Memorandum Submitted by the Environment
Agency
SUMMARY
The Environment Agency welcomes the opportunity
to submit evidence to the Environmental Audit Committee's inquiry
on "Greening Government".
We are committed to reducing the environmental
footprint of our own operations. We have set ambitious targets
and are making good progress towards meeting them. We were represented
on both the Government's Sustainable Operations Board and the
Sustainable Procurement Task Force during its development phase.
We believe Government must be a leader in embedding
sustainability within its own operations. Government procurement
accounts for almost half of GDP, providing significant opportunities
to reduce the sustainability impacts of suppliers. This leverage
should be used to deliver positive environmental outcomes and
Government suppliers should be encouraged to offer more sustainable
solutions to their private sector customers as well.
The high scores of some Departments reported
in the Sustainable Development Commission's Sustainable Development
in Government assessment, and our own performance, show that
delivery of the Sustainable Operations on the Government Estate
(SOGE) targets is achievable.
Our main points are as follows:
— Performance against SOGE targets should
be a priority for Departments and other Government bodies.
— The SOGE targets should be reviewed in
the light of policy changes and more stretching UK domestic targets.
We also believe there is scope for the target achievement dates
to be brought forward.
— An interdepartmental carbon trading scheme
should be approached with caution. Many central Government departments
will participate in the Carbon Reduction Commitment and will have
the facility to trade within that.
— Achieving carbon reductions from offices
are definitely achievable as demonstrated by our own performance.
1.0 Introduction
1.1 We welcome the opportunity to submit
evidence to the Environmental Audit Committee inquiry on "Greening
Government". The review of SOGE targets and the opportunity
to "raise the bar" could help to inject pace into the
delivery of government objectives for sustainable operations.
Our comments on the specific areas identified are set out below.
2.0 The role of the Centre for Excellence
in Sustainable Procurement and the Minister for Transformational
Government in co-ordinating and driving forward activity across
government.
2.1 We believe the Centre for Excellence
in Sustainable Procurement (CESP) could have been established
more quickly and that the challenge is now to inject pace. CESP
has explained that their role is to co-ordinate best practice
policy, strategy and processes that exist within government. There
are limited resources in the CESP team and their success will
depend upon the ability or willingness of Departments to embrace
and implement best practice. CESP need to retain specialists in
sustainable procurement who have procurement experience and can
communicate effectively with practitioners.
2.2 To facilitate the sharing of best practice
we have made a number of our sustainable procurement guidance
documents publicly available, including, for example, our sustainable
commodity guidance and our timber policy. We would encourage other
parts of Government to do the same.
3.0 The extent to which government commitments
and mandated targets are being enforced.
3.1 SOGE data returns are currently voluntary
for NDPBs. We would welcome the SOGE return being made mandatory
for all NDPBs.
3.2 Overall performance against the Mandated
Mechanisms is low. Many new builds are not achieving the BREEAM
"excellent" standard and sustainability appraisals of
office relocations are not being carried out. The Environment
Agency aims to achieve these mandates for all relevant projects
within our recently approved National Accommodation Strategy.
It is our view that the mandates and targets are not well enforced
and we would welcome more rigorous challenge.
3.3 We believe departmental targets and
mandates should be monitored by the Office of Government Commerce
or the Sustainable Development Commission. For NDPBs such as ourselves
monitoring should be through the sponsoring department. We suggest
that a good opportunity to enforce the mandates for standards
like BREEAM excellent would be at the business case sign-off stage
before any investment is committed.
3.4 Use of the Sustainable Procurement
Task Force Flexible Framework is limited in the Government estate.
We have developed a sustainable procurement action plan in
response to the framework and have recently won an award for our
timber purchasing policy from the Chartered Institute of Purchasing
and Supply. Mandating the use of the framework across all Government
departments would increase its use and effectiveness.
4.0 The gap between the level of ambition
set for the UK government policies and the level of ambition Government
sets itself within the Sustainable Operations on the Government
Estate (SOGE) framework.
4.1 We believe the Government should lead
by example. Achievement of SOGE targets should ensure that government
operations are leading edge. Since the launch of the SOGE targets
in 2006 the impetus and pace with which climate change in
particular needs to be addressed has increased.
4.2 The current SOGE targets to reduce
carbon dioxide (CO2) emissions by 30% by 2020 relative to
1999-2000 levels, should be reconsidered and brought into
line with the carbon budgets proposed by the Committee on Climate
Change. These require either a 34% or 42% decrease in all greenhouse
gas emissions from 1990 levels by 2020.
4.3 This is dependant on whether the EU
moves from its commitment to a 20% reduction in greenhouse gas
emissions to their planned target of a 30% reduction greenhouse
gas emissions if an international post Kyoto agreement is reached.
The longer term UK domestic target is an 80% reduction in 1990 levels
of greenhouse gas emissions by 2050.
