Starting to Live Differently

‘STARTING TO LIVE DIFFERENTLY’ CONSULTATION RESPONSE FORM

‘STARTING TO LIVE DIFFERENTLY’

CONSULTATION ON THE REVIEW OF THE SUSTAINABLE DEVELOPMENT SCHEME

RESPONSE FORM

Name / Marc Welsh
Organisation /

Wales Environment Link

Wales Environment Link is a network for voluntary environmental and countryside organisations with an all-Wales remit.
This response is submitted on behalf of the network, and formally endorsed by the following organisations :
·  Coed Cadw The Woodland Trust
·  RSPB Cymru
·  Wildlife Trusts Wales
·  Sustrans Cymru
·  WWF Cymru
·  Council for National Parks
·  Butterfly Conservation
·  Groundwork Wales
·  Council for British Archaeology Wales
·  CPRW
·  Open Spaces Society
·  Ramblers Association
·  The National Trust
·  BTCV Cymru
Further information about Wales Link can be obtained from the office (tel: 01970 611621), or our web site : www.waleslink.org

The National Assembly for Wales intends to publish the responses to this document.

Normally, the name and address (or part of the address) of its author are published along with the response, as this gives credibility to the consultation exercise. If you do not wish to be identified as the author of your response, please state this expressly in writing to us.

PART I: HOW WE PROPOSE TO UPDATE THE SUSTAINABLE DEVELOPMENT SCHEME

1.  Is it right to build upon the principles of the existing, original Scheme?

The original SD Scheme did not clearly identify these principles. We consider explicit identification in the revised Scheme to be a fundamental and necessary step.
There are many components in the current Scheme that could be described as “principles”. For example we would suggest the points in section 4.2 are principles that must underpin the actions of the Assembly.
WEL is strongly of the view that the Revised Scheme should set out clearly what are the principles of Sustainable Development that the Assembly will apply.

2.  Is it right to maintain and extend the distinction between a statement of principles in the Scheme, adopted by the Assembly, and a set of actions to deliver them in an accompanying Action Plan for the Assembly Government?

WEL see some value in the distinction between Part 1 of the Scheme (and its identification of underlying principles, long term targets and goals for governing Wales that belongs to the National Assembly for Wales), and the Action Plan to outline the main priorities of the Welsh Assembly Government in seeking to deliver on these goals. However, in order to fulfill the legal duty under Section 121 of the Government for Wales Act, we feel it must be made explicit that together Part 1 and Part 2 comprise the SD Scheme (see our Annex).
The principles, structure and purpose of the Action Plan should be stated clearly in Part 1 of the Scheme.
We support the view that the revised Scheme must be more focused on actions and outputs, and the Action Plan may be a good way of achieving this; however Part 1 of the Scheme must outline how the Assembly’s partners will be expected to contribute.

3.  Is it right to retain the basic layout of the original Scheme?

Supplementary to our response to the consultation we have attached an Annex that sets out how we suggest future revisions comprehensively restructure the Scheme to further enhance its value as a driver for change. We have attached this as an Annex for conveniance, to enable us to respond to the current consultation, however we would welcome an opportunity to discuss these ideas further.

WEL understands why the Assembly has chosen to retain the basic layout of the original Scheme, but whilst groundbreaking the original Scheme was a first attempt to embed SD into government. With hindsight we feel that there is a fundamental need to consider remaking the Scheme, to include altering the basic layout of the Scheme and ensuring that it is visionary, proactive and for the whole of Wales.
The Scheme has a number of different functions :
1 : to set out the basis on which the Assembly will operate (its principles – the tenets of sustainable development)
2 : to set out the sort of changes, or direction in which the Assembly seeks to take Wales to become more sustainable (the Vision)
3 : to outline how the above will be implemented (the framework within which the Assembly and its partners will work).
WEL has further suggestions on how the Scheme should be structured.
Please see the attached Annex.
Most substantive is the omission of the following in the current Scheme ;
·  objective identification of the extent to which Wales is currently unsustainable,
·  the challenges and changes that are required to enable Wales to become more sustainable,
·  and the global context within which all this activity takes place.

SECTION 1: THE DUTY

Questions

4. Would these changes clarify the relationship between the Scheme, its accompanying Action Plan and indicators, and other key documents?

See Q 2 for views on the Action Plan.
WEL fully endorses the retention of the first part of Section 1.2, confirming the relationship of the SD Scheme as “the over-arching framework for all of the Assembly’s work.”
The relationship between the SD Scheme, WAGs Strategic Agenda, and the Wales Spatial Plan could be clarified here (1.2). Section 1.3 should outline briefly the structure of this overarching framework, namely :
A Scheme that outlines the broad SD aims and aspirations of the Assembly, underpinned by a SD Action Plan for the Government. It is supported by and reflects the Assembly Government’s own strategic plans, with progress measured using a full set of headline and process indicators, reporting periodically on these to both the Assembly Government and National Assembly for Wales. They should respond accordingly, working in partnership with a range of directly sponsored and independent bodies and wider civil society in Wales to ensure that the aims of the Scheme are fulfilled.
The reference to the need for “a change in culture and working practice” should be retained, emphasising that this change is needed within WAG, the NAW, and the ASPBs.
We would suggest that mention of the Gauteng Declaration is better located in the revised section 4; this should also include reference to the EU and UN.
With regard to the indicators (1.3) these should be published as an integral part of the Scheme.

5. Would it be useful, in addition, to illustrate in what respects (in 1.3) our current way of living is unsustainable?

We consider that illustrating how our current way of living is unsustainable to be an excellent way of enhancing the relevance of the Scheme. However we would suggest that this follows on better from the definition / description of Sustainable Development (i.e. It is not part of the Duty).
Our Annex suggests a structure that would help achieve this.

