Supplementary memorandum from The Royal
Society for the Protection of Birds (RSPB)
Response to specific questions from
the Environmental Audit Committee following RSPB'S Oral Evidence
Session, 26 May 2004
The RSPB is Europe's largest wildlife charity
with over 1 million members. We manage one of the largest conservation
estates in the UK with more than 180 nature reserves, covering
more than 100,000 hectares.
The RSPB is the UK member of the BirdLife International
Partnership, a global alliance of independent national conservation
organisations working in more than 100 countries worldwide. The
BirdLife International Partnership strives to conserve birds,
their habitats and global biodiversity, working with people towards
sustainability in the use of natural resources.
The RSPB's policy and advocacy work covers a
wide range of issues including climate change, energy, education
for sustainable development, marine issues, water trade and agriculture.
The RSPB also provides financial and technical support to BirdLife
partners in Eastern Europe, Africa and Asia and supports community
based projects to help deliver local benefits from sustainable
natural resource management. The RSPB were actively engaged with
the World Summit on Sustainable Development (WSSD) and are now
working to ensure sustainable development is central to policy,
decision making and action at all levels.
INTRODUCTION
The RSPB is grateful for the opportunity to
submit supplementary comments to its written and oral evidence.
We will answer the questions in the order in which they have been
posed.
1. You stress the need to work safely within
ecological limits as the bottom line. In the case of greenhouse
gas emissions and global warming, the concept of an environmental
limit has become widely understood and accepted. How well developed
is this concept in other areas?[6]
Regrettably, we fear that, while the concept
is reasonably well developed in other areas, such as biodiversity
loss, and is intuitively reasonably easy to grasp, the gravity
of its implications has not yet swayed public opinion, or led
to meaningful policy change. For example, in 2002, in preparation
for the Johannesburg World Summit on Sustainable Development,
the RSPB and Cambridge University convened a panel of internationally
renowned ecologists and economists to assess progress on conserving
ecosystems since the Rio Earth Summit in 1992. The results of
that analysis, published in the journal Science, revealed
that the total economic value of global ecosystems (wild nature)
was at least 20 trillion dollars. The study further suggested
that, on average globally, over one percent of undegraded ecosystems
was being converted to human each year, incurring an economic
loss equivalent to a permanent, accumulating loss of an additional
$250 billion each and every year into the future. This was due
to the loss of irreplaceable ecosystem services provided by nature
(eg climate regulation, nutrient cycling, flood defence, water
cycling, etc). Conversely, an expenditure of only $40-50 billion
per year on conservation could yield economic benefits of around
$4-5 trillion—a benefit cost ratio of 100:1. Regrettably,
however, rather than investing in conservation at even a fraction
of this level, the global policy community invests in (perverse)
subsidies (through trade, agriculture, fisheries, energy, etc)
of $1-2 trillion a year that encourage unsustainable conversion
of wild nature. Some of the economists involved in the study were
concerned that we had seriously underestimated the true value
of wild nature, and underplayed the gravity of its continuing
loss, by calculating total values on the basis of average costs
of loss, not the marginal costs that would increase rapidly as
surviving wild nature diminished.
With regard to plan proliferation, you refer in
your memorandum (paragraph 3.6) to the tensions and contradictions
of various strategies. Can you give some examples?
Some examples of tensions and contradictions
can be found within strategies, others between them. For example,
within the UK strategy itself, there is a clear tension between
the objectives of "high . . . levels of economic growth"
and "effective protection of the environment" (see below).
Most tensions, though, occur between strategies. For example,
while it is commendable that the DTI has adopted a sustainable
development strategy, that strategy, which emphasises carbon reduction
and resource productivity, is not wholly consonant with the departmental
strategy, which emphasises growth and enterprise. Nor is it clear
that two strategies should be necessary; ideally, the departmental
strategy would be sustainable. In a similar vein, early drafts
of the Innovation Review made scant reference to the DTI sustainable
development strategy, even though its purpose, to promote innovation,
is closely linked to resource productivity. A similar type of
tension is evident at an EU level between the Lisbon Strategy
and the (Gothenburg) Sustainable Development Strategy. Even though
the latter has now been subsumed into the former, the thrust of
the two is quite different, and the amalgamation has largely been
at the expense of the principles of sustainability.
In other instances, there is less a tension
and more a simple diffusion and blurring of objectives between
strategies. For example, within the sixth environmental action
plan of the EU, there are four priority areas: tackling climate
change; nature and biodiversity-protecting a unique resource;
environment and health; sustainable use of natural resources;
and management of wastes. The EU Sustainable Development Strategy
contains a similar, but crucially different, set of priorities:
Climate change; Transport; Public health; and Management of natural
resources, including biodiversity. It is not so much that the
plan and strategy should not contain different priorities so much
as the fact that they contain quite similar priorities expressed
quite differently. To complicate matters further, the sixth environmental
action plan itself requires the development of a further seven
thematic strategies, on: soil; pesticides; marine; waste recycling;
management of natural resources; urban environment; air quality.
