COV0107

 

Clear Public Space Written Evidence Submission

Greening the Post-Covid Recovery

Submitted by Sarah Anelay MSc, Business and Operations Manager, Clear Public Space.

 

  1.                Clear Public Space promotes sustainable waste management and the circular economy through projects, campaigns and consultancy. Our founder Luke Douglas-Home is educated by Cambridge University's Institute for Sustainability and is soon to be a Chartered Environmentalist.
  2.                We work to advance public behavioural change with regards to waste circularisation, waste reduction, sustainable consumption and recycling by promoting popular understanding of waste as a resource within communities, schools, councils and businesses.

 

Executive Summary

  1.                A green recovery is only possible with the commitment of all sectors of society, with focus on the private sector. The UK Government should strengthen existing environmental reporting requirements and create new mandates for public, private and third sector organisations to drive towards a more circular economy.
  2.                The Government must make its green recovery commitments quantifiable, rather than aphoristic proclamations. Sustainability targets for the public, private and third sector must involve measurement, key performance indicators (KPIs) and benchmarks to promote sustainable, positive green growth whilst mitigating greenwashing.
  3.                To demonstrate its commitment to leading climate change innovation, the UK Government must premier a new integrated approach to information and knowledge sharing across nations at Cop26 and as leader of the G7.
  4.                Cabinet ministers across all departments must engage in making commitments to greening the post-Covid recovery to demonstrate that entire Government, as host of Cop26 and leader of the G7, is united in recovering and advancing as an environmentally sustainable nation.

 

  1.              How can any fiscal and economic stimulus packages be aligned with the UKs ambitions on net-zero, biodiversity, the circular economy, and Sustainable Development Goals?

Recommendation 1: Green Procurement

  1. Goal 12 of the Sustainable Development Goals is to ‘Ensure sustainable consumption and production pattern’.[1] Within Goal 12, there is target 12.7 to ‘promote sustainable public procurement practices’.
  2. The UK is a global leader in sustainable public procurement through the Greening Government Commitments which ensure that ‘government buys more sustainable and efficient products and engages with its suppliers to understand and reduce the impacts of its supply chain’.
  3. Both the Flexible Framework and Prioritisation Tool are effective instruments for measuring compliance with green procurement targets. The Government Buying Standards (GBS) also provide clear, definite guidance for green procurement, however they have remained largely unchanged since 2012-2015.
  4. We recommend that the Government Buying Standards (GBS) are reviewed and updated using the most up-to-date knowledge
  5. We recommend that recipients of fiscal and economic stimulus packages across all sectors, not only public, be required to assume the Green Government Commitments targets and Government Buying Standards within their organisation.
  6. This would strengthen the market transition to a more circular economy, green procurement and sustainable commodities across the UK and make the UK a world leader in green procurement strategy across all sectors.

 

  1.         In what areas should interventions be targeted to deliver both economic and environmental benefits in the short and long term?

