Consultation outcome

Summary of responses and government response

Updated 12 May 2022

Introduction and context

A 12-week public consultation on the draft environmental principles policy statement closed on 2 June 2021. This consultation sought feedback on the content and structure of the draft policy statement. The consultation built on the 2018 consultation on Environmental principles and governance after the United Kingdom leaves the European Union.

The Environment Act 2021 sets out 5 internationally recognised environmental principles to be considered in policymaking to protect the environment. These principles are:

• the integration principle
• the prevention principle
• the rectification at source principle
• the polluter pays principles
• the precautionary principle

The Environment Act 2021 requires the Secretary of State for the Department of Environment, Food and Rural Affairs to publish a policy statement on environmental principles, setting out how these principles are to be interpreted and proportionately applied by ministers when making policy. Once in effect, the statement will contribute to the improvement of environmental protection and sustainable development.

In addition, the Act places a legal duty on Ministers of the Crown to have due regard to the policy statement. In practice, this means that ministers across government will need to consider the 5 environmental principles when making new policy or revising existing policy. They will need to assess whether the policy has an environmental impact and work through the steps in the policy statement to consider if any of the principles are relevant to their policy, whether and how they should be applied.

The Environment Act 2021 requires the draft statement to be scrutinised through a public consultation and by Parliament.

This document sets out key themes from the consultation and how the government has amended the environmental principles policy statement in response to the feedback.

Methodology

The consultation, hosted on Citizen Space, included 7 substantive questions on the draft environmental principles policy statement. Respondents also had the opportunity to provide feedback on the online consultation tool, and 4 questions provided background information to assist with the analysis of responses.

To analyse the consultation responses, a thematic analysis framework was developed using existing codes from the 2018 ‘Environmental principles and governance after the United Kingdom leaves the European Union’ consultation. All codes were defined. Analysts conducted manual coding of each response and new emerging codes from the responses were added to the theme list. The most common themes for each question were used to frame the summaries with acknowledgement of less common opinions and themes throughout.

The response from Friends of the Earth, submitted via email, included a consultation response and a separate open letter to the Secretary of State. The covering email made it clear that the letter was co-signed by 33,850 supporters via act.friendsoftheearth.uk, but it was not clear that the support also related to the consultation response. Therefore, it was decided to analyse these documents together as one response on behalf of one organisation, whilst noting separately the level of endorsement from supporters.

Executive summary

Responses

We received a total of 216 responses to the consultation, although not all respondents answered each question. Questions 1 to 4 asked for details about the respondent, including if they were responding on behalf of an organisation, what kind of organisation, and whether they’d like their response kept confidential. Questions 5 to 10 asked specific questions relating to the draft policy statement. Question 11 asked for any additional comments.

In response to Question 5, 24% of all respondents agreed that the overview section was clear, whereas 45% disagreed.

In response to Question 6, 50% of respondents were concerned that step 1 does not allow policymakers to correctly assess the potential environmental effects of their policy, however 20% thought that step one does.

In response to Question 7, 51% expressed concern that step 1 would not ensure that the most important environmental effects would be addressed, whereas 16% of respondents agreed that it would.

In response to Question 8, 40% said that step 2 will not assist policymakers in selecting the appropriate principles whereas 26% felt it would.

In response to Question 9 on the individual principles, 26% of respondents did not agree that the integration principle provided a robust and sufficient framework, and 6% did. Similarly, 26% of respondents expressed that the prevention principle did not provide a robust and sufficient framework, whereas 6% felt that it did. 22% of respondents did not think that the rectification principle provided a robust and sufficient framework, and 6% did. 46% did not agree that the polluter pays principle provided a robust and sufficient framework, 4% did. Further, 41% did not agree that the precautionary principle provided a robust and sufficient framework and 3% did.

53% of respondents answering Question 10 were concerned that the process for applying the policy statement (the 3 steps) did not provide a robust and sufficient framework for the application of the environmental principles as a whole.

In response to Question 11, 63% of respondents wanted to comment further on the draft policy statement.

