Acct810 Issues In Taxation - Assessment Answers

Answer:

Introduction

With respect to the present scenario, the countries across the globe are trying, in one way or the other, to improve their economic as well as societal aspects. This is done in order to stay in constant competition with other countries. However, while giving importance to this competition several countries have started contributing towards various environmental issues like pollution, deforestation, waste disposal, overpopulation, etc. In order to deal with these growing environmental concerns, the governments of different countries are focusing on different environmental taxes. In this section the persisting environmental issues in New Zealand will be discussed. Along with the particular discussion, emphasis will be laid on the respective approaches taken by the country’s government in the context of environmental taxation.

A variety of taxation policies can be used by the government to reduce the level of pollution and other environment related issues to a greater extent. This proposed research paper has focused on the content “environmental issues and tax” in the context of New Zealand.

Among the 34 OECD countries and 5 partner economies, New Zealand has the 9^th lowest environmentally tax related revenue as a share of the GDP of the country. In the year 2014, the environmentally related taxes revenue in the New Zealand contributed about 1.34% of the GDP in comparison to an average of 2% contribution to GDP among the 39 countries (34 OECD countries and 5 partner economies). Similarly, in comparison to other nations, the taxes on energy in New Zealand represents 55% of the total environmentally related tax revenue. Whereas, in the other 39 countries the percentage is 70 on an average (www.oecd.org).

According to the online article on the proposed research content named as “Environmentally related taxes; taxes on energy use” by OECD, New Zealand is generally considered as the 9^th lowest environmentally related tax revenue company in terms of Share of GDP among 34 OECD labelled countries. In 2014-15, the environment related tax revenue of New Zealand was 1.34% of the total GDP, which was 2.5% of the total environmental tax revenues of 39 (35 OECD+ 5 Partner economics) countries.

From this online article, it can be understood that, in New Zealand, 29% of the total electricity is produced from the gas or coal fired power stations, from where, the idea of introducing “Green Taxes” has been developed. This paper also highlights upon the Tax Review, 2001, which stresses upon the formulation of such societal system or procedures, by which overall system or environmental scenario can be improved.

According to the OECD report (2014), it is evident that, now, environmental researchers have demanded for imposing tax on the polluters as increasing level of environmental degradation is inflicting pressures on the “green backyard” (www.oecd.org). According to Ericksen, “taxation on the environmental issues and pollution is far better than the taxes imposed upon the income rate of the population. If the environmental taxation base is enforced properly in broader society, it will make our environment a better place for living”. According to the current statistical data, New Zealanders are generally pay almost NZ$3 duty per week to the government on the basis of consumption of electricity, gas and the use of petrol; where the country is recognised as the first in the globe to introduce Carbon tax to keep control over the intensity of global warming (www.theguardian .com). According to Jacinda Ardern, the minister of New Zealand, responsible for climate change policy “if we want to tackle or keep control over the climate change, we have to start taking our environmental cost into vigilant consideration with respect to the economic choices we make”.

This entire research paper has devised by focusing upon the content “environmental issues and taxation”. The principal aim of this project is to emphasis upon the major environmental issues, predominant in New Zealand and on the corresponding environmental taxes.

This research work has been carried out with the objective of identification of the most predominant environmental issues in New Zealand and to address relevant environmental taxes. Along with that this particular research work has also aimed to evaluate all the beneficial influences of environmental taxation on society and the economy of New Zealand. Along with that the objective of this research work also includes the identification of the degree of governmental effort to maintain environmental balance of New Zealand via enforcement of Environmental taxation within the border society.

Research Questions

As the research aim and objectives have been already discussed above, there are certain research questions that can be framed based on the aims and objectives of the research study. These research questions include:

• What are the environmental issues that are predominant in New Zealand?
• How can the issues related to the taxes be addressed to?
• What are the benefits that are being received by the society or economy of the country due to the environmental taxation?
• To what extent is the government making efforts to maintain environmental balance in the country via the enforcement of environmental taxation within the border society?

