BIAC contribution to the strategic discussion on the. OECD programme of work

Transcription

1 BIAC contribution to the strategic discussion on the OECD programme of work EPOC meeting, October 2013 In 2012, world leaders, the private sector and other stakeholders came together in Rio de Janeiro to mark the 20 th anniversary of the 1992 United Nations Conference on Environment and Development, calling among others, for practical measures for implementing sustainable development and green economy policies. Importantly, the conference highlighted the crucial role of voluntary commitments and partnerships to advance sustainable development. The OECD Environment Policy Committee, which plays a key role by monitoring and reporting evolving environmental trends and providing fact-based policy recommendations, can make a major contribution to driving international action on sustainable development and green growth as well as to specific areas, such as climate change, biodiversity, resource efficiency and chemicals. Focusing on OECD s unique added value As an economic and multi-disciplinary organisation that has committed itself to the horizontal integration of sustainable development and green growth considerations across numerous areas of its work, the OECD can make an important contribution to global policy discussions on environment. Among others, the OECD plays a key role in monitoring and analysing evolving trends, providing factbased policy recommendations based on objective research, and fostering the necessary synergies in research and policy-making. In designing its future programme of work, BIAC recommends to keep the following over-arching considerations in mind: Prioritise activities and focus on those where the OECD has a clear added value by building on its economic strength and fact-based analysis to help countries identify and implement policies that are both economically efficient and environmentally as well as socially effective. Benefit from its multi-disciplinary nature and work towards true policy integration to ensure that environmental policies are not considered in isolation but how they interact with other policy objectives. Business and Industry Advisory Committee to the OECD Tel. +33 (0) /15 Chaussée de la Muette Fax +33 (0) Paris biac@biac.org France

2 Further broaden cooperation with non-member countries and consider how global environmental and natural resource challenges can best be addressed in cooperation between OECD and non-oecd countries, taking into account competitiveness and other impacts in a global environment. Recognise the importance of close cooperation with business as an important provider of solutions and identify opportunities for partnerships and for making concrete contributions. Key business messages Recognising the importance of moving from word to action, business should be considered as an essential partner and provider of solutions. As such, business would like to make a constructive contribution to environmental policy discussions. While in no way an exhaustive list, BIAC would like to highlight the following key messages: Getting the policies right for the necessary investments to come forward: Transformational change will require large-scale private sector engagement. To enable a successful transformation of scale, a long-term, transparent and predictable policy framework must be in place to allow business to make the long-lived and often capital-intensive investments that are required. Fostering innovation and technology development and deployment: Public policies should create the right market conditions to trigger innovation at the required scale, including through stable market frameworks, encouraging research cooperation, fostering the right skills and ensuring effective intellectual property protection. At the same time, open markets are indispensable for the diffusion and deployment of technologies. Emphasising resource efficiency and life-cycle thinking: There is a need for integrated policy approaches that work across a range of resource stocks and materials and recognise the full lifecycle impacts as well as the important role of value chains. Encouraging global discussion and partnerships: The greening of growth needs to be an attractive objective to both developed and developing countries, recognising that there are common but differentiated realities in different parts of the world. Policies and targets need to be achievable, taking into account national circumstances and priorities. Capacity building and close dialogue with non-member countries is crucial. Fostering integrated approaches: Overall policy coherence and close cooperation among Ministries is essential. The OECD as a multi-disciplinary organisation with excellent expertise in areas such as economics, environment, trade, investment, education, and competition, can make a significant contribution. At the same time, environmental policies should be considered as they relate to other global challenges, such as energy access, food, land use, and water challenges. Ensuring symmetry and equal treatment in the application of policies, rules and regulations for the private sector, state-owned enterprises and municipal operations. 2 P a g e

