Europaudvalget 2021
KOM (2021) 0082
Offentligt
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EUROPEAN COMMISSION
SEC(2021) 89
4.12.2020
REGULATORY SCRUTINY BOARD OPINION
Communication from the Commission to the European Parliament,
the Council, the European Economic and Social Committee
and the Committee of the Regions
Forging a climate-resilient Europe - the new EU Strategy on Adaptation to
Climate Change
{COM(2021) 82}
{SWD(2021) 25}
{SWD(2021) 26}
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EUROPEAN COMMISSION
Regulatory Scrutiny Board
Brussels,
RSB
Opinion
Title:
Impact assessment / EU strategy on adaptation to climate change
Overall opinion:
POSITIVE WITH RESERVATIONS
(A) Policy context
Climate change has impacts on the planet, people and prosperity. This makes adaptation to
this change important. Continued mitigation of greenhouse gas emissions also plays a role.
The new EU Adaptation Strategy was announced as part of the European Green Deal. This
initiative is an update of the 2013 Climate Adaptation Strategy, which was positively
evaluated in 2018. This impact assessment examines options to reach the objective of
making the Union a climate-resilient society by 2050. It aims to adapt to the unavoidable
impacts of climate change. This will contribute to the global goal on adaptation of the Paris
Agreement. The revised Strategy should improve knowledge on climate impacts,
accelerate adaptation action, and strengthen global climate resilience.
(B) Summary of findings
The Board notes the additional information provided in advance of the meeting and
commitments to make changes to the report. In forming its opinion, the Board took
into account that the impact assessment accompanies a high-level strategy, which
raises particular challenges in terms of proportionate level of analysis.
However, the report still contains significant shortcomings. The Board gives a
positive opinion with reservations because it expects the DG to rectify the following
aspects:
(1) The report is not clear enough about what will be decided in this Strategy and
which actions will require separate (legislative) follow-up. It does not sufficiently
specify what actions should be taken at the EU-level, as opposed to national or
local levels. It is not clear to what extent the listed actions refer to new elements,
or whether they are part of other existing initiatives or programmes.
(2) There is a discrepancy between the positive outcome of the 2018 evaluation and
the problem description that identifies a lack of preparation for climate change
impacts.
(3) It is not clear what an appropriate degree of preparedness would be, taking into
account the high degree of uncertainty on local climate change impacts.
________________________________
This opinion concerns a draft impact assessment which may differ from the final version.
Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 08/010. E-mail: [email protected]
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(C) What to improve
(1) The impact assessment should state clearly which decisions will be taken as part of the
Strategy and which actions will require separate follow-up proposals or analyses. The
report should further differentiate between actions that should be taken at EU level and
actions that will fall under the responsibility of (sub)national levels. It should also clarify
why the list of measures is not exhaustive and how it intends to add additional measures.
(2) The report should explain why, despite the positive 2018 evaluation of the current
Strategy, the EU is still underprepared for current and projected climate change impacts.
The report should explain why it does not consider a legal instrument as one of the options.
(3) The report should elaborate on the role of uncertainty in the Strategy. It should present
the rationale for stepping up the adaptation efforts in face of many uncertainties with
respect to location, size and timing of the climate impacts. It should better integrate how
uncertainty influences the desired level of climate adaptation. It should also consider
harnessing the pooling of risks to mitigate local uncertainty and incentivising adaptation to
balance expected damages.
(4) The report should define the baseline in more detail. It should be explicit about which
existing (or proposed) initiatives are incorporated (e.g. Horizon Europe, other financial
programmes, taxonomy, climate pact, relevant legislative acts…). On this basis, the
options should further specify what the new elements of the proposed actions are and,
where relevant, how they relate to and add value to linked initiatives.
(5) The report should clarify the expected degree of implementation, given the voluntary
nature of many of the actions. The estimation of costs and benefits should be aligned to the
expected compliance of concerned parties, and compared against the baseline. The impact
analysis should relate the reported macroeconomic costs and benefits to the risks of higher
local damages that adaptation aims to avoid.
(6) The report should discuss how future monitoring and evaluations will be carried out. It
should set out how the ‘success’ of the adaptation strategy will be measured.
The Board notes the estimated costs and benefits of the preferred option(s) in this
initiative, as summarised in the attached quantification tables.
Some more technical comments have been sent directly to the author DG.
(D) Conclusion
The DG may proceed with the initiative.
The DG must revise the report in accordance with the Board’s findings before
launching the interservice consultation.
Full title
Reference number
Submitted to RSB on
Date of RSB meeting
EU strategy on adaptation to climate change
PLAN/2020/7621
November 4, 2020
December 2, 2020
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ANNEX: Quantification tables extracted from the draft impact assessment report
Table 15 Overview of Benefits (total for all provisions) – Preferred Option
I. Overview of Benefits (total for all provisions) – Preferred Option
Description
Amount
Comments
Direct benefits
A1 – Effective utilization of
knowledge through systematic
data collection and sharing,
between key public and private
partners.
Common benefits for public and private entities: Data
Assumption: Climate data and knowledge is
harmonization; effective alignment between public and
perceived as common good with great societal
private responsibilities and effort sharing; improved
relevance. Data is of sufficient granularity
adaptation planning; better informed decision making;
better understanding between public and private losses.
