Energy UK’s response to Invest 2035: The UK’s Modern Industrial Strategy

Summary

The UK has a significant global competitive advantage across several low carbon energy subsectors in particular technologies associated with low carbon electricity (offshore wind, floating offshore wind, nuclear, long duration storage, flexibility and digital), Carbon Capture Usage and Storage (CCUS), hydrogen, heat and electric vehicles.

Businesses are ready to invest in supply chains and skills, but it is critical that they receive greater certainty of the size of future markets for low carbon goods and services. Greater clarity on future regulations, on building and heating requirements and more visibility of future renewable auctions can unlock significant investment.

The Government will also play a critical role in preparing for changes to the job market across the energy sector and its supply chain.It will need to support SMEs to take on apprentices, fund bodies to assess the skills and competency gaps, and support the retraining of staff to ensure we have a robust workforce.

In the face of volatile gas prices and rising carbon prices, businesses will need to decarbonise to remain competitive. There needs to be a comprehensive government strategy to decarbonise the full range of businesses across all sectors regardless of location, including greater support for SMEs to access technical advice and affordable finance. Corporate Power Purchase Agreements (CPPAs) enable businesses to drive investment in new low carbon capacity and fix some of their electricity costs longer-term.

Reforms to streamline the burdensome planning process are welcome but do not go far enough – there also needs to be additional resourcing put in place to ensure there is capacity to scrutinise applications. What is more, delays in securing grid connections act as a significant barrier to both the power sector and business decarbonisation and there needs to be significant investment ahead of need to ensure there is sufficient network capacity to enable economic development and decarbonisation. Expanding the network and accelerating connections at pace will be key going forward. There also needs to be greater flexibility and responsiveness in network funding to meet the demands of a rapid network buildout, especially at the distribution level. For large business connections at the transmission level, efforts are underway to speed up the connection queue by culling ‘zombie’ projects in the queue and aligning the queue with strategic planning.

The UK has the highest ratio of electricity to gas prices in Europe which is a major blocker to decarbonisation. Industrial strategy should look at this as a cross-cutting issue.

Finally,international partnerships are essential for advancing the UK’s industrial strategy and achieving Net Zero. Linking the UK ETS with the EU ETS is a priority to reduce trade barriers and minimise additional costs being placed on UK businesses.

Sector Methodology

1. How should the UK Government identify the most important subsectors for delivering our objectives?

The purpose of the industrial strategy is to target and support sectors that can disproportionately contribute to an increase in economic growth. Energy is central to a strong economy (as discussed in question 3), but merely delivering affordable, secure and reliable energy should not be the focus of industrial strategy for the clean energy industries subsectors. Subsectors in clean energy should be put into different categories:

1. Established technologies that should receive less focus: an industrial strategy cannot focus on everything. There are certain energy subsectors where the UK has no realistic prospect of being competitive, and these should not be the primary focus. The production of solar PV panels is a prime example, even though solar has a core role in delivering clean, affordable power.
2. Established technologies that the UK currently excels in or with high potential: some clean-energy technologies are well developed, such as offshore wind and nuclear. The UK already has a strong presence in parts of those supply chains and could expand that further with the right industrial policy.
3. Legacy sectors that can pivot to clean technology: the UK has a strong industrial base in sectors that will wind down in the transition to Net Zero, but have a strong potential to transition to a clean-tech role. This includes oil and gas pivoting to hydrogen, Carbon Capture Usage and Storage (CCUS) and floating offshore wind.
4. Emerging technologies where the UK could lead: new products and services will be developed as part of the energy transition. The UK is uniquely placed to lead some of them and export internationally. This is likely to be especially true for digital/smart parts of the clean energy sector. Those subsectors should be supported by the industrial strategy.

There will be trade-offs to consider, balancing the significant growth potential of emerging technology sectors with the critical role of legacy sectors in preserving jobs and sustaining local economies. Therefore, when considering subsectors, the Government should consider the following:

• Jobs/Productivity: to achieve its growth mission, the Government needs to support businesses to create good, high-paying jobs. That will only be possible in the most productive subsectors. These are likely to include developing and manufacturing high-value products and services, as opposed to lower value-add retail, installation and maintenance activities.
• Growth potential: an industrial strategy should be helping sectors that show signs of future success, rather than picking winners. It should only focus on subsectors with the greatest growth potential.
• The UK’s position in the global market: an industrial strategy should consider where the UK is best placed to succeed. While factors such as geography (e.g. availability of suitable CO₂ storage sites) and existing industries (e.g. automotive) will play a role, it is also important to work with the grain of UK economic strengths more broadly. For example, the UK is much more successful at exporting services than goods so it may be the case that an industrial strategy focuses more on energy-related services than supplying components on the global market.

2. How should the UK Government account for emerging sectors and technologies for which conventional data sources are less appropriate?

There is strong guidance on what the energy sector of the future will look like, especially from organisations such as the Committee on Climate Change and National Energy System Operator. Their Carbon Budgets and Future Energy Scenarios – respectively – give a good indication of what emerging technology is likely to play an increased role in the future and, therefore, might be ripe for support from the industrial strategy. There also needs to be engagement with companies leading projects who are at the forefront of developing these emerging sectors.

3. How should the UK Government incorporate foundational sectors and value chains into this analysis?

Energy is central to all sectors of the economy, and providing a clean, secure reliable energy supply is essential. Therefore, clean energy must be a cornerstone of the Industrial Strategy. And while these sectors may operate in silos, it is essential that we ensure that they work together and align to a common goal to deliver the industrial strategy, whilst they may in fact require delivery through separate policy streams, led by different government departments.

Ultimately, it may be possible (if undesirable) to deliver the energy transition with mostly overseas supply chains. There are separate considerations for the Government around the trade-offs between the greater reliance offered by domestic supply chains versus higher cost in some circumstances. That said, the industrial strategy should prioritise parts of the energy sector because of their economic contribution not their role in a clean energy system.

4. What are the UK’s strengths and capabilities in these sub sectors?

Lower carbon power and CCUS

The UK has significant potential for further renewable and low carbon power generation and storage technologies.

