Position paper - TEC - AmCham EU letter to Commissioner Arias Cañete on the impact assessment of the ETS proposal

The American Chamber of Commerce to the European Union (AmCham EU) represents U.S. companies across all sectors operating and committed to the European Union. Given the challenges posed by climate change, our members are committed to carbon reduction. We therefore recognise the importance of the EU Emissions Trading System (ETS) in EU climate policy and in reducing carbon emissions cost-effectively.
However, we believe that the legislative proposal released on 15 July falls short of the Better Regulation Standards set by the Juncker Commission.

The letter highlights 4 main points: 

1. The adoption of the proposal seems to have been rushed

2. The impact assessment is based on incomplete studies

3. Assessment is based on potentially invalid assumptions on ETS schemes globally

4. There is a lack of clarity in the process for determining sectors deserving of carbon leakage relief