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Chapter 4: Monetary flow accounts

Draft chapter:
Cover note:
Comment template:
Posted on:17/06/2011
Deadline for comments:29/07/2011
Number of comments:31

Comments from the global consultation
Posted onProvided byComments
02/09/2011UK/Office for National StatisticsPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
We are happy with the balance of the chapter and specifically the section on the link between EPEA and EGSS is very helpful. It would be useful to have some indication up front of how mature the various accounts are internationally, EGSS and subsidies being less developed.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. Resource use activities might be measured separately to provide context but if should not be classified directly as ‘environmental'' alongside environmental protection and resource management.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. Though reference to internationally available handbooks may be a useful addition.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. Significant amounts may be assigned for subsidies and grants for energy or transport projects, for example, a small element of which may be environmentally related. It could potentially significantly overstate the case to include the full amount of the payment, masking other transfers and resulting in limited usability of the accounts.
  Part III: Any additional comments including those of a more technical nature
Table A4.1 – EP classes – we have a continued user requirement to split out protection of ambient air from climate. Also the treatment of renewable energy activities remains unclear.
25/08/2011Latvia/Central Statistical Bureau of LatviaPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
No comments.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No opinion.
  Part III: Any additional comments including those of a more technical nature
No comments.
23/08/2011Israel/Central Bureau of Statistics IsraelPart II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Accounting for the natural resource use activities is important in order to be able to analyse activities in connection with flow of natural resources, however, the activity should be separated from the other three activities and perhaps another heading than "environmental activities" could be found. It is disappointing that energy from renewable resources and the treatment of activities associated with energy saving can not be incorporated in the classification in order to obtain international comparability. Even though the structure of energy supply in each country is different, it seems that certain types of renewable energy may be found in many countries.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
The wording of almost the whole section on the purpose of the EGSS is not clear. It would help to write "set of statistics on the Environment Goods and Services Sector" in stead of just "Environment Goods and Services Sector". Something should be said about the criteria for inclusion in the EGSS – since there are also non-specialist producers, is there a lower limit for the share of production of EGS to be included? The comparison between EGSS and EPEA is adequate,
  Part III: Any additional comments including those of a more technical nature
Under valuation of goods in par. 66: "if there is also a reduction in the associated future energy bills this reduction should be offset against the cost of the equipment and only the net cost of environmental protection should be recognised." - such an estimation seems very difficult to make. "Adjustments for intermediate consumption of specialist producers": it is not clear how such specialist producers are separated, and whether something else is necessary – in par. 67 it says: "In principle this adjustment should also be made in relation to the intermediate consumption on environmental protection services used by non-specialist producers to the extent that these services are used to produce and sell environmental protection services on the market." Financing environmental protection – the concepts could be clarified better, f.ex. is the wording in par. 73: "Many of the specific transfers will be subsidies and investment grants" confusing, since transfers and subsidies are two different concepts (at least in SNA), or in par. 74: "transfers paid for international cooperation in the field of environmental protection", since transfer means that there is no quid pro quo.
23/08/2011UNESCWAPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
Good.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. Environmental Protection groups and classes Table 4.2 page 38: Group 4: Protection and remediation of soil, groundwater and surface water: -Add category 5. Protection of Groundwater and surface water. This should be separated from soil to be more consistent with Assets accounts and to allow better analysis for the protection and management of water resources -Add category 6: Protection of coastal and marine waters (it might be under protection of landscapes but this category is important and should considered as a separate category.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes.
22/08/2011Sweden/Statistics SwedenPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
We appreciate the chapter on economic transfers and regard these parts as very important for the SEEA. The comments made in the consultation are all of interest to us and we thank you for putting them up on the web. We would like to support the comments by Eurostat and by Germany in particular as we found them very helpful. We would like to stress one specific note on the terminology, which is also further discussed below. Please consider that many, but not all, of the transactions that we measure have an environmental purpose and can thus be regarded as ‘environmental''. It is however just as important to realise that these transactions are often small compared to other transactions with a clear relevance for environmental issues, but whose purpose can be regional development or similar. Therefore, the tem "environmentally related" must not be used to mean "environmentally beneficial". This is something that is already established in the environmentally related tax definition which is not purpose defined, and it is important to maintain this distinction.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. We think that the resource use activities of natural resources is already covered in the economic accounts, and that it is confusing to label these flows ‘environmental activities''. In general, the text does not really show that the resource parts of the transfers is still being discussed and developed and that few countries have actually tried this. The environmental protection expenditure is a mature area of statistics. Now these are being described as if they were on equal footing. However, we are still struggling to understand if there can be any statistics produced by these definitions. The attempts that we have done in using RUMEA and Cruma for statistical purposes in the Eurostat Task Force leaves us with very mixed feelings. For example the management of forests cannot be divided into environmental and resource use management parts. In general we find that the distinctions between areas cannot be done. Therefore we suggest to leave this difficult area out of the suggested classification.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
No. We appreciate the text as a conceptual description of how the EPEA and EGSS in theory links to the SNA. The description is a nice contribution to give some background to the purpose of these extensions. However, we are at the same time worried by the amount of detail in the tables 4.3.1-4.3.4, as they easily give an impression of data quality that we cannot match in the statistics. For the standard to work as an introduction for countries that wish to implement the SEEA, the tables are likely to over emphasise the need for new and complicated questionnaires. Since you are asking about the EGSS statistics rather than the theory, we would like to take this opportunity to say that we avoid the EPEA and concentrate on the EPER statistics. We would appreciate if there could be a move towards making a "SEEA for dummies" that we ourselves could recognise as close to the statistical practices.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. [comments attached]
 Chapter4-Sweden1.pdf;   
  Part III: Any additional comments including those of a more technical nature
[comments attached]
 Chapter4-Sweden2.pdf;   
10/08/2011Malaysia/Department of StatisticsPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
Acceptable
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No comment
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
No comment
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No comment
  Part III: Any additional comments including those of a more technical nature
1. The Department of Statistics Malaysia (DOSM) has no experience in developing any environmental account using the SEEA framework. However, DOSM is currently collecting data on environmental protection expenditure and trying to develop one of the SEEA account. 2. DOSM face constrains in developing this account with lack of expertise in this field. 3. DOSM also wants to learn in detail how to develop the SEEA account. Please inform and include us if there is any training/workshop to be conducted in future. 4. Therefore DOSM is unable to contribute fruitful comments for the revision of the SEEA at this moment. However, DOSM would like to be involved in further development of this matter.
03/08/2011U.S. Bureau of Economic AnalysisPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
In general the coverage and balance are good. We have the following comments regarding missing content: 1. The draft of chapter 5 introduced the concept of "environmentally related assets," (hereafter "ERA") stating "There is also interest in economic assets that have a role in activities associated with the environment, so called environmentally related assets. These include assets relevant to the extraction and harvest of environmental assets such as oil rigs, water dams, cutting and drilling equipment, mineral exploration and evaluation expenditure; assets relevant to the undertaking of environmental protection and resource management activities and certain financial instruments. A discussion of environmentally related assets is included in Chapter 4" (from paragraph 41 in the draft f chapter 5).However, neither chapter 4 or 5 provides a definition for ERAs. A definition for ERAs is required, and a discussion of the boundary between ERAs and other assets needs to be introduced. It is clear from the discussion that the intended definition of ERA overlaps both economic and environmental assets as defined in chapter 5. However, the lack of a definition means that is it difficult for a third party to infer whether a given asset can be considered an ERA according to the SEEA. We have the following comments regarding structure: 2. There are a few terms that may create confusion. For example, in many places the chapter describes the "supply" and "demand" perspectives of measuring the EGSS. This terminology is potentially confusing given that the term "supply" is used elsewhere, most notably for "supply and use" tables. To avoid confusion, we suggest the "production" and "expenditures" perspectives of measuring the EGSS be the adopted terminology. 3. The structure of some tables is misleading. For example, table 4.3.4 ("Environmentally related goods and services sector") contains the item "Total output", which is the sum of environmental goods and services and "other output". However, a reader is likely to take "total output" to mean the total output of the EGSS, given the title of the table is "Environmentally related goods and services sector."In addition, it is unclear what the category "other goods and services" entails. Does it include only the non-EGS produced by enterprises that also produce EGS? Or does it include all non-EGS output from the entire economy? Without such clarity it is not clear what total output is intended to capture 4. The chapter should be definitive regarding what and what is not covered in the SEEA. For example, it should be stated in §138 that compliance with the SEEA guidelines does not include the measurement of potentially environmentally damaging subsidies.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No opinion. We defer to the UN expert group on classifications regarding final adopted of the CEA classification system.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. Provided other goods and services are not included in the EGSS from table 4.3.3. See our earlier comments
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. The proposed classification is contingent on determining the government''s intent. E.g. §131: "Thus, a subsidy or similar transfer should be considered to be environmentally related when the intent or purpose of the government is that money be used for either environmental protection or resource management purposes."The chapter should discuss how the statistician can validly discern the intent or purpose of the subsidy.And in the case of a subsidy with multiple intentions then some method of allocation must be determined.
