The 25 billion pound investment opportunity - through the lens of a MAC curve

Monday, April 11, 2011

18:00 - 21:15

We want to challenge our hypothesis that there is £25bn worth of attractive investment opportunities in carbon abatement in the biggest 2,000 companies in the UK. We define “attractive” as an IRR of 16% or more, which is a better IRR than most company’s core business. Many people in the Sustainability Function want more evidence of the scale of commercially attractive investments.

Why it’s important
If this hypothesis is correct, we estimate this would be the biggest commercially-attractive investment class in corporate sustainability. Most importantly, it does not require subsidies nor the consumer / investor / employee to drive the agenda – it is a true win-win, with everyone making profit. Put it the other way round, it would be a commercial crime if it didn’t happen.

About MACC’s
Marginal Abatement Cost Curves are a highly visual and effective way of seeing the commercial returns on abating a company’s emissions. It allows a number of initiatives to easily be seen together, when they can add up to substantial investments. One of the most advanced MAC’s that we have come across was at the Royal Mail, which identified £38m worth of investment with an IRR of 16%. MACC’s work because they encourage quality data collection and use of the latest in technology innovation.

Our panel of experts
We have confirmed the following line-up of speakers;

    Marcel Brinkman, McKinsey – on the size of the investment opportunity
    Professor David Strong – applying MACC’s to individual buildings, key lessons from Royal Mail Group pilot
    Richard Tarboton, Head of Energy & Carbon, BT
    Joanna Lee, Chief Partnerships Officer, The Carbon Disclosure Project

The April Survey
We will use our monthly survey to try to capture the most comprehensive list of real carbon abatement examples in major companies. We will give any corporates who give us key information on investments in excess of £1m a major discount on attending our June conference on MACC’s. We hope to capture data from over 100 major UK corporates, which we will share with our community.


Who is it for?
In addition to targeting senior members of the Sustainability Function in FTSE350’s & equivalent (the core Green Monday’s audience), we are going to reach out to Finance Directors and other members of the Finance function. We want 180 people, including 40 from the Finance Function.

Speakers

Joanna Lee Carbon Disclosure Project

See bio

Professor David Strong

See bio

Richard Tarboton BT

See bio
Round Tables

Built Environment

What are the top 5 energy efficiency measures?

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BUILDING MANAGEMENT SYSTEMS
• Easy to implement, key in assessing progress and results – as per Richard Tarboton, BT and panel speaker

SMART METERING
• Prevents wastage
• Using the data successfully, to manage and predict patterns of demand and wastage
• Expense however can create a chicken and egg situation, likewise, per the BT panel member.
• Deployed at Capital Shopping Centres

LIGHTING
• Some business tenants are unwilling to compromise on anything they perceive as changing their approach to customers. If they feel they need 8000 kw incandescent bulbs to promote their goods then this is non-negotiable
• There are significant regulatory burdens that also need to be considered before implementing these.
• Implementing each measure and then managing the measures successfully is almost as key to as any individual measure.

VOTLATE OPTIMISATION
• Care needs to be taken around critical functions
• Measuring results is key and how to explain this to tenants
• Degree days, for example, is a consistent measure but important to include in the calculations and needs to be adjusted for changes in temperature
• Tenants: Will only accept the service charge going one way
• Green leases are not yet attractive in their own right
• Sensitivity around tenants renegotiating leases: the rent and lease review process is “terrifying” at the moment in the current economy
• Service charge changes are also difficult: it is not simply a case of adding an extra amount to a service charge where the benefits are not clear

COST ALLOCATION
• Allocating costs and savings correctly are an important component in any building efficiency programme.
• This point further enhances the need for using building management systems to not only effectively manage patterns of consumption and wastage within the premises but also ensure correct and transparent allocation. Align benefits with investment, savings with costs!

SUB DISCUSSION - DEC:
• Display Energy Certificates: what effect, if any , will this have on the attitude of commercial landlords? Taking the example of the Neighbour scheme in Australia, it may well encourage the event. Australian property companies are in the gold zone of the Dow Jones sustainability index so this may be an example where property companies react positively to such regulatory events.

OFF BALANCE-SHEET MEASURES?
• Does taking these measures off-balance sheet, by allowing a third party to make the investments, add any benefits to the process?
• Alleviates capital investment requirements, however, can pollute the lease with other interests reducing the liquidity and possible value of the freehold to other investors.
• Off-balance sheet is emerging as a popular model for delivering zero risk results
• Guaranteed energy performance contracting: a possible means of delivering these off the balance sheet of the investor.

