2UK Export Finance’s support for the energy industry
30.UK Export Finance (UKEF) supports businesses through the provision of insurances, guarantees and loans. It reports the scale of this support in terms of maximum liability on all new business, which represents the maximum amount that UKEF would pay in the event of a successful claim.69
The scale of UKEF’s support for the energy industry
31.Between 2013/14 and 2017/18, 21% of UKEF’s support (£2.6 billion) was for the energy sector.70
Table 1: UKEF’s support to the energy sector
Source: Based on breakdown of UKEF support by Financial Year in written evidence by UKEF
32.Between 2013/14 and 2017/18, 96% (£2.5 billion) of UKEF’s support to the energy sector went to fossil fuel exports, and just 4% (£104 million) to support renewable energy exports.71 High-income countries received £272 million in energy support, while low- and middle-income countries received £2,361 million.72 The largest proportion of UKEF’s support to energy sector exports went to fossil fuel projects in low- or middle-income countries (£2.4 billion or 90% of total energy support to all countries between 2013/14 and 2017/18).
Figure 1: UKEF’s energy support by recipient country classification and energy type
Source: Based on breakdown of UKEF support by Financial Year in written evidence by UKEF
33.UKEF’s support to the energy sector grew between 2013/14 and 2016/17, from £392 million to £919 million, before falling to £250 million in 2017/18. UKEF told Committee staff that it attributes the decline in support to the energy sector in 2017/18 to demand for export finance and the nature of UKEF’s support. It highlighted that a delay in one or two large projects can easily lead to transactions being recorded in one financial year rather than another. Its figures for support in 2018/19 are due to be approved in June 2019.
UKEF’s support to exports to high-, medium- and low-income countries
34.There is a stark and growing difference between the profiles of UKEF’s support for energy-related projects in low- and middle-income countries, compared to high-income countries. While overall support for energy-related projects decreased in 2017/18 in both groups, in high-income countries UKEF has rapidly increased the proportion of its energy support to renewable exports.73 Renewables made up 96% (£68 million) of UKEF’s energy support to high-income countries in 2017/18, compared to 0%-5% (less than £0.5 million) in 2013/14.7475
35.By contrast, fossil fuels made up 99.4%, and renewables 0.6%, of UK Export Finance’s energy support to low- and middle-income countries (£178 million and £1 million respectively in 2017/18). This shows little change from UK Export Finance’s longer-term support patterns.
Figure 2a: UKEF’s support to energy exports in low- and middle-income countries, 2b UKEF’s support to energy exports in high-income countries
Source: Based on breakdown of UKEF support by Financial Year in written evidence by UKEF. All data is rounded to the nearest whole number.
36.UKEF CEO, Louis Taylor, told the Committee that he attributed UKEF’s high levels of fossil fuel support to low- and medium- income countries to three factors. Firstly, he said that the UK’s industrial capacity in the renewables sector is lower. He explained:
We just do not have the capacity to build wind turbines… We cannot support UK content where there is no UK content to support.76
37.Secondly, he emphasised that UKEF exists to “fill the gaps in private sector provision of finance, not to compete with the private sector.”77 This means that:
For renewable energy projects there is a considerable amount of liquidity available for those projects, so the need for UK Export Finance is reduced, to an extent.78
38.Finally, he argued that UKEF’s support for oil and gas should be seen in the context of a transition from fossil fuels which generate high carbon emissions (such as coal and diesel generators) to lower carbon fossil fuels, such as gas.79 He also emphasised that UKEF’s support represents just 0.02% of global oil and gas investment in any one year.80
Criticisms of UKEF’s support for fossil fuels
39.UKEF’s support for fossil fuel projects was widely criticised by witnesses to this inquiry and in written evidence. Below are some of the main themes.
