Karmenu Vella and the plastic tax

Karmenu Vella, EU Commissioner for the Environment, is enthusiastic about the possibility of a plastic tax being introduced throughout the EU. In his view, this tax – if properly designed – could be one of a number of tools for delivering environmental objectives as well as providing budgetary income. Planet Earth is drowning in plastic.

Vella made these comments in an interview published on Euractive last week on the subject of the EU’s new plastics strategy.

We have been there before and maybe it is time to consider the matter once more in Malta. Some 10 years ago in Malta we had an environmental tax which was known as an “eco-contribution”. It was a valid proposal, badly designed and arrogantly implemented. The lessons learnt from that exercise could, if properly analysed, lead to the development of effective policy tools addressing the generation of waste in the Maltese islands. Policies should be well thought out and not developed as a result of panic – as is clearly the case with the current government incineration proposal.

Ten years ago, the eco-contribution tried to address the generation of plastic waste including “single-use plastic”. This is one of the primary targets of the EU plastics strategy published on the 16 January.

Its title is very clear : A European Strategy for Plastics in a Circular Economy. Plastic is ubiquitous: it is present in all aspects of our economy and our daily lives. The plastics we use must be such that they can be re-used rather than thrown away. It is an important resource which can be put to good use rather than thrown away or incinerated.

It is for this purpose that the newly-published plastics strategy lays the foundations for a new plastics economy where “the design and production of plastics and plastic products fully respect reuse, repair and recycling needs and more sustainable materials are developed and promoted”.

A plastics economy would definitely not send “waste plastic” to the incinerator to be converted into energy. Even Malta’s latest version of the Waste Management Strategy, approved in 2014, emphasises that our approach to waste must be one based on the sustainable use of resources and, in line with the EU waste hierarchy, gives priority to recycling over incineration.

In fairness, it has to be said that our government’s advisors on incineration have already sounded the alarm. Apparently this has not, as yet, been understood – either by the government or by the Opposition. It would be pertinent to point out that the Special Assignment Report by Jaspers dated 23 February 2017 on a Waste to Energy (WtE) project in Malta specifically emphasises that “it would be difficult to justify a WtE facility that is not based on low waste growth and high recycling”.

Rather than talking about incineration, it is about time we discussed in detail the implementation of our Waste Management Strategy in order to identify why it has not to date succeeded in increasing Malta’s recycling rates. What initiatives need to be taken in order that the waste generated in Malta is minimised?

Malta’s waste management strategy, now complemented by the EU’s Plastic Strategy, is definitely a much better roadmap than the documentation encouraging incineration. And what about our commitments to encourage a “circular economy” : gone with the wind?

Karmenu Vella’s plastics tax is food for thought.

It is about time that Wasteserve is managed properly. As a first step, it should stick to its brief and seek to implement carefully the Waste Management Strategy, which establishes the year 2050 as the year when we should achieve a “Zero Waste Target”. This target will not be achieved through the use of incineration but through a policy encouraging waste minimisation as well as recycling.

This is not just a task for the Minister responsible for the Environment. The Minister responsible for the Development of the Economy also has a very important role to play in achieving a successful implementation of the Waste Management Strategy.

Unfortunately he is apparently completely absent.

Zero waste municipalities in Europe are continuously indicating that an 80 to 90 per cent recycling rate is achievable. The fact that Malta’s recycling rate is, at best, estimated at around 12 per cent, is a clear indication that there is room for substantial improvement – with or without Karmenu Vella’s plastics tax.

Published in The Malta Independent on Sunday 28 January 2018

 

Advertisements

The politics of e-waste

WEEE Electrical and Electronic Waste

 

Last Monday’s budget has placed waste on the national agenda once more.  This time the focus is on waste generated by electric and electronic equipment. Put simply the issue is that there exists conflicting legislation on the Maltese statute book. On the one hand it is the applicability of the Eco-Contribution Act. On the other hand its the WEEE Directive of the EU which has been transposed into Maltese legislation as of 2007 (Legal Notice 63 of 2007 since replaced by Legal Notice 204 of 2014). WEEE meaning Waste from Electric and Electronic Equipment.

The Eco-Contribution Act of 2004 established the quantum of an eco-contribution to be paid on electric and electronic equipment. This eco-tax was added on to the price of the various electric and electronic equipment sold in local shops: fridges, ovens, telephones, computers, electronic games, calculators, vending machines ………………….  The  amount of tax payable ranging from 25 euro cents to €69.88.

