Select Committee on Environmental Audit Second Report


Evaluating the impacts of the CCAs is extremely complex

24. As with the Climate Change Levy, the idea of the Climate Change Agreements is simple: firms in certain economic sectors (e.g., steel, chemicals, cement, etc.), selected essentially because these industries are both more energy intensive and exposed to international competition, are simultaneously incentivised to become more energy efficient and protected economically, through being offered an 80% discount on the CCL in return for agreeing to energy efficiency targets. As in the case of the Levy, however, what is straightforward in theory is complicated in practice.

25. The most recent figures for carbon emissions from the sectors covered by CCAs were published in July 2007. These show that as of December 2006 emissions from businesses covered by Agreements had gone down by 16.5 MtCO2. However, one cannot treat this figure as representing the amount of carbon savings attributable simply to the Climate Change Agreements. This is firstly because, as with the Levy, the Agreements are one among several other factors affecting firms' carbon emissions. These include changes in the absolute levels of output in different sectors, reflecting wider market upturns and downturns; as well as changes in energy efficiency driven by rises in energy costs—including the effects of the Climate Change Levy itself (or in this case, the 20% of the Levy paid by businesses covered by CCAs).

26. Secondly, particular aspects of the design of the CCA system make it impossible accurately to compare the performance of business sectors covered by Agreements over time. Principally this is because the progress of firms under the CCAs is not measured from a single baseline year. As the NAO explains:

27. It is not just that the years from which baseline emissions are taken vary from sector to sector; the baseline emissions figures themselves are subject to ongoing revision. This is to reflect the changing composition of each sector as new firms join or old firms or factories are shut down: baselines are adjusted at each biennial target period to reflect the estimated energy use in the baseline years of the participants currently within the Agreements. Between 2002 and 2004 baselines changed in 31 of 46 sectors—in 13 of these, by more than 10%.[29] As the NAO states: "Wherever there have been changes, it is meaningless to compare the original baseline set in 2001 with the current energy performance of a sector."[30]

28. Another way of evaluating the effectiveness of the CCAs would be to focus on progress of participants against their specific targets under the Agreements. Overall, progress has been very impressive: by 2004 businesses covered by the CCAs had achieved annual emissions savings of 8.8 MtCO2 in excess of their targets, and according to the NAO the results published at the 2006 milestone indicate that progress is being maintained such that CCAs should deliver their overall projected impact on emissions in 2010. However, this in itself cannot give a full picture of how effective the Agreements are as a carbon reduction tool: the significance of progress against targets obviously depends on the stringency with which the targets have been set. On this the NAO comments: "it seems likely that some proportion of Agreements targets have not been as stringent as possible."[31] From its survey, the NAO found that 24 businesses subject to Agreements considered their 2010 targets to have been set at "achievable" levels, and that 10 firms were willing to indicate that their milestone targets had been "relatively simple to achieve" thus far.[32]

29. One reflection on this is that CCA targets were specifically set by the Government at levels calculated to yield 'cost effective savings'—in other words, firms should save more money from reduced fuel bills than they spend in implementing energy efficiency measures to achieve such savings. In this sense, it would hardly be surprising that businesses had achieved good practice against their targets.

30. Some observers have argued that it may not have mattered whether CCA targets were strict or not, in that these targets may not have been the prime motivation for participants to reduce their energy use in any case; instead, they argue, the Agreements have led to changes by a general raising of business attention on energy saving. This would obviously render progress against targets less meaningful as a measure of the CCAs' success. The NAO observes: "A lack of stringency in the targets may not have limited the effectiveness of the policy: the overachievement […] may be due to better than expected efficiency improvements as much as weak targets."[33] Professor Paul Ekins argued that Agreements had genuinely helped to focus participating firms on finding extra energy savings, while telling us "there is no evidence to me that the targets in the original Agreements were really part of what drove the business response".[34]

31. A further complicating factor in seeking to evaluate the CCAs on the basis of performance against targets is that most targets are set in terms of relative rather than absolute reductions in energy use. As the NAO explains:

    Where targets are relative, the Levy discount can be secured even if there is an absolute increase in energy use and carbon emissions, providing efficiency has improved sufficiently. This could be the result of production output increasing at a faster rate than increases in energy use. Unsurprisingly, relative targets were the more popular amongst businesses: only four sectors have umbrella Agreements based on absolute targets […][35]

Indeed, as of 2006, 10 sectors saw rising carbon emissions, while managing to improve their carbon / energy efficiency per unit of output.[36]

