COMMISSION STAFF WORKING DOCUMENT STAKEHOLDER CONSULTATION - SYNOPSIS REPORT Synopsis report on the results of the 2030 Climate Target Plan consultation activities Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Stepping up Europe’s 2030 climate ambition Investing in a climate-neutral future for the benefit of our people
Date: 2020-09-17
Institutions: Directorate-General for Climate Action, European Commission
Subjects: EU Emissions Trading Scheme, EU energy policy, EU environmental policy, climate change, energy efficiency, environmental cooperation, green economy, greenhouse gas, reduction of gas emissions, renewable energy

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.9.2020  SWD(2020) 178 final  COMMISSION STAFF WORKING DOCUMENT  STAKEHOLDER CONSULTATION - SYNOPSIS REPORT  Synopsis report on the results of the 2030 Climate Target Plan consultation activities         Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Stepping up Europe’s 2030 climate ambition      Investing in a climate-neutral future for the benefit of our people    {COM(2020) 562 final} - {SEC(2020) 301 final} - {SWD(2020) 176 final} - {SWD(2020) 177 final}  
 
 
Synopsis  report  on  the  results  of  the  2030  Climate 
Target Plan consultation activities 

1.  Introduction  

In the context of the European Green Deal aiming to make Europe the world’s 
first  climate-neutral  continent,  the  Commission  carried  out  consultation 
activities  on  the  plan  to  increase  the  EU  2030  Greenhouse  Gas  (GHG) 
emissions  reduction  target1.  The  Inception  Impact  Assessment  for  the  2030 
Climate  Target  Plan was  open  for  feedback  from  18 March  2020  -  15  April 
2020.  An open  public  consultation  was  conducted through an  online  survey. 
The survey was open for 12 weeks (from March 31st to June 23rd, 2020). The 
Commission  asked a  contractor2  to produce  a  report  analysing  the  results  of 
the  online  survey,  including  the  submitted  position  papers.  The  results  are 
included  in  this  report.  Workshops  and  ad  hoc  stakeholder  meetings, 
originally envisaged, did not take place due to COVID-19 safety measures.   

2.  Inception Impact Assessment 

The  Commission  received  1  095  replies  that  vary  in  terms  of  geographical 
distribution,  type  of  respondents,  size  of  contributing  organizations  and 
topics  covered.  The  biggest  number  of  replies  came  from  citizens,  mostly 
originating from the EU (712 out of 772 citizen replies). The remaining replies 
came  from  different  organizations,  mostly  from  the  business  sector  (174 
replies),  NGOs  and  environmental  organizations  (101  replies),  academic 
institutions (19 replies) and public authorities (13 replies). 

The  great  majority  of  the  replies  give  strong  support  to  the  revised  cut  in 
emissions proposed by the Green Deal (a reduction of 50-55% of Europe’s GHG 
emissions by 2030) or suggest going even further in reductions.  

Among  the  particular  areas  of  focus  highlighted  are  just  transition;  energy 
efficiency;  adequate  financing  tools  and  investment;  climate  justice  and 
solidarity;  divestment  from  fossil  fuels;  renewable  energy;  carbon  capture 
usage and storage (CCUS); carbon leakage; the role of science and the carbon 
budget; decoupling of economic growth from resource use, etc. COVID-19 is a 
topic that was mentioned by several of the contributors.  

1 The details of the public consultation can be consulted at: https://ec.europa.eu/info/law/better-regulation/have-
your-say/initiatives/12265-2030-Climate-Target-Plan/public-consultation. 
2 Service contract n. 340201/2020/827061/SER/CLIMA.C.1. Consortium composed by Trinomics, Ricardo and Tyrsky. 

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3.  Open Public Consultation 

3.1. 

Overview of participants 

The  public  consultation  received  a  total  of  3  915  replies  from  26  Member 
States.  Further  116  replies  were  received  from  outside  of  the  EU.  3  302 
replies came from individuals and 729 from organisations.  

Figure 1. Country of origin 

Figure 2. Types of stakeholders 

As shown in Figure 1, the largest number of replies came from Germany (53%; 
2 136 respondents), and France (13%; 521 respondents). After individuals, the 
largest  proportion  of  respondents  (13%;  521  respondents)  came  from  
company/business organisations, business associations, and NGOs, as depicted 
in Figure 2. Respondents were mainly active in the sectors of education (23%; 
823  respondents),  and  transport,  storage  and  communications  (10%;  379 
stakeholders). 

