Select Committee on Environmental Audit Appendices to the Minutes of Evidence


APPENDIX 8

Memorandum from WWF-UK

SUMMARY

  WWF-UK welcomes the opportunity to submit evidence to the Environmental Audit Committee enquiry into the Climate Change Levy (CCL) and commends the committee for undertaking an inquiry at such a crucial stage in the process of introducing the levy.

  WWF welcomes the Government's decision to introduce a climate change levy on the business use of energy as a means of reducing the use of fossil fuel sources of energy and meeting the UK's commitments under the Kyoto Protocol. The main points of our submission are:

    —  In the short to medium term the best economic instrument for the commercial and industrial sector is a carbon tax, not a permit system.

    —  WWF believes that the introduction of the levy will be beneficial to the majority of UK business and will not damage its competitiveness. Research commissioned by WWF indicates that:

        Industries employing 93 per cent of the UK workforce and creating 90 per cent of GDP will either gain directly from the package or will only face a marginal increase in costs of less than 0.1 per cent of the value of the industry's sales.

        Overall the economic size of the sectors that benefit from the package are more than double the size of the industries that lose if size is expressed either as number of employees or contribution to GDP.

    —  WWF believes that some form of levy is also needed in the domestic sector, as a tool for both reducing energy use and relieving fuel poverty.

    —  WWF does not support the proposal that lower levy rates be applied to those industries which voluntarily put in place energy efficiency schemes:

        WWF has reservations about the process of negotiating sectoral agreements. Whilst recognising that negotiating with trade associations and their ability to negotiate on behalf of their members.

        Information from the DETR indicates that there is currently much confusion in the negotiation process with little evidence that they are going to produce an effective solution.

    —  WWF accepts that in exceptional circumstances a problem of competitiveness may remain. Where this is the case, competitiveness can be protected by ring-fencing the levy revenues paid by the particular sector and rebating the sum paid back to them on the basis of individual firms' economic output.

    —  WWF believes that the sums allocated to help the SME sector are insufficient. WWF also believes that more targeted help is required to make SMEs aware of the levy, its implications and some of the tools available to offset the levy. In addition WWF believes that to ensure SMEs are given an adequate voice in the discussions about the climate change levy, an inter-departmental SME task force should be created within Government.

    —  WWF welcomes the intention to recycle part of the revenues from the levy to give additional support to renewables but does not believe that electricity from renewable sources should be included in the levy.

1.  INTRODUCTION

  1.1  WWF-UK (the World Wide Fund for Nature) welcomes the opportunity to submit evidence to the Environmental Audit Committee inquiry into the Climate Change Levy and commends the Committee for undertaking an inquiry into this pertinent issue.

  1.2  WWF is one of Britain's leading environmental organisations, working on a wide range of environmental issues in the UK and around the world. WWF's philosophy is to conserve nature—wild species and wild places—by promoting the sustainable use of natural resources to meet the needs of current and future generations.

  1.3  WWF considers climate change one of the greatest threats to biodiversity. Taking effective action now to reduce greenhouse gas emissions is our best insurance policy against dangerous climate change in the future. To that end, fundamental changes are needed, in the energy sector in particular, to change unsustainable patterns of production and use.

  1.4  WWF welcomes the Government's decision to introduce a climate change levy on the business use of energy as a means of reducing the use of fossil fuel sources of energy and meeting the UK's commitments under the Kyoto Protocol.

  1.5  However, whilst welcoming the levy, WWF has some reservations as to its design, particularly its focus on energy, rather than carbon, the failure to exempt renewables, the lack of support for small and medium sized enterprises (SMEs) and the methods of recycling the levy revenues.

  1.6  WWF's submission to this inquiry concentrates on three areas. It begins by presenting the case for a levy as opposed to a system of emissions trading. Secondly, it looks at the effect that the levy will have on UK business and draws comparisons with the situation in other EU and G7 countries. Thirdly, it examines specific issues surrounding the design of the levy—whether it should be a carbon based or an energy based tax, who should pay the levy, the provisions for the energy intensive sectors and SMEs and the treatment of renewables and community heating.

  1.7  Above all, WWF urges the Government to take a strong line on this issue, and not bow to the pressure of a small, but vocal, sector of industry and to ensure that the levy is introduced as early as possible.

