EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

5 submissions in the snapshot (3 from organisations), portal total 5. Feedback list on the portal.

3 of 3 organisation submissions analysed; the model reads them as: wants changes 3

• MoroAK - University of Leeds Academic or research institution, GBR model reads as: wants changes source
  • Clarify the approval standards, reasoning requirements, and routes of challenge for decarbonisation investment plans across Member States.

    My submission is that a conditional entitlement is only as good as the process that decides the condition, and that the process should be in the instrument.

  • Provide Commission guidance on the approval standard and publish approval decisions in anonymised summary form to secure consistency.

    I suggest Commission guidance on the approval standard and publication of approval decisions in anonymised summary form.

  • Define a clear time horizon for the relocation clawback to avoid indefinite contingent liabilities for recipients.

    I did not find a stated horizon, and a clawback without one is an indefinite contingent liability for every recipient.

• Micro company, SWE Business association, SWE model reads as: wants changes source
  • Maintain the Linear Reduction Factor without reduction to preserve investment incentives.

    The Linear Reduction Factor (LRF) should not be reduced, as scarcity is essential for investment in CCS, CCU and electrification.

  • Retain the current intake rate and cancellation mechanism of the Market Stability Reserve.

    The Market Stability Reserve (MSR) should retain its current intake rate and cancellation mechanism.

  • Include waste-to-energy installations in Annex I with a shorter phase-in period.

    Waste to energy installations should be included in Annex I on harmonised terms, with a shorter phase in than 2031-2034, clear monitoring, reporting and verification requirements, and oversight of equivalent measures in Member States that opt out.

• INSULEUR - Network of Insular Chambers of Commerce of the EU Business association, GRC model reads as: wants changes source
  • Account adequately for the specific circumstances and maritime connectivity dependence of island territories.

    INSULEUR considers it essential that the specific circumstances of island territories and their structural dependence on maritime connectivity are adequately taken into account.