Third Way
TW
Third Way is a national think tank based in Washington, D.C.
ID: 651523046483-32
Lobbying Activity
Response to European Climate Law amendment
8 Sept 2025
Carbon-Free Europe welcomes the Commissions proposal to set a binding EU target of a 90% reduction in net greenhouse gas emissions by 2040 compared to 1990 levels. This ambition is essential to keep Europe on track for climate neutrality by 2050 and to provide predictability for citizens, industry, and investors. Our Annual Decarbonisation Perspective (ADP) modelling (2023 & 2024) confirms that a 90% reduction by 2040 is technically and economically feasible, but only through a technology-inclusive approach. All zero- and low-carbon solutions must be available: renewables, nuclear, geothermal, storage, CCS/CCU, hydrogen, and efficiency. Prescriptive frameworks that exclude proven technologies risk undermining delivery and delaying progress. While our modelling does not quantify every exclusion pathway, it clearly shows that only a technology-inclusive approach achieves -90% by 2040 at lowest cost. Excluding options raises costs especially for Member States with limited renewable resources. Economic feasibility and costs Our ADP 2024 shows that the -90% by 2040 pathway is more expensive in the short and mid-term than a linear path to 2050 (Core scenario), requiring additional 130 billion per year in the 2030s. Yet delaying action would make the final 10% of reductions prohibitively costly, as these hinge on energy-intensive industries and transport, leading to additional costs of 3.2 trillion by 2050. Early action forces preparation for these hard-to-abate sectors, avoiding a cliff-edge in the 2040s that could jeopardise the 2050 net-zero goal. Infrastructure requirements Achieving -90% emissions by 2040 requires a step-change in infrastructure deployment. Electricity generation capacity must triple from ~1000 GW today to ~3000 GW by 2040, demanding a faster, front-loaded buildout compared to a linear approach. Compared to the Core scenario, the 2040 pathway requires: Nuclear: +23 GW in the 2030s, reaching 67 GW/year new capacity. Offshore wind: up to 32 GW/year (+10 GW). Onshore wind: up to 31 GW/year (+67 GW). Solar: peaking at 70 GW/year (+20 GW). Utility-scale storage: up to 18 GW/year (+57 GW). Hydrogen pipelines: 108 GW by 2050, 30% less than Core (156 GW). CO2 pipelines: 455 Ht/hour by 2050; 20% more than Core (388 Ht/hour). While hydrogen infrastructure is reduced, CCUS and CO2 infrastructure must expand earlier and faster, adding ~54 billion industrial costs per year compared to Core. These infrastructures represent not only engineering challenges but also a need for secure access to critical raw materials (CRMs) (see Critical Raw Materials Act). Competitiveness and industrial strategy The 2040 target can only be delivered if anchored with the Clean Industrial Deal that ensures affordable energy, secures supply chains, and scales deployment of clean technologies. To decarbonise while remaining competitive, Europe must urgently: Accelerate backbone infrastructure (grids, CO pipelines, hydrogen corridors). Prioritise industry & transport decarbonisation with dedicated, tech-neutral investment. Secure CRMs to avoid deeper dependencies on adversarial suppliers. Support innovation and deployment through ETS revenues and the upcoming Industrial Decarbonisation Bank, the Industrial Decarbonisation Accelerator Act, and targeted state aid. Conclusion CFE strongly supports the Commissions proposal for a -90% by 2040 target and stresses the urgency of meeting the high investment, deployments, and industrial transition needs. This pathway, while more costly in the 2030s, drives critical infrastructure deployment and prepares hard-to-abate sectors for transition. Early action strengthens Europe's competitiveness, secures its leadership in clean technology and energy resilience, and prevents far higher costs in the future. For further detail, see our Annual Decarbonisation Perspective (2024): https://www.carbonfreeeurope.org/modelling
Read full responseResponse to Industrial Decarbonisation Accelerator Act
7 Jul 2025
Carbon-Free Europe (CFE) welcomes the opportunity to provide input to the forthcoming Industrial Decarbonisation Accelerator Act (IDAA). CFE supports the EUs 2050 net-zero target using a technology-inclusive approach combining renewables, nuclear, hydrogen, and carbon management. Our modelling and analysis demonstrate that a diverse energy mix enables cost-effective, resilient, and secure decarbonisation while allowing Member States (MS) to build on their strengths. This feedback draws on findings from the Annual Decarbonisation Perspective (ADP) and CFEs 2025 Jobs Report. Decarbonisation as Industrial Strategy CFEs 2025 Jobs Report shows that aligning decarbonisation and industrial competitiveness leads to net employment gains. Our Core scenario projects a gain of 4.65 million net jobs EU-wide by 2050, with strong growth in construction (1.2m) supply chains and manufacturing (1.0m). All EU MS have a net