Lubin, 20 August 2020

ZPPM / 78 / VII / 2020
 
European Commission
Directorate-General for Climate Action (DG CLIMA)
Unit A3- Adaptation
B-1049 BRUSSELS
Belgium
Public consultation: Ref. Ares(2020)2509310 – Adapting to climate change – EU strategy
  
Commission Work Programme/ Inception impact assessment (European Green Deal Strategy for Adaptation to Climate Change) – Ref. Ares(2020)2509310 – Adaptation to Climate Change, Blueprint for a new, more ambitious EU strategy
 

Employers’ Organization of Polish Copper position on European Green Deal Strategy for Adaptation to Climate Change

Employers’ Organization of Polish Copper welcomes a European Green Deal to put Europe on the right track to a sustainable future and is prepared to take the necessary measures to make it the world’s first climate neutral continent.
As the representative of the Polish metals mining, processing and smelting industry, we welcome the Commission’s renewed EGD Strategy for Adaptation to Climate Change as a part of actions for a greener and cleaner economy. We are committed to substantially contribute to climate change adaptation. We also believe that an updated Strategy for Adaptation to Climate Change should focus both on prioritizing policy areas and actions where EU interventions can be most effective as well as on assessing how to increase ambitions in a manner that best contributes to sustainable growth and enhances economic competitiveness.
The European & Polish metal mining industry plays a critical role in underpinning economic growth. The development of mineral resources is a pillar for many national economies, in terms of contribution to gross domestic product, foreign direct investment, tax & royalty revenues as well as other governmental revenues. Even more, the mining industry produces more than 42 different metals and minerals and employs 350.000 people directly and about 4 times as many indirectly. Modern extraction and processing of minerals and metals has brought huge benefits to society while reducing pressures on the environment, addressing green-house gas emissions, tackling pollution, minimizing waste and improving efficiency in the use of natural resources. Even more, the mineral industry will continue to enable downstream sectors to realize all these improvements.
The first segment of most value chains, the raw minerals sector is a supplier of critical materials and products to many sectors of the economy. With regards to climate change adaptation, the European minerals sector secures the availability of essential materials needed for a climate neutral, service and welfare orientated, circular and resource efficient economy. For example, the new infrastructure for alternative energies requires an increased use of metals and minerals, in particular steel for pipelines; copper and graphite for electricity cables, generators and electric motors; aluminium, primarily for electricity cables; and a host of other metals and minerals including phosphorous, potassium and nitrogen for biomass production. Also, solar photovoltaic panels and thermal systems use a combination of up to 22 non-ferrous metals, silicon, chemicals (e.g. organic electrolytes) and a specific type of flat glass.
All European strategic value chains are related to the two main drivers of industrial transformation – the transition to a climate-neutral economy and to a data-driven economy. They are directly linked to improving competitiveness, fighting climate change, and enhancing technological development.
And all of them will inevitably require raw materials: not only those that are currently being tagged as “critical”, but also huge amount of base metals such as copper, aluminium, silver, lead and others.
Europe’s metal producers are switching to clean electricity more than any other energy-intensive industry as one of the world’s leading environmental champions. Compared to 1990 levels, the European non-ferrous metal industry already reduced its greenhouse gas emissions by 61% in 2015.
Without the products of the European non-ferrous metals industry, the ongoing technological revolution around us would be much slower and much smaller than what we are all used to in recent years.
For example, about 15-20 tonnes of copper are needed to produce one 2 MW wind turbine, while the construction of a 1 MW solar power plant requires between 3.1 and 4.5 tonnes of copper. Another opportunity for copper is electro-mobility – up to four times more copper is needed to manufacture an electric vehicle than a combustion car, and another area of application is vehicle charging infrastructure.
As early as 2017 the World Bank predicted that by 2050, the growing production of wind turbines will require 300% more metals, 200% more metals for solar panels and 1000% more metals for battery production.
Other future metals are molybdenum and rhenium. The first is widely used in the aerospace, defence, oil, nuclear and electronics industries – more than two-thirds of production is used as an additive in alloys, mainly in high-strength and high-temperature steels. On the other hand, rhenium, of which KGHM is the only European producer, is used, due to its very high melting point, for the production of jet engine turbines, gas turbines and covers for space vehicles. Silver and palladium are also used in the electronics industry and in medicine.
A continuously changing climate generates a series of risks to mining operations especially because these industries are often located in challenging geographic areas, they rely on fixed assets with very long lifespans, include global integrated supply chains and must deal with environmental and climate sensitive resources. Increased temperatures, changes in precipitation, sea level rise, earthquakes and extreme events have already become stressors with the potential to negatively affect the mining activity.
The Polish metals industry is already dedicated to identifying and assessing risks so that disruption and damage arising from acute or chronic effects of climate change are minimized. At the same time, we actively contribute and support all stakeholders along the value chain to:

• improve knowledge of climate impacts (e.g. through increased awareness and better access to knowledge of individual and collective climate risks);
• reinforce planning and climate risk management in the public and private sector (e.g. through risk assessments and helping to close the climate protection gap via risk-transfer mechanisms);
• accelerate action with a focus on solutions (in addition to understanding), on deploying innovation (in addition to research), on implementation (in addition to planning), and on prevention (in addition to ex-post).

