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Innovation Fund – evaluation of its operation
Carbon Market Watch critiques the EU Innovation Fund for disproportionately funding carbon capture and storage (CCS) and carbon capture and utilisation (CCU), particularly in the cement and lime sector. The organization argues that the fund should prioritize technologies that encourage material savings and explicitly include material saving as a mandatory assessment criterion for projects.
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Document type: Statement
Feedback to call for evidence - ETS1 review
Carbon Market Watch argues that the EU ETS1 fails to drive industrial decarbonisation due to the continued allocation of free emission allowances, which it claims undermines the carbon price signal for sectors like steel, cement, and chemicals. The submission calls for the complete phase-out of free allocations and indirect cost compensation, suggesting that any remaining benefits be tied to decarbonisation milestones. It further advocates for expanding the ETS scope to cover all departing flights from 2027, including non-CO2 effects and flights to third countries, and extending maritime coverage to 100% of extra-EEA routes and all small ships by 2027. Regarding market stability, the document suggests maintaining existing Market Stability Reserve (MSR) and Linear Reduction Factor (LRF) rules until 2035 to preserve investment signals. Finally, it strongly opposes the integration of carbon removals into the EU ETS to avoid mitigation deterrence and the risk of using removals as a substitute for actual emission reductions.
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Document type: Statement
Guidance on Border Carbon Adjustment
This report presents guidelines for designing Border Carbon Adjustment (BCA) mechanisms, based on global stakeholder dialogues. It offers specific recommendations on measuring embodied GHG emissions, determining sectoral coverage, managing revenues, and crediting foreign carbon prices. The guidance emphasizes 'parallel treatment' between domestic and foreign producers and suggests mechanisms to support small and medium-sized enterprises (SMEs) and developing countries in their low-carbon transition, while cautioning against blanket country exemptions to maintain the effectiveness of leakage prevention.
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Document type: Report
How States Can Lead the Charge on Industrial Decarbonization
The industrial sector accounts for nearly a quarter of US greenhouse gas emissions in 2022, characterized by process-based and high-temperature emissions. Using an analysis of Washington state, RMI demonstrates that emissions-intensive, trade-exposed (EITE) sectors—particularly refineries, which produce 68 percent of EITE emissions—could reduce emissions by 39 percent by 2035 and 91 percent by 2050. This transition would require an additional 13,975 GWh of annual electricity by 2050 in Washington, representing a 65 percent increase in industrial demand. To enable this, states must leverage tools such as grid access, permitting reform, and financial supports like green banks to complement federal incentives.
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Document type: Briefing
Opportunities for Industrial Modernization in Washington
RMI's analysis of Washington's emission-intensive, trade-exposed (EITE) industrial sectors indicates that existing and near-term technologies can reduce emissions by 39% by the end of 2034. The report argues that these potential reductions justify updating the state's Cap-and-Invest program after 2034 with sectoral benchmarking and new no-cost allowance reduction schedules to maintain efficiency and equity. To support this transition, RMI provides 18 policy recommendations categorized by focus area—Updating Standards and Regulations, Cap-and-Invest Program Evolution and EITE Treatment, and State Support—and prioritized by urgency.
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Document type: Report
Accelerating the deployment of clean power technologies to reliably decarbonise Europe through enhanced planning and contracting mechanisms
The report argues for a 'hybrid market model' in Europe that combines proactive procurement for the market with competition in the market to ensure a reliable, 24/7 decarbonised power system. It identifies significant gaps in current National Energy and Climate Plans (NECPs), noting that many Member States are not on track to meet 2030 EU targets. To address this, the authors recommend expanding system needs assessments to include flexibility and resilience (including climate and cyber risks) and extending their time horizon to 2050. On the contracting side, the report suggests enhancing Power Purchase Agreements (PPAs) through standardisation and public demand, and improving Contracts for Difference (CfDs) by embedding dispatch incentives to avoid distorting market signals. It also proposes a tripartite contracting framework involving a central public entity to hedge risks for both the state and industrial consumers, thereby fostering industrial electrification and competitiveness.
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Document type: Report
OVERCOMING ALL BARRIERS TO INDUSTRIAL ELECTRIFICATION
The report argues that direct electrification is the most efficient way to decarbonize industrial process heat, outperforming alternatives like green hydrogen, bioenergy, and carbon capture. It identifies three primary barriers: economics (high electricity costs relative to fossil fuels), grid readiness (slow interconnection and outdated planning), and technology maturity (lack of awareness and scale for high-temperature solutions). To overcome these, the authors recommend a combination of financial incentives (such as a Clean Heat Production Tax Credit), grid reforms (including surplus interconnection and real-time pricing), and foundational RD&D and workforce training.
