T&E’s response to the European Commission consultation on the European Climate Law amendment
In view of the European Commission’s initiative to amend the European Climate Law, this briefing sets out T&E’s key recommendations for a 2040 EU climate target that accelerates and deepens the process started with the European Green Deal and its objective to decarbonise the continent by 2050.
T&E recommends:
Adopt an EU climate target of at least a 90% cut in domestic net greenhouse gas emissions by 2040. T&E calls for an EU climate target of at least a 90% reduction in domestic net greenhouse gas emissions by 2040 (compared to 1990). Starting from 2036, to increase the fairness and equity of its contribution to global climate efforts, the EU could consider including within its domestic net 90% reduction target the acquisition of a limited amount of high-quality, high-permanence international carbon credits characterised by stringent eligibility criteria. If these stringent criteria cannot be guaranteed, international carbon credits should not form part of the EU’s target.
Define a realistic split between emissions reductions and carbon dioxide removal. While the Commission’s initiative acknowledges that “priority should be given to domestic reductions in greenhouse gas emissions, complementing it by increased removals”, the 2040 target should define a realistic split between domestic reductions and domestic removals to enhance clarity and minimise overreliance on unproven carbon removal technologies. Given the technical and cost uncertainties surrounding engineered removal technologies, this split should be set at the lower end of what is currently assessed to be possible, and as the technologies are deployed this split can be revised based on empirical performance and cost data. Further, the use of carbon removals should be explicitly defined for use within hard-to-abate sectors.
Decarbonise the transport sector to reach the 2040 EU climate target. T&Eʼs Road to Zero scenarios show that the transport sector can cut its emissions by about 70% by 2040 compared to the 1990 baseline. Aside from the existing regulations, which mainly focus on accelerating electrification of road vehicles, carbon pricing, as well as ReFuelEU Aviation and FuelEU Maritime (FEUM) which cover the aviation and shipping sectors respectively, we advocate for transport system efficiency measures as well as a reduction of transport demand where possible.
Strengthen key measures to reach the 2040 target. An ambitious 2040 target is crucial for Europe’s transport sector, which alone will account for about 45% of EU emissions in 2030. To reach the 90% net reduction target, the EU must resist pressure to weaken its 2030-2035 zero-emission cars targets and the ETS2, while maintaining the ambition of green fuel targets for ships and planes. We also call upon the EU to introduce an ambitious regulation to electrify corporate fleets, tax the aviation sector, and strengthen truck CO₂ targets.
Include non-CO₂ aviation effects in the climate policy architecture. The Commission must account for non-CO₂ aviation effects and mitigation measures for the 2030–2050 GHG budget, the 2040 target, and the design of policy tools to meet EU’s climate goals. Contrail warming - the most significant of aviation’s non-CO2 emissions - must be mitigated to stay on track with the Paris Agreement's temperature goals.
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