Lessons for ex ante appraisal
(i) Appraisal should be undertaken where significant
(materially or politically)
44. Despite the Government's general commitment to
environmental appraisal we have noted a number of examples where
there is little evidence of such appraisal. The Government raised
the Fuel Duty Escalator in its first Budget, in July 1997, from
5 to 6 per cent in real terms with the explanation that this was
in recognition of the environmental and other costs attached to
road use. The Government gave an estimate that annual six per
cent real increases in fuel duty over the lifetime of the Parliament
would result in carbon savings of 2½ million tonnes a year
The Government's memorandum did not point the Committee to any
further appraisal documents supporting this decision.
Most of the large new environmental tax measures since that date
have been the subject of appraisals which have been in the public
domain. But we, and a number of organisations providing evidence
to us, noted that the Budget 1999 had included no obvious environmental
appraisal of measures not labelled as environmental taxes. Examples
are the increase in cold weather payments, the deregulatory drive
to be carried forward by the Better Regulation Task Force under
Lord Haskins, the Research and Development Tax Credits and the
establishment of the Small Business Service which could be set
up with sustainable development as an integral part of its remit.
We would expect all Budget measures to be subject to environmental
appraisal, and for this appraisal to be in accordance with the
points addressed below.
(ii) Appraisal should be undertaken at all appropriate
points in the development of policy
45. We note that ex ante appraisals are designed
to answer a number of questions and a single exercise can encompass
any subset of these depending on the particular circumstances.
In our view it is important that at each stage where a decision
is taken, on whether to introduce a tax or on key design features,
that decision should be supported by appropriate appraisal.
46. In the case of the Climate Change Levy Lord Marshall
was asked to report on whether, and if so how best, to use new
economic instruments to improve the industrial and commercial
use of energy to help reduce emissions of greenhouse gases. He
reported in November 1998
and the Government announced its decision to introduce
a levy in the March1999 Budget report, with further consultation
on some, but not all, design issues launched at that time. The
Government has not made available an environmental appraisal supporting
its Budget 1999 outline decisions on the Levy, although not all
of these drew directly from Lord Marshall's conclusions or were
explained in the consultation document. As Dr Hogg pointed out
it is not now clear whether these decisions are firm or whether
they are in practice open to consultation.
We will not know until final decisions are unveiled and it will
be important at that time for all aspects of the Levy and the
Carbon Trust to be supported by appropriate appraisal of their
objectives and expected contribution to the policy objective.
47. The approach taken for the Climate Change Levy
has contrasted with that applied to a possible pesticides tax,
where an initial appraisal of possible economic instruments to
minimise the environmental impacts of pesticides was completed
in November 1997 and followed by consultation. A further appraisal
of alternative possible designs for a tax was published in March
and is also now open to consultation and the Government will then
take a decision on the principle of whether to introduce a tax
in the light of these further consultations.
(iii) Options should be fully appraised, including
the "do nothing" baseline
48. As English Nature set out in its memorandum,
in common with most policy appraisals to date, the Budget 1999
simply set out the environmental effects of the preferred approach
rather than showing the options considered and demonstrating that
the best was selected.
Drs Hogg and Speck pointed out that tax measures are often best
used in conjunction with regulatory measures.
Given the traditional view of these being alternative measures,
we consider there is merit in the appraisal of the tax measure
addressing its context and role, and distinguishing this from
other measures which address associated environmental issues,
and assessing the complementarity of the package of measures.
The appraisal should also address different options for thresholds
and rates for the tax. We consider that together this approach
would help in preempting or at least informing arguments about
alternatives. For example the Automobile Association's argument
in relation to taxation of motoring, which says that the measures
are not needed because there are other better means of reducing
(iv) Appraisals should involve quantification
where possible, with the methodology fully explained
49. Quantification of impacts is helpful for addressing
all of the purposes of ex ante appraisal set out in paragraph
40 above. Yet it is clear from our discussions with Professor Smith
Dr Hogg that this is likely to be the area of greatest
50. Our witnesses drew attention to the difficulties
caused by a lack of directly relevant historical experience on
which to draw or by inadequate basic data.
There may also be some lack of understanding of likely behavioural
responses to taxation and difficulty in incorporating in any modelling
the complex impacts of other policy measures also affecting the
Dr Hogg added that in some cases the lack of data
and the lack of understanding of likely responses meant that trying
to model possible outcomes can stretch the credibility of the
exercise, citing the Landfill Tax upon its introduction as a case
in point, where modelling would have been incredibly difficult.
