Consultation response – The Effort Sharing Regulation
ESRThe European Commission has asked for responses to its proposal on the Effort Sharing Regulation, which came out on July 20th 2016.
This document provides Sandbag Climate Campaign’s response.
Our key recommendations are:
- The target needs to be made more relevant
- The latest possible starting point should be used for calculating the level from which emissions must be reduced
- Any use of flexibilities should be accompanied by a matching increase in the target
- Some of the proposed flexibilities are unsuitable, notably the link with the EUETS and the use of LULUCF, and should be excluded, at least for the present phase
- A European Project Mechanism should be developed
- Compliance should be on an annual basis