Environment, Food and Rural Affairs CommitteeFurther written evidence submitted by WWF-UK

Summary of WWF’s key Recommendations

Better integration and co-ordination is required in central Government of green economy policy with core economic strategy.

Greater transparency and representation in key advisory bodies, eg Green Economy Council and Ecosystem Markets Task Force.

Greater political commitment and a more strategic approach to reducing the economy’s impact on the natural environment overseas.

Ensure planning reforms promote genuinely sustainable development.

Actions for the forthcoming Water White Paper:

Develop a firm timetable (with 2027 as the end point) and a clear process to reform the water abstraction regime so that all licences reflect environmental limits.

Commit to funding solutions via the 2014 periodic review for the rivers where water company abstraction damage is officially confirmed.

Reform abstraction charges to reflect the value of water.

Develop a strategy for implementing the Walker Review recommendation to introduce meters in 80% of households by 2020, alongside tariffs to protect vulnerable customers and deter waste.

Local Nature Partnerships should be given the same level of support (financial and administrative) and recognition within the planning system as Local Enterprise Partnerships.

Natural Capital Committee should play a similar role to the Climate Change Committee: monitoring progress towards biodiversity and natural capital targets; providing policy recommendations; and considering impacts outside the UK.

More research on suitability of Impact Assessments in taking the value of nature into account in policy appraisal; develop consensual, multi-criteria, multi-stakeholder valuation processes that capture values of nature that cannot be meaningfully quantified in monetary terms.

WWF-UK Response to Inquiry Questions

What actions are required across Government Departments, from local government and by civil society to deliver the White Paper’s proposals to grow a green economy?

Better integration and co-ordination in central government of green economy policy with core economic strategy

1. One key element of the Natural Environment White Paper’s (NEWP) proposals to grow a green economy was the “green economy roadmap”. The publication of the roadmap (“Enabling the Transition to a Green Economy”) in July 2011 was a welcome step in providing greater clarity for business on the policy framework. However, WWF was disappointed that the document did not herald the new, comprehensive and strategic approach to green economy policy that is required to address the scale and urgency of the challenge. No significant new policies were announced and it is not clear whether this initiative will lead to better co-ordination of these policy areas on an ongoing basis.

2. Furthermore, although credit is due for effective collaboration between the Department for Environment, Food and Rural Affairs (Defra), Department for Business, Innovation and Skills (BIS) and Department for Energy and Climate Change (DECC), the most important department in terms of economic policy—the Treasury—was absent from the core project team. This gives the impression that green economy policy continues to be seen as an “add-on” to core economic concerns. Further evidence for this can be found in the Plan for Growth, published with the Budget in April 2011, in which, out of sixteen measures of success, only one weak environmental measure was included (“increased investment in low carbon technologies”). We recommend that in the second phase of the Growth Review, the Treasury and BIS put an ambitious green growth strategy at the centre of their plans to foster a sustainable economic recovery.

Greater transparency and representation in key advisory bodies, eg Green Economy Council and Ecosystem Markets Task Force

3. The NEWP announced the establishment of two business-led advisory groups: the Green Economy Council and Ecosystem Markets Task Force. In order to ensure their advice and recommendations are geared towards achieving environmental and equitable outcomes, as well as economic efficiency, we would like to see greater representation on these bodies for environmental scientists and economists, as well as other stakeholder groups in civil society. In addition, the proceedings of these bodies should be in the public domain.

Greater political commitment and a more strategic approach to reducing impact on the natural environment overseas

4. We welcome the Government’s ambition in the NEWP to grow “a green economy which not only uses natural capital in a responsible and fair way, but contributes to improving it.”1 The UK economy depends heavily on the natural capital we import from overseas—and consequently much of the environmental impact of our economy falls outside the UK. According to the Government’s National Ecosystem Assessment,2 over one third of the biomass (food, fibre, timber, biofuels etc) used in the UK is imported. WWF’s 2010 Living Planet Report shows that if everyone on Earth consumed resources at the rate of the average person in the UK, we would need almost three planets.

5. Although there is clear acknowledgement of this issue in the NEWP, overall the level of response proposed does not match this level of demand on overseas ecosystems. There is no explicit commitment to reduce or minimise the impact of our economy on the natural environment in other countries. There are some relevant measures in the Green Economy section but these do not add up to a concerted effort or strategic approach that would follow from a high level commitment to fully address England’s responsibilities in this area. The key measures proposed to put the natural environment at the heart of economic thinking focus on national rather than global impacts. Additional measures could include:

Sustainable public procurement: although the commitment to 100% sustainable seafood is very welcome, minimum standards for certified sustainable wood products, palm oil and soy should be applied to public procurement contracts at all levels including local government, schools and the NHS.

Adopt consumption-based indicators and strategies, including carbon, ecological and water footprints.

More financial and technical support for natural resource management in developing countries through the overseas aid programme.

Ensure planning reforms promote genuinely sustainable development

6. We are concerned that some elements of the emerging planning reforms (eg aspects of Energy National Policy Statements, the National Planning Policy Framework (NPPF) and the Localism Bill) are contrary to the aims of the NEWP and we query how conflicts and inconsistencies may be reconciled. In particular the reforms should ensure the planning system is geared towards achieving sustainable development, with a clear definition that includes economic growth within environmental limits. WWF considers that the presumption in favour of sustainable development, as currently drafted in the NPPF, is really just a presumption in favour of any and all development. Without fundamental amendments, it may cause significant damage to the natural environment, as well as the integrity of the planning system.

Actions for the forthcoming Water White Paper

7. The Natural Environment White Paper highlighted our critical dependency on freshwater ecosystems. In the NEWP, the Government stated:

“We will reform the abstraction regime. The new regime will provide clearer signals to abstractors to make the necessary investments to meet water needs and protect ecosystem function. We will also take steps to tackle the legacy of unsustainable abstraction more efficiently.”

