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Policy Submissions
30 Mar 2021

Carbon Market Watch’s response to the public consultation on the revision of the Industrial Emissions Directive

Carbon Market Watch fully supports the comprehensive feedback provided by the European Environmental Bureau to the revision and welcomes the opportunity to give specific views on how the Industrial Emissions Directive (IED) should be revised to support industrial decarbonisation in a complementary manner to the EU Emission Trading System.   While we support the general direction…

Policy Submissions
12 Feb 2021

Carbon Market Watch’s response to the public consultation on the EU Emissions Trading System (EU ETS) review

Summary The EU Emissions Trading System (EU ETS) covers around 40% of the EU’s greenhouse gas emissions from more than 11,000 installations and airlines.  As part of the EU Green Deal implementation, the scheme will be revised starting in the summer of 2021. The revision is a crucial opportunity to ensure that the sectors covered…

Policy Submissions
3 Dec 2020

Carbon Market Watch response to Inception Impact Assessment on the EU ETS

Key elements for the revision of the EU ETS The upcoming revision of the EU Emission Trading System represents a crucial opportunity to strengthen the Directive and ensure it contributes to the goals of the Paris Agreement.  Carbon Market Watch believes that the upcoming review should include the following elements.  An increase of the Linear…

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
5 Apr 2020

Carbon Market Watch’s feedback to energy taxation directive impact assessment

Carbon Market Watch welcomes the opportunity to provide feedback on the ETD revision. Several aspects of this directive are crucial to set the EU on a  pathway compatible with the Paris Agreement’s objectives. Carbon Market Watch supports the revision of the Directive, in particular with regard to the aim of “aligning taxation of energy products…

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
28 Sep 2019

Carbon Market Watch input to public consultation on Horizon Europe

With a proposed budget of 100 billion euro from 2021 to 2027, the Horizon Europe framework programme represents the largest collaborative multinational research and innovation (R&I) investment in Europe. A Strategic Plan will put forward the targeted impacts for the investment in research and innovation and the priorities for the first four years of implementation…

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
8 Dec 2018

Reflection Note on the necessity for stakeholder consultations, avenues for redress, and environmental and social safeguards under Article 6 of the Paris Agreement

Introduction Article 6 of the Paris Agreement creates mechanisms that allow for Parties to engage in cooperative approaches to achieve emission reductions and contribute to the implementation and progressive revision of NDCs. As Parties gather at COP24 to finalize the implementation guidelines, they need to ensure that any mechanism created under Article 6 does not repeat the mistakes of…

Policy Submissions
27 Apr 2018

Recommendations for the Article 6.4 of the Paris Agreement

Prepared for the Bonn Climate Change Conference 30 April – 10 May 2018 In elaborating the rules, modalities, and procedures for Article 6.4, it is imperative that Parties learn from past experiences with the Kyoto Protocol’s carbon offsetting mechanisms Clean Development Mechanism (CDM) and Joint Implementation (JI), and integrate provisions to ensure environmental integrity, foster…