An Environment Strategy for Northern Ireland

Transcription

1 An Environment Strategy for Northern Ireland Comments by Northern Ireland Environment Link 4 May 2011 Northern Ireland Environment Link (NIEL) is the networking and forum body for nonstatutory organisations concerned with the environment of Northern Ireland. Its 55 Full Members represent over 90,000 individuals, 262 subsidiary groups, have an annual turnover of 70 million and manage over 314,000 acres of land. Members are involved in environmental issues of all types and at all levels from the local community to the global environment. NIEL brings together a wide range of knowledge, experience and expertise which can be used to help develop policy, practice and implementation across a wide range of environmental fields. These comments are agreed by Members, but some members may be providing independent comments as well. If you would like to discuss these comments further we would be delighted to do so. Prof Sue Christie, Director Northern Ireland Environment Link 89 Loopland Drive Belfast, BT6 9DW P: E: Sue@nienvironmentlink.org W: Northern Ireland Environment Link is a Company limited by guarantee No NI and a Charity registered with Inland Revenue No XR

2 NIEL strongly supports the development of an Environmental Strategy for Northern Ireland. The environment crosses boundaries political, administrative, sectoral and physical and needs to be treated in an integrated fashion across all of these. Having an agreed Environmental Strategy which is adopted by the Assembly and implemented across all Departments, Agencies and political institutions, as well as promoted to all other sectors of society, is essential in delivering good environmental governance and practice. Adopting a long term view is essential when dealing with environmental matters, as is recognising the impacts on the Northern Ireland environment of events, drivers and legislation/policy across the world as well as our impact on global issues. The strategy needs to be both comprehensive and specific, with clear targets which are measurable and time bounded and reporting mechanisms identified to ensure compliance by all parts of government. Government needs to take the lead in developing the strategy, but cannot deliver it without full involvement and commitment by all other sectors; mechanisms to ensure such involvement must be an integral part of the strategy. We support the aim that the strategy intends to provide clear achievements that people recognise and support, and are pleased that it supports the development of performance indicators to demonstrate progress. Such indicators have been sorely lacking in many aspects of environmental quality (especially in biodiversity), and we should pursue a policy of developing these indicators and adhering to them. Question 1: Themes and Aims of Strategy. The three themes of NI Economy, Quality of Life and Resource Efficiency seem reasonable given the Programme for Government s strong emphasis on the economy. As long as the categories are broad enough to allow the inclusion of all major aspects the exact divisions are less important, and these seem to be a fair grouping and the subsets mentioned cover the main issues. These three categories are well chosen to resonate with politicians and the public and reflect priorities in many other government strategies which will help the integrative ability of the environment strategy. However, the major heritage themes (built and natural), ecosystem services and biodiversity are not explicitly mentioned and need to be. Ecosystem services and ecosystem level management involve all aspects of land use, are very important in their own right, and should not be seen as a subsection of biodiversity, which this wording inadvertently implies. We believe that heritage including (but not limited to) biodiversity, habitat conservation, historic environment and ecosystem services should be a theme in itself, in order to recognise the importance of the natural environment in effectively being the base required to deliver all other themes. Whether this is introduced as a fourth Broad Theme or is (probably preferably) an overarching goal/aim of the strategy needs considerable thought. The latter approach makes it clear that environmental protection is fundamental to the delivery of the outputs under the Broad Themes and establishes the basic requirement for a healthy environment if the outputs identified under the themes are to be delivered. WHAT a healthy natural environment capable of delivering many goods and services valued by people with sufficient resilience to continue service delivery in the face of challenges from climate change to food price instability. WHY the three broad outcome oriented themes of Economy, Quality of Life and Resource Efficiency. HOW the mechanisms (levers, cooperation, hierarchy, legislation). WHEN it is vital that this strategy address the issues with regard to the long term consequences of proposed actions. While many strategies purport to be for 20 or more years, this strategy must ensure that the environment is not damaged for 2