• Offshore Wind: The UK is primely placed to use offshore wind energy, with the North Sea being one of the UK’s best sources of consistent offshore wind energy as the area is extremely windy with a relatively shallow sea. Meeting the 2030 offshore wind target (50GW, including 5GW of floating) is forecast to employ 104,401 jobs, up from 32,257 today. A 60GW target of offshore wind would require a workforce of 120,000 – almost 90,000 new jobs.^[1]
• Floating Offshore Wind (FLOW): The UK’s floating wind industry could employ 97,000 by 2050 – with many of the jobs based in Scottish and Welsh ports, contributing £47bn to the GB economy.^[2] The UK already has one of the largest project pipelines in the world and is at a more advanced stage of development than any other country, with the seabed already leased for up to 24GW of capacity. We are well placed to lead this given existing skills and expertise in oil and gas.
• CCUS: Accelerating the deployment of CCUS, through securing FID for Track 1 projects, publishing a roadmap for Track 1 expansion and Track 2 projects could secure almost £30bn in private sector investment by 2030, deliver 70,000 new jobs and protect 77,000 more in existing carbon intensive industries.^[3] Track 1 CCUS cluster projects are an opportunity to deliver the world’s first large-scale integrated CCUS clusters. The technology is both important from a power system perspective and vital for the industrial decarbonisation that will be required to retain manufacturing capacity and jobs in the UK. For example, installing BECCS at Drax – the UK’s largest power station – could support up to 10,000 jobs at peak construction and safeguard over 7,000 direct and supply chain jobs during operation, mostly in the North of England.
• Hydrogen: It has potential as a flexible, dispatchable energy source making it a critical part of the UK’s future energy mix. The UK has one of the best salt cavern storage capabilities in Europe and could store hydrogen for neighbours in future. Hydrogen UK’s 2024 Economic Impact Assessment notes that the hydrogen economy will create over 320,00 jobs by 2030.^[4] Significant hydrogen infrastructure (new Hydrogen to Power (H2P) generation and conversion of existing CCGTs, new transportation and storage (T&S) infrastructure alongside repurposing of existing gas assets) will be needed to support the development of the hydrogen economy, including pipelines and storage to link supply and demand and provide energy security.
• Nuclear: With an established civil and defence nuclear sector uniquely suited to deliver nuclear innovation, the UK – alongside the US, China, and Canada – is amongst the most advanced countries in the development of SMR technology.^[5] The NIA has said there has been a 60% increase in the number of nuclear jobs in the last 10 years, driving the sector to 87,000 jobs, due to Hinkley Point C, Sizewell C, and the nascent SMR industry. Many of those are outside of London and the South East. Hinkley Point C alone tripled the amount of nuclear jobs from 8,500 in 2014 to over 27,000 in 2024, with around 10,000 being onsite. Hinkley Point C has brought £5.3bn of investment into the region,^[6] whereby 64% of its construction contract value has been awarded to British businesses and 1,320 apprentices have been trained so far.^[7]
• Long-duration energy storage: Being reliant on wind energy, the UK will require high levels of long-duration energy storage. This domestic demand, combined with good technological progress so far, means there is good scope for emergent technology developed here to be exported overseas (both longer duration lithium ion and emergent technology such as compressed air). UK innovators in this pace include Cheesecake (compressed air), Highview (liquid air) and Invinity (flow batteries). These companies are already having some success overseas where the technology is being used to ease thermal constraints with exports to Australia and the USA.
• Digital: Digitalisation will be needed to improve productivity across all sectors including energy and represents a significant opportunity for supply chain investment. Schneider Electric has invested £42 million in a new facility in Scarborough in North Yorkshire to manufacture electrical equipment to use in electricity networks, EV charging infrastructure and net-zero buildings. The UK is also developing a strong innovative energy flexibility sector. Piclo, Electron, Epex Spot, Kaluza and Kraken are all examples of innovators in the digital space that are reshaping the energy system and expanding overseas. Their software platforms are enabling distributed assets to access more markets and revenue in the power system.

Heat

The decarbonisation of heat will demand a broad range of technologies, some of which represent significant growth opportunities – such as the heat pump market and heat networks sector. The Climate Change Committee’s Sixth Carbon Budget ‘Balanced Net Zero Pathway’ estimates that 19% of low carbon heat installations in 2030 will be heat networks and that by 2050, 20% of heat could be distributed through heat networks.^[8] Achieving these targets could attract between £30 – £50 billion investment into the UK, directly creating between 20,000 and 35,000 jobs, while supporting local communities and regeneration.

Similarly, the CCC estimates that 57% of homes (16.2 million) will have a heat pump installed, the highest level in Europe in absolute and per capita terms.^[9] This creates a major opportunity for the UK to transition from one of Europe’s largest boiler manufacturers to one of its largest heat pump manufacturers. The UK already has a base of heat pump manufacturing including Kensa and Mitsubishi, with the potential for many of our boiler manufacturing firms to expand their European heat pump manufacturing capacity (Worcester-Bosch, Ideal) into the UK. The UK is already well placed as an earlier adopter and innovator in shared ground loops/geothermal networks and should build on this to create and export opportunities in both products and skills. There is considerable interest in the US for this technology driven by IRA and state-level support in places such as New York and Massachusetts. The Government’s 2035 target of 1.6 million annual heat pump installations requires a total workforce of 122,627 FTE individuals across all roles.^[10]

Heat batteries are also an important technology that should be considered within the subsector of heat. Indeed, heating technologies can provide storage and flexibility in and of themselves. For example, some heat networks have centralised thermal storage attached, or use multiple heat sources, allowing them to shift demand. Smart energy devices provide flexibility capacity, and this sector has the potential to save the country over £14bn in 2040 through reduced costs in system balancing, network reinforcement, and generation capacity. Several heat storage companies have facilities in the UK and are exporting. For example, Sunamp manufactures heat batteries in Edinburgh and exports to countries including Poland and the US. Tepeo manufactures heat batteries near Reading, exports to Jersey, and recently expanded its manufacturing site this year.

The roll-out of low carbon heating systems will require significant retrofitting of buildings to improve energy efficiency, driving significant activity primarily through increased SME activity. Analysis suggests that between 4-6 million additional jobs can be created retrofitting domestic and non-domestic buildings.^[11] Analysis by the IPPR finds that the distribution of jobs created by investment in retrofit would be concentrated in constituencies that are former or current industrial centres and coastal communities outside of London and the South East.^[12]

Transport

A reliable and decarbonised transport system does not only drives economic growth, but provides wider benefits such as social mobility, and clean air. It creates more resilient communities. More specifically, there are enormous benefits to investing in:

• Road freight (HGVs, vans etc): 1 in 14 people work in the automotive sector,^[13] with freight contributing £127bn to the UK economy every year.^[14] With road freight accounting for 17% of UK transport emissions, and given the value added to the economy, decarbonising freight should be a priority for the Government. In this sector, there are significant advancements in mobility technology which will attract further investment, such as autonomous driving, route optimisation technology, and fuel-efficient low-carbon vehicle designs. The fuelling opportunities for these technologies also offer attractive investment opportunities for the energy sector through electric charging and demand-side flexibility.
• Light Road Transport: Electric Vehicles: Domestic EV battery production and management is essential for the UK’s automotive industry, creating jobs as we transition to zero emission fleets. Not only gigafactories, but battery recycling, anode and cathode production help to reduce import dependency on fragile mineral supply chains, simultaneously lowering EV costs in the long term.

