Select Committee on Environmental Audit Minutes of Evidence


Examination of Witnesses (Questions 60-79)

DR KEITH ALLOTT, MS KIRSTY CLOUGH, MR JOHN LANCHBERY AND MR MARTIN HARPER

21 NOVEMBER 2006

  Q60  Chairman: We are hoping to have a session with him in due course. On emissions trading, he does say that post 2012, post Phase II, the shape of the ETS could be very influential in how global trading might or might not evolve. What is your judgment about how important the success or failure of the ETS is in terms of the global process of tackling climate change?

  Mr Lanchbery: It is very important. It is the only operational scheme of its size certainly in the world and, as the Environment Agency said, it is the only one that trades between different countries, albeit as part of the Union. So it is very, very important that it succeeds, which is why we have all been very disappointed about the over allocations for the first phases which brings it into disrepute.

  Dr Allott: I would entirely agree with that. Just to spell it out even more, there are two processes which are now running which will very much determine the credibility of the ETS. Firstly, the decisions on the Phase II Allocation Plans: we are expecting the first results of the Commission's thinking on that within the next few days, and then there is the review of directive for Phase III, both of which are happening right now, and both of those processes will be critical in determining whether the EU ETS is actually going to deliver on what we want it to be seen as, which is, and as Stern sees it, as a nucleus of a future global trading scheme. The basic principles of the ETS are right in terms of the framework of mandatory absolute caps. We are concerned that if ETS fails because of lack of political will, with a short-term focus that fundamental principle, for instance, will be lost and we will then have a global trading regime built on a much slacker framework.

  Q61  Mr Caton: Can we look at UK emissions targets now. The Government says that Phase II of the EU ETS will save eight million tonnes of carbon a year from the UK, but that is calculated on the basis of business as usual projections if we did not have an emissions trading scheme. What are your views on using those sorts of projections rather than looking for absolute cuts?

  Mr Lanchbery: We should not. It is a bizarre way of reaching a target to do a business as usual projection, lop a little bit off it and then say you are trying to meet a target. If you are going to meet an emission reduction target, you need an absolute budget of emissions which decreases over time so that your budget in the end is exactly the same as the target you are trying to get to. It is absolutely bizarre to use a projection, except to inform you of how much you would have to do (what is the difference between what you might do and what you need to do), but you need to set allocations to the EU ETS on the basis of an ever reducing absolute budget for carbon. There is not another way to do it. Projections do not take you to your target.

  Dr Allott: We entirely agree, and I would also point out that continuing to rely on business as usual projections, which assume a business as usual world in the absence of the ETS, is an increasingly bizarre and untenable approach. The ETS exists; therefore it forms part of the business as usual world; they are caught in its logical loop.

  Q62  Dr Turner: At the moment it seems difficult to think that the operation of the ETS so far has saved a single tonne of CO2 from being emitted anywhere in Europe, let alone determining whether it has been saved in the UK; but when Defra announced the Phase II allocations they said it would help reduce the UK's carbon emissions from the 16.2 level that we are at by 2010 as compared to 1990, in other words, the revised figure in the last climate change policy statement. Was Defra justified in making that claim?

  Dr Allott: The basis for that assumption is, firstly, that there is a robust emissions trading scheme around the whole system. An emissions trading scheme is only as strong as the weakest link. Every part of that chain needs to be robust. Behind your question there is the issue about where the emission reductions take place and whether they take place within the UK or in another country, and that is a difficult question to reconcile with the national cap. The truth is that once you have an international trading scheme you start to lose control over where your emissions do come from. Whether Defra is justified in making that claim, I think the jury is out, and a lot will depend on what happens in the next few weeks in terms of the Commission holding a line on the allocation plans that we are currently seeing. It is clear that the current overall picture is not good. We are getting positive signals from the Commission in terms of the line they are going to take, but clearly this is a high level political thing. We are getting positive signals from the DG environment, but this is a much wider high level political issue in all the aspects of the Commission, and some parts of the Commission take a different view.

  Q63  Dr Turner: If the ETS Directive is acted upon literally, the Member States have to accept national allocation plans that are in line with the Kyoto targets, but it does not really actually say how much it would work in practice. What wording or mechanism do you think the UK Government ought to be pressing for the Commission's review of this directive? Do you think it is sufficiently explicit to work?