2.  A CLIMATE CHANGE LEVY OR A TRADEABLE PERMITS SYSTEM

  2.1  WWF believes that the practical achievement of the Government's 20 per cent carbon dioxide (CO2) reduction target will require the use of all possible instruments: voluntary initiatives, economic instruments and direct regulation.

  2.2  WWF believes that in the short to medium term the best economic instrument for the commercial and industrial sector is a carbon tax, not a permit system. This view is based on three factors.

  2.3  (a)  Taxes promote greater innovation

  Controlling CO2 emmissions is a dynamic problem because the timing of action will have both environmental and economic impacts. Expert consensus, for example, at the International Energy Agency Modelling Forum, is that given the long lead times needed to replace invested capital and develop new technologies early strong incentives for abatement are required[12]. Transforming the fossil-based economy is like steering an oil tanker—even a slow change of course requires an immediate sharp change in the steering.

  2.4  WWF believes that taxes will give greater incentives for innovation, diffusion and investment in new technology than emission permits. Under a trading system the development of new technology in response to an emissions cap results in lower permit prices. However, under a tax system it results in greater technological diffusion and abatement because the tax rate does not decline as technology is introduced.

  2.5  The disincentives from lower permit prices will be exacerbated if international trading is allowed. If UK companies can buy cheap permits from Russia they may save abatement costs now, but will have lower incentives to change their operations or develop new technology. Therefore, when the "hot air" runs out and higher targets are in place, UK companies will neither supply the new, growing markets for abatement technology nor be competitive in existing product markets. This would repeat the experience of the global market in sulphur dioxide (SO2) reduction equipment, where UK companies lost out to Japanese and German manufacturers because we introduced emission controls later and more slowly.

  2.6  Empirical studies suggest that many of the energy efficiency gains achieved after the 1970's oil crisis came about due to the transmission of increased energy prices down the materials supply chain[13]. Therefore as materials become more expensive due to their energy content, designers use less of them in their products. This vital price signal depends on the marginal cost of emission reductions being reflected in the price of manufactured goods, which occurs with an energy tax.

  2.7  (b)  Taxes will have wider coverage and therefore produce lower cost reductions

  Research shows that the lowest cost CO2 reductions lie in small and medium sized businesses. However, it is unlikely that emission permits can be efficiently or fairly applied to SMEs in the short to medium term. Though permit schemes do exist at this level in small sectors—for example, milk quotas—they cover the bulk of firms' business, not the 3-6 per cent typical for energy costs in most companies.

  2.8  (c)  Taxes are flexible and administratively simple

  Energy or carbon taxes can be introduced immediately through existing systems, and tax rates can be easily altered as knowledge changes about their impact and effectiveness. In contrast, permit systems require a predictable allocation of property rights which will be hard to reverse if mistakes are made. The problems of base lining, admission of new entrants and room for growth will be endemic—especially in energy intensive industries—unless permits are auctioned annually. National permit systems must also be designed to be consistent with the international system yet to be defined in the Kyoto Protocol.

  2.9  Kyoto permits will be exchangeable (fungible) between all six controlled gases, but this is unlikely to be the case at national level due to the reluctance of companies to deal with gases that are hard to measure, such as methane and nitrous oxides. Any national system is likely to require a derived permit based around CO2 and perhaps the three industrial gases, which are easiest to monitor. Therefore national issues of buyer/seller liability, governmental risk, non-compliance penalties, permit convertibility, competition in the permit market, impacts on broader competition issues and dispute resolution will have to be resolved before a permit system can function.

3.  EFFECT ON BUSINESS

  3.1  WWF believes that the introduction of the levy will be beneficial to the majority of UK business and will not damage its competitiveness. The corresponding reduction in National Insurance Contributions (NICs) will compensate for the levy. Furthermore, there is evidence to suggest that energy prices are not a major factor in investment decisions, so that higher energy prices should not hinder economic success.

  3.2  A study carried out for WWF[14] indicates that industries employing 93 per cent of the UK workforce and creating 90 per cent of GDP will either gain directly from the package or will only face a marginal increase in costs of less than 0.1 per cent of the value of the industry's sales. Other findings of the study are:

    —  No sector will lose more than 2 per cent of the total value of their purchases.

    —  Overall the economic size of the sectors that benefit from the package are more than double the size of the industries that lose if size is expressed either as number of employees or contribution to GDP.

