Memorandum from Friends of the Earth
Friends of the Earth welcomes this opportunity
to respond to the Committee's inquiry. Our response focuses on
the headline questions posed by the Committee.
1. PROGRESS SINCE
1999
Friends of the Earth have always viewed the
development of a Sustainable Development Strategy (and the supporting
tools and structures) as being absolutely necessary (if not sufficient)
to achieving sustainable development in the UK and abroad.
Since 1993 Friends of the Earth has actively
contributed to the debate on what would constitute an effective
sustainable development strategy; in particular promoting the
core concepts of equity and environmental limits as a overarching
rationale for policy and target setting; which necessitates a
reframing of economic policy.
We believe that each successive strategy has
been a marked improvement on the previous version, both in terms
of the content, and the mechanisms to implement and monitor progress
across Government. The accompanying reporting on sustainability
indicators has also been a major step forward—the UK is
ahead of other nations in this respect.
In our view there are however three major obstacles
to the sustainable development strategy delivering its stated
aim of "a better quality of life for everyone, now and for
generations to come". Tackling these should be the priorities
for the strategy's revision.
First, the strategy, and indeed Government as
a whole, treats the economic growth objective as its overriding
priority. This often has major conflicts with the environmental
and social objectives, and must be addressed. We return to this
issue in section 2.
Second, the environmental and social objectives
are narrowly or weakly defined. Environmental limits—such
as climate change—are not seen as an absolute constraint,
but instead something which can be traded off against other objectives.
There is also very little definition of what the Government means
by or will do about the third objective: "prudent use of
natural resources". There has been considerable progress
on the social objectives, but the focus is primarily on social
objectives in the UK. Our impacts on people in other countries
(for example through the UK's large ecological footprint), and
people in other generations (for example from the release of persistent
bio-accumulative chemicals) are currently accorded less weight
in the social objective. Mechanisms such as "per capita equity"
in the climate debate should be used to address these international
and intergenerational social concerns.
Third, delivery of the strategy is severely
hampered by its location within Government. Sustainable Development
is an overarching objective, requiring the active participation
of all Government departments. It needs to be delivered from the
centre. This is not a criticism of DEFRA—it would be equally
inappropriate for the strategy to sit in DfT, or DoH, or the Home
Office. The strategy should be delivered from the Cabinet Office.
We return to this issue in section 4.
2. DEFINING SUSTAINABLE
DEVELOPMENT
The definition of sustainable development in
the Strategy is critical, because it should provide the context
for all Government policies.
The Government's use of four key objectives
has provided enough room for interpretation to allow wide political
support. However, the main problem which has arisen is that it
fails to recognise or analyse the relationships and interdependencies
between these objectives. Too often, measures or policies are
justified because they deliver on one objective, without regard
to the effects on the other objectives. There is a focus on "balancing"
or "trading-off" of objectives, when instead the aim
should be to meet these objectives together.
This ambiguity has allowed for progress to be
made in familiarising some areas of Government policy with the
need to improve, by accounting for each of the three basic elements
of sustainable development. But if the Sustainable Development
Strategy is to make a meaningful contribution in the next decade
and beyond the Government has to grasp the nettle and define sustainable
development in terms of relationship between society, the environment
and the economy. Only then will it be able to drive the transformation
required.
2.1 ECONOMIC
ISSUES
This is all the more important because evidence
from key areas of policy making demonstrates that the Government
already regards conventional economic growth as its primary objective
with social and environmental justice playing beneath this. We
wholeheartedly agree with the Sustainable Development Commission's
description of the current situation and the shift required to
achieve sustainable development:
"We see a society and a Government whose
primary objective is still the achievement of economic growth
as conventionally understood and measured, with as much social
justice and environmental protection as can be reconciled with
that central goal. We envisage a society whose primary goal should
be the wellbeing of society itself and of the planetary resources
and environment that sustains us all, with economic objectives
shaped to support that central goal rather than the other way
around."
The logic of this shift is to recognise that
the economy is one of the key means to achieve the goal of social
wellbeing and that it must operate in a way that protects the
environment upon which we and future generations depend.