In  total  14  Member  State  national  authorities  replied  to  the  2030  Climate 
Target  Plan  Consultation,  five  of  which  contributed  at  the  government 
and/or  legislative  level  (The  Netherlands,  Finland,  Denmark,  Czechia, 
France, ) while seven contributed at the ministerial level (Cyprus, Bulgaria, 
Lithuania, Estonia, Hungary, Spain and Slovakia). Additional submissions came 
from two non-EU  ministerial bodies  (Norway, Brazil). Among other member 
state authorities, several federal states of the Federal Republics of Germany 
and Austria provided their feedback, as well as Flemish Government and two 
(the  German  Environment  Agency 
national 
Umweltbundesamt and the French National Centre for Forest Property CNPF). 
Out of the EU Member State national authorities, six argue to increase the 
2030  climate  ambition  to  55%  (the  Government  of  the  Netherlands  and  of 
Finland, the Government as well as the Parliament of Denmark, the Ministry 
for  Ecological  Transition and  Demographic Change in  Spain,  the Government 
of France).  One EU Member State national authority opted for an increase 
of  the  2030  climate  ambition  of  50%  (the  Ministry  of  Environment  of 
Slovakia). By contrast, six EU national MS authorities would prefer to leave 

level  technical  bodies 

2 

EU citizen; 3 261; 81%Company/business organisation; 202; 5%Business association; 196; 5%Non-governmental organisation (NGO); 123; 3%Public authority; 59; 2%Other; 50; 1%Academic/research institution; 47; 1%Non-EU citizen; 41; 1%Environmental organisation; 36; 1%Consumer organisation; 8; 0.2%Trade union; 8; 0.2%[Q2] "I am giving my contribution as" (n=4 031) 
 
 
 
 
  
 
 
it  unchanged,  at  the  level  of  40%  GHG  reduction  (the  Government  of 
Czechia,  the  Ministry  of  Economy  of  Slovakia,  ministries  of  environment  in 
Lithuania and Estonia, the Ministry of Transport, Information, technology and 
Communication of Bulgaria and the Ministry of Energy, Commerce & Industry 
in  Cyprus).  Two  MS  authorities  did  not  indicate  a  preferred  level  of 
ambition  but  gave  further  precisions:  the  Ministry  of  Energy  of  Bulgaria 
considers  it  appropriate  to  further  revise  the  2030  GHG  emission  reduction 
target  provided  there  is  a  detailed  assessment  of  the  effects  at  national, 
regional and EU level. The Ministry for Innovation and Technology in Hungary 
argues  that  for  such  an  increase  of  ambition  at  the  EU  level,  deep 
decarbonisation  is  needed in  the energy,  transport,  heating  and  cooling and 
industrial sectors, which must remain the top priority. 

Among  the  identified  benefits  of  an  increase  of  the  2030  climate  ambition 
the  MS  national  authorities  evoked in particular  the  following  opportunities: 
this would be a chance to do our part in saving the planet and thus fulfilling 
our duty towards the future generations; it will allow a more gradual pathway 
to  reaching  a  climate  neutral  EU  by  2050;  it  will  help  mitigate  costs 
associated  with  climate  change  to  the  society;  it  will  ensure  a  growing  EU 
economy  based  on  new  production  and  consumption  models,  etc.  The 
challenges evoked for the increase of the ambition were: it will represent a 
significant  investment  challenge  for  EU  industry,  services,  transport  and 
energy  sections;  it  will  likely  lead  to  a  structural  shift  and  changing  skills 
requirements  in  the  economy;  it  may  lead  to  significant  labor  reallocation 
across  sectors,  occupations  and  regions;  it  will  confront  us  with  a  reduced 
lead-time  for  devising  and  implementing  measures  and  for  the  economic 
actors to adjust. 

Additional papers could be provided both through the public consultation and 
the Inception Impact Assessment.  In total,  500 attachments were submitted 
by  491  respondents.  Figure  3  shows  the  types  of  respondents  providing 
additional papers.  

Figure 3. – Types of stakeholders providing additional attachments 

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233  of  these  attachments  were  selected  for  analysis.  They  did  not  include 
Inception Impact Assessment attachments or duplicated campaign responses. 

3.2. 

