House of Commons - Budget 2011 and environmental taxes

Budget 2011 and environmental taxes - Environmental Audit Committee Contents

2 Principles of environmental taxation

4. Taxation has an important role to play in helping to protect the environment by helping to incorporate the costs of environmental damage into the price of the goods, services or activities which give rise to it. Often, the side-effects of production and consumption that impact on the environment ('environmental externalities') do not enter into the calculations of producers and consumers. By levying a tax on the activity giving rise to such externalities, those costs can be 'internalised', creating an incentive to shift away from environmentally damaging behaviour.[6]

Increasing the proportion of environmental taxes

5. In 2009, the Green Fiscal Commission[7] advocated a shift to environmental taxation— reducing taxes on the things that are valued by society (jobs, incomes and profits) and funding the lost revenue by taxes on things that damage society (pollution and environmental damage). The Commission found that such an environmental tax shift could help the UK meet its 2020 climate change targets with practically no cost to the economy overall and with an increase in employment.[8] Ben Shaw from the Policy Studies Institute, which has continued the Commission's research programme, told us that for environmental taxes to help deliver those climate change targets "how aggressive the policy can be is the issue and I think it is the politics, rather than the theory of the policy, that is going to determine whether we meet the targets".[9]

6. The Commission identified two main 'political' obstacles to a significant environmental tax shift—its perceived effects on, first, the international competitiveness of some vulnerable business sectors (energy intensive industries) and, second, on poorer households who pay proportionally the greatest percentage of their income on energy.[10]

7. The current Government has adopted the previous Government's commitment to increase the proportion of tax revenue accounted for by environmental taxes.[11] The UK Environmental Accounts[12] indicate that environmental taxation, as a proportion of all taxation and of Gross Domestic Product, peaked at 9.7% and 3.4% respectively in 1999. Then, until 2009, the proportions generally fell, reflecting the increasing tax revenue from income and profits before the global recession hit (Figure 1).

8. The Treasury has not set out a strategy for how it will increase the proportion of environmental taxes except to tell us that revenues from the new Carbon Floor Price, Carbon Reduction Commitment and receipts from auctioning of EU Emissions Trading System allowances will primarily deliver the increase.[13] These taxes were forecast to raise £1.7 billion in 2011-12, rising to £5.3 billion in 2015-16.[14] The Economic Secretary told us that she intends to look at the direction of travel rather than set a precise target for increasing the proportion of environmental taxation.[15] However, some of our witnesses told us that the Treasury should be more ambitious and aim to collect a significant, specific, proportion of tax revenues—perhaps between 10% and 20%—from environmental taxes, which would show the Treasury's intention.[16] We recognise that any target percentage would be an imperfect measure of the success of the Government's environmental policies. High environmental tax revenues could result either from high rates of tax or from high levels of taxable environmental harm.[17]As Andrew Leicester from the Institute for Fiscal Studies told us:

I am not convinced that the share of revenues that you raise from environmental taxes is a good indicator of anything very much, partly because it depends on how much revenue you are collecting from anything else. I think there was a huge jump in that indicator during the period of the recession because non-environmental revenues collapsed massively.[18]

EDF energy also cautioned against relying on an arbitrary percentage as a measure of success.[19]

Definition of environmental taxes

9. Clearly identifying any progress in increasing the proportion of environmental taxes will be difficult because there is no single definition of an environmental tax. The Treasury told us that it was conducting a review of its principles of environmental taxation and will set a new definition of environmental taxes once this work is complete.[20] That work, they indicated, suggests a narrow definition based on the primary intention behind the introduction of a particular tax, whereas the long-standing Office for National Statistics (ONS) definition looks more to the effect of a particular tax.[21] The Treasury listed six taxes which it regards as environmental taxes—Climate Change Levy, Aggregates Levy, Landfill Tax, EU Emissions Trading System, Carbon Reduction Commitment and the Carbon Floor Price.[22] As the Chartered Institute of Taxation explained, however, the ONS's 2010 Environmental Accounts also included Fuel Duty, VAT on Fuel Duty, Renewable Energy Obligation, Vehicle Excise Duty and Air Passenger Duty in its definition (and confusingly Air Passenger Duty appeared under an 'environmental tax' heading in the 'budget policy decisions' table in this year's Budget Report).[23]

