APPENDIX 8
Memorandum from WWF-UK
SUMMARY
WWF-UK welcomes the opportunity to submit evidence
to the Environmental Audit Committee enquiry into the Climate
Change Levy (CCL) and commends the committee for undertaking an
inquiry at such a crucial stage in the process of introducing
the levy.
WWF welcomes the Government's decision to introduce
a climate change levy on the business use of energy as a means
of reducing the use of fossil fuel sources of energy and meeting
the UK's commitments under the Kyoto Protocol. The main points
of our submission are:
— In the short to medium term the best
economic instrument for the commercial and industrial sector is
a carbon tax, not a permit system.
— WWF believes that the introduction
of the levy will be beneficial to the majority of UK business
and will not damage its competitiveness. Research commissioned
by WWF indicates that:
Industries employing 93 per cent of
the UK workforce and creating 90 per cent of GDP will either gain
directly from the package or will only face a marginal increase
in costs of less than 0.1 per cent of the value of the industry's
sales.
Overall the economic size of the sectors
that benefit from the package are more than double the size of
the industries that lose if size is expressed either as number
of employees or contribution to GDP.
— WWF believes that some form of levy is
also needed in the domestic sector, as a tool for both reducing
energy use and relieving fuel poverty.
— WWF does not support the proposal that
lower levy rates be applied to those industries which voluntarily
put in place energy efficiency schemes:
WWF has reservations about the process
of negotiating sectoral agreements. Whilst recognising that negotiating
with trade associations and their ability to negotiate on behalf
of their members.
Information from the DETR indicates that
there is currently much confusion in the negotiation process with
little evidence that they are going to produce an effective solution.
— WWF accepts that in exceptional circumstances
a problem of competitiveness may remain. Where this is the case,
competitiveness can be protected by ring-fencing the levy revenues
paid by the particular sector and rebating the sum paid back to
them on the basis of individual firms' economic output.
— WWF believes that the sums allocated
to help the SME sector are insufficient. WWF also believes that
more targeted help is required to make SMEs aware of the levy,
its implications and some of the tools available to offset the
levy. In addition WWF believes that to ensure SMEs are given an
adequate voice in the discussions about the climate change levy,
an inter-departmental SME task force should be created within
Government.
— WWF welcomes the intention to recycle
part of the revenues from the levy to give additional support
to renewables but does not believe that electricity from renewable
sources should be included in the levy.
1. INTRODUCTION
1.1 WWF-UK (the World Wide Fund for Nature)
welcomes the opportunity to submit evidence to the Environmental
Audit Committee inquiry into the Climate Change Levy and commends
the Committee for undertaking an inquiry into this pertinent issue.
1.2 WWF is one of Britain's leading environmental
organisations, working on a wide range of environmental issues
in the UK and around the world. WWF's philosophy is to conserve
nature—wild species and wild places—by promoting the
sustainable use of natural resources to meet the needs of current
and future generations.
1.3 WWF considers climate change one of
the greatest threats to biodiversity. Taking effective action
now to reduce greenhouse gas emissions is our best insurance policy
against dangerous climate change in the future. To that end, fundamental
changes are needed, in the energy sector in particular, to change
unsustainable patterns of production and use.
1.4 WWF welcomes the Government's decision
to introduce a climate change levy on the business use of energy
as a means of reducing the use of fossil fuel sources of energy
and meeting the UK's commitments under the Kyoto Protocol.
1.5 However, whilst welcoming the levy,
WWF has some reservations as to its design, particularly its focus
on energy, rather than carbon, the failure to exempt renewables,
the lack of support for small and medium sized enterprises (SMEs)
and the methods of recycling the levy revenues.
1.6 WWF's submission to this inquiry concentrates
on three areas. It begins by presenting the case for a levy as
opposed to a system of emissions trading. Secondly, it looks at
the effect that the levy will have on UK business and draws comparisons
with the situation in other EU and G7 countries. Thirdly, it examines
specific issues surrounding the design of the levy—whether
it should be a carbon based or an energy based tax, who should
pay the levy, the provisions for the energy intensive sectors
and SMEs and the treatment of renewables and community heating.
1.7 Above all, WWF urges the Government
to take a strong line on this issue, and not bow to the pressure
of a small, but vocal, sector of industry and to ensure that the
levy is introduced as early as possible.
2. A CLIMATE
CHANGE LEVY
OR A
TRADEABLE PERMITS
SYSTEM
2.1 WWF believes that the practical achievement
of the Government's 20 per cent carbon dioxide (CO2) reduction
target will require the use of all possible instruments: voluntary
initiatives, economic instruments and direct regulation.
