UK Infrastructure Bank Bill [HL] - Report – in the House of Lords at 3:30 pm on 4th July 2022.
Moved by Baroness Hayman
1: Clause 2, page 1, line 12, at end insert—“(ii) to adapt to any current or predicted impacts of climate change identified in the most recent report under section 56 of the Climate Change Act 2008, and(iii) to protect, enhance and restore the United Kingdom’s natural capital, including by supporting efforts to meet the targets and improvement plans under Chapter 1 of Part 1 of the Environment Act 2021,”Member's explanatory statementThis amendment clarifies that the Bank’s objective to help tackle climate change includes mitigation of climate change, adaptation to climate change, and the protection and restoration of the UK’s natural capital.
My Lords, I declare my interest as a director and co-chair of Peers for the Planet.
I thank the Minister for the constructive dialogue that has taken place throughout the passage of the Bill, including the meeting with the bank’s chair and chief executive last week to discuss their new strategic plan and the subsequent letter from the chief executive, which we received today. These meetings have been useful and have provided some comfort that the bank’s leadership, which is obviously of very high quality, has considered and intends to address many of this House’s concerns about issues such as natural capital, climate resilience and how certain types of infrastructure, such as gas and roads, will be treated. It would, however, be extremely helpful if the Minister made clear from the Dispatch Box the position on gas exploration and road building, concerns about which were raised in Committee and in our meeting. Although I know she believes that those concerns are unfounded, it would be helpful to have on the record some of the assurances that we received informally.
I welcome the Government’s amendment on energy efficiency, to which I have added my name. It is a much-needed signal of their recognition of the urgency and importance of making progress in this area. I hope the Minister may have an opportunity to have a word with her noble friend about the Social Housing (Regulation) Bill, where we could do with some movement on the same topic.
Where we have not made progress in making changes to the Bill is on the environmental priorities, including nature-based solutions, the circular economy and adaptation. It is with these issues, about which we spoke at length in Committee, that this group of amendments is concerned. I have tabled Amendments 1 and 6A, while similar related issues are raised in amendments tabled by the noble Lords, Lord Teverson and Lord Holmes of Richmond, and the noble Baronesses, Lady Jones of Whitchurch and Lady Bennett of Manor Castle. My amendments have signatories from all sides of the House, for whose support I am extremely grateful. Indeed, the Minister herself recognised the importance of these issues but simply queried the need to spell them out in the Bill.
Following the Minister’s comments in Committee, my Amendment 1 no longer sets out a third stand-alone objective for the bank, which she indicated would be extremely difficult to do, but is limited to expanding on the climate change objective to clarify exactly what
“to help tackle climate change” means for the bank in practice, and to reflecting what has been indicated by the Chancellor, the Minister and the bank itself—that is, that resilience and adaptation measures and nature-based solutions absolutely fall within the scope of the climate change objective.
Given the consensus on this, it is hard to understand the argument against including these additional proposed new subsections and making clear that the bank has within its founding objectives a coherent, integrated response to climate change, and sending a clear message to the markets that these are priority areas for market development. We all agree on this, so why do we not make that clear to everyone else out there?
Including nature in the Bill in no way ignores the fact, as has been argued, that the market for nature-based solutions is nascent. What it does provide is a strong signal that the bank recognises that it has a role in developing capacity towards a pipeline of investable projects and will be poised to act—crucially, encouraging others to do the same—when these come to fruition. Moreover, the bank has a role now in helping build and develop these markets, including through taking a nature-positive approach to near-term projects, building internal capacity for future projects and taking a joined-up approach across government-related bodies, including UKRI, the British Business Bank and local authorities, to help seed projects and initiate the local capital and innovation needed to bring those projects to market.
On adaptation, we are told that it is agreed that climate-resilient infrastructure is critical to reaching net zero, and that mitigation and adaptation will be considered together. But even the Climate Change Committee’s most recent progress report last week observed that the UKIB consultation on investment priorities focused on key net-zero infrastructure priorities, but
“has no mention of adaptation.”
Clarity, focus and policy direction are needed.
Amendment 6A, the second tabled in my name, offers an alternative approach to these issues by including the circular economy and nature-based solutions in the definition of infrastructure, by making explicit that the infrastructure solutions set out in the indicative list in Clause 2(5) include those related to the circular economy and nature. As the Minister will have noticed, it mirrors the approach that the Government themselves have taken to energy efficiency.
