Embedding sustainable development across Government, after the Secretary of State's announcement on the future of the Sustainable Development Commission - Environmental Audit Committee Contents

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, unsustainable).

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 accountable?

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 importance?

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 benefits.

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 government ever"?

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 Access)

11 October 2010

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