Select Committee on Environmental Audit Appendices to the Minutes of Evidence


APPENDIX 4

Memorandum from English Nature


EXECUTIVE SUMMARY

  1.  The main arrangements within the UK for greening government and promoting sustainable development require stronger engagement from the highest level of Government.

  2.  The fundamental requirements for an effective system for environmental accountability and audit in the UK are:

    (i)  All Government departments should produce a sustainable development strategy to integrate environmental considerations into policies and programmes, and prioritise greening operations.

    (ii)  DETR guidance on Policy Appraisal and the Environment should be reviewed to ensure it is consistent with the Green Minister's Biodiversity checklist, to clarify the requirements for the initial screening process and what constitutes a "significant environmental impact", and to confirm the Government's expectation that appraisals should be published.

    (iii)  The roles of the Green Ministers Committee and the DETR Sustainable Development Unit need to be strengthened to give them more influence across Government and better outreach to department's associate bodies and the key economic sectors they sponsor.

    (iv)  Departments and their associate bodies should report to a common standard on the outcome of policy decisions and their impacts on trends measured against the sustainable development indicators in Quality of life counts, and the requirements of Policy Appraisal and the Environment and the Green Ministers' Biodiversity checklist.

    (v)  Overall, we believe there is a strong case for mandatory environmental reporting, with independent scrutiny and verification, for both the public and private sectors.

    (vi)  Public audit bodies should have regard to environmental impacts, as well as conventional financial accounts. The Environmental Audit Committee has been very successful at scrutinising the policies and programmes of Government, produced useful reports and plays an important part in the integration of sustainable development into decision making. We believe the Committee should retain its independence and its functions should not be incorporated with those of the Public Accounts Committee, nor should its support come from the National Audit Office.

    (vii)  Voluntary commitments are a useful lever to promote good practice in both the public and private sector. We believe the fundamental changes in behaviour to achieve progress towards more sustainable development in the private sector require better use of economic instruments and regulation, combined with voluntary commitments where these can be made to work.

1.  INTRODUCTION

  1.1  English Nature submitted written evidence to the Committee's 1997-98 and 1998-99 inquiries on the Greening Government Initiative and the First Annual Report of the Green Ministers Committee 1998-99.[246] Our evidence is included as Annex 3 in the Committee's Fifth Report on the Greening Government Initiative.[247] We welcome this opportunity to make a further submission to the Environmental Audit Worldwide inquiry.

  1.2  Evidence is invited under four headings: overall, plugs, sockets and wiring it up. Our memorandum is structured according to these heading, following a short explanation of the context of English Nature's advice.

2.  ENGLISH NATURE

  2.1  English Nature is the statutory body responsible for advising both central and local government on nature conservation and for promoting the wildlife and natural features of England. In fulfilling its duties English Nature:

    —  advises Ministers on the development and implementation of policies for nature conservation;

    —  advises Ministers on other policies affecting nature conservation;

    —  identifies, notifies and safeguards Sites of Special Scientific Interest (SSSIs);

    —  establishes, maintains and manages National Nature Reserves;

    —  provides guidance and advice on the principles and practice of nature conservation to a wide constituency;

    —  commissions and supports research and other projects relevant to nature conservation.

  2.2  Through the Joint Nature Conservation Committee, English Nature works with sister organisations in Scotland, Wales and Northern Ireland to advise Government on UK and international nature conservation issues.

  2.3  Biodiversity is a key test of sustainable development and, as the Government's statutory advisers on biodiversity, English Nature gives advice to Government and others on the shape and direction of sustainable development policies in England.

  2.4  Green Ministers have agreed that, because biodiversity is a key test of sustainable development, they will promote biodiversity in their policies and programmes and in the management of their department's own estates. To help Green Ministers achieve this aim English Nature and the DETR Biodiversity Policy Unit produced Making biodiversity happen across Government: Green Ministers biodiversity checklist (March 2000). The checklist provides a framework for measuring progress in future annual reports of the Green Ministers Committee.


3.  OVERALL

  3.1  Article 6 of the Treaty of Rome requires environmental protection to be integrated into all Community policies and actions with a view to promoting sustainable development. A better quality of life—a strategy for sustainable development for the UK (May 1999) has a strong focus on indicators and integration. In particular, it seeks better integration of sustainable development in the policies and actions of every Government department, and greater involvement of and action by those outside Government.

