Although the ability of environmental interest groups to bring actions before the court has been extensively discussed in the context of the recent white paper on civil liability, the court itself has adopted a restrictive approach to who may bring proceedings. In a 1978 case (Greenpeace International v European Commission C-321/95) the pressure group Greenpeace brought an action attempting to annul the grant of funds to Spain to finance the building of two power stations on the Canary Islands, the building of which had commenced without carrying out appropriate environmental impact assessments (see Section 11.2). The Treaty provides that a decision addressed to another party (the grant of funds to the Spanish government) may only be challenged by a third party (Greenpeace) if it is of ‘direct and individual concern’ to them. It was held that Greenpeace had no attributes peculiar to them which meant that the decision affected them over and above anyone else, and therefore that they did not possess the necessary standing to challenge the decision.