Consumption-Based Emissions Reporting: Government Response to the Committee's Twelfth Report of Session 2010-12 - Energy and Climate Change Contents

Appendix: Government Response

This memorandum sets out the Government's response to the Committee's report published on 18 April 2012. The Government thanks the Energy and Climate Change Committee for its continuing interest and thorough consideration of consumption-based emissions reporting, and for its conclusions and recommendations.

This response is being submitted by the Department of Energy and Climate Change (DECC) because it was to DECC that the Committee addressed most of its recommendations. However, it is important to note that the Department for Environment, Food and Rural Affairs (Defra) leads on consumption-based emissions for Government. The Department for Business, Innovation and Skills leads on the package of compensation to Energy Intensive Industries, which the Committee highlights in the report. As such, the three departments have collaborated on the response.

Considering consumption-based emissions

1. There is a clear divergence between the UK's territorial emissions and its consumption-based emissions. Furthermore, the rate at which the UK's territorial emissions have fallen has been outpaced by the growth in its consumption emissions. We are concerned that the UK could be meeting its domestic carbon budgets at the expense of the global carbon budget. (Paragraph 15)

The Government does not agree that the UK's progress in cutting domestic carbon emissions is at the expense of the global carbon budget - rather, the UK's domestic achievements contribute to global progress. The increase in consumption-based emissions is associated with globalisation and consumption patterns, not caused by domestic environment policy.

Climate change is a global problem and it is very likely that the relocation of industry from the UK and the substitution of domestic demand into imports would increase global emissions at the margin. However, these two phenomena occur largely independently of UK domestic climate change policies and the evidence is mixed on the existence of such carbon leakage occurring directly as a result of UK policy. There is certainly no evidence that UK climate change policies create more carbon emissions outside the UK boundaries than they save inside.

We do, however, take the risk of carbon leakage seriously. That is why we are working to make sure that our energy intensive industries remain in the UK and become part of the green economy - for example, providing steel for offshore wind farms - and to minimise the risk of these companies relocating to countries which are not so strongly bound by climate change policies to tackle their carbon emissions.

2. We conclude that the fall in the UK's territorial emissions was not entirely or even mostly a consequence of the Government's climate policy. Rather, it was mainly a result of the switch from coal to gas-fired electricity generation that began in the early 1990s, and the shift in manufacturing industries away from the UK in response to the pressures of globalised markets. At the same time, the emissions embedded in the UK's imported goods have increased. To complement the UK's existing territorial carbon budgets, we recommend that DECC explore the options for setting emissions targets on a consumption-basis at the national level, and to set out the steps it will take to do this when responding to the Committee's report. (Paragraph 22)

The Government agrees there is a range of drivers contributing to the fall in the UK's territorial emissions. Analysis for Defra of the drivers for the UK 1992-2004 carbon emissions trends (the period prior to the EU Emissions Trading System launch) showed there were four major drivers: 30% of the emissions savings over this period could be attributed to relocation of production, with the remainder due to efficiency - 32%, shift to services - 17%, and switch to gas - 21%[1].

The Carbon Plan (published in December 2011) committed the Government to publishing available consumption emissions data on a regular basis. Our view, based on expert advice on the limitations of the models, is that the data is not robust enough to set targets. In terms of implementing policy to meet targets, the UK has greater and more direct control over its own territorial emissions and consequently fewer policy levers to influence overseas activities.

The Government is nonetheless committed to trying to achieve a reduction in consumption-based emissions. We are keen to understand, measure and be open about the impacts associated with consumption of imported goods and services. This will provide a basis to look at what is already being achieved by existing policy and what opportunities there could be to use UK and EU influence to target overseas emissions sources. This is one way the UK, already a leader in global climate change, might continue to punch above its weight. The Government will discuss with the Committee on Climate Change (CCC) whether it could usefully investigate the possibility of using life cycle analysis data to track trends for specific priority product groups, alongside the 'top down' data (from input-output models) that is published on national consumption emissions.

