APPENDIX 21
Memorandum from Scottish Natural Heritage
Scottish Natural Heritage (SNH) is a non-departmental
public body, sponsored by the Scottish Executive, responsible
for promoting the conservation, enhancement, enjoyment and understanding
of the natural heritage. The natural heritage comprises Scotland's
habitats, wildlife, and landscapes and the amenity which these
natural resources offer. In our founding legislation (Natural
Heritage (Scotland) Act 1991) we are required to "have regard
to the desirability of securing that anything done, whether by
SNH or any other person, in relation to the natural heritage of
Scotland is undertaken in a manner which is sustainable".
We also have a range of "balancing duties" which include
being required to take account of the needs of social and economic
development in Scotland.
A: THE DEFINITION
OF "SUSTAINABLE
DEVELOPMENT"
The Government has stated that the Brundtland
definition "is excessively narrow and puts undue emphasis
on environmental concerns. . .[It] lies at the environmental end
of the spectrum of views on sustainable development. At the other
end, there are equally sound definitions that favour a fundamentally
economic definition." Does the definition of "sustainable
development" matter?
1. Yes, the definition of sustainable development
is important, as a reference to which more specific aims and objectives
can relate. We think that the Brundtland definition is the best
place to start because it captures all aspects of sustainable
development. Like any definition of sustainable development it
is contested, but the alternatives that have sought to clarify
it are all disputed as well. These debates reflect the difficulties
in resolving the conflicts of interest that are embedded in sustainable
development.
2. We disagree that the Brundtland definition
"lies at the environmental end of the spectrum of views.
. .". It recognises the importance of development (which
is much broader than "economic growth") such that the
biosphere remains suitable for the existence of human kind. The
Brundtland definition acts as a centre point from which the complex
landscape of sustainable development can be explored. Evidence
for this lies in the use of the Brundtland definition by people,
organisations and governments espousing both "strong"
and "weak" sustainability.
3. The Brundtland definition has international
recognition and sustainable development raises a complex range
of international issues. It could be hard for the UK to show that
it remains fully engaged with those issues while working to a
different definition of sustainable development to that used by
the rest of the international community.
The Sustainable Development Strategy (the Strategy)
requires all four key objectives to be met at the same time. Is
this realistic? Is political support for this concept based upon
its ambiguity? Does it fail to place enough weight on the need
to make trade-offs between different objectives and the relative
importance to be attached to them in that event?
4. As indicated above (paras 1-2), we agree
that sustainable development necessarily brings together a range
of social and environmental objectives. Decisions we take now
that affect the environment will have a long-term effect on the
wellbeing of this and future generations. We believe that any
vision of the future should include looking after and improving
Scotland's high-quality natural heritage, not only for its own
sake and to benefit people now but also to leave the best possible
legacy for future generations.
5. We recognise that there is merit in the
hierarchy proposed by the UK Sustainable Development Commission,
as stated in "Mainstreaming Sustainable Regeneration: a Call
to Action", thus:
— protect critical natural capital
in all circumstances;
— wherever possible, seek to optimise
economic, social and environmental benefits over time;
— where that is not possible, seek
to minimise any potential damage to the environment, people and
their communities;
— only then can one trade off potential
economic benefits against unavoidable social and environmental
disbenefits.
However, a potential flaw of this hierarchy
lies in the extent to which mainstream decision-making is driven
by economic growth which tends to emphasise short-term cost considerations
over long-term social and environmental sustainability.
6. There is a fundamental question emerging
over the importance attached to "economic growth". In
particular we have always questioned the need to include "high",
as applied to economic growth, within the fourth of the UK Strategy's
four overarching objectives; as compared to "stable"
economic growth, which we support. Emphasis on economic growth
in decision-making can give greater weight to short-term economic
cost considerations over long term social and environmental sustainability.
While economic growth is often used as a measure of economic well-being,
a number of insightful reports have shown the two to be poorly
correlated (eg Life satisfaction: the state of knowledge and implications
for government, Cabinet Office, Strategy Unit, 2002; and Redefining
prosperity, UK Sustainable Development Commission, 2003). Economic
growth that leads to environmental degradation fails a major test
of sustainability but is even less defensible if it fails to enhance
well-being. The use of the title "A Better Quality of Life"
for the UK Strategy has however been helpful in setting economic
growth within a wider perspective.
B: HAS THE
STRATEGY ACTED
AS A
DRIVER OR
DOES IT
OCCUPY A
LIMBO EXISTENCE
WHICH HAS
LITTLE IMPACT
ON DEPARTMENTS'
REAL PRIORITIES?
