Department of Energy and Climate Change: Consultation on the Carbon Reduction Commitment
ACE have submitted a written response to the Consultation on the Draft Order to implement the Carbon Reduction Commitment.
ACE response to the consultation:
Carbon reduction targets
1.ACE welcomes the introduction of the CRC, a policy designed to deliver carbon emissions reductions from private and public sectors. As the only policy to focus on emissions from the large, non-energy intensive segment of the private sector, it is essential that the CRC is effectively designed to deliver on Government’s 80% by 2050 carbon emissions reduction target.
2.The current consultation document follows its 2007 predecessor in setting a target of 4.4 MtCO2 to be saved per year by 2020. What this consultation has failed to do however, is to raise this emission reduction figure in line with the increase in emission reduction target committed to by Government since the last round of consultation. The 4.4MtCO2 target was set in 2007 in the context of the Government’s 60% national CO2 reduction target. This target has subsequently been raised to 80% and therefore ACE calls for the CRC annual carbon delivery figures, to be achieved by 2020, to be raised to at least 5.86 MtCO2 in line with current Government carbon reduction target.
3.The Energy White Paper (2007) outlines the potential for carbon savings from the non energy intensive business sector and public sector of 6 MtC (5 MtC from the private sector and 1 MtC from the public sector): a potential of at least 22 MtCO2 savings annually by 2020. As the CRC and Climate Change Agreements are the only two policies to address carbon emissions in this sector, this potential 22 MtCO2 saving needs to be delivered by these two programmes alone. ACE calls on Government to consider carefully how this potential will be delivered. Given the 55 MtCO2 coverage of the CRC, ACE calls on Government to reflect on whether 5.86 MtCO2 is a reasonable proportion of the 22 MtCO2 potential to be delivered by the CRC and to raise the target if necessary.
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