Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági, Környezet- és természetvédelmi Egyesület
European CSR
Senior Corporate Silver Spoon is a Hungarian environmental and nature protection association focused on environmental policy, agri-environmental management, climate change, and social justice at European and national levels.
Lobbying Activity
28 Feb 2024
Dear European Commission and its Institution, Dear Ladies and Gentlemen, I am sending a professional opinion of our Association as an attached document. The attached professional opinion is a three-page document. The professional opinion is written in English and Hungarian. Kindest regards, Brigitta Balogh PR Lead
Read full responseResponse to Evaluation of the National Emission reduction Commitments Directive
17 Feb 2024
Dear European Commission, Dear DG, Dear Ladies and Gentlemen, I am sending as an attached file the professional opinion of the Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági Környezet- és természetvédelmi Egyesület to the Targetedness Examination. Title of the evaluation: The directive on national emission reduction obligations - evaluation. The professional opinion is a four-page document. Which was written in English and Hungarian. Thank you very much. Best regards, Anikó Márta Szűcsné Putics
Read full responseResponse to ESF+ mid-term evaluation
19 Jan 2024
Dear European Commission, Dear Ladies/Gentlemen, I am sending the formation of the professional opinion on behalf of the Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági, Környezet- és természetvédelmi Egyesület. Look: The attached two-page written document. The document was written in both English and Hungarian. Kindest regards, Brigitta Balogh PR Lead
Read full responseResponse to 8th Environment Action Programme – Mid-term Review
24 Dec 2023
On behalf of the members of our Association and myself: Wish you a Blessed and Peaceful Christmas to all the Staff/Colleague of the European Commission My opinion, which the Environmental Protection Engineers of our Association also agree with. Dear European Commisssion, Dear Directorate General ENV - 01, Dear Directorate General CLIMA - A2, Dear Ladies/Gentlemen, Thank you for the sent Call for Opinions on the Initiative (without an impact assessment). The title of the initiative: 8th Environment Action Programme - Mid-term Review (supporting the European Green Deal). Köszönet a megküldött Véleményezési Felhívás Kezdeményezéshez (hatásvizsgálat nélkül). A kezdeményezés címe: 8. környezetvédelmi cselekvési program - Félidős felülvizsgálat (az európai zöld megállapodás támogatása). For point "A" as necessity: "A" ponthoz, mint szükségességhez: - In this Call for Opinion, it is necessary for the current state for the quality of the objectives of the Environmental Protection - the belong related climate change - tasks taking the Mid-term Review. - Ebben a Véleményezési Felhívásban a megnevezett környezetvédelmi - és a hozzátartozó éghajlat változás - feladatok célkitűzéseinek a jelen állapotban lévő minőségéhez szükséges a Félidős felülvizsgálat megtétele. - Effective Protection of the Environment - both at the level of the European Union and at the Global level - requires the professional application and clear interpretation of Environmental Protection methods. - Az eredményes Környezet Védelemhez - mind az Európa Unió szintjén mind Globális szinten - szükséges a környezetvédelmi módszerek szakszerű alkalmazása és egyértelmű értelmezése. For point "B" as efficiency: "B" ponthoz, mint eredményességhez: - For the effective fulfillment of Environmental Protection professional cooperation in environmental protection between the Directorates General of the European Commission is essential. - A Környezetvédelem hatékony teljesüléséhez elengedhetetlen az Európai Bizottság Főigazgatóságai között a környezetvédelmi szakmai együttműködés. - Our Association - the Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági, Környezet- és természetvédelmi Egyesület has Environmental Protection Engineers, as with the human resources necessary for the activities of Environmental Protection tasks. - Szervezetünk, a Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági, Környezet- és természetvédelmi Egyesület rendelkezik Környezetvédelmi Mérnökökkel, mint a környezetvédelmi feladatok ellátásához szükséges humán erőforrással. S z e g e d, 24 December 2023 Best regards, Anikó Márta Szűcsné Putics / Szűcsné Putics Anikó Márta as a Landscape Management Engineer - Environmental Management Speciality as an Environmentalist Specialised in Law as a Graduate Labour Specialist and as Professional Leader of Association
Read full responseResponse to 2024 Evaluation of the European Labour Authority
3 Dec 2023
Dear European Commission, Dear Directorate-General in its E1. for your unit, Dear Ladies/Gentlemen, Look the attached three-page Official Professional Document. In English and Hungarian. Thank you very much. Best regards, Anikó Márta Szűcsné Putics
Read full responseHungarian NGO calls for engineering-led Modernisation Fund rules
4 Aug 2023
Message — The association argues that the current legal basis is outdated and requires immediate correction. They advocate replacing strictly economic criteria with professional environmental engineering applications to implement renewable energy.12
Why — This approach would prioritize engineering-led projects over those driven by strictly economic cost-effectiveness.34
27 Apr 2023
Dear European Commission, Dear Ladies and Gentlemen, I am attaching the three pages review. The opinions of our Association's Environmental Protection Engineers. Best regards, Brigitta Balogh PR Lead
Read full responseEnvironment association urges scientific definitions for 2040 climate targets
15 Apr 2023
Message — The organization argues the initiative contains incorrect definitions due to a lack of environmental science. They request a focus on stabilizing atmospheric concentrations rather than industrial carbon removal.123
Why — Adopting their engineering solutions would provide the group with professional cooperation and funding.45
Impact — Industrial carbon removal firms lose credibility as the group labels their technology non-existent.6
Response to 2024 evaluation of EU Agencies EUROFOUND, CEDEFOP, ETF and EU-OSHA
4 Mar 2023
Dear European Commission, Dear Ladies and Gentlemen, The labor professionals of the Senior Corporate Silver Spoon, Environment & Nature Association received the notice of the 2024 Evaluation Opinion of the EU agencies Eurofound, Cedefop, ETF and EU-OSHA with thanks. The labor experts provide the following professional information to the European Commission and its Directorate General after reading the work programs of the above-mentioned Agencies. - The activities of the Agencies are based on political ideas. - The activities of the Agencies are based on a politically based concept instead of applying deep knowledge of the given Science area. Look: 1. In the Eurofound Mission text section, "better social, development of employment and labor policies." etc.. The development of policies as a goal is wrong because for these the further tasks for the specialized areas are related to them it needs to be done by applying Sience. 2. In the second paragraph of Cedefop's Foreword, "Reliable and strong skills intelligence to inform the necessary up and reskilling and career transition policies is therefore indispensable." etc.. Furthermore, there is no such professional term as "sustainable competitiveness". etc. Look the third paragraph of the Foreword. 3. In the first paragraph of The ETF in brief, "external relations policies", etc. In the second paragraph of the ETF in brief, "on the reform of education, training and employment policies and systems." etc. 4. EU-OSHA Look: "How we do business" "The campaigns draw the attention of employees, businesses and European policy makers to workplace safety and health protection, and also serve an informational purpose." etc.. Based on the examples cited above, we politely inform the European Commission and its Directorate General that the purpose of the Agencies' activities cannot be based on political finish. It is also not correct to refer to the policy because it can be confused with a political-based idea. Only adequate/appropriate and deep professional knowledge can be the basis of all European Union actions. Which means that education, employment, social security, etc.. in the XXI. century is no longer determined by periodic political situations and political ideologies. Because education and other related tasks are determined by the relevant Science's deep professional knowledge. Because employment and other related tasks are determined by the relevant Science's deep professional knowledge. Because social security and other related tasks are determined by the relevant Science's deep professional knowledge. Because in the XXI. century the applications of the professional knowledge of the Knowledge-based society are necessary. Keyword: Knowledge-based society. Professional knowledge that can only be applied by those persons who have acquired the appropriate responsibility complete knowledge and the College issued a Diploma, the University issued a Diploma. Unfortunately, we have to say that the goals of the Agencies are already outdated, and the methods they use are also outdated compared to the requirements of the Knowledge-based society. Best regards, Anikó Márta Szűcsné Putics as a Professional Lead
Read full responseResponse to Measures addressing the environmental impact of imaging equipment including consumables
25 Jan 2023
Given an Opinion. Dear European Commission, The Senior Corporate Silver Spoon, Environment & Nature Association we give the following Opinion on behalf of: By providing the following Opinion for the Initiative called "Environmental impact of imaging equipment, including consumables", we inform the European Commission and its Institutions of the following. Unfortunately, the ideas presented in this Initiative are not suitable for carrying out the planned actions. Because the interpretation and reference to environmental impact is incorrect. Furthermore, below, we draw your attention to the following. For point "A": About the Circular Economy: - The creation of the Circular Economy is always based on the professional knowledge of Environmental Engineering. Because professional knowledge and experience in environmental protection engineering is indispensable. Indispensable for planning that requires specialist knowledge, planning that requires physical, chemical, biological, etc. for processes. About electrical and electronic equipment as products: - "identified electrical and electronic equipment as a key product value chain" In the text "electrical and electronic equipment has been identified as a key product value chain", the reference to "product as a value chain" is completely incorrect. Because the correct name is the life cycle name. About electrical and electronic equipment as waste: - Becoming waste is influenced by the applied Environmental Protection procedure. The legal basis is unfortunately also incorrect. The correct legal document Treaty on the Functioning of the European Union is XX. TITLE Environment Articles 191 - 193. For point "B": - The term impact assessment is incorrect. Because such an Environmental Protection term, "impact assessment" does not exist by itself. Therefore, its interpretation and reference are also incorrect. For point "C": Unfortunately, the references written in this section are also incorrect. Our Environmental Protection Engineers express their hope that the professional information provided above will facilitate and contribute to the Consultation strategy planned by the European Commission.
Read full responseResponse to European Year of Skills 2023
19 Oct 2022
Dear European Commission, Dear Ladies and Gentlemen,
Our Association's Labour Specialists also have read the "European Year of Skills 2023" address initiative.
Our Labour Specialists agree with the objectives of initiative.
The goals, objectives, and proposals have been put together very nicely.
Congratulations to the writers.
The realization of these goals, objectives and proposals requires, of course, the necessary professional expertise.
The necessary professional competence means that those persons who would participate in the activities of the "European Year of Skills 2023" must very, very well understand and be able to apply the professional knowledge of the field of Science they represent.
There is no place for superficial knowledge gathered back and forth and thus for the transfer of superficial knowledge.
For example: As with the Circular Economy, which is currently incorrectly interpreted and therefore erroneously spread.
Or regarding the wrongly and therefore incorrectly interpreted and referred to "sustainability" as also, such for a solution.
Or regarding gaps in professional knowledge that can be found in the Common Agricultural Policy and in the CAP Strategic Plan of
the Member States for the period 2023-2027 sent by the Member States by December 31, 2021.
And etc.
Kindest regards,
Anikó Márta Szűcsné Putics
a Graduate Labour Specialist
Read full responseSenior Corporate Silver Spoon urges reclassifying asbestos proposal
7 Oct 2022
Response to Requirements for access to electricity metering and consumption data
4 Sept 2022
Dear Ladies/Gentlemen,
Please, pass the attached Official Professional Informative Document to Ursula von der Leyen President.
Thank you very much.
Brigitta Balogh
PR Lead
Read full responseResponse to Developing social economy framework conditions
19 Aug 2022
Look attached file.
The attached document has three pages and is in Hungarian.
Best regards,
Brigitta Balogh
PR Lead
Read full responseSenior Corporate Silver Spoon slams chemical safety data proposal
21 Jul 2022
Message — The association claims the proposal's legal basis is incorrect. They argue it ignores REACH regulations and uses inaccurate scientific terms.12
Why — This shift would prioritize the group's environmental engineering expertise in EU policy.3
Impact — The public loses scientific rigor if the Commission ignores established environmental protection principles.4
Senior Corporate Silver Spoon slams waste report legal basis
6 Jul 2022
Message — The association demands correcting the legal basis, as a directive cannot serve as one. They also urge the inclusion of environmental engineering expertise.12
Why — Correcting the legal framework would align the report with established international environmental laws.3
Impact — Citizens lose out as environmental targets may not be achieved without specialized engineering input.4
Response to Circular economy monitoring framework - Revision
10 May 2022
Dear DG, Dear Ladies and Gentlemen,
As I cannot send a Professional informative document to Ms Ursula von den Leyen through another secure channel, I am sending the attached document on this interface.
Subject of the Professional informative document: Energy Security
I kindly ask you pass the President of the European Commission the attached Professional informative document.
Thank you very much,
Anikó Márta Szűcsné Putics
Read full responseResponse to Evaluation of the European Environment Agency for the period 2017-2021
2 May 2022
Dear European Commission, Dear DG, Dear Ladies/Gentlemen,
Our Association thanked you sent notification to: THE CALL FOR OPINIONS FOR EVALUATION OR TARGET MANAGEMENT TESTING.
Yesterday, on May 1, 2022, I also sent this information to those concerned in Hungarian.
As for the European Commission, as for the President of the European Commission, as for the Directorate-General responsible.
The main activity of our Association: Environmental protection.
To President of the European Commission to Ursula von den Leyen, to DG - Responsible Unit below we send a brief but important information of the professional opinions of our Environmental Engineers and Environmental Management Speciality Engineers.
Professional resolutions:
- The Environment Agency's task is for collecting environmental information in the European Union.
Processing and disseminating these environmental information.
Preparation of a report on the state of the environment.
In this professional resolution of our Association, it is necessary to draw the attention of the European Commission, the President of the European Commission, the Unit responsible for the Directorate-General - to:
- Every four years on the state of the European Union's environment need report to the European Environment Agency based on its task.
The four-year period for drawing up a report on the state of the European Union's environment has been reduced by a new regulation
transposing the Aarhus Convention into EU law.
This Ref. Ares (2022) 3209213 - 25/04/2022 Call for Opinions is aimed at examining and evaluating the administrative and financial functioning
of the Agency.
Look: The references in point “A” to “the evaluation focuses on five main evaluation aspects” in the Purpose and Scope references.
- For environmental issues, these evaluation criteria do not determine the evaluation of the work of the Agency and its monitoring network.
Because, - we repeat it again - these aspects examine the operational and economic aspects of the Agency.
These evaluation criteria do not determine the quality of their work in environmental matters.
Because these “five main evaluation criteria” are not needed to determine the legal instruments needed for the necessary environmental requirements.
Look: - Commission, SEC (93) 785 of 2 June 1993
- Commission, Press Release IP/97/636, 11 July 1997
S z e g e d, May 02, 2022
Kindest regards,
Anikó Márta Szűcsné Putics
a Landscape Management Engineer - Environmental Management Speciality,
an Environmentalist Specialised in Law,
a Graduate Labor Specialist,
Professional leader of the Association
Read full responseResponse to New EU Forest Monitoring and Strategic Planning Framework
9 Apr 2022
Dear European Commission, Dear DG, Dear Ladies and Gentlemen, We have thanked you for sending this Call for Opinions to our Association.
