Select Committee on Environmental Audit Appendices to the Minutes of Evidence


APPENDIX 1

Memorandum from Friends of the Earth

"BLUEPRINT FOR A GREEN BUDGET"

  Last year's Budget was one of the most remarkable ever seen, for three reasons.

  First, the Chancellor announced 22 environmental tax proposals, covering issues as diverse as energy, transport, chemicals, landfill and aggregates, which made Budget 1999 the greenest ever by a long shot. Second, he confirmed that hypothecated revenue spending was here to stay, by extending the principle of recycling "polluter pays" revenues for related spending measures to cover energy, transport and, as announced in November's Pre-Budget Statement, cigarette taxes. In doing so, Mr Brown threw 150 years of unyielding Treasury opposition to hypothecation out of the window. Third, these profound changes to the tax system went unnoticed by MPs of all Parties, and were similarly ignored by the media's Budget pundits.

  Budget 2000 is unlikely to be so radical, although Friends of the Earth (FOE) does expect to see some significant environmental tax/spending measures included. This will be a mistake, as extensive polluter pays taxation and respending is essential for sound economic and environmental policy reasons (see below). But, again, there seem to be three clear reasons why Budget 2000 will not be as green as Budget 1999.

  First, the orchestrated backlash against the Climate Change levy and Road Fuel Duty escalator by a few energy-hungry companies and the road haulage lobby has made the Government more cautious. Second, the General Election looms, and Budgets at this stage of the Parliamentary cycle tend to be traditional give-aways to key voter groups. But, third, and most relevant to this FOE's Sixth Blueprint for a Green Budget, the Treasury has concentrated too much on pushing environmental taxes as revenue raisers, and a penalty-driven spur for industry and householders to cut pollution or conserve resources. As a result, it has fewer allies than should be the case in industry or across Whitehall/Westminster. The Chancellor has not done nearly enough to develop green tax incentives and investments which reward environmentally virtuous companies and families, or persuade others to change their behaviour. There have been too many sticks (albeit necessary ones), and not enough carrots.

  Budget 2000 must address this weakness head-on. Otherwise, critical environmental problems will continue to get worse. And, vital opportunities to modernise the economy, improve industrial competitiveness and create large numbers of jobs through public and private sector investment in clean production technologies, and environmentally sound infrastructure, services and products, will be lost.

  FOE's Sixth Blueprint for a Green Budget recommends a package of affordable fiscal incentives and investments to resolve these problems. Polluter pays taxes are essential, but are often insufficient on their own to overcome the barriers which prevent businesses and households from going green. It is difficult for people to drive less, recycle more or save energy, if the public transport infrastructure, waste minimisation services or energy conservation products needed are either unavailable or too expensive to buy.

  Our recommendations below include proposals to increase public and private sector investments, remove perverse subsidies and/or tax penalties, and provide new incentives to industry and individuals. These can and should be paid for with the revenues from complementary polluter pays taxes.

  For example, we continue to argue strongly for increased spending on public transport, waste minimisation, organic and other sustainable farming methods, and renewable energy and energy conservation programmes. We think it a nonsense that individuals are penalised for buying energy-saving goods and materials, with these items taxed as luxury products at the ridiculously high VAT 17.5 per cent, when the Government is spending lots of money on advertising which urges "everyone to do their bit" in saving energy to combat climate change. Similarly, if the Government wants to modernise the economy, there are few better ways to do so then by extending the tax incentives for industry to invest in technologies, processes and products which cut pollution and use environmental resources much more efficiently than at present.

  The Chancellor has stated clearly, in Budget speeches since 1997, that the Government considers the quality of investment to be as important as the quantity made available. And, in his Foreword to the Government's Sustainable Development Strategy, the Prime Minister recognises that unalloyed economic growth can be detrimental to the quality of life. The Strategy calls for high quality economic growth and investment, which brings high and stable levels of employment, makes prudent use of natural resources, protects the environment effectively and brings social progress by recognising the needs of all people.

  The measures detailed in this Sixth Blueprint for a Green Budget meet these objectives, and demonstrate how Gordon Brown can realise the "win-win-win" opportunities of sustainable development by fulfilling economic, environmental and social policy goals together. In his Pre-Budget Statement, the Chancellor appeared to have second thoughts about many of the key measures in his Budget 1999, including proposals for new aggregates, pesticides, energy use and transport taxes. He should have more confidence, and progress these vital measures in this next Budget. On 21 March, we want to hear him emphasise that the Government's environmental tax reforms are here to stay, because they make sense: for the environment, for the economy and for people.

FOE'S RECOMMENDATIONS FOR BUDGET 2000

1.  REMOVE TAX BARRIERS TO QUALITY INVESTMENT

  1.1  Extend the restricted cut (from 17.5 per cent to 5 per cent) in VAT on energy saving materials to cover investments made by all households nationwide so that investing in energy saving is taxed at the same rate as using energy.

  1.2  Announce a series of reforms to VAT rates on housing development including:

    1.2.1  a cut in VAT on renovation and refurbishment of empty homes to 5 per cent to reduce the disincentive for housing developmers to bring empty dwellings back into use;

    1.2.2  introducing VAT at the full rate on new build housing, with a discounted rate of 5 per cent where such developments are in designated regeneration areas to provide an incentive for house builders to utilise brownfield sites;

    1.2.3  committing to seek a zero VAT ruling from the European Union for social housing developments in order to increase the supply of good quality, affordable housing for those who need it most.

2.  INTRODUCE TAX INCENTIVES FOR QUALITY INVESTMENT

  2.1  Install an enhanced capital allowance scheme for mainstream industry to invest in innovative environmental technologies that will increase the environmental productivity of firms, reduce pollution and provide a boost for the environmental industries sector in the UK.

  2.2  Confirm the reinvestment of £100 million of the Climate Change Levy revenues to finance an enhanced capital allowance scheme for businesses and energy service companies investing in energy efficiency.

  2.3  Announce a tax free credit scheme to cover interest and dividend income from green investment funds, in order to encourage private investment in sustainable development activities such as organic farming and renewable energy.

  2.4  Announce consultation on a further financial incentives for investment in urban regeneration areas proposed by the Urban Task Force.

