The Environment and Climate Change Law Review: France
The recent environmental and climate change policy in France has focused on two objectives: protecting biodiversity and ensuring a successful energy transition.
The Law on the Recovery and Protection of Biodiversity of the 8 August 20162 is based on a number of principles: 'avoid, reduce, compensate', non-regression in environmental matters, solidarity, and the protection of biodiversity; and new legal redress mechanisms to provide compensation for ecological damage and prevent environmental damage before it takes place, as well as helping to prepare projects that may harm the environment so as to mitigate such issues in advance.
The 2015 Energy Transition Act3 aims to promote renewable energies and reduce the share of nuclear energy in electricity production; France is still far behind its objectives regarding the development of renewable energies.
The main sources of legislation and regulations relating to environmental protection and climate change are gathered in an Environmental Code adopted in 2001.
In addition to the French Environmental Code, there is an environmental Charter4 enclosed in the Constitution, which is considered to be a superior right binding across all courts. It is under the control of the constitutional Council. After proclaiming the right to a healthy environment, the Charter contains the main founding principles of environmental law: prevention, precaution, polluter pays and the right to participation and information in environmental matters.
The Environmental Code concerns: on one hand, the essential elements of the environment – air, water, climate, fauna, flora, landscapes – and, on the other hand, the rules regarding pollution. These norms constitute the main provisions of books 2, 3 and 4 of this code, which is composed of eight books (including two devoted to the French Overseas territories).
Book 5 concerns all sources of environmental degradation by pollution and targets dangerous and environmentally hazardous establishments, chemicals, GMOs, biocides, nanotechnologies, nuclear safety and protection against natural hazards and noise pollution, as well as environmental damage related to aesthetics through posters and advertising.
French domestic law is strongly influenced by European Union law, which encompasses the same subjects, and has been inspired, since 1980, by the major systems of French law: impact assessment, classified installations, waste and hazardous products.
Finally, France, which, by virtue of Article 55 of its Constitution, recognises the superiority of treaties over domestic law, applies and recognises many international conventions that have direct effect, such as the 'Aarhus' Convention on Information and Access to Justice in Environmental Matters, the Basel Convention on Waste, a large number of conventions on air pollution, the law of the sea and the law of protected species. It is estimated that France has ratified more than 300 environmental treaties or conventions.
Regarding climate change, the provisions of the Environmental Code relating to climate are not mandatory but indicative.
Article L 229-1 of the Environmental Code states:
The fight against the intensification of the greenhouse effect and the prevention of risks linked to global warming are recognised as national priorities.
Nevertheless, the Environmental Code has relatively strong legislation on national observation about the effects of global warming, the issue of quotas and, above all, the issue of planning at local and national level.
The Ministry of Ecological and Inclusive Transition enforces the main policy regarding themes of environmental law and issues relating to spatial planning and energy law.5 It has two agencies, each with a relatively important role to play.
First, the Environment and Energy Management Agency (ADEME), whose statutes and powers are described in Article L. 131-2 of the Environmental Code, is a state institution. Its mission is to prevent and fight against air pollution, prevent waste production, reorganise and monitor waste storage facilities, achieve savings in energy and raw materials, develop clean and efficient energy-related techniques, fight against noise pollution and coordinate at a local level the Water Agencies in their area of common interest.
Second, the French Agency for Biodiversity was created by the law of 8 August 2016. Its mission is to ensure the preservation, management and restoration of biodiversity, the development of knowledge concerning the resources used and ecosystem services related to biodiversity, balanced and sustainable water management and the fight against biopiracy. It also plays a role in the application of the monitoring of the law on the recovery of biodiversity, nature and landscapes.
The most important aspects of environmental litigation are devolved to the administrative courts, which are organised in three levels: the administrative courts, the administrative courts of appeal and the Council of the State.
The procedure before the administrative courts is essentially a written, inquisitorial and contradictory procedure.
The courts of the judicial order attached to the Court of Cassation (High Courts and Courts of Appeal) judge disputes between private persons and those relating to the environmental liability of private persons for nuisances or pollution. Law No. 2016-1087 of 8 August 2016 on the Recovery of Biodiversity, Nature and Landscapes legalised the principle of compensation in kind for ecological damage; the rules relating to this dispute are contained in Articles 1246 et seq of the Civil Code.