2.2 WWF believes that in the short to medium
term the best economic instrument for the commercial and industrial
sector is a carbon tax, not a permit system. This view is based
on three factors.
2.3 (a) Taxes promote greater innovation
Controlling CO2 emmissions is a dynamic problem
because the timing of action will have both environmental and
economic impacts. Expert consensus, for example, at the International
Energy Agency Modelling Forum, is that given the long lead times
needed to replace invested capital and develop new technologies
early strong incentives for abatement are required[12].
Transforming the fossil-based economy is like steering an oil
tanker—even a slow change of course requires an immediate
sharp change in the steering.
2.4 WWF believes that taxes will give greater
incentives for innovation, diffusion and investment in new technology
than emission permits. Under a trading system the development
of new technology in response to an emissions cap results in lower
permit prices. However, under a tax system it results in greater
technological diffusion and abatement because the tax rate does
not decline as technology is introduced.
2.5 The disincentives from lower permit
prices will be exacerbated if international trading is allowed.
If UK companies can buy cheap permits from Russia they may save
abatement costs now, but will have lower incentives to change
their operations or develop new technology. Therefore, when the
"hot air" runs out and higher targets are in place,
UK companies will neither supply the new, growing markets for
abatement technology nor be competitive in existing product markets.
This would repeat the experience of the global market in sulphur
dioxide (SO2) reduction equipment, where UK companies lost out
to Japanese and German manufacturers because we introduced emission
controls later and more slowly.
2.6 Empirical studies suggest that many
of the energy efficiency gains achieved after the 1970's oil crisis
came about due to the transmission of increased energy prices
down the materials supply chain[13].
Therefore as materials become more expensive due to their energy
content, designers use less of them in their products. This vital
price signal depends on the marginal cost of emission reductions
being reflected in the price of manufactured goods, which occurs
with an energy tax.
2.7 (b) Taxes will have wider coverage
and therefore produce lower cost reductions
Research shows that the lowest cost CO2 reductions
lie in small and medium sized businesses. However, it is unlikely
that emission permits can be efficiently or fairly applied to
SMEs in the short to medium term. Though permit schemes do exist
at this level in small sectors—for example, milk quotas—they
cover the bulk of firms' business, not the 3-6 per cent typical
for energy costs in most companies.
2.8 (c) Taxes are flexible and administratively
simple
Energy or carbon taxes can be introduced immediately
through existing systems, and tax rates can be easily altered
as knowledge changes about their impact and effectiveness. In
contrast, permit systems require a predictable allocation of property
rights which will be hard to reverse if mistakes are made. The
problems of base lining, admission of new entrants and room for
growth will be endemic—especially in energy intensive industries—unless
permits are auctioned annually. National permit systems must also
be designed to be consistent with the international system yet
to be defined in the Kyoto Protocol.
2.9 Kyoto permits will be exchangeable (fungible)
between all six controlled gases, but this is unlikely to be the
case at national level due to the reluctance of companies to deal
with gases that are hard to measure, such as methane and nitrous
oxides. Any national system is likely to require a derived permit
based around CO2 and perhaps the three industrial gases, which
are easiest to monitor. Therefore national issues of buyer/seller
liability, governmental risk, non-compliance penalties, permit
convertibility, competition in the permit market, impacts on broader
competition issues and dispute resolution will have to be resolved
before a permit system can function.
3. EFFECT ON
BUSINESS
3.1 WWF believes that the introduction of
the levy will be beneficial to the majority of UK business and
will not damage its competitiveness. The corresponding reduction
in National Insurance Contributions (NICs) will compensate for
the levy. Furthermore, there is evidence to suggest that energy
prices are not a major factor in investment decisions, so that
higher energy prices should not hinder economic success.
3.2 A study carried out for WWF[14]
indicates that industries employing 93 per cent of the UK workforce
and creating 90 per cent of GDP will either gain directly from
the package or will only face a marginal increase in costs of
less than 0.1 per cent of the value of the industry's sales. Other
findings of the study are:
— No sector will lose more than 2 per
cent of the total value of their purchases.
— Overall the economic size of the
sectors that benefit from the package are more than double the
size of the industries that lose if size is expressed either as
number of employees or contribution to GDP.
— No industry is likely to lose out
from the combined effect of the CCL and the cut in NIC by more
than 4 per cent of the value of its sales even if the CCL is applied
at its full rate.
