Opinion of the European Economic and Social Committee on the Proposal for a Decision of the European Parliament and of the Council on the effort of Member States to reduce their greenhouse gas emissions to meet the Community's greenhouse gas emission reduction commitments up to 2020 COM(2008) 17 final — 2008/0014 (COD)
Date: 2008-07-09
Institutions: European Economic and Social Committee
Subjects: ESC opinion, EU environmental policy, climate change, developing countries, greenhouse gas, international agreement, reduction of gas emissions, sustainable development, tradeable emission permit

3.2.2009

EN

Official Journal of the European Union

C 27/71

Opinion of the European Economic and Social Committee on the ‘Proposal for a Decision of the
European Parliament and of the Council on the effort of Member States to reduce their greenhouse
gas emissions to meet the Community's greenhouse gas emission reduction commitments up
to 2020’

COM(2008) 17 final — 2008/0014 (COD)

(2009/C 27/16)

On 11 February 2008, the Council decided to consult the European Economic and Social Committee, under
Article 175 of the Treaty establishing the European Community, on the:

Proposal for a Decision of the European Parliament and of the Council on the effort of Member States to reduce their
greenhouse gas emissions to meet the Community's greenhouse gas emission reduction commitments up to 2020.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing
the Committee's work on the subject, adopted its opinion on 4 June 2008. The rapporteur was Mr Morkis.

At its 446th plenary session, held on 9 and 10 July 2008 (meeting of 9 July), the European Economic and
Social Committee adopted the following opinion by 116 votes to 2 with 8 abstentions.

1. Summary of the EESC's comments and recommenda-

tions

1.1
The European Economic and Social Committee welcomes
the European Commission's initiative under which, to combat
climate change, Member States are asked to share the effort of
meeting the Community's commitment to reduce greenhouse
from sources not covered under Directive
gas emissions
2003/87/EC (sources outside the EU emissions trading scheme
(EU ETS)) from 2013 to 2020.

1.2
The Committee recognises and endorses the EU's leading
role in the international negotiations on environmental and
climate protection commitments. Through its own commit-
ments, the EU is leading by example and seeking to spur other
countries on to comparable measures.

The Committee considers that civil society has a key role
1.3
to play in implementing the decision and meeting the commit-
ments undertaken by the countries concerned. The Member
States
should do more to promote community initiatives
designed to help cut greenhouse gas emissions and develop
ways of backing up such initiatives:

— Civil society as a whole could play a key role in imple-
menting this decision. The requirements of the decision and
its means of implementation in each Member State thus
need to be more widely disseminated.

— There is also a need to increase the emphasis on educational
campaigns to raise public awareness and understanding of
the need for efforts to reduce greenhouse gas emissions.

— It is also vital to train experts and raise broad public aware-
ness in the fields of energy-saving, environmental protection
and climate change.

The Committee believes that measures to cut greenhouse
1.4
emissions should be implemented in such a way as to protect
and even enhance Europe's economic competitiveness in a long
term perspective. Renewable energy development and energy
efficient products and modes of production will increasingly be
in demand in the world, and Europe is well placed to gain a
competitive edge by becoming a world leader in many of these
areas. The EU and the Member States must support such R&D.

1.5
Under Article 3(3) of the proposed decision, a Member
State may carry forward from the following year a quantity of
greenhouse gas emissions equal to 2 % of the limit of that
Member State or, if the emissions are below the limit in para-
graph 2, may carry over its excess reductions to the subsequent
year. This provision is too rigid, as the one-year timeframe lacks
the flexibility required to implement large-scale projects and
is especially important
deliver good results. That
for small
Member States
implementing large-scale GHG mitigation
projects.

The Commission proposes that each Member State should
prepare a plan for achieving its national target. However, the
average annual emissions of GHG during the period 2013-2020
should not be higher than the average of annual emissions from
2005 to 2020. In the Committee's view it will be important for
the implementation of these plans to be monitored regularly at
national and European level to allow any divergences to be iden-
tified promptly and corrective action taken.

