Memorandum submitted by the NSCA (National
Society for Clean Air and Environmental Protection)
1. SUMMARY OF
MAIN POINTS
1.1 NSCA supports most of the recommendations
in Sir Nicholas Stern's review of the economics of climate change
and believes that the long term measures set out in the Pre-Budget
Report put the UK on the right course to implementing the report.
We do however have concerns regarding the shorter term tax and
duty measures, in particular we think that the changes in road
fuel and air passenger duty are unlikely to have much of an effect
on demand.
1.2 NSCA believes climate change is a major
global problem and strongly supports work to reduce carbon emissions,
however we want to ensure that other environmental issues such
as air quality and noise are not downgraded by a focus on cutting
carbon emissions.
2. ABOUT NSCA
2.1 NSCA (National Society for Clean Air
and Environmental Protection) is the environmental protection
charity supported by pollution control professionals. We are working
towards better management and reduction of environmental problems
through policy development and education. We have regional divisions
throughout the UK, a head office in Brighton, East Sussex and
an office in Scotland.
3. TRANSLATING
THE STERN
REVIEW INTO
TREASURY POLICY
3.1 Clearly the key to implementation of
the Stern Review is the establishment of a global price for carbon.
In this regard NSCA supports the actions laid out within the pre-budget
report, but cautions that appropriate actions must be taken to
ensure that the carbon market does not stimulate technologies
that produce local air quality problems, for example biomass generation
with poor emissions control. This is a particular threat in some
developing countries that have weak controls on local air quality.
3.2 NSCA believes climate change is a major
global problem and strongly supports work to reduce carbon emissions.
We do, however, want to ensure that "traditional" environmental
issues such as air quality and noise do not get downgraded and
that measures to cut carbon emissions have a positive rather than
negative effect on local air quality.
4. THE TAX
AND INCENTIVE
REGIME FOR
BIOFUELS
4.1 NSCA believe that significant incentives
would have to be provided for large numbers of motorists to buy
a car, or convert an existing one, capable of running on high
percentage biofuel blends. For this reason we believe the Renewable
Transport Fuel Obligation is the key mechanism for increasing
take up of road biofuels as the existing 20 pence per litre is
unlikely to act as a sufficient incentive in low percentage blends.
4.2 A key stumbling block here is developing
fuel standards for biofuel blends higher than 5% and ensuring
manufactures warranty their engines for these fuels. We therefore
commend the Government's existing actions in this area and urge
them to push forward on this front whilst ensuring:
— that biofuels achieve appropriate
standards of carbon reductions and sustainability; and
— that appropriate research is
undertaken to ensure that using high percentage biofuel blends
will not increase tailpipe emissions.
5. TAXATION OF
AVIATION, INCLUDING
ITS VAT-STATUS
5.1 NSCA are concerned about the potential
impact of the apparent predict and provide approach that is currently
being taken with air travel. Whilst we commend the Government's
policies to bring airlines into the EU Emissions Trading Scheme
we want to ensure that the other negative environmental effects
of air travel are also addressed, principally noise and local
air pollution. Whilst progressively improving technology will
have an effect here the predicted growth in air travel is likely
to heavily impact technology's ability to mitigate these environmental
problems.
5.2 Whilst inclusion of air travel within
the EU ETS will effectively raise ticket prices, and therefore
reduce demand, we do not believe that the scale of the likely
price increases will have a large effect on demand. This is particularly
the case on short haul flights where carbon emissions for the
journey are lower than long haul, yet noise and local air pollution
in the airport zones similar. We therefore support the fixed charge
represented by Air Passenger Duty, but believe it should be progressively
raised to have a greater effect on demand.
6. SUPPORT FOR
CARBON CAPTURE
AND STORAGE
6.1 As the Stern Review suggests, carbon
capture and storage is an important technology for reducing carbon
emissions, and we strongly urge the Government to go ahead with
support for a trial plant. Stern confirms that research and development
spending in the power industry is comparatively low, and it will
take support for both demonstration and early implementation phases
for the industry to adopt this technology. As power generation
is a major emitter of local air pollution we also urge that the
technology chosen for the demonstration plant will also deliver
reduced emissions of local air pollutants when compared to conventional
plant.
7. SUPPORT FOR
MICRO GENERATION
7.1 Whilst the Government's reduced VAT
rates and Low Carbon Buildings Programmes are commendable we feel
more could be done to encourage adoption of micro generation in
the domestic market. In particular micro CHP shows particular
promise in reducing CO2 and local pollutant emissions due to its
ability to replace an existing gas boiler installation, rather
than be added as an extra item, and its suitability for up to
18 million homes in the UK. A grants programme to encourage early
uptake could bolster the effect of the current lowered rate of
VAT that micro CHP unit currently enjoy.
8. ROAD FUEL
GASES AND
SULPHUR FREE
FUELS
8.1 Whilst NSCA understands the reasons
for reducing the duty differential on CNG and LPG road fuel gases
we do have some concerns that the public memory of the erosion
of support for these fuels may hamper the uptake of alternative
fuels in the future. For example, fuel suppliers, service station
owners and vehicle purchasers may be unwilling to invest in infrastructure
and vehicles if they do not believe the Government will provide
long-term support to allow them to recoup their investments.
8.2 NSCA believes that transport biogas
could contribute significantly to solving waste management problems
and providing renewable energy to the UK transport fleet, as supported
by our recent study "Biogas as a Road Transport Fuel, an
assessment of the role of biogas as a road transport fuel".
We therefore urge the Government to keep the existing duty differential
during Budget 2007.
8.3 NSCA commends the Government's decision
to introduce regulation to speed the introduction of sulphur-free
road fuels in the UK. This is an important enabling technology
that will have a positive effect on air quality.
January 2007
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