APPENDIX 19
Memorandum from The School of Public Policy,
The University of Birmingham
This submission draws on a consultancy on cross-cutting
issues submitted to the Department of the Environment, Transport
and the Regions and published in February 1999.[13]
Dr Andrew Coulson, author of this submission, was responsible
for the Chapter on Sustainable Development. He has an MA and PhD
from the Faculty of Economics and Politics at Cambridge University,
and has worked as an economic adviser in Africa and for a local
authority in Britain, before joining Birmingham University in
1984. He is a member of the Midlands Regional Environmental Protection
Advisory Committee, the West Midlands Round Table on Sustainable
Development, and until recently chaired the Environmental Forum
of Birmingham City Council.
We welcome the revised strategy, especially
its emphasis on the social aspects of sustainable development,
and the discussion in Chapter 9 of its implications for the UK
in its relationships with the rest of the world. The strategy
correctly recognises that a sustainable UK requires sustainable
European and world economies, and the alleviation of extremes
of poverty. There are, however, limitations to the revised strategy,
and the rest of this submission considers some of these.
In particular, it does not assess, or refute,
arguments that are used against sustainable development. Nor does
it have a clear implementation strategy that will assist it when
conflicting interests have to be dealt with. It does not discuss
the issues which may arise when there are cross-cutting interests,
for example between short term benefits for agriculture and long-term
bio-diversity and maintenance of soil fertility, or between benefits
to industry and employment in the short term and undue use of
road transport or greenfield sites. It has little to say about
recycling, which it interprets mainly as a means of waste reduction
rather than an opportunity for the restructuring of key sectors
of British industry. It makes some useful points about sustainability
in the poorest countries of the world, but not with complete clarity.
We discuss these points in turn.
ARGUMENTS AGAINST
SUSTAINABLE DEVELOPMENT
Any intervention by a government in favour of
sustainable development is an admission of market failure. It
will have costs, and there is the possibility that it will have
unforeseen consequences. It follows that interventions should
be kept to the minimum, and kept under review.
On the other hand, it is undeniable that markets
find it hard to deal with the long-term negative implications
of policies, especially when these provide short term benefits.
It is also the case that many businesses, especially small enterprises,
do not take environmental issues seriously, even when minimal
change could have direct benefit to their bottom line, for example
through energy conservation, more efficient uses of materials,
savings in transport costs, or less usage of chemical inputs.
IMPLEMENTATION
It follows from the above that issues of implementation
have to be an essential part of any strategy for sustainability,
more so than the present document suggests.
In our report for the DETR on cross-cutting
issues[14],
we used analysis by Hall and Roome, who suggest that businesses
may approach sustainability in one of three ways[15].
These may also be phases in the life of a business:
— in the first phase, the business
is hostile, and has to be compelled to adopt environmentally progressive
policies reluctantly, ie by regulation or "compliance";
— in the second phase, the business
can be persuaded that it is in its own economic interest to take
the environment seriously. It reviews its activities, and finds
ways in which it can conserve or reuse resources, or make savings
in transport, energy and materials costs.
— the third of Hall and Roome's phases
involves cultural change, so that the business no longer sees
sustainability as a liability or a problem, but as a business
opportunity. By being at the forefront of environmental innovation,
it can find comparative advantages. It uses its commitments to
the environment as a marketing tool. It attracts employees who
are interested in innovation and improvement, and think laterally.
It is in a position to help in drawing up the rules by which companies
are regulated or audited, rather than being the passive recipient.
However, while such opportunities are open to
large companies, SMEs are less able to commit staff time and capital,
and often regard making a commitment to sustainability and environmental
improvement as an unnecessary risk which gives their competitors
an advantage in the short term.
The move from the second of these phases to
the third involves a quantum leap. It is easy to support the environment
when there are clear commercial advantages—"win-win
situations"—as when energy is saved, or a commercial
outlet found for what was hitherto a waste product. It is much
harder when the advantages are long term or difficult to quantify,
do not accrue directly to those who make the investment (as with
many of the advantages of not using road transport, which make
it easier for those who do), or involve untried new technology.
Most of the policy suggestions in the Strategy
assume that businesses are in the second of these phases: that
is that if they were better informed they would achieve short-term
bottom line benefits from implementing environmentally enlightened
policies. The reality is that many will only do so if compelled.
And that large well-resourced companies are best able to make
the investments in research and new technology that will put them
into the third phase, at the forefront of environmental practice,
with consequent long-term benefits.
INDUSTRY
Thus it is surprising that the Strategy document
does not say more about regulation of industry, and the problems
this raises for regulating agencies, the Environment Agency in
particular. There will often be significant commercial advantages
to firms that do not implement regulations. A level playing field
is essential, and that means that such firms cannot be allowed
not to obey environmental regulations. But prosecution is expensive,
not always successful, and risks severe damage to a business's
reputation. Thus regulators prefer to threaten prosecution, and
then to negotiate. The Government needs to make it absolutely
clear that, one way or the other, it will not tolerate non-implementation
of environmental regulations.
