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Taxation for Environmental Protection: A Multinational Legal Study.

I. Introduction

In anticipation of the Earth Summit in Rio de Janeiro there were hopes that the European Community's carbon emissions tax initiative,,would gain considerable endorsement from the international conferees.(1) Although those hopes were not realized,(2) the proposal was well-received and the delegates were able to advance the concept of an international tax on emissions through the process of preparing and publicizing the initiative.(3) While international policymaker, are recognizing for the first time the idea of using globally scaled taxes as a potential mechanism to protect, the earth's environment, many countries have already successfully implemented the use of taxes to combat environmental degradation at the domestic level. In Taxation for Environmental, Protection: A Multinational Legal Study,(4) the authors examine the specific ways in which France, Germany, Sweden, the United Kingdom, and the United States have used and are developing tax laws to help alleviate environmental degradation. The book explores various fiscal measures that the selected industrialized nations have adopted or proposed in their attempts to harmonize tax and environmental policies. The ultimate purpose of these efforts has been to synthesize nonlegal fiscal strategies that reach beyond the limits of direct regulation and legal sanction to protect the environment.

Taxation for Environmental Protection brings together, for the first time, an international study of fiscal measures for environmental protection. The hook draws on the expertise of Sanford Gaines and Richard Westin, the book's co-editors and co-authors of the chapter focussing on the United States; Robert Hertzog,(5) author of the chapter addressing France; Friedrich Von Zezschwitz,(6) author of the chapter on Germany's fiscal and environmental strategies; Asbjorn Eriksson,(7) author of the chapter discussing Sweden's efforts to combine tax and environmental policies; and John Tiley(8) and David Williams,(9) co-authors of the chapter concentrating on the United Kingdom. The book is more practical than theoretical, focussing upon specific fiscal measures as well as environmental legislation enacted in the countries covered in the study. The authors of each chapter generally use a positive analysis to describe the administration of tax and environmental programs in the country and to survey the tax laws and other fiscal measures that influence the environment.(10) From that foundation, some of the authors explore proposed measures of environmental fiscal policy, while others venture further, offering commentary and normative criticism.(11)

Taxation for Environmental Protection is about economic measures, such as taxes, fees, and other government charges or benefits, that have recently begun to receive attention as instruments of environmental policy. Although the book easily could have been a technical treatise approachable only by the microeconomist, tax scholar, or legal theorist, the text of Taxation for Environmental Protection is accessible to the lay person. The reader may credit the book's readability, in part, to the editors' introduction, in which they present the theoretical foundation for using fiscal instruments to promote environmental policy. The editors also classify and define the major types of such instruments, and explore some of the limitations and difficulties that are likely to arise in attempting to institute, specific environmental tax measures.

The theoretical foundation for taxing pollution(12) can be attributed to economists Pigou,(13) Baumol,(14) and the 1991 recipient of the Nobel Prize in Economics, Coase.(15) In contrast to the conceptual, academic approach of those economists, Gaines and Westin are more concerned with the practical policy applications of fiscal measures and, accordingly, direct the discussion to address specific measures that combine tax and environmental policy concerns. Each chapter of the book covers a different national government's general environmental plan. The chapter then focusses on specific fiscal or tax legislation that the country has passed or proposed for the Purpose of protecting the environment. The editors note that their book is not a strict comparative study, and invite their readers to draw their own conclusions about which mechanisms are the best and which legislation is the most enlightened.(16) In Accepting that invitation, this review sketches Taxation for Environmental Protection's discussion of each nation's approach to atmospheric pollution.

II. France

In the chapter focussing on France's fiscal and environmental approach, Hertzog traces his country's delayed efforts to create the Agency for Air Quality (AQA), which became operational in 1982. For the first three years of its existence, the AQA was practically devoid of authority. It was designated as a monitoring and informing body that was to prompt, coordinate, demonstrate and carry out initiatives for the development of techniques that contributed to the prevention of air pollution. However, in 1985, the French government gave the AQA the power to levy a parafiscal tax on the discharge of polluting substances into the atmosphere. The AQA allocates the revenues of that tax to fund the fight against air pollution. The tax, payable by all private and public parties, affected approximately 480 plants in 1985 - including waste-incineration plants, industrial processing plants, and collective heating plants. The AQA imposed the tax on installment exceeding certain standards based on both consumption of combustible material and annual discharges. Costs of administering the tax, that is, the costs of assessment, verification, and collection, amount to a small portion of the revenues generated, which is surprising given the broad base of the tax. One reason for the low administration cost is that the tax does not vary according to the fuel burned; it is levied strictly on caloric power and emissions. Another reason - one that is criticized by ecologists - is that French law limits the tax to only two types of air pollution: sulphur oxides and nitric oxides. In 1990, the French government expanded the tax base of the atmospheric pollution tax from 480 plants to 870 by lowering the taxable threshold.

