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 the Royal Society for the Protection of Birds

The Royal Society for the Protection of Birds (RSPB) is the charity that takes action for wild birds and the environment. We are the largest wildlife conservation organisation in Europe with over one million members.


Protecting the natural environment is core to sustainable development, but in the UK and in England we are still failing to put this into practice. The situation is worrying: species continue to decline, priority habitats and protected sites remain impoverished, carbon dioxide emissions are not being cut fast enough, and water consumption is unsustainable. Embedding sustainable development in Government is essential if the coalition is to achieve its ambition to be "the greenest Government ever".

  1. The loss of the Sustainable Development Commission is premature and its role and responsibilities must be taken on within Government and Parliament.
  2. Sustainable development must be dealt with at the highest level of Government.
  3. Short term spending cuts must not jeopardise the transition to a sustainable economy.
  4. Environmental limits must be defined.
  5. Policy decisions must be supported by a robust evidence-base and coherent across Government departments and sectors.
  6. Decision-making should be inclusive and encourage the participation of environmental (as well as social) partners.
  7. Policies must be assessed for their environmental impacts and subsequent delivery subject to public scrutiny and accountability.
  8. The Government must be prepared to intervene to enable the country to live within environmental limits.
  9. The SDC's work on education for sustainable development is of continuing importance, and the Government must continue to support this aspect of work.


1.  Nature matters. It has an intrinsic value, people's wellbeing depends upon it and its raw materials underpin our economy. Sustainable development is an issue because it is accepted that current levels of consumption and production (locally and globally) cannot be sustained indefinitely. In recognising this fact we have to act upon it. Change must be led from the highest levels of Government, within the Cabinet Office or Treasury (for matters reserved for England), urgently. All Government departments and public bodies must be answerable for their progress towards the sustainability of operations, procurement and policy-making. In this response, we focus on the requirements for improved policy-making.

2.  The twin goals of sustainable development have been defined as living within environmental limits and securing a healthy, just society. Given that the new UK Government has, through its planning reform proposals, proposed a presumption in favour of sustainable development, it is appropriate to either confirm this definition or establish a new one to aid decision-making.

3.  The current economic climate and justifiable concern over public debt is preoccupying Government thinking. There have been casualties already (notably the Sustainable Development Commission) and the spending review is set to unleash a further rash of cuts across departments and sectors. However, these short term gains in the book balance must not undermine efforts to steer England and the UK towards a sustainable economy. It is important that the purpose of development now and in the future is to achieve genuine improvements in environmental, social as well as economic wellbeing. Health, social and environmental indicators should be used to measure national progress.

4.  The UK Government and devolved administrations share the principle that we must live within environmental limits. This is a non-partisan position, intrinsic to sustainable development and should be core to Government strategy. Limits need to be defined. Governments tend to define environmental limits in targets and laws to safeguard the natural environment at different geographical levels. While these commitments are not in themselves sufficient to prevent environmental limits being exceeded, they do provide a useful reference point to assess Government progress. The RSPB supports a target-led approach because they provide a focus for action, encourage scrutiny and ensure accountability.

5.  Decision-making within Government should be based on a robust evidence base. It is important that the Government provides adequate funding to research the state of the natural environment, for example, on the location of key species and the condition of local wildlife sites. Where research has been undertaken, it should be publicly accessible and inform policy development. This point overlaps with our concern about finding a new home for regional environmental, economic and social data, which needs to be "owned" and kept up to date by appropriate groupings.

6.  If policy-makers do not understand how policies will affect the natural environment, they should adopt a precautionary approach and invest in further research. Improving the monitoring and dissemination of information can result in better decision-making. For example, with funding from Scottish Natural Heritage, RSPB Scotland produced a bird and wind farm sensitivity map. The map helps developers and local authorities to identify those areas where wind farms would pose a medium to high risk to important bird populations in Scotland. It is hoped this will help to minimise the conflict by enabling developers to avoid the most sensitive sites.

7.  Policies across Government should be coherent. For instance, aviation expansion would not consistent with aspirations to move towards a low carbon economy, and the use of palm oil to meet UK biofuel targets continues to be the cause of tropical deforestation. These two examples underline the need for cross departmental (or sector) communication and cooperation and illustrate the scale of the challenge in terms of behavioural change within Government and policy reform.

8.  Nature has no voice. Organisations like the RSPB speak for it. Government and public authorities need to adopt an inclusive approach when developing and implementing policies, to encourage the participation of environmental partners. Increased engagement and participation of environmental partners helps to improve the quality, relevance and effectiveness of Government policies. It ensures that socio-economic concerns are addressed alongside economic issues.

9.  Unless public bodies are called to account for their failure to meet environmental targets or commitments, sustainable development will be compromised. The building blocks of scrutiny include obligations to monitor and report on progress supported by independent bodies charged with holding the authority to account. In the absence of the Sustainable Development Commission, perhaps the only credible alternative is that this role is taken on by Parliament. The bottom line is that scrutiny and accountability arrangements must have teeth.

