Consultation response on the revision of the EU Emission Trading System (EU ETS) Directive

Position paper | 19 Mar.2015

Consultation response on the revision of the EU Emission Trading System (EU ETS) Directive

Background: On 24 October 2014, the European Council agreed on the 2030 framework for climate and energy, including a binding domestic target for reducing greenhouse gas (GHG) emissions of at least 40% in 2030 as compared to 1990. To meet this target, the European Council agreed that the emissions in the EU Emission Trading System should be reduced, compared to 2005, by 43%. A reformed EU ETS remains the main instrument to achieve the emission reduction target. The cap will decline based on an annual linear reduction factor of 2.2% (instead of the current 1.74%) from 2021 onwards, to achieve the necessary emission reductions in the EU ETS. The European Council furthermore gave strategic guidance on several issues regarding the implementation of the emission reduction target, namely free allocation to industry, the establishment of a modernisation and an innovation fund, optional free allocation of allowances to modernise electricity generation in some Member States.

The strategic guidance given by European leaders on these elements will be translated into a legislative proposal to revise the EU ETS for the period post-2020. This constitutes an important part of the work on the achievement of a resilient Energy Union with a forward looking climate change policy, which has been identified as a key policy area in President Juncker's political guidelines for the new Commission.

The purpose of this stakeholder consultation was to gather stakeholders' views on these elements.

CEPI's Key messages :

- The ETS in general, and the benchmarks in particular, should reward installations and sectors reducing GHG emissions, without penalising early movers, new investment made, and low-carbon economic growth. Fiscal and legislative stability and predictability are needed to enable investments in low-carbon technologies.
- The pulp and paper industry cannot pass through carbon costs to its customers: the global market of export goods sets prices, not the production costs of the European industry. This can be easily verified by the lack of correlation between carbon prices and final product prices.
- For “direct carbon costs”, free allocation is a necessary condition but not sufficient to avoid carbon leakage: support mechanisms should be set up to help the EU industry improve its energy efficiency and reduce its GHG emissions.
- Concerning “indirect carbon costs”, it would be better for a mandatory and harmonised EU-wide compensation scheme to address the impact of rising electricity costs due to ETS in all Member States. Financing of compensation schemes should include also, but not be limited to, auctioning revenues from ETS.
- Support for innovation in industry should not come at the expenses of carbon leakage protection: funding for innovation will have to come on top of free allowances for industry. It should be directed to directly finance large-scale demo and pilot projects, as well projects close to commercialisation stage (TRL 6-8). These are high risk, high capital investments where the private sector would not be able to deliver without the backing of public financing.
- The role that European industry plays in the circular economy and in the bioeconomy is of strategic importance for Europe’s access to raw materials and reducing Europe’s carbon footprint. This should be acknowledged when reviewing the EU ETS, by addressing the ETS impact on prices and availability of raw material, such as wood.
 

Read the full reponse.

Download here