Consultation outcome

Environment Agency charges proposal for greenhouse gas emissions: summary of consultation responses

Updated 1 April 2025

Introduction

The regulation of greenhouse gas emissions is carried out through several regulatory schemes:

• UK Emissions Trading Scheme (UK ETS) – currently installations and aviation, with waste installations and maritime to be included at some point after 1 January 2026
• Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA)
• the implementation of the UK ETS is supported by the UK ETS Registry – the UK also has a National Registry relating to its obligations under the Kyoto Protocol

UK ETS puts a cost on carbon emissions. This encourages businesses to reduce the amount of greenhouse gases they emit to meet the UK’s statutory emissions reduction commitments. The scheme works on the ‘cap and trade’ principle. A cap is set on the total amount of certain greenhouse gases that participants can emit under the scheme. The cap is reduced over time so that total emissions fall.

CORSIA requires qualifying aeroplane operators to offset their growth in international aviation carbon dioxide emissions above their 2019 baseline levels.

UK ETS participants need a UK ETS registry account to fulfil their surrender obligations and receive, if eligible, free allowances.

In developing our proposal, we reviewed the regulatory activity we need to do. This activity analysis informed the proposed charge. 

The consultation outlined how we aim to recover the full cost of our regulatory activity. We reviewed the charges to address:

• where it no longer recovers the cost of delivering our services
• inflationary pressures
• the additional costs to deliver our duties where current charges no longer cover this
• introducing waste installations and maritime to UK ETS
• additional regulatory activities needed
• separate charges for those participants who are registered for both UK ETS aviation and CORSIA

How we ran the consultation

The consultation ran for 8 weeks from 29 November 2024 to 24 January 2025. It was hosted on GOV.UK and our consultations website (Citizen Space). It was open to anybody to take part. Those who prefer to respond by email or post were able to request a copy of the consultation document and response form instead of responding online.

We ran the consultation in line with our legal requirements to consult following the Cabinet Office’s consultation principles guidelines. We notified ministers of our intention to consult.

It was important for us to give our customers the opportunity to understand the proposals and the impact they will have. We encouraged our customers to give us their views through the consultation and publicised it openly.

Throughout the development of the proposals and in the run up to the consultation, our staff informed 5,898 individuals registered against 2,779 accounts in both managing your emissions trading scheme (METS) and the registries about the pending consultation and released press statements in letsrecycle.com, Materials Recycling World, Circular, and Resource to reach other potential stakeholders. We also sent out a reminder before the consultation closed.

Key findings and actions we will take

This section includes an overview of responses to the consultation, key themes we identified within those responses and a summary of our response to each theme.

Overview of consultation responses

We received a total of 24 responses to the consultation. Of these responses, 23 were submitted using our Citizen Space consultation tool. We also received 1 further response by email to question 21.

The 24 formal responses were submitted by:

• 2 individuals
• 20 organisations or groups
• 0 others
• 2 who provided no information

These consultees described their main area of activity as:

• combustion – 7
• waste mineral oil refining – 1
• cement and lime – 1
• radioactivity manufacture of glass and similar – 1
• paper and pulp – 1
• chemical industry and other sectors – 1
• energy from waste and or waste incineration installation – 1
• hospital – 1
• small energy emitter – 0
• no response given – 10

You can find detailed information on the responses to each question in Annex 1. This includes analysis of the comments we received. Annex 2 gives a list of organisations and groups that participated in the consultation. These organisations represent a cross section of UK ETS Operators.

The overall response to this consultation represents 0.41% of all individuals contacted, or 0.86% of the number of accounts in METS and the UK ETS and Kyoto Protocol Registries. We would like to thank all those who participated in the consultation and took time to provide this valuable feedback.

Consultation outcome

We conducted a thorough review of comments to identify the key points from the themes and considered whether it may be appropriate to make changes to our original proposals. The consultation feedback was very helpful in understanding any concerns or issues relating to our proposals. It was also valuable to hear from those who expressed their support for the changes we proposed.

After careful consideration, we will implement all the proposed charges as outlined in the consultation document. A summary of feedback we received and our response to the key points are set out under separate headings.

