The IA offers a convincing explanation of the need to set a 2040 climate target. It is crucial, for instance, to provide predictability for the Member States, stakeholders, investors and decision makers, and to step up the current pace of emissions reductions across all sectors in order to meet the 2030 target. The assessment includes three policy options for analysis. The theoretical option 1 (O1) corresponds to the linear trajectory under the ECL and is assessed as being below the baseline. Option 2 (O2) corresponds to the baseline. Only option 3 (O3), which involves a minimum 90 % reduction in GHG emissions compared to 1990, goes beyond the baseline. This rather limited choice of options raises concerns about the completeness and realism of the alternatives, not least in light of the significant long-term challenges and corresponding EU policy ambitions. In line with the requirements of the Better Regulation Guidelines (BRG), the IA assesses a wide range of economic, environmental and social impacts and includes a comparison of options based on their effectiveness, efficiency, coherence and proportionality. The IA uses a number of economic modelling tools to quantify impacts, including the benefits of climate change mitigation, in order to ensure robust results. It ultimately concludes that O3 – the preferred option – is the most effective one for achieving EU climate neutrality by 2050. Additionally, it would position the EU as a strong leader in global climate action. When choosing the preferred option, the IA takes into account, inter alia, the strategic autonomy goals and discusses the evolution of the energy system, along with the need to decrease the EU's dependency on energy imports. While the IA warns against new dependencies on raw materials or technology from non-EU countries, it does not specify, for example, which factors will influence the scale-up of renewable hydrogen in the EU (considered key), or what amounts of this substance will need to be imported and from which countries. It also avoids discussing the evolution of global demand for critical raw materials in 2031-2040, and the impact this will have on third countries' labour conditions and local communities, or other impacts of increased mining. Nor does it examine the wider geopolitical context in this regard. Overall, the main IA report is comprehensive, self-standing and includes all necessary information further detailed in the annexes. However, in addition to twice exceeding the recommended length of 40 pages of text (BRG, p. 34), this complex IA report contains a number of formatting and proof reading errors that hinder its readability and transparency. Additionally, while the IA consistently references stakeholders' opinions, clearer statements regarding their support of the initiative would have been beneficial. The proposed target to reduce GHG emissions by 90-95 % compared to 1990 levels by 2040 aligns with the ECL's commitment to achieve climate neutrality by 2050 and with the goals of the Paris Agreement.
Authors
- Pages
- 12
- Published in
- Belgium
Table of Contents
- Problem definition 2
- Subsidiarity / proportionality 2
- Objectives of the initiative 3
- Range of options considered 3
- Assessment of impacts 4
- Table 1 – Effectiveness of options 7
- SMEs / Competitiveness 9
- Simplification and other regulatory implications 9
- Impacts on third countries 10
- The preferred option 8
- Monitoring and evaluation 10
- Stakeholder consultation 10
- Supporting data and analytical methods used 11
- Follow-up to the opinion of the Commission Regulatory Scrutiny Board 11
- Coherence between the Commission's legislative proposal and IA 11