Environment in emerging and transition economies

Enforcement and Compliance Indicators


The Guiding Principles for Reform of Enforcement Agencies in EECCA call for the development of indicators against which Agencies’ performance can be measured and continuously improved. Responding to this call this project assists enforcement agencies in designing indicators for both outputs and outcomes. Such indicators are instrumental to monitor the implementation of compliance assurance programmes, support policy making, and help to improve the transparency and accountability of enforcement authorities. The work also helps to establish procedures for regular feedback to managers, political leaders and legislature using quantitative and qualitative indicators. It also provides an input to the Peer Reviews of Enforcement and Compliance Systems.

The work on environmental enforcement and compliance (ECE) indicators has been carried out in close cooperation with the International Network for Environmental Compliance and Enforcement (INECE). An international workshop  was organised in November 2003 to share various countries experience to reform these indicators. Using a guidance document that resulted from this discussion, ECE indicators were reviewed in Armenia and Russia. These reviews showed a clear convergence with international benchmarks, for instance: data collection within institutionalised performance measurement systems; comprehensive coverage by ECE indicators of environmental media, industry sectors, and geographic areas; regular reporting, etc.

Nevertheless, a number of design flaws were revealed, most importantly:

  • The missing link between performance measurement and activity planning;
  • A perverse interpretation of ECE indicators whereby output indicators are used as “targets”. As a result, the effectiveness of environmental enforcement authorities is often associated with high numbers of imposed sanctions, in particular fines or other monetary penalties;
  • Poor standardisation of performance measurement terminology and procedures that opens up opportunities for misinterpretation or manipulation of data;
  • Prevalence of a mere description rather than analysis of compliance and enforcement data;
  • Limited coverage of the regulatory cycle, e.g. lack of indicators that describe compliance assistance efforts;
  • Focus on disclosing “outputs” with less attention to “inputs” (e.g. human, material and financial resources dedicated to specific tasks) that does not allow to scrutinise outputs versus costs;
  • Lack of intermediary outcome indicators that would link activities with environmental outcomes (e.g. levels of emissions and state of the environment).

In order to address some of these problems, the Secretariat drafted the Guidelines on Performance Measurement for Environmental Enforcement Authorities of EECCA. The Guidelines were discussed at the REPIN meeting in June 2006 where the need and proposals for a core set of ECE indicators were identified.

The work on ECE indicators was possible due to voluntary contributions from the European Commission and the Netherlands, as well as expertise offered in-kind by a number of other OECD and CEE countries.