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The document critiques the proposal for 'dynamic allocation' of free emission allowances in the EU ETS post-2020, which would remove caps on free permits for industrial sectors. It argues this model enables windfall profits, reduces incentives for innovation, and shifts a significant financial burden to taxpayers. The author recommends full auctioning of allowances as the default method to uphold the polluter-pays principle and suggests using auctioning revenues to fund an industrial innovation fund for low-carbon technologies.

The EU ETS is currently failing to promote low-carbon solutions due to a carbon price that has plunged to around 5 euros per tonne of CO2, driven by a surplus of 2.1 billion tonnes of CO2-equivalent allowances. This oversupply is attributed to weak emission targets, the inflow of international offsets, and reduced demand following the economic crisis. The document warns that this surplus allows the EU to transform current emission reductions from other policies into 'future rights to pollute', potentially reducing the domestic impact of the 2030 climate target from 40% to 34%. To fix the market, the author recommends increasing the linear reduction factor to 2.6%, permanently cancelling 1.6 billion excess allowances, enacting the Market Stability Reserve by 2017, and transitioning to full auctioning for all industrial sectors post-2020 to eliminate windfall profits and adhere to the polluter-pays principle.

The report analyzes the steel sector's transition to a low-carbon future, noting that while current carbon pricing (like the EU ETS) has had limited impact on plant location and investment, deeper emissions cuts will require breakthrough technologies such as carbon capture and storage (CCS). It emphasizes the need for collaborative research, development, demonstration, and deployment (RDD&D) and suggests a 'coalition of the willing' among major steel-producing nations to maintain competitiveness while decarbonizing.

The report argues that China can achieve a deep carbon reduction by 2050 through sectoral transformations in electricity, industry, transport, and buildings, provided it receives international financial and technological support. It proposes a combination of domestic carbon taxes, a future cap-and-trade system, and a new 'Inter-country Joint Mitigation Plan' to facilitate technology transfer. The analysis emphasizes that a low-carbon transition is essential for China's modernization, offering opportunities to move up the value chain and improve energy security, though it will require active labour market policies to manage job losses in heavy industry.

The report presents a mitigation scenario for the EU27 to reduce greenhouse gas emissions by 40% in 2020 and 90% by 2050 relative to 1990 levels. This is achieved through radical energy efficiency, a shift to renewables, and the phase-out of fossil fuels, nuclear power, and carbon capture and storage. The analysis also estimates that Europe's fair share of international climate finance for developing nations would range between €150 billion and €450 billion by 2020.

The document analyzes the Indian steel industry's high carbon intensity, driven by a proliferation of inefficient small-scale coal-based direct reduced iron (DRI) units and small blast furnaces. It argues that current project-based mechanisms like the Clean Development Mechanism (CDM) are insufficient for systemic change. The author proposes a combination of a harmonised carbon tax and administered manufacturing standards to incentivize a shift toward larger, more efficient blast furnace-basic oxygen furnace (BF-BOF) units and the long-term substitution of steel with low-carbon materials. The paper emphasizes that international cooperation in technology transfer and capacity building is essential to support these domestic policy shifts.

The submission argues that the EU ETS is the only credible mechanism for a common carbon price in Europe but requires reform post-2012 to be effective. The authors advocate for a shift from free allocation to auctioning to remove investment distortions and 'early action' problems. To protect low-carbon investments from price volatility, they suggest reserve prices for auctions or put options. While acknowledging carbon leakage, the report asserts it only affects a few specific sub-sectors—such as semi-finished steel and clinker—and suggests that border adjustments or sectoral agreements are preferable to free allocations, which are viewed as a second-best, temporary option.

The Appalachian Regional Clean Hydrogen Hub (ARCH2) is projected to create over 21,000 direct jobs, including 18,000 in construction and 3,000 permanent positions, through 11 major projects in Pennsylvania, West Virginia, and Ohio. The initiative involves a broad coalition of partners including project developers like Air Liquide and Plug Power, industrial equipment providers such as Baker Hughes and Bloom Energy, and various government, academic, and labor organizations across the region.

The document addresses common concerns and misconceptions regarding carbon capture and storage (CCS), asserting that it is a proven technology essential for reaching net-zero emissions, especially in industries like cement and steel where electrification is insufficient. It highlights Europe's significant storage potential and the role of government funding in scaling the technology.

The document outlines the three-stage process of carbon capture and storage (CCS)—capture, transport, and storage—and argues that these technologies are essential for decarbonizing hard-to-abate industries like cement and natural gas processing. It highlights Colorado's significant geologic storage capacity, estimated at nearly 150 billion metric tons of CO2, and identifies the Denver Basin, Cañon City Embayment, Piceance, and Sand Wash basins as potentially suitable sites. Economically, the document cites Rhodium Group estimates that CCS deployment could create 1,060–1,580 operational jobs and nearly 400 transportation infrastructure jobs annually over 15 years. It also details financial incentives, including the federal 45Q tax credit (offering up to $180/ton for direct air capture) and state-level support via the Colorado Industrial Tax Credit Offering and the Clean Air Program (CAP). Finally, it addresses safety concerns, noting that EPA Class VI permits regulate storage to protect drinking water and that CO2 pipelines have a long safety record in the U.S.

The Inflation Reduction Act of 2022 enhances the 45Q tax credit to make carbon capture and storage more accessible for hard-to-abate industries and direct air capture. Key changes include increased credit values, an extended construction window until 2033, the introduction of direct payment options, and lower capture thresholds for qualifying facilities.

