NEWS
20 March 2008
Minister John Gormley; David Healy, ministerial adviser and before that on original Editorial Committee for submission; Poolbeg, Unsustainable Development
eengo-submission-on-nsds.pdf
ABOVE IS the environmental sector (EENGO – don’t ask!) submission on the national sustainable development strategy (NSDS). Please try to read it. It’s the most important document ever to have come from the environmental sector. I think it is a very bad document. I’m sorry this is so long but here’s why.
Introduction
I’m a former chairman of An Taisce (1999-2003) and a founder member of EENGO, though obviously these comments are offered in a personal capacity.EENGO includes nearly all the campaigning environmental organisations such as Friends of the Earth, An Taisce, Feasta etc – around seventeen in total. The EENGO submission contains many radical and interesting ideas but sadly is simply not of the quality necessary for this the most important topic for environmentalists – from a sector that aspires to being taken into social partnership within a few years. Government is keen that the environmental sector should collaborate more. This document – its substance and its process – augurs badly for such collaboration. I believe the document must be rescinded as it undermines the credibility of the environmental sector. I am aware this document has already been sent to the Minister for the Environment and would have commented on it if I had been aware of it.
The Critique
1. Not Strategic
The National Sustainable Development Strategy should be strategic. Any submission on it should be strategic. The EENGO submission is largely utopian not strategic. It does not say how we get from where we are now (very unsustainable) to where we should be (sustainable). It largely outlines what we might look like once we are sustainable. And even here it makes little effort to justify its vision. It ignores a wealth of NGO experience in this sort of strategic thinking.
Much of the EENGO submission is absorbed with ownership rather than the environment.
2. Not practical
The EENGO submission underemphasises the practical changes that would transform the system. It ignores the wealth of NGO experience in monitoring and advocating mitigation of patterns of unsustainability. For example it does not emphasise the problems environmental NGOs encounter everyday such as rhetoric without enforcement; aspirations without timetables, targets or funding; short-termism; failure to integrate environmental goals with economic and social goals; lack of clarity of environmental goals; failure to decouple environmental degradation from economic growth; failure to give sustainable price signals; failure to plan; breaches of development and other plans; political intervention with professional environmentalists and planners; failures to apply European Law; inadequate assessments of the effects of proposals: incomplete EISs, no SEAs etc etc. Each of these problems has a practical remedy. The EENGO submission is dangerous because it goes into detail as if it were a precise response to actual practical problems but does not identify or address those actual problems. It is particularly surprising that it puts no emphasis on the need to enforce existing standards.
The EENGO submission notes [p18] that “the EENGO network is well informed from years of monitoring, commenting and campaigning on environmental issues” but the submission has been driven largely by an ideology, not experience or the lessons of campaigning.
It is highly significant that the document has nothing to say about cities or suburbs (and little to say about towns) – where most of our citizens live and will continue to live.
3. Inadequate mandate
The content of the EENGO submission has not been mandated. For example An Taisce has not had the submission’s policies approved by its Council. The document appears to have been written by a small number of people and many of its ideas are not as clear or coherent as they would be if they had been agreed line-by-line by a representative committee. Occasional name-calling and gratuitous swipes reinforce this sense.
Page 18 says merely NGOS are not against the economic and social content of the document. It says somewhat revealingly, “as many of our member NGOs have expertise in only a very particular area, not all actively support all of the ideas contained in the submission, particularly as they relate to social and economic issues. However, they are not either, against any of them as they respect the expertise of NGOs with a wider field of interest to contribute their recommendations”. Merely not being against something is not enough to give EENGO a mandate to publish a document in a group’s name. What mandate did component members seek and get from their members? I believe An Taisce did not, for example, put the document before its Council, as required. Many of the policies cut across agreed An Taisce policies.
There has been inadequate consultation of organisations’ members – though the submission says there has been, and the Department of the Environment requested it [p8].
4. Probably had no agreed written brief so some environmental issues have been omitted
Was there an agreed written brief for the submission reflecting a sectoral environmental vision? The approach seems desultory and haphazard. Many sectors seem to be treated in line with submissions received rather than with a view to proportionality, coherence or completeness. Perhaps for this reason some sections are strikingly discursive, laced with sage quotations, and too long – while others are paltry and short.