After reading the Call for Opinions we provide the following brief professional feedback to the European Commission, to Ms Ursula von der Leyen President of the Commssion, to the named Directorates-General as the Directorate-General concerned.
TITLE OF THE INITIATIVE: New EU Forest Monitoring and Strategic Planning Framework.
After reading the contents of this Call for Opinions, the following brief professional information will be provided by the Environmental Engineers and Engineers of our Association. We agree with the idea of the initiative.
But unfortunately, we cannot agree with the professional shortcomings that prevent us from reaching the imagined goals.
Because the first and indispensable condition for drawing up a professional strategy - an action plan - is to have complete professional knowledge of the field for which we want to draw up an action plan.In Environmental Protection in all cases, engineering expertise is required to prepare an action plan. Unfortunately, in the absence of a deep knowledge of the Environmental Protection, it is not possible to draw up a precise professional action plan. Mainly not in Regulation form. Because at European Union level, we are talking about planning documents.
Look: Varieties and Types of Plan Documents:
- Institutional work plan - operatíve plan document;
- Green Paper - Founding, planning document;
- White Paper - Conceptual planning document;
- Policy Strategy - Strategic planning document.
In the following is the required Environmental Engineering Information for point “A”:
- There is no Circular Economy Organic farm. There is only a Circular Economy. Therefore, the goal of “promoting the circular bioeconomy” is
not correct. Look: The definition of this goal in the second sentence of the first paragraph of point "A".- The task and goal of biodiversity it was
not quite correctly defined. Because Environmental Protection requires the study of the combined functions of several environmental systems in order to preserve the environment.- The ideas set out in point "A" have been in place at European Union level and in the Member States for many years.These tasks have already been regulated at European Union level.
Unfortunately, we now have to draw attention to the misinterpretation and therefore misapplication of the Impact Assessment, which has been repeatedly cited in this way. Look: In the Environmental Protection should be used, performed the Impact Assessment. The Impact Assessment is a mandatory task.Hence the professional title: Environmental Impact Assessment.The draft legislations does not require an Impact Assessment. In addition: Professional documents prepared during Environmental Impact Assessments are Environmental Impact Studies.
Environmental Impact Studies contain the information needed to protect the Environment and make decisions.
Look: The Planning Documents for the Promotion of Forest Protection Measures: - Commission, COM (2006) 302 (Forest Action Plan); - COM (2008) 645 (forests and climate change); - COM (2010) 66 (Green Paper on forest protection). This is important!
I have already sent these Planning Documents to the European Commission on 02 February 2020 for the revision of the FLEGT Regulation.
The revision of the FLEGT Regulation has been initiated by the European Commission.
Look also: - Council Regulation No 3528/86 [1986] OJ L 326/2. side. - Commission, Second Report on Biodiversity; Thematic on forests and biodiversity report (Luxembourg, 2003), 2.6. point. Attention is drawn to the existence and application of engineering expertise also necessary and indispensable for the Land use concept. The Land use concept has been based on completely new professional foundations and professional definitions since the year 2000. Also for this requires engineering expertis.
Read full responseResponse to Guidance on distributional impact assessments
5 Apr 2022
Dear European Commission, Dear DG, Dear Ladies and Gentlemen,
We have thanked you for sending this Call for Opinions to our Association.
After reading the Call for Opinions we provide the following brief professional feedback to the European Commission, to Ms Ursula von der Leyen President of the Commssion, to the named Directorates-General as the Directorate-General concerned.
TITLE OF THE INITIATIVE Poverty and Inequality - Guidelines for examining the effects of distribution.
EXPECTED TYPE OF INITIATIVE Commission Communication.
Information and feedback for point "A":
Look: The last sentence of the second paragraph of this "A" point:
"The EU aims to lift at least 15 million people out of poverty or social exclusion by 2030."
This goal is not solved by the distributional impact assessment.
Important information and it is important to know:
Professional applications for Poverty and Inequality examining do not start with a distributional impact assessment.
No such indicator exists.
Example of correct application method include: Poverty reduction can be realized through the growth or distribution component.
However, professional applications for poverty reduction are always and in all cases preceded by the performance of poverty assessment tasks.
In the case of the example above: Accountability improves the growth and distribution factor.
Eleven accountability indicators I sent in writing to the European Commission and Ms Ursula von der Leyen on 9 March 2022 in English and Hungarian.
The title of the European Commission document was as follows: CALL FOR EVIDENCE FOR AN INITIATIVE (without an impact assessment) whose address is: Recommendation on minimum income.
Look: In order to tackle poverty and inequality, for the purpose of resolving it we recommend the European Union's Cohesion Policy for study.
Information and feedback for point "B":
An important and first step in formulating and addressing poverty reduction as a goal is to determine by standard and dimension of poverty.
S z e g e d, April 05, 2022
Best regards,
Anikó Márta Szűcsné Putics
a Certificated Labor Specialist,
a Landscape Management Engineer Environmental Management Speciality,
an Environmentalist Specialised in Law,
Professional leader of the Association
Read full responseResponse to Sustainable Products Initiative
4 Apr 2022
Dear European Commission, Dear DGs, Dear Ladies/Gentlemen,
After reading this Initiative as the Commission's work program, our Association will provide the following professional information to Ms Ursula von der Leyen, President of the European Commission, to Mr Frans Timmermans EVP., to the named Directorates-Generals.
TITLE OF THE INITIATIVE Sustainable Products Initiative.
LIKELY TYPE OF INITIATIVE Legislative proposal.
The most important condition for the useful ideas in the “A” point of the initiative as possible tasks is the application of engineering expertise.
Therefore, the following should be taken into account in the initiative:
- The useful ideas set out in this initiative will not be taken as a possible task by the Legislative Proposal.
Rather, it is the application of engineering expertise required for useful implementation.
- The primary condition for creating a circular economy is the engineering expertise required and the application of this.
- Therefore, this engineering expertise provides the first and thus essential condition for a circular economy.
In the absence of engineering expertise, how could a professional and correct professional plan be written?
Look: the following sentence quoted from this initiative: “The March 2020 Circular Economy Action Plan (CEAP) provides a future-oriented
agenda…”
We know that this initiative is the Commission's work program.
But we need to point out that the instrument written in this initiative, as an 'EU policy framework', is not the right instrument.
Look: the sentence quoted below as the definition of the goal.
„The initiative will aim to set out the EU policy framework necessary to achieve this objective. For this, the scope of the Ecodesign Directive
needs to be widened beyond energy related products, and made applicable to the broadest possible range of products.”
Because in order to achieve the ideas described in point “A” as a goal, especially for the circular economy, the professional conditions determined primarily by the available engineering work must be present.
The engineering expertise required for these ideas, and especially for the circular economy, is held by the engineer involved already.
- Unfortunately, it is also necessary to point out that, in referring to sustainability as an implementation in the present initiative, engineering
expertise is also necessary and indispensable.
Which engineering expertise is also in the possession of the professional engineer dealing with it.
For point "B":
Sorry, it is incorrect to define the following and quoted goal: „ …on the EU market, achieving longer product lifetimes for example through more durable and reparable products, increasing circular material use rate, reducing waste and achieving higher recycling rates.”
Our Association has written to the European Commission and the Directorates-General so many times that the circular economy is not about recycling waste.
The circular economy is not about waste management!
Summary:
The ideas set out in this initiative are addressed in the science of environmental protection.
Therefore, possible modification of ideas is only possible with the application of this science.
The science of environmental protection is used by engineers who have learned and apply that science.
Without the Environmental knowledge and application of engineering, it is still not possible to change the ideas set out in this initiative at European Union level and especially at Global level.
The Engineers in our Association have the appropriate Environmental Engineering expertise, knowladge.
Read full responseResponse to Recommendation on minimum income
9 Mar 2022
Dear European Commission, Dear DG, Dear Lady/Sir,
After reading CALL FOR EVIDENCE FOR AN INITIATIVE (without an impact assessment) whose address is: Recommendation on minimum income.
The fight against poverty and social exclusion also requires data from the following Indicators from the 27 Member States.
But these Indicators are also needed to measure Sustainable Development.
I would therefore ask DG to inform the President of the European Commission, Ms Ursula von der Leyer, and Mr Frans Timmermans, EVP that our Association has sent the names of the required Indicators for the above purposes in English and in Hungarian.
A total of fourteen Indicator data are required from the 27 Member States.
Action by the European Union is need.
Because the 27 Member States are required to provide data since the year 2000 for the Indicators sent below, these datas they need communicated to the European Commission and to the designated DG.
The 27 Member States last sent data on the following Indicators to the European Commission and the designated DG in 2008.
Therefore, the Base year is 2008.
Thus, the Subject year is 2016. (Because 2000. year + 8 years = 2008. year + 8 years = 2016. year.)
The necessary calculations will have to be made from the data of these Indicators.
We are currently sending the names of eleven Indicators.
In the order of the Indicators:
- GDP per capita, PPs, EU-27 = 100
- Productivity per employee, EU-27 = 100.0
- Proportion of young people with at least a secondary education a 20-24 years old,%
- Ratio of R&D expenditure to GDP,%
- Relative price level, EU-27 = 100.0
- Investment in the corporate sector as a percentage of GDP
- Employment rate of 15-64 year olds,%
- Employment rate of 55-64 year olds,%
- Poverty rate,%
- Proportion of long-term unemployed in the active population,%
- Relative standard deviation of regional employment rate,%
In Hungarian
- Egy főre jutó GDP, PPs, EU-27 = 100
- Egy foglalkoztatottra jutó termelékenység, EU-27 = 100,0
- A legalább középfokú végzettséggel rendelkező fiatalok aránya a 20-24 évesekből, %
- K + F ráfordítások aránya a GDP-ből, %
- Relatív árszínvonal, EU-27 = 100,0
- Vállalati szektor beruházásai a GDP százalékában
- 15-64 évesek foglalkoztatási rátája, %
- 55-64 évesek foglalkoztatási rátája, %
- Szegénységi arány, %
- Tartósan munkanélküliek aránya az aktív népességben, %
- Regionális foglalkoztatási ráta relatív szórása, %
To the Senior Corporate Silver Spoon, Environment & Nature Association nor for its professionals, no monetary consideration was paid for this professional material.
The Senior Corporate Silver Spoon, Environment & Nature Association reserves all rights as the holder of the intellectual capital.
The Senior Corporate Silver Spoon, Environment & Nature Association reserves all rights as the owner of the intellectual property rights.
Please do not try to infringe these rights: as the holder of the intellectual capital and as intellectual property rights regarding.
Best regards,
Anikó Márta Szűcsné Putics
a Graduate Labour Specialist,
a Landscape Engineer - Specialization in Environmental Management,
a Legal Proffession Graduate Environmentalist
as a Professional Leader
Read full responseResponse to Protection of workers from risks related to exposure to asbestos at work
6 Mar 2022
Dear European Commisssion, Dear Lady/Sir, Asbestos 06032022
After reading this Call for Opinions, please provide the professional opinions of our Association below:
For the Call for Opinions on "Health and Safety at Work - Protecting Workers from Exposure to Asbestos ", our Association’s Environmental Engineers and Environmental Jurists recommend that you consider and study the following professional statements.
Specialization: Environmental protection - pollution.
The Call for Opinions on 'Health and safety at Work - Protecting Workers from Exposure to Asbestos' deals with two completely different environmental tasks.
One of the environmental tasks for Asbestos and the area of pollution is:
1. Demolition of facilities.
Legal basis: - Directive 87/217 on the prevention and reduction of pollution caused by asbestos [1987] OJ L 85/40, page.,
Article 7 of Directive 87/217 applies.,
- Article 13 of Directive 2008/98.
The general provisions of this Article shall also apply to the demolition of facilities, for other contaminants.
2. Products - Carcinogenic substances such as asbestos fibers.
Legal basis: - Directive 1999/77 [1999] OJ L 207/18. p.;
- Directive 76/769;
- Directive 87/217 on pollution caused by asbestos on the prevention and reduction of pollution [1987] OJ L 85/40. p..
This directive sought to establish integrated provisions for asbestos products that are already, yet in the environment.
- Directive 2001/95 on general product safety [2002] OJ L 1/4. p..
This General Product Safety Directive refers to "the safety and health of persons".
EU law should apply to the protection of workers at work, including the protection of the environment and the protection of health and safety.
Because references to "health" include environmental considerations.
Based on the Asbestos Legal Basis presented and referred to above, the legal basis referred to in this Call for Proposals under the heading Legal Basis is unfortunately incorrect.
"The primary legal basis for the policy on the health and safety of workers is Article 153 of the Treaty on the Functioning of the European Union (TFEU)." [.......]
Because this Article 153 under TITLE X. of the Treaty on the Functioning of the European Union is Social Policy.
The correct legal basis is the TFEU. Article 114 (3).
Because based on this Article 114, the use of a large number of asbestos fibers that have been classified as carcinogenic has been restricted.
For the Directive referred to we also recommend taking into account:
DIRECTIVE 2009/148/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 30 November 2009
On the protection of workers from the risks related to exposure to asbestos at work
Article 3 (1) paragraph
In this paragraph: "during which workers in the course of their work" interpretations and meanings of terms.
Thank you very much,
Best regards,
Anikó Márta
Read full responseResponse to Proposal for a Council Recommendation on long-term care
2 Mar 2022
Dear European Commission, Dear Lady/Sir,
This morning, through this secure channel, I sent a message on behalf of the Association to President Ms Ursula von der Leyer and Mr Frans Timmermans EVP.
The subject of my message was: Sustainable Development.
At our Association we ended the daily Engineering professional meeting a few minutes ago.
In this meeting, I reported on the email I sent this morning.
On this basis, we would like to draw the attention of the President of the European Commission and the Executive Vice-President, the following are: Sustainable Development also requires Russia and its neighbors States.
Our suggestion: If President Emmanuel Macron talks to President Vladimir Putin about the terms of peace, please ask Mr Vladimir Putin whether he would be involved in Sustainable Development with other countries on the continents.
Goal: For a habitable planet Earth.
Important: Russia and its President should be involved in world affairs.
Such a peaceful task: Protecting the environment.
Within the protection of the environment, Sustainable Development.
This joint task could be proposed to President Vladimir Putin.
Because the problem may be that President Vladimir Putin may feel excluded from world affairs.
Without world peace and reconciliation, there can be no Sustainable Development.
Thank you very much,
Anikó Márta Szűcsné Putics
a Landscape Engineer - Specialization in Environmental Management,
a Legal Profession Graduate Environmentalist,
a Graduate Labour Specialist
as a Proffesional Leader
Read full responseResponse to Soil Health Law – protecting, sustainably managing and restoring EU soils
20 Feb 2022
Dear European Commission, Lady/Sir,
On behalf of the Senior Corporate Silver Spoon, Environment & Nature Association [TR ID: 30399232694-16], we bought it with thanks your Call for Opinions on SOIL HEALTH - Protection, Restoration and Sustainable Soil Management in the Union.