BRITISH LAND ANECDOTE – BEWARE!
• Major US bank demand as a condition of tenancy: we will not be the tenant unless you can deliver a specific EPC level. In these circumstances, a third party off-balance sheet efficiency investor might be the answer to meet emergency requirements outside of investment case
• Better Buildings Partnership working group: exploring challenges of this model
• Owner Occupiers are better of course: TFL example where a longer tenancy and steady long term relationship can make implementation far simpler on retro-fit properties

SUB-DISCUSSION: “AUSTRALIAN NEIGHBOUR RATING”
• Guaranteed savings events using this programme. Extending the Carbon Disclosure Project more widely will have a similar impact and has been seen to be a worthwhile incentive.
• Verification is important, again, for all the parties after the event. Similar point to the measurement principle. Making sure everyone has “skin in the game” is key and lends itself more to 3rd party finance models

THE ACTUAL TOP 5 MEASURES FOR ENERGY EFFICIENCY!
Not all measures were correctly identified, here are the top 5:
• Office timer equipment
• Lighting (bulbs)
• Ventilation (waste heat recovery)
• Lighting (sensors)
• Voltage optimisation (voltage regulation)

Supply Chain

How can we implement marginal abatement curves to lower scope 3 emissions in the supply chain?

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Following the presentations on MAC Curves and their use in several sectors, the table had an interesting discussion covering the relevance of MAC curves to the issues of supply chain management. Discussion participants included a number of corporates or their consultants engaging with the supply chain, and an NGO encouraging the process.

A quick round table showed that no one had used MAC curves within their organisations to evaluate carbon abatement measures, though two had used them within the context of development of national policy on energy generation measures.

There was general agreement that MAC curves could be a useful mechanism to be promoted to the supply chain for their internal use, but their use as a means directly to assess and achieve carbon abatement measures across the supply chain was not useful – specifically because the retailer would not be making the investment. There was some discussion as to whether “generic” MAC Curves could be provided for specific sectors or types of supplier to encourage uptake of cost effective measures, but it was felt that supply chains were so varied, with impacts and opportunities varying widely, and with different IRRs, incentives and taxes globally and sectorally, that this would not be appropriate. Concern was also expressed that the “inter-relationships” between actions evaluated in MAC Curves may be very problematic at the supply chain level, as actions at different tiers could have counter-productive effects.

The role of the Carbon Disclosure Project and their investors encouraging Corporates to make investments in the bottom left of the MAC curve was felt to be analogous to the role of Retailers in encouraging their supply chain to do the same. There was discussion as to whether Retailers should be investing in their supply chain to reduce carbon, and how cost benefits should be shared. It was felt that many retailers would only make investments with very short term returns especially in areas such as fashion. It was agreed, however, that retailers could engage their supply chain to understand that they would not accept prices rising in line with energy costs, unless their suppliers were able to demonstrate that they had made efforts to undertake cost effective energy saving measures – through use of MAC Curves for example.

Discussion was completed with a quick round table of measures that participants were already taking within their supply chains, and identification of good practice – Compass (catering), Walmart and Dell were highlighted in the discussion.

How should companies respond to changes in the CRC Energy Efficiency scheme?

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The plan for the evening’s discussion was to examine company responses to proposed changes to the CRC Energy Efficiency Scheme, as announced by DECC in October 2010. The CRC was originally intended to incentivise investments that reduce energy consumption by large corporates in the UK through the gradual introduction of a cap and trade scheme, a revenue recycling scheme with bonuses and penalties, and a published league table. Seen from the perspective of the marginal abatement cost curve – the theme for the evening’s plenary discussion – these measures would combine to make more cost effective a broader range of greenhouse gas emission reduction investments. The October 2010 announcement set a fixed price for permits and ended revenue recycling based on league table performance. The overall effect was to increase significantly the financial cost of the CRC and convert it from a cap and trade scheme into a carbon tax.

Delegates expressed a range of views on how companies would respond to these changes, and whether the changes would lead to greater energy efficiency investment. Delegates tended to agree that increased simplicity and a predictable carbon price make long-term decision making easier, which could encourage investment. On the other hand, a number of delegates noted that the total cost of the CRC after the changes is only a fraction of their total energy spend – itself rarely the largest cost faced by CRC participant companies. As a result, the financial incentive posed by the CRC “tax” is likely to be modest, especially for companies that have already committed publicly to ambitious reduction targets. The end of revenue recycling may have eliminated the possibility of earning a small profit on CRC permit costs for the best performing participants. However, one delegate noted that the modest financial impact meant the revenue recycling change “hasn’t phased many boards”. For the CRC to bite, one delegate noted that the carbon price would have to rise significantly.