Methodology of data processing 

As  questions  in  the  online  survey  were  optional,  the  percentages  presented 
below refer to the total respondents that answered the concerned questions. 
Some questions allowed respondents to ‘rate’  options (1-5 or 1-8). On these 
ratings, the report provides figures for the “highest rating” category, as this 
is indicative of most support. 

The  position  papers  were  processed  via  cataloguing.  Data  from  each  paper 
was logged in a database to provide key themes and information from paper 
and author.  

Some campaigns were identified in the open replies and survey attachments. 
The  largest  campaign  (8%;  329  respondents),  constituting  of  mostly  private 
individuals,  advocated  mainly  for  a  higher  climate  ambition,  and  a  common 
carbon  price.  A  second  campaign (<1%;  40  respondents),  also  mostly  private 
individuals,  pushed  for  a  revision  of  the  methodology  to  calculate  the  GHG 
emissions of the agriculture sector. A third campaign (<1%; 35 respondents), 
supported  mainly  by  NGOs,  requested  coherence  with  the  Paris  Agreement 
and  a  bigger  focus  on  the  costs  of  inaction.  A  fourth  campaign  (<1%;  20 
respondents)  of  private  individuals,  proposed  a  climate  dividend for  citizens 
as a carbon pricing mechanism. 

3.3. 

Questionnaire 

The  questionnaire  was  composed  of  two  sections:  one  collecting  general 
feedback,  and  the  second,  seeking  the  views  of  expert  stakeholders  on 
specific policy measures. 

3.3.1. PART I – General feedback 

4 

EU citizen; 172; 34%Business association; 122; 24%Company/ business organisation; 71; 14%Non-governmental organisation; 56; 11%Academic/research institution; 25; 5%Public authority; 21; 4%Other; 13; 3%Environmental organisation; 11; 2%Trade union; 5; 1%Non-EU citizen; 2; 1%Consumer organisation; 2; 1% 
 
 
 
 
 
 
 
 
The first part of the questionnaire covered the overall 2030 climate ambition, 
sectoral action, and enabling conditions. 

Overall climate ambition for 2030, opportunities and challenges  
Figure 4 shows the answers provided in relation with different targets. First, 
regarding  the  EU  GHG  reduction  target,  most  respondents  believed  that  it 
should be increased to 55% (77%; 2 904 respondents). Most respondents (69%; 
2  613  respondents)  perceived that  the current target  for  renewable  energy 
(32%)  should be increased to a share higher than 40%.  Similarly, an increase 
to  greater  than  40%  of  improvement  in  energy  efficiency  compared  to  the 
current target (32.5%) was preferred (62%; 2 345 respondents).  

Figure 4.Views on EU’s climate and energy 2030 targets  

5 

7%12%81%22%23%55%9%14%77%0%50%100%It should remain unchanged (GHGemissions reduction by at least40%)It should be increased to at least50%.It should be increased to at least55%EU's 2030 target to reduce GHG emissionsTotal (n=3 765)In a professional capacity or on behalf of an organisation (n=581)As an individual in a personal capacity (n=3 184)4%4%5%12%74%12%13%16%19%39%6%6%7%14%69%0%20%40%60%80%100%Do not know/Do not have anopinion35% RE in the final energyconsumption32% RE in the final energyconsumption40% RE in the final energyconsumptionHigher than 40% RE in the finalenergy consumptionEU's renewable energy (RE) ambition by 2030 to contribute to the 2030 GHG reduction target and 2050 climate neutrality Total (n=3 799)In a professional capacity or on behalf of an organisation (n=598)As an individual in a personal capacity (n=3 201) 
 
 
 
 
 
 
The  main  opportunity  for  achieving  a  higher  ambition,  according  to 
respondents,  was  to  lower  pollution  to  improve  health  and  wellbeing  (14%;                    
3 081 respondents) whereas, the main perceived challenge was the decline in 
jobs  not  a  part  of  the  transition  (20%;  2  084  respondents).  Overall, 
respondents perceived that opportunities outweigh challenges (84%; 3 299 
respondents).  

Sectoral action and potential to reduce GHG emissions by 2030 
Respondents  rated  action  in  energy  supply  (48%;  1  705  respondents  with 
highest  rating),  mobility  and  transport  (16%;  547  respondents  with  highest 
rating),  as  the  most  influential  sectors  for  achieving  the  transition.  Table  1 
summarizes  the  views  regarding  the  role  of  various  sectors  in  the 
achievement of higher EU climate targets. 

