House of Commons - Environmental Audit

Select Committee on Environmental Audit Minutes of Evidence

Supplementary memorandum submitted by the Ministry of Defence.

NOTES AND DOCUMENTS PROMISED DURING ORAL EVIDENCE TO THE COMMITTEE ON 7 APRIL 1998

Q1. The number of miles flown on low-flying military exercises in the UK in 1997-98, compared to the previous two years and how the system for sharing the burden around the country works.

Answer 1

The Ministry of Defence does not record miles flown and our statistics do not differentiate exercise activity from other forms of routine low flying training. However, copies of papers published in 1997 (Official Report 20 March col 860-861) and 1998 (Official Report 31 March col 445) which detail the overall volume of low flying carried out in the United Kingdom and its distribution are attached which the Committee may find useful.[3] Measured against 1988 levels, the overall number of sorties flown at low level during 1997 has reduced by a third, and those by jet aircraft by well over a half. Other tables show the relative intensity of activity within each of the Low Flying Areas; a detailed commentary is also provided.1

It is the Government's policy that, in principle, the whole of the UK is open to low flying by military aircraft in order to spread the disturbance as thinly as possible. Certain areas are excluded, either for flight safety reasons (such as the restricted airspace surrounding airports and airfields, glider sites and major industrial hazards) or to minimise disturbance to large numbers of people (towns of more than 10,000 inhabitants). Outside these areas, it is inevitable that the less populated areas will see a proportion of low flying sorties.

In addition to spreading the burden as thinly and equitably as practicable, measures are taken to minimise disturbance to those on the ground. The amount of aircrew training is limited to that strictly necessary to achieve and maintain operational effectiveness, and is kept under continuous review. Sorties are normally limited to a minimum height of 250 feet and to speeds of no more than 450 knots, even though aircrew would be required to fly much faster and lower in operational theatres. Most low flying is carried out on weekdays, with only activity by Hercules transports and helicopters in support of reserve forces generally permitted at weekends. Finally, low flying at night is required to be completed as early as possible and only in exceptional cases would low flying by jets be permitted after 11pm.

Q2. What monitoring is being carried out by the MOD on pollution from the ordnance and other chemicals dumped by MOD at Beaufort's Dyke and other sites where there was dumping on the sea bed and the results from this monitoring.

Answer 2

The Ministry of Defence does not monitor disused marine dumping sites; nor are there any plans to do so. The consensus of international scientific opinion is that both conventional and chemical munitions dumped at sea present no significant risk to the marine environment or human health if left undisturbed.

Surveys of Beaufort's Dyke were conducted by the Scottish Office Marine Laboratory in 1995 and 1996. The Final Survey Report produced by the Scottish Office in November 1996 confirmed that there was no evidence of conventional munitions or the 14,000 tons of phosgene-charged rockets dumped in Beaufort's Dyke having an adverse effect on the quality of the marine environment or the living resources that it supports. The screening analysis of samples collected during the 1995 and 1996 surveys included phosgene and mustard gas, but no trace of these substances was detected. Copies of the Final Survey Report were placed in the Libraries of both Houses in November 1996.

However fisheries departments do undertake an extensive programme of monitoring in waters around England and Wales for a wide range of contaminants and their effects on the marine environment. The Ministry of Agriculture, Fisheries and Food (MAFF) have not carried out any monitoring specifically related to explosive dumping grounds in English and Welsh waters. Their monitoring of the Hurd Deep dump site is specifically in relation to radioactivity rather than chemical contaminates. For Scottish waters, the Fisheries Research Services Laboratory in Aberdeen routinely undertakes a programme of marine environmental monitoring on behalf of the Scottish Office. This includes investigations relating to the levels of contaminants found in coastal waters and an assessment of their biological effects. A significant proportion of this work is undertaken either as part of the joint monitoring programme of the Oslo and Paris Commissions or, working in collaboration with the Scottish Environment Protection Agency, is part of the National Monitoring Plan (NMP), which is a product of the UK Marine Pollution Monitoring Management Group.

In 1997, at the request of MAFF, the National Radiological Protection Board (NRPB) conducted an independent radiological assessment of previously unreported dumpings of radioactive waste in UK sea areas. This included the dumping by the Ministry of Defence of radioactive miss-distance indicators in Holyhead Deep off Angelsey in 1974. A Report of the NRPB assessments was published in November 1997. The report found that the dumpings in Holyhead Deep would give rise to doses well within the International Commission on Radiological Protection's recommended dose limit for members of the public. Moreover, the report stated that the calculated doses from these particular dumpings were at a level considered trivial in radiological protection terms. Copies of the NRPB report were placed in the Libraries of both Houses in November 1997.

