20.This chapter will use two case studies, capacity markets and renewable energy targets, to demonstrate emerging areas of tension and disagreement, as well as the advantages and opportunities associated with a common approach to EU energy governance. It will also highlight the implications for investors and the important needs of consumers.
21.As became clear during our stakeholder seminar, Member States have radically different visions of what an EU energy governance framework should look like and how it should be brought about. The UK Government, while largely supporting the Energy Union, has been clear that there should always be a degree of flexibility in EU energy policy to allow Member States to meet their differing national demands and retain the responsibility for deciding their energy mix. Andrea Leadsom MP, Minister of State at the Department of Energy and Climate Change told us:
“The Government are very supportive of the development of the energy union. Effectively implemented, it should deliver the competitive, interconnected and fully functioning single energy market that should provide good value for money for consumers in the UK and across the EU. I can assure the Committee that, as we move towards the UK presidency, we will be active in pushing it forward. But—there is always a ‘but’—the energy union must not be a straitjacket for Member States. We are very clear that it must respect Member States’ rights to determine their own energy mix and not constrain those policy choices that are best done at the national level, reflecting national circumstances and priorities.”
22.The reference to the UK presidency of the Council of the European Union, which is to take place between July and December 2017, is noteworthy, not least in the context of the forthcoming referendum on the UK’s continued membership of the EU.
23.The Minister went on to explain that the main focus of UK Government policy was energy security:
“The be-all and end-all purpose of DECC—the Department of Energy and Climate Change—is to keep the lights on, while decarbonising at the lowest cost to consumers. Ultimately, keeping the lights on is our complete focus, day in, day out. Keeping the lights on is non-negotiable. Energy security is absolutely our top priority.”
24.Of course energy security is a focus for all Member States, particularly those whose geography makes them naturally more dependent on external energy sources for their energy supply, but how energy security is perceived varies enormously. The domestic energy policies of Germany and Poland illustrate this point. The growth of the renewables sector in Germany is sizeable, while in Poland simply transposing the 2009 Renewable Energy Directive, which contains the 2020 commitments, into national law proved to be problematic. Germany is not as dependant on Russian gas as Poland, and Poland has traditionally been more dependent on its coal reserves than Germany. These differing perspectives were clearly articulated at the stakeholder seminar. On the wider subject of energy and climate policy, one set of respondents commented:
“Newer Member States like Bulgaria and Romania have limited support and capability to consider greenhouse gas emissions as part and parcel of energy governance at the national level. In many respects, greenhouse gas reduction policy is considered an external issue introduced by EU Directives and Policy.”
Differing levels of commitment and engagement on the part of different Member States will always be rooted in differing national energy mixes and geopolitical situations. An energy governance framework that neglects such realities will never command support or function adequately.
25.The differing domestic political situations and energy mixes of Member States result in significant differences in the relative priority afforded to safeguarding energy security, sustainability and competitiveness. Consequently, Member States’ visions of an EU energy governance framework are enormously varied. Shifts in the foci of Member States’ policies may be caused by both internal factors, such as domestic fuel prices, and external factors, such as a geopolitical crisis that threatens energy security.
26.Security of supply is, as we have outlined above, a key concern for the UK Government. Security of supply encompass both the dangers associated with over reliance on external energy supplies and the need to ensure that national energy infrastructure is able to guarantee a continuous and affordable supply of energy to the networks. The Government has sought to address the latter of these concerns, in part, through the development of the UK capacity market, part of the Electricity Market Reform (EMR) framework established by the Energy Act 2013. This seeks to secure future energy supply from energy providers through a series of capacity auctions, which will involve payments based not only on units of electricity sold, but also on the installed capacity which is on the grid. As the Minister explained:
“In the UK, as you know, we have introduced the capacity market, as have a number of EU Member States, deliberately to address the fact that, with the increase of intermittent renewables producing power for the network in our different countries, we want to be assured of power supplies. The capacity market will provide that security of energy supply that we want to see.”
Capacity markets or mechanisms are a set of measures taken to ensure that electricity supply can match demand in the medium and long term. Typically, capacity mechanisms offer additional rewards to capacity providers, on top of income obtained by selling electricity on the market, in return for maintaining existing capacity or investing in new capacity needed to guarantee security of electricity supplies. Potentially, capacity mechanisms can support not only power generation but also demand response measures, for example, incentives to households and businesses to reduce electricity consumption at peak times.
