Summary of progress so far in the UK 1.General support of a benchmarking methodology from 2 main stream glass subsectors in the UK: 1.float (4 installations/3 co.s), 2.container (12/5) 2.Recognised lack of statistical data for remaining: 1.fibre (1/1) 2.frit (1/1) 3.flaconnage (1/1) 4.rolled flat glass (1/1). 3.Key parameters identified 4.Would presumably require subsector MOUs.

UK Glass Sector EUETS 2008 survivors

Summary of progress so far in the EU 1.Discussion at EU level – Comite Permanente d’Industrie de Verre (Brussels) 2.Still at “storming” stage; emphasis appears on problems - not solutions, apparent lack of urgency in some quarters 3.Previous comprehensive benchmarking based on furnace energy efficiency with normalisation of furnace parameters e.g. Dutch Covenant (TNO), not CO2 4.Subsectors: flat, hollow, fibre (continuous and spun), domestic, crystal, tube.

Lessons Learnt in UK Phases 2 NER BM - 1 Comments in sector response to PH2 BM consultation March 2006 BM important - represented ~15% of sector allocation Government expected minimum number of parameters regardless of process constraints Addressed only new” installations, not existing Work put off until time table became very tight Lack of recognition in inherent differences in furnace design and operation potentially jeopardises UK production flexibility Failed to encourage production of energy saving products

Lessons Learnt in UK Phases 2 NER BM - 2 Simplistic assumptions on cullet availability- “will have access to ‘average’ cullet levels” then “do not necessarily have equal access to external sources of cullet” (Enviros report) Use of electric boost inappropriately incorporated Government unsympathetic to some industry constraints –Furnace aging, market demand, product SEC diversity, gas or oil availability, security of supply & demand side switching –Non direct carbon issues: e.g. extending furnace life to minimize environmental impact of construction and demolition In the UK it was suggested by industry that only the EA had the required skill, access to data and confidentiality to develop BM

Suggestions for the Directive True integration with other carbon reduction mechanisms: such as production of energy saving products Use of post hoc adjustment with benchmarking to stimulate efficient economy of scale production Mechanism to allow thematic or sectoral approaches if satisfactorily developed

Some Pros & cons of BM Pros –Helps to provide certainty –Encourages efficiency & economies of scale –Damps financial fluctuation Cons –Compromise between simplicity and process reality –Could limit inherent process advantages if too inflexible –Requires good data & knowledge base and understanding –Harmonisation essential

Way Forward Increase Awareness - Potential impact of non-benchmark system requires evaluation and explanation at all levels (UK/EU) Get Engagement - Some UK Industry representatives already engaged… –But others waiting on further clarification impact assessment from government Integrate with other policy instruments