Sandbag Climate Campaign CIC
Ember
Ember is the trading name for the Community Interest Company Sandbag Climate Campaign CIC.
ID: 94944179052-82
Lobbying Activity
Meeting with Dan Jørgensen (Commissioner) and
27 Nov 2025 · COP 30 Phase out of Russian Fossil fuels Energy Seucrity Framewrok
Meeting with Pascal Canfin (Member of the European Parliament)
28 Oct 2025 · Paquet réseau
Response to European grid package
23 Jul 2025
Embers full response is attached, with the relevant research and findings linked in the document. The key messages are summarised below. Ember recommends the upcoming legislation: 1. Recognises grids as strategic infrastructure for economic growth and competitiveness 2. Establishes a one-stop shop for grid financing that consolidates multiple EU funding streams and simplifies access to financing for grid infrastructure projects. 3. Sets out a new planning approach, firmly anchored in EU legislation, that reflects the following principles: 3a. Independent and integrated planning 3b. Harmonisation of energy system planning processes for coordination, consistency and reduction of administrative burdens 3c. A minimum planning horizon of at least 20 years for national grid development plans to enable anticipatory investments 3d. National Regulatory Authorities having a mandate to deliver on energy and climate objectives 4. Supports the better utilisation of existing infrastructure through deployment of flexibility and grid enhancing technologies by adopting a TOTEX-based regulatory approach 5. Strengthens TSODSO collaboration through data standards and visibility of distributed assets 6. Improves the EUs cost-benefit cost allocation (CBCA) framework for cross-border infrastructure by advancing the CBCA decision in project timelines and broadening the scope, amongst others 7. Requires system operators to publish grid-related data in a standardised, accessible and transparent format to monitor progress and unlock opportunities 8. Promotes the use of open-source modelling tools to support transparency, enable harmonisation across planning processes, and facilitate TSO-DSO coordination
Read full responseResponse to Fitness check – energy security architecture
25 Nov 2024
Energy security has risen to the top of the EUs political agenda, yet much remains to be done. The EU cannot continue relying on imported fossil fuels, putting its energy security in the hands of hostile nations. Solutions like wind, solar, battery storage, demand flexibility and electrification of transport and heating, coupled with power grid investments and cross-border collaboration, are already reducing fossil fuel consumption. But the pace of the energy transition needs to accelerate if the EU is to become self-sufficient, and thus secure for generations to come. The following recommendations mark a pathway towards the EUs ultimate energy security based on clean power and electrification. Broader analysis and data is provided in the attached document and referenced reports. 1. Accelerate the deployment of renewable energy sources The EU should intensify efforts to expand wind and solar power capacities. From 2019 to 2023, wind and solar electricity generation in the EU increased by 46%, displacing a fifth of fossil fuel electricity. Even during winter months, renewables and demand reductions are able to minimise fossil fuel electricity generation. However, renewables targets in EU Member States still fall short of the REPowerEU plan, hitting 66% of renewable electricity generation by 2030 compared to the 72% goal. Setting and delivering ambitious wind and solar targets will not only cut dependency on imported fossil fuels, but also enhance security by reducing single points of failure typically associated with centralised power systems. Solutions like agri-pv can additionally enhance food security. 2. Ramp up Smart Electrification Developing a clear electrification roadmap is essential for reducing reliance on imported fuels and harnessing domestic energy resources. Ember's analysis shows that homegrown energy sources can increasingly meet EU energy needs, reaching 85% in 2040, up from 41% in 2019. Electrification would also facilitate the complete stop of the EUs fossil fuel imports from Russia, with Russias gas used largely in heating. The bloc continues to import fossil fuels from Russia, financing a country that remains the single biggest threat to the EUs security. The EU needs to take much firmer and faster action to cancel all fossil fuel imports from Russia by 2027 at the latest. 3. Accelerate the deployment of clean flexibility To ensure stable supply of electricity, the EU must prioritise clean flexibility, improving market access for energy storage technologies and demand side flexibility. This will reduce the reliance on fossil gas for power balancing needs. For instance, in June 2024, an additional 2 GW of battery storage could have saved Germany 2.5 million in fossil gas imports. The Strategic agenda for the new EU mandate and political priorities of the newly designated EU Commission plan for ambitious electrification and investment in storage, but this is not reflected in many National Energy and Climate Plans. 4. Enhance grid infrastructure and cross-border interconnections Strengthening the EU's grid infrastructure and cross-border interconnections is crucial for energy security. Ember recommends the establishment of a dedicated Future Grids task force with the Commission, to efficiently deliver on its existing grid-related provisions. One-stop-shops that pool together multiple funding streams could improve access to grid financing. The role of interconnection in providing energy security should also be acknowledged, with projects such as the Baltic State synchronisation project being critical for the security of nations on NATO's eastern flank. Despite this, the vast majority of interconnection investments are planned in Western and Southern Europe, with Central and Eastern Europe yet to fully recognize the potential of North-South connectivity. A more active role of the European Commission in facilitating such cross-border cooperation would benefit the security of the whole bloc.