3 short term interests with long term consequences and therefore mechanisms must be incorporated to ensure that environmental issues are not over-ruled by short term economic arguments. It must explicitly recognize the benefits and costs of acting to protect the future status of the land; it must actually deliver on the concept of keeping the environment in trust for the next generation. The difficulties of delivering this output cannot be overemphasized, but it must be the fundamental aim of the strategy. Revision of the Biodiversity Strategy is one aspect of adopting the ecosystem approach to land management. The revised Biodiversity Strategy, supported by the Duty for Biodiversity from the Wildlife and Natural Environment Bill, needs to be fully adopted at all levels. The second level of issues of key concern need to be structurally clear; most of these are actually delivery mechanisms, and this should be made clear to help the reader understand how they relate to the Broad Themes. Question 2: Challenges The challenges identified seem to cover most necessary areas. The analysis of the economic challenges, noting the fundamental changes facing all countries and the emphasis on resource efficiency, are particularly welcome, as is the recognition of the need for ecosystem based management. The recognition of the changes facing the government and others who deliver environmental outputs is welcomed as providing a strong base for partnership approaches between government and non-governmental organisations to deliver improved environmental outputs. However, an integrated approach to all three of these themes is the only effective way to address the challenges and the opportunities for identifying specific programmes or activities which address all three areas should be explicitly stated. In the final document a more detailed listing of the issues may be useful, including some specific examples demonstrating how important a high quality environment is to delivering these three outcomes. In particular, we would like to see how the natural environment is actual being improved, in terms of biodiversity protection (for example), which we were committed to ensuring under EU legislation. It is not enough to simply protect the environment so that tourists can visit or people can partake in outdoor pursuits. While these are welcome goals that have very positive implications for human health and our economy, biodiversity protection should be given greater priority for its intrinsic value and ultimate value to providing resilience and ecosystem services as well. Question 3: Other Issues Land use, ecosystem services and biodiversity reach across all three of the categories, and can rightly be viewed as integrating. However, since they are not specifically mentioned there is the danger that they will not be given full weight in the strategy. The way all land is used is fundamental to environmental management and should be a strong theme throughout this document. A strategic approach to land management to enable it to deliver a range of outputs which can address many of the identified themes is required across departments and fully involving land owners. Public awareness, involvement, attitudes and behaviours are crucial to environmental management and delivering improved environmental outcomes. They are also fundamental to political prioritisation of environmental matters. While education of young 3

4 people is extremely important, public information leading to behavioural and attitudinal changes go beyond this and needs specific mention. It is vital to recognise the local impacts of global issues; food, energy and water security and price; peak oil; climate change; social unrest; etc. As details of these issues cannot be foreseen the key concept which must be incorporated into this strategy is resilience; ensuring that Northern Ireland has the necessary inherent ability to withstand unpredicted events. The strategy needs to consider these global aspects and the local impacts. The strategy needs to be explicit that it is a long term strategy for the future of Northern Ireland s environment; years, not 5 years. Decisions and programmes need to be thinking in the long term taking major changes into account. Doing otherwise can result in inappropriate decisions with long term consequences, including unintended and even perverse outcomes. The problems of predicting and costing long term consequences and justifying current spending to avoid them must be explicitly recognised in the strategy. This includes a huge range of consequences, from not successfully halting the introduction of invasive alien species to incurring EU fines for non-compliance. A risk register approach would be useful in this context. The need for increased localism or improved self-sufficiency in energy, food and other commodities should be addressed within the strategy as it has major impacts on land use decisions and indeed all aspects of managing the environment. Question 5: Partnership Opportunities & Question 6: Stakeholder Involvement Partnership within and outside of government is essential for the success of this strategy. Most of the actions will impact upon or be impacted upon by actions or policies of other government Departments or Agencies, local government, businesses and NGOs. Involving all of these other stakeholders in formulating as well as delivering the Strategy is essential. Identification of impacts by and upon other Departments for each area of the Strategy is a vital first step. Another is establishing full dialogue with the voluntary and community sector to help deliver on aspects of the strategy across all of its aims. Given the constraints on the public sector and funding limitations this radical approach to delivery of aspects of this strategy across all themes is required. The NGO sector should not be seen just as a deliverer of cost effective specific projects, but a full partner in devising innovative ways that result in improved environmental outcomes. The vital role that the NGO sector has in interfacing between government and the public (including business) needs to be developed and nurtured if environmental outcomes are not to suffer in economically straightened times. All sectors must identify priorities and work to their strengths in an integrated fashion. Question 7: Business Impact Providing appropriate incentives and sanctions to encourage business to care properly for the environment is essential to the strategy s success. The emphasis on risk-based approaches is understandable and right, but some attention needs to be paid to encouraging and enabling businesses (and others) to know what they should do (to be more resource efficient, environmentally sensitive, etc.) and how to do it. Schemes such as STEM and proactive advice are most useful in this context. Priority for the strategy should be to make it easy and economically beneficial for business (and the public) to behave in an environmentally sound manner through a combination of legislation/regulation, fiscal incentives/sanctions and public information/education. Only 4

