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.
In mid April 2014, the European Commission opened a consultation on disputed aid to 23 regional airports in relation to the newly revised state aid guidelines for airports and airlines which came into effect at the beginning of the month. T&E believes that decisions that will be taken on state aid under the new guidelines risk further distorting competition in an already heavily subsidised sector, wasting scarce public resources and expanding billions of euros in climate harmful subsidies that will generate more CO2 than the original emissions trading system intended to save. Transport & Environment believes that state aid can only be justified for select small airports in remote areas for which other transport is not a viable option. You can download our consultation response below.
This completed questionnaire is T&E's response to the public consultation on the review of progress towards the EU's 2020 energy efficiency objective and a 2030 energy efficiency policy framework. T&E thinks that transport must not be left out of Europe's overall efforts to boost energy efficiency. There remain huge opportunities to improve energy efficiency in transport at EU level.
In June 2013, the European Commission launched a consultation on the policy options for market-based measures to reduce the climate-change impact from international aviation. The consultation seeks input on questions concerning the policy options currently being developed on the international level at the International Civil Aviation Organisation (ICAO), and to obtain stakeholder views on options to reduce the administrative effort for small aircraft operators under the EU emissions trading system (EU ETS). A new scientific report recently released highlights the critical importance of taking early action when implementing measures to reduce the climate impact of rapidly increasing emissions from aviation. T&E's response to the consultation is below.
This paper is a response from Transport & Environment to the consultation in the context of the European Commission Green Paper ‘A 2030 framework for climate and energy policies’. The response focuses on the framework for EU climate and energy policies in transport.