What specific impacts can be attributed to the
Strategy since its introduction in 1999?
7. A key success of the 1999 strategy lay
in the breadth of the debate and the challenging agenda that it
set. The main weakness of its impact is in the extent to which
the strategy has become part of mainstream decision-making, for
example in transport policy in general, and air transport in particular.
How effectively has the Strategy linked to, or
acted as the driver for, lower level strategies—whether
topic specific strategies, such as the Climate Change Strategy
and the Air Quality Strategy, or strategies of devolved administrations,
regional and local government?
8. From a Scottish perspective, the links
between the UK strategy (1999) and the Scottish approach to sustainable
development set out in "Meeting the Needs . . . priorities,
actions and targets for sustainable development in Scotland"
(2002), are poor. These difficulties are explored very well in
the current consultation paper ("Taking it On"), and
the current process has the potential to develop a much more coherent
and coordinated approach to sustainable development throughout
the UK.
How much impact has the Strategy had on mainstreaming
the environment in terms of objectives and targets set for individual
departments in Public Service Agreements and in departmental strategies
and business plans?
9. Within Scotland, at Parliamentary level
there is a policy presumption that all policies should aim for
sustainable development; there is a Ministerial subcommittee on
Sustainable Development; and departmental programmes have been
appraised against sustainable development in arriving at the last
Spending Review decisions. It is arguable that none of these would
have happened had there not been a UK Sustainable Development
Strategy in existence. We believe the UK Strategy has acted as
an important driver as an overarching policy perspective.
10. From any perspective, whether UK, devolved
administration or local, the key test of any sustainable development
strategy lies in the extent to which it becomes part of mainstream
decision-making. This may require changes in the way that public
expenditure is justified, for example by auditing of public accounts
so that long-term social and environmental sustainability can
be more effectively taken into account over short term cost considerations.
This relates back to the question of emphasis on economic growth
(para 6). "Mainstreaming" sustainable development may
also require reviewing the remits of public bodies to make sure
they have duties for sustainable development (eg Local Government
in Scotland Act, 2003), or "balancing duties" with respect
to social, environmental and economic interests.
Can a UK Strategy ever amount to more than a set
of principles or aspirations, particularly in the context of devolved
government? Is it needed, given the fact that—where progress
is being made—it seems to be topic-specific and driven from
the bottom? If it is needed, should it focus much more specifically
on a small number of key themes and targets?
11. A UK strategy is important, because
it can help send out clear messages from government. The existence
of a UK strategy, coordinated with sub-national approaches, which
clearly drives decision-making on day-to-day matters in government
on how scarce public resources are allocated and accounted for,
sends a clear message about how seriously government itself is
taking sustainable development. Without this signal there could
be a reduced incentive for the private sector to take appropriate
action.
12. The question of priorities is important,
and is central to the Scottish approach ("Meeting the Needs.
. .", 2002) and is raised in "Taking it On". An
overarching strategy for Sustainable Development is necessarily
wide-ranging, and hence on its own may not be able to provide
answers about the allocation of scarce resources. However, focusing
on priorities can be problematic if they are pursued to the detriment
of "non-priority" issues. For example, in Scotland,
we are seeing loss of biodiversity and local landscape character
associated with terrestrial wind-farm development, driven by government
pursuit of climate change objectives. While that aim is worthy
and has our strong support, there is an inadequate effort being
made to secure a strategic approach which minimises adverse effects
on the local environment. There is a danger that in this way,
focusing on a small number of priorities can lead to successive
issues "leap frogging" to priority status. Tackling
the key priorities in way that does not exacerbate other issues
would lead to much sounder progress towards sustainable development.
One way of doing this would be to test all decisions against all
the major principles of sustainable development (eg the 10 principles
contained in the 1999 strategy, currently under review).
C: HOW EFFECTIVELY
DO THE
INDICATORS REFLECT
THE UK'S
"SUSTAINABILITY GAP"?
Could the Government have made greater use of
indicators to drive policy and set targets in departmental business
plans and Public Service Agreements?
13. Yes. The breadth of the 147 "Quality
of Life Counts" is impressive and the UK government has attracted
international regard for its work on indicators. However, there
is less evidence of significant steps to address adverse trends,
or how to prioritise work on a range of adverse trends. As suggested
above (para 12), the action arising from indicators needs to be
aligned with other measures (such as principles of sustainable
development) to make sure positive action on one trend is not
contributing to an adverse trend in another.