Eco-contribution collected peaked in 2008 at slightly over €15.6 million. It is estimated that around €7.8 million will be collected in 2014 and another €6 million in 2015.

As of 2007 producers (and their representatives), in addition to being responsible for the payment of the eco-contribution, have also been responsible for implementing the WEEE Directive in Malta. This Directive forms part of a number of a set of EU Directives which address different waste streams with the objective of ensuring that waste is considered as a precious resource. Hence the need to recover this resource in order to reintegrate it into the economy.  This means the transformation of all waste into useable resources.

The Directive applied the principle of extended producer responsibility throughout the life of the equipment.  This signifies that producers of electric and electronic equipment, directly as well as through their representatives (the importers) and those dealing with such equipment at points of sale retain responsibility throughout the life cycle of the products. This life cycle thinking has its first impact on the drawing board as producers seek to minimise the use of resources not only cost-wise but also due to the fact that if they do so they will have less to recover. This encourages eco-design. Thereby designing and subsequently producing products whilst keeping in mind their impact throughout their life. It is much more that a cradle to grave view. In fact it is considered as a cradle to cradle approach as at the end of its useful life a product will through recovery of the materials of which it is made up give rise to new products.

What does it signify for us?

Producers and their representatives have the direct responsibility of recovering  electric and electronic waste. In terms of the Directive they will either recondition the equipment or else strip it into its component parts and recycle the resulting materials. This will be done at a cost.  Depending on the efficiency of the process the producers and their representatives will recover a proportion of their costs when they sell the recovered resources.  The unrecovered costs may, in terms of the Directive, be added on to the price of the products. Producers’ representatives in Malta maintain that it is possible for the quantum of the unrecovered costs to be much lower than  what is currently being paid as an eco-contribution. Hence the net impact could be not only environmentally beneficial but also of direct benefit to the consumer.

The budget has announced a transition period lasting up to the end of August 2015 when it is planned that the eco-contribution on electric and electronic equipment is removed and producers (through their local representatives) assume their full extended responsibilities.

Electric and Electronic waste is currently collected by local councils through their bulky refuse service. It is also collected at bring-in sites operated by Wasteserve.  Producers will seek to coordinate these existing collection services with their already operational recovery schemes.

Alternattiva Demokratika-The Green Party as well as GRTU and other producers representatives have been insisting for ages that this is the way forward. In order to achieve results everyone must however play his part.

The net result will be beneficial for both the environment as well as the economy.

 

published in The Independent on Sunday – 23 November 2014

Joseph iħobb jiċċajta ………… ħafna

Joseph Muscat ihobb jiccajta

Iktar milli jiċċajta, forsi nkun iktar korrett jekk ngħid li jħobb jipprova jgħaddi n-nies biż-żmien.

F’waħda mill-okkazjonijiet li fihom indirizza lill-istampa riċentement qal li l-budget għall-2015 hu wieħed li jħares l-ambjent!

Ħadd ma jistax jiċħad li l-budget fih numru ta’ miżuri ambjentali. Imma b’daqshekk ma jfissirx li dan hu budget ambjentali. Kulma jagħmel il-budget hu li jiġbor flimkien id-diversi miżuri li qed jippjana li  jieħu l-Gvern matul is-sena 2015. Jonqsu viżjoni koerenti ambjentali li la għandu u l-anqas jidher li jista’ jkollu fil-futur immedjat.

Il-ħarsien tal-ambjent m’huwiex biss dwar il-kostruzzjoni, imma ukoll dwar il-bijodiversita, is-sostenibilita’, l-kwalita tal-arja, il-politika dwar ir-riżorsi, il-viżjoni marittima, l-ilma, il-politika dwar il-klima, l-enerġija alternattiva, t-trasport, l-ekonomija l-ħadra, l-ekonomija l-blu, l-ekonomija ċirkulari, it-tassazzjoni ambjentali u tant affarijiet oħra.