Hertzog's discussion of the difficulties of setting the tax rate is both awkward and self-contradictory. Some of the problem appears to be the translation from French to English. This is the only chapter in which language appears to be a problem. Substantively, Hertzog's tax rate analysis begins by observing that, when set at the proper rate, atmospheric pollution taxes amount to "quasi-regulations" because of their dissuasive or incentive effect. However, he ultimately retreats from that position, concluding that a punitively high rate will set off the hostility of those potentially affected by the tax such that an "incentive system operating too efficiently can produce results contrary to the objective being sought."(17) Accordingly, he backs the French government's choice of fixing the tax rate based on the expenditures of the AQA, rather than at a level that would be quasi-regulatory because that rate would carry the risk of economic disruption.

The AQA handles compliance with the French atmospheric tax through a system in which those liable for the tax submit annual declarations to an inspectorate that judges them as to their trustworthiness and, either passes the declaration on to the AQA or, if found improbable, calculates an amount due. French law allows deductions from the Amount due for gifts or fees paid to associations operating networks of atmospheric pollution measurement. Those liable for the atmospheric tax are also entitled to "subventions" - a type of tax credit - for amounts expended towards the prevention, reduction, or measurement of pollution. Although the author does not give any empirical evidence to establish that the French atmospheric tax deserves the credit, he does point out that the discharge of sulfuric dioxide fell fifty-seven percent in France between 1980 and 1989, while the drop in nitric oxide during the same period was twelve percent.

III. Germany

Germany's fiscal pollution policy appears to be a disparate conglomeration of measures lacking in comprehensiveness. In what is the most complete and best-written of the foreign surveys, Von Zezschwitz discusses the hodge podge of fiscal enactments that impact German air pollution. He notes the differences between German and American policies, observing that Germany has not adopted certain provisions contained in the U.S. Clean Air Act.(18) Among the various fiscal measures that affect air pollution are tax benefits for energy-saving investments. These include a ten-year write-off period on energy-saving building investments such as the installation of solar facilities, the construction of wind-power facilities, or biological gas facilities. The German government also imposes a tax on petroleum that reaches beyond the purpose of raising revenues because it burdens environmentally harmful fuels, such as leaded gasoline, with a higher tax rate. Similarly, the German motor vehicle tax varies according to the type of vehicle and its potential for harming the environment. German law grants tax relief for electric vehicles, local public transportation, and train freight. It also provides lower tax rates for cars equipped with catalytic converters as well as for lighter automobiles.

This chapter also included a section on tax reform proposals that have environmental ramifications. Von Zezschwitz discusses the proposals to tax air pollution by providing a breakdown of the four primary parties in Germany's political scheme and comparing the various choices of pollutants that each propose to target. While the author devotes special attention to German proposals for taxing carbon dioxide emissions, it is noteworthy that the European Community's carbon tax directive, which could receive approval by the beginning of 1993,(19) may supersede German proposals.

IV. Sweden

Eriksson argues that the Swedish tax system works for and against environmental protection. The author of the chapter on Sweden's tax and environmental approaches overmeticulously analyzes and goes into belabored detail of his country's tax system. For example, Eriksson scrutinizes the notion that Sweden's income tax rules promote the use of private cars by allowing deductions for commuting from home to work and by not taxing the value of the benefit of using employer-owned cars for private use. He finally determines that those tax aspects are discordant with environmental goals because of the harmful emissions caused by auto traffic.

Having established a system for taxing carbon dioxide in 1991, Sweden has moved on to develop taxes on sulfur oxides and nitrogen oxides, distinguishing itself as one of the leaders in taxing air pollution.(20) The Swedish government taxes carbon dioxide based on the carbon content of the fuels involved, because it is technologically much more feasible to use that measure than it would be to calculate the carbon content of emissions. The government levies the tax on fossil fuels only. It does not tax renewable biofuels because, in theory, their consumption does not add carbon dioxide to the atmosphere. Although Eriksson does not discuss the reason why Sweden has not subjected domestic solid fuels to the carbon dioxide tax, the exception is perhaps the result of political concerns for the domestic economy.

