Meeting the Target: Alternatives
to Taxation
11. When taxation is used to encourage the business
and commercial sectors to use energy more efficiently, the Government
stands back from mandating the degree of emissions reductions
which it would like to see achieved by individual firms, sites
and processes, relying on reductions being delivered by the market
instead. Another approach to emissions reductions, and the one
most commonly used up until now, involves the Government regulating,
directly or indirectly, the amount of greenhouse gases emitted.
Regulation of emissions can come in several guises, including:
- the Government capping emissions for individual
firms or plant over a period of time, penalising instances of
caps being exceeded. This is broadly the approach taken by the
EU Integrated Pollution Prevention and Control Directive (IPPC)
which will apply to 6,000 industrial installations in the UK when
it comes into force on 30 October 1999[26]
- agreements being reached between firms and the
Government about energy efficiency improvements which can be made,
or emissions reductions which can be achieved, over a period of
time. The Chemical Industries Associations entered into a non-binding
agreement with DETR in 1997 to improve its members energy efficiency
by 20% between 1990 and 2005.[27]
The Government is proposing reaching binding agreements with various
industry sectors to improve energy efficiency in return for lower
rates of Levy[28]
- emissions trading, which combines a regulatory
approach with market incentives. Permits to emit greenhouse gases
can be allocated or auctioned to firms which may then buy or sell
them according to decisions about their optimal levels of emissions.
An international system of emissions trading is provided for in
the Kyoto Protocol and a pilot scheme for carbon emissions trading
is being developed in the UK.[29]
12. Some witnesses from the industrial sector argued
that regulatory approaches to emissions reductions were preferable,
and more cost effective, than the use of taxation.[30]
Regulatory mechanisms can provide more certainty for firms about
the extent to which they should reduce emissions and the timescale
in which reductions need to be achieved. Firms are only penalised
in the event of a failure to stay within assigned limits or to
achieve targets. Nevertheless, there are significant disadvantages
to the widespread use of regulatory approaches:
- there is a limit to the number of firms or plant
which the Government can thoroughly assess and set caps or targets
for, which limits the extent to which regulatory approaches to
emissions reductions can be applied to small and medium sized
enterprises
- regulatory approaches require new, effective
monitoring and enforcement procedures to be in place, with significant
resource implications
- regulatory approaches run the risk of not achieving
emissions reductions in the most economically efficient manner,
by being too stringent or, more likely, too lenient in terms of
the emissions reductions they require.[31]
Firms would tend to be better judges of their capacity to improve
energy efficiency than the Government, suggesting the possibility
that some firms' or sectors' caps or targets might not be particularly
demanding.
13. The IPPC regime is planned to continue until
at least 2007 .[32]
By encouraging agreements with industry sectors and the development
of emissions trading, the Government is clearly committed to regulatory
approaches to emissions reductions. Regulation, of one sort or
another, is one tool in the Government's kit, but other tools
are needed to ensure that the UK meets its Kyoto target. We
are not persuaded that the Government can set emissions reductions
targets, or establish effective monitoring and compliance procedures,
for the great majority of small and medium sized enterprises.
Nor are we convinced that the Government is better able than the
market to steer firms towards the energy efficiency improvements
needed to cut emissions. Indeed, we were surprised by the enthusiasm
expressed by so many business representatives for Government intervention
in their industries when we have become accustomed to the mantras
that "the market knows best" and "the Government
should regulate with a light touch". Regulatory approaches
to emissions reductions have a role to play in ensuring the UK
meets its Kyoto target, but we reject the argument that regulation
by itself will prove sufficient.