— The two greatest beneficiaries of
the policy are education (£77 million) and the health service
industry (£66 million).
— The extra money available to the
education and health sectors is sufficient to fund an extra 7,000
employees in the health industry and about 3,500 more teachers.
— The industry that loses out the most
from the package is food production (87 million). However this
loss is a small fraction, about 0.15 per cent of the industry's
total turnover.
3.3 There is also empirical evidence to
indicate that energy prices have little bearing on overall trade
and investment decisions. Research by WWF[15]
found that energy intensive industries have a range of motivations,
not just energy prices, which influence their location decisions.
These include market access, product quality, existing trade links,
and trading restrictions such as import quotas and tariffs. Other
motivations include economic and political stability, secure legal
rights, efficient financial markets, and educated workforce and
reliable infrastructure services. These findings indicate that
any increase in energy prices will have little bearing on the
decision by energy intensive industries to relocate.
Energy Prices
3.4 The table below shows that in 1997 the
price of industrial electricity in the UK was more expensive than
in a number of other countries including the USA and France but
cheaper than other major economies such as Germany and Japan.
An energy tax of 0.6 p/kWh, about 15 per cent of the average price
of industrial electricity, would have made the price of UK electricity
marginally more expensive than Germany but still much less than
that in Japan.
3.5 In 1997 gas prices in UK were amongst
the lowest in the world. A tax of 0.2 p/kWh, about 30 per cent
of the average price of industrial gas, would have moved the UK
from the second lowest gas prices to the fifth lowest (out of
15).
1997 energy prices and indicative tax
rates in EU and G7 countries
|
| Country | United Kingdom
| Germany
| Netherlands
| Japan
| United States
|
| Fuel | Gas
| Electricity | Gas
| Electricity | Gas
| Electricity | Gas
| Electricity | Gas
| Electricity |
|
| Pre Tax Price (p/kWh) | 0.52
| 3.95 | 1.00
| 4.26 | 0.65
| 5.947 | 2.51
| 10.06 | 0.71
| 2.67 |
| Tax (p/kWh) | 0.21
| 0.60 | 0.11
| 0.69 | 0.05
| 0.003 | n/a
| n/a | n/a
| n/a |
| Post-Tax Price (p/kWh) | 0.77
| 4.52 | 1.11
| 4.95 | 0.70
| 5.950 | 2.51
| 10.06 | 0.71
| 2.67 |
|
| | |
| | | |
| | | |
Adapted from DTI 1998[16]
and OXERA 1999[17]
3.6 The table also shows that the UK is not alone in
introducing a tax on energy. Other EU countries have already implemented
energy taxes, including our main competitor Germany.
3.7 UK industry has benefited from the liberalisation
of energy markets. This has driven down energy prices for all
fuels over the past decade. In the past five years energy prices
have been at the same level as that implied by the CCL (with the
exception of coal) even in nominal terms. Average electricity
prices have dropped from 4.3 to 3.7 p/kWh since 1993, gas prices
from 0.78 to 0.56 p/kWh since 1994 and fuel oil from 0.8 to 0.6
since 1996. Prices of coal have dropped from 0.54 to 0.47 p/kWh
between 1993 and 1997, less than the CCL but a significant drop
nonetheless. The fuel prices that would result from the CCL have
all arisen in the recent past without any significant disruption
to the economy. The proposed level of the CCL will not push energy
prices up above levels that have been experienced within the recent
past.
Exchange Rate Fluctuations
3.8 One of the biggest business risks faced by industry
and especially the manufacturing sector are movements in the exchange
rate. The UK currency has appreciated against the European currencies
by between 20 per cent and 30 per cent since 1997. The total value
of UK exports of goods to Europe was £95,908 million in 1997.
The deterioration in the terms of exchange as a result of the
appreciation has increased the cost of exporting to Europe by
between £22 billion and £29 billion, yet the UK's economy
remains buoyant. This figure dwarfs the total £1.75 billion
yield of the CCL.
3.9 In addition, UK business has benefited from a number
of other tax cuts over the past year. For example, corporation
tax was reduced from 31p to 30p in the 1998 budget, the lowest
rate in the history of British corporation tax, as well as the
lowest rate of any major country in Europe, and the lowest rate
of any major industrialised country anywhere including Japan and
the United States. These additional tax cuts will compensate for
the introduction of the climate change levy.
3.10 However, WWF recognises that it is still possible
that some industries will face a higher tax burden, as a result
of the climate change levy, which could affect their economic
success, and for which special treatment may be required (see
para 4.10).