Themes

Across all questions in the consultation, 5 key themes commonly occurred within responses:

• a call for more examples or case studies to further assist policymakers
• respondents thought that the use of proportionality was excessive, and some wanted further guidance on how it would weigh against environmental impacts
• more clarity or detail was requested on aspects of the policy statement, such as the application of the principles throughout the policymaking process and the nature and certainty of environmental effects
• respondents questioned how the principles policy statement would be embedded in policymaking, and how this would be monitored and enforced in practice
• the legal robustness of the policy statement was questioned, and respondents were concerned about potential loopholes for policymakers

Breakdown of respondents

A total of 216 responses were received. 176 responses were submitted via the Citizen Space online portal, and 40 via email. The majority of respondents responded on behalf of an organisation (52%), followed by individuals (44%). A very small percentage of respondents were responding as academics (4%).

Respondents by organisation

The majority of respondents were non-governmental organisations and those responding on behalf of another type of organisation. There were similar numbers of respondents representing large businesses, industry associations and government bodies.

Table 1: Breakdown of responses by organisation.

Type of organisation	Number of respondents	Percentage of respondents
Large business (250 or more employees)	15	7%
Medium business (50 - 249 employees)	1	<1%
Industry association	17	8%
Responding on behalf of another type of organisation	31	14%
Small or micro business (less than 50 employees)	6	3%
Non-governmental organisation	30	14%
A government body	16	7%
Not answered	100	46%
Total	216	100%

Defra also held stakeholder events where attendees were able to provide feedback on the draft policy statement with Defra officials. Attendees included non-governmental organisations, trade bodies and industry.

Question by question analysis

Question 5: the overview section

We received 179 responses to question 5 which asked: “Do you think the overview section provides an adequate foundation for policymakers to apply the environmental principles in policymaking?” 97 respondents answered ‘No’, 52 answered ‘Yes’, and 30 answered ‘Other’. Further comments were received from 156 respondents that are reflected in the themes below.

Key themes in response to Question 5:

More prescriptive guidance or more detail required in the policy statement

Thirty-two respondents required greater detail or wanted the policy statement to be more prescriptive. Some respondents felt that the policy statement needed an explanation of the wider context, such as the implications for overseas policies and in relation to the Environment Bill.

More explicit definitions

Twenty-eight responses requested more explicit definitions or language to prevent the policy statement from being open to interpretation or overly ambiguous, with comments such as, “the statement leaves too much room for interpretation by ministers”.

Proposals need strengthening or need to go further

Twenty-five respondents wanted to add ‘enhancement’ as a principle, with a specific focus on creating environmental growth or improving the environment rather than protecting it. Some respondents also expressed concerns that the overview should be more ambitious and emphasise that the principles are at the centre of all policymaking. A large proportion of respondents felt there were limitations to the language used in the principles. Some suggested that the policy statement lacked key definitions of terms and the inclusion of caveats could be interpreted by policymakers to avoid abiding by the duties and would prove to be less effective in its application.

Remove exemptions or remove ‘insignificant’

Twenty-five respondents raised a significant limitation in the exempted policy areas (‘taxation, spending and the allocation of resources’, and ‘national security, defence and the armed forces’), particularly in order to influence corporate and consumer behaviour through taxation which could help deliver the government’s climate and nature ambitions.

Sustainable development

Nineteen respondents acknowledge the benefits of the policy statement and Environment Bill referring to sustainable development but felt that this reference is limited.

Government response to Question 5

We have strengthened the overview section by emphasising the importance of embedding the principles right from the outset, the benefits of applying the principles and their role in the wider environmental governance framework. For example, we have referred to environmental improvement plans (such as the 25 Year Plan) and net zero. As required by section 17(4) of the Environment Act, the Secretary of State is satisfied that the policy statement will contribute to the improvement of environmental protection and sustainable development.

Questions 6 and 7: Step 1 - understanding the environmental impact

Question 6

We received 184 responses to Question 6 which asked: “Do you think step 1 allows policymakers to correctly assess the potential environmental effects of their policy?” Of these 184 responses, 107 respondents answered ‘No’, 44 answered ‘Yes’, and 33 respondents answered ‘Other’. Further comments were received from 153 respondents that are reflected in the themes below.

Key themes in response to Question 6:

Amend definition of ‘the environment’

While some respondents welcomed the meaning of the natural environment defined in the Environment Bill, 24 respondents stated that it is too narrow in fully representing ecology. Historic England suggested that it “focused entirely upon the natural environment”.

Environmental assessment

Twenty-two respondents were unclear “how policymakers can correctly assess the potential environmental effects of their policy without carrying out some form of environmental impact assessment” (Environmental Services Association and FCC Environment).

