UK Climate Policy Briefing - September 2024
Summary Briefing
This Summary Briefing highlights the essential need-to-knows for NEDs in terms of emerging policy and regulatory developments, as well as signalling key events on the horizon, and some question prompts for the boardroom to consider when reading the full briefing below. The full briefing offers more detail on each of the key policy areas relevant for boardrooms in regard to the climate agenda.
Key takeaways for Non-Executive Directors
- Latest Climate Change Committee (CCC) report highlights the need for credible action plans to ensure UK meets its emissions reduction targets.
- The establishment of the UK’s £7.3 billion National Wealth Fund (NWF) aims to attract billions in private sector investment in “new industries of the future”.
- Government looks to accelerate grid decarbonisation through establishing GB Energy and focusing on unlocking the investment needed.
- In his first major speech, Foreign Secretary David Lammy highlights climate change as a major strategic issue for the UK and announces the launch of a new Global Clean Power Alliance and two new UK Special Representatives for Climate Change and Nature.
- SBTi launches tranche of key documents to support organisations with developing credible action plans:
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- A discussion paper on Scope 3 target setting
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- A report on the effectiveness of carbon credits
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- A draft of its Financial Institution Net Zero Standard for consultation in July.
- The results of the inaugural UK Net Zero Business Census were released in September: 73% of respondents citing net zero as a medium or higher priority for business strategy in the next year; however, costs, access to finance and enabling policy and support mechanisms were listed as key barriers.
- Oxera’s Growth Zero: Reframing net zero as a driver for growth report finds that net zero acceleration could add £765 billion to the UK economy before 2050, but achieving this will require a significant shift in momentum.
- UKRI’s overview of the Industrial Decarbonisation Challenge outlines that since its launch in July 2019, the project has invested £210 million in public funding, paired with £261 million in matched funding from industry towards innovative net zero projects.
- The Institute for Energy Economics and Financial Analysis (IEEFA) released analysis suggesting that the new Government could bring about a growth in green gilt issuance, i.e. the issuing of UK Government bonds to finance projects with clearly defined environmental benefits.
- The Financial Stability Board (FSB)’s report, Stocktake on Nature-related Risks: Supervisory and regulatory approaches and perspectives on financial risk highlights the significant opportunity for the financial sector to promote and direct investment towards developing frameworks for assessing and mitigating nature-related financial risks. More materials and guidance around developing Nature strategies and reporting will be released by Chapter Zero and the CGI in October ahead of COP16, including Taking TNFD to Your Board in collaboration with the Green Finance Institute.
- Gallagher survey points to a potential gap in current corporate approaches to carbon accountability: two thirds (63%) of those surveyed reported planning to achieve their sustainability targets through the purchase of carbon credits, with many organisations having no back-up plan in place should carbon credits fail. More information on carbon credits, and carbon offsetting more generally, for NEDs is provided in Chapter Zero’s 2021 briefing.
- Research from the LSE Grantham Research Institute finds that at least 230 new climate cases were filed in 2023, seeking to hold governments and companies accountable to climate action, with trends in corporate climate litigation showing a significant number of cases concerning ‘climate-washing’, as well as ‘corporate framework’ cases focusing on aligning group-level governance processes with climate goals.
- Research from East & Partners suggests that majority of global corporates (61.7%) plan to increase net zero spending in the next year. The study of more than 1,300 companies from across the world finds that UK businesses expect to boost their spending the most, by an increase of 40.8%.
- The Net Zero Stocktake 2024 was published by Net Zero Tracker (NZT) in September, reporting that the number of company net zero targets has increased by 23%, with nearly 60% of the 1,977 publicly-listed companies tracked by NZT now having climate targets. Alongside measuring corporate progress, responses to the report highlight that “a so-called 'commitment gap' in city, state, and regional government net zero targets is holding back the transition to a net zero emission economy”, emphasising the need for continued collaboration between private and public sector actors in net zero transition planning.
- As of 25 July 2024, the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) has come into force, setting out companies’ – i.e. EU and non-EU companies that meet certain size and turnover thresholds – obligations regarding the human rights and environmental impacts of their activities.
- US Securities and Exchange Commission (SEC)’s climate disclosure rule, the Enhancement and Standardization of Climate-Related Disclosures, was confirmed earlier in 2024 and requires companies to disclose material climate-related financial risks. More information on how the ruling impacts boards is provided in a briefing from the Climate Governance Initiative.