The perception that the CRC is now a tax could lead to a “tax avoidance mentality” amongst participants used to finding ways to mitigate their tax liabilities. Evidence was presented alluding to the transfer of compliance responsibilities from energy management teams to tax and audit functions, with a consequent shift of focus from energy management to tax avoidance (e.g. via offshoring of emissions rather than reducing them). In other cases, landlords, one of the groups most affected by the CRC, could feel emboldened to simply pass the “tax” on to their tenants as they do with other fees and charges.

Despite the changes, delegates agreed that some of the benefits and incentives of the CRC would persist. There was widespread agreement that the CRC has helped companies put their houses in order by forcing the collection and disclosure of accurate energy data, and in many cases highlighting inefficiencies and a more thoughtful approach to energy management. This effect is particularly noticeable in participants who had previously not reported emissions or collected data. In addition, consumer facing brands would continue to feel pressure from league table rankings, even without revenue recycling.

A summary of key conclusions:
• The CRC has had a positive impact in terms of delivering more accurate energy data for compliance and monitoring purposes.
• The CRC has been successful in getting energy discussions into the C-suite and board room.
• The CRC changes do not yet make or break the business case for energy efficiency investments.
• The increased perception of the CRC as a tax may have undermined its effectiveness as an energy efficiency incentive.

Finance & Corporate Sustainability

The pros and cons of the new energy efficiency financing markets

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After quick introductions and inputs from delegates as to what they hoped to get from the table discussion, the debate ensued.

We first tried to clarify the different forms of financing that were available for energy efficiency – detailed as - Debt; Leasing; Energy performance Contracts; Private Investors as equity Participants; Tax breaks / Capital Allowances; Carbon Finance from Carbon Trust / EIT. FITS, RECS and the Green Deal were also mentioned. The Green Investment Bank issue was discussed and lamented.

With the possibilities detailed, we set about an energetic and insightful debate about the practicality of securing such investments. The discussion was wide ranging.

THE OUTCOMES OF DISCUSSION:
The complexity of measuring real improvements due to competing movements was a barrier to investors

That risk was a hurdle - the biggest being political risk – too little consistency, too much change. Technologies were themselves a barrier – difficult to discern real measurable benefits at time, away from provider’s claims

Too many folk selling “things” to reduce energy – pumps, drives, motors – rather than solutions

There are only a handful f people in the UK who can provide proper, complex, live analysis of building energy performance – and it is hard to quantify savings and thus get finance

We concluded by asking delegates what they would like to see, from a clean sheet of paper approach, to resolve the issues of finding energy efficiency finance

• Standardisation of energy measurements
• Better dissemination of Corporations willing to invest
• De risk the change of building use scenarios
• Changes to leases so that tenants and landlords can share risk and rewards of energy efficiency (doesn’t need legislation change – just needs law firms for recognise and contract) (This single action could make significant change – NOW!)
• Clarification of what is on and off balance sheet as far as public sector financing is concerned

The conclusion – we are still mopping the floor while the taps are running!

Communications

How to engage your board in your sustainability strategies

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We had an interesting discussion which focused around three questions.

1. What are the messages for the Board?
2. Who do you need to get on board?
3. How do you get them on board?

Below I have tried to capture the main points we spoke about in relation to each of the questions and a couple of take away action points. If you have anything to add or think I have missed anything them please add them. I hope you find this write up useful and further food for thought.

A. POINTS TO CONSIDER
What are the messages for the board?
• This can be inspirational: Sustainability needs to inspire to gain real traction – try to go beyond just the rational business case argument
• Your opportunity to stand out: Play to the Board’s ego and show how this is an opportunity to stand out from the rest
• It’s not just about cost: Although you clearly need to have a strong business case, try and give the broader picture of how it fits in to the vision and values of the company
• This provides front line ammunition: There are requests for what business is doing on these issues coming from employees, clients, sales teams and others – the voices are rising
• It’s about delivering the corporate strategy: This stuff is closely linked to realising the corporate vision and showing the company values in practice (assuming you have them) – show how sustainability can meet the objectives and vision of the Board

Who do you get on board?
• Find a supporter: Find a supporter on the board that is more interested in these issues – can you engage them first to see the best way to get the board involved
• Establish who might be resistant: See if you can get time before the board meeting with those that might be more negative towards elements of sustainability