  Mr Lanchbery: No. It certainly has not worked, so therefore it is not sufficiently explicit or certainly not sufficiently mandatory. We would like to tighten that up considerably, at least to say that the allocation should be directly proportional to, or better than, that Member State's target. A better way still would be to have an overall EU cap. Let us assume that the EU, as a whole, agreed to a 30% reduction by 2020. If you did that, then that would be the level below the 1990 levels at which the allocation would be set. You would have to have a burden-sharing arrangement of some sort to divvy it up, but you could do that. At the moment, you are right, the directive is quite loose. I think at the time it went through the Council and Parliament they were actually being quite reasonable, and they said this covers about half of European CO2 emissions, very roughly, and there are measures you could take in other sectors. So, in some countries perhaps they really are going to tackle the transport, domestic sectors and make the most of their emission reductions in those sectors so the traded sector would not have to do very much, but, frankly, that was wildly optimistic thinking. The place where the biggest reductions can be made faster is mainly the sector covered by the Emissions Trading Directive and the transport and domestic sector have been politically harder to touch, so it was perhaps a bit idealistic, if not naive, of the original drafters to put the wording in the way that they did.

  Dr Allott: I would agree with all of that and also stress the importance of the targets, and in fact more than just a single target, which we think would be absolutely necessary, which would be at least a 30% cut for the EU by 2020. This is being proposed by at least three major countries at the moment, the UK—Gordon Brown confirmed this at the time of the Stern Report—also Germany and France are supporting this target. The big question will be whether the EU as a whole signs up to it next spring Council. That would provide a very strong framework. We would like to go further than that and actually see an elaboration of the carbon budget idea to give a clear trajectory.

  Q64  Dr Turner: Given the tenor of your remarks, do you have any optimism at all that the ETS is going to deliver significant carbon savings?

  Dr Allott: We have optimism that it is the right basic mechanism, but the mechanism is only as good as the targets that are set, and that is a question of political will. It is clear, as you say, that it is not delivering significant emission reductions, if any, in Phase I. That is to do with the cap-setting process. It is also to do with the fact that the rules for Phase I were very confusing because there were no Kyoto targets in place in Phase I, the benchmark was that Member States had to show that their cap was set to be on a trajectory to deliver the Kyoto target, so the trajectory can take any shape that you like. Now we have an absolute benchmark, which is the Kyoto targets, and we are really hoping that the Commission will stick to its guns on that and get very tough. It does have a benchmark and this is the crucial few weeks to determine the shape of the scheme.

  Mr Lanchbery: You mentioned when you were questioning the Environment Agency the possibility of a carbon tax, but in fact what has happened with the EU Emissions Trading Scheme is that because they have set the caps very low, or very high rather, it is the equivalent for the carbon tax of setting the rate at 0.01 pence. It is how you use the instrument properly that is the question and how you set the targets rather than the instrument itself which, like Keith has said, we think is basically sound although it has some deficiencies.

  Mr Harper: May I add one point about this. I suppose, as the UK Government is toying with the idea of introducing a carbon budget, the ETS is going to be the personification of why it is so important to make sure that the target is linked to caps and therefore the policy measures try to make a contribution to those targets, and until one has that carbon budgeting system in place, then any one policy measure could not necessarily be deemed to be making a contribution. I think the classic case with the Emissions Trading Scheme is that, unless it is directly linked to a target which determines the cap, as the Chairman said in his statement to the Environment Agency, then I think it will have its credibility undermined, which I think we all fear but we are all optimistic that there will be the political courage coming from the different Member States to try and put that in place.

  Q65  David Howarth: Can I go back to the question of auctioning allowances. I will be interested in any comments you might have on the exchange of the Environment Agency, but also there is one specific thing in the WWF memo to us about how much money the Government might make out of auctioning allowances, and I would like to put on record how much you expect the Government to make out of auctioning allowances and what might be the best way of spending that money?