4.4 The Environment Agency's aim is to
reduce emissions by 30% by 2012. We believe that all Departments
and Agencies should be able to achieve a similar target.
4.5 We believe the targets for water and
waste also need to be reviewed in the light of the Water Strategy,
the Waste Strategy and other new policies to ensure they are suitably
ambitious.
5.0 Whether attainment of SOGE targets at
the level at which they are currently set would result in sustainable
operations.
5.1 We believe there is a need to review
some of the targets to make them more stringent or to deliver
the targets earlier than originally intended for them to be considered
to be delivering sustainable operations.
5.2 Examples of the increased pace with
which we believe these targets could be delivered are:
— The target to reduce CO2 emissions
by 30% should be achieved by March 2015. The Environment Agency
has set itself a 30% reduction target in CO2 emissions by
March 2012.
— The target to reduce water use by 25%
by 2020 should be achieved by March 2015. Our target is to
reduce water use by this amount by March 2012.
6.0 The planned review of the SOGE framework.
6.1 We welcome the review of the SOGE framework.
The current set of targets are outcome focussed which we support.
The targets cover the key areas and we do not believe any additional
targets would be beneficial as they may dilute the focus of the
SOGE initiative.
6.2 We believe all Executive NDPBs, including
ourselves should be covered by the SOGE targets. Sustainability
should be at the heart of all Government and public sector business
and the achievement of the SOGE targets should help to ensure
it is delivered.
7.0 The potential for interdepartmental carbon
trading.
7.1 The advantages of cap and trade schemes
are well known and have been demonstrated through mechanisms like
EU ETS. The proposed Carbon Reduction Commitment (CRC) is a carbon
trading instrument which all central government departments as
well as other public and private sector bodies will participate
in. Under the CRC, which we will administer, central government
departments will trade between themselves and others within the
market.
7.2 The CRC does have some exclusions,
most notably transport emissions, but we believe government would
need to look carefully at whether the benefits of an additional
trading scheme (beyond the CRC) for central government departments
is justified. The efficiency of cap and trade schemes is increased
with the size of the market so we believe central government departments
should participate in the CRC.
8.0 The use of credits and offsetting in
achieving targets.
8.1 Though we welcome individuals
or organisations offseting their operational impacts (eg travel),
by buying offsets or using credits, we believe that practical
actions that cut the emissions from their activities is the priority.
High quality carbon offsets that genuinely deliver additional
carbon savings can play an important role in an organisation's
carbon reduction strategy. However we believe this should be at
the bottom of the hierarchy of actions to reduce CO2 emissions.
8.2 In 2007 we set up a Carbon
Reduction Fund to minimise our own carbon footprint. The fund's
original budget was based on how much it would cost to offset
our own emissions. We use the fund to:
— Reduce our own CO2 emissions by
investing in carbon reduction projects.
— Engage our staff in reducing our CO2 footprint
through inviting their bids for funding for carbon reducing projects.
— Stimulate the development of technologies
which can support CO2 reduction.
The key selection criteria for projects are
cost per tonne of carbon saved and innovation.
9.0 The Government's Greening ICT Strategy.
9.1 The Government spends significant amounts
of money on ICT (£billions). We believe this must be spent
in the most sustainable way possible. The Greening ICT Strategy
launched in July 2008 is an important means to help ensure
this happens.
9.2 We are on the Green ICT Delivery Unit
of the Cabinet Office Chief Technical Officer Council which provides
leadership across government for Green ICT. As part of the main
Council we had oversight of the development of the Greening ICT
Strategy.
9.3 We are currently looking to outsource
our operational IT service. Sustainability is a key factor in
this tender process.
10.0 The reasons behind the continuing poor
progress on reducing carbon emissions from offices.
10.1 Environment Agency progress on reducing
energy use from its offices has been good. We have seen reductions
in office energy use over the last three years.
10.2 It is often said that public sector
bodies find it difficult to make the business case for the necessary
investment in technologies to reduce energy use in offices. There
are a number of government backed funding streams, such as SALIX
Finance, which can help address this.
10.3 Not all reductions in emissions require
investment. Behavioural change can have significant effects. Part
of our success has been having our carbon reduction target as
a measure of corporate performance on our scorecard. The accountability
at Director level helps ensure performance is driven through the
organisation.
11.0 The reasons for the wide variations
in departmental performance on issues such as carbon emissions
from transport.
11.1 We have taken a dual approach to addressing
transport emissions. We have significantly reduced the miles we
drive (winning the 2008 Energy Saving Trusts Green Fleet
Hero award). We also factor in CO2 emissions when purchasing
vehicles. We achieved the government target of an average CO2 rating
of 130 g/km two years early.
11.2 The way we set targets and check performance
against them, from Chief Executive to individual teams in a delivery
unit, is instrumental in delivering the reductions we have achieved.
21 April 2009
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