labour growth by 2050 for clean energy jobs. Recommendation: Target support for strategic clean technology manufacturing and allocate transition funding to regions with high emissions and industrial restructuring needs. Identifying clusters through infrastructure ready zones: CFEs downscaled infrastructure maps highlight regions where clean energy buildout overlaps with industrial activity, supporting the co-location of clean energy supply and energy-intensive industries. Such co-location can reduce transport inefficiencies, improve system integration, and lower overall costs. Recommendation: Focus IDAA support on infrastructure-ready zones with high energy demand to optimise both emissions reduction potential and cost-effectiveness. Early action and flexibility for cost-effective support: CFE modelling demonstrates substantial cost benefits of early clean infrastructure investments. Our Core net-zero 2050 scenario reduces investments by 4.5 trillion compared to delayed-action pathways, while technology-diverse approaches save 500 billion versus business-as-usual scenarios that miss net-zero targets. These savings are particularly enabled through flexible technology approaches and country-specific implementation pathways allowing early investments. Recommendation: Design the IDAA to enable MS to pursue country-specific, technology-neutral pathways, supported by accelerated permitting procedures for essential infrastructure. Low-Carbon Industrial Products and Lead Markets While well designed voluntary carbon labelsincluding all clean inputs and based on actual emissions performanceare essential to support product differentiation, they must be supported by broader market measures. CFEs jobs analysis reveals that initial clean industry growth occurs in demand side sectorsretrofits, electrification, and energy efficiencysubsequently driving longer-term supply-side job creation. As major consumers of basic materials (cement, steel, and glass), downstream sectors can accelerate the development of low-carbon markets through public procurement, project pipelines, and industrial partnerships. Recommendation: Establish technology-neutral emissions-based product standards while activating downstream sector demand through strategic procurement and partnership programmes. Conclusion We encourage the Commission to consider strategic support for transition regions, targeted infrastructure deployment, flexible & technology-neutral implementation pathways and robust market creation measures to ensure that the IDAA successfully drives EU industrial decarbonisation. We attach the ADP reports, downscaled infrastructure maps, and CFEs Jobs Report as supporting evidence. ADP 2024 https://www.carbonfreeeurope.org/modelling ADP 2024 Downscaled Infrastructure Maps (interactive) https://public.tableau.com/app/profile/cfe2024/viz/DownscaledMaps/MAP ADP 2023 archive https://www.carbonfreeeurope.org/modelling/archive/2023 Jobs Report - https://www.carbonfreeeurope.org/product/decarbonisation-as-industrial-strategy
Read full responseResponse to Nuclear Illustrative Programme
11 May 2025
Carbon-Free Europe (CFE) welcomes the opportunity to provide evidence to the Commissions forthcoming Nuclear Illustrative Program (PINC). CFEs mission is to support the EUs 2050 net-zero target using a technology-inclusive approach that combines renewables, nuclear, hydrogen, and carbon management. Our modelling and analysis demonstrate that a diverse, technology-neutral energy mix is key for cost-effective, resilient, and secure decarbonisation, and allows Member States to build on their respective strengths. Nuclear energy is a critical contributor to achieving the EUs climate, competitiveness, and energy security goals, especially in the face of rapidly growing demand for clean electricity from electrification, industry, and digital infrastructure. Investment Needs for New Nuclear and Lifetime Extensions CFEs Annual Decarbonisation Perspective (ADP) 2024 shows that scenarios with less or delayed nuclear deployment lead to higher system costs and consumer electricity prices. In all cost-optimal pathways to net zero, timely new nuclear build and lifetime extensions are essential to avoid over-reliance on individual technologies, ensure affordability, and ensure energy security. CFEs ADP 2023 data shows that the EU27 needs 609 billion in nuclear investments by 2050less than offshore wind (930bn) or solar (1.1tn), yet critical to the EU's least-cost decarbonisation path. Our spatial infrastructure maps identify where and when new nuclear is deployed in the least expensive pathways, highlighting the long lead times and the urgency for early investment. Role and Potential of New Nuclear Technologies (SMRs and Advanced Nuclear) Our modelling, including national analyses such as Net-Zero Poland, indicates that Small Modular Reactors (SMRs) can play a vital role in decarbonising industry, enhancing grid flexibility, and providing clean, reliable energy in regions where grid expansion is constrained. However, effective policy