Towards a climate neutral EU:
efficient allocation of EU funds

Mistake to avoid: Combining brown and (uncertain) green measures in order to pass the DNSH test for new road infrastructure

Organisation: Umanotera Website: Added: July 07, 2023
Project start date: January 01, 2012
Project end date: December 31, 2028


The funding of new road infrastructure projects with EU funds is highly controversial and only possible if various mitigating measures are implemented. In Slovenia one such project is the Third Development Axis, which will create another road transport link between the Austrian border in the north and the Croatian border in the south. Some legs of this larger project were included in the draft National Recovery and Resilience Plan but later removed. However, Slovenia’s OP under European cohesion policy includes again sections of the Third Development Axis. Despite the fact that the EIA for the specific road sections predicted an increase of GHG emissions due to the project, the do-no-significant-harm (DNSH) test was passed. For this, various mitigating measures were announced (reducing mobility needs, alternative fuel infrastructure, public transport, changes in legislation of commuter allowances, etc.). However, the mitigating measures are not very specific (how many charging stations, which public transport will be improved where, what will the reformed commuter allowance look like and when will it be reformed?), they are not an integral element of the OP, but can be dealt with elsewhere, and they can be replaced simply by building a local cycling link. In the end, a certain and siginficant impact on the environment is justified with uncertain and vague mitigating measures.

Financial data

EUR 68 million (ERDF) for the specific road section, but the overall project is much larger and receives much national funding.


Do not mix mitigating measures into the DNSH analysis just to counterbalance the harm of an otherwise siginificantly harmful project. If, however, mitgiating measures are included in the scope of the DNSH analysis, they have to be integral part of the project, with clearly defined outputs, timelines and financing.

Information sources

Public cohesion policy documents

Other info

European Climate Initiative (EUKI)
This project is part of the European Climate Initiative (EUKI). EUKI is a project financing instrument by the German Federal Ministry for Economic Affairs and Climate Action (BMWK). The EUKI competition for project ideas is implemented by the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH. It is the overarching goal of the EUKI to foster climate cooperation within the European Union (EU) in order to mitigate greenhouse gas emissions.