House of Commons - Environmental Audit

Select Committee on Environmental Audit Written Evidence

APPENDIX 10

Memorandum from the Environment Agency

SUMMARY

The Environment Agency is a champion of the environment in the context of sustainable development. The Agency considers that:

— A revised strategy must show that sustainable development is at the heart of Government, and give priority to action and delivery.

— Defra, with the support of its Agencies, must promote the environmental leg of sustainable development across Government.

— All Government strategies and policies must show how they contribute to sustainable development.

— There should be independent scrutiny of progress against the sustainable development indicators.

— Government should promote sustainable consumption through greater use of economic instruments, and ensuring consumers have the information required to make informed choices.

— There should be a sustainable development duty on all Ministers and Public bodies.

1. INTRODUCTION

1.1 The Environment Agency's principle, statutory aim[25]is to undertake its work so as to contribute to sustainable development. The UK and Welsh Assembly Governments have provided guidance[26]on what this contribution should be. Put simply, it is the Agency's job to champion the environment, within the wider context of sustainable development. It is from this position that our evidence is submitted.

2. INQUIRY ISSUES

2.1 The definition of Sustainable Development.

2.1.1 Environmental concerns must lie at the heart of any definition of sustainable development. Good environmental quality is the foundation for a good quality of life, and underpins sustainable development. Poor environmental quality often goes hand in hand with social deprivation. Our research shows that people in the most deprived wards in England experience the highest concentrations of pollution[27]from traffic and industry. Environmental improvements can produce economic and social benefits. For example, it is estimated[28]that there are potential annual profits of at least £2-3 billion from waste minimisation in the manufacturing sector. Providing flood defences can catalyse wider social and economic regeneration. In Gainsborough our flood defence investment allowed the local authority to gear £3 million of Single Regeneration Budgets funds and further inward investment of over £24 million to deliver their waterfront strategy.

2.1.2 There is probably sufficient understanding of the principles (as opposed to the practice) of sustainable development as a concept amongst government policy makers, though this may not be the case in the general public. Although the Strategy's definition of sustainable development has shortcomings, the real concern is not the strategy itself but a lack of progress against its statements and commitments. The Prime Minister's statement that "the whole of Government is committed to . . . making sustainable development a reality" is not always reflected in practice. For example, although the Strategy highlights the fact that it is the quality of economic growth that matters, not just the quantity, the narrow focus on traditional GDP growth has still predominated.

Meeting the key objectives of A Better Quality of Life

2.1.3 Meeting the four key objectives at the same time is an essential component of sustainable development. We are now paying the price of neglecting environmental protection in favour of economic growth in the past. For example we are now having to:

— clean up the water environment, as result of decades of under investment by the water industry;

— change farming and land use practices that cause diffuse pollution and have destroyed the habitats on which much wildlife depends;

— restore land which industry has contaminated with toxic chemicals;

— reshape energy and transport systems that have ignored their cumulative impacts on air quality and climate change; and

— spend more on flood risk management as a result of inappropriate development in the flood plain.

2.1.4 Each of these examples, and there are many others, shows how ignoring environmental objectives in favour of economic (and in some cases social) growth has led to liabilities that have to be addressed at a later date, and usually not by those who benefited from the initial activity. If the environmental and social impacts had been addressed at the same time as the economic growth, then these problems could have been avoided.

2.1.5 We accept it may not be possible to meet the four objectives literally at the same time, particularly when applied at a local scale or to individual developments. However, the overall aim should be for no overall, long term or irreversible environmental degradation. The costs of mitigating and restoring impacts should be met by the activity that generated them. This requires rigorous application of the principle of respecting environmental limits, and the polluter pays and precautionary principles.

Trade-offs

2.1.6 Sustainable development cannot be delivered by sacrificing, for example, environmental standards in order to achieve economic growth. It requires "win-win-win" (environmental, economic and social) solutions to the challenges we now face. Historically, virtually all the trade-offs have, from an environmental viewpoint, been one way. We must now focus on the economic and social benefits created because of the environment, rather than at its expense.

2.1.7 For example, our rate of carbon dioxide and other greenhouse gas production now greatly exceeds the natural absorptive capacity of oceans and ecosystems. We must face up to the challenge of moving to a low carbon economy, if further climate change, beyond that already in the system, is to be avoided. This offers a huge opportunity to enhance our manufacturing capacity and provide new employment. It has been estimated[29]that the renewables energy industry currently sustains about 8,000 jobs in the UK. This could rise to up to 35,000 by 2020. The environmental economy is already a dynamic and buoyant sector. Though a national figure is not available, Regional studies show that it is an important component of the economy. For example, in the South East of England, it is estimated to support about 6% of the workforce, with an estimated turnover of £7.8 billion[30]

2.1.8 If we are to meet the overarching goal of sustainable development, Defra, with the support of its Agencies, must act as the "environmental champion" within Government, and highlight the social and economic benefits of a high quality environment.

