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INFORSE-Europe Response to EU Commission Consultation on Future Climate Policy and Commitments after 2012


In preparation of the above-mentioned communication, the EU Commission's climate change programme organised a discussion with stakeholders on the topic. This included written comments from stakeholders in October 2004 and a conference on the issue November 22, 2004. INFORSE-Europe's response to the discussion were:

(responding to 7 questions given by the EU Commission)

1. Is it important for the EU to continue to show leadership on addressing climate change?

INFORSE-Europe: Yes, it is very important that the European Union countries continue and strengthen their activities to limit man-made climate change. With some of the largest emissions worldwide, it is crucial that EU countries take a lead on the issue. The lack of commitments from USA make this even more urgent. With the EU internal market rules limiting national action in a number of ways, it is crucial that the EU institutions increasingly becomes a driving forces to limit greenhouse gases.

2. On the basis of the EU’s 2°C long-term objective, what objectives should the EU set for global and EU climate change policy (including targets, timeframes and pathways for emission reductions)?

INFORSE-Europe: Scientific findings (including IPCC 3rd Assessment report) show that in order to avoid catastrophic climate change (defined via the predicted impacts) global mean warming needs to be limited to a peak below 2°C (above pre-industrial level) and that the warming then should be reduced as fast as possible from this peak. This is why INFORSE has recommended that climate change is limited to 1’C in the 21st century, in addition to the 0.6’C in the 19th century. This is our preferred target, but we anyway welcome the objective to limit climate change to 2’C above pre-industrial levels. We propose that to this objective is added an objective of reducing the temperature after the peak of 2’C.

Given the risk of catastrophic effects of climate change for several eco-systems and for vulnerable human habitats, it is in line with the precautionary principle that the EU should act swiftly and strongly to implement long-term reductions with phase out of CO2 emissions from energy and land-use until 2050 and set intermediate targets coherent with the objective of realizing a peak of global GHG emissions before 2020. A delay of global actions by 10 years might make it impossible to reach objectives of limiting global warming to 1.6 – 2’C. Because of this, we support the intermediate target of at least 30% greenhouse gas reductions by 2020, achieved by domestic actions.

3. What type and level of participation should the future climate change regime seek from developed countries and developing countries, what should be the timeframe for such participation and what should the contribution from the EU and other countries?

INFORSE-Europe: EU should continue to seek the active participation in the future climate change regime from all countries in the world and constructively cooperate with them in accordance with UNFCCC article 3.1 common but differentiated responsibility and respective capabilities but should not take non-action from some parties as an excuse for not going ahead with a coalition of the willing if need be. In the long- run, most developing countries will also have to limit their emissions, in order for global emissions not to exceed the threshold of a 1.6 - 2°C maximum warming target. EU should put support for developing countries to mitigate climate change as a centrepiece in its foreign and development policy.

INFORSE-Europe support the proposal of a multi stage approach divided in three tracks: The Kyoto track, a Greening (decarbonization) track and an Adaptation Track.

The Kyoto track builds upon the UNFCCC and the Kyoto Protocol, with its system of legally binding absolute emission reductions and compliance regime. This track must be used to set targets for the coming commitments periods as soon as possible for countries that will cooperate to reduce climate impacts. This cooperation should be used to drive rapid technological development and diffusion, and provide the technological basis for win-win solutions to climate and sustainable development objectives, in particular for the participating countries.

The ‘Greening’ (decarbonisation) track would additionally drive the rapid introduction of clean technologies that can reduce emissions and meet sustainable development objectives in developing countries that do not have commitments yet under the Kyoto track. The industrialized countries should provide resources and technology for this track, but should do this in partnership with the developing countries and not conditioned on other policies.

The Adaptation track should provide the resources to the most vulnerable regions (small island states, least developed countries) to deal with unavoidable climate changes.

The level and the character of the mitigation actions within this framework would be determined by reference to agreed level of per capita emissions, ability or capacity to act
(including measures such as per capita income) and historical responsibility. Industrialized countries have the obligation to act first to reduce their emissions in absolute terms. A combination of factors such as per capita emissions, ability or capacity to act, and historical responsibility could be used to determine when and how countries move from the ‘Greening’ track to the Kyoto track.

4. Which technological solutions should be allowed or promoted (e.g. renewable energy, nuclear energy, carbon sequestration, carbon capture and storage)?

INFORSE-Europe: It is the position of INFORSE-Europe that the solutions to be promoted are renewable energy and energy efficiency, in a multitude of ways. Our network and many others are showing how this is possible, on national, EU and global level (see our website for details regarding our work on visions for sustainable energy developments).

Nuclear power is not a sustainable solution for a number of reasons including the safety and waste problems. One problem is that they it reduces the opportunities for renewable energy and energy efficiency because of the inflexibility of nuclear power reactors compared with other power plants and because of the large human and financial resources that the nuclear power require, resources that could be used more cost-effectively for energy conservation and renewable energy.

Biological carbon sequestration is not a real alternative to reductions: it is only possible to store carbon in plants for a limited period of time, the stored carbon can be released quickly, e.g. by forest fires, and the carbon cycle in the soil is not adequately understood to give sufficient certainty of the actual sequestration. In addition, some practical sequestration projects have shown very negative local impacts, mainly because of the introduction of monoculture plantations with substantial pesticide use.
While biological sequestration is not an alternative to reduce emissions, sustainable land-use is important. This must include that the land-use does not lead to net carbon emissions from the land. In some countries the restoration of the carbon balance of land-use, stopping unsustainable land and biomass might be the most important measure to reduce climate change impacts.

