Recommendations to Strengthen the EU's NDCs

The NDC Partnership is a network of over 120 countries, facilitated by UNFCCC, that is dedicated to helping each other strengthen their Paris Agreement Nationally Determined Contributions (NDC) Pledges. The Partnership has just released Version 3.0 of the NDC Navigator, an interactive tool that supports the development of updated country NDCs to be submitted in 2025. Below are Climate Scorecard Country Managers’ advice to their countries of what needs to be done to strengthen their NDCs based on the framework of the NDC Partnership Navigator.

Dear Mr. Wopke Hoekstra,

Given your role as Commissioner for Climate Action and the larger European Council’s role in submitting revised NDCs, I would like to suggest how the EU’s NDCs can become more aligned with the temperature goals outlined in the Paris Agreement.

The Paris Agreement highlights the need to keep the global average temperature increase to well below 2°C above pre-industrial levels, with a more ambitious goal of limiting the temperature increase to 1.5°C above pre-industrial levels.

The EU’s recommendation that was put forth on February 6, 2024, to cut net greenhouse gas emissions by 90% compared to 1990 levels by 2040 is a promising step in the right direction. According to studies performed by Climate Action Network (CAN) Europe, in order for the EU to meet the more ambitious goal of limiting the global temperature increase to 1.5°C above pre-industrial levels, it will be necessary for the EU to reduce its greenhouse gas emissions by at least 65% of 1990 levels by 2030. This means that a 76% net emissions reduction should be achieved. As the EU’s current policies aim to reduce greenhouse gas emissions by at least 55% of 1990 levels by 2030, and current projections show that it is uncertain that the EU will reach this goal, more ambitious policies will be needed to achieve a 65% reduction in emissions.

Some of the recommendations by CAN and the European Scientific Advisory Board on Climate Change (ESABCC) could be useful in helping the EU reduce its greenhouse gas emissions by 65% in 2030. One of these recommendations is the creation of a greenhouse gas budget that can be implemented in the immediate future instead of the budget that is currently set to take place from 2030 to 2050. This will allow the EU to reach more ambitious goals by 2030, making it easier for the EU to reach its zero net emissions goal in 2050.

Another of these recommendations is the creation of separate targets for net sequestration in the LULUCF sector and for industrial carbon removals that do not overlap with emissions reduction targets. According to the IPCC’s synthesis of its Sixth Assessment Report, in order for the EU to do its part in limiting global warming to 1.5°C, it will be necessary for industrial carbon removals to be performed in addition to emissions reductions not in place of emissions reductions. Part of the reason is that natural carbon sinks absorb carbon for a few years to a few decades, while fossil carbon can remain in the environment for millions of years. Companies and Member States will likely use industrial carbon removals to demonstrate that their emissions are lower than they are, allowing them to expose loopholes within the EU’s Emissions Trading System and Effort Sharing Regulation. Separate targets are needed for industrial carbon removals and fossil carbon removals. CAN suggest creating a separate LULUCF net sequestration target of at least 600MTCO₂e by 2030 and maintaining it up to the same level by 2040. More research should be performed to determine the net industrial carbon removal target, as this will depend on the capabilities of the carbon removal technology that the EU currently has at its disposal and what it will be able to develop within the coming years.

A final recommendation made by the ESABCC that I would like to bring to your attention is expanding the EU greenhouse gas pricing regime to all major sectors, including the agricultural and LULUCF sectors. The ESABCC outlines that the impact of these pricing mechanisms on vulnerable groups, such as small farms, should be assessed before implementation. The CAP budget could fund this, and revenues from the expanded pricing mechanisms could be used to finance redistributive measures. In order to monitor compliance with the pricing mechanisms, the ESABCC suggests that the EU carbon removal certification framework currently under development could potentially be used as a monitoring, reporting, and verification system.

Thank you for your time and consideration.

Sincerely,

Brittany Demogenes

EU Climate Scorecard Country Manager

Learn More Resources:

https://caneurope.org/can-europes-position-eu-climate-targets-ghg-budget/

https://www.c2es.org/2024/02/2040-climate-target-how-the-eu-plans-to-cut-emissions-by-90-percent/

https://climate-advisory-board.europa.eu