2.2 The role of the Strategy as a driver of Government priorities

Influence of the Strategy

2.2.1 There are an increasing number of Departmental sustainable development strategies and actions plans. This would seem to be as a direct result of the UK Strategy, and Defra's own efforts in pursuit of its PSA 1. (A notable exception here is a formal commitment from HMT.) What is less apparent is whether the Government's commitment to use the Strategy "as a framework to guide its policies" has really been taken seriously. Recent examples where the principles of the Strategy do not appear to have been carried forward into action include:

— the unwillingness by Government to tackle aviation's contribution to greenhouse gas emissions;

— slow progress in the expansion of environmental taxation;

— failure to address head on the challenge of moving to more sustainable patterns of transport.

2.2.2 PSA targets help set Departmental priorities. To reinforce the influence of the new strategy across Departments, the SR 20004 PSA targets should explicitly show how they contribute to sustainable development. Defra should have a new cross cutting target on promotion of sustainable development. Other Departments' targets should reflect environmental factors, particularly ODPM targets on Sustainable Communities, DfT targets on pollution and DTI targets on Energy.

Links to other strategies

2.2.3 Where Departments have produced their own sustainable development strategies, they usually make it clear that they are a contribution to the 1999 Strategy. However, with other strategies and policies such linkage is often less obvious. The Agency believes that all Government policies and strategies should state how they contribute to the four key aims of the Strategy. The Cabinet Office's guidance on Regulatory Impact Assessments has recently been strengthened in relation to appraisal of social and environmental impacts. The Agency considers this an important step in the right direction in incorporating sustainable development into the wider policy framework.

Mainstreaming the Environment

2.2.4 One weakness of the current Strategy is that it does not set priorities for action. In the absence of a specific Environment White Paper, the revised strategy must clearly set out Government's priorities for the environment.

2.2.5 Some progress has been made in mainstreaming the environment. We were pleased that the Energy White Paper[31]gave environmental issues far greater prominence than in previous government energy policy. The environment is now, at last, taking a more central role in agricultural policy, and the sustainable communities programme acknowledges the need to reduce the environmental impact of new housing. However, there is still more progress to be made before the environment can be said to have equal weight when key Government decisions are made.

Role of a UK Strategy

2.2.6 An overarching UK strategy is, if anything, even more important in the context of devolution. The global distribution of natural resources, populations, industry and commerce means that no country can achieve sustainability on its own, and trading and movement of skills and resources between countries, and regions, is essential. An overarching strategy will help ensure a concerted approach to the key challenges of sustainable development, and to effectively embed work at a sub-national level into the wider context. However, such a strategy must not be too prescriptive.

2.3 Indicators

Indicators as Drivers of Policy

2.3.1 The adoption of the full and headline sets of sustainable development indicators, and Government's annual reporting against them, are important positive outcomes of the Strategy. However, indicators are of little value if their messages are ignored. We agree with the recent SDC report[32]which concluded that, despite a commitment to the contrary, the fact that an indicator was going in "the wrong way" has not been a catalyst for action by Government. This is best illustrated by the continued adverse trends in waste production and road traffic, though we recognise it may take several years before the impact of policies become apparent.

2.3.2 There are disadvantages in frequently adjusting the indicators set. Much of their value is the picture they paint of trends over time. This will be lost if there is a lack of continuity. While some improvements are required, the Agency believes greater value could be obtained from the existing set if the annual report on progress was prepared in a more independent manner, with critical scrutiny of the emerging messages. Both the SDC report[33]and the EAC's own reports[34]have highlighted the tendency by Government to pay insufficient attention to negative trends.

2.3.3 Greater use should also be made of the relationship between indicators. The shortcomings of GDP as a measure of sustainability have been often highlighted, most recently by the SDC[35]We welcome recent Government proposals[36]to adopt indicators of the decoupling of economic growth from environmental degradation. These will help to show whether economic activity is sustainable.

2.3.4 One indicator that will require revision is H12, River Water Quality. In order to meet the requirements of the Water Framework Directive, the Agency (and our counterparts in Scotland and Northern Ireland) will soon be in a position to provide a much broader view of the health of our inland and coastal waters. This is likely to paint a much less satisfactory picture than the current indicator, which focuses on the impact of a limited set of determinants.

2.3.5 The EAC has previously noted the need to incorporate information from the Agency's survey of industrial and commercial waste. This will be available towards the end of this year. Government have stated that they will use these results as soon as they are available, thereby providing a fuller picture of the unsustainability of resource use in this sector.

2.4 Sustainable Consumption

2.4.1 Sustainable consumption and production (SCP) is an important part of the sustainability agenda, and covers many issues that are of particular interest to the Agency. However, we do not consider that it fully encompasses all aspects of sustainable development. For example, a major challenge for sustainable development is the need to adapt to anticipated climate change, even if we succeed in meeting greenhouse gas reduction targets. So, while mitigation can be delivered through sustainable consumption and production, adaptation cannot.