As a legislative initiative, we provide our professional opinion below on the tasks set out in the title of this Call for Opinions.
Title of the initiative: SOIL HEALTH - Protection, Restoration and Sustainable Soil Management in the Union.
Our professional responses to the Call for Opinions are as follows:
From Association’s Specialist Engineers:
Objectives in the title with specific sectors action programs.
Therefore, for the necessary professional actions, Specialization Engineerings knowledge, actions are needed.
- For the likely effects described under "C":
Accuracy is required to clarify professional tasks Engineering knowledge and application be need.
Therefore, our Engineers gives attention is drawn to the following information:
All European Commission's proposals must be examined for regarding their environmental impact.
But this is exactly the environment protection professional activity means that: A detailed environmental impact assessment need make.
Environmental impact assessment is as an environmental field.
Thus, it is a complex engineering field.
However, it is not just the environmental impact assessment that need make.
From Association’s Environmental Lawyers:
- In addition to the legal basis indicated in point 'A' and thus the legal bases in order to clarify it, we also recommend taking into account and
studying:
- the TFEU. Article 11;
- the TFEU. Articles 191 to 193 and paragraphs;
- the TFEU. Article 141 (4) to (8);
- the TFEU. Article 294.
- For "D" as "Quality Legislative Instruments"
"Impact assessment"
Impact assessment is not a legal category, but an environmental engineering task.
These are Association's briefly professional opinions to the Call for Opinions on SOIL HEALTH - Protecting, Restoring and Sustainable Soil Management in the Union as a legislative initiative.
The above Engineers opinions are based on the professional activities of the Environmental Protection Engineers, Environmental Management Engineers, Landscape Management Engineers and Environmental Protection Lawyers applicable today.
The Association shall be available to parties requesting the performance of professional duties.
Of course, for a fee to be paid to the Association for its professional activities.
In the framework of professional cooperation and funding.
Kindest regards,
Anikó Márta Szűcsné Putics
a Landscape Engineer - Specialization in Environmental Management,
a Legal Profession Graduate Environmentalist,
a Graduate Labour Specialist
as a Professional Leader
Read full responseResponse to Carbon Removal Certification
9 Feb 2022
Dear European Commission, Dear Lady/Sir,
On behalf of the Senior Corporate Silver Spoon, Environment & Nature Association [TR ID: 30399232694-16], we bought it with thanks your call for opinions on “Certification of carbon dioxide capture - EU rules”.
After reading this document, the text of which sets out the goal of "extending sustainable carbon dioxide sequestration", we provide the following and a brief summary of the expertise of our Association’s Environmental Professionals - Environmental Management Engineers:
Specialization: Environmental Protection - Climate Change
To point "A", "Problem to be addressed by the initiative".
- Our comment: It is an inappropriate and therefore incorrect goal and only to seek to 'remove' carbon dioxide.
Because in Environmental Science the right and therefore the right goal and task definition is:
Stabilizing atmospheric concentrations of greenhouse gases!
- Our comment: Environmental protection science is an environmental activity such as there is no “Industrial carbon dioxide removal” it does not
exist.
Environmental key concepts: - Atmospheric concentration of GHGs;
- The correct concept is CO2 concentration.
In summary:
- The stabilization of atmospheric concentrations of greenhouse gases and the achievement of this goal
are ensured by the environmental protection point of view operations of the respective industrial and
service sectors.
- The correct goal for CO2 management is to keep the CO2 concentration in the atmosphere.
- Environmental science can already handle these tasks.
To point “B” we recommend to consider and study:
- The Fourth Environmental Action Program;
- The Fifth Environmental Action Program;
- The Sixth Environmental Action Program.
- Directive 2009/31 on the geological storage of carbon dioxide [2009] OJ L 140./114. p.
Our Association for the work plan "Certification of carbon dioxide capture - EU rules" the above opinion was given on the basis of the professional activities of the Environmental - Environmental Management Engineers applicable today.
Engineers needed to promote action on climate change with reference to professional activities as a professional condition.
The Association shall be available for its tasks to all parties in need of professional cooperation and funding.
S z e g e d, 09, February 2022
Kindest regards,
Anikó Márta Szűcsné Putics
as a Professional Leader
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
27 Jan 2022
Hulladékgazdálkodás 27012022
Tisztelt Európai Bizottság, Tisztelt Környezetvédelmi Főigazgatóság B3, Tisztelt Hölgy/Úr,
A Senior Corporate Silver Spoon, Environment & Nature Association [TR ID: 30399232694-16]
nevében köszönettel vettük a Véleményezési Felhívásukat a Hulladékgazdálkodásra vonatkozóan.
A Dokumentum olvasása után az alábbiakban és röviden adjuk meg Szervezetünk Környezetvédelmi
szakembereinek - Környezetgazdálkodás mérnökeinek szakvéleményeit:
- a Dokumentum „A” pontjához a szakvélemény:
A hulladékgazdálkodás rendszer szintű környezetvédelmi - Környezetgazdálkodás tevékenység.
A hulladékgazdálkodás a többi környezetvédelmi tevékenységgel együtt bonyolultan összetett
- komplex - környezetvédelmi módszereket alkot.
Ezek a komplex környezetvédelmi módszerek egymással nem cserélhetők fel.
Ez a fel nem cserélhetőség vonatkozik a hulladékkezelésre is, amely tevékenységet a Hulladék-
piramis - hulladékhierarchia - határoz meg.
A Hulladék - piramis csúcsán helyezkedik el a Megelőzés; ez a szint alatt helyezkedik el
a Minimalizálás; ez a szint alatt helyezkedik el az Újra használat pl.: üveg; ez a szint alatt
helyezkedik el az Anyagában történő újrahasznosítás; ez a szint alatt helyezkedik el az
Energetikai hasznosítás; ez a szint alatt helyezkedik el a Lerakás.
Igen, tudomásunk van arról, hogy az EU-nak a hulladék megelőzés az egyik célja.
Amely célt - hulladék megelőzés - most is próbálna megvalósítani.
De csak a hulladék megelőzést nem lehet előírni.
A hulladékgazdálkodásban érvényesülnie kell a Hulladék-piramis többi szintjét alkotó hulladék-
kezelési területeknek is. Mert a hulladék erőforrást is biztosít.
Lásd: az „agyag- és az energia megmaradás törvénye. English: law of conversation of energy.
Mert: a hulladékgazdálkodás lényeges szempontja a hulladékokkal való zárt körforgalmú
anyaggazdálkodás.
A hulladékgazdálkodás komplex mérnöki tudást, tevékenységet, összefüggést alkalmazó környezetvédelmi
tevékenység.
A hulladékgazdálkodás végzését a fizika, a kémia, a biológia, a földrajz tudományok törvényeinek
alkalmazásai határozzák meg.
Sajnos a természettudomány törvényeit nem lehet adminisztratív módon felülírni.
Amit a hulladékgazdálkodás területén szakmailag csinálni lehet, azt az ezzel foglalkozó mérnökök
már tudják végezni.
A körforgásos gazdaság nem a hulladékkezelést jelenti.
A körforgásos gazdaság nem a hulladékmennyiség csökkentést jelenti.
A jogalaphoz figyelembe ajánljuk:
A 6. környezeti cselekvési program tanulmányozását.
Az EUMSz. 294. cikk tanulmányozását - az EUMSz. 192. cikk (3) bekezdésének vonatkozásában -.
Szervezetünk a Hulladékgazdálkodás környezetre gyakorolt hatása - az uniós hulladékgazdálkodás keret felülvizsgálata elnevezésű Vélemény Felhívásra a fenti véleményt a napjaikban alkalmazható mérnök szakmai tevékenységek alapján adta meg.
A hulladékgazdálkodás végzéséhez és a jobb végrehajtás előmozdításához szükséges mérnök szakmai tevékenységre történő hivatkozással, mint szakmai feltétellel.
A Szervezet a feladatokhoz rendelkezésre áll minden azt igénylő fél részére,
a szakmai együttműködés és finanszírozás keretében.
S z e g e d, 27, January 2022
Üdvözlettel,
Anikó Márta Szűcsné Putics
a Landscape Engineer - Specialization in Environmental Management,
a Legal Profession Graduate Environmentalist,
a Graduate Labour Specialist,
as a Professional Leader
Read full responseResponse to Amendment of the EU rules on victims’ rights
14 Dec 2021
Please, Look attached file for that opinion.
The professional informative document as opinion is two pages.
Read full responseResponse to Guidance on REDII forest biomass sustainability criteria
7 Apr 2021
Dear European Commission, Dear Ladies and Gentlemen,
The Renewable Energy Directive – guidance on the sustainability criteria for forest biomass used in energy production and the provisions of Article 29 of the Directive are briefly recommended.
- Applied field: Environment, Agriculture, Forestry, Energy.
Because the greatest opportunities in renewable energy utilization are agricultural by-
products - straw, stalks, trimmings, forestry by-products, forest wood waste, other waste, -
woody and herbaceous energy plantations, herbaceous energy crops, organic waste
utilization, motor drive bio-fuel material.
- Biomass: Energy biomass carriers are a collective term for the most diverse energy carriers.
This includes all plant and animal energy sources, from the utilization of wood, straw and
manure through rapeseed oil to methane production (biogas).
- Concept name and use:
Professional title: Energy biomass carriers.
Applications: - Biomass as a solid energy carrier, for thermal energy production, etc ..
Because biomass as a renewable energy and its types: solid, gaseous, bio-fuel materials.
Important!
REGULATIONS
COMMISSION REGULATION (EU) No 1407/2013 of 18 December 2013 on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de minimis aid (Text with EEA relevance).
Look: OJ L 352, 24.12.2013, p. 1-8.
Kindest regards,
Anikó Márta Szűcsné Putics
Read full responseResponse to Industrial pollution - revision of the European Pollutant Release and Transfer Register
29 Sept 2020
Dear European Commission, Dear Lady/Sir,
We have read the text of the Initiative and we draw your attention to the following.
It is expedient to take into account the existing Global and European environmental protection rules and regulations. To take into account their logic.
The area of expertise of this Initiative is environmental protection and within that pollutant.
Regulation EC 166/2006, indicated in this Initiative, concerns the creation of European Pollutant Release and Transfer Register.
Therefore, and in this case, we can talk about the Horizontal Instrument for Industrial installations as one of the Horizontal Instruments.
Therefore, the subject of this Initiative is the Register, as it is covered by the indicated Regulation EC 166/2006 - as pollutants -.
We also draw attention to the fact that pollution and pollutants are two different environmental concepts with many - many included and different - spheres of activity.
For the task of "revising the EU rules on addressing pollution from large industrial installations" in the Initiative, we recommend studying the following.
See: - Directive 2010/75 on industrial emissions (integrated pollution prevention and reduction) [2010] OJ L 334/17. p.,
- 1600/2002 Decision on the Sixth Environmental Action Program,
- The Fourth Environmental Action Program [1987] OJ C 328/1. p., its 3.4. point,
- The First Environmental Action Program on the environment [1973] OJ C 112/1. p., and 20. p.,
See also and you need to study the environmental protection rules and regulations for IPPC.
See also and you need to study the environmental protection rules and regulations for - IPP.
See also and you need to study the environmental protection rules and regulations for Industrial installations.
Read full responseResponse to Action Plan on synergies and cross-fertilisation between the civil, defence and space industries
27 Sept 2020
Dear European Commission, Dear Lady/Sir,
The Association thanks the Roadmap sent.
The subject of the Initiative is becoming more and more relevant nowadays.
After read the Roadmap Association’s proposal in relation to point B of this initiative is set out below.
New opportunities, new actors, new technologies for the future of the European Union and the 21st century to the world economy.
In modern society, in the modern economy and in international relations, in addition to the tools and methods of geopolitics, the method of geo-economics has also appeared in the world economy.
The existence and application of geo-economics in the XXI. century is already indispensable in the world economy.
But different methods of geopolitics and geo-economics can also complement each other.
Both geo-economics and geopolitics are analytical approaches.
The essential difference between the two methods is that geopolitics operates on the basis of control over the area.
Actors: - States,
- Groups of states,
- NGOs,
Geo-economics operates on the basis of the existence of emerging markets and the possession of available technologies.
Actors: - Various multinational companies,
- NGOs,
- States, Governments,
- activities of state bureaucracy,
- International Institutions,
Economic tools of geo-economy and emerging new players in the world economy:
- available capital,
- civil innovation,
- technological developments,
- the existence of a receiving market, the existence of a solvent consumer,
- the settlement of powers in global market processes, international and regional aspects,
- environmental protection, security technology, taxation, competition, etc.,
- an economy based on geographical proximity integration,
The main issue of geo-economics is defined by various multinational companies.
Because in the possibility of geo-economy, multinational companies are already interested in where marketplaces lie.
Geo - economics aims at geographical and market boundaries in order to:
- maintaining global peace and security - economic by means,
- cooperation in international relations - economic by means,
- cooperation in economic relations - economic by means,
- ensure a high level of employment for the local population,
- poverty reduction,
- reduction of risks to free trade,
In all cases, co - operation in a win - win environment, in line with each other 's logic, is a prerequisite for achieving these goals.
Read full responseResponse to Sustainable Products Initiative
17 Sept 2020
Dear European Commission, Dear Lady/Sir,
INCEPTION IMPACT ASSESSMENT
After read the Inception Impact Assessment, we will briefly explain our environmental management engineer proposal below.
In order to create Sustainable Products, the first step in changing the product structure is to create an environmentally friendly production method.
The development of an environmentally friendly production method is understood for all input - output systems.
For Article 192 (1) TFEU (environment) to be truly effective, one of the best ways to do so is to develop and implement Community Energy, to be developed and implemented by the European Union.
Community Energy = as a system of energy sources.
Because all products require the existing raw material and energy to produce.
Because the production of all products requires the energy to be used in addition to the existing raw material.
- The basis of the circular economy is also the existing and using the input material and the output material.
- All environmental legislation for products is already covered by European Union Environmental Law.
Future amendments to this environmental legislation could only take place - for the environment and all its branches - if we succeed in gradually introducing and switching to the use of Community Energy in the European Union.
Because, once again, we emphasize that one of the most important input materials is the availability of usable energy.
In the case of the production of products, it is necessary and essential - as for the commencement of all environmental protection actions - to carry out the engineering activities relevant to the given case.
Look: Environmental - Planning.
After all, in the case of all natural environments, built environments and their possible changes, the available renewable energy sources must be assessed and determined.
Then the possibilities of their utilization, application, etc ..
We are still talking about the use of renewable energy sources because they can only achieve the ‘European Green Deal’ goal.
Read full responseResponse to EU rules on transboundary waste shipments – update concerning plastic wastes
4 Jul 2020
Continued in this Part 2
The problems with hazardous waste are as follows:
- The EU definition of hazardous waste should be clarified.