Rising environmental pressures in New Zealand-OECD research 2017

Since 1990 the emission rate of New Zealand has been rapidly growing. The annual rate of this growth is almost 23%. The situation of New Zealand has become a major concern for this OECD because till now 80% of New Zealand electricity is generated from 80% renewable sources but even after that New Zealand is facing such kind of emission hike. In order to deal with such unexpected incidents, the government of New Zealand have reviewed their climate policies in such ways so that the level of carbon emission can be managed accordingly but still the environmental requirements have not been fulfilled. A range of research on this, has identified that the population of New Zealand has to be made much more aware about environmental imbalance and that their restricted social and economic behaviours can make the situation better. In order to increase awareness among the population of New Zealand, a range of environmental taxes have been implemented by government.

Green taxes: An initiative of the New Zealand parliament

This was the most fruitful initiative of New Zealand government regarding environmental pollution. According to these taxes, the population of New Zealand has to pay various kinds of charges for different social and business behaviours such as using of raw material or process that emits carbon, production of goods that generate CFC, effluent and emission from vehicle driving etc. However, in order to detect the amount of such taxes a range of instruments are used and those include the following;

Economic instruments : This type of instruments is comprised of various kinds of additional charges, subsidies, financial enforcement incentives etc.

Regulatory Instruments: These include various kinds of legislation that direct and limit the use of various kind of material that has been marked as pollutants, use of process that facilitate environmental pollution etc.

Suasive instruments: These include legislations that have been implemented in order to increase the awareness among the population New Zealand.

As a result of the green taxes, the producers or consumers will use lesser quantities of such substances thereby lowering the level of pollution. The key theory behind this application is that producers lower the use of those substances upon which taxes have been levied. If the producers are unable to do so, then they will experience reduction in their revenues or profit margins as the customers will refrain from expending on such highly priced products. It must be noted that the extent up to which the taxes reduce the pollution creating depends on certain factors. Often the circumstances do not turn out to be favourable for the producers and consumers. They may not be able to find out any alternative option on affordable price.

Changes in environmental taxes and its impact

According to the politician Sir Michael Cullen, the changes in the environmental taxes to be brought about by the tax working group can result in the lowering of the GST. The tax working group is deciding to apply certain changes to the tax system. The changes are to be applied after the elections of the year 2020. There are chances that some new taxes will get introduced along with the modification of some exiting taxes so that the increment in taxation can be controlled and that will be carried out through lowering of GST^8. Environmental taxes have been levied on water consumption, usage of petrol and disposal of wastes on the landfills.

Presently, New Zealanders pay an extra NZ$3 as a levy per week upon consumption rate of electricity, gas and petrol to the government. According to the provisions of the taxation policy in New Zealand, the business sectors or the organisations have to pay almost NZ$11 duty per metric tonne of carbon emitted, to the government.

Kyoto Protocol: It is an important international Treaty; formulate with the aim to reduce the rate of emission of greenhouse gas. This treaty has two parts: first one is completely based upon the prevalent rate of global warming and second part includes human-made carbon dioxide emission which is considered as the principle reason for global warming and environmental degradation. In order to highlights upon the impact of Kyoto protocol on the environmental issues in New Zealand, it can be said that, after this agreement, the price of the polluting energy sources like oil, coal become more expensive than the cleaner ones or natural energy resources like natural gas, hydro energy, biogas and so on.

Environmental tax can be considered as a tool, which includes both the incentives for the investment on clean and eco-friendly technology and penalties for continuing environmental degradation by the polluters, in New Zealand.

Environmental legislations of New Zealand:

In order protect some rare species of New Zealand this Act was introduced in 1953. According to this act if an individual violates the session of this act then accused individual will be punished by charging NZ $ 100,000. This Act is divided into total of five parts and part 1 is subdivided into 6 schedules. All theses schedules ensure that the species that are enlisted under the list of rare species according to New Zealand government can’t be hunted or eaten. Not only that the key objective of Part 1 of this act is to classify the all available wildlife species of New Zealand into different category to make the legislative action more specific and easily identifiable. The 7 classifications are ‘Wildlife declared to be game’, ‘partially protected wildlife’, ‘wildlife that can be haunted or killed in accordance with the situation’, ‘wild life not protected, except in areas and during specified in minister’s notification ’, ‘Non protected wild life’, ‘Animals declared to be noxious animal subject to the Noxious Animal Act 1956’ and the last one is the ‘Terrestrial and freshwater invertebrates declared to be animals’. Section 7 that means the legislations about freshwater vertebrates was amended to 7A and according to that marine species were also declared as animals.