5. What are the key enablers and barriers to growth in these sub-sectors and how could the UK Government address them?  

Low-carbon electricity, CCUS and hydrogen

Key barriers:

• Supply chain: There exists significant supply chain challenges and limited domestic manufacturing capacity for critical components for many clean energy technologies which increases reliance on imports and exposure to international price fluctuations.
• Skills: The CCC estimates that anywhere between 135,000 and 725,000 net new jobs could be created in the UK by 2030 directly in low-carbon sectors, reflecting significant uncertainty in the number of roles required and displaced by the transition. Many of the sectors involved are already facing considerable skills gaps including renewable energy, building energy efficiency and manufacturing sectors.^[15]
• Offshore wind: A lack of visibility on future Contracts for Difference (CfD) auctions creates uncertainty, which impacts supply chain investment and project planning.
• FLOW: Insufficient port infrastructure for manufacturing and assembling floating turbines, combined with strong competition from European suppliers, limits the UK’s ability to fully capitalise on the economic potential of FLOW.
• CCUS and hydrogen: There is limited visibility on the future long-term deployment for CCUS (how much, when and where) creating uncertainty for investors in CCUS projects and uncertainty around the potential for blue hydrogen production. In the short-medium term there is uncertainty over future support mechanisms for additional CCUS projects and upcoming Hydrogen Allocation Rounds. Progress is needed on hydrogen transportation and storage (T&S) infrastructure and a business model for Hydrogen to Power (H2P).
• Nuclear: Urgent decisions are needed on the next wave of nuclear projects to keep up momentum and sustain growth in the sector.
• Long-duration storage: High capital expenditure and uncertain future revenues due to expected increased demand post-2030 present challenges. Support for less mature technologies is needed to complement government business models.
• Flexibility and digital: Current electricity markets weren’t designed for Demand Side Response and smaller assets and need to be reformed to allow participation, better value benefits and enable stacking of revenue from different markets. A lack of regulation on the Greenhouse Gas (GHG) requirements for low voltage switchgear (SF6) is preventing investment in low GHG alternatives.
• Grid expansion and connection: The lack of anticipatory investment in network capacity is a key barrier to growth in the clean energy sector and has led to rising system operation costs due to growing constraints. At the transmission level, connections reform is underway to prioritise and speed up key connections for low carbon generation to meet the Government’s decarbonisation objectives. While the reform effort will have indirect benefits that will speed up connections for large transmission-connected businesses, there is no comparable, coordinated effort to speed up large demand-side connections and improve investor certainty. At the distribution level, businesses who are trying to connect suffer from a lack of standardised connection processes and fees, transparent connection design and costing processes, with poor communication from distribution network connection and legal teams, and a lack of incentives for the distribution network operators (DNOs) to connect parties at pace. Much of this results from a lack of access to granular data about the distribution network and a lack of staffing for the DNO’s legal and connection teams.

Enablers

• Supply chain: Policies such as the CfD Clean Industry Bonus (CIB) create increased demand for UK components. Expanded and targeted support for the manufacturing of components where the UK has significant or potential capability, for example the Heat Pump Investment Accelerator Competition should be combined withenhanced international trading and cooperation(see question 24 below).
• Skills: See answers to questions 8 and 9 below.
• Offshore Wind: Publishing a multi-year CfD allocation schedule with annual capacity targets and market-responsive parameters would increase visibility and supply chain confidence, signalling steady demand and a reliable project pipeline. (A private note which explains this in further details has been shared with DESNZ and can be shared if needed.) It is also critical that the Government is ambitious in the upcoming Allocation Rounds (AR7 and AR8), particularly if they are to remain in line with targets for Clean Power 2030 and National Energy System Operator (NESO) estimates on what must be procured.
• CCUS and hydrogen: The recent funding for the first Hydrogen Allocation Round (HAR 1) in the Budget is positive, but securing Final Investment Decisions (FID) for Track-1 CCUS clusters in the North West and North East is crucial. Track-1 expansion announcements are needed on shortlisted projects for HyNet and on the next steps for the East Coast Cluster (ECC), HAR 2, and future allocation rounds are needed, along with clarity on hydrogen certification, T&S allocation arrangements, and Track-2 project timelines, particularly for Scotland and South Humber.
• Nuclear: Funding for Sizewell C in the Autumn Budget is a strong commitment; however, reaching FID remains essential. Additionally, decisions on SMR competition winners must proceed without further delays, following the published timetable to sustain supply chain confidence.
• Long-duration storage: The cap and floor financing scheme only supports more mature tech (Tech Readiness Level [TRL] 9 in the mainstream and TRL 8 for newer tech) which leaves a gap for emerging technologies. A continuation of programs such as the Longer Duration Energy Storage Demonstration (LODES) is necessary to bring projects to commercial readiness for cap-and-floor support. Companies supported from proof of concept to commercialisation include those mentioned above Highview (liquid air), Cheesecake (compressed air) and Invinity (flow batteries). More funding and further competitive rounds are needed to support promising emerging tech to the point where it could apply for cap and floor financing.
• Flexibility: There is a need to accelerate reforms to enable ‘revenue stacking’ across multiple products and services is needed. Revisions to metering standards should allow for lower accuracy requirements for domestic assets, with aggregated standards instead of individual asset-level requirements.
• Network connection: The policy and regulatory framework for electricity networks will need to act as an enabler and may need to evolve to reflect the scale and pace of investment programmes.Initiatives currently underway to speed up the connection queue should add greater certainty to investors in clean energy, though there remain concerns about some proposed measures within connection reform such as the proposal for a financial instrument of £20k/MW to prove the seriousness of a project. Similar to what is being pursued for supply-side connections, demand-side connections at the transmission level should be brought forward and prioritised based on government objectives as part of a broader industrial strategy. Large demand connections could be brought forward based on the importance of the Industrial Strategy or the Industrial Decarbonisation Strategy. This would need to be harmonised with ongoing reforms to the connections queue. At the distribution level, standardised connection processes, improved staffing in DNO legal and connection departments, greater incentives to accelerate connections through the General Standards of Practice (GSoPs) and access to more granular data for those intending to connect to help them plan their connections are needed.

