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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
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
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
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.

Policy Submissions
15 Nov 2012

Recommendations to SBSTA-37

This paper outlines key issues under discussion at the 37th Session of Subsidiary Body for Scientific and Technological Advice (SBSTA). Carbon Market Watch provides recommendations in particular to the following agenda items on CCS, LULUCF and new HCFC-22 facilities.

Policy Submissions
15 Sep 2012

Submission to call for input: Sectoral Approaches – Emissions from international aviation and maritime transport (CAN-International)

This submission presents the views of the Climate Action Network on issues related to addressing emissions from international transport. Carbon Market Watch highlights the need for careful assessment of international offset credits shall these be considered as an option for international transport mitigation efforts.

Policy Submissions
12 Apr 2012

Submission to the European Commission on “Including maritime transport emissions in the EU’s greenhouse gas reduction commitment”

CDM Watch welcomes this opportunity for input and stresses the need for the EU to act promptly and address shipping emissions in the EU to halt climate change below 2°C while it needs to take responsibility as a climate leader and influential party in the development of future international climate systems. Often EU’s decisions have served as blueprints for decisions on UN level. We believe that any legislation including shipping in the EU’s climate policy must reflect the best possible option capable to deliver real reductions within the sector first and with the highest possible environmental integrity while delivering real contribution to sustainable development. Our main comments include: 1) no international credits should be allowed into a maritime sector, 2) revenues for climate finance for abatement in the maritime sector should not come from selling international offsets and 3) at least 50% of revenues should be directed to the Green Climate Fund.

Policy Submissions
28 Mar 2011

Submission to call for input (SBSTA): Inclusion of Forest in Exhaustion in the CDM

This submission regards the proposal to include forest in exhaustion in the CDM to be little more than an attempt to provide subsidies to industrial tree plantations in circumstances that encourage bad management practices and the establishment of plantations in inappropriate locations. Such a subsidy would insulate the wood growing and processing industries from commercial pressures to improve their efficiency, reduce wastage, increase recycling and select more suitable sites for plantation establishment. The “forests in exhaustion” proposal also risks undermining the recently established REDD+ mechanism by incentivizing the establishment of plantations under the CDM rather than the restoration of natural forest ecosystems under REDD+.