Greentervention
Greentervention was formed in response to the urgency of the climate problem, and the need perceived by the founders for coherent economic, financial and social policies at the European level in order to achieve the necessary (socially just) transition.
ID: 475915836797-75
Lobbying Activity
26 Nov 2024
NBIC ETHICS, a branch of NBIC WATCH, wishes to contribute to the Commission's consultation on the draft implementing regulation laying down rules for the application of Regulation (EU) 2021/2282 with regard to the procedures for joint scientific consultations on medical devices and in vitro diagnostic medical devices. NBIC Ethics wants to raise 5 areas of concern and requests on this draft regulation, in perspective of the EU treaties. 1. The principle of subsidiarity needs to be recalled and respected in EU Member States. Although competences on health matters are shared, Member States have jurisdiction on biethical legislation in their own state. Disparate regulation on matters such as the human body status, the embryo status, artificial procreation technics - IVF, prenatal, preimplantation testing procedures are non-consensual; the European Commission is required to draft applicable legislation to consensual areas only, excluding bioethics national law. 2. Embryos, fetuses, gametes and embryonic cells or embryonic tissues cannot be subject to european law even for the purposes of research or the technical evaluation of in-vitro medical devices. Embryos and fetuses are not raw materials and are not considered as such by European law. 3. Medical device involved in in-utero diagnosis performed on pregnant women, as well as their evaluation can not be included in the draft regulation. 4. The reliability of the rules of health data privacy are to be maintained at all cost as well as any patient-identifying data in the context of these evaluations 5. Informed consent on the use of these medical devices from patients involved in these IVF procedures is compulsory. This extends to patient's gametes or embryos which might have been cryogenized for self-preservation and/or research purposes.
Read full responseResponse to Legislative package on the Economic Governance Review
3 Aug 2023
The comments also relate to the COM2023/241 reform (corrective arm regulation). The primary objective of both regulations is the sustainability of public debt. A reduction in the public debt and deficit/GDP ratios or their maintenance at a prudent level would be the main determinant of "sustainability". For sure, the legislation refers to a set of other EU priorities. However, without any association with verifiable progress indicators. Countries pursuing a program geared to these priorities enjoy, in the best of cases, a certain degree of flexibility before having to strictly comply with the debt and deficit limits. //The plausibility of the debt projection and its sustainability and the related, instrumental net expenditure path is assessed with a method already used by the Commission in its Debt Sustainability Analysis. This method would be now enshrined in legislation. A central variable in this method is an unobservable variable, the potential output, estimated by a macroeconomic model that was the subject of intense controversy pointing on high uncertainty. In its communication 2022/583, the Commission acknowledged the difficulties created by the use of such unobservable variables, including lack of transparency and ownership. We will not address again these points here, even if still relevant. //Beyond that, the critical weakness of the proposal is that it does not integrate the links between fiscal policy, fiscal risks and climate policy, In particular the capacity to: //1.reduce the cost of the material consequences of climate change through early investment in adaptation and resilience //2.an early and coherent transition policy to reduce systemic financial and sovereign debt risks. This link was identified by the ECB in its 2023 report on financial stability (p. 119 ss.). Such a policy requires additional public investment and transfers to households and businesses.//The proposal imposes a strong numerical constraint on debt and deficit-to-GDP ratios without any significant flexibility. This lack of flexibility prevents a trade-off between increased debt and reduced fiscal and financial risks through more investment. EU economies risk therefore to be doubly penalized: activities at a lower level and climate risks at higher level than possible. This problem will vary in intensity from one country to another, which will affect the cohesion of European economies. It raises serious doubts about the enforceability of the proposed budgetary framework and its consistency with the objectives of the European Green Deal. //If the proposals are not rejected, the core of the amendments should concern the following elements: //1.The plausibility assessment of the path of public debt according to Art. 8 and Ann. V of the regulation takes account of methodological bias and is supplemented by transition scenarios inspired by those developed by the Network for the Greening of the Financial System and already used by the ECB to test the resilience of the banking system.//2.Member States are required to present a plan for reducing fossil fuel subsidies. //3.Including for countries that do not respect the Treaty reference values for public debt and deficit ratios, a set of so-called "transition expenditures are considered as off-budget. For the purpose of both regulations (preventive and corrective arm), they are deducted from structural and nominal balances as well as from net public expenditure. The cumulative amount of these expenditures are deducted from the debt. //4The maximum deductible amount of these expenditures is determined by deficit and debt levels, but is never less than 1.5% of GDP. The difference between the planned reduction in fossil subsidies and the actual reduction is deducted from or added to this amount. //5.Definition: "Transition expenditures" support sector or local transition plans associated with verifiable result indicators and whose expenditure complies, where applicable, with the European taxonomy (att.)
Read full response19 Feb 2020
Greentervention asbl welcomes this public consultation on reporting of climate action by EU governments. The success of the European cooperation on Climate change policies will indeed depend on a high level of transparency and the quality of information shared among Member States and with the public. A high degree of comparability of data between countries is also needed.
This contribution addresses reporting under article 37 of the draft implementation regulation as well as annex XXIV (reporting on national policies and measures). The regulation 1999(2018)) makes an explicit link between the Governance of the Energy Union and Climate Action, including the National Energy and Climate Plans, on the one side and the European Semester, including the fiscal rules of the Stability and Growth Pact on the other (whereas 63, art. 14(5),29(6),34(2c)). Accordingly, the implementing regulation should foresee that member states have to report on general government’s past and expected expenditures and revenues induced by national policies and measures on a way coherent with the methodology of the data requirements under the Stability and growth Pact (National account methodology – ESA). Public debt sustainability and securing expenditures related to climate change policies (green budgeting) should be treated with the same priority. Accordingly, past and expected impact of climate change and climate change policies on the public budget, on the accounts of the general government, should be reported so as to ensure the comparability between countries. National Energy and Climate Plans have also been mentioned as a potential source of information in the debt sustainability monitor 2019 by DG ECFIN (box on the inclusion of CC in the debt analysis). Distinguishing between central and local governments as well as between different categories of expenditures (capital transfers, current transfers, investment,..) is also necessary. We therefore suggest to add a table 1a to be elaborated using Eurostat methodology to include these numerical information as the requirement for the cost and benefit calculation under table 3 of annex XXIV are not specific enough to ensure their comparability and their relevance.
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