Heat

Key barriers:

• Imbalanced energy costs: The current structure of placing policy costs on electricity bills further increases the ratio of electricity to gas prices, making the electrification of heat uneconomic. Shifting costs from electricity to gas bills would help incentivise cleaner energy use.
• Market and policy certainty: Manufacturers and investors must be provided with clarity on UK market growth in the low-carbon heat sector to give them the confidence to invest. Under the last government, heat policy was subject to major uncertainty and delays. Virtually all the major policies set out in the heat and building strategy (Future Homes Standard, boiler phase out, Clean Heat Market Mechanism, electricity price rebalancing) were not delivered by the previous Government. Although schemes such as the Green Heat Network Fund and Boiler Upgrade Scheme provide support, these could be more effective if aligned with clear decarbonisation goals, including adding heat batteries to the scope. Need for clarity on Future Home Standard, fossil fuel boiler phase-out ambitions and what is happening regarding heat in the non-domestic sector.
• Support for the supply chain needs to grow and be aligned with regulation to drive demand: The Heat Pump Investment Accelerator Competition is a welcome step, but the scheme was introduced in the absence of wider policy and funding very limited. This should be introduced in conjunction with major policies to unlock the market. Energy UK member Kensa has a heat pump factory in Cornwall and is looking to invest in a second facility but needs reassurance on future demand for its products.
• Planning regime inconsistencies: Recently announced changes to permitted development rights for new heat pumps are welcome however the planning system does not fully support low-carbon heat objectives, and further work to establish heat network zoning and effective and standardised local area energy planning is required.
• High Upfront Costs and Limited Green Finance: Homeowners and SMEs struggle to afford low-carbon heat installations. A more supportive fiscal approach, including VAT adjustments, would help reduce costs. Access to low-cost green finance would also support homeowners to invest. Research by Public First for Energy UK found that in 2023, 31% of surveyed households made no energy efficiency improvements to their home. Of these, 35% of people said that they couldn’t afford the upfront cost.^[16]
• Complex customer protections: The current customer protection landscape for low-carbon heat and energy efficiency improvements is overly complex, with multiple quality marks and schemes that lack strong consumer recognition. Simplifying these protections and improving consumer advice are essential for a positive customer experience.
• Insufficient spatial planning of heat decarbonisation: An area-based approach is essential to create the demand assurance required by communal heating technologies such as shared ground loops and heat networks that will be required to decarbonise a number of properties unsuitable for individual heat pump units.

Key enablers:

• Policy cost rebalancing: Rebalancing energy bills, in the way Energy UK has set out for the domestic sector, to lower electricity costs relative to gas would make low-carbon technologies more accessible, creating fairer price signals for consumers.^[17]
• Market certainty for heat decarbonisation: Major market signals such as the Future Homes Standard (FHS), energy policy cost rebalancing, long-term trajectory for the Warm Homes Plan, long-term certainty on schemes such as the Boiler Upgrade Scheme (BUS), Energy Company Obligation (ECO), and Green Heat Network Fund (GHNF) all creates the right environment for investment in UK manufacturing capacity.
• Stable, aligned funding programs: Consistent capital funding and alignment of grants (such as ECO, Warm Homes: Social Housing Fund and Home Upgrade Grant) with heat decarbonisation objectives would strengthen sector growth and demand, particularly if heat networks are integrated within wider decarbonisation schemes.
• Higher minimum standards for buildings: Introducing mandatory standards, such as a phased ban on new fossil fuel boilers by 2035 and accelerating the Future Homes Standard to commence in 2025, will drive demand for low-carbon heating solutions and boost the retrofit market. Any ban on new fossil fuel boilers must be done with adequate customer support in place.
• Manufacturing Investment Incentives: Heat Pump Accelerator Round 2 – times to coincide with impact of major policies such as FHS, Warm Homes Plan delivery to create incentives to base manufacturing here in the UK and enable more exports to the growing global market for heat pumps. The Government should look to run a second round of the Heat Pump Investment Accelerator Competition of £100 million in 2026 when major policies are in place and taking effect.
• Supportive green finance and fiscal policies: Expanding green finance options for upfront costs and aligning fiscal policies, such as VAT reductions, with low-carbon goals would increase affordability and uptake. This is especially important for small businesses, as access to finance is a key barrier for small to medium-sized (SME) businesses investing in decarbonisation. Energy UK has previously supported proposals for government-backed institutions, such as the British Business Bank, taking steps to support SMEs investing in low-carbon technologies to reduce energy consumption and increase competitiveness. ^[18] This support should be introduced alongside improved access to impartial and tailored information.
• Streamlined consumer protections: Simplifying customer protections and enhancing brand recognition for quality schemes will build trust and improve customer journeys in the low-carbon heat and energy efficiency retrofit market.
• Robust area-based planning for heat decarbonisation Formalising the role of Local Area Energy Plans (LAEPs) to map our heat requirements at a local level, and devise strategies and support mechanisms to deliver mass scale home upgrades/heat decarbonisation. This is essential for creating a localised supply chain, critical for delivery but also to bring down costs through economies of scale. NESO should provide a coordinating role, using Regional Energy Spatial Plans (RESPs) to bring together LAEPs from local authorities into regional plans.

Transport

Key barriers:

• Lack of infrastructure: The EV charging network, while expanding, lacks sufficient accessible charging spaces for vans and does not yet meet the scale needed for HGVs, limiting practical deployment.
• Grid connections: Integrating low-carbon technologies at the distribution level is hindered by poor price transparency, insufficient asset data visibility, and inconsistent processes across DNOs. At the transmission level, there is a lack of consideration of large demand connections and how to accelerate them.
• Planning limitations: The current planning sector is not designed to support the rapid deployment of new technologies, especially in areas such as Strategic Spatial Energy Plans and Permitted Development Rights, which are essential to scaling infrastructure effectively.
• VAT/Incentives: With much higher VAT rates on public EV charging compared to home charging, EV owners who cannot charge their vehicles at home are put at a significant disadvantage. Coupled with uncertainties around incentives such as the Truck Plug-in Grant, it creates financial disincentives and adds cost burdens for adopters.
• Data sharing: The lack of a clear energy data strategy leads to inconsistent data sharing practices, lengthy data exchanges, and non-standardised data sets, making it difficult for suppliers and third parties to efficiently share and utilize data.