32. Finally, CCA participants have been able to use certain 'flexing mechanisms' in order to be counted as meeting their targets even where in fact they have not been able to do so through their own actions. Under one of these mechanisms firms were able to have their targets adjusted if they had changed the energy intensiveness of their output; this was used by 2.5% of target units in the 2006 milestone period, though it will not be allowed in future periods. The main mechanism used in these circumstances so far, and almost the sole mechanism to be used from the 2006 period onwards, is carbon trading. In the 2006 period, a third of target units bought carbon credits in order to make up a shortfall to their targets.[37] These trades were made via the UK Emissions Trading Scheme (UK ETS), which ran from 2001-2006. Until the end of 2006, credits for use in meeting CCA targets came from two sources: (i) firms operating within the UK ETS, where these emitted less than their allocated levels they were able to sell surplus emissions credits, and (ii) other CCA participants, where these had overachieved against their targets and were thus able to sell credits equal to this overachievement.[38] (Following the closing of the UK ETS, its trading mechanism continues to operate but solely for CCA participants; thus (ii) above is now the only source for CCA credits.)

33. While in theory the use of carbon trading has no adverse effect on the amount of carbon savings generated by the system as a whole, this depends on the stringency of the original targets: if some targets are weak, then the firms to which they apply may be able to overachieve relatively easily, and thus provide a high volume of cheap credits with a concomitantly lesser effect in driving emissions reductions. Regarding the UK ETS, the first source of credits up to 2006, a Defra report from 2007 describes it as having provided an "over-allocation of allowances […] linked to generous baseline setting and the inclusion of non-CO2 GHGs [greenhouse gases]."[39] This points to a serious weakness in the rigour of the CCA system so far, and underlines the fact that in all carbon trading schemes it is the level of the cap, rather than the trading mechanism, which is the key element. It also makes looking at the number of firms and sectors which have passed their Agreements targets an even less useful measure of the environmental impacts of the CCA system.

34. The Government's main assessment of the CCAs' impacts avoids the problems listed above; though it is not without problems of its own. What the Government has done, the Treasury first at Budget 2000 and subsequently Defra following the 2004 and 2006 milestones, has been to try to isolate the impact of the Agreements by projecting what business as usual emissions from participating firms would have been in their absence. At Budget 2000 the first round of targets were projected to yield annual savings of at least 9.2 MtCO2 in 2010 against BAU. These projected savings were then increased in 2004 to 10.6 MtCO2 in 2010, based on updated BAU projections, more stringent CCA targets set after the second milestone period, and the inclusion of twelve new sectors within the Agreements system. However, the most recent projection, made in July 2007, is for the impact of the Agreements to go down again, to 7 MtCO2 in 2010. The essential reason for this downward revision is the rise in energy prices in recent years. Updated projections of business as usual emissions are now lower, to take into account the effects these higher prices will now be having on energy demand and efficiency; this means that the added impact on emissions of the Agreements is now considered to be lower. To put it another way, BAU modelling now assumes that firms would have made more efforts to save energy anyway, even if the Agreements did not exist. The NAO's comment on this is instructive:

    The reduction in forecast impact does not mean that businesses are failing to achieve their targets, but it does illustrate the volatility of forecasting. Estimates of impact can change significantly even though businesses party to Agreements are entirely on track to meeting their targets. This 'shifting of the goal posts' applies to any policy whose success is measured against business as usual.[40]

35. In summary, it appears to us that isolating and enumerating the impacts of the Climate Change Agreements is even more complex and uncertain than accounting for the impacts of the Climate Change Levy. It is remarkable that the performance of most sectors is measured from a variety of different starting points that predate the start of the Agreements, in three cases stretching all the way back to 1990. While measuring the impact of Agreements by reference to business as usual projections avoids some of these problems, it also creates new ones of its own: as we have argued in previous reports,[41] BAU projections intrinsically lack certainty, and depend very much on the quality of the assumptions and data used to generate them. For these reasons we recommend that, when reporting figures for the impacts of the Agreements, the Government gives a range of uncertainty attaching to them.

