industry information > communications > publications and information > consultations and submissions

DEFRA: Consultation on Implementation Proposals for Carbon Reduction Commitment (formerly the Energy Performance Commitment) ? June 2007

The Department for Environment, Food and Rural Affairs (DEFRA) recently issued its consultation paper on implementation proposals for the Carbon Reduction Commitment (CRC). CRC is a cap and trade scheme which will affect any company with an energy bill over 6,000 Megawatt-hours (MWh).

SBAC has now made its sub,ission to DEFRA. The Government response can be expected at the end of December 07.

DEFRA sees CRC as a key part of the answer to the challenges of climate change, ensuring energy supplies and reaching the UK Government's four long term goals:

• Cutting CO₂ emissions by at least 60 per cent by 2050, with real progress being made by 2020
• Maintain reliable energy supplies
• Promote competitive markets in the and abroad
• Ensure every home is adequately and affordably heated

For an in depth summary, please see attachment.

	SBAC Carbon Reduction Commitment Submission to Defra (84.5 KB)
	DEFRA Consultation on Implementation Proposals for CRC (73.2 KB)

SBAC response to DEFRAs consultation on REACH enforcement

SBAC's key comments can be summarised as follows:

- Aerospace and defence companies place the highest priority on compliance with health, safety and environmental legislation, not least because of the harsh operating conditions that aircraft and such equipment faces and the need to ensure air worthiness.

- The aerospace supply chain is one of the largest and most complex in the UK. Major prime companies estimate that there are some 7,000 UK companies in their supply chains.

- It is essential that enforcement processes are joined-up, uniform and coordinated.

- The real key to ensuring compliance is raising awareness of REACH and the specific responsibilities of companies who are affected by the regulations. HSE needs to develop a communications plan in conjunction with industry to raise awareness of REACH requirements.

- SBAC would welcome an opportunity to view the detailed outcome of the review of legislation to ensure that products are not inadvertently made inaccessible to aerospace manufacturers as a result of REACH.

- SBAC recommends that any discussions about excluding substances from REACH on defence grounds should involve defence manufacturers, at the earliest opportunity, who will be able to provide direct experience, information and research to government on the likely nature of any substances which may need to be excluded from the provisions of REACH.

- SBAC recommends that the RIA should take into account the costs of companies in preparing for a REACH inspection, which can be the most time consuming aspect of a visit.

- SBAC would like to discuss with the department how the wording of article 5 can be modified to ensure that UK implementation does not impose additional requirements on UK companies.

For a full SBAC submission please see attached document.

SBAC response to DEFRAs consultation on REACH enforcement (85.3 KB)

DBERR Consultation on Simplilfying Business Support

The government is proposing that Business Links will be the primary means of access for publicly funded support, this has the potential to help businesses access export credit guarantee's and innovation finance and could help businesses setting up in overseas markets.

Full details can be found in the attached document

	SBAC response to Simplifying Business Support consultation (70.8 KB)
	Simplifying Business Support Consultation Paper Summary (62.7 KB)

Export Control Act 2002 - 2007 Review of Export Control Legislation

The Government is conducting a review of the Export Control Act 2002, as was promised after the introduction of its secondary legislation in May 2004. At this time a public commitment was made to undertake a Post Implementation Review of the new controls three years after introduction. The review, which affects defence exports to a large extent, is ongoing until 30 September 07 with the initial results being published by 31 December 07.

For further details see attachment:

Export Control Act 2002 - 2007 Review of Export Control Legislation 2007 Review of Export Control Le (60.8 KB)

The Trade and Industry Committee Inquiry: Creating a Higher Value-Added Economy

SBAC highlighted the importance of the aerospace industry as a highly attractive and growing industrial sector in its submission to the Trade and Industry Committee inquiry. Alongside pharmaceuticals, aerospace provides important balance to the UK economy and sustains high value careers in design, research, engineering and manufacturing. The high levels of investment that come natural to the sector mark it out as a major contributor to the success of other key industries.

SBAC drew attention to the critical period that aerospace is entering; increasing globalisation, intense cost pressures and the difficulties of selling in a US dollar denominated market are making aerospace research, development and production more internationally mobile. The defining business opportunities at this time are future single aisle programmes and the delivery of the fixed and rotary wing sector strategies, as part of Defence Industrial Strategy. SBAC emphasised the mportance of industry and Government working to maximise the opportunities for UK based businesses on these important programmes.

Department for Transport: Consultation on the emissions cost assessment

The Department of Transport has launched a consultation on the methodology that should be used to assess the external cost of aviation emissions. This will be called the aviation emissions cost assessment (ECA). The intention of the ECA is to consider whether the aviation industry currently meets the costs of its environmental impact. This consultation paper relays the Government's proposals for the ECA and requests views of all those affected.

Propositions for ECA

The DfT propose that the emissions cost assessment should be:

• a wide strategic assessment
• a means to increase understanding of the climate change cost of aviation in conjunction with the increases in aviation capacity
• undertaken approximately every three years to coincide with the review and report on progress in delivering the Future of Air Transport agenda.

SBAC has now submitted their contribution to DfT. The Departmental response can be expected towards the end of 2007.

For the full list of consultation questions see attachment.

	SBAC submission to DfT on Emissions Cost Assessment (86.8 KB)
	Department for Transport - Consultation on the Emissions Cost Assessment August 07 (67.7 KB)

The House of Commons Environmental Audit Committee: Are Biofuels sustainable?

SBAC's submission to the Environmental Audit committee sets out the research into Biofuels that is underway in the aerospace industry. It also identifies the requirements of any fuel used in aircraft and the progress that has been made on different fuel types. Biofuels remain an area of research that is of interest to the aviation industry, however, the technical and logistical challenges associated with their use will prevent its wide-spread application in the near term.

For SBAC's full submission, click here

The House of Commons Defense Select Committee inquiry into Defence Equipment

SBAC has submitted evidence to the House of Common's Defence Committee inquiry into Defence Equipment. This inquiry is designed to assess progress in the Ministry of Defence's procurement and support of defence equipment. For this year's inquiry, the Committee plans to examine:

• The performance of the DPA against it key targets for its last year of operation (2006?07);
• How Defence Equipment and Support (DE&S) is developing.

SBAC, in its submission, focused on the merger of the Defence Procurement Agency (DPA) with the Defence Logistics Organisation (DLO) which became the DE&S. SBAC recognised that this was a considerable undertaking effectively handled by MOD. SBAC also noted that the DE&S' recent creation has made it too early judge as to its effectiveness, but that it has been a key element of DIS which aims to improve industry working relations with MOD.

For more information click here