Written evidence submitted by Atkins Limited
NOTICE
This document and its contents have been prepared
and are intended solely for the Parliamentary Environmental Audit
Committee's information and use in relation to the Consultation
exercise regarding .
ATKINS Ltd assumes no
responsibility to any other party in respect of or arising out
of or in connection with this document and/or its contents.
CONTENTS
1. About Atkins.
2. Introduction.
3. Summary.
4. Body of Submission.
1. ABOUT
ATKINS
1.1 Atkins Ltd gives advice to Central Government
Departments and Councils across the UK on policy implementation
and how sustainable development can be achieved through a number
of work streams, and particularly through the planning and delivery
of infrastructure in town planning services and sustainability
and the roll out of energy services including renewables and all
forms of low carbon that affect the built environment, energy
generation and transmission. This Atkins submission has been drafted
by Atkins Planning.
2. INTRODUCTION
2.1 Some work for a future approach has already
been done in this area. The OGC CESP produced a review of sustainable
target measures in a paper in 2009 in which it called for a new
framework for sustainable measures to which we refer the EAC.
The EAC produced an excellent paper on climate change in March
2010 with many findings that Atkins Planning supports.
2.2 The DEFRA proposal to disband the SDC leaves
an opportunity to embed sustainable development more deeply throughout
all forms of governance by mainstreaming sustainable development
principles throughout all forms of Government, Central and Local
Government and all other public bodies. The work of the Sustainable
Development Commission (SDC) should be carried forward and ensure
that the interface between the three different elements of sustainable
development, environmental, economic and social, will not be coherently
addressed. Social progress in particular, which can be difficult
to measure, is the most vulnerable of these three elements.
2.3 The SDC legacy of "cutting edge advice
and hands-on capability building" (its own words) needs to
be preserved for the future and taken further. The success of
the SDC's thought leadership should be embedded further in the
policy and procurement process.
3. SUMMARY
3.1 The UK Government wishes to be able to measure
and verify its commitment to becoming the "greenest Government
ever". Leadership within Government at the highest level
is essential as the broad based consensus approach to implementation
has not produced consistency of action or response across all
levels of governance and indeed in the private sector. The reviewing
role of the SDC was too weak without powers to make statutory
intervention. It did not have sufficient weight in its role as
"steward". The Government may wish to account to Parliament
for progress of sustainable development and report on its inter-facing
elements. We suggest this could be referred to as a process of
cumulative sustainable development and similar to the process
of cumulative impact assessment in the environmental impact assessment
process.
- We support a role for cross-government independent
scrutiny of progress and a strengthening of mechanisms for ensuring
implementation of targets and benchmarks to monitor progress on
an annual basis.
- We would like to see a Minister responsible for
Sustainable Development in the Cabinet, and one who can provide
an overview of how policies and strategies promoted by CLG, DEFRA
and DECC work together, and where they do not, identify tensions
and how they could be addressed in future policy.
- Just as DECC now provides an Annual Energy Statement
to Parliament we think DEFRA, CLG and DECC should jointly prepare
a similar statement for Parliament on Sustainable Development.
This could link the reported outputs of the Annual Energy Statement
to environmental, economic and social progress for example. It
would go beyond the examination of sustainable development in
Government Departments. It could link up to important policy initiatives
on sustainable communities. It would clarify the statutory function
of sustainable development.
- We think there is a need for an identifiable
unit within Government to generate the future road map backed
by evidence and fresh innovative thinking: work it can only do
if it can monitor the performance of those actively involved in
the delivery of sustainable development. To date there has been
a tendency to devolve responsibility to RDAs and other quangos
to take leadership in the area of implementation for this area.
Overall we believe they have proved to have limited influence
in central Government although regional authority policy possibly
carried the most practical weight in terms of ensuring some aspects
of sustainable development roll out - at least in the built environment
and with social progress.
- We believe the SDC lacked influence because it
did not have statutory powers and could not actively intervene
in the statutory process, such as the planning process.
- We require more working models of sustainable
development in action. The future body could concentrate on behaviour
change especially with regard to energy and waste. It could work
on major policy areas - gaining acceptance of new waste disposal
and warming of home methods for example.
- We would support the creation of cross-departmental
body to integrate the implementation of sustainable development,
reporting to Cabinet and the Government and one which will perform
a role that will ensure that the former functions of regional
bodies are performed. A body (whatever its constitution) should
advise and direct local authorities on methods to achieve sustainable
development. It should also promote new practises on a world stage.
