The Society welcomes the opportunity to comment on this document and the other recent DETR consultation papers on sustainability. Professional chemists, like other concerned citizens, will have a variety of views on many aspects of this wide-ranging strategy. However, the following comments are written from the perspective of the profession of chemistry.

  We agree with the concept and ethos of sustainable development which is not an option but an essential requirement for the continued existence of mankind. We welcome the publication of this strategy document, which we see as an important step in making a start on the journey towards a more sustainable way forward. Our comments are of a general nature, as follows.

  Whilst it is no doubt true that sustainability is an extremely wide-ranging issue embracing all aspects of our lives there is one overriding feature which we believe should be drawn out in a more pointed manner in the strategy. The key to sustainability is being able to bring about some change in our lifestyles. This will only be achieved by encouraging us all to take an interest in our consumption of energy and resources. Whilst this is mentioned in the strategy document its vital importance is not sufficiently emphasised. For example there are several references in the document to "making the polluter pay". We strongly believe that recognition should be given to the fact that the ultimate responsibility for such pollution lies with us all as consumers—it is too easy and convenient to try and see this as someone else's problem. Unless we all accept that responsibility, or at the least recognise it, there will be little incentive for us to reconsider our patterns of consumption.

  Having made this most important of points there are several others which the Society believes warrant more emphasis.

  Most economic drivers at present point towards unsustainable development, with the greater the amount consumed the lower the unit cost. Energy and water pricing both follow this pattern. If this were to be reversed so that small users paid less and large users paid more both social equity and sustainability would be encouraged.

  Advances in chemistry will be needed in order to help bring about step changes in technologies that will be needed in the long term eg in developing greener production and products, in improving the way energy is generated, distributed, stored and used and in developing more energy and resource efficient ways of delivering goods, effects and services. Currently the UK research base is leaning towards the life sciences. We should recognise that investment is also vital in the areas identified above, and it is being pursued overseas.

  We welcome the attempt to begin to use indicators of sustainability. We recognise that these indicators will be subject to continual refinement in the future but applaud the fact that a start has been made.

  Finally it is likely that there will be stops and U-turns ahead on the path to sustainable development, as we review and reappraise decisions made and outcomes achieved along the way. There will also be many and disparate views to take into account. We should use best endeavour to include all stakeholders in the decision processes but must also recognise the need to use the best available expertise to inform the debate. The proposal for a Sustainable Development Commission is welcomed in this regard.

  The Society hopes that these comments will contribute to the Select Committee's deliberations.

BACKGROUND NOTE ON THE ROYAL SOCIETY OF CHEMISTRY

  The Royal Society of Chemistry was formed from a merger of the Chemical Society (founded in 1841) and the Royal, Institute of Chemistry (founded in 1877); it inherited the prestige and responsibilities of its parent bodies. It is both the learned society for chemistry and the professional qualifying body for chemists in the United Kingdom.

  There are about 46,000 members of whom 10,000 are based abroad Professional membership of the Society is an internationally recognised qualification. The Society also administers the examinations for the Mastership in Chemical Analysis (MChemA) which is a statutory requirement for practice as a Public Analyst.

  The Society is one of the world's major chemical publishing houses with a wide range of primary, secondary and tertiary literature, including research journals, abstract and indexes, educational publications and computer-based information services.

  Strong ties are maintained with government both at national and at European Community level. Formal contact with Parliament is maintained through the Society's two Parliamentary advisers and through its Link Scheme, whereby members of the Society are linked with Members of Parliament.

  The Society has 35 local sections in the United Kingdom and the Republic of Ireland and a number of local sections overseas.

INTRODUCTION

  1.  The TCPA welcomes the new strategy. It is a big improvement on the previous one, especially in its emphases on quality of life and policy integration, and the integration of the new indicators with the strategy. But we are disappointed that it retreats from the more creative thinking of the consultation paper Opportunities for Change and reinforces some of the barriers to sustainable development which that document started to tackle.

  2.  For this reason we are particularly disappointed that, contrary to Michael Meacher's clear statement to the Local Government Association, and in contradiction of the document's own insistence on the importance of consultation and consensus, the strategy has been issued as a final document with no opportunity for consultation. The earlier consultation on Opportunities for Change does not take the place of consultation on a draft strategy because, as we and many others pointed out at the time, Opportunities for Change did not include proposals for Government action.