- The British Standards Institute (BSI) released guidance in July on the role of standards in ESG reporting and launched a new Net Zero Pathway scheme to aid organisations in their transition to net zero. Through participating in the scheme, organisations are offered support in calculating their carbon footprint (including scope 3 emissions), verifying GHG emissions reporting in line with ISO standards, and auditing in line with ISO Net Zero Guidelines.
- Work is underway on the development of ISO’s first international net zero standard, which is expected to launch at COP30 in 2025.
- As of 31 July, the investment labels outlined in the Financial Conduct Authority (FCA)’s Sustainable Disclosure Requirements (SDR) are able to be adopted by firms. These labels are Sustainability Impact™; Sustainability Mixed Goals™; Sustainability Focus™; Sustainability Improvers™.
- ESG policy continues to be a central focus for the Government’s agenda, with Chancellor Rachel Reeves confirming that the previous administration’s plans to introduce a bill to regulate ESG rating agencies will go ahead in the next year.
- The Voluntary Carbon Markets Integrity Initiative (VCMI) announced plans to open a public consultation on the proposed development of a Scope 3 Claim, which offers companies a tool to report on Scope 3 emissions and accelerate decarbonisation and accountability throughout their supply chains. The Climate Governance Initiative’s new Carbon Pricing Navigator, developed primarily for board directors, provides a useful resource for NEDs interested in how their organisations may understand, implement, and navigate carbon pricing and carbon markets.
- 21 October – 1 November: COP16 – 2024 United Nations Biodiversity Conference: first Biodiversity COP since the adoption of the Kunming-Montreal Global Biodiversity Framework (GBF) in 2022. Key topics under discussion will include: implementation of the GBF; progress of Parties to the Framework on their National Biodiversity Strategies and Action Plans; mainstreaming of biodiversity within and across sectors; diverse values of biodiversity; biodiversity and climate change; mechanisms for planning, monitoring, reporting and review; liability and redress; resource mobilization and financial mechanism; capacity-building and development.
- 30 October: UK Autumn Budget
- 11-22 November: CO29 - 2024 United Nations Climate Change Conference or Conference of the Parties of the UNFCCC, held in Baku, Azerbaijan. Key topics under discussion will include: strengthening Nationally Determined Contributions (NDCs); advancing climate finance and the New Collective Quantified Goal (NCQG); growing the Loss and Damage Fund; carbon markets and operationalising Article 6 of the Paris Agreement; reviewing National Adaptation Plans (NAPs).
Board discussion questions
- Does our business strategy or transition plan reflect the latest policy and regulation developments?
- Do we need to expand or adapt our reporting to align with current and forthcoming regulatory changes, and/or incorporate any risks not currently accounted for?
- Could these developments impact the potential speed and cost of our transformation?
- Have these changes opened up any new opportunities for industry collaboration, investment or funding?
Full Briefing
Introduction
Our quarterly UK policy briefing aims to highlight the latest developments in UK climate policy relevant to Non-Executive Directors (NEDs). Since our last briefing, the new Labour Government has been elected, with the King’s Speech marking the formal start to the new parliament in July. The first 100 days of the new Government has been a busy time for policy announcements, as Labour’s environmental commitments (outlined in its election manifesto, which is covered in Chapter Zero’s 2024 election briefing) come into greater focus. Significant challenges to delivering these commitments remain, with Prime Minister Sir Keir Starmer, in an August speech at Downing Street, claiming that his government has inherited a £22 billion black hole in the nation’s finances. With the Climate Change Committee (CCC)’s latest report finding that the UK does not have all the credible plans in place required to meet its 2030 emissions reduction target, addressing these financing gaps is becoming all the more critical to keeping the UK’s climate transition plans on track. However, in his first major foreign policy speech in September, Foreign Secretary, David Lammy, spoke to the severity of the climate crisis as a central concern of the UK’s foreign policy, stating, “This is critical given the scale of the threat, but also the scale of the opportunity. The chance to achieve clean and secure energy, lower bills and drive growth for the UK, and to preserve the natural world around us, on which all prosperity ultimately depends.”
Major climate-related developments in the UK policy landscape
- Upon the election of the Labour Government, the CCC released its 2024 Progress Report to Parliament in July, setting out a comprehensive overview of the UK’s progress in emissions reductions. The report found that only a third of the emissions reductions required to achieve the target of a 68% (based on 1990 levels) reduction by 2030 are currently covered by credible plans. Analysis in the report suggests the UK is not on track to meet its Nationally Determined Contribution (NDC) target if it does not rapidly reduce oil and gas usage.