  2.5  Provide further incentives for investment in more energy efficient vehicles by:

    2.5.1  continuing to reduce the tax break for petrol provided free by employers;

    2.5.2  announce the promised system for taxing company car users according to carbon dioxide emissions;

    2.5.3  implement, as planned, a system of variable road tax (Vehicle Excise Duty) based on carbon dioxide emissions for new cars and engine size for older cars without CO2 emissions data;

    2.5.4  introduce a two pence per litre differential for cleaner low sulphur petrol to encourage investment by industry and its use by car drivers in order to reduce air pollution, particularly in urban areas.

3.  CONTINUED ENVIRONMENTAL MODERNISATION OF THE TAX SYSTEM IN ORDER TO ENCOURAGE QUALITY INVESTMENT

  3.1  Install the Climate Change Levy with provisions to:

    3.1.1  exempt electricity generated from renewable sources and combined heat and power plants;

    3.1.2  tighten the criteria for which sectors can negotiate an 80 per cent cut in the levy rate in order to ensure all energy intensive sites are included and to exclude the large number of sites that are not energy intensive;

    3.1.3  encourage energy intensive sectors to invest in innovative solutions to cutting CO2 emissions by including an "innovation factor" in the negotiated agreements.

  3.2  Install an Aggregates Tax to increase environmental protection by reducing the demand for quarrying and increase the prudent use of quarried materials through reuse, recycling and building design.

  3.3  Announce consultation on a proposal for a Pesticide Tax package that reinvests the revenues back to farming through measures to greatly reduce agricultural chemical use and/or convert to sustainable farming systems, such as organic methods.

  3.4  Increase Road Fuel Duty by 5 per cent above the rate of inflation, and reinvest all the additional revenues in public transport and road traffic reduction through a Sustainable Transport Infrastructure Fund.

  3.5  Increase the Landfill Tax escalator from £1 per year to £2 per year to increase its effectiveness and remove the perverse incentive to incinerate rather than recycle by bringing waste disposal by incineration within the tax.

  3.6  Announce consultation on the previously proposed Fertiliser Tax.

4.  REINVESTING THE REVENUES OF GREEN TAXATION

  4.1  Announce that the hypothecation of revenues from Road Fuel Duties will go exclusively to a Sustainable Transport Investment Fund so that under-investment in rail, bus and other networks, and measures to achieve traffic reduction, are addressed (details below).

  4.2  Make clear that the revenues from any Pesticide Tax will be recycled back to farmers through programmes to convert from chemically-intensive farming to low input and organic methods.

  4.3  Announce that the UK will utilise the full 20 per cent Modulation Option for Common Agriculture Policy subsidies by 2005, in order to shift from production target subsidies to spending that enhances the environment and strengthens local rural economies.

  4.4  Establish a nation-wide Home Energy Conservation programme targeting eight million fuel-poor households through a comprehensive 15 year programme to insulate 500,000 cold homes each year in order to eradicate fuel-poverty, improve public health and living standards and reduce polluting emissions.

5.  A STRATEGY FOR QUALITY GROWTH

  5.1  Publish proposals for significantly improving the assessment of the individual and collective environment impact of economic, fiscal and monetary policies announced at the Budget.

  5.2  Announce the formation of a high level and high profile Task Force to examine how the Government's measurement of economic growth can be modernised to reflect environmental and social "quality" factors as well as "quantity" considerations.

DETAILS OF KEY PROPOSALS

1.  REMOVE TAX BARRIERS TO QUALITY INVESTMENT

  1.1  Extend the restricted cut in VAT on energy saving materials to cover investments made by all households nationwide so that they are no longer taxed at a higher rate for investing in energy saving than for using energy.

  The vast majority of householders who wish to invest in energy efficiency, including many of the fuel poor, pay over three times as much VAT on products and services to do so as they do on using energy. If ever there was an example of the stupidities ingrained within the current tax system this is it. Following extensive criticism by FOE and the Association for the Conservation of Energy (ACE), the Government has made a limited and so far feeble attempt to reform this perverse state of affairs by reducing the rate payable on energy saving materials to 5 per cent for certain Government backed schemes covering just 40,000 homes.

  Customs and Excise argue that European Union taxation law prevents the Government from going further. FOE and ACE has taken legal advice which points quite clearly to a provision within European VAT law which allows for such VAT reductions to be made on measures fitted by contractors on social policy and job creation grounds. France, Italy and even the Isle of Man have taken advantage of this provision, and in all of these countries consumers now pay a lower rate of VAT on energy saving materials than they did a year ago. This blows apart the Customs and Excise argument that the current reduction cannot be expanded.

  FOE further believes that the lower 5 per cent VAT rate can be extended to all energy saving materials including DIY products—and indeed that a zero rate should be considered. We would argue that reforming VAT rates in this way amounts to a cheap home warmth for all programme which is a social and anti-poverty policy, and which brings clear environmental and employment benefits. The Government should extend the lower rate, and take up the issue of a zero rate vigourously in Europe.

  1.2  Announce a series of reforms to VAT rates on housing development including:

    1.2.1  a cut in VAT on renovation and refurbishment of empty homes to 5 per cent to reduce the disincentive for housing developers to bring empty dwellings back into use;

    1.2.2  introducing VAT at the full rate on new build housing, with a reduced rate of 5 per cent where such developments are in designated regeneration areas to provide an incentive for house builders to utilise brownfield sites;

    1.2.3  committing to seek a zero VAT ruling from the European Union for social housing developments in order to increase the supply of good quality, affordable housing for those who need it most;

  Dealing with the present demand for housing provides a significant challenge to the Government's sustainable development strategy. As well as meeting housing needs, the Government must ensure that investment in housing makes prudent use of natural resources, protects the environment and delivers social progress for all. There is serious and widespread concern that its policies are failing to achieve these objectives.

  Land is a precious resource in the UK that needs to be used wisely. Housing investment is putting considerable pressure on our countryside and greenbelts as developers continue to consume greenfield sites for new-build housing. The Government has acknowledged the need to redirect housing investment with its target of 60 per cent of new homes to be built on brownfield sites. Prudent use of the resources used to build homes also demands that far more is done to encourage the renovation of empty homes: in England alone there are some 750,000 empty homes.