frameworks, particularly streamlined permitting, standardisation, and demonstration support, as well as robust public funding are essential to accelerate SMR deployment at scale. These efforts are crucial to stay on track in the global race on new nuclear technologies, which will be key enablers for the EU's competitiveness and decarbonisation goals. Regulatory and Financing Enablers Our ADP results confirm that permitting delays and regulatory fragmentation significantly increase investment risk and system cost. Harmonised EU-level safety and licensing, together with financial de-risking tools such as contracts for difference and state-backed guarantees, are critical for making nuclear projects investable and delivering them on time. Workforce and Skills CFEs forthcoming Jobs Impact Analysis (June 2025) indicates that nuclear expansion will require a substantial increase in skilled workers (115k by 2034 and 155k by 2050). Without proactive investment in education, training, and workforce mobility, skills gaps risk becoming a deployment bottleneck. EU-level support for workforce planning is essential to realise nuclears full potential. Strategic Context As the EU advances efforts to phase out Russian energy imports (including nuclear fuel), nuclear cooperation with like-minded partners is key. Collaboration would speed up the deployment of nuclear technologies and diversify the EU's critical nuclear supply chain, aligning with its strategic autonomy objectives and strengthening its energy sovereignty. For further information and supporting analysis, please refer to: CFE Modelling Website and ADP 2024 report https://www.carbonfreeeurope.org/modelling CFEs ADP 2024 Downscaled Infrastructure Maps (interactive) https://public.tableau.com/app/profile/cfe2024/viz/DownscaledMaps/MAP
Read full responseResponse to Greenhouse gas emissions savings methodology for low-carbon fuels
22 Oct 2024
Third Way's Carbon-Free Europe (CFE) initiative welcomes the European Commissions efforts to establish a methodology for assessing GHG emissions savings from low-carbon fuels. However, excluding key low-carbon energy sources from this process risks diminishing the role hydrogen can play in the energy transition, as well potentially slowing the overall transition. The current reliance on national average emissions intensities distorts the environmental impact of hydrogen production, especially when nuclear energy is used to supply low-carbon electricity. CFEs analysis shows that supporting diverse low-carbon electricity sources like nuclear through Power Purchase Agreements (PPAs) is crucial to accelerating the transition to clean hydrogen. CFE recommends including nuclear PPAs in the methodology, adopting a technology-neutral approach, and shifting to source-specific emissions accounting to ensure an accurate and equitable decarbonisation strategy.
Read full responseResponse to 2040 Climate Target Plan
20 Jun 2023
Third Way is a think tank based in Washington, DC. Third Ways Climate and Energy program launched Carbon-Free Europe (CFE) to build international support for a technology-inclusive climate agenda and encourage governments to maximise the next decade to meet climate goals. With a presence in Brussels, the UK, and DC, CFE facilitates transatlantic collaboration on climate policy, innovation, and clean energy supply chains. Carbon-Free Europe conducts research to ensure policymakers and the climate community have access to comprehensive, robust analyses to make evidence-based decisions on decarbonisation strategies. As part of this, we assess the risks and tradeoffs of different net zero pathways as part of our Annual Decarbonisation Perspective to advise governments on credible trajectories to 2050. Below are some key findings from our 2023 modelling to keep in mind when crafting new EU 2040 climate targets: There is broad agreement on the path to 2030, but our scenarios diverge considerably by mid-century due to their distinct assumptions and limitations. To achieve a net-zero trajectory by 2050, policymakers must concentrate on near-term policies that prioritise the rapid electrification and implementation of renewable energy while supporting technology development for the future. It is vital to comprehend land-based natural resource availability and constraints when deciding which decarbonisation technologies to pursue since determining whether a technology, such as advanced nuclear or DAC or electric fuels, is feasible or necessary is challenging until the ability to use biomass, site renewables and transmission, and sequester CO2 is understood. These questions of resource availability may determine what share of decarbonisation is satisfied by decarbonised fuels and electricity produced within Europe vs the share imported from global markets (in the case of fuel) and neighbouring regions (in the case of electricity). The EU needs a comprehensive and intentional fuel strategy as it will determine the necessary scale of energy infrastructure in the long term. It may be economical to import