01 Apr 2011
I can appreciate some of the reasons the CBI have raised this as untenable as a scheme and have no doubt that it is regarded by many organisations as an unwelcome layer of compliance to deal with. Precisely why the CBI beleive the CRC is untenable, though, is not clear, nor is the evidence available to support Rhian Kelly's quote.....it's simply too early.
I hold the view that the CRC scheme is a well founded scheme in terms of the concept but its architecture is fundamentally flawed. When the scheme was being developed by DEFRA I was unable, as a consultee, and as a participant of a meeting held by the British Property Federation to secure an snwer to my question of "What principles is this legislation going to be built upon?" I amplified this by asking for a clear answer to "Does the principle of 'Polluter Pays' apply?", also without a satisfactory and clear response.
Now it strikes me that failing to establish the principles at the beginning or allowing these to be lost somewhere along the line is where many of the unworkable aspects of the CRC emerge from.
I do also believe that the Chancellor made a good call with the Comprehensive Spending Review. By removing the recycling payment mechanism he has removed the risk of a potentially low performing public sector group of CRC participants paying into the scheme for emissions allowances and failing to recover these at the end of each cycle. This would, under the old CRC scheme, have resulted in public sector funds becoming a subsidy for higher performing private sector participants. The current mechanisms are still flawed however because the league table mechanics remain ill conceived.
Perhaps we should not be so hharsh on a government which has recognised a poorly crafed compliance regime and taken a fast decision to try to correct it; after all the previous administration had over a decade to create it and only just did so before they were ousted.