Select Committee on Environmental Audit First Report


PRE-BUDGET REPORT

The Government's statements

15. This Government is committed to putting the environment at the heart of its decision-making. In terms of economic and fiscal policy, the Government has stated that:

      (i)  sustainable growth means stable and environmentally sustainable growth and delivering such growth is a core feature of economic policy;[6]

      (ii)  economic development must take place in a way which is consistent with high standards of environmental protection and in a way which safeguards the environment for present and future generations;[7] and

      (iii)  the next Finance Bill will be used to give effect, as far as technically possible, to a code for fiscal management, one of the five key principles of this code being 'fairness'.[8]

16. In the Statement of Intent the Government made particular commitments to:

      (i)  exploring the scope for using the tax system - as one instrument, in combination with others like regulation and voluntary action - to deliver environmental objectives; and

      (ii)  over time, aiming to reform the tax system to increase the incentives to reduce environmental damage. That will shift the burden of tax from 'goods' to 'bads'.

The Government concluded that environmental taxes must meet the tests for good taxation and, where these tests have been met, environmental taxes will be used.

17. We wholeheartedly welcome the Government's statements committing it to the pursuit of environmental sustainability and the use of environmental taxation.

Consultation

18. The Pre-Budget Report was published to initiate a national debate on the economy to inform the 1998 Spring Budget. We welcome this procedure and note the proposal in the Treasury document 'Code for Fiscal Stability' for a requirement on governments to "publish a consultative paper each year, several months before the Budget providing an update of...progress in meeting the fiscal rules, and laying out proposals for any significant changes to policy".[9] In evidence the Financial Secretary indicated that this would be the case.[10] We regard consultation in advance of each Budget as an essential process and we recommend that this consultation always address sustainable development objectives. We would expect to contribute to such consultation on a regular basis.

Code for Fiscal Stability

19. The principle of fairness in the proposed Code for Fiscal Stability was not well defined in either the Treasury document on the subject or the Pre-Budget Report. In neither case does explanation of the principle include any reference to the environment. The Treasury pointed out that chapter 5 of the Pre-Budget Report "makes it clear that fairness means, not least, fairness to future generations and the world in which we live" and "there are a number of aspects to 'fairness'. Within this, environmental concerns should be given their due weight.".[11]

20. We do not think that the position is clear. If, as we believe it should, the proposed Code is intended to reflect the Government's commitment to environmental taxation, it should say so. We conclude that the principle of fairness in the proposed Code for Fiscal Stability does not adequately reflect the Government's commitment to sustainable development. We recommend that any code for fiscal management includes a clear expression of the Government's commitments to integrate environmental, social and economic considerations and to reform the tax system to provide disincentives to causing environmental damage and incentives to following good environmental practice.

Environmental accounting and information

21. The Statement of Intent, and the further statements on environmental considerations in the Pre-Budget Report, were welcomed by the majority of those submitting evidence to the Committee. However, we agree with witnesses' concern that the rhetoric on the integration of economic and environmental considerations was not supported by the provision of any information on the impact of economic activity on the environment.[12]

22. The Government's statements in the Pre-Budget Report suggest that the promotion of economic activity should be circumscribed by high standards of environmental protection and the necessity to safeguard the environment for future generations. The Pre-Budget Report presents much economic data intended to illustrate and clarify aspects of past economic development and project future trends. But the report makes no attempt to show the impact of development upon the environment. We note the Treasury's evidence that "Pre-Budget and Budget Reports will set out as "as much of the environmental policy background as is necessary for an understanding of the Government's position on the tax or other instruments under discussion-Beyond this Treasury Ministers consider it is properly the business of their colleagues in the Department of the Environment, Transport and the Regions to report on the Government's performance and objectives on environmental issues".[13] We do not believe this position to be in accord with Government statements of its policy on integrating economic and environmental considerations.

