In it we argue that the status quo is retained for setting targets for sectors and target units, and that the risk of using the Carbon Reduction Commitment carbon market for trading is too great at present. We support a stand alone carbon trading scheme for participants of Climate Change Agreements – but with a long term view to link schemes.
We believe that government should split CCA and EU ETS targets but only if it doesn’t jeopardise state aid approval.That also, for the time being, the target currency to remains energy, not carbon
EEF would like to see government monitors risks of oversupply of allowances as a result of throughput at the sector level, not at the target unit level.
And we argue that government ensures that target periods are not annually set because energy efficiency programmes aren’t necessarily one of continuous improvement in the steel sector but of stepped improvements. Members need a longer target period if they are to justify the capital expenditure needed to implement energy saving measures.