Table 1–Role of various sectors and actions to achieve EU climate targets, as preferred by respondents 

Preferred sectoral contribution 

Energy 

Higher penetration of renewable energy in the energy 

system 

Fossil Fuels 

Respondents support  

(% of total replies per 

question; number of 

respondents) 

18%; 3 213 

Phase-out of public support on fossil-fuel investments 

16%; 2 925 

Stop the use of natural gas, as it will lead to issues (lock-

ins) for achieving targets 

Buildings 

59%; 2 265  

6 

6%5%8%14%67%14%19%14%17%36%7%8%9%15%62%0%20%40%60%80%100%35% EE (primary and final energyconsumption)32.5% EE (primary and final energyconsumption)Do not know/Do not have an opinion40% EE (primary and final energyconsumption)Higher than 40% EE (primary and finalenergy consumption)EU's energy efficiency (EE) ambition by 2030 to contribute to the 2030 GHG reduction target and 2050 climate neutralityTotal (n=3 784)In a professional capacity or on behalf of an organisation (n=586)As an individual in a personal capacity (n=3 198) 
 
 
 
 
 
 
Improve the thermal properties of residential buildings 

40%; 1 426 (highest rating) 

Applying energy management systems for non-residential 

buildings 

Industry 

Develop a circular economy 

Road transport 

40%; 1 426 (highest rating) 

63%; 2 245 (highest rating) 

Improve the affordability of sustainable road transport 

57%; 1 993 (highest rating) 

Remove barrier of the availability of recharge and 

refuelling infrastructure 

Land-Use, Land-Use Change and Forestry 

Sustainable forest management, restoration, and 

preservation 

31%; 2 755 

12%; 2 981 

Enabling conditions and other policies 
A  section  of  the  questionnaire  focused on the enabling conditions  and  other 
policies  necessary  to  achieve  the  2030  GHG  reduction  target,  and  covered 
consumer  choices,  just  transition  and  employment,  carbon  pricing,  and 
research funding. 

The most selected consumer choices to reduce emissions included travelling 
less  by  plane  (18%;  3  110  respondents),  and  reduced  car-use  (17%;  2  976 
respondents). 

Regarding just transition and employment, respondents stated that the most 
important action was economic diversification and modernisation away from 
fossil fuels (26%; 2 659 respondents). 

On carbon pricing, most respondents perceived that the revenue from carbon 
pricing  should  be  used  to  finance  green  technologies  and  low-emission 
mobility infrastructure (27%; 2 799 respondents).  

Finally,  respondents  selected  energy  storage  (12%;  2  423  respondents),  and 
circular  or  zero-carbon  industry  (12%;  2  405  respondents)  as  the  main  areas 
of research governments should fund. 

3.3.2. PART II – Specific policy design  

The  second  part  of  the  questionnaire  covered  the  design  of  climate  and 
energy  policies,  and  the  outreach  to  third  countries.  A  total  of  1  599 
respondents replied to this section (40% of total respondents, 1 141 providing 
their views as private individuals, 458 as representatives of an organisation). 

7 

 
 
 
 
 
 
 
 
 
 
Climate and energy policy design 
When discussing key pieces of the current EU climate legislation, the EU-ETS 
was  perceived  as  requiring  the  most  increased  climate  ambition  (55%;  883 
respondents with highest rating), compared to the ESR and LULUCF. 

The  main  instruments  considered  by  respondents  to  strengthen  the  EU-ETS 
were the introduction of a pricing policy (e.g. minimum price floor) (24%; 664 
respondents),  reducing  or  eliminating  the  share  of  free  allocation  (24%;  658 
stakeholders)  and 
linear  reduction  factor  (23%;  626 
stakeholders). With regard to free allocation, most respondents believed that 
the  share  of  EU-ETS  allowances  allocated  for  free  to  the  industry  should 
decline (60%; 870 respondents).  

increasing  the 

Concerning the extension of the EU-ETS to the road transport and buildings 
sectors,  most  respondents  preferred  carbon  pricing  to  complement  other 
sector-specific policies (64%; 1 009 respondents), principally in the form of a 
CO2  tax  (64%;  966  respondents).  For  both  buildings  (32%;  425  respondents) 
and  road  transport  (55%;  733  respondents),  a  plurality  of  respondents 
preferred a uniform carbon price across Member States by inclusion in the EU 
ETS, and a large majority favoured for both sectors a carbon price set at EU 
level.  

