Position papers

2022

June EURACOAL Response to European Commission Proposal on a revision of the Industrial Emissions Directive (COM(2022) 156)

2021

December EURACOAL response to public consultation on “air quality – revision of EU rules” questionnaire

November Fit-for-55 Package

August EURACOAL response to Targeted Public Consultation on Climate, Energy and Environmental State aid Guidelines (CEEAG)

April EURACOAL Position Paper on an EU strategy to reduce methane emissions (COM(2020) 663)

April EURACOAL Response to Public Consultation and Targeted Stakeholder Survey (TSS) on a revision of the Industrial Emissions Directive and European Pollutant Release and Transfer Register Regulation (IED-EPRTR-Revision-OPC-2020)

April EURACOAL questionnaire response on EU biodiversity policy initiatives – Evaluation of the EU Biodiversity Strategy to 2020, review of the application of the EU Regulation on Invasive Alien Species, and development of binding EU nature restoration targets for 2030

March EURACOAL questionnaire response to IED-EPRTR-Revision-OPC-2020

February EURACOAL questionnaire response on Public consultation on the EU Zero Pollution Action Plan

February EURACOAL questionnaire response on Updating the EU Emissions Trading System

February EURACOAL questionnaire response on Reviewing Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

January EURACOAL Position Paper on the European Climate Law and 2030-2050 targets as well as the “Fit for 55” package

January EURACOAL Response to Inception Impact Assessment on a proposal for a legislative act to reduce methane emissions in the oil, gas and coal sectors

January EURACOAL Response to Inception Impact Assessment on Revision of the Ambient Air Quality Directives

2020

December EURACOAL Position Paper on the proposed amendment to the regulation on access to justice in environmental matters (COM(2020) 642)

December EURACOAL Response to Roadmap
on a New Soil Strategy – healthy soil for a healthy life

December EURACOAL Response to Inception Impact Assessment on EU Nature Restoration Targets

November EURACOAL Response to Inception Impact Assessment on Water Framework Directive – revision of lists of pollutants affecting surface and groundwaters

November EURACOAL Response to Inception Impact Assessments on amendment of the EU Emissions Trading System and amendment of the Effort-Sharing Regulation (EU) 2018/842

October EURACOAL Response to Inception Impact Assessment on EU Action Plan “Towards a Zero Pollution Ambition for air, water and soil – building a healthier planet for healthier people”

October EURACOAL Response to Inception Impact Assessment on European Pollutant Release and Transfer Register (updated rules)

click to see full 1990-2050 chart

August EURACOAL Position Paper on the proposal to modernise the Research Fund for Coal and Steel

June EURACOAL Position Paper on the proposed European Climate Law and 2030-2050 targets in a regulation to establish the framework for achieving climate neutrality by 2050 (COM(2020) 80)

April EURACOAL Response to Public Consultation on a possible revision of the Industrial Emissions Directive (with a detailed commentary on the IED review in an annex)

April EURACOAL Response to Public Consultation on the Inception Impact Assessment for the proposed 2030 Climate Target Plan

April EURACOAL Response to Public Consultation on Access to justice in environmental matters

April EURACOAL Response to Public Consultation on the proposed revision of the Energy Taxation Directive (ETD) 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity

JTF

April EURACOAL Response to Public Consultation on a Carbon border adjustment mechanism

March EURACOAL Response to Public Consultation on the proposal for a regulation to establish the Just Transition Fund

February EURACOAL Response to Public Consultation on European Climate Law – achieving climate neutrality by 2050

2019

EURACOAL-20190904-Position-Paper-2050-vision-09-277x321.png
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September EURACOAL Position Paper on “A Clean Planet for All” – a strategic long-term vision for a prosperous, modern, competitive & climate-neutral economy (COM(2018) 773)

May EURACOAL congratulates the Ukrainian Deputy PM and his team ahead of the country’s electricity market liberalisation on 1 July 2019

March EURACOAL response to the European Investment Bank’s public consultation on its Energy Lending Policy

March EURACOAL Position Paper on the Fitness Check review of the EU Water Framework Directive
(WFD – 2000/60/EC)

2017

click to download full set

June EURACOAL Position Paper on the “Clean Energy for all Europeans” package and the proposed 550 gCO2/kWh emission performance standard for access to capacity markets

May EURACOAL Position Paper on the “Clean energy for all Europeans” package

2016

euracoal-201609-infographic-balancing-renewables-rev02-321x227
Infographic on balancing renewables

October EURACOAL Position Paper on proposed amendments to reform of the EU Emissions Trading Scheme (2015/0148(COD), rapporteur: MEP Ian DUNCAN, rapporteur ITRE opinion: MEP Fredrick FEDERLEY)

Infographic

July EURACOAL Response to Public Consultation on State aid to secure electricity supplies: keeping the lights on

EURACOAL_201605_Infographic_ETS_reform_rev02-321x227
Infographic on Modernisation Fund

May EURACOAL Position Paper on reform of the EU Emissions Trading System: walking a fine line (2015/0148(COD), rapporteur: MEP Ian Duncan)

Infographic

2015

EURACOAL-201510-Infographic-NOx-rev02-240x170
Infographic on NOx emissions

October EURACOAL Position Paper on revisions to the National Emission Ceilings Directive and on why the EU should not go beyond its international obligations (A8-0249/2015, rapporteur: MEP Julie GIRLING)
Annex – Gothenburg Protocol commitments for 2020)
Infographic

October EURACOAL response to Public Consultation by DG Energy on a new energy market design (“Market Design Communication” COM(2015)340)

