ERCST’s rationale accompanying the submission to the Public Consultation for the EU climate target for 2040

Chapeau

The European Roundtable on Climate Change and Sustainable Transition (ERCST) welcomes the opportunity to participate in the European Commission’s public consultation for the EU climate target for 2040.

ERCST’s response to the Public Consultation builds on the work that it has done previously, and a long- term interest and examination of issues related to addressing EU climate policy and competitiveness.

The questionnaire does not allow room for nuanced answers, which are necessary in order to provide a realistic position which takes into account the realities in which 2040 targets will need to be set in. ERCST feels that it is necessary to provide a rationale accompanying each of the relevant answers. EU Climate Policy is not operating in isolation and needs to be considered under a holistic approach, both through its interlink with other EU Climate Policies and in perspective with international climate developments taken by non-EU jurisdictions.

Some of the terms used in the questionnaire are not defined and can be used for purposes other than what the respondent has in mind. Some questions provide examples which significantly broaden the scope of the questions and can lead to misinterpretation.