Centrum pro dopravu a energetiku, z.s.
CDE
Centrum pro dopravu a energetiku (CDE) je nevládní nezisková organizace, která se dlouhodobě zabývá vlivem dopravy a energetiky na životní prostředí, a to zejména v souvislosti s ochranou klimatu a snižováním emisí skleníkových plynů.
ID: 745736047827-33
Lobbying Activity
Response to European climate resilience and risk management law
4 Sept 2025
As the fastest-warming continent, Europe is facing a severe crisis that will not impact the European population homogeneously. We advocate for an approach sensitive to the particularities of vulnerable groups, which will face more severe climate-related consequences, while having a lesser ability to face them. A just and ambitious approach to climate resilience is crucial, with continued dedicated support to disadvantaged regions and vulnerable groups. Europe needs to set strict domestic milestones and achieve climate neutrality by 2040, as the cost of inaction is becoming too high, and adaptation will not be possible in a 2 or 3°C warmer world. The prepared framework must be following robust evidence-based policy, expert reports such as the IPCCs, UNEPs Adaptation Gap reports, or EUCRA. Trust in institutions and social cohesion is a pillar of crisis response, therefore, we emphasize the importance of the partnership principle, which needs to be anchored in the disbursement of EU funds, the conception and implementation of policies. Transparency and independent monitoring is crucial, we highlight the importance of civil society, which needs to benefit from continued support, including through access to funds of the Technical Support Instrument, as it is an effective mediator between people and policies, but with limited access to European funds, needed to build capacity and expertise. Trust in institutions cannot be maintained without strict enforcement of the rule of law, which must be a strict conditionality to disbursement of EU funds, especially in enforcing EU climate and environmental legislation. It will be critical to dedicate sufficient funds to adaptation, including funds to preserve and strengthen biodiversity, as a decaying nature worsens crises. The EU should ensure that such funds are made more easily accessible to community-led initiatives under the next MFF. We side with CAN Europe and call for a 2-trillion EU budget that earmarks 50% for closing the climate and biodiversity investment gaps: EU funds should have accurate horizontal mainstreaming targets and earmarking, incl. strong definitions of qualifying adaptation actions; a more robust implementation of the Do No Significant Harm (DNSH) principle, incl. to adaptation objectives and avoiding maladaptation; dedicated finance for a socially just transition should be protected and expanded. Funds should be generated applying the polluter pays principle, and it is especially important that European funds reach groups most in need of public support, with strong indicators, and excluding support for fossil fuels. We advocate for continued investment in innovative projects, such as under the LIFE programme, which showed an impressive track record of funding innovative, pioneering, and often community-led projects. Additionally, the LIFE programme was the only fund dedicated to funding biodiversity, its dissolution is a net loss for the European climates resilience. Fostering community resilience is a pillar of effective crisis response and management. Investing in energy communities and a decentralized energy market will be crucial in reducing reliance on large power sources, as well as reliance on imported energy, which poses a new security threat, once again predominantly borne by vulnerable groups. Community energy is an effective way to combat energy poverty, while demonstrating benefits in strengthening social cohesion. The framework must take into account the importance of communities resilience, and support a fully renewable economy and the preservation and scaling up of the support of green jobs, including jobs in sectors not typically considered as green such as care or the social economy sector. This support is crucial to ensure no one is left behind.
Read full response8 Jul 2025
CDE does not support the use of free allocations, including for non-CBAM sectors, in order to ensure a full application of the Polluter Pays Principle and to provide the necessary incentives in support of lower-emission goods and practices and ensure policy coherence. Free allocation has muted emission reduction incentives for industry for the entire lifespan of the ETS, which translates into negligible decreases in emissions. The timeline for the phase out of free allocation of ETS allowances for CBAM sectors should not be delayed from what co-legislators agreed in 2022. Once a Carbon Border Adjustment Mechanism (CBAM) is fully operational, free allowances need to cease immediately. Indirect cost compensation should be phased-out through a planned inclusion of indirect emissions under the CBAM. The CBAM should be extended to more sectors and free allocation phased out for those as well as soon as possible. CDE supports the extension of the scope of the ETS1 in line with the Polluter Pays Principle, by lowering the nominal thermal power threshold for energy production units, by including municipal waste incineration and other waste management processes, and by including further emissions of the maritime sector, and by including emissions of international aviation. For what concerns lowering the nominal thermal power threshold for energy production units, we expect the Commission to assess the effectiveness of these steps in terms of regulatory efforts and carbon emissions covered, as we understand these installations will be subject to ETS2 once it is in full operationalisation. The ETS1 scope extension should not lead to an increase of the cap or decrease of the Linear Reduction Factor, which needs to be maintained also after 2030. It should also not lead to the creation of new free allowances. Carbon pricing should be complementary to and work in synergy with other policies which aim to reduce emissions and account for environmental and social impacts. The current scope and ambition of binding national climate targets and the compliance structure (ESR) need to be maintained, and further strengthened to ensure compliance from Member States. CDE opposes the inclusion of any removals into the ETS. This would remove pressure from reducing emission. Removals cannot substitute for immediate, deep and sustained emissions reductions. ETS still has significant mitigation potential (e.g. 30% coal). Incentivising permanent removals is better done by funding R&D and pilot projects - the ETS price will likely not be high enough to drive high-quality sustainable and permanent CDR. Instead, it is likely to incentivise the cheapest, biomass-reliant CDR, which would add further strain to the EUs already depleting carbon sink. The EU should set three separate targets and dedicated policy instruments for 1) gross emission reductions, 2) natural sequestration in ecosystems (LULUCF) and 3) permanent carbon removals, to be based on a thorough and science-based impact assessment of their sustainable scale-up, taking into account risks, benefits and trade-offs. CDE also emphasises that ETS instruments regulate domestic emissions only - in line with the 2030 target being a domestic one as enshrined in the European Climate Law - and that it is of key importance that this principle is maintained in the future, also beyond 2030, and no international credits are integrated, to ensure the effectiveness of this policy in achieving its goals of reducing EU emissions and the fairness of EU contribution to global climate mitigation. CDE also calls for improvement of transparency and reporting requirements for the use of ETS revenues, which should be strengthened and reports on the use of ETS revenues should be made available to the public in detail.
Read full responseMeeting with Ondřej Krutílek (Member of the European Parliament) and Hnutí DUHA - Friends of the Earth Czech Republic
22 Oct 2024 · Green Deal and Expected Legislation in ITRE Committee
Meeting with Mikuláš Peksa (Member of the European Parliament)
17 Jan 2024 · Climate agenda
Meeting with Mikuláš Peksa (Member of the European Parliament)
30 Sept 2022 · Fit for 55
Meeting with Mikuláš Peksa (Member of the European Parliament)
8 Apr 2022 · Fit for 55
Meeting with Mikuláš Peksa (Member of the European Parliament)
5 Nov 2021 · TEN-E