I have already spoken about the importance of including nature in the Bill. It was generally accepted how important an issue it was in Committee, so I can be brief on this point. It is not in question that nature-based solutions play a role. The bank’s new strategic plan, which is focused on short initial timescales, already provides examples of some of the main near-term opportunities in the water sector for nature-based solutions. Explicitly stating that nature may play a part in infrastructure projects which realise the bank’s objectives would provide the confidence and the clarity needed to give momentum to the development of these solutions.
Similarly, adopting circular economy structures within the definition should be uncontroversial and a signal of how infrastructure projects may be approached. The bank’s strategy already says that it is
“open to financing … circular economy projects.”
A circular economy approach is completely in step with producing positive synergies between the bank’s objectives. Circular economy principles recognise planetary boundaries, promote fairness and reduce overconsumption. It is estimated that circular economy infrastructure could support up to 450,000 jobs by 2035 in reuse, recycling and remanufacturing. Crucially, those jobs would be in occupations and areas suffering higher rates of unemployment.
In our debates, the Minister spoke at length about the need for clarity, but the Bill is Parliament’s only opportunity to be not only clear but explicit about policy priorities. The Government recognised that by proposing their own amendment on energy efficiency. I believe that there is support all around the House for taking exactly the same approach to nature-based solutions and the other issues covered in these amendments. I beg to move.
My Lords, I am pleased to follow the noble Baroness, Lady Hayman. I also welcome the Minister’s and the Government’s change of mind, if you like, on including energy efficiency specifically in the Bill. We all know that the International Energy Agency cried out about developed nations not doing anything about energy efficiency. We also know that it is the cheapest and most effective option: this programme would avoid huge amounts of further capital expenditure. We have not been good at making sure that we pursue that for our housing or building stock.
Having said that, energy efficiency, as measured by output against energy per year, has gradually increased over the years in this economy. This is the silent way of reducing the energy bills that so many of us receive in our inboxes these days—I was going to say through our letterboxes—and I really welcome that. But it is not enough.
I put down an amendment, similar to the noble Baroness’s, on including “biodiversity” and the recovery of nature as an objective. I do not understand why the Government do not find it straightforward to include this, because it accepts that there is a biodiversity emergency. The Treasury in particular produced the fantastic Dasgupta report, which went through the whole area of natural capital, partly covering how we can solve this issue but also clearly painting the challenges. I congratulate the Treasury on having initiated that report but perhaps not quite so much on the follow-up to date. But here is an opportunity to put this into the Bill.
However, if we cannot have this as an objective in the Bill, I very much support Amendment 6A tabled by the noble Baroness, Lady Hayman, which references
“the circular economy, and nature-based solutions”.
This could be a major step for government policy on the circular economy, which was very well described by the noble Baroness. But I get the impression that, out there in the real world, people are enthusiastic about local repair shops and being able to mend the stuff they buy so that they do not have to buy it again, saving money and resources and helping on climate change. So, the circular economy element is equally important.
Of course, nature-based solutions are a natural way—literally—not just for a number of climate change and biodiversity recipes but to help the natural environment in all sorts of ways. They do this more cheaply and, compared to just pouring concrete, have wider effects, as we know, on areas of adaptation like water quality and flooding, which have been so neglected, as the noble Baroness said.
I favour Amendment 9, tabled by the noble Baroness, Lady Bennett. If we saw any UK Infrastructure Bank investment in roads, we would be concerned about its climate change objectives. I also strongly support, and have put my name to, Amendment 11 in the name of the noble Baroness, Lady Jones of Whitchurch. I am sure that she will explain this herself, and I will not remark on it at this stage.
My Lords, I rise to speak in particular to my Amendment 9, and I thank the noble Lord, Lord Teverson, for his support. I very much agree that climate change means that we cannot be building new roads, although big issues of air pollution are of course also addressed in this group.
I have to begin, since I do not get the chance to do it very often, by commending the Government on their amendment on energy efficiency. It demonstrates the sentiment of our debate in Committee—and indeed throughout the House and the country—and shows that campaigning really does work. Let us see lots more of it.