  Dr Allott: The first principle of auctioning is that it is clearly the most environmentally and economically efficient way of sorting out this allocation process. We have got ourselves into a terrible mess, and what was initially designed to be a simple market mechanism has become incredibly complex and bureaucratic: because as soon as you move away from auctioning you have to start having all sorts of special rules to deal with new entrants, plant closures, plant modification, a whole range of other things start coming in which makes the system very complex. You have perverse incentives from grandfathering, you have the difficulty of benchmarking, a whole range of things come in. Auctioning is clean and simple, it does also provide, as the Environment Agency was saying, an internalisation of the carbon cost into all decisions, both existing plant and for new plant, which is precisely what we need to see in terms of influencing behaviour and sending long-term signals to companies when they are making investment decisions, and so, on all those bases, we think it ticks an awful lot of boxes, if not all of them. In terms of the revenue raising aspect of this, the positive side of that is that if you assume an EU allowance price of about 15 to 30 euros, which at the time we submitted the memo seemed a reasonable amount—clearly this moves up and down, but if you assume that range—with 7% auctioning as proposed by the UK Government, that would generate between roughly 250 and 520 million euros worth of revenue per year in Phase II. Clearly, there are very interesting questions about how you use that, though in the statement the Government also announced the Environmental Transformation Fund, although the linkage in the text was not direct. We are not quite clear whether all of that money is going to be spent on those things the Environment Agency mentioned, but we think that is basically the right way forward: to recycle the money so you have a positive feedback. You are using the revenues from pollution to pump-prime the solutions to this problem, the lower carbon technologies. There is a debate to be had, especially when you move to higher levels of auctioning, about the need for compensation for some sectors which may be exposed to international competition, and we fully accept that there are some sectors, although we think it is greatly overplayed, where it is an issue and I think, subject to state aid rules, there needs to be some creative thinking about the use of the revenues.

  Mr Lanchbery: Can I add to that, the reverse of auctioning, of course, is grandfathering, which is what we mainly have at the moment, although not entirely grandfathering for Phase II. That has led to massive windfall profits, particularly for the generators, which has not really caused a scandal here, but it has in Germany. They are furious about the huge profits they have made from giving away the allowances, especially when there is an excess of them, so it is a bit scandalous. The second point is that generators in the UK are increasingly coming round to auctioning—not the German generators, I hasten to add, although they are the same companies, so you do wonder why they have one opinion in the UK and another one in Germany! Nevertheless, the UK generators are tending towards that view, for all the reasons Keith outlined. If you do take early action, then you are rewarded for it; you do not have all these perverse incentives to keep a plant open longer and longer.

  Dr Allott: One notes also that if you have anything less than 100% auctioning, at least for a particular sector, then you lose many of the benefits, because one of the big benefits is the simplification. So, if you were to have 50% auctioning across the board, then you are not getting rid of the issue of how you deal with new entrants and planned closures. You may be thinking of putting up full auctioning for the power sector, for instance, and then that sorts that sector out. There are ways through this, but I think 100% auctioning for a sector is the way to think about this.

  Q66  David Howarth: And you produce an enormous return on lobbying, do you not, so the rules become very important, and lobbying becomes more important than economic activity? Can I turn to the Environmental Transformation Fund. I suppose the simplest way to look at the question is: is that a misnomer? Is the amount of money that the Government is going to make on its 7% auctioning enough to justify the name of the fund, assuming there is a connection between the two?

  Dr Allott: We would like to see the details of how much money they are actually planning to spend on the Environmental Transformation Fund and more details about how they are going to direct it. Clearly, if they spend all the revenues that we have tried to put a ball park figure on in supporting non-nuclear low-carbon technologies (I think is the definition), then clearly that could make a very significant difference.

  Q67  Chairman: Given the importance of making this whole scheme work properly and given the enormous obstacle that anything other than auctioning represents to making it work properly, do you think there is a realistic chance of getting to 100% auctioning in Phase III?

  Mr Lanchbery: There is a chance. I am not sure if it is highly realistic, but there is a chance. The UK's position is for 100% auctioning—they certainly favour auctioning—and a number of other states are coming round to that view, partly because of what Keith said. I was talking to an Austrian person on the way back from Nairobi and he was finding just doing all these things, like providing a new entrants reserve, and all that sort of thing, administratively terribly unwieldy from the Austrian Government's point of view. It does not really benefit industry in particular. Although it gives them initially a windfall, it does not benefit all industry, who also, as you were discussing earlier with the Environment Agency, find it administratively hard, especially small installations, and so you would just remove all their benefits. I think governments are increasingly finding that it would be rather worthwhile, certainly from their point of view, to get rid of all these very difficult, tricky things they have to implement with not auctioning. We live in hope, but I am not quite sure how much hope.