Recommendation 2: Enhanced Environmental Reporting

  1. In the UK, quoted companies must report on their global energy use and large businesses must disclose their UK annual energy use and greenhouse gas emissions, as required by the Companies (Directors’ Report) and the Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. Whilst the Government advice states that it is advised for other companies to report similarly, this remains voluntary.
  2. Within SDG Goal 12, there is the target to ‘Encourage companies, especially large and transnational companies, to adopt sustainable practices and to integrate sustainability information into their reporting cycle’ (Target 12.6)[2]. One of the indicator’s for a country’s attainment of Goal 12 is the ‘number of companies publishing sustainability reports’ (Indicator 12.6.1).
  3. To pursue such targets with a positive trajectory requires policy-making on a national level to mandate corporate environmental reporting and low-carbon initiatives.
  4. According to the recent SDG Report 2020[3], although the amount of companies publishing environmental reporting has increased, many omit aspects critical to sufficient environmental reporting such as waste generation and water use.
  5. Similarly, the International Institute for Sustainable Development stated that, ‘private sector reports often vary widely on the types of goals and indicators disclosed, even in the same industry. Public sector reporting is so mixed that it is often difficult to predict what the report will contain prior to opening it’.[4]
  6. Although the UK’s reporting legislation does mandate companies to report at least one ‘intensity ratio’, corporate environmental reporting is largely self-referential. This means it is difficult for both companies and consumers to compare or properly understand environmental data in practical terms.
  7. The disjointed and wildly varying nature of environmental reporting has led to a lack of integrated thinking in corporate environmental strategy. Such an approach simply cannot provide the Government the data or knowledge from which we can move forward with a green economy.
  8. We have also seen an exponential increase in greenwashing- the selective disclosure of positive environmental performance whilst withholding negative information on such dimensions. Greenwashing is made possible through loose and evitable reporting guidelines which allow companies to create an often erroneous green narrative. Net-zero targets have similar downfalls in that they focus solely on offsetting emissions rather than reducing or preventing them in the first instance.
  9. Lord Debden, former Environment Secretary, stated that “the facts of business life make it necessary to change our definition of economic growth to include social and environmental indicators. GDP is no longer a dependable index”.[5] The only way to ensure we ‘build back better’ as a green economy and mitigate greenwashing is to standardise environmental reporting and use these environmental metrics in tracking economic growth.
  10. As Michael R. Bloomberg, chair of the Task Force on Climate-Related Financial Disclosures, said, “Increasing transparency makes markets more efficient and economies more stable and resilient.[6]
  11. We recommend that the 2018 Regulations are expanded to require all organisations, public and private, regardless of size or nature, to publish comprehensive and sufficient environmental reportage as part of their existing financial reporting requirements.
  12. We also recommend that environmental reporting metrics are standardised and contain particular reference to the circular economy. Such metrics should focus quantitative measurement rather than narrative reporting and include compulsory targets for waste reduction, recycling rates, green procurement and natural resource usage.
  13. We particularly recommend that organisations applying for fiscal and economic stimulus packages be required to submit environmental impact reporting with a Paris-aligned economic recovery and business plan.

 

Recommendation 3: Expanding the Climate Change Levy

  1. The CCL was introduced in 2001 and is a UK-wide tax on electricity, gas, LPG and solid fuels supplied to businesses and public sector consumers.
  2. The CCL has been proven to have been successful due to the great monetary incentives for businesses to reduce their energy use and carbon emissions.
  3. We recommend expanding the Climate Change Levy to reflect a company’s attainment of environmental targets including waste production and recycling rates, green procurement measures and water usage as well as energy usage.
  4. The expansion of the CCL to include other environmental factors would reflect a truly systemic approach to building back better post-Covid embedded into a pre-existing and effective system.

 

Recommendation 4: Recycled Materials

  1. In 2016, only 12% of material resources in the EU came from recycled products or materials.[7] In 2019, A report from S&P Global Platts, a commodity market specialist, revealed that recycled plastic costs an extra $72 (£57) a tonne compared with newly made plastic.[8] Therefore, virgin plastic remains the more economically viable option, particularly for SMEs whose finances have been hit hardest by the pandemic.
  2. Whilst the new Plastics Packaging Tax[9] is a welcome initiative, its operation date of April 2022 does not reflect the speed with which we must approach a green post-Covid recovery.
  3. Subsidies on recycled materials would encourage mass procurement and usage of recyclate as well as reducing virgin material usage. This would also encourage producers to create packaging that is more than 30% recycled materials (the threshold for the Plastics Tax).
  4. We recommend that procurement of recycled material is subsidised to SMEs within the first half of 2021.

