134. The IEEP comments that Table 6.2 is accompanied
by very little discussion, or presentation of the underlying assumptions
or methodologies used in reaching the estimates set out in marked
contrast to the economic aspects of the budget.
We would agree with this while pointing out that for just over
half of the measures cited no estimates are in fact given. As
we mention above evidence from The Green Alliance "hoped"
that the lack of quantitative assessments given of the environmental
implications of proposals did not reflect the manner in which
the policies were developed.
Reference is made in the PBR (at para 6.101) to supporting analysis
but in very general terms.
135. Information is presented in quite a confusing
manner in Table 6.2. As we have noted above, the policy change
actually announced in this PBR on ultra low sulphur diesel for
example, is in fact a significant cut in duty. The Table fails
to set out the likely effect of this reduced duty (ie a rise in
consumption) but seems to pitch its analysis at the overall reduction
in NOx and particulates resulting from the existing differential
between ULSD and standard diesel (a done deal surely, now that
ULSD has captured 100 per cent of the diesel market).
136. A similar approach is again employed with regard
to road fuel duty overall despite previous criticism from this
The policy announced in this PBR is a freeze on petrol duties
in cash terms resulting in a 1.5p cut per litre. As in 1999, when
decisions on fuel duty were put on a budget-by-budget basis, the
analysis in the Table sets out the effect of the fuel duty escalator
between 1996 and 1999 rather than the impact of what the Financial
Secretary eventually agreed was a substantial change in policy
(leading to expected carbon dioxide emission reductions from the
FDE up to 2010 being halved). PBR 2000 is not alone in downplaying
the impact of shelving the FDE. We were disappointed that the
Government's annual report on the Sustainable Development Strategy
produced in January 2001 did not discuss, or even report, the
change of policy despite the fact that the original strategy referred
to the FDE, increased to 6%, as a key measure in tackling climate
change and air quality.
137. The Environment Agency and the RSPB both pointed
to the focus of Table 6.2 on specifically environmental measures.
Treasury has stated consistently that all budget measures are
appraised for their environmental impacts but we are intrigued
by the lack of non-environmental measures in the Table since the
first example in 1998. In PBR 2000, the only such entry is for
the reduced rate of VAT on domestic fuel and power (it is also
the only entry assessed to have a negative impact). Curiously
this policy change was introduced in 1997 and its inclusion, in
this part of a budget or pre-budget report for the first time,
was described by the RSPB as 'rather spurious'.
138. When we discussed the 2000 reduction in air
passenger duty with the Financial Secretary in 1999 he told us
"we have aimed to provide quantified estimates where it is
possible to do so...we do not think that the change in air passenger
duty is going to make a very significant quantifiable difference
to feature in the figures on this table...everything, where we
can quantify the impact sensibly, is in the tableso, by
default, the measures that are not, we do not think we can sensibly
put figures on".
We would again point to the nine measures that do appear in the
table but which have no quantified impact, sensible or otherwise.
The Treasury's environmental appraisal of its budget measures
appears to be little more than a summary list of the impacts of
its environmental measureseven at that there are some significant
139. The Treasury should improve the presentation
of its environmental appraisals as set out below:
a clear protocol for when and how decisions are included and assessed
to avoid accusations of data manipulation;
drawing clear distinctions between
the overall impact of policy measures and the effects of changes
made to the detail (ie where benefits remain but have been reduced);
setting out full and clear references
to supporting data and analyses; and
distinguishing between measures in
terms of the stage of policy development that they have reached
(consultation, announcement or implementation).
140. As we have previously noted, the Government
included in its observations on our Report on the 1999 Budget,
a commitment "to publish an ex post evaluation of its existing
environmental tax measures on an annual basis, to complement the
appraisal data for proposed new or amended measures which are
already included in the Budget".
We have seen no evidence of any action on this commitment and
we recommend that the Treasury's list of green budget measures
start to include information on what has been achieved (outturn
against estimate) for those measures that have been implemented.
At the very least reference should be made to where such data
141. The Treasury should demonstrate, perhaps
initially as a one-off exercise for the next Pre-Budget Report,
how it appraised the environmental implications of all
its proposals. This would increase the confidence of outside observers,
including Parliament, in this process.