Sustainability Board

CEEP Opinion on the Commission proposal for a “Clean Energy for All Europeans” package – PDF

Executive summary

  • CEEP welcomes the European Commission proposal for a “Clean Energy for all Europeans” Package and its overall direction. It puts consumers and CO2 emissions’ reduction at the heart of the energy system and contributes in a substantial way to the functioning of the internal energy market which is the basis for the achievement of the EU’s climate and energy objectives in the short and long term.
  • CEEP supports the Commission’s ambition to give the Energy Union a reliable governance system, aiming at higher regulatory stability and predictability than in the past through coherent and transparent European coordination. In principle, CEEP agrees that the objectives of climate action, competition and security of supply can be better achieved at European level. However, following the principle of subsidiarity, Member States should keep sufficient leeway for ambitious national climate and energy policies.
  • CEEP would like to recall that, in addition to the market integration of power from mature renewable energy sources, a well-functioning market for CO2 is an essential tool to drive investments in low carbon energy infrastructure at the least cost for consumers and tax payers and to implement the European climate ambitions. Therefore, the “Clean Energy for all Europeans” Package cannot be isolated from the ETS reform.
  • CEEP deems crucial to ensure that the interplay between the CO2 reduction, renewable energy and energy efficiency targets is fully taken into account. They must not counteract the efforts to strengthen the ETS, supposed to be the EU’s leading tool to achieve its climate and energy objectives.
  • CEEP pleads that the ongoing review of the energy market design recognises that system adequacy is vital to the functioning of the European electricity system and that capacity mechanisms are a tool to guarantee that enough capacity will always be available, especially at peak periods to supply demand.
  • CEEP in principle welcomes the creation of a EU DSO entity. In this context, it is crucial that the representation of all DSOs is ensured and that EU legislation for DSOs is limited to issues of EU-wide impact and of reasonable importance for the EU internal market development.
  • CEEP supports the explicit recognition of new participants in the energy market, such as aggregators, active consumers and local energy communities. However, when shaping the exact roles of different market actors, it is crucial to ensure a level-playing field and non-discriminatory treatment that does not privilege certain actors.

CEEP Opinion “A strategic approach to pollution in the context of the upcoming evaluation of EU Water Legislation” – PDF

Executive summary

  • Precaution is the fundamental principle of drinking water legislation: The current Drinking Water Directive (DWD) is centered on a health-based understanding of water quality as opposed to a mere technical assessment of parametric values and based on precaution as the leading regulatory principle. Any revision needs to maintain and strengthen this focus to preserve the high level of quality currently provided to citizens and preserve raw water resources for future generations.
  • Polluters need to be held responsible for the damage they cause: Currently, the responsibility to ascertain low pollution of drinking water and the necessary resources lies almost exclusively with the water and sewage utilities. This “end-of-pipe” arrangement is both counter-productive and unsustainable: It leads to an externalization of the cost of pollution while the polluter is not taken into account, disincentivising any efforts to improve the situation. A stringent application of the “polluter pays” – principle throughout the value chain, including financial contributions by polluters as well as preventive and other measures is thus crucial to ensure a fair retribution of costs and the long-term sustainability of water services
  • EU-water legislation should provide comprehensive protection from the source onwards: The existing legislative framework encompasses a series of distinct directives designed to archive the same ends, thus offering a great potential for a comprehensive protection of “later-to be” drinking water at the source. Yet they are often not complementary, making a coherent implementation difficult. Improving overall coherence between the different elements of EU water legislation should thus be a priority during the upcoming or ongoing evaluation exercises, including but not limited to an alignment of relevant thresholds and taking into account not only individual pollutants, but also specific combinations thereof.
  • Poor implementation and enforcement hinders good policy outcome: Incomplete or delayed implementation at Member State level is one of the major causes of pollution. Correct implementation and stringent enforcement at all levels of government should thus be made a priority by Member States. In case of non-compliance the EU-Commission should make more frequent use of disciplinary measures, especially if violation of duties under EU legislation continues over longer periods of time.

CEEP Opinion on the State of the Energy Union 2015, adopted by CEEP General Assembly on 16 May 2016 – PDF