Q3. Why over 200 cubic metres of mahogany was required to refurbish ships, what alternatives to mahogany were considered and why they were concluded to be unsuitable.

Answer 3

The 204.35 cubic metres of Brazilian mahogany purchased in July 1997 is needed for repair or refurbishment work to match existing timber installed in vessels. Brazilian mahogany is highly durable, easy to work and can be made fully fire retardant, which is not the case with all timbers. The volume purchased was considered the minimum required to meet known and future requirements.

The Ministry of Defence did not consider the purchase of specific alternatives in 1997 as trade in Brazilian Mahogany is legal provided the timber comes from a managed source, which is believed to be the case with the timber MOD purchased. MOD sought and was supplied with certificates of conformity, prior to contract placement, confirming that the Mahogany came from a legal source as authorised by the Brazilian National Environmental Agency (IBAMA). MOD has seen no evidence that would lead it to conclude that the timber supplied to the Ministry of Defence was logged illegally. However, MOD is keeping its procurement policies in this area under review and will make an announcement in due course.

Q4. What length of time MOD expects to need to complete Land Quality Assessments of the 143 sites which are identified for disposal and the 80 sites with potential environmental problems.

Answer 4

Land Quality Assessments (LQAs) for some of the 143 sites identified at the beginning of April 1998 for disposal and the 80 sites identified at the beginning of April 1998 as potentially containing environmental problems have already been started. However, the length of time taken to complete the LQAs will depend upon the number of LQA phases that need to be carried out and financial authority to proceed. Completion of an individual LQA could take from a minimum of six months to more than two years.

Q5. What the timetable is for the remediation of sites where:

(a) mustard gas and other chemical weapons were stored; and

(b) mustard gas and other chemical weapons were used?

Answer 5

The Ministry of Defence is unable to distinguish between sites where mustard gas was stored and sites where some limited training with mustard gas may have taken place. All work has been completed on the mustard gas sites at Lords Bridge, Barnham, Norton Disney (forward filling depot) and Eskrick. Activity is now focused on explosive ordnance disposal (EOD) at the remaining sites at Riseley, Bowes Moor and Norton Disney (Spalford Wood sub-sites). EOD should be completed at Risely by the end of December 1998 and at Norton Disney (Spalford Wood) imminently. The task at Bowes Moor is lengthy and no estimation for completion is available currently. In each case, once EOD is complete, an investment appraisal, which will include examination of the best practical environmental option (BPEO) will recommend how best to proceed. It is not possible therefore at this time to provide an estimate of when work on these sites will be complete.

Former Chemical Weapons (CW) sites, which have been disposed of, will have been remediated before sale to a standard acceptable at that time. Should CW be found subsequently, the Ministry of Defence would respond by providing specialists to investigate and undertake clearance work. The Army has two known sites of chemical contamination at Porton Down and at Base Ordnance Depot Longtown. A desk top study has been completed in respect of Longtown, and the next step will be to consider cost and funding availability. In the case of Porton Down, I have recently advised the local MP, Mr. Robert Key, that the cost of clearance (£1 Million) would be prohibitive. The alternative is for such sites to be fenced off.

Q6. How many vehicles owned or operated by the MOD currently use liquid petroleum gas and how many are planned to be converted to it in 1998-99.

Answer 6

Although a limited number of LPG powered fork lift trucks and specialist vehicles are operated by the Royal Navy, the Ministry of Defence has no plans to procure or to convert front line vehicles to LPG. Army operational vehicles are diesel powered and, under the NATO single fuel concept, are capable of using AVTUR (aviation turbine kerosene). It is a long-term aspiration that all vehicles with compression ignition engines must be capable of using AVTUR. LPG is highly volatile and would not be suitable for use in ground operations, whereas AVTUR is less explosive than diesel. The RAF are monitoring developments in both gas and electric powered vehicles and plan to carry out a trial with a gas powered vehicle this summer. Support vehicles are increasingly procured through Private Finance Initiative (PFI) contracts and, for these applications, LPG fuelled vehicles may be used.

MINISTERIAL STEERING GROUP

Q1. What are the terms of reference for the Group and its membership and how does its work relate to that of the Defence Environment Committee? How often does it meet and how does it take forward its conclusions? What was the agenda at the one meeting since May 1997?

