Noutăți Our Feedback to EC 14 April 2022

Have your say - Environmental crime

You can also get involved in forming EU laws. The European Commission would like to hear your views on laws and policies currently in development. They offer a platform "Have your say" with the list of all new EU initiatives open for public consultation. You need to register to write your feedback.

https://ec.europa.eu/info/law/better-regulation/have-your-say

There are always 5 stages of each EU initiative, each stage is open for public consultation for a specific time frame:

In preparation
Call for evidence
Public consultation
Draft act
Commission adoption

Environmental crime – improving EU rules on environmental protection through criminal law

About this initiative: The Environmental Crime Directive aims to protect the environment through criminal law, appropriate sanctioning and cross-border cooperation. The Commission recently evaluated the Directive, and found that it did not meet its objectives.

Feedback period: for stage 5 it was 15 December 2021 - 21 April 2022

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12779-Environmental-crime-improving-EU-rules-on-environmental-protection-through-criminal-law_en

Feedback from Europeans for Safe Connections

We "Europeans for Safe Connections" welcome this update of the Directive 2008/99/EC.

Page 6/69: We are happy that the Commission has identified new offence categories currently not covered by the Directive. However, we would like to add three more:

- operating RF EMF in nature reservations
- operating RF EMF in nature generally
- launching, operating and destroying satellites above the territory of EU

Page 30/69: We are happy about the Article 3, Offences, (1)(d)
stating that each unlawful and intentional execution of project without environmental assessment is a criminal offence as referred to in Article 1(2)(a) of Directive 2011/92/EU.

We would like to emphasize that 5G deployment and all telecommunication projects are also PROJECTS and therefore must be assessed environmentally. We suggest including point (i) under section Article 3(1)(d)
• (i) including 5G deployment and all telecommunication projects

Page 33/69: We are happy about the Article 3, Offences, (1)(o)
stating that criminal offence is any conduct which causes the deterioration of a habitat ...

We would like to emphasize that RF EMFs cause significant deterioration of a habitat. We suggest including point (i) under section Article 3(1)(o)
• (i) including man-made RF EMFs of any intensity lasting more than 24 hours

Page 38/69: Article 11, Limitation periods for criminal offences (2)(a),(b) and (c)
We strongly suggest changing the formulation of the part: "... from the time when the offence was committed ..."
as following:
"... from the time when the committed offence has ended ..."

Explanation: Imagine the toxic waste was hidden in the forest 20 years ago and it is still there. The crime is continuos and must be punishable now even if it started 20 years ago. The same applies to the telecommunication mast still standing and emitting, no one cares when exactly it was built.