Mr Artur RUNGE-METZGER

Head of Climate Strategy, international negotiation

And monitoring of EU Action

30 November 2007

Dear Mr Runge-Metzger

The UK Inter-Agency Climate Change Forum[1] (IACCF) welcomes the European Commission’s Green Paper Adapting to climate change in Europe – options for EU Action.

Regardless of the robustness of emission reduction targets, we are committed to several decades of climate change, arising from past emissions, the effects of which cannot now be prevented. We have no option but to prepare and adapt to those impacts which are now unavoidable and already happening.

In our view, the Green Paper is an important step in the right direction, as it demonstrates that climate change is being correctly recognised by policy makers as a ‘double challenge’ – to both reduce greenhouse gas pollution in order to minimise the risk of dangerous climate change and also to take action to adapt to unavoidable climate impacts.

Following on from the Green Paper, the IACCF would like to see the European Commission produce a White Paper which will drive pan-European action in response to the challenge of climate change adaptation. In our view, the White Paper should include the following three actions:

Set out the rationale and necessity for EU action on adaptation – robustly affirming the case for the EU to have a clear and defined role;

Propose establishing a EU-wide framework to inform and add value to the delivery of adaptation by Member States – the framework should include a programme of action to mainstream adaptation into the EU’s existing and future mechanisms;

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The Joint Nature Conservation Committee (JNCC) is the statutory adviser to Government on UK and international nature conservation, on behalf of the Council for Nature Conservation and the Countryside, the Countryside Council for Wales, Natural England and Scottish Natural Heritage. Its work contributes to maintaining and enriching biological diversity, conserving geological features and sustaining natural systems.

Prepare over-arching principles on which to base the adaptation framework, in which the natural environment is central.

These three points are embellished in the annex to this letter. We also enclose our response to the consultation on the adaptation Green Paper.

Yours Sincerely,

Marcus Yeo

Director of Resources and External Affairs

Michael Usher

Chair of Inter-Agency Climate Change Forum

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Registered office: Monkstone House, City Road, Peterborough, Cambridgeshire PE1 1JY

Annex A. Actions for the EU White Paper on Adaptation

Rationale and necessity for EU action

The impacts of unavoidable climate change both now and in the future will be widespread and significant. The physical and biological systems which are the foundations of human society and economy will be affected worldwide. Europe will not be spared: climate change will heavily affect the natural environment and all sectors of society and the economy across every MemberState.

Climate impacts will differ across Europe’s geographical regions and sectors. Some areas will face marked changes in temperature and water availability as a direct result of global warming. Increasing frequency, severity and unpredictability of extreme events is likely to be the most significant impact in many areas. Other areas will experience indirect impacts, such as changes to land use or increased migration, as a consequence of changing climatic conditions. As such, there will be different challenges in different parts of Europe, as well as opportunities, which will each need distinct adaptation responses. One size will clearly not fit all.

There will inevitably be tensions between regions and sectors with respect to EU resources and policy. An example, provided by Professor Martin Parry at the Green Paper stakeholder workshop in London, is the projected social, economic and environmental impacts of decreased water availability in southern and central Europe. The implications will be far-reaching across Europe, for example resulting in increased pressure for food production and possibly migration in the north, and will require a Europe-wide policy response.

The rationale for an EU approach for adaptation is therefore entirely consistent with the principles of the EU’s existing objectives on convergence, competitiveness and co-operation, as defined in cohesion policy and articulated by the Lisbon agenda.

Furthermore, to be effective many adaptation responses will have to take a Europe-wide approach. A good example is the need to build resilience for biodiversity through strengthening the Natura 2000 network. Similarly, cross-boundary approaches will be central to effective adaptation in the water and marine sectors.

We fully acknowledge and support the view that MemberStates (and their regions) will be the major delivery bodies of adaptation measures on the ground, especially through the land-use planning system which is not an EU competency. All Member States should, in our view, be encouraged to prepare cross-sectoral national adaptation programmes which will facilitate and guide regional delivery, as is proposed in the UK with the Climate Change Bill.

However, the varied and wide-ranging nature of climate impacts across Europe means that sustainable adaptation cannot be delivered solely at the MemberState level. There is a clear need for a Europe-wide approach, so that adaptation responses are holistic, cross-boundary and multi-sectoral.

There is therefore a distinct leadership role for the EU to play in adaptation. Indeed, adaptation to climate change must be recognised across the Commission, Parliament and Member States as one of the EU’s most important, fundamental and defining rationales in the twenty-first century.

