Welsh Government consultation

Proposals for a Sustainable Development Bill

Response from the Higher Education Academy

July 2012

Contact: Simon Kemp, Academic Lead (Education for Sustainable Development),

The Higher Education Academy (HEA) champions excellence in learning and teaching in higher education. It is committed to improving the student learning experience by raising the status of teaching, adding to the body of knowledge relating to pedagogy, enhancing professional teaching practice, and facilitating networks and communities of practice. The HEA works in partnership with institutions, student bodies, academic and professional staff, and sector agencies and funders.

The HEA has been working with the UK higher education sector on Education for Sustainable Development (ESD) since 2005. Its work on ESD helps institutions and subject communities develop curricula and pedagogy that will give students the skill and knowledge to live and work sustainably.

The HEA welcomes the opportunity to respond to this important consultation. The HEA’s response primarily addresses the overall consultation document rather than the individual questions listed on pages 53 to 56. Brief responses to some of the specific consultation questions are provided at the end of the HEA’s substantive response.

The HEA believes that the consultation document is a welcome contribution to the political pursuit of sustainable development. The HEA notes that Wales is recognised in the higher education (HE) sector as a leader in sustainable development policy and practice. This should be highlighted and celebrated in the Bill and its launch if implemented.

The HEA supports the primary purpose of the Bill to make sustainable development the central organising principle of the Welsh Government and Welsh public bodies. This is an admirable and adventurous policy approach which will be widely applauded across the sustainable development community – and for HE in particular, the ESD community.

The HEA is disappointed at the paucity of education within the document given the widespread recognition of the importance of education to the achievement of sustainable development. For example, the current United Nations Decade of Education for Sustainable Development is a demonstration of the importance placed on education by the UN through the work of UNESCO.

Education is addressed in the consultation document in terms of safety and health, but there is no mention of the value of primary, secondary or tertiary education for sustainable development. This is a disappointing reversal considering the leadership offered by the Welsh Government in 2006 through the publication of ‘Education for Sustainable Development and Global Citizenship – a strategy for action’, its 2008 update, and the inclusion of ESDGC in the school curriculum. In relation to this latter work, the HEA has facilitated the ESDGC working group which has expert input from ESD academic researchers and practitioners from each Welsh University[1]. Policy initiatives such as these have led to the Welsh Government being hailed for their progressive leadership in ESD andthe HEA believes that the continuation of this leadership in education is important to the successful implementation of a sustainable development bill. The HEA also believes it is important for there to be direct reference to ESDGC within the bill, including a requirement for statutory delivery of ESDGC across primary, secondary and tertiary education.

The HEA suggests reference is made to tertiary education in point 90 of the consultation document. The research outputs from universities have a valuable role to play in the provision of evidence informed decision making and havea potential wider impact on the economy, society, and the environment. Universities also have an important role to play in the creation of graduates literate in sustainability who are equipped with the key behaviours outlined as long-term thinking, integration, working across organisational boundaries, focusing on prevention, and engaging and involving stakeholders. The HEA has supported institutions in the development of ESD learning and teaching strategies to develop these skills – for example through its funding of NUS research into student attitudes to ESD[2]and facilitation of an ESD Policy Think-tank[3]. The HEA believes that the failure to recognise and include tertiary education in the Bill will make progressive sustainable development thinking and behaviours more difficult to achieve.

The HEA believes that there is scope for the inclusion of ESD as one of the Sustainable Development Objectives set out at point 92. This would enable the development of links between HE, policy-makers, local authorities, the Welsh government and business in order to facilitate evidence-based decision making and encourage futurity.

The HEA welcomes the inclusion of the list of organisations at point 120, in particular the inclusion of ‘Higher and Further Education organisations’ and ‘HEFCW’ considering the previous exclusion of higher educationfrom the earlier parts of the consultation document.

The HEA would welcome a legal definition for Sustainable Development and believes this will be of great value to organisations working in the HE sector. A legal definition consistent with the current, widely accepted, definition is important (point 127). However, the definition as set out in the consultation documentrefers to 'respecting limits' rather than an obligation to 'work within limits'. Sustainable Development requires a recognition that it is not acceptable to simply ‘respect limits’, it is vital to work within limits. To allow otherwise through ‘observing’ or ‘respecting’ will lead to a failure in sustainable development. This proposed word change is therefore put forward as an important consideration for the Welsh Government. However, if the agreement of a definition is not possible within the current available timeframe, this should not be allowed to prevent publication of a Sustainable Development Bill. Instead, the definition could be agreed as part of a regulatory framework within a specified time, preferably less than a year.

Responses to specific questions

Question 29: The HEA suggests that the HE sector should be represented within the ‘expert advice and guidance’ model.

Question 31: The HEA is in broad agreement with the proposed functions for a new body to be established on a statutory basis. However, it believes that, in order to accurately assess HEI submissions on how they are meeting the Sustainable Development statutory duty, the HE sector needs to be represented on the statutory body. The HEA also considers it important to have access to SD expertise from the HE sector when required to make representations. However, the member(s) of the statutory body would be excluded from the selection process when the body commissions research. The HEA would also welcome over-arching, independent scrutiny from the Sustainable Development commissioner, as it is not considered appropriate for this role to be purely advisory.

Question 32:The HEA believes that a duty for all primary, secondary, and HE and FE institutions to report on their ESD activities is required for the new statutory body to be successful. These submissions could then be assessed by the education representatives on the statutory body or selected associates.

[1] The ESDGC Working Group is submitting a response through the Chair, Dr Carl Peters.

[2]

[3] the report will be published soon and available from