  3.2  The Government and others face huge challenges to address the inherent tension between the three strands of sustainable development, and to ensure appropriate decision making on the balance between them in ways which promote integration. The nearest we have seen to this in UK Government departments is the draft DTI Sustainable Development Strategy (January 2000). This draft strategy, as yet unpublished, fits within the framework of A better quality of life, demonstrates a commitment to integrate environmental considerations into policies and programmes, and has priorities for internal greening operations. We suggest that all Government departments should produce similar strategies.

  3.3  We believe the main arrangements within the UK for greening government and promoting sustainable development[248] compare well with those in most other EU member states, with the possible exception of the Nordic countries which have a higher degree of political engagement (eg Finland's Sustainable Development Commission is chaired by the Prime Minister with five other Ministers as members). Sustainable development needs strong political leadership and engagement from the highest level of Government to raise awareness and commit to change towards more sustainable approaches. We see little evidence that the Cabinet Committee ENV has taken on the strategic function and proactive role recommended in the Environmental Audit Committee's 1997-98 Greening Government Initiative inquiry report. The Green Ministers Committee has yet to establish real "bite" across Government or within departments, nor does it have sufficient outreach to their associate bodies and the key economic sectors they sponsor.

  3.4  In our evidence to the Committee's 1998-1999 inquiry on the Greening Government Initiative, we suggested that the role of the DETR Sustainable Development Unit (SDU), and its capacity to influence the full range of Government policies across departments and associate bodies, could be strengthened if it was located within the Cabinet Office rather than the DETR. We work closely with the SDU, and despite its best efforts, we remain concerned that it lacks the necessary power, influence and resources to drive action towards sustainable development within Government and to facilitate action by others.

  3.5  We fully endorse the key actions, commitment and indicators set out in A better quality of life and Quality of life counts—Indicators for a strategy for sustainable development for the UK a baseline assessment (December 1999). We are using both documents to guide our policy development and advocacy at national, regional and local level. The "green housekeeping in government" indicator is weak in its present form and better guidance is required on what is expected of government departments and associate bodies within a framework of common standards and performance measures.

  3.6  The system for greening government policies and programmes has the potential to be very effective at regional level but in our experience has been disappointing. This is largely due to the mismatch in timing between the production of Regional Development Agencies' Strategies, Regional Planning Guidance and their associated sustainability appraisals, and the production of Regional Sustainable Development Frameworks. Reports on the links between the environmental and economy have also lagged behind RDA Strategies, with the exception of An environmental prospectus for South West England—linking the economy and the environment (March 1999). Opportunities for business growth which integrate environmental benefits (eg habitat restoration and recreation) have been slow to progress and much more needs to be done.

4.  PLUGS

  4.1  Annual reporting is essential to ensure that the actions of Government departments are transparent and accountable. The Green Ministers Committee has an important role to identify common reporting standards against specific objectives and targets with associated deadlines, to compare and challenge performance, and chase up laggards. The publication of the Green Ministers First Annual Report and subsequent scrutiny by the Environmental Audit Committee provides a firm base from which to build a monitoring and reporting system on greening government. Departments have set and reported progress against targets and good practice examples are widely used to encourage others to emulate across Government. There is scope to extend the range of targets reported on (eg use of Policy Appraisal and the Environment and the Biodiversity checklist), and to integrate department's reports to the Green Ministers Committee with the annual cycle of reporting by Government against the headline and core set of indicators in Quality of life counts. We believe departments and their associate bodies should report on the outcomes of policy decisions and their impacts on trends measured against the headline and core indicators.

  4.2  Clearer reporting lines are needed from the Green Ministers Committee, through Government departments to associate bodies. Departments' reports should extend to the performance of their outposts in Government Offices for the Regions. They represent the face of Government in the English regions and should play a lead role in demonstrating effective integration to regional and local institutions.

  4.3  Guidance on reporting standards is also very patchy. English Nature receives conflicting messages about what is required in terms of environmental management and subsequent reporting. The DETR guidance on Developing an effective travel plan: Advice for Government departments (January 2000) is a user friendly document and we would welcome similar publications on environmental management systems, environmental reporting and government procurement.