3. We received no evidence that electricity-intensive industry investment decisions were being driven by the Government's climate policy, and therefore no evidence that the compensation for electricity-intensive industries announced by the Chancellor in his 2011 Autumn Statement is necessary. If electricity-intensive industries are to be "compensated" for increases in the cost of electricity—which are being driven primarily by volatility in the fossil fuel market, not climate policy—we recommend that the Government requires the beneficiaries to make clear commitments to increased energy efficiency. In its response to our Report, the Government must set out clearly what these commitments will be. (Paragraph 26)

Energy Intensive Industries (EIIs) are responsible for 45% of all business and public sector greenhouse gas emissions in the UK.[2] They will therefore need to become more carbon efficient if the UK is to meet its legally binding climate change targets. Policies such as the EU Emissions Trading System (EU ETS) and Climate Change Agreements (CCAs) have already increased energy efficiency and reduced carbon emissions - the EU ETS will be responsible for about half of UK emissions reductions up to 2020. However, this does place additional cost on industry. By 2020, the Government estimates that energy and climate change policies will add between 8 and 28% to average electricity prices paid by large energy intensive users, some of whom are unable to pass this cost onto their customers.

Energy Intensive Industries employ around 600,000 people[3] and will play an important part in the UK's transition to a low-carbon economy. Whilst we want to continue to see reductions in emissions and further innovation in energy efficiency, we need to ensure our climate change policies do not drive electro intensive industries abroad to those countries where electricity costs are lower and carbon emissions less controlled, as this would increase global carbon emissions.

The package of measures announced by the Chancellor will provide compensation for the indirect costs of the Carbon Price Floor (CPF) and EU ETS, subject to State Aid rules. The package covers industry sectors which are electricity-intensive (not gas-intensive, given that UK gas prices are the lowest in the EU 15).

The European Commission has accepted the case for compensation to electricity intensive industries from the costs passed through to them by electricity generators, arising from EU ETS. For this reason, in May 2012, the Commission published guidelines to member states on how ETS compensation can be applied.

The CPF is a UK-only policy which will also affect the price of electricity in a similar way to the EU ETS. The presence of a compensatory measure for those most at competitive risk is an important element of the CPF policy - itself a policy measure designed to increase low carbon investment. The compensation for the costs of ETS and CPF need to be considered in this context and in the context of other energy efficiency measures placed on businesses, including CCAs.

The package also announced an increase on the Climate Change Levy (CCL) discount on electricity for CCA participants available from 1 April 2013 from the previously announced level of 65 per cent to 90 per cent. Sectors who receive the increased CCL rebate will still be bound by the energy efficiency targets of their CCA agreements.

We consider the compensation will offer crucial support to those most at risk of international competitiveness and carbon leakage during the period of transition to lower carbon energy.

Policy applications

4. It is evident that the consideration of consumption-based emissions encourages the development of new policy options, as revealed by the experiences of regional authorities that have adopted a consumption-based approach to emissions accounting. We recommend that DECC explore the options for incorporating consumption-based emissions data into the policy making process, and set out the steps it will take when responding to the Committee's report. (Paragraph 39)

The Government agrees it is important for new policies to consider consumption-based emissions. Appraisal guidance for valuing policy impacts on greenhouse gases (GHGs) and energy, jointly produced by DECC and HM Treasury, already recommends that consumption-based emissions should be considered when these impacts are expected to be significant and where the analysis can be appropriately carried out [4] For example, the recent Impact Assessment on revised UK packaging targets included consideration of 'international' emissions savings - where the additional recycling meant that there were savings in consumption emissions.

As the Committee are aware, there are inevitably important practical complications in assessing the carbon impact of imported products. For example, consumption-based emissions are product-specific, and depend on the country of origin, the brand, and the specific model. It is difficult to know exactly which products will be affected by a policy, and even when this is known, then it is difficult to quantify the level of embedded emissions within these.

Whilst the methods and data required to quantify the levels of embedded emissions in products are developing quickly, in practice, the limitations of existing data, and lack of precision on how policies impact on particular products, mean the quantification of embedded emissions in policy analysis is limited. It is possible that policy analysis could be adapted to consider the risk rather than the levels of embedded emissions, and the Government will scope a risk-assessment approach for evaluating the potential impacts of policy on consumption-based emissions. This will review how these emissions could be assessed in the context of policy appraisal. A peer review of this scoping note will then take place to determine the extent to which it could be incorporated into policy development and appraisal.

So that we may obtain a balanced understanding of the UK's contribution to reducing global emissions, the Government will also take steps to increase the prominence of consumption-based emissions on websites, and in statistical releases, where both territorial emissions and consumption emissions could be presented.