  3.  The following comments respond to those of the questions listed in the Committee's Press Notice 19 on which the TCPA has points to make.

THE BALANCE BETWEEN THE STRANDS OF SUSTAINABLE DEVELOPMENT: ECONOMIC, ENVIRONMENTAL, SOCIAL

  4.  We warmly welcome the considerable emphasis on social dimensions, and the recognition that the distinctive message of sustainable development—reconciling human needs with environmental limits—is both necessary and possible. Sustainable development does not mean sacrificing human wellbeing to environmental protection, but achieving both together. The Prime Minister's forward crystallises this superbly.

  5.  But the strategy's treatment of the economy threatens to undermine and obstruct this. The TCPA has previously argued that it is the type of economic activity that matters; that GDP growth tells us nothing about whether human needs are being met; and that the economy should be treated as a means to provide human wellbeing without eroding the environment rather than an end in itself.

  6.  This was recognised in Opportunities for Change's overarching theme of "proving goods and services which meet people's needs while requiring fewer environmental resources" (emphasis added). This seemed to us an excellent encapsulation of an important part of sustainable development. We are very sorry to see it has been suppressed in A better quality of life, and dismayed to see this sophisticated insight replaced with repeated ritual insistences that the economy must continue to grow, with no attempt to present any evidence or argument why this is necessary or why it will improve human wellbeing.

  7.  We are dismayed also by a kind of schizophrenic doublespeak embedded in the document on this point. For example much of paragraph 3.13 discusses the economy with great insight and sense, for example recognising that "the quality of growth matters . . ." and "there are environmental limits to some economic activities . . ." But then tacked on to the end is a further repetition of the slogan that "we must achieve economic growth . . ." which is not where the argument was leading at all.

  8.  The TCPA is not against economic welfare. Indeed it is precisely because we are passionate about providing people with better living conditions that we are dismayed by the uncritical, unquestioning continued promotion of a development path which has made things worse for many. To achieve the many excellent things in the strategy we need more of the right kinds of economic activity (much of which is not necessarily traded and picked up in GDP), and less of the wrong kinds. Whether the aggregate of all kinds of traded activity increases or decreases simply does not matter.

THE IDENTIFICATION OF BASELINES, PRIORITIES AND TARGETS FOR ACTION

  9.  There are a few very welcome specific "output" targets, such as for increases in renewable electricity generation. We repeat our welcome for the Government's 12.5 per cent greenhouse gas and 20 per cent carbon dioxide reduction targets and our admiration of the role the UK has played in international negotiations.

  10.  However apart from these, this aspect of the strategy is extremely weak—so weak, in fact as to make "strategy" something of a misnomer. The strategy totally lacks quantified "end state" targets based on sustainability principles. (Even the greenhouse targets just mentioned are no more than pragmatic interim steps: climate science and equity between countries suggest a need for the UK to reduce greenhouse emissions by at least 60 per cent and probably nearer 90 per cent.)

  11.  Setting such targets is of course difficult and subject to large uncertainties. However we feel Friends of the Earth's Environmental Space project (despite having only a fraction of the scientific and policy resources of the Government) made a convincing first attempt. We would urge the Government to adopt its targets as an interim measure pending any further work to confirm or refine them.

THE LINKS BETWEEN TARGETS AND INDICATORS

  12.  We welcome the aim of integrating indicators with strategy. But this means that poor indicators risk pushing the strategy in the wrong direction. We have particular concerns over several of the "headline" indicators:

—  We have already argued that GDP is a very poor and misleading proxy for economic welfare, since it ignores both non-traded activity that makes people better off and the fact that large amounts of traded activity—defensive, pollution cleanup etc—do not. If the Government feels it must include an aggregate headline indicator of economic activity (and we have grave doubts whether this is useful at all) we think it should be the Index of Sustainable Economic Welfare (ISEW). DETR statisticians have rightly pointed out that it is highly arbitrary. We would reply that, for use as an implicit measure of economic welfare it is no more arbitrary than GDP and considerably less misleading.

—  Conventional measures of employment and unemployment also tell us nothing about either the level of privation and exclusion which unemployment causes, or how fulfilling or secure the employment is.