51. Professor Smith argued that these difficulties
did not detract from the essential value of undertaking appraisal
and attempting quantification of impacts where possible. He said
that if you use relatively simple models you must accept that
things may not turn out exactly like you expect. But that appraisal
work can help narrow down the range of possibilities and in some
areas where there is no useful past experience to draw on you
can do what you can to build up a model based on what the likely
responses might be. This will result in ex ante appraisal for
different measures being tackled in different ways and with different
degrees of precision in the results.
He argued that this also supported the case for encouraging a
range of studies on a measure, because the evidence from them
is actually quite convergent,
although we note this may not always be the case.
52. Dr Hogg expressed reservation about basing a
decision to proceed with a tax solely on the assumption that the
tax could be set at an optimal rate to achieve a perfect market
for the good, incorporating its environmental costs as well as
traditional resource and production costs. He pointed to the fact
that valuation factors for an individual pollutant can vary by
as much as 25 fold and that for some impacts the uncertainty of
the valuation is too great to attach any real significance to
it. He also considered this approach could lead to the exclusion
from consideration of any factors which ultimately could not be
valued, such as ethical considerations and rights based debates.
In Dr Hogg's view in the case of the Landfill Tax this valuation
approach had resulted in a tax rate well below what was expected
and this has subsequently been raised to increase the impact of
In the case of a possible Aggregates Tax valuation of environmental
costs has fuelled a lot of discussion about the methodology used
but has not answered the central questions of whether, how and
if so by how much a tax would contribute to the policy objectives
of reducing the use of primary aggregates and increasing the use
of recycled aggregates. As an alternative to this approach Dr
Hogg advocated that the appraisal should address the question
of how to deliver the change needed to meet an environmental target.
This had been adopted in the development of the case for a pesticides
tax, undertaken for the Department of the Environment, Transport
and the Regions by ECOTEC. This started from the position that
the tax should be designed to address a range of policy objectives,
most particularly to reduce pesticides use and to achieve substitution
to less harmful pesticides or alternative techniques.
53. We have noted that whilst the Government has
made reasonable attempts at quantification of impacts for its
major environmental tax policies, such as the Climate Change Levy,
there has been little evidence of this in the Treasury's reports
for a number of smaller measures or changes to measures. We consider
that for small measures this is still important to help those
affected understand the case for the tax and its expected impact.
For example there is no quantification to support the Budget 1998
decision to provide an exemption from the Landfill Tax for inert
wastes used in the restoration of landfill sites and the infilling
of quarries. This is a concern because the exemption may result
in less incentive to find alternative, more productive, uses of
the waste for example as an alternative to primary aggregates.
The Budget1999 did not involve any quantification of impacts to
support the decisions to reduce duty on road fuel gas, set a threshold
for a lower rate of vehicle excise duty for small cars at 1100cc
and increase the discount from vehicle excise duty for less polluting
lorries and buses from £500 to £1000, and although the
impact of changes to taxation of company cars was estimated the
Budget documents gave no explanation of the methodology used.
In the case of the lower rate of vehicle excise duty on cars this
was particularly surprising in the light of the fact that the
threshold chosen was different from the illustrative one which
had been subject to consultation. This failure to provide quantified
information contributes directly to charges such as that from
the Automobile Association that the Government had set the low
rate for an "apparently arbitrary choice of engine size".
54. In the light of these concerns we were frankly
disappointed by the Economic Secretary's response that wherever
they had been able to quantify or run different options on models
they had done so, but in these cases they had not been able to
do so for example because the expected take-up was too small to
Clearly this was not strictly the case. In the case of reduced
duty on road fuel gas the Economic Secretary told us of an independent
forecast that the British market for liquid petroleum gas used
in road vehicles is likely to experience average annual growth
of over 60 per cent between now and 2008, in line with the predicted
increase in the number of gas fuelled cars on British roads to
500,000, and that the main incentive for that is the duty differential.
In the case of vehicle excise duty she told us that about 1.8
million drivers are expected to benefit from the new rate of duty
for cars smaller than 1100cc. Whilst it is likely that the impacts
of these measures will be small we consider the Government's appraisal
should at the least set out their likely scale.
(v) The incidence of a tax should be appraised,
by sector, with consideration of effects on income distribution
55. In evidence to the Committee the Economic Secretary
assured us that appraisal takes account of income distribution
and competitiveness effects.