The document outlines the three-stage process of carbon capture and storage (CCS)—capture, transport, and storage—and argues that the Midwest is uniquely positioned for deployment due to its industrial profile and geologic formations. It highlights the Illinois Basin, specifically the Mount Simon sandstone and Eau Claire formation, as a premier storage resource with an estimated capacity to store over 147 billion metric tons of CO2. The text notes that CCS can reduce harmful air pollutants and create between 8,050 and 11,880 operational jobs in Illinois, Indiana, Michigan, and Ohio. Financial viability is driven by the 45Q tax credit, which offers up to $180/MT depending on the method of capture and storage. Safety and regulatory oversight are managed by the EPA's Underground Injection Control Program and PHMSA.

The document argues that carbon capture and storage (CCS) is essential for the EU to achieve climate neutrality by 2050, particularly for harder-to-abate sectors like cement, steel, and chemicals. The signatories call for the Clean Industrial Deal to address critical gaps, including the lack of operational commercial-scale storage sites in the EU and the need for cross-border transport networks. Key recommendations include ensuring geographically balanced storage development to avoid leaving Central, Eastern, and Southern Europe behind, creating strong demand signals for decarbonised products through public procurement, and addressing funding gaps via the Competitiveness Fund and Important Projects of Common European Interest (IPCEI). The letter also emphasizes the need for international partnerships, specifically mentioning the removal of regulatory barriers to access storage in the UK and the Mediterranean Sea.

The document identifies cement manufacturing as responsible for 1.1% of total U.S. emissions, with 60% of those emissions stemming from the chemical process of calcination. It highlights three primary decarbonization pathways: feedstock substitutions and alternative production processes (including non-kiln pathways), clinker substitution using materials like slag or calcined clays, and Carbon Capture, Utilization, and Storage (CCUS). To accelerate adoption, the document recommends low-interest loans, public procurement standards requiring Environmental Product Declarations (EPDs), state-funded pilot programs, and Contracts for Difference (CfDs).

The U.S. chemical manufacturing sector accounts for 2.9% of total U.S. emissions, totaling 186 MMT CO2e. Decarbonization strategies include process electrification (such as electric steam crackers), replacing fossil-based feedstocks with clean hydrogen or bio-based inputs, and deploying carbon capture, utilization, and storage (CCUS). To accelerate these transitions, the document recommends that states implement supplemental tax incentives for CCUS and hydrogen, establish public procurement commitments for low-carbon chemicals, and offer accelerated depreciation for low-carbon equipment.

The document argues that for Central and Eastern Europe (CEE) to maintain industrial competitiveness and meet climate targets, it must rapidly deploy carbon capture and storage (CCS). A critical barrier is the current reliance on exporting CO2 to the North Sea, which increases costs; the report finds that developing domestic storage could reduce deployment costs by 23% to 48%. To bridge the funding gap between high deployment costs and the EU ETS price, the brief recommends a 'Coordinator' role for governments to align value chains, leverage EU funds like the Innovation Fund and Connecting Europe Facility, and implement de-risking tools such as carbon contracts for difference (CCfDs). Case studies of the Porthos (Netherlands) and Northern Lights (Norway) projects illustrate how layered public-private financing, including state-owned enterprise (SOE) participation and capital grants, can lead to final investment decisions.

The U.S. iron and steel sector accounts for 1.0% of total U.S. greenhouse gas emissions, totaling 63 MMT CO2e. While 70% of U.S. steel is already produced via electric arc furnaces (EAFs), which emit 75–90% less CO2 than blast furnaces when using clean energy, the remaining 30% of production relies on coal-fired blast furnaces. Key decarbonization pathways include expanding EAF capacity, deploying carbon capture, utilization, and storage (CCUS) for existing blast furnaces, and scaling hydrogen-based direct reduced iron (H2-DRI). Recommended state-level policies include providing low-interest loans or grants for capital financing, setting low-carbon procurement standards for public projects, and supporting clean hydrogen hub development.

The petroleum refining sector accounts for 2.6% of total U.S. emissions, totaling 164 MMT CO2e, with 136 facilities classified as high-emitting. Decarbonization pathways include energy efficiency upgrades, fuel-switching to alternatives like renewable diesel and biogas, and the deployment of carbon capture, utilization, and storage (CCUS), particularly at fluid catalytic crackers. To support these transitions, the document recommends that states implement supplemental tax incentives for CCUS and clean hydrogen, expand accelerated depreciation for low-carbon retrofits, and provide capacity-building support such as permitting assistance and workforce training.

The document outlines the necessity of shared CO2 transport and storage 'hubs' to enable the decarbonization of emissions-intensive industries and the deployment of Direct Air Capture in the U.S. It identifies critical barriers—including high costs, a 'chicken-and-egg' challenge between capture and transport, and the need for future-proof capacity—and proposes the SCALE Act as a solution. The Act includes programs for cost-sharing storage hubs, increased EPA permitting funding, FEED grants, and low-interest loans via the CO2 Infrastructure Finance and Innovation Act (CIFIA). The text notes that while the U.S. has 5,000 miles of existing CO2 pipelines, it lacks the comprehensive federal policy support seen in Canada, the EU, Norway, the UK, and Australia.

The Build Back Better Act (H.R. 5376) allocates $555 billion to climate change and clean energy to reduce emissions by over one billion metric tons by 2030. The legislation employs a sector-wide approach, providing tax credits and grants for zero-emission vehicles, clean hydrogen, carbon capture (via enhanced 45Q credits), and renewable energy. It specifically targets the decarbonization of heavy industry, the power sector—including support for existing nuclear plants—and agricultural and forestry sequestration, while directing 40% of investment benefits to disadvantaged communities.