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ClientEarth wrote to the European Commission to share our strong concerns regarding the legality of a possible Commission proposal for a delegated act under the Taxonomy Regulation establishing criteria under
which one or more uses of natural gas could be classified as contributing to climate change mitigation or otherwise as environmentally sustainable for the purposes of that Regulation.
For the reasons developed in the attached Annex, we urge the European Commission to refrain from proposing or adopting such a delegated act.
If it were adopted, this is likely to increase investments in activities utilising natural gas and would be in total contradiction with the commitments undertaken by the European Commission both at international and EU level.
Such a delegated act would conflict with various legal norms and commitments, and in particular: the commitment to reduce greenhouse gas emissions (‘GHGs’) as necessary to meet the specific temperature limits under the Paris Agreement, the EU commitments under the European Climate Law
to a ‘climate-neutral Union’ by 2050 and to reduce its net greenhouse gas emissions by at least 55 % compared to 1990 levels by 2030, obligations under Articles 11 and 191 of the Treaty on the Functioning of the European Union (the ’TFEU’) and provisions of the EU Taxonomy Regulation.