- CCC outlines key focus areas for the UK to regain and accelerate progress in, for example:
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- Annual offshore wind installations to increase by at least three times, onshore wind by double, and solar installations by five times the current amount.
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- The market share of new electric cars to increase from today’s 16.5% to nearly 100% by 2030.
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- Close to 10% of existing UK homes to be heated by a heat pump by 2030, in comparison to approximately 1% today.
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- The report outlines priority recommendations for the UK Government, including strengthening the third National Adaptation Plan (NAP3), publishing a Green Jobs Plan, and reinstating the phase-out of fossil fuel cars, vans and boilers.
- Secretary of State for Energy Security and Net Zero, Ed Miliband, published a letter to the CCC in August, seeking the organisation’s advice on the development of the UK’s 2035 Nationally Determined Contribution (NDC) and setting the UK’s updated carbon reduction target. As a signatory of the Paris Agreement, the UK is required to report its NDC at least 9 to 12 months ahead of the relevant COP. In this case, this next round of NDC target-setting to update the UK’s current NDC is due between November 2024 and February 2025. NEDs may find it useful to keep informed of this process to understand the direction of travel for national goals and policy and the implications for business climate leadership. Many businesses have already expressed support for ambitious NDCs, including the global coalition of business leaders, Mission 2025.
- Published in July, Oxera’s Growth Zero: Reframing net zero as a driver for growth report largely echoes the CCC’s calls for ramping up net zero action, finding that net zero acceleration could add £765 billion to the UK economy before 2050. This will require a major shift in momentum, considering that recent research finds that only 18% of financial institutions and 27% of investment firms have a net zero transformation strategy extending beyond the next 12 months.
- The results of the inaugural UK Net Zero Business Census were released in September. Over 2,005 organisations participated in the survey conducted by the UK Business Climate Hub and Planet Mark. Headline findings suggest varied, but significant, business engagement with net zero:
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- 73% of respondents stated that achieving net zero was a medium or higher priority for the business strategy in the next year
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- 65% of respondents have committed to net zero by 2050. A range of drivers for this were identified, with 46% of organisations reporting having received requests for carbon data from customers and/or tender applications
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- Across both larger organisations and SMEs, costs were identified as a major barrier to decarbonisation, with 59% of organisations citing finance as a significant constraint to net zero objectives
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- In considering support mechanisms to help address these financial barriers, the survey found that only 25% of organisations reported having access to support mechanisms such as government funding and grants. The survey puts forward a number of recommendations for policymakers to help improve access to these resources and empower organisations of all sizes to meet their net zero goals, including “greater partnership between government and business to develop sector-specific decarbonisation pathways and guidance, as well as enhanced financial mechanisms”.
- The British Standards Institute (BSI) released guidance in July on the role of standards in ESG reporting. This guidance serves as a precursor to the upcoming International Organization for Standardization (ISO) International Workshop Agreement on ESG principles for organisations, due to be published in late 2024. Relatedly, work is also underway on the development of ISO’s first international net zero standard, which is expected to launch at COP30 in 2025.
- Also in July, BSI launched a new Net Zero Pathway scheme to aid organisations in their transition to net zero. Through participating in the scheme, organisations are offered support in calculating their carbon footprint (including scope 3 emissions), verifying GHG emissions reporting in line with ISO standards, and auditing in line with ISO Net Zero Guidelines.
- As of 31 July, the investment labels outlined in the Financial Conduct Authority (FCA)’s Sustainable Disclosure Requirements (SDR) are able to be adopted by firms, . These labels are:
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- Sustainability Impact™
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- Sustainability Mixed Goals™
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- Sustainability Focus™
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- Sustainability Improvers™
The criteria for applying sustainable labels is outlined in greater detail in the latest updates to the ESG sections of the FCA handbook. While the deadline for implementing naming and marketing rules for asset members (i.e. ESG 4.3.2R to ESG 4.3.8R of the ESG sourcebook) is 2 December 2024, the FCA has announced that under certain exception circumstances, firms can apply for a delay until April 2025.