1.6
In order to enhance the overall cost efficiency of the
total commitment of the Community and to achieve the joint
objectives at the lowest cost, the Committee feels that the deci-
sion should enable a Member State, on the basis of bilateral,
intergovernmental agreements, to be able to transfer part of its
allowed GHG emissions entitlement to another Member State.

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Official Journal of the European Union

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The Committee feels that, by using flexible tools in
1.7
projects designed to secure the joint implementation of
the
Clean Development Mechanism, an appropriate balance must be
struck between action taken within the EU to cut greenhouse
gas emissions on the one hand, and a sense of solidarity in the
face of the introduction of emission-reducing measures in devel-
oping countries on the other. However, the use of flexible tools
should be appropriate only when they really reduce global
GHG emissions. They should not stimulate leakage of GHG
emissions from EU to non-EU countries.

1.8
The Committee endorses the commitments made and
approves effort-sharing between Member States. It believes the
public must be better informed about the principles underpin-
ning effort-sharing.
for effort-sharing, an
assessment must be made of the specific circumstances of each
individual country, the costs involved in cutting emissions and
the impact on that country's competitiveness and development.
The effort-sharing decision should lead to an equal relative cost
of mitigation in relation to GDP of each country.

In arrangements

The Committee calls on the Commission to establish a
for

1.9
compliance regime, under which Member States would,
instance, be fined for exceeding the set emission levels.

buting adequately according to their responsibilities and respec-
tive capabilities. Within these parameters,
the Community
would have to seek to cut greenhouse gas emissions by 30 %
by 2020.

The present proposal

for a decision determines the
2.5
contribution of Member States to meeting the Community's
greenhouse gas emission reduction commitment from 2013
to 2020 for greenhouse gas emissions from sources not covered
under Directive 2003/87/EC (sources outside the EU ETS).

The proposed decision lays down rules on the determin-
2.6
the contribution of Member States to meeting the
ation of
greenhouse gas emission reduction commitment of the Com-
munity from 2013 to 2020.

2.7
The Commission also takes the view that greenhouse gas
reduction efforts should be shared among Member States, taking
into account economic differentials and each country's per capita
GDP. Thus, Member States that currently have a relatively low
per capita GDP and high GDP growth expectations for the future
should be allowed to have higher greenhouse emissions in 2020
than in 2005.

2. Introduction: the Commission document

On 23 January 2008,

2.1
the European Commission
unveiled a package of proposals to combat climate change and
promote renewable energies.

2.8
In the light of the proposed differentiation, the Commis-
sion recommends that certain limits be established for indivi-
dual countries, albeit no Member State should be required to
reduce its greenhouse gas emissions in 2020 to more than 20 %
below 2005 levels, and no Member State should be allowed to
increase its greenhouse gas emissions in 2020 to more than
20 % above 2005 levels.

2.2
The purpose of the Commission proposal is to put into
effect the agreement reached at the European Council meeting
on 8 and 9 March 2007 under which the European Union is
committed to a 20 % reduction in greenhouse gas emissions by
2020 compared to 1990, and, also by 2020, to a target share
of 20 % of renewables in its energy consumption.

2.9
The Commission stipulates that each Member State must,
by 2020, limit its greenhouse gas emissions from sources not
covered under Directive 2003/87/EC by the percentage set for
that Member State in the annex to the decision in relation to its
emissions in the year 2005.

2.3
The total effort for greenhouse gas reduction is divided
between the EU ETS and non-ETS sectors. The Commission is
proposing the following approach: a 21 % reduction in EU ETS
sector emissions compared to 2005 by 2020; a reduction of
around 10 % compared to 2005 for the sectors that are not
covered by the EU ETS. Taken together, these reductions will
result in an overall reduction of 14 % compared to 2005, which
is equivalent to a reduction of 20 % compared to 1990.

The Commission's view is that reductions in greenhouse
2.10
gas emissions must
take place every year between 2013
and 2020. However, there is also some degree of flexibility, in
that each Member State is allowed to carry forward from the
following year a quantity equal to 2 % of the greenhouse gas
emission limit of that Member State. Any Member State whose
emissions are below its limit is also allowed to carry over its
excess emission reductions to the subsequent year.

