APPENDIX 17
Memorandum from the Royal Society for
the Protection of Birds
SUMMARY
The RSPB welcomes the publication of the new
strategy. Although it is an improvement on the previous strategy,
it could have been more "cross-cutting" and strategic.
It is weak on appraisal guidelines and sustainability principles,
for instance.
The RSPB recommends that:
— The Government should publish its
review of the sustainable development (SD) objectives of public
bodies, and clarify its intentions. It should, at least, ensure
that all Government Departments have SD aims and objectives (1);
— The Government should clarify the
relationship between the strategy and the sectoral or "daughter"
policy documents (2); and
— The Government should clarify the
relationship between this strategy and the forthcoming country
and regional strategies, and confirm that this strategy applies
throughout the UK (3).
INTRODUCTION
The RSPB is the largest wildlife conservation
charity in Europe, with over one million members. We protect wild
birds and the environment by managing nature reserves, raising
public awareness, carrying out research on species and habitats,
and by seeking to strengthen government policy towards the environment.
The RSPB is the UK partner of BirdLife International, a global
network of 62 NGOs, which has major conservation projects in Europe,
Africa and Asia.
The RSPB welcomes this inquiry. For several
years we have taken a keen interest in the UK's sustainable development
policies. Our starting point is that we believe that the conservation
of biodiversity is a key test of sustainability. We are therefore
pleased to see that the new strategy's objectives include the
protection of "things which people need or value, such as
wildlife".
1. GENERAL COMMENTS
The RSPB welcomes the publication of the strategy.
In our submission to the DETR on the consultation paper, we argued
that it should focus on "cross-cutting" or "generic"
issues, particularly the definition of sustainable development
(SD), principles for SD, SD duties for public bodies, and appraisal
guidelines. We said it should not try to explain the issues sector
by sector, but that such detailed analysis should be presented
in other documents. The Committee similarly argued in its Second
Report of 1997-98 that the strategy should address strategic issues
rather than policy details (para 54).
Set against this advice, the strategy is an
improvement on the consultation paper and the previous strategy,
but could still have been more cross-cutting and strategic. It
is weak on appraisal guidelines and SD duties for public bodies,
in particular. It does not set out clearly the relationship between
the strategy and all the sectoral policy documents. The implications
of devolution are unclear. The following sections discuss these
points in turn and then address some of the specific terms of
reference.
2. APPRAISAL
The strategy gives little guidance on policy
or project appraisal. Instead it refers to the Policy Appraisal
and the Environment leaflet (see para 5.5). We believe that the
strategy should have given much more guidance on appraisal, such
as the need to consider all options (including do-nothing and
demand management), to undertake environmental assessment and
to include wide consultation. Guidance is also needed on the treatment
of environmental impacts, like wildlife and landscape, which cannot
easily be expressed in monetary terms.
The strategy should also have clarified when
appraisal should be carried out. The above leaflet says it should
be carried out "whenever a policy or programme is likely
to have a significant effect on the environment". Recent
Parliamentary Questions have established that an environmental
appraisal was not completed for the Local Government (Best Value)
Bill or the Greater London Authority Bill. Although the Government
has claimed that an environmental appraisal of the Water Industry
Bill was carried out, as part of the Regulatory Impact Assessment,
this assessment hardly mentions the environmental impacts of key
measures. All these bills have significant environmental impacts.
In our view, the requirement for policy appraisal should apply
to bills as much as to other policy documents.
While the box on road appraisal is useful, further
examples of good practice should have been presented. Examples
could have included the weighting and scoring system used by the
Environment Agency to appraise investment projects designed to
improve water quality (the "Periodic Review"). Another
good example could have been MAFF's policy review of the Environmentally
Sensitive Areas scheme. This review included detailed environmental,
biological and landscape monitoring reports and economic evaluations
of the 22 ESAs in England.
We agree with para 5.6 on the need for economic,
social and environmental impacts to be considered together, and
look forward to the commitment to produce further guidance.
3. SUSTAINABLE
DEVELOPMENT DUTIES,
AIMS AND
OBJECTIVES FOR
PUBLIC BODIES
Para 5.4 states that whenever the Government
creates a public body, "it will consider whether to include
sustainable development in its remit". It also says that
it is reviewing the scope for including SD as an objective for
existing public bodies.
This is very disappointing—it seems that
the strategy has not taken this forward at all. We recommended
in our submission to the consultation paper that all Government
Departments and public bodies should have SD duties or purposes.