Answer 1

Terms of Reference

Under the Chairmanship of the Under Secretary of State for Defence, the group provides the Department's policy direction on environmental and energy efficiency matters. It determines the Department's environmental and efficiency strategies to ensure compliance with the relevant UK legislation and EC Directives and wider Government policy and to recommend the level of resources needed to implement these objectives; sets associated targets and objectives; is responsible for Departmental participation in the Government's energy efficiency campaign and ensures that Government targets are met; and receives and reviews reports from the Defence Environment Committee. The Committee meets as required and reports annually to the Secretary of State for Defence. In the past it has normally met once a year.

Membership

Under Secretary of State for Defence—Chairman

Chief of Fleet Support

Quarter Master General

Air Member for Logistics

Deputy Chief of Defence Procurement (Support)

Deputy Chief of the Defence Staff (Programmes and Personnel)

Deputy Under Secretary of State (Resources, Programmes and Finance)

Deputy Under Secretary of State (Civilian Management)

Deputy Under Secretary of State (Science and Technology)

Chief Executive Defence Evaluation and Research Agency

Special Adviser—external appointment

Director of Information Strategy and News

Assistant Under Secretary of State (Security and Support)—Secretary

Meetings/DEC

The MSG sets the agenda for environmental work to be carried out by the Department. The Defence Environmental Committee is responsible for co-ordinating its implementation through the Service, PE and DERA focal points and the Defence Estates Organisation. Rather like the Board of a company the MSG may meet once or twice a year, though of course it could meet more often should the need arise. Environmental issues are referred to Ministers and senior MOD managers outside this committee structure as and when they arise.

Agenda

The Group last met on 26 March 1998. The Agenda for that meeting was:

(1) The Government's new environmental policies and initiatives.

(2) MOD's environmental structure.

(3) The remediation of contamination/pollution and Explosive Ordnance Disposal.

(4) Environmental Appraisal and Sustainable Development.

(5) Future policies and Programmes and the Department's Green credentials.

SUSTAINABLE DEVELOPMENT STRATEGY

Q2. Has MOD contributed to the development of the consultation paper on a revised UK strategy for sustainable development (Opportunities for Change)?

Answer 2

Yes, and it continues to do so by participation in an Inter Departmental Working Group.

DEPARTMENTAL OBJECTIVES AND COMPREHENSIVE SPENDING REVIEW

Q3. Have all three Services produced strategies for implementing MOD's environment policy? Are actions to implement these strategies addressed in the Services' Management Plans?

Answer 3

The Royal Navy has an environmental strategy policy paper and its main aims were publicised by a Defence Council Instruction. Implementation of this strategy is addressed by the RN's Maritime and Land Environmental Policy Committees and management plans. The RN is developing an environmental management system.

The Army has a number of environmental manuals. Environmental management systems are in place and a co-ordinated review of all of Health and Safety and Environmental systems will be carried out this year.

The Royal Air Force's Health and Safety and Environmental manual contains comprehensive and detailed policy implementation guidance. The RAF is also developing an environmental management system. One element of EMS is the provision of trained personnel and this is being addressed within the RAF training strategy.

Q4. Has MOD considered the value of identifying budgets and expenditure on environmental initiatives to further its environmental policy?

Answer 4

The identification of budgets associated with environmental initiatives are considered during the Ministry of Defence's Long Term Costings (LTC) process. Though life costs, including disposal, are considered when assessing procurement options. This may favour more environmentally friendly solutions, but the MOD is required to have regard to the need to obtain best value for money (VFM) from the Defence budget for both the armed forces and the tax payer. The Paymaster General has recently confirmed that VFM remains the cornerstone of the Government's procurement policy.

Q5. What environmental appraisal is required for decisions regarding change in the level of military training land? Are appraisals required to incorporate consultation with the public? Are alternatives fully appraised, including increased use of simulation in training? As a particular case in point, will there be an environmental appraisal of changes consequent on decisions regarding the return of an armoured division from Germany which are being considered in the Strategic Defence Review?

Answer 5

Wherever there is a new or changed use of a defence site, including training areas, or where there is a development, a Notice of Proposed Development is submitted to the relevant planning authority which, in appropriate cases, is accompanied by an environmental statement of the implications of what is proposed. An environmental impact assessment would also be carried out if there was an intensification of use of a particular training area likely to have significant environmental effects.

At this stage, no decisions have been taken about the withdrawal of troops from Germany. In the event that any changes to training requirements would affect our use of training lands, MOD will honour its commitment to consult.

Simulation is already an essential element of training and there are proposals to expand this area, but simulation is only an aid to training and must not be regarded as a substitute.

RESOURCE ACCOUNTING

Q6. How will MOD account for its environmental policies and performance in its resource accounts?