  Q68  Chairman: Where is the resistance? First of all, these difficulties were not exactly unforeseeable. They may not have been foreseen, but they certainly were not unforeseeable. What was the objection in the first instance to having auctions and what is the resistance now to moving very swiftly towards it?

  Mr Lanchbery: I know it is primarily a business, but particularly some groups who have a reasonable wealth, like the energy intensive people who use a lot of energy, whose emissions are high, they would be quite hard hit by an auction because they feel that they cannot reduce emissions. Having said that, a lot of them say they have in the past made their organisations more efficient. In that case auctioning will reward them for their past behaviour, but they have tended to take a very blanket, overall industry view and say, "No, no, no, we want reward for our historical emissions", which is what is meant by grandfathering.

  Dr Allott: I think there is a chance of us getting towards 100% auctioning, we are certainly pushing it very strongly, but within that there is a debate. I think it is quite important to separate out the business group into the power sector (the electricity supply industry), and the manufacturing industry. They are very different in terms of their size, their exposure to international competition, their ability to pass on costs and make windfall profits. I think, as a bottom line, we would want to see 100% auctioning for the power sector which is, as John said, making huge windfall profits across Europe, and we are starting to see some movement within that sector. There is another debate to be had about the manufacturing industry where they are exposed to international competition, but for me the way through that is to have a discussion and a debate about the use of the revenues.

  Q69  Mr Challen: Carbon emissions have risen from the power sector by 14% since 1999, largely due to the increasing use of coal. Do you think that allowance prices should rise in order to make coal more uncompetitive?

  Dr Allott: I would like to see that.

  Q70  Mr Challen: How much would you have to go?

  Mr Lanchbery: As the Environment Agency people put it, to get a high price you need a tight cap. A tight cap would dominate the market. What has happened so far is there has been a market failure, the instrument is not working. If the instrument were properly applied, then it would dominate the market and it would dominate the effect of increases or decreases in fossil fuel supplies, but it does not. As the Environment Agency guy said, the difficulty is that fossil fuel prices are far more dominant in the market than the very small effect of the EU ETS, which is again making the case for a much tighter cap on the scheme.

  Dr Allott: I would like to point out an interesting point about the UK's return to coal. The UK is one of the countries in Europe where there is the greatest potential for fuel switching between gas and coal—this is one the of the stranger things that has happened—which has allowed the UK to position itself as having done very well and been one of the more aggressive countries in Phase I because our emissions were above our allocation, unlike many other countries. The reason for that is that we have rushed back to coal with a vengeance because we were able to, because of the scope for fuel switching, and they did that in the full knowledge of the carbon price, in the full knowledge of their cap, and they decided it was still economically justified to do that. So, to turn it round, the UK's claim to be the good guys is just that the power sector has rushed back to burning coal. If you look at the detail, again splitting up the power sector from the manufacturing industry, the manufacturing industry in the UK was just as over-allocated as everywhere else in Europe. The emissions from the manufacturing industry, which were based on a business as usual projection, were considerably below the actual allocation. In other words, we over-allocated, as did as everybody else, because we relied on business as usual projections, and the UK's slight halo on this in terms of, "We are the good guys in Phase I", is simply because we rushed back to coal and so our emissions were higher. It is a slightly perverse situation.

  Q71  Mr Challen: Looking at coal a bit more in the context of security of supply, that is a very important issue, very often on the lips of DTI ministers, there is equal importance given to that as to climate change issues. How should that issue be managed within the Emissions Trading Scheme particularly in relation to coal?

  Mr Lanchbery: I should say, as a preface, that a lot of the coal burnt is not ours. I cannot remember the ranking exactly, but it is the Digest of UK Energy Statistics produced by the DTI, and the three biggest importers of coal, the three biggest suppliers of coal into the UK are Russia, South Africa and Poland, so it is not our coal. If we are talking about security of supply, I am not sure if we are any more secure importing coal from Russia or South Africa than we are using imported gas, which comes from Russia or Algeria.

  Q72  David Howarth: Norway actually.

