Miljø- og Planlægningsudvalget 2007-08 (2. samling)
KOM (2007) 0354 Bilag 4
Offentligt
MINISTRY OF CLIMATE AND ENERGY
The European Commission
Ministry for Climate and Energy
The Danish government's consultation response to the EU-Commission's
"Green Paper on Adapting to climate change in Europe - options for EU action"
(COM(2007) 354 final)
The Danish government finds that observed and projected climate changes - as assessed by
the Intergovernmental Panel on Climate Change and others – should remain the unequivocal
basis for the European Commission Green Paper. The four “pillars” of the Green Paper con-
tains a balanced view of the challenges lying ahead. They address key vulnerabilities to im-
pacts and they provide a good foundation for future necessary adaptation measures from a
policy perspective. The Green Paper addresses priority issues within and outside EU in a
comprehensive manner.
The Danish government is of the opinion that because many adaptation measures can be or
are being planned locally, nationally, or at European level, it is important to determine the
role the EU has in this field, taking into account the subsidiarity principle.
The Danish government has published its own national adaptation strategy in parallel with the
consultation process on the Green Paper. Although there are many similarities between these
two, the Danish government would like to emphasize that national adaptation plans should not
be restricted or delayed because of future EU regulation with respect to adaptation. On the
contrary, future EU–legislation should support and reinforce national measures as much as
possible. An important role for the EU could be to facilitate and coordinate planning and im-
plementation of actions to reduce vulnerability and to secure societies against trans-national
impacts. This support could consist of offering common sources of relevant information and
by integrating climate change adaptation and mitigation measures into relevant sectoral legis-
lation and Community Funds. The dimensioning of adaptation measures should be based
upon a balanced assessment of the expected consequences of climate changes, the likelihood
that they take place as well as the costs of prevention. In this respect it should be taken into
consideration that an autonomous adaptation takes place in society.
The Danish government supports the Commission’s proposal to establish a permanent entity
under the European Climate Change Programme, which will provide the focus point of future
EU-work on adaptation.
Ministry of Climate and Energy
Stormgade 2-6
DK-1470 København K
Phone +45 33 92 28 00
Fax +45 33 92 28 01
E-mail: [email protected]
www.kemin.dk
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With respect to the four pillars of the Green Paper, The Danish government has the following
general comments:
Pillar 1
Where current knowledge is sufficient, adaptation strategies should be developed in order to identify optimal re-
source allocation and efficient resource use which will guide actions at EU level, through EU sectoral and other
policies and the available Community Funds.
The Danish government agrees that early action on adaptation in Europe is needed and feasi-
ble. Key trans-national impacts – such as droughts and major river floods – should foster
rapid action to include effective climate change adaptation measures into existing and future
legislation and funding programmes – rather than developing separate European adaptation
policies.
The Danish government would like to see a comprehensive listing of all legal instruments of
importance to adaptation, including any plans or agreements to revise or evaluate these.
Pillar 2
The EU needs to recognise the external dimension of impacts and adaptation and to build a new alliance with its
partners all around the world and particularly in developing countries. Adaptation action should be coordinated
with its neighbours and cooperation with international organisations should be further strengthened.
Because poor people in developing countries are the most vulnerable to climate change im-
pacts, the integration of climate change adaptation in European development collaboration ac-
tivities is imperative. It is primarily the responsibility of the member states to meet their
commitments in this area.
The Danish government welcomes the recent EU-initiatives as highlighted in the Green Paper.
This includes the establishment of the
Global Climate Change Alliance,
which is a good in-
strument to strengthen the dialogue and collaboration between the EU and developing coun-
tries. The Danish government further welcomes the Commission’s decision to allocate 50 mil-
lion EUR over the period 2007-10 to these activities, which will strengthen targeted adapta-
tion and mitigation efforts in developing countries.
The Danish government supports the Commission’s view that the
European Neighbourhood
Policy
(ENP) is a suitable instrument for supporting adaptation measures in neighbouring
countries including Russia.
Future adaptation initiatives should be aligned with and build on the UNFCCC Nairobi Work
Programme on impacts, vulnerability and adaptation to climate change.
Pillar 3
Where there are still important knowledge gaps, Community research, exchange of information and preparatory
actions should further reduce uncertainty and expand the knowledge base. Integration of research results into
policy and practice should be reinforced.
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The Danish government supports the Commission’s proposal to develop a European-level in-
formation system to facilitate exchange of data, methods, and information on good practice in
response to both autonomous adaptation and policy actions. The Danish government would
like to propose that coordination of this work as well as the elaboration of an updated synthe-
sis reports on impacts, vulnerability and adaptation to climate change should be undertaken by
the
Partnership for European Environmental Research (PEER)
involving 7 of the largest re-
search institutions in Europe including the Joint Research Centre and the National Environ-
mental Research Institute (NERI) in Denmark. The Danish government agrees with the re-
search strategy as indicated in the Green Paper and further agrees that there is an urgent need
to develop an up-to-date European-wide overview of available socio-economic assessment
methods and tools, which could be used to assess or estimate adaptation costs and benefits.
The Green Paper mentions a number of areas – including the North Atlantic – where under-
standing of future impacts could be improved. The Danish government would like to empha-
sise the need to focus on the Baltic as well. It is necessary strengthen the European research
effort to address the impacts of climate change in this vulnerable region, as the runoff area
from 8 European countries will contribute to increasing nutrient loads to the Baltic in a
warmer and wetter climate. This strengthening should take place within the context of the
Common Agricultural Policy,
the
Water Framework Directive
and the
Marine Strategy.