Key themes and our response

The overview of all the feedback to the consultation is provided in Annex 1.

These are the main themes we identified in the feedback from this consultation:

• support for proposal
• impact for customers
• charge scheme design
• the consultation design
• service we provide

Support for proposal

There were a lot of responses agreeing with the proposed charges across a wide section of the questions, covering most of the schemes. Some typical responses for the various charges were:

• UK ETS installations application charge -

“With no changes made to the process it is agreeable that the price remains unchanged”

• UK ETS installations transfer, surrender and revocation charges -

“We appreciate the EA review and the conclusion that the administrative cost burden can be reduced”

• UK ETS registry charge for new user additional or replacement account representative -

“I think that it is right to charge operators for additional account representatives or new users and the increase is modest”

Our response

We appreciate the positive feedback the responders provided.

Our charges reflect the work our teams carry out to provide the service. During assessment of this work, where efficiencies in our processes are seen, we will reduce our charges. We constantly strive to do this for the benefit of both the customer and our teams.

Impact for customers

We had many responses on customer impacts for several of our charges. These responses said the charges were too high or had a negative economic impact on their business. A typical response included:

“A 29.8% increase for an installation annual subsistence permit in receipt of free allocation is very high (compared to CPI) and does not appear to reflect the ‘additional’ work listed.”

“We understand EA’s position, however as an operator of UK ETS, we already incur high costs with EA, our external auditor and the UK ETS payments themselves. Any additional costs are to be avoided”

For the subsistence charge for the registries, a respondent said:

“While it is understood that the costs of managing the registry need to be covered, the 334% increase in annual registry subsistence fees is significant”

Our response

We intend to implement all the charges as proposed in the consultation.

Since the implementation of greenhouse gas emissions charges in 2021 inflation has been applied annually to our charges. However, the original scheme introduced in 2021 was based on conservative estimates, which was as accurate as possible at the time it was implemented.

We have now carried out a full review of the service we provide. To help to understand what costs are included when we develop our charges, we have published on GOV.UK how we calculate our charges.

As a result of the assumptions made when implementing the original scheme, some charges may have increased more than inflation to reflect the increased time taken by our teams to carry out their regulatory activities alongside higher costs to the Environment Agency, whereas other charges have reduced. Managing public money requires all government agencies to fully recover their costs through charges. This is reflected in the charges we have calculated and proposed in the consultation.

We appreciate many of the proposed charges have significantly increased and understand any increase in our charges puts additional financial pressures on our customers. However, to be able to manage the schemes to regulate greenhouse gas emissions, we need to have charges which fund the work we carry out making sure operators are compliant with them.

Charge scheme design

We had a number of responses which were related to our charging and permitting policy. These comments were across several of the proposed charges.

A typical response for aviation said:

“For a large airline, this might be justified but for small emitters, having to report and offset 4 tons of CO₂ emissions for instance, those costs are insane. Maybe introduce two charging schemes here. One for large and one for small emitters. That could be a good idea”.

A typical response to a registry charge proposal is:

“any additional costs should be avoided”

On the timing of consultations, comments included:

“Going forward, to aid financial planning, it would be useful to be consulted on any charge increases in the previous year’s summer if they are likely to deviate from the CPI.”

Our response

When the current UK ETS charging scheme was introduced, we removed tiered charging based on the size of installation for 2 reasons:

• to simplify our charging scheme
• the work carried out as part of the annual subsistence charge was similar irrespective of the size of the installation

For UK ETS aviation, subject to meeting the qualifying criteria, UK ETS aircraft operators can take advantage of reduced monitoring and reporting costs through simplified reporting.

The registry administrator is required by the UK ETS Order to be satisfied that all account holders and authorised representatives are fit and proper to hold and account and use the UK ETS registry. The national administrator of the Kyoto Protocol registry has similar duties. The current process for completing due diligence checks for voluntary traders on the registries will continue for the foreseeable future. Due to the nature and related risk of the transactions carried out by voluntary traders, many of whom are based outside the UK, we need to carry out a substantial level of due diligence checks. This includes the costs of purchasing the platforms and services used to complete the due diligence checks on applicants.