The process of complying with Agreements has led to energy savings

36. The same 2005 Cambridge Econometrics study on which the Government relies for its assessment of the Climate Change Levy also made an evaluation of the Climate Change Agreements. This was slightly less positive in its assessment of the CCAs, however. While stressing the uncertainty of their results due to some intrinsic limitations in the modelling, the authors suggested that the majority of businesses would have met their CCA targets whether or not the Agreements existed. They came to this conclusion based on assumptions as to the continuation of historic downward trends in emissions from the business sector, due to a "combination of technological change and relative decline in UK energy-intensive subsectors of manufacturing".[42] The study also found that, aside from the continuation of these historic trends, the price effect of the reduced-rate CCL (i.e., the 20% of the Levy paid by business covered by Agreements) would have been sufficient, on its own, for the majority of sectors to improve their energy efficiency in line with their targets, even if they had not actually been set such targets.[43]

37. At the same time, the CE authors were keen to stress that "it should not be interpreted from this that the CCAs were ineffective." In related research, one of the study's lead authors, Paul Ekins, suggested that, judging by the very significant over-achievement against the CCA targets at the end of the first target period (2002), the Agreements might indeed have stimulated additional energy savings: "The argument is that the CCAs had an 'awareness effect' analogous to the CCL's announcement effect".[44] As Ekins and Etheridge put it in their study: "Industrial managers were not generally aware of the extent of these opportunities before the process of negotiating the Agreements, but became aware of them during this process". According to this interpretation of events, "industrial managers persuaded […] the UK Government […] that cost-effective measures were limited, and then went on to prove themselves wrong".[45] The overall conclusion from CE and Professor Ekins is thus that firms would have improved their energy efficiency simply in line with their CCA targets even if the Agreements had not existed, but that Agreements stimulated them to exceed this performance.

38. The amount of carbon savings attributed to the Climate Change Agreements, especially relative to the CCL, was a source of much controversy in the evidence we received. Many business groups argued vehemently not just that the Agreements were responsible for significant carbon savings but that they were far more decisive in driving reductions than the Levy. In doing so, however, such groups strongly endorsed the diagnosis of an announcement effect for the CCAs. The memorandum we received from UK ETG was typical in arguing that Cambridge Econometrics had simply got things the wrong way round: "the 'announcement effect' of CCAs has been included in the apparent savings achieved by the announcement of the CCL. This leads to an optimistically high figure for the savings from CCL alone. Conversely, the figure for CCAs is believed to be an underestimate".[46]

39. UK ETG and many others argued that what could be referred to as the CCAs' announcement effect really applied to the entire CCA process: not just the process of negotiating targets but, even more, that of putting systems in place to monitor and improve progress towards them. The Manufacturers' Climate Change Group (MCCG), for instance, said:

    It should be acknowledged that the success of the agreements has not only come from the quantitative targets and the resulting reduction in energy usage, but also the qualitative requirements, that required business to develop energy management systems […] CCAs have managed to push energy management near the top of the Boardroom agenda, at a time when energy prices were significantly lower than they are now.[47]

Gareth Stace of EEF expanded on this theme in evidence:

    [We] have seen a huge shift from 1999, when we started to negotiate the agreements, where we would go and ask companies for data in order to form a base year and they would find it very difficult to get that data—you might talk to an engineer and he might have the data in an oily book but he does not see the bills, the finance departments have those. We have seen a huge shift in those companies, where almost every one within that company is aware of the current efficiency of their facility, how that is improving, what they can do to improve it, with new schemes within their company to drive efficiency improvements to meet their Climate Change Agreement targets.

    Then we meet companies within the EEF membership who do not have agreements, who cannot get Climate Change Agreements, and the story is very different, and, in my mind, we are almost still back to that place in 1999 where you ask about energy efficiency and it is not really there. I think that is why we are really strong believers in Climate Change Agreements, both for the actual emissions reductions that are taking place […] but also, as I keep saying, for driving this up the agenda and helping those companies […] going beyond their targets and realising that they can do more.[48]

40. The argument that the CCAs have played a key role in improving companies' internal awareness of their energy use was endorsed to us by AEA Energy & Environment, the consultancy contracted by Defra to help design, evaluate, and audit the CCA system: "When we started this process many sectors did not really have a clue what their energy performances were like, they did not have good baseline data [… T]he sectors have many more years now of much better quality data".[49] In this context, AEA raised the point that the sector associations, responsible for co-ordinating the relationships of participant firms with Government, including negotiating umbrella Agreements, played an important role in spreading good practice and improving the quality of information on energy use.[50] This was echoed by UK ETG, who referred to the way in which the Agreements system has led to the building up of networks within industry, focusing on energy efficiency and carbon emissions, as an "enormous benefit".[51]

41. Although there are difficulties in arriving at a firm evaluation of the carbon savings driven by the Agreements, the anecdotal evidence suggests that the process of complying with CCAs has had a very positive effect, leading to a widespread improvement in energy management systems, greater sharing of good practice, and a general raising of energy efficiency as a boardroom priority among participating firms.