Executive summary

  • CEEP welcomes the First State of the Energy Union as a clear step towards more reliability of European energy and climate policies. CEEP therefore supports the Commission’s attempt to realise reliable national energy and climate plans. They should ensure a more coherent approach towards the achievement of the objectives of the EU’s 2030 Climate and Energy Framework, while avoiding to limit Member States in the choice for their way towards decarbonisation.
  • CEEP encourages the European Commission to involve social partners even more in the whole process and to keep citizens and customers at the heart of the transition of the European energy system. More than ever, public acceptance is indispensable for the successful implementation of energy and climate policies. In this context, a stronger focus on the local and regional dimension of the Energy Union, with the inclusion of citizens beyond their sole capacity as consumers, would also be helpful.
  • As heating and cooling account for half of Europe’s final energy demand, CEEP very much welcomes that the Heating and Cooling Strategy sends out a clear sign in favour of efficient and sustainable solutions. We very much welcome that this has already been announced by the State of the Energy Union, among others by underlining the good example of high-efficiency combined heat and power (CHP).
  • A fully-integrated internal energy market should indeed be at the heart of the Energy Union project, among others through the full implementation of the Third Energy Package and a market based approach to renewables. As in the medium to long run the energy-only market will not be sufficient to ensure security of supply, a new market design that values the provision of firm capacity should be developed.
  • CEEP very much welcomes the holistic approach that the State of the Energy Union announces for upcoming Commission initiatives and is particularly delighted by the recognition of the crucial role of transport. The decarbonisation of this sector has to be tackled more than in the past through concrete action at EU level.
  • CEEP members need the right conditions to actively anticipate and manage the energy transition and therefore welcome that this crucial issue is highlighted in the State of the Energy Union, among others in view of its skills dimension.

CEEP Opinion on the Commission’s Proposal for a Circular Economy Strategy and Reviewed Waste Legislation, appoved by CEEP General Assembly on 16 May 2016 –PDF

Executive summary

  • CEEP welcomes the European Commission’s Circular Economy Strategy and the legislative proposals on waste for their holistic approach, taking into account the whole value chain. They are an important step towards a more circular economy in which resource efficiency becomes the key driver for both economic growth and environmental protection.
  • CEEP agrees that waste prevention has rightly been placed at the top of the waste hierarchy. This includes in particular improved product design, influencing the whole product lifecycle and durability of a product and thus optimising its future reuse and recycling. EU legislation needs to be further adapted in order to support this ambition.
  • CEEP supports the Commission’s proposal to introduce clear definitions into waste legislation and welcomes that the definition of municipal waste is closely aligned with the one given by the European Waste Catalogue and the OECD. However, CEEP pleads that the definitions of both municipal waste and bio-waste should refer solely to their nature, property and composition, and not their quantity.
  • CEEP underlines that the proposed recycling targets for municipal waste are very ambitious. Recycling measures should be further boosted in the European Union. This should be done as long as recovery of secondary raw material is less expensive and resource intensive than primary raw material extraction. It should also be kept in mind that primary and secondary raw materials need to be treated equally in a way that same environmental requirements should apply to both.
  • CEEP welcomes the introduction of minimum requirements for Extended Producer Responsibility (EPR) schemes while leaving it in the remit of the Member States to decide on the use of this instrument. Nevertheless, more clarification is needed in order to avoid misinterpretations, in particular regarding cost recovery and the relation between organisations in charge of the implementation of EPR schemes and public waste management operators.
  • CEEP asks for a quick landfill ban for biodegradable waste as well as for waste that can be recycled or thermally recovered. Such a ban needs to be introduced in all Member States as this would be the most effective way to support waste prevention, reuse, recycling and other efficient ways of recovery.

CEEP Opinion on the Review of the Drinking Water Directive 98/83/EC (DWD), adopted by CEEP General Assembly on 16 May 2016 – PDF

Executive summary

  • The Drinking Water Directive 98/83/EC (DWD) has been and still is a well-functioning European legal instrument contributing to the supply of wholesome and clean drinking water throughout the EU. The DWD should be kept in place and further improved.
  • CEEP welcomes the elaboration of policy options for the introduction of integrated source-to-tap Risk Based Approaches in the DWD. This elaboration should include considerations of subsidiarity and flexibility at Member States’ level to leave room for approaches tailored to the legal and institutional framework in Member States.
  • CEEP stresses the need for better integration of the protection of drinking water resources in the administrative arrangements, Programme of Measures and River Basin Management Plans under the Water Framework Directive (WFD). The revision of the DWD should therefore include the introduction of a cross-reference to Water Framework Directive, in particular Article 7 thereof, the Groundwater Directive and the Priority Substances Directive.
  • The precautionary principle should be kept as a leading principle in setting drinking water quality standards and environmental quality standards for source water.
  • The revision of the DWD should include a sound legal basis (health/hygienic requirements) for the harmonised acceptance of materials and chemicals in contact with drinking water, taking full account of the work on the 4MS Common Approach.
  • Objective and scope of the DWD should be kept unchanged. Issues such as benchmarking, water as a human right, costs should be addressed separately from the revision of the DWD.