3 Overall direction of the programme of work Taking into account the above-mentioned overarching key business messages and the need to focus on the clear added value the OECD can provide, we strongly support the recommendation in the future programme of work to consider the realities of fiscally difficult times and advancing policy proposals that represent good value for money, are supportive of economic growth and contribute to social priorities at the same time that they advance environmental performance. This clearly underlines the importance of smarter regulation and minimising administrative burdens and should guide future work going forward. We are also interested in further work on better understanding the drivers of business behaviour as economies emerge from the crisis, building on previous OECD analysis in this area. To facilitate better informed policy choices, cost-benefit analysis of different policy options is key before introducing environmental policies. In addition, ex-ante policy analysis can provide additional information on the actual effectiveness of policies. It can thus provide valuable information both for reviewing existing policies and when the introduction of new policies is being considered. We would therefore support further work aimed at identifying best practices in this area. One specific issue mentioned in the first part of the paper against which BIAC would caution is the recommendation to design environmental policies so as to raise fiscal revenues. Such revenues should primarily be used to protect the environment. This recognises that to the extent that such instruments are successful at discouraging environmentally undesirable behaviour, their revenue collection will invariably decline. Thus, they are an inherently unreliable revenue source. Business involvement in on-going OECD activities BIAC is actively involved in the activities below and recommends that they remain high on EPOC s agenda as the future programme of work is being discussed: Green Growth: BIAC welcomed the OECD Green Growth Strategy, which provides concrete recommendations and measurement tools and proposes a flexible policy framework that can be tailored to different country circumstances and stages of development. BIAC has underlined that green growth policies should aim to support economic growth and foster innovation and entrepreneurship across sectors, taking into account life-cycle approaches and the importance of cost-effective policies, which ensure the continued competitiveness of all businesses, including SMEs. We appreciate continued efforts to foster close cooperation among OECD Directorates and look forward to making a constructive contribution to the discussions at the Global Forum in December. The OECD project on nanotechnology and tires, which was initiated by business, highlights a very concrete contribution to the green growth project. Climate Change: BIAC welcomes OECD s analytical contribution to international climate change discussions and supports the activities of the OECD/IEA expert group. BIAC encourages the OECD to focus among others on how to finance actions to limit, mitigate and adapt to climate change, which will depend to a large extent on the investment environment, and continue to provide fact-based analysis of the economic effectiveness and environmental efficiency of various policy 3 P a g e

4 options and the design of market mechanisms. We call upon policy makers to support publicprivate partnerships, collaborative arrangements and voluntary initiatives to address mitigation and adaptation challenges and to foster technology development and diffusion. Water: Water is a fundamental driver and foundation of sustainable development, yet nearly half of the world's population are inadequately served with water and sanitation services, 80% of wastewater is returned to natural environment without treatment and many aquifers and surface water sources are overexploited. Further work is necessary to overcome data gaps and generate evidence that shows the level of avoided costs and true benefits of water management across the whole of society. Through its Horizontal Water Programme, the OECD is uniquely placed to contribute sound whole-economy analysis and policy advice, stressing the benefits of strategic financial planning for sustainable cost recovery, thus encouraging more private investment, the benefits of better governance, and the importance of boosting access to water and sanitation services which are reliable, predictable and sustainable. An increased focus on controlling the management of man-made water pollution is also essential and should be considered in relation to the OECD s planned work on the economics and governance of urban water management. Biodiversity: A coordinated whole-of-government approach that spans across sectors and value creation chains is required to promote the conservation and sustainable use of biodiversity. This approach should consist of policies that take into account a range of different challenges, including environmental, energy security, renewable feedstock, agriculture, and water challenges. Therefore, policies should be based on sound analysis of environmental as well as socio-economic impacts. Equally important is ensuring policy cohesion across borders, since, activities in one country might affect the biodiversity of another. OECD can play a key role in this respect, by providing guidance to policymakers and facilitating global discussions. Resource Productivity and Waste Management: The OECD has made a major contribution to addressing resource efficiency, by promoting sustainable use of materials in order to reduce the negative environmental impacts of particular material flows. We support further work to ensure a comprehensive, global movement towards resource efficiency. This requires further emphasis on the overall policy framework that needs to be in place for resource efficiency, including in the areas of innovation, environment, trade and investment; sharing of global data and information systems on the state of the natural world and utilisation of such data in strategic planning. We also support the exchange of best practices and indicators for resource efficiency. Mechanisms and platforms for discussion need to be utilised for all stakeholders to realise opportunities and overcome existing governance gaps. Chemicals, Pesticides, Biotechnology and Nanotechnology: BIAC is closely involved with OECD work on chemicals, pesticides, biotechnology and nanotechnology and underlines the need to recognise the benefits they can provide in the pursuit of green growth. We offer our strong support for the technical work of the EHS programme, which contributes to burden-sharing, reducing barriers to trade, optimising the use of resources, and saving time and money for governments and industry through cooperative working on chemicals, pesticides, biotechnology and nanomaterials. BIAC sees a unique and continuing role for OECD in promoting mutual 4 P a g e

