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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 Jan 2020

Carbon Market Watch input to a public consultation on the circular economy action plan

Carbon Market Watch welcomes the European Commission initiative to develop a New Circular Economy Action Plan. The Roadmap of this initiative is presented in view of the European Green Deal and the contribution of the EU’s industry to achieve a climate-neutral continent by 2050. It is therefore crucial that the Circular Economy action plan to…

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
5 Sep 2019

Carbon Market Watch input to public consultation on the Industrial Emissions Directive

Carbon Market Watch would like to draw attention to the following shortcomings of the Industrial Emissions Directive (IED): -The environmental impacts of greenhouse gas (GHG) emissions are not addressed by the IED, which is a major gap in the Directive aiming to prevent and control pollution arising from industrial activities. Article 9(1) of the IED…

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
12 Feb 2019

Comments on the regulatory proposal of Environment and Climate Change Canada for The Output-Based Pricing System regulations under the Greenhouse Gas Pollution Pricing Act

Carbon Market Watch (CMW) welcomes the opportunity to submit comments on the OBPS regulations under the GGPPA which entered into force on June 21, 2018, and would like to formulate comments as below. 1. Carbon leakage and the calculation of the emissions limit We express strong concerns with the decision to revise the starting point of the…

Policy Submissions
29 Nov 2018

Recommendations for SBSTA49 agenda item 11(b) as it relates to rules, modalities and procedures for the mechanism established by article 6.4 of the Paris Agreement

Prepared for the Subsidiary Body for Scientific and Technological Advice 49th meeting, COP24, Katowice In determining the rules, modalities, and procedures for Article 6.4, it is imperative that Parties learn from past experiences and strive for this mechanism to contribute to greater ambition. Specifically, lessons should be drawn from the Kyoto Protocol’s carbon offsetting mechanisms,…

Policy Submissions
29 Nov 2018

Recommendations for SBSTA49 agenda item 11(a) as it relates to the guidance for cooperative approaches referred to in article 6.2 of the Paris Agreement

Prepared for the Subsidiary Body for Scientific and Technological Advice 49th meeting, COP24, Katowice As part of the Paris Rulebook discussions at COP24, further elaborations are needed on the rules for article 6. Guidance for cooperative approaches under article 6.2 is an important element of these rules, and will need to be determined in a…

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…

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…