  Dr Allott: I think an issue on the future of coal is that coal does have a role. The existing power stations and their lifetimes have recently been extended to an extent which has surprised everybody by the number of power stations which have opted in to the Large Combustion Plant Directive. This means that they have decided to fit sulphur dioxide abatement equipment, which allows them to run at an unrestricted load factor for as long as they like[21]. Because of an unfortunate combination of circumstances, including very perverse signals in the UK allocation plan detail, they have been encouraged to opt in to the Large Combustion Plant Directive which means that we are now committed to burning more coal to justify those very heavy investments in abatement. That is the first point to make. The second point is that, if coal does have a role, and think it is a very open question in the future as to how it should look, it should be on the basis of clean coal, and that means carbon capture and storage. We and other environmental groups have very serious issues around carbon capture and storage. We think it may have a potential role as part of a global solution to the climate change problem we are facing, but the first question is: is it going to work? If it is going to work, we need to find out as soon as possible. If it is not going to work, we need to find out as soon as possible so we can devise alternative strategies. So we see a role for it, especially for countries like the UK to be at least making sure that we are exploring the technology and finding out if it is a runner. The question then will be whether the ETS is a vehicle to make sure that this happens or not. We do not think it is. I think the way that we would like to frame this would be in terms of—. We have talked about the Large Combustion Plant Directive which sets timelines for abatement and emission limits for sulphur dioxide. Maybe we need to think in terms of a new Large Combustion Plant Directive aimed at carbon dioxide with absolute deadlines for fitting abatement plant. Any new plant would have to be fitted with carbon capture from the outset and maybe deadlines for phasing in carbon capture for existing plant if they want to carry on running. This is not necessarily a pro carbon capture and storage position at all, it is an anti-unabated coal position. Especially in the industrialised countries, where we need to be moving towards very significant cuts in our emissions of 80% or more by 2050, we simply should not be building unabated coal-fired power stations.

  Mr Lanchbery: I should add that CCS is seen in general, I think, as only an interim measure, it is at best an interim measure, so it would always be wiser to go for energy efficiency or renewables of some sort, and, of course, they are far more secure. Energy efficiency is ultimately secure, of course, and so are renewables because they are all domestic. So that is our concern, that CCS might divert people's attention away from the real long-term options, although, as Keith has said, it is absolutely clear that China and India are going to use their coal, because they have got an awful lot of it, and so the problem does have to be addressed abroad as to whether or not they use CCS, and one suspects they probably should.

  Dr Allott: I fully agree with that point.

  Q73  Mr Challen: Somebody is going to have to use it. Forty per cent, I believe, of our generation comes from coal, I might be slightly out on those figures, but it is a huge percentage and will be for quite some time. You were expressing doubts about CCS. Is that on a technical basis or for some other reason?

  Mr Lanchbery: It is mainly that if the industry were prepared to develop the technology and deploy it, then that is fine. If they want to do that, that is okay. What we are concerned about is that they are mainly asking for government or international money from the World Bank to develop these programmes and we are concerned that there is always only a finite pot of money and if they put it into CCS they will not put it into renewables and energy efficiency, that is all.

  Q74  Mr Challen: There are a lot of things we do not want to put into money into, and nuclear is another competitor for that honour.

  Mr Lanchbery: Indeed.

  Q75  Mr Challen: Forty per cent of the UK's electricity generation, as I understand it, comes from coal. We have heard about the one gigawatt a week in China, and I do not know what the figure is in India. We are going to have to have CCS whether we like it or not, regardless of these other strategies, so should not the ETS encourage that through carbon credits rather than us taking a sort of sniffy line about it and saying, "We do not really like it because it is just a filling in"?

  Dr Allott: I think the response to that would be to say that it may be the ETS might not be the vehicle. If you do want to have CCS coming into play, the ETS may not be the vehicle to deliver that. The analogy I would draw would be on the model I suggested in terms of having some regulation to remove unabated coal from the market, for instance, with energy efficient appliances, perhaps having some regulation which could remove the least efficient appliances from the market and then some fiscal incentives to encourage people to buy the more efficient appliances that are still on the market. That would be the model for regulation to rule out unabated coal, and then the ETS would provide the incentive within the acceptable boundaries defined by that regulation. Just to come back to the security of supply point, I think there are some issues buried in your question which are to do with this energy gap question and coal's role and the role for nuclear. Various pieces of work that we did for the Energy Review showed very clearly that the energy gap is actually a political choice. When we talk about "energy gap", it is always an electricity gap. This is part of the problem that we have got in terms of energy policy in this country, but, just talking in terms of electricity, serious policies to curb electricity demand and to also deliver on the stated targets on renewable energy would essentially make that electricity gap, rather than energy gap, virtually go away, both in terms of coal and gas, without leading to ridiculous degrees of overdependence on imported gas.