Diskors tal-budget li ħa kważi 4 siegħat biex inqara ma sabx imqar ftit sekondi biex jispjegalna kif il-Gvern ta’ Joseph Muscat ser jimplimenta politika ta’ żvilupp sostenibbli. Mhux biss. Imma fl-estimi għall-Ministeru bl-isem twil u bombastiku okkupat minn Leo Brincat (Ministeru għall-Iżvilupp Sostenibbli, Ambjent u Tibdil fil-Klima) kullma hemm ivvutat għall-politika tal-iżvilupp sostenibbli hu għaxart elef ewro. Dikjarazzjoni onesta li tfisser biss li matul l-2015 il-Gvern ta’ Joseph Muscat m’għandu l-ħsieb li jagħmel xejn f’dan il-qasam. It-terminu Żvilupp Sostenibbli fid-diskors tal-budget jissemma darbtejn. Jissemma biss fiż-żewġ tabelli fejn hemm imniżżel l-isem tal-Ministeru ta’ Leo Brincat.

Il-politika tal-Gvern ta’ Joseph Muscat dwar l-Iżvilupp sostenibbli (jekk  teżisti) tqieset mill-Ministru Edward Scicluna bħala li m’għandiex relevanza għall-budget tal-2015

Il-politika dwar l-iżvilupp sostenibbli tinseġ flimkien il-politika ambjentali, dik ekonomika u soċjali. Meta tkun żviluppata kif imiss, il-politika dwar l-iżvilupp sostenibbli tassigura l-interessi tal-ġenerazzjonijiet futuri billi tmexxi l-quddiem l-ekonomija b’rispett sħiħ lejn l-ambjent u lejn il-bniedem. Għalhekk ngħidu li l-politika dwar l-iżvilupp sostenibbli hi mibnija fuq erba’ pilastri: l-iżvilupp ekonomiku, l-ħarsien tal-ambjent, il-ħarsien soċjali u l-politika kulturali.

Fil-ġranet li ġejjin ikolli l-opportunita’ nispjega iżjed fid-dettall kemm il-budget ippreżentat għall-2015 bl-ebda mod ma jista’ jitqies budget li jħares l-ambjent.  Minkejja li hemm miżuri individwali li huma pożittivi ma teżistix viżjoni ambjentali ċara u koerenti.

Għalhekk Joseph qed jiċċajta meta jgħid li dan hu budget ambjentali.

sd strategy budget 2015

Reforming eco-taxation

Time for Radical Change

Malta Today reports this morning that in tomorrow’s Budget Speech Government will be proposing a reform of the Eco-Contribution Act. Malta Today further reports that the eco-contribution due on electric and electronic equipment will be discontinued. Instead, states Malta Today, Government will proceed with ensuring the implementation of the Waste from Electric and Electronic Equipment  (WEEE) Directive of the EU.

The WEEE Directive shifts responsibility for the recovery of waste from electric and electronic equipment to producers and their representatives. It is an Extended Producer Responsibility which has so far not been implemented in Malta notwithstanding various warnings  and infringement proceedings initiated by the EU Commission. It requires the  direct involvement of the private sector who will now have to assume direct responsibility for waste recovery in the WEEE stream.

The matter is dealt with extensively in AD’s Electoral Manifesto. In fact in the Environmental Chapter of AD’s 2013 Manifesto it is stated that :

“We encourage waste separation in localities. However we recognise that this is not enough. As a country we still lag behind and have failed to reach targets on packaging waste as well as waste generated by electrical and electronic equipment.

It is essential to address the operation of scrapyards. These process waste which is subject to at least three Directives of the EU, namely the WEEE Directive, the End of life Vehicles Directive and the Batteries Directive. The manner in which scrapyards have been permitted to operate signifies a total disregard of the principles and safeguards listed in the said Directives. The fact that after more than eight years of EU membership we are still discussing these issues signifies the low level of preparedness to shoulder environmental responsibilities resulting from EU adhesion.

It is essential that environmental taxation (eco-contribution) is reformed in order that it be ascertained that environmental objectives are attained. The private sector should not be penalised through double payment in order that it fulfils its responsibilities relevant to waste on which eco-contribution was due.

Environmental taxation has two objectives. Generating funds to be used by the exchequer as well as to serve as a deterrent and consequently to reduce environmental impacts. For the deterrent to be effective it is essential that when environmental taxes are proposed it be ensured that as far as possible an alternative product or service to the one being taxed which generates less impacts than the taxed product or service is available.

On the other hand we are aware that environmental taxes which are not properly designed can be regressive. That is they can have a negative social impact due to their impacting the quality of life of those with limited means. In order to ensure that the primary objective of environmental taxation would be environmental improvement AD proposes that environmental taxation should be the joint responsibility of the Ministry of the Environment and the Ministry of Finance.”

