The submissions to official inquiries and similar publications are listed below. Papers outlining EIUG’s policy positions are available in the Position Papers section. Press releases are available in the Press section.

02.05.18Response to Ofgem RII0-2 Framework Consultation
EIUG supports maintaining simplicity, making use of exiting forums for stakeholder consultation and extending competition in the RIIO-2 price control
16.02.18Comments on Ofgem Forward Work Plan 2018-19
EIUG welcomes commitments to action on network costs, Brexit preparedness and security of supply
20.12.17Response to BEIS Call for Evidence on Cost of Energy Review
EIUG supports policy simplification, market-led power decarbonisation, action to reduce network costs
and benchmarking to ensure international competitiveness
14.12.17Response to IGEM Questionnaire on Changes to Gas Quality
EIUG says impacts must be considered across a full range of industrial processes and urges the survey to be extended so more companies can respond
04.09.17Response to Ofgem Open Letter on RIIO-2 Framework
EIUG welcomes proposals to strengthen the consumer voice in business plan development and price control decisions
18.07.17Response to National Grid consultation on System Needs & Product Strategy
EIUG supports simplification and appropriate standardisation of products to encourage wider participation in provision of balancing services
30.05.17Response to Scottish Government consultation on Draft Energy Strategy
EIUG argues for focus on cost effective decarbonisation, and caution over energy efficiency and renewable targets
04.05.17Response to Ofgem consultation on Targeted Charging Review
EIUG supports the proposed Significant Code Review and establishment of Charging Coordination Group, which should include representation of industrial energy user and co-generation interests
26.04.17EIUG Manifesto for 2017
Issues an incoming government must consider so UK energy intensive industries can thrive in global markets, including early repeal of the Carbon Price Floor, extension of the compensation package, and realistic and achievable decarbonisation targets
09.04.17Response to BEIS Green Paper – Building our Industrial Strategy
EIUG says secure, internationally competitive industrial energy supplies should be a key objective of industrial strategy
16.02.17Response to Labour Party Industrial Strategy consultation
EIUG calls for balance in energy and climate policy to ensure decarbonisation, not deindustrialisation, occurs within the UK economy
10.02.17National Infrastructure Assessment Call for Evidence
EIUG calls for market-led, least cost decarbonisation of heat and maintenance of internationally competitive
baseload and dispatchable electricity generation
08.02.17Coal Generation in GB: The pathway to a low-carbon future
EIUG argues for flexibility in coal phase out to minimise consumer impact, noting BEIS’ Impact Assessment shows
zero benefits to the UK economy
20.01.17Representation on Spring Budget 2017
EIUG calls for HMT to continue cap on decarbonisation subsidies after 2020/21, clarity over their likely impact on industrial energy users,
and assurance over continuity of relief from RO/FIT costs
12.01.17Response to BEIS/Ofgem call for evidence on Plan for a Smart, Flexible Energy System
EIUG calls for intermittency costs to be internalised, and for safeguards to ensure access to smart metering data does not compromise safety or commercial confidentiality
07.10.16Representation to HMT on Autumn Statement 2016
EIUG calls for abolition of the Carbon Price Floor and assurances over the EII compensation package
30.09.16Submission to House of Lords Economic Affairs Committee inquiry into The Economics of UK Energy Policy
EIUG argues for return to market-led energy policy to address international competitiveness concerns
27.09.16Submission to BIS Committee Inquiry into the Government's Industrial Strategy
EIUG calls for strategy to include a commitment to maintain secure, internationally competitive energy supplies and better alignment between industrial and climate policy objectives
23.09.16Response to Ofgem open letter on charging arrangements for embedded generation
EIUG calls for a comprehensive, formal review of transmission charging so impacts on industrial co-generators and other stakeholders can be properly analysed and taken into account in any reform proposals
14.09.16Submission to Energy & Climate Change Committee inquiry into implications of Brexit for UK energy policy
The UK must retain non-discriminatory, tariff-free access to the single EU energy market, but take advantage
of no longer being bound by economically damaging EU renewable targets.
