IEMA’s Head of Policy Ben Goodwin discusses IEMA’s response to Defra’s environmental policy statement consultation, setting out where improvements are required to ensure that it has maximum impact.

Over the past few months Defra have been consulting on a draft environmental policy statement to strengthen environmental policymaking across all Whitehall departments.

The policy statement contains five principles that Ministers, and policymakers will be required to have ‘due regard’ to when making policy decisions.

The five principles

  • The integration principle is the principle that policy-makers should look for opportunities to embed environmental protection in other fields of policy that have impacts on the environment.
  • The prevention principle means that government policy should aim to prevent, reduce or mitigate harm.
  • The rectification at source principle means that if damage to the environment cannot be prevented it should be tackled at its origin.
  • The polluter pays principle is the principle that those who cause pollution or damage to the environment should be responsible for mitigation or compensation.
  • The precautionary principle states that where there are threats of serious or irreversible environmental damage, a lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.

The policy statement and principles are part of the wider Environment Bill framework, which is now continuing its passage through parliament.

IEMA’s perspective on the statement and principles

While IEMA welcomes the intention of embedding environmental and sustainability principles in policymaking that takes place right across government, we believe that there are a number of improvements that are required to the policy statement and principles in order for them to have the best chance of being effective.

In our response to the consultation we set out the following recommendations:

  • An explanation of ‘due regard’ should be provided in the policy statement or supporting guidance, so that policymakers across government can better understand what is expected of them legally in using the policy statement and its five principles.
  • To eliminate any potential confusion, an explanation of how the policy statement should be used in conjunction with existing government appraisal guidance (e.g. the Green Book) should be provided in the statement or supporting guidance.
  • Examples and case studies should be used in step 3 of the policy statement to help policymakers across government understand what each of the five principles means in practice and thus to help their application.
  • A decision-making tree or similar process tool should be set out in the policy statement or supporting guidance to aid policymakers across government in selecting and applying the five principles when developing policy.
  • The policy statement is almost exclusively focused on the prevention and mitigation of environmental harm. Throughout and particularly in the commentary on the five principles, ways through which policymaking across government can enhance the natural environment should also be offered.
  • Connections should be made in the policy statement to the other governance components of the Environment Bill – including the long-term environmental targets, Environmental Improvement Plans (EIP) and the Office for Environmental Protection – to ensure that the application of the policy statement is effectively used in the policymaking process across government to support achievement of environmental targets and EIPs.

IEMA’s response to the consultation was informed through engagement with members and other expert stakeholders.

Next steps

With the consultation closing today, we expect government to now take stock of all of the submissions that it has received before publishing a response later in the year. Throughout, IEMA will stay close to developments and update members as appropriate.

Read IEMA's full response HERE


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