Consider overseas policy or impact

Twenty-two responses felt that the statement “appears to discourage policymakers from considering the international impacts of many domestic policies” (UK Health Alliance on Climate Change).

Question 7

We received 182 responses to Question 7, which asked: “Do you think step 1 ensures that policymaking will address the most important environmental effects?” Of these, 111 responded with ‘No’ to the question, 35 with ‘Yes’, and 36 said ‘Other’. Further comments were received from 153 respondents that are reflected in the themes below.

Key themes in response to Question 7:

More prescriptive guidance or more detail required in the policy statement

Twenty-six responses felt that the complexity of environmental impacts were not sufficiently covered in the policy statement and require a more robust assessment framework, and acknowledgement of indirect and direct impacts.

Examples – how will it work in practice?

Twenty-one respondents, predominantly responding on behalf of non-government organisations or government bodies, stated that step one could be improved with greater guidance on application through practical examples or case studies.

More explicit definitions

Throughout the responses, further clarity was requested by 19 respondents on what constitutes ‘important’, who defines this, and how this would be measured in practice. Multiple respondents expressed concern that without detailed guidance on what ‘important’ means, cumulative effects would not be addressed, and some impacts may be missed as a result.

Proportionality

Eighteen responses stated that proportionality was over referenced, and several responses requested greater instruction or guidance on how environmental considerations would be balanced with proportionality. However, while some found proportionality to be a limiting addition, multiple responses welcomed the use of proportionality, on the condition that more explicit guidance on how the most important impacts would be addressed was included.

Amend definition of environmental impact

Fourteen respondents identified that due to the complex and variable nature of environmental impacts, step 1 was insufficient in providing a robust assessment framework. Possible solutions that were raised included the use of case studies or examples, additional detail, or supplementary guidance. There were also significant concerns about the extent to which step 1 will address the most important environmental threats if economic interests, such as expanding infrastructure and housing, will prevent substantial mitigation of environment degradation.

Question 8: Step 2 - understanding which principles are relevant

One hundred and eighty-two responses were received to Question 8 which asked “Will step two assist policymakers in selecting the appropriate environmental principles?” 86 respondents said ‘No’, 57 said ‘Yes’, and 39 said ‘Other’. Further comments were received from 147 respondents that are reflected in the themes below.

Key themes in responses to Question 8:

Guidance on selecting the appropriate principles

Thirty-four respondents thought that “As currently drafted, step 2 appears to be a short description of what each principle means; it provides no guidance on how to select the most relevant principles or the circumstances in which each principle should be used” (National Farmers Union).

More prescriptive guidance or more detail required in the policy statement

Seventeen responses suggested that greater detail is required in the policy statement to assist policymakers with selecting the appropriate principles.

Examples – how will it work in practice?

Many respondents suggested that “providing practical, real-life examples of when the environmental principles have been used” would be “useful and essential in ensuring policymakers fully understand the opportunities to embed these principles” (Aldersgate Group).

More explicit definitions

Fifteen respondents commonly referred to the definitions of the principles outlined in step 2, suggesting they could reflect a higher level of environmental ambition.

Government response to Questions 6, 7 and 8

We recognise the benefits of using case studies to illustrate the intended use of the principles and intend to provide examples and case studies for each principle in resources we are developing to support policymakers in their decision making.

Taking a proportionate approach plays an important part in policymaking. These principles exist to ensure that environmental considerations are factored into policymaking, and this must be done in parallel with other policy considerations. This means that ministers should balance social, economic, and environmental considerations in making policy. Therefore, we have not substantially altered the role of proportionality in the policy statement but have reviewed the statement as a whole to ensure the definition of proportionality is consistent and clear.

Question 9: Step 3 - applying the principles

Question 9 asked “Do you think step 3 provides a robust and sufficient framework for the application of each individual environmental principle?”

9.1 The integration principle

We received 178 responses to question 9.1 in relation to the integration principle. 89 respondents said ‘No’, 56 said ‘Yes’, and 33 said ‘Other.’ Further comments were received from 126 respondents that are reflected in the themes below.

Key themes for 9.1 the integration principle:

More prescriptive guidance or more detail required in the policy statement

Twenty respondents welcomed the intention of the integration principle, but some specified that it was too high level and vague. Some suggested that more tools and additional guidance to explain how much weight will be given to the integration principle in comparison to other legislation would be valuable.