  The current pattern of housing investment also threatens the environment through the destruction of wildlife habitats, increased road-building and traffic in some cases the unsustainable use of water. Shifting a greater proportion of housing investment toward renovation and new-build on brownfield sites would reduce these impacts.

  Urban decline in the UK has seen exodus from inner cities, leaving widespread social exclusion with problems of crime, unhealthy environments and poor housing. As the Deputy Prime Minister states: this is "bad for our people, bad for quality of life, bad for our economy and bad for society". FOE agrees, and we call on the Chancellor to tackle this issue in the Budget.

  The tax system provides no significant incentives for housing investment to be directed toward renovation and brownfield sites. In the case of renovation and refurbishment of empty homes there is a perverse disincentive. Existing VAT policy for housing absurdly provides an incentive for volume new-build housing through exemption, and penalises developers wishing to renovate or refurbish empty homes by charging the full 17.5 per cent rate.

  Removing this anomaly would bring environmental, social and economic benefits. The demand for land and materials would be reduced. Existing resources invested in existing homes would be used more efficiently. Pressure on greenfield sites would be reduced, along with the potential for increased traffic, road-building and unsustainable water use usually associated with out-of-town developments. Channelling investment into urban regeneration in this way would also aid the development of those communities and their local economies. In previous years, FOE has called upon the Treasury to harmonise VAT rates on new-build and renovation at 5 per cent. This proposal has support amongst a wide range of organisations including many in the housing industry. We believe that this would bring significant environmental, social and economic benefits by increasing the amount of housing investment directed at renovation and refurbishment.

  However, harmonising VAT rates in this way would not provide an incentive for new-build housing investment to be directed at brownfield sites. In order to install such an incentive the Chancellor should charge the full rate of 17.5 per cent VAT on new-build housing. Adding VAT to the first sale of new-build homes would generate in the order of £1.5 billion per annum. In areas of high land values the change could be absorbed by the market, and would become a predictable cost of any intended development scheme. This measure would also tend to dampen extreme fluctuations in house prices, by reducing the relative supply of new build housing when market prices are low and increasing it when they are high. Most other countries in Europe charge VAT on new build housing.

  Areas of low land value where housing development needs to be encouraged, such as in urban regeneration areas and other brownfield sites, will require substantially lower rates or exemptions. The Chancellor should announce such exemptions to provide clear incentives to direct new-build housing investment away from greenfield sites.

  The Chancellor should reinvest a proportion of the revenues by cutting VAT to 5 per cent for investment in the renovation and refurbishment of empty homes, and setting a zero VAT rate for investments in social housing as the primary source of good quality, affordable housing.

  The wider package of financial incentives for investment in urban regeneration proposed by the Urban Task Force should be the subject of a public consultation, commencing soon after the Budget.

2.  INTRODUCE TAX INCENTIVES FOR QUALITY INVESTMENT

  2.1  Install an enhanced capital allowance scheme for mainstream industry to invest in innovative environmental technologies that will increase the environmental productivity of firms, reduce environmental pollution and provide a boost for the environmental industries sector in the UK.

  There were many tax incentives for business to innovate and invest in new technologies in the Budget `99. Environmental technologies will benefit from these on the same basis as any other type. But the Government's sustainable development strategy demands more than just investment in traditional patterns. It wants a better quality of investment that will, in particular, use resources prudently and protect the environment: in other words, investment of a high environmental productivity, which is able to get more benefit in terms of quality of life from using fewer environmental resources.

  At Budget 2000 the Chancellor should develop the next element in his strategy for investment and bring in measures that increase the quality as well as the quantity of investment. One measure that exemplifies this approach is to install a scheme of enhanced capital allowances for innovative environmental technologies.

  If the UK is to develop a dynamic and environmentally sustainable economy there has to be substantial investment in innovative environmental technologies. Encouraing UK industry to both develop and adopt such technologies will lead to: increased industrial competitiveness as inefficiency in the use of raw materials and energy is reduced; improved environmental performance through a reduction in pollution and waste; and, positive encouragement for the environmental technology industry, one of the sunrise sectors of the global economy. This case has been argued convincingly by the Environmental Industries Commission (EIC).

  But recent research has shown that while firms accept the commercial benefits of investing in environmental technologies, many are hesitant to actually do so. To overcome this barrier the Government needs to provide a financial incentive. FOE agrees with the EIC and calls for an acceleration in the depreciation deductible from tax on investments in innovative environmental technologies, so that British firms can set 100 per cent of the capital investment in such technologies against their tax bill in one year.

  Doing so greatly increases the incentive for mainstream businesses—in sectors as diverse as computing, food and drink manufacture, chemicals and water services—to invest in technologies that save money on raw materials and energy, and reduce adverse environmental impacts. A recent survey for the EIC showed that 94 per cent of business leaders support investment allowances for clean technology. At the same time, such a measure would stimulate the home market for British firms selling environmental technologies and services, and thus provide a vital boost for the UK to capture an increased share of the global environmental technology market, which is set to increase from £175 billion to £400 billion by 2010.

  A similar scheme, run since 1991 in the Netherlands, allows firms that install innovative environmental technologies to depreciate their investment in one year, instead of over 10 years. Qualifying technologies are placed on a list which is periodically updated. Listed technologies are emerging ones with less than 30 per cent market penetration, but which are judged to have a higher environmental performance than the alternatives. In 1995, there were around 450 technologies on the list. In the first three years, over 10,000 firms took advantage of the scheme, which has been reviewed and considered such a success that it will be continued indefinitely. The Government has moved in this direction with the announcement in the PBR that it is to establish an enhanced capital allowance scheme within the Climate Change Levy package to encourage business investment in energy efficiency technologies. It should now extend this option to these other areas.

  The details of the criteria for selecting which technologies should attract such favourable tax treatment will need public consultation. FOE urges the Chancellor to follow the process used for introducing the Landfill Tax by making a commitment to introduce a scheme at the next Budget and announcing a consultation process to determine the details.

  2.2  Announce a scheme to make interest and dividend income from green investment funds tax free in order to encourage greater private investment in activities that will help deliver the Government's aim of quality growth, such as organic farming and renewable energy.

  Most decision-makers in the investment community act on financial criteria to the exclusion of other factors in deciding their investment strategies. If and when environmental threats or poverty relief, for example, are considered, it is usually in the context of liabilities that may arise from damage to property or health. This means that short-term economic and financial interests generally override longer-term environmental priorities.