The above-mentioned jurisdictional mechanism is an effective device in the case of a violation of environmental laws and regulations, but especially so in case of damage to the environment.
The creative and interpretative role of judges must also be emphasised as the law of impact studies and the right of compensation for ecological damage both result from decisions of first degree courts, preceding the Environmental Code.6
Anyone with a direct, material and certain interest may take legal action, whether a legal person, individual, local government, association or company.
The interest must be direct, material and certain. For associations, the statutes must be precise and aim at the very object of the dispute. Litigation generally arises from the initiative of civil society.
Access to justice is in principle free of charge, but costs and expenses can be significantly incurred. In principle, all corporation or legal persons, even under public law (local authorities, departments, regions) except the state, may be sued in criminal courts.
The European Court may be seized – after exhaustion of domestic remedies – for violation of the principles and rules set by the International Treaty of Paris, which is based on the model of the 1948 Declaration.
The European Court of Human Rights has an undeniable role to play in the development of the jurisprudence of the courts. The same applies to decisions of the Court of Justice of the European Union insofar as, for example, this jurisdiction makes it possible to interpret the directives on referral of preliminary questions by the national courts.
This jurisdictional system is important but does not operate on a system of oral evidence, which is testimonial; on technical matters it operates on the expert opinion procedure, which is very strictly regulated. However, the judge is not definitively bound by the expert's decisions.
Reporting and disclosure
The issue of environmental information is rooted in the highest level of law: constitutional law (Article 7 of the 2005 environmental Charter).
This right is generally exercised according to a very precise system allowing the referral to a committee that sits under the Prime Minister: the Administrative Documents Access Commission.
Any citizen who wishes to obtain a document relating to an environmental issue may make a written request to the authority concerned, and in the event of refusal may refer the matter to the administrative court.
Parliamentary committees of inquiry in France have often been assembled on several subjects; they are intended to enlighten both Parliament and citizens. However, they do not have the same power as in common law countries.
With regard to cases of violation of environmental regulations or permits issued by the administrative authority, most are placed under the jurisdiction of the administrative courts and the appeal must be lodged within a very short period: two months from the date of publication or notification of the administrative act unless otherwise specified.
Regarding the litigation of soil contamination, there is a relatively significant dispute in the case of the sale of polluted land and in the absence of information or lack of compliance of land for industrial use or contaminated land (Article 514-20 of the Environmental Code).
With regard to the environmental information obligations, the essentials are found in the Environmental Code and in Book I of Title II.
Recent case law of the Council of the State also considers that the powers of the public authorities generally extend to the past operator but also to the owner of the land. The actions must result in full restoration or compensation for the damage caused; waste liability is treated in the same way, but only concerns the obligation to dispose of the waste and not necessarily the restoration of the site.
The climate litigation involves expert opinions and is about to become effective in France and in Europe (the Urgenda case and 11 families in what has been called The People's Climate case). The Urgenda case, which is a Dutch case, has recently been confirmed by the Court of Appeal. It calls into question the responsibility of the Dutch state for insufficient measures taken against global warming.7
The '11-families litigation' is directed against the European Commission; in France, one litigation is currently planned against the French state for failure to act and another against Total SA for failing to provide an information report on its action regarding climate change.
i Air quality
Air quality management must be distinguished from emission control even though regulation of emission sources is necessary to achieve quality standards.
Article L. 220-2 of the Environmental Code defines atmospheric pollution. The right of everyone to breathe air that does not harm their health has been set out in Act No. 96-1236 of 30 December 1996, known as the LAURE Act, and is listed in Article L. 220-1 of the Environmental Code. This principle has been constitutionalised and enshrined in the environmental Charter.8 In France, the number of deaths attributable to air pollution is at least 45,000 per year, according to the European Environment Agency.