26.08.16Response to BEIS consultation on EII exemption from indirect costs of contracts for difference
EIUG preference is for EIIs to be directly responsible for repaying any over-exemption, rather than their suppliers
22.08.16Submission to Energy & Climate Change Committee inquiry into implications of Brexit for UK climate policy
Climate policy must not leave UK energy intensive industries at a competitive disadvantage relative to their EU and global competitors.
26.05.16Response to DECC consultation on exempting Energy Intensive Industries from the costs of the RO and FITs
EIUG supports the exemption, but calls for eligibility threshold to be lowered to ensure a level playing field for UK EIIs
07.04.16Comments on CMA Energy Market Investigation Provisional Decision on Remedies
EIUG supports CMA recommendations for DECC to publish transparent impact assessments on cost implications of CfD budget allocation between technologies, and before awarding CfDs outside the auction mechanism
06.11.15Response to HMT consultation on Reforming the business energy efficiency tax landscape
Exemptions and tax relief for energy intensive industries must be maintained to the extent permitted in the EU Energy Taxation Directive to prevent carbon leakage
12.08.15EIUG submission to Energy & Climate Change Committee inquiry on priorities for holding Government to account
Suggestions include prospects for security of supply, industrial decarbonisation, impact of climate policies on energy prices, and likely implications of the 5th Carbon Budget for UK energy users
01.06.15Response to Committee on Climate Change call for evidence on 5th Carbon Budget
EIUG urges caution in setting fifth carbon budget, recognising the continuing lack of global commitment to emission reductions, slower than expected deployment of nuclear and CCS in the UK, and need to preserve industrial competitiveness to avoid carbon leakage.
17.03.15Comments on Ofgem Simplification Plan 2015-16
EIUG asks for Ofgem communications to highlight key decisions, proposals or consultations of greatest interest to industrial energy users, and include high level, plain English consultation summaries
23.10.14Response to BIS consultation on Electricity Intensive Industries’ Eligibility for Relief from Indirect Costs of Renewables
Eligibility should be broadened, and compensation levels increased in certain cases, so UK energy intensive industries are not disadvantaged with respect to their EU competitors
18.09.14EIUG Manifesto for 2015
Issues an incoming government must consider to prevent carbon leakage in energy intensive industries, including early repeal of the Carbon Price Floor, extension of the compensation package, and environmentally responsible development of shale gas
09.05.14Response to Ofgem consultation on proposals for regulating non-domestic Third Party Intermediaries
EIUG supports licence condition on suppliers only to work with TPIs accredited to the code of practice
14.02.14Response to DG Competition consultation on Draft Guidelines on environmental and energy State aid for 2014-2020
EIUG calls for a more flexible approach to determine state aid eligibility, allowing full compensation for the cumulative impact of climate policies on trade exposed energy intensive industries
12.02.14Response to DECC consultation on Competitive Allocation of Contracts for Difference
EIUG supports moving to market based RO and CFD pricing for mature technologies at the earliest opportunity
10.02.14Budget submission - Compensation Package for Energy Intensive Industries
EIUG calls for a clear signal on the duration of the compensation package, compensation for the impact of renewable subsidies, and freezing the trajectory of the Carbon Price Floor
08.02.13Response to DECC consultation on Electricity Demand Reduction
EIUG questions the practicality of market wide interventions, pointing out that intensive industries already have adequate incentives to maintain and improve energy efficiency, not least through Climate change Agreements
23.11.12Memorandum to Environmental Audit Committee Inquiry into Energy Intensive Industries Compensation Scheme
EIUG highlights limited scale and scope of compensation compared with more generous support available to EU competitors, criticising the proposed use of an inappropriately low emissions factor that would under compensate UK industry
01.10.12Evidence to Energy & Climate Change Committee on Impact of Shale Gas on Energy Markets