Reduced costs to be expected as robust data can drive CBA
A single platform would reduce time to action, reducing
costs. A first stop platform can guide to others without
trying to stay up-to-date on everything at all time.
Distinction to be made between data provisioning,
gathering of information and knowledge sharing.
Different platforms for data, like Copernicus,
EUROSTAT already provide some climate-related
data. These services should be expanded per platform
and linked to Climate-ADAPT
A2 – Proven performance from
Climate-ADAPT as the ‘first-stop
shop’ for adaptation information
in Europe.
A3 - Robust evaluation,
monitoring, reporting and
implementation of adaptation
strategies
A4 - Mainstreaming nature-based
adaptation, including coastal
protection and green and blue
infrastructure.
A5 - Stepping-up efforts to build
resilience in cities and empower
local action.
A6 - Further mainstreaming and
integrating adaptation in EU
legislation and instruments
A7 - Climate Proofing of
Infrastructure and Disaster Risk
Management.
A8 - Closing the Climate
Protection gap - microeconomic
aspects of adaptation to climate
change.
A9 - Supporting partner countries
and regions in their efforts on
climate change and disaster
preparedness
A10 - Scaling up international
adaptation finance and disaster
risk financing, and unlocking
private finance
A11 - Strengthening EU
engagement globally and learning
from adaptation forerunners.
A12 - Horizon Europe Mission on
adaptation to Climate Change
effectively deploying adaptation
Solutions
A13 - Closing the Climate
Protection Gap - macroeconomic
aspects of adaptation
A14 - Ensuring the availability of
Fresh water
Insight into Europe’s vulnerability at the efficient level of
granularity. Uniform and harmonized indicators can track
impacts across Europe, and promote better exchange
between Member States.
Socio-economic and environmental benefits are more
easily associated with ecosystems services. Therefore
making more robust business cases warranting contribution
and progress for sustainable development goals
Reduced public expenditures on losses as result of climate
impacts as city action plans put into action.
Greater spending on climate resilience in sectors affected
by policy.
Standardized guidelines and procedures to design, develop
and integrate climate proofing solutions to ensure robust
and resilient infrastructure across Europe
Having systematic approach to assess, reduce, and
optimally transfer climate-related disaster risk in economic
activities
Implementation of NDCs and to building capacity at
national and sub-national level in line with national
priorities and vulnerabilities
Having more funds available from both the public and
private sector, fostering the transition to be become climate
resilient
Access to granular and meaningful data information to
ensure better informed decision making
Better informed decision making by means of climate risk
management and community-based emergency plans
Better-informed decision making for fiscal and financial
stability: on disaster risk assessment and management, risk
pooling and cross-sectoral losses.
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Indirect benefits
A1 – Effective utilization of
knowledge through systematic
data collection and sharing,
between key public and private
partners.
A2 – Proven performance from
Climate-ADAPT as the ‘first-stop
shop’ for adaptation information
in Europe.
A3 - Robust evaluation,
monitoring, reporting and
implementation of adaptation
strategies.
A4 - Mainstreaming nature-based
adaptation, including coastal
protection and green and blue
infrastructure.
A5 - Stepping-up efforts to build
resilience in cities and empower
local action.
A6 - Further mainstreaming and
integrating adaptation in EU
legislation and instruments
A7 - Climate Proofing of
Infrastructure and beyond.
A8 - Closing the Climate
Protection gap - microeconomic
aspects of adaptation to climate
change.
A9 - Supporting partner countries
and regions in their efforts on
climate change and disaster
preparedness
A10 - Scaling up international
adaptation finance and disaster
risk financing, and unlocking
private finance
A11 - Strengthening EU
engagement globally and learning
from adaptation forerunners.
A12 - Horizon Europe Mission on
adaptation to Climate Change
effectively deploying adaptation
Solutions
A13 - Closing the Climate
Protection Gap - macroeconomic
aspects of adaptation
A14 - Ensuring the availability of
Fresh water
Better water pricing and practices improves resource
efficiency and water availability and quality for ecosystems
and recreation.
Pioneering innovations can create opportunities for EU
firms to commercialise success stories.
Improved EU standing on adaptation, and working with
partners, may support building of diplomatic coalitions in
other climate (mitigation) areas, or policy and economic
areas more broadly.
Overall benefits to society from wide range of stakeholders
benefitting from better data availability and informed
decision making by public authorities and firms.
N/A
Direct benefit to users is most relevant.
Benefits to vulnerable stakeholders as monitoring and
reporting brings public action into focus, and stimulates
further action.
Benefits to biodiversity and climate change mitigation
from projects in addition to main climate resilience
benefits.
Benefits to vulnerable stakeholders in cities as
strengthened CoMo and action by cities can lead to co-
benefits in air quality, transport and public spaces.
Benefits to recipients of funding, as their vulnerabilities
will be better addressed.
Long term benefits to public budgets in Member States as
reduced costs for repairs from climate damages to
infrastructure.