The plan for the protection of the atmosphere's measures (PPA) must be elaborated by the prefect in agglomerations of more than 250,000 inhabitants. This plan also aims to implement traffic restriction measures. In February 2018, France sent the European Commission the elements of its action plan, which aims to guarantee breathable air for all French people. The prefects of the areas affected by the exceeding of the pollution thresholds were to present on 31 March 2018 the roadmaps prepared with all stakeholders to define the new short-term actions for a quick return to below the regulated thresholds. The Commission brought an action before the Court of Justice of the European Union against France for 'non-compliance with the limit values for nitrogen dioxide (NO2) and for failure to take appropriate measures to shorten the periods of exceedance as much as possible'. France must review its solutions to fight the sources of atmospheric pollution.
ii Water quality
Water law in France is characterised by its complexity because both the statute and legal regime are related to the right of ownership. Under the Civil Code, water is considered a common good. The legislator did not elaborate a water code, and there is no legal definition of the term 'right to water'. The legal regime applicable to water is found in several codes. Three important laws have made it possible to establish the basis of a positive right to water. First, the law of 16 December 1961, which establishes the legal framework for regulating the pollution of water resources. Second, the law of 3 January 1992, which allows the harmonisation of the legal regime of water. Finally, the law of 30 December 2006, which recognises the priority use of water for human consumption and establishes a right of access to drinking water. The main texts on this subject are codified in Title 1 of Book II 'Water and aquatic environments' of the Environmental Code. Article L. 211-1 guarantees the principle of balanced and sustainable water management. Article L. 210-1 of the Environmental Code implicitly grants the state the right to organise the use of this water for the benefit of people other than solely the locals.
To this must be added European law, which constitutes an essential source of water law, as well as international conventions. When the 2000 Water Framework Directive was adopted, France transposed it with Act No. 2004-338 of 21 April 2004. This directive reflects the will of the member states' to harmonise their water legal systems.
There are several organisations responsible for water management. Placed under the authority of the Minister of Ecological and Inclusive Transition, the Water Department's9 mission is to develop and monitor the application of the rules relating to the water regime. At its side is the National Water Committee, an advisory body, whose secretariat is taken up by the Water Department. It gives its opinion on the projects of development and distribution of waters with a national character, on large regional arrangements or on the quality of the public services of water distribution.10 Finally, the French Agency for Biodiversity,11 which is an administrative public state body, ensures the balanced and sustainable management of water and promotes the coherence of other policies that would have an impact on biodiversity and water.
The legislator organises water management through two urban planning documents: the Main Plan for Water Development and Management (SDAGE) and the Water Development and Management Plan (SAGE). The 2006 law strengthens the legal scope of the SAGE by giving it the status of a document with regulatory value. Several specialised institutions in the field of water management ensure its management: the water basins whose prefects are coordinators, the basin committees that develop the SDAGEs, as well as the water agencies that implement the principle of balanced and sustainable management of water resources. Finally, a local water commission is created by the prefect to review and monitor the application of the SAGE.
The law relating to chemicals appeared in the 19th century, first through the decree of 15 October 1810 on unhealthy, inconvenient or dangerous factories and workshops, then through the law of 19 December 1917, and finally through the legislation on classified installations by law No. 76-633 of 19 July 1976. A national plan for the prevention of risks to health related to the environment is drawn up every five years.12 The first 'National Health-Environment Plan' was developed in June 2004 by the government to guide the regulation from 2004 to 2008. A second plan (PNSE 2) was adopted in July 2009. Adopted in November 2014, the PNSE 3 for the period 2015–2019 provides several measures, including risk mapping.
The European Union has set up the REACH system and has created a European Chemicals Agency.13 The REACH regulation requires companies that manufacture and import chemical substances to evaluate and assess the risks resulting from their use and to take the necessary measures to manage any identified risks. This regulation replaces more than 40 previous directives and regulations and creates a single system applicable to all chemicals.
In France, the administrative bodies responsible for chemicals are divided between several ministries. The prevention and precaution committee14 has a dual mission: on the one hand, to monitor and alert on all environmental issues likely to have an impact on human health and, on the other hand, to conduct expertise in the assessments of health risks related to the environment. Victims of chemicals have several avenues of action available when they seek redess for their injury. The protection of health is guaranteed by the nation under Article 11 of the preamble to the 1946 Constitution, which is incorporated into the 1958 French Constitution. The regime for the prevention and reparation of damage caused to the environment by hazardous professional activities is established by Act No. 2008-757 of 1 August 2008, codified in Articles L 160-1 to L. 165-2 of the Environmental Code. Currently, chemicals are subject to legal rules that may engage the responsibility of the various stakeholders throughout this process.
