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ETS reform as part of a package to collectively increase climate ambition Deutsche Umwelthilfe (DUH) notes that even with a 2030-climate target of 55%, Europe remains off track to reach the Paris Agreement 1.5°C objective. Emission cuts of at least 65% are required for the EU to fully honor its international commitments.

LanzaTech commends the European Commission’s ambition in its revision of the Emissions Trading Scheme (ETS). We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward. The following outlines our feedback and recommendations on some of the specific policy mechanisms put forth in the EU Commission’s proposal.

Immediate social concerns and unclear climate benefits Environmental Action Germany (DUH) welcomes pricing in climate damage costs in the transport and building sectors, where emissions reductions are slow at best. We are concerned, however, that the introduction of a new emissions trading system is not the right instrument.

LanzaTech commends the European Commission’s ambition in its revision of the Energy Taxation Directive (ETD). We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward.

Environmental Action Germany (Deutsche Umwelthilfe, DUH) notes that the many tax exemptions in the Energy Taxation have led to a very disparate and complex energy tax landscape in Europe, which also hinders the integration of the internal energy market.

We support the EU-SAF Blending Mandate with recommendations: a) Should come into force after min. of 3 years to enable implementation of commercial SAF projects and to allow airlines, airports, and other stakeholders time to prepare. b) To be effective, the cost of non-compliance should exceed and possibly be tied to the cost differential between SAF and conventional fuels.

Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.

LanzaTech commends the European Commission for its consideration of policies in support of aviation greenhouse gas reductions and increased supply and offtake of sustainable aviation fuels in the EU. We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward.

Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.

LanzaTech commends the European Commission for its proposal to boost the uptake of sustainable fuels in shipping and ports to reduce emissions from the sector. We welcome the opportunity to respond to the EU Commission's proposal and working alongside the co-legislators in the future.