10. The Treasury's treatment of motoring taxes and Air Passenger Duty differed from the ONS's. The Treasury did not consider these to be environmental taxes as they were not primarily structured to change environmental behaviour (Figure 2).[24] We recommend that the Treasury should set out its detailed plans for increasing the proportion of environmental taxes as part of an environmental tax strategy (paragraph 80), along with how these taxes are defined. We favour the Office for National Statistics' definition, which considers the effects of a particular tax, because the most important characteristic of an environmental tax is that it promotes more sustainable and less environmentally damaging behaviours regardless of why it was introduced.
Figure 2: Comparison of environmental tax definitions

Office for National Statistics[25] HM Treasury[26]

Definition An environmental tax is defined as a tax whose base is a physical unit such as a litre of petrol, or a proxy for it, for instance a passenger flight, that has a proven specific negative impact on the environment. By convention, in addition to pollution related taxes, all energy and transport taxes are classified as environmental taxes. The Government is developing a workable definition of an environmental tax that will be based on the following broad principles:

The tax is explicitly linked to the Government's environmental objectives; and
The primary objective of the tax is to encourage environmentally positive behaviour change; and
The tax is structured in relation to environmental objectives, for example: the more polluting the behaviour, the greater the tax levied.

Taxes which meet that environmental taxes definition Landfill Tax
Aggregates Levy
Climate Change Levy
EU Emissions Trading System
Fuel Duty
VAT on Fuel Duty
Vehicle Excise Duty
Air Passenger Duty
Renewable Energy Obligations
Landfill Tax
Aggregates Levy
Climate Change Levy
EU Emissions Trading System

Carbon Reduction Commitment
Carbon Floor Price

11. At present the Office for National Statistics publishes, as part of the Environmental Accounts, statistics on the proportion of revenues collected by environmental taxes (using its definition).[27] Budget 2011 announced changes which will reduce forecast revenues to be collected by motoring taxes and Air Passenger Duty. On both the ONS's definition and the Treasury's, we calculated that environmental taxes as a proportion of all taxes will rise over the period up to 2013-14 before levelling out (Figure 3). The forecast proportion of environmental taxes increases over the life of this Parliament, under both the Treasury's and ONS's definitions. By excluding Fuel Duty and Air Passenger Duty from the Treasury's new definition of environmental taxes, however, there will be no incentive to increase them as part of the Government's commitment to increase the proportion of environmental taxes.

12. It will also make less transparent the Government's progress in increasing the proportion of environmental taxes. The Treasury should therefore publish statistics (including in its Annual Report) on the proportion of environmental tax under both definitions. Figure 3: Projected trend for the proportion of revenue raised from environmental taxes, based on Budget 2011 forecasts of the relevant taxes

Setting the tax rate—raising revenue or promoting environmental change

13. As well as raising revenues, environmental taxes are also intended to promote more environmentally friendly behaviours, typically by ensuring that at least some of the cost of damaging behaviour is borne by those responsible.[28] According to the Chartered Institute of Taxation, environmental taxes can be split into three broad categories which influences the rate at which the tax is levied:

a) Cost covering charges—aiming to ensure that those making use of the environment contribute to, or cover, the cost of monitoring or controlling that use.

b) Incentive taxes—aiming to change environmentally damaging behaviours, though not to raise revenues.

c) Revenue raising taxes—taxes intended to change behaviours while also generating substantial revenues.[29]

14. The Government has not been clear about the basis for how it has set environmental tax rates; whether to cover environmental costs, to change behaviours or to raise revenues.[30] This may be in part because calculating the cost of environmental externalities associated with an activity is complex and there is no agreed methodology for deciding which costs to include. On aviation, the International Air Transport Association was of the opinion that aviation is over-taxed, estimating that Air Passenger Duty produces enough revenue for the Government to cover the carbon cost of the UK's flights four times over.[31] TUI said that aviation pays its external environmental costs, yet pays in full for its own infrastructure, unlike subsidies for rail and surface transport.[32] Others, on the other hand, considered that aviation does not pay fully for its environmental costs. As Chris Hewett from Green Alliance told us:

... in comparison to other transport modes, aviation is under-taxed. It is exempt from VAT. It is exempt from Fuel Duty. You pay roughly three times as much tax if you drive a car to Edinburgh than if you fly to Edinburgh.[33]

15. On Fuel Duty, PricewaterhouseCoopers estimated that the implicit carbon price was £247 per tonne of carbon compared to the EU ETS where the carbon price was only €17.[34] And the Taxpayers' Alliance were of the view that motorists are taxed excessively (estimating this amounted to £18 billion in 2008-09) because of, for example, the benefits of supporting a broad network of amenities and enabling economic activity to be more geographically dispersed. Its modelling therefore only took into account a narrow view of the costs—only those associated with maintaining or building additional roads and the cost of carbon emissions.[35] Matthew Sinclair told us that:

The tax charged now is so far beyond the Pigovian rate,it is why every time you challenge the Treasury on this the response you get isn't, 'We disagree with your analysis' but 'Well, we are using this to raise revenue'. That is the reason why no one trusts green taxes and it is the reason why, in the end, this is seen as an attempt to take money from motorists and it isn't functioning effectively as a green tax, and people need to stop trying to sell it as one or they will discredit other green taxes, rightly.[36]

The Campaign for Better Transport, on the other hand, were of the opinion that the revenue raised from road transport taxes did not outweigh the costs involved, including the costs from delays, accidents, poor air quality, physical inactivity and noise.[37]

16. There is an argument that sometimes a focus only on identifying environmental costs is misplaced. Andrew Leicester from the Institute for Fiscal Studies highlighted the importance of setting some tax rates to meet specific environmental (e.g. emissions reduction) targets.[38] And Ben Shaw from the Policy Studies Institute noted that to say that environmental taxes should be about covering externalities is "the wrong approach" because they also serve to raise revenue and "create a very clear behaviour signal".[39]

17. The Chartered Institute of Taxation was of the opinion that Government needs to be clear for each tax whether the environmental objective or the revenue-raising objective is paramount, in order to measure its success—an environmental tax that raised no money at all could be a success simply because it had driven out the behaviour it was targeting.[40] The Institute of Directors felt that the onus must be on Government to demonstrate the cost of the environmental externalities when setting the rate of environmental taxes.[41] The Treasury told us that badly designed taxes can do more harm than good, reducing economic output and harming the UK's long-term growth prospects.[42]

18. Even when the aim of an environmental tax is not focused on revenue raising, an appropriate tax rate alone will often not be enough to change behaviour. There is a role for other policy instruments to achieve the desired change.[43] As the Campaign for Better Transport noted, environmental taxation must be part of a larger package of measures for achieving environmental goals and targets.[44] Chris Hewett from Green Alliance cited the Landfill Levy as an example of an environmental tax that has been relatively successful because of a strategic package of complementary regulations, investments and incentives for waste reduction and recycling.[45] It is not clear, however, how the Government determines the most effective package of interventions (tax, regulations, guidance, spending) to affect the required behavioural change. The Association of Chartered Certified Accountants found that there was often little cost-benefit analysis to support the use of tax over other possible measures.[46] Feeding into the choice of whether an environmental tax is preferable to affect the required behavioural change, with or without complementary regulations and incentives to support it, should be a thorough assessment of the environmental impacts of the various possible interventions so that the most effective is selected. As the custodians of the 'Green Book' methodology for investment appraisal across Government, the Treasury should be in an ideal position to utilise such a comprehensive approach. In justifying tax changes in each Budget, the Treasury should explain how it has assessed the environmental impacts of the various possible interventions to arrive at their optimal mix.