Key enablers:

• Standards alignment of new technologies: Aligning with EU standards for HGV infrastructure and driving conditions (such as AFIR and TEN-T) will facilitate seamless movement of goods across borders, while updated regulations for e-mobility vehicles will address the unique needs of electric vans, which currently face the same MOT requirements as HGVs due to their weight. Streamlined standards for energy-smart appliances will also support timely manufacturing adjustments as regulatory frameworks evolve.
• Public and industry engagement: Engaging both the public and industry workforce on upcoming changes and their roles will be essential for a smooth transition, fostering greater understanding and readiness for the shifts expected in the next decade.
• Mandates for new vehicles: The ZEV Mandate has set firm and ambitious targets for car and van manufacturers. A mandate for the decarbonisation of new heavy goods vehicles could do the same.

Business Environment

6. What are the most significant barriers to investment? Do they vary across the growth-driving sectors? What evidence can you share to illustrate this?

The current planning system is a key barrier to growth, both for the energy sector and the wider economy. Improving the efficiency of this system could add a 0.3-1% productivity boost to the UK economy.^[19] While the Nationally Significant Infrastructure Scheme (NSIP) aims to expedite key projects, average approval times have doubled from two to four years since 2019.^[20] With initiatives such as Clean Power 2030, NSIP applications are expected to increase, and delays will worsen without intervention. Legal challenges have also been increasing since 2019, with Judicial Reviews increasing and local authority opposition curtailing over 6GW of renewable generation from being built since 2021.^[21]   

Environmental consenting requirements are further lengthening timelines. Data gathering under the Environmental Impact Assessment (EIA) requirements is often inefficient, resulting in complex, time-consuming applications. Some projects have produced planning documents up to 90,000 pages long.^[22] This complexity adds strain on both applicants and the planning inspectorate, making assessments more resource-intensive and drawing out the entire process.

The lack of certainty around how the planning system will resolve these challenges is diverting investment to countries with more efficient processes. In addition to planning and consenting barriers, delays in grid connection are a serious obstacle. Despite progress on reforms, some electricity generation projects are still waiting for connection licenses until the late 2030s, effectively holding back hundreds of gigawatts of potential capacity in the connection queue.

Electricity network connection is also a significant barrier for investment in existing and new businesses that need to increase the electrical capacity of their connection to the electricity network (see question 15 below). It will be vital to ensure there is sufficient network capacity available to enable future industrial growth in line with efforts to decarbonise business (and this should be a key consideration in future network planning).

Additionally, the UK Green Taxonomy will be vital for attracting sustainable, low-carbon investment and preventing corporate greenwashing. Energy UK believes that it will be essential for the UK to establish its own Taxonomy, aligned with global standards such as the EU’s, while tailored to the UK’s needs to uphold its climate leadership and green finance position.

An industrial strategy must also account for current and planned policies. While we support a UK Carbon Border Adjustment Mechanism (CBAM) from January 2026 to counter carbon leakage, it’s crucial to acknowledge that global competition already raises costs for technologies and supply chains, and a CBAM will add to project delivery costs. This impact should inform government decisions.

Uncertainty is also critically affecting the transport sector with policy uncertainty, because of changes to the Zero Emission Vehicle (ZEV) Mandate, or technology uncertainty with many technologies facing public and investor mistrust.

Finally, a decarbonised energy system is reliant on data sharing. From emerging driving technologies to energy smart appliances and the use of AI to optimise energy, technology is predicted to be the highest energy consumer in the future. If we want to decarbonise the energy system, we need to align the technology industry with the energy industry to ensure we have enough digital infrastructure in place to meet the demands of a digital, low-carbon economic whilst minimising its carbon footprint.

Business Environment – People and Skills

7. Where you identified barriers in response to Question 7 which relate to people and skills (including issues such as delivery of employment support, careers, and skills provision), what UK Government policy solutions could best address these?

Jobs in the clean energy sector vary significantly by region and filling skills gaps will require long-term joint public and private planning and investment. Greater long-term visibility of project and technology deployment and government funding commitments would improve confidence in technology rollout, enabling greater investment in skills provision and supply chains.

Energy UK supports the creation of Skills England to work with the Industrial Strategy Council, Migration Advisory Committee, local authorities, businesses, and unions. Skills England should identify regional skills gaps in the low-carbon sector and focus on retraining in areas where carbon-intensive jobs may decline. Partnerships with industry bodies, such as Energy & Utility Skills, will be crucial for expanding skills programs such as apprenticeships and employer-led schemes.

Skills England must also assess potential closures in advance and coordinate with businesses, educational institutions, unions, and communities to minimize job loss impacts. National oversight should be balanced with local authority and metro mayor powers to deliver tailored, region-specific skills programs.

Targeted support should be given to subsectors where specific skills are required as we transition to a low carbon energy system. For example, the Heat Training Grant has supported a growth in the number individuals who have successfully completed a training qualification to install heat pumps and needs to be maintained.^[23]

Consistent competency frameworks, such as the skills passport, will aid worker mobility, but require strong funding support. Promoting STEM at all educational levels is essential for sector diversity, and awareness campaigns should highlight pathways such as T-Levels to apprenticeships and university degrees. Energy UK is eager to work with government to ensure a relevant curriculum, clear career guidance, and a central portal for energy career information.

Expanding on the previous post-16 skills strategy will address barriers to skill acquisition, improve training quality, and embed sustainability and digital skills in programs. Successful public-private partnerships, such as Humberside’s collaboration with Ørsted and Siemens Gamesa, show the value of regional cooperation in developing skills, fostering regeneration, and creating jobs.

8. What more could be done to achieve a step change in employer investment in training in the growth-driving sectors?

Businesses are ready to invest in training and skills for both existing employees and new apprentices, but this has been challenging due to sudden changes in policy and lack of long-term clarity on the transformation of the energy system. There needs to be clear, long-term clarity on government policy and regulation to enable businesses to plan and develop training programmes to fill skills gaps associated with the delivery of low carbon projects and infrastructure. Provision of clear policy direction across all energy areas including hydrogen, electric vehicles, CCUS, heat and power and greater regional planning is required. For example, greater clarity around building standards in both domestic and non-domestic sectors would provide greater confidence in the new build and retrofit market, enabling businesses to invest in training staff to install and maintain low carbon heating systems.