Read full responseMeeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)
19 Nov 2024 · climate policies
Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)
2 May 2023 · Methane regulation
Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)
9 Feb 2023 · Presentation of Ember report about the European electricity transition “European Electricity Review 2023”.
Meeting with Jens Geier (Member of the European Parliament, Shadow rapporteur)
6 Feb 2023 · Exchange on the Methane Regulation (Staff Level)
Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and The Green Tank
18 Jan 2023 · RePowerEU implementation
Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Global Witness
28 Jun 2022 · Discussion about RePowerEU Plan and the impacts on climate neutrality objectives
Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)
16 Dec 2020 · Methane emissions from coal
Response to Updating the EU Emissions Trading System
25 Nov 2020
Whilst the EU ETS price has seen a significant increase over the recent years, the carbon market is not yet resilient to external factors, and so a stable and growing carbon price is not guaranteed. As the European coal phase-out accelerates, and wind and solar become the cheapest energy source across most of Europe, the gap between the ETS cap and real emissions will continue to grow. The EU ETS cap is also not yet orientated with Europe’s long term climate targets.
The EU ETS should be reformed in the following ways:
1) Rebase the cap to bring it down to real emissions - to tackle the existing structural allowance surplus and the expected increase to the surplus in coming years as the European coal phase-out accelerates, and following effects from the COVID-19 pandemic.
2) In addition to rebasing the cap, the Market Stability Reserve (MSR) will likely need to be reinforced with an increase in the intake factor, alongside cancellation of allowances which have been in the reserve for more than 5 years.
3) A new Linear Reduction Factor (LRF) must be set that brings the ETS cap to zero before 2050, ensuring ETS sectors are on the pathway to zero emissions well before the middle of the century.
4) Introduce a carbon border adjustment mechanism
-First for the electricity sector, to tackle coal power ‘leaking’ into Europe
-Secondly for all other sectors, to end any risk of carbon leakage, and enable the withdrawal of free allocation to industry
5) Expand the geographic scope of the EU ETS, to include Energy Community countries
6) Expand the sectors covered by the EU ETS, especially:
-Introduce a carbon price for biomass burnt for power, which should not be assumed to be carbon neutral
-Explore expanding the EU ETS to cover methane leakage, especially coal mine methane leakage
7) As further protection against flaws in the EU ETS design, introduce a carbon floor price to give certainty to businesses and investors.
The carbon price is only a backstop to support other climate policy. Alongside improvements to the ETS, and bringing the Effort Sharing Regulation target in line with net zero, the EU needs to deliver a comprehensive strengthening of all climate and energy policy to meet the new 2030 target.
To further boost support for carbon pricing across Europe, the ETS directive should encourage member states to use ETS auction revenues as a carbon dividend to citizens.
Read full responseResponse to Revision of the guidelines for trans-European Energy infrastructure
8 Jun 2020
The power sector is key to delivering a net-zero energy system, as electrification (direct or indirect) drives emissions reductions. As the Commission correctly acknowledges in this roadmap, huge infrastructure investment will be required to enable this low-carbon revolution. Given the long timescales involved, it is crucial these projects are guided by robust, impartial evidence.
1) Infrastructure should anticipate an immediate and accelerating decline in fossil energy
The 4th PCI list should be the last to include fossil gas projects. A recent review of EU energy pathways [1] towards net-zero by 2050 found unanimous agreement across all pathways that fossil gas consumption decreases by 2030, and “dramatically decreases” by 2050.
Furthermore, it has been shown that the EU’s current fossil gas infrastructure is not only sufficient to cope with future demand, but resilient enough to maintain security of supply in the event of extreme supply disruption [2]. Investment in new fossil gas projects would therefore represent a catastrophic misdirection of public and private funds, at a time when investment in renewable energy and grid infrastructure is below what is needed.
Europe will eventually need large scale Hydrogen infrastructure. However, the efficiency, maturity, and supply of sustainable Hydrogen is currently limited. Projects should be prioritised in regions that have both high potential for large scale Hydrogen production from renewable electricity, and large potential offtakers in hard-to-decarbonise services and sectors. Repurposing existing gas infrastructure should be prioritised under the same conditions.
