Reports and briefings

The following reports and briefings have been produced thanks to the support of our core funders: The European Climate Foundation, the The Ecofin Foundation and the Esmee Fairbairn Foundation.

Bespoke analysis, reports and briefings on a range of topics can be commissioned - please contact us if you wish to discuss options.

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    October 2016
    This report looks at whether additional actions to reduce emissions lead to net emissions reductions over time in the EU Emissions Trading System. The argument that total emissions are always equal to a fixed cap is sometimes called the "waterbed effect" by analogy with a fixed volume of water in a waterbed, where if you squeeze in one place it pops out in another.  
    Although often repeated this claim turns out to be more urban legend than fact. Under the EUETS at present the vast majority of emissions reductions from additional actions will be permanently retained. This is due both to the effect of the current surplus and introduction of the MSR, and the fact that over the long term supply of allowances is not fixed, but responds to circumstances.

    October 2016
    • Increasing CO2 intensity: Data from the Cement Sustainability Initiative shows that the carbon intensity of EU cement increased from 2008 to 2014.

    • No carbon leakage: Since 2011, the EU cement sector has vastly increased exports of cement clinker outside the EU, demonstrating that the EU Emissions Trading System has not made the sector globally uncompetitive.

    Earlier this year, research by Sandbag revealed that perverse incentives in the design of the EU Emissions Trading System (EU ETS) have driven higher GHG emissions in the cement sector.

    Sandbag’s new analysis of recently published figures from the Cement Sustainability Initiative show that European Portland cement producers have not reduced the carbon intensity of cement from the beginning of the EU ETS in 2008, up until the end of 2014 (the most recent year for which data is available).  In fact, the sector made greater strides in reducing emissions in the years prior to the EU ETS.

    October 2016

    Today, we launch a report written by Sandbag, the European Environmental Bureau (EEB), the Health and Environment Alliance (HEAL), Climate Action Network (CAN) Europe and WWF.

    Effective coal regulation could slash deaths from toxic fumes by 85%.  Effective emissions limits could save thousands of lives every year, yet more than half of coal power stations in Europe are operating with ‘permission to pollute’ above limits set in EU law. 

    ‘Lifting Europe’s Dark Cloud’ shows how improving environmental performance at European coal power stations could save 20,000 lives every year. By setting and enforcing pollution limits in line with the best industry-recognised, tried-and-tested techniques, the annual number of premature deaths caused by burning coal could be reduced from 22,900 to 2,600 deaths.

    The report also finds that current legislation is failing to deliver its intended health benefits because special exceptions have been granted that allow for emissions over the agreed ‘safety net’ levels. At the time of publication, more than half of the coal power plants in Europe have ‘permission to pollute’ beyond the limits set in the Industrial Emissions Directive.

    Before the end of the year, the EU and Member States will have the opportunity to adopt improved environmental performance standards, the ‘revised LCP BREF’. By agreeing these standards and implementing effective limits on coal pollution, real progress can be made in improving the health of people across Europe. The revision process has already been delayed for more than two years, leading to 5,600 unnecessary deaths and a total health bill of more than 15.6 billion euros.

    The best available techniques we call for in this report are all tried-and-tested and were already being demonstrated under technically and economically viable conditions decades ago. The EU considers itself a world leader on environmental issues but when it comes to coal, decision makers have their heads stuck in a dark cloud!”, says Christian Schaible,  Policy Manager on industrial production from the European Environmental Bureau (EEB).

    Medical professionals have expressed support for the report; “Air pollution kills,” says Professor Bert Brunekreef of the European Respiratory Society. "Experts in lung health want to see immediate remedial action. Inaction cannot be justified when it is human health and lives that are at stake."

    As there are no techniques which completely eliminate emissions from burning coal and with coal power plants responsible for 18% of all of Europe’s greenhouse gases, lifting Europe’s Dark Cloud will require the complete phase-out of coal power in favour of sustainable renewable energy sources and reduced energy consumption.