- In July 2024, the CMA released guidance, Marketing green heating and insulation products: Consumer law compliance advice for businesses, which offers advice on how to prevent potentially misleading marketing claims, including around headline price information and/or about products and services. This guidance applies to any business involved in marketing green heating and/or insulation products for UK consumers, as well as businesses based outside the UK providing services to UK consumers and standards bodies.
- SBTi has published four technical outputs as part of the revision of its Corporate Net-Zero Standard. These outputs include:
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- Scope 3 discussion paper, Aligning Corporate Value Chains to Global Climate Goals, discussing potential changes to Scope 3 target setting, without proposing draft requirements or criteria.
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- Results from a 2023 open call for evidence on the effectiveness of Environmental Attribute Certificates
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- Report on the effectiveness of carbon credits in corporate climate targets
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- An independent systematic review on the effectiveness of carbon credits when used as a substitute for direct abatement.
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- In July, SBTi also released a draft of its Financial Institution Net-Zero (FINZ) Standard for a second round of public consultation. The draft standard outlines a variety of climate-aligned commitments including transition plans consistent with achieving net zero by 2050 or sooner, as well as reporting GHG emissions inventories based on gross emissions in portfolios without deducting or netting emissions from the use of carbon credits.
- Chancellor Rachel Reeves has confirmed plans to bring forward a UK law to regulate ESG rating agencies in the next year. It is proposed that the FCA will set the new rules for the industry, with the intention for these to develop in alignment with international recommendations and the regime being created in the EU.
- The North Sea Transition Authority (NSTA) released a report in July on the importance of ESG reporting to unlocking investment in North Sea. The report finds that more than half of analysed companies now link executives’ variable pay with key ESG performance indicators, and are promoting ESG data consistency through the use of “data centres”.
- As of 25 July 2024, the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) has come into force, setting out companies’ – i.e. EU and non-EU companies that meet certain size and turnover thresholds – obligations regarding the human rights and environmental impacts of their activities. These obligations require that a company conduct mandatory risk-based due diligence across its ‘chain of activities’, ensuring compliance across a range of impacts such as child labour, forced labour, pollution, biodiversity loss, ecosystem degradation, and waste management.
- NEDs should also be aware of the US Securities and Exchange Commission (SEC)’s climate disclosure rule, the Enhancement and Standardization of Climate-Related Disclosures, which was confirmed earlier in 2024 and requires companies to disclose material climate-related financial risks including:
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- Scope 1 and 2 emissions metrics and third-party verification
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- Expenditure data related to carbon offsets, renewable energy credits, and severe weather events
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- Disclosure of transition plans, climate risk scenario analysis, and use of an internal carbon price
More information on how the ruling impacts boards is provided in a briefing from the Climate Governance Initiative.
- Research from the LSE Grantham Research Institute finds that at least 230 new climate cases were filed in 2023, seeking to hold governments and companies accountable to climate action, with trends in corporate climate litigation showing a significant number of cases concerning ‘climate-washing’, as well as ‘corporate framework’ cases focusing on aligning group-level governance processes with climate goals. The UK has seen a number of these cases, which are evidenced below.
- In July, the Government defended against legal action pursued by three environmental organisations – Friends of the Earth, Good Law Project, and ClientEarth – which claims that the objectives of the National Adaptation Programme (NAP3) released by the previous UK government are in breach of both the UK’s Climate Change Act and Human Rights Act. This follows legal action against the former Government’s Carbon Budget Delivery Plan, for which a May 2024 High Court ruling found the climate action plan unlawful, due to delivery risk, and ordered a revised plan by May 2025.
- A legal challenge has been raised against the decision to build a new “net zero” gas power station in Teesside, claiming that the project’s developers failed to consider emissions linked to supplying and transporting gas. Originally projected to be responsible for 5.9 million tonnes of carbon, challenging projections total more than 20 million tonnes of carbon. In August, London’s High Court dismissed the legal challenge and ruled the approval of the gas-fired power station as lawful, stating, “The development was strongly supported in national policy, both planning and energy policy.”
- The Supreme Court ruled in June that the decision to grant planning permission to retain and expand the Horse Hill oil production site in Surrey was unlawful as it failed to assess the downstream, Scope 3 greenhouse gas emissions that will arise from the burning of the produced oil. This case could have significant implications for future fossil fuel projects in the UK, as “planning authorities will have to consider the downstream GHG emissions when deciding whether to grant planning permission”.