How do you get them on board?
• Grassroots that builds confidence: Tap into and encourage informal networks from around the business – use this as bottom-up momentum to show how important these issues are to everyone in the business
• Start small and get something started: Complete a small project to show tangible outcomes that can then be taken to the Board to show it works
• Do something edgy: To really stand out and get traction in sustainability you need to do something a little bit edgy – don’t just do another me too
• Simplicity is good: Technical detail can help, but often simplicity wins through – try and make sure your are not trying to get too many messages across

B. ACTIONS TO TAKE AWAY
• What other examples (beyond M&S) do we have about the traction sustainability can have and the results (reputation or otherwise) it can deliver? Examples mentioned
o Stella Artois low carbon campaign
o Fiat eco-drive
o Commercial Group overall approach
o What others are there...?
• Take a look at BITC’s new Vision 2050 http://www.bitc.org.uk/visioning_the_future/index.html – could this help the case for the Board?

Technology

The five technologies that have the quickest paybacks in a typical large corporation

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While panel discussions had focused on energy efficiency and the built environment, the table decided not to restrict the discussion to a specific sustainability issue area.

> The discussions revolved less around what the top 5 technology opportunities are, rather the process and key considerations when applying any new technology. That said, some technologies were specifically raised as providing strong payback:
o A Building Management System – BMS implementation allows for visibility of energy/resource usage activity and can enable significant reduction opportunities with the ability to control usage centrally. It was quoted that in some companies up to 18% absolute energy savings were achievable.
o Solar PV installation was previously a strong contender. This has now been significantly limited by the UK Government’s decision to review (and reduce) the Feed-in-tariff subsidy.
o Social media technology: A short side discussion identified the importance of new technologies related to social engagement (social networking etc.). They have a significant role as an enabler/communicator of sustainability issues/opportunities. Where appropriately capitalised, this can enhance the opportunity for effective collaboration with a corporation’s stakeholder group.

> The remainder of the discussions focused on the key elements necessary to successful technology implementation. These included:
o People, process, technology: It was made clear that technology implementation on its own will never be successful in achieving lasting sustainability performance improvement. There needs to be equal consideration to the stakeholders that need to collaborate in the implementation and the business processes that need to be incorporated to embed the change.
o Business case: Developing the business case for installing new technology is not a simple task. It needs to fit the business key criteria for investment and have evidence to back it. There was a number of different examples where the case could be adapted to meet these investment needs. For example, is there a way of spreading the capex spend, or moving it off the balance sheet? Is there a way of collaborating with local partners to spread the investment/risk?
o Supply chain risk: Emerging technologies and immature supply chains represent a potentially significant risk to the end-user. It is key to have as much visibility as possible on the major players in the supply chain and the risks that they may pose to successful installation and on-going operation. This is often more easily achieved where you are not reliant on a middle-merchant and technologies have been developed/manufactured in local markets
o Measurement: Prior to implementation of any new technology, it is critical to invest the time to measure current performance. There were numerous examples provided where corporations where failing to get a handle on data collection, either as a result of over-complex, independent (but overlapping) measurement systems or because there was no method in place where sufficient accuracy could be achieved. There are a plethora of data management software solutions, and this is indeed part of the problem.

Further thoughts on the above and indeed getting a clear top 5 list of technologies would be welcome.

Energy Effeciency

The best 5 energy efficiency investments in the market

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Each member of the table first offered their consideration of the most valuable energy efficiency measure/development in their business. These were the first ideas: SMART metering, Display Energy Certificates, Ensuring new builds meet the standards they were sold with, Converting from halogen to LED, text messages on the worst performing sites, having over-rides.

Nobody on the table mentioned a specific technology and agreed that the cultural challenges and the internal myth targeting (i.e. challenging ingrained corporate perceptions, e.g. around the need to keep store lights on all night) were more valuable and important. Measurement had to be the basis for all activity – to understand where you were, to draw up a holistic plan and to have the information flows in place that help you understand when you are performing well. Often the entrenched ways of the Energy or FM management could prove a serious obstacle. Senior buy in and clear ownership for sustainability or someone with a more strategic outlook is needed to drive a more strategic approach to carbon and energy efficiency. Reputational, policy and technological drivers were all noted by the table, and it was agreed that different organisations would have different solutions at their disposal – and that different drivers would have different relative impact.

The effectiveness of different Building Management Systems was brought up by many of the table members.

