UK Business Council for Sustainable Energy: Renewables Greenwash

“Business used to be depicted as a primary source of the world's environmental problems. Today it is increasingly viewed as a vital contributor to solving those problems” Livio de Simone. Chairman of the World Business Council for Sustainable Development.

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Introduction

The UK Business Council for Sustainable Energy (UKBCSE) is a high level energy lobby group and a reputable mainstream authority on climate policy and renewable energy potential in the UK. This report aims to examine ways in which this recently formed group exerts significant policy pressure for market based solutions to climate change which promote business growth for their members and related consortiums. A comparison of government documents and UKBCSE consultation responses and policies and an analysis of their Public Affairs strategies will be carried out, alongside profiling of important people and linked organisations using official websites, press releases, and academic commentaries. Interestingly, the organisation make a large volume of press releases, policy consultations, images, events reports and climate negotiation contributions publicly available on their website. These will make up the majority of the report.

Background to formation

The UKBCSE was established in May 2001 and formally launched in Jan 2002 following the Prime Minister's Environment Speech on 6th March 2001 in which he emphasised the business opportunities presented by Kyoto and renewable technologies, and announced plans to invite 'CEOs from key sectors...together with the leaders of NGOs, to work to develop innovative strategies' in preparation for the World Summit on Sustainable Development in August 2002 . Though depicting themselves as an independent lobby group, the UKBCSE have clearly worked closely with government on policy and initiatives from their conception as their website states,

'the UKBCSE took the lead role for the UK Government in bringing together the UK Energy Sector input to the World Summit on Sustainable Development. At the World Summit, the UKBCSE worked with the UK Government to launch the Renewable Energy and Energy Efficiency Partnership (REEEP).'

Grosvenor Gardens House. Home to the UKBCSE, London Climate Change Services, Carbon Aided, Carbon Capture and Storage Association, Combined Heat and Power Association and a number of other carbon trading and offsetting organisations.

The organisation went on to have 'a key role in the development and delivery of the UK Prime Ministers agenda for his G8 and EU Presidencies'.. In line with Blair's assertion that 'we have led the way in integrating environmental and economic goals within a liberalised electricity market', the UKBCSE joined with sister organisations in Washington (USBCSE), Frankfurt (European BCSE or e5) and Melbourne (AUBCSE) in using strong sustainability rhetoric to push for emissions trading and other liberal market based solutions to climate change historically favoured by the UK government, and which tend to favour large scale existing technologies such as wind and nuclear, which their members predominantly supply.

Despite claims that they were formed 'at the request of major NGOs' the UKBCSE has no NGO membership or declared connections, and was formed of the largest energy suppliers and distributors in the UK.

Greenwash and Corporate Sustainability

The origins of the 'corporate capture of sustainable development' can be traced to the late 1980's, when corporations reacted to their portrayal as a-moral and uncaring by environmentalists and saw the opportunity to promote a green image through the notion of 'sustainable economic growth' and corporate social responsibility, usually involving self regulation and domination of the sustainability agenda. . Gramsci describes how corporations absorb their enemies into coalitions he calls 'new historical blocs', formed to deal with a specific issue or public affairs campaign . Similarly Najam notes how the use of sustainability rhetoric has wooed universities, NGO's and governments into various corporate partnerships which helped to promote business as part of the solution, as opposed to the problem . Sklair also describes how corporate input to the UN Commission on Sustainable Development resulted in the definition of 'sustainable consumption' as addressing 'how the goods and services (including energy) required to meet people's needs can be delivered in a way that reduces the burden on the earth's carrying capacity'. The wording leaves 'needs' open to interpretation by commercial interests and advocates sustaining production and consumption levels, while reducing only waste. Others have argued that growth capitalism necessarily involves exploitation of resources, and a sustainable society must therefore minimise economic growth.

Oil and gas companies joined the sustainability bandwagon en masse in the late 1990's after the Exxon Valdez spill and the Brent Spa fiasco created a wave of bad press, and a renewables based image was deemed commercially prudent (BP's Beyond Petroleum campaign was one of the first and most notable of the reformed oil company images) . Business/government partnerships on environmental issues were also promoted by Kofi Annan at the 1999 World Economic Forum.

The term 'greenwash' has evolved in recent years to describe false or misleading claims to environmentally beneficial behaviours by businesses or governments such as those explored in this study.

How Sustainable?