To what extent do the existing indicators, in
particular the headline indicators, properly reflect the extent
to which the UK is unsustainable? What additional or alternative
indicators could address this gap?
14. We note and support much of the analysis
carried out by the UK Sustainable Development Commission on this
subject (Shows Promise, but Must Try Harder, April 2004; Assessment
of progress against the headline indicators, April 2004). This
study highlights the tendency to report narrowly against the indicators
themselves, rather than as a "way-in" to the complicated
picture that indicators are designed to simplify. Our answers
to the previous two questions highlight the need to combine the
use of indicators with more rounded evaluation against underlying
principles—which is the methodology used by the UK SDC in
their study.
15. Our main concern is that there should
be a consistent set of headline indicators in use across the whole
of the UK. We welcome discussion of this issue in "Taking
it On". Our view is that the indicators for the UK strategy
should be capable of being broken down to sub-national or local
levels, so that the measures of sustainable development (and other
indicators, for example on energy) are directly comparable across
the whole of the UK. The current differences in approaches in
different parts of the UK and in different sectors, makes like-for-like
comparisons very difficult.
16. We have commented elsewhere (paras 6
and 10) on questions raised about the emphasis on economic growth,
and agree with the UK SDC that a different approach is required
to measure economic progress, and one that better reflects "wellbeing".
D: HOW CAN
THE CONCEPT
OF SUSTAINABLE
CONSUMPTION BE
INTEGRATED WITHIN
THE STRATEGY?
Should sustainable consumption and production
be seen as only one constituent part of sustainable development
(ie a lower level strategy which sits alongside others), or as
another way of looking at sustainable development itself?
17. Sustainable consumption and production
relate primarily to resource use and hence are focussed on a particular
aspect of sustainable development—environmental capacity.
This is only one of a range of objectives which require to be
met—the "Taking it On" consultation identifies
"environment and social justice" and "helping communities
to help themselves" as two others. Hence, we would argue
against viewing sustainable consumption and production as another
way of expressing the totality of sustainable development. They
are a means of securing some, but not all, of the required objectives.
Sustainable consumption has so far been interpreted
mainly in terms of sustainable production. What is the role of
government with regard to encouraging changes in consumption itself—eg
by managing demand or facilitating choice? What difficulties does
it face in doing so?
18. This question is particularly relevant
to the questions of energy policy and climate change. Repeated
analyses show that the main threat to meeting targets for the
reduction of greenhouse gas emissions lie in the transport and
domestic sectors. In these areas, and especially in transport,
the overall increase in demand is far outstripping any efficiency
gains. Managing demand in these sectors is politically very challenging.
The use of the emission trading scheme model might be useful here,
as it has the potential both to penalise over-consumption and
to incentivise ongoing reductions in resource use. Consideration
might be given to extending this model both at a business level
(eg to waste production) and at a personal and domestic level
(eg to transport fuel consumption). Care would have to be taken
so as not to contribute to adverse redistributive effects, and
to safeguard other interests that are not the direct focus of
specific emission trading schemes. These are difficult issues,
and some trials may be required to test the tool.
19. Any drive to reduce consumption overall
may be seen by some as conflicting with the need for economic
growth—and our comments on that raised in the other sections
are relevant here.
E: ORGANISATIONAL
STRUCTURES AND
COSTS
Do the present organisational structures and policy
mechanisms within Government contribute to the effective implementation
of the Strategy? What improvements could be made in this respect?
Is there a case for rationalising the number of organisations
involved in key sectors?
20. See our response to Section B (paras
9-10).
Is there a need for a more consistent approach
to incorporating sustainable development as an overarching objective
in all Government organisations? Or would the ambiguity of the
term prove unhelpful?
21. Yes. The ambiguity could be removed
by testing decisions against the principles of sustainable development
(as agreed through the current consultation "Taking it On").
Has a lack of sufficient Government financial
support for programmes and policies hindered the implementation
of the Strategy in any way?
22. Our comments under paragraph 10, indicates
that it is the degree of "mainstreaming" that is key,
rather than specific funding. Even if specific funding streams
were increased if they are viewed in isolation of mainstream decision-making,
then the latter are likely to outweigh many of the benefits gained
through increased funding. Significant changes are required in
aspects of public accounting, the remits of public bodies and
audit functions to encourage solutions that favour long term social
and environmental sustainability over short term cost considerations.
The latter tend to be driven by an emphasis on economic growth
and minimisation of immediate costs, combined with a more risk
averse rather than innovative culture.
May 2004
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