27.The UK capacity market is the first to allow the participation of other Member States in capacity auctions and, after examination, has achieved EU state aid approval. As DECC explained:
“One area where we are particularly keen on working with other Member States is how to open capacity markets to non-GB participation. We are the first EU Member State to allow interconnection to participate in our capacity market. Interconnectors will participate directly in the capacity auctions from 2015 and hold capacity obligations in a way similar to other capacity providers.”
28.Although external participation through increased interconnection may create a more integrated internal energy market, the implications should be considered. As E3G explained:
“As EU energy markets continue to integrate, they are becoming increasingly interdependent … It also means … that it becomes increasingly important for any market interventions to be done in a coordinated and predictable fashion, or they will be liable to deliver perverse results.”
E3G described the possible results as a:
“wasteful and uneconomic over-procurement of resources … consumers in countries with capacity mechanisms … effectively cross-subsidising the energy security of consumers in countries without such mechanisms … and the pushing up [of] the overall costs of decarbonisation across the EU.”
29.The debate highlights the degree to which European capacity markets should be connected and the extent to which they should be coordinated through regulation and market design. A more co-ordinated approach could make for a more cost effective delivery of energy for consumers, including potential EU-wide cost savings of €40–70 billion per year by 2030. However, questions have been raised about the extent to which co-ordination will be required and about the mechanisms needed to enable Member States to cope with simultaneous stress events (see Box 3). Clear political agreement between connected Member States and technical agreement on co-operation between Transmission System Operators are necessary if these obstacles are to be overcome.
The power system will become stressed when supply is insufficient to meet demand in particular localities. Interconnectors play an important role in the resilience of the power network because in times of system stress, with lower supply or higher demand than expected, electricity can be imported from neighbouring markets. However, the effectiveness of interconnectors could be limited by simultaneously high demand or low supply capabilities amongst interconnected regions. As the House of Lords Science and Technology Committee concluded, “There is a worrying lack of clarity about what options exist if a number of interconnected countries experience system stress simultaneously.” The European Network of Transmission System Operators for Electricity (ENTSO-E) has been mandated by the EU to prepare common adequacy assessment on both the regional and EU level as a means of developing better cross-border planning.
30.Energy UK and EDF Energy argued that a common framework for cross-border participation in capacity markets would further the internal energy market and create clearer investment signals:
“There would be benefit to the UK and other EU countries developing capacity markets in establishing a common framework for cross-border participation in capacity mechanisms. Such a framework should be consistent with the development of the European single market and should encourage an efficient level of investment in firm capacity to help each country to ensure security of supply at the lowest cost.”
Such a common framework could also result in common security and adequacy standards, help to ensure price stability and secure availability of supply.
31.E3G argued that differing capacity market designs would unintentionally distort the single energy market:
“Uncoordinated or poorly-designed capacity mechanisms are market distorting and risk undermining the business case for demand-side resources and for interconnection.”
ClientEarth echoed this point, stating that a governance system “can set a framework to optimise the use of national capacity mechanisms to ensure an equal playing field for energy efficiency and demand-side response, storage and interconnections, and to minimise competitive distortions.” The possibility of greater co-ordination raises questions of regulation and specifically the role of the European Agency for the Cooperation of Energy Regulators (ACER). The Commission is expected to bring forward proposals in the areas of market design and regulation in 2016.
32.National Grid argued that “whilst capacity markets may be needed in a number of Member States, they should be designed to mitigate any negative impact on the internal energy market.” Centrica argued for flexibility in market design, and Oil and Gas UK said that “it is important that the EU does not adopt a highly prescriptive approach which imposes a sub-optimal market design and inefficient capacity market arrangements.”
33.E3G suggested that “capacity adequacy assessments should be carried out on a regional basis … and require that the regional assessment forms the basis for any national capacity mechanism.” We found E3G’s threefold argument for increased regional co-ordination persuasive:
“First, capacity adequacy calculated nationally rather than at regional level will systematically overestimate the resources required for safe operation of the system, as it discounts available capacity in neighbouring countries. This leads to wasteful and uneconomic over-procurement of resources. Second, in an interconnected system, it does not make sense to try to maintain a higher security standard in one jurisdiction than in its neighbours. This produces perverse signals for the location of new generation, and effectively means that consumers in countries with capacity mechanisms are effectively cross-subsidising the energy security of consumers in countries without such mechanisms. Third, uncoordinated or poorly-designed capacity mechanisms are market distorting and risk undermining the business case for demand-side resources and for interconnection. This, in turn, risks pushing up the overall costs of decarbonisation across the EU.”