5 acceptance of data and international harmonisation, while at the same time taking on a leadership role in on-going discussions on global chemicals management. BIAC looks forward to continuing its active contribution at all levels of the OECD EHS programme and assisting the OECD and its members in bringing these programmes forward. Initial specific comments on selected proposals in the programme of work Scoping paper on spatial planning (Annex 1) The work could benefit from looking at the opportunities presented by the new technologies of Remote Sensing and Geographical Information systems. It would also be helpful to further analyse the linkages between urban morphology, geographical features and the effectiveness of critical infrastructure (particularly networked infrastructure, such as water supply, sewers electricity grids transport networks, etc.). It would also be useful to further develop the understanding of the interrelationship between urban and peri-urban zones and the hinterlands that serve these areas. Under paragraph 7, 1st bullet, it would be useful to add flooding and flood risk to the list. Cities and the environment (Annex 2) BIAC agrees that green growth considerations should be incorporated in urban planning. In light of the challenges of building green urban infrastructure in the context of severe budget constraints facing governments, it is essential to investigate and foster the role business can play in large infrastructure projects. This underlines the importance of ensuring that the right incentives are in place to encourage long-term private investment. Business can make a significant contribution in a wide range of areas, including, with regard to integrated energy supply systems, construction and refurbishing buildings, water, waste management, and transportation. Due attention should be given to the role of the ICT industry in providing information technology platforms and smart city IT infrastructure. After the third bullet concerning water resources, it would be helpful to add another bullet point on the effects of wastewater and urban run-off on the downstream environment. We strongly support the suggested focus on water policies for future cities (last bullet on page 5) and reiterate the point made above in the context of spatial planning about linking the urban environment with the hinterland, which is raised in paragraphs 18 and 19. Oceans and the marine environment (Annex 3) The paper should further emphasise the effects of land-based water pollution on the ocean environment thus sending a strong signal to upstream policymakers. Further emphasis should also be put on solid waste pollution, recognising that solid waste materials entering the oceans via rivers constitute a significant source of pollution. In a similar way, the problems related to still sanitation due to bad land management and farming practices need to be addressed. There should also be some reference to desalination of seawater or estuarial water as a growing source of freshwater supplies. 5 P a g e

6 The first line of the last bullet point on page 3, urban should be added between agricultural and industrial. We would support proposed future work in particular as described in paragraphs 25 and the 2 nd and 3 rd bullet points of paragraph 27. Soils (Annex 4) As mentioned in the scoping paper, soil, in addition to all the other media such as water, sunlight and plant nutrients, is a crucial necessity, and to a large extent still the foundation for sustainable productive agriculture. In line with the quotes of Franklin D. Roosevelt and Charles E. Kellogg, the Law of the Minimum developed by Carl Sprengel and Justus von Liebig (1828) describes the interdependence of all factors influencing agriculture and soil quality, in its challenge to sustainably provide enough and high quality food to a growing world population. Where the scoping paper rightfully attributes a lot of importance to the carbon and organic content of soils, we also believe, to achieve the objective of satisfactory food security and nutrition, due attention is deserved by the other aspects of the earlier mentioned Law, such as: - Balanced plant nutrition and avoidance of plant nutrient mining of all primary nutrient N, P and/or K, - Correct choice of plant nutrients and farming practices, pursuing optimal nutrient use efficiency in a sustainable manner. The scoping paper rightfully focusses on carbon in soils as it has a strong supplementary function for plant growth and retention potentials. However, carbon is equally important to the primary need of sufficient nutrients in soil, as an agricultural productive asset. Again also here, the Law of the Minimum applies. Mineral plant nutrients are nevertheless a prerequisite stimulus, at the origin of organic soil supplements through root formation and litter and carbon sequestration through biomass, thus contributing to the organic and biological quality of soils in addition to a productive benefit. With mineral plant nutrients in mind, ever since their invention at the beginning of the 20th century, the knowledge of balanced and precision fertilization has grown tremendously and has faced the challenge of feeding 50% of the ever growing world population. And precisely this relentless, exponential growth and challenge has necessitated further development of plant nutritive products to assist in managing and mitigating the problems arising with more densely populated but limited habitats and soils. Mineral fertilizers can assist in solving these issues such as climate change, water scarcity and land use change through : - The right choice of nutrients - The right application of agricultural practices pursuing optimal nutrient use efficiency. The right balance between all above mentioned factors will indeed make global soils as our most important legacy and asset. 6 P a g e