UKBCSE members are the eight largest UK energy and transmission companies who dominate the UK renewables market, representing around £3 bn investment in sustainable energy according to the UKBCSE . Aswell as members they also list 'strategic partners' from the atmospheric gas and hydrogen industry, oil and gas and large scale wind lobby. Their literature uses sustainability language such as 'strong carbon targets' and 'energy descent' but in other places alludes to the need to maintain current demand for energy (unsurprising given their membership). The main emphasis of UKBCSE policy (analysed in more detail later) is on creating strong carbon markets, emissions trading and other market based mechanisms. These neo-liberal 'solutions' have been shown to favour large companies and existing technologies, at the expense of small or independent generators and new technology . It is also speculated that such emphasis on lowest short-term cost market solutions can make 'clean coal' and nuclear energy more appealing, as demonstrated in the current case of the UK, while countries who adopt 'command and control' policies tend to promote innovative technologies, independent generation and long term growth in renewable energy provision. Toke compares the UK's freemarket policies with Germany's REFIT command and control policy which has led Germany's large renewable energy sector being dominated by small independent suppliers. The UK is one of the only European countries pushing for a deregulated carbon market, supported by the USA, while most other EU countries favour REFIT type systems . Though the main image on their website contains the names of many renewable technologies, UKBCSE literature promotes wind almost exclusively as a carbon reduction strategy, and though it is not made explicit in their literature it is speculated their activities promote nuclear and 'clean coal'. A brief look at the activities of member companies, related lobby groups and key figures sheds light on these claims.

Member Companies

• Centrica is an international top 30 FTSE100 company which split from British Gas in 1997. It is now owned by parent company BG group (British gas renamed) which also owned Lattice group, now merged with National Grid, the UK's main transmission provider. Centrica dominates 45% of the total gas market in the UK and is in the process of buying out North sea gas producer Venture. Talks are also ongoing for a proposed £3.1 billion share in British Energy, UK nuclear energy generator now owned by EDF energy. Despite its commitment to rapid growth in these sectors Centrica has also been active in promoting itself as a renewable energy provider through its creation of British Gas New Energy in 2007, and is a large supplier of wind power. The company is working with Progressive Energy to develop Carbon Capture and Storage for coal-fired power stations in the UK.

• EDF Energy is a subsidiary of internationally operating French company Electricite De France and is one of the largest UK nuclear energy companies, through its ownership of British Energy. They are the largest supplier of nuclear energy in France, running 58 reactors on 19 sites, and also have nuclear operations in China and the USA. EDF own two UK coal-fired power stations. EDF have been accused of land grabs for nuclear developments and CEO Vincent de Rivaz has been pushing for more reactors in the UK by 2017. In April 2009 a senior executive of EDF was reportedly charged on suspicion of spying on Greenpeace, who were campaigning against their proposed nuclear developments in Flamanville, France.

• E.ON UK is part of the E.ON group, which is based in Germany and operates internationally. They operate 12 nuclear power stations in Germany and have been lobbying the government to develop nuclear reactors as 'green energy' for the UK. E.ON owns coal and gas power stations in the UK and is one of the shortlisted companies funded by BERR to develop carbon capture and storage for so-called 'clean coal' technology . The company is the largest supplier of renewable energy to the UK grid and operates 20 winds farms and a hydro power scheme.

• RWE npower is a subsidiary of RWE, an international energy and water company operating in the UK, the US and across Europe. They built the first offshore wind farm at Hoyle, Wales and own considerable wind power resources as well as hydro and cogeneration plants in the UK. RWE also run coal, gas and oil power stations. RWE Nukem is a subsidiary who design, build and decommission nuclear plants, with a UK turnover of £60 million per annum (£245 million worldwide). RWE are developing a 450MW carbon capture demonstration plant, to be completed in 2014 . Outgoing RWE group CEO Harry Roels has emphasised the need for 'clean coal' and nuclear to ensure fuel security in the UK. 2000 to 2005 CEO of RWE trading Brian Count was the founding chair of the UKBCSE.

• National Grid is an international transmission and energy distribution business who own and run the transmission system for UK gas and England and Wales's electricity. They stand to profit significantly from changes to the transmission system needed for a transition to alternative energies.

• Scottish Power is an international energy business based in Glasgow with close connections to the Scottish parliamentary Executive . It operates in the UK and US in coal mining, gas storage and supply. It also operates large Scottish wind farms and plans to initiate a £10 million wave power project in Scotland. The company has been accused of 'fat cat payoffs' by Spinwatch for £10.9 million pay and pension compensation to ex CEO Ian Russell.

