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survey see chapter 5 found that only the largest companies more than 3,000 employees thought they had the necessary knowledge.
4.2 Ways to mitigate the negative interaction
In our 2007 audit report on the implementation of the CO
2
emissions trading system, we recommended that the government review the cost
benefit ratio of each instrument to reduce CO
2
emissions and reconsider its use Netherlands Court of Audit, 2007. In 2009 we investigated the
follow-up to this recommendation Netherlands Court of Audit, 2009a. Although the Ministries of EZ and VROM recognise the interaction and its
consequences, the government has not reconsidered the policy. Yet measures can be taken, separately or jointly, to resolve this problem.
1. Focus energy saving policy on energy consumption outside the emissions trading system
A first option is to sharpen the policy focus on energy consumption not subject to the emissions trading system. This consumption comprises a
the gas consumption of manufacturers that are not subject to the CO
2
emissions trading system, b the gas consumption of the household, trade, services and public sectors, and c the energy consumption of the
transport sector. 2. Focus energy saving policy on long-term effects innovations
A second option is to apply the policy instruments used in the sectors participating in the CO
2
emissions trading system to develop innovations that are viable in the long term, for example in the biobased economy or
alternatives to fossil fuels. At present, CO
2
emissions trade encourages measures that are viable in the short term.
3. Lower the CO
2
emissions ceiling A third option is to strengthen the operation of the trading system to
make emission allowances so expensive that companies invest in meaningful energy efficiency improvements and in renewable clean
energy. This can be achieved by lowering the emissions ceiling before the next trading period after 2012 or by significantly cutting it for the
period after 2020. This option would require a decision at European level. As a member state, the Netherlands can seek support for this option. If
a decision is not taken at European level, the government could buy up emission allowances and take them temporarily out of the market.
This expensive option would require cooperation among several European countries.
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Finally, the additional effect of Joint Implementation and the Clean Development Mechanism CDM should be studied. The schemes enable
companies to invest in clean technologies abroad and use or sell the allowances awarded for the greenhouse gases saved abroad. There is
some doubt about whether the projects facilitated by these schemes are really additional or not. The University of Stanford studied the CDMs
potential to the United States. The authors advised against introducing a similar mechanism, partly because the current CDM market did not
produce a real reduction in CO
2
emissions Wara Victor, 2008.
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5 Energy saving opportunities in
the manufacturing sector
This chapter presents the main findings of our in-depth audit of the manufacturing sector. The in-depth audit asked three questions:
What reasons, objections and preconditions encourage one manufacturer to invest in energy savings and another not to?
What are the cost benefit ratios of the governments policy instruments to save energy in the manufacturing sector?
To what extent do policy instruments agree with the companys energy saving reasons and do those that agree more work better?
5.1 Characteristics and policy instruments in the
manufacturing sector
The distinction between energy intensive industries and other industries in the manufacturing sector is very important. Energy intensive
industries, such as refineries and chemical and base metal companies, together accounted for 28 of national energy consumption in 2008 CBS
et al., 2010a. The manufacturing sector as a whole was responsible for 42 of national energy consumption in 2008 CBS et al., 2010b.
The key instruments in the fourth Balkenende governments energy and climate policy for the manufacturing sector were the CO
2
emissions trading system and the voluntary and multiyear agreements. The key
instrument for companies not participating in the voluntary agreements or the trading system was the Environmental Management Act. The
instruments were backed up with financial schemes such as grants and fiscal instruments.
Below, we look at the assumed operation of the policy instruments. The audit is based on the adopted policy and did not consider whether the
underlying policy assumptions were correct. The European CO
2
emissions trading system Although the trading system is designed primarily to reduce CO
2
emissions, we included it in our audit as an energy saving instrument