EIUG urges government to support the development of shale gas in the UK, noting its impact on energy markets and the consequent boost it has given to the competitiveness of energy intensive industries in the USA
04.05.12Response to BIS Call for Evidence on Compensation for the indirect costs of Carbon Price Floor & EU Emissions Trading Scheme
EIUG supports compensation for electro-intensive installations in trade-exposed sectors to address carbon leakage risk
04.04.12Response to Energy Efficiency Deployment Office Call for Evidence on Energy Efficiency
EIUG calls for a more formal link between support measures for industrial energy efficiency and revenues from energy taxation
14.03.11The Cumulative Impact of Climate Change Policies on UK Energy Intensive Industries – Update Against New Government Policy
Report by Waters Wye Associates for EIUG on the latest DECC and Treasury proposals for unilateral increases in UK energy and carbon costs
Response to DECC consultation on Electricity Market Reform
EIUG gives qualified backing for Contract for Difference Feed in Tariffs for low carbon generation but is sceptical about the case for Capacity Payments and Energy Performance Standards
11.02.11Response to HM Treasury Carbon Price Support Consultation
EIUG cannot support HMT's carbon price proposals without measures to mitigate the cumulative impact of this and existing climate policies on industrial electricity prices, which has yet to be transparently disclosed.
01.02.11Second ENA consultation on the EHV Distribution Charging Methodology
EIUG calls for a review of reactive power charging, capping of overall charging and phased implementation of major cost increases for individual Extra High Voltage industrial sites.
27.07.10The Cumulative Impact of Climate Change Policies on UK Energy Intensive Industries – Are Policies Effectively Focussed?
Report by Waters Wye Associates for EIUG and TUC on vulnerability of intensive industries to massive unilateral increases in UK energy and carbon costs
16.07.10Response to Energy Networks Association consultation on Extra High Voltage Charging Methodologies
EIUG criticises the inadequate timescale for the consultation, and calls for greater notice and phasing of future price increases to EHV users
01.07.10Response to DECC Minister Lord Marland on Reducing Red Tape
UK climate policies are unnecessarily complex and costly to manage; future impact assessments should look at the cumulative effect of related climate policies on energy intensive users specifically
26.04.10Response to Renewable Heat Incentive Consultation on the proposed RHI financial support scheme
EIUG agrees with DECC's impact assessment which shows 'the RHI as a whole fails to pass the cost effectiveness test' and calls for modifications to limit the burden on intensive users exposed to international competition
22.02.10Response to consultation on draft National Policy Statements on Energy Infrastructure
EIUG urges swift adoption of the NPS to facilitate timely energy investment, but queries DECC’s grossly unrealistc ambitions for renewables, especially wind, which should be amended so they can be taken seriously
30.11.09Response to Ofgem Project Discovery Consultation
In light of Ofgem's analysis, EIUG calls on government to place energy policy on a more economically sustainable footing and warns that increasing risk of disruption to industrial energy supplies will damage the UK’s standing as a manufacturing location
10.11.08Response to Ofgem request for views on proposed merger between British Energy and EDF
Users express concern about negative impacts on competition in power generation and wholesale market liquidity, and possible implications for industrial supply.
01.10.08Response to BERR consultation on UK Renewable Energy Strategy
EIUG calls for re-negotiation of the impractical EU 2020 renewable energy target and protection for UK industry from consequent energy cost increases to prevent carbon leakage.
Supplementary Evidence to Business & Enterprise Committee Inquiry into UK Energy Prices
Update on declining competitiveness of UK industrial gas and electricity supplies and response to Ofgem's oral evidence on forward prices and the influence of LNG.
01.04.08Evidence to Business & Enterprise Committee Inquiry into the UK Energy Market
EIUG notes declining competitiveness of UK industrial energy supplies and growing vulnerability to external price shocks.
