Memorandum submitted by the Environmental
Industries Commission
ENVIRONMENTAL INDUSTRIES
COMMISSION (EIC)
EIC was launched in 1995 to give the UK's environmental
technology and services industry a strong and effective voice
with Government.
With over 330 Member companies, EIC has grown
to be the largest trade association in Europe for the environmental
technology and services (ETS) industry. It enjoys the support
of leading politicians from all three major parties, as well as
industrialists, trade union leaders, environmentalists and academics.
EIC's Sustainable Development and Management
Working Group includes over 100 Member companies.
EIC is pleased to provide the following response.
Before I address the specific questions the
Committee has invited comments on, I would like to take this opportunity
to set out EIC's concerns on the following issues:
PUBLIC SECTOR
BUILDING PROJECTS
EIC believe that one key area where the Government
is failing in its efforts to improve its sustainability is in
public sector building projects.
Since 2002 it has been a requirement under the
Government's "Common Minimum Standards"—which
set mandatory standards for construction procurement in the public
sector—for a BREEAM (or equivalent) assessment to be carried
out on all public sector building projects. Furthermore, it is
a requirement for all new projects to achieve an "excellent"
rating and all refurbishment projects to achieve at least "very
good" rating.
However the recent Sustainable Development Commission
report "Sustainable Development in Government 2007"
showed that, in 2006-07, only 46 of 351 Government new build or
refurbishment projects were assessed against BREEAM. This is against
a requirement for all public sector projects to carry out
a BREEAM (or equivalent) assessment.
Of the projects that did carry out an assessment
only 28 met the Common Minimum Standards. Overall, for all 2006-07
projects, only 8 per cent achieved the required standards.
EIC Members' experience of supplying to public
sector construction projects is that they commonly procure the
cheapest, most polluting option, even where whole-life costs are
higher than with more efficient alternatives.
This remains the situation and is in line the
Sustainable Development Commission report.
The commitment in the Government's response
to the Sustainable Development Commission report to ensure "stronger
enforcement of the Government's policy on BREEAM "Excellent"
certification of new buildings and "Very Good" certification
on major refurbishments, such that no new builds or major refurbishments
will happen unless they meet the BREEAM (or equivalent) standards"
is welcome.
However, unless this positive rhetoric is backed
up with genuine action, the Government risks further undermining
its stated aim to make the UK one of the EU leaders in sustainable
procurement by 2009. For example the current Buildings Schools
for the Future programme only requires a BREEAM "very good"
rating—in contradiction of the Government's standards.
Major public building projects such as schools
and hospitals will be in operation for many years and the failure
to ensure they are energy efficient and sustainable is a huge
wasted opportunity.
PUBLIC SECTOR
LEADERSHIP
EIC believe that the public sector must lead
by example.
The recent report from the Committee on Environmental
Markets and Economic Performance stated that "many private
sector companies, for example the large retailers, are already
engaged in the process of positioning better environmental performance
as a product feature, believing that this gives them a competitive
advantage with the consumer. However, environmental performance
is still only a business-critical matter for a relatively limited
number of companies.
This means there is a huge opportunity for the
public sector to amplify the role of low carbon and other sustainability
characteristics in products in their purchasing requirements,
creating a credible market need for these features so that business
will invest in them to gain competitive advantage."
EIC believes, therefore, that the Government
has a critical role to play in demonstrating its environmental
and sustainability leadership and creating a market for environmental
goods and services.
However, the Sustainable Procurement Task Force
recently identified the lack of consistent leadership on sustainable
procurement. EIC believes, therefore, that the Government must
ensure that there is a clear commitment to sustainability from
the very top of Government and down through Permanent Secretaries,
local authority members and Chief Executives in all public bodies.
The Government could show a significant degree
of leadership by simply meeting its own targets—for example
meeting the Common Minimum Standards. Policies such as requiring
all new homes to be zero carbon by 2016 can be significantly undermined
by a Government that fails to achieve its own targets.
How successfully is the Government providing centralised
leadership, guidance, and funding for Departments and Agencies?
How well are Departments making use of expertise and funding provided
by central bodies, as well as each other? Should anything be done
to improve co-ordination?
EIC Members believe that more could be done
to centralise leadership with regards to guidance and funding
for Departments and Agencies. Due to the array of policies and
working practices that are often expected to be followed by procurement
staff and others within Government Departments, it is common for
the message of one policy to be confused, contradicted or over
shadowed by another. This results in policies being less than
fully implemented, or can lead to the partial implementation of
policy which then gets superseded by another. Due to the complex
nature of sustainable procurement, it is important that this does
not occur and that the often long term objectives laid down are
completed.
