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EuLA acknowledges the European Commission proposal for the 2030 Climate Target Plan under the first European Climate Law. This legislation will set the intermediate pathway to achieve the 2050 climate neutrality ambition to reach the objectives of the Paris Agreement and ensure that once the 2030 target is implemented in the European Climate Law, no step back is taken to undermine the credibility of the climate objective, not only at European level but also within the international context. EuLA recognises the importance of the current discussion and wishes to participate actively as a notorious contributor.
A robust Impact Assessment (IA) is necessary to evaluate the effect of the new climate target on the energy intensive industry. Moreover, the Impact Assessment should cover and investigate the potential for further reduction of GHG emissions of all economic sectors (non-ETS sectors) contributing to the global European objective. The current European climate policy is based on a GHGs reduction target of 40% (compared with 1990 levels) by 2030. If an increase of this target to 50% – 55% GHGs by 2030 is considered necessary to achieve climate neutrality by 2050, it has to be proposed after a detailed and robust analysis demonstrating that the European Industries are technically and financially capable to adapt under short notice without losing their competitiveness. Moreover, the current deep global COVID-19 crisis is far from being behind and the IA cannot ignore in its analysis, the different impacts of the crisis on the social and economic strengths in short and medium terms.
The 2030 Climate Target Plan must ensure carbon leakage protection for exposed sectors. An increased level of ambition on the GHG emission reduction target shall be accompanied by a similar increased level of industry protection. Increasing the risk of carbon leakage should be accompanied by additional measures on top of free allocation. The European Commission, while leading by example, should encourage other countries to introduce similar GHG mitigation measures.
The Impact Assessment on the 2030 Climate Target Plan must also recognise the potential impact of increasing the climate ambition on other European policies. It is extremely important to mitigate the consequences that increasing the GHGs target could trigger on other EU policies, such as “use of biomass as energy source and its impact on land use, food production and biodiversity”.
The 2030 Climate Target Plan must be an enabler for technological development for carbon removal. It is also important to consider that the innovative technologies necessary to contribute to the 2030 challenge, have not reached a sufficient level of maturity yet. Indeed, the challenge of transformation to deliver on climate objectives for the lime sector requires important investments on innovation. For the lime industry, due to the high share of CO2 emissions coming from the decarbonisation of the raw material (68% on average), the most important CO2 mitigation measures are “end of pipe” solutions, notably CCS, CCU and carbonation. We call the EC to strength the support of these instruments to enable decarbonation.
Thus, EuLA is also supportive of the joint statement of the Alliance of Energy Intensive industries, accessible through the current website.
 CLM BREF (2010), p.254