Analysis of social and cultural life of New Zealand it can be seen that bird hunting is considered as a traditional game in New Zealand society, hence in order to preserve the birds Part II of this legislation have outlined a range of provision under which the game birds can haunted. However in order to ensure well-being of New Zealand population of bird species Part II, IV and V have also been included under wild life Act and that focus on administrative matters, dealing with injurious species of birds and general provision for ownership and preservation of various wildlife specimens.

In Incorporated v Director-General of Conservation Case [2017] regarding wild life has been raised few years back. Shark cage diving is one of the most popular water game in New Zealand and PanuaMACC5 is the most popular commercial fishing organisation that arranges such diving for interested individuals. However as with increasing numbers of cage drivers this area is getting riskier regarding shark attack, due to which some sharks have been killed in order to save human life. The PaumMAC5 authorities have argued that they have killed those sharks according to the permit issued under S 53(1) under the Wildlife Act which allows the Minister to authorise any “catch alive or kill” of protected wildlife that was granted in December 2014. However, some judges of this case argued that the shark cage diving falls under the offences session that means S63 and 63A session of Wild Life Act. According to S63 and 63A, cage diving disturb the life of shark which was established from the case of Solid Energy New Zealand Ltd v Minister of Energy [2008]. After long arguments the Cage diving activity of New Zealand has been finally regulated under Marin Mammals Projection Act 1978.

This Act set out the functions of ministry for environment that includes management of natural as well as physical resources of New Zealand. The legislation associated with this act controls the use and access of hazardous substances, reduction of natural hazards etc. the session associated with this act classify the hazardous in terms of natural and artificial, not only that this also regulate a range of policies that provide the scope of penalties and legislative obligation in terms of hazardous material usage, production and accesses or even the cases of environmental balance violation.

This is the case law that was associated with the interpretation of Resources Management Act 1991 (Environmental Defence Society Incorporated v The New Zealand King Salmon Company Limited & Ors [2014]). The reason of this case was that Marlborough sound resource Management plan of King Salmon Co Ltd got changed and appealed for undertaking some sites those are under government prohibition in terms of resource use. His appeal was argued by the Supreme Court of New Zealand on the basis of 67(3) of RMA that required proper regional plan to access those prohibited areas for resource usage. Finally their appeal was rejected in 2014 by Supreme Court as this would provide “adverse effect” on environmental balance of those area.

The Aoraki Water Trust v Meridian Energy Ltd [2005] 2 NZLR 268, can be referred to in this specific context regarding the principle of non-derogation from grant. In this case, it was held by the court that it would have been an unlawful matter for the concerned authority to grant for the permission to another operator regarding a water permit where this resource was allocated in full and added to that doing so would also in turn reduce for the total amount of water that was available regarding the satisfaction of the consents that were then presently. Although this case is concerned to the property but the same also brings about the concern for the respect for the value of the natural resources as per the laws in the New Zealand and that brings about the concern that the resources are planned to be effectively used within the nation which is a better sign towards the development of the concerns of the environment.

Also in the Quarantine Waste NZ Ltd v. Waste Resources Ltd [1994] NZRMA 529 the permission was granted to the Waste Resources Ltd regarding the usage of the excess capacity of the carbonize the waste from even outside the premises of the airport with subject to certain restriction. The authority that provided for the consent in this case was however much sure regarding the fact that the adverse effect of such activities would be very minimal in regards to the hampering of the environment. But the Quarantine Waste felt that this would in a manner affect the environment and brought the entire decision to be judicially reviewed. Also, in case of the Rural Management Ltd v Banks Peninsula District Council, the appellant started discharging the sewage into the sea water some years prior to passing of the Resource Management Act of 1991. But with the advent of this act, this entire activity of discharge of the sewage was cancelled as that harmed the environment in turn.

Bio security act, 1993 is a legislation enacted by the parliament of New Zealand before any other country. The main objective of this statutory legislation is to remove and eradicate pests and other unwanted organisms which might be harmful for other living organisms by effective management of the same. The provisions incorporated in the Act provides the mechanism of preventing unwanted and harmful organisms entering any region, undertaking various surveys for the purpose of detection of these pests once they had already entered and implementing measures to fully eradicate them or make them ineffective. It also undertakes steps for the development and flourishment of management plans for pest control. The bio security functions are divided MPI, governmental agencies and departments and with the regional councils. At present in New Zealand very few regional councils are operating who are undertaking the role of monitoring and preparing pest management strategies.