  Part III: Any additional comments including those of a more technical nature
1. We are concerned that the term "negative effects" in the definition of environmental protection activities may be open to interpretation. We suggest it is changed as follows § 17: "Environmental protection activities are those activities whose primary purpose is the avoidance of the degradation of the environment from economic activities." The term "degradation" is defined and used elsewhere in the SEEA. 2. We do not understand the use of the term "media" in§ 17: "monitoring of the quality of the environmental media". Please clarify. 3. The purpose of § 28 is unclear. 4. § 46 "Measuring the financial exposure of an economy to environmental protection helps to …" is unnecessarily suggestive of risk. We suggest "measuring the amount of production of an economy for environmental protection helps to …" 5. The definition of environmentally-related taxes includes "proven, specific negative impact" on the environment. The chapter should point out however that authorities in different countries take different positions on what substances are and what substances are not pollutants. This is very common in health standards, for example. This may then undermine cross-country comparability. 6. § 161 states that the SEEA will defer to the SNA treatment of tradable permits. However there is no statement in § 161 iii b that the discussion here is for non-tradeable permits. 7. § 119 deals with the case where a VAT tax is levied after an environmentally related tax is levied, and states that "the relevant amount of VAT (equal to the VAT rate multiplied by the amount of the environmentally related tax) should be considered to be an environmentally related tax." The environmental tax is defined in § 113 as a specific (i.e. per unit) tax, and thus there should be a one-to-one correspondence between the recorded tax amount and the physical quantity of units sold. (That is, if the tax is $1 per litre of gasoline, and 100 litres are sold, then the total tax amount due to the excise tax is $100, regardless of the VAT tax rate.) However, the proposal in § 119 breaks this one-to-one relationship since the VAT tax rate affects the amount of recorded environmental taxes.
03/08/2011Germany/Federal Statistical Office & BfN – Federal Agency for Nature ConservationPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
Chapter 4 is well structured. In each of the parts of the accounting (EPEA, EGSS, environmentally related transfers and similar flows, other transactions) it focuses on the main aspects. Highlighting the relationships between EPEA and EGSS (Section 4.3.4) is helpful. However, important aspects remain unclear or partly contradictory. For example it remains open to what extent expenditures for resource use (among others for exploration and extraction of oil and natural gas) are to be included into the accounts (for further details see the following questions). In addition, for compiling detailed accounts more information will be necessary by way of handbooks, compilation guides or the like. As compilation guides exist for European purposes (for EPEA, EGSS, Taxes) this should be mentioned. We support the proposals made by the European Commission/Eurostat.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. We are against the inclusion of RU into environmental activities. Environmental activities should comprise of activities that are environmentally beneficial. The EP and RM do meet this criterion, but the expenditures for RU activities such as mining, oil extraction or harvesting of timber are usually damage the environment. Therefore they should be left out of the scope of the SEEA, especially since they are covered by the economic accounts. Expenditure to spare or save resources are part of RM We strongly support the statement and proposals made by the European Commission/Eurostat concerning this point. Besides, we do not agree with the proposal of the treatment of borderline cases. According to the proposal activities related to energy saving/renewable energy production can either be classified EP or as RM depending on the main purpose of the activity or the main policy concerns. This seems rather difficult to assess and also may lead to statistics that are not comparable between countries. We therefore would propose to opt for one of the possibilities. (§13,14 of Annex A4.1) The same is valid for waste incineration (§ 16 of Annex A4.1). Make a definite choice how to classify this activity in order to allow international comparability.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. However, with view to EGSS please note the general comments in Part I concerning the need for compilation guides. Section 4.3.4 rather describes the differences than the links between EGSS and EPEA. The differences are comprehensible. Again, we would like to support the proposals made by the European Commiccion/Eurostat concerning this question. To prepare the ground for the SEEA Experimental Ecosystem Accounts it would be favourable to include an indication of the differences between Environmental Goods and Services and ecosystem goods and services. It should be mentioned that ecosystem goods and services, e. g. climate regulation, water purification etc., exist but that, due to the limited stage of knowledge, they are not referred to in the SEEA core accounts.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. The main purpose should - as generally in statistical classifications - be the guiding criterion. Section 4.4.4 does not state clearly how to deal with payments for which the primary purpose is not an environmental one. We do not agree including this kind of payments into the accounting. While compiling an environmental share of a multi-purpose payment seems to be not feasible in practice, it does not make any sense to us to include the total amount of a payment which has a secondary, tertiary or even less important environmental purpose. Still we do support the measurement of payments with environment as the main purpose on the basis of their total amount. In section 4.4.3 on environmental taxes it is stated that "In practice, the ability to isolate this amount of VAT may be difficult depending on the breadth and complexity of the VAT system" (§ 119). Possible solutions for this problem would be very helpful for the compilers and should therefore be included into the section.
  Part III: Any additional comments including those of a more technical nature
§17: Add "restoration" and "ecologic functions" and "ecological entities" in "(…) the preservation and restoration of ecological entities and landscapes including their ecologic functions; monitoring of the quality of the environmental media and ecological entities and the research and development (R&D); (…) §18: Add "biodiversity" and "restore" in "(…) the replenishment of natural stocks of resources (incl. biodiversity and landscape), and the general management of natural resources. The management of natural resources includes activities such as monitoring, control, surveillance and data collection. Resource management activities also include the production of goods and services to manage, restore and conserve natural resources." § 30: Instead of "characteristic products" Eurostat uses the term "environmental specific services" in its handbook on EGSS, which is more straight forward. § 31: The Eurostat handbook on EGSS is more explicit about the definition of a connected product: "In the case of EGSS, a connected product directly serves and has no use except for environmental protection." In EPEA is given a rather similar definition: Connected products are products whose use by resident units directly serves an environmental protection objective but which are not characteristic services. A list of connected products has to be drawn up for each domain." Products from the preliminary list are e.g. catalytic converters, septic tanks or rubbish containers. We propose to use one of these examples instead of the car for RM. (See also comments from Eurostat). In general, it should be emphasized that only those components are to be measured that directly prevent, reduce, eliminate… pollution and can be identified as a final product. The information on how to deal with households should also be introduced in chapter 4.3.2 (§45ff) on EPEA. See for example chapter 2, § 103. §73: Include Non-profit institutions serving households (NPISHs) in "Many of the specific transfers will be subsidies and investment grants where government is the payer of the transfers and it is industries, NPISHs or households that benefit." §78: There is only a very slight difference between i) and iii). This should be aligned. Concerning ii): what is "damage to waste" or "damage to noise"? An alternative wording could be: "ii) repairing damage to air, water, soil, biodiversity and landscape" Waste and noise activities need not be mentioned here while they are included in iii). § 80: Adapted goods might be relevant to the EGSS in specific countries, such as developing countries. In Germany we focus on environmental technologies ("characteristic and connected products"); adapted goods are beyond the scope of our survey. To our understanding, the international comparability of data on EGSS regarding adapted goods might be even harder to achieve than is already the case with environmental technologies. The definition of adapted goods is less harmonized. § 95: An explanation on the valuation of integrated technologies is necessary here. A4.1, §6: Add explanation in brackets in "With reference to the "functions" of environmental assets, environmental protection (EP) activities preserve and maintain the sink and service functions (supporting, regulating, provisioning and cultural services) provided by all kinds of environmental assets covered by the SEEA, except or the mineral and energy resources which are mainly relevant from the point of view of their resource functions.