Because the main problem is that Member States use different terms for hazardous waste in their national law.
For example: "special waste", "chemical waste", "specially controlled waste",
"Non-degradable waste", etc.
This is a problem because these different definitions allow for the establishment of national waste lists other than the EU list.
- The situation with regard to hazardous waste is further complicated by the fact that both the Basel Convention on the Transport of Hazardous Waste and the OECD have drawn up lists of hazardous waste.
However, these lists of hazardous wastes differ from the EU list.
This created a legal situation that creates inconsistencies, not clarity, inaccuracies, illegal practices.
With regard to the export of hazardous waste, all exports for disposal are prohibited.
Except EFTA countries. Officially called the European Free Trade Association.
European Free Trade Association stands for EFTA.
Which are also signatories to the Basel Convention.
The European Union has already taken steps to ban all shipments to third countries for recycling from 1 January 1998.
This measure followed a decision under the Basel Convention to ban shipments of waste to non-industrialized third countries for recycling.
Except for industrialized countries.
The exemption was formally granted to countries which apply the OECD Decision of 30 March 1993 on shipments of waste for recycling.
Look also: - Regulation No 120/97, as amended by Regulation No 2408/98 [1998] OJ L
298/19. p.
- Decision 97/640 on accession to the decision taken under the Basel Convention
[1997] OJ L 272/45. p.
We also recommend the Protocol to the Basel Convention on Shipments of Hazardous Wastes.
Read full responseResponse to Strengthening of Europol’s mandate
18 May 2020
Part Two
The courts have completely disregarded the legislation on enforcement proceedings, the procedure that falls within the scope of enforcement, in the course of their work and without regard to me.
Krisztián Papp, Independent Bailiff, has continuously and seriously violated the legislation on enforcement proceedings.
The Bailiff has completely disregarded my information in writing that I could not evict the Mansion before proceeding.
In order to protect my property rights to my real estate, the title of the acquisition of property, and the acquisition of the right of ownership, the Land Registry Department of the Legal and Authority Department of the Hungarian State Csongrád County Government (6724 Szeged, Kálvária sgt. 41- 43.) as II. There has been a continuous and serious breach of the law on the cancellation and registration of rights in the public real estate register.
In the course of its work and without regard to me, the Authority completely disregarded the constitutional provisions on the protection of property rights, title to the acquisition of property, acquisition of property rights and fundamental rights, and the law on the cancellation and registration of rights in the public real estate register.
In order to enforce the legislation on the protection of my property rights, the title to the acquisition of property, the acquisition of property rights, and the enforcement of my human rights and fundamental rights, on March 20, 2020, at 7:20 am, I sent to Dr. Péter Polt the Attorney General of Hungary the following:
My formal request “Submission of a Request for Review for the Purpose and Purpose of a Review Initiative with the Prosecutor General’s Office”.
As an attachment, I have attached five official supporting documents.
Thus, I sent a total of six official documents to Dr. Péter Polt.
I sent these official documents to the publicly provided e-mail address of the Attorney General's Office.
E-mail address: info@mku.hu
In my Prosecutor's Review Request, submitted on March 20, 2020, I also requested the action of the Attorney General's Office to annul the administrative authority's decision in violation of the law, referring to the following law.
Founded: 2016 CL. Act General Administrative Procedure Entered into force on 1 January 2018.
65. Prosecution call and action
122. § [Prosecution call and action]
If the prosecutor makes a call under the Prosecution Act or acts in the event of an unsuccessful call, the authority the decision challenged by the prosecutor without restriction
it may be amended (changed) or revoked (annulled) even if the legislation on administrative authority procedure otherwise restricts or does not allow it.
On 20 March 2020, I also sent you a letter of formal notice on the background presented above.
I am sending you this official notification also for the fact that I received the Information Letter sent to me from the General Prosecutor's Office of Hungary as a document on Tuesday, May 12, 2020.
The information letter was sent by registered mail.
So not a return letter as a shipment.
Which means my return receipt with my signature didn’t go back to the Attorney General’s Office.
The information letter is the General Prosecutor's Office of Hungary Department of Public Interest.
It was sent to me on a letterhead addressed and named by the Department of Administrative, Child Protection and Environmental Affairs.
File number or registration number: T. KvFK. 2752/2020/2-I.
Date of issue of the information letter: Budapest, 29 April 2020
The text content of the letter document is two pages on an A/4 sheet.
In the fourth paragraph of the second page, I received the following information from the Public Prosecution Department of the General Prosecutor's Office of Hungary.
'The enforcement measure of 12 October 2018 and other proceedings falling within the scope of enforcement, as well as the claim for damages, which are not mentioned above in his application for review, are being prosecuted
Read full responseResponse to 2030 Climate Target Plan
6 Apr 2020
Dear European Commission, Dear Lady/Sir,
To: Frans Timmermans Executive Vice-President
Subject: Environmental protection - environmental health science - Protection of public
health - European Union environmental law.
Topic: Notification
We kindly ask the person receiving this electronic document to send our message below to Frans Timmermans Executive Vice-President.
Below we provide information on the prevention and action of additional environmental health, environmental - economic, economic losses and damage caused by the Covid-19 pandemic or only Covid-19 virus at the European Union level.
Definition of environmental health science:
Area of one special part: human protection.
It deals with the impact of the environment on human health, the issues of health limit values for pollutants.
Definition of virus: smaller than a bacterium,
for reproduction and independent metabolism only live cell-capable pathogen.
Therefore, keeping a distance between people between one and two meters plays an important role.
In addition to humans, animals are also at risk.
Not to mention the plants. Because the plant cell has inanimate parts.
We would also like to draw your attention to:
- The European Parliament and the Council on the Third Program for Health Growth.
Period: 01 January 2014 to 31 December 2020
Look: Directive 5.2011/24/EU of the European Parliament and of the Council of 9 March 2011.
2.3. paragraphs
Protection of public health
- Cross-border health threats, such as pandemic influenza or SARS, etc.
- National capacity building, preparedness.
Look also below:
Human health - protection measures
- the TFEU. Article 36 "people health"
- the TFEU. Article 191 (1), "human health",
- the TFEU. Article 169 on "human health",
- the TFEU. Article 168 on "public health"
the differences between the articles of the TFEU indicated above are precise legal their application may require settlement.
Due to legal precision for their use.
- the TFEU. Article 114 (4) to (8)
I kindly ask the European Commission to keep the information confidential.
Because the information is in vain well-meaning if the Member State concerned is likely to
endanger the protection of privacy and the integrity of the person concerned.
Rights protected in the Charter of Fundamental Rights of the European Union as rights.
Sincerely,
Read full responseResponse to New Strategy for the Implementation of the Charter of Fundamental Rights
23 Mar 2020
Dear European Commission, Dear Lady/Sir,
After reading the New Strategy for Implementation of the Charter of Fundamental Rights roadmap, below are our suggestions for a more extensive use of the Charter.
The Charter of Fundamental Rights of the European Union entered into force on 1 December 2009 as a legal act at contractual level.
This makes the application of the Charter of Fundamental Rights of the European Union mandatory.
Knowledge of the Charter is a prerequisite for compulsory application.
The main function of the Charter of Fundamental Rights of the European Union is:
- an effective legal protection system; - an instrument for the enforcement of interests.
The Charter of Fundamental Rights, as the control of fundamental rights, covers EU law, international law and the constitutions of the Member States.
International agreements to which the European Union or all the Member States are party, in particular the European Convention for the Protection of Human Rights and Fundamental Freedoms.
For the wider application of the Charter of Fundamental Rights of the European Union, we recommend the following:
- Article 51 (1) of the Charter.
- Rules and boundaries for the application of EU law in the Member States,
Whether EU law is enforced by Member States?
- EU procedural rules not yet harmonized clarification of Member States' procedural rules, and for,
Whether EU law is enforced by Member States?
- Non-harmonized EU law and substantive rules in the Member States the scope and applicability of the Charter of Fundamental Rights,
Whether EU law is enforced by Member States?
- Decisions of the Court of Justice of the European Union the scope and applicability of the Charter of Fundamental Rights.
Whether EU law is enforced by Member States?
Is there a legal standard for EU law?
Look: One of the principles of the Court of Justice of the European Union is “a sufficiently close relationship”. As a test application.
For example: in the area of rules of criminal procedure, tax law, administrative law,
compensation for damages, etc..
Read full responseResponse to Access to Justice in Environmental matters
11 Mar 2020
Dear European Commission, Dear Lady/Sir,
Thank you for submitting your Access to Justice in Environmental Matters Roadmap.
After reading and thinking about what else to pay attention to in section A, " Problem the initiative aims to tackle”
For the further application of the Aarhus Convention.
Look: Second paragraph, "It will therefore be relevant to clarify that a reviewable act in itself…".
The basic aim is for interested parties to have access to the courts of the Member States:
Enforcement of European law on access to justice.
In order to further the enforcement of this European law, there would be a need for European Union legislation which guarantees this right to those seeking legal redress.
In this case, EU legislation would be needed to remove one of the obstacles to access to justice.
Therefore, in this proposal we would like to draw attention to the Searchable right.
Because the rules on the Searchable right also represent procedural obstacles to access to justice.
In these cases, the rules governing the admission of court cases and court proceedings would be clearly defined by the European Union Searchable right.
Further, procedural barriers to access to justice are the high and hitherto unpublished fees for court proceedings in the Member States.
As well as the amount of the Member State fee for the subject matter of the court proceedings in the Member States, calculated and paid as a percentage.
All rights reserved. Including the text of this Roadmap as an initiative.
Read full responseResponse to EU Strategy on victims' rights (2020-2024)
10 Mar 2020
Continued in Part Two:
This obligation, read in conjunction with other articles such as Articles 2 (right to life) and 3 (prohibition of torture and inhuman and degrading treatment), requires States to take positive action to ensure that the rights of individuals are not violated be violated by state representatives.
The Charter of Fundamental Rights of the European Union covers all rights derived from Union law in the application of Union law and empowers individuals to effectively assert those rights before the courts.
Application of environmental law in Member States and States Parties.
- Empowering victims of crime to prioritize.
- Victims' rights as a priority.
The field of environmental law includes civil law, social and economic rights, political rights.
The right to a healthy environment is a collective right because a healthy environment affects communities - both now and in the future.
The ECHR does not guarantee the right to a healthy environment, but rights guaranteed by the ECHR, such as the right to respect for private and family life, can be incorporated into environmental matters.
However, the ECoHR does not provide for actio - popularis (public interest litigation).
In environmental matters, only those specifically concerned have the right to participate in decision-making.
No actio - popularis for the protection of the environment is envisaged - a legal procedure for the protection or enforcement of the environmental right enjoyed by the public (litigation in the public interest).
Important! We recommend the Environmental Democracy Index (EDI) a for the application of environmental rules.
All rights reserved. Including this roadmap as communication and as an initiative the text content.
Read full responseResponse to Wildlife trafficking - EU action plan (evaluation)
25 Feb 2020
Dear European Commission, Dear Lady/Sir,
After reading the Wildlife trade - EU action plan (evaluation), we will provide information below on this Roadmap.
Next to the following: - Commission Regulation (EU) 2019/2117 of 29 November 2019 amending Council Regulation (EC) No 338/97 on the protection of species of wild fauna and flora by regulating trade therein.
- Commission Regulation (EU) 2019/220 amending Regulation (EC) No 865/2006 laying down detailed rules concerning the implementation of Council Regulation (EC) no 338/97 on the protection of species of wild fauna and flora by regulating trade therein.
Protection of endangered species.
- Animal and plant species
Wildlife is part of the natural environment.
Therefore, measures to protect wildlife - endangered species, non-endangered species - as living beings are environmental measures.
We recommend the following: Member States had to send the Commission reports on national derogations every two years.
See: - Article 9 of Directive 2009/147.
- Eighth report from the Commission on the application of Community law
(1991) OJ C 338/1. p. 220, p.
- Birds
Directive 2009/147 protects not only endangered birds but also all wild birds within the EU.
The directive provides for conservation measures, restrictive measures.
With this Directive 2009/147, the European Commission has acted as a coordinating and validating body and it is necessary to continue this work.
Because no international convention has so far produced similar results in protecting the bird world.
Conservation and protection of the bird world is not only affecting the EU's biodiversity.
- Trade Restrictions
We recommend the following: Regulation 338/97 only provides for conservation measures.
See: - [1992] OJ C 26/1. p.
- WTO rules on international trade.
- Other measures
See: - 2009/147; Annexes to Directive 92/43.
- Rivers in the EU could be subject to review, fishing for seas, natural lakes re-authorize,
activities for those who live there and the livelihoods of river, sea and lake fishing
populations for the purpose.
Because the position of the Court of Justice of the European Union is that the provisions of EU law cannot be interpreted as "leading to a result which is incompatible with the general principles of Community law, in particular fundamental rights".
- Animal welfare - Animal welfare and the Treaties
Animal welfare looks at animals as living things.
See: Fourth Environmental Action Program (1987-1992) [1987] OJ C 328/1. p., 5.1.9. point.
The protection of endangered species is part of the terminology,
- Animal experiments,
- Seal protection, red coral, ivory protection, etc ..
- Instead of foot traps, the “gentle trapping standards ".
See: - [1996] OJ C 58/17. p.
- Decision 98/487 [1998] OJ L 219/24. p.; this decision shall be taken by the TFEU. 207. and 114. founded.
- European Parliament [1998] OJ C 210/31. p., which does this does rejected the agreement.
- Decision 97/602 [1997] OJ L 242/64. p.
- Commission, COM (2004) 532 of 30 July 2004.
- WTO rules on the introduction of import restrictions.
- Keeping animals in zoos.
As a measure to conserve biodiversity.
See: - [1991] OJ C 241/14. p.
- COM (95) 619 of 12 December 1995.
- Directive 1999/22 on the keeping of wild animals in zoos [1999] H1 L 94/24. p.
Read full responseResponse to EU post-2020 Roma policy
20 Feb 2020
Dear European Commission, Dear Lady/Sir,
As an initiative to develop Roma policy - tackling discrimination and socio-economic exclusion beyond 2020, we propose the following recommendation.
From the point of view of the Governments of the Member States, as executive bodies, their role in how people experience socio-economic change is not neglected.
What measures are taken by Member State governments to make European Union citizens happy or unhappy?
By what measures and by what measures do Member States' governments feel satisfied or dissatisfied with the citizens of the European Union?
Quality of life indicators can be used to effectively address and enforce Roma policy as a means of addressing discrimination and socio-economic exclusion.
Such a quality of life indicator is the result type, which is the number one indicator of the impact of Member State measures, investments and better quality of life programs (outcome).
The establishment of a social monitoring system remains important in European integration.