Eco-taxation can be of considerable benefit. It however needs to be properly designed. Alternattiva Demokratika looks forward to a discussion on the new proposals.

Time to realign actions with words

On Budget Day next week, the government ought to explain the extent to which its actions are consistent with its political programme read during Parliament’s inauguration by the President in 2008.

It would be pertinent to remember that the President had then stated: “The government’s plans and actions are to be underpinned by the notion of sustainable development of the economy, of society and of the environment. When making decisions today, serious consideration will be given to the generations of tomorrow.” Sustainable development, the President had informed Parliament, was a main goal of this government.

Well, since then, and for a number of months before that too, the National Commission for Sustainable Development has not met. It has been dormant for three years. Not a good sign for a government that considers it should direct itself onto the sustainability path. In addition, targets and objectives of the National Sustainable Development Strategy have been ignored.

Alternattiva Demokratika considers that next week’s Budget could be the opportunity for the government to realign its actions with its declarations.

Cabinet approved a national strategy for sustainable development towards the end of 2007 after extensive consultations with civil society carried out by the NCSD. This strategy laid down a number of specific actions for government ministries to follow. These have been honoured in the breach.

The selected method for implementation of the strategy is through action plans drawn up by ministries. Within 18 months from the strategy’s adoption, that is by mid-2009, ministries were required to prepare their action plans to implement the strategy. They are already 12 months late.

This has occurred because, at least to date, the government has considered the NCSD as a formality.

The mere fact that the Prime Minister, who ex-ufficio is chairman of the NCSD, hardly ever attended commission meetings since 2004 is, in itself, the clearest indication of the mismatch between declarations and actions, the end result being the prevailing state of affairs.

The NSDS identified 20 priority areas: environment (eight areas), economy (three areas), society (four areas), cross-cutting issues (three areas) and implementation (two areas).

Priority area 19, for example, established that, by 2008, that is 24 months ago, a permanent structure properly staffed and funded had to be in place to monitor and review the strategy’s implementation. A role for major stakeholders was also envisaged in order to “critically evaluate progress relating to the strategy”.

Priority area 17 identified the year 2008 as the target for the drawing up of a strategy “to enhance the use of economic instruments such as charges, taxes, subsidies, deposit refund schemes and trading schemes” in order to apply the polluter-pays principle and to promote sustainable development in Malta. Instead of drawing up this strategy, the government drew up a national environment policy issues paper and queried whether and to what extent the public considers it advisable “to move towards a taxation system that penalises pollution rather than jobs”.

To add further to the indecision, the pre-Budget document published in July declared the government was considering introducing a carbon tax. It further advocates a tax shifting mechanism whereby the taxes collected through this carbon tax are offset by the reduction of taxes that “penalise jobs”. Has a study analysing the impacts of this proposal been carried out? While reducing carbon emissions would be positive, what analysis has been made of the economic and the social impacts of such a measure?

On behalf of AD I have sought an answer to this question. In terms of the Freedom of Access to Information on the Environment Regulations 2005 I requested the release of studies commissioned by the Ministry of Finance.

The reply I received last Monday is another proof of the amateurism prevalent at policy formation level. The reply drew my attention to a number of academic journals dealing with tax shifting. I was further informed that the issue (of tax shifting) is being discussed in the Green Economy Working Group, which is expected to present its initial findings to the government by the end of 2010. These findings, it was stated, will be subject to public consultation in early 2011.

While consultation is always to be viewed positively, my point is that the announcement in the pre-Budget document that carbon taxation and tax shifting are being considered was premature in view of the fact that no studies have been concluded to date. Not even preliminary ones.

It seems the government has not yet learned its lessons from the introduction of eco contribution.

Serious policy formation and announcements have to be accompanied by studies detailing impacts of the proposals. Premature policy declarations serve no purpose except to mislead.

Ending all this by realigning actions with words would be a good first step. Our future depends on it.

Published in The Times, October 23, 2010

Reflections on an Environment Policy

The current debate on what should form part of a National Environment Policy is a healthy exercise. It is focusing not only on the different aspirations of each citizen but also on the role of each one of the towns and villages which together constitute this country.