(1) Estimates are relative to the baseline for the preferred option as a whole (i.e. the impact of individual actions/obligations of
the preferred option are aggregated together); (2) Please indicate which stakeholder group is the main recipient of the benefit in
the comment section;(3) For reductions in regulatory costs, please describe details as to how the saving arises (e.g. reductions in
compliance costs, administrative costs, regulatory charges, enforcement costs, etc.; see section 6 of the attached guidance).
Table 16 Overview of costs – Preferred option
Citizens/Consumers
One-off
Recurrent
II. Overview of costs – Preferred option
Businesses
One-off
Recurrent
Administrations
One-off
Recurrent
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II. Overview of costs – Preferred option
Citizens/Consumers
One-off
A1 – Effective
utilization of
knowledge through
systematic data
collection and
sharing, between key
public and private
partners.
A2 – Proven
performance from
Climate-ADAPT as
the ‘first-stop shop’
for adaptation
information in
Europe.
A3 - Robust
evaluation,
monitoring,
reporting and
implementation of
adaptation strategies.
Businesses
One-off
Recurrent
Administrations
One-off
Measures to
develop
Roadmap,
establish
framework
(EC)
Recurrent
Recurrent
Data sharing and
provision
Direct
costs
Indirect
costs
Direct
costs
Indirect
costs
Provision of
additional data
Through Horizon
Europe
Establish and
maintain Health
Observatory (EC)
Direct
costs
Potential costs
related to
implementation
(behaviour
change,
investments in
individual
resilience)
Potential costs
Potential costs
related to aligning related to
business activities implementation
with the strategies
Establish
framework
(EC)
Indirect
costs
Potential loss of
revenue for
sectors still
building grey
infrastructure
Tool
development
(EC)
Possible via
linking of
insurance
products to NbS
MRE under Climate
Law (MS & EC)
A4 - Mainstreaming
nature-based
adaptation, including
coastal protection
and green and blue
infrastructure
Direct
costs
Indirect
costs
Direct
costs
Indirect
costs
Direct
costs
Indirect
costs
Legislation to
protect workers
from high
temperatures
Potential higher
costs associated
with alignment
with new
adaptation
requirements
A5 - Stepping-up
efforts to build
resilience in cities
and empower local
action.
A6 - Further
mainstreaming and
integrating
adaptation in EU
legislation and
instruments
Policy support facility
(EC)
Implementation of
adaptation plans (MS,
cities)
Revision of existing
legislation and
instruments which do
not incorporate
adaptation
considerations (EC)
A7 - Climate
Proofing of
Infrastructure and
beyond.
Direct
costs
Enhance and
apply climate
proofing
methodology
(EC)
Study on
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II. Overview of costs – Preferred option
Citizens/Consumers
One-off
Recurrent
Businesses
One-off
Recurrent
Administrations
One-off
Climate risk
management
(EC)
Recurrent
Indirect
costs
A8 - Closing the
Climate Protection
gap - microeconomic
aspects of adaptation
to climate change.
Applying climate
proofing
guidelines
Common
methods for
risk
management
(EC)
Adaptation
integrated into
SEAI
Mainstreaming in
BRG (EC)
Allies for climate
resilience (EC)
MS reporting on
disaster aid (MS)
Various measures
(EC)
Direct
costs
Indirect
costs
A9 - Supporting
partner countries and
regions in their
efforts on climate
change and disaster
preparedness
A10 - Scaling up
international
adaptation finance
and disaster risk
financing, and
unlocking private
finance
A11 - Strengthening
EU engagement
globally and learning
from adaptation
forerunners.
A12 - Horizon
Europe Mission on
adaptation to
Climate Change
effectively deploying
adaptation Solutions
A13 - Closing the
Climate Protection
Gap -
macroeconomic
aspects of adaptation
Direct
costs
Indirect
costs
Direct
costs
Indirect
costs
Direct
costs
Indirect
costs
Direct
costs
Indirect
costs
Direct
costs
Indirect
costs
Direct
costs
Indirect
costs
Potentially
higher product
costs
Potentially
higher water
costs
Redesign of
products,
processes. New
standards/labels
Potential need to
engage with and
use EC tools.
Regulatory
changes and
studies to
support them
(EC)
Potentially higher Water Safety
water costs
Plans
development
(MS)
Studies on
Climate proofing of
just resilience EU external
(EC)
investments (EC)
Balance in mitigation
and adaptation
spending (all
countries)
Discussions,
exchanges, alliances
(EC and partners)
Horizon Europe and
other activities
funding (EC)
EC activities EC engagement
to provide
activities (EC)
tools, models,
tests (EC)
Involvement in EC
driven processes (MS)
A14 - Ensuring the
availability of Fresh
water
(1) Estimates to be provided with respect to the baseline; (2) costs are provided for each identifiable action/obligation of the
preferred option otherwise for all retained options when no preferred option is specified; (3) If relevant and available, please
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present information on costs according to the standard typology of costs (compliance costs, regulatory charges, hassle costs,
administrative costs, enforcement costs, indirect costs; see section 6 of the attached guidance).
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Electronically signed on 04/12/2020 11:25 (UTC+01) in accordance with article 11 of Commission Decision C(2020) 4482