The Government can increase the number of "win-win"
situations by use of economic instruments, such as the landfill
tax. This is undoubtedly a sensible approach, provided taxes are
not levied in such a way as to make whole swathes of industry
uncompetitive, and that strong enforcement regimes are in place
to deal with those who avoid the taxes.
There are potential problems when industrial
investment creates jobs but at a cost to the environment. The
technology used by inward investors is usually state-of-the-art,
and relatively environmentally friendly. But problems are created
by the requirement of some inward investors for greenfield sites
which not only use agricultural land, but create urban sprawl
into the countryside, and also may require large numbers of car
journeys and lorry movements. The Government Offices in the Regions
and Regional Development Agencies need to be given specific performance
measures to channel as much inward investment as possible to brownfield
sites. Where greenfield sites are used, rail and bus networks
should be developed, and wherever possible these businesses should
be assisted in using railfreight. These problems are expressed
in more detail in our report already referred to.[16]
AGRICULTURE
The Strategy correctly points out that reform
of the Common Agricultural Policy is the key to minimising the
environmental impact of agriculture.
There are many cases where farmers, like the
owners of many other types of small business, could increase their
profits and at the same time have less adverse impact on the environment—true
"win-win" situations. A good example is where excessive
nitrate fertiliser is used on grassland, with much of this running
off into streams and rivers. The strategy is forthright about
the excessive use of pesticides—many of the same arguments
apply to fertilisers.
Many farmers have also taken a short term view
of biodiversity, for example when allowing hedgerows to be grubbed
up to create larger fields—the main reason for the loss
of species of hedgerow and woodland birds, and increased risks
of plant diseases, requiring increased chemical controls.
The Strategy should stress the value of locally
produced seasonal crops, and seek ways of promoting them, for
example "farmers' markets".
The Strategy avoids confronting the vested interests
that have such influence on agriculture—supermarket chains,
chemical companies, seed companies, drug companies (eg makers
of antibiotics) and the large food and feed processors. The Government
should be very wary of any technology or marketing tool that concentrates
control of agricultural technology in few hands.
RECYCLING
Recycling is described in the Strategy as a
desirable means of reducing waste. But it is much more than this.
The work of Robin Murray[17]
and others has shown that it is possible to achieve recycling
rates from domestic and industrial waste of 60 per cent or more;
but only if there are long-term stable markets for the recycled
materials. Thus Murray sees London as a "mine" for paper—because
of the large quantities that could be recycled. But for this to
be economic, industry has to adapt by building more paper mills
that used recycled paper as a feedstock, and then to negotiate
long-term contracts at fair prices with those who collect recycled
paper. Similar arguments can be made about plastics and glass.
The benefits will be less use of raw materials, less use of energy,
less discharges of greenhouse gases, and more jobs created in
this country.
However, we need a greater degree of sophistication
in the arguments than has to date been common. Thus it will not
be the Best Practicable Environmental Option to recycle glass
in Cornwall if it has to be shipped by road to St Helens. Nor
is glass recycling environmentally best practice if large numbers
of short car journeys are required to deliver small quantities
of materials.
Murray also demonstrates the environmental advantages
of recycling, based on industries geared up to use recycled products
as feedstocks, when compared with incineration, which is, at best,
an inefficient method of generating electricity and heat. The
government would be well advised to consider these arguments and
the economic logic behind them in detail, and to avoid being pushed
by industry and local government into a "dash for incineration".
INTERNATIONAL DEVELOPMENT
An important aspect of this is that countries
and regions should grow as much of their own food as possible,
and at times this may require them to protect their markets from
imports. It would be useful to clarify the government's position
on this point, since it is not absolutely clear on page 92.
In conclusion, there is much that is worthy
in this Strategy. What it now needs is joined up thinking, involving
DTI, MAFF, the Environment Agency, the Regional Development Agencies,
and the representatives of private business, to put more teeth
into the implementation. The worst mistake we could make would
be to imply that this will be painless.
June 1999
13 Cross Cutting Issues in Public Policy and Public
Service, Sue Richards ed, DETR, 1999. Back
14
ibid, Chapter 2. Back
15
Hall, Sue and Nigel Roome (1996) "Strategic Choices and Sustainable
Strategies" in Peter Grownewegen et al (eds.) The Greening
of Industry: Resource Guide and Bibliography Washington DC:
Island Press, pp 9-36. Back
16
Ibid. Back
17
Re-Inventing Waste: Towards a London Waste Strategy (by
Robin Murray et al) Ecologika, August 1998. Back
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