    —  No industry is likely to lose out from the combined effect of the CCL and the cut in NIC by more than 4 per cent of the value of its sales even if the CCL is applied at its full rate.

    —  The two greatest beneficiaries of the policy are education (£77 million) and the health service industry (£66 million).

    —  The extra money available to the education and health sectors is sufficient to fund an extra 7,000 employees in the health industry and about 3,500 more teachers.

    —  The industry that loses out the most from the package is food production (87 million). However this loss is a small fraction, about 0.15 per cent of the industry's total turnover.

  3.3  There is also empirical evidence to indicate that energy prices have little bearing on overall trade and investment decisions. Research by WWF[15] found that energy intensive industries have a range of motivations, not just energy prices, which influence their location decisions. These include market access, product quality, existing trade links, and trading restrictions such as import quotas and tariffs. Other motivations include economic and political stability, secure legal rights, efficient financial markets, and educated workforce and reliable infrastructure services. These findings indicate that any increase in energy prices will have little bearing on the decision by energy intensive industries to relocate.

Energy Prices

  3.4  The table below shows that in 1997 the price of industrial electricity in the UK was more expensive than in a number of other countries including the USA and France but cheaper than other major economies such as Germany and Japan. An energy tax of 0.6 p/kWh, about 15 per cent of the average price of industrial electricity, would have made the price of UK electricity marginally more expensive than Germany but still much less than that in Japan.

  3.5  In 1997 gas prices in UK were amongst the lowest in the world. A tax of 0.2 p/kWh, about 30 per cent of the average price of industrial gas, would have moved the UK from the second lowest gas prices to the fifth lowest (out of 15).

1997 energy prices and indicative tax rates in EU and G7 countries


Country
United Kingdom 
Germany 
Netherlands 
Japan 
United States 
Fuel
Gas
Electricity
Gas
Electricity
Gas
Electricity
Gas
Electricity
Gas
Electricity

Pre Tax Price (p/kWh)
0.52
3.95
1.00
4.26
0.65
5.947
2.51
10.06
0.71
2.67
Tax (p/kWh)
0.21
0.60
0.11
0.69
0.05
0.003
n/a
n/a
n/a
n/a
Post-Tax Price (p/kWh)
0.77
4.52
1.11
4.95
0.70
5.950
2.51
10.06
0.71
2.67


  Adapted from DTI 1998[16] and OXERA 1999[17]

  3.6  The table also shows that the UK is not alone in introducing a tax on energy. Other EU countries have already implemented energy taxes, including our main competitor Germany.

  3.7  UK industry has benefited from the liberalisation of energy markets. This has driven down energy prices for all fuels over the past decade. In the past five years energy prices have been at the same level as that implied by the CCL (with the exception of coal) even in nominal terms. Average electricity prices have dropped from 4.3 to 3.7 p/kWh since 1993, gas prices from 0.78 to 0.56 p/kWh since 1994 and fuel oil from 0.8 to 0.6 since 1996. Prices of coal have dropped from 0.54 to 0.47 p/kWh between 1993 and 1997, less than the CCL but a significant drop nonetheless. The fuel prices that would result from the CCL have all arisen in the recent past without any significant disruption to the economy. The proposed level of the CCL will not push energy prices up above levels that have been experienced within the recent past.

Exchange Rate Fluctuations

  3.8  One of the biggest business risks faced by industry and especially the manufacturing sector are movements in the exchange rate. The UK currency has appreciated against the European currencies by between 20 per cent and 30 per cent since 1997. The total value of UK exports of goods to Europe was £95,908 million in 1997. The deterioration in the terms of exchange as a result of the appreciation has increased the cost of exporting to Europe by between £22 billion and £29 billion, yet the UK's economy remains buoyant. This figure dwarfs the total £1.75 billion yield of the CCL.

  3.9  In addition, UK business has benefited from a number of other tax cuts over the past year. For example, corporation tax was reduced from 31p to 30p in the 1998 budget, the lowest rate in the history of British corporation tax, as well as the lowest rate of any major country in Europe, and the lowest rate of any major industrialised country anywhere including Japan and the United States. These additional tax cuts will compensate for the introduction of the climate change levy.

  3.10  However, WWF recognises that it is still possible that some industries will face a higher tax burden, as a result of the climate change levy, which could affect their economic success, and for which special treatment may be required (see para 4.10).

