Exempting energy intensive industries from the indirect costs of the renewables obligation: consultation analysis

Analysis of information provided by respondents to the consultation where we were seeking views on the eligibility of Energy Intensive Industries to be exempted from indirect costs associated with renewable electricity policies.

3. Consultation Responses

A total of 3 responses were received from interested parties. During the consultation we arranged meetings with some interested stakeholders to discuss the topic. These meetings helped to informed our thinking on the way forward.

2 respondents gave permission for their responses to be made public. Published responses are available to see on the Scottish Government's consultation website at https://consult.gov.scot/energy-and-climate-change-directorate/widening-the-exemption/consultation/published_select_respondent.

Responses were received from the following type of organisations:

Trade Association 1
Energy Intensive Businesses 1
Energy Suppliers 1

A number of issues were addressed by respondents which are outlined below:

Issue Raised
Current rules risks "eligibility movement" - where a company's GVA increases, separate to energy usage, and makes the company ineligible 2
Competition with EU countries who already have a lower exemption threshold 1
Charging bill payers as opposed to tax payers 1
The impact of widening exemption of other bill payers 1
Increased burden on administrators if eligibility is widened 1
Divergence in Scotland creates market distortions for companies operating across the UK 3
Administrative burden of divergent schemes 1
The need for consistency for consumers 2


Email: andrew.mccall@gov.scot

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