To address the alarming fall in the numbers of apprenticeships, Government needs to accelerate plans to reform the Apprenticeship Levy into a Growth and Skills Levy and provide greater clarity on how any underspend is to be used. We welcome the proposal to offer shorter or more modular courses, make the scheme more flexible so it can be better adjusted to business needs and easier to use to increase uptake. Alongside this the Government must address the broader, structural barriers to apprenticeships. These include a lack of limited careers advice and awareness of different apprenticeship delivery options, insufficient financial support, and opaque funding structures.^[24] The Government should increase the Apprenticeship Incentive Payment for employers from £1,000 to £3,000 and increase the Apprenticeship Rate to make the scheme more attractive to businesses and applicants. The Government could also consider ring-fencing a proportion of the levy to workers to re-skill in low carbon areas such as installing heat-pumps. The Growth and Skills Levy should be used to fund external modular programmes developed in conjunction with industry eg those under the Auto Upskilling Project.

Energy UK welcomes the Government’s proposals for a youth guarantee of access to training, apprenticeships, and employment support and want to see further details on how this might be delivered.

Retraining existing staff will also be vital and additional support including match-funding is needed to help businesses cover the cost of training and backfilling. Government should consider the model used in Germany where the government funds the classroom component, while employers cover the costs of work-related training. This will be particularly important for SMEs who often lack the resources to retrain staff but will play an essential role in the decarbonisation of the energy sector – for example, those involved in building retrofit and changes to heating systems.

Government could consider requiring businesses to conduct detailed skills audits to understand how the skill set of their workforce will change over time and what skills will be needed.

Business Environment – Infrastructure

9. Where you identified barriers in response to Question 7 which relate to planning, infrastructure and transport, what UK government policy solutions could best address these in addition to existing reforms? How can this best support regional growth?

The new Government has initiated planning reforms, including coordination on the Electricity Act with the Scottish Government, and a Welsh consultation on the Infrastructure (Wales) Act 2024.[25] [26] Energy UK welcomes the reintroduction of onshore wind to England’s planning regime and supports the NPPF proposals, with plans to respond to Scottish and Welsh consultations soon. However, more is needed to expedite consenting timelines and simplify processes. While additional planning officers from the Autumn Budget are a positive step, ongoing investment will be crucial. Updates to the National Policy Statements should emphasize both network and generation priorities, particularly to accelerate transmission and distribution build-out for Clean Power 2030.

A thorough review of land rights and consenting for network infrastructure across Great Britain is essential, with strong community engagement to ensure benefits are tailored locally. This engagement must be collaborative, not top-down, to support local decision-making. Planning reforms should align with other policies, including the NESO’s new spatial planning initiatives (Strategic Spatial Energy Plan (SSEP), Centralised Strategic Network Plan (CSNP) and the RESPs), and improve environmental consent processes by requiring decisions within six months for NSIP permits. Enhanced data sharing and standards for Judicial Review would streamline Environmental Impact Assessments (EIA) without compromising outcomes. Additionally, reforms to Permitted Development Rights are needed to facilitate the installation of EV chargers, and small-scale solar projects.

10. How can investment into infrastructure support the Industrial Strategy? What can the UK Government do to better support this and facilitate co-investment? How does this differ across infrastructure classes?

There needs to be significant CCUS and hydrogen infrastructure investment to enable both energy system and industrial decarbonisation. Improving the competitiveness and decarbonisation of British businesses also depends on delivering robust electrical transmission and distribution infrastructure. Beyond making electricity cost-competitive, securing reliable grid connections is essential. Although the current price control system has encouraged investment, it needs greater flexibility and responsiveness to meet the demands of a rapid network buildout, especially at the distribution level.

To support growing connection requests and necessary upgrades, it is essential that the regulatory framework for Distribution Network Operators (DNOs) adapts accordingly, ensuring they are well-resourced and capable of meeting high support standards. While penalties for DNOs may drive accountability, the focus should be on establishing an enabling regulatory environment to incentivise good performance, speedy connections and quality connection offers as well as ensuring that sufficient resources are in place to manage the increasing workload. Ofgem’s intensified scrutiny on spending is a step forward, but an adaptive approach to planning the network’s development, rather than frequent reopeners or rigid upfront plans, is necessary to support anticipated buildout volumes for the next price control period.

The cost benchmarking for RIIO-ED3 also poses challenges, with supply chain uncertainties, amplified by global events, risking the obsolescence of current cost assessments. To mitigate these risks, Ofgem should engage closely with industry and government, aligning business plans with real-time conditions and market dynamics.

Effective coordination across utilities remains crucial – not only across sectors such as water, gas and telecoms but also with government alignment to support integrated planning. Government leadership in coordinating ambitions across sectors will underpin utility-led integrated plans, and market reforms, price signals, and infrastructure upgrades must be aligned to support a truly interconnected infrastructure.

Regulatory uncertainty remains, particularly concerning future demand locations, technology adoption rates, and the role of existing infrastructure, including gas, hydrogen, and CCUS. Methods such as DEFRA’s adaptive planning for water projects and the Department for Business and Trade’s work on Smarter Regulation offer useful frameworks for tackling regional planning complexities in the energy sector.

Business Environment – Energy

11. What are the barriers to competitive industrial activity and increased electrification, beyond those set out in response to the UK Government’s recent Call for Evidence on industrial electrification?

Energy UK concurs with the Government’s assessment of barriers to electrification. Options to reduce electricity costs for non-domestic users could include moving legacy policy costs into general taxation in a way that is fiscally sustainable and protects domestic customers. Energy UK is exploring options in these cases to build on our work looking at the domestic sector. ^[27] Ideally, these would be moved into general taxation however a blended approach may be achieved through a mixture of increasing gas prices in some sectors.

Network connection challenges, both at the transmission and distribution levels, create significant hurdles for businesses and generators. Long connection times and current network charges remain problematic, particularly after the Targeted Charging Review removes triad avoidance, which has reduced demand-side response (DSR) incentives and added substantial costs for many users. We advocate for carve-outs to assist affected end users and for an enduring mechanism that rewards DSR when it helps lower network investment.

Electrification support will remain essential, especially for smaller companies that struggle with capital expenses and find it challenging to access the Industrial Energy Transformation Fund (IETF). Additionally, operational support will vary by sector and type of company, so flexible assistance is needed.

