6.1 Summary and General Observations

In this submission, we have developed in some detail the principles which should underlie an ecologically sustainable society as well as some of the general policy issues which need to be addressed. In this section, we examine the Commonwealth discussion paper from the point of view of the framework of ideas and concepts that we believe should underpin ecologically sustainable development.

Section 6.1 provides a summary and overview of our critique of the discussion paper. Section 6.2 et seq provides a detailed commentary on the Commonwealth paper, with a view to highlighting the major concerns we have about much of the paper's content.

6.1.1 Overview

Flawed Conceptual Framework

The framework adopted in the discussion paper for defining ecological sustainability is flawed, in that the principles adopted are not sufficient or adequate to achieve ecological sustainability. The flawed conceptual framework leads to a biased analysis in the discussion paper. This is evidenced by the fact that the paper seeks to integrate environmental concerns where these are reconcilable with economic demands, but where they are not, environmental concerns are sacrificed "to ensure present and future economic benefits".

The conceptual framework adopted in the Commonwealth paper is inadequate to the task of achieving ecological sustainability, and is biased to current economic policies.

Marginal Approach to Policy Changes

The discussion paper assumes that only marginal changes to economic policy will be needed to achieve ecological sustainability. There is a strong sense throughout the paper that ecological considerations are an optional, 'add on extra' to economic policy. Ecological considerations are secondary to traditional "growth" objectives.

The discussion paper essentially assumes that historic patterns of economic activity and growth must continue into the future, and does not question this assumption. Whilst some acknowledgement is made of "the need for some changes in the pattern of resource use, improvements in the way in which air, land and water resources are used...", the overall emphasis of the paper is that no major changes in policy will be required.

Reference to the need for the Australian economy to undergo "far-reaching restructuring unless our material living standards are to decline" is in the context of current economic policy, rather than an acknowledgement of the need for restructuring to occur to put the economy on an ecologically sustainable basis. The emphasis on further resource processing is locking Australia into a policy position with grave risks.

Confusion of Means and Ends

The government's discussion paper confuses economic means with social and ecological ends.

The government's paper emphasises enhancement of material living standards as an objective. This is an illogical approach, as the desirable level of material living standards would be an outcome of the desired quality of life, not vice versa. It may be entirely feasible for material living standards, defined as per capita resource consumption, to decline whilst overall quality of life improves.

Emphasis on Production

The discussion paper emphasises the production side of the Australian economy, rather than the overall patterns of consumption and life style that lead to ecologically unsustainable outcomes. Such an approach is unreasonable, and biases the policy debate in favour of the status quo. Most environmental problems relating to pollution and waste are intimately linked to patterns of consumption and are often most efficiently controlled at the level of end-use. This is in contrast to the Dutch NEPP which emphasises an end-use and life-cycle approach to pollution reduction and waste reduction.

The government has assumed that "there will be the need for more value-added processing of our natural resources", rather than putting this up as an issue for debate. The level of intensity of use of natural resources is a fundamental parameter in the achievement of ecologically sustainable development.

Failure to Set Targets and Goals

The government has not set targets or specific environmental goals in its discussion paper. Without such goals, it is difficult to focus attention on the kinds of measures needed to achieve environmental objectives. Sufficient information exists in a number of areas which would have enabled the establishment of at least interim targets for pollution reduction, energy efficiency, recycling of materials and greenhouse gas emissions. The failure to set targets is in contrast to the Dutch NEPP, which established a variety of goals for reducing material resource consumption and waste.

Omission of Population

Population and per capita resource use are omitted as a serious policy issue in the paper. Population policy has a crucial role to play in determining the ultimate level of impact of any given society on its environment and natural resources.

Parochial Outlook

The discussion paper takes a decidedly parochial outlook on the ecological sustainability debate. Many of the policy measures proposed are almost entirely self-serving, and omit a consideration of broader global issues.

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6. l .3 Policy Stance

The policy stance evidenced in the Commonwealth discussion paper is extremely weak. Few policy targets are set out, no goals are established and there is little commitment to anything more than the status quo in economic policy.

The Commonwealth approach is in stark contrast to the kind of policy stance that is taken by the Dutch government in its National Environment Protection Plan. At the outset, this plan acknowledged the need to reduce material resource consumption and waste, and sets a range of targets which could be achieved through a variety of mechanisms. The Commonwealth discussion paper is extremely vague about these things, and could be read as contemplating a significant increase in the rate of material use in the Australian economy.

There is little or no commitment to developing an adequate means for measuring progress towards sustainability. Traditional measures of economic growth are assumed congruent with measures of human welfare, a position which is entirely inadequate. Possible approaches to measuring natural resource depletion and incorporating such measures as part of, or satellite to, our conventional economic National Accounts are rejected, in spite of viable alternatives.

In general terms, questions are raised about the overall intent of the Commonwealth discussion paper. The term "ecological" appears to have been tacked on very much as an afterthought. Little serious consideration appears to have been given to its implications. The content of the discussion paper itself reflects an adversarial process within the govemment departments that were involved in its preparation.

There is a need to be mindful of the previous Commonwealth government processes attempting to reconcile economy and ecology. The National Conservation Strategy of Australia is a case in point. After an extensive process in which environmental organisations generally felt marginalised, a National Strategy was agreed to which heavily emphasised the utilisation aspects of the natural environment, as opposed to conservation. Perhaps more importantly though, most of the priority national actions identified in the NCSA have not been addressed. In other words, an extensive process involving a high level of commitment of time and energy resulted in a document that was never really implemented.

The Commonwealth discussion paper and proposed sectoral committee process appears to lack clear definition of objectives, a clear policy framework and a clear relationship with government policy processes and other relevant agencies.

The government discussion paper almost totally fails to acknowledge the need for a whole lifecycle approach to products in the market place in order to minimise the use of resources and the production of pollutants. This is evidenced by the failure to acknowledge the need for demand side measures to limit and reduce the use of resources such as energy produced from fossil fuels, basic metal products, plastics and a host of other materials used in a modern industrial economy.

The final concern we wish to mention here, in relation to the general policy stance of the discussion paper, is the goverment's promise not to withhold approval for development projects whilst the sustainable development debate is underway. The same guarantee has not been given for policy options and commitments which would, by any view, assist in the development of an ecologically sustainable economy.

There appears to be a significant risk that the govemment could hold off action on issues such as climatic change policies, an Environmental Protection Authority, national regulation of energy efficiency and so on, until policies on ecologically sustainable development are worked out. In the meantime, important investment decisions are being made that further entrench historic patterns of ecologically unsustainable activities. There is a risk, therefore, that opportunities for concrete action to achieve sustainability could be delayed, lost or eroded in the course of a longwinded debate over sustainability.

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