  Mr Lanchbery: As to whether the EU ETS should encourage carbon capture and storage or, indeed, nuclear, it is an interesting point in that, of course, if you built a new plant and it is genuinely a zero carbon technology, then your allocation under grandfathering would be zero; or, indeed, if you are going to auction, then you would need to buy no credits, and so it depends how it is introduced. If you are talking about encouraging it through the clean development mechanism, that is another matter, although I would not see CCS or, indeed, new nuclear plant coming on within the period of the second phase of the EU ETS.

  Q76  Dr Turner: You do not seem to have much confidence in ETS making any contribution to encouraging CCS. The Carbon Capture and Storage Association tell me that they have a raft of big projects ready to go which would be greatly accelerated if the fiscal conditions were right, and at the moment they are a rather cloudy screen. I am still not quite clear why it is you think that putting in place a credit system for carbon capture and storage in the ETS could not be part of that picture and could not be useful?

  Mr Lanchbery: If you had auctioning it would not so much credit it as it would not debit it. So, if you are going to build a conventional coal-fired plant, then you would have to buy a lot of allowances and, if you were going to build a plant with CCS which had no emissions, then, of course, you would have to by no allowances. So it would, in that sense, incentivise it. It would not penalise it, in other words, rather than incentivise it, but it amounts to the same sort of thing; so there would be a benefit, yes.

  Q77  Mr Caton: Both your organisations have close links with sister bodies in other European countries, and so I guess you are in a good position to give us a bottom up international perspective. Can you give us a picture of the level of pressure on tackling climate change in other European Union countries and, in particular, the state of debate on the future of the ETS?

  Dr Allott: One general observation. I think it is rising very rapidly. John and I were at the UN Climate Change Conference in Nairobi last week and in Germany (and we will come on to Germany and talk about their allocation plan, which is much less good than we might have liked) one of the things that was very striking there was that the German Environment Minister got by far the biggest round of applause (four minutes)—much more than David Miliband—when he stood up and gave very strong support for the EU as a whole taking on a 30% reduction target by 2020, and he said that if the EU did that Germany would take on a 40% target. So there is real movement happening around Europe on this, and we just need to see it translated into real, hard decisions on things like the ETS. I do not know if John has any general comments, but Kirsty has got a very good picture of some of the individual ETS related aspects.

  Mr Lanchbery: In general we have worked on WWF's work, and I know WWF have done quite a lot of work on this, where we all belong, with most of the big development groups, to a grouping called Climate Action Network Europe. We have worked through that and that has been active in most of the big countries and quite a lot of the small ones, but it is more active, as in most environmental areas, in the northern European countries—the Scandinavians, the Brits, the Dutch, the Germans—and the activity declines as you go down, generally speaking. There is very little activity in Spain, some in Portugal though. Most northern European states have been pressurised to a greater or lesser extent by the environmental groups and to some extent by the development groups actually, and most southern European states have seen little or no pressure.

  Ms Clough: Following on from what Keith has said about the German NAP, Germany is now looking at its NAP, I guess on the basis of what was said in Nairobi last week, but also there is an indication from the Commission that it is likely to be rejected in the next few days anyway. There are issues, I guess, with all the NAPs that have been submitted, but some strong caps have been set eg Spain's cap. The Italian cap in its initial draft was quite strong; that has now been watered down somewhat, but it is still looking quite good. To highlight an activity that WWF did, we created a statement that was then signed by 50 economists across Europe showing support for emissions trading as the best way to tackle climate change, and that was delivered to the Commission a few weeks ago to try and show consensus amongst that sector of the community. I can talk about some of the other NAPs if you would like to hear about those too.

  Q78  Mr Caton: If we could have that in writing it would be useful for the Committee?

  Ms Clough: Yes, sure.

  Q79  Mr Caton: From your knowledge and perspective, is there anything the UK should be doing now to influence the Commission and perhaps the more reluctant Member States to move forward at this time?

  Dr Allott: On emissions trading specifically?

  Ms Clough: On Phase II?


21   Clarification from witness 27.11.06: This means that they have decided to fit sulphur dioxide abatement equipment, which allows them to run at an unrestricted load factor up to 2016 and potentially beyond if they then fit nitrous oxide abatement equipment. Back


 
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