There is evidence that CO2 storage capacity will be needed as early as 2030. However, this should also be concentrated on difficult-to-decarbonise industries, as net-zero pathways do not show significant need for CCS in the power sector before 2050.
2) Increasing the share of RES in the power sector must be a priority
RES capacity must increase 2-3 fold to meet the EU target of at least a 50% reduction in CO2 emissions by 2030 [1]. Deployment of energy storage will be essential to maintain security of supply in a system that relies this heavily on variable RES. Batteries will be increasingly important, as well as smart grid technologies and demand side response. However, battery projects struggle to attract finance due to weak business cases and outdated regulation [3].
Despite this pressing need for flexibility, the 4th PCI list includes only 6 smart grid projects, and no battery storage (only pumped hydro and compressed air). It seems the current PCI criteria under-value the contribution of grid flexibility to security of supply, indicating a bias towards a supply-side paradigm.
PCIs should also address the differing deployment rates of RES across Europe. The roadmap rightly highlights the need for improved offshore grid infrastructure, crucial for north and west Europe. However, analysis of NECPs reveals the RES ambition gap is largest in CEE and SEE, suggesting this is where the real challenge lies.
Regarding interconnection with third countries, Ember research [4] has highlighted the risk of carbon leakage if this is not done in unison with a border carbon adjustment.
3) Ensure Independent and transparent infrastructure governance
The responsibility for writing the TYNDP should be expanded beyond the two ENTSOs. This will reduce conflicts of interest, and help rebalance scenarios towards demand-side and non-infrastructure solutions. The need for new infrastructure should be assessed against realistic predictions for future energy demand, which may be subject to significant downward revision as the efficiency first principle emerges as a central element to the EU’s green recovery.
[1] Tsiropoulos et al. (2020)
[2] Artelys (2020)
[3] EU pubs (2020): Study on energy storage- Contribution to the security of the electricity supply in Europe
[4] Ember: The Path of Least Resistance
Read full responseResponse to Carbon Border Adjustment Mechanism
31 Mar 2020
Response to the Open Feedback invitation on an inception impact assessment for the implementation of Border Carbon Adjustments.
This is Sandbag’s response to the March 2020 open feedback invitation launched by the European Commission on the topic of the introduction of Border Carbon Adjustments (BCAs). This policy tool is part of the current Commission President’s political mandate for 2019-2024 and of the EU Green Deal, as well as it is part of the EU Industrial Strategy. Our organisation’s response summarises the conclusions of our recent research work on BCAs.
It draws on analysis in Sandbag’s two recent reports on BCAs, published in December 2019 , which both provide further details on the issues covered here.
Conclusion on BCA from previous research: BCAs appear to be the most direct and best option for addressing the issue of creating a level playing field for EU industry on their way to developing net zero processes.
The EU Climate Law presented in March 2020 introduces the net-zero economy into EU law. It focuses on the importance of a trajectory as a means to reach this goal. This transition is imperative and requires urgent action, the longer we delay the bigger the burden left on industry, which would otherwise need to deliver a whole system change in less than 20 years (i.e. by pushing a change in the system post 2030).
The EU ETS is the only currently standing policy in the EU with its built in trajectory and will be of fundamental importance in capping emissions to ensure the net-zero goal is reached. Currently covering industry and power generation, it is clear that the trajectory will bring both to the same end point by 2050, even though looking at the past and next decade it is quite clear that industry has been lagging behind, partly due to the built in counter incentives the ETS has created for EU industry.
Free allocation of EUAs has been used until now to address the so-called “risk or carbon leakage” in industries covered by the EUETS. This system is flawed in several respects . Nevertheless, the use of free allocation combined with the low prices for EUAs prevailing for much of the last decade has meant that there is no evidence of significant leakage to date.
However, it is clear that free allocation is not sustainable into the long term and the cancellation mechanism built into the Market Stability Reserve of the EU ETS further strengthens this principle. As the EUETS cap declines, eventually towards net-zero by 2050, there will be fewer and fewer allowances to allocate. Our analysis shows that this is problem is likely to make full continuation free allocation unsustainable sometime in the early 2030s. However, giving industry an incentive to reduce emissions as well as a guarantee of a level playing field only in 2030 is too late. Action is needed now and it is clear that a Border Carbon Adjustment could be a good policy tool to transition EU industry outside of the free allocation regime already in the second phase of Phase 4 of the EU ETS.