iv Solid and hazardous waste
Waste is defined in Article L 541-1-1 of the Environmental Code. Hazardous waste is characterised by one or more of the hazard properties specified in Annex III of the waste Directive 2008/98/EC. An asterisk in the list of waste mentioned in Article R 541-7 of the Environmental Code allows to report it. Every waste holder is required to characterise his or her waste, and in particular to determine if it is hazardous waste in order to direct them to the right treatment, or, failing that, to any producer.15
The mayor or the chairman of the group of local authorities responsible for collecting waste shall, by reasoned decree, after consulting the decision-making body of the municipality or the group of local authorities responsible for the collection of household waste, establish the terms of the collection various categories of waste.16
The prevention of waste is one of the pillars of the circular economy, according to Article L 541-1 of the Environmental Code. Waste management must not endanger human health or harm the environment. The extended responsibility of waste producers is reaffirmed in the name of the polluter pays principle, regardless of the legal nature of the producer. French legislation incorporates European guidelines in this area: the 2015 Energy Transition Act includes the European objective of reducing by 50 per cent the stored waste by 2025.
v Contaminated land
It is with the aim of limiting urban sprawl that a legislative framework dedicated to 'Polluted Sites and Soils' was brought into the Environmental Code. Article 173 of the 2014 Law17 on access to housing and renovated urban planning has provided a number of clarifications that are now codified in the Environmental Code. In particular, this is with regard to land use changes in land that have hosted a facility that has been decommissioned and rehabilitated,18 or construction or subdivision projects located in a land information area.19 The legislator has confirmed the idea of ex officio execution of works in the case of pollution of the land or risks of soil pollution presenting threat for the health, the safety of the public and the environment regarding the use taken into account.20 The person responsible is either, in order of priority: the past operator of the installation causing the soil pollution, or the person designated under Articles L 512-21 and L 556-1 of the Environmental Code. For soils polluted by another origin, it is the producer of waste who has contributed to the origin of the soil pollution or the waste holder to whom the fault is contributed. In the absence of a responsible party, one turns towards the owner of the land base of the soil polluted by an activity or waste, if it is shown that he or she has been negligent or that he or she is not a stranger to this pollution. Soil pollution is also assessed in terms of the damage it is likely to cause to the environment with a risk of serious injury to human health due to soil contamination resulting from direct or indirect introduction of substances, mixtures, organisms or microorganisms.21
The state is not meant to replace the designated officials. However, their failure may lead it to do so under the conditions laid down in Articles L 131-3 and L 541-3 of the Environmental Code.
French climate law is enshrined in Article L 229-1 of the Environmental Code. The state obligation contained in this article cannot be considered as a source of the development of a climate dispute under French law in the context of a of local public interest conflict. For the administrative judge since judgment Commune de Heidwiller of 21 June 2007 sentenced by the Nancy administrative court of appeal, this provision has no mandatory effect. The text of Article L 229-1 of the Environmental Code remains unsuitable. Only parliament could take up the text of this Article L 229-1 of the Environmental Code to make it directly effective. From a purely contentious point of view, the association Notre Affaire à Tous has set itself the mission of acting for climate justice in France, particularly through the petition filed in autumn 2017 to hold the state liable for a failure to act in the fight against climate change. Consequently, the areas of competence assigned to local authorities could be strengthened in this matter. For example, under Article L 121-1 of the Urban Planning Code, the law should encourage the need to preserve air quality to allow elected officials to promote in their policies the challenge of reducing GHG emissions. The prefects, mayors or the president of the general council would risk being held responsible if they did not intervene when the populations of their locality are endangered. We would like to recall the importance of the contributions of Article 173 of Law No. 2015-94 of 17 August 2015 on energy transition, which contains obligations to follow-up and control measures intended to fight global warming; to our deepest regret, the government is struggling to make a real application of all said texts.
The fight against climate change is the subject of joint action by European countries. The integration of the environment into the policies of the European Union was marked by the Paris European Council in October 1972.22 Since 1973, the need to create a multiannual action programme in the field of the environment has been realised. In this respect, the Seventh Programme for the years 2013–2020 under Article 192(3) TFEU, sets out the priority objectives to be achieved in terms of environmental protection. This programme aims, inter alia, to '(f) ensure investment in support of environmental and climate policies and combat environmental externalities' and to '(i) increase the Union's effectiveness in tackling international environmental and climate problems'. It was not until the 1987 Single European Act that the first legal basis for the EU's environmental policy was established. Then, the following treaties maintained the spirit of this commitment: the 1992 Maastricht Treaty and the 1997 Amsterdam Treaty. It was through the 2007 Lisbon Treaty that climate change became a full-fledged objective of the Union's policies.