2.4.2 The Agency supports the existing Government framework on sustainable consumption and production and recommends further action in this area. We agree that there needs to be greater attention paid to consumption aspects of SCP. A growing proportion of resource use is driven by household consumption, and the environmental impact of the use of products will need attention as well as the impacts of their manufacture.

The Role of Government

2.4.3 Government should give priority to two ways in which it can encourage changes in consumption. Firstly, it should continue to use economic instruments, such as environmental taxes and tradable permits, to ensure that the price of resources takes into account environmental impacts. This will help consumers and businesses to anticipate that the cost of certain resources such as fossil fuel, energy or water, and hence also of goods that consume them, will increase. They can then take action to reduce their use of such resources and goods. Fiscal incentives have been successful in encouraging the choice of more energy efficient goods. They should be extended to cover a greater range of products; for example, those that are water efficient and those that generate less waste.

2.4.4 Secondly, the Government should provide information to allow business and individuals to make informed choices. Central Government purchases some £13 billion of goods and services every year, and government spending overall is over 40% of GDP. It is therefore a significant player in procurement and its behaviour sends a strong signal to both industry and markets. It should:

— make Integrated Product Policy (IPP) an important way of improving resource efficiency and create a new focus on sustainable product policy;

— draw together existing work on product policy and life cycle analysis to build a central information base on products to guide labelling, procurement, professional buyers, and future policy development;

— use its own procurement policy to promote the market for sustainable products and services;

— support the principle of environmental impact assessments for products, beginning with the adoption of new EU measures for eco-design and product standards.

2.5 Organisational structures and costs

2.5.1 Effective implementation of a sustainable development strategy will always rely on action across Departments. Structures and policy mechanisms will never operate effectively if there is not firm commitment and ownership right across Government. Sustainable development must be seen to be at the very heart of Government, not just through production of strategies, but by its explicit incorporation into all policies and actions.

An Objective for all Government organisations

2.5.2 We are pleased to see that sustainable development is being identified as a statutory objective or purpose of an increasing number of public bodies, including the Regional Development Agencies (RDAs). Some of the RDAs have made significant efforts to take on a wider sustainable development viewpoint, but their powers and remit inevitably makes economic development their primary focus. More needs to be done to make sustainable development the common thread that joins up the strategies, and work on the ground, of the range of Regional Government organisations. The proposed Elected Regional Assemblies must have an overarching a statutory duty to contribute to the achievement of sustainable development, to which all regional strategies contribute. The overall purpose of spatial and development planning, enshrined in the Planning and Compulsory Purchase Bill, must be enacted, and given real meaning in revised planning policy, including PPS1.

2.5.3 The Agency is encouraged by the progress made by the Welsh Assembly, stemming from its sustainable development duty[37]We have noted a far greater awareness of sustainable development across a range of Assembly departments, which we believe can be directly attributed to the Scheme. As a consequence of the Scheme, we have also noted a clear shift towards sustainable development among sponsored bodies such as the Welsh Development Agency, and an increase in partnership working across sectors and policy areas. While the final proof must be in changes on the ground, we believe there are lessons to be learned from the approach adopted in Cardiff.

2.5.4 In the light of progress in Wales and elsewhere, the Agency believes that all public bodies, including Ministers, should have a duty to contribute to sustainable development when exercising their functions. While there may need to be supporting guidance on how such a duty may operate for specific organisations, we believe that it would help align the work of the public sector to provide a common, shared purpose.

3. CONCLUSIONS

3.1 The Environment Agency welcomes the progress that has been made under the current strategy, but it considers far more must be done to ensure its statements and commitments are adopted right across Government. The focus of the new revised strategy must be to set priorities and ensure action on the ground. Delivering sustainable development must be presented as an investment for the future, rather than a cost for the present, with a quality environment as the foundation for a good quality of life.

May 2004

25 Environment Act 1995 Section 4. Back

26 The Environment Agency's Objectives and Contribution to Sustainable Development: Statutory Guidance. Defra Dec 2002. The Environment Agency's Objectives and Contribution to Sustainable Development in Wales: Statutory Guidance from the National Assembly for Wales. National Assembly for Wales March 2003. Back

27 Environmental Quality and Social Deprivation. Environment Agency R & D Technical report E2-067/1/TR Sept 2003. Back

28 The Benefits of Greener Business A report to the Environment Agency by Cambridge Econometrics and AEA Technology. April 2003. Back

29 The Renewables Supply Chain Gap Analysis. DTI/Pub URN 04/CD3 Jan 2004. Back

30 Economic Profile of the South East. SEEDA 2002. Back

31 Our energy future-creating a low carbon economy. DTI February 2003. Back

32 Assessment of progress against the headline indicators. A report by Levett-Therival consultants for the Sustainable Development Commission. April 2004. Back

33 Ibid. Back

34 The Sustainable Development Headline Indicators 2002. House of Commons Environmental Audit Committee 11th Report of Session 2002-03. October 2003. Back

35 Ibid. Back