If the carbon costs of EU industry cannot be lowered, the only alternative that adequately addresses the risk of carbon leakage is to raise the cost of emissions embodied in imports. Direct financial subsidies to all EU producers to compensate for their carbon costs is not a realistic option for a variety of reasons. Zero carbon production, which would not incur a carbon price, would be another solution but it is not realistic in the short to medium term, especially for existing production.
This means that some form of BCA will in any case be required.
See attachement for recommendations on how this policy tool can best be designed.
Read full responseResponse to Climate Law
6 Feb 2020
The development of a new EU Climate Law should be informed by best practices from existing climate change legislation globally. Past experience shows that a number of key elements can contribute to successful climate law: First, a new Climate Law should establish an overarching comprehensive policy framework that allows for the development of more specific measures to reduce greenhouse gas emissions, as well as to increase climate resilience. Second, that framework must be governed by a clear science-based emissions trajectory with short- and long-term legally binding emissions targets. Third, clearly assign duties and responsibilities should be established for meeting those targets as well as an implementation forum established. Developing climate laws in this way provides a means of upholding a consistent level of climate ambition across all policies, both at EU and Member State levels.
A core component of a new EU Climate Law should be a science-based EU-wide carbon budget, consistent with the proposed 2050 net zero target. This carbon budget can be divided into long- and short-term intervals:
The long-term budget will state the quantity of emissions remaining up to 2050, based on an emissions trajectory that is in keeping with a 1.5 degree warming scenario.
Five-yearly carbon budgets, timed to coincide with the Paris Agreement “ratchet mechanism” (i.e. 2020, 2025, 2030, etc..), will set a stable trajectory to meeting the 2050 target. Each of the 5-year budgets should be set at least a decade in advance. Consequently, all short-term budgets up to 2030 should be agreed by the time at which the new Climate Law becomes effective.
Introducing a direct link between real emission levels and complementary policies, to promote a virtuous cycle, could be achieved through the introduction of a 5 year baseline automatic adjustment to the EU ETS. This would mean that every 5 years, the balance of supply and demand on the market would be adjusted to reflect the level of emission reductions reached through complementary policies.
This option can further create the link to the Paris Agreement process, which also operates on 5 year cycles. As such, in 2020 the baseline could be adjusted to reflect the level of 2018 when the Paris facilitative dialogue will take place and in 2025 it could be adjusted to 2023 and the updated information we will have resulting from the Global stock take.
The upcoming Climate Law, is the right legislative instrument to ensure that reductions within the sectors covered by the Climate Action Regulation for the implementation of the Paris Agreement would take place in the most cost-effective, advanced and fair way. We very strongly encourage the development of a governance infrastructure which would enable to fast paste reductions in the covered sectors, most notably through the introduction of an European Project Based Mechanism, governed by the EIB.
To ensure that climate and emissions policy is evidence-based and consistent with best practice, a climate law should also establish a body to independently advise policymakers on meeting emissions targets in the most effective manner. This particular aspect is discussed in more detail in the document attached.
Please find recommendations on how these can be achieved in the attached document.
Read full responseResponse to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters
31 May 2018
Amendment of the Aarhus Regulation is the only means available to the EU legislature to bring the EU into compliance with its international law obligations. On 17 March 2017, the Aarhus Convention Compliance Committee (ACCC) found the EU to be in violation of the Aarhus Convention by failing to provide members of the public with access to the EU courts (CJEU). The findings of the ACCC are unequivocal: The EU fails to comply with the Convention and is recommended to amend the Aarhus Regulation (or adopt new legislation) in the absence of a change in jurisprudence of the CJEU. The lack of agreement on the findings at the last Meeting of the Parties was due to the unprecedented clash provoked by the EU’s attempt to block endorsement of the ACCC’s decision. However, some of the other State parties were strongly opposed to the EU’s argumentation. The decision was therefore postponed. During the meeting, a number of States voiced concern that the EU was seeking to obtain a special status under the Treaty, a status that is justified neither legally nor politically. By now, the EU Member States have also realized the disastrous precedent set and that the EU cannot exempt itself from international law obligations, as demonstrated by the intent of the Council to make an official request based on Article 241 TFEU to the Commission asking them to adopt a legislative proposal. The European Parliament and the EESC have also called upon the Commission to comply with the findings of the ACCC and to revise the Aarhus Regulation. The Commission seems to be the only one hesitating as to the way to bring about compliance. Rather than being “already complete” as stated