34.The Renewable Energy Association argued that security of supply should not be the only consideration when designing and operating European capacity markets:
“We believe any mechanism should address all elements of Europe’s Energy Trilemma—ensuring security of supply, value for money and low carbon supplies. We believe many such mechanisms should be improved, for example the UK’s by better supporting energy storage and demand side response capacity, and more closely enshrining value for money considerations into new contracts. It is also not acceptable that absolutely no account is made of the carbon intensity of contracted capacity in such mechanisms.”
36.We welcome proposals that seek to achieve a greater co-ordination and harmonisation of EU capacity markets. Such proposals should aim to mitigate the distortion of competition between capacity providers and the distortion of cross-border trade to ensure adequacy of supply.
37.Much of the evidence to this inquiry focused on the agreed EU targets for greenhouse gas emissions, renewable energy, energy efficiency and interconnection. In examining the differing opinions on these targets, we have distinguished between, on the one hand, the monitoring and reporting of progress against these targets, and on the other, enforcing them and legislating for them.
38.The reporting requirements for progress against decarbonisation and renewable energy objectives are well established by the European Commission, but there has often been a tendency for this reporting to focus on carbon reduction, while other objectives, such as security and competitiveness, have been overlooked. We highlighted this tendency in our 2013 report, No Country is an Energy Island: Securing Investment for the EU’s Future. The State of the Energy Union report and accompanying Member State factsheets took an encouragingly holistic approach, measuring progress against each of the five aims. Given the need to monitor a range of EU objectives, there is a clear need for meaningful reporting, which may act as an early warning if progress is not being achieved. The Commission has suggested that this may be achieved through the development of a range of reference and policy scenarios. However, we emphasise that this work should not be overly burdensome on Member States or duplicate existing reporting frameworks.
39.Many witnesses told us that the current reporting requirements should be simplified. ClientEarth told us:
“A simplified and streamlined planning and reporting regime that sits within a legislative framework, with binding and soft elements where necessary, is not inconsistent with Member States’ right to flexibility over their national energy mix ... The [October 2014 European Council] Conclusions … state that the governance system will simplify and streamline the separate planning and reporting strands (those dealing with renewable energy and energy efficiency etc.); with greater emphasis henceforth being placed on Member States’ National Energy and Climate Plans (National Plans). If this simplifies and reduces the administrative burden under current reporting regimes, it is to be welcomed.”
In this light we welcome undertakings in the Commission Work Programme 2016 to begin the Energy Union Reporting initiative under the Regulatory Fitness and Performance (REFIT) programme, which will conduct evaluations in the area of energy and climate policy in order to assess the consistency and administrative burden of reporting obligations.
40.The Commission’s proposed National Energy and Climate Plans are seen by some as the basis for a strengthened governance framework. EDF Energy supported such a move, suggesting that plans create policy stability for investors:
“All Member States should have credible long-term plans for meeting both EU and national energy and climate objectives. These plans should be regularly reviewed and updated as necessary to ensure that they remain on course, while taking full account of the importance of policy stability for investors.”
The Department of Energy and Climate Change insisted that Member States should retain ownership of their National Plans, and Vattenfall cautioned against the scope of the plans clashing with Member States’ freedom to determine their national energy mix.
41.E3G explained that the UK Government should not regard the lack of an EU-wide binding renewables target as a challenge, but rather as an opportunity:
“The UK will need to deploy considerable volumes of renewable energy if it is to meet its own domestic obligations under the Climate Change Act—particularly as nuclear power and CCS have proven slower to deploy than previously assumed. It is unlikely that the UK’s proportion of a 27% EU-wide RES target would be more than it would need to implement domestically in any case. The UK national interest has little to gain by stripping the ‘EU-binding’ renewables target of all content: instead the UK should focus on how to use the target and associated governance arrangements to support the UK’s own decarbonisation goals, and to create a level playing field in Europe.”