10.  The true value of the natural environment should be fully assessed and taken into account when developing and implementing policies. Tools, such as regulatory impact assessment, strategic environmental assessment (SEA), and cost-benefit analysis can ensure that environmental considerations and policies are integrated into all policy and decision-making at an early stage. Without a full and thorough consideration of the costs and benefits, well intentioned policies can result in unforeseen outcomes (e.g. the impact of palm oil, described above).

11.  More than 100 duties have been established requiring public authorities to "contribute to" or "have regard to" sustainable development or nature conservation. Some work better than others, depending on the appetite of those in authority. We cannot afford not to take sustainable development seriously. The coalition Government must be prepared to intervene through fiscal, policy and regulatory reform to help the country live within environmental limits.


12.  In 2009 the previous UK Government and devolved administrations confirmed that the Sustainable Development Commission's (SDC) three strategic aims were to:

  1. build organisational capacity within Government, to enable sustainable development to be put practice in policies and programmes;
  2. achieve breakthroughs in policy areas with the greatest immediate impact on progress towards sustainability, and
  3. to hold Government to account for its progress towards delivering sustainable development, and to mainstream a scrutiny role within other public sector monitoring and audit bodies.

13.  In 2010, while progress has undoubtedly been made, none of these critical objectives can be said to have reached a natural end. All remain of continuing importance. The SDC has acted as advisor, advocate and as a critical friend to the UK Government and devolved administrations. It has done this as an independent body outside Government (a non-departmental public body) able to push the Government in the right direction. It is difficult to see where the impetus will come from within the coalition Government to do this by itself. As discussed above, Parliament should perhaps take on some of its scrutiny function.

14.  The SDC's work programme covered ten policy areas: climate change, consumption, economics, education, energy, engagement, health, housing, regional and local government and transport. The Government should continue to fund and oversee projects in each policy area, taking into account: knowledge gaps in government, new policy initiatives, contentious issues and technological innovations. In essence, the SDC's role is still needed, its work is still very relevant and this element could be taken on within Government. The Cabinet Office or Treasury, not Defra, should be the responsible department in keeping with the gravity of the issue and its cross-cutting nature.


15.  In 1999, the Panel for Education for Sustainable Development's (ESD) report "Education for Sustainable Development in the Schools Sector" made recommendations to the then DfEE and Qualifications and Curriculum Authority (QCA) as to "what education for sustainable development looks like in practice, in terms of learning outcomes." The DCSF launched the National Framework for Sustainable Schools in 2006, with the aspiration that all schools in England be sustainable by 2020. Underlying the framework are three widely cited competencies of care; for oneself, for each other, and for the environment.

16.  In July 2009, the SDC's Breakthroughs Project identified the ideas with the most potential for tackling climate change, resource depletion and inequality in the 21st century. Natural Values, an idea promoting outdoor experiences for all children in the UK to develop the values, knowledge and understanding that underpin sustainable lifestyles, was submitted by lecturers at the University of Cumbria and selected by the SDC as one of the final 19 breakthrough ideas. Alongside the Natural Values idea, the SDC showcased RSPB Rainham Marshes as delivering precisely the type of learning in the natural environment that children need to confront the challenges of 21st century. Speaking at the time, Jonathon Porritt, then SDC Chair, said:

"If we're to be suitably ambitious about how the environment contributes to young people's well-being, and how young people contribute to the well-being of the environment, we should aim to make outdoor experiences a sixth objective in the Every Child Matters Framework."

17.  The benefits to schools and children have been reported by Ofsted - the schools inspectorate in England - on a number of occasions over recent years:

  1. In May 2008, "Schools and sustainability: a climate for change" recommended that the DCSF and QCA "should ensure that the curriculum reflects the importance of learning about sustainability [and] stress the importance of education for sustainability as part of a broad and balanced curriculum."
  2. In December 2009, "Education for sustainable development: improving schools - improving lives" recommended that schools should "ensure that all pupils have access to out-of-classroom learning to support their understanding of the need to care for their environment and to promote their physical and mental well-being."
  3. In August 2010, "To sustainability and beyond: inspecting and reporting on progress in sustainable development" sets out how Ofsted will be "integrating sustainable development principles into our strategic planning and performance management frameworks and our core business activities of inspection and regulation."

18.  Despite the crucial role that education plays within enabling sustainable development - and evidence of the diverse impacts on children's learning and more widely in society - the Department for Education has indicated that it will no longer support the Sustainable Schools framework. Progress has been made over the last decade in establishing ESD in many schools, along with Ofsted's recent statement of intent to embed this across their work. The role of the SDC in enabling these advances in schools (as well as supporting local authorities, NGOs, and the Government) has been pivotal. To ensure that ESD is taken up by all schools, this area of work must be considered as an aspect of the SDC's work which remains of particular continuing importance. The Government must send a clear message of support to schools (and all organisations working in this area) to reflect the importance of ESD for sustainable and environmentally-responsible future.

12 October 2010

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