Environmental audits in local government: a useful means to progress in sustainable development

Feature article

Environmental audits in localgovernment: a useful means toprogress in sustainable developmentLinda Lewis

Abstract

Criticisms have been made about the proliferation of ‘audits’ in non-fin-ancial contexts and in particular about environmental audits with con-cerns for a lack of objectivity and their encouragement of (non)-pro-fessional expertise (Power 1991, 1994). Much of this criticism is rootedin accounting meanings of audit and is usually drawn from experiencesin the private sector. Using a longitudinal study of environmental audits inUK local authorities, this paper investigates the potential of environmentalaudits to be socially useful in their roles of ‘enabler’ and ‘evaluator’ aslocal government responds to pressures from central government to makeprogress towards sustainable development.

IntroductionIn a deliberate attempt to avoid the problems of corporate account-ability, this paper focuses on local authorities under the assumption(admittedly perhaps naively) that local government will be aware of,and concerned with, local needs, local stakeholders and the resultingnotions of accountability. ‘Accountability’ is percieved here as an essen-tial part of the reflexive relationship between local government andlocal stakeholders in terms of the former’s actions and the latter’s needs.Any communication between the two parties is thus a form of enactingthis (social) accountability relationship. The choice of the public sectorwas further strengthened by Gray and Bebbington (1998) who assertthat sustainable development should not be left in the hands of business.It seems worthwhile therefore to investigate the potential of localgovernment to make better progress on this important issue with theenvironmental audit as a possible aid to enhancing participative democ-racy through informing the relevant publics (see, for example, Wittig,1996; Perkins, Brown and Taylor, 1996; Boggs, 1997; Neu, Warsameand Pedwell, 1998). At the same time, data derived from a study ofenvironmental audits in local government and analysed in the paper,sheds some light on the changing implications of accounting and com-

Correspondence should be addressed to Linda Lewis: University of Sheffield, Man-agement School, 9 Mappin Street, Sheffield S1 4DT, UK. email: L.A.LewisKsheffield.ac.uk

Blackwell Publishers Ltd. 2000, 108 Cowley Road, Oxford OX4 1JF, UK and 350 Main Street, Malden,MA 02148, USA.

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munity which become more apparent as our understanding of thechanging state of the natural environment develops (see Dryzek, 1996).It is pertinent at this point to explain that ‘environment’ in the paperis being interpreted in a much broader sense than ‘the physical’. In com-mon with a number of other writers social, or rather eco-justice con-cerns, are regarded as an important part of environmental issues (Owenet al, 1997), physical environmental effects impacting on the quality oflife in societies and vice versa (Galhofer and Haslam, 1997). If thisbroader interpretation of ‘environment’ is acknowledged, there seems tobe a link between environmental audits and moves towards sustainabledevelopment in local government that is worth exploring.

The interest in ‘audit’ for this purpose is similar to that of Humphreyand Owen (2000, p31) when they suggest that audit can be viewed associally useful if it leads to ‘doing’ (sic) rather than being perceived as‘checking’ (sic). Another reason for investigating environmental auditin local government is, paradoxically, to both accept and reject Power’s(1994) criticism of (environmental) audit. He maintained that thenotion of environmental auditing (and indeed other types of audit) con-ducted by people external to the organisation for the purpose of ‘credi-bility assessment’ had been replaced by audit taking a ‘managerial turn’.As the paper will show this observation bears some resemblance to theway in which environmental audits developed in UK local authorities.Power’s concern with such managerialism was that management policymakers were being made guardians of the environment where once theyhad been regarded as perpetrators in its degradation. Such concernmight be relevant in a private sector context, but whilst local authoritiesare not completely blameless, would seem to be a weak argument whenapplied to local government. The paper serves, therefore, to supportHumphrey and Owen (ibid) who assert that while Power has made avaluable contribution to knowledge in questioning the pervasiveness ofaudit, more work needs to be done to understand the role of audit incontemporary, and more importantly in non-accounting, contextswithin society. In other words, to not perceive ‘audit’, in its managerialguise, as necessarily negative or lacking in social usefulness.

It must also be clear, even at this early stage, that there is an assumptionin the paper that local government can have an influence on actiontowards sustainable development in local areas. This is not merely wildoptimism. It is supported by a number of White papers in recent yearsemanating from UK central government compelling local authorities toplan and work towards sustainable development. These initiatives areoutlined below and make it apparent that in terms of policy making agreat deal seems to be expected of local authorities in the promotionof a national commitment to sustainable development.