It is imperative that adaptation is not perceived as only being an issue of direct relevance to one or two Commissioners, but is recognised as the collective responsibility of all of the EU’s institutions.More work is needed by the Commission in developing the White Paper to ensure that the strong rationale for EU action on adaptation is made clearer and given more weight.

Establishing a EU framework for adaptation

Adaptation cuts across sectors and disciplines. Without a clear EU framework, there is a major risk that adaptation responses across Europe will at best be ad hoc, and at worst lead to conflicting or damaging outcomes. Key to this framework will be finding solutions that incorporate flexibility and adaptive management to help manage uncertainty, and that follow the precautionary principle, so that options for society are kept open, and natural systems are allowed to respond to change. The framework should integrate the need to reduce greenhouse gas emissions so that adaptation does not compromise mitigation nor vice versa. Options appraisal will be an important tool in finding the best measures and can also be used to assess the carbon intensity of proposed solutions.

The IACCF believes that the EU should develop an over-arching framework which will inform and guide the delivery of adaptation across Europe by the EU’s own mechanisms and by Member States. Such a framework would not duplicate the national programmes being developed by Member States, but help to inform, guide and add value to them.

The framework will need to set out a coherent EU-wide message on adaptation. In doing so, it will drive co-ordinated and consistent action by Member States whilst fully recognising that responsibility for much of the delivery of adaptation measures will be at MemberState level.

An EU framework will add value to Member States’ own programmes by expanding the knowledge base on climate impacts and vulnerability, coordinating information-sharing between MemberStates and sectors, and developing and demonstrating best practice.

We do not suggest such a framework should be legislative, as this would be an overly rigid and inflexible response that would risk putting adaptation into a separate box when it requires a cross-sectoral, cross-thematic and cross-boundary approach.

However, we strongly believe that the framework should put in place an immediate programme of action to ensure that all EU institutions, mechanisms, legislation and funding programmes are contributing tosustainable adaptation.

The EU has competency in a number of sectors that are likely to be directly impacted by climate change, notably agriculture, forestry, water and energy infrastructure. These sectors, as well as cohesion policy, including transport infrastructure, are also likely to impact upon the capacity for both society and wildlife to adapt to climate change. There is therefore a clear role for the EU to take the initiative and demonstrate leadership by directly contributing to the delivery of adaptation through its existing mechanisms.

The Green Paper recognises the importance of early action to mainstream adaptation into the EU’s own legislative and funding mechanisms. We fully support this goal. In our view, it is essential that the White Paper sets out a clear timetable to:

evaluate the degree to whichexisting mechanisms are currently contributing to delivering adaptation or where they are resulting in mal-adaptation, and identify areas where existing mechanisms could be or need to be improved and/or new mechanisms developed to ensure better adaptation;

develop implementation guidance for all existing mechanisms and for future mechanisms to strengthen their contribution to delivering adaptation;

commit to making necessary legislative amendments where existing mechanisms need to be strengthened to improve their contribution to adaptation, or where existing mechanisms are directly causing mal-adaptation;

ensure that all future legislation and provisions will directly contribute to delivering adaptation.

We recognise that making legislative amendments risks re-opening previous debates which could result in the significant weakening or revision of legislation. For example, in our view it is extremely important that the evaluation process we are advocating is not used as a vehicle for attempting to de-designate protected areas. Although the Habitats Directive could be strengthened to better deliver connectivity of the Natura 2000 network, maintaining and enhancing existing protected areas, for example, through the provision of buffer zones and/or wildlife corridors, is fundamental to adaptation and must not on any account be weakened as a result of this evaluation. These protected areas will be vital in supporting high-quality habitats both for the survival of biodiversity in the face of unprecedented environmental change, and as the bedrock for maintaining the ecosystem goods and services upon which society and the economy depend.

In our view, the evaluation process described above should be seen not as a wide-scale review of all EU mechanisms, but as a relatively light-touch mainstreaming exercise. Where existing mechanisms are already making a positive contribution to adaptation (albeit indirectly and/or unintentionally) there is no need to seek formal amendments. In most cases, the preparation of implementation guidance for delivering adaptation is likely to be sufficient.

Intervention should only be necessary where there is a clear need to strengthen a mechanism so that it can make a significantly improved contribution to adaptation, or where a mechanism is currently a barrier to sustainable adaptation.

We have some concerns that mainstreaming in other EU programmes has not always been successful or effective in the past. There is a risk that climate change adaptation may also not be effectively mainstreamed, especially if it is perceived to only be an ‘environmental’ issue. As we noted in our first headline message above, it is imperative that adaptation is recognised as being integral to the EU’s core purpose and rationale. The White Paper must ensure that adaptation goes beyond the EU’s environmental competencies and reaches across the full range of its functions. In our view, this is why an EU framework is necessary.