It was therefore disappointing to see that current UK energy policy announcements do not yet reflect the distinct aspects of the Energy Union. The speech given by Amber Rudd MP, the Secretary of State for Energy and Climate Change, on 18 November 2015 only made a passing reference to the Energy Union, and then rapidly resumed a domestic focus:
“That is why the Prime Minister has been calling for an ambitious Energy Union for Europe—to save hardworking families money and to guarantee energy supplies for future generations. So we welcome the report out from the EU today on the ‘State of the Energy Union’ which lays out the steps Europe needs to take to strengthen our partnership. And I can say to Europe that Britain stands ready to help make this vision a reality. This is an example of where we can achieve more working together than alone, and where Europe can adapt to help its citizens where it matters to them. But we do need to do more at home.”
42.Guidance from the Commission on the National Energy and Climate Plans was published alongside the State of the Energy Union report, and calls on Member States to structure their planning around the five dimensions of the Energy Union:
“The national plan should take a holistic approach and address the five dimensions of the Energy Union in an integrated way which recognises the interactions between the different dimensions … While Member States have the right to develop policies suitable to national circumstances, national plans should set out the direction of national energy and climate objectives and policies in a way that is coherent with delivering on the commonly agreed objectives of the Energy Union, in particular the 2030 targets (greenhouse gas emission reductions, renewable energy, energy efficiency and electricity interconnections) agreed by the European Council in October 2014.”
43.ClientEarth and E3G suggested that an independent body be established to monitor progress against the agreed targets:
“A collection of 28 national plans developed in isolation and with no feedback loops would make little difference. Instead, it is important that collective assessment is made of the national plans, and the outcomes of this assessment are used to ensure more robust decision-making at both national and European level … This function could most usefully be fulfilled by the creation of an independent Climate and Energy Observatory tasked with supporting member state climate and energy policy development rather than transferring further powers to the European Commission.”
44.As an alternative to an new, independent observatory, ClientEarth suggested bolstering the powers of the European Environment Agency (EEA):
“There is also a case to be made for an enhanced role for participation of independent experts to assist the Institutions, including the Commission, in driving policy forward. This could be achieved through providing an enhanced role for an existing body (e.g. the European Environment Agency).”
45.In contrast, the Minister told us:
“I would always question additional bodies. To the earlier point about regulation, that is another budget that has to be divvied up. Someone has to pay for it, it is a lot more staff, they come up with their own rules, then the Commission comes up with its rules, there is potentially a clash and someone has to resolve those issues. I always think that, ideally, we do better to work with what we have.”
46.We welcome the introduction of National Energy and Climate Plans, which will help to streamline and add clarity to reporting requirements. The Plans will help to present an overall picture of progress at a pan-EU level against the five dimensions of the Energy Union: energy security; the completion of the internal energy market; energy efficiency; emissions reduction; and research and innovation.
47.We also welcome the proposal for Member States to provide integrated projections to the Commission covering both reference and policy scenarios, which will give an early indication of progress against EU level targets.
48.The UK Government should be transparent, timely and comprehensive in reporting on its own progress against each of the dimensions of the Energy Union as well as against its own additional domestic targets, such as those required by the Climate Change Act 2008, Fuel Poverty Objectives and the creation of a more competitive retail energy market.
49.We agree that there should be an overall assessment mechanism for the 28 National Energy and Climate Plans in order to ensure consistency, but we are not persuaded by the arguments for a new institution or monitoring body. Such assessment should be open and transparent and should be undertaken by the Commission itself, or by an existing body such as the European Environment Agency.
50.The future legislative landscape is uncertain, and the extent to which new EU legislation will be necessary to create an EU-wide system of energy governance is hard to predict. Member State governments will need to be incentivised to take action and the Commission should be clear about what the enforcement mechanisms are if collective progress is insufficient. Binding targets accompanied by clear legislative proposals continue to divide opinion.
51.The implications of greenhouse gas reduction targets for the UK’s renewable energy mix in 2030 have been the subject of much discussion, and what they will mean in practice has been covered by the Committee on Climate Change. Of course, the different targets which have been agreed, such as the greenhouse gas emissions target, the renewables target and the energy efficiency target, have very different legal status, but there was a clear hesitancy on the part of the UK Government to follow through the implications of a binding EU-level renewables target. The Minister told us:
“The core theme running through my evidence is that member states should be given every bit of leeway to determine their own energy mix and their own way of meeting their legally binding targets. That should not be either second-guessed or presided over by some kind of supra-EU authority telling them what to do.”