- In August, the Government announced that it will not fight a legal challenge brought by Greenpeace and Uplift against the decision to grant consent to develop new oil wells at the Rosebank and Jackdaw oil fields in Scotland. While the litigation does not mean that the licenses for Rosebank and Jackdaw have been withdrawn, if the court rules in favour of the green lobby, the operators will be required to resubmit environmental impact assessments to be reconsidered for approval and licensing. The government’s decision to concede the legal challenge has been welcomed by green campaigners, with the Executive Director of Uplift stating, “This government has rightly accepted that this huge oil field cannot proceed without the full extent of the damage it will do to our climate being taken into account.”
- In collaboration with the Green Finance Institute, the Government has published a National Wealth Fund Taskforce report, following the establishment of the UK’s £7.3 billion National Wealth Fund (NWF). An initiative aimed to attract billions in private sector investment in “new industries of the future”, this interim report outlines the recommended design and governance principles for the NWF to effectively drive step-change in green investment.
- The Institute for Energy Economics and Financial Analysis (IEEFA) released analysis suggesting that the July 2024 election of the Labour government could bring about growth in green gilt issuance, i.e. the issuing of UK Government bonds to finance projects with clearly defined environmental benefits. Since the launch of the green gilt programme in September 2021, close to £40 billion cumulatively has been issued, which has been directed towards transportation primarily, as well as renewable energy, nature, and climate adaptation projects.
- The Local Authority Pension Fund Forum (LAPFF) published a report in August outlining recommendations for UK climate policy. In its recommendations for corporate governance policy, the report argues that the proposed allocation of £20 billion in funding for Carbon Capture and Storage (CCS) outlined in the 2024 Spring Budget represents a misallocation of resources that could lead to a reliance on CCS to deal with carbon emissions, rather than innovating to eliminate emissions at source.
- The Association of British Insurers (ABI) reported a record quarterly high in property insurance payouts in August. Claims for damage to homes due to heavy rain, storms, and frozen pipes reached £144 million in the second quarter of 2024, with claims for weather damage to businesses remaining high at £81 million. This represents the fifth consecutive quarter in which weather-related claims have been above £100 million, which reflects wider concern that climate change is destabilising the insurance industry, “driving up prices and pushing insurers out of high-risk markets.”
- In one of its first acts in office, the Government removed the de facto ban on onshore wind, which was originally introduced in 2016. Lifting the ban has been seen as key to delivering grid decarbonisation by doubling onshore wind energy by 2030, as per Labour’s 2024 manifesto. The Government has also outlined plans to consult on bringing large onshore proposals within the scope of the ‘nationally significant infrastructure projects’ (NSIPs) to help speed up delivery timelines.
- Just days after the election, the Government approved three solar farms, which together account for 1.35GW, or about two thirds as much as the total solar capacity installed in the UK last year. This amount of power is expected to supply around 400,000 homes with electricity.
- In July, the Government confirmed a £1.5 billion budget allocation for the Contracts for Difference (CfD) renewable energy auction round, which is an uplift of more than 50% compared to the previous commitments. The Energy and Climate Intelligence Unit (ECIU) suggests that this year’s CfD auction could secure between 4GW and 6.5GW of offshore wind capacity, out of the 10GW of projects that are eligible to enter. Successful CfD projects will be announced in September 2024.
- Another energy milestone was announced in August, with the UK reaching a historic level of 30GW in wind generation capacity. This level of capacity is expected to meet the annual power needs of more than 26 million homes and cut carbon emissions by over 35 million tonnes annually. With wind remaining the UK’s biggest source of clean power, July statistics from the Department for Energy Security and Net Zero (DESNZ) show that renewables provided a record 46.4% of the UK’s electricity in 2023.
- A partnership between Great British Energy (GB Energy) and the Crown Estate was announced in July. The first major partnership for GB Energy, it is estimated that the collaboration will lead to up to 20-30GW of new offshore wind developments reaching seabed lease stage by 2030. This amount of energy would be enough to power almost 20 million homes, helping boost the UK’s energy independence and lower energy prices. Two bills, the Great British Energy Bill and the Crown Estate Bill, have been introduced to help grant the two national institutions the powers needed to rapidly deliver the goals of the partnership.
- In August, the Government announced a new industry group, the Energy Crisis Commission, bringing together experts from Energy UK, National Energy Action, Citizens Advice and the CBI, to assess how the UK is prepared to deal with future energy shocks. The group has been tasked with gathering evidence to present to policymakers in the autumn, with a public call for evidence having closed at the start of September.