EMISSIONS TRADING
14. Lord Marshall, noting the likelihood that
international trade in greenhouse gas emissions permits would
be up-and-running by 2008, concluded that "it may not be
sensible for Government to introduce a statutory scheme in the
UK at this stage".[33]
His thinking was influenced by the difficulties involved with
speedily setting up an effective national emissions trading system
and the possibility that any such system might not be compatible
with an international system established later on.[34]
Witnesses were divided over whether or not Lord Marshall had shown
undue caution in his assessment of the viability of a national
emissions trading scheme. Mr Lehmann of the Energy Saving Trust
said that "emissions trading is quite a nice name and it
sounds very, very marketed, but it has to start off with somebody
deciding how much carbon emissions are permitted from each firm
in the land. That is a very, very tough and tall order".[35]
Mr Hewett of the Institute for Public Policy Research warned that
it had taken ten years for a sulphur emissions trading scheme
to be established in the US and that there would be a lot of "wrangling
over the issue of permits and how they are allocated" when
a carbon emissions trading scheme was initiated.[36]
Many witnesses from the industrial sector disputed these points.[37]
The Major Energy Users Council described the grounds on which
the introduction of a full-scale emissions trading scheme had
been rejected as "spurious" and claimed that "many
City institutions (including the International Petroleum Exchange,
the London Stock Exchange and the Bank of England) are of the
opinion that the Government had over-estimated the time required
for carbon emissions trading schemes to be established".[38]
15. The Minister for Energy and Industry said that
"I passionately believe that Lord Marshall under-estimated
the value and the benefits of emissions trading". He told
us that the Government was pressing the CBI and the International
Petroleum Exchange to develop at least a working model of an emissions
trading scheme, for discussion.[39]
Mr Agar of the CBI and Mr Porter of the Association of Electricity
Producers both told us that, on 30 June 1999, Michael Meacher
and John Battle had been present at the launch of an industry
pilot emissions trading scheme which was backed by several major
companies. [40]
Mr Agar thought that at least an outline of what could be achieved
by the scheme would be clear "before the end of the autumn".[41]
He stated that "at least parts of the
Government believe that we should be pressing ahead rather faster
with emissions schemes for the United Kingdom" and Mr Porter
called for "much more serious consideration" to be given
to emissions trading.[42]
We were surprised to hear of the depth of the Minister for
Energy and Industry's commitment to emissions trading. The Government
has sent out mixed messages on the feasibility of a national carbon
emissions trading scheme being quickly introduced. We see no reason
why the UK should hold back from developing its own carbon emissions
trading scheme ahead of the proposed international scheme, which
the UK might be in a strong position to influence. We seek early
clarification from the Government of its views on whether a national
carbon emissions trading scheme, if feasible, should be introduced
prior to the start of an international scheme.
16. In his Report, Lord Marshall said that "participation
in trading will probably never extend to the small business sector".[43]
Many witnesses accepted this conclusion, although the Association
of Electricity Producers did not and the Major Energy Users Council
suggested that small firms could employ agents to trade in emissions
permits on their behalf.[44]
The Economic Secretary to the Treasury envisaged some small and
medium sized enterprises participating in emissions trading schemes
electronically, but only "a very long way down the line".
She emphasised the Government's view that, for this reason, the
Levy and emissions trading schemes were "complementary rather
than substitutes for each other".[45]
One of the major aims of the Climate Change Levy is to incentivise
small and medium sized enterprises, many of whom are not likely
to become involved in emissions trading, to use energy more efficiently.
The Levy cannot therefore be dismissed as a short term measure,
introduced in lieu of emissions trading and likely to be abolished
once such trading begins in earnest.
16 Ev, p57; Apps, p1 paragraph 2, p3 paragraph 1,pp10,16,
p19 paragraph 2, pp35-6, 40, p44 paragraph 14, pp56, 59, 62,
71; Marshall Report, paragraph 5 Back
17
For instance Apps, p23 paragraphs 11-18, pp68, 71-2 including
paragraph 2; C&E response from National Farmers Union paragraph
2 Back
18
Apps, p19 paragraph 2 Back
19
Apps, p1paragraph 2 Back
20
Q3 Back
21
Ev, p58 section 4; Apps, p1 paragraph 2, p10 paragraph 2, p15
paragraph 26, p19 paragraph 4, p23 paragraph 7, p29 paragraph
5.2, pp42, 59; C&E responses from the Utility Buyers Forum
p2 and the UK Steel Association section 2.1 Back
22
Qq8, 111 Back
23
Ev, p15 Back
24 Apps,
p10 paragraph 2 Back
25
Apps, p59 Back
26
Memorandum from the Parliamentary Office for Science and Technology,
Appendix 56; Marshall Report, paragraph 31; for more information
on how regulatory approaches to emissions control work in practice
see Trade and Industry Committee, Fourth Report, 1997/98, Coal,
HC404, paragraphs 72-87 and HC404-II pp103-79 Back
27 Apps,
p20 paragraph 19 Back
28
See paragraph 42 Back
29
Marshall Report, paragraph 42; and see paragraph 14 Back
30
For instance Qq152, 162; Ev, p75 Back
31
Eg see Q116 Back
32
Marshall Report, paragraph 31 Back
33
Marshall Report, paragraph 74 Back
34
Marshall Report, paragraphs 50-73 Back
35
Q140 Back
36
Q143 and Ev, p30; Apps, p41, p64 paragraph 7 Back
37
Ev, p51 paragraphs 5-6; Apps, p1 paragraph 4, p4 paragraph 13,
pp9, 23, p38 paragraph 11, p45 paragraph 17, pp54-5 sections 3.0
and 4.0, p58 paragraph 4, Appendix 57 Back
38
Apps, p9 Back
39
Q10 Back
40
Qq149, 219 and see Q36 Back
41
Q219 Back
42
Qq149, 219 Back
43
Marshall Report, paragraph 55 Back
44
Q152; Apps, p9 and Appendix 57, paragraph 3 Back
45
Q101 Back