 

  1.         What sustainability conditions should be attached to Government bailouts for high-carbon industries?

Recommendation 5: Mandatory Reporting for High-Carbon Industries

  1. We join other witnesses to this inquiry in calling for companies receiving public financial support, but specifically those in high-carbon industries, to significantly hasten their attainment of net zero emissions across scope 1, 2 and 3 to the 2020s rather than 2030-2050.
  2. In 2019, the Government announced a £315 million investment drive in decarbonising heavy industry.[10] This funding is laudable and the application process for the Industrial Energy Transformation Fund requires much of the reporting data we are recommending in this evidence.
  3. The success of the funding project, alongside pursuits of a green Covid recovery, will be predicated on the production of systemic change within high-carbon industries.
  4. Such systemic change can only be monitored, measured and scrutinised through comprehensive, qualitative data reporting and analysis published regularly, not as a one off. 
  5. Following our Recommendation 1, we recommend that high-carbon industries who receive Government bailouts assume the Greening Government Commitments and Government Buying Standards within their organisation.
  6. Following our Recommendation 2, we recommend that high-carbon industries who receive Government bailouts be required to publish high-quality, quantitative environmental reporting with a Paris-aligned environmental business plan and commit to continuous measurement and reporting of their environmental impact.
  7. We would like mandatory reporting requirements to encourage high-carbon industries to pursue even more ambitious targets than net-zero which may be achieved by simply offsetting emissions rather than reducing them.

 

  1.         In the run up to Conferences of the Parties to UN conventions on climate change and biodiversity next year, how can the UK use its influence, as both host of COP26 and when holding the Presidency of the G7 in 2021, to influence the nature of economic rescue packages around the world?

Recommendation 6: The UK as an International Leader for Climate Change

  1. Around 80% of UK environmental legislation has been derived from EU membership over the last 30 years.[11] Whilst the Environment Bill seeks to address this governance gap, there is more the UK can, and should do to embody green leadership.
  2. In 2015, the material footprint per capita in high-income countries was over 10 times larger than in low-income countries.[12]
  3. The UK’s climate leadership has inevitably been sullied in light of the recent announcement of international aid cuts. Ban Ki Moon, former UN Secretary General, stated that ‘at a time when we need to boost the funds available to tackle climate change, this sets the wrong precedent and lends an excuse for others to follow suit’.[13]
  4. We do welcome the announcement that the £11.6 billion on climate finance for developing countries over 2021-25 will be protected.
  5. However, the Government must make some ambitious and concrete commitments to helping the world’s very poorest with regards to climate change.
  6. However, some of the world’s poorest countries have proven the most innovative in regards to climate change. The UK must not assume a paternalistic narrative to international climate change initiatives, there is a lot that high-income countries should learn from the climate practices of lower-income nations.[14][15][16]
  7. We recommend that the UK Government develop a Glasgow Initiative at Cop-26 for international cooperation and information-sharing on best practices for climate change.

 

Recommendation 7: Cabinet Alignment

  1. Compared with the United States’ most recent climate commitments under President-elect Biden, the UK is now trailing behind. Biden’s cabinet announcements have demonstrated prioritisation on climate issues including nominating Janet Yellen, a founding member of the Climate Leadership Council, as Treasury Secretary.
  2. In the UK, the cabinet does not represent the same integration of climate issues across departments.
  3. We recommend that cabinet secretaries across all departments produce departmental area-specific plans for greening post-Covid recovery.
  4. This would demonstrate the entire Government’s commitment as host of Cop-26 and leader of the G7 to promoting climate issues and influence other nations to integrate environmental issues throughout all facets of their governments.
  5. The uptake of the ‘polluter pays principle’ within the Environment Bill is another welcome step towards a more sustainable and circular economy, shifting the cost of waste management away from the tax payer and towards the polluter. We recommend that this clause and the OEP is given the necessary power to hold polluters to account and enforce transparency.