Proposals need strengthening or need to go further

Twenty respondents expressed concerns surrounding the degree to which the principles would be enforced and followed. Numerous respondents raised concerns about how the guidance was presented and questioned whether this offered a coherent and sufficient framework to inform planning and policy. The majority of responses were in favour of stronger proposals to ensure that economic interests would not override the effectiveness of the integration principle. A common theme across responses that focussed on strengthening proposals was that the focus on balancing environmental damage against economic gain would not lead to progress or protection.

Potential benefits

Despite some concerns about the robustness of the framework, multiple respondents felt that the integration principle was effective within the wider framework. Some welcomed the visibility of the step in the policy development process and recognised the potential for it to be incorporated into a wide range of policy measures for holistic improvements in a phased manner.

Examples – how will it work in practice?

Fifteen respondents suggested that there should be more guidance for ministers in applying the principles. For example, improvement could be made by including what the application would look like in practice and how it will align with other objectives or conflicts with other policies that lack a focus on sustainable development.

More ambition

Fourteen respondents stated that step 3 could be more ambitious. Respondents called for the integration principle to be applied at the earliest stage of policy making for a greater commitment to environmental protection. Multiple non-governmental organisations emphasised that a more ambitious strategy would be to explicitly highlight the benefits of an integrated and multi-sector approach for potential environmental outcomes. Multiple respondents also suggested that the draft policy statement should align with the government’s 25 Year Environment Plan and should be proactive in optimising potential environmental outcomes.

9.2 The prevention principle

We received 176 responses to question 9.2 in relation to the prevention principle. 91 respondents said ‘No’, 53 said ‘Yes’, and 32 said ‘Other’. Further comments were received from 133 respondents that are reflected in themes below.

Key themes for 9.2 the prevention principle:

More prescriptive guidance or more detail required in the policy statement

In response to the prevention principle’s level of detail, 22 respondents expressed that it needed to be clearer on the nature and extent of the advice that policymakers are required to obtain to meet this requirement. Several respondents required further clarification on when it would be considered “disproportionate to prevent all possible damage”.

Multiple responses required clarification on how the prevention principle would interact with other principles, predominantly the precautionary principle.

Proposals need strengthening or need to go further

Twenty-two respondents felt that the prevention principle could be stronger within the policy statement and expressed that the statement widens the application to include ‘reduce or mitigate’. UKELA (UK Environmental Law Association) suggested that the definition of the prevention principle would be more effective if redefined as: “the prevention principle means that government policy (and decision-making) should always aim to prevent environmental harm.”

Does not go far enough

Fifteen respondents voiced that the principle should be expanded to be applied to all policy, rather than only being relevant to those causing environmental harm. For example, one respondent suggested that the prevention of environmental harm should extend beyond a natural capital approach.

Examples – how will it work in practice?

Fourteen respondents proposed that despite the structure of the framework being helpful, additional examples of the prevention principle being applied would be helpful.

To improve the current policy statement, some respondents, particularly businesses and non-governmental organisations, argued that the inclusion of case studies would be beneficial.

9.3 The rectification at source principle

We received 176 responses to question 9.3 in relation to the rectification at source principle. 87 respondents said ‘No’, 59 said ‘Yes’, and 30 said ‘Other’. Further comments were received from 123 respondents that are reflected in the themes below.

Key themes for 9.3 the rectification at source principle:

More prescriptive guidance or more detail required in the policy statement

Twenty-one respondents required further details to support the individual rectification principle. For example, the majority noted that there was “insufficient information” regarding the principle and “more detail needed”.

More explicit definitions

Seventeen respondents, including multiple large businesses stated that the rectification principle should define its purpose more explicitly, for example, one respondent stated that it “needs to state explicitly that the rectification principle does not prevent environmental damage. It is associated with actual damage and should only be adopted as a last resort” (Arcadis).

Examples – how will it work in practice?

Thirteen responses, including multiple non-governmental organisations, suggested that additional examples of application could be embedded in the policy statement. For example, FCC suggests “it should be expanded to include actual examples of where this approach has been used appropriately and with success in the past”.

Proposals need strengthening or need to go further

Thirteen respondents felt that there are too many caveats, and view this as a limiting factor in the enforcement of regulations. Accountability for damage to the environment is described as being absolved from “responsibilities”. Some anticipated that the principle would be difficult to enforce, with “loopholes” delaying environmental rectification, or a lack of a guarantee in policymakers and planners following the guidance.