The Committee has similarly recommended that
all Departments should have SD aims and objectives(see 1 (h),
Third Report, 1998-99). As the Committee reported, seven main
departments still do not have these aims or objectives (para 40).
We are also disappointed that the strategy did
not try to summarise or explain the current SD duties, aims and
objectives, and seek to remove the "confusing array of terms
used" (in the Committee's words).
Recommendation 1:
The Government should publish its review of
the sustainable development objectives of public bodies, and clarify
its intentions. It should, at least, ensure that all the main
Government Departments have SD aims and objectives.
4. SECTORAL OR
"DAUGHTER" POLICY
PAPERS
The strategy refers to these papers in para
2.2, but does not explain what will happen to them. There is no
commitment to publish them all. For forestry, for example, there
is a commitment to publish a strategy paper (see para 8.60). For
biodiversity, we understand that there are no plans to publish
a separate document, but there will be the Millennium report published
towards the end of 2000 (see para 8.57). Other "sectoral"
papers are not mentioned in para 2.2, even though they will have
a key role in implementing the overall strategy and they have
been, or are about to be, published—eg the Transport White
Paper and papers on renewable energy, climate change and rural
policy. In fact references to other strategy documents are littered
throughout the report. Table 1 summarises some of them.
Table 1
STRATEGY PAPERS MENTIONED IN THE "KEY
ACTIONS AND COMMITMENTS" TABLES
|
| Strategy | Timing
| Page
number
|
|
| Waste strategies (draft) | 1999
| 33 |
| 6 business sectoral strategies | 2000
| 36 |
| Tourism strategy | February 1999
| 48 |
| Sustainable construction | Autumn 1999
| 49 |
| Chemicals | End 1999
| 49 |
| Sustainable distribution | March 1999
| 49 |
| RDA SD frameworks | 2000
| 54 |
| Integrated Transport Policy | July 1998
| 61 |
| Fuel poverty strategy | ?
| 61 |
| Urban and Rural White Papers | 1999?
| 69 |
| Air quality strategy | ?
| 76 |
| Sustainable shipping strategy | 1999
| 80 |
| Soil strategy | ?
| 81 |
| Biodiversity Action Plans | Summer 1999
| 84 |
| Sustainable forestry policy | 1999
| 86 |
| Eliminating world poverty | 1997
| 94 |
|
Many other references are included in the main text, for
example climate change programme (8.11), renewables (8.14) and
SD strategies for developing countries (page 89). We were unable
to find any reference to the utility review, even though one of
the outcomes of it is that ministers will issue statutory guidance
to the regulators on how they should meet environmental and social
objectives (see A Fair Deal For Consumers: Response to Consultation,
DTI, July 1998). Nor could we find any reference to the ports
policy, which is currently subject to consultation.
It would have been very helpful if the strategy had presented
a table showing all of these documents.
A key challenge will be to try to ensure co-ordination between
these initiatives. The role of the main strategy should be to
try to promote coherence and consistency. The new Sustainable
Development Commission should have a role in this (see below),
together with the DETR's SD Unit and the Environmental Audit Committee.
A related point is that in some cases the strategy presents
"sectoral" targets and in others it refers to these
other policy documents. For example, the bathing water targets
are shown on page 80, while there are no shipping targets—only
references to the shipping strategy (pp79 to 80). To be consistent
with our general approach, we would suggest not including sectoral
targets in the main document.
Recommendation 2:
The Government should clarify the relationship between the
strategy and the sectoral or "daughter" policy documents.
5. DEVOLUTION
The strategy makes it clear that much of the domestic policy
covered by the strategy will be the responsibility of the new
devolved administrations. Thus "while some of the policies
described in the strategy apply to the UK as a whole, others are
exclusive to England" (para 2.5). There is a real danger
that there will be contradictions and gaps between the different
countries' strategies, weakening the UK's overall commitment to
sustainable development. The case of the headline indicators reveals
the problems. Some of them, such as road traffic and air quality,
are domestic, but are expressed at a GB or UK level. What happens
if the devolved administrations disagree with these indicators?
The Committee should have a key role in ensuring that the
country strategies are broadly consistent with each other and
with the UK strategy. In our view the UK strategy should provide
the UK context for country and regional strategies.