The Department of Energy and Climate Change echoed this when it said that “the Government does not currently foresee a need for the governance system to be enshrined in legislation.”
52.The Royal Society for the Protection of Birds, on the other hand, insisted that the governance mechanism should be robust:
“In the absence of effectively binding national targets for energy saving and renewables, the governance mechanism will need to be very robust if it is to ensure delivery of the targets in a way that is fit for purpose, affordable and acceptable to the public.”
53.The wording of the European Council conclusions in October 2014 was a clear political compromise, with the renewables target binding on the EU but not on individual Member States, with the failure to articulate an enforcement mechanism and with the inherent vagueness of the term ‘at least’. Opinion is clearly divided over the consequences of failing to meet the 27% renewables target and the question of enforcement.
54.Some witnesses favoured Member State targets, while others were firmly opposed. Nevertheless, as long as a binding target lacks a method of enforcement, the integrity of the political agreement will be seriously compromised and the confidence of investors will be weakened. Without ‘teeth’ there will always be a danger of certain Member States ‘freeriding’, and there will be less incentive for other Member States to be ambitious.
55.It is clear that legislative proposals in the area of governance would be met with mixed reactions. While unnecessary legislative proposals are to be discouraged, the Commission should not be deterred from proposing measures seeking to guarantee commitments that have already been made, such as the 2030 renewables target.
56.The EU-wide binding renewables target of at least 27% by 2030 has been agreed with the intention of increasing the diversity of supply and reducing the EU’s dependency on imported and domestic fossil fuels. But without an effective, transparent, accountable, and legitimate governance mechanism, the significance of the target is considerably diminished, the incentive to Member States to be ambitious is weakened, and any prospect of achieving the overall objective is jeopardised.
57.Although there has been a great deal of discussion concerning governance, clear policy direction is lacking. Moreover, there are areas where, despite agreement being reached, there is insufficient political will to implement policy. Failure to commit to long term planning leads to underinvestment in the necessary infrastructure and technology required to complete the internal energy market, increase interconnection, decarbonise and secure supply. Both the Commission and the Council (and therefore the UK Government) have a role in sending much clearer signals to investors. Effecting greater policy certainty should be a key goal of future governance announcements.
58.As E3G told us:
“Erratic regulatory regimes and weak governance raise the risk profile for investments and as a result push up financing costs and energy costs for consumers. This is not a problem that can be resolved within national boundaries alone: the interconnected nature of the European energy system means that states are affected by the decisions of their neighbours. In this context, it is in the interest of all member states to have a stable and workable governance regime in place that enables predictability of outcomes. This requires a governance system underpinned by a firm legal basis.”
59.Energy developments in one region are increasingly affecting energy decisions taken in another. For example, in March 2011 the German government opted to suspend the operation of eight of its oldest nuclear power plants following the Fukushima accident in Japan. Another example is the proposed Nord Stream 2 gas pipeline from Russia to Germany, through the Baltic Sea.
The Nord Stream 2 pipeline would run from Russia to Germany, through the Baltic Sea. The project is jointly owned by Gazprom (50%) with 10% each owned by Eon (Germany), Wintershall (Germany), OMV (Austria), Shell (Netherlands) and ENGIE (France). The project has proved to be controversial because of the plan to circumvent Ukraine and central European Member States. In November 2015 Bulgaria, the Czech Republic, Estonia, Hungary, Greece, Latvia, Lithuania, Poland, Romania and Slovakia signed a joint letter calling on the Commission to block the pipeline, arguing that it was contrary to the EU’s energy diversification and security policies.
60.As we have already noted, many have argued that the uncertainty surrounding the application at national level of the EU-wide binding 27% target has had an effect on investor confidence. Ecologic Institute argued that the existence of binding national renewable energy targets had increased “investor stability and confidence despite changes in government at national level.” Firmer and longer term policy signals are needed.
61.Like all investors, those who invest in energy need clear medium and long term policy signals. The European Council should, with the Commission, present a much clearer timetable for the establishment of the energy governance framework.
63.The UK Government should be clear about its own renewable energy strategy and target for 2030 as part of its decarbonisation and energy security objectives. This will help create investor confidence and protect jobs at a time of uncertainty.
