Memorandum from The Royal Society for
the Protection of Birds
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 spendingas
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"
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
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
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.
Only four departmentsDETR, MAFF, FCO
and FCrefer to the environment in their CSR summaries.
There is no evidence that the environment is "at the heart
of policy making".
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
Again there is little evidence of this. Certainly
the CSR paper does not include an overall assessment of environmental
implicationsunlike 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
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,
Extra £6 million for English
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
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 publishedand open to consultation.
We support the DETR's intention to
develop the framework so that it can be used for "multi-modal"
appraisalso that alternatives to roads can be considered
alongside road proposals. This should be a high priority for DETR.
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.
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
3. WHETHER THE
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.
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 documentsbut
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.
Analysis of CSR aims and objectives
Source: HM Treasury paper issued 14 July 1998
|Department/office||Do aims include SD or environment?||Do objectives include SD or environment?
|OPRAF (rail franchising)||X
|ORR (rail regulator)||X||n/a|
|Northern Ireland Office||X||Yes|
The new departmental aims and objectives do not lay a
firm foundation for the pursuit of sustainable development.
The Committee should ask the Government why environmental
objectives are lacking for some departments and offices with major
impacts on the environmentparticularly the DTI and HM Treasury.