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 by the Commission in the Inception impact assessment are therefore unhelpfully limiting the scope of the impact assessment and risk to seriously damage the EU’s climate architecture and undermine emission reduction policies that have already proven successful in Europe.
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