Essentially, I agree with everything the noble Baroness, Lady Hayman, and the noble Lord, Lord Teverson, have said, so I will not repeat those points. However, we are increasingly hearing from the Government about the importance of biodiversity and the state of nature. Indeed, I had the pleasure recently of attending an event at the Groundswell Regenerative Agriculture Show & Conference, at which the Government and Members of this House and the other place expressed their concerns and spoke of the importance they place on restoring nature. Surely, the Infrastructure Bank should be explicitly directed to do that.
As the noble Baroness, Lady Hayman, said, we are talking about sending a message to the bank and to the country about the importance of biodiversity in nature, and we can also look to the international stage. We see reports expressing grave concern about the state of the COP 15 biodiversity talks, and the entire nature community is screaming out for leadership in those talks. Clearly, as the chair of COP 26, it should be our responsibility to lead the way. As the noble Baroness said, if the Government are saying, “We already mean this anyway”, what is the harm in including such a provision in the Bill and sending that message out to the international community as well as to the country?
On the circular economy amendment, in Committee I tabled an amendment calling for a reduction in resource use. In the interests of efficiency and time—and given that I was not getting many positive signals from the Government—I did not table it this time, but I think the Government will come back to this issue so that we can make at least some progress on it. Explicit support for a circular economy, which is a necessary but not a sufficient condition, given that we continue to treat the planet as a mine and a dumping ground, is essential in order to see some progress. We will certainly see the other place pushing on the question of resource use.
My Amendment 9 is a modest amendment, and it is perhaps worth making clear what I mean by it. I am very happy if the Government want to look at using different terminology, but I point out that what I mean by “roads” is major stretches of roadway. I do not mean tracks up to new onshore windfarms, government enthusiasm for which we are finally seeing signs of in the media, which is greatly encouraging. If the Government wish to find another form of wording, I point out that, clearly, what I am referring to is major road infrastructure. As the noble Lord, Lord Teverson, said, the climate emergency does not allow that. This issue crosses over with the clean air amendments in this group, and the issues of disadvantage that we are going to discuss in the next one. Broadly speaking, air quality is worst in the poorest, most disadvantaged areas of the country. New roads are the last thing those areas need, as they would make the air quality even worse.
To say that the Infrastructure Bank is not for roads but for mass transport should be considered uncontroversial. It is not my intention to put the amendment to a vote, but this is a debate that will continue in the other place. I commend all these amendments to your Lordships’ House.
My Lords, I rise to speak to Amendments 7 and 10 in my name, but before I do I join others in congratulating my noble friend the Minister on tabling the government amendment on energy efficiency. It speaks to an amendment that I and others tabled in Committee, and it is certainly welcome that it will now, rightly, be included in the Bill.
Amendment 7 would insert just three words: “nature-based solutions”. There is a lot in the Bill about climate and carbon, but the reality is, as noble Lords are well aware, whatever we do and must do on that front, we will still be left with a pressing, urgent need for nature-based solutions. As other noble Lords have mentioned, we have “roads” in the Bill. As the noble Baroness, Lady Bennett, has just pointed out, I do not think anybody would necessarily be against roads as a secondary, tertiary or lower-level aspect of an infrastructure project—to get to the shoreline for offshore wind, to give another example. However, that is at best a tertiary part of the bank’s investment, or of that particular infrastructure project, yet it is in the Bill. If “roads” can be there, surely “nature-based solutions” has at least an equal place in the Bill. Would my noble friend consider including “nature-based solutions” and, in exchange, taking “roads” out of the Bill? That would be a thoroughly good thing.
Finally, in similar terms, my Amendment 10 would insert “clean air”—perhaps one of the most significant, precious and essential parts of our infrastructure. Does my noble friend the Minister agree that it would not be difficult or controversial, and that it would be a thoroughly good thing, to have “clean air” on the face of our infrastructure bank Bill?
My Lords, the House this afternoon represents one of the Prime Minister’s favourite metaphors: a nest of singing birds. Everybody who has spoken agrees with each other; I agree with everything that has already been said, but particularly with what my noble friend Lady Hayman has said. I have added my name to her Amendment 1, and I will make just two additional points to the ones she made.
First, the Government agree that nature, nature recovery and nature-based solutions are important, and they say that all of that is encompassed within the Bill as drafted. But if nature is not mentioned on the face of the Bill, it will always look secondary; it will always nest behind climate. It will not have the same prominence or importance, yet all the facts suggest that the biodiversity crisis is at least as urgent as the climate crisis. These two things, according to the facts and the evidence, deserve to be side by side. If they are not, the bank and others will draw obvious conclusions.