Carbon capture and storage is a more costly and less safe solution than change to efficient use of renewable energy. Large investments in this technology instead of investments in renewable energy and energy efficiency is an unnecessary costly way of mitigating climate change. Regarding storage, storage in the sea is very likely to have substantial negative effects, and must be excluded for this reason alone.

The promotion of renewable energy and energy efficiency must include a number of measures on European as well as on national levels. We are in favor of:
· Internalisation of external costs, primarily with increased energy and carbon taxes that partly replace other taxes, partly are recycled to promote shifts away from fossil fuels to energy efficiency and renewable energy.
· Stronger enforcement of cost-effective energy-efficiency standards, to reduce the most energy consuming products This could be done as part of an ambitious implementation of the coming eco-design directive.
· A faster and more visible energy efficiency labelling system, covering more categories of products
· Reduced emission caps in all sectors covered by the emissions trading scheme
· Substantially increasing allocations for renewable energy and energy efficiency technologies during the next mandate of the Commission. These allocations should correct the present bias toward nuclear and fusion technologies.
¨ Dynamic feed-in systems for renewable energy with guaranteed prices
¨ That the EU member states commit to binding annual reductions of at least 1% energy consumption per year in the EU-25.
¨ Implementation premium prices. To be successful, tariffs must be high enough to ensure competitiveness, be based on 10–15 year contracts, and reduced over time.
¨ Provide priority access for renewable energy to the grid, including transparent and economically fair charging systems for grid access for renewable energy and cogeneration;
¨ Align other policies, particularly transport, development, regional and structural funds and education with the climate change policy framework;
¨ Improve financial support for renewable energy start-ups;
¨ Promote green public procurement of energy efficient products as well as energy from renewable sources;
¨ Keep decision-makers well-informed about energy efficiency and renewable energy technologies and markets;
¨ Ensure EU, multilateral and national public sector financial institutions to support the transfer to renewable technologies adequately;
¨ Promote renewable energy at regional and local levels;
¨ Include local solutions as eligible for support from Trans-European network funding, when the local solutions yield the same benefits (security of supply etc) as the network projects do;

5. Should the future global climate regime maintain the key elements of the Kyoto Protocol, including the Kyoto mechanisms (joint implementation, the clean development mechanism and emissions trading) and what other elements should such regime contain?

INFORSE-Europe: The land use, land use change, and forestry measures under article 3.3 and 3.4 of the Kyoto Protocol are flawed and threaten to seriously undermine the environmental integrity of the protocol and should therefore not be included in future agreements.

The use of emissions trading (as defined in the Kyoto Protocol) has not proven effective to reduce global emissions, and should not be maintained in future effective climate regimes.

In general, flexible mechanisms should not be used to replace national action. They should be brought into play when countries experience higher than expected emissions at a too late stage to introduce sufficient national actions.

There is a great need to create additional financial streams independent of current UNFCCC Annex I pledges e.g. international aviation ticket taxes, levy on financial transactions to increase funding for adaptation, technological transfer and mitigation measures in LDCs and Non Annex I countries.


6. What are the costs of taking further action on climate change, including competitiveness impacts, and how can/should impacts be addressed?

INFORSE-Europe: The question of costs of taking action to combat climate change is secondary in the face of the grave threat we face to the general well-being of our citizens.

There is widespread agreement among scientific energy modellers that the costs of meeting ambitious climate targets are low compared to expected income growth.

Given the other benefits of reducing fossil fuel use (security of supply, reduce market demand, local environmental benefits), the costs for energy efficiency and many types of renewable energy can be paid by these other costs, if sufficient markets are built, and financing is available on the conditions used for energy infrastructure investments.

If renewable energy and energy efficiency is introduced when replacements of equipment is anyway needed (from new appliances to new power plants), the extra costs are very often offset by the energy savings.

It is also crucial that the policy measures used are cost-effective. E.g it seems that grandfathering of emission permits for emissions trading is a very inefficient and costly approach; thus this approach should be limited.

7. What are the benefits of taking further action on climate change, including avoided damages, competitiveness impacts and ancillary benefits, and how can/should these be encouraged or optimized?

INFORSE-Europe: Early climate policies in Europe will speed up technological development and create competitive advantages for the time when other countries start cutting GHG emissions.

Efficiency gains from restructuring company operations can in many sectors lead to great gains for industry instead of costs. These so-called ‘no regret options’ should be embraced by all companies and should be encouraged.

Activities that reduce fossil fuel use and replace it with use of local resources have a number of additional benefits such as increased security of energy supply & reduced local pollution. Many of them also contribute to increased employment in the EU countries, where a large part of the equipment is produced.

Further actions on climate change, included increased use of renewable energy and increase of energy efficiency, should be encouraged in a number of ways, on local, national and European level. This should include, but is not limited to, the proposals given in the answer to question 4.

The solutions should be optimised by:
· setting the market conditions right to promote low-carbon solutions
· control existing monopolies that promote fossil fuel use in the energy sector, not allowing these to halt the phase out of fossil fuels
· give targeted support to technologies that could become substantially more cost-effective via technology learning, if their market is expanded.

Read INFORSE-Europe article about European climate policy here

Read about the Commission activities at

All inputs to EU Commission Stakeholder Consultation, October 2004

Read other comments to future climate policy:

Climate Action Network Europe