Other  sectors  respondents  wished  to  integrate  in  the  EU-ETS  included 
maritime transport (41%; 541 respondents). In case that the EU ETS would be 
extended to buildings and transport, also other energy-related CO2 emissions 
should be integrated (46%, 676 respondents). If so, views are rather similar on 
agriculture  (35%;  557  respondents),  municipal  waste  (34%;  550  respondents) 
and small industrial installations (31%, 494 respondents). 

On  the  challenges  and  opportunities  related  to  the  extension  of  the  EU 
ETS, the major opportunity was perceived to be helping the EU to achieve its 
climate  and  environmental  objectives  (51%;  660  respondents  with  highest 
rating),  while  the  largest  challenge  was  social  acceptability  (45%;  539 
respondents with highest rating).  

A plurality of respondents were unaware or had no opinion on the role of the 
ESR  in  reflecting  an  increased  EU  climate  ambition  (40%;  585  respondents). 
Those  with  a  view  favoured  that  the  ESR  ambition  should  be  derived  from 
cost-effective  contribution  compared  to  EU  ETS  and  LULUCF  (22%;  328 
stakeholders)  and  rather  preferred  that  CO2  emissions  from  ESR  sectors 
covered by EU ETS should remain in the ESR (18%) than being excluded (9%). 

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The  last  piece  of  climate  legislation  covered  in  the  questionnaire  was  the 
LULUCF. Respondents on average prioritised making LULUCF accounting rules 
more stringent (53%; 437 respondents with highest rating).   

From  EU  energy 
instruments,  respondents  perceived  the 
Renewable Energy Directive (RED) as requiring most revision to achieve higher 
targets (30%; 884 respondents). 

legislative 

Table  2  summarizes  the  views  regarding  a  variety  of  policy  areas  in  the 
achievement of higher EU climate targets. 

Table 2 – EU policies to achieve higher climate ambition, as preferred by respondents  

Policy areas 

Preferred policy contribution 

Respondents support 

(% of total replies per 

question; number of 

respondents) 

Energy  

Increased Renewable 

Develop the necessary infrastructure 

energy target 

to increase production 

56%; 718 (highest rating) 

Increased Energy 

efficiency target 

Energy 

infrastructure and 

sector integration 

Building 

More stringent energy performance 

requirements for the transport 

57%; 667 (highest rating) 

vehicles 

Focus on electricity transmission and 

smart grids  

38%; 862  

Encourage better urban planning and 

construction of sustainable buildings 

9%; 909 

Building renovations 

and green infrastructure 

Remove barrier of long pay-back 

periods 

14%; 830  

Industry 

Industrial 

The implementation of circular 

transformation 

economy processes 

Waste 

48%; 607 (highest rating) 

Waste policy 

waste incineration to increase 

23%; 860  

Prohibiting landfilling and limiting 

recycling 

EU policies and outreach towards third countries on climate change policy 
The G20 and the G7 was believed by respondents as the areas the EU should 
focus on for its  climate diplomacy and cooperation efforts in coming years 
(14%;  839  respondents). The circular economy and decent supply chains was 

9 

 
 
 
 
 
 
 
the  favoured  approach  for  development  assistance  and  finance  for  third 
countries  (15%;  842  respondents).  On  improvements  to  trade  and  foreign 
policy  instruments,  respondents  favoured  border  measures  to  avoid  carbon 
leakage (16%; 890 respondents). 

Regarding  most  important  deliverables  to  be  achieved  at  the  UNFCCC 
Conference  of  the  Parties  (COP  26),  respondents  favoured  finalising  the 
Katowice rulebook to make the PA fully operational (17%; 951 respondents). 

Additional information 
Respondents  provided  comments  to  both  Parts  of  the  questionnaire,  I  (47%;    
1  883  respondents)  and  II  (14%;  604  respondents).  The  key  themes  provided 
by respondents included the importance of behavioural change and improved 
education on climate change, and the urgency of ambitious climate action. A 
few  respondents  (2%;  66  respondents)  provided  comments  related  to  the 
formulation of the questions and structure of the survey, with most of these 
stating  that  the  questionnaire  was  not  neutral  or  that  it  used  a  biased 
formulation. 