- In September, the Foreign Secretary also announced the launch of a new Global Clean Power Alliance, focusing on boosting investment in clean energy by sharing technology and financial resources with countries falling behind in the transition.
- As decarbonising Britain’s power system by 2030 is arguably the most ambitious of Labour’s five core “missions”, a range of further policy developments are expected over the coming months, with events including Energy UK’s 2024 Annual Conference in early September bringing together stakeholders from across the UK’s energy sector to determine ways of working with the Government to “unlock the billions of pounds of extra investment that will be needed to meet the UK’s energy security and Net Zero Targets”.
- In her first public spending audit in the House of Commons on 29 July, Chancellor Rachel Reeves set out plans to increase the windfall tax applied to energy generators as a result of the ongoing energy price crisis – the Energy Profits Levy (EPL) – from 35% to 38% as of November 2024. Also as of November, there will be a phased decrease in the Levy’s investment allowance which developers can claim back on spending for exploration and extraction – a move that reflects Labour’s manifesto commitment to ending new oil and gas licenses in the UK. There remains a risk in higher energy costs if energy companies pass on the increased tax costs through higher energy prices.
- Ofgem has launched a consultation on a proposed common Flexibility Market Asset Registration (FMAR) solution to enable a shift towards more flexible energy use on the UK grid. Greater energy flexibility is highly needed, as energy systems become increasingly dependent on intermittent power generation from low carbon sources such as wind and solar power. With the overall objective “to create the tools necessary for distributed assets like electric vehicle chargers, heat pumps, and home battery storage systems to seamlessly register for markets in a one-stop-shop, eliminating the complexity of the myriad platforms and processes” stakeholders have to navigate. This round of consultation welcomes responses particularly from stakeholders at the domestic and small-business scale. NEDs may benefit from keeping up to date with developments in this space, as consideration of flexibility and FMAR is likely to be a component of energy transition planning for organisations and asset managers.
- The first half of 2024 saw a steep increase in heat pump installations, to levels 45% higher than those recorded during the same period last year. Industry experts have suggested that 2024 is set to be another record-breaking year for installations, but have cautioned that there is still significant need for a clear government approach to growing both heat pump demand and manufacturing and installation workforces. In August, it was confirmed that the UK had reached a major milestone of 250,000 heat pump installations.
- It was announced in July that universal winter fuel payments will be scrapped this year. From September, those not on means-tested benefits or pension credit will no longer receive the annual payments worth between £100-300. The move has attracted debate with the Chair of the Committee on Fuel Poverty, claiming “there has been a stalling of progress” on the UK’s fuel poverty reduction and calling for a plan to help improve affordability for struggling households.
- The Voluntary Carbon Markets Integrity Initiative (VCMI) announced plans to open a public consultation on the proposed development of a Scope 3 Claim, which offers companies a tool to report on Scope 3 emissions and accelerate decarbonisation and accountability throughout their supply chains. The consultation is set to run from 2 September to 7 October, with publication of results expected in late 2024. The Climate Governance Initiative’s new Carbon Pricing Navigator, developed primarily for board directors, provides a useful resource for NEDs interested in how their organisations may understand, implement, and navigate carbon pricing and carbon markets.
- In August, a report from Centrica, Drax, Equinor, National Grid, SSE, and Uniper calls for the Government to align the UK’s carbon trading scheme with the EU’s. The report argues that linking the two systems could reduce the costs of decarbonisation for both the UK and EU and help the UK Government avert £8 billion in revenue loss. The report references the importance of ensuring a level playing field, particularly as the UK CBAM comes into effect in 2027. The UK CBAM was included as a key climate commitment in the Labour manifesto. NEDs should be aware of the implications of the UK CBAM, helping to push for a full assessment of their organisations’ carbon-intensive supply chain risks at the strategic level, and to prepare and plan for changing regulatory requirements.
- In August, Gallagher published results of its survey research from over 100 sustainability executives at UK firms, finding that nearly two thirds (63%) of all sustainability targets set by large businesses in the UK will be achieved by the purchase of carbon credits. The survey also found that a quarter of businesses do not have a back-up plan to reach climate goals should carbon credits fail, pointing to a potential gap in current corporate approaches to carbon accountability. More information on carbon credits, and carbon offsetting more generally, for NEDs is provided in Chapter Zero’s 2021 briefing.