These issues are likely to be the most controversial in any proposal
and so the way in which they are handled will be key to the success
of the measure and we consider a more rigorous approach is required.
56. In the most recent appraisal, of a pesticides
tax, the consultants analysed the possible impact of the tax on
farms' profitability and this is likely to be the subject of much
of the feedback in the consultation currently underway on this
possible tax measure.
57. In the case of the Climate Change Levy Lord Marshall
explicitly addressed the impact of a tax on the energy intensive
sectors. However, Dr Barker considered that given the importance
of the point it would be good to have more information on competitiveness.
He believed the Government tends to rely on other people's work
on this and said that there was no evidence that it had used the
Department for Trade and Industry's model to look at the effect
of the climate change levy on competitiveness.
58. In the case of the Fuel Duty Escalator the Government
did not produce any public statements on distributional and competitiveness
effects. The Department of the Environment, Transport and the
Regions reported to us that it keeps under review any unintended
consequences and has increasingly sought to evaluate the distributional
impacts of its policies. It told us, however, that it is up to
the Treasury to make a full assessment of the range of tax measures
introduced in any one Budget.
We have seen no evidence from the Treasury taken from this type
(vi) Mitigation and complementary measures, including
those to be funded out of tax revenues, should be appraised alongside
the main tax measure
59. In our last report we briefly considered the
merits of hypothecation, whilst concluding that any such proposals
should be subject to rigorous appraisal to ensure that they do
not result in new distortionary subsidies.
In evidence to this inquiry English Nature, the Environment Agency
and various non-government organisations expressed their support
for hypothecation in appropriate circumstances.
English Nature called specifically for the Treasury to amend its
Statement of Intent on Environmental Taxation to set out the Government's
view on the broad circumstances where hypothecation of revenues
from environmental taxes may be appropriate and to give early
indication in its consultation exercises of how revenues will
60. Despite the obvious benefits of holistic appraisal,
including the appraisal of the use of tax revenues, we have observed
that this practice has often not been followed. In the
case of the Climate Change Levy Lord Marshall included his "impressions"
of the merit of the main proposals made to him for how the revenues
should be recycled to business and recommended that "at least
some of the revenues are channelled into schemes aimed at promoting
energy efficiency and reducing greenhouse gas emissions directly".
The Economic Secretary told us that the Government had wanted
to return the overwhelming bulk of the revenue to business through
tax cuts. She said that "the £50 million fund for both
energy efficiency and renewables could, for instance, permit a
doubling in the support that is specifically given for advice
on energy efficiency. If there are proposals to vary the £50
million by some small amount the Government would look at those
This explanation does not sound as if it derives from as full
an appraisal of potential impact as one would expect of an important
element of a significant tax. Likewise the most recent pesticides
appraisal work focussed on the design of the tax. Although this
reported that there would be merit in making use of the revenue
from the tax to support the incentives of the tax and reported
ideas for such complementary measures this was not an integral
part of the options subject to full appraisal.
It has therefore been left to subsequent appraisal work to assess
the scale and nature of any such complementary measures. And on
aggregates there has as yet been no discussion of the likely use
to which any tax revenues would be put.
(vii) The sensitivity of the estimated impact
of the measure should be formally appraised
61. Given the difficulty of producing precise estimates
of the likely impacts of a measure it is important to consider
the sensitivity of the results to changes in assumptions in the
model and input data. From the information available to us we
find it difficult to judge the sensitivity of the estimated environmental
impacts for the two really large measures presented in the Government's
environmental assessment table in the Budget 1999, the Climate
Change Levy and the Fuel Duty Escalator. This is critical because
of the importance of these two measures to meeting the legally
binding Kyoto Protocol targets.
62. The Government estimates that the Climate Change
Levy with the proposed revenue take of £1.75 billion
will result in carbon savings of 1.5 million tonnes a year by
2010. This is said to be based on Lord Marshall's report,
which included the estimate of carbon savings of 1 million tonnes
assuming a tax take of £1 billion, based on modelling by
the Department of Trade and Industry using its energy model. Lord
Marshall also quoted the Cambridge Econometrics modelling which
shows carbon savings would be of the order of 70 per cent higher.
As Dr Barker told us, sensitivity analysis is a complicated
exercise but it can be done and is done by clever companies in
their business planning. In the case of the Climate Change Levy
it would look at the robustness of the estimates to changes in
growth rates and this would have given a better feel for what
the risks and benefits might be, with the advantage of giving
more information and helping business plan for change.