In contrast to what Eriksson considers to be a somewhat arbitrary choice of tax rates on carbon dioxide, the Swedish government calculated the tax rate on the sulfur content of fuels according to the estimated costs of desulfurizing the fuel. The government estimates that the Swedish sulfur tax will reduce emissions of sulfur oxides by at least sixty five percent by 1995.

Unlike the carbon and sulfur taxes, the tax on nitrogen oxides is a true emission tax. The government based the tax on measured emissions because the emissions of nitrogen oxides vary with respect not only to the fuel used, but also to the combustion technique and the size of the furnace. Because of the expense and difficulty in measuring true emissions, however, only operators of large combustion, plants - which constitute only forty percent of total nitrogen oxide emissions - are liable for the tax. Further, because of the difficulty involved in estimating the environmental damage due to nitrogen oxide emissions, the government has set the charge by reference to the marginal cost of reducing the emissions.

V. United Kingdom

The chapter on the United Kingdom's tax and environmental policies is the briefest, and focuses more on tax aspects than it does on environmental concerns. The U.K. did not articulate a general statement of its approach to environmental control until 1990, when it produced This Common Heritage: Britain's Environmental Strategy (the"White, Paper").(21) In that paper the government stated that it would strive to obtain its objective of reducing greenhouse gases by reducing the amount of energy consumed. Although co-authors Tiley and Williams suggest that Britain can achieve much of that objective by placing statutory obligations on the electric industry as it becomes privately owned, they note that the Electricity Act of 1989(22) uses both grants and levies toward the purpose of reducing energy consumption. The 1989 Act places a tax on fossil fuels and allocates revenues to subsidize the generation of electricity from nuclear and renewable energy systems.

No coherent fiscal strategy exists in the U.K. with regard to motor vehicles. Rather, the British government has imposed myriad subsidies and revenue raising taxes, only a few of which the government has geared towards environmental protection. The Hydrocarbon Oil Duties Act of 1979(23) is the only noteworthy tax measure with regard to air pollution that the authors discuss. The British government assesses that tax in several layers: first, it levies royalties and production taxes on the derivation of fuels; then it imposes a separate excise tax on the fuel as it is conveyed to the pumps for sale to motorists; finally the government levies a substantial Value Added Tax on the combined price. In 1987 the government introduced a lower rate for unleaded petrol. Subsequently, the price break for unleaded petrol was increased in 1988 and 1989, with a significant increase in 1990.

VI. United States

The find chapter in Taxation for Environmental Protection is a comprehensive discussion of the impact of the U.S. tax code on the environment. Taken largely from Westin and Gaines' 1989 Article,(24) this well-organized and well-documented chapter is a section-by-section analysis of the Internal Revenue Code as it relates to the environment, noting the ad hoc nature of that relationship and calling for harmonization between tax legislation and environmental regulation. With regard to environmental regulation, the authors address the 1990 Clean Air Act,(25) noting that the Act constitutes clear evidence of congressional willingness to use federal taxes as a primary mechanism for inducing environmental compliance. The Clean Air Act contains a number of fees - which the authors qualify as thinly disguised taxes - to compel conformity with federal clean air standards. It also obligates states to come up with plans to meet U.S. Environmental Protection Agency (EPA) standards and authorizes them to include in their plans economic incentives, such as fees, permits, and auctioned rights to pollute.(26) under the Miscellaneous Revenue Act, the revenue collected pursuant to Clean Air Act fees will go into the Treasury's general funds unless there is specific legislation to earmark the funds.(27)

Another example of a U.S. tax provision that combats air pollution is the excise tax on certain ozone-depleting chemicals sold or used by manufacturers, producers, or importers.(28) The government determines the amount of that tax according to a scientific "ozone-depleting factor" that rises in proportion to the destructiveness of the material. An excise tax on coal extracted from U.S. mines is another tax that has the effect of reducing air pollution, although it was enacted for the purpose of raising revenues for the benefit of miners disabled with black lung.(29) Section 48 of the Internal Revenue Code offers tax credits for energy-saving investments in solar and geothermal equipment. Finally, under [section] 169, taxpayers may depreciate certified pollution control facilities over a five-year period.

