APPENDIX 23
Memorandum from HM Customs and Excise
A1.
Customs and Excise's (C&E) key tax policies
were identified by the KPMG study on Policy Appraisal as being
some of the least sensitive across Government in terms of environmental
impact. Nevertheless, when the Department is required to consider
new or variations to taxation/enforcement policy the Department
incorporates environmental appraisal techniques. The approach
taken by DETR, HM Treasury and Customs and Excise to introduce
the Landfill Tax was praised in the KPMG report.
It is C&E's responsibility to ensure
that the environmental impact of such changes to policy are discussed
fully with HM Treasury.
Green housekeeping programmes carried out
by the Department to pursue its business are the responsibility
of an Environmental Team within the central estates function.
C&E has an environmental policy, which
has been distributed to all staff, and an ongoing strategy. The
Team is responsible for identifying environmental concerns and
reducing them. Significant problems not capable of resolution
within normal constraints would be identified to the Minister.
(b) C&E makes available an annual report
and further briefings to the Green Minister as required.
2. There are at present no other arrangements
for providing the Green Minister with advice on environmental
impacts except as identified above.
C&E has one full time HEO equivalent dedicated
to green housekeeping policies and operations and liaising with
other Government departments, including HM Treasury. In addition
two or three staff years are estimated to be spent across a wide
range of posts to support the Department's environmental objectives.
3. The Department provides statistics to DETR
as required. The Green Minister is briefed by HM Treasury for
Green Ministers' meetings.
4. C&E is committed to sustainable development
in line with Government policy and Treasury aims. The environment
is one factor that influences policies and programmes. Taking
proper account of the environmental impact of policy and programmes
is an important part of sustainable development.
B5. C&E has an environment policy document
which is widely available. When issued it was not intended for
publication other than to staff, visitors, suppliers and contractors.
A revised policy document has been prepared as part of a programme
to obtain ISO 14001 accreditation in one of the Department's regions.
This revised document will be made more widely available, probably
by intranet and the DETR website before the end of this year.
The revised version addresses policy appraisal
and green housekeeping policies and operations but excludes some
areas where we have only very limited or indirect responsibilities.
Strategy is documented in a guide available to estate and other
key personnel.
(a) John Cole is the "Green Contact"
and Environmental Policy Manager for C&E. He is responsible
for developing and implementing the Departments' environmental
strategy. He also chairs the Energy and Environment Inter-departmental
Liaison Group which brings together at working level representatives
from over 35 departments and agencies.
(b) C&E has 18 Energy and Environment
Managers located in HQ and regional offices. Total Departmental
resources including Mr Cole are between three and four staff years.
Excluding staff costs, fuel and water allocations and major work
projects the financial resources available specifically to support
environmental initiatives in 1996-97 were £250,000.
6. C&E's strategy clearly details the extent
of national and international commitments. A Legislative Register,
compatible with ISO14001, has been prepared which will be soon
issued to all the Department's estates offices.
7. (a/b) The Department's environmental objectives
and targets are listed at Annex A. Each region and policy unit
sets its own objectives to meet the Department's overall policy
aims.
8. C&E has set benchmarks for levels of
recycled waste paper in all offices where there is a collection
scheme. General waste figures are currently being assembled for
each site. The Department actively promotes recycling of paper,
cans, toner cartridges and NiCad batteries. Nearly all seized
alcohol that is destroyed is broken into its components and recycled
or reused. Where possible, third party incineration is with heat
or energy recovery. Reuse and sensible purchasing is promoted
at all times. C&E has produced, with DETR, a training video
on waste called "Waste Matters".
9. C&E has no agencies or NDPBs. The Department
is committed to promoting environmental awareness amongst staff
and has implemented a wide range of initiatives (e.g., courses,
energy wall charts, posters, stickers, videos, competitions, in-house
articles, exhibitions etc.). A BRECSU publication is attached.
No publicity is targeted at the general public.
10. The only stakeholders consulted on the C&E
strategy have been staff and their contracted representatives.
11. C&E is seeking accreditation to ISO14001
in one of its London regions comprising 1,000 staff and three
sites. It is expected that ISO14001 will be achieved during 1998.
The result will be reviewed and the EMS may be extended to other
areas. C&E is represented on a new Inter-departmental Working
Group on EMS.
12. A brief summary of activity/achievement
is included in the Department's published Annual Report and regular
reports are made throughout the organisation at various levels.
These reports are not made publicly available.
13. There is regular bespoke training for:
Energy and Environmental Managers two days
Building Representatives one day
Local awareness seminars and materials (etc.,)
are also available. The Department's full time environmental policy
HEO is being funded for distance learning MSc course on Environmental
Management.
C14. C&E's environmental policy contains
a commitment to sustainable development.
15. Sustainable development is a key part of
all environmental training.
D16. The Department's key impacts are listed
at Annex C.
17. The other impacts are due to the destruction
of seized goods (i.e., drugs, tobacco, alcohol);
— air emissions (incineration) and
ash disposal;
— disposal of alcohol (and packaging).
or disposal of specialised equipment and consumables;
— specialised equipment (radios, boats
etc.).
18. There are no known environmental liabilities.
19. An environment effects register has been
established for the sites being accredited to ISO14001. It is
not publicly available.
20. Only Departmental staff and contractors
have been consulted on the impacts register.
E21. The KPMG study identified the Department
as of "low" risk.
Most policy planning is led by HM Treasury.
Because of the low level of perceived risk, environmental appraisal
has not yet been incorporated into Departmental policy guidance.
Appraisal and Evaluation in Central Government 1997 is available
to key staff.
Programmes such as major works, procurement
exercises, estate rationalisation (including PFIs) and other estate
projects are subject to project initiation and post implementation
reviews in which the environmental issues are thoroughly considered.
Detailed guidance is available. Policy appraisals methodology
is not as detailed as the 1991 guide recommends but are effective
in identifying key impacts that must be addressed by the Environment
Team. Appraisals and other services have not been summarised and
are not publicly available.
22. The Department undertakes environmental
appraisal for policies after discussion with HM Treasury and for
programmes after consultation with the Environmental Team.
To ensure the Department's environmental policy
is consistently applied a Green Contact's Group is being assembled
across tax, customs and support policy teams. In the longer term,
ISO14001 will create a regularised system with an audit programme.
23. Where C&E is unable to carryout the
appraisal the service is provided by a consultant using an existing
call off contract or by tender.
24. The Department has not yet appraised the
environmental implication of recommendations arising from the
Comprehensive Spending Review as the impacts are of "low"
risk and other more significant impacts of other programmes are
being reviewed.
F25. C&E's main achievements are listed
in Annex D.
26. C&E has detailed environmental purchasing
guidance and in all major purchases reference to the environment
strategy is included in the specification and evaluation, where
relevant. A guide, "Selling to C&E" which sets out
the Department's environmental purchasing requirements, is available
to all suppliers.
27. C&E had achieved 20 per cent. savings
at the end of the first five years of the government estate energy
campaign.
G28-32. Not appropriate.
A Objectives and Targets (Draft version for ISO14001).
B BRECSU Publication.
C Key Impacts.
D Achievements.
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