- The Government launched Skills England in July, bringing together government, businesses, training providers, and unions. This is especially significant in terms of developing the workforces needed to deliver the climate transition. Recent research predicts a skills gap of approximately 200,000 workers in the energy sector, with around 20% of energy sector workers expected to retire by 2030. Of the 400,000 jobs needed to build the new energy workforce across areas including renewables, nuclear, and hydrogen, there are currently around 270,000 workers in the oil and gas sector who can transfer their skills towards delivering net zero.
- The 2024 National Environmental Services Survey conducted by Environmental Services & Solutions Expo (ESS) finds that 58% of respondents from the environmental services sector believe there is or will be a green skills gap, reinforcing the importance of focusing on the training and capacity building needed to meet current and future industry needs.
- Barclays has called on the Government to address a £1.5 billion financing gap for growth-stage climate tech firms, calling for the UK Infrastructure Bank and British Business Bank to launch a dedicated climate tech fund. Its July report, Scaling growth-stage climate tech companies, includes a number of policy-related recommendations on how public finance institutions can best support climate tech companies at the growth stage, highlighting that climate finance needs to increase to $4.35 trillion annually by 2030 to meet climate targets.
- Defra released initial extended producer responsibility (EPR) base fees for packaging in August, to come into effect in 2025. The announcement has seen positive industry reaction, with WRAP’s Director stating, “We welcome the clarity that the publication of these illustrative fees gives to businesses. Now, businesses can better plan their packaging with a greater focus of designing out waste.” The UK is also a member of the High Ambition Coalition (HAC), which is working to develop a legally binding instrument to end plastic pollution. The UK strongly supports an ambitious treaty covering the full lifecycle of plastics, the Global Plastics Treaty (INC5) – the final round of negotiations of which will take place in November.
- Representatives of the UK chemicals sector have called for the Government to set out a clear vision for the industry’s future in the forthcoming Industrial Strategy. Research from Green Alliance suggests that 140,000 industry jobs are at risk over the long term if the chemicals sector remains dependent on fossil fuels and fails to plan for its decarbonisation. Suggested policy measures include, “requiring a certain amount of carbon in chemicals to come from greener sources through a ‘green carbon mandate’.”
- UKRI released a report in July offering an overview of the Industrial Decarbonisation Challenge, which since its launch in July 2019, has invested £210 million in public funding, paired with £261 million in matched funding from industry towards innovative net zero projects. Support is offered across three interrelated strands of projects: deployment projects focusing on technologies including carbon capture, usage and storage (CCUS) and hydrogen; Cluster Plan projects focusing on attracting investment and driving emissions reductions within industrial cluster regions; and multidisciplinary projects run through the Industrial Decarbonisation Research and Innovation Centre (IDRIC) focusing on knowledge-sharing between industries, research institutions, policymakers, and investors.
- In July, the Financial Stability Board (FSB) published a report, Stocktake on Nature-related Risks: Supervisory and regulatory approaches and perspectives on financial risk, identifying a number of challenges to developing methodologies for nature-specific guidance on financial risk including the lack of publicly available nature scenarios and modelling capabilities, pointing to the significant opportunity for the financial sector to promote and direct investment towards developing frameworks for assessing and mitigating nature-related financial risks.
- The Taskforce on Nature-related Financial Disclosures (TNFD) LEAP approach, which has been developed to identify and assess nature-related issues, can help organisations prepare for CSRD reporting and get ahead of the curve prior to any instigation of mandatory nature-reporting in jurisdictions relevant to their operations. With over 400 companies now committed to disclosing their material nature-related issues based on TNFD recommendations, there are a range of resources, including a ‘Talking to your board about TNFD’ presentation toolkit and ‘TNFD Board-Level Overview’ tools available to NEDs.
- The Government has now published a letter to nature conservation organisations, setting out a vision for working with the environmental sector to deliver building targets and planning system reform, stating “we want to use the value gained from enabling development to proceed quickly and smoothly to support nature recovery”. The Government’s approach looks to allow developers to start building “and then strike agreements on mitigation measures.” Some suggested ways of achieving this include the Wildlife and Countryside Link’s proposal for a ‘National Strategic Mitigation Pot’, which would be a fund in which developers pay into finance measures that offset pollution.