63. The Government estimates that the Fuel Duty Escalator
operating over the committed period of 1996 to 2002 will produce
carbon savings of 2 to 5 million tonnes a year by 2010.
The Department of the Environment, Transport and the Regions explained
to us the complexity of its traffic model and the large number
of variables involved, from the price of crude oil, through changes
in the nature and growth rate of the economy, to shifts in the
type of vehicles on the road and added that there were a number
of variables not currently included which were being investigated
for possible inclusion, such as the impact of rising incomes on
road users' responses to fuel price increases. It told us that
in the light of the number of these variables no sensitivity analysis
in its formal sense has been carried out, with the Government
relying instead on showing the range of possible impacts, based
on two different models, its own traffic model which forecasted
carbon savings of 2 million tonnes and the Department of Trade
and Industry's energy model which forecasted carbon savings of
5 million tonnes.
It was interesting that the simpler model produced in evidence
to us by the Centre for Social and Economic Research on the Global
Environment estimated much higher levels of carbon savings on
the basis of different estimates of the elasticity of motor fuel
consumption to changes in real prices.
This illustrated to us the importance of Government undertaking
sensitivity appraisal work and reporting it with more detail on
the methodology used to assess likely environmental impact, so
that those expert in the field can examine the differences in
approaches and resulting estimates to establish whether they throw
doubt on the Government's ability to meet its overall commitments.
64. As Professor Smith said the danger when producing
forecasts with a single estimate is that undue reliance is placed
on them and the uncertainty is not fully taken account of in policy.
In respect of the Fuel Duty Escalator he added that he thought
it unlikely that at a research level they would not have investigated
sensitivity. He thought there may be reasons why the Government
may be reluctant to publish such information, although he did
not accept them.
(viii) Responsibility for ex post appraisal should
be clarified at the outset
65. As set out in the Government's guidance on environmental
appraisal it is important to make sure that appropriate arrangements
are in place for effective monitoring and evaluation, to address
this requirement early in the appraisal process, and to consider
what is the appropriate timing for the evaluation.
We have found no evidence in appraisal documents of budget measures
from this Government that this has been formally addressed. The
Economic Secretary told us that the Government monitors the impact
of taxes on all environmental indicators and that in relation
to the Climate Change Levy and the road tax package it will be
done as part of the continuing climate change strategy.
The Department of the Environment, Transport and the Regions told
us that it, the Department of Trade and Industry and the Treasury
have a common interest in assessing the impacts of the Fuel Duty
Escalator and that estimates are kept under review. It also said
that the Government expects to publish an environmental appraisal
of its environmental tax measures on an annual basis.
From this we infer that if this review of estimates led to a change
in the forecasts of impacts this would be reflected in the Budget
environmental assessment table. Whilst in some degree reassuring
we consider that these responses do not amount to commitments
to thorough, rigorous ex post appraisal.
(ix) There should be appropriate consultation,
allowing stakeholder input before key decisions are taken
66. It is particularly important to include consultation
as part of the appraisal of budget measures given the difficulty
of calculating precisely the expected incidence and environmental
impacts and yet the importance of getting the proposed measure
broadly right. We therefore welcome the formal commitment the
Government has given to consultation in the recent Treasury code
of practice, whilst noting that the Government has reserved for
itself the right not to consult where it considers this appropriate.
67. We consider that for the major Budget measures
the Government has introduced or proposed the degree of consultation
has been a strength of its approach. As Dr Hogg noted the pattern
has generally been for the Government to take a fairly thorough
view of what is going on and then put the matter out to consultation,
although he thought the example of the Fuel Duty Escalator might
have been an exception to this.
Dr Barker considered this Government had pursued an approach which
involved a "very great improvement in consultation with business
and with other interested parties".
He and Mr Hewett both considered that there had also been evidence
of good cooperation between departments in the preparation of
We received further positive comments on the extent of the Government's
consultation on Budget measures from others.