5. The 9% fall in the UK's consumption-based emissions between 2008 and 2009 was primarily a result of the economic downturn, rather than of the UK's policies to reduce greenhouse gas emissions. Discounting the effects of the recession, the UK's consumption-based emissions have been on an upward trend since 1990. (Paragraph 43)

It is too early to say whether the UK's consumption-based emissions are still on an upward trend. Although the recession - and other factors such as changes to electricity production and mild winter periods - clearly had an impact on the figure for 2009, we do not have firm evidence to support the assertion that the UK's consumption emissions are still on an upward trend once the effects of the recession are discounted. Setting aside the 2009 estimate, Defra's recent statistical release shows that the UK's carbon dioxide consumption-based emissions decreased by 2.7% between 2006 and 2008, while household final consumption expenditure rose by 2.6%.[5]

6. DECC's argument that there is insufficient, robust data on embedded emissions to make policy, overlooks the extent to which consumption-based emissions can be used to connect an individual's consumption to their impact on the climate. We are not convinced that consumption based emissions data are too complex or time consuming to gather, as Defra's work in this area shows. The experiences of regional authorities has demonstrated that there is sufficiently robust data available to encourage the development of new policy options and identify carbon-intensive behaviours that are overlooked by concentrating on territorial emissions alone. We recommend that in this case, the Government does not make the perfect the enemy of the good. In its response to the Committee's report, the Government should avoid using the uncertainties inherent to consumption-based emissions data as an excuse for inaction. (Paragraph 48)

Please see the response to recommendation 4.

7. We conclude that that the UK's energy and climate change policy challenges do not lend themselves to simplistic analysis by a single data set. The growth in the UK's consumption-emissions does provide a counter-story to the one suggested by territorial emissions and we recommend that the Minister give more detailed consideration to the evidence gathered in our inquiry and presented here. We recommend that DECC no longer rely exclusively on territorial emissions as their primary policy driver. DECC's belief that territorial emissions are a better indicator of the UK's impact on the global climate is short-sighted and neglects the global impact of our consumption. Basing policy decisions on a single method of accounting for emissions is likely to have unintended consequences. In order to avoid perverse incentives, we recommend that DECC increase the extent to which they consider consumption-based emissions when making policy. (Paragraph 53)

Please see the response to recommendation 4.

8. The Committee on Climate Change has stated that it would welcome the opportunity to explore the implications that consumption-based emissions accounting may have for the UK's carbon budgets, and that they could undertake such work after they publish their fourth progress report on the carbon budget in June 2012. We recommend that the Government commission the Committee on Climate Change to undertake this work. (Paragraph 56)

The Government will discuss with the CCC what work could be done on consumption-based emissions, subject to sufficient space in their work plan. More detailed discussions would need to take place with the CCC to agree the scope of work, and the specific questions we would seek advice on, before it could be formally commissioned by the Government.

The Government's position

9. DECC's claim that the UK is only responsible for 2% of global emissions—without acknowledgement of the caveat that this is on a territorial basis and does not take account of the emissions embedded in the goods we import—is unhelpful in terms of understanding our impact on the global climate. We recommend that when the Government refers to the proportion of global emissions that the UK is responsible for it should always state on what basis that proportion has been determined: territorial or consumption. (Paragraph 60)

The Government agrees on the need to be as transparent as possible when communicating the basis for statistics. In future, where appropriate, press notices and other public-facing documents, will state whether the proportion of global emissions being referred to is determined on a consumption or territorial basis.

In addition, as described in our response to Recommendation 4, we will take steps to increase the prominence of embedded emissions on websites and in statistical releases.

10. We recommend that Government departments work together to communicate the full picture of the UK's impact on the global climate. DECC is correct in stating that the UK's territorial emissions have been falling since 1990. Defra is also correct when it states that the UK's consumption emissions have been rising since 1990. It is only when these two perspectives are presented together that the full picture of the UK's impact on the climate is revealed. (Paragraph 63)

The Government agrees presenting territorial and consumption emissions together presents the fullest picture of the UK's climate impacts; 'Measuring Progress: Sustainability Development indicators 2010' already sets out to do this. It provides an extensive range of economic, social and environmental indicators to give an overview of the country's progress towards sustainable development. The greenhouse gases section presents carbon dioxide emissions from UK consumption alongside the UK's domestic emission totals.

