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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 Effort Sharing Regulation (ESR)

We regret that the Commission did not include a policy option that would ensure the current climate policy architecture is maintained in order to raise the emission reductions achieved by the Effort Sharing Regulation (ESR), Emissions Trading Scheme (ETS), and the LULUCF Regulation as three separate but mutually reinforcing policy instruments. The three options presented…

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
25 Jun 2020

Carbon Market Watch response to public consultation for the EU climate ambition for 2030

EU climate policymaking should be informed and aligned with the latest available science and the EU’s commitment under the Paris Agreement, in particular the objective of limiting global temperature rise to 1.5°C. In light of the EU’s capacity to act and principles of global equity, the Union should achieve at least 65% emission reductions by…

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
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…