  FOE calls on the Chancellor to provide a tax break for interest and dividend income earned from green investment funds that invest in projects meeting strict environmental and social criteria. We believe that areas of investment that should be included are those where mainstream funding is more difficult to obtain but which have a vital role to play in delivering sustainable development, such as: renewable energy, organic agriculture, public transport, energy saving, water saving, sustainable forestry, countryside management and green housing projects and programmes.

  This measure would increase the flow of investment into these vital sectors and promote quality investment and growth. It would also make citizens who are private investors more aware of and connected to green investment projects. Businesses in these sectors would be further encouraged to present well-prepared business plans in order to fit the criteria which will be more likely to attract investment from other sources.

  The Netherlands has run such a scheme for over five years. The success of the scheme in encouraging investment into these important areas has meant that the Dutch Government has increased the amount available under the scheme fourfold.

  At Budget 2000 the Chancellor should announce his intention to introduce a scheme in April 2001, following a consultation process.

3.  CONTINUED ENVIRONMENTAL MODERNISATION OF THE TAX SYSTEM IN ORDER TO ENCOURAGE QUALITY INVESTMENT

  3.1  Install the Climate Change Levy with provisions to:

    3.1.1  exempt electricity generated from renewable sources and combined heat power plants;

    3.1.2  tighten the criteria for which sectors can negotiate an 80 per cent cut in the rate to include all energy intensive sites and exclude sites that are not energy intensive;

    3.1.3  encourage energy intensive sectors to invest in innovative solutions to cutting CO2 emissions by including an "innovation factor" in the negotiated agreements.

  New Labour's only new environmental tax shift measure to date is the Climate Change Levy that is due to be included in the Finance Bill this year. It is essential that the Chancellor does not backtrack on this timetable. The Levy will make a significant contribution to securing the Government's welcome manifesto commitment of a 20 per cent cut in UK carbon dioxide emissions by 2010.

  FOE has worked hard to help achieve three important changes to the design of the Levy announced in the Pre-Budget Report (PBR). First, electricity generated from renewable sources of energy will be exempt from the Levy. This is a crucial improvement, as the primary purpose of the Levy is to reduce carbon dioxide emissions. Second, electricity generated by "good quality" combined heat and power (CHP) plant will be exempt. Investment in CHP will be a cost-effective and readily available option for many firms in response to the incentive to increase energy efficiency installed by the Levy. This exemption will tip the balance for a large number of schemes, and boost the market for a technology that is central to achieving Britain's obligations under the Kyoto Protocol.

  Third, a greater proportion of the revenues from the Levy will now be reinvested in schemes to help firms invest in energy efficiency and renewable energy. A further £100 million per year will be used to fund a targeted capital allowance scheme, as called for in previous FOE Budget submissions to Treasury. The list of technologies proposed is too narrow, and the Chancellor should release details of a process for both adding and removing technologies from the list over time as the Levy itself is likely to stimulate technical innovation in these areas. Despite the likely increased administrative costs, we also urge the Chancellor to include energy service (demand management) companies within the scheme, as they are likely to be key deliverers of energy-efficiency targets.

Negotiated Agreements

  We are extremely concerned that the current proposals to allow certain business sectors up to 80 per cent discounts from the Levy, if they enter into legally-binding agreements to implement energy saving measures, are badly designed. They are too widespread, too secret, will be difficult to enforce and crucially, include no incentive for innovation or continuous improvement.

Targeting the right firms

  Ensuring the environmental and fiscal efficiency of the Levy demands that negotiated reductions in the Levy should be very tightly targeted at truly energy intensive processes. This is currently not happening.

  The Government has chosen to use the EU's Integrated Pollution Prevention and Control (IPPC) Directive as the basis for determining eligibility for a rate-cut. However, there is a wide range of energy intensity amongst the thousands of installations that will be covered by IPPC. To grant an 80 per cent discount to all is inefficient both from an environmental and fiscal viewpoint.

  In manufacturing industry, energy costs on average make up only 1.6 per cent of total production costs, compared to average business expenditure on energy of 1 per cent of costs. Intensive energy users within manufacturing, for whom energy represents more than 10 per cent of costs, account for just 2.2 per cent of manufacturing businesses.

  Modelling work conducted for Friends of the Earth of an industrial energy tax indicates that some sectors with installations that come under IPPC, such as pharmaceuticals and general manufacturing, are already likely to be net gainers from the levy/NICs package. Moreover, these less energy-intensive installations stand to benefit from the new options announced in the Pre-Budget Report of switching electricity supply to renewable energy sources and investing in combined heat and power. The Digest of UK Energy Statistics identified many of the less energy intensive sectors currently negotiating agreements with the Government as having the greatest opportunity to make cost-effective savings by investing in combined heat and power.

  The Government does not have to abandon the legal certainty of using IPPC as the initial criteria for eligibility for a negotiated discount, while making these suggested reforms. The Pollution Prevention and Control Act 1999 includes enabling powers to force companies to disclose detailed information regarding their energy consumption. These powers were brought into force by Government amendments. Ensuring that the Levy discounts are accurately targeted at those installations most needing and capable of justly benefiting from the reduction would, in our view, be an appropriate use of these powers.

Preventing free-riders

  It is vital that all firms party to negotiated agreements act to cut climate change emissions, and improve energy efficiency. The design of the agreements has to ensure that free-riders are identified and dealt with in a timely manner. Although each firm in each sector may not sign an individual agreement with the Government—as agreements have been negotiated with trade associations—they must be legally bound by those agreements, and implement them.

  In order to identify free-rider companies, information on action taken by firms needs to be available on a site by site basis. This would provide a clear and strong incentive for firms to comply with the agreement, and would allow the Government to move quickly to reintroduce the full-rate of the levy where a firm fails to meet the conditions of the agreement.

  In order to reinforce this process, and help businesses to make cost-effective investments, the agreements should require that each company pays for an independent site-by-site audit of its annual emissions, which is submitted to the Government. Each company should also be required to fund an independent energy audit of its processes and premises to establish opportunities for energy saving and the uptake of renewable energy sources. A progress report on exploiting these opportunities should be required each year, and a new audit conducted every three years.