We take onboard the feedback regarding the timing of our charge consultations. We try to give customers ample notice when we are consulting on charges, where timescales allow.

The consultation design

We had many responses highlighting that you felt there was insufficient information in the consultation document to explain why some charges had increase by the percentage they had. Some examples of your responses are;

For the UK ETS installations subsistence charge you said:

“Justification does not seem to be provided for the 39.7% increase in annual subsistence for permits not in receipt of a free allocation. Whilst the Environment Agency’s requirement to cover the costs of regulating ETS for the sector is recognised, more information is required to understand the reason for the increase.”

For the registries’ application charge you said:

“While we acknowledge that costs have generally increased and that this should be reflected in the new proposed charges, the percentage increase in this particular charge appears significant. It would be helpful to receive further information regarding the additional costs and time involved in processing the application, as a 171.8% increase does not seem justified.”

For the registries’ subsistence charge you said:

“We do not support the 334% increase in the registry’s annual subsistence charge. There is insufficient evidence in the consultation to support this and we question why industry should pay extra due to the failure to design and implement an IT system which reduces the administrative burden.”

Our response

The work currently carried out as part of the annual subsistence charge for UK ETS installations is similar for both participants with and without a free allocation. Therefore, the staff costs to carry out these activities are also similar. We acknowledge installations with a free allocation have 2 new activities proposed in the consultation, which has resulted in the subsistence charge for installations with a free allocation increasing by a larger monetary amount.

All responders of the consultation were UK ETS operators, aircraft operators or organisations who represent them. The separate registry subsistence charge applies only to voluntary traders who wish to trade allowances and carbon units for profit from a trading account. Registry costs relating to compliance accounts required by operators and aircraft operators to meet their UK ETS obligations are included in the permit or emissions monitoring plan application fees and the annual subsistence fee.

The following provides further insight into the registry charges.

The application charge for a trading account funds:

• the time to manage, support and determine an application for a trading account
• the costs of due diligence platforms and services

The subsistence charge for a trading account funds:

• the help desk support service including the new help desk
• the ongoing costs for hosting digital systems, support, developer help desk, and service integration management
• the costs of further development of the registries’ digital systems

Service we provide

We had a lot of responses requesting we improve our IT systems and service due to inefficiencies, with comments saying:

“This seems the type of project that can benefit from improved IT systems - the reason for the failure to deliver these savings is not identified”

“We question why industry should pay extra due to the failure to design and implement an IT system which reduces the administrative burden”

“With the increases it is difficult to accept paying for inefficiency, for example the consultation states a new IT system has been installed but efficiencies were not realised”

Our response

We recognise the IT systems implemented at the start of UK ETS in 2021 were not fully developed and deployed to make processes as efficient as possible.

Since the IT system was introduced, they have been fully updated, which has cost more money that we are seeking to recover. This will ensure we provide a service for our customers that is value for money. We will continue to invest in the IT system, working with the IT provider to make sure subsequent improvements achieve further efficiencies that will reduce the overall cost of our service.

Next steps

The updated Environment Agency (Greenhouse Gas Emissions) charging scheme 2025 will come into force on 1 April 2025 having gained approval by the Secretary of State for the Department of Energy Security and Net Zero (DESNZ) and consent from HM Treasury. The changes will be implemented under Part 5 of the Greenhouse Gas Emissions Trading Scheme Order 2020, Part 4 of the Air Navigation (Carbon Offsetting and Reduction Scheme for International Aviation) Order 2021, and Section 41 and 41A of the Environment Act 1995.

The scheme which will come into force on 1 April 2025 will not include the charges relating to waste installations and the maritime sector. The scheme will be varied at a later date, when these sectors are brought into the UK ETS.

This will be published on GOV.UK at Environment Agency (greenhouse gas emissions) charging scheme.

Annex 1: Detailed summary of consultation responses

This annex sets out the responses we received to our consultation on Environment Agency charges proposal for greenhouse gas emissions.

The consultation questions were divided into several topics: 

• about you (additional questions)
• UK ETS charge proposals: installations
• UKETS charge proposals: waste installations
• UK ETS charge proposals: maritime
• UK ETS aviation and CORSIA charge proposals
• UK ETS Registry and Kyoto Protocol National registries
• additional comments about the charging proposals

We received 23 responses through the online tool and consultation response form. We also received 1 email with comments relating to the consultation.

