"The plan is very general, which means that it does not provide concrete solutions on how the draft will specifically contribute to the climate goals," was the first point Võrklaev made in his statement.

The minister of finance noted that the draft does not specify how to distribute targets for reducing Estonia's greenhouse gas (GHG) emissions and increasing GHG sequestration, especially since the sectoral working groups' proposals are likely to fall short of the country's targets.

"It is unclear who (i.e., what entities) will be held accountable for meeting the emission reduction and/or sequestration targets that will be established, and whether these entities will be appropriately equipped to do so," he said.

The finance minister said that the document suggests that the climate law will allow for a "greenhouse gas budget" but does not specify how and for how long. "The impact of the European Union's emissions trading system on GHG reductions has also not been described," he said.

Although the proposal considers potential positive impacts of the proposed law, Võrklaev cautioned that it may overlook immediate negative effects that should be offset by long-term benefits.

"As said in the document, additional analyses of the socio-economic, environmental, and cost-benefit implications of climate action will be undertaken in areas where these are now insufficient; however, the timeline does not specify when, in practice, these analyses could be complete in order for the planning process to take into account their findings," Võrklaev said.

The minister noted that among the studies mentioned in the document was the "Research Partnership Framework Tender" to carry out research in support of climate change objectives, including the necessary complementary impact assessments, which was procured under the auspices of the Ministry of Finances, but recently fell through and a new process has now been launched.

"However, the draft suggests a possible timeline for the development of the Climate Bill. This means that the results of the studies might not be available before the draft bill is finalized. This means that there might not be enough information to set GHG emission reduction targets across and within sectors," Võrklaev said.

At the end of September, the Ministry of Climate sent out a draft climate change law for public consultation, seeking feedback from stakeholders on what a climate change law should look like to provide clarity, legal certainty, and a roadmap to climate neutrality by 2050. By the October 25 deadline, 30 parties had provided feedback on the draft, but the Ministry of Finance only submitted its comments this week.

Kristi Klaas, undersecretary for green reform at the Ministry of Climate, told ERR on October 26 that the feedback revealed an expectation for a very clear description of the law and the setting of sectoral targets, as well as an assessment of socio-economic impacts.

The draft Climate Bill is expected to be ready in April and to reach the Riigikogu in autumn 2024.

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