The Council of Experts on Climate Change has presented a special report commissioned by the German government to examine the 2024 projection data describing the future development of greenhouse gas emissions in Germany. The reason for the commission is the amendment to the Federal Climate Change Act (Bundes-Klimaschutzgesetz, KSG), which has yet to be signed by the Federal President. The amended Federal Climate Change Act stipulates that the Council of Experts will make a determination on compliance with the total annual emissions targets for the years 2021 to 2030 inclusive.
According to the projection data for 2024, the emissions budget specified in the Federal Climate Change Act for the period 2021 to 2030 would only just be met. The cumulative target shortfalls in the transport and buildings sectors would be offset by overfulfillment in other sectors, particularly the energy sector and, to a lesser extent, industry. The Council of Experts has analyzed the projection data both in total and by sector on the basis of a multi-part review scheme with regard to methodological approach, actuality and plausibility.
The projection of future emissions is naturally associated with considerable uncertainties. However, no information is provided in the projection data on the probability of the emissions pathway shown. For a summarized assessment of the results of its review, the Council of Experts uses a presumed benchmark pathway that is just as likely to be exceeded as undercut by all possible future emission pathways. Overall, the Council of Experts came to the conclusion that such a benchmark pathway is likely to be above the emissions pathway from the 2024 projection data, and so significantly so that – in contrast to the 2024 projection data – it should not be assumed that the target will be achieved.
Hans-Martin Henning, Chairman of the Council of Experts, says: „After examining the data, the Council of Experts confirms that total emissions will fall substantially by 2030, albeit probably less sharply than the projection data. The Council of Experts considers the projected emissions in the energy, buildings and transport sectors as well as – with restrictions – in industry to be underestimated.“ The Council of Experts sees reasons for this in current developments that were not taken into account when the projection data was prepared. These include, in particular, the cuts in the Climate and Transformation Fund, but also changes in market expectations for gas prices and CO2 certificate prices in the EU ETS. Methodological limitations also contribute to possible underestimates. In summary, Henning states: „Overall, we cannot confirm the cumulative target achievement for the years 2021 to 2030 shown by the 2024 projection data; on the contrary, we assume that the target will not be met.“
According to the amendment to the Federal Climate Change Act, there are no immediate consequences for the federal government if targets are exceeded for the first time. The projected failure to meet the targets under the European burden sharing from 2024 and the target of reducing emissions by at least 65% by 2030, as confirmed by the Council of Experts, do not oblige the federal government to take further climate policy action. „Against this backdrop, we recommend that we do not wait for the targets to be missed again, but instead examine the timely implementation of additional measures. This is all the more important given that our analysis of the 2023 projection data already revealed such a target shortfall last summer,“ notes Vice-Chair Brigitte Knopf, adding: „The focus here should be on the two sectors relevant to European burden sharing, buildings and transport, which also have the largest target overruns.“
The Council of Experts also sees a need for action when looking beyond 2030. According to the projection data, the targets would be exceeded in the period from 2031 to 2040 and the target of greenhouse gas neutrality would not be achieved by 2045 or 2050. According to projection data, the LULUCF land use sector would also fall far short of the targets set out in the Federal Climate Change Act. Instead of becoming an increasingly pronounced greenhouse gas sink, the sector would even be a source at times. „Overall, there is a lack of a long-term strategy for the period after 2030 as to how the goal of greenhouse gas neutrality can be achieved,“ continues Brigitte Knopf.
In light of the great importance that projection data has gained as a new trigger criterion for the adoption of additional climate policy measures, the Council of Experts has also looked at the process for their preparation. In the view of the Council of Experts, new requirements arise for this process. These concern issues relating to the treatment of uncertainties in connection with projection calculations, aspects of the data and models used and the process for commissioning and producing the projection data. The Council of Experts sees potential for improvement in all of these points and provides specific advice. The Council of Experts also sees a need for clarification regarding the responsibilities and roles for implementing the amended Federal Climate Change Act.
„As the amendment to the Act transfers responsibility for action to the Federal Government as a whole if it is determined that targets have not been met, we see a need to clarify who is in charge within the Federal Government,“ says Henning. The Council of Experts therefore recommends that the Federal Government quickly specify in regulations exactly how the process between determining the need for measures and the corresponding decision should take place.
The Council of Experts on Climate Change is an independent body of five expert persons from various disciplines. It was appointed in September 2020 and its mandate derives from sections 11 and 12 KSG. The panel consists of the five members Prof. Dr. Hans-Martin Henning (Chair), Dr. Brigitte Knopf (Vice Chair), Prof. Dr. Marc Oliver Bettzüge, Prof. Dr. Thomas Heimer and Dr. Barbara Schlomann. In addition to other statutory tasks, the Council of Experts examines the measures to be adopted in the event of target failure with regard to the greenhouse gas reduction assumptions on which they are based, in accordance with Section 12 (2) KSG, and issues an opinion before a Climate Action Programme is adopted, in accordance with Section 12 (3) KSG.