17.10.07Response to BERR Consultation on Future of Nuclear Power
EIUG calls for a formal government decision in favour of new nuclear without further delay.
15.01.07Response to DTI Gas Security of Supply Consultation
EIUG requests DTI investigates supplier obligations, supports voluntary demand response and greater fuel efficiency.
10.07.06Impact of Uncompetitive Prices on Manufacturing Industry
Briefing note on the effect of soaring energy prices on energy intensive manufacturing in the UK
28.04.06EIUG Reform Agenda for the UK Gas Market
Discussion paper on proposals to improve security and competitiveness of UK gas supplies
13.04.06Response to DTI Energy Review Consultation
EIUG calls for balanced energy policy to ensure security of supply, recognising need to retain nuclear capacity
14.10.05Action Points from Gas Prices Working Group
List of key issues and conclusions agreed between EIUG and DTI on industrial gas prices
15.09.05Article for CBI's 'Business Voice' Magazine on Users' View of the Nuclear Debate
EIUG argues there is no alternative to nuclear if the UK is to cut emissions and retain competitive electricity supplies
19.07.05Response to draft DTI Report of the Gas Prices Working Group
EIUG expresses concern at government failure to recognise the seriousness of the current situation under which security and competitiveness of UK gas supplies will remain compromised
08.06.05Response to DTI paper on availability of information
EIUG requests access to offshore information at the same time as it is made available to shippers and producers
12.11.04Response to Ofgem Consultation and Impact Assessment on GB Charging
EIUG urges Ofgem to reject NGT's proposed transmission charging methodologies which risk disadvantaging consumers
01.07.04Response to Ofgem on Review of Transco's Structure of Distribution Charges
EIUG supports changing the split between capacity and commodity charges
05.05.04Response to Ofgem Consultation on Distribution Price Control
EIUG supports bringing EHV charges within the scope of the price control
31.03.04Response to Ofgem consultation on a possible derogation to Standard Condition 4E of Transco's Gas Transporters Licence
EIUG supports a temporary derogation to facilitate a voluntary agreement on access to offshore information
23.03.04Evidence to Trade and Industry Select Committee Inquiry into Fuel Prices - Appendix
Europe Economics report on Impact and Possible Causes of the Rise in Wholesale Gas Prices
23.03.04Evidence to Trade and Industry Select Committee Inquiry into Fuel Prices - Memorandum
EIUG calls for a comprehensive investigation of the wholesale gas market
12.03.04Response to Consultation on Draft UK Allocation Plan for the EU Emissions Trading Scheme
EIUG urges DEFRA to reconsider cutting emissions beyond Kyoto target and prepare for delay in implementation to get the scheme right.
23.02.04Evidence to House of Lords Inquiry into EU Climate Change Policy
EIUG calls current EU policy 'economically unsustainable' and questions whether Europe is ready to introduce emissions trading.
12.01.04EIUG letter to Financial Times on emissions target (published 15.01.04)
EIUG calls for government to consider effect of its proposals on global emissions.
21.11.03Letter to the Chancellor, DEFRA and DTI on the Impact of EU Emissions Trading on Industrial Competitiveness
EIUG urges caution in implementing the trading scheme to avoid damaging competitiveness, recognising that the Kyoto Protocol may never come into force.
18.11.03EIUG Representation on Network Code Modification 0658
EIUG rejects changing the gas interruption regime during a current contract period without customers' assent.
10.10.03EIUG Response to Consultations CCM-M-07, UoSCM-M-10 and UoSCM-M-11
EIUG questions the need for radical change in transmission charging arrangements and cautions against weakening the Triad incentive to manage peak demand.
02.09.03Response to DTI on Draft Social and Environmental Guidance to Ofgem
EIUG argues DTI's guidance should recognise the importance of economic growth in achieving social and environmental aims, and take account of international constraints with regard to greenhouse gas emissions.
29.08.03Response to European Commission Consultation C 52/03 on Restructuring Aid for British Energy
EIUG rejects claims of a structural over-capacity in UK generation and urges the Commission to accept government restructuring proposals.