Carbon v Energy

  4.1  WWF believes that a carbon tax provides both the most efficient incentives and the simplest tax system design. A tax that differentiates between fuels will give automatic incentives for increased use of renewables and combined heat and power systems, as well as increasing the use of low carbon fossil fuels.

  4.2  If the Government wishes to preserve security of supply through a diverse fuel mix this is best done through direct regulation or subsidy to non-dominant fuels, not by distorting environmental taxes. Using a carbon tax should not tend to lead to increased use of nuclear power because new construction is constrained by non-greenhouse gas pollution issues. Nor should it lead to increased imports as the inter-connector to Europe already operates at full capacity.

Which sectors should be covered by the Climate Change Levy

  4.3  Whilst welcoming the introduction of a levy on the business use of energy, WWF believes that some form of levy is also needed in the domestic sector, as a tool for both reducing energy use and relieving fuel poverty. With careful recycling of revenues into energy efficiency and compensatory schemes for low income households, it is possible to target fuel poverty more effectively than through across-the-board low energy prices.

Energy Intensive Industries

  4.4  WWF does not support the proposal that lower levy rates be applied to those industries which voluntarily put in place energy efficiency schemes.

  4.5  As the Marshall Report made clear, dropping the marginal rate of the tax is enefficient and will introduce undesirable market distortions. In addition, and as shown above, the introduction of a tax on the business use of energy should not have a major impact on competitiveness thus making a reduction in the levy unnecessary.

  4.6  WWF believes that the recent fall in energy prices has sent the wrong signal to industry and the levy will encourage them to take steps to improve their energy efficiency. There is plenty of evidence that this action can be taken cost effectively. For example, a study by ETSU[18] has found that in the energy intensive sectors of industry there is the potential for energy savings of up to 10 per cent by 2020 through implementing all cost-effective measures available.

  4.7  WWF has reservations about the process of negotiating sectoral agreements. Whilst recognising that negotiating with trade associations simplifies the process, WWF is concerned as to the legal status of the trade associations and their ability to negotiate on behalf of their members. In addition, it is unclear what happens if an industry within a sector fails to meet its efficiency target, ie, whether this would mean the whole sector losing its levy reduction. WWF is also concerned that the big players within the sector could unfairly force the smaller players to do more.

  4.8  Information from the DETR indicates that there is currently much confusion in the negotiation process with little evidence that an effective solution will be produced. This confusion seems to stem from exactly who the final agreements are going to be between—the negotiating body (Trade Associations) or the individual firms—exactly what they are going to sign up to and how the agreements are going to be verified.

  4.9  WWF urgest the Government to conclude these negotiations as soon as possible and publish the results so it can be clearly seen who has signed up to do what. WWF would also like to see a public review process of the "allocation of effort" built into the levy legislation to ensure that all parties are seen to be taking an equal share of the burden.

  4.10  WWF believes that the levy rate should not be reduced for energy intensive industries as it is unnecessary, inefficient and the allocation process is fraught with difficulty. However, we accept that in exceptional circumstances a problem of competitiveness may remain. Where this is the case, competitiveness can be protected by ring-fencing the levy revenues paid by the particular sector and rebating the sum paid back to them on the basis of individual firms' economic output. Each firm would then face the same marginal incentive to save energy, but the sector as a whole would not pay any more tax. In addition, it is WWF's view that rebating the levy in this way will be administratively simpler than lowering the levy rate.

Small and Medium sized Enterprises (SMEs)

  4.11  According to Government figures[19], there are 3.5 million small businesses in the UK (those with less than 50 employees). This sector accounts for 99.2 per cent of all businesses in the UK, more than 40 per cent of the private sector workforce and around 40 per cent of UK turnover.

  4.12  Unless there is adequate support for this sector, for example in terms of energy efficiency advice, this sector of UK business could be disadvantaged by the introduction of the climate change levy. WWF believes that the SME sector is not fully aware of the climate change levy or its implications and that there is a need for a specific programme targeting the SME sector.

  4.13  WWF welcomes the announcement by the Chancellor that £50 million of the levy receipts will be allocated to give support to smaller businesses. In view of the size of the sector, and its importance to the overall economy of the UK, WWF believes that the sums allocated to help this sector are insufficient. WWF also believes that more targeted help is required to make SMEs aware of the levy, its implications and some of the tools available to offset the levy.