Ensure agreements are dynamic

  It is vital that the signed agreements provide a dynamic incentive for firms, and does not lock them into investing in existing technologies with short payback times. One of the key attributes of an economic instrument like the Climate Change Levy is that it shoud provide a dynamic incentive for firms to reduce emissions through stimulating innovation. It would be ludicrous if the agreements made with the most energy-hungry sectors failed to do this. FOE remains concerned that the current negotiations are locked into business-as-usual options—rather providing an incentive to innovate, go beyond compliance and change the pattern of investment.

  The Government could learn from BP Amoco on this issue. In its internal emissions trading scheme, BP Amoco set a target which took current cost effective opportunities to reduce emissions and then added a further factor for future innovation, technologies and better practice ideas. If negotiated agreements are to genuinely encourage firms to innovate then merely adding up cost-effective measures, as currently proposed, will not be enough. The inclusion of an "innovation factor" in the targets in the agreements would address this oversight.

  An alternative approach would be to use a system of international benchmarking, as adopted in the Netherlands. The recent Dutch Energy Efficiency Benchmarking agreement requires processes to be benchmarked against similar processes around the world in terms of energy efficiency, with the requirement that firms achieve a top five rating within a certain period of time. The aim is to move these firms toward making more far-reaching energy efficiency investments. Such investments have a payback period of eight to 10 years, rather than the more normal two to four year payback period, which companies are already putting in place as part of the normal business cycle.

Making the agreements compatible with emissions trading

  The Government has already announced that it wants to allow some form of trading within the agreements. This could create significant barriers to the development of wider emissions trading schemes. There is general agreement that, once the practical difficulties surrounding emissions trading are addressed, these schemes will play an important role in reducing CO2 emissions. The Government needs to ensure that the design and extent of any trading provisions included in the agreements do not create barriers to establishing such trading systems. There are three particular problems.

  First, all agreements are likely to be based upon improving energy efficiency per unit output. Emissions trading schemes will rely upon an overall ceiling or cap for emissions, regardless of output. However, the trading scheme within these agreements would be "cap-less", and as such directly incompatible with any domestic emission trading scheme and lacking credibility on the international stage. We understand that the Government intends to offer firms the chance to convert from energy efficiency based agreements to carbon-based agreements, in order to allow firms within the agreements to trade with firms in trading systems outside the agreements. The effectiveness of such a system will depend on both the targets set and the details of the conversion process.

  Second, the negotiated agreements are being agreed on the basis of what is cost-effective for firms in that sector alone. They are likely to vary in how accurately they reflect this cost, given the process of negotiation involved and the unsatisfactory reliance by the Government on the firms themselves revealing the necessary full and accurate information in order for targets to be set. Emission trading systems operate on the basis that trading occurs between sectors according to a common metric. There is a real concern that, if the trading market within agreements is more attractive to the firms involved, they will not engage in wider emissions trading systems when they are established.

  Third, emissions trading systems have to be transparent to operate properly.The negotiated agreements have not been transparent to date. Firms wishing to prevent outside scrutiny would tend to stay inside a less-transparent agreement.

  3.2  Install an Aggregates Tax to increase environmental protection by reducing the demand for quarrying and increase the prudent use of quarried materials through reuse, recycling and building design.

  There are two ways of looking at the Chancellor's actions over developing a quarrying tax. He could be seen as dithering over a tax reform for which the case has been made, or he could be seen as astute in giving the industry enough rope to ensure he can progress without being accused of having ignored its proposals.

  Either way at Budget 2000, the Chancellor should conclude the process he started in 1997 and announce the introduction of a Aggregates Tax, for which Customs and Excise have already produced a legal draft.

  In the Pre-Budget Statement in November 1998, the Chancellor concluded that there were "significant environmental costs" of quarrying, which were not already covered by regulation. As a result, he pledged to consider the case for an aggregates tax and a set of alternative proposals put forward by the quarrying industry. In Budget 1999, he accepted the case for an aggregates tax and asked Customs and Excise to draw up draft legislation ready for introduction at Budget 2000. At the same time, the Treasury concluded that the quarrying industry's voluntary package fell "well short" of what was required, but they would be given one last chance to come up with a credible alternative. In the PBR last November, the Government again concluded that even a revised industry package "continues to fall short of what is necessary to match the overall environmental and economic effects of a tax on primary aggregates" (6.95). Since then the single industry body, the Quarry Products Association (QPA), which had been presenting the proposals, has split and a rival body formed in British Aggregates Association.

  Attempts by the industry to rise to the Chancellor's challenge have failed, as the progressive firms have tried in vain to move the rump of laggard quarrying firms onto best practice initiatives. Not only has the quarrying industry failed to offer any significant new measures which convincingly might make an aggregates tax redundant, but it has also failed to deal with fundamental weaknesses in its apprach. The proposals contain no clear quantitiative targets and there is no independent and transparent verification scheme, either overall or for individual firms. The motivations for firms to comply with the commitments are either too weak or will not effect enough firms—resulting in a significant free-rider problem.

  But the hammer blow for the Government's flirtation with a loose voluntary approach has been the split in the industry's ranks. At a time when the QPA needed to strengthen its case that it was the sole representative organisation for the industry, capable of delivering compliance with agreement across the sector, the formation of a breakaway body shows that the voluntary approach is neither deliverable nor credible.FOE has continually warned the Government that attempting to use a representative organisaton as an enforcement body would prove unworkable and the arrival of the British Aggregates Association confirms our fears.

  Unless the Chancellor decides to do a complete U-turn, he must now move to install an aggregates tax, as FOE has long argued for. This will provide an incentive for innovation and investment to increase the efficiency with which these important non-renewable resources are used through greater recycling, reuse and improved construction design; and, as a consequence, over time reduce the land take of quarrying. By moving the industry away from its current "pile it high and sell it cheap" mentality, the aggregates supply sector will begin to meet the Government's aim of encouraging economic producitivity that makes increasingly prudent use of natural resources .

  Budget 2000 should include the installation of an aggregates tax. But the Chancellor needs to make clear that such a tax will act in concert with the existing regulatory framework. He should also announce that a proportion of the revenues will be reinvested into a sustainability fund for the sector that deliver the main positive proposal put forward by the industry. However, FOE continues to believe that the majority of the revenues can be used by the Government to make further progress in shifting the burden of taxation.