Some of the technologies and actions that had the most positive outcomes were referenced in the following anecdotes (from work carried out at the companies represented):

1. Dynamic Management Burner Unit (DMBU = –17% energy use)
2. Basic behavioural tips > -28% energy use
3. Voltage optimisation with old lighting (not with new)
4. On site data monitors with rewards that incentivise the site (e.g. by profit/money saved for some, but by “green-ness” for others)
5. Bureau services that monitor and manage off site
6. Senior engagement – CFO and CEO need to be on board
7. Lightweight PV breakthroughs please
8. Voltage optimisation that was sorted out at the
9. ESCO co-operation

Verdantix’s report on energy efficiency was highlighted as a place to go for good information.

Some things to avoid:

1. Voltage optimisation without consideration of what is being achieved downstream
2. BMS without proper management
3. One technology being sold and implemented in isolation

The final top five energy efficiency investments:
1. Measurement systems
2. Winning senior buy in
3. Site specific business cases
4. People incentives
5. Good BMS’s

Corporate Strategies

Case studies: Supply Chains

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SUMMARY
Supply chain management is playing an increasingly prominent role in the sustainability strategies of leading companies. Why is this happening? What are the challenges in managing supply chains? How can we learn from the experiences of leading companies?

KEY DRIVERS
• Source of competitive advantage – Client tenders can be won or lost on the record of suppliers
• Reputation – NGOs and the media regularly scrutinise company supply chains
• Efficiency – Greater oversight of suppliers can strengthen procurement relationships and drive down costs

CHALLENGES
• How best to move from monitoring suppliers into partnerships and remediation of their issues?

DISCUSSION
• Influencing the supply chain is a key aspect of implementing a sustainability strategy from a cost, innovation and reputation perspective.
• There was evidence of companies starting to adopt performance oriented measures of sustainability in the supply chain.

INSIGHTS FROM THE MARKET
• There was general agreement that leading companies aspire to move away from auditing their supply chain to developing collaborative partnerships, however while there were clear examples of leading practice, it was by no means common practice.
• Influencing performance down the supply chain is a key element of the recent sustainability strategy launches of a number of large corporate companies. This goes beyond managing reputational risks e.g.; monitoring compliance against standards, to setting performance standards in order to reduce carbon impacts up and down the supply chain, and using expertise and knowledge in the supply chain to drive innovation. We were told of examples of companies that are moving towards closed loop supply chain systems. For example we were told that one company had implemented an initiative to turn its construction waste from stores that were being demolished into a usable asset and it was seeking to work with its suppliers to find uses for that waste including being stored and re-used in other retail stores.
• One supplier mentioned that there remained a separation between commercial departments and sustainability departments. Sector leading supply chain performance was not necessarily being reflected in improved commercial terms.
• There are clear examples of strategies e.g., sustainable agriculture initiatives and government led initiatives, such as ‘The Green Deal’ that have the potential to drive innovative collaborative relationships along the supply chain. As these initiatives develop they will drive innovation and new ways of working.
• Influencing customers to live sustainably and providing product choices to enable them to do so, was a theme that was raised on a number of occasions. Retailers stated that their eco-products ranges were growing above trend and a supplier stated that in a stagnant market its range of eco products were growing strongly. Companies increasingly recognise that their sustainability strategies need to address impacts both up and down the value chain.
• A key element of embedding sustainability strategies and allowing people to develop innovative partnerships along the value chain comes from the commitment and leadership at the top of the organisation. We were told that one CEO’s bonus was tied to the company’s sustainability performance, ensuring that the sustainability strategy was aligned to the core business strategy.

PROPERTY ILLUSTRATIONS
• In the property sector there are systemic problems in influencing the supply chain as the priorities of the landlord and tenant diverge, meaning that the organisation investing in the sustainability of the property doesn’t reap the benefits of that investment. Hence there is a disincentive to invest in commercially viable initiatives. The point was made that the actual performance of the building depends on the behaviour of the tenants probably even more than the design features of the buildings.
• We were told that in Scotlandm the situation is slightly different as there is evidence in the property market of value appreciation due to the energy efficient properties of the buildings.

Energy Policy & Strategy

A review of the Electricity Market Reform from a corporate perspective

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The Electricity Market Reform (EMR) consultation is now closed and Government is in the process of reviewing the 320+ responses ahead of publishing a White Paper later this year. Last week in line with Budget 2011, the Government published its response to the carbon floor price consultation, one of the four key policy measures the Government hopes will unlock the £200bn of private sector investment needed over the next 20 years to upgrade UK energy infrastructure. The other three policy measures include long-term contract for difference (CfD) feed in tariffs to be sold by the government for low carbon generation, or an alternative ‘premium’ feed in tariff; a capacity mechanism to ensure there remains an adequate safety cushion of capacity; and, an Emissions Performance Standard to ensure that no new coal plant is built without carbon capture and storage.

