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23 February 2010
BUSINESSEUROPE PROJECT “7th EU Environment Action Programme”
QUESTIONNAIRE on CLIMATE CHANGE
The 6th EU Environment Action Programme (EAP6) defined a Community environment
policy framework for the period July 2002 – June 2012. It sets out objectives and
priority areas for action for 1) climate change, 2) nature and biodiversity, 3)
environment and health and 4) sustainable use and management of natural resources
and waste.
In the field of climate change policy, the present questionnaire aims at collecting
opinions on:
- evaluation of the EAP6
- future long-term (horizon 2020) challenges and opportunities for business.
It is proposed to evaluate climate change policy1 and to reflect on the future long-term
challenges/opportunities in relation to the following six key criteria:
I. Priorities and targets
II. Policy instruments
III. Better regulation / policy-making process
IV. Integration of environmental concerns into other policy areas (and vice-versa)
V. Global level playing field / international dimension
VI. Implementation and enforcement / Internal Market
For each section of the questionnaire, a first analysis from the BUSINESSEUROPE
EAP7 Drafting Group2 is included in order to provide a basis for further input from the
relevant Working Group (Climate Change Working Group).
The input provided by the Drafting Group is structured according to the sub-points laid
out in Article 5.2 of the 6th EAP (1. Kyoto Protocol, 2. Energy Sector, 3. Transport, 4.
Industry, 5. Other Sectors, 6. Other Instruments)
A final section of the questionnaire, offers the possibility to provide additional
comments on issues not covered by other questions.
Thank you for sending your comments by 10 March to: [email protected]
1
As stated in the 6th EU Environment Action Programme and ensuing EU plans and policies
This Drafting Group consists of business representatives from various sectors. It has devised
this questionnaire and will be responsible for incorporating the comments received from the
responsible Working Groups.
2
THE CONFEDERATION OF EUROPEAN BUSINESS a.i.s.b.l.
AV. DE CORTENBERGH 168
TEL +32(0)2 237 65 11
BE-1000 BRUSSELS
FAX +32(0)2 231 14 45
BELGIUM
VAT BE 863 418 279
E-MAIL: [email protected]
WWW.BUSINESSEUROPE.EU
I.
PRIORITIES AND TARGETS
A) Evaluation of EAP6:
Guiding questions:
- Do you think that the climate change priorities and targets set in EAP6 were adequate
and well-defined (e.g. integration of the three pillars of sustainability, i.e. economical,
social and environmental, worldwide impact, balance between indicative and legally
binding targets, etc.)?
- Were any important climate change priorities or targets missing?
- Were climate change priorities and targets based on a sound scientific knowledge?
Elements from a first exchange of views in EAP7 Drafting Group:
Overall:
- EAP6 rightly recognises the need to tackle the risks of climate change. The ensuing
2007 Energy and Climate Package with the "20/20/20 targets" constitutes an ambitious
approach to tackle the challenge comprehensively.
- However, the targets and priorities set risk tackling the challenge not in the most costefficient manner: the 20% renewable energy target could translate into increased
energy costs for European society, while not enough weight is being put on energy
efficiency or cost efficient low-carbon technologies like nuclear energy. The EAP6
target of doubling the share of CHP in the EU has not been followed up by appropriate
legislation. If the 20% emission reduction target stays unilateral, the risk of carbon
leakage increases.
3. Transport
The emissions from domestic transport have increased considerably between 1990
and today.
What is your opinion (please provide facts and figures)?
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B) Definition of long-term challenges and opportunities for business:
Guiding question:
- On the horizon 2020, what are the key challenges and opportunities for business in
terms of climate change priorities and targets?
Elements from a first exchange of views in EAP7 Drafting Group:
1) Ambitious climate policies must continue to be pursued but better integrate the
dimensions of energy-security and economic competitiveness. For example, no "away
from oil" strategy at all cost: Industry needs reliable and competitive supplies of raw
materials.
2) Fostering high energy efficiency (e.g. from transport and buildings) throughout the
value chain – do we need a binding energy efficiency target?