  3.3  Announce consultation on a proposal for a pesticide tax package that reinvests the revenues back to farming through measures to greatly reduce agricultural chemical use and convert to sustainable farming, such as organic methods.

  The Pesticides Tax has become a political football since the last Budget, with the Treasury bowing to pressure from No 10 and deciding to drop, at least temporarily, this proposed "polluter pays" measure.

  After the completion of research on the design of a tax or charge scheme for pesticides, which was widely well-received, the Chancellor has concluded that "a tax or charge could be a useful tool, in conjunction with other measures, in addressing the environmental impacts of pesticides" (6.108). The Environmental Audit Committee of the House of Commons in its report on the PBR also found "in favour of introducing a pesticides tax as part of a package of measures" (Summary p 1).

  Yet in his recent address to the National Farmers Union, the Prime Minister announced that the pesticide tax proposals were being dropped. The Treasury similarly announced in January that the proposals for a voluntary scheme put forward by the pesticide industry would now take-over from proposals for a pesticide tax as the method for addressing the failure of existing regulations to control pesticide pollution. But Treasury also confirmed that a pesticides tax is still on its long-term agenda.

  These events and statements do not send clear signals about the Government's intention to tackle what Ministers accept is "increasing evidence that there are significant environmental impacts associated with pesticide use" (6.106) under current regulations. The PBR made clear that current regulations are not enough and further action is required (6.106). Most worryingly, they seem to indicate that, rather than giving an opportunity to the pesticide industry to come up with an alternative to a pesticide tax at the same time as the Government made sure the design of a tax package was right, the tax is to be shelved while the industry outline proposals are discussed with no apparent deadline or timetable.

  The Government does not seem to have learnt the lessons of the aggregates tax. There the twin-track approach of developing tax proposals and encouraging alternative solutions highlighted the lack of credibility of a loose voluntary approach.

  FOE believes that pesticide pollution is a pressing issue because of the impact upon wildlife, ecosystems and human health, and should not be marginalised in this way. We share the concern of the Environmental Audit Committee, which was "astonished and disappointed" that the pesticide tax appears to have been dropped "without even making the industry's alternative proposals public for consultation and discussion" (summary p 1). In all likelihood the proposals from the British Agrochemicals Association will turn out to be little different from existing approaches, which are failing to curb unnecessary contamination.

  What is needed is a new pesticide tax, of the type long advocated by FOE. A tax on pesticides would, for the first time in the UK, create a powerful incentive to reduce unnecessary pesticide use. Experience from other countries, including Sweden, Austria and Denmark, has shown that a package of measures, including a pesticide tax and other incentives such as information, advice and grant-aid schemes, designed to encourage farmers to adopt less chemically intensive or organic farming systems, are a highly effective method of reducing pesticide use.

  The package can be paid for by recycling revenues from the tax. In Sweden and Denmark, respective reductions in total pesticide use of 65 per cent over nine years, and 30 per cent over seven years, have been achieved. In 1986, Sweden set a pesticide use reduction target of 75 per cent by 1997, and introduced a pesticide charge in conjunction with a range of measures aimed at reducing pesticide use. The Charge has raised between £1.8 million and £3.0 million per year, compared to the cost of the package of reduction measures of £1.6 million in 1993-94.

  The impact of the tax upon farming and rural economies is a vital consideraton in designing the tax, and deciding how to use the revenues. Trends in agricultural policy in Europe are to cut subsidies. This process of reform should mean that cutting pesticide use will increasingly become both easier and more attractive for farmers. The rapidly expanding market for organic produce offers farmers the opportunity to meet consumers' preferences without paying such a tax. A proportion of the revenues from a pesticide tax should be used to directly support existing organic operations, and conversion from chemical intensive systems to organic. Recently the Government set aside £16 million to support farmers converting to organic systems over a two year period, but the demand was so high that within six months the total amount was accounted for. The research on a pesticide tax commissioned by the Government suggested that revenues would be in the range £84-£131 million per year, which could comfortably support a scheme meeting such high demand from farmers.

  In the short-term, the substantial majority of the revenues from the tax need to be recycled back to farming. Using the revenues from a pesticide tax to fund policies that help encourage investment in a dynamic, mixed and environmentally, socially and economically sustainable farming sector that delivers real food is vital. In the longer-term revenues may be available to further cut NICs on farm labour.

  3.4  Increase Road Fuel Duty by 5 per cent above the rate of inflation and reinvest all the additional revenues in public transport and road traffic reduction through a Sustainable Transport Infrastructure Fund.

  Road transport is responsible for 20 per cent of the UK emissions of carbon dioxide. Health-threatening vehicle pollution prematurely kills between 12-24,000 people annually, and is the prime cause of poor air quality. Congestion reduces the efficiency of the economy, and the cost to the health service drains public finances. The present transport system is also deeply inequitable, and is unable to meet the needs of the one third of UK households who have no regular access to a car.

  The road fuel duty escalator—the pre-announced annual 6 per cent increase above the rate of inflation—has been the Government's most effective weapon in the battle to reduce CO2 from road transport. New incentives to buy more fuel efficient cars through changes to Vehicle Excise Duty and Company Car Allowances, and commitments by car manufacturers to produce more fuel efficient cars, will also play a role. But as the Chancellor noted in his 1998 Pre-Budget Report, "growth in road traffice offsets the reduction in emissions from individual vehicles". According to the Commission for Integrated Transport (CIT) traffic will grow by 35 per cent between 1996 and 2010 without the congestion charges and parking levies included in the Transport Bill and 27 per cent with these measures in place.

  Despite this the Chancellor announced in the Pre-Budget Report that the escalator is to be replaced by Budget by Budget decision-making. If the decision is not to increase road fuel duty between now and 2002 when the escalator was planned to finish, then the failure to reduce CO2 emissions will be significant. Treasury estimates that it will lead to a loss of 1-2.5mtC savings, and DETR a loss of 1.3-3.3mtC savings. This is unacceptable.

