Council of Experts on Climate Change classifies Climate Action Programme 2023

Council of Experts on Climate Change classifies Climate Action Programme 2023
August 22, 2023 |

The Council of Experts on Climate Change comments on the Climate Action Programme 2023. Significant emission reductions are possible with it, but there is still a gap to the KSG targets. EWI Director Marc Oliver Bettzüge is part of the five-member panel.

The Council of Experts on Climate Change has published its statement on the German government’s Climate Action Programme 2023. The Council comments on the assumptions regarding the reported greenhouse gas reductions and gives the programme an overarching classification.

According to the German government, the measures included in the Climate Action Programme for the buildings and transport sectors also constitute measures under Section 8 (1) of the Federal Climate Change Act (Bundes-Klimaschutzgesetz, KSG) (immediate action programme). In a separate report, the Council of Experts has therefore examined the measures for the buildings and transport sectors proposed by the Federal Ministry of Economics and Climate Protection (BMWK), the Federal Ministry of Housing, Urban Development and Construction (BMWSB) and the Federal Ministry of Digital Affairs and Transport (BMDV) in more detail in this respect.

Council of Experts assumes substantial contribution

With its Climate Action Programme 2023, the German government has proposed a comprehensive programme of around 130 measures. If the programme is implemented consistently, the cumulative gap to the KSG target path for the years 2021 to 2030 should be reduced to around 200 Mt CO2 eq. Thus, the Climate Action Programme has a high but insufficient reduction claim according to the Federal Climate Change Act. The German government does not specify how the remaining difference to the KSG targets is to be closed.

The Council of Experts has received extensive, but overall insufficient data from the German government. Therefore, it cannot confirm the programme’s reduction effect as stated by the German government. Nevertheless, the Council of Experts assumes a substantial contribution. “The measures in the Climate Action Programme can enable significant greenhouse gas reductions, especially in the energy and industry sectors, but also in the building sector – depending on the implementation of the amendment to the GEG,” says Hans-Martin Henning, Chairman of the Council of Experts.

Henning: “Expected total reduction probably overestimated”

A plausibility check on the basis of the draft of the new projection report and other documents shows considerable imprecision and uncertainty. The Council of Experts assumes that even after full implementation of the Climate Action Programme, a larger gap will remain than that identified by the German government. “For quite a few measures, we take a critical view of the probability of realization and the deviation between reality and the assumptions made by the German government in the documents. The expected total reduction is therefore probably overestimated,” says Hans-Martin Henning. In addition, the Climate Action Programme also falls short of the legal requirement due to the lack of an assessment of economic, social and other ecological consequences.

The separate examination of the measures for buildings and transport shows that the greenhouse gas reductions reported by the German government for the two sectors would not be sufficient to compensate for the sectoral missed targets. Thus, according to the expert reports reviewed by the Council of Experts, a cumulative gap of 35 Mt CO2 eq. remains for the buildings sector by 2030. In the transport sector, the gap by 2030 is between 117 and 191 Mt CO2 eq. The range results from the different estimates of BMDV and BMWK. The Council of Experts thus concludes that, according to the German government’s figures, the measures presented do have an emissions-reducing effect, but do not meet the requirement for an immediate programme under the Federal Climate Change Act.

Council of Experts criticizes lack of overall concept and overarching framework of measures

In addition, the shortcomings identified by the Council of Experts in quantifying the effects of the measures are also noticeable in these two sectors. Hans-Martin Henning says: “We suspect that the assumed greenhouse gas reduction in the building sector is likely to be lower than calculated in the report. This is mainly due to the expected significant changes in the design of the GEG. In the transport sector, we see optimistic assumptions regarding, for example, the speed of implementation and financing of the measures, as well as in overcoming implementation obstacles.”

The Climate Action Programme contains important innovations, particularly in the industry, buildings and transport sectors. However, the measures are primarily aimed at those fields of action for greenhouse gas reduction that have already been addressed in the past. Brigitte Knopf, vice chair of the Council of Experts, says: “What would be needed is an addressing of the reduction potential of all available fields of action, for example also the dismantling of climate-damaging subsidies, which has so far only been vaguely formulated.”

In the view of the Council of Experts, there is a lack of a coherent and consistent overall concept and an overarching framework of measures. Consistent enforcement of the fixed cap in national emissions trading as early as possible, including flanking measures for social and economic safeguards, would be an obvious option for this. “We see a need for action on the part of the German government both in terms of improving the data basis for climate policy, with regard to closing the remaining target gap, and in developing an overall concept. Particular attention should be paid to the sectors affected by European burden sharing, which have so far not been given separate consideration in the context of the amendment to the Federal Climate Change Act,” says Brigitte Knopf.

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. Further information at