The Union has set itself the goal of devoting 20 per cent of the 2014–2020 budget to the fight against climate change, namely, €180 billion. Member states have committed to reduce by 20 per cent their GHG emissions for the second period (2013–2020) compared to 1990. Since 2005, the Union has adopted its main tool for carrying out its climate policy: the Emissions Trading Scheme encourages the reduction of the volume of greenhouse gases emitted by the industrial sector. To combat climate change by 2030, the European Union has set itself the target of reduction emissions by 40 per cent from 1990 levels, and has committed to increase of at least 27 per cent energy efficiency as well as to promote renewable energies. In the long term, by 2050 the Union intends to reduce its emissions by between 80 and 95 per cent compared to 1990.
To integrate the objectives of the Kyoto Protocol, France adopted the Climate Plan in 2004, which provides the possibility for local authorities to establish territorial climate-energy plans, which have become territorial climate-air-energy plans (PCAET) under Article L 229-26 of the Environmental Code resulting from the Law on energy transition for green growth. According to Article R 229-51 of the Environmental Code,23 this plan 'includes a diagnosis, a territorial strategy, an action programme and a monitoring and evaluation system'. The decree of 4 August 2016 on the territorial climate-air-energy plan sets out the list of atmospheric pollutants and the sectors of activities to be taken into account by the authorities concerned.
In the five-year Climate Plan report presented in July 2018, France has acknowledged its delay in meeting its greenhouse gas emission reduction targets. The National Low Carbon Strategy for the period 2014-2018 has been set at a target of 440 MtCO2, but could reach 458 MtCO2 by the end of the year.24 France would aim for carbon neutrality by 2050 and wants to become champion of the transition to fossil fuel-free economy.
Outlook and conclusions
The legal movement in climate litigation and corporate social responsibility is flourishing in France. To date, there have been three appeals: first from the association Notre Affaire à Tous (1), then from the municipality of Grande-Synthe (2) and finally from the failure of the multinational Total to exercise due diligence (3).
i The recourse named the 'case of the century'
Following the Urgenda case, lawyers and activists founded the association Notre Affaire à Tous to bring the first action for liability against the state in climate matters. On 17 December 2018, the case of the century was launched by sending a preliminary request for compensation to the head of government and 11 ministers. Two months later, on 15 February 2019, the government responded to the request by recalling its climate change policies. This was an insufficient response.
Subsequently, on 14 March 2019, the appeal in full litigation against the State's inaction on climate change was filed with the Paris Administrative Court. On 20 May 2019, the associations Notre Affaire à Tous, Greenpeace France, Oxfam France and the Fondation pour la Nature et l'Homme filed a supplementary brief with the Paris Administrative Court. The claimants are thus bringing an action for liability against the state for climate inaction by detailing the state's failures in the field of climate change since the first IPCC report in 1990 and the Grenelle de l'environnement. The case is ongoing.
ii The appeal of the municipality of Grande-Synthe
Damien Carême, the mayor of Grande-Synthe in the North, filed an ex gratia appeal with the State on 19 November 2018 for 'inaction in the fight against climate change'. It should be recalled that the city of Grande-Synthe is located below sea level and is particularly exposed to the risk of flooding. The mayor of this municipality, through his lawyer Corinne Lepage, brought three actions: on the one hand, an application to appoint an expert on the effects of climate change, on the other hand, an action to characterise the liability of the State for failing to take sufficient measures, and, finally, an action in excess of the power to challenge the Climate, Air and Energy Plan.
The request of the municipality of Grande-Synthe was registered on 23 January 2019 with the Administrative Jurisdiction Division of the Conseil d'Etat. On 9 September 2019, the Minister of Ecological and Solidarity Transition responded to the request through several observations to the request that do not support the request. The case is ongoing. Requests for intervention from large public authorities will support the initial request in the coming days.
iii The recourse against the multinational Total for breach of the duty of care
On 23 October 2018, 13 local authorities called on the multinational Total, France's largest greenhouse gas emitter according to the Heede report. The local authorities have requested that Total's compliance plan be brought into line with the provisions of Act 2017-399 of 27 March 2017 on the duty of vigilance of parent companies and ordering companies.
