EEF Response to Taking It On - Revising UK Sustainable Development Strategy

Question 1 - What do you think of our approach to the content and structure of the new strategy?  

EEF is supportive that the UK Sustainable Development strategy should be reviewed but it is difficult to see within the consultation document how this strategy will differ and move forward from the original document.     It is extremely important that clear focus and outcomes are demonstrated in the strategy. Stakeholders are still extremely perplexed in terms of what sustainable development means for them and keen to know the benefits.    Government needs to ‘walk the talk’ in terms of sustainable development. Stakeholders will be unwilling to further commit to a revised strategy if they feel government is not playing their part in the full SD agenda. Government comments within the consultation document that they are already doing a lot but the revised strategy needs to demonstrate how they aim to build on this work.    

Question 2 – Is an explanation of what sustainable development means based on the UK Governments four objectives approach of the 1999 strategy useful? 

Defining the term ‘sustainable development’ within the strategy is vital. However, the definition needs to be clear and concise otherwise it runs the risk of becoming meaningless. Relating these definitions and objectives to real life examples is important for stakeholders as it aids understanding of where SD fits into their particular niche of life.  

Question 3 – What should be our vision of sustainable development for the UK? To demonstrate a vision on sustainable development for the UK people need to understand the benefits and consequences of their actions. SD is the way in which our economies will grow in the years to come. There are already some key drivers for sustainable development emerging and the aim should be to build on these in the future:

Supply chain - environmental performance standards are being driven through the business supply chain
Society driving change - People are better educated and have greater access to information than ever before - business is adapting to serve these new needs.
Rise of the stakeholder - For many companies this sort of dialogue is nothing new, businesses large and small alike, form the fabric of the local community. 
Effective management of risks - In order to run a company with a sustainable future we need to continually improve our ability to manage risks.
Access to capital - Companies with a sustainable agenda are likely to be more attractive to investors.  

Question 4 – What should be the guiding principles of UK decision makers, and how can they be made widely practical and relevant both within and beyond government? 

The guiding principle should be to make the strategy as practical and realistic as possible. Industry will not be keen to endorse a strategy that contains objectives and targets that are unachievable.   

Question 6 – Are the four priority areas identified above the right ones for the UK as a whole to focus on over the next few years? 

Yes – the four priority areas take a holistic approach to the environment as a whole and the interrelationship between the economic, social and environmental aspects. 

Question 9 – How can more people and organisations be encouraged to consider the impacts of climate change of their activities, and to respond to them?

What are the opportunities and barriers, to progress? Businesses must be encouraged that to ignore climate change is also to ignore a dynamic market of the future that is already taking shapes. Trade for the future will be in products and services that create less carbon emissions and other green house gasses. Initiatives from the government such as the Enhanced Capital Allowances (ECA) Scheme act as an incentive to companies to produce more efficient products and also to customers investing in new equipment.    

Question 10 – What opportunities are there for making sure that considering the impacts of climate change are an essential part of policy and decision making as part of the drive for sustainable development? 

The UK has already pledged it commitment to combating climate change and placed climate change at the centre of policy and decision making. For example the UK is standing by its commitment to the Kyoto Protocol and as part of achieving this has introduced a Climate Change Levy on business. Further measures being introduced include an EU Emissions Trading Scheme.   

It is the EEF opinion that climate change is already an essential part of policy and decision making within the UK. However at present it seems that the main thrust of this policy making is aimed a UK business. If the government truly want their sustainable development strategy to take a holistic approach they need to encompass other areas of society into their policy and decision making on climate change. Other areas of society such as transport which arguably have the biggest potential impact on climate change have not been targeted by government as severely as business.  Sustainable consumption, production, and use of natural resources

Question 11  - What steps do you think government, business, and others should be taking to promote a more innovative, competitive, resource-efficient, low-waste, economy whilst also improving our environmental performance?

Business organisations such as EEF have a positive role to play as catalysts in the process of supporting and enabling businesses to deliver sustainable development. However, government needs to make the right resources of help available to business. Our experience is that businesses with the manufacturing sector are keen to participate and become more sustainable.  UK industry is extremely innovative and in today’s market businesses are continually striving to cut costs and become more competitive. However, at present industry is seeing the introduction on a plethora of new legislation relating to producer responsibility and waste. Implementation of new regulations has often been managed by government departments in isolation, with little evidence of an overall strategic view of how the UK needs to change to meet the totality of the new requirements. Government needs to ensure that there are no clashes of priority when new regulations are being introduced. 

Question 12 - What steps do you think need be taken by government, business, and others over the short and long-term to help businesses make more sustainable products (ones that have reduced environmental and social impacts)?