Out of step with the UK’s climate goals
40.Many contributors, such as E3G, criticised UKEF’s support for overseas energy investment in fossil fuels for being inconsistent with the UK’s international climate commitments:
Despite the UK’s signing of the Paris Agreement, the majority of UK Export Finance’s overseas energy investment supports fossil fuels. This is leading to an increase in greenhouse gas emissions, carbon lock-in and the risk of stranded assets. Such support severely undermines the UK’s domestic and international climate action as well as its commitment to the UN’s Paris Agreement on Climate Change.81
41.Global Witness argued that
Funding fossil fuels also undermines our International Development goals. The £4.8 billion total UKEF support for fossil fuel projects between 2010–16 is nearly equal to the UK’s total spend on its International Climate Fund for a similar period, 2011–17, which came to £4.9 billion.82
This view was supported by The Elders (an independent group of global leaders who work for “peace, justice and human rights”), and E3G.83
42.The Elders called on the UK Government to use this Committee’s inquiry as an opportunity to “demonstrate a clear shift in policy away from fossil fuel use” and to
Recalibrate its export finance policy so it is fully consistent with international climate trends and obligations as a G20 member state.84
Former UN Secretary-General, Ban Ki-moon, wrote that UKEF’s policy needs “recalibration” to meet international climate trends and obligations and argued:
“The best way for any country to avoid climate complacency is to develop robust, holistic and people-centred policies across government, so short-term trade or financial priorities do not trump the wider imperative of cutting global emissions.”85
43.On the other hand, Baroness Fairhead claimed that UKEF’s activities are in keeping with the Paris Agreement. She said that UKEF had conducted a review because of the Paris Agreement which led to UKEF’s agreement to support the Powering Past Coal Alliance (PPCA), which the UK founded jointly with the Government of Canada in 2017.86 The PPCA commits members to “the rapid phase-out of unabated coal power”, as well as to “supporting clean power generation through their policies … and investments, and to restricting financing for unabated coal power generation.”87 Baroness Fairhead emphasised that beyond the PPCA commitments, “we did not feel that there was any immediate change needed in our policy,”.88 She explained that:
Even under the IPCC report there is an acknowledgement that further investment will be required in oil and gas, as we manage the transition.89
44.However, while there was generally a consensus that there would be some role for gas during transition to renewables, there was significant disagreement over the extent and timing of support for gas projects. A confidential submission argued that a full transition towards clean energy growth “will take decades, not single digit years,” and would require further UKEF support for the oil and gas industry during this time.90 By contrast, the UK Student Climate Network argue that “all subsidies, investments, credit lines and material support for fossil fuel exploration, extraction and development must cease immediately.”91
45.Analysis by Oil Change International found that the remaining global carbon budget to limit warming to 1.5°C would be more than used up by the oil, gas and coal fields already in existence, without investment in establishing more.92 Oil Change International compared data from its 2016 The Sky’s the Limit report to the IPCC projections for possible fossil fuel use whilst still limiting global heating to 1.5°C (with a 50% change) and 2°C (with a 66% chance). It concluded that:
The oil, gas and coal to be extracted from already-developed fields and mines would take the world well past the 1.5 degrees specified in the Paris goals, and almost to 2 degrees of warming. Even if coal were phased out overnight, the oil and gas alone would take the world beyond 1.5 degrees.93
Figure 3: Committed emissions from developed fossil fuel reserves compared to carbon budgets in the IPCC Special Report
Source: Written evidence by Oil Change International
46.Much of the evidence referred to the tension between the UK’s domestic and international approaches. Carbon Tracker Initiative raised concerns that, comparing UKEF’s behaviour to the UK’s ambitions through the Clean Growth Strategy and Sustainable Development Goals:
The UK is in our view perhaps an extreme example of how an anomaly between national and international approaches can manifest itself.94
47.Navraj Ghaleigh, Senior lecturer in climate law at the University of Edinburgh, supported this view, saying “We are making enormous efforts to decarbonise domestically … but making significant contributions to the problem through our exporting activities. That is a classic case of policy misalignment.”95 He also warned that this needs to be realigned quickly to meet the UK’s climate goals:
If we are going to hit 1.5° or anything close to it, all the pathways say that we need very rapid decarbonisation, demand-side mitigation, electrification and emissions reductions now—meaning the decade from 2020 to 2030—as well as carbon dioxide removals. If that is correct, and if it is what we want to do, the current pattern of UK export finance is simply flatly inconsistent with it.96
48.Some, such as the Elders, have argued that this discrepancy between domestic and international policy is a form of exploitation:
It stirs painful memories of past exploitative behaviour to see the UK and other rich, industrialised countries proclaim their good intentions and act in a progressive way at home, whilst effectively exporting their emissions to poorer foreign countries and leaving them to pay the price socially and environmentally.97
49.This was backed up by the Abibiman Foundation, who appealed for UKEF to “stop supporting fossil fuel projects in Ghana” and instead invest in “renewable energy to promote a just energy transition.”98 Moreover, Baroness Brown of Cambridge told the BEIS Committee that the UK has a moral obligation to move further and faster in responding to climate change:
We are a wealthy country because of the industrial revolution and what has happened since then. We have benefitted from the creation of the problem over hundreds of years. Other countries such as China have not. On a per capita basis, we are responsible for the second largest contribution to historic emissions, which are causing the climate change we are seeing now. We therefore have an obligation to go faster than developing countries in addressing that problem99
50.By contrast, Baroness Fairhead emphasised that UKEF’s support for the offshore oil and gas field in Ghana is helping the country to lower its emissions:
[It] will help to reduce CO₂ emissions because the gas that is piped ashore and burned in power stations will obviate the need for hundreds of diesel generators that will pollute far more than the gas. This is genuinely a transition story.100
51.We will explore the role of UKEF’s support in energy transition in more detail in Chapter 3.
