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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
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 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
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
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,…