APPENDIX 8
Memorandum submitted by The Royal Society
for the Protection of Birds
The RSPB works for the conservation of wild
birds and their environment. We are Europe's largest wildlife
conservation charity with over one million members. The RSPB was
involved in the HM Treasury's consultations during 2002 that developed
the "Tax and Environment" document.
SUMMARY
1. The publication of the Government's Pre-Budget
Report (PBR) 2004 and the outcome of the 2004 Spending Review
(SR04) outline the Government plans to address and resource its
environmental priorities. In summary, the RSPB believes that:
— Public Service Agreement targets
for farmland birds and Sites of Special Scientific Interest have
helped to improve delivery.
— The new PSA target for international
biodiversity and the allocation of joint responsibility to the
Department for Transport for reducing carbon emissions are welcome.
— SR04 was a missed opportunity to
identify new PSA targets to improve protection of the marine environment
and tackle diffuse pollution.
— The next Government should build
on the existing green taxes, by delivering more rapid environmental
tax reform.
— The Treasury should support the implementation
of a sustainable development duty for all government departments
and public bodies, linked to the delivery of the emerging UK Sustainable
Development framework.
— Biodiversity should be considered
an integral part of Regulatory Impact Assessments.
PBR 2004 AND SR 2004
2. The RSPB has welcomed the introduction
of Public Service Agreement (PSA) targets to focus departmental
resources on implementing key priorities. PSAs have, for example,
helped to increase the proportion of Sites of Special Scientific
Interest (SSSIs) in favourable condition and to begin the process
of reversing the decline of farmland birds. The PSA targets on
farmland birds and SSSIs respectively represent the health of
our countryside and best natural heritage sites, and must be retained
as crucial targets for delivery.
3. The new PSA targets in the 2004 spending
review (SR04) are very welcome, particularly the Defra target
on international biodiversity and the inclusion of the Department
for Transport in the target on carbon emissions. However, the
lack of targets on the marine environment, and water quality and
resources, mean the coverage of key environmental priorities is
not complete.
4. The RSPB is concerned that environmental
priorities such as tackling diffuse water pollution and providing
marine protection remain short of resources and policy action.
Marine protection requires an appropriate legal framework to be
put in place, but funding is also required, for example for data
collection and analysis to enable the identification of Marine
Protected Areas.
5. On international biodiversity, it is
unlikely that the 2010 target to halt the loss of biodiversity
will be achieved unless much more funding is transferred from
developed to developing countries, a commitment clearly made in
Johannesburg in 2002. Although it is quite clear globally that
current funding is inadequate in relation to the scale of the
problems of species and habitat loss, accurate assessments of
current UK funding are not available and are extremely difficult
to calculate from the data available.
6. The RSPB acknowledges that keeping track
of international biodiversity expenditure is difficult because
of its complex nature and the way in which aid is channelled through
national or sector level programmes. There is no dedicated UK
budget line for international conservation other than the Darwin
Initiative, which is extremely important but relatively small.
To overcome this problem, we believe the Government must endeavour
to structure their accounting practices, or introduce subsidiary
reporting methods, to explicitly keep track of what they spend
on international biodiversity (as opposed to general "environmental
projects"). Doing so is essential for assessing the effectiveness
of our contribution to redressing global biodiversity loss.
THE TREASURY'S
OVERALL FISCAL
STRATEGY
7. The RSPB has advocated that taxes should
be used to address environmental externalities. For example, we
argued for a carefully designed pesticides tax before the introduction
of the voluntary agreement in 2001, and supported the introduction
of the climate change levy and landfill tax. We also support the
concept of environmental tax reform; increasing taxes on things
that damage the environment, and reducing tax on good things such
as employment.
8. The RSPB was encouraged by the positive
language in the 2004 PBR on biodiversity targets in the voluntary
initiative on pesticides, the effectiveness of the climate change
levy, and the future of the landfill tax credit scheme. However,
the RSPB is concerned at the lack of overall progress on environmental
tax reform.
9. As we approach the end of this Government's
second term, we consider the landfill tax, in particular the use
of a pre-announced tax escalator, to be a positive step. However,
in proportion to the current measured and predicted rates of environmental
damage, we consider the level of progress on environmental tax
reform inadequately slow. In order to contribute to sustainable
development, the Government's environmental tax strategy must
shift a greater proportion of the burden of taxation to environmentally
damaging goods and services. Following an anticipated 2005 general
election, the RSPB would hope and expect to see the shift in environmental
taxation occurring far and fast enough to affect actual practice.
10. We do not believe the Treasury has developed
an adequate strategy to implement its environmental PSA objectives.
An adequate strategy would assist other government departments'
environmental PSA targets. It would help tackle severe environmental
issues, especially when the benefits of doing so are clear, but
monetary values are not fully understood; for example, by supporting
a higher value for the social cost of carbon, and the greater
use of economic instruments to reduce emissions of greenhouse
gases.
11. The Treasury's fiscal strategy for the
environment could be improved by better links to the work of the
Sustainable Development taskforce. The Treasury should use appropriate
economic instruments (and allocate adequate funds), to support
implementation of a sustainable development duty for all government
departments and public bodies, linked to the delivery of the UK
Sustainable Development framework. The Treasury should support
work to "get the prices right" to incentivise sustainable
development.
ENVIRONMENTAL APPRAISALS
AND REGULATORY
IMPACT ASSESSMENTS
12. The RSPB recognise the need to balance
environmental issues against economic and social impacts. We support
the use of integrated methods of policy appraisal, provided that:
(i) environmental issues are adequately
covered;
(ii) the environment is considered at an
early stage of policy development; and
(iii) environmental requirements such as
environmental impact assessments and strategic environmental assessment
are fulfilled.
13. We are concerned that Regulatory Impact
Assessments (RIAs) are not adequate as a vehicle for capturing
all environmental costs and benefits. The reliance on monetary
values under represents the benefits and costs of protecting the
environment, being dependant on economic valuations capturing
the severity of the environmental change in question. Such valuations
are inevitably uncertain, controversial and partial. The RSPB
is concerned that regulatory impact assessment may not further
sustainable development, because it can overlook or underestimate
the value of protecting or enhancing biodiversity for society
and, especially, future generations.
14. Biodiversity is a key test of sustainable
development, and the need to include it in appraisal tools like
regulatory impact assessment has been highlighted in Defra's England
Biodiversity Strategy. The Strategy has provided Defra's Better
Regulation Unit with initial guidance on incorporating biodiversity
into Regulatory Impact Assessments. The Treasury and the Regulatory
Impact Unit should support this initiative.
15. The appraisal of individual policy measures
in the PBR could be improved by collectively relating them to
the policy issue they are trying to tackle. For example, instead
of separate appraisals of transport fuel taxation and the climate
change levy, budgets and PBRs could give an appraisal of the overall
effects of multiple policies on greenhouse gas emissions. This
could combine all the policy measures announced, and forecast
rates of growth (and therefore emissions) in the economy, to assess
their contribution to the Governments Climate Change Strategy.
20 January 2005
| 