Even more confusing, the so-called Cardiff process called upon
all formations of the Council to produce sector-specific strategies
for integrating environmental concerns into economic policy. Partly
as a result of this kind of plan proliferation, in which plans
are rarely cross-referenced, none of these initiatives has so
far delivered real change and some, such as the Cardiff process,
and even the EU Sustainable Development strategy, appear to have
ground to a halt.
Do you think the UK Sustainable Development Strategy
should simply provide an overarching statement of aims and principles,
or should it drive progress more actively?
The strategy should at the very least provide
a statement of aims and principles. But it could go further, in
particular by committing to particular policy measures to internalise
external costs in particular sectors, through: regulation and
standard-setting; taxation; damage liability; capped levels of
tradable permits, and so on. Internalising external costs, combined
with a programme of public awareness-raising, would do more than
anything else actually to change behaviour.
If the latter, would you welcome the inclusion
of specific topic areas (eg waste, energy) and associated targets?
A greater degree of specificity about priority
issues, targets for them, and policy mechanisms to be used to
achieve them would be very helpful. However, without a considerably
longer period of consultation, and in order to avoid a very large
and complex strategy indeed, it might be preferable to commit
in the strategy to certain priority issues, but to propose developing
targets for those issues, and the policy mechanisms to achieve
them, subsequently. The strategy, however, should make a firm
commitment to making such targets firm, rather than aspirational,
and to developing them in a fixed period of time.
What implications would such a focus on specific
areas have for other topic-specific strategies (eg the waste strategy)
and for the strategies of devolved administrations?
As indicated above, it would be possible to
identify priority issues, and to commit to producing issue-specific
targets within fixed time frames, without duplicating or making
redundant existing or future issue-specific strategies. On the
contrary, issue-specific strategies would become the vehicles
whereby priorities identified in the strategy would be taken forward.
The principal change from current practice would be that the (sustainable
development) strategy would make a clear commitment to producing
firm issue-specific targets on firm timescales; and the issue-specific
strategies would be created or revised (in the timescale specified)
to include a much higher degree of specificity than is currently
the case both about the target(s) to be achieved and the policies
to achieve them. Assuming the sustainable development strategy
were reviewed periodically, it would be possible at that time
to revisit priorities, and consider whether they needed new targets,
or replacing with emerging priorities.
Do you have any specific suggestions for ways
to reduce plan proliferation and ensure consistency across different
strategies?
Reducing plan proliferation and ensuring consistency
are two different objectives, though each would be made easier
by achieving the other. By and large the number of plans could
be reduced by considering areas and ways in which plans currently
overlap or duplicate each other, thereby introducing the possibility
of contradiction or confusion. Where overlap currently occurs,
plans could either be revised in such a way that their purpose
is more clearly differentiated from that of parallel plans, or
they could be eliminated or amalgamated. For example, there is
plenty of room for the relationship between the Lisbon and Cardiff
processes, the EU Sustainable Development Strategy, and the Sixth
Environmental Action Plan to be rationalised in this way. If such
rationalisation does occur, however, it will be crucial to avoid
economic considerations prevailing even more completely than they
already do over environmental and social ones. It is this concern
that, on balance, makes retention of a separation between HMG
departmental strategies and departmental sustainable development
strategies advisable at least for the foreseeable future. Where
such separation is retained, however, there should be a much greater
degree of cross-referencing among strategies, and active efforts
to ensure that their content, especially their objectives, are
consistent and mutually compatible.
Do you think that changing the way sustainable
development is defined in the strategy (in terms of overall definition,
key objectives, and principles) would make the slightest difference
in practice to the way Government departments implement policies?
Although it would take time for any substantial
changes to become fully internalised in the culture and practice
of Government, we do believe that an orientation in the definition
of sustainable development away from economic growth and towards
quality of life or well-being would bring about change. Nor is
it inconceivable that some such change might be both rapid and
significant. For example, had the Department for Transport taken
on the Public Service Agreement target that is currently shared
between DTI and DEFRA to reduce carbon dioxide by 20% by 2010,
it would have been much more (politically) difficult for the DfT
to have published an aviation white paper that paid so little
attention to managing and reducing demand for air travel. A white
paper emphasising demand management would have been a significant
improvement.
Apart from your suggestion for a marine indicator,
are there any other measures you would like to see included in
the indicators to reflect the extent to which the UK is currently
unsustainable?
The only other change to the basket of headline
indicators that should be considered is the removal of GDP and
GDP per capita. Not only is it far from clear that high levels
of economic growth are compatible with sustainable development,
but it is far from clear that GDP is a complete measure of economic
growth. Moreover, to a much greater extent than most of the other
headline indicators, it is a complex, heavily weighted composite
indicator, with very little transparency about its underlying
assumptions. This is not to suggest that GDP should be abandoned
for all purposes. It clearly has an important role to play in
helping to determine monetary and economic policy. But a strong
argument can be made that it is not suitable as an indicator of
sustainable development.
Is the Government adequately addressing the issue
of sustainable consumption (as opposed to production), and to
what extent will the next Strategy be undermined because of the
failure to make more progress on this agenda?