The use of a tax discount has been key in capturing business interest

42. Another viewpoint shared by AEA Energy & Environment and UK ETG, as well as a number of others, was on the peculiar effectiveness that appears to derive from the way in which the Agreements are based around a tax discount. Robert Bell of AEA remarked:

43. What such evidence highlighted was that, according to economic theory, companies should have been more active in pursuing energy efficiency improvements in any case, in order to benefit from reduced fuel bills. The introduction of the Climate Change Levy was in keeping with such economic theory; it simply sought to add to the existing financial incentive to cut the wasteful use of energy. Given that the targets under the Climate Change Agreements were specifically set by AEA Energy & Environment at levels calculated to achieve cost-effective energy savings, economic theory would again suggest that this would be enough on its own to stimulate significant action. And yet, AEA and others told us that it was the extra financial incentive of claiming a tax discount that was key in making companies act.

44. This was a point made particularly strongly by Andrew Warren, director of the Association of the Conservation of Energy (ACE):

    I suspect that probably one of the reasons why the Agreements delivered savings in the way in which, if you like, one would have anticipated that rational man might have delivered because they were quintessentially cost-effective in the first place, was just simply that it is much more fun saving money from the taxman than it is just saving money. I think it does concentrate minds if you are being told you can save money in that way. I think we have seen this in the residential sector too in the way in which people have sought to deliver the energy efficiency commitment by dint of using ostensibly money off the council tax. It does concentrate minds in a way which you would not get if you were merely making the very rational argument that there is an awful lot of cost-effective energy saving which at the present moment is foregone.[53]

ACE has for a long time, in fact, argued that simply relying on a price signal alone is not enough to drive behavioural changes in energy efficiency, at either an organisational or personal level. Indeed, describing the interrelation of the tax, discount, and measures required to receive that discount, Mr Warren went so far as to describe the Climate Change Agreements as:

    the first example of an integrated policy approach in this context, combining 'carrots' (80% discounts), 'sticks' (the threat of full payment for non-compliance) and 'tambourines' (drawing management attention to energy consumption), which this Association has long described as absolute prerequisites for any successful energy efficiency scheme.[54]

The stringency and value for money of the CCA system should be increased

45. Certain questions were raised during our inquiry on the extent to which the Climate Change Agreements were sufficiently stringent. A key criticism is that CCA targets were too generous when initially set, have so far been tightened only once since the system began—in 2004, but before the performance data on the first milestone period, from 2002-2004, were known—and that they were still too generous even after this revision. The Environmental Industries Commission, for instance, wrote to us: "EIC's Members, who have great experience advising business on energy efficiency, have regularly informed Ministers since the introduction of the Agreements that the potential for savings in the sectors covered is much greater than reflected in the Agreements."[55] Certainly the NAO is clear that there is room for targets to be made more stretching: current CCA targets "are forecast to maintain a steady annual level of additional carbon savings, but will not drive energy efficiency to the next level."[56]

46. As the NAO describes, a lack of information, both before the initial targets were set, and during the process of setting revised targets in 2004, hampered the Government's ability to take a tougher position in negotiating sectoral Agreements. The result was that after setting revised targets in 2004, intended to be tougher and to drive further efficiencies, the Government discovered that many sectors were making more rapid progress than expected—to the extent that 10 sectors had already improved performance enough to pass their newly revised targets for the next three milestone periods, all the way to 2010.[57] At the 2006 milestone period the number of sectors that had already met their 2010 targets had increased to 25, very nearly half of all sectors. On this progress at the 2006 milestone Defra has written to us: "This suggests that targets can be further tightened in the 2008 target review".[58] However, while we are reassured by this, we are surprised and disappointed that 2008 represents only the second opportunity for targets to be reviewed since the beginning of the Agreements.

47. We are highly surprised that the Government has not tightened the Agreement targets since data from the first milestone period revealed that both the initial set of targets, and those revised in 2004, were too lax. We recommend that CCA targets should be reviewed at every milestone period.

