Letters to Policy Makers

Letter to Italian ENVI committee MEPs on the Climate Action Regulation implementing the Paris Agreement

CAN Europe has written a joint letter to Italian ENVI Committee MEPs ahead of their vote on the ‘Effort Sharing’ Regulation, or the ‘Climate Action Regulation implementing the Paris Agreement’ on 30 May.  

The letter, written by a coalition of NGOs, calls for greater ambition in the legislation. The Regulation covers almost 60% of the total CO2 emissions of the Union from sectors such as road transport, agriculture, buildings and waste, and which will set the path of the decarbonisation of the European economy in the coming decades. As well as ensuring the EU lives up to its international commitment under the Paris Agreement, the legislation has the opportunity to contribute to more liveable cities, cleaner air, reduced energy poverty and the creation of millions of jobs in Italy and across the EU.

However, the proposal from the European Commission is unambitious and sets a target for 2030 which is too low. In addition, it sets a starting point which is too high and introduces several loopholes. If adopted, these provisions will undermine the effectiveness of the regulation, put EU’s climate leadership at stake and miss out on investment opportunities and the creation of millions of jobs.

The European Parliament is facing an important political opportunity to raise the profile of this regulation, and the letter calls on the ENVI committee (as lead committee) to make sure that the loopholes are closed. More specifically, the signatories to the letter call on Italian MEPs to:


  • Support a starting point that reflects reality, to avoid an inflated carbon budget. The starting date set by the European Commission (average emissions 2016, 2017 and 2018) unnecessarily increases the EU’s carbon budget, allowing member states to emit more than their actual emissions. This would also create a big pool of ‘hot air’ credits, with the risk of making this climate instrument nonfunctional . NGOs propose to set a linear decreasing emission trajectory starting at 2017 -not 2020 - emission levels, reducing the carbon budget by about 500Mt CO2e compared to the EC’s proposal.

  • Reduce the amount of LULUCF and ETS offsets. A total of 380 Mt of non-permanent forestry credits and ETS surplus can currently be used to undermine climate action in the ESR sectors. s . If we are to meet EU’s and Paris’s climate commitments we need both reductions in the ESR and carbon sequestration in the LULUCF sectors - it’s not either-or. On the other hand, the ETS is massively oversupplied, and taking credits from one market to the other will be like moving hot air.

  • Limit the banking flexibility. As it stands now, member states will be able to bank their unused flexibilities without any limitation in quantity nor time. These unused credits can be used in the end of the period, when the targets are more stringent. This will allow member states to meet their targets in paper but not in practice. Setting a 5% limit on the amount of credits that a member state can bank would result in about 400Mt CO2e extra savings.

  • Include a review clause which allow for ambition to be raised over time, as the EU submits a new 2030 climate target to the United Nations Framework Convention on Climate Change.

A copy of the letter (in Italian) which was sent out on 12 May can be found below:

pdf ESR letter to Italian MEPs 12 May 2017 (181 KB)

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