Written evidence submitted by Chartered
Institute of Water and Environmental Management |
1. The Chartered Institution of Water and Environmental
Management (CIWEM) welcomes the opportunity to comment on the
Environmental Audit Committee's inquiry on embedding sustainable
development across Government (we contend that the correct term
should be "sustainability" because "development"
has strong connotations with economic growth; the basis of the
current global economic model which seeks to attain perpetual
economic growth and which in a finite world is, by definition,
2. The extent of the (Coalition) Government's
commitment to sustainability is far from clear. Thus far, political
rhetoric concerning "the greenest government ever" and
"driving the sustainability agenda across the whole of government"
is not being reflected in practice and the swift announcement
of the decision to end funding of the Sustainable Development
Commission (SDC), which was a highly cost efficient "critical
friend" of Government, and which demonstrated significant
progress and delivered many tens of millions of pounds of efficiency
savings, appears ruthless, ideological and ill-considered.
3. The Government, having taken such action and
made such pronouncements, has placed itself in the position of
needing to make real improvements to the integration of sustainability
thinking and practice across its departments, if it is not to
be seen as reckless with the interests of future generations.
If the pronouncements are based on genuine intent, then CIWEM
considers such action to be bold. However, the functionality of
the SDC must now be implemented from the spearhead of Government
(i.e. the Cabinet Office, which can take an overview across Government
and can hold other departments to account) and its principles
taken up by traditionally hostile departments such as the Treasury
and BIS. CIWEM believes that with the appropriate level of political
will, there is no reason why Government could not drive forward
the sustainability agenda significantly; the reality of the past
is that Governments didn't have this will, which is one reason
why the SDC was created.
4. Our remaining comments are set out in answer
to the questions posed by this inquiry.
How can mechanisms to ensure the sustainability
of Government operations, procurement and policy-making be improved
and further embedded and mainstreamed across Government departments?
5. The best mechanisms to ensure the sustainability
of Government operations, procurement and policy-making rely on
the quality and integrity of the Government politicians and their
supporting civil service. Very few politicians have the necessary
training to understand their role in sustainability, whereas civil
servants can develop sufficient knowledge in their area if given
adequate training to provide the necessary guidance to politicians.
6. Currently there is a pronounced lack of consistency
in the way that sustainability principles are worked into Government
operations, procurement and policy-making. Different departments
appear to have entirely different approaches to "sustainable"
procurement. There is a need to introduce consistent procedures
and standards across departments to ensure that a consistently
high standard procurement approach is adopted.
7. In relation to other, more specific activities,
there is a need to ensure that awareness and training of civil
servants is relevant to an individual's role. Depending upon activity,
one size will not fit all and there will be a major professional
development undertaking required to ensure that all civil servants
are properly aware of what sustainability means, and requires.
Currently, this required level of understanding is almost non-existent.
There is also a clearly persistent ideology present in many central
tiers of Government (for example the Treasury), that the environment
and sustainability issues are little more than "nice to haves"
and way down the hierarchy of importance below immediate concerns
of economy, health, security etc. In fact, the environment is,
or will be, a crucial component of all of these concerns. A clear
example is the economic decisions associated with coastal protection
or "managed retreat" which clearly affects environmental
and social issues but the dominant element is economic. Government
needs to put greater weight on the aspects for which it is not
possible at present to put economic value.
How can governance arrangements for sustainable
development in Government be improved, and how can sustainability
reporting by Government departments be made more transparent and
8. The SDC played an important role as a watchdog,
assessing Government performance on sustainability and holding
it to account as necessary. This independent policing role has
been lost and it must be replaced by similar functionality elsewhere.
The importance of independence in auditing the Government's own
performance is significant, if its policies (which may need to
be stringent) are going to hold credibility.
9. Governance arrangements for sustainable development
in Government could be improved through focussing on sustainability
outcomes by setting out the potential effect on the three tenets
of sustainability (environmental, social and economic), rather
than the current results-based sustainability reporting. This
might be done by raising the profile and improving the process
of Sustainability Appraisal, which currently languishes in planning
and gathers dust once completed.
Was the SDC successful in fulfilling its remit?