19. Rather than introducing new environmental taxes, existing taxes can also be flexed to provide incentives for environmental friendly behaviour.[47]The Chartered Institute of Taxation suggested that this approach would minimise the burden placed on taxpayers, and in particular small businesses, given the existing complexity in the tax system.[48] Such an approach could also be used to complement Government policies that would otherwise be supported outside the tax system. Tax incentives could be used, for example, to improve the take up of the Green Deal. As Friends of the Earth suggested, to encourage people to take up the Green Deal:

...incentives will be hugely important —both carrots (financial incentives) and sticks (legislation for future minimum standards on energy efficiency). Financial incentives could take the form of a council tax rebate or money off stamp duty and would make a significant difference to the attractiveness of the Green Deal to consumers.[49]

We recommend that the Government consider providing tax incentives, such as a council tax rebate or stamp duty discount, in next year's Budget to support the take up of the Green Deal.

Complexity and fairness

20. To be effective, environmental taxes need to be straightforward so that taxpayers understand the behavioural change signal being sent, and seen as fair so that political momentum can be gained for higher environmental taxation.

21. The UK has a complex mix of environmental taxes and price signals, particularly for energy. For example, there are now four carbon 'tax points' in the electricity supply chain[50] and there are a multitude of different effective tax rates on carbon emissions that vary between different users of energy and between different fuels.[51] The Mirrlees Review of the tax system concluded that there is a long way to go to achieve a consistent price for carbon and that the range of policies and emissions sources is so complex that it is hard to say what the effective carbon prices are.[52] Several of our witnesses were concerned that the Carbon Floor Price announced in the Budget would add to this complexity, calling for a rationalisation of existing climate change tax policies to improve their effectiveness.[53] As PwC put it:

Taxpayers need to be able to understand what the environmental tax seeks to achieve, how it is levied, how much it costs and what behaviour is needed to avoid paying it...The private sector is frustrated in their attempts to understand the carbon prices currently applying...[54]

22. The present complex mix of environmental taxes and price signals undermines the effectiveness of both in securing beneficial behavioural changes. Businesses cannot be expected to change their behaviours and investment decisions if they are unaware of the cumulative impact of the environmental taxes affecting them. Consumers do not know exactly how much they are paying through their fuel bills to fund the various environmental taxes and policies.[55] The Budget amended existing environmental taxes (and introduced a new one—the Carbon Floor Price), but did not address this growing issue of complexity.

23. Environmental taxes can penalise those responsible for harming the environment and therefore have the potential to be popular, but in practice they are not. The Chartered Institute of Taxation attributed this in part to many people perceiving environmental taxes as just another means of raising revenue.[56] In advocating a shift towards environmental taxation, the Green Fiscal Commission envisaged such tax increases being offset by reductions elsewhere. Andrew Raingold from the Aldersgate Group told us, however, that the Budget was a missed opportunity in that regard because the £10 billion raised by increasing the supplementary charge on North Sea oil and gas production should have been used to reduce taxes on income rather than to pay for a decrease in Fuel Duty.[57] The EEF, a trade body for manufacturers, told us that the proposed Carbon Floor Price will inefficiently duplicate existing carbon taxes.[58] The Mineral Products Association complained that the Budget increased environmental taxation without an equivalent reduction in non-environmental taxation. Matthew Sinclair of the Taxpayers' Alliance, citing the example of Vehicle Excise Tax, told us that people no longer trusted Government to implement environmental taxes in a revenue-neutral way.[59]

24. Environmental taxes are also seen as regressive as they are not clearly related to the ability to pay. A high fraction of low-income household budgets is spent on electricity, heating fuel, and transportation, but the gains from environmental protection may accrue to higher income households who have the most 'willingness to pay' for that protection.[60] In 2008, 18% of households were classified as being in 'fuel poverty'.[61] Ben Shaw from the Policy Studies Institute suggested that improving information about environmental taxes, including why they are introduced, would increase trust and support for them.[62] Andrew Leicester from the Institute for Fiscal Studies suggested that the Government should be more upfront and label a tax a 'tax' rather than "calling it 'a levy' or 'a support rate' or whatever name you want to call it apart from the 'T' word".[63] To tackle the growing complexity of environmental taxes and to build greater trust in their purpose, a coherent and clearly articulated approach is needed towards environmental taxes and broader environmental policy. A clear environmental tax strategy, as we discuss below, should be a key component of this (paragraph 80).

