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28 | THE PERFECT FIT REGULATORY ASSISTANCE PROJECT measures. Because the ETS would lead to more balanced prices, the overall subsidy levels required to support heat pump deployment in line with the EU’s energy and climate targets would also likely need to be lower for non-energy poor and low-income households, allowing public funds to go further. Similarly, if the economics of fuel switching improve, the introduction of regulation to ban fossil-fuel heating systems is likely to face less resistance. What should the EU do to make the policy proposals better? The emissions trajectory of the ETS 2 cap to 2030 is ambitious but aligned with climate requirements. Nevertheless, there is a high degree of uncertainty around the ability and willingness of Member States to make rapid emissions reductions in the buildings and road transport sectors. This imbalance creates a very real risk that the price of ETS 2 allowances will escalate to levels that would place unacceptable financial burdens on households if Member States fail to deliver adequate support policies. This risk is of particular concern for low-income building owners and households in private rental accommodation that are vulnerable to additional energy costs and least able to invest in low-carbon technologies to avoid the higher costs. To mitigate this risk, the EU should ensure that sufficient emission reductions are delivered through complementary EU laws and Member State policy measures while ensuring that the social impacts of emissions trading are sufficiently taken into account. Strengthening requirements for Member States to make emissions reductions through the Effort Sharing Regulation, Energy Efficiency Directive (EED), and the Renewable Energy Directive (and indeed in transport-related laws) would reduce the demand for ETS 2 allowances, keeping carbon prices under control. Within the ETS directive itself, provision can be made to: • Require ETS revenues to be spent on building decarbonisation measures, through the Social Climate Fund and the Modernization Fund, with a ring-fenced proportion to be spent on energy-poor households in the worst-performing buildings, while recognizing that ETS revenues would need to be supplemented by other funding to tackle heat decarbonisation among energy-poor households; and • Introduce a price cap for the ETS 2 allowances, while recognizing that unanimity could be needed across Member States to agree both in principle and to the price cap trajectory. What should Member States do now? Member States could plan to use future ETS 1 and 2 revenues now to make energy efficiency and heat decarbonisation improvements to the worst-performing buildings in which energy-poor, vulnerable or low-income households live. Early action would enable some of the negative social impacts of ETS 2 to be avoided and help to kick-start the Renovation Wave. There is also nothing to stop progressive Member States from reforming their own energy prices to reflect carbon costs in advance of the 2025 ETS 2.PDF Image | RAP Perfect Fit Heat Pump
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