In March 2019, Total published its second compliance plan. The applicants noted that climate change is mentioned, but the measures announced are insufficient in relation to the objectives set by the Paris Agreement. On 18 June 2019, the same claimants gave notice to the multinational Total to comply with the law on the duty of care and to take effective measures to deal with global warming. Having failed to submit adequate measures to reduce greenhouse gases, the applicants, on 19 September 2019, brought an action against the French multinational to have it ordered to reduce its greenhouse gases and to comply with the law on the duty of care and the Paris Agreement.
For almost 40 years, French environmental law has benefited from an almost complete system, and the Environmental Code has only brought together existing texts.25 As a result, it is constantly updated.
The statements relating to the important role that France would play in the fight against climate change do not correspond to the effectiveness or sufficient development of domestic law on the protection of biodiversity and energy transition.
Fortunately, the constant support of European law for French law, as well as the place given to the case-law of international courts such as the European Court of Human Rights (which allows citizens' appeals under certain conditions), constitute a bulwark against attempts to make environmental law regress, although the non-regression principle resulting from the law of 8 August 2016 was validated by the Constitutional Council.
1 Christian Huglo is associate lawyer and founder at Huglo Lepage Avocats, Doctor of Law, and Co-director of JurisClasseur Environnement (LexisNexis France). The author thanks Mrs Chancia Plaine for her contribution to the documentation. The information in this chapter was accurate as of January 2020.
2 Law No. 2016-1087 of 8 August 2016 for the reconquest of biodiversity, nature and landscapes, NOR: DEVL1400720L.
3 Law No. 2015-992 of 17 August 2015 on the energy transition for green growth, NOR: DEVX141313992L.
4 Constitutional Act No. 2005-205 of 1 March 2005 on the Environmental Charter, NOR: JUSX0300069L.
5 Decree No. 2008-680 of 9 July 2008 on the organisation of the central administration of the Ministry of Ecology, Energy, Sustainable Development and Town and Country Planning, NOR: DEVK0815768D.
6 Case concerning the pollution of the Mediterranean, and the pollution of the Rhine; see our book Avocat pour l'environnement, LexisNexis, 2013.
7 See Christian Huglo, Le contentieux climatique: une révolution judicaire mondiale, Bruylant, 2018, 396p.
8 Constitutional Act No. 2005-205 of 1 March 2005 on the Environmental Charter, NOR: JUSX0300069L.
9 Decree No. 2008-680 of 9 July 2008 on the organisation of the central administration of the Ministry of Ecology, Energy, Sustainable Development and Town and Country Planning, NOR: DEVK0815768D.
10 C. envir., Article L. 213-1.
11 Law No. 2016-1087 of 8 August 2016 for the reconquest of biodiversity, nature and landscapes: Article 23.
12 C. Public health, Article L. 1311-6.
13 Regulation (EC) No. 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency amending Directive 1999/45/EC and repealing Council Regulation (EEC) No. 793/93 and Commission Regulation (EC) No. 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC, Article 125 and 126: OJ L 396, 30 Dec; rect. No. . L 36, Feb. 5, 2009.
14 Order of 30 July 1996 establishing the Prevention and Precaution Committee, NOR: ENVG965050263A.
15 C. envir., Article L. 541-7-1.
16 CGCT, Article R. 2224-26.
17 Law No. 2014-366 of 24 March 2014 on access to housing and renovated urban planning, NOR: ETLX131313501L.
18 C. envir., Article L. 556-1.
19 C. envir., Article L. 556-2.
20 C. envir., Article L. 556-3.
21 C. envir., Article L. 161-1, I, 1° issued from Act No. 2008-757 of 1 August 2008 on environmental liability and various provisions for adapting to Community law in the field of the environment, NOR: DEVX0700028L.
22 See point 8 of the Declaration.
23 Decree No. 2016-849 of 28 June 2016 on the territorial climate-air-energy plan.
25 See our commented edition of the LexisNexis Environmental Code, 2018.