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St1 Nordic Oy welcomes the initiative of the Commission to review the ETS regulation. As climate change is a global challenge, also the proposed solution for solving it should be designed in a flexible manner to avoid sub-optimization.

T&E welcomes the Commission’s initiative to align the ETS directive with the EU’s 2030 target of at least -55% emissions reduction and to ensure that all sectors contribute, in line with the EU’s international commitment to economy-wide action under the Paris Agreement. However, T&E regrets that the Commission is considering to switch gear on tackling emissions in the road sector.

This response is about the inclusion of 1)shipping and 2)road transport into the ETS: 1.SHIPPING Shipping accounts for around 3.5% of the EU’s total GHG emissions, but has so far avoided regulation on its climate impact. Integrating shipping into the ETS is a positive step in the right direction and will put shipping on the path towards climate neutrality in line with the Paris Agreement.

Overview T&E supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector, but only if certain conditions are met for such a mandate to provide both a clear environmental benefit and investor certainty.

St1 welcomes the EU’s Green Deal and supports the target to achieve climate neutrality in the EU by 2050. Even though the length, depth and the recovery profile of COVID19 caused reduction in the aviation activity level is not known yet, it is fair to assume that it will reach and surpass the pre-corona levels significantly, over the coming decades.

Dear Madam or Sir, Please find attached T&E's position paper on the ReFuelEU Aviation Regulation, which includes our recommendations for SAF targets. We believe that the text has a solid basis, especially when it comes to its scope applying to all departing flights and its exclusion of food and feed crop-based biofuels.