64.The European Council should not only reiterate the binding targets agreed in October 2014, but should also call on the Commission to propose monitoring and enforcement mechanisms that act as a guarantor for the agreement and ensure that Member States share the effort equitably. Maintaining the integrity of the agreement is essential for securing investor confidence.
65.Any governance discussions should take account of all consumers, including domestic users, SMEs and heavy energy users. As the Minister explained:
“Keeping the bills down is incredibly important for consumers. As we have seen only recently with the steel industry, which has cited energy costs as one of the reasons for its problems, it is a very real consideration. Bills for consumers and businesses must always be a vital part of our consideration.”
66.Affordability is one of the three pillars of the energy trilemma. For business and industrial users it can determine their competitiveness, and for individuals fuel can represent a significant proportion of household expenditure. Communicating the potential benefits of cross border energy co-operation and interconnection, in terms of price as well as energy security, is important. At the same time, new technologies such as smart meters and market mechanisms such as dynamic pricing can provide individuals with the tools they need to become more active consumers.
67.The Government’s focus on real consumer priorities should not be forgotten in more elevated discussions with policy makers outside the UK. Similarly, the Commission should ensure that consumer benefits are articulated in governance proposals. Tim Abraham told us:
“Consumers will be quite a big focus of the work that the Commission is now doing on energy markets and its market reform. Indeed, Ministers will be discussing the consumer angle of market design at the next Energy Council. I think that you will find that consumers, the effect on consumers, the potential for smart ways of helping consumers and so on will be an important plank in the energy union.”
68.Consumer interests should not be segregated in energy policy, and the interests of industrial, business and domestic consumers should be considered in energy governance framework discussions. The UK Government should consult stakeholders and consumers during the development of the UK’s National Energy and Climate Plan.
13 Written evidence from Greenpeace ()
14 Written evidence from IEEP ()
15 Written evidence from Dr. Simona Davidescu, Dr Ralitsa Hiteva, Dr. Tomas Maltby ()
17 Written evidence from DECC ()
18 Written evidence from E3G ()
19 Written evidence from E3G ()
20 Written evidence from E3G ()
21 and Written evidence from Greenpeace ()
22 Science and Technology Committee, (1st Report, Session 2014–15, HL Paper 121)
23 Written evidence from EDF Energy ()
24 Written evidence from E3G ()
25 Written evidence from ClientEarth ()
26 Written evidence from National Grid ()
27 Written evidence from Centrica ()
28 Written evidence from Oil and Gas UK ()
29 Written evidence from E3G ()
30 Written evidence from E3G ()
31 Written evidence from Renewable Energy Association ()
32 European Union Committee, , (14th Report, Session 2012–13, HL Paper 161)
33 Communication from the Commission: State of the Energy Union 2015,
34 Written evidence from Ecologic Institute ()
35 Written evidence from ClientEarth ()
36 Communication from the Commission: Commission Work Programme 2016, No time for business as usual,
37 Written evidence from EDF Energy ()
38 Written evidence from DECC ()
39 Written evidence from Vattenfall ()
40 Written evidence from E3G ()
41 Speech given by Amber Rudd MP, Secretary of State for Energy and Climate Change, A new direction for UK energy policy, 18 November 2015: [Accessed 20 November 2015]
42 Communication from the Commission: State of the Energy Union 2015,
43 Written evidence from ClientEarth () and E3G ()
44 Written evidence from E3G ()
45 Written evidence from ClientEarth ()
47 Committee on Climate Change, The Fifth carbon budget report : The next step towards a low-carbon economy (November 2015): [Accessed 3 December 2015]
49 Written evidence from DECC ()
50 Written evidence from the Royal Society for the Protection of Birds (RSPB) ()
51 Written evidence from IEEP ()
52 Written evidence from DECC ()
53 Written evidence from E3G ()
54 Written evidence from Ecologic Institute ()
55 Written evidence from IEEP ()
56 Written evidence from E3G ()
57 Nord Stream 2, ‘Gazprom and ENGIE modify Nord Stream 2 shareholdings, equalizing EU-Russian ownership’: [Accessed 3 December 2015]
58 Barbara Lewis, ‘Ten EU nations say Nord Stream gas extension not in EU interests’, Reuters (27 November 2015): [Accessed 3 December 2015]
59 Written evidence from Ecologic Institute ()