The UK greenhouse gas emissions section of the DECC website provides details on different approaches for reporting UK greenhouse gas emissions as well as information related to climate change published by other government bodies. This includes: information about emissions that is set out in the National Accounts, produced annually by the Office for National Statistics; consumption-based emissions reporting produced by Defra; and the "UK Biodiversity Indicators in Your Pocket" produced by the Joint Nature Conservation Committee. The website already provides an explanation of the differences between the Environmental Accounts (EA) and United Nations Framework Convention on Climate Change (UNFCCC) reporting. To provide further transparency, the Government will publish an explanation of differences between UNFCCC reporting and consumption-based emissions reporting.

11. We were concerned at the start of our inquiry that DECC officially regard consumption-based emissions as nothing more than an intellectual curiosity. Since then, possibly in response to our inquiry, there have been signs of positive developments in its understanding and approach. This is encouraging. Consumption-based emissions reporting does more than inform debate: it is an invaluable tool that should be used alongside data on territorial emissions when making energy and climate change policy (Paragraph 67)

Climate change negotiations

12. The UK has been a leader on climate policy for many years. If the UK wishes to lead on low-carbon growth—and encourage emissions reductions in countries that manufacture and export goods to the UK—we recommend that the Government acknowledges the growth in the UK's consumption-based emissions. The Committee is not proposing that a legally binding agreement on emissions reductions should be based on consumption rather than territorial emissions. However, we do recommend that the Government acknowledge that the UK's consumption is driving up territorial emissions in other countries. This admission could increase the UK's leverage over those emissions. DECC should not dismiss out of hand the potential leverage of a more holistic assessment of the UK's emissions, and an acknowledgement that the UK's consumption drives up territorial emissions elsewhere. (Paragraph 76)

The Government acknowledges that there was a growth in UK consumption based emissions between 1990 and 2008 and it is the work that has been carried out by Defra that has helped draw attention to this. The Government has focussed on getting international agreement in the UNFCCC to a global legally binding agreement that will include emission reduction targets for all major economies as the most effective way of limiting global emissions and putting pressure on countries to decarbonise, which should help reduce the emissions embedded in products. Many of the countries from which we import goods with embedded carbon have economy wide pledges that will reduce the carbon content of the traded goods including the US, EU and Japan. We also engage with other countries to support low-carbon development and hence support emission reductions across their economies and exports. For example, the UK and China Low Carbon Co-operation Memorandum of Understanding promotes low-carbon growth at provincial and city level, and we are collaborating with India on the development of its flagship energy efficiency-based trading scheme.

We welcome the Committee's recognition that the focus on territorial emissions is the right one and we accept that UK consumption of imported products impacts on territorial emissions in exporting countries. If there were opportunities where focussing on consumption emissions would leverage greater action rather than distract from the primary focus of the discussions then we would look to exploit them.

13. We accept that territorial emissions should remain the basis for international climate negotiations. However, the UK Government's emphasis on territorial emissions means that the responsibility for reducing emissions embedded in the products that we import lies with the—often, developing—countries where the goods are manufactured. We accept there is a risk that some exporters could have concerns that an increased emphasis on consumption-based emissions by the UK could be a precursor to anti-trade policies that penalised high-carbon products. On balance, however, we conclude that the potential benefits of an increased emphasis on consumption based emissions outweigh this risk. We recommend that the Government acknowledges the extent of our responsibility for these emissions in developing countries, in order to encourage a more equitable approach to reducing emissions globally (Paragraph 80)

The benefits of trade accrue to both the exporting country in the generation of income and to the importing country in satisfying a demand. While Governments and citizens should have a clear understanding of the emissions that arise as a consequence of their consumption choices, in terms of designing policy, national governments, both the UK and others, have greater responsibility for and more direct control over their territorial emissions. We will continue to direct control over our territorial emissions. In addition, strong opposition to border adjustment mechanisms means that these could risk undermining our push for an equitable and effective international deal - the most effective way to reduce emissions globally. If we identify opportunities where discussing consumption-based emissions will catalyse greater global action we will pursue them.