Contribution of Public Services’ Providers to Climate Action for a Successful and Ambitious COP21 – PDF

Executive summary

  • Ahead of the COP 21 in Paris, CEEP calls for the conclusion of an ambitious and robust climate agreement that includes binding commitments. These should be regularly reviewed and strengthened by all parties.
  • Public services providers support ambitious climate action. They are committed to climate action through their business culture and their sectors of activity. Their approach is based on the logics of sustainability, taking into account its environmental aspects, as well as its economic and social dimensions.
  • Mitigation policies should take a comprehensive approach and be structured around resource efficiency and decarbonisation. Public services sectors such as transport, telecommunications, energy, waste management and water treatment, as well as R&D have an important mitigation potential.  In order to fully exploit this potential, the current orientation in Europe to put into place a European Emissions Trading Scheme (ETS) must imperatively provide a true and fair carbon price, creating a level-playing field in order to incentivise investments that foster the decarbonisation of the European economy.
  • Adaption policies should be seen as complementary to mitigation policies as they provide measures needed to tackle the negative consequences due to climate change. Adaptation measures should include the protection of infrastructure in order to increase their resilience. The implications of climate change on sectors such as water, energy and transport, need to be urgently considered.
  • Climate change policies cannot ignore the investment challenge. There is a strong economic case for investing in climate action as this will create the sustainable growth and jobs Europe needs. In order to unleash the full potential of investments in climate-friendly solutions, private investment needs to be underpinned by public investment.

CEEP Opinion on the “Framework Strategy for a Resilient Energy Union with a Forward-Looking Climate Change Policy” – PDF

Executive summary

  • CEEP welcomes the Energy Union project as a solid basis for an ambitious and sustainable European energy and climate policy as well as for the achievement of the EU’s overarching priorities for economic growth and job creation. CEEP particularly supports that the Energy Union is not presented as an isolated project, but that it is deeply intertwined with other major European strategies. The implementation of concrete measures will now prove the Energy Union’s success.
  • First of all, the Energy Union should focus on fully implementing existing legislation rather than pursuing new legislation. Particular attention should be given to the implementation of the Third Energy Package as well as to the revival of the Emission Trading Scheme (ETS) through the quick introduction of a market stability reserve.
  • CEEP fully supports that an ambitious climate policy is seen as an integral part of the Energy Union. It can thus be considered a major contribution to the EU’s leading role in the view of the international climate negotiations in Paris. In this context, it is now necessary to quickly implement the 2030 Climate and Energy Framework.
  • CEEP shares the ambition to put citizens and customers at the heart of the ongoing transition of the European energy system as public acceptance is indispensable for the realization of highly needed infrastructure projects. In this context, a stronger focus on the local and regional dimension of the Energy Union is needed.
  • CEEP highlights the contribution social partners can make to maximize the growth and job creation potential of the Energy Union in its governance and concrete implementation. It can represent a success factor in the transition to a more sustainable economy, in particular through reinforced training, up-skilling and re-skilling of workers as well as the improvement of the current European framework on recognition of competences.

CEEP welcomes the presentation of the Digital Single Market Strategy by the European Commission. It is a key step towards a fair regulatory environment, crucial to boost the European digital economy and a more inclusive society, to ensure a level-playing field for all, to encourage future investments in digital infrastructures and to sustain investment in original digital content which is one of the main drivers of the digital economy and society. The Strategy rightfully focuses on both networks and content, going hand-in-hand as a virtuous circle.

Valeria Ronzitti, CEEP General Secretary, specifically emphasised the importance of an inclusive e-society in the Strategy, including digital skills and expertise as well as the access to e-services. “The Digital Single Market Strategy stresses the growing importance of e-services, such as e-government, e-energy, e-transport and e-health. Since the beginning of the economic crisis, public services providers have been facing new and complex challenges, such as budget cuts and the search for improved efficiency. For our members, e-services clearly represent an important instrument to become even more efficient and effective.
However, in order to reach the full potential of those services, there is a need for citizens and businesses to have access to efficient and reliable networks. In that context, additional investments are needed in digital infrastructures, in particular broadband rollout, in urban as well as in rural areas.”

PDF version

Today, Filippo Brandolini, CEEP Executive Vice-President, represented public service providers at the public hearing on the Circular Economy Package at the ENVI Committee of the European Parliament.

In the context of the current discussions on a possible withdrawal of the Package, Mr Brandolini encouraged the European Commission to acknowledge the wide-spread support for it and highlighted its crucial role for the European economy as a whole:

“The Circular Economy Package is an important step towards a more circular economy in which resource efficiency becomes the key driver for both economic growth and environmental protection in the European Union. CEEP embraces the Circular Economy Package as it represents an outstanding opportunity to realize the objective of an even more sustainable economy. For CEEP, managing waste means managing resources.”

“The Circular Economy Package underlines that it is not about choosing between the prevention of the environment on the one side, and growth and jobs on the other, but about achieving benefits in all these fields.”

“The Package has an enormous potential to set free investment in resource-efficient technologies and services. It could thus become a driving force for the European economy as a whole. The Package should not be delayed in order to create the right framework for the highly needed increase in investment in Europe.”

Mr Brandolini underlinded that recycling must be increased in terms of quantity and, in particular, of quality. In this context Mr Brandolini highlighted: “Landfill reduction targets are a crucial part of achieving a circular economy. Both landfill targets and recycling targets should apply to all waste, not only municipal waste.”

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