Secondly, the only point I have heard made for why there is resistance to having nature on the face of the Bill is that there are not really any projects ready to go. My answer to that is: so what? This Bill is setting the course for the years ahead. It does not matter that there is not something ready to go in the next few months, because these projects will surely come. One issue that has detained your Lordships’ House time and again over the last year has been water quality and the fact that water companies are dumping sewage hundreds of thousands of times a year into our rivers and the sea. It is easy to imagine a project on water quality that would not really be about climate but would be all about nature. Surely that would deserve to be supported by the UK Infrastructure Bank. So I ask the Minister to reconsider one last time.
My Lords, first, I apologise for not attending the earlier stages of the Bill. I was caught out by conflicting diary commitments, but I have been following the debates and the developments around the Bill through all the stages, and my noble colleagues will know of my interest in this issue.
We have been grateful to the Minister for the continued dialogue on the contents of the Bill. However, as we heard today, there remains unfinished and unresolved business, and I am therefore grateful to the noble Baroness, Lady Hayman, and all noble Lords who set out the case for their amendments so clearly; we share their concerns. The number and range of amendments in this group on the environmental priorities demonstrate that there is a feeling across the House on this issue. The noble Lord, Lord McDonald, described it beautifully as a “nest of singing birds”. I concur with that description, because there is a concern that the ministerial responses in Committee simply have not been good enough to embed “nature-based solutions” and the “circular economy” into the bank’s founding legislation. However, we believe that these principles are crucial for the creation of green jobs, for harnessing the best science and technology, and for reshaping the economy away from the damaging fossil fuel mentality that exists at the current time.
Amendments 1 and 3 demonstrate our ongoing concerns about the implementation of the “biodiversity” and “natural capital” commitments of the Environment Act, which, as the noble Lord, Lord Teverson, quite rightly pointed out, were designed to underpin the very compelling evidence in the Dasgupta review. In that report, Dasgupta made it clear that enhancing nature and biodiversity are more than aspirational extras; they lie at the heart of our future economic and social well-being and are fundamental to delivering our climate change commitments. This is why we believe that these principles should be a major driver of the bank’s activities and spelled out in the Bill. As the noble Baroness, Lady Hayman, has made clear, the Chancellor’s strategic steer in March set out that the Government are already calling for the bank to grow natural capital markets through its investment. This Bill seems the proper vehicle to drive that policy through.
I have also added my name to Amendment 6A, which would make it clear that the definition of infrastructure projects should be widened to include “nature-based solutions”, rather than just concrete and metal. I also think that Amendment 9 of the noble Baroness, Lady Bennett, quite rightly challenges the emphasis on “roads”; surely public transport and green energy should be priorities in future. “Nature-based solutions” can be anything from creating natural flood defences to restoring our woodland, peatland and parks. The growing market for investment in nature-based land use is an illustration of its potential for delivering our climate change commitments.
The amendment also embeds the principle of the “circular economy”, putting greater emphasis on our scarce resources through better reuse, repair, recycling and remanufacturing. As noble Lords have said, these are principles to which the Government are already committed but have been slow to implement. Placing these in the Bill would provide the means for drawing in new revenue streams to transform our manufacturing processes. The noble Baroness, Lady Hayman, has already set out a convincing argument for Amendment 6A and—depending on the Minister’s response—if she wishes to test the opinion of the House, we will support her.
We also have our Amendment 11 in this group, which seeks to expand the definition of “harmful pollutants” to include those
“which are not greenhouse gases but” other forms of “particulate matter”, such as car tyre air dust, which can be just as
“detrimental to air quality and human health.”
Therefore, we think that the case for expanding that definition is vital. I am grateful to the Minister for her discussion with my noble friend Lord Tunnicliffe on this issue, and hope that some of those assurances can be placed on the record today.
As is the case with so many other Bills, there seems to be a significant gap between what the Government say they want to achieve and what they are willing to commit to in legislation. Whether it is biodiversity, air quality, the circular economy or ensuring that infrastructure projects use nature-based solutions, their record of delivery does not match their stated ambitions. There always seems to be a political or legal excuse for delay. All we are doing in these amendments is formalising policy commitments already agreed by the Government, and providing a mechanism for financial support. There is already a review process built into this, but, if we are not rightly ambitious about delivering projects outside the normal investment portfolios, we will find ourselves in the seven-year review stage facing a tally of missed opportunities. This is why it is so important for noble Lords to support the amendments in this group, and I hope that they will.