Setting out adaptation principles

Our final headline message is that the White Paper must set out the key principles which will form the basis of an EU adaptation framework.

These principles must be based on the concept of sustainable development and equity and we firmly believe that the natural environment must be central for four key reasons:

Society has placed significant emphasis and resources on the need to protect the natural environment from degradation. Climate change will have major impacts on biodiversity and further exacerbate existing pressures. Action is needed to minimise these threats.

Ecosystems will need to be resilient to climate change impacts in order to maintain the supply of goods and services essential for European society and the economy. A degraded natural environment threatens the life-support systems on which human health and prosperity depend. An ecosystem-based approach, which considers impacts across the ecosystem, should therefore be applied when developing adaptation measures.

Measures to deliver a resilient natural environment will also contribute to wider social and economic adaptation. Examples include ‘soft engineering’ schemes to reduce flood risk, sustainable urban drainage and hydrology, mitigating the urban heat island effect and heatwave stress.

There are a number of adaptation measures for the natural environment that will also contribute to mitigation. Examples include reducing the loss of carbon to the atmosphere from soils and from unsustainable deforestation and increasing sequestration by woodland creation.

The IACCF welcomes and fully supports the Green Paper’srecognition that the natural environment is “at the centre of any adaptation policy”. We believe it is essential that this important point of principle is retained throughout the development of the White Paper.

Recognising that the natural environment is central to adaptation should not mean that climate change is interpreted as just being a ‘green’ issue which is of little relevance to wider sectors of the European economy or society.

The primary economic sectors which utilise natural resources (such as agriculture and food, forestry, fisheries and energy) will be more directly impacted by climatic changes than secondary and tertiary sectors (such as finance, services, tourism and manufacturing). However, the knock-on effects of climate change on degraded ecosystems and natural resources will be felt across all sectors of the economy and therefore across the whole of society. At the Green Paper consultation workshop in London, Professor Martin Parry made this point very clearly when he noted that global food production accounts for approximately 90% of the trends identified when modeling the impacts of climate change on global GDP.

In our view, the Green Paper does not fully capture the magnitude of the threat climate changes poses to the European natural environment. It falls short in three key areas:

Fragmentation: mostimportant wildlife areas are isolated with sharp boundaries between them and adjacent land managed or used for non-wildlife purposes (e.g. built development, transport infrastructure and farmland). Isolated species are unable to move in response to a more rapidly changing climate, which makes them increasingly vulnerable to extinction. As the Stern Review noted: “conservation efforts will increasingly be required to operate at the landscape scale with larger contiguous tracts of land that can better accommodate species movement”. The role that the existing Natura 2000 network of protected sites can play to maintain and enhance connectivity across Europe will need more emphasis in the White Paper.

Existing pressures: there is insufficient recognition in the Green Paper that many habitats and species are already under great strain from non-climate pressures (such as agricultural intensification, eutrophication, habitat loss, invasive species and water abstraction). Climate impacts will generally exacerbate existing trends; for example, water availability will decrease at a faster rate in already dry areas such as the Mediterranean basin. Climate impacts could easily ‘tip the balance’ and threaten the viability of natural systems and the resources they provide.

Indirect impacts: the implications for the natural environment of adaptation and mitigation responses to climate change by different sectors, especially agriculture, forestry, fisheries, flood risk management, tourism and energy infrastructure is not accounted for in the Green Paper. This is a major failing that must be addressed in the White Paper. An example was given by Professor Parry at the London stakeholder workshop, where he noted that demand for food production may shift northwards as southern and central Europe becomes less viable for agriculture due to water shortages. An intensification of agricultural production in the north could bring some initial economic opportunities, but also risks significant environmental damage that could quickly reverse the moderate gains delivered from rural development and agri-environment schemes in recent years.

Our detailed response to the Green Paper consultation questions sets out in more detail the key principles that will need to be delivered for a more resilient natural environment and so should, in our view, be central to the EU’s over-arching adaptation framework.

Annex B. IACCF response to the consultation on the climate change adaptation Green Paper

1) What will be the most severe impacts on Europe's natural environment, economy and society?

Climate change represents the most serious threat to Europe’s natural environment and the ecosystem services (terrestrial, freshwater and marine) upon which European society and economy depend.

Climate change is happening now and we are already observing direct impacts on the natural environment such as changes in the timings of seasonal events, shifts in suitable climate conditions for species, changes to habitat function, and changes in the number and severity of extreme weather events.