 

December 2020

 

References

 

Ambrose, Jillian, ‘War on Plastic Waste Faces Setback as Cost of Recycled Material Soars’, The Guardian, 13 October 2019, section Environment <http://www.theguardian.com/environment/2019/oct/13/war-on-plastic-waste-faces-setback-as-cost-of-recycled-material-soars> [accessed 1 December 2020]

Carattini, Stefano, Greer Gosnell, and Alessandro Tavoni, ‘How Developed Countries Can Learn from Developing Countries to Tackle Climate Change’, World Development, 127 (2020), 104829 <https://doi.org/10.1016/j.worlddev.2019.104829>

Department for Business, Energy and Industrial Strategy, ‘Press Release: Heavy Industry to Cut 2 Million Tonnes of Carbon Emissions with New Tech’, 2019 <https://www.gov.uk/government/news/heavy-industry-to-cut-2-million-tonnes-of-carbon-emissions-with-new-tech>

EuroStat, ‘Circular Economy in the EU: Record Recycling Rates and Use of Recycled Materials in the EU’, 2019 <https://ec.europa.eu/eurostat/documents/2995521/9629294/8-04032019-BP-EN.pdf/295c2302-4ed1-45b9-af86-96d1bbb7acb1> [accessed 30 November 2020]

HMRC, ‘Policy Paper: Plastic Packaging Tax’, 2020 <https://www.gov.uk/government/publications/introduction-of-plastic-packaging-tax/plastic-packaging-tax>

IEMA, ‘The Environment Bill: Background, Content and Passage through UK Parliament’, 2020 <https://s3.eu-west-2.amazonaws.com/iema.net/documents/Environment-Bill-Primer-September-2020.pdf?mtime=20200911142354&focal=none>

Lord Debden, ‘Green Recovery: Why Resilience through the Lens of Sustainability Is the Only Strategy’, Edie.Net, 2020 <https://www.edie.net/blog/Green-recovery-Why-resilience-through-the-lens-of-sustainability-is-the-only-strategy/6098780> [accessed 30 November 2020]

Moon, Ban Ki, ‘Abandoning Aid Target Sends the Wrong Signal before Cop26’, 26 November 2020, section comment <https://www.thetimes.co.uk/article/abandoning-aid-target-sends-the-wrong-signal-before-cop26-jn23gk2qs> [accessed 1 December 2020]

Searcy, Cory, and Livia Bizikova, ‘Aligning Sustainability Reporting Between the Public and Private Sectors’, International Institute for Sustainable Development, 2016 <https://www.iisd.org/articles/aligning-sustainability-reporting-between-public-and-private-sectors> [accessed 1 December 2020]

Task Force on Climate-Related Financial Disclosures, Recommendations of the Task Force on Climate-Related Financial Disclosures, 2017, p. 74 <https://assets.bbhub.io/company/sites/60/2020/10/FINAL-2017-TCFD-Report-11052018.pdf>

UN Department of Social and Economic Affairs, Sustainable Development Goals Report 2020 (S.l.: United Nations, 2020) <https://unstats.un.org/sdgs/report/2020/The-Sustainable-Development-Goals-Report-2020.pdf>

UN General Assembly, ‘Global Indicator Framework for the Sustainable Development Goals and Targets of the 2030 Agenda for Sustainable Development’, 2017 <http://ggim.un.org/documents/A_RES_71_313.pdf>

United Nations Climate Change, ‘How Developing Countries Are Scaling up Climate Technology Action’, UNFCCC, 2019 <https://unfccc.int/news/how-developing-countries-are-scaling-up-climate-technology-action> [accessed 2 December 2020]

———, ‘In Bonn, 9 Developing Countries Showcase Action and Innovation to Reduce Emissions’, UNFCCC <https://unfccc.int/news/in-bonn-9-developing-countries-showcase-action-and-innovation-to-reduce-emissions> [accessed 2 December 2020]


[1] UN General Assembly, Global Indicator Framework for the Sustainable Development Goals and Targets of the 2030 Agenda for Sustainable Development, 10 July 2017 <http://ggim.un.org/documents/A_RES_71_313.pdf>.

