EURACOAL aisbl

EURACOAL is pleased to submit its attached response paper on the proposed amendments to the Renewable Energy Directive. In summary, we wish to make four points in response to the European Commission's proposal: • EURACOAL welcomes the support for electricity generated from biomass at coal power stations.

Over the last two centuries, Europe’s prosperity, its industrial base and indeed world civilisation has been built on coal. After the Second World War, the unification and peaceful co-operation of Europe started with the coal and steel industries.

Over the last two centuries, Europe’s prosperity, its industrial base and indeed world civilisation has been built on coal. After the Second World War, the unification and peaceful co-operation of Europe started with the coal and steel industries.

EURACOAL is pleased to submit its attached position paper on the proposed Carbon Border Adjustment Mechanism. Summary EURACOAL cautiously supports the proposed Carbon Border Adjustment Mechanism (CBAM). While it might give some relief to European coal and steel producers by shielding them from global competition that benefits from different social and environmental standards, we are concerned about unintended side…

EURACOAL understands that calls for a CBA mechanism are a logical counterbalance to the EU’s stringent, unilateral policies linked to climate action. Currently, EURACOAL has not reached a position on a CBA mechanism. We await concrete proposals, but offer some initial views here in our response paper. 1.

EURACOAL is pleased to submit its attached position paper on the proposed amendments to the EU ETS Directive. In summary, we have twelve key points to make in response to the European Commission's proposal: 1. The current energy crisis highlights the need for secure, reliable and diverse energy supplies at affordable prices. Coal provides these and so benefits EU society. 2.

Reducing greenhouse gas (GHG) emissions demands concerted action on all fronts; the EU Emissions Trading System (ETS) cannot be considered in isolation from the Effort Sharing Regulation or any other measures at the EU level, such as minimum tax rates under the Energy Taxation Directive or any carbon border adjustment mechanism.

EURACOAL is pleased to submit its attached position paper on the proposed amendments to the Energy Taxation Directive. In summary, we have seven key points to make in response to the European Commission's proposal: • EURACOAL supports the concept of energy taxation based only on the energy content of fuels. In practice, coal has been priced and sold on an energy basis for many decades.

EURACOAL supports the Commission’s efforts to align the Energy Taxation Directive (ETD) with other measures such as the EU ETS, the Renewables Directive and the Energy Efficiency Directive. However, as this discussion is at a very early and preliminary stage, with no draft proposal or impact assessment presented by the European Commission, our comments can only be of a very general nature. 1.

The European Association for Coal and Lignite (EURACOAL) supports efforts to restore degraded ecosystems. The reclamation of post-mining areas is in fact a natural stage of mining activity, which compensates for the unfavourable changes caused by mining and in many cases is the beginning of ecosystem renewal, including among others the creation of new biodiverse sites.

EURACOAL is pleased to submit its attached response to the European Commission's proposal to revise the IED. The proposal would result in the further de industrialisation of Europe as it puts a disproportionate burden on European industry and the energy sector.

The IED is well-drafted and provides a structured framework for a techno-economic process for the preparation of BAT conclusions. However, the “Seville process” appears to be in need of improvement. Based on our experience with updating the LCP BREF, the process was biased towards political considerations rather than the technical and economic factors specified in the IED.

EURACOAL supports the aim of reducing methane emissions from the energy sector. As coal mining in the EU continues to decline, coal-related methane emissions are forecast to fall by 62% in the decade to 2030 according to the European Commission’s own impact assessment of the proposed Methane Regulation. This far exceeds the Global Methane Pledge to reduce methane emissions by 30% between 2020 and 2030.

EURACOAL has closely followed the preparation of the EU Methane Strategy and given its advice. Our members work to eliminate the safety risks of methane release in coal mining, as required by law, as well as monitor emissions, design effective capture and use systems, and estimate fugitive emissions. Post mining, the management of methane from underground workings remains a priority.

The European coal industry is subject to strict EU pollution control legislation and has successfully implemented this to meet some of the worlds highest standards. The coal sector has invested heavily in pollution control technologies and achieved impressive results for example, sulphur dioxide (SO2) and oxides of nitrogen (NOx) emissions from coal use in the EU have fallen by between 60% and 90% since 1990.

EURACOAL welcomes the aim of more effective pollution control policies. We support the UN Sustainable Development Goals and the aim of creating a cleaner environment in the EU. Current legislation already sets high standards and contributes to a cleaner planet for all.

A Just Transition Fund is very much needed if the EU, with the agreement of member states and the European Parliament, is to complete the huge transformation to a climate-neutral continent. Under the European Green Deal, many member states need to make great changes to their economies as they are no longer viable under current EU rules for energy systems and the even greater efforts envisaged in light of more…

A Just Transition Fund is very much needed if the EU, with the agreement of member states and the European Parliament, is to complete the huge transformation to a climate-neutral continent. Under the European Green Deal, many member states need to make great changes to their economies as they are no longer viable under current EU rules for energy systems and the even greater efforts envisaged in light of more…

EURACOAL welcomes this opportunity to respond on the important topic of access to environmental justice and how this relates to EU law. Our attached position paper explains why EURACOAL rejects proposals to amend the Aarhus Regulation. The proposal to extend the rights of review and legal action is not in line with EU law which requires equal access to justice.

An extension of the current rights to legal action beyond administrative acts must be rejected, as it would be contrary to EU law and the universal principles of just law and open government which require stability and fairness. Such an extension would undermine democratic processes.

EURACOAL cautiously welcomes the European Green Deal’s proposed zero-pollution ambition for air, water and soil, noting however that to reach zero may entail costs tending towards infinity. The European Pollutant Release and Transfer Register (E-PRTR) holds emission data for 91 pollutants at around 30 000 industrial facilities, including annual mass releases (and transfers) to air, water and land.

The European Association for Coal and Lignite (EURACOAL) welcomes this opportunity to contribute to the European Commissions public consultation on establishing an occupational exposure limit (OEL) for polycyclic aromatic hydrocarbons (PAHs).