APPENDIX 11
Memorandum submitted by the National Insulation
Association Ltd
Thank you for inviting us to contribute to the
inquiry. To some extent we are not qualified to comment in detail
on international implications of emissions trading schemes. The
insulation industry, however, strongly believes energy saving
is as important an issue as carbon saving. The twin targets are
both closely linked and completely divergent.
The potential to save energy offers major financial
savings to participating ETS countries: carbon savings are a bonus
to the financial benefits of more efficient use of energy.
To reduce the carbon content of energy is a
cost which countries have to acknowledge and accept. To save energy
is an investment capable of substantial financial return. For
instance, many building fabric insulation measures return savings
in energy use in the range of 8% to 30%, on investment cost, consistently
year by year (generally tax-free savings in comparison with typical
central bank rates of 2% to 6%). To save energy is highly beneficial
to countries importing energy, assisting their balance of payments
position and reducing the twin needs to invest in energy infrastructure
and in security of energy supply.
Investment in building fabric insulation is
generally for the life-of-the-building, adding equivalent value
to the building.
We would request your consideration of this
contention, to the extent that UK government is influenced to
adopt an energy reduction target as well as the carbon saving
target.
We thank you for your consideration.
27 October 2004
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