    October 2016


    On September 30th 2016, the Polish Ministry of Development completed a broad public consultation on the Government's Responsible Development Strategy (Strategia Odpowiedzialnego Rozwoju).

    In a recent report "How the << Responsible Development Strategy>> contributes to the implementation of climate policy?" published by The Institute for Sustainable Development (ISD), independent evaluation by Polish research organizations reveals that only five of the 29 major courses of action targeting low-carbon investments presented in this document are likely to be undertaken.

    In our new briefing (in Polish), Sandbag presents a number of recommendations on how to increase the likelihood of Responsible Development Strategy implementation. These are based on previous studies available, in particular Bend it, don’t break it and Sharing the Burden. We argue that such actions will increase investor and public confidence in Government planning.

    We encourage the Ministry of Development to consider the following steps to respond to the results of the public consultation:

    • increase the cooperation between the Ministries of Development, Finance and Environment in order to expand sources of funding for the implementation of Responsible Development Strategy,
    • introduce a European Project-Based Mechanism to the Effort Sharing Regulation (ESR) in order to increase foreign funding for investment in projects that can generate additional emission permits within the ESR and to contribute to compliance with EU targets for 2030,
    • use funds available under the EU ETS through the National Investment Plans strategically and support changes that might increase the real value of these funds during 2021-2030. 

    The above steps will positively influence the financing of Responsible Development Strategy projects such as those creating infrastructure for e-mobility, improving building sector energy efficiency and supporting changes to the agricultural and breeding sectors. They will also contribute to the implementation of tasks aimed at modernizing and expanding electricity and gas transmission and distribution networks as well as supporting combined heat and local energy distribution projects and development of micro-renewables.

    October 2016

    Modelling Phase 4 reforms to Free Allocation - Avoiding the CSCF

    For this report Sandbag has built a model to compare different combinations of ETS reform choices for Free Allocation of allowances. We have used the Commission’s Proposal as a starting point and compared amendments proposed by the ENVI committee.

    Crucially, we have tried to find reform combinations that avoid the unfair Cross Sectoral Correction Factor (CSCF) in Phase 4.

    We also look at how Free Allocation reform could help bring down the surplus.

    As a result of this detailed modelling, Sandbag recommends:

    • use a targeted rather than binary approach for carbon leakage protection,
    • realign the 2020 starting point for calculating the Phase 4 cap (to reflect the reality of where emissions have reached),
    • take all Phase 4 New Entrant Reserve (NER) allowances from the Phase 4 cap (to avoid augmenting Phase 4 with surplus Phase 3 allowances),
    • retire unallocated Phase 3 allowances, or at least leave them in the Market Stability Reserve (MSR),
    • take all Innovation Support allowances from the auction share of the Phase 4 cap,
    • increase the auction share in the event of comparative efforts for mandatory emissions reductions outside the EU ETS region.

    September 2016

    The 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

    September 2016

    The EU carbon market is broken for all the wrong reasons. Successful advances in the Energiewende agenda across Europe now require adjustment of the EU Emission Trading System (EU ETS) to fit with the reality of falling emissions. We have already accumulated a surplus of more than 1,827MtCOe  and by 2020 emissions will be likely well below the EU ETS cap due to past emission reductions.

    While European leaders discuss the EU ETS post-Paris review clause, in light of reductions in emissions from electricity generation that occurred over the last decade, the priority should be enforcing and harmonising the current EU climate legislation.

    Saving the EU ETS will take German leadership. Sandbag encourage German Ministers to take more responsibility for past emission reductions and propose as a part of their Government’s position that:

    • the EU ETS Phase 4 starting point in 2021 is based on actual emissions in 2019 or 2020;
    • the MSR is stabilised through a provision for a size limit of 1 billion allowances in the MSR (10 years’ worth of the return rate). Any allowances above this threshold should be retired.

    In our new briefing Germany and the EU ETS we explore how presented policy options can be implemented in a way that ensures that German industry genuinely exposed to carbon leakage is protected with free allocation of allowances after 2020.