The environmental issues we face are the result of the manner we organise our lives both individually and as a community. In fact it can be safely stated that the manner in which economic activity has been organised throughout time has created different environmental and social impacts.

The exercise at this point in time is hence the clear identification of these impacts and subsequently seeking the best manner in which they can be tackled. This is done on two fronts: firstly through the formulation of an environment policy and secondly by integrating this environment policy with economic and social policy within the National Strategy for Sustainable Development (NSSD).

The NSSD has already been formulated and approved by Cabinet almost three years ago after a long process of consultation. It established targets and objectives which have unfortunately been ignored by the same Government which has approved them. This necessarily leads to the conclusion that these exercises can be a waste of time as their only purpose seems to be an exercise to prove that the new hands on deck can do things in a better way than those they have replaced. 

The National Environment Policy Issues Paper identifies a number of areas which are to be tackled but excludes a number of important ones. What is in my view objectionable and bordering on the insulting is the ignoring by the Issues Paper of the NSSD. It also ignores matters which have been tackled by the NSSD as well as the specific targets identified. This the NSSD did after extensive consultation with civil society, which the Issues Paper promises to go through again.

 

Eco-taxation

One such case refers to the use of economic instruments to attain environmental objectives. The Issues Paper queries whether and to what extent there is agreement  with the use of such instruments to further environmental objectives. Simultaneously with the publication of the Issues Paper, Finance Minister Tonio Fenech through the pre-budget document was lauding the idea of introducing a carbon tax and the possible utilisation of the proceeds to affect a tax shift. This is in the spirit of the former EU Commission President  (French Socialist) Jacques Delors’ 1993 EU White Paper entitled “On growth, competitiveness and employment. The challenges and ways forward into the 21st century”.

So whilst the Environment Ministry is requesting our opinion on the use of eco-taxation (and other instruments) it seems that the Finance Ministry is dead-set to proceed.  Do these two Ministries form part of the same government? 

Both the Environment Ministry and the Finance Ministry would do well to go back in time to the debate on the introduction of the eco-contribution (2003-05) where they could identify a number of issues raised by civil society.

Should fiscal objectives be the purpose of environmental taxation or would it rather be environmental improvement? All over the globe governments declare that their aim in applying eco-taxation is environmental improvement. Yet they resist transferring political responsibility for environmental taxation from the Finance Ministry to the Environment Ministry. Such a move would lend credence to statements on the environmental objectives of eco-taxation and would ensure that the design of specific measures is more in line with encouraging changes in behaviour. Retaining political responsibility for environmental taxation at the Finance Ministry on the other hand signifies that the objective is to tax behaviour but not  to change it. This reluctance is generally reflected in the manner  in which eco-taxes are designed. Fiscal policy makers pay attention to the fact that changing behaviour would mean drying up a source of revenue. Hence eco-taxes designed for fiscal objectives are intended not to affect the elasticity of demand. This is done by selecting items in respect of which there are no alternatives and thus irrespective of tax added to the price there is no alternative to purchasing the product or service. The eco-contribution exercise clearly illustrates this argument.

 

Environmental nuisance 

The Issues Paper has failed to project an understanding that environmental issues can be most effectively tackled at a micro-level. In fact the Issues Paper adopts an exclusively macro approach and does not give any weight to the real life issues. Issues of environmental nuisance are the ones which the man in the street feels strongly about. These include primarily noise, air quality and odour nuisance caused by neighbours in residential areas. They could range from an air conditioner fixed below your bedroom window to a neighbour’s fireplace chimney spewing smoke right into your living room or a bakery belching black smoke onto your washing line. Or the newly opened restaurant or snack bar in a transformed ground floor flat whose operator wouldn’t care less about where the odours from his kitchen end up.    

Information

Access to environmental information is an important aspect of environment policy. Yet the drafters of the Issues Paper ignored it. The environmental information aspects of the Åarhus Convention have been incorporated into Maltese legislation as a direct result of Malta’s EU accession. This legislation provides a mechanism through which the citizen requests the release of information which up till then would be withheld by the authorities. This is a very primitive form of governance. The state should release information without having its hand forced to do it. This is the minimum required in an age of transparency and accountability. 

Policy proposals and other initiatives must be buttressed by studies which not only justify the proposal or initiative but which also identify the resulting impacts and the manner in which these can be addressed. Studies must be published at an early stage and not in the final stages of a discussion. Otherwise the public debate cannot be fruitful.

