Browse by topic: Publication, Consultation response


T&E responses to consultation on an EU strategy for LNG and gas storage

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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.

Submission on a CO2 standard for new aircraft

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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.

Public consultations on the Effort Sharing Decision and Land use, Land Use Change and Forestry

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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.

Discussing the VECTO test to measure CO2 emissions from trucks and buses

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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.

New South Wales's sulphur fuel requirements for cruise ships

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The following submission is in support of the introduction by the state government of New South Wales in Australia of stricter sulphur content requirements in marine fuels used by cruise ships entering Sydney Harbour and berthed at the White Bay cruise ship terminal, aimed at reducing emissions. Residents living close to the terminal have been complaining about the effects of air pollution from cruise ships calling at the terminal and this lead to a public consultation.

Aviation competitiveness submission

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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.

Submission to the European Ombudsman's public consultation on transparency

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Transparency within all realms of policy development are not only treaty-embedded obligations for the European Commission but a practical and necessary condition to secure respectful and beneficial outcomes for European society as a whole. In response to the European Ombudsman’s investigation into transparency within trade negotiations, T&E suggests concrete measures and raises examples of best practice that would enable meaningful and constructive input from civil society across Europe and the Atlantic.