Elevating this "means-to-an-end" to
a standing well above the overall end itself and the real-world
limits it has to operate within has had perverse and disastrous
consequences. Aiming for simply more, not better, economic growth
has:
— powered the burning of fossil-fuels
at a scale that has brought the environmental limits of the planet
within touching distance and made real the threat of dangerous
climatic change;
— stimulated the development of chemicals,
materials and organisms that are toxic, bioaccumulative and threaten
human health and living systems both in the short and long term;
— driven the irreversible destruction
of habitats around the world resulting in the loss of biodiversity
on a catastrophic scale;
— widened inequalities between rich
and poor between and within nations, and between regions in the
UK;
— and—according to the New Economics
Foundation's recent publication "Chasing progress"—failed
to increase the happiness of people.
In defining sustainable development to underpin
a strategy that will actually deliver the transformations required
by these urgent challenges the Government must recognise that
the elements it currently lists as objectives are in essence an
overarching goal ("social progress which recognises the needs
of everyone"), a real-world framework based on environmental
limits within which to achieve this goal ("effective protection
of the environment" and "prudent use of natural resources")
and a powerful method for achieving it (economic activity).
Under this definition dynamic economic activity
remains central to achieving sustainable development but critically
it has to become more effective by focusing on delivering its
goal—the wellbeing of society—and by avoiding damaging
the resources and environment upon which society and the economy
itself depend. In short, for significant progress to be made toward
sustainable development economic policy has to be firstly about
quality and secondly about quantity. At present it is about quantity
full-stop.
The 1999 strategy contained good rhetoric from
the Prime Minster on this point: "But focusing solely on
economic growth risks ignoring the impact—both good and
bad—on people and on the environment. Had we taken account
of these links in our decision making, we might have reduced or
avoided costs such as contaminated land or social exclusion. Now,
as we approach the next century, there is a growing realisation
that real progress cannot be measured by money alone . . . We
must ensure that economic growth contributes to our quality of
life, rather than degrading it". This approach has also been
endorsed within the strategy: "The quality of growth matters,
as well as the quantity. Some forms of growth are more sustainable
than others". However, in practice there is no strategy for
quality growth—quantity still remains the priority.
Below are four examples of how at present the
Government's interpretation of the relationship between society,
environment and economy plays out on the ground.
AVIATION
The December 2003 Aviation White Paper is a
clear example of how the Government trades off environmental and
social concerns for economic growth, rather than promoting economic
activity which meets environmental and social goals. In particular:
— it predicts its policies will lead
to a tripling of aviation's carbon emissions, in the context of
a 60% reduction target for the country as a whole;
— it suggests that price signals could
be used to tackle aviation's carbon emissions through economic
instruments. However, the models it uses to forecast demand assume
that there is no effect of such instruments on price and therefore
demand. The need for increased capacity is based on demand forecasts
that assume a 1% annual fall in prices when merely keeping prices
constant removes the need for any additional capacity (and also
does not price people off the airlines);
— it asserts that "not providing
that additional capacity would significantly damage the economy
and national prosperity" when passenger numbers can increase
60% without additional capacity;
— having made it clear that even the
potential of slowing quantitative growth in this sector of the
economy is not acceptable to the Government it treats the environment
as a secondary concern where it will "seek to reduce and
minimise" damage to the environment and communities.
We agree with the Environmental Audit Committee
that the increases in emissions predicted from this approach of
placing quantitative economic growth as the prime objective is
likely to render the Government's carbon reduction target "unachievable".
We also note that on economic instruments on the one hand the
Government commits itself to externalising the substantial external
costs of aviation and on the other hand failed at Budget 2004
to use the one current tax measure at its disposal to make progress
on this (Air Passenger Duty) despite record passenger numbers
passing through BAA's seven UK airports in the year up to March
2004.
TRANSPORT SPENDING
Currently, large revenue streams are diverted
into road building, in a relatively futile, environmentally damaging
and socially regressive attempt to tackle congestion. The 2004
spending review and the review of the Transport 10 year plan offers
an opportunity to realign transport priorities so they meet environmental,
social and economic objectives together. Friends of the Earth
and 30 environment and social justice groups are advocating the
Way to Go Manifesto—13 policies to transform UK transport
policy. The Way to Go Manifesto advocates that transport funding
should prioritise providing decent alternatives to motoring, by
promoting safer streets for walking and cycling and providing
quality public transport. This would meet three Government objectives
together—it will reduce environmental impact, it will reduce
social exclusion (by providing decent alternatives for the 28%
of households who do not have access to a car) and it will reduce
the need to travel. These measures are also financially progressive,
unlike current transport spending (see figure 1 and 2).