5 this three pronged approach will succeed in changing attitudes and behaviours in the major way required. Businesses based in rural areas, especially farms and produce growers, have a vital role in maintaining our distinct rural environment. However, they therefore also have great potential to harm the environment. The importance of maintaining a healthy environment in delivering ecosystem services in a sustainable manner should be emphasised, and new ways of working (with environmental impact) promoted through policy and fiscal drivers (e.g. CAP conditions and grant aid). Question 8: Key Outcomes Clear identification of the results the strategy is designed to achieve is required; SMART targets, monitoring mechanisms, public reporting and defined lines of accountability are all necessary and must be an integral part of the strategy. Layers of targets, with long term as well as interim targets, are required. High level - decreases in Greenhouse Gases, improved resource efficiency, effective protection of high value sites, functional ecosystems providing multiple services, halted biodiversity loss, waterways at good status: Medium level effective control of invasive alien species, increased proportions of waste recycled, habitats designated: Specific targets within each strategic area such as numbers of prosecutions for pollution, biodiversity action plans delivered or students provided with training. However, the danger of proliferation of large numbers of targets must be avoided. The entire area of excessive bureaucracy and reporting taking up the resources which need to be targeted to action must be addressed (across government). The risk based approach needs to be adopted, as does the principle of proportionality, to ensure that partnerships across sectors are able to deliver outcomes and perform efficiently and effectively. Developing the right targets and indicators is essential. A strategy must contain targets; this may make it more difficult to pass in the Assembly, but without targets and a full, agreed implementation plan a strategy is little more than paper. The dangers of this approach have been fully realised with the Sustainable Development Strategy, and the Environment Strategy must not repeat these mistakes. Question 9: Indicators and State of the Environment report This is a good basis for Indicators and the advantages of having something already developed and with some years of data already collected is very useful. There may need to be additional indicators developed and added to future SoE reports as this Strategy evolves. Question 10: Other Comments The emphasis throughout this document is on sustainable economic GROWTH, a concept which has faced much criticism in recent years. The current emphasis on continuously increasing GDP needs to change; Northern Ireland is currently running at a three planet footprint economy and clearly this needs to decrease rather than continually increasing. Economic prosperity needs to be decoupled from GDP growth (see for example work by Tim Jackson for the SDC on Prosperity without Growth; work by the New Economics Foundation). Economic prosperity can improve a lower proportion of the population can be in poverty or the Index of Economic Welfare can increase for instance. There are many opportunities for development of social capital and alternative schemes 5

6 such as LETS, Time Banks or Work Credits which can help to improve the economic wellbeing of society without being linked to unsustainable and increasing levels of consumption. This strategy should begin discussions on these major changes in emphasis which are required both in Northern Ireland and globally (it can only start the discussions, but the issues need to begin to be given increased credibility). Attached are the notes from the NIEL/NIEA conference which explored many aspects of the proposed strategy on 7 March which might be of further use in your deliberations on taking this strategy forwards. 6