23. A wealth of information on the environment is published separately in the annual Digest of Environmental Statistics. In addition the previous Government sought to illustrate the pressures on the environment, and the policy responses to those pressures, in the reports on the UK Strategy for Sustainable Development presented in the annual This Common Inheritance series.[14] Further data on the three elements of sustainable development, economy, environment and social development, were available in the form of a set of preliminary indicators published in 1996, "Indicators of Sustainable Development for the United Kingdom".[15] And finally there is the Office of National Statistics' work on environmental accounts, which attempt to quantify emissions of pollution and resource consumption, and identify the responsible industry, using concepts and classifications from the national accounts.[16]

24. We recognise that work on indicators that can measure the impact of economic activity on the environment is in its infancy compared to that on economic performance alone. Nevertheless, taking the Pre-Budget Report as an example, it is difficult to reconcile the status of environmentally sustainable growth as a 'core feature' of the Government's economic policy with the absence of any illustration of environmental trends that have a clear link to economic activity. Even a discussion of efforts to develop such measures would be welcome and would have sat comfortably alongside other innovations which were given space in the Chancellor's report such as resource budgeting and accounting, the National Asset Register, whole of government accounts and UK generational accounts.[17]

25. We understand that the indicators for sustainable development are being revised, in conjunction with consultation on a new UK strategy for sustainable development. One of the Government's aims is to identify a core set of indicators for sustainable development out of the 120 or so currently identified.[18] We recommend that, as a minimum, the core set of sustainable development indicators be included in key economic documents such as the Pre-Budget Report and the Financial Statement and Budget Report in future.

Strategy

26. Some of our witnesses felt that the Pre-Budget Report demonstrated little progress on environmental measures from the situation in July.[19] The Financial Secretary warned that: "I understand people's frustration, that they do not feel we are going fast enough, but...this is a vitally important agenda as we all understand and we cannot afford to make mistakes".[20]

27. We were concerned that the Pre-Budget Report did not contain any evidence of a strategic approach in line with the Statement of Intent. We also noted the Financial Secretary's scepticism over the 'double dividend' and the Treasury's supplementary evidence that it "considers the use of revenues raised by environmental taxation to be a separate issue to the justification, on environmental grounds. It should not be assumed that the introduction of any environmental taxes would be on a revenue neutral basis". The CBI Green Taxes Working Group also said that problems of environmental degradation and those of cost barriers to employing people should be treated separately. The Treasury's supplementary evidence on this point appears to demonstrate a retreat from the ideas expressed in the Statement of Intent.

28. We would welcome a transparent attempt to define the problem and identify a strategy for addressing it. In this task we would emphasise the importance of identifying and quantifying the 'goods' and 'bads' under discussion and the relative tax burdens which currently apply to them. Also important is evidence of price elasticity in these areas. This will demonstrate the potential for taxes to influence choices and behaviour and indicate where complementary measures are needed to support any proposed change of tax. We would include in any strategic approach the need to examine the provision of environmentally damaging subsidies. One estimate of the scale of these subsidies was provided by the Centre for Social and Economic Research on the Global Environment and was in excess of £20,000 million per annum (i.e. over 40 times greater than landfill tax revenue).[21] Finally we would emphasise the need to review the current provision of incentives for businesses to invest in environmental technologies and the encouragement of research and development in such technologies. We will return to these latter topics in examining the conclusions of the Government's Comprehensive Spending Review.

29. The Financial Secretary told us that the Government was "actively taking forward the environmental tax agenda" and that the "Treasury was leading from the front".[22] She also stated the importance of the 'rigorous analysis' that Treasury brought to bear on proposals. The Minister described the Treasury's agenda for the tax system as including, in addition to the measures set out in the Pre-Budget Report, the forthcoming identification of the UK's legally binding obligations under the Kyoto Protocol on climate change; and the review of the national air quality standards by the Department of the Environment, Transport and the Regions in collaboration with the Treasury.[23] We note the possibility of further calls on the tax system to deliver environmental objectives coming out of the current reviews of transport and housing policies. On the question of existing incentives and disincentives, as opposed to new proposals, the Financial Secretary told us: "this is a vast area of work. On the principle of the Government's objectives for the tax system, as laid out by the Chancellor, it naturally follows that over time the Government is scrutinising the system in terms of whether it does what we want it to".[24]

30. We welcome the Minister's commitment and statement of analytical rigour in pursuing the environmental taxation agenda. The policies referred to above, in addition to the commitment to reduce CO2 emissions by 20 per cent on 1990 levels by 2010 (by which time the economy may have grown by 50 per cent), pose a significant demand on the Treasury for action. However, we do not feel that the requirements of specific policies should rule out, or defer, looking at the tax base in the strategic way that the Statement of Intent appeared to be suggesting. Indeed given the scale of the implications for the tax system of the Government's commitment to environmental protection and sustainable development we believe that the need for work on a long term strategic approach is both vital and urgent.

