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“Energy discussions play a major role in the overall situation for industry andare always on the background of carbon leakage discussions. Be it cheapshale gas in the US and Middle East or subsidised coal in China, the impact ofenergy prices is real.”- Carbon Leakage Evidence Project 129In addition, numerous commentators from both business and beyond have warned that EUpolicies are contributing to the closure of businesses. The International Energy Association’schief economist recently warned that Europe’s high gas prices risked driving away a bigshare of its Energy Intensive Industries such as cement and steel: “These industries arecritical for the European economy as they employ over 30 million people and it could havea major knock on effect on the European Union economy”. 130Any estimate of the exact number of firms who have left the EU because of expensiveenergy are unlikely to be satisfactory. There are several reasons why a firm may chooseto leave the EU, including a desire to tap into the national resources of other countries. 131Attempts to calculate the relative importance of energy prices in any firm’s investmentdecisions is incredibly difficult. At the same time the Commission’s attempts to mitigateagainst carbon leakage via a host of different rules and allowances produces a very complexset of circumstances, with each different sector affected differently by new and existing EUlaws. It is very hard to find a situation in which firms identify high energy costs as the solereason for closing down their facilities (and even harder to find situations in which onespecific policy is blamed for the decision to move facilities).However it is possible to see incidents where individual EU laws are named as overwhelmingreasons for the decision to close a facility. 132 It is also possible to identify cases of firms havingto close or to move onto other areas as a result of high energy costs. CIVITAS looked intoincidents of carbon leakage in the UK and pointed out that in 2003 Britannia Zinc near Bristolwas closed (with a loss of 400 jobs) and in 2006 EIUG warned that the gas price spike hadcontributed to 6,000 job losses in the glass sector. 133 Beyond the UK a similar pattern can beseen elsewhere in Europe, in 2013 BMW announced that it was moving its manufacturingfacilities to the US to benefit from the cheaper energy. 134129 Ecorys, Carbon Leakage Evidence Project, p.11, 23 September 2013, found at 130 International Energy Agency, World Energy Outlook, found at 131 More information provided by Oxford University, see D. Buchan, Costs, competitiveness and climate policy: distortionsacross Europe, p.5, April 2014, found at 132 RWE, Report on the first half of 2013, p. 10, found at 133 CIVITAS, Lea and Nicholson, British Energy Policy, p.11, June 2010, found at 134 C. Bryant, “High European energy prices drive BMW to US”, Financial Times, 27 May 2013, found at 39

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