# Emissions ETS געזעץ קאַנטראַדיקץ די קאָמיסיע ס בעסער רעגולירן פּאָליטיק

The legislative proposal revising the EU Emissions Trading System (ETS)  for greenhouse gas emissions is based on data and analysis that cannot be independently verified, says a new ייי לערנען.  Proper scrutiny of the legislation is impossible since the underlying analytical model is not accessible, despite many requests from stakeholders for full transparency.  The Impact Assessment also did not fully analyse all the policy options reflected in the proposal.  These factors undermine the Commission’s intentions for Better Regulation.  The study concludes that the data and Impact Assessment are an insufficient basis to support decision-making in such a key area of public policy.

The IAI studied the Commission’s Impact Assessment SWD (2015) 135 accompanying its legislative proposal on the revision of the EU Emissions Trading System (ETS) for the post-2020 period.  Fundamental to the legislation is the already adopted 40% greenhouse gas reduction target by 2030, which was supported by the Impact Assessment for the January 2014 Commission Communication on Climate & Energy Policy to 2030.

However, the 2014 Impact Assessment utilised an analytical model whose inputs and outputs were not published and whose algorithms are not available for public scrutiny.  The result is that EU Climate & Energy policy and the ETS revision legislation are based on intransparent data and analysis, preventing validation by stakeholders of the targets and policy measures.

In addition, the ETS revision Impact Assessment does not explicitly assess the option package for free allocation of emission allowances that is embedded in the legislative proposal.  This denies stakeholders the possibility to analyse the specific evidence and rationale behind the chosen legislative approach.
In conclusion, to allow independent validation of EU Climate & Energy policy and the ETS legislation, all details of the underlying models should be publicly available.  This would generate confidence amongst all stakeholders in the policy provisions and legislation, enhancing the value and level of acceptance of the final outcome.

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