01/08/2011Australia/Australian Bureau of StatisticsPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
This is a consolidated Australian response incorporating input from the Australian Bureau of Statistics, the Bureau of Meteorology and the Department of Resources, Energy and Tourism. Section 3 of the introduction states that a …"strong motivation…is to assess whether money spent on improving the environment is being used effectively.. and different policies may be compared and contrasted". The draft chapter appears to provide fairly comprehensive framework environmental activities, goods and services, but is essentially restricted to expenditure and transactions relating to protection of assets. There is little if any reference to quantification of the accrued improvements in environmental services from investment. There is also no attempt to value the total environmental services being provided by the assets. It is therefore unlikely that the objective stated above can be achieved in its current form. To provide the necessary context and ability to assess the impact of investments, the assets will need to valued in terms of their capacity to provide goods and services; actual physical yields and the changes in physical yield of those services which can be attributed to the investment. Importantly, given Australia''s climatic variability it is almost a given that the majority of benefits will be accrued years to decades after the investment. Alternatively short-term seasonal or climatic variability may also mask accrued benefits, unless the changes in the extent or condition of the assets are adjusted "un-mix" climate or management signals. All of these factors must be taken into consideration.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes. These activities need to be clearly defined and separated from other environmental activities. Nevertheless, they are important activities in the context of natural resource use and changes to expenditures on natural resource use are potentially vitally important. Note that these activities must exclude those related to the harvest of cultivated biological resources.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes - Partial. The section adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA. But it is marred by a lack of complete clarity in defining EGSS e.g. Para 78 Points i and iii are very similar – can these be combined? Or else delete "reducing, eliminating" from point iii so that its thrust becomes one of ‘treating and managing'' Paras 80 and 81 These paragraphs presently look inconsistent – suggest that the key difference to emphasise is that adapted goods have been specifically modified to be more environmentally friendly.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes. Assuming that the environmental purpose is a significant motivation in offering the subsidy, then on practical grounds we support this proposal.
  Part III: Any additional comments including those of a more technical nature
Para 4 delete "in terms"; replace with "its discussion" Para 10 replace "Most" with "The principal" Para 14 Last sentence: What are "these issues"? – Are they "Issues related to classification of multi-purpose activities"? Para 18 Last sentence: change to "…manage or conserve…" The Australia agency responsible for energy and resources (Department of Energy Resources and Tourism) raised a number of questions here: (1) how do we define Replenishment of natural stocks of resources? – Examples would be helpful e.g. both water and CO2 occur naturally in geological traps, so if they are reinjected into similar strata, is this replenishment, or is restoration / rehabilitation of degraded land (i.e. a mine site) or ''replenishment? (2) Are expenditures aimed at improving efficiency of natural resource extraction (by, say, reducing the extent of mining overburden) part of expenditures aimed at ‘reducing the extraction of natural resources''? Para 21 Delete "while potentially very similar" Para 30 Delete "to those undertaking the activities" insert "or own use" Para 31 This example did not convince – Para 32 You say that characteristic and connected products are defined in section 4.3, but I could not find these definitions. Para 34 Second sentence: insert "relevant" before "set of producers". Last sentence, replace "are all of" with "comprise" Section 4.3 Change title to "Environmental revenue and expenditure accounts and statistics" Para 49 Last sentence: replace "in most cases" with "typically" Table 4.3.1 Given the importance / policy interest, suggest further split column "Specialist Producers" into "Government" and "Other". Delete existing stand-alone column "Government producers" Delete para 55. Table 4.3.3 Footnote "NR = not required" Para 61 Para simply did not make sense – is there a word or comma missing? Para 67 Place comma after "double counting" Para 71 Start third sentence with "Financing information" Para 74 We suggest corporations can also fund environmental protection. Para 76 Last sentence replace "parts of" with "reasons for" Para 107 Suggest start para with "Many of the mechanisms by which economic behaviour is influenced toward meeting environmental objectives involve payments to government…" Para 124 Second last sentence. From the perspective of the payer, the distinction is between payments as purchases of goods and services or taxes (not sales of goods and services)
29/07/2011Belgium/Federal Planning BureauPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
Sections 4.4 and 4.5 are presented as two different subjects. This implies that transactions concerning environmentally related assets are not to be considered as environmentally related transfers and similar flows. However, in section 4.4 rent, which is a transaction concerning environmentally related assets, is included. And in paragraph 108 in the introduction of section 4.4 environmental expenditure on fixed assets is mentioned as one of the environmentally related transfers and similar flows. Logically, section 4.5 should thus be part of section 4.4.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes [comments attached]
 Chapter4-Belgium.pdf;   
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. Overall the description is good. Some details could be improved. In paragraph 78 ii repairing damage to noise is shown as one of the purposes environmental goods and services are made for. What is meant here ? How can noise be damaged ? Or is the repairing of damage due to noise what is meant ? And does this imply that the production of hearing aids should be included ? I believe "noise" does not really belong in the list of environmental problems enumerated in 78 ii. Paragraph 86 defines a type of environmental goods and services called "sole-purpose products". The example given is air pollution control devices. According to the definition of end-of-pipe technologies such products could belong to this type of environmental goods as well, since the latter contain equipment produced for control of pollution. The fourth category, next to specific (or characteristic) services, environmental technologies, and adapted goods, is the category of "connected goods and services". These contain goods and services used for a specific environmental purpose, although they belong to a category of products that are not produced for a specific environmental purpose. An example is a plastic bin bag. Plastic bags are used for other purposes than throwing litter as well. Therefore it is not a characteristic good. It clearly is no environmental technology, unless of a very rudimentary sort. And it is also not an adapted good. However, its use is clearly connected to waste management, which is an environmental activity. Therefore, it is a connected good. Paragraph 90 touches upon the complexity of defining adapted goods. The major complexity is said to consist of the fact that such goods only exist in relation to similar but non-environmentally friendly goods. An aspect which certainly deserves mention in this paragraph is that what is an adapted good today will be the normal (non-environmentally friendly) good tomorrow. In other words, exactly the same good will be considered an environmental good in one period of time, and a non-environmentally friendly good in a following period of time. This implies that when all goods in the world are environmentally friendly, no adapted goods will exist, and the economic value of the EGSS of a country will be smaller than when part of the goods the world produces are non-environmentally friendly. This is quite a paradox. The inclusion of adapted goods in the definition of environmental goods implies that the definition itself becomes time-dependent. Consequently, only cross-country analysis is possible on the basis of this definition, or short run time series analysis in which the definition of adapted goods is fixed.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes. Multi-purpose environmentally related transfers are often impossible to distribute over the different purposes. In such cases there are only two options as far as registration in the accounts is concerned: or the transfer is entirely considered to be environmental, or the entire transfer is considered not to be environmental. If one of the purposes is environmental, the transfer should be included.
  Part III: Any additional comments including those of a more technical nature
In paragraph 17 a number of activities are enumerated. The following part is quite confusing: ...;monitoring of the quality of the environmental media and the research and development (R&D); and the general administration... This suggests that monitoring of the quality of R&D is an environmental protection activity. Instead it should read: ...;monitoring of the quality of the environmental media; and the research and development (R&D), the general administration, and training and teaching activities oriented... In paragraph 47 it would be handy to refer to the supply table as EPEA table B, the use table as table A, the supply-use table in which supply at basic prices is balanced with use at purchaser''s prices as table B1, and the financing table in paragraph 48 as table C. The following sentence in paragraph 47 is also confusing: The third table broadens the scope of demand to include all products purchased by those undertaking environmental protection activities. It is not all products purchased by every unit undertaking environmental protection activities which is added in table A, as rather the purchase of environmentally connected and adapted goods and connected services (next to the characteristic services) by each institutional unit. In paragraph 105 it should be mentioned that part of the environmentally related transfers are also part of EPEA. If not, it would be impossible to calculate the financing of environmental expenditure table. In paragraph 108 the first sentence would be clearer if some words (see italics) were added: In addition to payments to and from government there are other transactions, apart from those discussed in section 4.3, recorded in the... Paragraphs 139-141 concerning environmentally related transfers by non-government institutional units should not be part of section 4.4.4 which is entitled "Environmentally related payments by government".