—  We criticised the previous proposal for a "public investment" indicator as meaningless because it failed to differentiate between (for example) hospitals, prisons, roads or cycleways and thus lumped good bad ugly together, and as perverse since it put pressure on public agencies to spend on things rather than people. The new measure of all "investment" is even more meaningless because it also includes even more categories of very different significance such as investment in out of town business parks, machine tools and information technology. "Investment" as an aggregate category may have some significance for macroeconomic analysts. It tells us nothing of any interest for sustainability.

—  The TCPA has long argued that the percentage of housing built on greenfield or brownfield sites is a crude, misleading and unhelpful polarisation of what needs to be a much more subtle debate about what sort of housing should be built where to meet human needs and to protect the environment.

  13.  Above all, we regret the absence of any attempt to measure the environmental intensity of quality of life which should be the kind of measure guiding all eco-efficiency work.

THE IDENTIFICATION OF RESPONSIBILITIES WITHIN GOVERNMENT

  14.  The strategy is much better than the previous one on this. However too many of the responsibilities are expressed in terms of outputs such as policy papers to be produced. There are too few deadlines, and almost no commitments to achieve quantified results. Together with the lack of explicit targets for sustainability outcomes this is arguably the stategy's biggest weakness.

DEGREE TO WHICH THE NECESSARY PARTNERS FOR SUSTAINABLE DEVELOPMENT, THAT IS LOCAL AUTHORITIES, BUSINESS AND INDUSTRY AND THE VOLUNTARY SECTOR, AND SIGNED UP TO THE PROCESS OUTLINED IN THE STRATEGY

Local authorities

  15.  The best local authorities have been ahead of central government in commitment to sustainable development since 1992. The current strategy should be seen as central government starting to catch up. The main barrier to more local government action has been central government limiting its funding and powers, and failing to set a national policy framework within which local action is practicable and effective.

  16.  The agenda set out in the Modern Local Government White Paper provides a welcome change. We particularly welcome the promise of more power and funding to councils which show they will use them responsibly, the emphasis on consultation and joined up action, the proposed new duty to promote social, economic and environmental welfare of the area and the proposals for "community planning". It is a pity this has all been developed apparently in isolation from Local Agenda 21, which has been developing tools to do very much the same things since 1992. We would urge the government to "join up" its promotion of joined upness"!

  17.  We are also very sorry to see that, after the Local Government Management Board took an acclaimed pioneering role supporting local government sustainability action over many years, now that this excellent work is finally coming into its own, the LGMB's successor organisation, the Improvement and Development Agency is apparently downgrading its priority.

Business

  18.  Most businesses are continuing to ignore sustainable development, and they are perfectly sensible to do so since the Government has not made sustainability pay in the market. The few exceptions, such as retailers developing high levels of energy efficiency, and some developers establishing niches in inner city regeneration, demonstrate the general rule that the private sector will bring its problem solving energy to bear on sustainability only as and when the economy makes it profitable to do so. Most businesses will continue to use cars as the preferred mode of transport, develop on greenfield sites where possible, use automation to reduce the need for staff, and only bother with the easiest and fastest-payback measures to reduce energy and water consumption and waste until the government changes the context (for example through increasing energy, road and waste taxes) to provide an incentive for less unsustainable approaches. The ball is in the Government's court.

Voluntary sector

  19.  Voluntary organisations have over the years made a huge contribution to setting the sustainable development agenda. The new Government strategy has still not caught up with the sophistication of analysis achieved by environment and development NGOs collectively some years ago, most notably through the Real World coalition. The voluntary sector is also at the forefront of practical action for sustainability through (for example) the community insulation movement, the community recycling and composting networks, Sustrans, Groundwork and Local Exchange and Trading Schemes. Lottery and landfill tax money has given a lot of these a great fillip. After the Millennium, the Government should focus these funding streams more explicitly on sustainability related work.

THE RESEARCH BASE FOR SUSTAINABLE DEVELOPMENT

  20.  We would identify three particular priority areas for research:

—  Much more thorough and detailed knowledge of the functioning of ecological systems at all levels from local to international to inform better setting of environmental outcome targets and thresholds in plans and strategies.

—  Sociological and ethical (rather than economic) research into the nature of human needs and satisfiers, and on what quality of life is, to inform consideration of how human wellbeing (as distinct from growth in goods and services) can be delivered more eco-efficiently.

—  Systems modelling of cities and city-regions to put holistic urban management on a more rigorous basis. The TCPA-sponsored Manchester University Regional Interactive Sustainability Atlas project seeks to make progress on this.

October 1999