In this case during the year 2010 there was an outbreak of bacteria named Psa in Te Puke, New Zealand. These bacteria infested two neighbouring kiwifruits orchards. Due to its outbreak in New Zealand the kiwifruit industry was getting hugely affected. At the initial stage of the infection the orchardists tried their best of eradicating the bacteria by undertaking various measures but all such measures went in vain (Strathboss kiwifruit limited vs. Attorney general [2018]).Then the government decided to compensate those who had suffered losses due to this infestation. But the damages were not adequate in nature so the plaintiffs of the case instituted a proceeding against the government due to the incursion of Psa. They contended that MAF had an express authority and duty to take reasonable care while permitting the kiwi pollen from china. The rules and regulations were not followed clearly by the concerned authority. Under the Act it was their responsibility to protect the New Zealand’s border. On the other hand the crown contented that they were under no duty to take care towards the plaintiff as Bio security issues are not the appropriate kinds of allegations for which the crown can be held responsible. Ultimately it was held by the judge that MAF did had the duty to take the reasonable amount of care and that there was negligence on the part of the authorities actions. With the entry of this kiwifruit vine disease the impact on the industry was very devastating as a result of which the kiwifruit growers have run into huge losses so ample amount of compensation needs to be granted.

The conservation Act 1987 was usually promulgated for the purpose of protection and conservation of New Zealand’s natural resources along with the varieties of flora and faunas developing in the region. Under this Act different departments are established in order to undertake the process and functions of conservation which were formerly done and controlled by the governmental agencies. The Act has defined the areas which are to be conserved specifically in the interest of the development of the country. Part IV of the Act categorises the areas that are to be protected and preserved, sections 18 – 23 deals with the same. The main area over which the Act focuses is the preservation of the indigenous fisheries and adopting measures for the purpose of recreation.

In this case an appeal was put before the supreme court of New Zealand regarding the revocation of the special conservation status of a portion of the Ruahine Forest Park (RFP) given by the director general of conservation department for acquisition of more land for the purpose of the Ruataniwha Water Storage Program. The land that was revoked forms part of the conservation park allotted under the conservation act 1987. The appellate court went for the judicial review of the judgment given by the high court (MERIDIAN ENERGY LIMITED V CENTRAL OTAGO DISTRICT COUNCIL And Ors HC DUN CIV [2009]). It was concluded that the decision was not rendered at par with the conservation Act and directed the director general to set aside the previous decision as it was considered ultra vires. A central inquiry was instituted to declare the purposes for which the power of revocation of the special protection can be exercised. It was held by majority view that in order to exercise the discretionary power of revocation of special protection the director general is first required to judge and verify that the land which was previously under the scope of special protection under the Act does not require any more further conservation which was not done in this case. Hence the decision rendered formerly for the expulsion of the park area was set aside with the additional task on the part of director general for reconsideration of the issue.

Resource Management Act, 1991

The resource management act 1991(RMA) was passed in the year 1991 in order to promote the sustainable development and progress of the environment in New Zealand. It is one of the significant acts that were being developed to keep a check on the environment and natural resources of the country. The RMA Act provides the mechanism of an integrated framework which is different from the processes that were previously followed for the purpose of environmental resources protection. With the incorporation of an integrated framework all the policies, rules and regulations are completely focused at raising the standard of the environment. The RMA Act provides all the necessary legislations for the purpose sustainable management of resources relating to water, land and coastal regions, preserving the landscapes historic heritages etc.

In this present case, meridian energy limited is one of the state owned enterprise and a popular energy company, for the purpose of resource consents applied to the central Otago district council (COCD) in order to get a permission to operate a substantial wind farm to generate electricity in central Otago. Eventually consent was granted to the company (MERIDIAN ENERGY LIMITED V CENTRAL OTAGO DISTRICT COUNCIL And Ors HC DUN CIV [2009]). Aggrieved by the decision of the court the other respondents of the case appealed to the environment court. The decision of the environment court didn’t went in favour of the company and the project was declared to be incorrect under section 5 of the RMA Act 1991 as it was not complying with the features of the sustainable management. Against this decision of the court meridian went for an appeal under section 299 of the Act alleging that the environmental court’s decision was not in accordance with the provisions of the act. Under the second appeal sought by the company the adverse judgment of the court was set aside leading to reconsideration of the facts once again by the concerned court. Ultimately the final decision was rendered on 6 November 2009. Two points were discussed in the final judgment that is the economic reasons and viability which implies specific costs and benefits of the proposal and any matter of national importance under section 6 of the Act. The conclusion of the court stated that the company has to give a cost benefit analysis in which non market techniques are to be used and put up a plan which complies with the provisions of the act.