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Document type: Report
India’s 2035 Climate Target: A Business Opportunity for Growth and Global Leadership
The document argues that India's next NDC for 2035 should reflect technological progress and corporate ambition to attract investment and ensure energy security. It proposes three pillars for action: raising NDC ambition with clear sectoral targets, implementing consistent policies across power, industry, transport, and nature, and strengthening government-business engagement. The briefing highlights that 99% of Indian executives support a transition to renewable energy and suggests specific policy levers, such as Zero Emission Vehicle (ZEV) targets and the National Carbon Market, to accelerate decarbonization.
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Document type: Briefing
Opportunities for federal leadership: Energy innovation, commercialization, and deployment
The policy brief outlines federal leadership opportunities to bolster U.S. energy security and global competitiveness through the deployment of carbon capture and storage (CCS), advanced nuclear fission and fusion, and superhot rock geothermal energy. It emphasizes the need to bridge the "missing middle" investment gap—where projects are too large for venture capital but too risky for institutional investors—by utilizing a combination of R&D funding, demonstration grants, and extended tax credits. Key recommendations include increasing the 45Q tax credit to $120, extending tech-neutral credits (48E and 45Y) through 2040, and streamlining permitting for CO2 pipelines and Class VI wells. The brief also calls for scaling the nuclear supply chain, modernizing spent fuel policy, and establishing a Geothermal Center for Excellence to ensure the U.S. maintains a competitive edge against international mechanisms like the EU's Carbon Border Adjustment Mechanism.
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Document type: Policy brief
Powering China’s New Era of Green Electrification
China has surpassed its 2030 wind and solar capacity targets six years early, with clean electricity meeting 84.2% of additional demand in 2024. However, the report argues that the 'more renewables, more coal' era is ending and the next phase requires a shift from adding capacity to engineering a 'megasystem' involving smart grids, long-duration storage, and industrial electrification. While the 'new three' sectors (solar, batteries, EVs) have driven GDP, they face saturation and competition, making the development of next-generation technologies essential for sustaining China's 'growing by greening' economic strategy.
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Document type: Report
Hydrogen hubs are key to domestic energy production and regional economies across the U.S.
The Regional Clean Hydrogen Hubs program is designed to demonstrate localized hydrogen production and end-use to create a synergistic national hydrogen economy. The author warns that planned funding cuts by the Trump administration would jeopardize an estimated 334,280 jobs and tens of billions of dollars in private sector investment. The document emphasizes that a network of hubs is necessary to create a viable market for hydrogen-fueled equipment and to maintain U.S. leadership in low-carbon hydrogen production and technology exports.
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Document type: Statement
Designing decarbonisation pathways for heavy industry in Central and Eastern Europe
The document argues that Central and Eastern European (CEE) countries must implement coordinated national and regional strategies to decarbonise heavy industries like refining and ammonia production. It identifies four priority actions: cost-competitive policy design, targeted deployment in industrial clusters, shared financial risk schemes, and cross-border collaboration for infrastructure. The analysis highlights that CEE accounts for nearly 25% of EU hydrogen consumption, with Poland as the dominant user, and emphasizes that the lack of domestic regulatory frameworks for CO2 storage in Poland currently forces a reliance on more expensive export options.
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Document type: Briefing
Improving Green Competitiveness for Inclusive Transformation
The document argues that traditional nationalistic industrial models must shift toward collaborative frameworks to avoid excluding developing nations from green value chains. It suggests strategies such as disaggregating energy-intensive production to regions with abundant renewables, moving from 'technology transfer' to 'sharing of know-how', and utilizing industrial clusters to reduce costs and aggregate demand. The paper emphasizes the role of Multilateral Development Banks (MDBs) in providing concessional capital and the potential for 'climate-smart' public-private partnerships, including philanthropic funding, to bridge financial gaps. It highlights the importance of regional trade frameworks and the need to recycle revenues from carbon border measures back into developing economies to catalyze green industrialisation.