25. Hypothecating revenues—earmarking them for a specific propose—would be likely to increase support for environmental taxes. Research by the Green Fiscal Commission found that while 51% of people supported environmental taxes, this rose to 73% if revenue raised by them were hypothecated for reducing emissions.[64] The Campaign for Better Transport argued that Government should, in particular areas such as motoring, spend at least as much as it collected in taxes.[65] The previous Government told our predecessor Committee that spending was not determined by the way in which the money is raised, and that hypothecating revenues to particular spending programmes would impart inflexibility in spending decisions and lead to a misallocation of resources.[66] We questioned the Economic Secretary on the current Government's view. She told us that she does not see a role for greater hypothecation, but wanted a "more thoughtful and genuine approach" that changes behaviours.[67]

26. Andrew Leicester, from the Institute for Fiscal Studies, argued that tax and spend decisions should be driven by the overall effectiveness of taxation and expenditure programmes rather than by hypothecation, and that the only merit of hypothecation was in terms of "a kind of public acceptability role ... of trying to ensure that people believe that environmental taxes are not just there to take a few extra pounds from their pocket but are designed for a specific purpose".[68] An example was the Aggregates Levy Sustainability Fund which was funded by partial hypothecation (around 10%) of Aggregates Levy revenue and aimed to support projects that reduce the effects of aggregate extraction on local communities and the natural environment.[69] (The 2010 Spending Review announced that the scheme would be discontinued.[70]) Hypothecating revenues for environmental ends can restrict spending flexibility. It can also help, however, to build trust and acceptance of environmental taxes. The Treasury should therefore consider greater use of at least partial hypothecation of revenues from environmental taxes, as applied for example to the Aggregates Levy.

Evaluation

27. A problem with environmental taxes is that it is difficult to evaluate the efficacy of measures because the actual environmental impact is often uncertain.[71] It is difficult to identify the extent to which taxation rather than any other factor or policy initiative is responsible for behavioural changes.[72] The Economic Secretary told us that the Treasury had held workshops to consider initiatives in particular tax areas, including environmental taxes, to look at their impact on behaviours "from the perspective of the public and the company, back to the tax, not the other way round".[73] The Government's workshops on particular tax areas are welcome, but detailed research is needed on the impact of environmental taxes on behaviours to establish what works, and that analysis should be made public to help engender public trust in the purpose and application of environmental taxes.

28. At present, the only information provided on the environmental impact of taxation changes announced in the Budget is on CO? emissions levels. HM Revenue and Customs produces Tax Information and Impact Notes, detailing the specific impact from tax changes. These showed, for example, that removing the Fuel Duty escalator and cutting Duty by 1p a litre could result in a relatively small, 0.4 MtCO?e, increase in emissions in 2011-12.[74] There appears to be no publicly available modelling of wider knock-on effects to the environment from changes to environmental taxes, such as poorer air quality, land-use change, congestion and traffic accidents. The Economic Secretary told us that the Treasury, along with the Department for Transport, had done much work looking at 'the overall burden of taxation in relation to the externalities caused by motoring'.[75] We asked to see that assessment, comparing the cost of environmental damage with the tax revenue received.[76] However this has not been shared with us. Instead, the Treasury simply told us that motoring contributes 20% of UK emissions and that 'work is carried out with other Government departments on the wider environmental impacts of relevant taxes to ensure that we have robust data to form our assumptions'.[77] We are disappointed that the Treasury did not provide the information we require for this inquiry. The material we sought is important for demonstrating the full impact that environmental taxes are having, and for building greater trust and acceptance of environmental taxes. In its response to this Report, we wish to see the Treasury's assessment of the environmental costs of motoring, beyond a simple quantification of the emissions involved.

