Response to the 25 Year Environment Plan Indicator Framework Consultation by the Resource Recovery from Waste Programme.
The 25 year environment plan (25YEP) “sets out our goals for improving the environment within a generation and leaving it in a better state than we found it”. In other words, it aims for a net-improvement of the environment that is proposed to be enshrined in law in the draft Environment Bill. A key commitment to the 25YEP is the development of an indicator framework to monitor environmental change.
The framework adopts a natural capital approach, distinguishing three types of outcomes and goals: reducing pressures on the environment; improving the state of environment assets; and increasing the benefits from environment assets. In total 65 system indicators are proposed, grouped under 15 headline indicators that are linked to key themes of the 25YEP. Indicators will use a traffic light system to clarify whether it is positive/ improving, negative/ deteriorating, or no change/ uncertain.
A critical ability of the indicator framework must be to measure net-environmental gain in line with the core ambition of the 25YEP and proposed Environment Bill to improve the environment. We assessed the likelihood that the proposed set of indicators will pick up on net-benefits and herein respond to consultation question 2 regarding “Potential gaps in the headline indicators and / or system indicators and how to fill those gaps”.
Generally the indicators appear to be open to interpretation and the implementation will determine whether the values that are to be assessed will measure the slowing down of environmental decline, i.e. whether the impact of essentially unsustainable behaviours is decreasing, or if there is an actual reverse of negative trends by adopting sustainable behaviours that contribute to net-environmental gains. Taking waste management as an example, then the increased recycling of materials at end-of-use is generally an improvement compared to landfill and energy-from-waste but the production of wastes is still in essence an unsustainable behaviour, and it would be best replaced by the more sustainable behaviour of preventative measures that design wastes out of the production-consumption system where it is avoidable.
The overriding model underpinning the framework appears to largely assume that people cause negative pressure on the environment on the one hand and take benefits from nature on the other hand. This expresses largely a negative relationship with our environment, while people also have the ability to enrich and strengthen it. For example, some of the most biodiverse landscapes are those that are managed by people. People are an integral part of the environment and must exploit resources to live, we would like to see more attention for approaches that positively restore and regenerate the environment and for the adoption of accompanying indicators. This change in thinking appears to have happened for biodiversity conservation already, in which goals and actions are increasingly defined to grow biodiversity rather than to focus only on reducing negative impacts from our behaviours on the living world. This approach not only tells people which behaviours to reduce, but also which behaviours to promote. A similar switch in thinking must be made for other areas of the 25YEP and associated indicators too, such as for air quality, soil health, and resource efficiency and waste.
Looking into the detail of the headline indicators, we assessed the likelihood that net-gains can be picked up. The overall picture is mixed:
- Indicators on wildlife, nature on land and water, health and diversity of seas and people enjoying and caring for nature are most likely to measure positive behaviours while they can also pick up negative trends if they occur.
- Indicators such as for quality and quantity of water, exposure to harmful chemicals, and production and harvesting of natural resources appear to primarily measure reductions in negative impacts but technically could also pick up positive behaviours, the likelihood of which may depend on the framing of the associated goal and context in the 25YEP.
- Indicators such as air quality, impacts of exotic pests, resource efficiency and waste, and greenhouse gas emissions from the natural environment appear completely focused on reducing negative impacts, without opportunity to measure behaviours that may be truly positive.
Ensuring that all areas of the 25YEP include indicators that can measure net-environmental improvements is a considerable challenge. Here we provide initial ideas for the development of indicators that are particularly relevant to the development of a sustainable circular economy, core focus to the Resource Recovery from Waste programme:
- Raw materials consumption (indicator ID H32) is proposed to be expressed as raw material consumption per GVA (Gross Value Added), i.e. a decrease in this indicator would demonstrate an improvement. We suggest to turn this around and measure GVA per unit of raw material consumed, in which an increase in the indicator signifies a positive effect. This would be more intuitively aligned with two further indicators that should be included. First, raw material consumption should also be measured as the proportion of total material consumption, this is important in comparison to recycled materials processed into new products (covered in point 2 below). Second, we suggest to measure sustainably sourced raw materials as a proportion of raw materials consumption. This will help ensuring that the raw materials that do have to be sourced are at least taken in the most sustainable manner possible. Finally, all these indicators can show improvement when materials consumption is still increasing, while an overall decrease of material consumption would render the most positive effect on the environment. This has to be controlled with another metric, and for this we propose to expand metrics on greenhouse gas emissions (point 4).
- Residual waste arising by type and sector (H34) focuses on reducing residual waste and impacts thereof, but it is not about developing a positive relation to our environment via our resource use. We should also keep track of the amounts of materials that are actually recycled into new products, expressed by additional indicators a) Measuring GVA per unit of material recycled into new products, and b) Recycled material use in products as a proportion of total material consumption – enabling direct comparison to raw material consumption indicators. Finally, for the promotion of a sustainable circular economy and increased resource productivity it is crucial to include additional indicators that keep track of material and product design, intensity of resource use (e.g. benefiting from shared consumption), reuse, repair, and remanufacturing.
- Hazardous chemicals preventing recycling (H33) is aiming to measure the reduction of hazardous chemicals i.e. a reduction in a negative behaviour, but the resulting behaviour of increased potential for recycling is a positive one. This indicator should be linked closely to headline “Exposure to harmful chemicals” and include the measurement of positive design choices for chemicals that could be returned safely to the natural environment at their end-of-use.
- Greenhouse gas emissions from the natural environment (H36) should focus on measuring anthropogenic greenhouse gas emissions of the full production-consumption system, from primary production to manufacturing, consumption and waste management. Increased resource efficiency is one of the largest opportunities to reduce carbon emissions and this point should be integrated more into both the 25YEP and its indicator framework, such as in the form of measuring greenhouse gas reductions resulting from adopting sustainable circular economy practices such as outlined in point 2 and 3 above.
The indicator framework is part of a series of publications such as the 25YEP, the Resources and Waste strategy and the Clean Growth plan, that grow momentum for environmental improvements and positively instilling the creation of economic and environmental win-wins as the new normal. The indicator framework is planned to be continuously improved via a process of regular reviews. This offers the opportunity to update the indicators to match the overriding ambition and pick up on net-environmental improvements for all goals of the 25YEP and the key areas covered by the Environment Bill including air, wildlife, water, and waste including, in our view, resources too.
The Resource Recovery from Waste programme is a NERC, ESRC and Defra funded research partnership engaging academia, government, industry and the general public to deliver the environmental science needed to support a radical change in waste and resource management. This consultation response was based on evidence accumulated within the programme and was written by Dr Anne Velenturf (former programme lead and impact fellow) and Prof Phil Purnell (programme convener) at the University of Leeds.