    July 2016

    This report shows that EU-wide cost-effective emission reduction opportunities will not align with Member States’ national reduction targets. These targets will be set based on GDP/capita with some adjustments in line with the solidarity principle. If the sharing of effort were aligned better with cost-effective reduction opportunities spread across the Member States, the Effort Sharing Decision (ESD) target could be increased to 50% below 2005 and up to 2 billion tonnes of additional emission reductions could be delivered between 2021-2030. 

    This report should be considered alongside The Effort Sharing Dinosaur (May 2016), our report revealing problems with the current scheme.

    Key recommendations

    In order to facilitate additional, fair, and cost-effective emissions reductions in the ESD by 2030, and consequently, in the whole economy by 2050, in its proposal for ESD II, the EU institutions should:

    • Introduce a new market-based flexibility between Member States; the European Project-Based Mechanism (EPM).
    • Prevent the inclusion of any flexibilities that would dilute the 2030 target and increase the surplus of AEAs. This includes not carrying-over the expected surplus of AEAs from ESD I to ESD II and avoiding the creation of flexibilities with other climate policies (particularly ETS and LULUCF) before 2030;

    If an EPM is introduced into ESD, it could pave the way towards the establishment of an EU economy-wide carbon budget post-2030 that will make use of the efficiency created by market based mechanisms (an EPM and the ETS) to enable a more ambitious emission reduction effort in the period until 2050. 

    July 2016

    Coal pollution and its health impacts travel far beyond borders, and a full coal phase-out in the EU would bring enormous benefits for all citizens across the continent. Today Sandbag has published a new report on the health impacts from air pollution of all EU coal-fired power stations for which data is available (257 out of 280). We cooperated with the Health and Environment Alliance (HEAL), Climate Action Network (CAN) Europe, the WWF European Policy Office to make this publication possible. 

    The report reveals that in 2013 their emissions were responsible for over  22,900 premature deaths, tens of thousands of cases of ill-health from heart disease to bronchitis, and up to EUR 62.3 billion in health costs.

    For the first time, the report analyses how the harmful dust caused by coal plants travels across borders and the effect this has. Watch a visualisation of how pollution spreads around Europe here.

    The five EU countries whose coal power plants do the most harm abroad are Poland (causing 4,690 premature deaths abroad); Germany (2,490); Romania (1,660); Bulgaria (1,390) and the UK (1,350).      
    The five EU countries most heavily impacted by coal pollution from neighbouring countries, in addition to that from their own plants are: Germany (3,630 premature deaths altogether), Italy (1,610); France (1,380); Greece (1,050) and Hungary (700).

    The report shows that each coal power plant closed provides a major boost for the health not only of those living nearby, but also for those abroad: the UK planned phase-out of coal by 2025 could save up to 2,870 lives every year - more than 1,300 of them in continental Europe. If Germany decides to phase out coal, it could avoid more than 1,860 premature deaths domestically and almost 2,500 abroad every year.

    You can find more background information, including quotes from the experts who contributed to the report, on WWF European Policy Office  website.

    July 2016

    A report produced with the Ecofin Research Foundation, Element Energy, Poyry, and the investment community represented in the UK CCS Commercial Development Group. 

    This report outlines the key actions needed for the government's forthcoming CCS strategy, due Q4 2016. The report reviews the literature on CCS development thusfar, and shows that crucially, the new strategy must:

    1. Establish a new CCS delivery model in collaboration with CCS investors
      To get the UK’s first commercial CCS projects off the ground, it is vital that the government, project developers and private sector capital providers work together (through working groups, workshops and bilateral discussions) to develop a bankable investment mechanism for CCS on power and industry.
    2. Make the business case for government and industry co-investment
      It is positive news that the government is continuing to provide some level of support to remaining projects. It is important that funding to existing and future projects is provided not as an isolated initiative but as part of an overall business plan and policy to deliver CCS.

    See all our reports.