• Scottish and Southern Energy (SSE) is the second largest energy supplier in the UK with revenues of £15.3 billion in 2008. It was formed in 1998 following the merger of Scottish Hydro-Electric and Southern Electric and operates coal fired and gas power stations. SSE is the second largest renewables operator in the UK, mainly dealing in wind. Powerful CEO with Scottish Executive connections Ian Marchant was another UKBCSE Chair and used his position to push for the controversial Beauly-Denny powerline which it is claimed will damage valuable biodiversity.

Oil and gas giants Shell and BP are also supporters of the UKBCSE, and Shell in particular has worked closely with the UKBCSE on various initiatives, most recently the high profile 'Sustainable Cities Tour' on low carbon cities..

Key Figures

• David Green has been CEO of the UKBCSE since its launch in 2002, before which he was Director of the Combined Heat and Power Association (which shares offices with the UKBCSE). He was awarded an MBE in 1986 and OBE in 2003. He has considerable board room and government connections and according to World Energy is,

“a fellow of the Royal Society of Arts, fellow of the Energy Institute, member of the Council of the Parliamentary Group for Energy Studies, member of the high level Ministerial Advisory Group on Zero Carbon Homes, member of the UK Governments Delegation to the World Summit on Sustainable Development, and the follow up International Renewable Energy Conference and Executive Officer of the British Energy Association.”

• Brian Count was founding Chair of the UKBCSE and CEO of Innogy plc, which merged with RWE in 2003, after which he became CEO of Europe wide energy trading group RWE Trading, based in Essen, Germany. He is a non executive director of Eskom, the Africa's largest coal and nuclear company accused of making electricity unaffordable for black South Africans during apartheid, and continually accused of price differentiation which favours industry and the rich. According to the Ceres Power directors page he is;

“Chairman of Progressive Energy, a company that is working with Centrica to develop a clean coal fired power station in the UK; and is also a member of the UK Industrial Development Advisory Board of the DTI. He has extensive experience of international energy utilities and has been involved with governments and regulatory matters in both the UK and Europe. He sits on the BERR Energy and Climate Security Panel formed following the publication of the Energy white paper: meeting the energy challenge in May 2007.”

• Ian Marchant was Chair of UKBCSE until March 2008. He is a powerful Scot with multiple board room connections in the energy sector. In an article on the top 20 most powerful Scots, Lindsay McIntosh says:

“Ian Marchant is head of Perth-based Scottish and Southern Energy, which is behind the highly controversial Beauly-Denny power line.... He is also chairman of the Climate Change Business Delivery Group, a member of Ofgem's Environmental Advisory Group, the Coal Forum and of the Energy Research Partnership. In all senses, a powerful Scot with huge influence in the crucial energy sector - and in the crucible of discussion where business meets the green lobby and tries to find answers suitable for the future of Scotland.”

Marchant is also a proponent of clean coal technology, describing it as necessary to tackle climate change, despite the financial cost; "the charge sheet on climate change will be far more severe than the cost of CCS, and the cost of bailing out the financial system."

David Green (UKBCSE CEO), Peter Mandelson MP, and Brian Count (Innogy CEO) at UKBCSE New Years Reception

• Peter Mandelson publicly became the first UKBCSE patron in 2003, with considerable potential to aid the UKBCSE in policy through his role as Secretary of State for Business, Enterprise & Regulatory Reform (BERR). As CEO David Green commented,

“Peter’s vision, drive, policy perspective and experience will help the UKBCSE in its task to build the market conditions needed to deliver year on year growth in the development of sustainable energy. We are very pleased to have his support.”

His experience as Britain's Commissioner of the European Union for Trade (2004-2008) and strong pursuing of the neo-liberal agenda in Brussels fit well with UKBCSE market aims.

A 2003 UKBCSE Press Release suggests that more patrons would soon be announced , but there is no record of more announcements and the UKBCSE denied any knowledge of patrons in a phone-call the researcher made to their headquarters.

Political Schmoozing

The UKBCSE holds an annual Parliamentary reception, and has a presence at all three major political party conferences at which it holds holds fringe events and receptions. The 2007 annual Parliamentary reception included guests such as Rt. Hon. Alistair Darling MP, the Secretary of State for Trade and Industry, Lord Truscott, Parliamentary Under Secretary of State for Energy and Claire Durkin, Head of Energy, Innovation and Business, Department of Trade and Investment.

