EU COMMISSION: NATIONAL TARGETS AND FLEXIBILITIES
The update of the EU Climate Law has now entered into force. Bioenergia ry – the Bioenergy Association of Finland believes that reducing emissions must be at the core of implementing the EU Climate Law.
The association underlines the importance of EU’s emissions trading systems in implementation of the EU Climate Law. One principle is of paramount importance both in terms of clarity and consistency of EU’s policies: if a sector is included in an emissions trading system, it should no longer be subject to a national target under EU legislation. During the 2030s, the EU should assess whether it is justified to maintain two parallel emissions trading systems.
In the land-use sector, the EU has so far not put in place successful policies. Future expectations for the sector must reflect on the sector’s current situation, the particularly high measurement uncertainty, and be more moderate than before. The varying size of the land-use sector across Member States must also be taken into account, and responsibility for financing measures in the sector should be shared more evenly.
Bioenergia ry considers that binding climate targets are essential in the implementing legislation of the Climate Law. National targets should include separate targets for emissions, net emissions in the land-use sector and technological carbon sinks. For fossil-based emissions, the association considers an annual trajectory to be the best approach, but notes that for carbon sinks a longer time-period can be justified. Alongside emission reductions, the role of permanent carbon removals is central, and a large volume of removals will already be needed by 2040. Without permanent carbon removals—carbon dioxide capture, storage and utilisation—it will not be possible to achieve the EU’s post-2030 climate targets. For these solutions, it is critical to create a clear regulatory and investment framework. A centralised fund to promote technological carbon sinks across the EU could also be explored.
The allocation of climate targets under effort sharing must be based more than before on cost-effectiveness and on the convergence of targets as 2050 approaches. The EU’s competitiveness is currently so weak that climate legislation for the 2030s must be streamlined and sufficiently simple. At the same time, national targets must include a sufficient set of different flexibilities, as is already the case under effort sharing today. As new flexibilities, both the use of international emission units and technological carbon removals should be considered. To increase the effective use of flexibilities, transparency around trading opportunities could be improved. If a Member State does not make progress towards its targets, the association supports recommendations from the Commission for additional measures—not financial contributions to funds.
National targets and flexibilities Public Consultation 04 05 26