UKEF’s symbolic role
52.The total energy support provided by UKEF between 2013/14 and 2017/18 was £2.6 billion. Louis Taylor, CEO of UKEF, emphasised that “UKEF is only 0.02% of global oil and gas investment in any one year.”101 However, this figure minimises the significant role that UKEF plays in enabling fossil fuel projects through removing risk and sending investor signals to the market. Greg Muttitt, Research Director at Oil Change International told the Committee that UKEF plays an important role in “de-risking investments” as its support means that:
Other investors and companies … get involved in projects that would not otherwise in the absence of UKEF support, and so it has a role in unlocking much larger amounts of investment and capital.102
53.E3G highlight that, in addition to de-risking projects, UKEF’s support “sends a clear and important signal to the wider investment market. Investors and companies will follow these signals and support fossil fuel projects they otherwise may not have considered.”103 UKEF’s disproportionate impact is backed up by UKEF’s own evidence. UKEF wrote that many UK businesses “would not have been able to go ahead with their exports or supplies for exports” without UKEF’s support.104 A confidential submission to the inquiry stated that UKEF has been “one of the bright lights of positivity” after “four very difficult years in the UK energy sector, especially for oil & gas.”105
Carbon lock-in
54.The Overseas Development Institute (ODI) argues that by continuing to support fossil fuel-based developments, UKEF contributes to “carbon lock-in that commits countries to polluting energy systems and increases the risk of stranded assets.”106 This view is supported by E3G and Ban Ki-moon.107 Professor Anderson explained the consequences:
It is completely incompatible to be investing in fossil fuels elsewhere in the world if we are going to meet our Paris commitments. We need to be very clear about this: when we invest in fossil fuels, we are locking in high-carbon infrastructure for decades to come, sometimes in poorer countries, along with all the other accompanying air pollution issues.108
55.Written evidence by Tearfund pointed out that “The Prime Minister has recognised that ‘clean energy is already an easier, cheaper and safer option’ and ‘by adopting 21st-century methods such as solar and wind power and energy storage, developing economies can today leapfrog the dirty technologies of the past.’”109 Tearfund argued that “focusing investment on clean energy sources will decouple economic growth from increased GHGs, enabling countries to leapfrog to a low-carbon economy.”110 Investment in fossil fuel infrastructure puts this at risk.
Stranded assets
56.Global Witness, E3G, Both Ends, ODI and WWF all highlight that UKEF’s support for fossil fuels, particularly in developing countries, may contribute to stranded assets.111 The Smith School of Enterprise and Environment at the University of Oxford defines stranded assets as:
57.“Assets that have suffered from unanticipated or premature write-downs, devaluations or conversion to liabilities. They can be caused by a range of environment-related risks and these risks are poorly understood and regularly mispriced, which has resulted in a significant over-exposure to environmentally unsustainable assets throughout our financial and economic systems.”112
58.Research by Alexander Pfeiffer et al, published in May 2018, found that even if the entire current pipeline of all power generation plants was cancelled, about 20% of current in-use global capacity would need to be stranded (that is, “prematurely decommissioned, underutilized, or subject to costly retrofitting” to meet the 1.5°C–2°C warming goals.113 ODI explains how this can lead to an increased risk of stranded assets, including among UKEF’s projects:
If new fields and mines are developed … this can do one of only two things: either they push the world beyond climate limits, or they require a greater amount of existing infrastructure to be closed early, at a cost of economic and social disruption: stranded capital assets and lost jobs.114
59.Ben Caldecott told the Committee that he was “very concerned” about the risk of stranded assets from fossil fuel energy projects overseas.115 He argued that:
UK Export Finance is exposed to the risk of stranded assets through, of course, the loans and guarantees it is providing. It is also having an impact on the environment through those loans and guarantees, and through the activities that it is supporting.116
60.UKEF told us that while they were aware that some fossil fuel energy projects, such as oil refineries, “may fall into the category of assets that are considered potential stranded assets in the future” they were “comfortable” with the fact that they “do not really calculate [their risk] in terms of climate risk.”117 While the projects UKEF supports may be at risk of stranded assets, as they have “very long life spans, up to 40 years,” Louis Taylor told the Committee that UKEF’s risk exposure, in contrast, was less:
Our lending to those projects can last up to 17 or 18 years, depending on the length of time of their construction period.118
Subsidies
