Tina Schirr

Published: February 28, 2020

Submitting To: Ministry for the Environment (MfE)

Issue for Business: The key premise for our submission is that greater ambition, and therefore policy action, is not only increasingly accepted, but welcomed by many businesses (no more tangibly demonstrated than through leading businesses pledging to adopt science-based targets). However, the greater ambition needs to be balanced with the long-term durability of the framework and policy settings being put in place. To ensure this durability, a holistic approach must be taken to policy decisions, one that would recognise the inter-dependent nature of various Government work streams running in parallel. We are therefore concerned about what appears to be a fragmented and rushed policy push. The current array of consultations involve overlapping and sometimes contradicting proposals. In some cases, assumptions are based around unproven and/or yet to be implemented additional policy measures (e.g. EV incentives, Clean car standard and clean car discount programmes). In other cases, the impact assessment is incomplete. All this goes to undermine business confidence and the base on which investment decisions are made. We have previously commended MfE for having adopted a progressive approach to the development of an incredibly complex system by staging the consideration of the issues. It would be regretful to see this undone.