Carbon v Energy
4.1 WWF believes that a carbon tax provides both the
most efficient incentives and the simplest tax system design.
A tax that differentiates between fuels will give automatic incentives
for increased use of renewables and combined heat and power systems,
as well as increasing the use of low carbon fossil fuels.
4.2 If the Government wishes to preserve security of
supply through a diverse fuel mix this is best done through direct
regulation or subsidy to non-dominant fuels, not by distorting
environmental taxes. Using a carbon tax should not tend to lead
to increased use of nuclear power because new construction is
constrained by non-greenhouse gas pollution issues. Nor should
it lead to increased imports as the inter-connector to Europe
already operates at full capacity.
Which sectors should be covered by the Climate Change Levy
4.3 Whilst welcoming the introduction of a levy on the
business use of energy, WWF believes that some form of levy is
also needed in the domestic sector, as a tool for both reducing
energy use and relieving fuel poverty. With careful recycling
of revenues into energy efficiency and compensatory schemes for
low income households, it is possible to target fuel poverty more
effectively than through across-the-board low energy prices.
Energy Intensive Industries
4.4 WWF does not support the proposal that lower levy
rates be applied to those industries which voluntarily put in
place energy efficiency schemes.
4.5 As the Marshall Report made clear, dropping the marginal
rate of the tax is enefficient and will introduce undesirable
market distortions. In addition, and as shown above, the introduction
of a tax on the business use of energy should not have a major
impact on competitiveness thus making a reduction in the levy
unnecessary.
4.6 WWF believes that the recent fall in energy prices
has sent the wrong signal to industry and the levy will encourage
them to take steps to improve their energy efficiency. There is
plenty of evidence that this action can be taken cost effectively.
For example, a study by ETSU[18]
has found that in the energy intensive sectors of industry there
is the potential for energy savings of up to 10 per cent by 2020
through implementing all cost-effective measures available.
4.7 WWF has reservations about the process of negotiating
sectoral agreements. Whilst recognising that negotiating with
trade associations simplifies the process, WWF is concerned as
to the legal status of the trade associations and their ability
to negotiate on behalf of their members. In addition, it is unclear
what happens if an industry within a sector fails to meet its
efficiency target, ie, whether this would mean the whole sector
losing its levy reduction. WWF is also concerned that the big
players within the sector could unfairly force the smaller players
to do more.
4.8 Information from the DETR indicates that there is
currently much confusion in the negotiation process with little
evidence that an effective solution will be produced. This confusion
seems to stem from exactly who the final agreements are going
to be between—the negotiating body (Trade Associations)
or the individual firms—exactly what they are going to sign
up to and how the agreements are going to be verified.
4.9 WWF urgest the Government to conclude these negotiations
as soon as possible and publish the results so it can be clearly
seen who has signed up to do what. WWF would also like to see
a public review process of the "allocation of effort"
built into the levy legislation to ensure that all parties are
seen to be taking an equal share of the burden.
4.10 WWF believes that the levy rate should not be reduced
for energy intensive industries as it is unnecessary, inefficient
and the allocation process is fraught with difficulty. However,
we accept that in exceptional circumstances a problem of competitiveness
may remain. Where this is the case, competitiveness can be protected
by ring-fencing the levy revenues paid by the particular sector
and rebating the sum paid back to them on the basis of individual
firms' economic output. Each firm would then face the same marginal
incentive to save energy, but the sector as a whole would not
pay any more tax. In addition, it is WWF's view that rebating
the levy in this way will be administratively simpler than lowering
the levy rate.
Small and Medium sized Enterprises (SMEs)
4.11 According to Government figures[19],
there are 3.5 million small businesses in the UK (those with less
than 50 employees). This sector accounts for 99.2 per cent of
all businesses in the UK, more than 40 per cent of the private
sector workforce and around 40 per cent of UK turnover.
4.12 Unless there is adequate support for this sector,
for example in terms of energy efficiency advice, this sector
of UK business could be disadvantaged by the introduction of the
climate change levy. WWF believes that the SME sector is not fully
aware of the climate change levy or its implications and that
there is a need for a specific programme targeting the SME sector.
4.13 WWF welcomes the announcement by the Chancellor
that £50 million of the levy receipts will be allocated to
give support to smaller businesses. In view of the size of the
sector, and its importance to the overall economy of the UK, WWF
believes that the sums allocated to help this sector are insufficient.
WWF also believes that more targeted help is required to make
SMEs aware of the levy, its implications and some of the tools
available to offset the levy.