These policies would also help to meet nine
different Public Service Agreement Targets—across Government
(DEFRA, DfT, DTI, Home Office, DoH). They would also be good for
the economy—in many instances better for the economy than
road building (for example public transport investment creates
more jobs per pound than investment in road infrastructure).
Figure 1—Who benefits from Way to
Go spending increases
The proposed measures for funding are also progressive:
as Figure 2 shows, 7% would come from the poorest households,
37% from the richest.
Figure 2—Who would pay for Way to
Go spending increases
Economic policies designed to meet environmental
and social goals together are better at meeting the Government's
4 sustainable development objectives together. This is a more
effective approach than pursuing economic growth first and hoping
that the revenues created can offset the gross environmental and
social damage caused—the central theme running through the
last 20 years of transport policy.
SCIENCE POLICY
AND THE
CASE OF
GM CROPS
Science and innovation is identified by the
Government as an important method of increasing the quantity of
economic growth but it has also proved to be a double-edged sword
for the environment and society. The Wellcome Trust, for example,
found that only 43% of the public thought the benefits of science
are greater than any harmful effects[1]
Innovation trajectories that have powered the phenomenal growth
in fossil fuel burning, the spread of chemically intensive farming
systems, the widespread use of toxic chemicals and development
of nuclear power have all resulted in clear and significant negative
impacts upon the environment and society. Redressing these will
require, amongst other things, strong on-going economic and industrial
policies and fundamental technological transformations that radically
alter production and consumption.
Yet the Government in both its policy initiatives
and its treatment of particular technologies clearly sees the
prime objective of science and innovation is to drive quantitative
economic growth. Although it accepts that public involvement with
science is required it presents this as being about smoothing
the progress of all science and innovation rather than the public
being able to both more clearly identify which innovation trajectories
are most likely to enhance the wellbeing of society and adequately
assess the risks and uncertainties to society and the environment.
It characterises society's involvement with science as having
the potential to "inhibit the future development of science
and innovation in the UK to the detriment of public services and
the economy"[2]
One clear message from the public debate about
GM foods was that people not only had serious concerns over the
risks and uncertainties involved both human health, biodiversity
and living systems, they also seriously questioned the public
benefit of the application of this area of science to crops as
opposed to, for example, medicine. Yet the Government has been
bullish in trying to speed the progress of GM crops, even characterising
those in society who correctly questioned the quality of the science
supporting this technology and the assessments of uncertainty
as "anti-science".
If the Government did not regard economic growth
as the primary objective for science and innovation it would not
only avoid the long list of crises from BSE to GM crops but could
install a precautionary approach where means that risk decisions
must embrace different possible assumptions, recognise the incommensurability
of many risks and acknowledge the full uncertainties at stake.
In the longer run and in terms of sustainable development this
would be far more efficient.
INTERNATIONAL TRADE
Friends of the Earth has been at the forefront
of calls for the persistent drive for trade liberalisation to
stop, in order to assess whether the assertion on which it is
based—that it increases the wellbeing of all people—is
correct (because there is strong evidence to suggest it increases
inequality, environmental destruction and environmental injustices).
Once again the issue is whether this economic policy is succeeding
in increasing the wellbeing of society and doing so within environmental
limits.
A few years ago the UK Government was one of
the main cheerleaders for new "investment" laws in the
World Trade Organisation to make it more difficult for countries
to screen foreign companies and prioritise protecting the environment
and the poor. After a concerted NGO campaign and the collapse
of the Cancun WTO talks last September (largely due to investment
laws being so unpopular with developing countries) they seemed
to change their mind. But this month the EU is reported to be
pressing ahead with Bilateral deals with South American Countries
which would effectively force them to take on the same investment
rules.
Each of these cases demonstrates that defining
the role of the economy in achieving sustainable development as
operating within environmental limits, and with the purpose of
increasing well-being, in no way underplays its importance or
suggests it should be anything other than dynamic. As the European
Economic and Social Committee states[3]
"Sustainable development can mean further
development of the market economy linking environmental, employment,
competitiveness even more closely with issues of distributive
justice and intergenerational justice . . . for some sectors,
this will give a new boost to growth while for unsustainable activities
it will mean economic decline."
In other words sustainability is an opportunity
for a different economy.
2.2 SOCIAL EQUITY
ISSUES
We believe there is a need for strengthening
and broadening the scope of the social objective. The strategy
rightly notes that the objective should be "social progress
which recognises the needs of everyone ", however we feel
that there is less of a focus in the strategy on the needs of
people beyond the UK, and people in future generations; there
are also wide inequalities in environmental impacts and access
to environmental resources even within the UK, which have only
recently been recognised.