29/07/2011Austria/Statistics AustriaPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
In general the chapter is well structured. But in comparison to the System of National Accounts the SEEA is related to methodological aspects characterized by vague wordings and recommendations. In contrast, it would be helpful to operationally outline an ideal and consistent concept and to provide additional information on methodological alternatives that should be given priority if the proposed approach is not suitable.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes.
29/07/2011Romania/National Institute of StatisticsPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
The chapter is globally clear, very well structured and balanced.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. We do not agree that natural resources – such as mining, oil and natural gas extraction, fishing and forestry – be included as "environmental activities ". We prefer to have expenditure on resources use out of the scope
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. The chapter explain very well the differences between EGSS and EPEA, but it will be interesting to put these differences into a table, or schema.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. The issue is of the information sources of these transactions because not allow the indetification of the final purpose of environmental flows
29/07/2011Philippines/National Statistical Coordination BoardPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
In the introduction (para 5), it might be helpful to cite that not all environmental activities are covered in this chapter as discussed in ….
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. Some examples or cases would be helpful in clarifying the links between EGSS & EGSS.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. Such an approach might mislead users of the accounts particularly the policy makers.
29/07/2011Poland/CSOPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
The general view is (as already expressed for chapter 5) that the document is comprehensive and systematic, which is convenient for the user. However, there are some differences with respect to previous and other international documents and frameworks of a similar (environmental) scope and this fact should be clearly underlined in the preface to allow for easy comparisons.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes. We agree that the scope of activity considered here ought to include the full set of environmental activities (item 11, page 3), not only those considered as "environmental" (read e.g. beneficial for the environment) in order for the framework to be consistent and comprehensive.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. As stipulated in item 90 the major complexity in defining adapted goods is that they exist only in relation to similar but non-environmentally friendly goods. Therefore, the idea is to consider the total value of the good, as in EGSS, rather than the extra cost of the environmentally beneficial component, as in EPEA (item 94). At the same time in item 95 there is a distinction made for an end-of-pipe technology which from the economic point of view can be differentiated from the environmentally beneficial component of an adapted good only if it is separately sold to the customer. Otherwise, its valuation may remain artificial. Adapted cars (with a hypothetical integrated technology) and cars with catalytic converters (the mentioned above end-of-pipe technology) can be equally beneficial for the environment and sold for the same price, therefore the environmentally friendly component is economically indistinguishable, but here it is suggested to consider it differently. This will inevitably bias somehow any economic analysis on environmental concerns based on data collected in this way and therefore reduce the value of the collected data. However, we do answer "Yes" because the question above does not reflect directly this problem.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. There is a risk that virtually all mentioned activity may become "environmental" in many cases. Because of the legal differences between countries and the presence of different levels of "soft corruption" (as to how freely in each country activities would be reclassified as environmental) great differences of a virtual rather than real character may arise between countries. This would make the collected data useless for analyses and any comparisons between countries impossible in this respect.
29/07/2011Lithuania/Statistics LithuaniaPart II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. We do not agree on inclusion of natural resources use activities in the scope of environmental activities.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No opinion.
28/07/2011Canada/Statistics CanadaPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
Overall the chapter is less complex and the table structures clearer than the previous edition of SEEA and the SERIEE compilation guide. This chapter should be restructured, however. Sections 4.4 and 4.5 appear to be relevant to the compilation of full EPE accounts, however the accounts are discussed under 4.3.2 and are mixed with the EPE statistics discussion. It would appear that some of the material in other sections, e.g. 4.3.3 on EGSS are relevant to the construction of the supply side of the EPE accounts as well. Therefore, it might be useful to have a discussion of EPE statistics and EGSS statistics separately, and leave the discussion of EPE accounts until the end of the chapter when all the elements of those accounts have been fully described. In short, the chapter lacks guidance on the specifics of which data sources should be used and how exactly they should be combined into an account. This is an important omission given that SEEA will be consulted primarily for guidance on accounting rather than on the compilation of statistics. Paragraph 28 describes the boundary issue of activities associated with the production of energy from renewable resources and the treatment of activities associated with energy savings. The text suggests it may be necessary to consider the compilation of separate statistics on these activities outside the "framework" of the CEA. This is contrary to the most recent draft classification of the CEA where energy savings and renewable energy would fall under the same umbrella principle as the rest of the EPEA – primary purpose. We believe that this issue should be resolved before the revised SEEA is finalized as this is a very important consideration for countries investing heavily in energy savings and renewable energy production. In fact, paragraph 66 uses the costs of installing energy savings equipment as an example of an EPE. The argument that the treatment of these types of expenditures could lead to difficulties with international comparison is not unique to these types of expenditures. In fact, the overall definition of primary purpose lends a degree of subjectivity to how the EP expenditures are classified within each country that cannot be avoided. Therefore, we recommend that the primary purpose criterion be used to classify all of the CEA categories.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. The implication of "environmental" in this chapter is that the activity is meant to be beneficial to the environment. This motivation is not central to resource use activities, and as such they should be out of scope. Otherwise, all expenditures related to the environment in one way or another (for good or ill) would have to be included. We agree with Norway that one exception could be ‘water abstraction'' as part of ‘water management''. Para 28: Suggest re-wording. The idea is that the production of energy from renewable sources may be of interest in its own right. There are some clear links to EPE if the primary purpose of the activity is environmental protection, but the activity is not restricted to that purpose. So, the paragraph should state that production of energy from renewable sources and energy saving expenditures can both be viewed as EPE if they satisfy the primary purpose criterion. However, the activity is also of general interest, and separate statistics on this activity outside of the EPE framework may be compiled for analytical purposes. The basic idea is covered in the annex, but it bears mention here.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
No. The EPEA includes the measurement of the provision of environmental protection and resource management services. These services are provided by specialized and non-specialized producers. These concepts are part of the accounting framework of the EPEA, which follows the concepts and framework of the SNA. The EGSS, on the other hand, is not an account and does not follow many of the same definitions and principles as the EPEA. If the EPEA is a "demand" side perspective while the "EGSS" is a supply side perspective, then it is our opinion that the EGSS should follow the same rules, concepts and framework as the EPEA, which it does not. In addition, the explanation and description of how to compile EGSS statistics is much more detailed in the Eurostat Handbook, and it is our recommendation that the SEEA be used to provide users with a reference to this document, and the entire detailed text related to the EGSS should be removed from Chapter 4. If the EGSS section remains in the revised SEEA, we have several recommendations: As suggested in the opening comment, this section should be restructured in combination with the other sections to ensure a full presentation of relevant statistics occurs before their compilation into accounts is discussed. Para 41. The first two sentences seem to fully define the scope, but the second two add confusion by suggesting that only certain products would be in scope. As long as the primary purpose of the expenditure is environmental, then it is in scope regardless of the type of product that is purchased. Thus, suggest deleting the last two sentences. Table 4.3.1 has a spot for the supply of environmental protection services, but EGSS is not discussed until later. If EGSS is to be the source of these supply estimates it would be preferable to discuss those statistics first, as was done with the EPE statistics. Para 70 may require some re-wording. Is the first bullet meant to read: Final consumption, intermediate consumption and gross fixed capital formation "on all goods and services for the purpose of environmental protection"? Should the second and third bullet close with the precision "by the EGSS"?
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. This restriction of subsidies to protection and management suggests that "use" does not belong in the classification of environmental activities as noted in question 1. Following the main purpose criterion, only the environmentally relevant portion should be included if any amount is included at all.
  Part III: Any additional comments including those of a more technical nature
[detailed comments attached]
 Chapter4-Canada.pdf;   
28/07/2011Palestine/Central Bureau of StatisticsPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
The structure of the chapter, the balance of material and the coverage of the chapter are good.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes.
