The European Commission released on 20 July a proposal for regulating emissions of the non-ETS sectors: the Effort Sharing Regulation (ESR). It was followed by a “feedback period” on which stakeholders could provide comments and suggestions to the proposal. This is T&E’s feedback to the ESR.
An ETS with 85% free allowances, combined with the fuel tax and VAT exemptions, while charging buses and trains and thus distorting competition, is simply self-defeating. Member states and the European Commission vice-presidents must take responsibility for these failures and start to address aviation in a joined-up way, not via silos where directorates abrogate joint responsibility for addressing cross-cutting questions such as fuel tax, VAT or state-aid scandals. Non-CO2 emissions must be taken seriously and measures should be prepared.
The European Commission opened a public consultation on “Preparation of a sustainable bioenergy policy for the period after 2020”, which closed on 10 May 2016. The objective of this consultation is to consult stakeholders and citizens on an updated EU policy on sustainable bioenergy for the period 2020-2030, as part of the EU renewable energy package, expected by the end of 2016. This is T&E’s response to the consultation.
The Commission opened a public consultation on a new Renewable Energy Directive for the period after 2020. This is T&E’s answer to the consultation.
In July 2015 the European Commission opened a public consulation on an EU strategy for liquefied natural gas and gas storage. In its response T&E state that natural gas cannot deliver the decarbonisation that the sector needs to achieve the EU climate goals up to 2050. Investing in this technology would divert necessary resources from truly low-carbon alternatives in the transport sector and would create lock-in effects. Public resources for energy transition in transport should go where it offers the greatest public benefits, improved efficiency, and sustainable electrification.
An efficiency standard is a key element of ICAO’s basket of measures and is intended to deliver emissions reductions beyond business-as-usual. But on current indications the ICAO standard for new aircraft types will not affect any new aircraft types and will only cover 5% of the world fleet in 2030. In this submission T&E outlines its position that the EPA should ensure that any standard adopted ensures efficiency improvements that go beyond business-as-usual.
This is the T&E’s response to the European Commission’s public consultation on the handbook on Sustainability Impact Assessment (SIA).
In these documents, T&E responds to the public consultations on the EU Effort Sharing Decision (ESD) and Land use, Land Use Change and Forestry (LULUCF). As transport is currently the largest sector within the ESD, it is vital to have a strong ESD with limited flexibilities to avoid watering down the EU climate targets and to achieve reductions in the transport sector. The way LULUCF is dealt with is also fundamental to avoiding a decrease in the level of ambition in sectors such as transport. For these reasons, T&E provided input to both consultations in close coordination with other environmental NGOs.
The European Commission has developed a test procedure called VECTO to measure CO2 emissions from new trucks and buses. The VECTO test procedure is a simulation tool that aims to provide truck buyers with accurate fuel consumption information. The details of the test procedure are currently being discussed in a DG GROWTH expert committee and the final legislative proposal is expected in mid-2016. In this submission, T&E advocates a truck CO2 test procedure that is reliable, transparent and easy to use for third parties. T&E also demands that the VECTO simulation results be verified through a form of testing for real-world compliance.
T&E provided a detailed submission to the European Commission's public consultation on aviation competitiveness, which closed on 10 June 2015. T&E's response to this consultation is to call for the EU to adopt measures that create a more efficient aviation sector, making EU operators the market leaders globally. This includes adopting the most effective environmental standards possible, ending inefficient subsidies to operators and airports and adopting a common EU negotiating position for air service agreements to prevent excess capacity in the European market. With aviation emissions projected to grow considerably by 2030, such measures are necessary to meet the EU's ambitious climate objectives.