- In July, the Government announced a review of the 2023 Environmental Improvement Plan (EIP) – which is the first revision of the UK’s 25-year Environment Plan – to be completed by the end of 2024. The announcement follows the release of the Environmental Improvement Plan Annual Progress Report, which finds that the UK’s all-species indicator has shown an overall decline of around 69% from its starting value in 1970. Through the review, the Government is set to develop a new statutory plan for nature restoration and preservation which includes delivery plans to meet each of the Environment Act targets.
- Also in July, the Retail Soy Group, an offshoot of the British Retail Consortium (BRC) which comprises all major UK supermarkets, called on Defra to adopt the UK’s anti-deforestation regulation – the Forest Risk Commodities (FRC) legislation. Initially introduced by the previous government, the retailer consortium calls for Defra to adopt the FRC legislation within the first hundred days of this new government. The regulation would make it illegal for larger businesses operating in the UK to use key forest risk commodities sourced from land used or occupied illegally, and would require businesses to undertake annual due diligence exercises on their supply chains to ensure this transparency. A similar EU law, EUDR, comes into effect at the end of December 2024, which is expected to affect UK companies operating in the EU.
- The National Trust announced in August that it has achieved its aim of creating or restoring 25,000 hectares of priority habitat on its land by 2025. This target was set in 2015 in line with the charity’s conservation goals.
- The Wildlife Trusts published a report in August revealing that drought is now considered the biggest risk to UK nature reserves. The report calls on the UK Government to commit to a total investment in adaptation for nature and nature-based solutions of at least £3 billion per year up to 2030 – with a strong focus on strengthening partnerships that provide nature-based solutions and continuing the Nature for Climate Fund.
- The Institute for Public Policy Research (IPPR) also released a report in August, Driving 'Natural' Renewal, that finds that the UK is in the bottom 10% globally in terms of remaining biodiversity. The report cautions that the UK might fall short of its legal duty to protect 30% of the land and sea for nature by 2030, suggesting that “restoring nature must be a cornerstone of the Government’s national renewal strategy.” There has been international development in legislating for nature restoration, with the EU’s Nature Restoration Law, which entered into force in August, setting a target for the EU to restore at least 20% of the EU’s land and sea areas by 2030 and all ecosystems in need of restoration by 2050.
- In August, the World Benchmarking Alliance (WBA) updated its Nature Benchmark, assessing how more than 800 major companies across sectors are impacting nature and ecosystems. The research finds that, according to company data and performance from 2022 to 2024, only 5% of all companies have carried out an assessment of the impact of their operations on nature, and less than 1% have assessed their dependencies on nature.
- The Government announced a public consultation on proposed reforms to the National Planning Policy Framework (NPPF) and other changes to the planning system in July. The draft text for consultation, which looks to revise the NPPF “in order to achieve sustainable growth in our planning system” is available here. The consultation closes on 24 September.
- In August, SBTi launched the Buildings Sector Science-Based Target-Setting Criteria, a new framework for corporations and financial institutions that own, develop and finance buildings to determine how much and how quickly they need to reduce GHG emissions to remain aligned with the latest science-based targets, including the Paris Agreement. Published resources include an explanatory document, criteria assessment indicators, and a target-setting tool.
- In August, NBS released its Sustainable Futures UK Report 2024 which surveyed around 600 built environment professionals. The report finds a marked improvement in the UK construction sector’s focus on environmental sustainability, with 70% of construction projects now incorporating sustainability targets. While previous years’ reports found that lack of client demand was the main concern for pursuing green construction projects, this year’s finds price to be the primary obstacle to pursuing sustainability targets. CEO UKI of Byggfakta Group responded to the findings, “Many of the profession are predicting increased project starts, leading to a sense of optimism […] Both tax incentives and enforced regulation will ensure the UK can cope with climate change.”
Forthcoming policy publications
- In our next piece, we will cover the Chancellor’s Budget, which is set for 30 October 2024.
- We will discuss COP 16, the sixteenth Conference of the Parties (COP) to the Convention on Biological Diversity (CBD), which will take place from 21 October to 1 November 2024. This will be the first full biodiversity COP since COP 15 in December 2022, and the main agenda topics include assessing international action following the adoption of the Kunming-Montreal Global Biodiversity Framework.
- We will highlight the key outcomes from COP29 in Azerbaijan, the 29th COP of the UN’s Framework Convention on Climate Change (UNFCCC), which will be held between 11 and 22 November, and what these mean for the business community and board directors. This will include analysis of any additional commitments made by the UK Government in its updated NDC.