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EEF Submission on the EU Emissions Trading Draft National Allocation Plan

The EU Directive on an Emissions Trading Scheme aims to set up a scheme across Europe to start in January 2005. This will manage carbon emissions from various industrial sectors, but it will also place constraints on energy generators themselves. Each European member state must submit a national allocation plan, showing how it will allocate the right to emit certain amounts of carbon amongst the sectors - with the overall objective of bringing down these emissions over time. The trading scheme will play a major role in helping the EU and UK to achieve their Kyoto commitment.
  • Our major concerns about the existing proposals centre around their impact on the competitiveness of the manufacturing sector. We cannot see the attraction of ‘first mover advantage’ when no one appears to be, or is indeed actually following the UK’s lead.

  • The allocation equivalent to 16.3% reduction in CO2 on 1990 levels is too high, at a time when no other European member states are likely to commit to more than their Kyoto Protocol targets. Of the UK’s 12.5% Kyoto target, around 8% is attributable to CO2, so this new goal amounts to more than doubling of our existing commitments. The cost of reaching this higher level of cuts than other countries will have serious competitiveness implications for our members.

  • EEF’s direct participation in the scheme is through our members in the steel sector. Therefore, this response from EEF should be read in conjunction with the one from our UK Steel division (see Attachment 1) that addresses the detailed points on their proposed allocation.

  • We support the principle of an effective emissions trading scheme, as we believe it is a sound mechanism for securing the most low cost reductions in carbon emissions. However, we believe that the current plans do not make for an effective scheme, due to the tight timescale and lack of action from other EU member states.

  • EEF believes that government must consider what its alternative plan will be, should other member states fail to support the EU scheme. At this stage, it is better to be concerned about the quality, effectiveness and cost of the scheme, rather than the need to rush it in very quickly. We urge government to press the Commission for a six month delay to the start of the scheme in order to ensure it operates effectively and with minimal impact on competitiveness.
downloads
Full EEF Submission on Draft National Allocation Plan
further information:
Helen Woolston
Head of Environment
hwoolston@eef.org.uk
related links
EU Emissions Trading Web Site

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EEF Limited is the organisation for manufacturing, engineering and technology-based businesses. It is an employers association regulated under Part II of the Trade Union and Labour Relations (Consolidation) Act 1992 and a company limited by guarantee. EEF Limited is registered in England and Wales, registered no 05950172, and its registered office is Broadway House, Tothill Street, London, SW1H 9NQ

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