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".
- The loss of the Sustainable Development Commission
is premature and its role and responsibilities must be taken on
within Government and Parliament.
- Sustainable development must be dealt with at
the highest level of Government.
- Short term spending cuts must not jeopardise
the transition to a sustainable economy.
- Environmental limits must be defined.
- Policy decisions must be supported by a robust
evidence-base and coherent across Government departments and sectors.
- Decision-making should be inclusive and encourage
the participation of environmental (as well as social) partners.
- Policies must be assessed for their environmental
impacts and subsequent delivery subject to public scrutiny and
- The Government must be prepared to intervene
to enable the country to live within environmental limits.
- 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
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:
- build organisational capacity within Government,
to enable sustainable development to be put practice in policies
- achieve breakthroughs in policy areas with the
greatest immediate impact on progress towards sustainability,
- 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
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:
- 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."
- 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."
- 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
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