A
number of EU financial instruments should be applied to tackle increasing problems with
eutrophication of the Baltic i.e. through establishment of wetlands, which act as buffer areas
to reduce excessive nutrient loads entering the Baltic Sea.
Pillar 4
Coordinated strategies and actions should inter alia be further analysed and discussed, in a European Advisory
Group on Adaptation to Climate Change under the European Climate Change Programme
.
The Danish government welcomes the Commission’s initiative for a broad stakeholder in-
volvement. Since the impacts of climate change will display a varied geographical pattern –
e.g. droughts and forest fires will affect mainly southern Europe and leaching of nutrients in a
warmer and wetter climate will affect mainly northern Europe – there may be scope for a
stronger sub-regional organisation of this new entity. The main purpose of establishing such
an entity should be to set priority on those areas in which specific European action would be
most needed and effective. There is a strong need for a cross-sectoral approach. Dealing with
each sector or each governance level separately may not be enough. Building bridges between
different levels of governance should be in the core of the consultation process leading to a
future White Paper on Pan-European adaptation measures. Regarding the process, the Danish
government very much welcomes the Commission’s proposal to involve stakeholders in soci-
ety, business and the public sector in the process towards the White Paper. In this context, the
Danish government supports the establishment of a new permanent structure under the
Euro-
pean Climate Change Programme
with focus on adaptation. The Danish government has not
addressed in detail how this new entity could be mandated. However, the Danish government
would prefer to be consulted prior to nomination of one or more Danish members of this new
entity.
The Danish government’s position on a number of specific issues raised in the Green Paper is
outlined in the following (numbers refer to Section number and Question number in the Green
Paper):
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3.3 Further important impacts
Should further important impacts be added? If yes, which ones?
The Danish government considers the following issues as not yet well reflected in the Green
Paper
•
Resilience against extreme events will require sustainable development and strate-
gic disaster risk reduction measures on a global scale.
•
Disaster risk reduction on a global scale will require technology innovation and
export of adaptation methods and tools.
•
Impacts of climate change on urban areas and the possibilities to adapt need more
focus since 80 % of the population lives in cities.
4.5 A coherent adaptation framework
What should be the different roles of EU, national, regional, local authorities and
the private sector?
The Danish government would like to see EU develop its role primarily addressing trans-
national challenges related to climate change. To this end it is important to focus on the social
consequences of climate policies. Prevention of mass migrations due to environmental degra-
dation in concordance with climate change is a key EU responsibility. A pro-active effort,
which includes both mitigation and adaptation, should remain one of the highest priorities in
the years to come.
5.25 Research communication and outreach activities
How should research results be communicated and made available to decision makers and a
broader public at local, national, EU-level and internationally?
The Danish government shares its view with the Commission that an integrated and holistic
research effort is needed to tackle adaptation in the future. Communication of research results
related to adaptation will primarily be a national challenge due to linguistic constraints. One
of the key components of the Danish Adaptation Strategy is the establishment of a dedicated
web portal for this purpose. The Danish government thus find that a new EU-wide communi-
cation hub should be carefully planned, restricted in scope to matters related to trans-national
adaptation measures, and be fully integrated in existing research networks, such as the PEER
initiative (see http://peer-initiative.org).
5.28 Regional aspects
Would the establishment of a European Advisory Group on Adaptation be helpful in further ex-
ploring an EU response to the effects of climate change? If yes, which areas should such an Advi-
sory Group concentrate its work on?
The Danish government foresees that a new entity under the
European Climate Change Pro-
gramme
would need to have a number of sub-regional focus areas in order to operate effi-
ciently. As stated already, two main adaptation challenges will require trans-national collabo-
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ration. Tackling drought problems in southern Europe is one key component. The other key
component would be concentrated around the Baltic region. Securing the long term stability
of the Baltic Sea in a warmer and wetter climate will require close collaboration between the
bordering countries. Main emphasis should be on the multiple threats to the marine environ-
ment. Leaching of nutrients from agricultural soils is expected to lead to more harmful algal
blooms and an-oxic conditions near the bottom. Adding to the complexity will be higher wa-
ter temperatures, higher runoff and changing wind conditions in the future. Adapting to these
circumstances will require trans-national expert knowledge of the highest calibre.
Conclusion
The Danish government is generally positive towards the Green Paper and supports the
Commission’s view – in line with the Danish Adaptation Strategy – that existing and new
EU-legislation should be streamlined to include adaptation to climate change. A strengthened
effort to focus research on adaptation issues is also very much in line with the Danish view. It
is of primary importance to engage citizens, authorities and industry in the process, since they
will have the main responsibility for autonomous adaptation in practise.
The Danish government would like to emphasize the following:
•
•
The work to turn the Green Paper into a White Paper should be pushed forward as
soon as possible in a way that the EU-legislation on adaptation supports and comple-
ments ongoing work with national adaptation strategies and plans.
The work related to coordination of research on adaptation to climate change should
take place within the remits of the
Partnership for European Environmental Research
(PEER)
and that a special research focus is needed to address adaptation in the Baltic
region.
A new permanent entity should be established under the European Climate Change
Programme (ECCP), which will concentrate its efforts on strengthening the European
adaptive capacity.
•
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