2.4
The Council announced even more ambitious targets
provided that a global and comprehensive agreement is signed
for the period beyond 2012 and that other developed countries
commit
themselves to comparable emission reductions and
economically more advanced developing countries to contri-

Each Member State is to annually limit these green-
2.11
house gas emissions in a linear manner to ensure that the emis-
sions do not exceed the maximum level for that Member State
in 2020 as specified in the annex to the decision.

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2.12
In order to provide for further flexibility for Member
States in implementing their commitments, to promote sustain-
able development in third countries, in particular in developing
countries, and to provide certainty to investors, the Commission
is proposing that Member States should continue to be able to
use CDM credits to help ensure a market for those credits even
after 2012.

2.13
To help ensure such a market as well as to ensure
further greenhouse gas emission reductions within the EU and
thus enhance the implementation of the objectives of the Com-
munity relating to renewable energy, energy security, innovation
and competitiveness, it is proposed to allow the annual use by
Member States of credits from greenhouse gas emission reduc-
tion projects in third countries, until a future international
agreement on climate change has been reached, up to a quantity
representing 3 % of the emissions of each Member State from
sources outside the ETS in the year 2005. This maximum quan-
tity is equivalent to around a third of any Member State's reduc-
tion effort in 2020. Member States should be allowed to transfer
the unused part of that quantity to other Member States.

2.14
The Commission feels that once a future international
agreement on climate change has been reached, Member States
should only accept emission reduction credits from countries
which have ratified that agreement and subject to a common
approach.

2.15
The Commission also takes the view that, following the
conclusion by the Community of a future international climate
change agreement, Member State emission limits should be
adjusted on the basis of the Community's new greenhouse gas
emission reduction commitment as set out in that agreement.

2.16 Member States, in their annual reports submitted under
Article 3 of Decision 280/2004/EC, must report their annual
emissions resulting from the implementation of Article 3 and
the use of credits in accordance with Article 4. Member States
are also to submit an update of their projected progress before
1 July 2016.

3. General comments

The European Commission's initiative under which, to
3.1
combat climate change, Member States are asked to share the
effort of meeting the Community's commitment
to reduce
greenhouse gas emissions from sources not covered under
Directive 2003/87/EC (sources outside the EU ETS) from 2013
to 2020 is an important link in a chain of decisions taken to
combat climate change.

The Committee is convinced that this decision will help
3.2
the Community meet its tasks vis-à-vis environmental protec-
tion and climate change. Community policy in this area must
secure a considerable reduction in greenhouse gas emissions

through the imposition of mandatory requirements on the
Member States, coupled with strict compliance checks.

3.3
At the same time the Committee would like to draw the
attention to the fact that the effectiveness of the Parliament and
Council decision on sharing efforts to reduce greenhouse gas
emissions is significantly dependent on the other two compo-
nents of the energy and climate change package: the directive
on renewable energy sources and the EU-ETS directive. This
means that they must function in direct synergy; any amend-
ment to one will impact on the others.

the negotiations launched in Bali,

3.4
The Community's commitments are to be adjusted
should an international agreement be reached. There are high
in
hopes for
December 2007, which may potentially be of vital importance
for worldwide action up to 2020. It would be most helpful to
wind up these negotiations and secure a climate protection
agreement at the Climate Change Conference in Copenhagen
in 2009. Progress on this front is also expected to be made at a
further climate summit due to be held before then in Poznań,
Poland.

Indonesia,

3.5
It is good that EU is taking the lead in these negotiations.
Through its own commitments, the EU is leading by example
and seeking to spur other countries on to comparable measures.
Although emerging countries such as China, India and Brazil are
not, understandably, set to cut emissions, they are in a position
to curb any increase relative to economic growth. The EESC
encourages the Commission to make every effort to reach an
international
(post-Kyoto) agreement, committing developed
countries to a 30 % cut in greenhouse gas emissions by 2020,
compared to 1990 levels; this would be in line with the projec-
tions of the 4th IPCC report, which estimates that a 25-40 %
reduction by 2020 on 1990 levels is needed to limit global
warming to 2 degrees Celsius above pre-industrial levels. If this
international agreement can be concluded, it will of course be
necessary to revisit this and the other proposals contained in
the Commission's energy and climate change package in order
to recalibrate their objectives to the tighter target. It is important
therefore that all concerned should recognise and plan on the
basis that the targets currently proposed for 2020 are only the
first step and that tighter targets will be needed in due course,
possibly as soon as 2020 and certainly in later years.

