Memorandum from English Nature
We support the use of measures, such as differentiated
fuel duties, to encourage the take up of fuel types which improve
local air quality. However, Government needs to appraise fully
the environmental efficiency of such fuels.
Fuel duty is an appropriate measure for climate
change objectives because it is correlated with carbon emissions:
for a given type of fuel, more fuel used means more carbon emissions.
Over the long term, we need more significant
reductions in greenhouse gas emissions, beyond the current targets,
and for a greater share of these reductions to come from the road
transport sector. Road fuel duties have a clear role here.
We accept that recent price rises will reduce
the need for a formal rise in the rate of fuel duty in the next
Budget. However, over the long term a fuel price incentive needs
to be maintained to help achieve our environmental objectives.
The effectiveness of the price signal would
be increased if more emphasis were put on its environmental objectives,
and if society could see that fuel duty increases are being accompanied
by similar investment in alternative transport choices. This does
not necessarily require a formal hypothecation fund.
1.1 English Nature is the statutory body
that champions the conservation and enhancement of the wildlife
and natural features of England. We do this by:
agencies, local authorities, interest groups, business, communities,
the special nature conservation sites in England;
enablinghelping others to
manage land for nature conservation, through grants, projects
conservation for all and biodiversity as a key test of sustainable
1.2 In fulfilling our statutory duties,
establish and manage National Nature
notify and safeguard Sites of Special
Scientific Interests (SSSIs);
advocate to government departments
and others effective policies for nature conservation;
disseminate guidance and advice about
promote research relevant to nature
1.3 Through the Joint Nature Conservation
Committee, English Nature works with sister organisations in Scotland,
Wales and Northern Ireland to advise Government on UK and international
nature conservation issues.
1.4 Following discussion with advisers to
the Committee, we understand that the term "UK air quality
targets" in the Committee press notice is to be interpreted
as covering both local air quality and international climate change
1.5 Government policy in relation to road
fuels and air quality targets is relevant to the following areas
of concern to English Nature:
Impacts of climate change on our
Other impacts from air pollution,
such as acidification and nutrient enrichment from sulphur dioxide
and nitrogen dioxide, which cause damage to our wildlife.
1.6 Government policy on road fuels is also
relevant to our concerns about the construction and operational
impacts of new road building. Direct impacts arise from land take,
changes in topography, surface and sub-surface water drainage,
stream diversions, earthworks, disposal of surplus material and
2. INQUIRY ISSUE
(1): THE CASE
MEET UK AIR
Local air quality objectives
2.1 We support the use of measures, such
as differentiated fuel prices, to encourage the take up of fuel
types which improve local air quality. Such policies will help
reduce air pollution damage to our ecosystems.
2.2 However, the Government needs to evaluate
the efficiency of so-called green fuels such as low sulphur petrol,
in case they lead to increased greenhouse gas emissions.
Climate change objectives
2.3 Fuel duties are an appropriate instrument
to help tackle greenhouse gas emission targets. It is often argued
that the fuel duty escalator has been a blunt instrument for environmental
policy. While this view is valid in relation to the more locally
specific costs of congestion, fuel duty is very well correlated
with carbon emissions: for a given type of fuel, more fuel used
means more carbon emissions.
2.4 We believe that all sectors emitting
greenhouse gases should make significant contributions to emission
reductions. Even with the Integrated Transport White Paper the
Ten Year Transport Plan and other measures, traffic is forecast
by Government to grow significantly in the next ten years. Government
measures in the transport sector, including the plan, will lead
to a small reduction in emissions over the next decade. However,
the reduction in this sector is modest in relation to the overall
Kyoto target and the Government's more ambitious targets. Over
the long term, we suggest the need for more significant reductions
in greenhouse gas emissions overall, beyond the current targets.
This will require a greater level of reduction from the road transport
sector. Road fuel duties have a clear role here.
2.5 We recognise that fuel duty increases
can have social impacts in some areas, and recommend the use of
targeted measures to offset such effects.
2.6 Traffic congestion creates a variety
of environmental costs, including additional air quality problems.
Local incentive schemes, including road use charging, are the
most appropriate measures to tackle congestion. The Government's
Integrated Transport Commission has suggested less emphasis on
fuel duties and more on local charging schemes. However, such
programmes will take time to get off the ground and are being
promoted cautiously by Government. This suggests an important
continuing role for fuel duties in the medium term and a managed
transition towards a wider mix of instruments over the longer
3. INQUIRY ISSUE
(2): THE RELATIONSHIP
3.1 We acknowledge the particular circumstances
caused by the recent fuel price rises. However, these concerns
should be considered in the appropriate context:
Despite recent price rises, motoring
costs remain similar in real terms to the level in the period
During the same period, real incomes
have grown significantly, as have the costs of other forms of
transport. So road transport has become comparatively cheap;
Motoring costs seem likely to reduce
further, compared with income levels, in the future.
3.2 This context suggests the need for a
long term fuel duty incentive to be maintained in order to help
achieve our environmental objectives. We recommend that the Government
commits to an informal price indexing process to maintain the
necessary long term signals.
3.3 Some question the effectiveness of fuel
duties as an environmental signal. We believe this is primarily
because of background trends: while fuel duties have had an effect
on emissions, this has been offset by the overall growth in traffic.
However, as the Government has recognised, the position on emissions
would have been significantly worse if the duty had not been in
3.4 Some research estimates that the short
term reduction in fuel use is proportionately less than the rise
in duty. However, this should not be interpreted as meaning that
the duty is ineffective. Indeed the short term price response
seems to be similar or higher than other areas considered for
environmental taxes, such as pesticides and aggregates.
3.5 The effectiveness of the price signal
would be increased if more emphasis were put on its environmental
objectives, and if society could see that fuel duty increases
are being accompanied by similar investment in alternative transport
choices. This does not necessarily require a formal hypothecation
4. THE GOVERNMENT'S
4.1 We welcome the attempts at environmental
appraisal of measures in the Pre-Budget Report, but believe that
a more detailed analysis should be provided including the effects
of different options. For example, the 10 Year Transport Plan
suggests that if motoring costs were to be held constant over
the next decade, this would lead to a further emission saving
of about 1 million tonnes of carbon by 2010.
4.2 We would welcome further explanation
of carbon reduction resulting from changes to Vehicle Excise Duty
(VED). Presumably the increase in environmental differentiation
will lead to carbon emission savings and other benefits. However,
the effect of lowering overall motoring costs is not made clear.
4.3 Our comments in paragraph 2.2 are also
4.4 The pre-Budget report describes some
carbon savings in tonnages, and others in percentage terms, which
5. OTHER COMMENTS
5.1 We welcome some of the additional transport
measures in the Pre-Budget Report, such as the Green Fuel Challenge
and the further reforms of company car taxation.