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To: Energy & Environment Ministers
Re: Turning EU Effort Sharing Proposal into EU Benefit Sharing Agreement “Climate Action and Renewable Energy Package”

Turning EU Effort Sharing Proposal into EU Benefit Sharing Agreement “Climate Action and Renewable Energy Package”

3rd July 2008, Council Meeting, Paris

Dear EU Energy and Environment Minister,

As you meet tomorrow, we would like you to consider reframing the current debate on Effort Sharing into one on Benefit Sharing. This will help create political acceptance for greater ambition levels and ensure that the EU abides by the principles of better regulation in considering both costs and benefits to it decisions.

The Health and Environment Alliance (HEAL), a broad coalition of health professionals, environmental health and patient groups throughout Europe, urges you to ensure the highest possible level of health protection for EU citizen’s by supporting an ambitious Climate Action and Renewable Energy Package that exploits the important co-benefits to health of domestic climate change mitigation policies.

The proposed Effort Sharing emission reduction target of the EU’s Climate Action and Renewable Energy Package is in violation of the COP13 Bali agreement for developed countries to reduce emissions by 25 - 40 per cent by 2020, a yardstick for staying below 2 degree global warming.

To keep mean temperature rise below 2 degree and avoid a public health crisis, HEAL and its members call for:

1. A minimum domestic EU 30% cut in collective emissions from developed countries by 2020 to stop global warming before it reaches dangerous levels. The current proposal from the Commission equates to about a 10% domestic reduction target below 2005 (20% overall reduction target below 1990).

2. External credits from schemes such as the Kyoto Protocol’s Clean Development Mechanism (CDM) need to meet strict additional environment and health criteria, and should be in addition to an EU-wide 30% emission reduction. The EU must recognize the important co-benefits to health of domestic cuts and must therefore not "outsource" its emission reductions and associated co-benefits.

3. Co-benefits to health of reducing CO2, NOx, Particulate Matter and SOx need to be considered more prominently throughout the climate and energy package. Such co-benefits include improved local air quality, reduced noise, traffic pollution and accidents.

The current 20, 20, 2020 EU’s Climate Action and Renewable Energy Package assessment estimates that the health benefits just for Particulate Matter (10ug/m3) alone would amount to a substantial €550Billion to €1350Billion per year. However, the modeling of energy scenarios or associated health benefits has NOT been considered in relation to different levels of ambition. This one-dimensional “coherent scenario” does not allow a flexible analysis of degrees of ambition as highlighted by an amendment voted in the European Parliament Committee on Environment and Public Health and Food Safety:

“13a. Regrets that the current cost benefit impact assessment of the ’20 20 by 2020 Europe’s Climate Change Opportunity’1 only considers the health benefits of reduced air pollution at a 20% reduction of greenhouse gas emissions by 2020; calls on the Commission to ensure that the (ancillary) co-benefits to health of various levels of ambition, in line with the International Panel on Climate Change recommendations of domestic 25% to 40% as well as possibly 50% or more of greenhouse gas emission reduction by 2020, are urgently investigated and modelled into an impact assessment by the Commission;” 1 COM(2008)0030. [Frédérique Ries (PE404.442v01-00) Mid-term review of the European Environment and Health Action Plan 2004-2010 (2007/2252(INI)]

In this regard we recommend to Ministers and other decision makers, in addition to a 30% level of ambition, a flexible solution to allow no-regrets actions and policies up and above agreed targets, which is being promoted by Member of European Parliament Mr John Bowis (EPP-ED, UK).

Proposed Amendment: Recital (8a)new

“Member States may justify unrestricted levels of domestic greenhouse gas emissions reduction up and above their greenhouse gas emission limits, based on no-regrets actions and policies that have co-benefits. In this regard primacy should be given to the co-benefits to public health (partcicularly related to air quality) and improved safety, ecosystem preservation and biodiversity, poverty reduction and employment, and energy security.”

Amendment justification: “The IPCC working group III on mitigation clearly indicates that the co-benefits of action in the form of reduced air pollution, more energy security or more rural employment offset mitigation costs. There is a general consensus for all world regions analyzed that near-term health and other benefits from GHG reductions can be substantial, both in industrialised and developing countries. Such near-term co-benefits of GHG control provide the opportunity for a true no-regrets GHG reduction policy in which substantial advantages accrue even if the impact of human-induced climate change itself turns out to be less than that indicated by current projections.”

We attach a summary of the current macroeconomic understanding by Dr. Terry Barker, University of Cambridge and Cambridge Econometrics and IPCC author which shows that climate change mitigation efforts don’t necessarily reduce GDP. Indeed Dr. Barker indicates that: “There seems to be an impression that mitigation automatically incurs macroeconomic costs. This is not the case from the literature. e.g. see attached quote from IPCC AR4 SPM agreed by ALL governments in Bangkok, 2007.” Of course, as public health advocates we must highlight that many of these studies do not include health and other societal co-benefits.

To fight climate change the international community will require not flexibility but global leadership from the EU. As it currently stands, the current EU’s Climate Action and Renewable Energy Package and underlying economic modeling and scenarios display pessimism on the outcome of international climate negotiations. It demonstrates to the world a lack of ambition in the EU’s level of commitment to the global effort to combat change and the unfounded assumption that EU citizens do not value healthy environments, a healthy society and indeed the health of their children, particularly in light of the significance of climate change endangering human health and well-being.

Yours sincerely,

Genon Jensen,

Executive Director, Health and Environment Alliance (HEAL)

Last updated on 6 July 2011

About HEAL

The Health and Environment Alliance (HEAL) is a leading European not-for-profit organisation addressing how the environment affects health in the European Union (EU). We demonstrate how policy changes can help protect health and enhance people’s quality of life. Read more »


HEAL has over 70 member organisations, representing health professionals, not-for-profit health insurers, doctors, nurses, cancer and asthma groups, citizens, women’s groups, youth groups, environmental NGOs, scientists and public health institutes. Members include international and Europe-wide organisations, as well as national and local groups. Read more »

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