- A new statutory body requires an enabling role
in terms of policy implementation and should assist with the process
of public consultation to gain greater acceptance of the changes
society needs to take in order to adapt to more sustainable lifestyle
choices.
- We support the retention of targets such as N186
and N188. We suggest there should be other targets in relation
to economic, environmental and social targets and that these could
be "bundled" together for the purposes of policy monitoring.
Government can then draw on the results to monitor progress and
its own policy direction. That would feed into an Annual Statement
for Parliament.
- We think there is wastage generated by the bureaucracy
of the procurement process which is not economically sustainable.
We also have concerns about the way in which sustainability of
private bodies bidding for contracts is weighted as this is not
transparent.
- The SDC was well served by specialists who raised
awareness of issues and advised Ministers within Government; however
the organisation possibly lacked a strategy regarding the integration
of issues to articulate where multiple beneficial outcomes could
be achieved, where the costs and benefits (specifically intergenerational
trade-offs) inherent in policy or other decision-making would
lie within society, and critically assessing the assumptions underlying
Government's vision and strategy for sustainability.
- Sustainability and resource efficiency create
business and growth. Examples of the kind of businesses and jobs
needed to service the demand for green savings include energy
auditing and advice, retrofitting three million London homes,
creating district heating, power and cooling systems and refuelling
infrastructure for low carbon vehicles and renewable energy production.
The Government will need to monitor economic growth stimulated
by Green Opportunities.
- The financial sector could be involved in this.
It could engage in actions relating to corporate social responsibility
and should be independently monitored. The local authority remit
includes statutory duties regarding sustainable development but
in this time of financial austerity it seems appropriate for the
task to be extended to the Financial Services Authority (or successor
body) and the banking sector.
4. OUR RESPONSE
TO THE
CONSULTATION:
How can mechanisms to ensure the sustainability
of Government operations, procurement and policy-making be improved
and further embedded and mainstreamed across Government departments?
4.1 We have separated the response to policy
and procurement as we think they should be treated separately.
(i) The challenge of sustainable development
in policy
4.2 Sustainability is an inter-disciplinary (beyond
multi-disciplinary) exercise and successful implementation depends
on Government and Parliament understanding the shape and colour
of the "big picture" and how specific contributions
contribute to the big picture, so that they are not left as single
issue topics.
4.3 One model for its dissemination has been
through the tier of regional governance, especially through policy
making in Regional Spatial Strategies and more lately Regional
Strategies. This policy formed part of the Development Plan and
was material to decision making for strategic planning schemes.
Through this tier of regional planning we expected to see sustainable
development making a qualitative difference to the planning of
major infrastructure such as energy, transport and housing delivery,
for example. The role of the regional tier was particularly important
to the Development Plan because local authorities on these topics
particularly looked to the regions to provide the guidance that
effectively sought to impose and achieve national and sometimes
EU targets. Without the regional tier we expect the implementation
of sustainable development to be piecemeal, occupying a smaller
stage.
4.4 Many local authorities lack the skills and
budget to understand what they must do to contribute and deliver
the "big picture". Regional authorities commissioned
evidence based papers to provide research and findings for the
future planning of infrastructure within the context of the Development
Plan. The provision of this information requires specialist skills.
These findings often affect policy and future planning, and the
skills required to arrive at long term implementation cannot often
be readily funded within local authorities. We do not expect them
to be in the near future and the challenge for the localism agenda
is how it will ensure that there continues to be a system in place
that secures the mainstreaming of sustainable development in all
aspects of policy. For example, the implementation of planning
permissions and monitoring of carbon emissions from new developments
is now feasible through the use of sophisticated carbon tools
-more could be done to make a provision that the planning permission
must achieve a certain carbon target over say, a ten year period
so the sustainability of a permission gets a scoring and an enforcement
mechanism to control breaches relating to carbon thresholds could
be created.
4.5 Planning for infrastructure is more than
just planning at a regional level - it should be a truly spatial
activity that integrates the goals of sustainability across a
number of sectors. Research shows implementation of planning
and climate change reforms is patchy and more joined up working
is needed. In the draft policy PPS 1 Supplement 2010 it clearly
stated that climate change in the then Regional Strategy should
be on an equal footing with housing and economic development (an
example of joined up sustainable development) . The Regional Strategy
would have set the plans in place for a decentralised energy supply
- so relieving LPAs of some of the burdens of target implementation.