3) Foster innovation and growth as a prerequisite for the ability to finance climate
protection measures. How should the EU climate strategy be revised to achieve more
action in other parts of the world?
What is your opinion (please provide facts and figures)?
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II.
A)
POLICY INSTRUMENTS3
Evaluation of EAP6:
Guiding questions:
- What are the policy instruments in existence in the field of climate change?
- Are these instruments appropriate (i.e. integration of the economic dimension, costeffective and flexible enough to create opportunities for innovation and business
development?
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E.g. Market-based instruments (emission trading, tradable environmental permits), fiscal
instruments (taxation, etc.), financial instruments (subsidies, etc.), standards / minimum
requirements, demand-side policy (green public procurement, product labelling, etc.), R&D
programmes, voluntary instruments, etc.
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Elements from a first exchange of views in EAP7 Drafting Group:
Kyoto Protocol:
- Global Climate Strategy: Top-down strategy with a conditional offer of reducing
emissions by 30% by 2020: has so far failed to trigger international action towards a
legally binding, post-Kyoto agreement
Energy and 4. Industry:
- The EU Emission Trading Scheme (ETS), has been in force since 2005 to reduce
emissions from energy-producing and -using industries. This has incited some EU
companies to become first movers in low-carbon solutions. But is has also created
some distortion of international competition, which looks likely to increase due to the
auctioning of a large part of the allowances from 2013.
- Renewable Energy Directive:
has helped create long-term predictability for
renewable investments and thus underpinned the first-mover advantage of renewable
energy companies in some EU countries. However, renewable energy subsidies are
very costly in terms of increased energy prices for society. So far, shortcomings in
technologies, economic efficiency, safety of supplies and quality are limitations to a
wider use of renewable raw materials. Frequent limitations to a wider use of renewable
raw materials are lacking quality or low volumes of these materials, non-competitive
prices and the non-availability of processing technologies. Here, methods of white and
green biotechnology can be of much help.
Directive 2004/8/EC supporting the dissemination of CHP technology in EU: expert
evaluation of this Directive needed ...
Transport:
- The policy to set standards is the right one in principle but the directive setting
emission standards for vehicles does not give enough time for companies to do
necessary investments (to check by transport experts ...)
Other Instruments:
- SET Plan to stimulate research and development in new technologies: lacks teeth
due to lack of money
What is your opinion (please provide facts and figures)?
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B) Definition of long-term challenges and opportunities for business:
Guiding question:
- On the horizon 2020, what are the key challenges and opportunities for business in
terms of policy instruments in the field of climate change?
Elements from a first exchange of views in EAP7 Drafting Group:
1) Devise policies which encourage and enable private investments in low-carbon
solutions
2) Strengthen carbon trading across the world
What is your opinion (please provide facts and figures)?
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III.
A)
BETTER REGULATION / POLICY-MAKING PROCESS
Evaluation of EAP6:
Guiding questions:
- Have impact assessments for legislative proposals on climate change taken into
account all relevant costs and opportunities?
- Has climate change legislation been simplified / become more coherent?
- Has the administrative burden been reduced?
- Is climate change legislation applicable by SMEs?
- Are stakeholders sufficiently and adequately involved?
- Was the policy-making procedure of sufficient quality (example of conciliation in
Waste Framework Directive)?
Elements from a first exchange of views in EAP7 Drafting Group:
General:
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- The political decision to rapidly adopt the Climate and Energy Package by end-2008
was not conducive to the quality of the legislation. Especially in the revised ETS
Directive many crucial decisions had to be deferred to the comitology procedure.
- The comitology procedure does not provide for adequate consultation of
stakeholders.
Energy and Industry:
- The revised ETS Directive constitutes a significant administrative burden. An opt-out
for SMEs is foreseen but the modalities for this opt out are not clear as yet.
What is your opinion (please provide facts and figures)?
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B) Definition of long-term challenges and opportunities for business:
Guiding question:
- On the horizon 2020, what are the key challenges and opportunities for business in
terms of better regulation / policy-making process in the field of climate change?