VII. Analysis

The countries included in Taxation for Environmental Protection are key players in this new application of fiscal policy, but the absence of Japan in the list is noticeable.(30) Japan has taken a wait-and-see approach to introducing environmental taxes.(31) The Japanese government is considering taxing fossil fuels and carbon dioxide emissions as well as other market mechanisms. Before Japan adopts any of those proposals, however, it insists on assessing the effect of any policy on international competitiveness. The government is also concerned with the domestic ramifications of those tax proposals, specifically, the incidence of the tax.(32)

On the topic of tax incidence, the authors have diplomatically addressed the self-posed question: "Who ultimately bears the burden of the taxes?" The regressive nature of most environmental taxes plagues their potential attractiveness and could ultimately doom the entire approach. Gaines and Westin point out, that a government must consider several factors in determining whether a tax will fall disproportionately on the poor. The regressive effects of consumer-based taxes are direct. Poor people spend a higher proportion of their income on consumption relative to the rich and thus taxes on carbon, packaging, and a variety other "ecotax" proposals will fall more heavily upon the poor. With regard to taxes on producers, one must consider the competitiveness of the industry; that is, the ability of the producer or manufacturer to pass on the tax to the consumer by raising the price. The price elasticity of demand for the particular product - whether the good is a luxury or necessity - is also a consideration.

The authors admit the limits of their treatise prevent them from dealing extensively with the distributive effects of the taxes discussed therein. They further acknowledge that the book does not propose remedies for the regressive effects. However, Gaines and Westin recommend that those who propose taxation as a deliberate instrument to promote environmental protection must be sensitive to the distributive effects of their proposals and that they must be prepared to offer corrective measures consistent with a national policy on tax progressivity. They offer the solution of a general tax cut with a progressive impact. However, that suggestion is unlikely to succeed because of the practical implementation problems and the concomitant reduction in revenues.

If one is to find a defect in Taxation for Environmental Protection, the flaw would be the text's apparent bias towards tax. The authors concentrate on the intimate fiscal details of the various measures only to pass over the environmental aspects with broad brush strokes. The professional backgrounds of the contributing authors may explain this imbalance. Of the seven authors, only Gaines specializes exclusively in environmental law while Von Zezschwitz, who is a professor of tax law, serves as chairperson of an environmental law research center. The other authors are all tax experts.

Nevertheless, Taxation for Environmental Protection will appeal to polcymakers, economists, attorneys, and environmentalists as a practical and enlightened "solution to pollution" - or at least as an intriguing alternative to the present system. The lure of fiscal measures, as opposed to command-and-control regulation and lawsuits, as a means of protecting the environment lies in their economically efficient applications. From that perspective, the authors note that the most cost-effective method of promoting environmental protection would be to correct the existing tax structure. Taxation for Environmental Protection is, among other things, a call for a full-scale legislative review and reform of the tax legislative process, an appeal for coordination between finance ministries and environmental ministries, and a summons to assess the environmental impact of fiscal policy. Fortunately, there is evidence that the harmony sought by these scholars is beginning to come to fruition through tax proposals in the United States and abroad.(33)