  Last year FOE called upon the Chancellor to reinvest the revenues from the escalator through a Sustainable Transport Infrastructure Fund. This would allow the Government to make the investments in public transport that are so important to achieving reduced traffic levels. He responded by announcing that future revenue from increased road fuel duty would be used to provide extra transport funding. If the Chancellor does not increase road fuel duty he will reduce the opportunity to make key investments in provided integrated public transport networks. Each 1 per cent will raise £230 million.

  We call on the Chancellor to use the flexibility he granted himself to reduce the increase below 6 per cent when necessary. The recent rise in crude oil prices does represent a reason to ease back on the rate of increase, but this has to be balanced against the damage this will do to the Government's drive to meet both its legal CO2 reduction target and its own manifesto 20 per cent target. FOE recommends that at Budget 2000 the Chancellor increases road fuel duty by 5 per cent above the rate of inflation. We also recommended that he makes clear that the reinvestment of the revenues from this increase, some £1.1 billion, is directed at public transport and traffic reduction schemes.

  3.5  Increase the Landfill Tax escalator from £1 per year to £2 per year to increase its effectiveness and remove the perverse incentive to incinerate rather than recycle by bringing waste disposal by incineration within the tax.

  A comprehensive report into the economics of recycling has just been completed by ECOTEC Research and Consulting Ltd. The report was commissioned by FOE and UK Waste Ltd, and the research project was managed by Waste Watch. The research looked at the economic costs of recycling, as well as the costs of landfill and incineration. It looked in detail at external impacts of these waste management systems and used existing environmental cost valuations of these impacts to model various scenarios. It also critically examines the use of environmental cost estimates in decision making. The report generally supports FOE's position that the Landfill tax should increase in price and that a tax on incineration should be introduced.

  However, while we do recognise that the existing annual £1 tonne escalator on the standard rate of the Landfill Tax will make the tax gradually more effective at encouraging firms to recycle and minimise waste, we also believe that it needs to increase faster if it is to have any real deterrent effect. Only firms with significant waste costs have responded to the disincentives provided by the tax to date. An FOE survey of more than 70 companies found that only 31 per cent had either stepped up or started programmes to reuse or minimise waste. Some firms and sectors have responded by looking for innovative solutions. In other cases, waste producers have asked for their waste arisings to be charged by the tonne to allow them to take a more strategic approach to waste minimisation and recycling.

  FOE maintains that the rate of the escalator should be £2 per year, because evidence from the waste industry suggests that a level of £15 per tonne (reached under a £2 per annum escalator by 2004-05) is the minimum required to have a significant impact on the activities of a wide range of waste producers. An escalator helps business to adjust in a planned way. The Government target for recycling 30 per cent of household rubbish by 2010 will not be reached unless appropriate penalties and rewards are increased.

  It is worth noting that Biffa Waste Services, in their recent excellent report "Sustainable Waste Management? It depends which way you look at it", stated that the impact of the landfill tax has been limited to date, and have also called for substantial rises in the level of the tax.

  If the Landfill Tax is to operate effectively, it must also be extended to waste disposal by incineration. While incineration remains an untaxed waste disposal route for materials that can be reused, recycled or composted, it blocks progress towards meeting targets and reduces the incentive for investing in, and innovating for, waste minimisation and recycling. We are aware that there is concern that extending the tax to cover incineration may involve most of the additional revenue being spent on collection, because of the currently small number of incinerators in operation. To overcome this problem, but still send a clear signal of future intentions, the rate could be initially set at zero, as in the Netherlands, allowing it to be raised when appropriate.

  The use of the revenues from the Landfill Tax is important. The additional revenues from the increase in the standard rate of this tax, announced by the Chancellor in his last Budget, were not used to cut employers' NIC as was the case when the Landfill Tax was first introduced. This break from green tax reform must be resisted in the future—if environmental taxes are to promote integrated economic, environmental and social objectives, and not just get a bad name in industry as simply another cynical revenue raising exercise by the Treasury (as happened when Norman Lamont tried to deflect criticism of his increase in VAT on fuel use by subsequently claiming it was an environmental measure).

  The announcement in the 1999 Budget of a change to the tax credit scheme to direct more of that money at recycling was welcomed; however, this reform has resulted in little change. Our position remains that funds should flow to recycling from either the income received by the Treasury or through a reform of the landfill tax credit scheme. We do not accept that landfill tax monies should be spent on non-waste related activities.

4.  REINVESTING THE REVENUES OF GREEN TAXATION

  4.1  Announce that the hypothecation of revenues from future increases in road fuel duties will be so exclusively to a Sustainable Transport Investment Fund rather than to general transport spending including so that appalling under-investment in rail, bus and traffic reduction is addressed head-on.

  In the Pre-Budget Report the Chancellor announced that, in-line with Friends of the Earth's recommendations, he would ring-fence revenues from future rises in Road Fuel Duty for transport spending. To date increases in Road Fuel Duty under this Government have brought £3.6 billion in extra revenue to the Exchequer and will continue to bring in around £1.5 billion per year (according to the Treasury's estimates published in Budget 1997, Budget 1998 and Budget 1999). Every 1 per cent increase in Road Fuel Duty announced by the Chancellor at this Budget will be equivalent to an extra 230 million for transport spending.

  But the Chancellor failed to target this reinvestment of green tax revenues at reversing years of under investment in public transport and facilities for cyclists and pedestrians. If rail, bus, cycling and walking are to play their part in a modern, efficient, safe, convenient and environmentally sound integrated transport system, the balance of transport infrastructure spending has to be shifted substantially. What better example of joined-up Government could there be than using the revenues from a tax aimed at reducing traffic, by making motorists pay more of their environmental costs, to invest in providing people with attractive alternatives to the car? It would also sharpen up the impact of what is often criticised as too blunt a tax instrument.

  At Budget 2000 the Chancellor should announce that ring-fenced will be targeted at transport spending which helps reduce road traffic, with non available for further traffic-generating road building. This will provide added resources for delivering on the objectives of the Integrated Transport White Paper, and should be administered by a Sustainable Transport Investment Fund. Such a fund could provide finance for major public transport investment schemes, such as the upgrading of the London Underground and investing in the safety and efficiency of the national rail network and selected smaller locally based projects.

  4.2  Announce that the UK will utilise the full 20 per cent modulation option for Common Agricultural Policy subsidies by 2005 to shift from production target subsidies to subsidy measures that enhance the environment and strengthen local rural economies.