31. One suggestion we heard to address this lacuna was for Treasury to establish an advisory body such as a green tax commission[25] to assist in the identification and implementation of environmental tax reforms. Such bodies are made up of representatives of a broad range of interests: individual Government departments, business and industry, academia, non-governmental organisations, consumers and other stakeholders. This range of representation institutionalises important elements in the process such as consultation and consensus-building as well as reflecting commitments to openness and transparency. The Treasury demonstrated some resistance to this idea on the grounds that like bodies in other countries have frequently worked inappropriately towards a "targeted level of change in the balance of taxation"[26]. It appears to us that, while the key feature is its broad constitution, the precise remit of such a body is for Government to decide. A number of helpful suggestions were put to us in evidence.[27]

32. We believe that there could be a useful role for an external advisory body to explore the potential use of environmental taxation in more detail, and to help build wider knowledge, understanding and consensus about all the issues at stake. Such a body might assemble relevant evidence about externalities, elasticities and potential influences on behaviour. It could also explore effects and impacts on competitiveness and social equity. In addition to examining the arguments for potential new environmental taxes it could also advise on monitoring the impact, effectiveness and efficiency of existing environmental taxes and environmentally damaging subsidies and assess the experience of other countries in this area. We therefore recommend that the Government should establish an advisory body on environmental taxation. Such a body could take the form of a standing green tax commission as recommended in our evidence and this would be our preference. Alternatively, it might be established as an ad hoc body to conduct a baseline review of the tax system and the scope for a strategic shift towards the taxation of environmental 'bads' and the provision of incentives for good environmental practices. In this instance longer term monitoring arrangements could be the subject of further consideration in the light of the initial work.

Auditing performance

An indicator

33. We would regard the development by the Treasury of an indicator to demonstrate the shift in the burden of taxation from 'goods' to 'bads' as a logical step following the Statement of Intent. In the absence of an indicator being identified and agreed between Government and other interested parties, such as this Committee, it will be impossible to audit progress and discuss it in a meaningful way. An agreed indicator would at least set a benchmark against which such progress could be assessed. We note the Treasury's evidence regarding the 'considerable' definitional difficulties involved in classifying environmental taxes. We asked the Treasury what percentage of revenue yield is currently from 'bads' and what proportions have applied over the last five years and a table of OECD statistics was included in Treasury's submission (as set out below).[28]


Year

1990

1992

1993

1994

1995

% revenue yield

% of GDP


7.5

2.7


7.9

2.8


8.2

2.8


8.4

2.9


8.5

3.0

Note: Table considers revenues raised from: hydrocarbon oils, gas levy, NFFO, car tax (until 1993), air passenger duty (from 1994) and vehicle excise duty. Data are for calendar years.

Source: "Revenue Statistics, 1997 Edition", OECD.

The OECD figures appear to represent a reasonable basis for the development of an indicator over the medium-term, and an acceptable proxy for such an indicator in the short-term. We accept the methodological difficulties in defining taxes on environmental 'bads' but conclude that ultimately this is a matter for political decision. We recommend that the Government identify its list of environmental taxes and the proportion of total tax revenue contributed by these taxes and publish this figure as an indicator of taxation on environmental 'bads'.

A target

34. The Treasury said that setting targets for the shift of the burden of taxation from 'goods' to 'bads' would not meet the principles of good taxation and that there was no "compelling reason to single out environmental taxes for treatment in this way".[29] We agree that working to an overall target should not detract from the careful consideration, appraisal and rigorous analysis of individual proposals. This is as true for taxation matters as it is for other policy areas. We would argue that it is the Government who have rightly singled out environmental taxation for special treatment with the Statement of Intent. It is this statement that suggests to the Committee that while, as Treasury wrote[30], there might be no "'correct' burden of tax-identifiable in advance-that should be raised by environmental taxes", the Government has concluded that the current burden is incorrect.

35. We recognise the difficulties in identifying the ideal proportion of the UK's total tax revenue that should be coming from environmental 'bads' . We believe however, that incremental movement in this proportion from its current level is a reasonable objective and one that is amenable to the development of a target. We therefore recommend that consideration be given to the setting of a target for a progressive increase in the proportion of revenue yield from environmental taxes thereby creating the potential for reductions in the taxation of 'goods'. Progress on this target should be reported in each Budget assessment.