(1.) Private National Commission to Urge U.S. Adoption of EC-Like Carbon Tax, Int'l Envt Daily (BNA), July 9,1992, available in DIALOG, BNA-IED at 6; Europe's Industries Play Dirty, Economist, May 9, 1992, at 85. (2.) John Bierman, Who Supports EC's Oil Tax Proposal Anyway?, The Financial Post, July 20, 1992, at S4; Commission Finalizes [CO.sub.2] Strategy, Council Fails to Sharpen Rio Stance, Financial Time Ltd., E.C. Energy Monthly, June 19, 1992; David Warsh, The Road From Rio: Bush Maneuvering for a Carbon Tax, Boston Globe, June 14, 1992, at 81. (3.) EC Tax Commissioner, Parliament Differ on Success of U.N. Earth Summit in Rio, Intl Env't Daily (BNA), July 22, 1992, available in DIALOG, BNA-IED at 4; Alan S. Blinder, What Wasn't on the Rio Agenda? A Little Common Sense, Bus. Wk., June 29, 1992, at 16. (4.) (Sanford E. Gaines & Richard A. Westin eds., 1991). Mr. Gaines is a Deputy Assistant U.S. Trade Representative, Environmental Matters. Mr. Gaines is a former Associate Professor of Law at the University of Houston Law Center where he taught environmental law and directed the Environmental Liability Law Program. Mr. Westin is a Professor of Law at the University of Houston Law Center. Professor Westin teaches federal income taxation, including resource tax law. (5.) Director of the Centre for Public law, a research organization associated with the French Centre National de la Recherche Scientifique. He holds a joint, appointment as Professor of Public Law at the Institute of Political Science and in the Faculty of Law at Robert Schuman University, France. He has published books on fiscal law and serves on the editorial board of a French public finance review. (6.) Professor of Public Law and Tax Law at Justus-Liebig University in Giegsen, Germany. In addition to teaching, Von Zezschwitz is the executive chairperson of the Research Center for Environmental Law at the university and serves as a judge in the Higher Administrative Court of Appeal for the state of Hesse. (7.) Lecturer in Law at the University of Umea, Sweden. Eriksson specializes in the field of business taxation and, outside of teaching, practices as a private consultant and writes books on Swedish tax reform and income tax law. (8.) Professor of Law at Cambridge University where he specializes in teaching tax law, including comparative taxation. (9.) Price Waterhouse Professor of International Business Taxation at Queen Mary and Westfield College, University of London. Williams is a lawyer who specializes in tax law, particularly European tax law. (10.) With the exception of the chapter on France, each chapter introduces itself by providing the reader with a general background of that country's governing system. From that perspective, the reader is then able to put the discussion of the fiscal and environmental policies into context. Unfortunately, the chapter on France does not use that format. Instead, the chapter forces the reader to trudge through roughly-translated and choppy text to get to Appendix 1 which contains a brief overview of France's environmental administration scheme. (11.) The commentary of Gaines and Westin is the most notable. It penetrates deeply in criticizing the political system of the United States and pointing out the deficiencies and faults of the tax code with regard to its environmental impact. See, e.g., Taxation for Environmental Protection 183 (Sanford E. Gaines & Richard A. Westin eds., 1991) (commenting on the effect that political lobbyists have on tax legislation and noting the political promises that President Bush made to oil companies and oil state voters, especially Texans, while campaigning for office); id. at 187 (opining on employer-subsidized commuting expenses, that, as an environmental matter, "it would be preferable to eliminate the exclusion of the non-taxable parking benefit and to increase the public transit exemption.") See also, id. at 189. Commenting on the amorality of the tax code, Gaines and Westin criticize Congress for not harnessing the code to discourage deductions for environmentally unsound business practices. They complain that, as things stand now, "the Code effectively encourages unsound practices." See also, id. at 205. The authors' criticism is at its best when it comes to their discussion of amortization of pollution control facilities. They lament: Overall, section 169 typifies the haphazard federal approach toward coordinating tax and environmental policies and highlights the need for much more thoughtful and systematic integration of taxation with environmental quality goals. It also completely disregards the "polluter pays" principle in that it provides a subsidy to polluters to come into compliance, rather than forcing "full pricing" of the product. Id. (12.) For a discussion of the historical development of using tax theory and fiscal policy to solve environmental problems, see Adam Chase, The Efficiency Benefits of |Green Taxes', 11 U.C.L.A. J. Envtl. L. & Pol'y. (forthcoming, Dec. 1992). (13.) See Arthur C. Pigou, Economics of Welfare (4th ed. 1932). Pigou borrows from the Marshallian tax-bounty scheme to his own analysis