My Lords, we start Report with a topic that has already been central to our discussion of the UK Infrastructure Bank: its role in investing in nature and the environment. I thank the noble Baroness, Lady Hayman, and all noble Lords who have engaged with the Government on this important topic.
I turn first to Amendments 1 and 3, in the names of the noble Baroness, Lady Hayman, and the noble Lord, Lord Teverson, which seek to add natural capital, biodiversity, wider environmental targets and climate adaptation to the bank’s climate change objective. As we discussed in Committee, nature-based solutions and projects to support climate adaptation are already within scope for the bank. Those who attended the briefing with the bank’s chief executive and chair last Tuesday will have heard that the bank is keen to explore this area. We have given thorough consideration to the question of adding to the bank’s objectives through our environmental review on whether nature-based solutions should be in the objectives. We engaged with a wide range of stakeholders during this review, from think tanks to investors, and we heard from a majority of them that they felt that there was already significant scope for intervention in nature-based solutions within the bank’s existing mandate without adding a third objective.
In considering this question it is important to acknowledge that the bank already has two stretching and broad objectives that are the outcome of significant work, starting from the recommendations of the National Infrastructure Commission and the national infrastructure strategy. Ultimately, the bank is an infrastructure bank, so it should invest in nature as a means of achieving its objectives and to enhance the UK’s infrastructure. The Chancellor made this clear to the bank when he sent it a strategic steer in March this year. The bank’s strategic plan sets out that it will explore opportunities to invest in nature and highlights opportunities to invest in water-related projects, as the noble Baroness, Lady Hayman, mentioned.
While the bank’s scope to invest in nature is already significant, it is important to note that this is not the only, or indeed primary, government intervention to support the market for natural capital projects. I will mention just a few areas. To provide an accredited route for income for nature projects, the Government are backing the maturation of the woodland carbon code and peatland code through the nature for climate fund and woodland carbon guarantee. To create demand for nature projects, we are implementing regulation to grow the market—for example, through mandating biodiversity net gain for development. The nature recovery Green Paper also sets out plans in this area, specifically on ensuring that environmental regulation and regulators, including Natural England, the Environment Agency and Ofwat, are equipped to support the uptake of nature-based solutions and more strategic, landscape-scale approaches to environmental protection and enhancement by industry. To help the market mature from grant support to a more commercial basis, Defra has established the natural environment investment readiness fund of up to £10 million, which will provide grants of up to £100,000 to environmental groups, local authorities, businesses and other organisations to help them to develop nature projects in England to a point where they can attract private investment. Defra is also initiating the big nature impact fund, a blended finance vehicle designed to use public concessionary capital to attract private capital into the fund. The fund will invest in a portfolio of natural capital projects that can generate revenue from ecosystem services to provide a return on investment. These initiatives will support the growth and commercialisation of the natural capital market.
I thank the noble Baroness, Lady Hayman, for her support for the government amendment in my name. I again reassure noble Lords that it was always the Government’s intention that the bank could invest in projects to increase energy efficiency—for example, the retrofitting of homes. In fact, this forms a key aspect of the bank’s strategic plan. However, recognising the points raised in debate on this, I have tabled this amendment to add “energy efficiency” to the non-exhaustive definition of infrastructure in Clause 2 to ensure that it is explicit that the bank can invest in projects to increase energy efficiency.
Amendments 6A, 7, 9, 10 and 11 all seek to make further changes to the definition of infrastructure in the Bill. Amendments 6A and 7 seek to add “nature-based solutions” to the definition of infrastructure. As noble Lords have already heard, the Government are confident and, through our review of the bank’s environmental objectives have sought third-party views to ensure, that the definition we have included covers nature-based solutions. The bank’s strategic plan also makes clear its commitment to supporting the development of a circular economy.
On Amendment 9 in the name of the noble Baroness, Lady Bennett, I hope she has received the letter from John Flint, the bank’s CEO, on this issue. As highlighted in the bank’s strategic plan, we do not anticipate the bank investing much in roads. However, it is important that it has the flexibility to do so under the right circumstances. The bank may, for example, consider supporting local authorities in road upgrades that feature as part of their wider transport infrastructure and transport decarbonisation plans. For example, the bank has already financed the West Midlands Combined Authority’s sprint bus programme, which includes road adaptations such as priority signalling, redesign of junctions and additional bus lanes.