  4.4  The Environment Agency's Annual Environmental Report 1998-99 could be used by the Green Ministers Committee as an example of good practice. The Report was commended at the Association of Certified Chartered Accountants 1999 Environmental Reporting Awards. It has specific performance targets, a framework for environmental accounting and has been independently verified.

5.  SOCKETS

  5.1  The right frameworks appear to be in place for Parliament to judge the Government's efforts to put the environment at the heart of public sector activity but we have concerns about their effectiveness. Lack of common reporting standards for Government departments and their associate bodies makes comparative performance measurement very difficult.

  5.2  The Green Ministers Committee seems to be implementing change at the rate of the slowest Government department and needs to set tougher targets with penalties for those who do not comply. This is imperative given the advances made by the private sector. An increasing number of large companies are well ahead of Government with their environmental programmes and in the way they publish reports on environmental performance.

  5.3  It is important to learn from the "bolt on" experience with sustainability appraisals at regional level. This is being addressed, at a late stage, through the Regional Sustainable Development Frameworks against which implementation of other regional strategies can be assessed.

6.  WIRING IT UP

  6.1  Integrated policy appraisal. DETR guidance on Policy Appraisal and the Environment continues to be applied inconsistently or not at all, and there are few published examples of policy appraisals by departments. We believe the guidance should be reviewed to clarify the scope and content of the initial screening process and what constitutes a "significant environmental impact", and to confirm the Government's expectation that appraisals should be published. As a minimum criteria we would expect policies which have an "adverse and irreversible effect on biodiversity" (particularly where habitat cannot be replaced or re-created elsewhere) to be screened out by environmental policy appraisal. This is consistent with the Green Minister's Biodiversity checklist which needs to be integrated with the policy appraisal guidance.

  6.2  There will also be a need to the "duty of care" for Sites of Special Scientific Interest which the Government is proposing to give to all government departments, public bodies/agencies, local authorities and statutory undertakers under Schedule 9, section 28E(2) of the Countryside and Rights of Way Bill. This gives "a section 28E authority" a duty to "take reasonable steps, consistent with the proper exercise of the authority's functions, to further the conservation and enhancement of the flora etc . . . by reason of which the site is of special scientific interest".

  6.3  We recommend the Committee should review the approach taken with the regional sustainability appraisals when assessing departmental policies, programmes and decisions. The appraisals use the sustainable development indicators in A better quality of life as the criteria for screening the impacts (positive, negative or neutral) of policies. This also acts as a gap analysis to show where further information is required to make an informed decision. Fourteen of the sustainable development indicators apply to biodiversity (see Annex 1) and we would expect new policies to have a neutral or beneficial effect on these indicators.

  6.4  Sustainable Development Commission. The Commission could make an important contribution to monitoring and reporting on progress towards sustainable development. It should fulfill a "watchdog role" to review and monitor the impact of Government's policies on the sustainable development indicators and should challenge departments when annual reports show the indicators are going in the wrong direction. The Commission will need ready access to Ministers, adequate resources and the capacity to build consensus and promote deeper engagements between the Government, associate bodies, the private sector and local communities. Its membership should be broadly based, drawing on the key economic sectors in which strategic change is needed, as well as social and environmental expertise. Its reports should be published and subject to a response from Government within six months of publication. It would also be useful of the DETR SDU and Commission secretariat to provide a "one-stop-shop" information service for the Greening Government Initiative (eg in a similar way to the Environmental Technology Best Practice Programme).

  6.5  Public audit bodies and environmental impacts. Public audit bodies should be charged with assessing environmental impact, as well as conventional financial accounts, to integrate environmental protection and sustainable development into the heart of Government. The Environmental Audit Committee has been very successful at scrutinising the policies and programmes of Government, produced useful reports and plays an important part in the integration of sustainable development in decision making. We believe the Committee should retain its independence and its functions should not be incorporated with those of the National Audit Office.

  6.6  Prudent use of natural resources is an integral part of "economy, efficiency and effectiveness". The Landfill Tax, Climate Change Levy, the new Aggregates Tax and other fiscal measures which provide environmental incentives, particularly in relation to transport policy, are strong "drivers" of better environmental performance and competitiveness in the private sector. Government departments with good environmental management practices will also lower costs and reduce their exposure to environmental risk.