of the producers' surplus. (14.) See William J. Baumol, Environmental Protection at Minimum Cost, 30 Am. J. Econ. & Soc. 337 (1971); William J. Baumol, On Taxation and the Control of Externalities, 62 Am. Econ. Rev. 307 (1972); William J. Baumol & Wallace E. Oates, Economics, Environmental Policy, and the Quality of Life (1977). (15.) See Ronald H. Coase, The Problem of Social Cost, 3 J.L. & Econ. 1 (1960); Ronald. Coase, The Firm, The Market and the Law (1988). Coase's 1960 article formed the premise of the "Coase Theorem", which is the proposition that when property rights in all relevant resources are clearly assigned and transaction costs are zero (e.e., parties can freely negotiate without significant costs of informing one another, enforcing the agreement, excluding free-riders, dealing with hold-outs, etc.), the parties will be motivated by market forces to enter into voluntary agreements that shift the cost of the "pollution" in such a way as to maximize the joint welfare of the contracting parties - i.e., reach Pareto optimality. Thus, the Theorem holds, when transaction costs are negligible it does not matter which party has the right to pollute or enjoin the pollution because they will eventually contract with one another so that the allocation of pollution is optimal. (16). Taxation for Environmental Protection, supra note 4, at 12, 13. (17.) Id. at 42. (18.) Germany has not adopted a bubble policy, emissions offsets, emissions banking instruments, transferable certificates, or marketable permits. Taxation for Environmental Protection, supra note 4, at 80. The adoption of those provisions would strengthen Germany's fiscal environmental approach, giving it more flexibility and perhaps - by connecting the government's disparate policies - some of the comprehensiveness it lacks. (19.) According to European Community Tax Commissioner Christiane Scrivener, The Community's proposed tax on carbon dioxide emissions hopefully would receive approval from EC ministers by the end of 1992. EC tax Commissioner, Parliament Differ on Success of U.N. Earth Summit in Rio, Int'l Env't Daily (BNA), July 22, 1992, available in DIALOG, BNA-IED at 4. (20). Coalition Government Proposes Rise in Country's Carbon Dioxide Consumer Tax, Int'l Env't Daily (BNA), May 13, 1992 available in DIALOG, BNA-IED at 11; A Day in the Life of Mother Nature; the Good News . . . , L.A. Times, May 26,1992, at 4: Private National Commission to Urge U.S. Adoption of EC-Like Carbon Tax, Int'l Env't Daily, July 9, 1992 available in DIALOG, BNA-IED at 6. (21.) See Taxation for Environmental Protection supra note 4, at 159. (22.) See id. at 174. (23.) See id. at 178. (24.) Richard A Westin & Sanford E. Gaines, The Relationship of Federal Taxes to Toxic Waste: A Selected Study, 16 B.C. Envtl. Aff. L. Rev. 753 (1989). (25.) 12 U.S.C.A. [subsection] 7401-7671q (West 1988 & Supp. 1992). (26.) The Clean Air Act's provision for tradable emisision allowances recently has made the leap from theory to reality. In May 1992, two utilities announced that they had signed a contract for the sake of emission allowances. The Tennessee Valley Authority (TVA) bought, the right to emit 10,000 tons of sulfur dioxide from Wisconsin Power and Light. That transactions will give the TVA additional time to install smokestack scrubbers or the replace high-sulfur coal with cleaner fuels. Matthew L. Wald, Utility is Selling Right to Pollute, N.Y. Times, May 12, 1992, at 1A> (27.) Ideally, the government would use the revenues generated by those fees directly to compensate victims of air pollution, or generally to fund evironmental programs. However, because of the targeting problems involved in identifying the direct impacts of air pollution, the displacement effect cause by putting the revenues into the Treasury's general funds as substitute for other taxes, results in an efficient allocation. (28.) 26 U.S.C.A. [section] 4681 (West Supp. 1992). (29.) 26 U.S.C. [subsection] 4121, 9501 (1988). (30.) Gaines and Westin expressed their regrets that the arrangements with a Japanese author fell through. Westin commented that the Japanese have developed some advanced tax proposals for protecting the environment, but have yet to pass any of those initiatives. Instead, Westin pointed out, the Japanese have sold a package of these tax programs to the Columbians. Telephone Interview with Sanford Gaines (Nov. 1991) Telephone Interview with Richard Westin (Apr. 11, 1992). (31.) Miyazawa Against Early Imposition of Environment Tax, Japan Economic Newswire Plus, July 22, 1992, available in DIALOG, Japanecon. (32.) Id.; Environment Tax Could Raise More than Money, Nikkei Wkly, June 13, 1992, at 6, available in LEXIS, Nexis Library. (33.) See, e.g., Project 88 - Round II, Incentives for Action: Designing Market-Based Environmental Strategies (sponsored by Sen. Timothy Wirth & Sen. John Heinz, 1991: A Day in the Life of Mother Nature, supra nmote 20.
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Author:Chase, Adam
Publication:Environmental Law
Article Type:Book Review
Date:Apr 1, 1993
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