SC(3) CR-I&PB14

Sustainability Committee

Inquiry into Carbon Reduction in Wales: Carbon Reduction by Industry and Public Bodies

Response from UPM-Kymmene (UK) Ltd

CO2 Questions

Response

Q1. Is the proposed 3 percent annual reduction target by 2011 'in areas of devolved competence' sufficient to enable Wales to make its full contribution to meeting UK-wide targets?  If not, what targets should be in place?

A1. Agreed

Q2. Should the emission reduction target be based on Welsh consumption or production, or both (i.e. should it take into consideration the carbon dioxide generated in Wales (production), or the carbon dioxide emissions that Wales' residents are responsible for, regardless of their source (consumption))?

A2. The basis for emissions targets in Wales should be in accordance with UK wide measurement methods to avoid double counting.

Q3. What particular challenges does Wales face in reducing carbon dioxide emissions from industry and public bodies, and how can these challenges be overcome?

A3. The challenges faced are economic.  Some industries have made significant reductions in CO2 emissions already and further measure would leave Wales disadvantaged.  Welsh industry has benefited from significant inward investment from UK and overseas and measures to reduce CO2 emissions over and above European targets would inhibit future investment.

Q4. Do the current Welsh Assembly Government economic development policies give sufficient emphasis to carbon reduction?

A4. Yes.

Q5. To what extent has the Welsh Assembly Government been successful in utilising the powers available to it in order to reduce carbon dioxide emissions from industry and public bodies?

A5. CO2 emissions have been successfully reduced due to European and UK measures.  The previous role of the Welsh Assembly Government is little understood.

Q6. Could alternative targeting of Welsh Assembly Government financial resources lead to greater emissions reduction from industry and public bodies than is currently being achieved?  If so, where could additional resources lead to greatest impact?  (Please provide detail to support your evidence).

A6. WAG financial support for energy efficiency and renewable fuel development is widely welcomed.  Investment support for energy from waste projects would lead to the greatest immediate impact.

Q7. What examples from other administrations (devolved, UK and overseas), where other means have been used to achieve reductions in carbon dioxide emissions from industry and public bodies, could be adopted in Wales under current powers?

A7. It is not clearly understood how Wales could add or subtract from current Renewable Obligation, CCL, UK ETD and EUETS schemes.  This should be explained further.

Q8. In the context of the Government of Wales Act 2006, which further means of reducing carbon dioxide emissions from industry and public bodies could only be achieved with the introduction of further legislative competence for the National Assembly for Wales.

A8. Further Welsh legislative competence is not needed for industrial sectors.  Retail, housing and transport sectors may require further legislative competence at a local level to ensure emission reduction.

Q9. If specific carbon dioxide emissions targets are to be set for Wales, should those targets be subdivided into shares by sector?  If so, what share of the total should reductions by industry and public bodies comprise?

A9. It is not clearly understood how a sector approach would operate with Welsh boundaries.  Significant industrial sectors are covered by umbrella agreements UK wide, for example the Paper Sector.

Q10. How will the Carbon Reduction Commitment affect your business? Should the proposed Commitment be amended in any way?

A10. With current understanding our business would not be affected by the Carbon Reduction Commitment as greater than 25% of energy is within a CCA.