61.In 2016, the UK agreed, as part of the G7, to phase out inefficient subsidies for fossil fuels by 2025.119 As a member of the G20, the UK has repeated its commitment to phase out fossil fuel subsidies every year since 2009.120 Under the WTO Agreement on Subsidies and Countervailing Measures, WTO members are prevented from providing certain “subsidies” and includes in its examples of prohibited subsidies, export credit programmes priced at premium rates which are inadequate to cover their long-term operating costs and losses.121 UKEF explained:
The net result of [these] requirements, and those of the Treasury, is that UKEF is precluded from providing subsidies for exports, whether they are destined for projects involving fossil fuels, renewables or otherwise.122
62.In evidence to the inquiry, Neil McCulloch summarised the prevailing definitions of government subsidies as:
Price gap method: which considers the gap between the price that fuel/energy is sold and the cost of production. This is good at capturing consumption subsidies (e.g. where the government sets the price below the market price), but not so good at capturing production subsidies (e.g. tax concessions given to energy companies) [or]
Inventory method: this approach compiles an inventory of all forms of government support e.g. through the budget or through tax reliefs and exemptions. It captures production subsidies better than the price-gap method but misses consumption subsidies that are not included in the budget.123
63.UKEF focuses on the first of these approaches, defining subsidies as “a government action that lowers the pre-tax price to consumers below international market levels.”124 Since part of UKEF’s remit is to conduct its business at no net cost to the taxpayer, it asserts accordingly that they do not provide subsidies. The UKEF business model involves a fee for the exporter and, further, the premiums charged are set by the OECD and calculated to reflect commercial rates. On that basis, UKEF claim their customers are paying a cost similar to what they would in the private sector and so are likely to charge a price that reflects full market costs.125
64.However, this approach has received significant criticism. Christian Aid claims that “the OECD, IMF, International Energy Agency, World Bank and G20 all agree that the UK does subsidise fossil fuels under any widely accepted international definition of subsidy.”126 Similarly, Neil McCulloch told the Committee:
The UK Government argue that they have no subsidies for fossil fuels. That is clearly false. It is very easy for them to hit a target of having no subsidies if you define yourself as having no subsidies. The reality is the OECD—which compiles an inventory on fossil fuel subsidies—makes it clear that there are substantial subsidies for fossil fuels, part of which is from UK Export Finance.
… What we are talking about here is transparency. … There is an issue as to whether or not the UK taxpayer should know how much UK Export Finance currently supports fossil fuels … we should at least know how much that subsidy currently is.127
65.In comparison E3G highlighted that the World Bank has committed to ending all finance to upstream oil and gas investment after 2019, other than in exceptional circumstances.128
Measuring subsidies
66.In 2018, the OECD published its Companion to the Inventory of Support Measures for Fossil Fuels 2018. Using a credit rating-based approach, the report offers a practical strategy on how to “quantify the support element of government credit assistance (i.e. preferential loans and loan guarantees) to fossil-fuel-related projects.”129 The report explains:
Government credit assistance can confer substantial benefits to carbon-intensive infrastructure, thus hampering the transition towards a low-carbon world, while inducing revenue losses for Governments. Quantifying the support elements of such measures therefore enhances transparency on the use of public resources.130
67.Neil McCulloch argues that this report is significant for transparency in the case of UKEF:
Now we have a methodology that has been adopted by the OECD there is no reason whatsoever for all export credit agencies, including UKEF, to support that and to report on the findings.131
Peer review mechanisms
68.An alternative to eradicating fossil fuel subsidies that some countries have adopted is the concept of subsidy peer review. Oil Change International explains that the peer review process:
Aims to provide a platform for countries to provide feedback on each other’s subsidy estimates and progress on phase-out. Although the peer review process may not produce a standardised method and format for fossil fuel subsidy tracking, it could help to improve wider transparency on fossil fuel subsidies and accountability for their phase-out.132
69.The OECD report identified “more than 1,000 policies conferring a benefit to the use or production of fossil fuels in 43 countries.”133 It attributes a majority of these to policies which were “introduced decades ago in the form of tax expenditures, which are not revised with the same regularity as budgetary transfers.”134
70.The report notes that:
