of formal enforcement power.