29. To tackle the uncertainty over whether environmental tax rates adequately reflect externalities (or indeed over-tax them), the Treasury should seek to build consensus on a methodology for calculating environmental externalities. That would allow evaluation criteria to be formulated for assessing whether environmental taxes are having the desired effect on changing behaviours. Such a methodology and evaluation criteria should then be included in a published environmental tax strategy (paragraph 80).

30. The Treasury should also publish an 'environmental impact assessment' alongside future Budgets, in a similar manner to the 'Household assessment' in Annex A of the Budget Report. This should cover the fullest possible assessment of the environmental impacts of proposed tax changes, including a monetised assessment of the environmental cost compared with the change in tax revenue.

Natural capital

31. In June 2011, the Government published the National Ecosystem Assessment, which found that ecosystems are 'consistently undervalued in conventional economic analyses and decision making'. It estimated that natural ecosystem resources are worth £30 billion a year to our economy. Soon after, Defra published its Natural Environment White Paper.[78] The White Paper recognised that more needs to be done to reflect the economic value of the natural environment in decisions made by Government, business and people. It set out measures aimed at putting 'natural capital at the centre of economic thinking and at the heart of the way we measure economic progress nationally', including incorporating natural capital within the UK Environmental Accounts and producing an action plan to expand markets and schemes in which payments are made by the beneficiary of a natural service to the provider of that service.

32. In our January 2011 report on embedding sustainable development we noted that the Treasury was in a position to exert influence over departments and help drive sustainable development across Government, including the valuation of natural capital in policy-making to reflect the Treasury's 'Green Book' methodology.[79] The Natural Environment White Paper noted that the Government would update the 'Green Book' to reflect the natural environment in policy appraisals '[covering] techniques for monetary and non-monetary valuation and the need to take into account values from individuals, communities, businesses and other interested parties when undertaking environmental valuation'.[80] In the light of this we were surprised during our current inquiry to learn that the Treasury, at that stage, did not appear to have been clearly involved in this work. As the Economic Secretary told us, "Defra are engaged in that work and, from a Treasury perspective, we would be very interested to work with them on that".[81] The Treasury should take greater ownership of the Government's efforts on valuing and managing the country's natural capital, to ensure that policy-making in all departments reflects such valuations.

33. Once stocks of natural capital are quantified and valued, it could be possible to include these in the tax system in some way. We put this idea to the Treasury who told us that due to the absence of a 'simple and robust way of attaching value to natural capital it is unlikely the taxation system could be used to directly protect and increase stocks of natural capital —there is a strong risk of high costs and challenge'.[82]

34. We welcome the Government's plans to incorporate natural capital into the Environmental Accounts. In the light of that work, the Treasury should keep under review the possible scope for broadening the tax base in due course to include natural assets, to help protect or increase our stocks of natural capital. While taxes based on natural capital valuation might be open to challenge at this stage, the Government should explore using the scope for financial incentives outside the tax system to reward positive environmental behaviours, calibrated according to the value of the natural capital involved.

Strategy

35. The previous Government's vision document for environmental taxation—The Statement of Intent on Environmental Taxation—has not been refreshed since it was introduced in 1997 and the Treasury Select Committee has previously expressed disappointment that commitment to this Statement had faltered.[83] The Budget detailed the Government's high-level aim for environmental taxation:

... a simple efficient and cost effective policy framework will meet environmental objectives while supporting growth and maintaining sound public finances. Market-based solutions to price carbon are at the heart of this approach, achieving objectives at the lowest possible cost.[84]

36. The Government has not yet set out its strategy, however, articulating how the Treasury will deliver on its objectives for environmental taxation. Witnesses have highlighted a need to set out a clear strategy for environmental taxes to help taxpayers understand and accept the environmental rationale.[85] Andrew Leicester, from the Institute for Fiscal Studies, told us that what was lacking from the Budget was a sense of the big picture in terms of environmental taxes: "So there was a lot of tinkering, there was a lot of fuss around Fuel Duty, but what is the big long-term strategy for transport taxes or energy taxes going forward?".[86] The Government should set out a strategy for how its vision for environmental taxes will be delivered by individual taxes. Such a strategy should set out why environmental taxes are set and what they are there to achieve (paragraph 80).