3.4. 

Attachments and other relevant position papers 

Key messages of reviewed papers: 

  Provided additional depth to themes explored through the questionnaire; 
  Considered wide range of emissions sources, specifically transport and energy; 
  Technologies  considered  ‘critical’  to  the  transition  were  in  line  with  sectors  considered 

‘important’; 

  Some  proposed  need  for  changes  to  existing  legislation:  for  example,  review  of  RED  II 

Directive or funding for energy efficiency technologies in buildings; 

  Identified  range  of  barriers  to  achieving  the  climate  targets,  including:  fossil  fuel 

subsidies, growth of aviation and lack of sufficient co-ordination between MS. 

Proposed revised 2030 targets 
Regarding  the  2030  targets,  some  of  the  revised  papers  (17%;  39  papers) 
rated  the  current  2030  GHG  emission  targets  as  appropriate,  while  others 
(18%;  42  papers)  rated  them  as  being  too  low.  Only  few  (5  %;  12  papers) 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
indicated  that  the targets  are  too  high.  The  largest  share  (60%;  140  papers) 
did not provide an opinion. 

Among  the  papers  analysed,  some  (9%;  21  papers)  provided  a  new  specific 
target  of  55%  GHG  reductions  of  1990  levels  by  2030.  Smaller  shares  stated 
that the value should be higher than 55% (4 %; 10 papers), and that it should 
be raised to 50% (2%; 5 papers).  

Sector coverage 
The  main  two  sectors  identified  in  the  position  papers  reviewed  were 
Transport  (19%;  43  papers)  and  Energy  (25%;  58  papers).  In  each  case,  the 
papers  noted  key  decarbonisation  actions,  including  banning  combustion 
vehicles  by  2025,  decreasing  aviation,  promoting  low  emission  zones  and 
developing  public  transport;  and  phasing  out  coal  and  increasing  nuclear 
energy  sources.  Opinions  were  also  expressed  on  energy  savings  from 
buildings,  through  renovation;  circularity  in  the  waste  sector;  promoting 
green and healthy diets and food production; green economy without leaving 
disabled citizens behind and greater collaboration between States.  

Key sectorial actions, means or technologies 
The  papers  further  highlighted  technologies  within  the  sectors  identified  as 
critical  to  the  low-carbon  transition.  Some  (22%;  52  papers)  mentioned  the 
need to transition away from coal energy to either gas or a green supply. A 
second group (7%; 17 papers) mentioned the need to support carbon capture 
and storage projects. Several papers identified technologies associated with 
the transport sector as key to reaching the targets, including alternative and 
zero emission vehicles, sustainable fuels, infrastructure for cleaner modes of 
transport, and lighter vehicles. Others (8%; 18 papers) discussed the need to 
become  more  energy  efficient  within  their  sector,  including  5  papers 
mentioning the use of increasing volumes of data to inform action.  

Changes to EU climate and energy legislation  
A  group  of  submissions  (19%;  45  papers)  discussed  the  role  of  the  ETS  in 
driving  decarbonisation,  presenting  mixed  arguments  to  both  tighten  or 
loosen its scope, and arguing for an expansion to the buildings and transport 
sectors. Others (3%; 7 papers) discussed the role of the RED II Directive.  

Barriers to meeting targets 
Barriers to meeting the climate targets were discussed by some of the papers 
(38%,  88 papers). The biggest barrier was considered  issues with legislation 
(14%; 32 papers), the most frequent comments being ‘ineffective’ or ‘unclear 
strategy or framework’. Other comments linked to poor governance state the 
threats of legislators ‘being complacent’ in addressing climate change (4%; 10 

11 

 
 
 
 
 
 
 
 
papers).  In  addition,  many  other  papers  highlighted  that  a  lack  of  political 
will  would  likely  result  in  inaction.  Some  (5%;  12  papers)  also  noted 
continuation of subsides for fossil fuels would affect the achievement of GHG 
emissions targets, while others (3%; 8 papers) stated that a lack of financial 
support  will  be  a  barrier  to  progress.  Other  issues  highlighted  included  the 
growth  in  aviation  transport  rather  than  rail,  lack  of  sufficient  cooperation 
between countries, untreated landfill and recyclable waste, societal attitude, 
and lack of awareness. 

12