3.6
The Committee believes that measures to cut greenhouse
emissions should be implemented in such a way as to protect
and even enhance Europe's economic competitiveness in the
long term. Renewable energy development and energy efficient
increasingly be in
products and modes of production will
demand in the world, and Europe is well placed to gain a
competitive edge by becoming a world leader in many of these
areas. The EU and the Member States must support such R&D.

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3.2.2009

Otherwise, the objectives will be difficult to achieve. It is also
vital to train experts and raise broad public awareness in the
fields of energy-saving, environmental protection and climate
change.

3.7
Civil society has a key role to play in implementing the
decision and meeting the commitments undertaken by the
countries concerned. The Member States should do more to
promote community initiatives designed to help cut greenhouse
gas emissions and develop ways of backing up such initiatives:

— Civil society as a whole could play a key role in imple-
menting this decision. The requirements of the decision and
its means of implementation in each Member State thus
need to be more widely disseminated.

— There is also a need to increase the emphasis on educational
campaigns to raise public awareness and understanding of
the need for efforts to reduce greenhouse gas emissions.

— It is also vital to train experts and raise broad public aware-
ness in the fields of energy-saving, environmental protection
and climate change.

4. Specific comments

The Committee feels that, by using flexible tools in
4.1
projects designed to secure the joint implementation of
the
Clean Development Mechanism, an appropriate balance must be
struck between action taken within the EU to cut greenhouse
gas emissions on the one hand, and a sense of solidarity in the
face of the introduction of emission-reducing measures in devel-
oping countries on the other. However, the use of flexible tools
should be appropriate only when they really reduce global GHG
emissions. They should not stimulate leakage of GHG emissions
from EU to non-EU countries.

4.2
The Commission is proposing that Member States should
continue to be able to use CDM credits to help ensure a market
for those credits even after 2012. The Committee has concerns
regarding the quality of the certified emissions reductions (CER)
resulting from the CDM and proposes that,
if the investing
States (in projects begun pre-2013) are to continue to benefit
from CER, the baseline should be revised and verified to deter-
mine whether the project is still additional. In the case of new
CDM projects that are planned to go towards a Member State's
contribution to sharing efforts to reduce greenhouse gas emis-
sions, only projects using BAT (best available techniques) as the
baseline should be considered.

per capita GDP, different countries may require different degrees
of effort to achieve the same results in cutting emissions. In
arrangements for effort-sharing, an assessment must be made of
the specific circumstances of each individual country, the costs
involved in cutting emissions and the impact on that country's
competitiveness and development. The effort sharing decision
should lead to equal relative cost of mitigation in relation to
GDP of each country.

4.4
The Committee also draws attention to a glaring incon-
sistency in the text of the decision. The Commission proposes
2005 as the reference year for assessing Member States' efforts
to reduce their greenhouse gas emissions, and 2020 as the end
of the period. Under the second subparagraph of Article 3(2),
each Member State is to annually limit the greenhouse gas emis-
sions concerned in a linear manner. At the same time, under
the first subparagraph of the same article, each Member State is
to ensure that its total greenhouse gas emissions in 2013 from
sources not covered under Directive 2003/87/EC do not exceed
the average annual greenhouse gas emissions of that Member
State from those sources during the years 2008, 2009
and 2010, as reported and verified pursuant
to Directive
2003/87/EC and Decision 280/2004/EC. This means that 2008,
2009 and 2010 serve as the reference years for evaluating the
position in 2013.

