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As also indicated in the document, the first thing that needs to be established is to which extent CORSIA, in its current shape, will contribute to the goals of the Paris agreement. It needs to be seriously considered whether CORSIA is a climate policy targeted to solve climate change, or whether it is an attempt to block any effective climate policy for the foreseeable future.

Sandbag welcomes the opportunity to give feedback on the Inception Impact Assessment on updating the EU ETS rules for aviation. In the context of the European Green Deal and the enhanced ambition for 2030, changes to the EU ETS for aviation should not result in a step backwards in terms of tackling CO2 emissions, but a step forward.

When developing new policies, consistency with existing policies must be ensured. For the Citizens' Climate Lobby, the Fit For 55 package and the EU climate targets are obviously the most important ones. We want to raise our concerns about the amendment. It is not by demanding consistency in a legal text that this is indeed the case.

We welcome immediate action to reduce Europe’s dependency on Russian fossil fuels in the face of its aggression against Ukraine. However, the European Commission’s proposal reflects the impossibility of meeting this objective while keeping conflicting incentives in force.