The 2005 G8 related conference “Climate Change - the Business Forecast” included a speech from Prime Minister Gordon Brown, Secretary of State for Trade & Industry, Rt Hon Alan Johnson MP. Secretary of State for Environment, Rt Hon Margaret Beckett MP, and Minister of State (Climate Change and Environment) Elliot Morley MP. Acknowledging their close ties Alan Johnson's speech at the event asserted that,

“we know we can only lead successfully by working with the business community…which is why events like today and organisations like the UK Business Council for Sustainable Energy are so valuable.”

Similarly the UKBCSE regularly issues responses which 'welcome' and praise government climate policy.

Pushing the Envelope: UKBCSE Strategies.

As their boardroom connections show, the UKBCSE wields considerable power in relation to government and the UK energy sector. Despite their membership makeup of companies mainly involved in coal, oil, gas and nuclear, they claim to be a lobby for renewable energy, and emphasise their members involvement in the renewables sector (predominantly wind). The close involvement of the UKBCSE with government and policy development raises concerns about potential conflict of interest between the UK's largest energy suppliers and a strong sustainable energy policy. Their lobbying activities push for 'strong renewables targets' and 'energy efficiency' but only if accompanied by the establishment of competitive markets for carbon trading which promote the lowest cost solution to carbon reduction (favouring wind, and also potentially 'clean coal' and nuclear, though these are never mentioned in their literature).

The researcher can find no evidence of UKBCSE's PR company, and it is possible that they do not have one. At any rate their PR work has been well executed in buying them a respected image in the eyes of government, business, local councils and NGO's. The next section will look at the UKBCSEs policies and some of the Public Affairs strategies which have made the UKBCSE a respected resource on renewable energy matters as well as an influential lobbyist in the UK and internationally.

Tactical transparency

The UKBCSE hosts an extensive website which archives all of their oft quoted official press releases, climate negotiations, reports, policy consultations and events since their inception. Such a display of openness is effective in giving an impression of transparency and accountability and reveals their consistent message that 'a real step change is needed both in the policy process and in the actual implementation, in order to enable the practical delivery of a low carbon economy' However a detailed examination of this archive reveals contradictory messages their attitude to energy descent.

Interestingly Freedom of Information Requests regarding meeting and correspondence between the UKBCSE and BERR, DECC, Ofgem, UK Trade and Investment and the Climate Change Projects Office returned responses that public interest relating to policy would be threatened if material was released and that the UKBCSE's relationship with these departments may be damaged, suggesting that perceived transparency only extends into certain areas of their operation.

Innovative technology or profitable incumbents?

The 2008 report 'Implementing the EU Renewable Energy Target in the UK Emerging Issues for Consideration' is referred to by BERR and DECC and has become a seminal government source on EU renewables target issues, strongly echoing the themes of the 2007 Energy White Paper. The paper similarly speaks of 'creating the right conditions for investment', reforming the planning system, and creating stable carbon markets. . It makes recommendations to the government's upcoming 'Renewable Energy Strategy' and claims to be a 'high level analysis' of the implications of the UK Renewables Obligation to generate 15% renewable energy by 2020. The report outlines potential capacity for expansion of renewable generation in the UK, focusing on onshore and offshore wind, with some mention of the Severn Barrage project, while totally ignoring other forms of generation. They estimate that 68GW of new build will be needed by 2020 to meet the target and back up capacity necessary (highlighting that this figure does not account for inevitable increase in energy demand). This will almost double the current usage of 76 GW (mainly due to the back up capacity needed for wind power which the report focuses on). However, available wind projects will only give an extra 16GW (though in the executive summary they give a figure of 38GW) (and Severn Barrage will not be online in time), leaving 50GW of demand capacity unmet, and 34GW of new transmission (powerlines etc) capacity needed. Emphasis is put on the controvesial Beauly-Denny power line from Scotland to England which is being built by ex Chair Ian Marchant's Scottish and Southern Energy.