Member States' social conditions, performance, quality of life, social well-being and aspects.
The Maastricht Convention set out these aspects. Which was signed in 1992.
According to the Convention, one of the main objectives of the European Union is to improve the quality of life of its citizens.
Social indicator programs are used to measure quality of life, which take into account aspects beyond the economic dimension.
For example: - GDP is an economic indicator beyond which quality of life indicators are used to measure the quality of life of citizens.
- Quality of life indicators such as housing, education and access to various goods, access to health care, etc.
The situation of quality of life can be examined - the relationship between welfare, economic, social, environmental, health, and cultural situation - using a combination of objective and subjective indicators.
For example: How people perceive and appreciate the changes around them.
For example: Examining the quality of living in a social and natural environment.
For the initiative we recommend:
- Maslow Needs Pyramid,
- Erik Allardt's needs theory,
- OECD studies on improving quality of life,
- GPI - Genuine Progress Indicator,
- HDI - Human Development Index,
- the United Nations Development Program (UNDP),
- WISP - Weighted Index of Social Progress,
- etc.
Read full responseResponse to Accession to the Judgments Convention
16 Feb 2020
Dear Europe Commission, Dear Lady / Sir,
After reading and presenting Proposal for a Council Decision on the accession by the European Union to the Convention on Recognition and Enforcement of Foreign Judgments in Civil or Commercial matters.
Below are the details are the questions and suggestions from citizens.
Citizens of the European Union, interviewed in short interviews, support and agree that the EU will sign the 2019 Hague Convention. Because this Convention facilitates the recognition and enforcement of judgments in civil or commercial matters in foreign jurisdictions.
The following question was asked: What is the future jurisdiction agreement between the parties?
Our suggestion for this question is:
Look: Article 4 of the former Regulation;
Brussels I Regulation (recast), Article 83.
It was recommended that Member States take into consideration and examine their existing legal assistance treaties with third countries in the context of civil or commercial litigation.
Example: Serbia, Ukraine, Russia, Mongolia etc ..
It was also recommended that consideration should be given to and consideration of the removal of the "ordre public" clause.
Look: The jurisprudence of the Court of Justice of the European Union for reducing the public policy clause. European civil procedural law.
The reason for the interview subjects was:
There should be no major differences between the economic, social and social systems and systems of the Member States within and across the European Union.
Further suggestions: Even after the abolition of exequatur, it would be necessary to standardize the enforcement procedure and enforcement law at European Union level.
To this end, an integration process would be justified.
Look: Comparison of the Brussels I Regulation and the Brussels I Regulation (recast) for improvement.
They consider it important and necessary to regulate the enforcement of judgments by the Court of Justice of the European Union and to establish the application of the uniform enforcement law contained in an EU Regulation.
Read full responseResponse to Minimising the risk of deforestation and forest degradation associated with products placed on the EU market
7 Feb 2020
Dear European Commission, Dear Lady/Sir,
After reading the Roadmap for Minimizing the Risk of Deforestation and Forest Degradation Associated with Products on the EU Market,
The following are my suggestions below for achieving your goals.
Applicable field: Economics / Environment - economics.
Therefore, risk and related concepts are also applicable in the context of environmental economics.
Risk is defined by economics and includes, but is not limited to:
For example: - Danger is the ability to cause harm, while risk is the probability of harm (under certain circumstances and generally by determining the severity of the injury) (Health, Environment & Work - University of Manchester).
- The possibility of an event occurring that will affect the objectives pursued (AS/NZS 4360: 1999 standard).
- The inherent uncertainty of planning and the possibility that the prospects of achieving business or project goals may be affected by the occurrence of something (BS 6079-3: 2000).
For the purpose of this Roadmap - Minimizing the risk of deforestation and forest degradation associated with products placed on the EU market - and in this case, I draw attention to external risks.
For example, external risks are the result of changes in the regulatory environment for the industry, sudden changes in competitors, drastic and unfavorable changes in demand, or adverse effects of the natural environment (severe drought in agriculture).
Therefore, in the context of risk and risk management, account should be taken of the interactions between farming and other activities and the opportunities for farmers within and outside the holding.
For external or macro risks, six types of risk need to be considered in order to achieve the goal.
Types of risks listed by name below:
(1) economic, (2) environmental, (3) legal, (4) political, (5) market and (6) social risks.
It is very important for risk management activities to have a clear understanding of the risk context.
Knowledge and application of the risk correlation system is primarily applicable and important in the case of business companies and companies.
However, the system of risk relationships is determined by the risk conditions surrounding the productive operators.
The methods described are also suitable for classifying the risks surrounding agricultural activities.
The most important risk groups in agriculture are:
(1) Production risk (2) Market risk (3) Personal risk (4) Institutional risk (5) Financial risk.
Look: - European Commission, Directorate-General for Agriculture (2001)
- ISO document (ISO / IEC Guide 73: 2002) but not a replacement a uniform
international standard.
(AS/NZS 4360: 2004) Risk Management Standard as National standard.
- Towards market-based risk management solutions on turning (OECD, 2000)
- The European Commission (2005) states that public the role should play the purpose of
agricultural risk management field to be market based development and availability of
risk management tools a for farmers.
- European Commission (2006 and 2008)
Read full responseResponse to Illegal logging – evaluation of EU rules (fitness check)
2 Feb 2020
Dear European Commission, Dear Lady/ Sir,
After reading the Roadmap Illegal logging - evaluation of EU rules (fitness check), I would like to recommend the following to help control deforestation as a Global problem and as an environmental and socio-economic problem existing at EU level.
With regard to the FLEGT Regulation and before its entry into force in 2005, I consider it necessary to re-examine the regulations already in place by the European Commission for further regulation.
Forests, as habitats and regulatory areas, are subject to complex environmental definitions - environmental principles, environmental management procedures, and environmental legislation.
Legal basis for environmental protection measures against forests against fire or air pollution, as decided by the Court of Justice of the European Union: Article 175 TEC.
It is the appropriate legal basis and application for Article 175 TEC, since the protection of forests against fire and air pollution is primarily an environmental measure.
Look: European Court of Justice, C-164/97. and 165/97. joined case number.
In the future, for the sake of consistency, the issue of forest protection may need to be addressed in the past.
To this end, I will provide non-exhaustive regulatory locations below:
- Regulation No 3528/86, [1986] OJ L 326/2. p.; On the protection of forests in the EU.
Forestry Strategy - Commission. COM (98) 649, 3 November 1998.
- Council Resolution of 15 December 1998 [1999] OJ C 56./1. p.
- Sixth Environmental Action Program of the European Union (2002-2012).
- 1600/2002. Decision [2002] OJ L 242./1. p.; Article 6 (h) point.
Look: - Commission COM (2006) 302 (Forest Action Plan)
- Commission COM (2008) 645 (Forests and Climate Change)
- Commission COM (201) 66 (Green Paper on forest protection)
- Regulation (EEC) No 3529/86 [1986] OJ L 326/5. p.; Regulation (EC) No 2152/2003 concerning forest control and environmental interactions in the Community (Forest Focus) [2003] OJ L 324/1. p. It was repealed in 2007 but can be instructive and useful.
- Regulation No 3528/86 [1989] OJ L 326/2.p. (Air pollution); Regulation (EEC) No 2158/92 [1992] OJ L 217/3, p. (fire) replaced by decree 2152/2003 and replaced by decree 614/2007 Regulation.
The need for a revision of the EUTR, the modalities and the conditions for its action can be determined not only by the FLEGT Regulation, but also in many respects by the existence of environmental-socio-economic conditions.
Read full responseResponse to Gender equality in the EU
18 Jan 2020
Dear European Commission, Dear Lady/Sir,
After reading the Gender Equality Strategy 2020-2024, below I will provide information and suggestions for a future directive.
One of the most important general principles of European Union law is equal treatment.Equal treatment in EU law is a primary law.
The Member States of the EU are required to establish their national legislation on equal treatment and the promotion of equal opportunities under Council Directive 2000/43/EC of 29 June 2000.Look: In the context of international law:-Article1(3) of the Charter of the United Nations (1945).-Universal Declaration of Human Rights (1948), Art.2. - Article 2(1) of the International Covenant on Civil and Political Rights (1966). - Article 2(2) of the International Covenant on Economic, Social and Cultural Rights(1966). International conventions on the special field of equal treatment have also been concluded under the auspices of the United Nations:- Convention on the Elimination of All Forms of Discrimination against Women (New York,1979),- Convention on the Rights of Persons with Disabilities (New York,2006),- Convention on the Elimination of All Forms of Racial Discrimination (New York,1965) Look: - Article 14 of the European Convention on Human Rights (ECHR)- Protocol No 12 to the Convention for the Protection of Human Rights and Fundamental Freedoms (2000), Article 1 entered into force in 2005.
http://www.coe.int/web/conventions/full-list/-/conventions/treaty/177/signatures?p_auth=FeocLCL8. Source: Treaty Office on http://conventions.coe.int Look: Primary law:-Article 3 TEU. - Article 9 TEU (in Chapter on democratic principles) - Article 21(1) TEU. - TFEU. Article8. - TFEU. Article10.The original version of this article was incorporated into primary law by the Treaty of Amsterdam (1997/1999).The Treaty of Nice (2001/2003) added a paragraph 2, the so-called the principles of incentive measures. "But excluding any harmonization of the laws and regulations of the Member States." TFEU. Article19(2). - TFEU. Article 153(1). point (i) In the case of supplementary support powers, the Union shall have competence to carry out actions to support, coordinate or supplement the actions of the Member States. However, without thereby depriving the Member States of their powers in these areas [Art. Article 2(5).] - TFEU. Article 157(1) - Article 6(1) TEU. - The Charter of Fundamental Rights of the Union, which has had the same legal value as the Treaties since Lisbon. Look: Secondary Law: - 2002/73/EEC - 79/7/EEC - 2000/43/EC - 2000/78/EC - 2004/113/EC - 2006/54/EC - 2010/41/EU Look: Potter, Michael, The EU Horizontal Directive Northern Ireland Assembly Research and Information Service (NIAR 419-11), 2011, 2. p. Look: - Council Decision 2010/48/EC on the conclusion, by the European Community, of the United Nations Convention on the Rights of Persons with Disabilities [OJ 2010 L 23} Because the Union is also bound by this international treaty. It is settled case-law of the Court of Justice of the EU that unwritten principles of EU law also constitute sources of primary law. Including fundamental rights, the rule of law, as general principles, and specific principles of EU law. The principle of equal treatment thus forms part of primary law in general, unwritten form, in accordance with the case-law of the Court of Justice. The European Commission monitors the implementation of equal treatment in the EU. Compliance requires proper implementation of EU legislation by Member States.Lack of compliance may lead to infringement proceedings.-An important step forward in the EU's system of equal treatment would be tthe adoption of the so-called horizontal directive on equal treatment.A proposal to this effect was already presented by the Commission in 2008.-There is still a need to increase the legal awareness of the citizens of the EU in order to raise awareness of the protection already provided.-Improve the application of the Directives in the MS.
Read full responseResponse to Climate Law
12 Jan 2020
Dear European Commission, Dear Lady/Sir,
After reading the European Climate Law - Achieving Climate Neutrality by 2050, I will provide information on European Union environmental regulation below.
I will provide information on European regulation on environmental impact assessments.
Impact assessment is a specific decision support tool for environmental regulation.
The environmental impact assessment has detailed procedural rules.
It is also characterized by its comprehensive nature (meaning a high level of internal integration).
These include not only administrative but also management tools.
A complex approach to these tools is therefore also a social context leads to a more versatile evaluation.
For the first time, EU environmental law has introduced the requirement to investigate specific environmental uses.
However, the impact assessment goes far beyond the authorization of environmental uses.
Look: - The most common types of impact assessment used in environmental protection.
Including environmental impact assessment of legislation.
- Integrative Environmental Law.
- Article 3 of Directive 2011/92 EU Council and Parliament.
This Article 3 sets out the substance in accordance with the rules of the Directive and
including climate.
The Environmental Impact Assessment Directive, as interpreted by the European Court of Justice, fulfills the conditions of direct effect.
The direct effect of the Directive is objective.
The directive imposes obligations not only on national legislators but also on national authorities.
The results of the Environmental Impact Assessment are summarized in the Environmental Impact Study.
After these documents have been generated, an application for the environmental protection or the single environmental permit will follow.
Because the environmental impact study is a mandatory annex to the application.
Look: - Espoo Convention (1991).
- Unified environmental use authorization.
European Regulation (IPPC).
2010/75 Directive of the European Parliament and of the Council (2010).
Over time, it may become necessary to evaluate and examine the application of the IPPC -Directive.
These regulations referred to above should also apply to the Climate Protection Regulations.
Important! Currently, the conditions of environmental use are not subject to EU Climate Protection measures.
Because an environmental permit, or in most cases a single environmental permit, is currently required under the general rules.
Another option for Climate Protection is the so-called green certificate system in force in the EU.
Look: - The Clean Development Mechanism.
Emission allowance - a new type of property right under the title Climate Protection.
For the purposes of this Roadmap, I propose these two areas for the effective establishment of Climate Protection.
In the case of Climate Protection, international law and EU law are the starting points.
Look: - Article 1 (2) of the United Nations Framework Convention on Climate Change 9 May 1992 New York.
The EU acceded to the UN Framework Convention on Climate Change in 1994 and adopted the Kyoto Protocol thereto.
Important! Article 25 of the Kyoto Protocol.
- Decision 2002/358 on the acceptance by the European Community of the Kyoto Protocol to the United Nations Framework Convention on Climate Change and the joint fulfillment of commitments thereunder {2002} OJ L 130./1. p.
- Decision No 406/2009 {2009} OJ L 140/136. p.
- EU IV. - V. - VI. Environmental action programs.
All rights reserved! Including information in this case: environmental regulations, environmental legislation, and proposals for Climate Protection.
Read full responseResponse to A new Circular Economy Action Plan
27 Dec 2019
Dear European Commission, Dear Lady/Sir,
After reading the EU New Circular Economy Action Plan - Roadmap - I would like to recommend the following.
I recommend the following documents because the goals contained therein should be studied first.
I would like to draw your attention to the following.
To point B. "What does the initiative aim to achieve and how"
It is not possible to "accelerate the transition" as stated in this section, "as stated in the objective of the initiative", without assessing the results achieved in meeting the environmental objectives set out in the EU Environmental Action Programs.
So far, the European Union has seven environmental action programs.
In these Environmental Action Programs, the most common elements of environmental regulation are built on the basis of environmental objectives and principles.
Because these environmental principles cannot be applied otherwise.
Because environmental protection has the following characteristics:
Goals and environmental principles are not only closely linked to each other, but also where relevant.
These form the order of values that are defined to determine the direction of further regulation (strategy-making, legislation, enforcement) and non-regulatory measures (interventions to improve the environment, etc.).
