Alliance of Energy Intensive Industries comment on the draft 2030 Target Climate Plan
The Alliance of Energy Intensive Industries welcomes the opportunity to comment on the draft 2030 Target Climate Plan. Our main policy recommendations are outlined below.
Climate and industrial transformation agendas should be implemented simultaneously
In the Masterplan for a Competitive Transformation of EU Energy-intensive Industries Enabling a Climate-neutral, Circular Economy by 2050 the High-Level Group on Energy Intensive Industries has highlighted the need for rapid progress on the demonstration of first-of-its-kind technologies by 2030, considering the short time left until 2050. Energy-Intensive Industries (EIIs) support the Commission’s long-term vision for industry, but we now need to go beyond the vision and the high-level statements: industry needs an enabling regulatory framework and specific supporting measures creating the framework conditions for the transformation of our sectors. Setting up the “right enabling framework conditions for this transition” is a must, here and now: hence we call for a Clean Industry Package with concrete actions in the next 12 months, matching Europe’s climate ambition.
An increase of the 2030 targets should be based on a thorough impact assessment
EIIs welcome the fact that the EC conducts an in-depth impact assessment, to be published by September to underpin the decision to raise the EU’s 2030 climate ambition. It should include a full assessment of the social and economic impacts and a comparative analysis of the costs and benefits of different levels of ambition.
Investment cycles should also be taken into consideration as innovation will not follow a linear path. Disruptive breakthrough technologies needed for the climate-neutrality objective require sufficient time to be developed, upscaled and commercialised. Similarly, major energy- and other infrastructure changes will need to be identified and implemented to enable disruptive emission reductions.
It also remains important that the Commission’s analysis also takes into account levels of climate ambition from our main trading partners and where available, their Nationally Determined Contributions. Unfortunately, we note that the timing of the 2030 target decision-making process does not allow to consider third countries’ climate ambition to be submitted to the UNFCCC. The plan also leaves comprehensive analysis regarding the revision of the effort-sharing regulation and the ETS directive, including carbon leakage measures, for a separate initiative at a later stage. A simultaneous debate would be more appropriate.