Crucially, the report also seems to encourage a growth in energy demand in the UK (which is not surprising considering their membership):

'The extent to which energy efficiency policies are implemented in the UK will have a significant impact on the amount of renewable energy that will be needed to meet the target. It is worth noting that the biggest opportunity for energy efficiency is in reducing heat consumption, and is less likely to impact on future demand for electricity. '

This report can be seen as biased as it ignores the potential for a diversity of renewable technologies and focusses soley on wind energy. Using only wind figures and without consideration of energy demand reduction or energy efficiency measures the report shows a shortage of available wind power to meet the target. This conclusion not only points to raised profits for UKBCSE members in wind and transmission (through increasing demand, huge restructuring, customer price rises and government support) but also leaves the issue of energy shortage open, while also promoting continued economic growth, creating an excellent (though unspoken) case for nuclear or clean coal. Despite the expensive and experimental nature of Carbon Capture and Storage (CCS), these technologies are promoted by the energy sector as more developed and economically viable than alternative renewable options (such as wave and tidal power). The acceptance of this data by government departments shows considerable bias towards the policy wishes of large energy companies represented by the UKBCSE.

In contrast to the sustainability rhetoric in this document, another UKBCSE report speaks of renewables in terms of fuel security, not environmental quality, and sees their value as a hedge against high fossil fuel prices, similarly suggesting that any cheap and secure fuel source should be pursued.

Carbon trading and market based solutions at the expense of the climate.

Central to the UKBCSE's strategy is emphasis on strong carbon markets, emissions trading and lowest cost market based solutions to climate change, which they see as key to fulfilment of the renewables target by their members.

The UKBCSE approaches this policy through a number of lobbying strategies and a wide range of collaborations. In a joint letter with top environmental NGOs Greenpeace and Friends of the Earth, to the Secretary of State Margaret Beckett in 2005, they emphasise 'an ambitious and practical' programme on climate change, noting the 'unique opportunities' presented by climate change. (For the UKBCSE's members this may refer to stimulating large alternative energy contracts.) The letter asks for 60% emissions reduction targets for 2050 but only in the context of continuation of the EU Emissions Trading Scheme (EU-ETS), which it sees as essential to achieving this target. EU-ETS is a liberal market based measure which encourages lowest cost solutions as opposed to long term investment in truly sustainable technologies. A European Commission 2005 survey of EU-ETS stakeholders revealed that only 19% thought the system would have a strong impact in developing renewable technology.

In another government commissioned report written with The Climate Group (large business lobby representing major transnational corporations such as PepsiCo, BP and Dow Chemical), the UKBCSE makes a different argument. It notes that large multinationals are not primarily driven by International policy but by their own analysis of the economic benefit of changing behaviours, suggesting that low cost market solutions that will ensure continued economic growth for big business are the only way to meet carbon targets. Since economic growth in a capitalist system ultimately centres on resource extraction, the continued expansion of large multinationals can be seen as absolutely 'part of the problem'. These groups are generally not supportive of strong and effective climate policies, which, to the contrary of their argument here, do depend upon low or zero economic growth of large scale polluting industries. This report also makes the bold statement that businesses want to be part of policy development at a national level from the earliest stage possible, highlighting the possibility of serious conflicts of interest arising in the formation of such policy. It would be interesting to know whether such a high profile report has also been commissioned by government from proponents of strong climate policy to balance this point of view.

The UKBCSE's successfully created reputable status allows the Council to collaborate with many, and sometimes divergent groups, from government to NGO's, and international energy sector to small micro-power lobbies, strengthening their lobbying objectives, by approaching them from a number of different angles, and enhancing their networks and public image.

Climate Negotiations and EU strategy

The UKBCSE send submissions and a delegate to climate negotiations in collaboration with their USA, EU and Australian sister groups and the London Climate Change Services (an affiliated organisation who share staff and are based in the same building as the UKBCSE). These high level submissions effectively represent the largest energy companies from western countries with the most neo-liberal policies (Australia and the USA are particularly well known for holding back the Kyoto process and demanding international emissions trading against stronger climate policies).

These submissions generally assert the importance of stable carbon markets, emphasising the importance of the contentious Clean Development Mechanism which they see as 'working' to stimulate investment and 'change attitudes' internationally in the business world. In praise of continued economic growth Jim Wolf (USBCSE), delegate to the negotiations for this coalition, states: "We are positive proof that the right framework and signals on climate change will unleash the ingenuity of the private sector to deliver profitable solutions." Given the ineffectual nature of market based Kyoto policies to date it is hard to see where such 'proof' might lie.