28/07/2011Colombia/DANEPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
Es pertinente incluir un glosario aclarando los términos relevantes para el desarrollo de las cuentas, particularmente, el concepto de reciclaje, reutilización, recuperación. Adicionalmente, es pertinente determinar explícitamente la clasificación a la cual pertenece dentro de las actividades de protección ambiental, en el documento no es claro, por tanto no es posible definir el alcance de la actividad de reciclaje en el contexto de la cuenta de gasto en protección ambiental.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. i) Es importante definir el concepto de "actividad ambiental" ii) Es importante ampliar la conceptualización de "actividades ambientales", "actividades de protección ambiental" y "actividades de uso de recursos naturales", esto con el fin de aclarar el alcance de cada concepto y determinar si efectivamente los usos hacen parte de las actividades ambientales. iii) No hay claridad conceptual sobre cuales serian las actividades ambientales asociadas al "uso de los recursos naturales" iv) ¿Que se pretende registrar como actividad ambiental en el "uso de los recursos naturales"? v) ¿Que se pretende registrar como actividad ambiental en el "manejo de los recursos naturales"? vi) Hay que definir el alcance de la categoría de actividades de uso de los recursos naturales, dado que, según lo indicado en el documento se puede interpretar que las actividades ya están incluidas en las categorías de protección y manejo ambiental.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
No. i) Es importante definir el concepto de "actividad ambiental" ii) Es importante ampliar la conceptualización de "actividades ambientales", "actividades de protección ambiental" y "actividades de uso de recursos naturales", esto con el fin de aclarar el alcance de cada concepto y determinar si efectivamente los usos hacen parte de las actividades ambientales. iii) No hay claridad conceptual sobre cuales serian las actividades ambientales asociadas al "uso de los recursos naturales" iv) ¿Que se pretende registrar como actividad ambiental en el "uso de los recursos naturales"? v) ¿Que se pretende registrar como actividad ambiental en el "manejo de los recursos naturales"? vi) Hay que definir el alcance de la categoría de actividades de uso de los recursos naturales, dado que, según lo indicado en el documento se puede interpretar que las actividades ya están incluidas en las categorías de protección y manejo ambiental.
  Part III: Any additional comments including those of a more technical nature
i) Las actividades de protección ambiental están definidas o determinadas a través de las categorías tomadas de la clasificación de actividades de protección ambiental – CAPA 2000. Dentro de la medición de gasto en capital encaminado a actividades de protección ambiental se definen dos tipos de gasto: uno en tecnologías usadas para el tratamiento y otro es el gasto en inversión integrada enfocada hacia la prevención. Al revisar las sub-categorías de la CAPA pareciese que se requiere una actualización de la misma guardando el enfoque (prevención y tratamiento), o por el contrario se requiere una mayor amplitud en los conceptos que permitan una exactitud en la medición. ii)No sé explica en el texto cómo hacer la medición del GPA a través del ahorro en materia prima en el renglón de formación bruta de capital fijo (Inversión en Tecnologías Limpias).
28/07/2011Macao, China SAR/Statistics and Census ServicePart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
Structure and technical contents of this chapter are clear. However, it will be very difficult to compile the tables due to insufficient data, especially for the developing countries.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No opinion.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
No opinion.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Topic of environmental related transfers and similar flows is new for us so we can''t have any opinion.
27/07/2011France/Ministry in charge of EcologyPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
We find this chapter correctly structured and well argued. The § 4.3.4 studying the relationship between EPEA and EGSS is particularly relevant. The Section 5 does not contain any table so it may be difficult to establish a link with the previous developed concepts or to see the relevant uses to be done.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes. We agree that the scope of environmental activities includes natural resource use activities. However, it should be added that only the part of these activities devoted to reduce the intake or the consumption of natural resources, for example through reuse or recycling, has to be considered. According to this point of view, the CEA should be seen as an aggregation of the CEPA (Classification of Environment Protection Activities) and the CRUMA (Classification of Resource Use and Management Activities and Expenditure).
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. We are not sure to understand well the second sentence in the point 84. Anyway, it would be relevant to give an example of this kind of services.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes. We agree even if ideally it would be better to select only the proportion of the payments which are considered to be for environmental purposes. However, we have to admit that most of time this distinction is out of reach and such a recommendation may lead to apply non harmonized breakdown methods and to false international comparisons. We don''t agree with the recommendation expressed in the 2nd § below the question 3 (point 133 in the chapter). We support that the primary purpose criterion should always apply and no exception should be made to this rule. How can be made a decision if the primary purpose is not environmental? All other purposes have to be examined? The risk in doing so is to increase the needs of much more detailed information and those will not be available in every case inside a country or given in the same basis from a country to another.
  Part III: Any additional comments including those of a more technical nature
* Table 4.3.3 p 13: it would be useful to add in the text that the expenditures breakdown between intermediate consumption, final consumption and gross fixed capital formation is not feasible for every product, especially for wastewater domain (only global expenditures are available in France). * Point 117 p 23: We suggest to replace potential by possible. * Point 124 p 25: Can it be argued why the distinction between taxes and sales of services can be difficult to assess? * Points 138 & 138 p 27: the issue of preferential tax rates and the lack of these transactions recorded in the national accounts should come before (when environmentally related subsidies are addressed). * Point 161: On the one hand this drafting is not up to date since the Inter-Secretariat has brought his conclusion (with the choice considering 2 assets, which we don''t support). On the other hand, for the previous consultation, we argued for an alternative treatment (considering the atmosphere as a fixed asset delivering services and which use gives rise to a rent paid by the pollutant producer to the government at the market price). * Point 173 p 33: the precision brought by the second sentence is not necessary insofar as different methods of depreciation valuation are applied and we are not sure that the net present value method is the most employed in order to estimate CFC.
26/07/2011Sweden/Statistics SwedenPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
As the revision period happened to come under the Swedish holiday period, we will have to send more detailed comments until the 19th of August, when there has been some time to consult. However, since these monetary flow accounts are one of the most important parts of the environmental accounts, we leave some of our comments now, and so give the other countries responding our view in the consultation.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. We think that the resource use of natural resources is already covered in the economic accounts, and that it is confusing to label these flows ‘environmental activities’. The area of adding environmental resource use is not that well developed. We will come back with more comments on it, as the detailed categories shown there may be very difficult to actually fill with data.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. We are worried by the amount of detail in the tables, as they easily give an impression of data quality that we cannot match in the statistics. We will get back with more detailed comments on the tables in August.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. We are slightly confused by the terminology used, and the meaning of this question. Also here, we will get back with more detailed comments in August.
  Part III: Any additional comments including those of a more technical nature
It is important in the accounts that the monetary flows can be used with the physical flows. Thus, rather than regarding the areas as accounts in themselves, as in presenting the EPEA, we prefer to stay with the EPER, showing the environmental protection expenditure by industry and sector, rather than to present it as its own account.
25/07/2011International Monetary FundPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
Presentation, structure and technical contents are satisfying. However, further clarity on some of the issues would be beneficial and these are highlighted below in part II and part III of this form.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes. We agree with the inclusion of natural resource activities like use of mineral and energy resources, wild fish resources, water resources, and other natural biological resources within the scope of environmental activities. If we don’t include the natural resource use activities within the scope of environmental activities, how we can include the related assets under the scope of environmental assets? Therefore, to be consistent with discussion on environmental assets in chapter 5, we recommend their inclusion.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. [detailed comments attached]
 Chapter4-IMF1.pdf;   
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. The text of the document is drafted following 2008 SNA terminology exclusively. No reference is made to GFSM 2001 terminology. The intention of the section is to identify environmentally related transactions recorded in the national accounts. In principle, the identification is straightforward. Based on the purpose or intent of a transaction, those that are environmentally related could be identified as such and grouped together in a separate category. However, in practice, the identification is difficult, as the purpose or intent of a particular transaction is seldom known, or the transaction incorporates a nonenvironmentally related component which can’t be separately identified. The section provides limited practical guidance to identify the desired transactions. Furthermore, it treats several transactions (other than VAT and rent) related to natural resources as being environmentally related. These include excises, transport taxes, and resource taxes; which may well not have an environmental purpose but simply an income purpose. From a GFSM 2001 perspective there are no categories to identify separately environmentally related transactions. Current categories would need to be broken down into their environmentally related component and their non-environmentally related component, a difficult task in practice. A better approach would be to use the functional classification of expense (outlays), which has a separate category for the environment. This could be complemented by memorandum items identifying separately specific taxes (e.g., pollution taxes) or transfers e.g., subsidies to producers of alternative energy sources) known to be environmentally related. In addition, the proposed approach would create all sorts problems regarding the estimation of subsidies/transfer for environmental protection. In our opinion, we should include subsidies to activities whose primary purpose is environmental protection or resource management. As mentioned in paragraph 133, if we include other payments that have an environmental protection or resource management purpose (but for which primary purpose is something different), then are we not under estimating the subsidies received by producers of other activities? Is there any criteria for deciding the level of secondary purpose based on which a decision can be made to include it under environmental protection? As there is no rational for this inclusion and this may result in erroneous estimation of subsidies provided for other purposes (different from subsidies compiled for COFOG), we find this proposal to be not optimal or not fully articulated. One option could be to estimate these subsidies separately for primary environmental protection and secondary environmental protection purposes.
