European Commission Replies to Councilor Martini’s letter about the Bosco dello Sport



Recovery & Resilience Task Force

SG.RECOVER.A.1 – Italy, Finland, Sweden, Denmark – European Semester



Dear Ms Martini,

Thank you for your letter dated 21 April 2022 addressed to the President of the European Commission Ursula von der Leyen. The President asked me to reply on her behalf.

The presentation of an Investment Plan for Urban Integrated Plans for the 14 metropolitan areas of Italy is one of the ‘milestones’ (M5C2-13) of Italy’s recovery and resilience plan (RRP). The Annex to the Council Implementing Decision (CID) on the approval of the Italian RRP sets out the end of 2022 as indicative timeline for the submission of the Investment Plan to the European Commission1.

At this stage the European Commission is not in possession of all the elements of the Urban Integrated Plan of the City of Venice and, in particular, the project “Bosco dello Sport” mentioned in your letter. We have requested the Italian authorities to share all the material well in advance to enable us to assess the relevant milestone and, where needed, adjust any elements to ensure full compliance with the provisions of the CID (including the “Do No Significant Harm” (DNSH) principle and that all interventions fall under one of the milestone’s three categories.

I would like to add that leaving aside the assessment of the satisfactory fulfilment of the milestone by the Commission, Member States are primarily responsible to ensure compliance with EU law. The EU’s Strategic Environmental Assessment Directive applies to land use plans and may be relevant in this case. Other potentially relevant EU legislation includes the Environmental Impact Assessment Directive, the Habitats Directive and the Ambient Air Quality Directives. Italy has transposed all four directives into its national legislation and is following closely their implementation.

In this context and in particular regarding the implementation of the Ambient Air Quality Directives, the European Commission decided on 17 May 2018 to refer the Republic of Italy to the Court of Justice of the EU for exceedances of particulate matter (PM10) limit values2, on 7 March 2019 for exceedances of nitrogen dioxide (NO2) limit values3 and sent a letter of formal notice concerning exceedances of PM2.5 on October 20204. On 10 November 2020 and on 12 May 2022 the European Court of Justice concluded that Italy persistently exceeded the daily limit value for particulate matter (PM10)5 since 2005 and since 2010 for NO26.

Yours sincerely,


Head of Unit






5 Italy has infringed EU law on ambient air quality (

6 CURIA – Case information (


[Ed. Note: I publish this letter here in its original unedited form (including the misnomer of Andrea Martini as “Ms”), but cannot help but notice that the letter points out that Italy is bound by at least four EU environmental laws that could impact the Bosco dello Sport project, one of which – the Ambient Air Quality Directives – Italy has already been found to be in long-standing violation.]

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