Which aspects of its work have reached a natural end, or are otherwise
of less importance, and which remain of particular continuing
10. The SDC's remit was fourfold: Advisory, capacity-building,
advocacy, and watchdog. As an advisory body and advocator, it
drew on independent experts to consider issues that challenged
conventional thinking and helped to feed them into policy. The
contribution that the SDC made to policy and decision-making can
readily be brought back into Government, and may indeed have greater
impact in such a setting than if promoted by a small, independent
body which could be held at arm's length if required.
11. As an advisor, capacity-builder and watchdog,
the SDC oversaw improvements in efficiency (resource use and waste
reduction) which, according to its most recent report, amounted
to between £60 and £70 million per year. Such figures
will have been heavily quoted by critics of the decision to end
its funding, but the cost effectiveness of this body for an annual
cost to the taxpayer of around £4 million (including the
contributions made by the devolved administrations) makes its
removal hard to fathom. Even more so when in its most recent report
it had identified hundreds of millions of pounds' worth of additional
savings that could realistically be made, and will have to be
made by the current Government if it is indeed to mainstream sustainability.
12. CIWEM agrees that now is the time to implement
major change by properly mainstreaming sustainability into all
aspects of the Government's work. However, before that, it is
important that mainstreaming is thoroughly understood and the
barriers to it removed. It is arguable that the SDC had the expertise
at its disposal to lead this mainstreaming process. This may need
to be delivered from a position of greater influence within Government
in order to provide it with the necessary political "clout".
For this reason, CIWEM would recommend that this pool of expertise
is integrated within the appropriate tiers of Government, affording
it the influence required to overcome the many ideological barriers
that will be faced in order for sustainability to be mainstreamed.
In formulating a future architecture for sustainable
development in Government, how can it take on board wider developments
and initiatives (e.g. to develop "sustainability reporting"
in departments' accounts) and the contributions that other bodies
might make (e.g. Centre of Expertise in Sustainable Procurement)?
13. The primary barriers to effective implementation
of sustainability principles are the boundaries which exist between
departments. This silo effect and the inability to effectively
consider cross-boundary opportunities results in the limitation
of many strategic decisions to achieve sufficient positive sustainable
14. There is potential to create clear linkages
between issues such as policy, procurement and implementation
by establishing a cross-cutting review process which would identify
key sustainability issues of relevance to the whole of government,
with the aim of identifying aspects which need to be dealt with,
either directly or through another particular department.
How, without the assistance of the SDC, will the
Government be able to demonstrate that it is "the greenest
15. If the Government is serious about being
judged against this claim, it is going to have to open up its
own performance to independent scrutiny. Whether this is undertaken
by a specific sustainability regulator which takes on the SDC's
watchdog role, or a more central Government auditing body, is
clearly for discussion. It may be possible for this role to be
provided by the Environmental Audit Committee, or an offshoot
thereof (e.g. a new Sustainability Audit Committee). Alternatively,
the National Audit Office may be appropriately placed to take
on this role. Much will depend on how Government is prepared to
be held to account and how it will react to the results of any
auditing. In light of its comments that "transparency is
the new accountability", it should be prepared to be scrutinised.
16. The Government will also need to demonstrate
a sound understanding of the issues surrounding sustainability,
and incorporate these into its policymaking. "The greenest
Government ever" is a serious claim, and a serious target.
The previous Government, whilst not achieving anywhere near as
much as is required to move the UK onto a sustainable footing,
did put in train a number of frameworks and introduce policies
which moved things in the right direction. Current indications
are that the present Government is not moving forward from this
position, but if anything risk moving backwards.
17. The first step will be to move the tax regime
more towards rewarding sustainable living and sustainable businesses.
There are many opportunities for businesses to help their employees
to become more sustainable, but these are blocked by archaic notions
of "taxable benefit" and therefore clamped down on by
the Treasury. Economic benefit is still the main driver for individual
choice and this same measure has to be applied to rewarding a
sustainable lifestyle if behaviour change of the scale required
is to be achieved.
18. Many of the actions required are detailed
in CIWEM's Manifesto for Environmental Action, published in November
2009. We refer the Committee to this document. (http://www.ciwem.org/FileGet.ashx?id=977&library=Public
11 October 2010