Letter to HM Treasury
THE GREEN TECHNOLOGY CHALLENGE AND UNITED
KINGDOM GOVERNMENTS FISCAL POLICIES
In your Consultation Document published in July
you listed six Environmental Objectives—viz Climate Change,
Air Quality, Water Quality, Waste, Land use and Toxicity—and
we would fully endorse the importance and value of those objectives.
We would wish to add Sustainability, since in a world of finite
resources it must surely be beholden on each of us to minimise
the use we make of the materials and energy that we use, and after
use, to recover as much as possible of these resources from the
waste stream.
Specifically you refer to the desirable reductions
in greenhouse gas emissions and air pollution emissions from transport—to
which we would wish to add a desirable reduction in overall road
congestion from the minimising of road haulage journeys.
You then rightly target a reduction in water
consumption and in waste water production. Equally, you cite the
need to reduce the volume of waste produced, to reduce the volume
of waste sent for disposal, reduced hazardousness of waste sent
to landfill and the reduced potential for contamination of land.
Since we find ourselves in total agreement,
you may perhaps understand our frustration and incredulity that
Treasury policy so heavily penalises the one material which meets
all these criteria—plastics!
Not only do maintenance-free plastic components
confer so much towards light weighting all our road and rail vehicles,
they play a vital part in every walk of life, from our homes,
schools and offices through to our hospitals, building construction
and agriculture. Plastics also constitute a major component of
packaging and perhaps today more than two thirds of everything
we buy retail is at some stage packaged in plastic films.
Yet almost all these conversion processes are
essentially pollution free, they use little water and the materials
are non-hazardous and will not contaminate the land.
However, when the application of the Climate
Change Levy was announced, it was also made possible for sections
of industry to enter into agreement with DEFRA whereby they might
secure a CCL rebate of up to 80 per cent as part of a negotiated
energy reduction programme. The criteria for such negotiated agreements
required that the manufacturing sites in that specific industry
sector were registered under the IPPC regime, ie, they were to
be the most heavily polluting processes.
So we find, in the particular example I quoted
of packaging, that the competing materials sectors,—glass,
metal, and paper—are all supported by CCL rebate arrangements,
but the one material that can bring about the environmental benefits
we all seek, does not qualify and must therefore be penalised.
How can an anti-competitive measure of this
type possibly conform with Treasury policy on the environment?
A CCL rebate does of course fall under the EU
classification of State Aid to Industry and under the original
EU Guidelines it was clearly stated that State Aid should not
be used to "conceal the true costs of pollution". I
suggest therefore that not only is the criteria for a negotiated
rebate anti-competitive but it is also contrary to the letter
and spirit of these EU Guidelines.
Your comments would be much appreciated.
J R Pugh
Chief Executive
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