[2] UN General Assembly, Global Indicator Framework for the Sustainable Development Goals and Targets of the 2030 Agenda for Sustainable Development, 10 July 2017 <http://ggim.un.org/documents/A_RES_71_313.pdf>.

[3] UN Department of Social and Economic Affairs, Sustainable Development Goals Report 2020 (S.l.: United Nations, 2020) <https://unstats.un.org/sdgs/report/2020/The-Sustainable-Development-Goals-Report-2020.pdf>.

[4] Cory Searcy and Livia Bizikova, Aligning Sustainability Reporting Between the Public and Private Sectors, International Institute for Sustainable Development, 2016 <https://www.iisd.org/articles/aligning-sustainability-reporting-between-public-and-private-sectors> [accessed 1 December 2020].

[5] Lord Debden, Green Recovery: Why Resilience through the Lens of Sustainability Is the Only Strategy, Edie.Net, 2020 <https://www.edie.net/blog/Green-recovery-Why-resilience-through-the-lens-of-sustainability-is-the-only-strategy/6098780> [accessed 30 November 2020].

[6] Task Force on Climate-Related Financial Disclosures, Recommendations of the Task Force on Climate-Related Financial Disclosures, 2017, p. 74 <https://assets.bbhub.io/company/sites/60/2020/10/FINAL-2017-TCFD-Report-11052018.pdf>.

[7] EuroStat, Circular Economy in the EU: Record Recycling Rates and Use of Recycled Materials in the EU, 2019 <https://ec.europa.eu/eurostat/documents/2995521/9629294/8-04032019-BP-EN.pdf/295c2302-4ed1-45b9-af86-96d1bbb7acb1> [accessed 30 November 2020].

[8] Jillian Ambrose, War on Plastic Waste Faces Setback as Cost of Recycled Material Soars, The Guardian, 13 October 2019, section Environment <http://www.theguardian.com/environment/2019/oct/13/war-on-plastic-waste-faces-setback-as-cost-of-recycled-material-soars> [accessed 1 December 2020].

[9] HMRC, Policy Paper: Plastic Packaging Tax, 2020 <https://www.gov.uk/government/publications/introduction-of-plastic-packaging-tax/plastic-packaging-tax>.

[10] Department for Business, Energy and Industrial Strategy, Press Release: Heavy Industry to Cut 2 Million Tonnes of Carbon Emissions with New Tech, 2 November 2019 <https://www.gov.uk/government/news/heavy-industry-to-cut-2-million-tonnes-of-carbon-emissions-with-new-tech>.

[11] IEMA, The Environment Bill: Background, Content and Passage through UK Parliament, 2020 <https://s3.eu-west-2.amazonaws.com/iema.net/documents/Environment-Bill-Primer-September-2020.pdf?mtime=20200911142354&focal=none>.

[12] UN Department of Social and Economic Affairs.

[13] Ban Ki Moon, Abandoning Aid Target Sends the Wrong Signal before Cop26, 26 November 2020, section comment <https://www.thetimes.co.uk/article/abandoning-aid-target-sends-the-wrong-signal-before-cop26-jn23gk2qs> [accessed 1 December 2020].

[14] Stefano Carattini, Greer Gosnell, and Alessandro Tavoni, How Developed Countries Can Learn from Developing Countries to Tackle Climate Change, World Development, 127 (2020), 104829 <https://doi.org/10.1016/j.worlddev.2019.104829>.

[15] United Nations Climate Change, How Developing Countries Are Scaling up Climate Technology Action, UNFCCC, 2019 <https://unfccc.int/news/how-developing-countries-are-scaling-up-climate-technology-action> [accessed 2 December 2020].

[16] United Nations Climate Change, In Bonn, 9 Developing Countries Showcase Action and Innovation to Reduce Emissions, UNFCCC <https://unfccc.int/news/in-bonn-9-developing-countries-showcase-action-and-innovation-to-reduce-emissions> [accessed 2 December 2020].