Environmental appraisal and a Green Book

36. The Government is committed to integrating environmental considerations into all of its decision-making and publishing more information thereon. In 1996 the then shadow spokesperson for the environment, Joan Ruddock, MP, told the House that "each year [Labour] will publish a 'Green Book' alongside the Chancellor's Red Book, setting out the environmental implications of Government policy."[31] In July 1997 the Financial Secretary undertook to fulfill that promise "from the first full Budget".[32] In evidence to this Committee the Financial Secretary emphasised the Treasury's support for increased environmental appraisal of policy and told us that Treasury departments were now required to "answer the environment assessment question" for Budget proposals.[33] She said that Treasury was working with other departments to encourage them to do likewise.[34] With regard to the performance of other departments in environmental appraisal, we note the high priority assigned to these matters by the Deputy Prime Minister and his evidence to us, on the Greening Government initiative, concerning the various structures aimed at ensuring that the 'environmental assessment questions' are asked and answered throughout Government.[35]

37. The Treasury described to us the current intentions with regard to a Green Book in the following terms: "the Government is committed to taking into account environmental impacts in considering policy options. It is intended that future Financial Statement and Budget Reports will incorporate an assessment of the environmental impact of the Budget...The appraisal of Budget measure-in the process of policy formation-should include consideration of environmental impact. The assessment that will form part of the next Budget... is likely to cover measures where the environmental impact is significant."[36] In our view it is essential for the Government to publish an assessment of the environmental impact of the Budget and we regard the key features of such an assessment to be:

  • comprehensiveness;

  • the identification of both positive and negative impacts;

  • the quantification of impacts; and

  • the provision of a clear statement regarding when and how actual impacts will be assessed.

We regard Treasury's current intentions as falling short of the original proposals.

38. We recognise the scale of the task involved in scrutinising existing incentives and disincentives (as opposed to working from the appraisals of new proposals). However, correcting existing imperfections appears to us to be as important as ensuring that new measures do not add to the problem. The Government is unlikely to suffer from a shortage of suggestions and developing this approach may be a further task for a green tax commission. The fruits of this scrutiny, where relevant to the environmental objectives of the tax system, should then be fed in to the annual Budget assessments over time so as to build up a more comprehensive picture of the signals being given out by the tax system with regard to environmental protection and sustainable development.


6   Statement of Intent on Environmental Taxation, Financial Secretary to HM Treasury (2 July 1997), hereafter 'the Statement of Intent'. Back

7   Pre-Budget Report, HM Treasury (Cm 3804), p7 Back

8   Code for Fiscal Stability, Treasury, November 1997, p7 Back

9   Op. Cit., p6 Back

10   Q5 Back

11   Ev p3, paragraph 24 Back

12   See for example Ev pp25 & 58 Back

13   Ev p105, paragraphs 3 & 4 Back

14   Op. Cit., 1997, Cm. 3556 Back

15   Op. Cit., March 1996, ISBN 011753174 X  Back

16   Ev p105, paragraphs 5-10 Back

17   Pre-Budget Report, pp 17 & 23-26  Back

18   Opportunities for Change, Consultation paper on a revised UK strategy for sustainable development, paragraph 16.  Back

19   See for example Ev p19 Back

20   Q7 Back

21   Ev p100 Back

22   Q1 Back

23   Q7 Back

24   Q37 Back

25   Q48 Back

26   Ev pp2 & 3 Back

27   Ev pp17, 21-3 and 101-2 Back

28   Treasury said that the table shows total revenue raised from a number of taxes with at least an environmental element as a proportion of GDP. Because of the difficulty of classifying tax revenues as deriving from 'bads', the list may not be exhaustive. For example, the yield from VAT, which is levied on hydrocarbon oils for example, has not been included. Landfill tax, which began in 1996, is not covered [see Ev p 3]. Back

29   Ev p3, paragraph 20 Back

30   Ibid Back

31   HC Deb, 4 December 1996, col 991 Back

32   HC Deb, 10 July 1997, col 1062 Back

33   Q3 Back

34   Ibid Back

35   HC No. 517-i (1997-98) Back

36   Ev p4, paragraphs 26 & 27 Back


 
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