It is important that Government sets clear objectives
for the implementation of policies and objectives and that this
is consistently conducted across departments. With regards to
sustainable procurement, the flexible framework assists in this
process. However the degree to which this is applied across Departments
varies significantly and greater accountability and central drive
is required.
How well are Sustainable Operations on the Government
Estate (SOGE) data and targets embedded into core management information
systems and priorities within Departments and Agencies? How could
this be improved?
There is a mixed level to which SOGE data and
targets are embedded into core management information systems
and priorities. However, SOGE targets are often addressed separately
from the central management information systems. It is not uncommon
for SOGE information to be gathered on an ad hoc basis at the
time of reporting. This can lead to a rushed approach and a lack
of detail in the submissions. By planning the returns in advance,
Departments would be able to complete more comprehensive reports
and therefore more value could be gained. The lack of planning
and information associated with SOGE returns could be attributed
to the following:
— Resources allocated to the collection
of information.
— Importance associated with completion
of the returns.
— Access to information required for
the returns.
This may be improved by more regular collection
of the information required for input to the SOGE returns. This
could be coupled with a simpler returns mechanism to enable core
data to be reported automatically throughout the year, reducing
the annual rush that constitutes the SOGE returns.
Although departments may have experienced environmental
staff at "head office" level, those made responsible
for implementing environmental management systems and initiatives
typically are junior grades, often with little experience of environmental
and sustainability issues. In many cases, they lack adequate resources
and support from senior and operational management staff. Many
consider that their efforts are not integrated into mainstream
departmental management processes. Turnover of environmental management
staff is high as, once they start to gain experience; they can
find better-remunerated posts in the private sector (often in
outsourced functions serving government). As we understand the
situation, many of these people are paid the standard administrative
grade salary, despite being expected to work in a specialist technical
area.
What should be done to accelerate progress from
Departments in using combined heat and power, and sourcing electricity
from onsite renewables?
In relation to the means that could be used
to encourage the use of combined heat and power, and sourcing
electricity from onsite renewables the following recommendations
have been raised:
— Enforcement of existing requirements
for BREEAM assessments on all new builds and major refurbishments
would increase the likelihood of combined heat and power, and
sourcing of electricity from on site renewables. Alternatively,
increased focus on the percentage of energy obtained or used in
such processes could increase their implementation and use.
— Enforcement of existing requirements
for all new building projects to achieve an "excellent"
rating and all refurbishment projects to achieve at least "very
good" rating.
— Introduction of minimum requirements
for leased buildings, ensuring that energy sources are considered.
Is a green energy tariff available? Does the landlord have sustainability
plans? Is combined heat and power or on site renewables available.
SOGE targets currently cover core Departments
and Executive Agencies. Is this adequate, or should they be extended
to cover all Executive NDPBs (Non-Departmental Public Bodies)—especially
given the growing volume of Government business covered by arm's-length
bodies?
It is the experience of the EIC, that arm's-length
bodies and NDPB's are under represented when considering policy
objectives. Arms length bodies are often key to the delivery of
Departmental targets and objectives however it may not be the
case that they are governed by the same policies and objectives,
or even have visibility of these items. Therefore if such targets
and objectives are set, arms length bodies should be intrinsically
included in their delivery. This would increase buy in to Departmental
initiatives and ensure that a greater proportion of ALBs are included
on training courses and their opinions voiced throughout the process
of implementing policy. Currently, arms length bodies may be "opted
in" by their umbrella Department resulting in inconsistency
across the Estate.
Why are some Departments not including "Quick
Wins" clauses in their contracts, when this has been mandatory
since 2003? Why do so few catering contracts have a sustainability
clause? What more should be done to embed sustainability into
Government procurement?
A key reason for Departments not including "Quick
Wins" in contract clauses is a degree of confusion over their
use. Problems that have been encountered when this question is
addressed with Departments are as follows:
— The quick wins are not up to date.
— Awareness of quick wins amongst procurement
officers is not high enough—EIC believe that there is a
need for greater information sharing between Government organisations
so that the products and services that comply are well known.
A centralised data set of quick win purchases could be developed
and easily circulated to all relevant organisations.
In order for sustainable procurement to be more
completely embedded into Government Procurement, it is important
that existing tools, included the Flexible Framework are prioritised.
This tool provides an easy to follow solution to integrating sustainable
procurement into the Government Estate. The framework should be
integrated at Director level within Departments and individuals
should be made accountable for its delivery. However, it is currently
the case that the framework is not being applied consistently
across the Estate and therefore cannot be used as a reliable tool.
11 April 2008
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