About you (additional questions) 

Within the online tool and response form, we included an ‘about you’ section to provide us with an understanding of who responded and to help us better analyse the consultation feedback.

We asked if consultees were giving a personal response as an individual or providing their response on behalf of an organisation. The 24 responses (23 online and 1 response by email), stated:

• responding as an individual – 2
• responding on behalf of an organisation, group or trade association – 20
• other – 0
• no answer given – 2

We asked respondents, which UK ETS scheme they participate in, and they said: 

• stationary installation – 14
• aviation – 8
• maritime – 0
• registry traders – 0
• do not participate in UK ETS – 1
• no answer given – 1

We then asked for those who responded as ‘stationary installations, to select the most relevant sector that applied to their business: 

• combustion – 7
• mineral oil refining – 1
• iron, steel, and ferrous – 0
• cement and lime – 1
• manufacture of glass and similar – 1
• ceramics – 0
• paper and pulp – 1
• aluminium and non-ferrous – 0
• chemical industry and other sectors – 1
• energy from waste and or waste incineration installation – 1
• hospital – 1
• small energy emitter – 0
• no response given – 10

We asked how respondents found out about the consultation and they said:

• from the Environment Agency – 20
• from another organisation – 0
• through an organisation, group or trade association you are a member of – 2
• press article – 0
• social media, for example, Facebook – 0
• through a meeting you attended – 0
• other (please specify) – 0
• no response given – 1

Consultation questions

Questions are set out in the same format as they were presented in the online consultation tool and response form. Multiple choice questions gave respondents the option to select one response. These were followed by a free text box for comments.

For each question, we report the multiple choice options selected and the ‘themes’ identified in free text comments.

Themes or key points: We reviewed the free text comments and used content analysis to define and group recurrent ideas or concerns. We used descriptive labels (called ‘tags’) to summarise specific ideas. More than one ‘tag’ can be used in a comment. We then grouped ‘tags’ of a similar nature within a ‘theme’. These ‘themes’ help us to describe the overall response to each question and show where particular feedback was given about the consultation, environment or Environment Agency. The tag ‘not applicable’ is used if a comment does not include any relevant themes.

Themes are given in descending order with the most frequently identified first. Any ‘tags’ identified more than 2 times are noted alongside themes to give additional detail about the feedback we received. The number of times a tag is identified is given in brackets. When the number of each individual tag identified in a theme are added together, and is less than 4, we report the theme only.

UK ETS charge proposals: installations

UK ETS installations permit application charge

Question 1: Do you agree or disagree with the proposed change to the permit application charge for UK ETS installations?

This question received positive (10) responses:

• strongly agree – 5
• agree – 5
• neither agree nor disagree – 4
• disagree – 0
• strongly disagree – 0
• do not know – 0
• not applicable – 0
• did not answer – 10

Free text comments were submitted by 8 respondents to the consultation (33%):

• charge scheme design - ‘customer not affected’ (5)

The following theme ‘support for proposal’ was identified fewer times. One comment was ‘not applicable’.

UK ETS installations subsistence charges

Question 2: Do you agree or disagree with the proposed change to the annual subsistence charges for UK ETS installations?

This question received more negative (10) than positive (3) responses:

• strongly agree – 1
• agree – 2
• neither agree nor disagree – 1
• disagree – 4
• strongly disagree – 6
• do not know – 0
• not applicable – 0
• did not answer – 10

Free text comments were submitted by 13 respondents to the consultation (54%):

• impact to customer– ‘charge is high’ (7)
• charge scheme design - ‘other suggestion for proposal’ (3); ‘charging and permitting policy’ (2)

The following themes of ‘the consultation design’, ‘support for proposal’ and ‘service we provide’ were identified fewer times. One comment was ‘not applicable’.

UK ETS installations supplementary charges

Question 3: Do you agree or disagree with the changes to the proposed transfer, surrender and revocation charges for UK ETS installations?