I take this opportunity to comment on the bank’s investment in gas, which the noble Baroness, Lady Hayman, asked about. The bank will not lend or provide other support to projects involving extraction, production, transportation or refining of crude oil, natural gas or thermal coal, with very limited exemptions. These exemptions include projects improving efficiency, health and safety and environmental standards, without substantially increasing the lifetime of assets, for carbon capture and storage or carbon capture, usage and storage where projects will significantly reduce emissions over the lifetime of the asset, or those supporting the decommissioning of existing fossil fuel assets. The bank will not support any fossil fuel-fired power plants unless this is part of an integrated natural gas-fuelled CCS or CCUS generation asset.
Finally, I come to Amendments 10 and 11 tabled by my noble friend Lord Holmes and the noble Baroness, Lady Jones of Whitchurch. This is a difficult area to tackle, so let me set out how the bank considered the wider environment within its policy framework. First, there are investments which, while addressing climate change or growth, can help to improve the environment. Separately, there is a policy framework considering whether and the extent to which the bank’s investments impact environmental factors beyond climate change. With this in mind, I shall set out how the objectives of the bank relate to pollution.
The bank’s objectives are tackling climate change and regional and local economic growth, but not wider pollution. The bank can invest in projects that tackle pollution, but only so long as they also help to achieve its core objectives of tackling climate change or regional and local economic growth. Investments directly into infrastructure to tackle other pollutants that can impact clean air will already be broadly covered by the existing definition of infrastructure and the objectives in the Bill. For example, tyres would fall under transport, in the same way that water pollution is covered by water, and tackling those pollutants is in scope as long as that investment is also tackling climate change and/or facilitating regional and local economic growth. As we have discussed, there are likely to be large numbers of synergies in this area.
I know that there has been interest from Peers in broadening the bank’s definition of infrastructure to ensure that the bank takes into account the wider environmental impacts, beyond climate change, of its investment decisions. Widening the definition of infrastructure in this way is not the best way to achieve this. Instead, the way that wider environmental impacts are dealt with is via the bank’s environmental, social resilience and governance policy. The ESRG policy and framework that the bank is developing will be used to screen projects and provide transparency on its portfolio. Part of this policy will involve collecting data from each investment to meet reporting standards, such as the forthcoming sustainability disclosure requirements, which will include green taxonomy reporting. The objectives of the green taxonomy include pollution prevention and control, which the bank will need to report on for its investments.
More broadly, infrastructure projects are subject to a range of environmental regulations appropriate to their specific type and circumstances. It would not add value to apply these directly to the bank when they already bind the project developers directly. Defra is consulting on new legal targets for air quality, water, waste, and biodiversity, which the Government are required to set under the Environment Act by October this year and which noble Lords will be well aware of.
I hope, therefore, I have provided sufficient reassurance for the noble Baroness, Lady Hayman, to withdraw her Amendment 1 and for other noble Lords not to move the other amendments in this group when they are reached.
My Lords, I am extremely grateful to all noble Lords who have spoken in this debate. As in Committee, we saw support from all around the House. Unfortunately, the Minister has not completely reassured me. I am grateful for her reassurance on gas and understand the reason for including roads, with caveats, in the infrastructure. I sort of understand not wanting to change the objectives, because of the process she described with consultation and wanting to keep clarity for the two objectives.
What I cannot understand is refusing to include the circular economy and nature-based solutions in the infrastructure. I am afraid her arguments are undermined by the Government’s actions. They keep roads in there even though they need to be caveated and we need reassurances that they will not be a mainstream activity of the bank. However, they tell us that they are absolutely committed to making these an activity for the bank. We know that the Treasury, departments and everyone who talks about these issues understands the connection between nature-based solutions and climate change. They understand that we need to tackle these areas; there is no difference between us. These are not tablets of stone, unlike the objectives—and the Government are seeking the leave of the House to change the objectives on energy efficiency. If they can do it for energy efficiency, why cannot they do it for nature-based solutions and the circular economy?
I rest my case on that issue and will return to it when we come to Amendment 6A. I beg leave to withdraw Amendment 1.
Amendment 1 withdrawn.