  4.14  Specifically, WWF would like to see meaures taken to ensure that SMEs are given adequate information about the levy. This should include:

  4.15  (i)  Explaining that a levy is being introduced, how it is to be implemented and the implications for business. It should be made clear what the levy is for ie to reduce CO2 emissions as part of the UK's overall climate change programme. The link needs to be made between energy use and CO2 emissions to make businesses aware of the contribution they can make to the UK's overall climate change targets, whilst saving money at the same time.

  4.16  (ii)  Increased support and promotion of some of the tools available to SMEs to enable them to reduce their tax burden through reducing their energy use. These tools include:

  4.17  (a)  Generic packages such as "The Better Business Pack"[20]. This is a tool developed by WWF and the NatWest Group in conjunction with the SME sector. It contains information and advice on how SMEs can increase their profits by reducing the environmental impact of their operations. Real case studies are given outlining results achieved by businesses who took relatively simple energy efficiency. For example:

    —  A business fitting low energy light bulbs saved 13,500 kWh or £550 per year.

    —  A firm replaced old equipment with up to date efficient models and saved 54,000 kWh or £2,000 per year.

  4.18  (b)  More specific tools such as the DETR/DTI funded Environmental Technology Best Practice Programme and specifically its "Energy and Environment Helpline." This provides businesses with sector specific energy efficiency information tailored to their particular business. They can supply various publicatons outlining energy efficiency measures and put businesses in touch with relevant consultants and local energy efficiency offices and can also provide free energy audits of premises.

  4.19  WWF sees no benefit in setting up another "energy efficiency" agency and believes that the money raised from the levy should be used to strengthen existing tools and agencies such as the Energy Saving Trust.

  4.20  WWF believes that to ensure SMEs are given an adequate voice in the discussions about the climate change levy, an inter-departmental SME task force should be created within Government. This should include representatives from the DTI, DETR, Treasury and Customs and Excise, with close contact with the Small Business Association. The focus should be on utilising exisitng incentives to offset the levy burden, tax breaks for efficiency investments and using information schemes outside energy use to communicate the levy message. The taskforce should also consider ways to ensure existing schemes for encouraging SME investment result in energy efficiency investment, including the £470 million of measures introduced in the 1999 budget.

Renewables

  4.21  WWF welcomes the intention to recycle part of the revenues from the levy to give additional support to renewables but does not believe that electricity from renewable sources should be included in the levy.

  4.22  If the levy is to contribute to the Government's greenhouse gas reduction commitments it makes no sense to include renewables in the proposals. They are already disadvantaged in the current system where the external costs of electricity generation are not fully accounted for. The levy would go some way to removing this distoration in the electricity market, but only if renewable technologies are exempted.

  4.23  As an example, the following table shows the price effect that exemption of the levy could have on wind energy, compared to fossil fuel generation. It shows that large wind farms are within the price range of gas and oil fired generation and that the price of small wind developments becomes more competitive.

EFFECT OF THE CLIMATE CHANGE LEVY ON THE PRICE OF WIND AND FOSSIL FUELLED GENERATION


Technology
Pre-levy price (p/kWh)
Levy (p/kWh)
Post-levy price (p/kWh)

Large Scale Wind[21]
2.4-3.10
0
2.4-3.1
Small Scale Wind
3.4-4.60
0
3.4-4.6
CCGT[22]
1.8-2.20
0.6
2.4-2.8
New coal
2.6-3.25
0.6
3.2-3.9
Existing coal
1.4-1.95
0.6
2.0-2.5

  4.24  The figures in the table show that whilst exempting renewables from the levy will help in making them more competitive, the effect is marginal and additional mechanisms supporting renewable technologies will be needed if the market is to expand. Additionally, the figures indicate the effect that any future increase in the levy will have. It is clear that increases in the price of non-renewable energy, through an increase in the climate change levy for example, will greatly improve the competitiveness of renewables if they are exempted, and possibly make them the least cost means of providing base load generation.

  4.25  Many businesses are concerned about their corporate environmental performance but a higher price for renewable electricity is a disincentive for companies to switch to a green supplier. Exempting renewable energy from the levy will provide an additional incentive for businesses to sign up to a green supply.

  4.26  WWF believes the introduction of the so-called "green electricity" schemes provides a mechanism for identifying and exempting electricity supplied from renewable sources. In particular, WWF believes that the Future Energy scheme launched by the Energy Saving Trust in July 1999 will provide a mechanism for identifying and exempting renewable electricity supplies.