48. A further concern was raised about the value for money offered by the Agreements. According to Cambridge Econometrics, the 80% discount on the Levy given to CCA participants represented a cost to the Exchequer, in terms of CCL revenue forgone, of approximately £350 million in 2003-04.[59] Andrew Warren asked whether the current CCA regime was sufficiently rigorous in terms of driving emissions reductions to justify tax rebate of this size.[60] This was particularly appropriate to ask, he felt, given that the Marshall Report had suggested:

    [...] that we would get just as much of an incentive there to companies to look at this if the discount was 50% rather than 80%. […] By dint of having a reduction of 80% rather than 50%, there is certainly about £120 million extra that has been forgone […] If you were to ask me whether or not that £120 million which the Treasury have not taken in could perhaps have been better spent in terms of delivery of the end objective, which is improved energy efficiency and improved carbon savings, I have to say the answer would almost certainly be yes. I am dubious as to whether it was strictly necessary to be as generous as the Government turned out to be in the end.[61]

We might add to this point by drawing attention once again to the fact that CCA targets are meant to have been set at 'cost-effective' levels, thus that meeting them ought in itself save companies money.

49. The questions this raises are how far CCA targets should be toughened, as well as whether the size of tax discount provided under the Agreements should be reduced. This in turn partly hinges on the question of how much can be asked of firms under the Agreements without seriously damaging competitiveness. That is to say, how much further potential is there within energy intensive industries to make ongoing energy and emissions savings, and when and to what extent will 'cost effective savings' start to dry up—i.e., when might new levels of energy savings begin to cost more money to achieve than they save in fuel bills?

50. AEA Energy & Environment argued that there was still considerable room for efficiency savings, even from energy intensive industries:

    We do not necessarily hear exactly what companies do in order to meet their targets, they are not required to tell us, but my feeling is that at the start of the agreements, in 2001/2002, once companies knew that the game was on and it was going up to board level people found more savings, probably much more low-hanging fruit than they actually anticipated [… C]urrent activities have mainly been directed more at the utility side of energy use and there is scope in many sectors for more energy-saving capability on the process lines—heat recovery, […] installing more efficient motors, but generally looking at "how am I making it, and indeed why am I making it?", rather than just looking at a new steam system or a new compressed air system. There is still a lot of that basic stuff to be had but there is also another level of thinking which is yet in some areas to be had, saying "are we doing this processing in the most efficient way or can we schedule it differently?" or whatever. That is why I think there are more savings to be had.[62]

This opinion was echoed by Paul Ekins, who declared that "technology develops; long-hanging fruit once picked is inclined to grow, especially if there are price incentives to do that."[63]

51. By contrast, representatives of several business groups argued that the pursuit of energy efficiencies was either naturally subject to diminishing returns; or if it were to be continued, would require major technological innovations, in turn requiring significant amounts of time and money to develop. Ray Gluckman of UK ETG argued that while "there is enormous low-hanging fruit still available" in smaller and non-energy intensive organisations outside the Agreements, and "some low-hanging fruit available" in some industries within CCAs, in "that top band of highly energy-intensive industries—steel, cement, glass, and so on—the low-hanging fruit is long gone."[64] Steve Bryan of SABIC Europe, an international plastics and chemicals company, argued that for much heavy industry further increases in carbon savings, along the lines recommended by the Stern Review, will require step-changes in technology; "they are not, if you like, a natural continuum of the process we have been discussing under the existing agreements."[65] EEF and UK Steel also argued that for energy intensive industries such as "the steel sector, there have always been substantial drivers towards improving energy efficiency because energy is such a huge part of our costs", implying there was little scope for further incremental improvement. (We would observe, however, that this argument seems to rather contradict EEF's point about the value of the Agreements, and the way in which CCAs raised energy management from "oily book" to boardroom.)

52. We also received evidence on this issue from Dr Ian Bailey, lecturer in economic geography at the University of Plymouth, and the author of a number of papers on industry's responses to carbon reduction instruments. He told us:

    I have spoken to an awful lot of business leaders over the course of the last ten years. […] The issue of the actual existence of technology seems to be a lesser issue for most of the energy intensive sectors that I have spoken to. The greater issue is the affordability of that technology and the various either internal company financing requirements or the need to go out on to open capital markets and persuade other investment organisations to invest in things which have got a very long pay back lead-time.[66]

The conclusion he drew was that more public funding should be made available for industries to make such investments.

53. Given both that targets have been readily overachieved so far and that meeting them should have saved participating firms money, and given the overall imperative to accelerate carbon reductions, we recommend that targets are considerably toughened at the next milestone period. To help preserve a constructive relationship with industry, protect competitiveness, and accelerate emissions reductions, the Government should increase public investment in low carbon technology, as well as grants or loans to aid its procurement.