The Sustainable Development Commission's report
points out:
— In the UK inequalities between rich
and poor people and between regions are increasing.
— Concentrations of combined social
and environmental disadvantage continue to cause blight.
— We work longer hours and with bigger
income inequalities and wage gender gaps than any other country
in Europe.
— Poorer people still die younger.
— Housing for the poor is still below
standard and housing is getting much more expensive for the poorest
quarter of the population.
— People without access to a car have
more difficulty accessing amenities but are also more exposed
to damage and pollution from traffic.
— We draw in large quantities of natural
resources and manufactured goods and services from other parts
of the world and our footprint thereby adds to the pressures on
other countries' resources and their environment (if our patterns
of consumption in the UK were repeated around the world, by 2050
we'd need an extra eight planets).
— Our policies on trade, aid and investment
can have an adverse impact on the prospects for sustainability
on other parts of the world.
We believe that the revision of the strategy
should place a stronger emphasis on ensuring that everyone is
able to live in a healthy environment, in the UK, other countries
and future generations. This would mean:
— Reducing disparities in environmental
impacts in the UK.
— Taking into account the impact on
future generations (eg through using precaution).
— Considering the impact on people
and resources across the world—in a world of limited
environmental resources (to protect the rights of future generations)
it will be unacceptable for the UK and other developed countries
to continue to appropriate the enormously unequal share of the
world's resources we currently do. All countries should have fair
shares, in order to reduce the over-consumption in the north and
reduce the poverty and allow for growth in the south.
— Ensuring citizen's rights—to
get information, to participate in decisions that affect them
and to have access to justice and redress.
We also think there is merit on working with
the definition the Sustainable Development Commission suggests:
"Sustainable development involves advancing
the well-being of society as a whole, remedying injustices or
inequity and protecting the planetary resources and environment
that sustains us all. It presents a large and urgent challenge,
which should unite everyone on earth and the interests of present
and future generations."
This approach is strong for several reasons:
— It is explicit about protecting resources,
ie environmental limits.
— It goes beyond a vague notion of
social and is explicit about remedying injustices and inequity.
— It has an intergenerational focus.
— It talks about wellbeing rather than
a blunt notion of economic growth.
3. ORGANISATIONAL
STRUCTURES
We believe that the strategy needs to be delivered
from the Cabinet Office. Sustainable Development needs to be a
core concern for all Government departments, in decisions as diverse
as the WTO Ministerials, the review of the five year transport
plan, the review of the climate change strategy, the spending
review (all due this year), the budget, and the UK presidencies
of the G8 and EU in 2005. To achieve this will require central
delivery. It will not be as effective in doing this if it is in
DEFRA, or indeed any Department other than in the centre.
We note that there are strong precedents for
this central approach in other European countries. France, Finland,
Portugal, Malta, Estonia, Latvia and Lithuania have all placed
the responsibility for coordination of sustainable development
directly under the Prime Minister's office.
4. INDICATORS
The publication of Quality of Life Counts—the
Government's indicators strategy—and subsequent update was
a major improvement and achievement. But the major area where
change is needed is in the economic indicators.
The most important advance in Quality of Life
Counts (QOLC) and the accompanying sustainable development strategy
A Better Quality of Life (ABQOL) was the recognition that the
quality of economic activity is critically important, not just
the quantity.
However, QOLC then failed to reflect this thinking
in its choice of indicators. In our view this is the major failing
of the indicators package. This section outlines the problems
this causes, and suggests changes to overcome them.
First, QOLC does not include measures of the
quality of economic activity or of how well the economy meets
needs. Worse, it persists in the flawed use of Gross Domestic
Product (GDP) for these purposes. There is a pervasive implication
that—despite statements to the contrary—the strategy
treats GDP as an indicator of economic welfare. Despite the excellent
words, GDP is still the first indicator in a headline set called
"quality of life counts" which aims to measure quality
of life.
GDP (among other failings):
— takes no account of how total welfare
is distributed (yet ABQOL argues that the reason for high economic
growth is "so that everyone can share in high living standards");
— counts the erosion of environmental
capital as a benefit;
— does not count large quantities of
non-conventional economic activity—such as voluntary, self-help
and mutual activity.
