We find that the call for evidence:
- Fails to ask input on a crucial weakness of the EU ETS, namely the weakness of the price signal due to excess price volatility, when such an issue could be easily addressed, just as it already is for agricultural commodity prices;
- Seems to focus in large part on ensuring cost effectiveness, growing our economy, and preserving our competitiveness, even though these same paradigms contributed to creating the ecological crises in the first place;
- Given our fast-dwindling remaining carbon budget, we believe that:
- all flights departing from and landing in the EEA should be reintegrated under the emissions cap, in order to remove their licence to grow;
- Emissions from international shipping departing from or arriving at EU ports should not be removed from the ETS under the pretence that they are offset, as it would give them a licence to grow;
- carbon removals should not be included in the ETS;
- non-permanent carbon capture and storage is no reason to remove emissions from the need to buy allowances and from being under the cap;
- There should be no linkages between the EU ETS and carbon offset markets, as past experience showed that it created the current massive surplus and consequently weakened the ETS;
- The Market Stability Reserve has had a very limited impact so far and its rules need to be tightened.
Overall, we strongly hope that the EU Commission will not choose political expediency over following the science and protecting our collective future, despite the difficult political context.