4.5
Under Article 3(3) of the proposed decision, a Member
State may carry forward from the following year a quantity of
greenhouse gas emissions equal to 2 % of the limit of that
Member State or, if the emissions are below the limit in para-
graph 2, may carry over its excess reductions to the subsequent
year. This provision is too rigid, as the one-year timeframe lacks
the flexibility required to implement large-scale projects and
for small
deliver good results. That
Member States
scale GHG mitigation
projects.

is especially important

implementing large

The Commission proposes that each Member State should draw
up a plan to achieve its national targets. However, the average
annual emissions of GHG during the period 2013-2020 should
not be higher than the average of annual emissions in 2005. In
the Committee's view it will be important for the implementa-
tion of these plans to be monitored regularly at national and
to be identified
to allow any divergences
European level
promptly and corrective action taken.

4.3
The Commission refers only to the general principle that
countries that have a high per capita GDP are to take on board
tougher reduction commitments, which are to be less stringent
for countries where per capita GDP is lower. However, it is quite
possible that, even if — in relative terms — they have a similar

4.6
In order to enhance the overall cost efficiency of the
total commitment of the Community and to achieve the joint
objectives at the lowest cost, the Committee feels that provision
should be made in the decision whereby a Member State should,
on the basis of bilateral, intergovernmental agreements, be able
to transfer part of its allowed GHG emissions entitlement to
another Member State.

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The Committee calls on the Commission to establish a
for

4.7
compliance regime, under which Member States would,
instance, be fined for exceeding the set emission levels.

4.8
Also, in terms of the equitable geographical distribution
of projects, Article 4(1)(c) is not specific enough as to the appli-
cation of measures on the purchasing of credits.

this decision,

To implement

the Commission should
4.9
provide the Member States with pointers for action, instruments
and other measures. A good first step could be to issue a guide
containing examples of successes already achieved in the EU.

To achieve the objective of this decision, the Committee
4.10
recommends that Member States make use of the Structural and

Brussels, 9 July 2008.

Cohesion Funds for projects that do not produce, or that even
reduce greenhouse gas emissions.

4.11
For ETS installations, provision has been made for the
auction of emission allowances during the next allocation round
from 2013 to 2020. This will secure the funds needed to reduce
greenhouse gas emissions from non-EU-ETS sectors. Part of the
funds obtained in this way should be directed towards economic
sectors that are making an effort to reduce greenhouse gas emis-
sions. The other part should be channelled into a solidarity fund
for developing countries, and allocated to climate change adap-
tation projects in those countries.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

Opinion of the European Economic and Social Committee on the ‘Proposal for a Directive of the
European Parliament and of the Council on the geological storage of carbon dioxide and amending
Council Directives 85/337/EEC, 96/61/EC, Directives 2000/60/EC, 2001/80/EC, 2004/35/EC,
2006/12/EC and Regulation (EC) No 1013/2006’

COM(2008) 18 final — 2008/0015 (COD)

(2009/C 27/17)

On 8 February 2008 the Council of the European Union decided to consult the European Economic and
Social Committee, under Article 175 of the Treaty establishing the European Community, on the

Proposal for a Directive of the European Parliament and of the Council on the geological storage of carbon dioxide and
amending Council Directives 85/337/EEC, 96/61/EC, Directives 2000/60/EC, 2001/80/EC, 2004/35/EC,
2006/12/EC and Regulation (EC) No 1013/2006.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing
the Committee's work on the subject, adopted its opinion on 4 June 2008. The rapporteur was Mr Wolf.

At its 446th plenary session, held on 9 and 10 July 2008 (meeting of 9 July), the European Economic and
Social Committee adopted the following opinion by 138 votes to one with four abstentions.

Contents

1. Summary and conclusions

2. Introduction

3. Commission proposal

4. General comments

5. Specific comments

1. Summary and conclusions

1.1
Capture and long-term storage (CCS) of carbon dioxide
(CO2) released by the use (combustion) of fossil fuels would

substantially help to combat climate change. This technology
should therefore be developed more rapidly and used as soon as
possible.

1.2
The Committee welcomes the Commission's proposed
directive as a prerequisite for the development and use of CCS,
and broadly endorses its content.

1.3
The directive addresses the most important aspects and
sets out provisions to deal with them. In particular, human and
environmental safety issues and the associated responsibilities
are covered, thus helping to secure public acceptance of the
directive and addressing safety concerns on the part of ordinary
citizens.