Answer 6

Provision will be required to be made in Resource Accounts where the Ministry of Defence's operational activities gives rise to environmental liabilities, i.e., an actual or constructive obligation to carry out decommissioning or restitution. Where the expenditure covered by environmental provisions gives rise to future Departmental outputs, the provisions are capitalised. The capitalised values are depreciated over the estimated useful lives of the assets.

Provisions are shown on the face of the Resource Accounting Balance Sheet and in the notes to the accounts which set out a brief description of the obligation, the amount provided for, the discount rate (if appropriate) with amount provided for discount, undiscounted amounts, and movements in year.

The accounting policy for environmental provisions is contained in the MOD Resource Accounting Policy Manual.

ENVIRONMENTAL APPRAISAL

Q7. MOD notes that appraisals may contain sensitive security or commercial information which could not be released to the public. The policy guidance recently distributed by the DETR on Policy Appraisal and the Environment suggests that the best way of publishing environmental appraisals will often be as part of the announcement to introduce a new policy or programme. Could MOD comply with this? Could MOD also not state for all major equipment purchases the environmental implications considered and the environmental performance of the item procured?

Answer 7

In cases where appraisals do not contain sensitive security or commercial information we would be able to publish the environmental appraisals. In the case of major equipment procurements it is likely that the environmental performance of the equipments would be bound up with information of a sensitive nature. However, it is the Government's policy to be as open as possible in the publication of information of concern to Parliament and the public.

ENVIRONMENTAL MANAGEMENT SYSTEMS

Q8. Is there a difference in the order of magnitude in the costs of accreditation of Environmental Management Systems and quality management systems (ISO 9001) and Investors in People? What would this cost cover? To what extent would this be for costs which should be borne in any case to achieve best practical environmental management systems?

Answer 8

The actual cost of developing and implementing Environmental Management Systems depends on the size and complexity of the site under consideration. Costs for one of the more complex sites belonging to the Defence Evaluation Research Agency (DERA) have been estimated at £80K with a further £20K likely to be incurred fully to establish the system, including the training of personnel. The costs of accreditation are relatively small when compared to development and implementation costs. The potential cost of accreditation to ISO 14,001 at one site are summarised as follows (figures as provided by Lloyds Registry):

Application fee	£445
Review stage 1	£625
Review stage 2	£625
Routine survey	£550	(conducted every six months).

Similarly the cost of IS0 9,001 will vary considerably according to the size and technical complexity of the contractor being assessed. These costs could range from £10K up to £250K.

The Ministry of Defence currently has some 400 units seeking accreditation for Investors in People (IIP) and the average costs of assessment are £550 per day. The achievement of IIP accreditation by the end of 1999 accords with wider Government policy, whereas there is no similar mandate for ISOs 9,001 or 14,001.

A comparison of the relative costs of these systems cannot be made in any meaningful way given their different purposes and the variety of separate factors which can affect cost in each case.

PROCUREMENT

Q9. What are the procedures for authorising procurement which requires exemption from UK environmental legislation on grounds of national security or operational reasons?

Answer 9

The Ministry of Defence's policy is that procurement should comply with all current and foreseen environmental legislation and that defence exemptions would only be invoked for essential national security or operational reasons. All project approval submissions must state whether procurement options comply with current and foreseen legislation; the need to exercise Crown exemptions will be one of the factors considered during the approval process. Where Crown or Defence exemptions can only be granted by the Secretary of State, submissions will be made which will include legal advice on the scope for exemptions.

Q10. Has the Department audited actual procurement practices to confirm whether purchases are being made in accordance with the policy requirements?

Answer 10

Formal guidance on managing the environmental aspects of procurement was issued in November 1996 to all staff involved in equipment procurement. Procurement of defence equipments, particularly those which require a formal Environmental Impact Statement, can take many years and it is probably too early to audit the effectiveness of the new instructions. In the meantime, submissions for approval of procurement are checked to ensure that all aspect's including environmental issues have been addressed and Equipment Support Managers are required to report to procurement staff any environmental difficulties associated with equipment.

Q11. What quantities of hazardous chemicals were purchased by the MOD in 1997-98 and how does this compare with quantities purchased in the previous two years?

Answer 11

The Ministry of Defence does not monitor centrally the purchase of hazardous chemicals. All uses of hazardous chemicals require Risk Assessment before any process using these chemicals can take place under the detailed requirements of the Control of Substances Hazardous to Health (COSHH) Regulations 1988 (as amended 1994), and the more general requirements of the Health and Safety at Work etc. Act 1974.

The Secretary of State for Defence has issued a policy statement on health and safety which requires the Ministry of Defence to meet all the requirements of such legislation. There is no exemption from the requirements of COSHH.

ENERGY EFFICIENCY