Transparency and accountability

Transparency and accountability are not only duties of the state. They are also a responsibility of private enterprise.  Corporate Social Responsibility (CSR) reporting is one way in which private enterprise informs the public on its activities. It is a function as important as financial reporting. Financial reporting having been accepted by society for quite a long time as a reporting requirement.

In Malta currently two companies publish a CSR report. Vodafone (Malta) and Bank of Valletta (BOV) have already published two editions of their CSR report. There has been considerable improvement in the information made available by Vodafone (Malta) in its second report, but BOV’s reporting  can be substantially improved.

The environment policy should identify the type of organisations that should have the duty to report publicly and on a regular basis on their environmental and other impacts. By organisations I understand not just industry and business but also public corporations, government departments and local authorities. A reasonable first step would be for companies quoted on the stock exchange to take the lead followed by public bodies such as Enemalta, Water Services Corporation, Heritage Malta and Air Malta.

CSR reporting should be guided by international standards such as the Global Reporting Initiative G3 guidelines and should be subject to auditing in order to verify that the statements made reflect what the organisation is really up to. 

Alternattiva Demokratika, AD, the Green Party in Malta has earlier this month published a document in reply to the National Environment Policy Issues Paper which lists and discusses the areas missed out by the said Issues Paper.  In addition to focusing on the urgent need to implement the NSSD, environment information, environmental nuisance and environment information it also points out the need to tackle the uptake of environmental management systems such as ISO 14001 and the Eco-Management and Audit Scheme (EMAS) Regulations of the European Union, light pollution, contaminated land, environmental and sustainability planning at a locality level better known as Local Agenda 21,  the role of civil society and environmental NGOs in environment policy and environment  research.  

We hope that when the environment policy is drafted it will include the widest possible list of issues and will tackle them in an holistic manner keeping in mind the parameters established in the National Sustainable Development Strategy.                 

Alternattiva Demokratika considers that environment policy is one of several instruments through which improvement in the quality of life can be attained. Protecting the environment signifies that we better our quality of life. It also signifies that each one of us acts in a responsible manner. However primarily it must be government which leading the way should act in an appropriate manner in order that it leads by example.

 published in

The Independent on Sunday, October 17, 2010, Environment Supplement

AD on Government’s Environment Policy

During a press conference in Valletta, Michael Briguglio, AD Chairperson, said: ‘Alternattiva Demokratika is presenting its reactions to Government’s proposed environment policy. In a nutshell we believe that it would have been wiser if Government implemented the recommendations of the National Commission for Sustainable Development, which have been ignored by Government for over two years. A holistic and effective environment policy should be based on the concept of sustainable development through which environmental, social and economic considerations are given due importance in order to improve the quality of life of people and to protect species. This is precisely what is being proposed in our policy paper, which covers various areas’.
 
Carmel Cacopardo, AD Spokesman on Sustainable Development and Local Government said that AD’s detailed reaction to the National Environment Policy Issues Paper was presented to Parliamentary Secretary Mario de Marco yesterday during a cordial meeting.
 
AD, said Cacopardo, is of the opinion that environment policy and environment measures have to be buttressed by studies which analyse the economic, social and environmental impacts of the proposals. Environmental research is absent from the list of issues dealt with by the document government published for public discussion. This is not a surprise for AD as acting without analysing impacts a priori is this government’s preferred method of action as has already happened when the eco-contribution legislation was introduced.
 
Government has just announced that it is toying with the idea of introducing tax shifting by reducing taxes on labour and introducing a carbon tax. This proposal communicated in the pre-budget document is scant on details such that it is not at all clear what Government is considering. In addition no studies indicating targets, methods and impacts has been published. Nor is it known whether in fact any studies have been carried out. It is for this reason that AD has 15 days ago requested the release of studies on the “carbon tax” proposal in terms of the provisions of LN 116 of 2005 (Freedom of Access to Information on the Environment Regulations).
 
The use of economic instruments for environmental improvement should be the responsibility of the Ministry of the Environment and not of the Ministry of Finance. This would ensure that environmental objectives and not fiscal ones are the primary objectives when such instruments are used
 
The Issues Paper added Cacopardo does not consider a number of important areas of action such as : Light Pollution, Environmental Impacts of Organisations, CSR, environmental nuisance, land contamination, the role of civil society and eNGOs in environment policy formulation, access to environment information and environment research.
            
