EEF does support the government’s commitment to increase energy efficiency and reduce emissions in the large non-energy intensive sector. However, we are sceptical that the current proposed structure of the Scheme is likely to succeed in achieving these aims without placing unnecessary burden on businesses.
Some of the key issues raised in our response are:
- As awareness of the scheme is low and the guidance from government on the scheme as led to a great deal of confusion the Scheme does not start until April 2011 and participants be given sufficient time to prepare for the schemes introduction.
- Government must assess the impact on companies’ cash-flow in light of economic conditions and hence reconsider holding revenue for six months.
- Government must gives organisations flexibility in determining CRC administration most relevant to their operations, and therefore allow large subsidiaries to operate in the CRC in their own right if they wish to do so.
- Encourage companies to invest in renewable energy generation within the CRC.
- Expand the Early Action metric to include other accredited carbon management schemes and standards.
To read the full EEF response click here.