Important sectors have been extraordinarily left out or dealt with cursorily. Only pp 134-148 out of a hundred and eighty two pages deal with the sectoral environmental agenda.There are no sections on waste, air pollution, nuclear, agriculture, industry, chemicals, mitigating the local effects of climate change, national Migration (a crucial issue for Ireland) or Demographics; and there are negligible sections on water quality (less than one page), forestry (one page with no clear targets) etc.
5. The quality of the policies advocated is inadequate in theory and in detail [see also points 7, 8, 9 and 10 below]:
Structural problems with the submission
Much of the good material is lost through lack of emphasis and clarity.
The EENGO submission does not have a clear list of concrete recommendations.
It includes few recommended targets and dates.
For example, much of the treatment of climate change is discursive. A lot of the text on climate change is gratuitously-detailed descriptions of particular technical approaches. Another example is there are no targets even for improving the building regulations where there is much received wisdom.
There is an extraordinary dearth of citation of Irish academic works.
In general the EENGO submission makes too much use of esoteric and alienating jargon.
It is also badly edited and proofread (e.g. bottom p 18) and uses jarring terms like “ditto” [p129].
Problems with the submission’s ideas
The five “key elements” of a renewed NSDS set out on p 18 [point 5] of the submission (Risk Management and Resilience Building etc) are too unconventional for this mainstream environmental sector submission. Remedying some of the problems mentioned at 2 above should have infused this section.
The submission assumes that the goal of sustainability, and government policy, should be “Human Wellbeing”. Planetary not human wellbeing is the accepted goal for the environmental sector.
Commons, Trusts and eco-villages are over-emphasised for what is supposed to be the key, mainstream environmental submission. This leaves little room for treatment of the private sector and of the planning realities.
The section on Production and Consumption fails to make the critical point that we should establish measures of the ecological footprint of goods and services.
Even on climate change the authors suggest that “the government’s strategic priority we suggest, should not be to reduce its greenhouse emissions but to reduce the country’s use of all imported fuel whether fossil or not” [sic]. This is a crucial statement on the most important issue for environmentalists and the most important problem facing humans. For the EENGO submission to posit this strategy as central is highly controversial. George Monbiot for example suggests that the energy future may be in linking renewable electricity supplies with Atlantic countries contributing wind and wave power, Saharan countries contributing solar etc to a shared grid. Importation may be the future not a dead-end.
Under Social inclusion, Demography and Migration the EENGO submission comments, critically, “equality of opportunity is promised but equality of access to and enjoyment of the social and ecological commons is not”. Is it really, as implied, the concern of the environmental sector that equality of opportunity should be mitigated in this way (only)? It would be expected that the environmental sector would have concerns with the (liberal) notion of equality of opportunity and it certainly should be concerned with the treatment of private property and not just the treatment of the Commons. Key concepts are thrown around unconvincingly.
The built heritage is treated almost as if there were not a wealth of practical wisdom built up of long experience – despite what looks like an attempt to go into detail.
6. Too many naïve policies and factual errors
The submission has too many errors. I include a mere sample. For example is it really intended as a goal that we should halve the volume of road transport in 2012 compared to 2000 [p126]? It would be impossible. Ireland is not the most car-dependent EU member [p125]. The recommendation that subsidies should be withdrawn for “inter-regional” air travel should have said “intra-regional”. The programme for government does not envisage annual three per cent reductions in transport emissions [p125]. Is it really wise to contemplate that putting the electricity grid into a Trust should happen even if it leads to power cuts [p17]? Does the submission really need to assert on behalf of the broad environmental sector the possibility that the Company PLC is of itself “psychopathic” [p64]? Does the environmental sector agree that the government really needs to “scrap” as opposed to overhaul and redirect its National Development Plan [p38] which deals adequately amongst much else with issues like health and education? Is it really the case that “no government is going to be able to contemplate massive cuts in carbon dioxide unless the money creation system is changed”? [p82]
7. Unclear to what extent the EENGO submission is a critique of the EU NSDS and it does not make significant reference to the seminal 1997 Irish NSDS
These seminal documents (with their admittedly dated wisdoms) should at least be reference points if the intention is to be effective. There are desultory references to the EU NSDS around but they are notably incomplete.
8. Inadequately states the goal of society as “wellbeing” rather than quality of life or sustainability
It is shockingly wrong to answer the Department of the Environment’s key question to the environmental sector, “what should be the focus of a renewed sustainability strategy?” with “Human Wellbeing” [p18]. Sustainability recognizes the planet and other life not just humans and particularly addresses the long-term . It is universally recognized as the key concept here but the submission underplays it. The environment has an independent imperative and does not depend entirely on how it is enjoyed by humans.