  6.7  We welcome the publication of the UK Round Table's Report Not too difficult!—economic instruments to promote sustainable development within a modernised economy (April 2000). We hope the Green Ministers Committee will help to implement the key recommendations of the report and alleviate concerns that environmental taxes impact on social equity and international competitiveness.

  6.8  Lessons and experience from the private sector. The two main factors influencing the private sector's environmental commitment are size of company and the sector within which it operates. Large companies with resources and in-house expertise have implemented and reported on their environmental management systems for many years and are now moving towards social reporting and sustainability management systems. Those at the forefront tend to be the most heavily regulated industries who have to monitor all of their impacts closely. The utility companies, in particular water, include many examples of environmental reporting good practice and are the most progressive in implementing corporate Biodiversity Action Plans.

  6.9  Voluntary commitments. Voluntary commitments can create step changes in environmental performance and act as a useful leverage tool to promote good practice in both the public and private sector. But it is often time consuming to find common ground and commitments are easily threatened by a change in management or policy of one of the participating organisations. More sustainable development will require fundamental changes in business behaviour and we believe this will only be achieved through better use of economic instruments and regulation, combined with voluntary commitments where these can be made to work. This applies especially to the many SMEs for whom environmental commitments are not even on the agenda.

  6.10  Mandatory environmental reporting. DETR guidance (eg on greenhouse gas emissions) and global guidelines such as the Global Reporting Initiative are encouraging the private sector to adopt common reporting standards. Given the emphasis which the Government is placing on private/public sector partnerships to achieve environmental objectives, the private sector can reasonably expect public bodies to have a similar commitment to report on their environmental performance against comparable standards.

  6.11  It is also important to highlight the move towards independent verification of corporate environmental reports, auditing of processes and data analysis and development of environmental accounts. The Greening Government Initiative should be looking at all three areas if the policies and programmes of Government departments and their associate bodies are to become more transparent and accountable.

  6.12  The drive towards a more coherent and transparent environmental reporting system in the private sector could be reinforced by possible changes in regulation:

    (a)  The Turnbull Committee report on Internal Control (guidance under the Combined Code on Corporate Governance) recommended that companies should be required to "identify, evaluate and manage their significant risks . . . and review regularly reports on effectiveness of the systems of internal control . . . for the purpose of making their statements on internal control in the annual report". This would place management of environmental risks, as well as financial ones, firmly on the corporate agenda.

    (b)  The independent Company Law Review, due to report in 2001, is likely to recommend new legislation to require company directors to disclose environmental, social and ethical performance data in annual reports.

  6.13  Overall, we believe there is a strong case for mandatory environmental reporting for both the public and private sectors. The core requirement should be all public bodies and private sector organisations to report against relevant headline and core indicators in Quality of life counts. This was one of the conclusions from DETR's seminar on a monitoring and reporting system for sustainable development (Birmingham, January 2000), and would be consistent with what the Government and other stakeholders increasingly expect from business. Any such requirement would not preclude reports against more detailed indicators, specifically tailored to the character and needs of their business or area, but wherever possible these should be fully integrated with and capable of analysis and reporting within the framework provided by Quality of life counts.

  6.14  The Local Government Bill provides a certain opportunity to give local authorities a duty to report on their performance against sustainable development indicators and how they implement their Community (ie Sustainable Development) Strategies.

  6.15  There is increasing competition between private sector companies for awards which accredit good environmental reports and performance (eg the Business in the Environment Index of Corporate Environmental Engagement and Association of Certified Chartered Accountants Environment Reporting Awards). Introducing a "Green Ministers Committee Award" or incorporating environmental performance into existing public service standards (eg Service First and Best Value) could encourage better performance in the public sector.

May 2000


246   Environmental Audit Committee. Inquiry into the First Annual Report of the Green Minister's Committee. Memorandum of Evidence by English Nature, September 1999. Back

247   EAC Fifth Report, The Greening Government Initiative: First Annual Report from the Green Ministers Committee, 14 March 2000, HC 341. Back

248   Cabinet Committee ENV, Green Ministers Committee, Sustainable Development Unit, policy appraisal, A better quality of life, Quality of life counts, the UK Round Table and Government Panel (to be replaced in June 2000 by the Sustainable Development Commission), and the EAC. Back


 
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