Memorandum submitted by Vodafone
1. Energy use and our resulting carbon footprint
is one of our most significant environmental impacts. Limiting
our contribution to climate change is therefore a priority for
our business.
2. We are currently implementing a strategy
to reduce our impact. To date, we have focussed on increasing
energy efficiency, and introducing renewable energy sources where
it is feasible to do so. We have not yet introduced measures to
offset any of our carbon footprint, although as our energy efficiency
improves, it is something we may consider to further reduce our
impact on global warming.
3. Vodafone has been concerned about the
lack of standardisation in the carbon offset market. We welcome
the proposal for a voluntary code of Best Practice for the provision
of carbon offsetting set out in Defra's consultation document
published on 18 January 2007. Given the range of offset providers
and products now available it is important to have a recognised
standard which will give consumers and business confidence in
the projects and mechanisms they purchase.
4. With regard to some of the specific questions
that you pose in your invitation, we have the following responses:
Ought there to be a compulsory UK or European
accreditation scheme for carbon offset project companies?
Yes—we believe this would greatly assist
potential customers of these projects and allow meaningful comparisons
to be made between schemes. Defra's proposal to introduce a voluntary
code and quality mark[6]
is a positive step in this direction. It will enable customers
to have confidence in the integrity and value for money of the
offset products available to them. In order to be of greatest
benefit, standardisation and accreditation should be as international
as possible. Existing schemes such as those for sustainable timber
production and the scheme operated by the Marine Stewardship Council
could provide some useful learnings.
5. Should offsetting become mandatory for
some of the more carbon-intensive activities such as flying?
No—the approach favoured by Vodafone,
and by many of the stakeholders who inform our strategy, is that
reduction in energy consumption, improvements in energy efficiency
and introduction of renewable sources should all be considered
before offsetting is introduced. The mandatory introduction of
offsetting may disincentivise the reduction in carbon emissions
by other means.
6. Is there enough clarity within the offset
market to allow customers to make informed choices based upon
robust information about different schemes at different prices?
No—a recent review of the carbon offset
market by the Context Group Ltd * highlighted huge variations
in the activities, costs and verification methods of different
providers. As a potential customer of these providers, we do not
believe there is enough standardisation to allow an informed choice
to be made. We would encourage more transparency in the carbon
offset market with regard to price and the process by which carbon
offsets are calculated.
* Carbon Offset in Context, Providers and
Advisers 2006
7. What impact will the voluntary carbon offset
market have on the compliance market if the former continues to
grow as steadily as it has done over the last few years?
Many of the organisations who have introduced
offsetting have attracted media attention. This has encouraged
growing interest from other organisations, and there is a danger
that at some point, demand may outstrip supply.
January 2007
6 Defra: Consultation on establishing a voluntary
Code of Best Practice for the provision of carbon offsetting to
UK customers. January 2007. Back
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