Select Committee on Environmental Audit Third Report



APPENDIX 7

Memorandum from The Royal Society for the Protection of Birds

INTRODUCTION

  The RSPB is interested in the CSR because Governmental expenditure decisions have a major impact on birds, biodiversity and the wider environment. The Government has made commitments to the conservation of biodiversity and to sustainable development, which need to be supported by modest additional spending—as we identified in our submissions to the CSR last year.

  The UK's Biodiversity Action Plan states that "Conservation of biodiversity should be an integral part of Government programmes, policy and action (page 15)." The Sustainable Development Strategy calls for "integration of environmental concerns into decision-making at all levels" (29.2).

  Our conclusion is that the CSR largely failed to reflect these commitments.

  Our submission is presented in order of the terms of reference.

1. WHETHER DEPARTMENTS AND THE TREASURY TOOK ENVIRONMENTAL AND SUSTAINABLE DEVELOPMENT CONSIDERATIONS INTO ACCOUNT IN REVIEWING PUBLIC EXPENDITURE ALLOCATIONS.

  There is little evidence that many Departments, including the Treasury, took account of environmental considerations in the CSR. The nine-page overview chapter of the CSR White Paper (Cm 4011, hereafter referred to as the CSR paper) has only one reference to sustainable development (under transport policy). Chapter 2 includes a section on promoting sustainable growth (paragraph 2.1 to 2.8) which makes no mention of the environment. Only a box, two pages later, on "Environmentally sustainable growth" redresses the balance, but this has all the signs of being an after-thought.

  Paragraphs 2.1 and 2.2 sum up the problem. Paragraph 2.1 refers to the Government's central aim of raising the sustainable rate of growth. Paragraph 2.2 identifies new challenges to improve the quality of life. Neither paragraph mentions the environment.

  The Chapters on DETR, MAFF and FCO, and the section on the Forestry Commission, contain some good references to the environment. However the chapters on DfID, DTI, the Scottish Office (except the Forestry Commission), the Welsh Office and the Northern Ireland Office do not even mention the environment, although we would have expected them to. For all these departments (except for DTI) this is at odds with the departmental objectives (see table below) which do cover the environment (surprisingly, the DTI does not have any environmental objectives). Other departments also have no mention of the environment. Overall there is no evidence that the Government is fulfilling its manifesto pledge:

    "We will put concern for the environment at the heart of policy making".

  Critically there is no evidence in the CSR that the Government is interpreting the term "sustainable growth" as environmentally sustainable growth. This is despite pre-election statements and the July 1997 Budget which stated:

    "(The Government's) central economic objective of achieving high and stable levels of growth . . . must be achieved in a way that is environmentally sustainable" (paragraph 1.70, Red Book).

  This could be addressed, in part, by using terms such as "environmentally-sustainable economic growth" or "sustainable economic development" instead of "sustainable economic growth" in this type of document.

Conclusion

  Only four departments—DETR, MAFF, FCO and FC—refer to the environment in their CSR summaries. There is no evidence that the environment is "at the heart of policy making".

Recommendation

  Future CSRs should ensure that all departments which have a major impact on the environment fully address environmental issues in their reviews.

2. WHETHER NEW SPENDING PROPOSALS HAVE BEEN SUBJECT TO ENVIRONMENTAL APPRAISAL AND APPROPRIATE MEASURES TAKEN TO ADDRESS POSITIVE AND NEGATIVE SUSTAINABLE DEVELOPMENT IMPLICATIONS

  Again there is little evidence of this. Certainly the CSR paper does not include an overall assessment of environmental implications—unlike the Budget of March 1998 which at least attempted to do this (see Table 5.3 of the Red Book).

  The CSR paper does include reference to a limited number of measures which will benefit the environment, for example:

    —  Extra £174 million on energy efficiency (paragraph 8.8).

    —  Replace production-related support for hill farming with a scheme to maintain the environment (paragraph 18.7).

    —  Cessation of forest sales and increase in FC budget to make up shortfall of income.

  Since the publication of the main paper further announcements have been made which will benefit the environment, such as:

    —  Extra £6 million for English Nature.

    —  Extra funding for the National Parks, the Broads Authority and the National Forest Company.

  These measures are all welcome, even though there is no evidence that they have been subject to environmental appraisal. The RSPB awaits announcements on a number of key environmental initiatives, such as funding for the Agri-environment measures (to support environmentally-sensitive farming). This highlights the fact that the publication of the main paper in July has not concluded the CSR; many announcements on detailed measures are still to be made.

  The CSR paper does not appear to refer to any measures to address "negative sustainable development implications"—nor indeed does it acknowledge that any proposals will have negative implications. However, because the paper is so "broad-brush" it is difficult to identify any specific proposals which will damage the environment.