So, it is essential and therefore necessary to know the environmental principles, which are also explicitly formulated as basic principles.
These environmental principles are the Alpha and Omega of the European Union's environmental policy.
To summarize: The transition to a circular economy requires a deep understanding of what has been briefly described above.
In-depth knowledge of these environmental principles is needed to ensure that they are properly applied in the future.
For use when it is difficult to decide on a value, whether it is an environmental principle or rather an objective.
I also recommend:
- Document adopted by the “Rio+20” Conference.
Which includes the concept of "green economy".
- The 6th EU Environment Action Program (2002-2012).
Its environmental principles and objectives form the basis for the transition to a circular
economy.
- The “Europe 2020” Strategy.
Because all the necessary environmental principles and environmental goals have been set in this
Strategy and in the Environmental Action Programs and they are still relevant until 2030.
In addition, in-depth knowledge and application of these recommended documents is necessary to
enable a gradual transition to a circular economy at some time in the future.
To ensure that existing environmental principles are applied and enforced in the future.
All rights reserved! Including the text content of this Communication!
Read full responseResponse to EU 2030 Biodiversity Strategy
26 Dec 2019
Dear European Commission, Dear Lady/Sir,
After reading the EU Biodiversity Strategy to 2030 Roadmap, I would like to recommend the following.
I recommend the following documents because the goals contained therein should be studied first.
It should be studied how the goals will be achieved by 31 December 2020.
In these Environmental Action Programs, the EU sets out the goals of its environmental policy.
In addition, these Environmental Action Programs set out the priorities for EU environmental policy, the measures required for environmental legislation, international cooperation, implementation, financing, etc. in the circle of.
At the end of a given Environmental Action Program, it is necessary to evaluate the results achieved.
For the purpose of what has been accomplished and how it has been realized from the set goals.
Then, if there are evaluations of the results achieved, then it is possible to plan new goals from 2021 to 2030.
Recommended documents:
- “Europe 2020” strategy
As a general strategy, this strategy influences the development of the European Union's environmental policy.
This is the framework of this Europe 2020 strategy as a framework for environmental policy.
That is why it is already influencing the content of the next, most recent Environmental Action Program, and is about to be the backbone of a comprehensive strategy such as the Europe 2020 strategy from 2010.
- The European Union's 7th Environment Action Program for the period 2013-2020.
This should be followed by the 8th Environmental Action Program.
Defining goals in it.
So, naturally, the goals are set for ten years.
So the duration of the 8th Environmental Action Program would be from 2021 to 2030.
IMPORTANT REASONS FOR MY RECOMMENDATIONS ARE AS FOLLOWS:
Of the European Union's policies, action has only been taken in the field of the environment to ensure the continuity of programs.
All rights reserved! Including the text content of this Communication.
Read full responseResponse to Final Evaluation Employment and Social Innovation programme (EaSI) 2014 - 2020
9 Oct 2019
Dear Sir or Madam,
Ex-post Evaluation of the EU Program for Employment and Social Innovation - (EaSI) 2014-2020 Goals and Future Objectives our organization continues to agree and deserve to have this program post-2020.
We consider the continued operation of the program important and decisive because the children of the new millennium will grow into young and starting workers from 2021 onwards.
This young workforce is already entering the labor market of the future with completely new knowledge.
Innovative knowledge creates higher added value.
Evaluation of the impact of the program and its added value:
The EU's employment and innovation program has offered and offers an opportunity to promote high-quality and sustainable employment at EU level and to create higher value-added labor markets.
The program contributes to the realization of projects of a larger scale and professional value added.
The projects, with the help of EaSI, create, among other things, employment growth.
By promoting projects, creating social innovation as well.
Thus, the impact of the European Union's employment and innovation program is a huge opportunity and opportunity for members and groups of European society.
This includes, inter alia, young workers entering the labor market after 2020.
One of the criteria for the impact of the program is the creation of added value.
Because the application of innovative technologies cannot negate the desirability of adding value.
Governance, accountability and transparency of the program:
The European Union's employment and innovation program is managed directly by the European Commission.
The management of this program will continue to be desirable and should remain under the direct responsibility of the European Commission.
As the European Commission has the power to supervise the implementation of European Union law at Member State level, the implementation of Union law at Member State level.
The accountability and transparency of any European Union program, including the employment and innovation program, can be accounted for and verified on the basis of its lawful implementation, implementation and enforcement.
From the total budget for the period 2014-2020, the stability of the projected payable EURO amount for 2020, possibly due to exchange rate fluctuations in the case of non-EURO Member States, perhaps it could be corrected by creating a provision.
Read full responseResponse to EU farm policy - Evaluation of its impact on sustainable management of the soil
3 Aug 2019
Dear European Commission,
EU agricultural policy - In order to assess its impact on the sustainable management of soil, I propose the following.
The proposal for a directive on soil protection in the European Union is based on the TFEU. based on Article 192 (1).
This legal basis is appropriate for the sustainable management of soil linked to the Common Agricultural Policy, because it deals with the protection of the environment.
Indeed, the effects of sustainable soil management on this environmental element affect the land as a suitable agricultural land.
Specific EU legal measures directly related to soil protection might be needed.
Because agricultural measures can only affect the sustainable use of soil in general.
See: Communication from the Commission on a sustainable agricultural economy [1999] OJ C 173/2. (point 2.3).
Special EU rules on soil protection, in particular against soil erosion, may also be needed.
EU-level soil protection measures may also be required.
To create a sustainable agricultural economy beyond and beyond 2020.
Special EU rules on desertification prevention may also be needed.
For the purpose stated in the previous sentence.
Any EU land use measures are subject to the TFEU. It would have to be adopted on the basis of Article 192 (2).
As far as I know, forestry has not been part of the Common Agricultural Policy.
See: European Court of Justice, European Parliament v Council (Joined Cases C-164/97. and 165/97.): [1999] ECR I-1139. p.
Kind regards,
Anikó Márta Szűcsné Putics
Read full responseResponse to European network of employment services EURES – evaluation 2016-2020
18 Jul 2019
Dear European Commission,
The European Network of Employment Services (EURES evaluation 2016-2020) initiative we sending the experience of job seekers arriving to the Organization.
Jobseekers are among the 30-40 age group by age.
Job seekers have knowledge of German and English.
Job seekers have secondary education.
They have not even heard about the operation and service of EURES.
That's why they went to work in one of the other countries recommended by their friends.
But since they did not hear about the operation and service of EURES, they were unable to seek help in finding a job and finding a job that would provide a better workplace, better work for them.
The other case is when German-speaking jobseekers are unable to find work in another Member State because they have also not heard about the functioning and service of EURES.
Our suggestion for evaluation is therefore:
The EURES activities and performance could be enhanced by better information from job seekers on the part of the Member States.
Because of the opportunity and the possibility of using the information to stop the information, it is unlawful for the citizens of the European Union to be deprived of this opportunity.
In the European Union, the objective of employment and social affairs is to improve the employment of European citizens and to improve their living conditions and their sustainability.
Creating, operating, and sustaining a knowledge-based European society.
Yours sincerely,
On behalf of Non-governmental organisation (NGO) volunteer staff.
Read full response18 May 2019
Dear European Commission,
Thank you for sent the Roadmap.
The Roadmap deals with the assessment of the impact of the EU's Common Agricultural Policy, which takes stock of impacts and assesses the socio-economic aspects of the impact on rural development in rural areas.
Evaluation criteria include an assessment of direct payments to farmers and their effects, which determine the life of farmers, their agricultural activity and the maintenance of a diversified agricultural sector and the maintenance of balanced territorial development.
The following are the areas of evaluable payments that I believe are still relevant for the territorial development of rural areas, and their amounts by target group.
This evaluation roadmap also mentions the existence of CAP instruments and measures and wants to assess the impact and extent of these tools and measures also on the balanced territorial development of rural areas, focusing on socio-economic aspects, including social inclusion.
In my opinion, I would categorize and evaluate the various agricultural applications and payments and purchases as CAP instruments and measures.
I consider the evaluation of CAP proposals useful because, for example, many agricultural companies were able to increase the number of agricultural machinery and agricultural machines by taking part in such tenders and thus obtaining the necessary financial resources for the procurement and investment.
But the evaluation would need to take into account the fact that the really new original agricultural machine was actually made, the purchase of the agricultural machine from the agricultural company or the loan to each other, transferred, sold the machines, after the machine specified in the tender expired preservation and use time.
Then another company could apply for machine purchases.
But by fulfilling the requirements of a company already purchased and the delivery of the machine.
So two or more companies have applied for it after five years, and in fact only one original and new machine was purchased.
It is also irrelevant whether agricultural companies have actually acquired an original, new and unused machines.
All power machines, machine investments that can increase, increase productivity, increase economic development, employment, growth, competitiveness, etc.
It may be worthwhile from this point of view to carry out the evaluation criteria and their effects.
Read full responseResponse to Evaluation of the information Policy on the CAP
18 Mar 2019
Second part:
There was nothing to ask me about the case in the Kúria.
So since they didn't ask anything so I didn't have to argue.
The probationer advised us to follow the request made in the Review Request.
Thank you very much for the supervision and assistance of the European Commission in this know - how.
If the European Commission, at my request, does not supervise this matter, it would have completely abandoned the procedure.
Thus, from July 10, 2015 until 20 February 2019, the case was brought to court.
They thought they'd slip up the case until July 10, 2020, when five years would have passed for money.
Even after five years, money claims expire in Hungarian law.
So I can still apply to the European Court of Justice for an annulment of the judgment and then to the Hungarian court.
I didn't have to pay the court costs
Best regards,
Anikó Márta Szűcsné Putics
Read full responseResponse to Review of Agricultural Block Exemption Regulation
18 Feb 2019
Dear Commission,
I've read the roadmap for my part.
Which is called Review of Agricultural State Aid Guidelines.
During the reading of Section „A” my suggestion has already been developed and I will present this proposal as an initiative to develop a new legal framework for the CAP in the future.
First as a Landscape Management Engineer, I was thinking about the different and expected effects. Such as economic effects, social impacts, environmental impacts.
Then, as an environmental and environmental law expert, I have been thinking about these fundamental rights as well as the very important fundamental rights that affect the future of the CAP's new legal framework.
I start with the relevant fundamental rights:
The first fundamental right concerned is the right to property.
Because agricultural land, farms, agricultural machinery as production tools are privately owned, forests and forest areas are also privately owned. Maybe they are state-owned.
But breeding animals are also privately owned.
But in rural areas, their dwelling houses, their animals and their lands are also private property.
The second fundamental right is the right of the third generation to a healthy environment.
Continue to section "B" in relation to:
I fully agree with the objective.
And as I have already indicated in previous roadmaps and consultations, I consider it important to reduce the financial burden and taxes on farmers in Member States where the government of a Member State has set much higher amounts than necessary.
Furthermore, I consider the third option to be implemented.
Since state aid can also be direct financial support from the Member State's budget, it can also be subsidized by tax.
And state support may also come from the Union's Funds for Agriculture and Rural Development.
Therefore, the amount of EU support and the amount of support from the Member States together provides and facilitates agricultural activities, forestry, non-agricultural activities and the preservation of rural areas as a way of life for the sake of efficiency and effectiveness that the CAP intends to regulate.
Last but not least, I recommend the environmental impact assessment.
There are many reasons for the need to assess the natural environment of the Member States as an environment suitable for agricultural production, as well as the potential for landscape use.
These reasons are:
- Ecological changes cause ecological uncertainty. They affect the destruction of the natural environment.
But the natural environment, the agricultural environment, the culture landscape, and the rural area are further affected by:
- Climate change
- Useful and successful use of alternative resources
- food safety
- food - self- determination
- developing a garbage-free lifestyle
- developing a waste-free lifestyle
And social effects can affect:
- keeping the local lifestyle, new ways of living in the local lifestyle because of the changed, transformed culture
Rural areas, rural areas are not only the scene of agricultural production, but also the biological and social life of the people living there.
To sum up: For the new legal framework for the CAP, for the period 2021-2027, a preliminary, reassessment of the above-mentioned aspects and disciplines is necessary in order to develop a successful and useful legal framework for agriculture, forestry and rural areas for all concerned.
Information as Post-it: On February 19, 2019, I am going to Budapest.
Because the know-how is negotiated at the Hungarian Curia on 20 February 2019 will be at 10:30 am o’clock.
My legal assistant lady, who has been assigned to legal aid, said she will come at the Curia.
Based on the discussions, we will meet at the Curia.
Thank you very much everything.
Best regards,
Anikó Márta Szűcsné Putics
Read full responseResponse to Protecting citizens against health threats
20 Apr 2018
Dear European Commission,
Dear Lady/Sir,
We will present the initiative and then the technical factors necessary for strategic planning.
The application of these factors is necessary at both European Union and global level.
Objective: To maximize the public health of the population of the European Union.
Task: - Identify public health - identify hazards and risk factors affecting public health.
One of the categories of factors affecting public health is the environmental factor that is organically linked to environmental protection.
Environmental and infrastructure issues in environmental protection as a horizontal principle are important in the European Union's society.
One area of environmental protection is Environmental Health.
Environment - Health deals with the impact of the evolving nature of the threats to public health and the emergence of a natural disaster or human activity involving prevention, preparedness or public health.
Paragraph A.
Defining the problem.
May cause damage to the environment:
- biological and chemical incidents,
- rearrangement of climatic belts,
- change in rainfall conditions.
Altered natural effects create health hazards, such as infectious diseases and non-communicable diseases, with these cross-border health hazards and in order to protect public health, measures and solutions are needed to prevent the epidemic.
Paragraph B.
The basis for the initiative and the EU intervention is also based on:
The competitiveness of European society is enhanced by the existence of a natural and artificial environment that promotes public health, the provision of community environment planning and environmental development.
Read full responseResponse to 2018 EU Justice Scoreboard
9 Mar 2018
Dear European Commission,
After reading the scoreboard 2017, after studying the diagrams, I will share the following thought with you.
They are also members of our organization to achieve high quality justice at European level.
This kind of quality and effective justice is needed by EU citizens and Hungarian citizens who are turning to the organization.
The scoreboard 3.2. is about the quality of justice systems.
This includes the four data for measuring quality.
The most important quality standard application is the high quality professional knowledge.
Knowledge of high-quality professional knowledge and its application is the most important prerequisite for effective, reliable and lawful justice delivery in the Member States.
Here, referring to quality and quality requirement, refer to Figure 7, Figure 8, Figure 9.
These figures show that the majority of the Member States rated their performance at 100%, giving them an example of the scale, activity and action of the figure.
Here is the question of the quality of professional knowledge, which is as follows: How effective are these courts in the Member States, but what kind of professional quality and legitimate justice they have done have been given to the European citizens of the Member States who are coming to them?
Let us refer to Figure 10, Figure 11, Figure 12, where the extent of pending cases was given by the Member States.