WWF-UK welcomes these new commitments. They are essential to protect freshwater biodiversity and help us manage in the context of increasing hydrological stress and uncertainty as the climate changes. We are hopeful that the forthcoming Water White Paper (WWP) will include the actions for ensuring these commitments are delivered. These are:

Develop a firm timetable and a clear process to reform the water abstraction regime so that all licences reflect environmental limits

8. It is vital that the Government includes a clear statement that it intends to reform all abstraction licences to reflect environmental limits, with a timetable for doing so by 2027 at the latest.3 Water companies need clarity as soon as possible in order to minimise the impact of changes on water resources—and the pressure on customers’ bills. The longer water companies have to plan, the more cost effective the solutions they are likely to be able to deliver—short term planning tends to lead to high expense solutions (such as desalination). The Government must set out a process that encourages early and voluntary action (by use of incentives) before 2027, and send a clear signal that 2027 is the ultimate backstop when licences that have not been reformed in a satisfactory manner by then will be subject to compulsory reform.

Commit to funding solutions via the 2014 periodic review for the rivers where water company abstraction damage is officially confirmed

9. There are 170 outstanding sites affected by water company abstraction under the Environment Agency’s Restoring Sustainable Abstraction programme—sites where a significant risk of environmental damage is confirmed. In the WWP, the Government must ensure that solutions for these sites can be funded in the 2014 periodic review.

Reform abstraction charges to reflect the value of water

10. The NEWP placed great emphasis on valuing ecosystems services including those provided by rivers. Both the Walker4 and Cave5 reviews recommended that reforms to abstraction licensing and water charging arrangements were needed to reflect the true value of water taken from the environment. The WWP should include a commitment to reform abstraction charges by introducing volumetric and scarcity based charging in order to better reflect the full environmental value of water.

Develop a strategy for implementing the Walker Review recommendation to introduce meters in 80% of households by 2020, alongside tariffs to protect vulnerable customers and deter waste

11. The only way to truly address affordability issues is to develop social tariffs hand-in-hand with a strategy for widespread metering. By 2015, 50% households in England and Wales will pay for the water via a meter; based on “business as usual” it will be 80% by 2030. The question is not so much “should we move to meters?” but “when?” The WWP must include a commitment to implement the Walker Review recommendation of 80% household metering by 2020. It should enable the cost-effective roll out of metering and the introduction of tariff schemes to protect vulnerable customers and encourage all customers to use water efficiently, as well as measures to help customers through the transition. In addition, the WWP should include a commitment to allow all water companies to install compulsory meters where there is social and environmental benefit in doing so.

Will the institutional framework outlined for delivering the proposals (in particular Nature Improvement Areas and Local Nature Partnerships) be effective?

12. While WWF welcomes the establishment of the Local Nature Partnerships, we have some concerns that the creation of separate bodies to deal with particular local issues (economy, environment) will lead to a siloed approach that does not promote sustainable development at the local level. To be effective, LNPs must be given the same level of support (financial and administrative) and recognition within the planning system as Local Enterprise Partnerships.

Does the proposed natural capital committee have sufficient powers?

13. WWF welcomes the intention set out in the NEWP to establish a Natural Capital Committee. This is likely to be a useful addition to current structures, complementing the work of the Climate Change Committee. We would like to see it playing a similar role: monitoring progress towards biodiversity and natural capital targets; providing policy recommendations (the wording in NEWP is ambiguous on this point); and considering impacts outside the UK. Although of course the conservation of UK natural capital is important, as previously mentioned, UK economic activity also has very significant impacts on natural capital overseas. It is important to research and find equitable ways to reduce these impacts. Within the UK, the conservation of natural capital should be part of what the phrase “sustainable development” is taken to mean within the planning system, and we would like to see the Natural Capital Committee explicitly highlight this aspect of its remit.

What further research and/or evidence is required to develop practical programmes sufficiently detailed to deliver the White Paper’s ambition to fully embed the value of nature into policy delivery?

More research on suitability of Impact Assessments in taking the value of nature into account in policy appraisal

14. We welcome the Government’s commitment in the NEWP to publish new guidance on valuing the natural environment in appraisals. Currently the main mechanism for this is Impact Assessments which are based on Social Cost Benefit Analysis. In order to integrate the value of nature in this process, the impact of policy options on ecosystem services and biodiversity is estimated in monetary terms. Although environmental valuation methods are improving there remain a range of problems and challenges with this approach. For example:

Much hinges on the valuation method used. Different methodologies applied to the same valuation question can lead to different results. Results may be precise in monetary terms but not precise in representing “true” costs or values.

Valuation methods based on “willingness to pay” may lead to valuations lower than are required to ensure sustainability of ecosystem services and biodiversity in the context of environmental limits.

Valuation processes are time-consuming and expensive, and there are significant challenges in taking results from previous studies and applying them to different environmental contexts (ie “benefits transfer”).

Large-scale but uncertain costs and benefits over the long term tend to have much less weight than short-term costs and benefits in the appraisal process. This can lead to a bias against conservation of ecosystem services and biodiversity in decision making.6

15. More research is required not only to improve the capturing of monetary values, but also to develop consensual, multi-criteria, multi-stakeholder valuation processes that capture values that cannot be meaningfully quantified in monetary terms. These include some cultural services, supporting services (such as nutrient cycling) and the intrinsic value of nature. In addition, further research is required to ensure economic models used by the Treasury better take into account effects on, and of, natural resource use and environmental degradation.

WWF-UK’s full response to the Government’s consultation on the Natural Environment White Paper can be accessed here: http://assets.wwf.org.uk/downloads/response_defra_natural_environment_1010.pdf

21 September 2011