The mechanism for its replacement in the localist agenda is unclear.
4.6 Local Economic Partnerships have been relieved
of targets and the future role of National Indicators which are
so important for energy have not been set out. We therefore advocate
long term support for current regional energy "agencies"
where they exist and support for new bodies that address these
cross county/ cross- Council concerns. We do not think that local
authorities have sufficient skills, resources and experience to
devolve energy policy without substantial support. We say this
from our experience in dealing with renewable energy applications
and the roll out of low carbon development.
4.7 In terms of regional policy succeeding we
know that the London Region has been influenced by the findings
of the Sustainable Development Commission; in particular through
the London Plan which has successfully:
- increased the numbers of affordable housing
in many strategic housing developments to 35% or more (see the
Annual Monitoring Reports from the GLA) so contributing to the
housing pool in London for the less well off and securing housing
for essential key workers required for London's world city status;
in so doing affordable housing has also helped to regulate pricing
in certain sectors of the housing market to some degree.
- Increased the production of low carbon and
renewable energy production with the application
of mechanisms such as the Merton rule (achieving a reduction in
carbon dioxide emissions of 10% from on site renewable energy
generation in new buildings); although Atkins believes that the
formula for low carbon development needs to change and move to
a whole life carbon analysis, the Merton rule triggered acceptance
of the requirement for a low carbon policy in the private housing
and commercial sectors. GLA policy and strategy has been influential
in the grant of planning decisions with respect to carbon output
as research from the London Southbank University Report 2009
details. This shows that the London Plan has been successful
in getting developers to go much further than basic requirements
under building regulations to incorporate sustainable measures
and cut carbon. The carbon savings being secured from developments
has increased from an average of 29% in 2006 to 34% by mid 2009.
The study shows that setting challenging targets has successfully
driven developers to reduce their carbon emissions and the planning
system has been responsible for delivering tangible targets.
- Improved the quality of design
at masterplan and site brief level affecting the built environment
across a range of typologies. Working with Design for London and
the CABE Design Review Panel, London boroughs have improved design
quality evidenced by improved housing standards, public buildings
and amenity spaces around London. Similar evidence can be found
in other parts of the country.
4.8 We do not believe that these achievements
would have been made without a Mayor of London and the specialist
support teams he had in place to push through these policies and
their respective implementation. We suspect that political divisions
amongst London Boroughs could not be overcome in the name of sustainable
development because it is a "big picture" feature of
policy. What it shows is that Governance structures need specialist
support with the implementation of complex policies that embrace
sustainable development. Such support is required at all levels
of governance. The new localism agenda needs to be supported by
a level of strategic planning to address the nation's most pressing
issues
Sustainable development
in the built environment
4.9 We note that CABE will not continue to function
after March 2011. However, we would urge Parliament to ensure
that some of its functions with respect to the safeguarding of
sustainable development for the built environment continue. For
example it is sometimes difficult to measure the benefits of its
enabling role in terms of improving the role of consultation and
the value of design but its efforts have proved to be good value
for the public purse. One example is the White City Westfield
development in Bourbon Lane which provided affordable housing
for the Octavia Housing Association and which was achieved through
a design competition with the help of CABE design review skills.
The housing development that was built as part of the Shepherds
Bush Westfield complex is written up here: http://www.cabe.org.uk/case-studies/bourbon-lane
Understanding sustainable
development in the mix
4.10 All new development should now be low carbon
development. This has implications too for transport, waste planning
and water management. The arm of Government responsible for sustainable
development could, for example, ensure that non-energy developments
do not prejudice substantial development that could take place
for renewables.
(ii) Procurement
4.11 In its provision of consultancy services,
Atkins is affected by the public procurement process in every
aspect of the work it performs across the EU and the UK, (and
indeed in other parts of the world where UK practice is required
to be copied).
4.12 The mechanisms for achieving sustainable
development can be raised in the procurement process and we have
seen some Councils scoring consultancies on their own sustainable
practices as part of the quality control procurement monitoring
exercise. Atkins has actively engaged in this process but it is
not clear to us how that affects scoring in the commissioning
process. More transparency is required from public bodies about
the criteria private sector organisations should meet. An understanding
about its weighting in the procurement process needs to be disseminated.