  Part III: Any additional comments including those of a more technical nature
Selected payments to and from government and similar transactions (Table 4.4.1): Corporations may make payments (donations) to NPISHs in the Rest of the world. Similarly, from the Rest of the world (corporations or govts.) payments may be made to NPISHs. Therefore, include two additional entries for: i) payments (donations) made by corporations and received by the ROW, and ii) payments made by ROW and received by NPISHs. In addition to 2008 SNA, providing GFSM 2001 reference would be useful from the perspective of GFS compilers. Potentially environmentally damaging subsidies (PEDS): Paragraph 138 states that there is no clear limit on the activities and purposes that might be used to define a scope for PEDS. This statement contradicts paragraph 137, which mentions that “the concept of PEDS has been developed ...” In any case, we could not understand how this concept is relevant to the discussion on environmental subsidies presented in this section if this concept is not applicable/feasible. For example, petroleum and fertilizer subsidies are provided in many countries. How one can establish whether they are environmentally beneficial or damaging? Classification of environmentally related taxes (Table 6.1 from SEEA 2003) and an example of identifying environmental taxes (Table 6.2 from SEEA 2003) are quite useful and we suggest their inclusion in section 4.4. Environmentally related types of fixed assets (164-167): This shall be placed in relevant section of chapter 5 which explains the accounting for these assets. Sub-sections on the treatment of terminal costs and remedial costs would benefit fromnumerical examples. Paragraph 32 and 41: It is mentioned that characteristic and connected products for environmental protection activities are considered in detail in section 4.3. However, the section does not include additional details on the definition, identification and measurement of these products except a brief mentioning about them in paragraph 41. Expenditure on environmental protection services is called expenditure on characteristic products. However, the scope of characteristic products is not clear from the discussion in section 4.3. Table 4.3.1: a) Specialist producers may be presented separately from specialist general government producers and other specialist producers. In addition, government producers in col. 4 may be changed to non-specialist govt. producers. b) As the title of the table is ‘production of environmental protection services’, it should be presented on the lines of the production account of SNA. However, the table includes items like gross fixed capital formation, acquisition less disposal of non-produced non-financial assets and labour input, etc. Therefore, the table content seems at odd with the title. Supply-use table of environmental protection services (in simple format) may be presented by taking inputs from table 4.3.1 and 4.3.2, instead of production table and use table.
22/07/2011Slovak Republic/Statistical Office of the Slovak RepublicPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
The chapter is well-arranged and appropriately presents the issue of environmentally related transactions. The material seems to be adequately balanced.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No opinion. Topic of environmental activities, goods and services is relatively new for us so we can´t give qualified opinion on this methodological issue.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. In general we agree that this section adequately describes the measurement of EGSS and relation between EPEA and EGSS. Maybe it would be useful to have portrayed links between EGSS and EPEA in scheme or table.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No opinion. Topic of environmentally related subsidies and similar flows is new for us so we can´t give qualified opinion on this methodological issue.
22/07/2011BPS-Statistics IndonesiaPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
Structure of the chapter: OK Balance of materials: OK; however the subchapter on EGSS and EPEA needs more elaboration/description. Coverage: OK
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes. Natural resource use should be considered as environmental activities because it relates to the making balances of supplying and use of natural resource in the world; in the sense that natural resource should be used as wise as possible, not too many and not too few, enough for consumption/production and not to damage natural resource/environment.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
No. Section 4.3 (not 3.3 as written above?) does not clearly describe the measurement of the EGSS; and even the description of EGSS is not clear. It needs more description on the links between EGSS and EPEA.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. Only that proportion considered to be for environmental purposes should be included in the central framework because only that portion which relates to the environment.
  Part III: Any additional comments including those of a more technical nature
No more comment.
20/07/2011Netherlands/Statistics NetherlandsPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
• Tables for recording emission permits (see outcome paper issue 8b) seem to be missing. This should be included in this chapter . • Some additional text is needed on environmental investments (gross fixed capital formation). Next to environmental expenditure, this is an important indicator that may be derived from the EPEA.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. Water supply and oil and gas extraction are very often unfriendly environmental activities in stead of activities that reduce or eliminate pressures on the environment and aim at making more efficient use of natural resources. Secondly, extraction activities are generally very big and overschadow expenditures on protection of the environment and expenditures for resource management.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. A bridge table may be added to explain the main differences between the EGSS and the supply table from EPEA.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes.
  Part III: Any additional comments including those of a more technical nature
4.1 Introduction: mention functional accounts here (link with chapter 2) Paragraph 14: The definition for environmental activity here is primarily focussed on EPEA. Environmental production activities (EGSS) where the primary purpose usually is economic rather than environmental, seem to be excluded by this general definition. A more general discussion relating the economic activities (production, consumption, accumulation) to environmental activities is needed here. Paragraph 22: climate change adaptation may be mentioned here explicitly Paragraph 30-33 This section is not very clear, consider rewriting. Connected products are products that can only be used for environmental purposes (e.g. sceptic tanks) and are not environmental protection services. The example of a car is not correct. Adapted products also need to be mentioned in this section. There is no need to have an alternative approach for the supply perspective. Paragraph 49-51: An additional paragraph should be added how total output for own account producers is calculated, i.e. the sum of intermediate consumption, compensation of employees, taxes less subsidies on production and consumption of fixed capital (net operating surplus is by definition zero). In the context of EPEA own account producers are very important. Paragraph 57: Add that all supply of own account production is consumed as intermediate consumption of EP services by the same sector that is producing it. What are (iii) expenditure on other goods and services ? Please explain in the text. Table 4.3.3 ‘Specific transfers for environmental protection'' and ‘environmental protection transfers to and from the rest of the world'' merit some text for explanation. Paragraph 69: Not clear why earmarked taxes need special consideration. Paragraph 70: This seems not correct: ‘Less Intermediate consumption on environmental protection goods and services for environmental protection activities'' add by specialised producers Paragraph 77: Investments and exports may be added here as important variables Paragraph 84: Text is not clear Paragraph 89: Definition adapted goods: More explanation is needed here. Some goods are "cleaner" because less pollution is generated in producing these goods (renewable energy). Some goods are more environmentally friendly because they generate less pollution in their use phase (cleaner washing machines etc.). Thus also resource efficient products are included. Paragraph 89: Imports are (of course) not part of EGSS output, however, imports by the EGSS may be an important economic variable to consider, so this statement is a bit to strong. Paragraph 130: A little more text may be dedicated to the scope of transfers included here, namely: Subsidies, Social benefits to households, Other current transfers, Investment grants, and other capital transfers (see outcome paper). Please describe what these are and how defined (with reference to SNA). Paragraph 136: This observation is also very true for environmental taxes, so please also add this also there.
18/07/2011Lebanon/Central Administration of StatisticsPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
• Very structured chapter • Easy to read • Excellent tables • Excellent annex on pp.36-41
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes. • Could you please precise some UN or international literature if available about the minimisation of the impact of natural hazards as we are interested with its association with the theories of agency and of incentives in economics as we talk about moral hazard? • This literature may help in the research about moral hazard in economics and its effects on natural hazards especially forest fires in Lebanon because of climate change of the human factor.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes, of course.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes.