Costs and benefits

Eight respondents required further detail regarding the feasibility and cost-benefit analysis of rectification at source when compared to alternative options. In response to the cost-benefit analysis model proposed in the “Criteria for taking action” section, greater clarification was needed to overcome potential challenges of quantifying the benefits of regulation compared to costs of regulation in a way that protects the environment.

9.4 The polluter pays principle

We received 178 responses to question 9.4 in relation to the polluter pays principle. 84 respondents said ‘No’, 57 said ‘Yes’ and 37 said ‘Other’. Further comments were received from 139 respondents that are reflected in the themes below.

Key themes for 9.4 the polluter pays principle:

Consider prevention before mitigation

Twenty-six respondents were concerned that the principle continues to allow polluters to harm the environment.

Difficult to identify polluter

Sixteen respondents raised concerns about the difficulty in identifying the polluter. There was concern that the guidance states that “policymakers must use judgement to identify who polluter is” (Game and Wildlife Trust) and that it is “important to clearly identify the ‘polluter’” (Cosmetic, Toiletry and Perfumery Association).

Examples were given about the difficulty in identifying different sources of pollution (that is, point and diffuse) in addition to the different types of pollution such as waste and emissions. Country Land and Business Association (CLA) stated that: “A more robust interpretation of the polluter pays principle should manifest itself in better enforcement of fly-tipping and other forms of littering that blight the countryside causing social and economic, as well as environmental harm.”

How will it be enforced?

Fifteen respondents were concerned about the lack of enforcement and the mechanism by which polluters will be held accountable.

Increased cost to consumer

Fifteen respondents said that the polluter pays principle “will only increase costs to the consumer” (London Borough of Barnet). Multiple respondents highlighted some of the challenges with the polluter principle such as the ability of the polluter to pay and in what format (that is, taxes) and further, who will hold polluters accountable?

9.5 The precautionary principle

We received 175 responses to question 9.5 in relation to the precautionary principle. 89 respondents said ‘No’, 57 said ‘Yes’, and 29 said ‘Other’. Further comments were received from 128 respondents that are reflected in the themes below.

Key themes for 9.5 the precautionary principle:

Add innovation

Twenty-one respondents expressed the need to use the precautionary principle to encourage innovative solutions.

Environmental Services Association stated that:

“The precautionary principle should not be used to stifle innovation or to block the deployment of safe and proven technologies, including environmental technologies, where they represent the best practicable environmental option”.

The principle should include the ‘full’ scientific certainty

Eighteen respondents frequently mentioned the need for the principles to include the full scientific certainty. Respondents requested more information regarding the level of uncertainty and level of risk. UK Health Alliance on Climate Change stated that: “principle does highlight the tension between scientific certainty and the level of risk; this is a real concern. However, the principle sets too high a threshold for certainty around the risks before it applies.”

Innovation at the risk of safety

Nineteen respondents raised concerns about the risks associated with innovation – especially newer technologies verses older ones. The Royal Society of Biology stated that: “The precautionary principle enables protection of environments from actions that are not fully understood but may cause significant damage.”

Greater research and evidence

Fourteen respondents called for greater research and evidence under the precautionary principle. The Aberdeen University Centre for Energy Law (AUCEL) suggested that: “Further guidance is required on the extent of scientific advice required to be taken into account when applying the precautionary principle and what ‘best available scientific evidence’ entails.”

Cost effective should or should not be important

A common theme from 14 respondents was the use of the phrase ‘cost-effective’ under the application of the precautionary principle. The National Trust stated that: “Cost-effectiveness is important, but in pursuing economic savings, we should not sacrifice our environment. We also note that rectifying environmental harm is likely to be far costlier than changing policies to prevent it.”

Government response to Question 9

To recognise policy can have both positive and negative influence on the environment, we have changed environmental ‘impacts’ to a more neutral term environmental ‘effects’. We have ensured that the language explaining the certainty of effects is consistent across the individual principles. We have not amended the definitions of the principles as they follow the internationally recognised definitions.

For the integration principle, we have added clarity on the need to consider opportunities for environmental protection, maintenance, restoration or enhancement.

For the prevention principle, we have moved text regarding ‘reduce or mitigate’ to the interaction between the principles section because it is more relevant to rectification at source and the polluter pays principles. In relation to the precautionary principle and innovation, we have made clear our intention that innovation is not part of the definition of this principle.