4.13 Greater consistency of approach regarding
Councils' own internal application of sustainable development
and how they expect partners to engage with it is required. We
think the process of thought leadership in this area possibly
comes from the interplay of the public/private engagement process
and this should be encouraged with some form of official recognition.
A successor body to the SDC could adopt a brokerage role in promoting
new practices and procedures.
4.14 We think the procurement process could be
simplified and shortened. Systems of registration dealing with
the administrative aspects of procurement can be centralized (a
model used by the GLA/LDA in CompeteFor for example and by the
London Borough of Newham). We would recommend a Standard Application
Form that all Councils can use and then supplement for bespoke
issues if required so there is greater consistency and uniformity
of approach across the procurement process.
4.15 Government should support voluntary forums
for dialogue between the private and public sector such as the
newly formed Regeneration UK. The Government's "big society"
initiative should provide funding for linking initiatives between
the private and public sector.
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)?
4.16 The major challenge is for Government to
understand how the interplay between the various topic strands
of sustainable development plays out - something which is particularly
relevant to Government in an era of cut back.
4.17 Dedicated sustainability "champions"
(who have a good understanding of the inter-disciplinary nature
of the concept) operating at key points within Government, with
recourse to expert support (through universities and expert bodies
for example), may be a more effective strategy to embed sustainability
into Government departments, rather than have an expert within
every Government department take on the role of sustainability
"champion" as an adjunct role. However, it will be important
to have sustainability "stewards" within Departments
that operate as points of contact and serve to "translate"
the function of the Department into sustainability terms. Within
Cabinet there is a requirement for a defined role to contribute
to the role of thought leadership in government.
4.18 Public bodies and organisations from Councils,
the HCA, the Carbon Trust, the Carbon Hub, to organisations working
in the private sector like Atkins and other infrastructure/environmental
consultancies are key to the delivery of public sector aims and
objectives. Some form of reporting mechanism needs to be set up
with measurable outputs which should actively encourage organizations
to provide feedback on particular challenges and achievements
associated with sustainable development in order to provide best
practice case studies and methodologies.
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?
4.19 The weakness of the SDC in our view is that
it did not have a statutory function or statutory powers to engage
in the planning process.
4.20 In addition sustainable development is referred
to in a number of town planning statutes but it is not defined
in those statutes. So the result was that the SDC body did not
have a statutory duty to intervene with the statutory process
of planning, a process which enables the delivery of sustainable
development. We are aware that the lack of definition has generated
tensions around its interpretation. e.g. its role in the future
of the draft London Plan policies.
4.21 We think that a successor body and/ or Government
Department could actively intervene in the delivery process and
that the case for that is overwhelming now that the regional tier
of governance through Regional Spatial Strategies has been removed.
4.22 A "rich" concept of sustainability
is required to provide the narrative necessary to drive sustainability
through all levels of Government and move away from a single-issue
focus; the introduction of dedicated sustainability champions
to direct the "big picture" and support "stewards"
within Departments and also have a role in auditing sustainability
reporting may provide the necessary facilitating structure within
Government.
4.23 In general, the concept of sustainability
needs to be improved and disseminated to all levels of Government
so that there is a common understanding of the richness of the
concept throughout; sustainability is not just about responses
to climate change, biodiversity and equal access issues. Single
issue targets provide a valuable way of measuring progress (and
their retention in energy must be kept for example to ensure compliance
with the Low Carbon Transition Budgets) but is limited. The concept
needs to be translated into a working model that is sufficiently
suited to the main functions of Government, such as procurement,
service-delivery and policy-making.
4.24 The basis for a future architecture for
sustainability is a step change in understanding the rationale
for sustainability as a way of working within Government; and
a scheme of penalties and incentives to enforce the processes
that aim to integrate sustainability within operations and achieve
the desired outcomes.
OUTSTANDING QUERIES
Should you have any queries on this submission please
do not hesitate to contact Liz Loughran, Principal Planning Consultant,
Planning Landscape & Heritage, Atkins Water and Environment
Group, Atkins Limited, Euston Tower, 286 Euston Road, London,
NW1 3AT
liz.loughran@atkinsglobal.com Telephone +44 (0)20 7121 2000, Direct
Line +44 (0) 20 7121 2574
4 December 2010
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