54. A further theme in our inquiry on the subject of the value for money of the CCA system concerned the extent of auditing of and compliance with targets. At the time of our inquiry only 9% of target units had been audited to ensure they had achieved the performance against targets they had claimed—and that in nearly one in five of these audits serious errors had been found. Andrew Warren commented on this: "To have only done less than 10% of these is really not sufficient to give one complete confidence that these tax breaks are justifiable."[67] AEA Energy & Environment, the consultancy which carries out the audits, was more relaxed, arguing that audit coverage will increase with time, and that most of the errors found so far are related to poor quality base year data, and thus not of ongoing concern.[68]

55. Perhaps more worryingly, the NAO report highlighted that some 6% of target units were treated as having passed their 2004 milestone, and as a result had their 80% discount on the Levy renewed, despite failing to meet their efficiency targets. This is because if a sector overall is judged to have met its umbrella Agreement, then all units within it are treated as having passed, even if some of them may have failed individually; Defra/AEA initially look at sector performance, and only drill down to the level of individual target units if the sector as a whole has failed to meet its target. This claim was contested by UK ETG, who said: "We have some rather strong views here. We think that the NAO have misunderstood the way that most of the Climate Change Agreements work. [… V]irtually all businesses with Climate Change Agreements either meet the target by saving the energy as required or they meet the target by purchasing CO2 allowances in the emissions trading mechanism."[69]

56. We would respond to this criticism by stating that the NAO is not referring to target units which did not reach their own Agreement targets, but which bought carbon credits to make up the difference; this, after all, happened in 27% of cases in 2004, not 6%.[70] Rather, the NAO has drawn attention to a significant number of businesses which have both failed to meet their CCA targets through their own actions, and failed to make up the difference to these targets through other mechanisms such as carbon trading—and yet which continue to enjoy their CCL discount. Regulations should be tightened to ensure that this cannot continue. The trading mechanism established within the CCA system should make this straightforward: any firm that does not meet its target through its own actions should be required to purchase credits to make up the difference, or lose its Levy discount.

28   NAO, The Climate Change and Climate Change Agreements, p 27 Back

29   NAO, The Climate Change and Climate Change Agreements, p 28 Back

30   NAO, The Climate Change and Climate Change Agreements, p 28 Back

31   NAO, The Climate Change and Climate Change Agreements, p 27 Back

32   NAO, The Climate Change and Climate Change Agreements, p 29 Back

33   NAO, The Climate Change and Climate Change Agreements, p 30 Back

34   Q192 Back

35   NAO, The Climate Change and Climate Change Agreements, p 21 Back

36   British Meat Federation, Ceramics - fletton, Craft Baking, Eurisol [Mineral Wool], Glass, Gypsum Products, Poulty Meat Processing/Feed, Printing, Rendering, and Slag Grinders. NAO, The Climate Change and Climate Change Agreements, pp 41-2 Back

37   NAO, The Climate Change and Climate Change Agreements, p 23 Back

38   NAO, The Climate Change and Climate Change Agreements, p 23 Back

39   Defra, Climate Change Instruments: Areas of overlap and options for simplification, October 2007, p 65 Back

40   NAO, The Climate Change and Climate Change Agreements, p 24 Back

41   Notably: Environmental Audit Committee, Seventh Report of Session 2006-07, Beyond Stern: From the Climate Change Programme Review to the Draft Climate Change Bill, HC 460. Back

42   Cambridge Econometrics, Modelling the Initial Effects of Climate Change Levy, p 7 Back

43   Cambridge Econometrics, Modelling the Initial Effects of Climate Change Levy, p 7 Back

44   Cambridge Econometrics, Modelling the Initial Effects of Climate Change Levy, p 7 Back

45   Paul Ekins and Ben Etheridge, in NAO, The Climate Change and Climate Change Agreements, p 30 Back

46   Ev 19 Back

47   Ev 121 Back

48   Q14 Back

49   Q118 Back

50   Q118 Back

51   Q58 Back

52   Q128 Back

53   Q85 Back

54   Ev 49 Back

55   Ev 111 Back

56   NAO, The Climate Change and Climate Change Agreements, p 31 Back

57   NAO, The Climate Change and Climate Change Agreements, p 30 Back

58   Ev 137 Back

59   NAO, The Climate Change and Climate Change Agreements, p 61 Back

60   Q102 Back

61   Q103 Back

62   Q140 Mr Huddlestone Back

63   Q194 Back

64   Q82 Back

65   Q82 Back

66   Q168, Q179 Back

67   Q102 Back

68   Q119 Back

69   Q85 Back

70   NAO, The Climate Change and Climate Change Agreements, p 23 Back

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