  Part III: Any additional comments including those of a more technical nature
Liked paragraph 15 on p.41.
14/07/2011Mexico/INEGIPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
Regarding the EPEA, it would be important to consider the "SERIEE Environmental Protection Expenditure Accounts - Compilation Guide 2002 edition" that EUROSTAT published, which presents international experiences about the elaboration of the account including sources of information, as well presents tables of results. Actually in the introduction of this guide it is mentioned that this has the appropriate tools to replace the SERIEE 1994, because it contains updates and recommendations about related and adapted products.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes. In general, we agree with the inclusion of the natural resource use activities, however, the CEA should expand the explanation of the activities that would be part of this concept, for example, oil and gas extraction activities itself is an economic activity included in the National Accounts. On the other hand, it should be noted that these activities are not covered in the natural resources management or as environmental protection activities.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. We agree that the relationship between EPEA and EGSS is clear regarding what measures each one, however, including examples or experiences of countries would result in a better understanding of the complex relationship between EGSS and EPEA.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes. We agree in considering the aggregate amount of payments, since the information sources of these transactions does not allow the identification of the final purpose of environmental flows, however, it is important to make efforts and strategies to identify the amount related to the protection of the environment or other environmental activities, using for example, similar results to those presented in the financing tables of the EPE.
  Part III: Any additional comments including those of a more technical nature
Section 4.2 mentions the environmental activities and the corresponding classification; however, it is not specified which tables will be the ones to be developed and whether the coverage it is only for the EPEA. Section 4.3.2 does not mention possible sources of information to generate the EPEA as stipulated in the SEEA 2003 for suggested inclusion again, what is considered important for this issue as well for use and management for natural resources. It would be important that in Annex A4.1, the CEA include a detailed explanation or examples of the activities that are in their classes and categories, since there are border cases whose classification can be complex.
14/07/2011Norway/Statistics NorwayPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
(a) The chapter is still rather confusing to read. Admittedly when you read the chapter, you think you understand what it says, but there are so many ambiguities that when you start discussing it with colleagues you find that the text is unclear and potentially contradictory in places. The comments by Eurostat confirm that some of the text and definitions are not correct and we support their proposed corrections to the various definitions. (b) The title of the chapter “monetary flow accounts” elicits incorrect associations for some readers. We would suggest that the title be closer to that used for Chapter 6 in SEEA-2003 and propose the title, “Accounting for environmentally related transactions”. (c) We would expect that emissions permits and related property rights topics would be covered in this chapter. This topic and related environmental “property rights” as they were called in SEEA-2003 (Chapter 6, Section 3.2, §6.39-6.57) should be included in the revised SEEA. If the full treatment of emissions permits cannot be provided at this time since the treatment in the national accounts has yet to be determined, then the two main alternatives could be presented so that readers at a later date can know what to do once a choice has been made. Some guidance regarding the development of CO2 emissions quota statistics (at least in physical units) should be included in SEEA.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. We do not agree that resource use activities – such as mining, oil and natural gas extraction, fishing and forestry – be included as “environmental activities.” These activities should be removed from the scope of environmental activities (§12) and from the CEA (remove Group III from Table 4.2.2 and A4.1 and all of A4.4) and all other references in the text (such as §20-21, §165) and in the Annex (§A10-11, remarks to Table A4.4). A boundary issue arises with water abstraction. In some ways it seems desirable that water abstraction is included as an environmental activity. If some way can be devised to include “water abstraction” as part of “water management”, this might be a good idea but no other “extraction” type of activity (mining, fishing, forestry) should be included as environmental activities. Environmental activities named in §12 should only include 3 types of activities: (i.) Environmental protection, (ii.) Natural resource management and (iii.) Minimization of the impact of natural hazards.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
No. Section 4.3 does not adequately describe the measurement of EGSS because there are inherent measurement problems related to “adapted goods.” It adequately describes the differences between EGSS and EPEA, but it would seem to be advantageous to get these two groupings to have fewer differences. With this goal in mind, we would suggest that “adapted goods” be dropped from both EPEA and EGSS. The inconsistent way that the same product is included in the different groupings (EPEA (additional cost) and EGSS (entire cost)) would thus be eliminated. In EPEA the “additional cost” is not observable so this also argues in favour of elimination. In addition, §90 states that “The major complexity in defining adapted goods is that they exist only in relation to similar but non-environmentally friendly goods.” If this is how adapted goods are evaluated then adapted goods can only exist if there are actually comparable products available to that consumer. If there are no available alternatives then it cannot be considered an “adapted product” and is therefore simply “standard equipment” and should not be included in EGSS or EPEA. An additional problem related to adapted products arises with the idea that “net cost” of environmental protection should be recognised (see §66). Identifying cost savings and subtracting them from the investment of a piece of equipment is not realistic. These types of estimates of future cost savings, for example electricity costs, depend on knowing electricity prices in the future and how would these savings be calculated? Would NPV of the proposed future savings be subtracted from the current investment? These types of energy savings estimates would only be possible in the first year. After that there is no valid comparison possible since the old equipment has been replaced. The proposed approaches for including adapted goods in EGSS and EPEA are not feasible and should simply be eliminated. Theoretically we can understand the desirability of including these types of products but there are too many measurement problems to realistically include them in official statistics.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. This is a question of implementation and not of principle and relates to a statistical technique that has been called “budget analysis”. When trying to develop statistics where data sources such as budgets (national, state, municipal) are used, each line item needs to be analysed and categorized as being all, none or partially related to environmental protection or resource management. The problem arises when there is an indication in the description of the budget line that a portion of the line item is relevant to environmental protection or resource management. This situation then requires some additional work to identify the portion of that line item that is related to the environment. There are various approaches for identifying and estimating this portion provided in various guidelines produced by Eurostat, for example. Since this is a question of implementation, only that proportion considered to be for environmental purposes should be included. However, there is an underlying principle question which relates to the validity of purpose based classifications and the statistics that are based on these types of approaches. It is seldom that we know what actors are thinking, wanting or took into consideration when the expenditure was made, therefore, purpose based or functional classifications and methods based on knowing the purpose behind the expenditure have high levels of assumptions and therefore uncertainty.
  Part III: Any additional comments including those of a more technical nature
(a) In §13 it states that activities and expenditures that relate to people and produced assets are excluded. On the other hand in §169-170 it clearly states that termination costs and remedial costs are included – and we would like to note that terminal and remedial costs can be related to produced assets such as oil rigs which are specifically mentioned in §170. This inconsistency needs to be corrected. (b) In §33 the description of environmental goods and services include those “designed such that they are considered to be beneficial to the environment.” This seems to open for including a range of non-harmful products at the discretion of the producer so it would be difficult to determine if too much was included or not. (c) §45b states that the EPEA is intended to respond to the question regarding how the expenditure is financed by different institutional units. It is difficult to find where this is explained in the chapter – with only the small section of §71-75 addressing this topic. This discussion should be made more obvious if it is supposed to be addressing one of the three main questions to with EPEA responds. (d) §62 and §65 (and then in §80 and §85 from the EGSS perspective) have a common theme of valuation of adapted capital equipment and adapted goods. The inherent problems in the identification and then proper quantification make it very difficult to obtain reliable and meaningful data. These ideas may look good theoretically but are not implementable and should therefore be eliminated. Making comparisons between existing equipment and some notion of “more polluting” equipment leads to guess work on the part of reporting units and imprecise measurements. Previous environmental adaption and subsequent (ongoing) product and process development will, after a few cycles, be inseparable. It is always a question of measuring against a moving and newly defined target. It is insufficient to just make a note of the problem, and not address these implications. (e) In §73 the example of EPE by households is “house insulation” or “other energy saving devices.” According to §66 (and footnote 1) these types of expenditures may or may not be considered environmental protection expenditures – since they may simply be motivated from an energy savings point of view and have no environmental protection component. Suggest that less ambiguous examples are used for illustration. But this also points out the problem with identifying the “motivation” and using this as the decision criterion for inclusion or exclusion. (f) The definition of an environmentally related tax (or preferably ‘environmental tax’) in §113 is not theoretically grounded and does not resonate with economic theory. Environmental taxes are instruments used to internalize the environmental externalities following production or consumption activities and are well specified as such. The identification process should then address the purpose of the tax instead of applying the tax base as “being a physical unit (or proxy) with a proven, specific negative impact on the environment”. The tax rate is the relevant policy measure and the tax revenue should say something about the recycling tax potential (and thereby, possible double dividend potential), while the tax revenue in the present definition has no environmental policy implication whatsoever. (g) Environmental subsidies and similar transfers are to be identified based on the intent or purpose of the government. Different government units may stress different aspects of a specific transfer package – whose perspective is the “right” or determining one? Is it a “jobs” package or an “environment” package? (h) Indirect subsidies (such as preferential tax rates) are not mentioned in the section for environmentally related subsidies (§130-134). It would make sense that a similar statement to the final sentence in §138 be included in the section on environmental subsidies.