This question received positive (9) responses:

• strongly agree – 4
• agree – 5
• neither agree nor disagree – 5
• disagree – 0
• strongly disagree – 0
• do not know – 0
• not applicable – 0
• did not answer – 10

Free text comments were submitted by 9 respondents to the consultation (37%):

• support for proposal – ‘agrees with proposal’ (4); ‘partially agree with proposal’ (2)

The theme of ‘the consultation design’ was identified fewer times. Two comments were ‘not applicable’.

Question 4: Do you agree or disagree with the change to the allocation from new entrant reserve charge for UK ETS installations?

This question received a few positive (3) and one negative response but main response was ‘neither agreed nor disagree’ (6):

• strongly agree – 1
• agree – 2
• neither agree nor disagree – 6
• disagree – 1
• strongly disagree – 0
• do not know – 0
• not applicable – 3
• did not answer – 11

Free text comments were submitted by 8 respondents to the consultation (33%):

• support for proposal – ‘supports proposal (no objection noted)’ (3)

The following theme ‘impact for customers’ was identified fewer times. Four comments were ‘not applicable’.

Question 5: Do you agree or disagree with the proposed change to the charge for increase to emissions target for hospitals and small emitters?

This question received mainly positive (6) responses:

• strongly agree – 4
• agree – 2
• neither agree nor disagree – 2
• disagree – 0
• strongly disagree – 0
• do not know – 0
• not applicable – 6
• did not answer – 10

Free text comments were submitted by 4 respondents to the consultation (17%):

• support for proposal – ‘agrees with’ (2)

No other theme was identified. Two comments were ‘not applicable’.

UK ETS charge proposals: waste installations

Question 6: Do you agree or disagree with the proposed charges for permit applications for the MRV transition period into UK ETS, for energy from waste and waste incineration installations?

This question received 2 responses, these were mainly positive (3):

• strongly agree – 2
• agree – 1
• neither agree nor disagree – 1
• disagree – 0
• strongly disagree – 0
• do not know – 0
• not applicable – 2
• did not answer – 18

Free text comments were submitted by 3 respondents to the consultation (13%):

• support for proposal – ‘agrees with proposal’(2)

No other theme was identified. One comment was ‘not applicable’.

Question 7: Do you agree or disagree with the proposed charges for annual subsistence for the MRV transition period into UK ETS, for energy from waste and waste incineration installations?

This question received 4 responses with equal positive (2) responses to those neither agreeing nor disagreeing (2):

• strongly agree – 1
• agree – 1
• neither agree nor disagree – 2
• disagree – 0
• strongly disagree – 0
• do not know – 0
• not applicable – 2
• did not answer – 18

Free text comments were submitted by 3 respondents to the consultation (13%):

• support for proposal – ‘agrees with proposal’ (1)
• the consultation design – ‘insufficient information’ (1)

No other theme was identified. One comment was ‘not applicable’

UK ETS charge proposals: maritime

Question 8: Do you agree or disagree with the proposed application charge for UK ETS maritime?

This question received 2 responses with one positive and one neither agreeing nor disagreeing:

• strongly agree – 0
• agree – 1
• neither agree nor disagree – 1
• disagree – 0
• strongly disagree – 0
• do not know – 0
• not applicable – 4
• did not answer – 18

Free text comments were submitted by 2 respondents to the consultation (8%):

• support for proposal – ‘agrees with proposal’ (1)

No other theme was identified. One comment was ‘not applicable’

Question 9: Do you agree or disagree with the proposed annual subsistence charge for UK ETS maritime?

This question received 4 responses one positive response but mainly neither agree nor disagree (2):

• strongly agree –
• agree – 1
• neither agree nor disagree – 2
• disagree – 0
• strongly disagree – 0
• do not know – 1
• not applicable – 0
• did not answer – 20

Free text comments were submitted by 3 respondents to the consultation (13%):

• impact for customer – ‘charge too high’ (1)

No other theme was identified. Two comments were ‘not applicable’

Question 10: Do you agree or disagree with the proposed determination hourly rate for UK ETS maritime?