4.14 Specifically, WWF would like to see meaures taken
to ensure that SMEs are given adequate information about the levy.
This should include:
4.15 (i) Explaining that a levy is being introduced,
how it is to be implemented and the implications for business.
It should be made clear what the levy is for ie to reduce CO2
emissions as part of the UK's overall climate change programme.
The link needs to be made between energy use and CO2 emissions
to make businesses aware of the contribution they can make to
the UK's overall climate change targets, whilst saving money at
the same time.
4.16 (ii) Increased support and promotion of some
of the tools available to SMEs to enable them to reduce their
tax burden through reducing their energy use. These tools include:
4.17 (a) Generic packages such as "The Better
Business Pack"[20].
This is a tool developed by WWF and the NatWest Group in conjunction
with the SME sector. It contains information and advice on how
SMEs can increase their profits by reducing the environmental
impact of their operations. Real case studies are given outlining
results achieved by businesses who took relatively simple energy
efficiency. For example:
— A business fitting low energy light bulbs saved
13,500 kWh or £550 per year.
— A firm replaced old equipment with up to date
efficient models and saved 54,000 kWh or £2,000 per year.
4.18 (b) More specific tools such as the DETR/DTI
funded Environmental Technology Best Practice Programme and specifically
its "Energy and Environment Helpline." This provides
businesses with sector specific energy efficiency information
tailored to their particular business. They can supply various
publicatons outlining energy efficiency measures and put businesses
in touch with relevant consultants and local energy efficiency
offices and can also provide free energy audits of premises.
4.19 WWF sees no benefit in setting up another "energy
efficiency" agency and believes that the money raised from
the levy should be used to strengthen existing tools and agencies
such as the Energy Saving Trust.
4.20 WWF believes that to ensure SMEs are given an adequate
voice in the discussions about the climate change levy, an inter-departmental
SME task force should be created within Government. This should
include representatives from the DTI, DETR, Treasury and Customs
and Excise, with close contact with the Small Business Association.
The focus should be on utilising exisitng incentives to offset
the levy burden, tax breaks for efficiency investments and using
information schemes outside energy use to communicate the levy
message. The taskforce should also consider ways to ensure existing
schemes for encouraging SME investment result in energy efficiency
investment, including the £470 million of measures introduced
in the 1999 budget.
Renewables
4.21 WWF welcomes the intention to recycle part of the
revenues from the levy to give additional support to renewables
but does not believe that electricity from renewable sources should
be included in the levy.
4.22 If the levy is to contribute to the Government's
greenhouse gas reduction commitments it makes no sense to include
renewables in the proposals. They are already disadvantaged in
the current system where the external costs of electricity generation
are not fully accounted for. The levy would go some way to removing
this distoration in the electricity market, but only if renewable
technologies are exempted.
4.23 As an example, the following table shows the price
effect that exemption of the levy could have on wind energy, compared
to fossil fuel generation. It shows that large wind farms are
within the price range of gas and oil fired generation and that
the price of small wind developments becomes more competitive.
EFFECT OF THE CLIMATE CHANGE LEVY ON THE PRICE OF WIND
AND FOSSIL FUELLED GENERATION
|
| Technology | Pre-levy price (p/kWh)
| Levy (p/kWh) | Post-levy price (p/kWh)
|
|
| Large Scale Wind[21]
| 2.4-3.10 | 0
| 2.4-3.1 |
| Small Scale Wind | 3.4-4.60
| 0 | 3.4-4.6
|
| CCGT[22]
| 1.8-2.20 | 0.6
| 2.4-2.8 |
| New coal | 2.6-3.25
| 0.6 | 3.2-3.9
|
| Existing coal | 1.4-1.95
| 0.6 | 2.0-2.5
|
|
4.24 The figures in the table show that whilst exempting
renewables from the levy will help in making them more competitive,
the effect is marginal and additional mechanisms supporting renewable
technologies will be needed if the market is to expand. Additionally,
the figures indicate the effect that any future increase in the
levy will have. It is clear that increases in the price of non-renewable
energy, through an increase in the climate change levy for example,
will greatly improve the competitiveness of renewables if they
are exempted, and possibly make them the least cost means of providing
base load generation.
4.25 Many businesses are concerned about their corporate
environmental performance but a higher price for renewable electricity
is a disincentive for companies to switch to a green supplier.
Exempting renewable energy from the levy will provide an additional
incentive for businesses to sign up to a green supply.