in the Roadmap, the EU system of remedies suffers from considerable shortcomings. As recognized already in the first ACCC’s findings in 2011, the preliminary reference system under Article 267 TFEU does not meet the requirements of Article 9(3) of the Convention. Over the last years, the CJEU has further consolidated its case law in claims brought by NGOs, thereby clarifying that members of the public have no standing under Article 263 TFEU to challenge acts and omissions of EU institutions that are not addressed directly to them. The Aarhus Regulation is the only remaining avenue for the public but it remains unduly restrictive in its current form. Since the adoption of the Aarhus Regulation in 2006, members of the public have attempted to request the internal review of a range of acts of the EU institutions. However, to this day only 7 out of 35 requests were declared admissible. Almost all of these requests were denied on the basis of the requirement that an ‘administrative act’ must be of “individual scope”, “adopted under environmental law” and “have legally binding and external effects”. The Compliance Committee found that all of these requirements, as well as other aspects of the Regulation, fail to comply with the Convention. The situation is therefore clear: (1) The EU is a party to the Aarhus Convention in its own right; it, therefore, constitutes an integral part of the EU legal order. (2)The EU is in non-compliance with the Convention and therefore violates international law and primary EU law. (3)Based on one of the fundamental principles of the international legal order (article 27 of the Vienna Convention of the Law of Treaties), the EU cannot avoid performing its obligations by invoking its internal law. (4)The only option open to the Commission to remedy this violation of international law is to propose an amendment of the Aarhus Regulation. There is no need to conduct a further assessment of “how access to justice works”. For over 10 years, the Commission has been presented with legal analyses, an abundance of specific case examples and statistics on access to justice. Nonetheless, the Commission has delayed remedying this issue, contrary to calls by international bodies and its fellow institutions. The time for studies is over – it is time to amend the Regulation.
Read full responseResponse to Revising the rules for free allocation in the EU Emissions Trading System
16 Apr 2018
Sandbag Climate Campaign is a not-for-profit EU climate policy think tank. Our focus is on informing and influencing European climate legislation, particularly with respect to increasing ambition in line with the Paris Agreement, the EU emissions trading system, the Effort Sharing Regulation and industrial decarbonisation.
The EU ETS Directive 2003/87/EC states that free allocation is necessary for as long as carbon compliance obligations in non-EU jurisdictions are not comparable to those faced by emitters operating within the EU ETS. Furthermore Article 10a states:
“The Commission shall, upon the approval by the Community of an international agreement on climate change leading to mandatory reductions of greenhouse gas emissions comparable to those of the Community, review those measures to provide that free allocation is only to take place where this is fully justified in the light of that agreement.”
While equivalent compliance measures are not yet in place universally, various forms of carbon regulation or compliance instrument have now been implemented in many parts of the world since the start of Phase III of the EU ETS with a resulting increase in ambition levels. These include:
- Reforms to existing cap-and-trade programs and regional carbon pricing impacts.
- Policies implemented by national governments as part of their Paris Agreement pledges.
- Recent emissions standards for energy and industrial plants implemented in various regions.
The extent to which such measures compare to the ETS should be taken into account in determining an appropriate level of free allocation to award to eligible EU installations during Phase IV.
The 2003 ETS Directive also clear states that free allocation should diminish over time with a view to reaching zero free allocation by 2027. Sandbag analysis has found that free allocation will rise for some heavily emitting sectors at the start of Phase IV compared to 2020 levels (https://sandbag.org.uk/project/carbon-leakage-conundrum/). This discrepancy between the wording of the ETS Directive and implementation should be reconciled.
Finally, soon-to-be-published findings of a call for evidence launched by Sandbag will present anecdotal evidence of where ETS benchmarks lead to process lock in and favour polluting processes over low carbon substitutes. This unintended outcome, again, conflicts with Article 10a of the directive which states that benchmark “shall not provide incentives to increase emissions”. The evidence submitted to Sandbag of benchmarks supporting more polluting steelmaking process, for example, demonstrates a clear and urgent imperative to update the descriptions of benchmark processes such that low carbon processes and product substitutes are treated accordingly and that implementation of benchmarks is carried out in accordance with the ETS directive.
Read full responseMeeting with Miguel Arias Cañete (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and
11 Apr 2017 · mobility package 2017,ETS, ESR,Clean Energy Package
Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)
18 Jun 2015 · New policy work on CCS and ETS Review
Meeting with Jos Delbeke (Director-General Climate Action)
4 Mar 2015 · Market Stability Reserve
Meeting with Dominique Ristori (Director-General Energy)
21 Jan 2015 · European Energy Policy priorities