  The agricultural industry is in its worse recession since 1939. To make matters worse, farmers are held in low esteem by consumers, who generally regard them as over-subsidised producers of inferior qualilty food who damage wildlife and landscapes.

  To date the nature of the subsidies handed out through the Common Agricultural Policy (CAP) for over intensive production has been the main cause of environmental damage in this sector. But CAP reforms have now given national governments a degree of real flexibility in how they pay out subsidies. No longer do all subsidies have to be direct production payments. Up to 20 per cent can be redirected through measures such as support for organic farming and the positive management of wildlife sites, and others listed in the new Rural Development Regulation (RDR).

  Currently, the UK Government plans to redirect only 2.5 per cent of conventional production payments, rising to 4.5 per cent by 2005. This is grossly inadequate given the economic, social and environmental benefits that flow from modulating subsidies away from Soviet style production targets towards payments that encourage the environmental modernisation of the farm sector and crops/food that people want to eat.

  Modulation allows for a far fairer distribution of subsidy between farmers. At present just 20 per cent of farmers receive some 80 per cent of subsidies. Most of these beneficiaries are large arable farms in the south and east of England. Yet these farmers are the least in need of support. Modulation of subsidies through the RDR offers a real opportunity to target payments to small, low input farms that are delivering environmental and local economic benefits.

  Modulation also allows for an increase in support for organic farming, in response to the increasing demand for organic food from consumers and from farmers to convert to this sustainable farming practice. At present Government support for organic farming is only 0.2 per cent of agricultural spending, and fails to meet these demands by a considerable margin. If the level of support is not raised, the increased demand for organic produce will continue to be met by imports from EU nations that have provided adquate support. Already the UK imports 70 per cent of organic food consumed here.

  Modulation enables farmers to reverse the environmental damage caused by the intensive farming methods encouraged by conventional production subsidies. Directing subsidies to farmers through schemes that deliver environmental protection will enhance our countryside and wildlife, and boost tourism. Schemes like this operating in the UK have already been shown to increase farm productivity, and create jobs both on farms and in the local economy.

  Finally modulation can strengthen and diversify local rural economies through funding for schemes that encourage production and processing of farm products, such as food and sustainable timber, back to rural areas; develop the potential for farms to grow energy crops; and, increase support for training and new enterprises in rural economies. Small farms tend to have a more positive impact upon local businesses as they are more likely to buy inputs locally. Organic farming has also been shown to both increase on-farm employment, and, crucially, to increase employment in the local economy through increased preparation, processing and marketing of food products. Generally, organic farms employ between 10-30 per cent more people than conventional farms.

  Environmental management schemes increase on-farm employment through the need for environmental maintenance work and increased demand for materials and services from the local economy. Small, mixed farms managed in harmony with the environment also create and maintain landscapes that are more attractive to tourism than large-scale, intensive monocultures.

  In its Election manifesto, New Labour promised to "reform the Common Agricultural Policy to save money, support the rural economy and enhance the environment". Modulation offers them exactly that opportunity and the Government's refusal to make more of this provision is incomprehensible. The longer they stall on these reforms, the worse it will be for farmers, rural communities and the environment.

  FOE therefore calls on the Chancellor to announce a new programme of shifting public investment in farming and rural economies away from production subsidies and toward measures included in the RDR. This programme will see the UK utilising the full 20 per cent modulation limit by 2005 in a strategy that will provide support to small farmers, strengthen and diversify local rural economies, increase environmental protection and expand organic production in the face of increasing demand.

  In order to ensure a well-designed strategy, the Chancellor should consult on how to design the rolling programme of investment measures that will meet this target of 20 per cent modulation by 2005. The UK already has schemes in operation that provide evidence of what works and what does not, and the modulation programmes in other EU member states also can offer insights. The consultation should be concluded to allow the Chancellor to release full details of the strategy no later than the PBR in November 2000.

  4.3  Establish a nation-wide home energy conservation programme targeting eight million fuel-poor households through a comprehensive 15 year programme to insulate 500,000 cold homes each year in order to eradicate fuel-poverty, improve public health and living standards and reduce polluting emissions.

  Eradicating Fuel Poverty can help deliver both sustainability and cost-savings across departments. At present up to eight million households in the UK are suffering from fuel poverty—they cannot afford to heat their homes properly. One effect is that between 30,000 and 60,000 more people die during the winter than summer months in the UK. This is a national scandal which will continue every year until fuel poverty is tackled.

  By maintaining current spending plans, the problem of fuel poverty is set to cost the Government:

    4.3.1  around £1 billion per year on the National Health Service in treating cold and damp related illnesses such as respiratory diseases, heart and cerebro-vascular complaints

    4.3.2  £1.4 billion a year on personal fuel subsidy payments

    4.3.3  over £700 million a year on energy conservation measures through property improvement programmes.

  FOE agrees that the immediate needs of the fuel poor should be met by cold weather payments, but the Government should be tough on the cause of the problem to avoid endlessly paying for the effects. It is the energy efficiency of the home environment that determines whether a low income family can obtain adequate warmth and comfort. It is here that the Government can spend to save; it is here that the Government can make environmental and social progress towards sustainability.

  FOE and the Association for Energy Conservation (ACE) have helped draft the Warm Homes and Energy Conservation Bill. This requires the Government to draw up and implement a national home efficiency strategy aimed at ending fuel poverty. 143 MPs voted for the Bill at Second Reading and the Government and all Opposition parties signified their support. FOE and ACE are currently pushing to ensure that the Bill becomes law. Detailed costings prepared by FOE and ACE suggest that such a programme would be revenue positive. A 15 year programme of work on 500,000 homes a year would cost £1.25 billion a year. These costs would be recouped by savings in other areas over the life of the programme. Areas where savings would be made include: the £1 billion per annum burden on the NHS of coping with cold/damp related diseases; savings in benefit payments and additional tax revenues from unemployed taking up the 30,000 new long-term jobs that would be created; and large savings in the maintenance and management of public sector houses improved under the programme.

  In addition to these benefits, this programme would make significant contributions to Government efforts to deliver decent public housing, reduced health inequalities, creating job opportunities, cutting CO2 emissions, and reducing air pollution.

March 2000


 
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