12/07/2011Republic of Croatia/Central Bureau of StatisticsPart II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes.
  Part III: Any additional comments including those of a more technical nature
CBS didn’t develop environmental accounts. For the time beings we collect only data on environmental protection expenditure, material flow, environmental taxes and charges and the next steps will be work on water accounts and NAMEA AIR.
11/07/2011Switzerland/Federal Statistical OfficePart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
This chapter is globally clear, well structured and balanced. Nonetheless, we would prefer that the word “expenditure” doesn’t appear in the title of subchapter 4.3, which doesn’t only concern expenditure but also production data. A possible title could be “Environmental activities accounts and statistics”. Besides that, we agree with the so-called purpose based approach for defining environmental activities.
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
Yes. Please specify how activities like ecological agriculture, eco-friendly tourism or resource-efficient manufacturing are treated in this context and outline what the next steps should be in the area of the fourth category, the minimisation of the impact of natural hazards.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. We globally agree that this chapter adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA, but we would like to have an overview of these links in form of a schema or a table.
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
Yes.
  Part III: Any additional comments including those of a more technical nature
Table 4.3.3 : please specify that NR means “Not required” § 17: Please add "restoration" in “(…) the preservation and restoration of ecological entities and landscapes; (…)" §115: Please mention incentive taxes, for which the intended purpose is also known. §116: Please add “taxes on sealing” in “Resource taxes This category typically includes taxes on water abstraction, extraction of raw materials and other resources (e.g. sand and gravel, forests), and the sealing of land."
08/07/2011European Commission/EurostatPart I: Please supply any comments on the structure of the chapter, the balance of material and the coverage of the chapter including any thoughts on missing content
In general the structure is OK but there are problems related to definitions and concepts that seriously impair the readability of the chapter. [see attached]
 Chapter4-Eurostat1.pdf;   
  Part II: 1. Overall, do you agree that the scope of environmental activities in the SEEA should include natural resource use activities?
No. We are opposed to the SEEA including activities such as high sea fishing, oil extraction or mining among "environmental activities". We prefer to have expenditure on resource use left out of the scope, in particular resource extraction (mining, fishing of wild fish, harvesting natural timber, etc.). In addition to the problem that fishing or mining are not commonly considered environmental activities, one reason is that the focus only on non-cultivated resources makes the economic information less useful. We note that water supply is in some ways different from the other resources and could be retained. If the resource extraction activities in relation to mining, fishing or forestry are excluded then water supply could be added to resource management. If the above is not possible, as a minimum we suggest to: (A) add a paragraph after paragraph 21 which is modelled on paragraph 24 and makes fully clear that there has been little work in this area of resource use with the exception of water supply. (B) remove the resource use part from the CEA on page 6. We note also that paragraph 165 states that "…assets used in undertaking environmental activities …. includes oil rigs." With the exclusion of resource use, the oil rigs should be deleted from this paragraph.
  Part II: 2. Overall, do you agree that Section 3.3 adequately describes the measurement of the EGSS and explains the links between EGSS statistics and information in the EPEA?
Yes. Overall this section makes the differences quite clear. The way the text is written can however be improved. We suggest the following: (a) move paragraph 103 before paragraph 98 (b) paragraph 98 over-emphasises the differences. Please add here that satellite accounts for resource management could be made along the lines of the EPEA which would then remove this difference. (c) in paragraph 99, replace ''considers'' by ''includes''. (d) in paragraph 100, the text stating "…focus on those products that are characteristic of environmental protection and resource management…" is misleading in view of the definition of characteristic products elsewhere in the chapter. We suggest you replace the first sentence by this new sentence: "The EGSS, on the other hand, focuses on environmental goods and service from the production side and defines the scope of these products from a technical production perspective. (e) in paragraph 100, delete the last two sentences. They seem to imply differences that do not exist. (f) paragraph 101 includes some complicated text. Simply say that the EPEA describes the expenditure of residents including expenditure on imports and the EGSS describes production (output). (g) in paragraph 102, also mention the subsidies and other transfers that are added to national expenditure. (h) in paragraph 103, the last sentence is misleading. The EGSS does not ''focus on the supply…'' but it focuses on production (compare also with paragraph 101).
  Part II: 3. Overall, do you agree with the proposal to measure the value of environmentally related subsidies and similar flows on the basis of the total amount of the payments not only that proportion considered to be for environmental purposes?
No. We think what is described here is a false problem that should be deleted from the SEEA. The issue is a general one of main purpose and functional classifications (e.g. classification by COFOG). A short reference to this general issue should suffice. In case the issue is kept, then we disagree with the rule to allocate the total amount to environmental purposes even if environment is only a secondary purpose. We prefer the main purpose principle stated elsewhere in the Chapter 4. What can be added is some practical advice that in reality the problem is to analyse available sources (e.g. expenditure items in government budgets) and to allocate them by purpose. These items are not individual transactions but government programmes which may well be split by purpose based on information from the agencies implementing the programme etc. This is a different viewpoint as it assumes that within a government programme there are groups of transactions with different main purposes.
  Part III: Any additional comments including those of a more technical nature
GENERAL REMARKS (A) Rationalise the way the SEEA refers to the SNA. Currently there are sections with very extensive and detailed referencing and other sections with none at all. (B) Rationalise the way definitions are presented (sometimes e.g. in chapter 5 they are bold, in chapter 4 they are mostly not bold) (C) TERMINOLOGY PROBLEMS: The term ''monetary transactions'' is incorrectly used to mean all economic transactions expressed in money terms (see SNA2008 paras 3.55 et seq), for example in paragraphs 1 and 3. Delete ''monetary'' everywhere to leave only ''transactions''. In general it would be good to review and rationalise the large number of uses of the adjective "monetary" throughout the book Also, in paragraph 3, the ''money spent'' should be replaced by ''economic resources''. Section 4.3.2 is called "Environmental protection expenditure and activity account" in the table of content but not on the actual section – delete the ''and activity''. On page 27, before paragraph 135 we have a title that uses the terminology "environmentally related subsidies and other transfers". Elsewhere the term used is ''similar transfers''. Be consistent and change "other" to "similar". In paragraph 3: ''changing state of the environment''. Expenditure and the state of the environment are a long way apart. Add before:'' changes in the pressures on the environment and…'' In paragraph 22, add ''could'' before ''include research, observation….'' This is to make clear that this definition is an experimental one. In paragraph 46, replace "exposure of an economy" by "commitment of an economy" In paragraph 67, delete one time "expenditure". Paragraph 123: replace ''income taxes'' by ''taxes on profits'' to make this paragraph clearer. Paragraph 125: Delete the following: '' and need to be distinguished from payments of taxes and sales of goods and services'' Paragraph 136: states that ''it may be relevant to separate the transfers into those of a current and capital nature '' Replace ''it may be relevant'' by ''it is necessary''. In paragraph 138, in the second sentence add ''currently'' into the phrase '' …there is currently no clear limit…'' In paragraph 170 in sentence 1, after ''timing of the costs'' add ''(see below)'' In paragraph 171, replace ''generally'' by ''often'' In paragraph 175, delete ''value of'' from the 1st sentence. In paragraph 181, start the paragraph with ''Costs of a remedial nature are often…''
 

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