One of the market based initiatives pushed by the UKBCSE and similar UK energy lobby groups is the current renewables obligation, which requires suppliers to produce a certain percentage of energy from renewable sources (creating Renewable Energy Certificates (ROCs)). UKBCSE has continually pushed for a liberalisation of this policy, and lobbied for extra-EU trading of ROCs in line with policy on deregulation pushed by Eurelectric. Eurelectric is a powerful EU level electricity producers lobby promoting market based neoliberal approaches to climate change, and whose head has privately criticised EU renewables targets as too high. Its two UK members, The Association of Electricity Producers and the Energy Networks Association representing electricity production, distribution and transmission providers in the UK, share most of their members with the UKBCSE.

Evidence from observations of different EU state national policies have shown that REFIT (Renewable Energy Feed In Tariff) type 'command and control' policies, such as in Germany, Denmark and much of Europe, have been more effective in delivering carbon reductions than ROC type schemes favoured by the USA and UK. Market based schemes such as the UK's have been accused of favouring existing technologies and market dominance by major suppliers and preventing the growth of independent generators or emergent technologies. It is even suggested that dominating large energy companies (represented by the UKBCSE) deliberately keep fulfilment of the obligation low to maintain competition for ROCs and a high carbon price.

The UKBCSE and Energy Retail Association (another lobby group with almost identical membership makeup) have also lobbied against 'banding' of the Supplier Obligation, a reform to encourage the growth of smaller suppliers and newer technologies. Toke accuses large energy companies who dominate the ROC market of rejecting these REFIT-like changes because they perform better than deregulated trading and would encourage competition from other companies. This policy suggests that in contrast to their sustainability rhetoric, the UKBCSE is not in favour of strong carbon targets, but only policies which are profitable for their members.

Redefining Energy Efficiency

Confusingly, against this backdrop of economic growth and energy demand, the UKBCSE names 'the development of energy efficiency' as a key policy area. However a closer look at their literature reveals a similarly liberal attitude to 'energy efficiency'. The UKBCSE puts emphasis on 'low carbon' as opposed to 'low demand'. In a report on the Supplier Obligation it states:

'Although the call for evidence indicates that this policy is about demand reduction and efficiency improvements, a number of key players believe that the policy should focus more directly on carbon reduction. The main arguments for a carbon-based mechanism are that: it would facilitate more innovative approaches and products; it would facilitate the ‘zero carbon homes’ policy commitment; and could assist the alignment of policy instruments around a single cost of carbon.'

Language of 'carbon reduction' not 'demand reduction' make room for offsetting, carbon capture, trading (hence the emphasis on carbon price) and other contentious 'innovations', which avoid the essential need to reduce energy demand in addressing the serious threat of climate change.

The report talks of uncertainty around a 'market for energy services', and the need to focus on heat not electricity, and notes that energy companies should not be held excessively responsible for energy demand reduction, for which considerable onus is also on government, building designers and other bodies (e.g the Energy Saving Trust). In other places the UKBCSE talks about efficient homes products supplied by its members.

Beneath the greenwash such rhetoric speaks of creating markets which will benefit its business members, through supplying energy efficiency services, without aiming to limit electricity demand.

The UKBCSE recently carried out the 'Sustainable Cities Tour'; a high profile carbon reduction campaign hosted with Shell to assist 'core cities' identified by the government to 'cash in' on the green economy, and divert some of the national £50 billion a year council spending to green initiatives (e.g energy and services provided by themselves).

Conclusion

With offices in Grosvenor Square close to governmental buildings, and board room and personal connections across the government and international energy sector, it is clear that the multinational energy companies represented by the UKBCSE have exercised considerable influence on UK and EU policy. However the market based and growth centred strategies they promote constitute considerable conflicts of interest with strong climate policy in the UK, as evidenced by the small percentage of renewable energy generated in comparison to less deregulated European countries (such as Germany). They promote opportunities for large scale growth in the green energy sector, emphasising that virtually the entire transmission, distribution and plant network will have to be renewed and rebuilt, stimulating business for their members. Further it is suggested that the UKBCSE's lobbying objectives point to the possibility that the organisation could be acting as a green front for new coal and nuclear policies, through the promotion of ineffective mechanisms for renewables and growing energy demand.

Despite their high media and public presence, the researcher can find no existing critiques of this organisation, suggesting that their public affairs strategy has been most effective. These strategies can be seen as greenwash, as the rhetoric and image the UKBCSE creates do not match the lobbying actions of the organisation, or the activities of their members companies.