AD considers that in view of the large number of vacant properties a moratorium on large scale residential development is long overdue. The regulating of funding of political parties would also ease the pressure of the building development lobby on politicians.  
 
Press here to download full AD paper

Environment Policy and the Budget

The National Environment Policy Issues Paper, launched by the Parliamentary Secretary for the Environment, Mario de Marco, on July 27 requested the views of the public on a move towards a taxation system that “penalises pollution rather than jobs”.

When launching the 2011 pre-Budget document on the same day, Finance Minister Tonio Fenech was more clear as to the government’s intentions. Under the heading Tax Shifting, he proposed the shifting of taxes from economic goods to economic bads. The pre-Budget document goes on to say: “In order to incentivise the creation of work by making labour less costly we are proposing the lowering of government-induced employee costs as well as corporate and income taxation.” The pre-Budget document then praises the merits of a carbon tax as a fiscal tool.

It seems that both the minister and the parliamentary secretary have forgotten that taxation does not penalise jobs. It is an instrument for the attainment of social solidarity. That is what the post-1977 Nationalist Party I remember was in favour of. It seems that time has changed the PN. It cannot be anymore described as being “un partito di centro che guarda a sinistra” (a party of the centre that looks to the left), as the old guard, quoting Alcide de Gasperi, justifiably boasted.

The drafters of the documents launched could have consulted the Cabinet-approved National Sustainable Development Strategy for the Maltese Islands (page 59), which established 2008 for the conclusion of a strategy on environmental taxation. The year 2008 is 32 months away and the strategy on the use of economic instruments to regulate environmental impacts is still not in place. Instead of asking for views of the public they should have drafted the strategy that has been promised but not delivered. It could be a useful guide for the finance minister.

At issue in this debate on tax shifting are points already emphasised during the eco-contribution legislation debate in 2004/05. Which ministry will be in the driving seat of environment taxation policy: Finance or the environment? Will the primary objectives of environment taxation be environmental or fiscal?

The strategy to be adopted and, thus, the specific proposals to be brought forward will depend on whether fiscal policy is used to regulate and reduce environmental impacts or whether the environment will be used to compensate for shortfalls in tax revenue.

After 17 years, the government has woken up to the proposals of a Jacques Delors EU White Paper in 1993 on growth, competitiveness and employment [COM (93) 700 final] who had the argued in favour of taxing environmental impacts and resource use.

In its 2008 electoral manifesto, the PN promised it will reduce income tax in the higher bands. It is now seeking ways to deliver without subjecting the Exchequer to further problems. It is very unfortunate that an inappropriate tool was selected. As a result of the tax shifting proposal, a tax, which is socially progressive (income tax) will be partially substituted with a carbon tax that, viewed on its own, can be socially regressive. The proposal aims to reduce taxation from a band which is paid mostly by companies and those who have a substantial income. To compensate for the resulting shortfall, it will spread the tax-load on everyone without discrimination, irrespective of their means.

Once the government decided on the reduction of the higher band income tax, I understand that it did not have much of a choice. In order to ensure a regular flow of income, which would have to substitute a reduction of the forfeited income tax, it had to select a subject in respect of which (at least, in the short term) demand is largely inelastic to tax-induced price changes.

It would be interesting if any studies on the impacts of the pre-Budget tax-shifting proposal are available. Such studies should clearly demonstrate the two basic flaws of the proposal: first it’s being socially regressive and, secondly, it’s exploiting of the environment as a tax revenue generator without ensuring environmental improvement as a primary objective.

If environmental improvement was a primary objective, the projected tax revenues would not be generated as they would be reduced gradually, in line with environmental improvement.

A carbon tax would force business and industry to address their environmental impacts. However, the impacts of a carbon tax on SMEs and households have to be assessed more carefully before policy declarations are made in view of the limited size of the former and the lack of resources of both. Given that most of Malta’s business is in the SME sector, matters should first be studied in their proper perspective before declarations are made or decisions taken.

There are various alternatives to the government’s proposals. Each one of them must however be tested through studies to ensure that the social and environmental impacts of fiscal policy are either positive or else substantially mitigated.

Studies made must be available at this stage. Otherwise, the discussions on both the National Environment Policy and the pre-Budget document would be just kite flying exercises.

 

published in The Times Saturday, September 4, 2010