In this case, it is also clear from the figures that the Member States have indicated a low degree of contingencies in their courts.
But, for example, if we look at controversial cases in the Hungarian courts, then people will know that there are cases that last for 5-6 to 7 to 8 years.
Justice, judging the real results of the courts, would be needed for the judiciary and for the judicial control of courts in the Member States.
Unfortunately, societies have come to the conclusion that, without control, they are not very effective and do not work very effectively.
Humanity and citizens of the Member States would sooner not be disassociated, but would settle their interests at EU level in order to settle disputes brought by the European Union's judiciary and to enforce justice.
Member States' governments should take the lead in the best implementation of judicial reform in the Member States, as they undertook to maintain the rule of law, the market economy and the social market economy.
It is also important to mention the cost of court proceedings and the demand for prices to be put on the courts by citizens.
The scoreboard 3.2.2. We fully agree.
Here, quality professional knowledge is also being highlighted.
Read full response15 Nov 2017
Third part
Because, as of July 10, 2015, I have applied for a civil non-litigation request.
So much for that.
I hold myself to the deadline for submission of 24 November 2017 for the original deadline for submitting a request for a review of know-how.
On 14 November 2017 I was invited to the address of the National Conference for Sustainable Development, as an audience, which was held in Budapest on 29 November 2017 from 10.00 to 14.00.
Address of the conference: Budapest, Arany János street 10th in the Aranytíz Culture House
At my conference, I filled in and sent the registration form.
This is all about our affairs, my affairs.
Thank you very much for everything.
Please continue my assistance in my court cases and my continued support for my life.
I am pleased to be able to represent the European Commission's authority and authority to European citizens and thus to the Hungarian citizens who are seeking help.
The house insulating lady told the attorney's interest that "he was able to reach a neighbor with the help of a European Union citizen".
I did not look for the environment technology I mentioned earlier and its owner.
But I hope I can get to him.
Thanks and regards:
Anikó Márta Szűcsné Putics
Read full responseResponse to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)
30 Oct 2017
Dear European Commission,
Thank you very much for sending me the timetable.
After reading the schedule, I will give you information about the following.
Directive 91/271/EC referred to in the Roadmap, on the management of urban waste water [1991] OJ L 135./40. p. amended by Commission Directive 98/15/EC (1998) OJ L 67./29. p.
I recommend the following guidelines for cleaning municipal waste water treatment and quality measures:
- Directive 98/83 on the quality of water intended for human consumption [1998] OJ L 330./32. p.
- Directive 80/778 on the quality of water intended for human consumption [1980] OJ L 229./ 11. p.
- Directive 2007/60 on the assessment and management of flood risks [2007] OJ L 288./27. p.
- Directive 2006/7 on bathing water quality [2006] OJ L 64./37. p.
- Directive 91/676 on the protection of waters against pollution of nitrates from agricultural sources [1991] OJ L 375./1. p.
- Directive 91/692 on the standardization and rationalization of reports on the implementation of certain Directives on the environment [1991] OJ L 377./48. p.
Read full responseResponse to Carbon Leakage List 2021 - 2030
30 Oct 2017
Dear European Commission,
Thank you very much for sending me the roadmap.
After reading the timetable I will give the Commission the following information.
Directive 2003/87 / EC, referred to in the Roadmap, establishing a scheme for greenhouse gas emission allowance trading within the Community [2003] OJ L 275./32. p.
This Directive was revised in 2009, Directive 2009/29 [2009] OJ L 140./63. p.
The amendment in 2009 provided that, from 2013, the units will be sold at auction. On this basis, units are no longer distributed free of charge.
The amendment of Directive 2003/87 / EC in 2009 provided that, from 2013 the total quantity of allowances should be reduced by 1,74% per year.
I recommend the following guidelines for review:
- Resolution 406/2009 on Member States' efforts to reduce greenhouse gas emissions to meet the Community's greenhouse gas emission reduction commitments up to 2020 [2009] OJ L 140./136. p.
- Directive 2004/101 [2004] OJ L 338/18. p. this Directive amended Directive 2003/87 / EC in 2004.
- Regulation (EC) No 443/2009 defining the emission standards for new passenger cars as part of the Community's integrated approach to reduce CO2 emissions from light-duty vehicles [2009] OJ L 140./1. p.
- Regulation (EC) No 595/2009 on the type-approval of motor vehicles and engines with respect to emissions from heavy duty vehicles [2009] OJ L 188./1. p.
- Directive 2009/31 on the geological storage of carbon dioxide [2009] OJ L 140./114. p.
Read full responseResponse to Fitness Check of the Water Framework Directive and the Floods Directive
29 Oct 2017
Dear European Commission,
Thank you very much for sending me the roadmap.
The aim of the evaluation is to draw attention to the re-thinking of the tasks to be improved in the field of water management, which should be reviewed at the level and level of the European Union.
Because both groundwater and surface waters are a common natural heritage of mankind.
On the basis of the EU Water Policy and Law: A task to be solved is the emission of pollutants (eg. t / year), immission of pollutants (eg. mg / m3) for water use, the determination of transmissions (the path of pollutants, their diffusion in the environment) should be determined taking into account their use of water bases and their water use. Who? For what purpose and for what purposes are the waters of the water basins used? To what extent? How often do water basins be used? What are they doing to protect the water bases to replace the water used? etc ..
It would be necessary to re-examine and examine both qualitative and quantitative data on water bases at Member State level and at European Union level, their practical water use and water use habits.
For example, the basins of the water bases could change due to their environmental impacts, but not only the condition of the riverbed and its changes could determine the future destiny of living creatures living in the aquatic world and, accordingly, the quantity and quality of freshwater available. However, further water consumption is influenced, for example, by water capacity, water flow, river velocity, etc. in the water base.
It would be necessary to review the joint environmental measures of international river basin districts, to renew and to establish common environmental management.
Where a catchment area covers the territory of more than one Member State, it shall be assigned to an international river basin district.
- In the international river basin districts, the Member States concerned should cooperate jointly.
- Where non-EU countries belong to a catchment area, Member States must cooperate to ensure that they are provided.
The establishment of a joint environmental management of the international river basin districts and one of the reference bases and predecessors of these provisions is Directive 91/271 on waste water treatment. Directive 85/337 obliges Member States to carry out an environmental impact assessment ... .etc. ..
It would be desirable to draw up a European Union hydro-ecological plan for the management of sweet-water shortages.
It would be necessary for the European Union's water rights to fully apply and control the various provisions, which is the general and most important task of the European Union's environmental law.
Read full responseResponse to Evaluation of the PES Network Decision
28 Oct 2017
Dear European Commission,
Thank you very much for sending me the roadmap.
After reading the Decision 573/2014 / EU, I will give the following proposal to the European Commission.
My suggestion is to improve the functioning of the labor markets for the period after 2020. It will put the creation of the new European employment modes forefront of creating the renewal of nature and labor market services.
Among other things, it affects the labor market of a Member State and determines the services of the Public Employment Service.
Changes in the future of the labor markets (labor supply and labor supply) can be expected.
These changes are triggered by the generation of new labor entering the labor market, which appears on the labor market. New generations of workers have new working conditions and needs. These employee needs must be taken into account and need to develop in the future for employers. Therefore, change management is needed to change management both on the employees 'and at the employers' side.
To do this, it is necessary to carry out the Labor Force Management and then the Labor Force Planning. Firstly, at Member State level, to look at the new and effective functioning of the single European labor market, I would assess the number of active jobs expected from current and post 2020 and those with a qualification and working age.
After that is expected to be established in the labor resources (labor headcount actually available depends on many factors) the level of the European Union together with the associated States.
Necessary to draw the changed working conditions, employers' attention in addition to determining the number of potential workers. To assess, evaluate and evaluate active labor market initiatives to develop new employer opportunities.
Read full responseResponse to Fitness check of the EU Ambient Air Quality Directives
2 Aug 2017
Dear European Commission,
Dear Lady/Sir,
I have read the roadmap sent to me along with the guidelines in the roadmap title.
I refer to in Directive 2008/50 / EC below.
Directive 2016/2284 / EU refers to Directive 2008/50 / EC and Directive 2001/81.
The objectives of these directives are to be respected by the governments of the Member States in order to improve the air quality of the environment and the stakeholders concerned.
The generation of air pollutants and the consequent harmfulness of these pollutants - beyond the limit, but which is already a minor cause to some extent - the amount of emissions into the air is determined by the economic development of the Member State.
It would perhaps be possible to compensate for the different levels of economic development in the Member States if they would move uniformly and gradually to the use of renewable energies.
The use of renewable energies can achieve a lasting improvement in ambient air quality and prevent the deterioration and subsequent deterioration of air quality.
The use of renewable energies is also competitive in air protection.
In the case of Directive 2008/50 / EC, I still have air quality values.
- I know that the troposphere's ozone content and the "PM2,5" limit has not yet been recorded.
- It may be possible to determine the permissible emission it would be more appropriate to establish and fix the limit only for the purpose instead of defining values.
- It can be absent from mercury and hence it would be necessary to control of emissions, limitation of emissions.
Read full responseResponse to Agricultural de minimis aid
25 Jul 2017
Dear European Commission,
Dear Lady/Sir,
Thank you very much for sending me the roadmap.
I read the roadmap.
After reading the Commission Regulation (EU) No 1408/2013, I will give the following proposal to the European Commission.
The increase in the ceiling for de minimis amounts is made necessary by the product structure of the primary production of agricultural products
change.
Product structure is triggered by changes in land use, changes in available natural, human and financial resources (the economic situation of the Member State, economic and internal market situation in the European Union) in the life of an agricultural small and medium-sized enterprise.
Adaptation to change carries the risk.
As these small and medium-sized enterprises in the agricultural sector decide to switch to the required product structure, they are taking risks.
Their risk exposure, the reduction of the negative effects of risk factors, may have a positive impact on de minimis aid.
The possibilities of the ceilings indicated in point B are determined by the agricultural activities carried out in the Member State and their financial value in the national economy.
The possibilities for raising the ceilings are influenced by the tax system of the Member State.
Like the central budget of a Member State as a tax for the local government budget.
In order to reduce the administration, but with the need to maintain transparency, I would call for the creation of a de minimis database for a de minimis European de minimis database to require de minimis subsidies and a faster payment option.
Read full responseResponse to REFIT evaluation of the SEA Directive on Strategic Environmental Assessment
18 Jul 2017
Dear European Commission,
Dear Lady/Sir,
Thank you very much for sending me the roadmap.
I read the roadmap.
Based on the conventions referred to in the roadmap and as described below, it is still important to examine the environmental impacts of certain plans and programs.
I propose the possible and expedient extension of the EC Directive mentioned in the roadmap below.
An essential task for the necessary environmental management is the understanding, analyzing and analyzing environmental data, making the decision to further action to ensure and maintain a viable and sustainable earthly life.
Citizens of the European Union are thus interested in the citizens of the Member States in what kind of environment they live in, what health effects and risks they are exposed to.
The Charter of Fundamental Rights of the European Union states that everyone has the right to know about the state of the environment, environmental pollution, environmental activities and the effects of the environment on human health.
The Aarhus Convention states the right to environmental information and information.
(C.3) Other tasks may be.
In addition to the rules and regulations of the Espoo Convention, the European Union Environmental Impact Assessment Directive and the Integrated Pollution Prevention Directive, it may be expedient to include a rule in the area of land use, and the necessary environmental protection measures for settlement developments.
Here I refer to the Initial Interference Logic for the External Factors and the following example.
The expected increase in the number of humanity, the increasing number of the population, the existing living environment or the already destroyed living environment - due to its changed environmental and natural condition - may make new areas of habitation, landscapes, urban and village settlements new habitats , Makes it necessary.
When designing these newly-built residential areas, consideration should be given to the ability to support the new area.
Environmental and economic science needs to be taken into account and accounted for by the surviving life of the population already living there, affected by the environmental and natural factors of the landscape and the existing and present ones.
These existing environmental and natural resources and resources can determine the potential for future development of land and settlement.
Existing living environments can have environmental impacts on their environment due to the increased environmental burden.
Read full responseResponse to Evaluation of marketing standards [Regulation (EU) No 1308/2013]
12 Jul 2017
Dear European Commission,
Dear Lady / Sir,
Thank you very much for sending me the roadmap.
After reading the roadmap give the following suggestions to the European Commission
(A.1) Purpose The standardization of products is defined by the way in which agricultural products and crops are made, the production method used for the ingredients.
The first question could be to find out what kind of farming system, farming mode, crop products were produced, what crops were produced?
Is it possible to produce or produce ecologically via production method, or even traditional production mode or new production mode?
The new mode of production is the precision farming mode that is increasingly growing in agriculture.
The production method of production would be the first to determine because it has an impact on the competitiveness of the product and the crop.
One of the most important preconditions for the production of agricultural products and crops is the high quality of available soil.
Agricultural crops, products are excellent, and their quality of production requires more than one condition. For example: Production equipment machines, human labor, irrigation, water use, storage, warehousing conditions, pest control, etc. How are producers available to distributors?
These are the economic conditions which also have an impact on the economy,
Quality classification, distribution, competitive product, product.
My proposal: evaluation and prior to the creation of a new law is definitely old but the existing marketing standards need to be remaining in the old and the new forms of agricultural production and animal husbandry practices in the EU survey.
This form of management assessment survey is necessary because of a change in the availability of natural resources - soils, forests, szántók-, water resources fields, livestock farms, etc ..
Methods of production, production systems in agriculture and livestock production should be measured and defined.
(Point B.2). The conditions and possibilities for intervention can only be determined if equal conditions of competition are available and we know what and how and why and how and how to change the production, the economic and the financial support system for competitiveness.
(B.3) Objectives. Products, products and products produced from agricultural production can be tested and graded.
Though this applies to animal husbandry for animal products as well.
After the definition and definition of quality categories and quality classes, a new definition of the quality assurance system could come.
Creating a guarantee for quality assurance.
Marketing - the business policy of selling and selling - together with all of its activities, it is possible to find the necessary production data as outlined above and to the extent that they are related to it.
Read full responseResponse to Evaluation of the long-term unemployed recommendation
11 Jul 2017
Dear European Commission,
Dear Lady/Sir,
Thank you for the roadmap you sent to me.
I read the roadmap and read the following suggestions after reading it
European Commission.
(A.1) point The purpose of the four main areas presented in the LTU Recommendation was a noble thought and action, and this is the case at present and is in operation.
I think that not only does the state-level Employment Office and the other state offices dealing with the unemployed and long-term unemployed work well in Hungary.
I believe that employment agencies in the Member States work well and produce good and bad indicators of the employment situation because from the European Union, from the various financial foundations of these employment offices in the Member States to their work to promote employment, etc. necessary money.