Elements from a first exchange of views in EAP7 Drafting Group:
1) A better management of the comitology process. The involvement of industry is
essential when technical provisions have to be adopted
2) The EU20/20/20 strategy must be coherent with a future EAP7
3) The schedule timing for legislation implementation must take into account the
industrial investment cycles
What is your opinion (please provide facts and figures)?
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V) INTEGRATION OF ENVIRONMENTAL CONCERNS INTO OTHER POLICY
AREAS (AND VICE-VERSA)
A)
Evaluation of EAP6:
Guiding question:
- How have climate change concerns been integrated in other policy areas and viceversa (e.g. in transport, buildings / cities, energy industry, agriculture, research and
innovation)?
Elements from a first exchange of views in EAP7 Drafting Group:
- In general, climate policy aspects have been integrated in all related policy areas.
- Possible exception: agriculture (check with experts...)
What is your opinion (please provide facts and figures)?
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B)
Definition of long-term challenges and opportunities for business:
Guiding question:
- On the horizon 2020, what are the key challenges and opportunities for business in
terms of integration of climate change concerns into other policy areas (and viceversa)?
Elements from a first exchange of views in EAP7 Drafting Group:
1) Reform of the CAP in the new EU budget review to take into account climate policy
objectives (?)
2) Include systematically, in the legal basis, the articles 175 and 95 of EC Treaty, when
new legislation is developed (?)
What is your opinion (please provide facts and figures)?
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VI) GLOBAL LEVEL PLAYING FIELD / INTERNATIONAL DIMENSION
A)
Evaluation of EAP6:
Guiding questions:
- Does the EU climate change policy create a competitive advantage for EU business?
- How does the climate change policy create distortions of competition for EU
business?
- Are the right transnational / international arrangements in place?
Elements from a first exchange of views in EAP7 Drafting Group:
Kyoto Protocol:
- The UNFCCC process to reach an international and legally binding post-Kyoto
agreement has so far not been successful. Is the policy coordination with major
economic partners sufficient?
Industry:
- The Climate and Energy package created distortion of international competition
through unilateral pricing of CO2 in some sectors and a general upward pressure on
electricity prices.
What is your opinion (please provide facts and figures)?
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B)
Definition of long-term challenges and opportunities for business:
Guiding question:
- On the horizon 2020, what are the key challenges and opportunities for business in
terms of global level playing field in the field of climate change?
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Elements from a first exchange of views in EAP7 Drafting Group:
1) Easing of competitive distortion through adequate allocation of free ETS allowances
and compensation for indirect cost effects
2) Continue promoting a binding global agreement in the areas of mitigation,
adaptation, technology or finance. Is a stronger policy coordination with major
economies outside the UNFCCC process necessary?
What is your opinion (please provide facts and figures)?
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VII) IMPLEMENTATION AND ENFORCEMENT / INTERNAL MARKET
A)
Evaluation of EAP6:
Guiding questions:
- Are the EU climate change policies correctly/sufficiently enforced?
- Are EU/national implementation and enforcement activities transparent?
Elements from a first exchange of views in EAP7 Drafting Group:
Energy and Industry:
- The ETS revision in 2008 improved the distortion of competition created by the
National Allocation Plans through EU-wide allocation rules.
- It remains to be seen how the increase in electricity prices induced by the ETS
(indirect effects) can be compensated by measures allowed by the revised ETS from
2013 onwards.
- The national support schemes for renewable energy production have created a strong
renewable sector in some countries but also competitive distortions throughout the EU.
What is your opinion (please provide facts and figures)?
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B)
Definition of long-term challenges and opportunities for business:
Guiding question:
- On the horizon 2020, what are the key challenges and opportunities for business in
terms of implementation and enforcement in the field of climate change?
Elements from a first exchange of views in EAP7 Drafting Group:
1) Harmonisation of renewable energy support schemes
What is your opinion (please provide facts and figures)?
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VIII) ADDITIONAL COMMENTS
Please add any additional comments on your evaluation of climate change policy
under EAP6 and on future long-term challenges and opportunities
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