30.07.03Response to Issues raised by DTI on Gas Information Disclosure
EIUG argues for fair access to timely information that is already available to other market participants, saying costs of widening access would be immaterial.
30.07.03Response to National Grid's Initial Charging Methodologies Consultation, July 2003
EIUG urges caution on changing the current methodology, but supports strengthening incentives to manage peak demand.
04.07.03Views on Summer Gas Interruptions
EIUG calls for Ofgem to launch a formal investigation into the circumstances leading to unprecedented summer gas interruptions.
Response to DTI Consultation on Zonal Transmission Losses in Electricity on a GB Basis
EIUG rejects the case for introducing charges for zonal losses in England and Wales, and the case for their extension into Scotland.
29.01.03EIUG Response to Transco Consultation on Proposed Changes to the Modification Rules
EIUG supports increased participation rights for customers in Network Code modifications.
20.01.03Response to NGC SO Incentive Schemes from April 2003 - Initial Proposals (Phase I)
EIUG opposes proposal to impose changes by October 2003.
11.12.02Response to Ofgem Consultation Centrica's Acquisition of Dynegy Storage
EIUG calls for ring-fencing and undertakings for storage, with option of Competition Commission referral to consider wider market implications.
09.12.02Response to NGC Consultation UoSCM-M-08 on New Winter Peak TNUoS Charges
EIUG opposes proposal to replace Triad-based peak transmission charges.
21.10.02Response to Consultation on BSC Modification Proposals P75 & P82
EIUG opposes introduction of zonal transmission losses for demand.
27.09.02Letter to the Minister of State for Energy on the progress of DTI's Gas Market Consultation
EIUG expresses dismay at the lack of progress in response to the DTI's consultation into gas prices and market efficiency.
13.09.02Response to DTI Energy Policy Consultation
EIUG argues the primary aim of policy should be acheiving secure energy supplies at internationally competitive prices.
06.09.02Letter to Secretary of State on NETA and the future of British Energy
EIUG rejects calls to interfere with NETA in order to rescue British Energy or other troubled generators.
19.08.02Response to Ofgem Consultation on separation of Transco's Distribution Price Control
EIUG gives qualified support to the prospect of separate regional network businesses.
02.07.02Response to Ofgem Consultation on LEB Acquisition of SEEBOARD
EIUG voices concern about impact on I&C market and European market liberalisation issues.
Response to Ofgem Consultation on RWE Acquisition of Innogy
EIUG asks for effects of creeping consolidation and impact on demand side to be taken into account.
06.12.01Response to Ofgem Consultation on Proposed MRA Modification
EIUG objects to proposal allowing electricity suppliers to block customer transfers.
03.12.01Response to Transco Consultation on Reforming the Interruptible Regime
EIUG supports greater customer choice in interruptible tariffs but objects to premature implementation.
12.10.01Response to DTI Consultation on Renewables Obligation
EIUG warns of impact on industrial electricity bills and objects to premature implementation whilst Energy Policy Review is in progress.
08.08.01Response to Ofgem Consultation on Draft Proposals for Transco Price Review
EIUG calls for substantial investment to improve NTS flexibilty and increase entry capacity at St Fergus.
11.07.01Response to Ofgem Consultation on Transmission Access and Losses
EIUG opposes proposals for transmission access auctions and locational charges for losses.
27.04.01Response to DTI Consultation on Market Abuse Clauses in Generator Licences
EIUG supports market abuse clauses but rejects suggestion of them being time-limited.
23.03.01Response to Competition Commission Rejection of Market Abuse Licence Conditions
EIUG urges DTI to consider additional measures to prevent generator gaming under NETA.
15.03.01Response to Ofgem Consultation on Innogy Acquisition of Yorkshire Energy
EIUG objects to increase in consolidation and vertical integration and fears for the impact on the demand side.