We will provide practical examples of application of the individual principles in any resources we develop.

Question 10: application of the principles as a whole

We received 183 responses to Question 10 “Do you think the process for applying the policy statement (the 3 steps) provides a robust and sufficient framework for the application of the environmental principles as a whole?” Of these, 114 answered ‘No’, 42 respondents said ‘Yes’ and 27 (13%) respondents said ‘Other’.

Key themes found in response to Question 10:

Not legally robust

Twenty-eight respondents stated that the 3 steps do not provide a robust framework for the application of the environmental principles. This was included through issues regarding the use of the term proportionality, the number of caveats, insufficient information and the lack of strength needed to hold ministers accountable and enforce environmental policy.

How will it be enforced?

Twenty-four respondents required more information about how the policy statement will be enforced and monitored. They believe that lack of enforcement limits the robustness of the framework. Questions were particularly raised over how ministers will be held accountable.

More prescriptive guidance or more detail required in the policy statement

Overall, 22 responses believed that more detail on certain elements of the policy statement is required. Most respondents requested information regarding the principles – more information about each individual principle, how they interact and their application. More information was requested on proportionality, overseas considerations, and guidance for ministers.

Proportionality

Twenty-two responses stated that the reference to proportionality can limit the robustness and sufficiency of the framework. Respondents were concerned that the use of proportionality would cause an inconsistent application of the principles.

Further, the respondents stated that the number of references to proportionality leaves too much opportunity not to apply the principles and to not consider “non-immediate effects and the cumulative effects of multiple approaches” (Institute for Environmental Sciences).

Too many caveats

Twenty-two responses explicitly stated that there were too many caveats and hence, this could limit the framework for applying the principles.

Government response to Question 10

Based on the consultation response, we have replaced the 3-step process with an iterative process as we had intended. The importance of considering the principles from the very outset and during all subsequent stages of policy development has been made clear. We will consider the use of diagrams or illustration in any resources we develop to support policymakers.

Question 11: final thoughts

One hundred and thirty-five respondents specified that they had additional comments relating to the draft policy statement which were not covered by previous questions.

Key themes in response to Question 11:

Climate change and biodiversity loss

While many responses were positive about consideration of the environment in policymaking, 30 respondents identified that the policy statement was limited in its emphasis on climate change and biodiversity. Several responses proposed the inclusion of the UK’s legislated target of net zero greenhouse gas emissions by 2050 within the statement.

Should be subject to parliamentary scrutiny, review process, to review and amend principles in the future

There were various suggestions from 25 respondents for a greater auditing process, and that government departments should report annually on the application process of the principles and provide an evaluation of policy effectiveness to create a more transparent and effective assessment process.

Some recommend that an independent body should monitor and review the process continuously. There were multiple suggestions to establish a “watchdog” organisation where the application of principles would be subject to scrutiny by an independent body.

Not legally robust

Twenty-three responses outlined that the environmental principles needed to be embedded in the legislation to be more legally robust, rather than including them in a separate policy statement. Some respondents refer to language such as “due regard” as being “weak”. A response that highlighted this suggested that the policy statement should: “Provide further detail on the ‘due regard’ requirement” (Chartered Institution of Wastes Management and Institute of Materials, Minerals and Mining).

Does not go far enough

Twenty-one responses felt that the draft policy statement weakens the approach to environmental protection through insufficient compliance and enforcement measures, limitation to policymaking and ministers, and lack of specification on wildlife, cultural heritage and biodiversity. Many non-government organisations welcomed the environmental ambitions of the policy statement but were disappointed that the applicability of the principles was too narrow and discretionary with little legal binding to comply. For example, Greener UK suggested that effectiveness could be improved through more ambitious language and tone, presenting “a positive economic case for the principles” and removing the overemphasis and number of references to innovation and proportionality.

Government response to Question 11

We have explained the requirement of the duty to have ‘due regard’ and provide clarity on where it applies. This will be supported with further information in supplementary resources as appropriate. We have also made it clearer in the policy statement where the duty applies and does not apply in relation to reserved matters and the devolution settlements. We have clarified the application of the principles to overseas policy development, and to arm’s length bodies.

We are actively working with government departments to develop their understanding of the duty and to embed the environmental principles in their policymaking processes. Defra is supporting departments by providing training on applying the principles and developing methods for recording compliance.