SECTION 2: THE DEFINITION OF SUSTAINABLE DEVELOPMENT

6. Would this change be helpful?

It would be better to say “will use our influence to enable others to do the same.” or “actively promote and ensure that others etc”.

7. Are any other changes or additions needed in order to clarify what is meant by sustainable development?

Whilst helpful and well accepted we suggest that a more applicable, meaningful and usable definition of SD, (as an example that used by WWF - Improving the quality of all human life while living within the carrying capacity of supporting ecosystems) that is easier to apply to the development of policy than the Bruntland Definition but sits comfortably alongside that definition should be developed for the Welsh SD Scheme.
We do not necessarily propose the above as a definitive statement. We do suggest that a definition that can be easily understood and interpreted in a consistent manner with a more explicit sense of purpose is desirable.
Our Annex outlines some further thinking on the use of a ‘definition’ of sustainable development.

SECTION 3: THE VISION OF A SUSTAINABLE WALES

8. Does this renewed vision give a clearer sense of what needs to be done, and of where we are going?

See also our response to question 1.
We are concerned that the proposed new wording fails adequately to cover the key principles needed and that were included in the original Scheme.
The majority of Section 3.2 will be lost inappropriately, since the existing wording reflects concepts not replicated in the new text. We strongly urge the Assembly to retain 3.2 as currently written.
We question the substitute wording of 3.1 and 3.2. ‘Demand on the environment ‘ and ‘transport demands’ need to be more explicit.

SECTION 4: SUPPORTING UK ACTIVITY

9. What input should the Welsh Assembly Government make to the review of the UK strategy, in light of our experience?

This is a separate issue, and should not be included as a supplementary question in the SD Scheme consultation, but form the subject of a separate debate. It would probably be better to include it as part of the Action Plan.
It is clear that, as part of the review of the UK Strategy, it needs to be “devolution proofed”, perhaps more explicitly identifying the roles of devolved institutions and administrations in delivering the commitments of the Strategy. In particular, for Wales to deliver its commitment to SD requires Westminster support, time and facilitation.
The Assembly might consider building on the more rigorous, action orientated UK Strategy, which is also more integrated with a monitoring and reporting regime and explicitly sets out its Guiding Principles in a separate section.

10. Would it be helpful to refer here to the Assembly’s wish to contribute to the success of the EU’s and UN’s strategies for sustainable development?

This heading should be “The UK and International Context”.
WEL believe it to be fundamental that the Scheme should outline how the Assembly envisages it will contribute to UK, EU and wider international commitments and strategies for sustainable development.
The Scheme needs to summarise the nature of the key strategies and commitments. Some of these can only be delivered through international negotiation and action; other international commitments can only be delivered by regional and local institutions. The key overarching commitments are :
·  UK SD Strategy,
·  EU SD Strategy,
·  the 6th EU Environmental Action Plan,
·  WSSD and Gauteng 2002,
·  the Malmo Declaration 2000, Kyoto Protocol 1997,
·  Agenda 21 and Rio Declaration 1992
… the Scheme should set out the Assembly’s intentions with regard to contributing to the above.

SECTION 5: FULFILLING THE DUTY

11. Is any important implication of translating the Assembly’s vision into action missing from this list?

We consider that this list under 5.1 is comprehensive and useful.
The last bullet needs updating.
On the otherhand much of the remaining parts of Section 5 would better sit in the Action Plan
The global context, how the Assembly will reconcile long-term against short-term aims and how the Assembly will address ‘crunch’ issues are missing.
As a whole this section should set out what the Assembly aims to do (to be followed through in the Action Plan), and how it aims to do it. This bit of the Scheme should set out what the accompanying action plans are to be for.

SECTION 5A: Through decision making

12. Are these changes acceptable?

Changes acceptable.
Missing bit – monitoring.
See Annex for an indication of how we would propose this section be structured.

13. Are any clarifications necessary?

Yes: there is a need still to develop the Policy Integration Tool and to ensure it becomes a SD Appraisal Tool.
We also support the consideration of proposals to embed green and local procurement together with clarification of the definition of “Value for Money”, into Assembly and ASPB remits, thus ensuring ASPB’s be issued with targets that define the proportion of their procurement that meets environmental standards, as set by WAG for a suite of goods and services.

SECTION 5B: Through strategic policies which contribute to sustainable development including

14. Is this all-embracing statement sufficient?

WEL agree it is not necessary to list the key policy documents, but the new statement is very unclear. The list should appear as an Annex to the Action Plan.
We are concerned that the reworded pre-amble to 5.3 would lose the fundamental concept of the original wording, namely that the Assembly’s key strategies are underpinned by SD principles and linked together.
The relationship between the Action Plan and the SD Scheme is unclear. Our view is that both should reflect the responsibility of the National Assembly as an institution under Section 121 Govt Wales Act 1998. See Annex for details.
Clearer indications are needed for how policies can be taken forward together in an integrated manner, with integrated delivery mechanisms. This is particularly important for planning, land use, transport, economic development and health.
It would be appropriate therefore, if this statement noted :
·  the Welsh Assembly Government’s commitment to the National Assembly to implement the SD duty as set out in this Scheme, by means of implementing existing government Strategies in an integrated manner for the purpose of delivering a more sustainable pattern of development.
·  The key aims outlined in Part 1 of the Scheme will be delivered through the accompanying Action Plan.
·  WAG will design all future strategies to underpin the implementation of the SD Scheme and Action Plan, integrated with existing Strategies, and will consult to test whether it is achieving this.
·  Specific actions on key policy areas will be covered in the accompanying Action Plan.

SECTION 5C: Through specific policy actions

15. Is this approach acceptable?