The four peer reviews undertaken to date, by the People’s Republic of China, Germany, Mexico, and the United States, have identified several fossil fuel subsidies as inefficient, and have described plans to phase them out over the short or medium term. These peer reviews highlight the importance of transparency in this domain. They have proven to be instrumental for learning and sharing best practices on estimating support, assessing its effectiveness on meeting public-policy objectives, and on sequencing reform. They have also revealed existing definitional gaps, both among and within countries (i.e. across ministries), particularly over what constitutes a ‘fossil fuel subsidy’ and under what conditions a given subsidy can be considered ‘efficient.135
71.The report also highlights work by countries such as India, Indonesia and Mexico to reform prominent fuel pricing policies that used to support fuel consumption.136 It argues that “phasing out fossil fuel support results in a dual benefit of addressing climate policy objectives to reduce CO₂ emissions and local pollution, and raising public revenues.”137
The UK’s climate leadership
72.In December 2017 Prime Minister Theresa May said:
There is a clear moral imperative for developed economies such as the UK to help those around the world who stand to lose most from the consequences of manmade climate change. But by putting the UK at the forefront of efforts to cut carbon emissions and develop clean energy, we can also make the most of new economic opportunities.138
73.In its 2018 25 year Environment Plan, the UK Government said that it “has a role in protecting and improving the environment both at home and abroad” promised to “show leadership” on climate change.139 The UK Government has signed up to repeated pledges by the G20 and G7 to phase out fossil fuel subsidies, and was one of the first countries to commit to ending unabated coal power generation by 2025 as part of the Powering Past Coal Alliance.140
74.The UK’s Clean Growth Strategy promises:
To maximise the domestic and international opportunities for the UK, we will strengthen our support for businesses as part of the transition to the low carbon economy. We have added billions of pounds in potential support for UK exporters, doubling the capacity of UK Export Finance and increasing available cover for individual markets by up to 100 per cent, and will dedicate resources within the Department for International Trade to promote investment into the UK renewable energy landscape, develop this supply chain further and support UK exports.141
75.However, Both ENDs have said that “the scale of UKEF support for fossil fuel-related transactions clearly does not match British leadership in international efforts to combat climate change,” and CAFOD have described UKEF as the “’elephant in the room’ undermining UK climate and development leadership.”142
76.Although UK Export Finance’s (UKEF’s) support to UK businesses in the energy sector is demand-led and makes up just 0.02% of global oil and gas investment, UKEF’s support “de-risks investments” and “sends a clear signal” to the wider investment market, attracting further finance to the projects which it chooses to support. Changes to UKEF’s climate-related practices would have significant symbolic and real-world value as evidence of the UK’s leadership on tackling climate change. UKEF have already shown some willingness to address climate concerns by phasing out coal support (through the Powering Past Coal Alliance), following consultation, after the 2015 Paris Agreement.
77.UKEF’s support for fossil fuel energy projects is unacceptably high, particularly in low- and middle-income countries. UKEF gave £2.6 billion to support the energy sector between 2013/14 and 2017/18. Of this, 90% (£2.4 billion) went to fossil fuel projects in low- and middle-income countries. While there has been an increase in the proportion of support given to renewables projects in high-income countries, this is not reflected in support to low- and middle-income countries. In 2017/18, renewables made up 96% of UKEF’s energy support to high income countries, compared to just 0.6% of energy support to low- and middle-income countries. Low- and middle-income countries are due to see the greatest increase in energy demand over the coming years. Supporting fossil fuel energy infrastructure in these areas risks stranded assets or “locking in” reliance on fossil fuel energy production for decades to come.
78.A small number of UKEF’s projects help the transition from high-emission fossil fuels to lower-emission fossil fuels, such as oil and gas. However, the scale of UKEF’s contributions to fossil fuel projects, particularly in low- and middle-income countries, provides an adverse incentive to the energy industry, expanding an international fossil fuel market at a time when Parliament has announced a climate emergency and when innovation should be focused on low-carbon energy and energy transition.
79.In line with recommendations by the IPCC and the CCC, and in keeping with the UK’s commitments under the Paris Agreement, the UK Government should set out how UKEF will work towards net-zero emissions by 2050. Making this commitment would show climate leadership and a willingness to align the UK’s domestic and international approaches to job creation and climate change.
