Climate Policy Engagement Analysis
Climate Policy Engagement Overview: The Community of European Railway and Infrastructure Companies (CER) is actively and positively lobbying EU climate change policy in 2021-23. CER expresses top-line support for the EU’s Green Deal, while advocating for more ambition under the EU Emissions Trading Scheme, the taxation of jet fuel, the development of high-speed rail, and policies to promote a low-carbon modal shift to rail.
Top-line Messaging on Climate Policy: CER’s top-line statements in 2021-23 have expressed support for the EU’s Green Deal and the need for regulation in response to climate change. In a June 2022 fact sheet, CER supported GHG emissions reductions in line with a 1.5°C target and in a November 2022 essay, CER stated support for the EU’s Green Deal. In a July 2021 fact sheet, CER advocated for a carbon pricing in transportation, stating that it would “level the playing field for transport modes”. CER also seemed to support national and EU policy in response to climate change, including the Fit for 55 package, in a March 2022 essay. Similarly, a May 2021 joint letter, signed by CER, appeared to advocate for an “ambitious approach” under the Fit for 55 package. A May 2022 open letter, signed by CER Executive Director, Alberto Mazzola, expressed support for the Paris Agreement.
Engagement with Climate-Related Regulation: In 2021-23, CER appeared to advocate for a more ambitious EU Emissions Trading Scheme (EU ETS). In a July 2021 fact sheet and December 2021 position paper, CER stated support for the extension of the EU ETS to all modes of transport, and the phase-out of aviation’s free emissions allowances. Similarly, in a January 2021 EU consultation response, CER supported the extension of the EU ETS to all international flights and opposed aviation’s free emissions allowances. In a February 2021 EU consultation response, CER appeared to support the full inclusion of maritime under the EU ETS, including all emissions from intra-EEA and extra-EEA voyages. CER Executive Director, Alberto Mazzola, described the application of the EU ETS to maritime and road transport, alongside extending the coverage of aviation, as a “positive step”, in an April 2023 press release.
Regarding a low-carbon modal shift to rail, in a November 2021 pledge, CER advocated for policy to “send a strong signal and make rail the default option”. CER supported the implementation of the Trans-European Network for Transport (TEN-T) to enable a modal shift to rail in a December 2022 publication and in a December 2021 fact sheet, CER stated that the “TEN-T policy should support modal shift from air and road connections to a European high-speed and conventional railway network and to rail freight”. CER also advocated for “dedicated concrete policy” to meet modal shift targets in a November 2021 essay. In a May 2021 position paper, CER appeared to support national modal shift initiatives and advocated for an EU approach. CER further advocated for measures to promote a low-carbon modal shift from short-haul aviation to rail in a January 2021 consultation response. CER Executive Director, Alberto Mazzola, also appeared to urge the EU Commission to develop a strategy to protect its modal shift objectives in a September 2022 press release.
In a December 2021 position paper, CER supported an “ambitious” EU Effort Sharing Regulation (ESR), complemented by GHG emissions reductions targets for 2030 and 2040. Similarly, a July 2021 fact sheet, appeared to advocate for a more ambitious ESR which requires member states to set interim GHG emissions reduction targets for transport. In a November 2021 essay, CER also appeared to support GHG emissions standards for road transport.
Positioning on Energy Transition: In 2021-23, CER appeared to support the transition of the energy mix for transportation. CER stated support for the Sustainable and Smart Mobility Strategy, including its target to double high-speed rail by 2030, in a November 2021 pledge. A January 2023 study commissioned by CER further supported policies promoting the development of high-speed rail. In a March 2022 essay, CER also supported the completion of the TEN-T, Sustainable and Smart Mobility Strategy targets for high-speed rail, and advocated that renewable electricity is used to power rail. In a April 2021 position paper, CER also advocated for the increased use of green hydrogen in rail, and supported the inclusion of rail under the Alternative Fuels Infrastructure Regulation. CER Executive Director, Alberto Mazzola, appeared to support the TEN-T and the implementation of a high-speed rail network in Europe in a December 2021 press release. However, a May 2021 joint letter, signed by CER, appeared unsupportive of reduced tolls for low-and zero-emissions trucks, citing modal shift concerns. In a July 2024 consultation response, accessed via freedom of information request, CER also opposed mandatory zero-emission targets on functional vehicles operated by railway companies.
CER also appeared to support the taxation of jet fuel under the Energy Taxation Directive in 2021-23. In a July 2021 fact sheet, CER stated that fossil fuel subsidies in transport should end by taxing kerosene and high-carbon fuels. CER also appeared to advocate for an EU jet fuel tax in a December 2021 position paper, while asserting that rail should have exemptions while kerosene receives exemptions. In a December 2021 press release, CER also advocated for the abolishment of VAT on international train tickets and “equal treatment in energy taxation” for air and rail.