7 Joint Work with the Chemicals Committee BIAC would like to bring to the attention of EPOC, at an early stage, the investments and developments being made by the pesticide industry in Green Chemistry and areas which could result in the stimulation of the bio-economy. The emerging technologies are the result of research into natural biological processes and would appear to fit under the umbrella of Green Technology. Industry would welcome the support of EPOC in ensuring that, in terms of the harmonisation of regulatory and testing requirements, sufficient support is made available at OECD for the introduction of this new type of product. Industry believes it would be appropriate for EPOC to include these developments in its work plan as the first steps to granting approvals are being made by some OECD member states. Environmental implications of shale gas and hydraulic fracturing We caution the Secretariat that, while hydraulic fracturing is a high profile issue, the number of national, international, and stakeholder initiatives in this field translates to a multitude of existing effective fora. Adding value in this arena requires a strong commitment backed by the resources to thoroughly and objectively investigate issues of emerging science, technology, regulation, social, economic and environmental issues. We would question what specific added value OECD work would currently provide. Extensive analysis of hydraulic fracturing would in our view be more appropriately housed within the IEA. Beyond the Golden Rules effort, in September, the IEA and a consortium of energy companies debuted the IEA gas and oil technology network, which will highlight a number of evolving technological and regulatory considerations designed to address many of the concerns the OECD s Environment Directorate has highlighted. Many OECD member governments, including the U.S., Canada, Australia, and various countries within the European Union, have comprehensive efforts underway to evaluate the many potential environmental implications and corresponding risk management programmes related to hydraulic fracturing within the context of their own national circumstances. Furthermore, many of the questions which the OECD indicates a potential to investigate are hard core scientific issues still under discussion by experts in collaborative efforts by industry, various national governments, and some well-placed NGOs. Definitive information is not yet available at this time. One idea discussed has been that at the cooperative chemical assessment meetings (CoCAM), an attempt could be made to elaborate and disseminate conclusions on hazards of chemicals used in hydraulic fracturing. In view of on-going efforts in the U.S. and other countries which are conducting comprehensive assessments of hydraulic fracturing and the chemicals used in those operations, BIAC would not support further work by CoCAM in this area. Similarly, we believe it would be premature for the OECD to initiate work to characterise hydraulic fracturing fluid chemical exposure scenarios. Before any potential future effort to develop exposure scenarios, it would be important to gather information on and thoroughly understand models and studies that are in progress around the world. With regard to the OECD Clearspace forum for 7 P a g e

8 chemicals used in hydraulic fracturing, BIAC has underlined that information to be included should be fact-based and objective and be carefully reviewed for its quality prior to posting. ICT and environment We are generally interested in scoping work on increasing our understanding of how the internet economy might change environmental footprints, as suggested in the programme of work, recognising that the deployment of smart systems increases efficiency of production and of consumption in transportation, energy and manufacturing sectors and that ICT generally can help reduce global emissions via reduction of consumption in materials and energy. 8 P a g e