October EURACOAL response to Public Consultation by DG Energy on risk preparedness in the area of security of electricity supply (“Market Design Communication” COM(2015)340)

EURACOAL-201508-Infographic-LCP-BREF-rev04-240x170
Infographic on LCP BREF

February EURACOAL Position Paper on Industrial Emissions Directive (IED) and “Best Available Techniques” (BAT) Reference Document for Large Combustion Plants (LCP BREF): a tale of leapfrogging standards

Infographic (updated August 2015)

January EURACOAL Position Paper on proposed amendments to the draft ITRE committee report on European Energy Security Strategy (2014/2153(INI), rapporteur: MEP Algirdas Saudargas)

2014

EURACOAL-20141000-Infographic-2030-rev05-240x169
Infographic on EU 2030 targets

October Why less climate ambition would deliver more for the EU

Infographic

March Action Plan for Coal in the 21st century

February EURACOAL Response to Public Consultation on the Draft Community Guidelines on State Aid for Environmental Protection and Energy for 2014-2020 (ref. HT 359)


2013

November The Warsaw Communiqué

September EURACOAL Position Paper on the proposal for a regulation concerning the notification to the Commission of investment projects in energy infrastructure within the European Union and replacing Council Regulation (EU, Euratom) No 617/2010 COM (2013) 153 final

August EURACOAL response to EBRD public consultation to the draft Energy Sector Strategy

July EURACOAL response to the public consultations on the 2030 Green Paper and on the future of CCS in Europe

June EURACOAL response to the public consultation on the 2015 International Climate Change Agreement

April EURACOAL position on “The Unpaid Health Bill: how coal power plants make us sick”

March EURACOAL comments on the proposal to amend the EIA Directive

March Open Letter from EURACOAL President on EU Emissions Trading Scheme – no short-term fixes to a long-term strategy

February EURACOAL Position Paper on structural reform of the EU ETS

February Joint position of the Sectoral Social Dialogue Committee “Extractive Industry” on EU ETS back loading: no short cuts to short-term measures


2012

December EURACOAL Response to EIB Consultation Paper dated October 2012 on the European Investment Bank’s review of its energy sector lending policy

December EURACOAL position on the “back loading” of auctioning and “set aside” of allowances under the EU ETS

November EURACOAL Position on the Emissions Performance Standards under the UK Energy Bill 2012-13

September EURACOAL Position on the “back loading” of allowance auctioning under the EU ETS

September Joint Statement on the further improvement of the working conditions and occupational health of employees in the extractive industries in the context of European social dialogue

September EURACOAL Position on Recommendation on SCOEL/SUM/53 (June 2012) for NO2

April Joint Position Paper on the Importance of including Flexible and Efficient Conventional Power Generation in the Horizon 2020 Framework Programme / Proposed Amendment to the Horizon 2020 Text

March EURACOAL Position on the Energy Roadmap 2050

February EURACOAL Position on set aside of ETS allowances

February EURACOAL Position Paper on Silica and the Carcinogens Directive


Mr. Philip Lowe, Director-General for Energy
Mr. Philip Lowe, Director-General for Energy at European Coal Days, November 2011

2011

September EURACOAL Position Paper on the Seveso III Directive

March EURACOAL response to the Public Consultation by DG Energy on the external dimension of the EU energy policy

March EURACOAL response to DG Energy Public Consultation on the Roadmap for a low-carbon economy by 2050


2010

December EURACOAL response to DG Climate Action Public Consultation on the Roadmap for a low-carbon economy by 2050

October EURACOAL Position Paper on State Aid for Coal (Council extends state aid regime for the coal sector – European Council press release, 10 December 2010)

September EURACOAL Position Paper on Heat Benchmarks

June EURACOAL Position Paper concerning the Public Consultation “Towards a New Energy Strategy for Europe 2011–2020”

May EURACOAL´s position on the Industrial Emissions Directive after the ENVI vote in the European Parliament

January EURACOAL Position on CO2 Capture and Storage / EURACOAL zur CO2-Abtrennung und Speicherung


2009

December EURACOAL position for the second reading of the proposal for a directive on industrial emissions (integrated pollution prevention and control) in the European Parliament

November EURACOAL’s Position on the Draft Directive on Energy Taxation

October EURACOAL Position on the Commission’s Declaration ad Art. 10(3) of the Emissions Trading ETS Directive

September EURACOAL Position Paper on the “Non paper: Best Use of EU’s Indigenous Resources”

August EURACOAL Position on the revised version of the recommendations from the SCOEL on occupational exposure limits for NO2 from September 2008 (SEG/SUM/53)

January EURACOAL Position on the Strategic Energy Review II


2008

May Opinion of the European Coal Industry: European Commission´s Proposal for a Directive on CCS – 23rd January 2008

April EURACOAL Position on the Draft Directive on an EU Scheme for the Trading of Greenhouse Gas Emissions Certificates as from 2013 / EURACOAL-Stellungnahme zum Entwurf einer Richtlinie für ein EU-System für den Handel mit Treibhausgasemissionszertifikaten ab 2013


2007

December The future of Emissions Trading after 2012 in Europe and in a global context

October Emissions Trading – Energy and Environmental Policy: Two Sides of the Same Coin: Preparing the 2012 – 2020 Period

September The Long-term Perspectives for Coal in the Electricity Sector in the EU

July EURACOAL Position on Future Legal Framework for CCS

July EURACOAL Position on CO2 Capture and Storage


2006

November On the Green Paper: A European Strategy for Sustainable, Competitive and Secure Energy