14. We recognise that the introduction of border tariff adjustments, to account for the carbon embedded in a product as it crosses into a country, is unlikely to be welcomed by exporting countries, particular those whose economies are developing. We recommend that the Government examine the challenges and opportunities that border tariff adjustments present when considering ways to limit consumption emissions and mitigate leakage risks. The Committee on Climate Change has declared its willingness and availability to undertake an investigation into consumption-based emissions, including an exploration of border tariff adjustment. (Paragraph 83)

We agree with the Committee's finding that there is opposition from many developing countries to pricing carbon in international trade flows. This strong opposition means that border tariff adjustments could undermine prospects for a cooperative international agreement, which is the most effective way to tackle emissions. But there are even more fundamental difficulties. Border tariff adjustments (BTA) pose a number of serious problems in terms of practicality, legality and wider impact on the world trade system. Even assuming any system of BTAs could be made WTO-compatible, it is likely to impose serious administrative burdens on companies and would stifle trade. BTAs could also be open to protectionist abuse. As the Committee highlights, BTAs pose a number of serious problems. They could be highly damaging to the international trade system and wider trade relations and could have large unintended costs; they would also be costly to administer and would be challenging to implement in a way that accurately reflected the carbon content of internationally traded goods.

To date, the UK position is that the arguments against BTAs are stronger than the arguments in favour - current evidence suggests BTAs do not offer a viable solution to the issue of consumption-based emissions. We have therefore opposed their use, instead favouring alternative policies to tackle carbon leakage (location of production to outside the EU) and promote international cooperation to limit carbon emissions. However, we remain open to exploring BTAs further and welcome studies which offer more detail on the issues.

Changing behaviour

15. We disagree with DECC's claim that the only way to affect emissions associated with UK consumption is for countries that export the products we consume to lower their carbon intensities. Reducing the carbon intensity of exporting countries is helpful, but it fails to address that emissions are also rising because the UK is consuming more. The UK's consumption cannot rise indefinitely and we see a role for consumption-based emissions reporting in addressing this unsustainable behaviour and in encouraging UK-based consumers and businesses to pay more attention to the overall carbon footprint of the goods and services they purchase. (Paragraph 88)

The Government agrees with the Committee that we need to improve the efficiency of the UK's consumption as well as driving down production emissions in order to reduce our overall carbon footprint. The Waste and Resources Action Programme has published evidence on the contribution of resource efficiency to climate change[6] which shows that consumption side strategies could deliver significantly larger savings than production based ones.

Businesses increasingly have a good grip on their own supply chain impacts and have a key role in targeting emissions 'hotspots' and in enabling consumers to make lower-carbon choices. There is a range of policies in place to support businesses to do this:

a)  Sharing supply chain evidence and impact data.   
The Product Sustainability Forum, hosted by the Waste and Resources Action Programme, is developing open source evidence and guidance for the grocery and home improvement sectors. Making this data and hotspots information freely available will enable businesses in these sectors to find out where to target their efforts, without undertaking full scale life cycle analyses for all of their products. WRAP plan to co-ordinate similar work for other sectors in future.

b)  Footprinting methodologies and standards.   
The Government has supported the development of the PAS2050, a publicly available specification providing a method for assessing the life cycle GHG emissions of goods and services. It can be used by organisations of all sizes and types, in any location, to assess the climate change impact of their products. The Government also supports the promotion and adherence to standards which embody the life cycle approach, such as the CEN TC350 standard in construction, which has been developed in Europe to homogenise the measurement of embedded emissions in sustainable buildings.

c)  Stimulating markets for low carbon products.   
The UK's Government Buying Standards set minimum sustainability criteria for public purchasing and are mandatory for central government. These take a whole life-cycle approach and in some cases these standards take into account the embodied carbon from the production process. For example, the assessment methodology used in the UK's Code for Sustainable Homes and Government Buying Standards on new builds and major refurbishments recognises and encourages the use of construction materials with a low environmental impact (including embodied carbon) over the full life cycle of a building. We are seeking to develop the Government Buying Standards so they in many more cases take into account whole life cycle emissions, including production impacts. We believe that the European Procurement Directives allow this, but, as the Directives are in the process of being renegotiated, we are seeking to address any outstanding uncertainty.

d)  Greener business models.   
As part of the drive towards a green economy, Government is seeking to encourage greater commercial uptake of service-based business models. Switching consumption away from new product sales and towards service solutions will reduce resource use and waste and cut embedded emissions. We are working, with the Waste and Resources Action Programme, to help businesses to develop and pilot new greener business models. For example, they might move to leasing products rather than selling them, or to making money from repair, upgrading or refurbishment, or through re-use of products by successive customers.

e)  Company environmental reporting  
Defra encourages companies to measure and report on their direct and indirect emissions, including those in the supply chain. We publish guidance and emission factors to help calculate emissions for all scopes. Further discussion of consumer information and behaviour is included at Recommendation 17 below.