Government has taken significant steps in an effort to force business to be more sustainable regarding the products they manufacture. We are in the process of seeing the implementation of the ELV Directive, the WEEE Directive and Energy Using Products Directive, plus the EU has a proposal for Integrated Product Policy in the pipe-line. These new pieces of legislation are encouraging the proactive businesses to look at the way they produce their products. However, for those businesses that choose to take a ‘business as usual approach’ the price of compliance will be higher. There is a lack of overall design to delivery strategy for these policies and it is important that government integrate and co-ordinate these activities. We are seeing significant problems develop from the lack of strategy in ensuring alternative routes for waste disposal following the reduction in access to landfill for hazardous waste at a time when the scope of the classification for such waste has been broadened.

Question 13 - What steps do you think need to be taken by government, business and others over the short and long-term to help business and household consumers choose more sustainable goods and services?

Making the wider public more aware that they have a choice in terms of the goods they buy. There is a common opinion that ‘environmentally friendly’ or ‘Fair Trade’ goods are always more expensive. In the past this has sometimes been true but publicity of Fair Trade and the eco-labelling of products have made the consumer more aware of the ethical and environmental impacts of products.  More awareness raising programmes need to be carried out to allow the consumer (both business and household) to make an informed choice when buying goods or services.  Many organisations including government, have introduced a green procurement programme into their business, this is something that should be further encouraged by government. The business benefits of this should be espoused e.g. returnable containers mean no waste and therefore cost saving.

Question 14 - What areas of consumption do you think need to be tackled first? Why? What actions need to be taken by whom?

Consumption of natural resources is an issue that should be a primary focus for the government. Clearly at the current rate of consumption the use of resources is unsustainable and business will play its part in reversing this trend by using resources, including water and energy more efficiently.  It is essential that the business benefits of this are made apparent as not only is this good for the natural environment but it also reduces costs.Government has already funded programmes such as Envirowise and WRAP who have carried out a lot of work with industry looking at resource efficiency but more effort and funding from government needs to be focused into this area. 

Question 20  - How is the UK likely to be most successful in achieving the behaviour changes that will be needed if we are to move toward long-term sustainability, and what would be the right balance of measures by government and others? 

Behavioural changes are unpredictable and will take time to filter through the population. However, over the past decade people have become more environmentally aware, for example kerbside recycling schemes are being normal practice within some households but build on this and achieve long-term sustainability, the concept of sustainable development should be introduced into everyday life, for example schools, colleges and universities should be incorporating sustainable development into their curriculums. School leavers and graduates will then carry these changes through to their home and working lives.   In order to achieve this government needs to put SD onto the agenda within every government department.  

Question 22 -  What are the top international and EU priorities for sustainable development that should be dealt with in the new sustainable development strategy? 

To ensure that rigorous and realistic regulatory impact assessments for all EU legislation are carried out to include EP amendments and sunset clauses. It should be ensured that the introduction of new legislation does not constrain EU business unfairly. Otherwise their ability to innovate into new sustainable technologies may be hampered. 

Question 27 -  What do you see holding back effective action by Government? 

A lack of joined up thinking seems to be a common problem across government on a wide range of issues. To deliver an effective SD strategy all government departments need to make a commitment and lead by example.  The business contribution to sustainable development 

Question 36 -  What more needs to be done to improve the business contribution to delivering sustainable development? 

Businesses are naturally adaptive and are already making a significant contribution to the governments SD agenda. It is important that this is recognised and business is encouraged to build upon this success. To encourage further business contribution dissemination of good practice is a way to get the attention of businesses who are not actively participating in the SD agenda. It is essential that businesses that are continuing to operate in an unsustainable manner ask themselves how long they can survive in a landscape that is more and more influenced by sustainability drivers. 

Question 37- What actions should we take to support, enable or require a higher level of business contribution? 

It is essential that business is provided with the right support from government to enable them to actively contribute to UK sustainability agenda. The government SD pioneers group was an excellent example of how support from government can actively deliver results. Unfortunately this group seems to have lost momentum and the government seems keen to decrease its active participation at a time when they are reviewing their own SD strategy. Sector Associations such as EEF can play a key role acting as the link between the government and business in dissemination of information and delivering this strategy. However, in an era where businesses is having to comply with what seems like a never ending stream new legislation, placing a requirement on business to participate in the government SD Strategy would only serve to alienate the business community.   

Question 39 -  What needs to be monitored and measured UK-wide? 

The current UK indicators capture all necessary information.   

Question 40 -  Who are the audiences for indicators and how could we better meet their needs? 

The audience for these indicators should be all stakeholders with a vested interest in sustainable development. 

Question 41 -  Should any set of indicators supporting the new strategyconcentrate on just the main priorities in the strategic framework; or be wider and more comprehensive?

The indicators should concentrate on the main priorities of the strategy. They should not be too onerous and prescriptive – this will make the process of reporting complicated and off putting for all those involved.  

 42 Should important high-level sustainable development indicators focus on monitoring general progress towards final outcomes; specific delivery actions and targets;