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.
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.
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.
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.
T&E strongly disagrees with the European Commission objectives and approach in relation to the inclusion of investment protection in the Transatlantic Trade and Investment Partnership (TTIP) through the investor-state dispute settlement (ISDS) mechanism. We believe that the proposed reforms will not solve any fundamental flaws of ISDS, and in our view, they never can, since the whole concept of ISDS undermines the rule of law by bypassing regular courts. Hence, ISDS should be excluded from TTIP and the Comprehensive Economic and Trade Agreement (CETA) with Canada.
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.