Lower Waitaki river Management Society Incorporated vs. Canterbury regional council

In this present case efficiency of under section 7(b) of the RMA Act is analysed. The provision under this section requires an authority to provide consent regarding the use and applicability of the relevant resources with their existing benefits and costs (Lower Waitaki River Management Society Inc V Canterbury Regional Council [2010]). If this process is not complied with then the consideration of the benefits of resources involved through artificial weighing under sections 5 to 8 of the Act will be of no use. Hence in order to be in proportion of the statute this cost analysis very essential.

Also we can take a considerable look at the Hampton v Canterbury Regional Council (Environment Canterbury) [2015] NZCA 509. This was the case where the appeal was made by Simon Moffatt in the High Court against the decision that granted the cousin of Simon Moffatt, Robert Moffatt the specific right to take and utilize the water resource to the extent that the water rights of Simon Moffatt regarding the irrigation of the farmland of Robert Moffatt were not at all exercised. However, contrary to the case that is mentioned above, this time the appeal was reject and the court emphasised for the fact that while proceeding with the application of irrigation of both the land of the appellant and that of the land of his cousin, it was much inconsistent for the appellant to argue for the fact that even his consent must be varied regarding the land of any other third party.

Also in regards to the impacts on the environment in New Zealand, the WEST COAST ENT INCORPORATED v BULLER COAL LIMITED [2013] NZSC 87 can be referred to. In this case, the Buller Coal Ltd. and Solid Energy Ltd. applied to the Buller District Court and that of the West Coast Regional Council regarding getting the consents for the resource as mentioned within the Resource Management Act of 1991 for being able to mine the coal resources for the purposes of continuing the exports. However, the Supreme Court had dismissed this specific appeal citing to the fact that 2004 Amendment Act prevented the consent authorities regarding taking into the specific account regarding the indirect discharges of the discharges of the greenhouse gases regarding providing the consent for the applications that are associated with the consents for the resources.

Research Methodology

The research has been done based on the available information on the environmental taxes of New Zealand. This is a secondary research and different articles; reports and journals have been studied in order to prepare the report for the research. The exploratory research method has been used for this research and every topic related to the research study have been explained and detailed. The researcher has also included the details of many acts which are associated with the topic of the research study. The research philosophy that has been used here is positivism research philosophy as the researcher is an independent researcher studying the various data and information available on the environmental issues of New Zealand. The information that has been used here has been simplified from the information available in a proper manner so that the details that the research wants to convey clear, interpretable and understandable.

Analysis

According to the research paper “environmental taxation in New Zealand: what place does it have?” written by Frank Scrimgeour and Ken Piddington, in order to get positive environmental impact, implication of environmental taxes on society cannot be denied. This review is based upon the 2001 Tax Review in New Zealand. The principle aim of this paper is to highlight upon, decarbonised the society in the context of environmental issues and current scenario of New Zealand. By analysing this paper, it can be understood that, in order to decarbonise the society, New Zealand government has the necessity to implicate climate policies within the country’s energy manufacturing sectors to curb the carbon-dioxide emission to a greater extent. This research paper mostly include the transport and agricultural sectors of the New Zealand, as the majority of the population of this country depend upon the dairy firm and agricultural profession and, the flatulence of the cattle or live stock are considered as the prime responsible for increasing the greenhouse gas emission up to 50%.

This above graph denoted that the agricultural sector of the New Zealand contributes 49% to the greenhouse gas emission. The extensive growth in dairy production, excessive use of sheep and cows or livestock for farming purposes can be considered as the major source to increase the level of nitrogen in soil and in the surface water to a large extent. By analysing this paper, it can be evident that, in order to restrain the level of water pollution and soil erosion, government of New Zealand has took initiatives of imposing taxes on the agriculture: “methane tax”, and “fresh water policy and corresponding tax”.