It appears to be true for many sectors and activities
that cost-reducing efficiency gains yield lower prices and increased
demand that offset, or more than offset, initial efficiency gains.
As a result, overall consumption increases. It is also true that,
while the UK is to be commended for having developed a strategy
for sustainable production and consumption, the strategy neither
acknowledges nor addresses the magnitude of the problem of consumption
or its paradoxical relationship with productivity. Indeed, by
preferring indicators that focus on relative (to levels of production)
rather than absolute reductions of resource use, it arguably masks
the problem.
That having been said, the question of how to
reduce absolute levels of consumption is probably the most challenging
we face. Certainly, there can be a business incentive to improve
productivity, and to produce services rather than goods (so long
as the environmental consequences of manufacturing are not simply
displaced, or even exacerbated, by exporting them overseas). It
is certainly possible to incentivise the move to service provision
financially, by fundamental environmental tax reform. Nevertheless,
there will still be pressure to consume. For in a free market
economy, where success is defined by economic growth achieved
through advertising, trade and commerce, there is little incentive
for commercial entities or Governments actually to discourage
consumption. Profit in the private sector and tax revenue in the
public sector would fall. So, unless the rate of efficiency gain
outstrips the rate of consumption, resource use will increase.
Nevertheless, a combination of pricing signals
that fully reflect external costs, combined with a large-scale
effort to raise public awareness and change consumer values, would,
over time, and especially if undertaken globally, take us in the
right direction, particularly if price and value messages are
reinforced by real world evidence (for example extreme weather
events) of the consequences of profligate consumption.
Was the potential conflict between sustainable
consumption and consumerism fully appreciated when this initiative
was agreed at the WSSD?
In two senses, it was appreciated. Just as there
is an intuitive understanding of the concept of ecological limits
among policy makers and the public, there is an intuitive grasp
of the conflict between consumerism and sustainable consumption.
But, like ecological limits, the conflict tends to remain an abstraction,
rather than a reality, so long as the limits have not yet been
reached. For some constituencies at the WSSD, however, especially
environmental and social interests on the one hand, and business
interests on the other, the potential conflict was more tangible.
Given that the conflict was tangible, and that the stakes are
so high, the fact that agreement was reached at all suggests perhaps
that there is little commitment actually to implement it.
Are there any machinery of Government changes
you would like to see in order to reflect better key priorities
in any future Sustainable Development strategy?
The publication of the Treasury assessment of
departmental spending bids against sustainability criteria and
PSA targets would be helpful.
In particular, do you think that overall responsibility
for Sustainable Development should remain with DEFRA, or would
it-and the SDU-be better placed elsewhere (eg Cabinet Office)?
The keys to effective mobilisation and coordination
of sustainable development, including an effective SD unit, are
adequate resources, clear objectives, and the ability (and location)
to take an overview across Government. Wherever responsibility
and the unit are located, they must be given clear political authority
from the highest levels, with clear signals and structures for
all departments to contribute. In that context, a sustainable
development network, similar to the group that formed in the run
up to Johannesburg, and similar to the new sustainable energy
policy network (SEPN), but run from DEFRA by the SDU, might be
helpful, with named participants from prescribed agencies and
departments taking part.
During the fuel duty protests of 2000, what action
did the RSPB take to make the case for maintaining the fuel duty
escalator?
For years and months before the fuel duty protests,
the RSPB had been publicly supportive of the fuel duty escalator
and had supported it in formal communications with Government.
When the protests occurred, the RSPB took action both directly
with policymakers, and through the media. Specifically, with respect
to policymakers, along with several other environmental NGOs,
we submitted (different) letters to both the Prime Minister and
the Chancellor, supporting the escalator, and requesting a meeting
with Mr Brown.
With respect to the media, we made strenuous
efforts to gain coverage for our perspective but, without previous
environmental justification for the escalator from Government,
or overt commitment to hypothecate fuel duty revenues to sustainable
transport spending, and without an environmental justification
for the escalator from Government at the time of the protests,
environmental groups found it very difficult to capture press
attention. For example, the RSPB organised a letter to the press
from a group of environmental NGOs, but the letter was not published
by the Times or the Guardian, only by the Independent.
We also arranged a joint NGO press conference in Brighton at the
start of the Labour Party conference, which was preceded and followed
by press releases announcing the conference and reporting its
results. However, only one or two representatives from the national
media attended the conference, and none reported the event. We
did gain coverage in the Independent subsequently.
All that having been said, it is probably the
case that, just as the Government could have been more explicitly
supportive of the reasons for the escalator, the RSPB could have
anticipated better the likely opposition to it, and have prepared
a more comprehensive response, including alerting our membership
to the issue, and requesting their support. In that context, when
protests appeared possible again recently we did write to some
of our members, explaining the environmental reasons for fuel
duty, and asking for their support in requesting the Government
to honour its commitment to raise fuel duty by 1.9p/litre in September.
July 2004
6 Please see a further explanation on this issue on
Ev 170-171 Back
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