This question received 2 responses with one positive and one neither agreeing nor disagreeing:

• strongly agree – 0
• agree – 1
• neither agree nor disagree – 1
• disagree – 0
• strongly disagree – 0
• do not know – 0
• not applicable – 4
• did not answer – 18

Free text comments were submitted by 2 respondents to the consultation (8%), both were’ not applicable’.

UK ETS charge proposals: aviation and CORSIA

Question 11: Do you agree or disagree with the proposal to apply separate charges for operators who participate in both UK ETS aviation and CORSIA regimes?

This question received 5 responses, which said they did not know (3), and a few gave negative (2) responses:

• yes – 0
• no – 2
• do not know – 3
• not applicable – 9
• did not answer – 10

Free text comments were submitted by 5 respondents to the consultation (21%):

• other issues – ‘CORSIA Regulation’ (2)

The following themes of ‘impact for customer’ and ‘the consultation design’ were identified fewer times. Two comments were ‘not applicable’

UK ETS aviation charges

Question 12: Do you agree or disagree with the proposed change to the application charge for an emissions monitoring plan for UK ETS aviation?

This question received mainly negative (7) and a few positive (2) responses:

• strongly agree – 1
• agree – 1
• neither agree nor disagree – 1
• disagree – 1
• strongly disagree – 6
• do not know – 0
• not applicable – 4
• did not answer – 10

Free text comments were submitted by 8 respondents to the consultation (33%):

• impact for customers – ‘charge too high’ (6)
• charge scheme design – ‘charging permitting policy’ (3)

No other theme was identified. One comment was ‘not applicable’

Question 13: Do you agree or disagree with the proposed change to the subsistence charge for UK ETS aviation?

This question received mainly negative (5) responses and a few positive (2) responses:

• strongly agree – 1
• agree – 1
• neither agree nor disagree – 3
• disagree – 2
• strongly disagree – 3
• do not know – 0
• not applicable – 4
• did not answer – 10

Free text comments were submitted by 7 respondents to the consultation (29%):

• charge scheme design – ‘charging permitting policy’ (3)

The following themes of ‘impact for customers’, ‘support for proposal’ and ‘our business approach’ were identified fewer times. One comment was ‘not applicable’.

CORSIA charges

Question 14: Do you agree or disagree with the proposed change to the emissions monitoring plan application charge for CORSIA?

This question received 5 responses, these were mainly negative (3) with one neither agreeing or disagreeing:

• strongly agree – 0
• agree – 0
• neither agree nor disagree – 1
• disagree – 0
• strongly disagree – 3
• do not know – 1
• not applicable – 9
• did not answer – 10

Free text comments were submitted by 6 respondents to the consultation (25%):

• impact for customer– ‘charge too high’ (2)

The following themes of ‘charge scheme design’, ‘the consultation design’ and ‘other issues’ were identified fewer times. Two comments were ‘not applicable’.

Question 15: Do you agree or disagree with the proposed change to the annual subsistence charge for CORSIA?

This question received 5 responses, of which a few were positive (2) and one was negative:

• strongly agree – 1
• agree – 1
• neither agree nor disagree – 1
• disagree – 0
• strongly disagree – 1
• do not know – 1
• not applicable – 9
• did not answer – 10

Free text comments were submitted by 5 respondents to the (21%):

The following themes of ‘support for proposals’, ‘charge scheme design’ and ‘other issues’ were identified once. Two comments were ‘not applicable’.

UK ETS Registry and Kyoto Protocol National Registry

Question 16: Do you agree or disagree with the change to the proposed charge for an application for a trading account or a person holding account in the registry?

This question received mainly negative (9) responses with a few positive (3) responses:

• strongly agree – 1
• agree – 2
• neither agree nor disagree – 4
• disagree – 1
• strongly disagree – 9
• do not know – 0
• not applicable – 0
• did not answer – 7

Free text comments were submitted by 13 respondents to the consultation (54%):

• impact for customer– ‘charge too high’ (7)
• service we provide – ‘improved digital technology needed’ (3); ‘more transparency’ (2)

The following themes of ‘the consultation design’, ‘support for proposal’ and ‘charge scheme design’ were identified fewer times. One comment was ‘not applicable’

Question 17: Do you agree or disagree with the change to the proposed charge for additional or replacement authorised representatives for a new user in the registry?