80.The UK should leverage its position among other OECD Export Credit Agencies to encourage them to follow UKEF’s example in aligning its work with net zero emissions by 2050, revisiting their energy support strategy in light of the IPCC’s report, and introducing a strategy to end support to new fossil fuel energy projects by 2021. UKEF should seek multilateral agreement amongst OECD ECAs to join UKEF in making finance flows consistent with a pathway consistent with the Paris Agreement and net zero emissions by 2050.
81.UKEF prioritise a “price gap” approach to measuring subsidies and argue that UKEF do not provide fossil fuel subsidies because they operate at no net cost to the taxpayer. However, critics have argued that this ignores the “inventory method” of support which captures production subsidies. The OECD’s 2018 Companion to the Inventory of Support Measures for Fossil Fuels provides a methodology for quantifying the support element of government credit assistance, to increase the transparency of the “substantial benefits” of government credit assistance to carbon-intensive infrastructure.
82.In addition to considering whether UKEF subsidises fossil fuels under the “price gap” method, UKEF should publish a measure of its inventory support for fossil fuels using the OECD method. UKEF should volunteer to peer-review its fossil fuel support mechanisms, which has been effective in identifying opportunities for increased efficiency in China, Germany, Mexico and the United States.
69 The figure shows issued and effective business. It does not include amounts counter-guaranteed or reinsured by another official export credit agency where UKEF was acting as lead ECA on a jointly supported transaction. It does not include businesses supported where the private reinsurance market was subsequently used to offset risk for active portfolio management purposes. It also includes the value of support in the form of direct loans and scheduled interest, which is accounted for on a different basis.
72 Ibid.
78 Ibidem.
79 Ibidem.
85 Ban Ki-moon, “UK must stop investing in fossil fuels in developing countries”, The Guardian, (2019), [date accessed: 13/05/2019]
87 Powering Past Coal Alliance, Declaration, (November 2017), [date accessed 14/05/2019]
88 Ibidem.
90 Confidential written evidence
93 Ibid.
99 Baroness Brown of Cambridge, Oral evidence to the Business, Energy and Industrial Strategy Committee, Clean Growth Strategy and International Climate Change Targets, Q219
105 Confidential written evidence
107 E3G (EXF0034); Ban Ki-moon, “UK must stop investing in fossil fuels in developing countries”, The Guardian, (2019), [date accessed: 13/05/2019]
109 Written evidence by Tearfund (EXF0015), citing Theresa May, “It’s Britain’s duty to help nations hit by climate change”, The Guardian, (2017), [date accessed: 13/05/209]
111 Global Witness (EXF0033); E3G (EXF0034); Both ENDS (EXF0005); Overseas Development Institute (EXF0004); WWF (EXF0007)
112 Smith School of Enterprise and the Environment, Stranded Assets Programme: Discussion paper, (2014), p.2
113 Pfeiffer, A., Hepburn, C., Vogt-Schilb, A., and Caldecott, B., “Committed Emissions from Existing and Planned Power Plants and Asset Stranding Required to Meet the Paris Agreement,” Environmental Research Letters, Vol. 13 No. 5, (IOP Publishing Ltd, 4 May 2018)
114 Ibid.
119 G7, G7 Ise-Shima Leader’s Declaration, (May 2016)
120 G20, G20 Leader’s Statement: The Pittsburgh Summit, (September 2009); Overseas Development Institute (EXF0004)
121 World Trade Organisation, Agreement on Subsidies and Countervailing Measures, (1994)
125 Ibid.
129 OECD, OECD Companion to the Inventory of Support Measures for Fossil Fuels 2018, (2018), p.3
130 Ibidem.
133 OECD, OECD Companion to the Inventory of Support Measures for Fossil Fuels 2018, p.3
134 Ibidem.
135 Ibid., p.9
136 Ibidem.
137 Ibidem.
138 Theresa May, “It’s Britain’s duty to help nations hit by climate change,” The Guardian, 12 December 2017 [accessed 20 January 2019]
139 HM Government, A Green Future: Our 25 Year Plan to Improve the Environment, 2018, p.9
140 Powering Past Coal Alliance, Climate Change Minister Claire Perry launches Powering Past Coal Alliance at COP23, 16 November 2017 [accessed 30 January 2019]
141 HM Government, The Clean Growth Strategy: Leading the way to a low carbon future, October 2017, p.29
Published: 10 June 2019