B. point. "Long-term unemployment has increased as a result of the economic crisis between 2007 and 2014." "According to the latest data, today it affects about 9.3 million people."
This is because the European Union and its Member States have a capitalist economic system. So the laws of capitalist economics work.
In the capitalist economy, because of its economic bills, the full employment of the working-age population has never been and will never be and will never be realized - SEE the Economics of Science, including parts of the workforce on the capitalist structure, offering job opportunities, macroeconomics,
In capitalism there is a market economy and, in vain, we call it a social market economy, we can never realize the full employment of the whole working population. In vain, some groups of the working-age population are called, for example, young unemployed, unemployed people over the age of 55, etc ..
The full employment of the working-class population was realized in the economies of the socialist structure and could only be realized.
Such a socialist economy has worked for example in Hungary and other former socialist states.
In socialism, full employment could be realized because of the lawfulness of socialist economics. SEE also the Economics of this topic.
Everyone worked, everybody was employed but small, for little pay. Socialism did not have to pay personal income taxes to working people.
I could quote the legalities of the economics of capitalism which have an effect and thus affect the non-feasibility and non-realization of the full employment of the working-age population.
The economics affecting the socialist economy also have the regulations governing employment, but as we see it is obviously different from the economics of the states in capitalist states.
(C.2) One of the important questions to be considered is how can the long-term unemployed help the European Union and its Member States?
How and where do you live, eat, reside, and how to get rid of their expenses, etc.?
Once again, I emphasize that in working capitalism would want to work in vain if there are not enough jobs available.
Creating a job in capitalism is not the task of the state, but the task of the labor market.
Labor supply determines labor demand and labor supply.
Which is determined by the creative power of private farms.
Therefore, it is not just the reintegration of people and their low qualifications.
But an economic rule is played by the capitalist system
In their economies.
This law is best defined by private-owned production units such as factories, factories, schools, hospitals, agricultural production companies, etc.
The European Pillar of Social Rights in the European Union, in the tasks of the European Union's Social Charter, is also needed, it is necessary to establish and introduce social measures, benefits, rights that allow for a short period of time and a long Unemployed people can live a life worthy of human life for a long time.
It is necessary to establish what these guaranteed EU social rights, welfare services and social benefits are, which should and should therefore be mandatory in
Read full responseResponse to Summary of the ex-post evaluations of 2007-2013 rural development programmes
10 Jul 2017
Dear European Commission,
Dear Lady/Sir,
Thank you very much for the Summary of the ex-post evaluations of 2007-2013 rural development programmes.
After reading this roadmap I give the following professional recommendations to the European Commission.
My professional suggestions, in conjunction with point (C.2) of the roadmap, to improve the quality and implementation of future programs “recommendations (with the aim of improving the quality and the implementation of future programmes).” and I give it to the points of (C.3) and (D.4).
My suggestions will be given to the interests of the European Union Rural Development Program, which includes the European agriculture, which is to be established from 2020 onwards, and hence to the following years.
I still consider important aspects as the goals to be achieved in this way, the tasks identified in the three rural development program axes.
Is the name of the axis naming the Pillar now?
The axis name is 2007-2013. Was used during the years?
For 2014-2020 are we talking about the Pillars?
The future rural development opportunities and thus the future agricultural activities can be done by the natural landscape at all times and the available space.
Therefore, I am planning on transforming or transforming natural / cultural landscapes into the planning of the future rural development program, in addition to the still existing and therefore viable and usable natural landscape / culture landscape.
Because the natural area, the natural landscape, carries the future
Energy sources, new energy carriers that can be renewable energies the basics of using it.
A healthy living environment provides a viable life.
The status of natural landscapes / landscapes can be taken into account in the territories of the Member States, for example by using the tools of the GIS, and by personalizing the landscape, involving people living in the landscape and using it.
With the consideration of natural sites / cultural landscapes, and then I will examine the changes in these areas, the causes of the changes, the proportions of the changes and the possible use of land.
Landscape Management is a tool for environmental protection and one of its areas is environmental management, one of the special areas of agri-environmental management.
But environmental management involves several other areas.
If changes in the characteristics of the landscape / area have been identified for landscapes / landscapes in the Member States of the European Union and not in their Member States, then we can determine the possible landscape / area use and landscape / area use potential in the future. Including land and town development, common agricultural policy, use of renewable energies, industry and so on urban and rural quality of life, etc.
If we know what kind of landscape / area the European Union has in the future - as we can manage it - then we will know about agriculture, the industrial economy, the conditions for the competitiveness of the health industry.
I continue to maintain my view that, in order to implement a successful rural development program for the post-2020 period, no financial access would be granted to the governments of the Member States.
The current governments of the Member States and their officials and officials only participate in non-financial administrations and only in their own Member States.
The targeted use of money - money management, money payments, money grants / grants - would solve all financial activities in all areas within the institutions of the European Union.
Read full responseResponse to Commission Delegated Regulation establishing the Innovation Fund
24 Jun 2017
Dear European Commission,
Dear Lady/Sir,
Thank you very much for the draft initiative sent to me.
I have read the draft and give you the following suggestion for further development.
To point A. Initial Goal: To reduce the environmental burden of the planet Earth and thus to the living and inanimate part of the natural environment, to reduce the environmental burden, to reduce the use of environmentally friendly technologies for living and healthy Earth, for living life, for Earth Earth itself.
B. Another goal: Implementing Green Government - which would provide lifelong life on Earth - the introduction of available environmental technologies, their application makes it feasible. -
Economy science source: All environment use for analysis, analysis, resource reduction, to increase the solution of environmental economics science application.
Environmental economics responds to how to introduce and disseminate innovative systems and innovative environmental investments in the economy - in commerce.
How and how should it be funded.
For example: I would create a system for switching to the use of green energies.
These incentive tools are also known and used by environmental economics science.
Environmental economics deals with incentive systems.
Environmental taxes, burdens, fines.
Even one of the schools of conventional economics does not give the right answer to the management of the environment and environmental resources based on economics.
Because the economics of the economy counts with economic indicators and elements that traditional science does not use, it does not use.
However, environmental assets and environmental resources already exist as bank, shareholder funds and shares.
Considerable and applicable methods are environmental, social and management (ESG) factors.
The creation and existence of the Innovation Fund is a good thing.
Its purposeful operation was to determine when, where and by what innovative environmental technology it was created for what new environmental investment could be used.
Reducing carbon dioxide emissions requires environmental technology processes, and the possible renewal of carbon dioxide quota trading can also be the answer to environmental economics.
But let's not just deal with carbon dioxide emissions and its absorption and storage.
D. point. Expected effects.
In my opinion, Fundamental Rights have an impact as contracts are created, are created between the contracting parties and the terms of the contract are defined by the Fundamental Rights and the Fundamental Rights.
See! Freedom of contract, mandatory and non-mandatory elements of the contract.
Read full responseResponse to Revision of the Shipping MRV Regulation
22 Jun 2017
Dear European Commission,
Dear Lady/Sir,
Thank you very much for sending me the roadmap.
I have read the roadmap and propose the following proposals for further development of the living and living environment protection of the marine environment.
Protection of the marine environment naturally affects the social and economic environment as well.
Maritime shipping - seaworthiness - cargo shipping must also seek to operate an innovative energy based vessel for use in its introduction.
Energy-efficient change can make the use of an innovative energy source.
An electric powered vessel.
B. Objectives and Policy options.
What data is required to report?
It defines the environmental element of the living and inanimate marine environment. We want to protect all of our elements - sea water, atmosphere, living creatures in the sea, sea-bed platforms, islands, beaches, coves, etc.
All environmental elements are affected by harmful emissions of carbon dioxide.
In my opinion, a global report would be needed.
This is based on International Public Law which also includes the international environment law.
The creation of a new information system for the collection of data on maritime transport provides an opportunity to avoid duplicate and burdensome data provision in all maritime navigation areas.
C. Likely impacts on simplification and/or administrative burden.
If a new information system for collecting, analyzing, analyzing, managing information and document management in the field of marine environmental data would be created, it would not be necessary to review the existence of an additional document for port State control purposes.
Everyone should use a form document to provide data for the same data request and provide data services requiring the required deviation.
Read full responseResponse to Evaluation of the impact of the CAP on climate change and greenhouse gas emissions
19 Jun 2017
Dear European Commission,
Dear Lady/Sir,
Thank you very much for the Evaluation and FC roadmap sent to me.
I read the roadmap, understood the content of text and graphics.
I agree with the three general and five other objectives, I agree with the justification and subject matter.
I agree with the issues to be examined and the basis for proof of verification.
I also agree with the need for innovation and thus the actions that are needed to achieve the set goals.
It is very important to carry out this review and make it a reality in the CAP and in its areas by the end of 2020.
Based on the roadmap, I am connected to the Mixed category and thus to the point "How to achieve the goals" (B.3) "How the objectives were to be achieved" in the roadmap.
In order to achieve these goals, I will inform the European Commission of the following:
In the framework of innovation, there is the carrying out of an engineering innovation activity enabling the timeline (B.2) "Original objectives of the intervention" to achieve the initial objectives of the intervention.
This innovation technology, process can greatly contribute to reducing climate change, to the development of a circular economy.
This technology incorporates everything that will make the use of renewable energy sources and the new potential of their use.
Thus, it provides energy efficiency.
It triggers and eliminates high carbon dioxide emissions.
Protect the natural environment and natural resources.
It changes the use of land, in a good sense and advantageously.
It will be innovative and useful in all aspects of European society and in all its sectors.
This innovative technology has come to me in an interesting way.
I also plan to personally and as an engineer afterwards I will use this new application.
I plan to go after in October 2017.
To introduce and present this new environment technological process to the application at EU level and to improve life, I would only like to give it to the European Commission.
But that is my decision and intention not only to me.
This may include the Intervention Logic for Pillar II Pillar II Specific Objectives (Priorities)
Category 1. which the Knowledge transfer and Innovation category.
In my opinion, this new environment technology was brought to me to get to the Commission's attention for usability.
I accept this task as an honor and I have received it.
I have not talked about it and I will not be just the European Commission.
In my opinion, in order to apply this new environmental technology in the European Union, the assessment and control described in this roadmap is needed in all areas of CAP and in all Member States.
I still maintain that money will not be given to the governments of the Member States.
Otherwise, I would put the financial resources provided to the CAP to the parties concerned.
Read full responseResponse to Strategic approach to pharmaceuticals in the environment
8 May 2017
Dear Lady/Sir,
Responding to the roadmap described below, I will give the following answer: The best strategy is to create a flexible approach to the natural environment that is environmentally friendly.
The decision makers adapt flexibly to the environment, not just to the natural environment.
For adaptable decision-making, the choice of decision strategy is influenced by the type of problem, the environment, and personal factors.
Account must be taken of the benefits and disadvantages, the effectiveness and the necessary expenditures when selecting the assets.
The pollutant, the characteristic of the problem situations, determines what kind of decision is to be made in the affected area.
Discerning is important in terms of knowledge and ability required for the solution.
When designing a strategy, it is an important task to adapt to planning, targeting, environmental opportunities and their threats.
The answer to the "how-to" is influenced by other factors other than those described above.
Read full responseResponse to Interim evaluation of the Rights, Equality and Citizenship Programme (2014-2020)
25 Apr 2017
Dear Lady/Sir,
Thank you for sharing your roadmap with our Organization.
What the roadmap is about and what its purpose is in agreement.
There is still a need to raise the rights of the European Union to citizens of the Member States and thus to European citizens.
But it is also necessary for people from third countries to get to know their European Union rights if they want to live in the European Union.
Everyday experiences show that people do not yet have access to the rights granted by the European Union.
We can now contribute to your further work so we can draw your attention to the following:
To roadmap (B.2): Achieving the General Purpose.
The A-B-C-D-E-F points have become less problematic in the public administration offices and administrative offices of the Member States.
G-H-I points are a problem for people in their every day life, in their office administration. Not knowing the existence of their EU rights, not their knowledge.
If people do not know their EU rights then they can not live with these rights to enforce these rights.
(B.3) For the purpose of achieving the objectives.
In our opinion: By personal exemplification, by every person whose task is to make people's personal and official affairs.
(C.2) Questions to be examined.
Further information on EU citizens is still needed on EU rights and their rights.
Because there are people who know about their rights, but this information is slowly getting to the majority.
Slowly, but once every citizen of the Union understands their rights to them.
As mentioned above, the EU's intervention on this legal activity remains necessary.
To roadmap E point, our Civil Society was in related of the Hungarian Equal Treatment Authority - invited our Organization leader, the organizer of the Office, the events of the Office - our audience - to invite our Organization to take part.
We would be happy to cooperate with all interested parties on behalf of the European Union in order to get acquainted with all interested parties - European Union law, such as fundamental rights, environmental law and competition law. Our Organization does not offer itself in Hungary at any level and in cooperation with any Institution.
Only on the basis of a delegation by the European Union institutions could we be able to cooperate in the interest of the European Union and its citizens.
In the meantime, our daily mission is to personally provide information to Union citizens seeking access to the Organization.
We used to go to the Hungarian authorities for the sake of the citizens, but because we have only achieved the citizenship of the Hungarian citizen - who is a Hungarian citizen - we have asked for help from the European Commission for the enforcement of the law, we have been abandoning our activity for the time being.
Our organization helped, for example, to Hungarians who moved from Romania - but they have moved back to Arad. We have been involved in organizing a Hungarian entrepreneur - French trade dispute. Nowadays, Hungarian people continue to fight with each other, or the Hungarian office with the Hungarian people or vice versa.
Conclusion: There is a great need for the involvement of the institutions of the European Union, so that everyone has access to its European Union law - no matter whether natural persons or legal entities are concerned -.
Read full responseResponse to Interim evaluation of the Justice Programme (2014-2020)
23 Apr 2017
Dear Lady/Sir,
I’ve read the 6 page annex of Justice Programme.
I also perceive the lack of recognition of the rights of the European Union - Community law - at national level, including at all levels of the judicial service.
Many citizens complain about their lack of European Union rights.
The Member States do not apply these Community law in their offices because they are not familiar with officials.
A concrete example is the case where a customer wants to live in the European Union, working in a Member State. He claims to have told him that this can not be.
To this we gave the citizen of a Member State the right to move, reside and work as a fundamental right of the European Union.
There is a lot of legal breach of the EU citizen in his own country.
The Member State creates superfluous laws and says that the Union has brought these stricter laws. Especially in the field of environmental protection, in the Common Agricultural Policy, in the field of waste management, water management and water use.
My suggestion: It is not the creation of new laws, but the existing one the enforcement and application of European Union law in the Member States,
from the offices to the citizens.
Read full responseResponse to Revision of the Written Statement Directive
29 Mar 2017
I sent this proposal to the initiation of a review.
Read full responseResponse to Council Recommendation on Common EU Values
17 Mar 2017
I send my proposal as an attached document.
Read full response