Royal Commission on Environmental Pollution

RESPONSE BY THE ROYAL COMMISSION ON ENVIRONMENTAL POLLUTION TO THE CONSULTATION PAPER PUBLISHED IN NOVEMBER 1998 BY THE DEPARTMENT OF THE ENVIRONMENT, TRANSPORT AND THE REGIONS

1.       The Royal Commission on Environmental Pollution strongly supports the government's intention to monitor progress towards the goal of sustainable development by identifying and publishing statistical indicators. It endorses the proposal to select a smaller set of 'headline indicators' which together represent the different facets of sustainable development. It sees the main value of such headline indicators as promoting public awareness, and public discussion, of sustainability, and in some cases giving businesses and individuals a clearer understanding of the contributions they can make.

2.       While headline indicators of sustainable development may also be useful in helping to inform policy decisions, it would be unwise to place too much weight in decision-making on a particular set of indicators, at least until its validity and robustness have been established in the light of experience.

3.       For example, focusing resources on improving populations of wild birds, still more particular kinds of wild bird, might lead to neglect of projects directed towards improving populations of plants, small mammals or other bird species. Moreover, because statistical indicators direct attention to what is quantifiable, there is a risk that important but less easily quantifiable things might be overlooked when funding or policy decisions are made.

4.       If the set of headline indicators is to be effective in serving its primary purpose, people must be able to see clearly how the individual indicators are linked to sustainability. Achieving sustainable development will involve changes in present practices and some aspects of present lifestyles. Whether or not headline indicators relate to something which is directly affected by the actions of individuals or individual businesses, they ought to be of such a kind that they can be expected to demonstrate the results over time of the desirable changes in practices and lifestyles. Some of the indicators in this proposed set of headline indicators do not appear to meet these criteria.

5.       In the nature of things there are linkages, which are sometimes complex, between the various indicators. While an attempt was made to portray these linkages in chart 1 of the consultation paper, that was admittedly an incomplete representation, and does not seem helpful as an aid to understanding.

6.       Achieving sustainable development involves resolving conflicts between competing considerations. More emphasis should be put on the likelihood that, as with economic indicators, indicators of sustainability will sometimes turn out to be in conflict with each other.

7.       Sustainability entails both equity between generations and equity within generations. As the government's consultation paper on the strategy for sustainable development, Opportunities for Change, put it, social progress must recognise the needs of everyone. The Royal Commission is concerned that this dimension of sustainability is not adequately covered in the proposed set of headline indicators. That can be remedied if, rather than simply being in the form of national totals or averages, the indicators for employment, life expectancy, education and training, and housing quality can be modified to incorporate some measure of the scale of the differences between different communities or social groups.

8.       The choice of valid headline indicators is also likely to vary to some degree from area to area because of differences in physical or social circumstances. The Royal Commission is concerned to see that, as an example, some of this proposed set of headline indicators have been criticised as not appropriate to Scottish conditions. If headline indicators are to have their full effect, their use at the UK level must be accompanied by the introduction of sets of headline indicators at country, regional and local levels.

9.       On more specific aspects of the present proposals, the Royal Commission offers the following comments:

• prudent use of natural resources is only partially covered by the proposed indicator for waste and waste disposal;
• although targets for the proportion of new homes built on previously developed land are very important as policy instruments, it would be preferable to include in the set of headline indicators a more direct measure of the extent to which the countryside is being safeguarded against development or degradation. This might be the rate of loss of green-field land to all forms of development. If on the other hand that approach is not adopted, the indicator for re-use of previously developed land ought to relate to re-use of brown-field sites within established urban envelopes, and exclude open land in rural areas which is classified as previously developed;
• there is a strong case for adding an indicator of the quality of coastlines and beaches;
• although it is not easy to construct a suitable indicator, a major omission from this proposed set of headline indicators is the quality of the sub-surface environment. The condition of soil and groundwater provides vital evidence about long-term deterioration of the environment.

10.       The time origin of the indicators presented in the consultation paper varies considerably. It does not appear that the choice of starting-date has been dictated purely by the availability of data. As sustainability is concerned with long-term trends, the longer the time series published for an indicator, the more informative it becomes. Wherever possible, the starting-date for an indicator should be 1950, or at the latest 1970.

11.       Lastly, circumstances will change with the passage of time, The set of headline indicators eventually defined should be reviewed regularly in order to ensure that the correlations between them and what they were originally meant to represent remain valid.

9 February 1999

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