The EENGO submission totally ignores work done by the ERSI, CSO, OECD, EU etc on quality of life and sustainability indicators, though it recognizes their existence. Quality of Life is a gratifyingly wide concept and most of its indicators have been ignored in this document which centralizes “health” as an indicator.
Health and wellbeing are not the key concepts for the environmental sector. The EU SDS includes the concept of wellbeing under Public Health (which it says comprises Health and Wellbeing). Wellbeing is taken by most commentators to embrace only issues like diet, contamination, disease. Quality of life is broader and less subjective and embraces environmental, social, economic and cultural objectives.
The section on “wellbeing” in the document is incomplete, over-emphasising indicators of health (US researched, at that), the land value tax and eco-villages. There is a section on social capital but there is no recommendation that the widest range of environmental indicators should be used to assess the success of society – along with the widest range of social, economic and cultural indicators. These indicators should apply to all development. The submission implies at one stage that some such indicators should apply to infrastructure only pp 78-9].
9. Skewed towards ownership and taxation not planning and the environment
The EENGO submission pays far too much attention to ownership (but only of the “Commons” which does not extend to buildings or infrastructure) reflecting the social concerns of the authors but not a mainstream environmental sectoral agenda. The land value tax that would apply to the site value, if it could be implemented, would tend to encourage development of the right sort of development, but unlike implementation of something like the Kenny Report (combined with cross-sectoral Agenda 21-style composition of sustainable plans) would not guarantee it. The EENGO’s proposed annual land tax does not guarantee local authorities the right to rezone and sell on land for suitable purposes like the current CPO regime combined with the Kenny Report would. In a country developing as fast as Ireland applying a land value tax instead of something like the Kenny Report would amount to a fatal missed opportunity to overhaul the fundaments of planning and development to start immediately serving the common good. It would be the wrong focus.
The Oireachtas Committee on the Constitution has already – following wide-ranging consultation – recommended implementation of a version of the Kenny report but the EENGO submission is ideologically opposed to this – a realistic corrective add-on to the existing statutory regime – as it does not facilitate the vision of Henry George, and the derivative notions of Commons and annual land tax.
There is also a strange emphasis on government rather than public performance [e.g. p 128 in the Objectives part of the Consumption and Production section].
10.Ingenuous vision of planning
Planning is perhaps the most important agent for sustainability (or unsustainability), particularly in a country growing as fast as Ireland. The EENGO submission includes no reference to the national spatial strategy which is the most important planning document widely accepted as an important (though flawed and flouted) salvo at sustainability. The EENGO submission implies that the future lies with eco-villages like Cloughjordan. Eco-development adjoining villages and towns is peremptorily dismissed as currently impossible in view of inflated land prices. The document has nothing, at all, to say about cities or suburbs. The submission has nothing to say to the ninety per cent of the population who would not consider living in an eco-village (and who do not live in social housing) about how to retrofit their housing.
There is a section [pp 55 and 56] which may (it is unclear) refer to towns as well as villages, providing for Framework Plans. It is naïve and utopian in assuming that a “team of consultants” whose relationship with the local authority is unclear can prioritise certain sites over others for development when the history of zoning in Ireland is so tainted and so much money would under the proposed system continue to be at stake. The report goes on [p56] in effect to recommend, in pursuit of the legitimate goal of ensuring Community-driven planning, use of CPO powers against recalcitrant “rural landowners” adjoining villages. But if this is recommended in the case of landowners’ recalcitrance adjoining rural villages the document does not make it clear why CPOs should not be used instead of land value taxes generally – where landowners are greedy rather than just recalcitrant and where the land is in a town, suburb or city.
The submission also envisages an unclear but very limited role for the private sector in future planning and development. The EENGO submission posits that developers of eco-villages should be not-for-profit. It is naïve to expect a speedy move from an avaricious building industry to a not-for-profit one, though that is not to say that might not ultimately be desirable. For the EENGO submission to suggest this peripheralises the environmental movement. The submission asserts that consultants are an exception to the rule against profits. If the vision is not for profit then surely no-one should earn a fee rather than a salary.
In any event the vision of eco-villages outlined is inadequately ambitious since it does not adequately address the issue of car-use and allows up to fully 40% of inhabitants to be holiday-homers or commuters.
Conclusion
The submission is on an important enough topic that it should be rewritten, recognizing the current document’s lack of mandate, lack of range, inadequate quality and inappropriate ideological biases.
