The Court of Auditors publishes an investigation into the brownfield fund and land recycling measures

It also falls within the 2020-2021 recovery plan. The Court's investigation focuses on two aspects: firstly, the implementation of land recycling subsidies, including its administrative organization, territorial scope, and budgetary impact; and secondly, the effectiveness and efficiency of the program in relation to its assigned objectives. Four years after the initial commitments, and with some projects completed, the Court acknowledges the program's positive effects but criticizes its implementation and makes recommendations for its long-term sustainability.

A new tool serving the objective of land conservation, which remains too poorly targeted and monitored.

While land conservation policies are not new in France, employing various public action tools – taxation, urban planning and land artificialization reduction standards, land banking on developed sites, and the remediation of polluted sites with ADEME (the French Agency for Ecological Transition) – the brownfield fund, and subsequently the "land recycling" measure of the Green Fund, represent a shift in method and scale, with a budget of €1,4 billion over four years, compared to the €2 to €6 million previously allocated annually by ADEME to the remediation of polluted sites. This fund is characterized by an original decentralized structure, overseen by the Ministry of Ecology and managed at the local level. This approach would require more regular local engagement as well as more robust monitoring and oversight. The criteria for defining brownfield sites and eligible projects demonstrate a broad openness which, at the time of making the scheme permanent, should be better circumscribed.

Furthermore, the difficulty in identifying other state funding sources contributing to the same objectives, as well as the infrequent nature of audits, hinders an evaluation of results in light of the established goals. The Court therefore recommends ensuring the professional development of the relevant departments regarding land redevelopment and tightening the eligibility criteria for brownfield sites, particularly with regard to environmental requirements.

Unsatisfactory results compared to the objectives pursued.

The Court notes that the evaluation process did not accompany the implementation of land recycling subsidies and that the ability to measure their effectiveness is hampered by unreliable data. In total, the brownfield fund and the land recycling measure of the green fund (2021-2024) financed 2.778 projects, for an average amount of approximately €500.000. These projects originated primarily from local authorities or their agencies (61% of project promoters), with a clear underrepresentation of private actors. The investigation highlights the priority given to the urban regeneration of rural or peripheral areas, rather than to the objective of land conservation. The uncertain results regarding the actual reduction of the artificialization of natural and forest areas, or support for housing production, demonstrate that the coexistence of too many dispersed objectives hinders the clarity and measurement of expected results. The Court recommends monitoring, tracking and evaluating projects, their financing and their effects with an appropriate tool and carrying out impact assessments by type of brownfield site to improve targeting and the expected leverage effect of the scheme.

A mechanism to be included in a broader public policy

To ensure the effectiveness of the land recycling subsidy program, several obstacles need to be addressed. First, the potential of brownfield sites remains uncertain despite the existence of a new national tool for identifying them. Accurately identifying brownfield areas and their characteristics appears to be the primary lever for mobilizing stakeholders around land recycling. Secondly, it would be necessary to strengthen partnerships with local authorities responsible for urban planning strategies and frequently co-financing land recycling projects, and to better utilize existing support, land acquisition, and development tools and structures. State subsidies, better targeted, should serve as an incentive for local authorities to fulfill their obligations to implement the "zero net land take" (ZAN) policy. Finally, it would be essential to ensure the consistency of the subsidy with other public policy levers, particularly regulatory and fiscal ones.

The effectiveness of the subsidy has not been demonstrated.

Thus, considering the numerous and evolving objectives assigned to the brownfield fund, the Court's assessment suggests that its effectiveness and efficiency, and particularly its ability to trigger funded projects, are inconclusive. The observations and results of the survey, conducted using econometric tools on a significant sample of projects, call for rigorous evaluations to define criteria for targeting these subsidies to projects where the leverage effect is most certain. They also argue, without delay, for a review of certain overly open allocation procedures and, more fundamentally, for clarification of the intended purpose of this tool. More than just an additional envelope available to the territorial State to requalify rural or declining territories, the brownfield fund, like the related measures of the green fund that succeeded it, if they are to have as their objective to act in favor of reducing the artificialization of soils, should be thought of and prioritized for this purpose, in support of the planning policies of local authorities.