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Høringssvar 2007

Høringssvar på EU's grønbog om markedsbaserede instrumenter for miljø og energi

Høringssvar The Danish Ecological Council's reply to the consultation from the Commission of the European Communities on:

“Green paper on marked based instruments for environment and energy related policy purposes” SEC (2007) aaa

Summary

  • Implementation of a green tax reform ought to be an integrated part of the EU tax and environment policy. Introducing at least a 10% shift of tax income in each country within ten years, away from labour and towards energy and the environment, and agree on a minimum level of coordination on how to achieve this.

  • Community minimum tax levels should be divided into energy and environmental elements and the minimum levels ought to be set higher to secure the polluter pays principle including the effect on climate and the implementation of the Kyoto goals. We oppose any nuclear energy advances. The green taxation of nuclear power has to be based on a strong implementation of the precaution principle.

  • Sectors outside the current ETS scope, such as aviation and international shipping and small installations, shall be included in ETS. We should take the higher impact of emissions, released from flights in upper atmosphere, into account, by adding a factor between 2,7 and 5 to the CO2 emissions. Other sectors not included in ETS should be covered by the Energy Tax Directive.

  • The green paper suggests excluding sectors covered by ETS from the Energy Tax Directive’s scope. We are strongly against that. The ETS system has increased the profits of the covered industries. Therefore, the permits ought either to be auctioned out by EU or taxed in the single countries to make sure that the public get the revenue instead of the private industries.

  • We find that all areas, where green taxes can reduce the ecological and environmental impact and improve the nature ought to be included in the area of the Tax directive. We oppose replacing emission limits or direct measures to ban certain pesticides and certain discharges of hazardous chemicals, with taxes and trading schemes. In this field taxes can be used to promote the development of alternatives to hazardous substances. When the alternatives are available at the market the hazardous substances should be banned or limited by law.

  • The tax principles on transport have to be tightened up. The possibility to include national transport in ETS has to be investigated fx the climate gas emissions from cars could be included in the ETS system by making the car producers responsible for the emissions from the use of new cars and the national states responsible for the emissions from the rest of the cars. The Climate change elements should be included in the tax base on registration tax and annual circulations taxes, as proposed in the proposal for passenger cars related taxes. Vans and lorries should be included in the proposal. The EURO vignette directive provides a charging framework on trans-European road networks. The tax system ought to be replaced by a distance based infrastructure charge, with the possibility also to differentiate after time and area. The directive ought to be changed, so it includes not only infrastructure cost, but also the environmental cost of infrastructure use. It also ought to be extended to all types of roads - not only motor- and highways - and all modes of transport.

The Green Paper acknowledges that environmental tax reforms (ETR) can accomplish multiple objectives of growth, jobs and a clean environment: (p. 5): “An environmental tax reform (ETR) shifting the tax burden from welfare-negative taxes, (eg on labour), to welfare-positive taxes, (eg on environmentally damaging activities, such as resource use or pollution) can be a win-win option to address both environmental and employment issues.” Linked to this is its clear statement that points to the damage from environmentally-harmful subsidies on competitiveness, environment and health. The argument for green taxes ought to be supplemented with the possibility to generate income and thereby make it possible to reduce tax on labour. Therefore implementing a green tax reform ought to be an integrated part of the EU tax and environment policy

The Danish Ecological Council has called for an Environmental Tax Reform for a long time. Therefore it is gratifying, that the Commission has published this green Paper. The Danish Ecological Council has together with other European Environmental organizations asked for at least a 10% shift of tax revenue in each country within ten years, away from labour and towards energy and the environment, and to agree on a minimum level of coordination on how to achieve this. The Green Paper lacks any such reference.

As part of a policy on environmental taxes The Commission ought to set a binding goal. This would be in line with and support the polluter pay principle, EU’s 6 Environmental Action program, EU’s Sustainable Development Strategy and the Lisbon strategy. Instead, the Commission has only offered to help share best practice between countries and has suggested setting up a forum on MBI.

The negative social effects of an Environmental tax reform can be offset by the social benefit systems and lower income taxes for lower income groups.

The Green Paper suggests Community minimum tax levels should be divided into energy and environmental elements, which would then be reflected at the national level in the form of energy and environmental (emissions) taxes. This would mean introducing a tax on the energy content of all fuels, together with a differentiated environmental tax, that would distinguish between greenhouse gases and non-greenhouse gas emissions of the fuel used. This will support generation of green renewable energy. The minimum levels ought to be set higher to secure the polluter pays principle, including the effect on climate and the implementation of the Kyoto goals, without disturbing the competition between countries.

The implications of such a system on nuclear energy use need further investigation. We opposes any nuclear energy advances, whether under disguise of reducing climate change or otherwise. Although nuclear energy does not directly emit CO2, it represents no solution to the energy and climate problem, among other things because nuclear can only to a small extent be combined with renewable energy like windmills, and a safe and sustainable solution of the nuclear waste problem do not exist. The green taxation of nuclear power has to be based on a strong implementation of the precautionary principle.

The Green Paper includes a suggestion on the review of the EU Emission Trading Scheme (ETS). One is to ensure that the environmental impact of sectors outside the current ETS scope, such as aviation and small installations, are covered by the Energy Tax Directive. We find that aviation and international shipping should also be included in the ETS. In relation to aviation the ETS have to take into account the higher impact of emissions, released from flights in upper atmosphere on the climate, adding a factor between 2,7 and 5 to the CO2 emissions. The possibility to include national transport in ETS has to be investigated fx the possibility that the climate gas emissions from cars could be included in the ETS system by making the car producers responsible for the emissions from the use of new cars and the national states responsible for the emissions from the rest of the cars.

The paper also suggests excluding sectors covered by ETS from the Energy Tax Directive’s scope, suggesting that their environmental impacts have already been taken care of by the ETS. Analyses have shown, the industries include the indirect cost of the quotas in their cost calculation. The ETS system therefore has increased the profits of the covered industries. Therefore, The Danish Ecological Council finds that the permits either ought to be auctioned out at the EU level or taxed of the single countries to make sure, that the public get the income from the ETS system instead of the private industries.

The paper explores other areas where MBIs might be applied. These include surface transport and shipping, and using MBIs to address pollution and protect resources, water, waste management, biodiversity, and air pollution are specified areas. The Danish Ecological Council finds that all areas, where green taxes can reduce the ecological and environmental impact and improve the nature ought to be included. We oppose replacing emissions limits or direct measures to ban certain pesticides and certain discharges of hazardous chemicals, with taxes and trading schemes.

The Greenhouse gas emissions from transport will account for an increasing part of the total emissions. Therefore it is important to tighten up the tax principles on transport. The possibility to include national transport in ETS has to be investigated. The Climate change elements shall be included in the tax base on registration tax and annual circulations taxes, as proposed in the proposal for passenger cars related taxes. Vans and lorries should be included in the proposal. The EURO vignette directive provides a charging framework on trans-European road networks. The tax system ought to be replaced by a distance based infrastructure charge, with the possibility also to differentiate after time and area. The directive ought to be changed, so it includes not only infrastructure cost, but also the environmental cost of infrastructure use. It also ought to be extended to all types of roads - not only motor- and highways - and all modes of transport.

Yours sincerely

Johan Nielsen
Policy adviser - Environmental and Energy economics
Johan@ecocouncil.dk
+ 45 33 18 19 38


     

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