Session 2010-11
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Embedding sustainable development across Government, after the Secretary of State’s announcement on the future of the Sustainable Development Commission.

Written evidence submitted by Atkins Limited (ESD 37)


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.


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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 per cent in 2006 to 34 per cent 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:

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 Telephone +44 (0)20 7121 2000, Direct Line +44 (0) 20 7121 2574

4 December 2010