This question received mainly negative (8) responses with some positive (5) responses:

• strongly agree – 2
• agree – 3
• neither agree nor disagree – 4
• disagree – 4
• strongly disagree – 4
• do not know – 0
• not applicable – 0
• did not answer – 7

Free text comments were submitted by 12 respondents to the consultation (50%):

• impact to customer– ‘charge too high’ (3); ‘economic impact to customers’ (1)

The themes of ’support for proposal’ charge scheme design’, ‘service provided by EA’ and ‘business approach’ were identified fewer times. Two comments were ‘not applicable’.

Question 18: Do you agree or disagree with the change to the proposed charge for additional or replacement authorised representatives for an existing user in the registry?

This question received mainly negative (9) responses and some positive (5) responses:

• strongly agree – 1
• agree – 4
• neither agree nor disagree – 3
• disagree – 2
• strongly disagree – 7
• do not know – 0
• not applicable – 0
• did not answer – 7

Free text comments were submitted by 11 respondents to the consultation (46%):

• impact to customer impact – ‘charge too high’ (4); ‘economic impact to customers’ (1)

The theme of ‘support for proposal’, the consultation design’ and ‘charge scheme design’ was identified fewer times. Four comments were ‘no additional comment’.

Question 19: Do you agree or disagree with the change to the proposed charge for the registry annual subsistence charge?

This question received mainly negative (13) responses with a few positive (2) responses:

• strongly agree – 1
• agree – 1
• neither agree nor disagree – 1
• disagree – 3
• strongly disagree – 10
• do not know – 0
• not applicable – 1
• did not answer – 7

Free text comments were submitted by 16 respondents to the consultation (67%):

• impact to customer– ‘charge too high’ (11); ‘underestimated economic impact’ (1); ‘wider economic issues (1)
• the consultation design – ‘insufficient information’ (7)

The themes of ‘service we provide’ and ‘supports proposal’ was identified fewer times. Three comments were ‘not applicable’.

Question 20: Do you agree or disagree with the introduction of a proposed charge for an authorised representative with surrender and return only permissions for the registry?

This question received mainly negative (9) responses with some positive (5) responses:

• strongly agree – 2
• agree – 3
• neither agree nor disagree – 3
• disagree – 3
• strongly disagree – 6
• do not know – 0
• not applicable – 0
• did not answer – 7

Free text comments were submitted by 11 respondents to the consultation (46%):

• charge scheme design – ‘charging permitting policy’ (4); ‘charge proposal confusing’ (3)
• support for proposals – ‘agrees with proposal’ (4)

The following theme ‘impact for customers) was identified fewer times. One comment was ‘not applicable’

Additional comments about the UK ETS charge proposals

Question 21: Please share any additional comments that you think may help us improve our current proposals for UK ETS.

Free text comments were submitted by 17 respondents to the consultation (71%):

• charge scheme design – ‘charging permitting policy’ (5); ‘other suggestion for proposal’ (2)
• impact for customer– ‘wider economic impact’ (4); ‘charges too high’ (3)
• service we provide – ‘improved or digital technology needed’ (3); ‘make efficiency savings (2)

The following themes ‘service we provide’, ‘support for proposal’ and ‘the consultation design’ were identified fewer times . One comment was ‘not applicable’

Annex 2: List of consultation participants

The number of respondents in the consultation who said they were an organisation or business will differ from the number of organisations named in this list. This is because some respondents stated they were a business but did not include their business name or organisation, or they did complete the question to allow their response to be published.

List of organisations or businesses that gave a name

AIR INDIA LIMITED

British Glass

Confederation of Paper Industries - representing UK paper mills obligated under UK ETS.

E.ON

ETS & More is a consultancy service for aircraft operators in the business aviation sector

Foodchain & Biomass Renewable Association (FABRA UK)

Fuels Industry UK

GESTAIR SAU

Jet Story sp z o.o.

JOINT STOCK COMPANY “ANTONOV”

KLM Royal Dutch Airlines

Mineral Products Association

National Gas Transmission

Peterborough City Hospital

SSE

Syngenta Huddersfield

Uniper UK Limited