16. We conclude that consumption-based emissions reporting can be used to inform people of the impacts of their own behaviour on global emissions. This has been demonstrated by the experience of regional authorities, which have used consumption-based emissions metrics to engage with their citizens more effectively. We recommend that this is reflected in the forthcoming demand-side work of the recently opened Energy Efficiency Development Office in DECC. (Paragraph 92)

The Energy Efficiency Deployment Office (EEDO) has a wide remit to consider where the additional energy efficiency potential is in the UK economy and, accounting for the impact of existing Government policies, consider how this potential could be best addressed. This will include reviewing how individuals and businesses are better empowered to make decisions that, for example, will benefit them through lower energy bills and benefit the planet through lower carbon emissions. Whether consumption-based emissions' reporting is the most effective way to do this will need to be considered against the other options that are available and the customer behaviour evidence base that EEDO is developing.

In this assessment it will be important to take into account lessons from behavioural economics/science, which shows that providing information often has surprisingly modest impacts when it attempts to change individuals' behaviour. For example, the MINDSPACE report prepared by the Institute of Government for Cabinet Office states that "One meta-analysis of pro-environmental behaviours reported that at least 80% of the factors influencing behaviour did not result from knowledge or awareness".

17. We acknowledge that progress has made on eco-labelling of products in order to encourage more sustainable consumption, but we conclude that more could be done to make use of the data that Defra collects on consumption-based emissions. Government should do more to make people aware of the consumption-based emissions data gathered by Defra. We recommend that DECC recognise the limitations of territorial emissions in trying to communicate to consumers how they can change their behaviour in order to reduce emissions globally. Even if an increased emphasis on consumption-based emissions has no impact on the UK's local territorial emissions, the UK has to address its consumption if it is to make an effective contribution to a global reduction in greenhouse gas emissions (Paragraph 96)

The Government agrees that it is important to communicate the UK's total carbon footprint, as illustrated by the consumption emissions data published by Defra. Measures to do more to communicate this information are discussed at Recommendation 10 above.

We also agree that behaviour change has a role to play in addressing the UK's consumption emissions. However, to be helpful, information for citizens needs to be based more on "bottom up" life cycle analysis data which will enable them to make decisions about how to buy and use specific products and services, rather than the 'top down' data from input-output models of the whole economy that is published on national consumption emissions.

Green claims and labels can help people to make informed choices by giving information about the environmental impact and qualities of products or services. Defra's Green Claims Guidance provides advice to help business make clear, accurate, relevant and substantiated environmental claims on products and in advertising. It highlights the need to consider full lifecycle environmental impacts.

Some environmental product labelling schemes, such as the EU Ecolabel, which provide citizens with assurance of high environmental standards do cover embedded emissions (e.g. the criteria for Ecolabelled paper include a maximum threshold for carbon dioxide in production). However, it is not clear that consumers will buy one product rather than another just because less carbon was emitted in its production, so measures to encourage citizens to behave differently need to go beyond direct messages and product labelling.

We already have the range of policies outlined at recommendation 15 above and, as part of its work to support the green economy; the Government will continue to look for opportunities to use policies to address consumption emissions.

1   Minx, J.C., Baiocchi, G., Wiedmann, T. and Barrett, J., 2009, Understanding Changes in UK CO2 Emissions 1992-2004: A Structural Decomposition Analysis, Report to the UK Department for Environment, Food and Rural Affairs by Stockholm Environment Institute at the University of York and the University of Durham, DEFRA, London, UK. Back

2   House of Commons Parliamentary office of Science & Technology postnote on low carbon technologies for EIIs -No 403, Feb 2012. Back

3   House of Commons Parliamentary office of Science & Technology postnote on low carbon technologies for EIIs -No 403, Feb 2012. Back

4   Valuation of energy use and greenhouse gas emissions for appraisal and evaluation. DECC and HM Treasury, October 2011 Back



6   WRAP, 2009, Meeting the UK climate change challenge: The contribution of resource efficiency. WRAP Project EVA128. Report prepared by Stockholm Environment Institute and University of Durham Business School, WRAP. Back

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