  We are awaiting clarification on some aspects of the CSR announcement relating to the FC which have environmental implications, including the requirement to "provide better accountability of decisions on environmental outputs." Any proposal to meet the FC target of generating additional income from the forest estate by selling long term felling rights must be subject to a strategic environmental assessment before this experimental approach is adopted. No such assessment is presently planned.

The appraisal of roads schemes

  The main area where CSR proposals have definitely been subject to environmental appraisal is trunk roads policy in England. The details are contained in New Deal for Trunk Roads (DETR, July 1998) and three supporting papers on Understanding the New Approach to Appraisal. The CSR paper does not include any details, but refers to the main transport White Paper.

  The RSPB has produced a four-page assessment of the new appraisal framework (available on request). Our main points are as follows:

    —  The new appraisal framework uses a multi-criteria approach, which has definite advantages over cost benefit analysis. In particular, it does not require monetary valuation of environmental impacts, which is so problematical.

    —  A major concern is that it is unclear how decisions were taken under this framework. Despite statements that there will be a "strong presumption" against damage to SSSIs etc., three road proposals which will seriously damage biodiversity were approved.

    —  Road schemes are analysed against 15 sub-criteria, including biodiversity. For each sub-criterion there is an "assessment"; for biodiversity this is a descriptive assessment which ranges from "very large negative" to "large positive" impacts. Although all these assessments have been published, and much more material generally has been published than ever before, the RSPB would like to see the justification for these assessments published—and open to consultation.

    —  We support the DETR's intention to develop the framework so that it can be used for "multi-modal" appraisal—so that alternatives to roads can be considered alongside road proposals. This should be a high priority for DETR.

Conclusion:

  There is no evidence of widespread environmental appraisal within the CSR process. The only area where detailed appraisals have been published is trunk roads in England.

Recommendation:

  The Committee should welcome the new roads appraisal framework, and support the use of similar multi-criteria approaches in other policy areas, as an alternative to cost benefit analysis.

3. WHETHER THE NEW REGIME FOR PLANNING AND CONTROLLING PUBLIC EXPENDITURE LAYS A FIRM FOUNDATION FOR THE GOVERNMENT IN ITS PURSUIT OF SUSTAINABLE DEVELOPMENT (INCLUDING THE NEW DEPARTMENTAL AIMS AND OBJECTIVES; PUBLIC SERVICE AGREEMENTS, AND CABINET COMMITTEE REVIEW OF DEPARTMENTAL PERFORMANCE)

  Our comments above indicate that the new regime does not provide a firm foundation for the pursuit of sustainable development. The section below reinforces this conclusion. We do not have any specific comments on public service agreements or the Cabinet Committee, although we do believe that your Committee should have a key role reviewing departmental performance.

NEW DEPARTMENTAL AIMS AND OBJECTIVES

  The table below lists those departments/offices which the RSPB would have expected to have environmental aims or objectives. They all have a significant impact on the environment. It is therefore disappointing that only four have environmental aims and eight or nine have environmental objectives.

  The DTI and the Treasury are the most prominent examples of departments with major impacts on the environment, which fail to have environmental aims or objectives. These impacts and responsibilities have been acknowledged in other documents—but not here.

  This, again, is at odds with the Government's commitment to put the environment at the heart of policy making. The RSPB would like to see all the departments in the table, at least, to have environmental objectives. Preferably all departments should have such objectives. Furthermore, those with significant impacts on biodiversity, should have specific biodiversity objectives (as does the Forestry Commission).

  However, having environmental objectives alone is obviously not enough. The analysis of the CSR paper (see section 1) shows that four departments (DfID, Welsh Office, Scottish Office (excluding FC) and Northern Ireland Office) have environmental objectives which are not reflected in the CSR paper.

TABLE 1

Analysis of CSR aims and objectives

Department/officeDo aims include SD or environment?Do objectives include SD or environment?
DETRYesYes
OPRAF (rail franchising)X Yes?
ORR (rail regulator)Xn/a
FCOXYes
DFIDXYes
DTIXX
OFFERXX
OFGASX?X
DCMSXX
MAFFYesYes
Scottish OfficeYesYes
Forestry CommissionYesYes
Welsh OfficeXYes
Northern Ireland OfficeXYes
HM TreasuryXX
Source: HM Treasury paper issued 14 July 1998

Conclusion

  The new departmental aims and objectives do not lay a firm foundation for the pursuit of sustainable development.

Recommendation

  The Committee should ask the Government why environmental objectives are lacking for some departments and offices with major impacts on the environment—particularly the DTI and HM Treasury.

November 1998


 
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