Appendix A – organisational respondents

• Bakkavor Group plc
• London Borough of Barnet
• Perrancoombe
• Arundel Bypass Neighbourhood Committee
• Patagonia Consultants
• TJ Chapman & Partners
• Trant Engineering Ltd
• Cornwall Seal Group Research Trust
• AW Alston
• SUEZ Recycling and Recovery UK Ltd (SUEZ)
• Dŵr Cymru Welsh Water
• British Association for Shooting & Conservation
• Cumbria Farmer Flood Group
• Institution of Environmental Sciences
• Tyburn residents
• Brookemead Assoc Ltd
• Sustrans
• Stop Portland Waste Incinerator
• Medway Council
• Association of Local Government Archaeological Officers
• Rotherham Borough Council
• Thakeham Homes Ltd.
• Chemical Industries Association
• South East Water
• North Yorkshire County Council
• Vale of White Horse District Council
• South Oxfordshire District Council
• Friends of Carrington Moss
• National Parks England
• Historic England
• Country Land and Business Association
• Countryside Alliance
• The Zero Carbon Campaign
• Animal Aid
• WM-Air project team (https://wm-air.org.uk/), University of Birmingham
• Surrey Environment Partnership (made up of Surrey County Council (SCC) and the 11 district and borough councils in the county)
• UK Health Alliance on Climate Change
• Thirteen
• Natural England
• Chartered Institution of Wastes Management and Institute of Materials, Minerals and Mining
• Humanist Climate Action
• The Heritage Alliance
• Farm partnership
• Association of Environmental Clerks of Works
• Greener UK
• The Institute of Historic Building Conservation
• ADEPT
• Woodland Trust
• Pupils 2 Parliament
• Food and Drink Federation (FDF)
• National Grid
• Institute of Environmental Management and Assessment
• The Law Society
• Game & Wildlife Conservation Trust
• arc21
• Aldersgate Group
• Royal Town Planning Institute (RTPI)
• The Royal Institute of British Architects
• FCC Environment
• Kent County Council Heritage Conservation
• Dorset Catchment Partnerships
• United Utilities
• Barnsley Metropolitan Borough Council
• Chartered Institute for Archaeologists & Council for British Archaeology
• Environmental Protection UK
• Sandwich Environment Conservation Group
• Dorset Local Nature Partnership
• Environmental Services Association
• Mineral Products Association
• Lancaster City Council
• Cut Carbon Not Forests Coalition
• The Society of Motor Manufacturers and Traders
• Southern Water
• Doncaster Council
• Sustain: The Alliance for Better Food and Farming
• Royal Society of Biology
• The Law Society of England and Wales
• The Crown Estate
• Cosmetic, Toiletry and Perfumery Association (CTPA)
• Anaerobic Digestion and Bioresources Association
• Institute of Economic Affairs
• Watlington In Bloom
• Bioabundance Community Interest Company
• Royal College of Physicians
• South West Water
• The National Trust
• Hale Village
• South Yorkshire Waste Partnership
• Chartered Institute of Ecology and Environmental Management
• SSE
• Aberdeen University Centre for Energy Law (AUCEL) members Mary Gilmore-Maurer, Professor Abbe Brown, Dr. Daria Shapovalova, Professor Roy Partain
• Arup
• Honor Frost Foundation (HFF) Steering Committee on Underwater Cultural Heritage
• Bat Conservation Trust
• Brighton and Hove City Council
• National Sheep Association
• Arcadis
• EDF Energy
• Client Earth
• Federation of Small Businesses
• Local Government Association
• ScottishPower
• Landscape Institute - Inspiring Great Places
• Queenborough LitterAngels Animals’ Champion and the Tree-Planting Cost Savings Detective Agent
• Make UK
• UKELA (UK Environmental Law Association).
• Friends of the Earth
• Energy UK
• CIWM and IOM3
• Environment Agency
• West Suffolk
• The Law Society of Scotland
• Clean Air London
• National Farmers Union
• Ilkley Civic Society

Appendix B – Interim Office for Environmental Protection’s advice on the environmental principles policy statement

The Interim Office for Environmental Protection was set up in a non-statutory form in July 2021 in advance of being legally created as the Office for Environmental Protection in November 2021. Its advice on the environmental principles policy statement was published in July 2021.