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Policy Submissions
10 Apr 2020

Carbon Market Watch’s feedback on the inception impact assessment on the Carbon Border Adjustment Mechanism

Carbon Market Watch fully supports efforts to price GHG emissions, within and outside the EU.  The EU ETS has been successful for certain sectors, but has failed to incentivise large scale decarbonisation of European industry, in part because of its excessive measures to guard against the hypothetical risk of carbon leakage. Industrial companies have gained…

Policy Submissions
11 Mar 2020

Carbon Market Watch input to public consultation on draft ETS state aid guidelines

Given that there is as yet no hard evidence of carbon leakage caused by indirect costs passed through by power companies, Carbon Market Watch cannot support using taxpayer money to protect the industry from an unproven “carbon leakage risk”. Indirect cost compensation, coupled with free allocation of emission allowances, undermines the polluter pays principle and…

Policy Submissions
14 Jun 2019

Carbon Market Watch’s briefing note for the June 2019 Bonn UNFCCC session

Dear respected colleague, Ahead of the Bonn Climate Change Conference 17-27 June 2019, Carbon Market Watch is pleased to share our recommendations for Article 6 negotiations. Strong rules to avoid double-counting of emission reductions There is a significant risk that emission reductions under the Paris Agreement could be counted towards two or more climate commitments…

Policy Submissions
10 Apr 2018

Carbon Market Watch’s response to the public consultation on the EU ETS Innovation Fund

Europe’s energy-intensive industries need an urgent transformation in order to dramatically reduce their emissions in line with the Paris climate goals. This is far from the reality: EU industrial emissions rose by 2% in 2017 and projections show that they are not expected to decline up to 2030. One of the more challenging elements of…

Policy Submissions
31 Jan 2018

Submission on methodology to determine the list of sectors and subsectors deemed exposed to a significant risk of carbon leakage

This feedback was submitted to the European Commission, expressing Carbon Market Watch’s views on the inclusion of sectors on the carbon leakage list of the EU Emissions Trading System (EU ETS). The carbon leakage list identifies all sectors which are deemed by the Commission to be at risk of leakage, i.e. the geographical displacement of…

Policy Submissions
15 Nov 2017

Response to impact assessment of the carbon leakage list for the period 2021-2030

The assessment of the carbon leakage list for the post-2020 period will need to be informed by the performance of the carbon leakage provisions to date. So far, the excessively generous handout of free permits has resulted in over 25 billion euros windfall profits (e.g. the polluter has been paid, rather than having been made…

Policy Submissions
6 Feb 2017

How the EU ETS can incentivize cement’s low-carbon transition

On 14 February 2017, the plenary of the European Parliament will vote on the revision of the EU Emissions Trading System (EU ETS) for the 2021-2030 period. Members will vote on the report of the environment committee (ENVI) which was adopted in December 2016. A key element of the compromise reached between all major political groups in ENVI is the introduction of a mechanism that requires importers of cement and clinker to also pay for their pollution, while ensuring that carbon costs are reflected in material prices.

Policy Submissions
4 Nov 2016

Recommendations for APA Items 3, 5 and 6 as they relate to the market-based measure established by ICAO

Carbon Market Watch welcomes the opportunity to provide input to the APA discussions[1] as they relate to the market mechanism agreed in October 2016 at the International Civil Aviation Organization (ICAO) 39th Assembly and adjustments needed to accurately harmonize the climate measure with ongoing work in the UNFCCC.

Policy Submissions
31 May 2016

Consultation to the EU Commission: How to reconcile the Global Market Based Mechanism with the EU Emissions Trading System

Following the Paris Agreement and considering the agreed long-term goal, what kind of effort should come from international aviation and how should this develop over time? The international CNG2020 goal should be legally binding and enforced from the start of the GMBM in 2021. In the future, the cap should then be progressively tightened and…

Policy Submissions
17 Jun 2015

Carbon Market Watch response to the EU consultation on addressing greenhouse gas emissions from agriculture and LULUCF in the context of the 2030 EU climate and energy framework

1. In your view, which of the multiple objectives of agriculture, forestry and other land use will gain most in relative importance by 2030?

It will be critical to ensure the long-term stability of carbon pools for carbon storage, biodiversity protection and ecosystem preservation in the future. Currently the emissions from land use represent a quarter of all human emissions and it is hence vital that the land use sector also contributes to tackling climate change.
The use of biomass is limited due to finite land availability and therefore the use of biomass should follow the cascading hierarchy and only as a last resort be used for lower-quality applications where other viable alternatives exist, which is the case with power generation.
Finally, it should be recognised that food security and sustainable farming should go hand in hand. Actions that support this include no-till farming, silvopastoral practises and demand-side measures to limit excess consumption.