Motivation for the EMR is due to low carbon prices in the EU Emissions Trading Scheme (ETS) plus a need to boost investment in low carbon technology at a faster pace. The UK is mandated to cut its carbon emissions by 34% on 1990 levels and by 80% by 2050, and must generate 15% of its energy from renewables by 2020. Alongside the carbon reduction challenge, the UK faces an unprecedented challenge in replacing its aging power infrastructure, at the same time guarantee a secure and cost effective energy supply.

Low carbon prices suggest that significant carbon reductions could be made at marginal costs that are lower than they would be through the building of new nuclear plants. Carbon trading favors emissions reductions where the abatement costs are lowest first; once those options have been realised, then marginal abatement costs increase. By contrast, it was suggested that feed in tariffs with CfD actually target the most expensive options first, for example investment in offshore wind, and risks placing too much reliance on a central body to decide the future generation mix.

The UK government’s energy policy objective is to ensure the security of energy supply, the reduction of emissions of greenhouse gases, and the provision of affordable and sustainable energy to UK citizens. The dilemma it faces is how to promote a legislative environment that provides competitive power prices and reliable supply—especially during times of peak demand—without appearing to pay direct subsidies to the nuclear power industry, or causing power prices to spiral.

Achieving this transition will require significant investment, but with the government focused on spending cuts, it is clear that this investment will not come from the public purse. Almost all of this investment will therefore need to come from the private sector, with the UK consumer ultimately bearing the cost.

The issue of cost was one of the main themes discussed as some felt that combined the impact on consumer’s energy bill was too much of a cost to bear. Some felt that by giving people a choice they would favour paying more to fund a transition to renewables, and questioned what price do businesses place on security of supply. Germany was highlighted as an example where despite costing approx. €9 per person to fund renewables, people were happy to pay a premium.

It was mentioned that the direct cost of the carbon floor price had already added £2 or 8% to power prices from 2013, since the policy was announced in Budget 2011, notwithstanding the rise in commodity prices through higher global demand and ongoing unrest in the Middle East. A complaint was that the UK’s carbon and energy policy has become far too complex to administer and perhaps there was a possibility of merging or disbanding some of the policy measures.

It was discussed that business users are paying for carbon through 4 different mechanisms (EU ETS, Climate Change Levy, Carbon Reduction Commitment, Carbon Floor Price), in addition to the cost of the Renewables Obligation and micro-generation Feed-in Tariff being incorporated into electricity bills. All of these policies may lead to UK businesses paying the highest global price on carbon putting the competitiveness of UK plc under threat, and the prospect of businesses relocating operations to territories where carbon policies are more relaxed. It was mentioned that Scandinavia, the Netherlands and Germany are looking at similar measures to expand low carbon generation.

One way of hedging against future cost rises is through long-term contracts. Power purchase agreements (PPAs) were used as an example to show how businesses can take more control of how much money they spend by reducing exposure to future price rises at the same time as increasing renewable offtakes.

A third point of note was the risk of distortion between the UK and EU markets, not only in the price of carbon through the carbon floor price and risk of carbon leakage, but also in terms of power price differentials and new build signals. It was hoped that the Government would take heed of these points to ensure a level playing field.

CONCLUDING REMARKS
• Corporates are supportive of measures that will enable a transition to a low carbon future
• Ensuring businesses remain competitive must remain Government’s top priority
• An urgent review of the myriad of carbon measures is needed to reduce complexity
• Requirement for a more market oriented approach towards infrastructure planning and less reliance on a central body
• Policy measures must remain technology neutral and be fit for purpose for the next decade and beyond; investors and corporates value certainty.

Venue Detail

Bank of America Merrill Lynch: King Edward Hall

King Edward Hall | 2 King Edward Street | London | EC1A 1HQ

Directions

Bank of America's offices are a very short walk from St Paul's tube station (Central Line). Exit the station at Cheapside/Newgate Street. Go past the BT centre, with it on your right-hand side and take the first available right down Edward Street. Continue down this road for 80m and the entrance to the venue is on your left-hand side.

Do not go to the main reception desk at their offices when you arrive. You are looking for an entrance that leads you directly into the King Edward Hall.