  4.27  Allowing the electricity supplied by an accredited green scheme to be exempt from the levy will have two benefits:

  4.28  (i)  It will provide a stimulus for businesses to sign up to these schemes, thus increasing the demand for renewable generation with a corresponding reduction in the need for fossil fuel generation.

  4.29  (ii)  It will stimulate supply companies to sign up to Future Energy, helping to ensure that the green energy market develops in a way that is simple and easy to understand.

Community Heating Schemes

  4.30  WWF believes that the benefits community heating schemes provide in terms of efficiency should be reflected in exemption from the levy. Not only can such schemes provide efficiency benefits, they can also result in financial benefits to the users of the heat (as the heat tends to be cheaper than other forms of supply). Allowing community heating schemes to be exempt from the levy would also provide an incentive for them to be developed.

5.  CONCLUSIONS

  5.1  WWF welcomes the Government's intention to introduce a climate change levy on the business use of energy as a means of reducing the use of fossil fuel sources of energy and meeting the UK's commitments under the Kyoto protocol.

  5.2  WWF has some concerns as to the design of the levy but believes that overall UK business will gain from the introduction of the levy and the corresponding cut in National Insurance Contributions. Research carried out for WWF indicates that industries employing 93 per cent of the UK workforce and creating 90 per cent of GDP will either gain directly from the package or will only face a marginal increase in costs, and that overall the economic size of the sectors that benefit from the package are more than double the size of the industries that lose if size is expressed either as number of employees or contribution to GDP.

  5.3  WWF accepts however that a small, but important, minority of companies will lose as a result of the levy and they should be given special treatment to enable them to offset the additional levy burden. But WWF does not believe that they should be given reductions in the rate of the levy in return for negotiating energy efficiency improvements as this is inefficient and the negotiations are fraught with difficulty.

  5.4  WWF belives that competitiveness can be protected by ring-fencing the levy revenues paid by a particular sector and rebating the sum paid back to them on the basis of individuals firms' economic output. Each firm would then face the same marginal incentive to save energy, but the sector as a whole would not pay any more tax. In addition, it is WWF's view that rebating the levy in this way would be administratively simpler than lowering the levy rate.

  5.5  The SME sector needs to be given adequate support to ensure it is both aware of the levy and that adequate tools are available to enable them to respond to the introduction of the levy. In particular WWF believes that an inter-departmental SME task force should be created within Government.

  5.6  Renewables must be exempted from the levy. If the aim of the levy is to contribute to the UK's greenhouse gas reduction targets it makes no sense to include renewables in the proposals. WWF believes that the Energy Saving Trust's Future Energy accreditation scheme will provide a mechanism for exempting renewables from the levy

  5.7  Above all WWF urges the Government to take a strong line on this issue, not bow to the pressure of a small, but vocal, sector of industry and to ensure that the levy is introduced as proposed and on time.

September 1999


12   See selection of papers on incentives for innovation and instrument choice presented at the World Congress of Environmental and Resource Economists, 25-27 June 1998, Venice, Italy. Abstracts available at http:\\www.feem.it\\worldcongress. Back

13   Nick Mabey, Stephen Hall, Clare Smith and Sujata Gupta (1997), Argument in the Greenhouse: The International Economics of Global Warming, Routledge, London 1997. Back

14   ECOTEC (1999), Who Gains from the Climate Change Levy, WWF-UK. Back

15   WWF (1997) The Economics of Climate Change-Myths and Realities, WWF-UK. Back

16   DTI (1998) The Energy Report, Transforming Markets, The Stationery Office, London. Back

17   OXERA (1999) Workshop on The Energy Levy, May 1999.4. DESIGN OF THE LEVY Back

18   ETSU (1997) Industrial Sector Carbon Dioxide Emissions, Harwell. Back

19   DTI (1997) Small and Medium Enterprise (SME) Statistics for the UK, Statistical Press Release. Back

20   WWF/NatWest (1997), The Better Business Pack, WWF/NatWest Joint Initiative 1997. Back

21   Figures from the latest NFFO round (NFFO 5). Back

22   Figures taken from Government White Paper-Conclusions of the Review of Energy Sources for Power Generation, DTI 1998. Back


 
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