This paper emphasises upon the fact that, environmental tax reform has become an important political agenda in New Zealand, over past few decades, by using which government has taken several initiatives to limit the level of environmental issues to a large extent. From this research paper, it can be shown that, Kyoto Protocol has to be formulated with the aim to force most of the OECD countries like New Zealand to switch over to new technology or mechanism for industrial production purposes. This in turn can limit the emission of the Greenhouse gases to a greater extent- the fact of Carbon tax has also mentioned in this article, from where, it can be comprehended that, almost NZ$11 taxes is usually paid by every transport and industrial sectors of the New Zealand to the government on the basis of the per metric tonne carbon emission.

With respect to the paper “Is There A Future For Environmental Taxes In New Zealand?” published by Lisa Marriott, New Zealand is becoming vulnerable to changes associated with climate due to the noticeable rise in the sea level³⁵. Also the country rely on agriculture the most, a sector which is criticised to be a major contributor of greenhouse emissions. This particular paper has tried to discuss about the strategies that can be used by New Zealand for dealing with its emission problems. According to the author of this paper there are several other reasons besides climate change because of which emissions have to be controlled these reasons are fatal health conditions. This paper has identified that up to this date the country have not taken adequate measures for dealing with these factors. The first research question in this work has discussed what knowledge can be gained by New Zealand from the initiatives taken by European countries in dealing with the emission via tax incentives. The second research question in this paper has highlighted the fact that what initiatives New Zealand have to consider for reducing their greenhouse gas emissions. This particular study has analysed the various tools implemented by UK, Norway and Ireland for reducing the emissions and encouraging the use of low-emissions vehicles. On the basis of this study an argument has been produced that it is necessary for New Zealand to take strong actions for handling the climate changes and adopt tax system for encouraging the use of electric vehicles.

According to this paper New Zealand has shown reluctance towards the adoption of tax system for initiating change behaviour. This research work has discussed the climate change policy and the current environment policies used by the country. But it has been identified by the paper that the approaches taken by the country is not adequate. The paper has five sections discussing the approaches of European countries and comparing them with those of New Zealand. In the last section the paper has suggested that New Zealand has to make suitable use of tax system for improving the emissions as its transport sector is quite weak when compared with other countries under OECD.

Conclusion

From the above discussions and findings inference can be drawn that environmental taxes perform a strategic role with respect to the promotion of sustainable development of a country. This fact can be supported by stating that environmental taxes are potential enough in achieving environmental targets. This also ensures for increase in revenues which in turn will integrate the economic and environmental goals. It is very much important to design the environmental taxes in an appropriate manner so that they do not result in imposing costs which may negatively affect the potential benefits. In this paper the environmental issues faced by New Zealand has been discussed. The gradual degradation of its environmental condition is noticeable enough. Proper environmental taxes are the need of the time for the country. All relevant sources of information is of the opinion that properly designed environmental taxes are lot more reliable for preventing the degradation rather than any other environmental policies. Initially the country has led out plans for reducing their contribution towards the environmental issues. After the signing up of the Kyoto protocol taxes to be levied on energy sources like oils and coal have been decided. Currently the average tax rates with respect to transport fuels are higher for New Zealand approximately 5.75 EUR per GJ. The average tax rates on coal amounts to 0.06 EUR per GJ. The green taxes were not previously implemented and the methane tax was also abandoned due to the criticism on the part of the farmers. But the present scenario of New Zealand has changed. With respect to the data of 2016 the environmental taxes has amounted to $4.9 billion from $1.6 billion since the year 1999. The environmental taxes of New Zealand are mainly made up of transport and energy taxes. Presently the energy taxes have increased to $2.5 billion and the transport taxes have increased to $2.3 billion. However the resource taxes and the pollution taxes have decreased over the years. Now they only form 2% of the environmental taxes. These days New Zealand’s contribution towards environmental degradation has declined to a considerable amount. The country now solely depends on the use of renewable resources for energy supply. However it needs to focus on certain other aspects that have started becoming a concern for New Zealand. Its farming sector is resulting in becoming a threat to the environment. The agricultural and farming activities of the country are harming the standard of quality of water and soil. They are also contributing to greenhouse gas emissions. Thus it is required by the tax working group of New Zealand to expand and improvise their environmental tax system for dealing with the present environmental issues.

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