68. However, we have also noted that other smaller
budget measures have not been subject to consultation, for example
those set out in paragraph 53 except the change to vehicle excise
duty for cars. We do not consider that the likely small impact
of these measures is sufficient reason not to consult, since apparently
small changes can sometimes be mis-specified and can have unexpected
or undesirable results. If the measures are likely to be uncontentious
there is no harm and there is unlikely to be much work generated
from opening them up to consultation as a check of the Government's
assessment, and in this respect we would urge the Government to
widen its presumption to consult to include smaller as well as
Lessons for ex post appraisal
(i) Measures should be appraised shortly after
implementation to check ex ante expectations and identify teething
69. Both our expert witnesses stressed to us the
value of undertaking appraisal shortly after the implementation
of a measure. Professor Smith told us that after 12 months or
so it may be difficult to see responses to the policy measure,
but there may be useful lessons to learn about the way a particular
policy has been operated, about administrative costs and complexity
and anecdotal stories about the way in which operators have responded
to the measure.
This feedback would be useful in considering whether small changes
to the measure were needed.
Dr Hogg considered that early review would allow
you to look at what taxpayers' intentions are, so that you can
then later revisit them to see whether the intentions have been
followed through. He considered this was valuable to help in understanding
the influences of specific instruments and the case for complementary
measures to generate more positive environmental response to the
tax measure. He considered that this sort of micro analysis was
therefore a useful complement to macro analysis which looks at
the overall data, for example, to establish whether consumption
has been affected by the measure.
(ii) The impact of measures should be formally
appraised as soon as this is possible
70. The challenge in undertaking ex post appraisal
is to identify evidence of a long-term change in the behaviour
targeted by the measure and to disentangle the impact on this
behaviour which results from the measure itself rather than other
influences. For policy reasons there is advantage from early feedback,
but the appraisal of impact has to be left as long as necessary
to allow this real evidence of impact to show through. Professor
Smith illustrated this with respect to the responsiveness to changes
of energy prices. He estimated that most energy-using equipment
would have a life span of some 15 years and therefore that half
of it would have been replaced in seven years. He therefore considered
you would only be able to confirm trends in investment decisions,
that is the purchase of more energy efficient equipment, after
say five, six or seven years. He considered that some policies
designed to have shorter-run effects could be evaluated two to
three years after implementation.
71. In respect of the Fuel Duty Escalator the Department
of the Environment, Transport and the Regions stressed that it
is a long-term measure and that by 2010 it should have a much
more accurate picture of events, although even then the precise
impacts of the escalator will be difficult to isolate.
Professor Smith agreed that in this case, given that there are
already reasonably soundly based estimates of how fuel consumption
responds to price, there is little to be learned from each extra
year's worth of actual data. But he considered there were things
you could learn sooner than 2010. In two to three years it could
be possible to see the response of motor vehicle manufacturers
to fuel prices. And before 2010 there would also be a need to
assess whether the policies in place are sufficient to meet the
We certainly believe that it should be possible to detect any
changes in vehicle ownership patterns and driving behaviour due
to the tax compared to baseline forecasts well before 2010.
72. In the light of these discussions about the timing
of ex post appraisal and our concern about the apparent lack of
ex ante appraisal of the introduction of the exemption from tax
for inert wastes used in the restoration of landfill sites, we
were pleased to learn that ECOTEC are already undertaking a study
for the Department of the Environment, Transport and the Regions
on the impact of the Landfill Tax on inert wastes.
(iii) The Government should encourage a variety
of ex post appraisals
73. As we have argued in the ex ante case, paragraph
51, we see advantage in encouraging a variety of ex post appraisals,
using different methodologies to build up a more rigorous analysis
of actual impacts. Professor Smith pointed us to the fact that
there are both advantages and disadvantages from the Government
undertaking ex post appraisals of its measures itself. He considered
that internal assessments had the advantage that they are carried
out by people who are well-informed, have access to good information
and who as a result of having carried out the appraisal feel ownership
of the results. He stressed the importance of the latter in getting
the evaluation translated into effective modification of the policy.
On the other hand he also pointed out that internal appraisals
can turn into a justification for what was going on. This is avoided
if the work is carried out independently.
He concluded it was helpful to try to stimulate a broad base of
research on these issues, within and outside Government, for example
in the academic community. He considered this would provide a
credibility check on the work done.
Publication of environmental
74. In addition to encouraging diversity of research
on economic measures, and indeed in support of that, both Professor
Smith and Dr Hogg stressed the importance of the publication of
appraisals and greater transparency. The commitment to publication
provides a deterrent against partial internal appraisals and in
putting the detail of appraisal work in the public domain allows
others with an interest in this complex area to unpick the methodology
and subject it to appropriate challenge.