Beyond electrification (which is suitable for a growing range of industrial applications but not viable for all and does not tackle process emissions), wider decarbonisation barriers persist, making businesses vulnerable to rising carbon prices and energy volatility. This includes a need for clarity on infrastructure for hydrogen, carbon capture and storage, and CO₂ transport from dispersed sites.

Carbon pricing provides a technology-neutral incentive for industry to decarbonise. To act as an effective incentive, the carbon price under the UK Emissions Trading Scheme must be robust, with any increase over time being steady and predictable to aid the industry in its investment decisions in decarbonisation. Energy UK supports the linking of the UK and EU Emissions Trading Schemes to create a larger, more liquid market and prevent barriers to trade between the UK and EU, particularly for goods impacted by the EU’s Carbon Border Adjustment Mechanism (CBAM), with particular focus on trade between Great Britain and Northern Ireland. 

Introducing a quantity-based supply adjustment mechanism in the UK Emissions Trading Scheme will also help to raise prices from currently low levels and smooth price rises in future. To expand carbon price incentives for industry, there will be an opportunity to phase out the emissions trading allowances that are issued for free for the UK-based manufacture of certain products, when the importing of those products comes under the scope of the UK’s own CBAM when this is introduced in 2027. Energy UK urges the Government to publish its responses to the ‘UK Emissions Trading Scheme: future markets policy‘ and ‘UK Emissions Trading Scheme: free allocation review‘ consultations to provide certainty to industry regarding its intentions, alongside announcing an intention to link carbon markets with the EU at the earliest opportunity.^{[28] [29]}

Supporting the adoption of all low-carbon technologies is crucial. Businesses require a comprehensive decarbonisation package that includes free technical audits, increased access to grants and loans for SMEs, reformed capital allowances and business rates, and clear regulations (eg clarity on Future Buildings Standard (FBS), non-domestic Minimum Energy Efficiency Standards (MEES), and permitted development rights). To improve the energy and carbon performance of commercial building there needs to be reforms to non-domestic EPCs alongside introduction of the previously proposed performance-based policy framework. Additionally, improvements to policies such as the Industrial Energy Transformation Fund (IETF), Supercharger and further changes to Climate Change Agreements would enhance their effectiveness in supporting industry-wide decarbonisation efforts.

12. What examples of international best practices to support businesses on energy, for example, Purchase Power Agreements, would you recommend to increase investment and growth?

International approaches to decarbonisation provide various forms of government support for companies to electrify and reduce emissions. The US uses substantial funding under the Inflation Reduction Act to drive decarbonisation and strengthen domestic industries, emphasising a “just transition.” France balances incentives and regulations with tax credits and financial tools for low-carbon technology, alongside obligations such as reducing energy consumption by 40% in the services sector by 2030. Germany’s significant package includes Carbon Contracts for Difference, energy efficiency funding, and protections for economically critical industries. Italy’s Transition 5.0 initiative offers tax credits tied to energy-saving improvements, while the EU directs ETS revenue to national decarbonisation efforts through the Modernisation and Innovation Funds.

SME support programs are key in several regions. Germany’s Federal Funding for Industry and Climate Protection and Italy’s New Sabatini scheme offer SMEs incentives and low-interest financing for energy-efficient upgrades. In Scotland, the Business Energy Scotland program provides free assessments and interest-free loans up to £100k, cutting participant energy costs by up to 60%. ^[30] The scheme has provided Scottish businesses with over £26 million in loans for more than 950 projects.^[31]

In terms of supporting Corporate Power Purchase Agreements (CPPAs), Energy UK has published a report on measures to grow the CPPA market.^[32] Internationally several countries are helping businesses lock in long-term electricity pricing, particularly those with strong ESG goals. Germany and Spain lead in CPPA activity, with Spain’s FERGEI guarantee scheme supporting PPAs for companies lacking credit. Other countries with PPA guarantee schemes include Norway, offering price certainty to industry, and France, where Bpifrance launched a fund in 2023 to back CPPAs for renewable energy projects. Reforms to the Renewable Energy Guarantee of Origin (REGO) scheme are required to help unlock the CPPA market and could increase the supply of more time-matched or firm products required by industrial end users to reduce the exposure to volatile wholesale prices.

Business Environment – Regulation

13. Do you have suggestions on where regulation can be reformed or introduced to encourage growth and innovation, including addressing any barriers you identified previously?

Businesses in the energy industry spend a considerable amount of time and resource navigating the complex industry regulations and market arrangements. This can often incur significant costs which ultimately diverts resource away from innovation. We suggest that existing policy reform including the Review of Electricity Market Arrangements (REMA) and SSEP should be prioritised and streamlined to produce the most efficient pathways to overcoming barriers.

Business Environment – Crowding in Investment

14. What are the main factors that influence businesses’ investment decisions? Do these differ for the growth-driving sectors and based on the nature of the investment (e.g. buildings, machinery & equipment, vehicles, software, RDI, workforce skills) and types of firms (large, small, domestic, international, across different regions)?

In the short-term, implementation of policy that supports investment such as Track 2 of the cluster sequencing program and the Long Duration Energy Storage (LDES) cap and floor mechanism are critical as they directly influence business’s ability to take Financial Investment Decisions (FID) on projects. Greater longer-term visibility of the deployment of different technologies and Government funding is also needed to give businesses the confidence to invest.

Business Environment – Trade and International Partnerships

15. How can international partnerships (government-to-government or government-to-business) support the Industrial Strategy?

International partnerships are essential for advancing the UK’s industrial strategy and achieving Net Zero. Many countries are also competing for critical components such as transformers, cables, and microchips to expand energy systems. To secure the supply chains needed for decarbonisation, the UK must collaborate with global partners with whom we share our Net Zero ambitions. Establishing a UK-EU trade and technology council, similar to the EU-US model, would be one way to promote dialogue between both parties and further support industrial development and secure supply chains.

The Government should announce an intention to link the UK and EU emissions trading schemes as soon as possible. This is an action supported by stakeholders from across the economy and will provide certainty for investment, reduce trade barriers and prevent up to £800m being paid annually to the EU by UK businesses under the EU’s carbon border adjustment mechanism (link here). Linking the UK and EU carbon markets will also protect the island of Ireland from further uncertainty created by the creation of both UK and EU carbon border adjustment mechanisms (operational in 2027 and 2026 respectively).