European Green Deal will require more copper, here are the reasons:
Renewables
Copper plays an important role in renewable energy solutions – such as solar, wind, todal, hydro, biomass and geothermal – by improving their overall performance. For example a 3 MW wind turbine contains up to 4,7 tons of copper. In case of solar energy due to its intrinsic characteristics copper has always been the material of choice for the efficient extraction of electricity from solar cells. Relatively thick but soft copper is preferred for use in silicon cells to reduce fragility, and because soft copper offers faster throughput and better low yield strength.
Energy efficiency
Copper has the highest electrical conductivity of any metal, after silver. Products containing copper (e.g. engines) tend to operate more efficiently, with typical cost-effective reductions in energy use in the range 20-30%.
Transportation
Beyond the energy sector copper is also key component in new, low-carbon modes of transportation, such as electric vehicles, playing an important role in their batteries and control systems as well as charging infrastructure. An electric car contains on average almost four times more copper than its counterpart with a combustion engine (83 kg to 23 kg).
Energy footprint
Compared to 1990 levels the European copper industry has managed to reduce its per-unit energy consumption by 60%. Emissions from copper production in Europe are now very modest at 0.4% of total EU greenhouse gases emissions.
Copper’s circularity
In addition copper is 100% recyclable and can be used over and over without losing its engineering properties. Copper is also a carrier of valuable metals present in electronics, batteries (cobalt for instance, is as a key by-product of copper metallurgy – 60% of cobalt production; other metals accompanying copper are, inter alia, nickel, silver and gold).
Greening  by  European  mineral  products  also  trigger  emission  reductions  in  other  sectors  of  the  economy.
Furthermore, in November 2018 the European Commission underlined the importance of continuing exploration and extraction in its document, A Clean  Planet  for  all,  a  strategic  long-term  vision  for  a  prosperous, modern, competitive and climate-neutral economy by 2050. “Raw materials are indispensable enablers for carbon-neutral solutions in all sectors of the economy. Given the scale of fast growing material demand, primary raw materials will continue to provide a large part of the demand.”
We believe that efforts, climate ambitions and targets should be aligned with the fundamental principle of sustainable development, ensure the essential current needs and safeguard the needs of future generations while contributing to the economic, social and environmental development. Therefore, the 2030 Climate Target Plan should carefully assess how to increase the ambition in a manner that best contributes to sustainable and inclusive growth and enhances economic competitiveness through accelerating innovation and developing Europe’s industry. Climate transition and competitiveness must go hand in hand. It is crucial that in the transition to become climate neutral, the industry can maintain and even improve competitiveness.
According to estimates, European industries need to invest €250 billion on an annual basis for the next ten  years  in  order  to  stay  on  track  with  the  2050  climate  neutrality  objective. The  mineral  raw materials  industry  is  already  a  front  runner  and  has  already taken several  measures  to improve its energy  efficiency  and  decrease emissions. Our  industry  is committed  to  take  the  step  to  net-zero emissions but there is a need for financial support. Also, electrification is key for many industries to reach their climate target, which requires access to fossil-free electricity at competitive prices and the reimbursement of indirect costs for industries facing higher electricity prices. The financing instruments at EU and Member States level should continue  to  be present and to facilitate investments. Support for development, piloting and up-scaling of key innovative decarbonisation and energy efficiency technologies is still needed.
It is our belief, that the different EU Green Deal related pieces of legislation should be coherent, holistic, ensure stability and avoid overlapping on a medium and long term, especially when it comes to the relation energy efficiency and/or the emissions trading system (ETS). They should complement each other in supporting the industry to become climate neutral by getting the incentives right. Many industrial players already have committed through their recent industrial roadmaps to achieving the objective of a climate-neutral Europe by 2050 and have already set several plans and strategies in place. A close dialogue with the industrial sectors about what measures is most effective in supporting their roadmap to climate neutrality.
According to estimates, European industries need to invest €250billion on an annual basis for the next ten years to stay on track with the 2050 climate neutrality objective. The mineral raw materials industry is already a front runner and has already taken several measures to improve its energy efficiency and decrease emissions. Our industry is committed to taking the step to net-zero emissions but there is a need for financial support. Also, electrification is key for many industries to reach their climate target, which requires access to fossil-free electricity at competitive prices and that indirect costs for industry of a higher electricity price is considered. The financing instruments at EU and Member States level should continue to be present and to facilitate investments. Support for development, piloting, and up-scaling of key innovative decarbonisation and energy efficiency technologies is still needed. The EU must open itself to cooperation worldwide. Countries that are increasing their reduction commitments should be included in Europe’s emission-reducing cooperation. At the same time, the World Bank and the Green Climate Fund should support developing and emerging countries.
The COVID-19 outbreak, which is first and foremost a sanitary crisis, has put the EU economy in a very critical situation. This makes a comprehensive recovery strategy absolutely necessary, one that considers environmental, social and economic aspects in a mutually reinforcing way. It also increases the investment demand for a more sustainable and resilient economy, and reminds the central role of companies in ensuring the resilience and dynamism of European economies and their role in society.
Employers’ Organization of Polish Copper welcomes a European Green Deal to put Europe on the right track to a sustainable future and believes that our common climate actions should carefully assess how to increase the ambition in a manner that best contributes to sustainable and inclusive growth and enhances economic competitiveness through accelerating innovation and developing Europe’s industry. It is crucial that in the transition towards becoming climate neutral, the industry maintains and even improves its competitiveness.
 
Yours sincerely,
Beata Staszków, President of the Board/ Chief Executive Officer
Position based on documents by: KGHM, Euromines, BusinessEurope