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Document type: Briefing
Navigating CBAM in China: Exploring Policy Pathways for Guangdong Province
The report analyzes how the EU's Carbon Border Adjustment Mechanism (CBAM) affects Guangdong province, a major hub for iron, steel, and aluminium exports. While initial exposure is limited, the report warns that pressure will increase as CBAM expands. It recommends that Guangdong accelerate industrial decarbonization—specifically through electrification and green hydrogen for steel and renewable energy for aluminium—and establish a carbon pricing system compatible with the EU Emissions Trading System (ETS). Additionally, it suggests that EU policymakers enhance dialogue on emissions accounting, allocate CBAM revenues to support climate action in developing economies, and engage in international platforms like the Climate Club.
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Document type: Report
RE-powering India’s heavy industries: 20 GW today, 24/7 tomorrow
India's heavy industries—steel, cement, and aluminium—have a 20 GW profitable opportunity to integrate solar power today through green energy open access, potentially reducing annual emissions by 29 million tonnes. While sourcing 50% renewable energy (RE) is currently cost-effective without storage, achieving 24/7 RE is prohibitively expensive, costing up to 3.5 times the price of standard RE generation due to the massive battery storage and capacity oversizing required. The report highlights that steel offers the most immediate cost-saving potential, whereas aluminium remains heavily reliant on captive coal power, requiring stronger regulatory mandates to transition.
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Document type: Report
The new State aid Framework to support the Clean Industrial Deal
ClientEarth's response to the CISAF consultation emphasizes the need for horizontal integration of the 'Do No Significant Harm' (DNSH) principle and the removal of aid for fossil gas in industrial decarbonisation. The organization warns that proposed 36-month project completion deadlines may compromise environmental permitting and public participation. It further advocates for stricter conditions on carbon capture and hydrogen aid, suggesting that support be limited to 100% renewable hydrogen and hard-to-abate sectors.
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Document type: Statement
FLEXIBLE, CLEAN INDUSTRY AND SUSTAINABLE ENERGY POWER STRONG ECONOMIES
The document proposes an "energy park" model that co-locates renewable generation with flexible industrial loads and long-duration storage to replace retiring coal capacity. Using Pueblo, Colorado, as a case study, the authors model a system combining 2,000 MW of solar, 1,600 MW of wind, short-duration batteries, and flexible loads (thermal batteries and electrolyzers). The findings indicate that such a park can achieve 99% reliability in mimicking the dispatch of the Comanche Unit 3 plant while providing significant local economic benefits, including over $40 million in annual property taxes and 350 permanent jobs. Financially, the energy park is estimated to be at least 50% cheaper for electricity ratepayers than a comparable small modular nuclear reactor.
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Document type: Case study
STRATEGIE DE DEVELOPPEMENT A LONG TERME A FAIBLE EMISSION DE CARBONE ET RESILIENT AU CLIMAT DU TOGO
Togo's LT-LEDS 2025-2060 aims for carbon neutrality by 2060 through a 'conforming' scenario, focusing on the AFAT (Agriculture, Forestry, and Other Land Use) and Energy sectors. The strategy requires an estimated investment of 11,920.59 billion FCFA (19.87 billion USD), with 67% allocated to mitigation and 28% to adaptation. Key goals include increasing forest cover to 30% by 2050 and achieving 75% renewable energy in the energy mix by 2060. The document also details a comprehensive adaptation plan for sectors including health, water resources, and coastal zones, while integrating gender equity and social inclusion into climate action.
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Document type: Report
Powering Progress: Industrial Decarbonization Planning at the State Level
The report examines 26 state-level Priority Climate Action Plans (PCAPs) submitted under the Climate Pollution Reduction Grants (CPRG) program, finding that most plans rely on generalities and high-cost incentives rather than sector-specific strategies. It argues that states must transition from high-level commitments to tailored, long-term roadmaps that prioritize cost-effective tools, such as operating-cost supports and regulatory standards, while leveraging co-benefits like public health improvements and workforce development to maintain American industrial competitiveness against international peers like China and the EU.
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Document type: Report
The State of the European Steel Transition
The document argues that while Europe leads in near-zero emission steel innovation, it faces increasing competition from China and the MENA region. It calls for urgent policy action in 2024, specifically recommending the phase-out of coal-fired blast furnaces and the advancement of hydrogen-based green steel to secure jobs and industrial resilience. The text also critiques the Commission's Steel and Metals Action Plan (SMAP) for lacking input from environmental NGOs.
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Document type: Press release