Finally, expanding clean energy MoUs with countries such as Ireland, Denmark, and Belgium, or creating a UK Green Alliance model, could strengthen cooperation on clean technology, regulatory alignment, R&D, and green finance.

Place

16. What public and private sector interventions are needed to make strategic industrial sites ‘investment-ready’? How should we determine which sites across the UK are most critical for unlocking this investment?

One of the key areas that both the Government and the private sector can help with is accelerating connection times for businesses trying to decarbonise through electrification by:

• Ensuring the plans for distribution are sufficiently anticipatory and adaptable to local uncertainties at the distribution level.
• Standardisation of markets and connection processes across DNOs.
• Removing barriers to better utilisation of flexibility, without disincentivising necessary network buildout.
• Improving the quality of and access to data at the distribution level to allow speedier delivery of connections and upgrades and better use of the existing capacity on the network.
• Improving the clarity of the state of connections and issues behind delays to connections at distribution level, and taking actions needed to address this such as streamlining planning barriers, ensuring adequate organisational resourcing in local authorities and DNOs, and tightening DNO delivery obligations for grid works.
• At the transmission level, connections for large demand users should, similar to what is being done on the supply side, be prioritised and have their connections brought forward based on their alignment with strategic economic objectives such as through the Industrial Strategy and Industrial Decarbonisation Strategy.

Another key area to maintain investor confidence in electrifying businesses is to ensure network charges are as competitive as possible whilst ensuring that costs for the maintenance, operation and building of the system are fairly distributed.

Ofgem is currently reviewing policy on standing network charges, including the ‘residual’ network charges that have increased notably for businesses since 2022 because of the Targeted Charging Review (TCR). At the same time, work on the network charges for the distribution network, on pause since 2023, is due to restart with the intention to improve the fairness of the charging regime.

Currently, the debate on how to reform residual network charges is zero-sum. Reducing them for one party means other parties somewhere in the system must inevitably bear the cost. There is a need for a solution that can benefit businesses operating in GB whilst limiting the need to redistribute network costs to other parties. One option could be to allow network demand users to see some of their residual charges reduced by displaying clearly, under strict Ofgem approved guidance and calculation methodology, that various on-site flexibility measures are quantifiably reducing the costs of network buildout and maintenance.

Because the reduction in residual charge is based on an accounted-for system-wide reduction in network buildout and maintenance costs, the residual charge would theoretically not need to be redistributed to other consumers. In this way, network costs can remain competitive for GB businesses even as the grid expands. In terms of site identification, this must be determined, through the priorities of the Industrial Strategy and Industrial Decarbonisation Strategy, by examining which sites require the most intervention to remove legislative and cost barriers.

Inevitably, there will be some businesses that cannot flex their energy consumption in order to reduce residual charging in this way. In these cases, a strictly defined lists of types of electricity demand sources that are essential either for GB’s decarbonisation or economic growth should see their residual network charges written down or exempt. The list of demand sources must be based on a cost benefit analysis of the impact to consumers of enabling the profitability of these businesses against redistributing the residual network costs onto other consumers’ energy bills.

16. How should the Industrial Strategy accelerate growth in city regions and clusters of growth sectors across the UK through Local Growth Plans and other policy mechanisms?

The key to the success of the UK’s Industrial Strategy in local areas is through the harmonisation of policy aims of other emerging regional initiatives. Crucial among these include the RESPs. Access to abundant and affordable energy will be key to enabling the industries of the future, especially those clustered in dense populations and growth centres. Therefore, ensuring the harmonisation of local decarbonisation and business strategies is essential.

For more information, please email shauna.dubler@energy-uk.org.uk.

[1] Offshore Wind Industry Council (2023), Offshore Wind Skills Intelligence Report

[2] Renewable UK (2024), Floating Wind: Anchoring the next generation offshore

[3] CCSA (2024), CCUS priorities in first 100 days of the new government   

[4] Hydrogen UK (2024) Economic Impact Assessment for the Hydrogen Sector to 2030

[5] Enerdata (2024) SMR Technology Trends Worldwide

[6] New Civil Engineer (2024) New nuclear projects drive record-breaking 87,000 jobs in sector

[7] EDF (2024) Realising the socio-economic benefits

[8] CCC (2020), The Sixth Carbon Budget, The UK’s path to Net Zero

[9] IPPR (2024), The heatwave unlocking the economic potential of UK heat pump manufacturing

[10] Heat Pump Association (2024), Projecting the future domestic heat pump workforce

[11] RICS (2020), Retrofit: saving energy and creating jobs

[12] IPPR (2022), Train local, work local, stay local retrofit, growth and levelling up

[13] SMMT (2024) Written evidence from The Society of Motor Manufacturers and Traders SMMT

[14] DfT (2022) Future of Freight: A long term plan

[15] Imperial Energy Futures Lab (2024), Net-Zero Skills Jobs, skills and training for the Net-Zero energy transition

[16] Public First (2023), Public First Polling for Energy UK

[17] Energy UK (2024), Policy solutions: Taking immediate action to make bills affordable this winter

[18] Energy UK (2023), Small business, big impact Enabling SME energy customers to decarbonise their demand

[19] National Infrastructure Commission (2024), James Heath: urgent planning reform needed to remove “binding constraint” on UK’s economic future

[20] Department for Levelling Up, Housing and Communities (2023), Getting Great Britain building again: Speeding up infrastructure delivery

[21] DESNZ (2024), Renewable Energy Planning Database: quarterly extract

[22] Department for Levelling Up, Housing and Communities (2023), Getting Great Britain building again: Speeding up infrastructure delivery

[23] Heat Pump Association (2024), Projecting the future domestic heat pump workforce

[24] Aldersgate Group (2024), Beyond the levy: ensuring the effective implementation of the growth and skills levy

[25] DESNZ (2024), Electricity Infrastructure Consenting in Scotland

[26] Welsh Government (2024), Implementing the Infrastructure (Wales) Act 2024

[27] Energy UK (2024), Policy solutions: Taking immediate action to make bills affordable this winter

[28] DESNZ (2023), UK Emissions Trading Scheme: free allocation review

[29] DESNZ (2023), UK Emissions Trading Scheme: future markets policy

[30] Energy Saving Trust (2024), Business Energy Scotland Case Studies

[31] Energy Saving Trust (2023), Supporting Scotland’s Green Ambitions Energy Programmes delivered by Energy Saving Trust on behalf of the Scottish Government

[32] Energy UK (2024), Maximising the Corporate Power Purchase Agreement market