Recommendation 3:
The Government should clarify the relationship between this
strategy and the forthcoming strategies for Scotland, Wales and
Northern Ireland and for the English regions, and confirm that
this strategy applies throughout the UK.
Next we turn to some of the specific points raised by the
terms of reference.
6. THE IDENTIFICATION
OF BASELINES,
PRIORITIES AND
TARGETS FOR
ACTION
The strategy is quite good on priorities (see para 10.3)
but weak on targets. However many of the detailed targets have
been (and should have been) presented in other documents, rather
than this strategic report. This would have been acceptable if
the links with these other documents had been clearer (see above).
7. THE LINKS
BETWEEN TARGETS
AND INDICATORS
The RSPB supports the linking of targets to indicators, but
only where appropriate targets can be set. The main advantage
of setting targets is that they can encourage action to reverse
adverse trends.
For some of the headline indicators, such as greenhouse gas
emissions, specific targets already exist. For the wild birds
indicator there is no specific, dated, target, but there is a
welcome commitment to "take action to reverse (farmland and
woodland bird) declines" (para 3.24). We recognise that there
are particular difficulties with developing a more specific target
for this indicator:
— First, any targets should relate to the woodland
and farmland species indicators, rather than the overall bird
indicator. The problem with targeting the latter is that even
if it was met it could conceal continuing declines in farmland
birds;
— Second, there is a danger that the targets would
supersede the Biodiversity Action Plan (BAP) targets for individual
species and would be inconsistent with them. Irrespective of any
index targets, the RSPB will continue to stress the BAP targets.
A drawback of any index target is, of course, that it could conceal
the decline of particular species.
While generally supporting the 14 headline indicators, we
still have reservations about the "brownfield" indicator.
The indicator could move in the "right" direction, with
the percentage of brownfield developments increasing, but this
could conceal an increase in the area of greenfield sites lost
through development and an increase in the loss of brownfield
sites of conservation and recreational importance.
We agree with the Government's position (see para 3.9) that
a single overall index of progress on sustainability is inappropriate:
it could conceal many adverse trends; the relative weighting of
each indicator would be controversial; and the index might not
be well understood by the public.
The other indicators outlined in the strategy require further
work. The indicators on page 30, for instance, include "Prices
of key resources (eg fuel, water)". It is unclear whether
a fall in the price of fuel is a move towards sustainability.
It would be better to focus on the overall cost of energy services
or the cost for disadvantaged households.
8. THE IDENTIFICATION
OF RESPONSIBILITIES
FOR ACTION
WITHIN GOVERNMENT
The strategy is weak on this, although admittedly it is a
difficult area. Many actions require the involvement of several
different departments and agencies, particularly when they must
be undertaken across the UK and/or in the English regions, or
require EU agreement.
9. THE ACCOUNT
TAKEN OF,
AND LINKS
MADE TO,
EU AND INTERNATIONAL
POLICY INITIATIVES
We welcome, in particular, the commitment to using the bilateral
aid programme to help implement the Convention on Biological Diversity
in developing countries (para 8.57).
10. THE STRENGTH
AND SUITABILITY
OF THE
STRATEGY COMPARED
TO (A)
EU AND INTERNATIONAL
COMPARATORS AND
(B) THE
UN REQUIREMENTS UNDER
THE RIO
PROCESS
The strategy does fulfil the Rio requirements. It reflects
many of the themes mentioned in Agenda 21 and the Declaration
on Environment and Development, such as public and NGO participation,
the integration of environmental and economic considerations in
decision-making, the precautionary principle, the polluter pays
principle and environmental assessment. The priority now must
be to implement the strategy.
11. THE ARRANGEMENTS
FOR MONITORING,
REPORTING AND
REVIEW, INCLUDING
THE PROPOSAL
FOR A
SUSTAINABLE DEVELOPMENT
COMMISSION
We agree with the plans to review progress on the strategy
annually and to conduct a full review after five years (see page
96).
The RSPB supports the role of the new Commission as outlined
in the strategy: to monitor progress and to make recommendation
for policy changes (see para 10.13). In addition, it should try
to ensure consistency between the strategy and sectoral or "daughter"
papers (see section 4) and country and regional strategies (see
5). The Commission will require adequate staffing and resources.
It must have sufficient funds to carry out detailed research and
analysis. The responsibilities of the Commission must be defined
so as to complement those of the Sustainable Development Unit,
the Environmental Audit Committee and the RCEP.
June 1999
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