4.26 WWF believes the introduction of the so-called "green
electricity" schemes provides a mechanism for identifying
and exempting electricity supplied from renewable sources. In
particular, WWF believes that the Future Energy scheme launched
by the Energy Saving Trust in July 1999 will provide a mechanism
for identifying and exempting renewable electricity supplies.
4.27 Allowing the electricity supplied by an accredited
green scheme to be exempt from the levy will have two benefits:
4.28 (i) It will provide a stimulus for businesses
to sign up to these schemes, thus increasing the demand for renewable
generation with a corresponding reduction in the need for fossil
fuel generation.
4.29 (ii) It will stimulate supply companies to sign
up to Future Energy, helping to ensure that the green energy market
develops in a way that is simple and easy to understand.
Community Heating Schemes
4.30 WWF believes that the benefits community heating
schemes provide in terms of efficiency should be reflected in
exemption from the levy. Not only can such schemes provide efficiency
benefits, they can also result in financial benefits to the users
of the heat (as the heat tends to be cheaper than other forms
of supply). Allowing community heating schemes to be exempt from
the levy would also provide an incentive for them to be developed.
5. CONCLUSIONS
5.1 WWF welcomes the Government's intention to introduce
a climate change levy on the business use of energy as a means
of reducing the use of fossil fuel sources of energy and meeting
the UK's commitments under the Kyoto protocol.
5.2 WWF has some concerns as to the design of the levy
but believes that overall UK business will gain from the introduction
of the levy and the corresponding cut in National Insurance Contributions.
Research carried out for WWF indicates that industries employing
93 per cent of the UK workforce and creating 90 per cent of GDP
will either gain directly from the package or will only face a
marginal increase in costs, and that overall the economic size
of the sectors that benefit from the package are more than double
the size of the industries that lose if size is expressed either
as number of employees or contribution to GDP.
5.3 WWF accepts however that a small, but important,
minority of companies will lose as a result of the levy and they
should be given special treatment to enable them to offset the
additional levy burden. But WWF does not believe that they should
be given reductions in the rate of the levy in return for negotiating
energy efficiency improvements as this is inefficient and the
negotiations are fraught with difficulty.
5.4 WWF belives that competitiveness can be protected
by ring-fencing the levy revenues paid by a particular sector
and rebating the sum paid back to them on the basis of individuals
firms' economic output. Each firm would then face the same marginal
incentive to save energy, but the sector as a whole would not
pay any more tax. In addition, it is WWF's view that rebating
the levy in this way would be administratively simpler than lowering
the levy rate.
5.5 The SME sector needs to be given adequate support
to ensure it is both aware of the levy and that adequate tools
are available to enable them to respond to the introduction of
the levy. In particular WWF believes that an inter-departmental
SME task force should be created within Government.
5.6 Renewables must be exempted from the levy. If the
aim of the levy is to contribute to the UK's greenhouse gas reduction
targets it makes no sense to include renewables in the proposals.
WWF believes that the Energy Saving Trust's Future Energy accreditation
scheme will provide a mechanism for exempting renewables from
the levy
5.7 Above all WWF urges the Government to take a strong
line on this issue, not bow to the pressure of a small, but vocal,
sector of industry and to ensure that the levy is introduced as
proposed and on time.
September 1999
12
See selection of papers on incentives for innovation and instrument
choice presented at the World Congress of Environmental and Resource
Economists, 25-27 June 1998, Venice, Italy. Abstracts available
at http:\\www.feem.it\\worldcongress. Back
13
Nick Mabey, Stephen Hall, Clare Smith and Sujata Gupta (1997),
Argument in the Greenhouse: The International Economics of
Global Warming, Routledge, London 1997. Back
14
ECOTEC (1999), Who Gains from the Climate Change Levy, WWF-UK. Back
15
WWF (1997) The Economics of Climate Change-Myths and Realities,
WWF-UK. Back
16
DTI (1998) The Energy Report, Transforming Markets, The
Stationery Office, London. Back
17
OXERA (1999) Workshop on The Energy Levy, May 1999.4.
DESIGN OF THE LEVY Back
18
ETSU (1997) Industrial Sector Carbon Dioxide Emissions, Harwell. Back
19
DTI (1997) Small and Medium Enterprise (SME) Statistics for
the UK, Statistical Press Release. Back
20
WWF/NatWest (1997), The Better Business Pack, WWF/NatWest
Joint Initiative 1997. Back
21
Figures from the latest NFFO round (NFFO 5). Back
22
Figures taken from Government White Paper-Conclusions of the
Review of Energy Sources for Power Generation, DTI 1998. Back
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