The use of GDP systematically undervalues all
of these issues. However a greater problem with continuing to
use GDP is that there are no tools or indicators to allow us to
choose more sustainable types of growth.
The one type of measure of "quality"
allowed by this continued use of GDP is a narrow measure of economic
"efficiency"—this is the environmental impact
per unit of GDP, or "doing more with less". This measure
is undoubtedly useful—and a programme to reduce the energy
use, water use, pollution, and waste per unit of economic output
from all industrial and business sectors will lead to major sustainability
benefits. However, it is not the whole story. True eco-efficiency
is reducing the environmental impact per unit of welfare gained,
not per unit of economic output[4]
True eco-efficiency reflects two components:
(i) choosing the most environmentally
efficient means to meet needs;
(ii) ensuring minimum environmental impact
per means chosen.
So the current narrow focus of eco-efficiency
means that all the options to improve welfare from a different
sort of economic activity—type (i)—are foregone. One
illustrations to highlight this is road transport—one of
the most difficult sectors for reducing carbon dioxide emissions.
Fuel efficiency is a narrow eco-efficiency indicator,
of how environmentally efficient a car or bus is at travelling
a mile. But the need being met is not travel but access—and
access can be influenced in many ways. Car sharing, land use planning
to reduce the length or number of journeys needed, teleworking
and making cycling and walking more attractive are all ways of
delivering the need (access) with far less environmental resources.
Reducing fuel costs per unit of access offer greater potential
improvements than reducing fuel costs per mile travelled by car
or bus—yet these risk being ignored with a narrow approach
of "doing better with less".
It is worth stressing that this issue is important
because narrow eco-efficiencies will not be sufficient to ensure
the Government's aim of more growth while staying within global
environmental limits. For example, to meet the global Intergovernmental
Panel on Climate Change (IPCC) recommendation of 60% carbon dioxide
(CO2) cuts by 2050, when there will be a global population of
9 billion, implies global per capita emissions of 1 tonne of CO2
or less. So assuming global fair shares in allocations will require
around a ten-fold reduction in UK CO2 consumption (currently nine
tonnes per capita). At 2.5% growth a year, the UK economy will
have grown three-fold by 2050. This implies that a factor 27 improvement
in the GDP output per unit of CO2 will be needed by 2050. Existing
eco-efficiency trends—relying on greening existing economic
activities—will not be sufficient to achieve such a rate
of change. Different sorts of growth will be needed. Much growth
is heavily environmentally and socially destructive, these types
of growth should not just be made more efficient, there should
be less of them.
A final problem with the continuing high profile
focus on GDP with a low profile focus on the quality of growth
is in the signal it gives for new developments. For example, Regional
Development Agencies and their strategies all have GDP as the
headline indicator—with GDP even equated in the regional
section of QOLC with "vitality"—and many RDAs
aim to be in the "top 10" in Europe, where "top"
is determined solely by GDP per capita. These regions are in danger
of all competing with each other for inward investments to boost
GDP growth whatever the environmental or social impact—as
witnessed by the regional airport expansion plans.
We have argued broadly that the economic section
of QOLC needs major revision to reflect its analysis of the need
for quality economic growth. Otherwise we do not see how the indicators
can guide the Government's to deliver economic actions and policies
without damage to welfare and the environment. Initial steps should
include:
— Removing GDP from the headline set,
and putting it in an economy core set as a contextual indicator.
— Commissioning research and developing
sectoral strategies which look into ways to meet needs with least
environmental impact.
— Development of an overall resource
use indicator—which should compare UK use with other countries.
We advocate the Total Material Requirement indicator, and that
an indicative target is also set for it—to reflect the need
for reductions in overall resource impacts—"absolute
decoupling". Overall resource use can also be represented
in an indicator of ecological footprint—which has the advantage
of being easier to visualise than other indicators—and we
support measures to develop footprint indicators. We also support
the recent work on sustainable production and consumption decoupling
indicators.
May 2004
1 Wellcome Trust, 2002. Public attitudes to science,
engineering and technology in Britain. www.wellcome.ac.uk Back
2
HM Treasury 2004, Science and innovation: working towards a ten-year
investment framework, paragraph 5.17. Back
3
Opinion of the European Economic and Social Committee on Assessing
the EU Sustainable development strategy-exploratory opinion 29
April 2004 NAT/229. Back
4
Environmental impact per unit economic output would be a true
indicator of eco-efficiency only if economic output was directly
equivalent to economic welfare. Back
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