For example Dr Barker told us that better information would be
needed for third parties to be able to assess the reliability
of the Government's estimates of the likely impact of the Climate
75. We also consider that more information on the
calculations behind the Climate Change Levy would have helped
understanding of the impact of the proposals for including or
exempting renewable energy from tax. Furthermore, we consider
publication of appraisals also brings value through helping those
affected by the tax to understand the incentives it is intended
to give, the responses which are favoured and hence perhaps to
reinforce the behavioural impact of the tax. For example, with
the fuel duty escalator it may serve to remind people of the benefits
from considering fuel efficiency when purchasing a vehicle and
fuel efficient driving habits as well as the more obvious benefit
of reducing their mileage. And, Dr Barker added that secondary
benefits could also usefully be given in more detail to show that
there are other benefits beside the immediate ones.
76. In our earlier reports we have been critical
of the level of appraisal information published by the Government
in its Budget documents
and this has not significantly changed. English Nature consider
that at this summary level what is required is information showing
the baseline against which the policy change is being considered,
the predicted outcome without the policy measure and the predicted
outcome with the policy measure.
For major measures detailed ex ante appraisal work has often been
published which has included this level of information. In addition,
as Professor Smith pointed out, often at a working level it is
possible for people who are interested in the precise detail of
particular approaches to modelling to go and talk at a technical
level with those concerned.
However, there is a gap between this level of detail and the very
limited information presented in the environmental assessment
table in the Budget. This gap is at the level of information required
to address each of the key elements of best practice as set out
above, which is required by us and others, to audit the Government's
approach and performance and to identify policy areas where change
may be needed.
Conclusions and recommendations
77. As with other fields of Government policy
making, there is room still for improvement in the environmental
appraisal of budget measures in accordance with the Government's
guidance and the procedures outlined in this report.
78. When appraising the case for an environmental
tax measure the Government should not be over-reliant on identifying
a rate for the tax that it is hoped will deliver a perfect market
in the good. It is most important for the appraisal work to determine
the outcome wanted, do the work necessary to identify likely behavioural
responses, include positive complementary measures as an integral
part of the appraisal and consider the incidence of the measure
and distributional implications.
79. The Government should recognise the value
of consultation on possible environmental budget measures for
smaller changes as well as larger ones and where it has not consulted
on the measure it should explain this decision as a matter of
80. The Government should make a proper commitment
to undertake full ex post appraisals of all Budget measures, and
should report the intention and the likely timing of the review
for each new or substantially amended measure when it is introduced.
81. The Government should ensure that the environmental
assessment table in its Budget and Pre-Budget Reports includes
the baseline against which the policy change is being considered,
the predicted outcome without the policy measure and the predicted
outcome with the policy measure. For smaller measures the predicted
outcome may be couched in terms of the likely scale of the impact.
This summary information should be fully referenced to more detailed
supporting information, including an intermediate level, accessible
publication setting out the key elements of the appraisal approach,
results and conclusions and, where appropriate, a detailed technical
82. There should be a periodic independent evaluation
of the Government's approach to appraisal of Budget measures,
and this could potentially be a part of the remit of a Green Tax
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Op. cit. pp 82-85 Back
QQ4 and 37 Back
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Sixth Report form the Environmental Audit Committee, The Greening
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See for example, Ev p 87 Back
Ev p 51 Back
Ev p 52 Back
QQ194 and 206 Back
QQ118 and 165 Back
Ev p 54 Back
HM Treasury, Budget News Releases, 2 July 1997, Number 4 Back
Ev pp 68-69 Back
Economic instruments and the business use of energy, A report
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Design of a tax or charge scheme for pesticides, DETR, March 1999 Back
Ev p 78 Back
Ev p 52 Back
Ev p 63 Back
QQ160, 164 and 199 Back
Ev pp 53-54 and QQ196-198 Back
Ev p 53 Back
Ev p 63 Back
Op. cit. Back
Ev p 75 Back
Op. cit. paragraph 22 Back
Ev pp 79-80, 81, 91-92 and 111 Back
Ev p 80 Back
Op. cit. pages 25-26 Back
Op. cit. pages 162-163 Back
Op. cit. page 58 Back
cit. page 84 Back
Ev pp 70 and 73-74 Back
Ev pp 36-37 Back
Op. cit. Back
Ev p 12 Back
Code of Practice on Consultation, July 1999, HM Treasury, Back
QQ10, 14 and 23 Back
Ev pp 79 and 86 Back
Ev p 74 Back
Ev p 49 Back
QQ173 and 207 Back
Op. cit. paragraph 18 Back
Ev p 79 Back