zero-carbon fuels from other regions, which limits critical production infrastructure (low-carbon generation, electrolysers, e-fuels synthesis), but this creates a situation where a large residual of Europes energy consumption remains exposed to global markets. Electricity supply in the long term is dictated as much by resource availability as relative economics. Foreclosing technological options, like nuclear, advanced geothermal, or biomass power, given their lack of competitiveness against current renewable prices, will inevitably lead to shortcomings. Building new clean energy infrastructure at an unparalleled pace is essential to achieve a net-zero status by mid-century. Despite setting ambitious energy efficiency goals, Europe must construct new industrial-scale low-carbon infrastructure to meet this challenge in the next thirty years. The choices consumers make when purchasing technologies like electric vehicles and heat pumps instead of conventional alternatives, as well as their operational behaviour, such as enabling flexible load management, are crucial for cost containment in decarbonisation. These actions can help limit the necessity of upgrades to the electricity distribution systems and the need to purchase flexibility and reliability services from thermal generators and electricity storage. In summary, policymakers should develop flexible decarbonisation frameworks that acknowledge both risks and opportunities in the long term. We are grateful for the opportunity to provide feedback. For more details, please see the links below to our modelling webpage and the technical report on our latest Annual Decarbonisation Perspective for the EU and UK. Thank you. https://www.carbonfreeeurope.org/modelling https://www.carbonfreeeurope.org/modelling/Carbon-Free-Europe-Annual-Decarbonization-Perspective-2023.pdf
Read full responseResponse to Net Zero Industry Act
19 Jun 2023
Third Way is a national think tank based in Washington, D.C. Carbon-Free Europe (CFE) was launched by Third Way's Climate and Energy program to build international support for a technology-inclusive climate agenda and encourage governments to maximise the next decade to meet climate goals. CFE facilitates transatlantic collaboration on climate policy, innovation, and clean energy supply chains and conducts research to ensure policymakers and the climate community have access to comprehensive, robust analyses to make evidence-based decisions on net-zero strategies. As part of this, we assess the risks and tradeoffs of different net-zero pathways annually to advise governments on credible trajectories to 2050. The NZIA should be designed and implemented in a way that strengthens the EUs strategic autonomy through a holistic energy technology and supply chain approach, without neglecting the fundamental role that cooperation and international trade play in the rush to accelerate the green transition. Recognizing that CCU and Nuclear have a fundamental role to play both when it comes to the achievement of the EUs climate objectives and for our strategic domestic autonomy is a key step into making the NZIA a successful industrial policy. CCU and Nuclear comply with all the three criteria identified by the Act in order to be considered a strategic net-zero technology. According to CFEs Net-Zero Outlook 2023: CCU could contribute up to 150 Mt of CO2 reductions per year. Nuclear, could contribute up to 36% of Europes electricity and nuclear derived heat could provide 50% of overall primary energy by 2050. We are grateful for the opportunity to provide feedback to this proposal. Please see our attached position paper on the scope of the NZIA. Thank you for your time.
Read full responseResponse to Revision of the EU’s electricity market design
23 May 2023
Third Way is a national think tank based in Washington, D.C. Third Ways Climate and Energy program launched Carbon-Free Europe (CFE) at COP26 to build international support for a technology-inclusive climate agenda and encourage governments to maximise the next decade to meet climate goals. With a presence in Brussels, EU Member States, the UK, and Washington, DC, CFE facilitates transatlantic collaboration on climate policy, innovation, and clean energy supply chains. Carbon-Free Europe conducts research to ensure policymakers and the climate community have access to comprehensive, robust analyses to make evidence-based decisions on net-zero strategies. As part of this, we assess the risks and tradeoffs of different net-zero pathways annually to advise governments on credible trajectories to 2050. We are grateful for the opportunity to provide feedback to this proposal. Please see our attached position paper on Electricity Market Design Reform principles. Thank you for your time.
Read full responseMeeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans) and Kreab Worldwide
5 Sept 2022 · RePowerEU implementation
Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)
10 Jun 2022 · To discuss Carbon-Free Europe’s modelling analysis on achieving a net-zero future.