The first part of the paper outlines some of the recent UK government

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White papers which have particularly affected local authorities and thedrive towards sustainable development. Attempts to ‘green’ localgovernment have been going on for a number of years, significantly,with ‘environmental audit’ often playing a prominent role. Thus thepaper will also outline some of these earlier initiatives. This, relativelybrief, history is useful in highlighting the changing but pervasive natureof environmental audit. However, while there have been studies,notably, for the Local Government Management Board (Tuxworth andThomas 1996) which have periodically tried to ascertain the type of‘green activities’ local authorities have undertaken, there have been fewlongitudinal studies of the extent and practice of environmental auditin local authorities. The second part of the paper addresses this situationproviding an analysis of a study covering a five year period in order tobetter understand the contribution of environmental audit to the formu-lation of green policies in UK local government. As a country, the UKis not alone in making a national commitment to sustainable develop-ment. It is hoped therefore, that though the paper is written from a UKperspective, there may be lessons to be learned for comparative workto be conducted in other countries who are similarly developing localinitiatives for sustainable development. Using the previous analysis, thefinal part of the paper concludes with the implications for the futureof environmental audits in light of the social and political pressures forprogress to be made towards sustainable development given the insti-tutional structures that currently exist.

The ‘greening of local government’ andlegislative developments for sustainabledevelopmentFrom the late 1980s, environmental audits seem to have been implicatedin the activities of UK local authorities as they have responded to aseries of pressures to be more environmentally responsible. Notableexamples of such pressure are the Friends of the Earth (FoE)’s Charterfor Local Government (1989) which provided a framework for environ-mental auditing and the Local Government Management Board(Jacobs,1991) which issued detailed guidance on environmental audits.Such encouragement for environmental audits was followed by the Eur-opean Union’s Eco-Management and Audit Scheme (EMAS). After theRio Earth Summit in 1992 and the promotion of Local Agenda 21,central government encouraged the adoption of EMAS within localgovernment, local authorities being perceived to have the power, or atleast the means, to influence and reflect the values of local people. Thuslocal authorities may be in a better position than central governmentto make progress on sustainable development owing to the more directrelationship with local communities. As the longitudinal study under-



taken will show, a range of initiatives have been adopted by local auth-orities in the drive for sustainable development with environmental aud-its present to a greater or lesser extent in many of them.

Using the earlier reference to ‘doing’ and ‘checking’ provided byHumphrey and Owen (ibid), an environmental audit is a means fororganisations to both assess the environmental impact of their activitiesand to monitor the results of any environmental improvement pro-grammes they decide to enact (Gray and Collinson, 1991). In this sense,if environmental programmes are designed to achieve sustainable devel-opment then environmental audits can be conducted to monitor theimpact of such programmes. Admittedly, environmental audits conduc-ted by local authorities in the early 1990s were not designed with sus-tainable development in mind but were part of a range of initiativesdesigned for the greening of local government. Sustainable developmentemerged as a specific objective to pursue a few years later when socialand economic concerns were recognised as inextricably linked withthose of the environmental.

In fact, the earliest evidence of an environmental audit, within localgovernment, came in the form of an Association of Metropolitan Auth-orities (AMA) document titled ‘Action for the Future: Priorities for theEnvironment’ (1989). The document represented the first local govern-ment policy audit covering the environment. It has been credited withmaking a useful contribution to putting local issues into a national con-text (Ball and Wright, 1991) though it was designed more for sendinga message to central government than to guide local authorities. In theyear following ‘Action for the Future’, FoE defined environmental auditas the means:

‘to assess the current state of the local environment, the factors affect-ing it and the environmental impacts of local authority policies. It isto be used as a baseline against which to assess the progress of localenvironment policy and practice.’ (1990, p. 1)

The FoE’s ‘Charter for Local Government’(ibid) recommended that alocal authority examine each department and identify the range ofactivities and how they impact upon society. The guide provided byFoE, proved popular with many local authorities, some adopting it sec-tion by section and others adapting only parts of it (Ball and Wright,1991). Its merit was clearly that some detailed guidance arose for localauthorities to follow at a time when limited direction was available.The notion of ‘environmental audit’ as a means of greening localgovernment, also became formalised at this time by the publication of adocument entitled ‘Environmental Practice in Local Government’ (LocalAuthority Associations, 1990). The document highlighted examples ofgood environmental practice and contained a chapter explaining why


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environmental audits were necessary, what they consist of and how toconduct one.

Attempting to combine the approaches of both the AMA and the FoE,the LGMB (1991) promoted two principle forms of environmentalaudit; an assessment of the local environment, resulting in a State OfThe Environment report (SOE); and a Policy Impact Assessment (PIA),consisting of a review of the objectives, policies, services, practices,structures and procedures of the authority itself and their effect on theenvironment. No external verification was suggested by the LGMB butthere was an encouragement to make the resulting SOE or PIA reportsavailable to the public. The significance of verification is that ‘audits’are usually associated with some sort of independent validation. Forexample, financial audit is part of the means of ensuring accountabilityby managers to principal stakeholders. The definition of environmentalaudit outlined above, when associated with local authorities, equallyimplies the role of accountability even if financial accountability is notthe primary purpose. The LGMB felt it important that local authoritiesmake visible the progress of local environment policy and practice. Ifsuch progress has been assessed through conducting an environmentalaudit then it might be presumed that external verification of the under-lying processes would also be necessary if ‘accountability’ to the localelectorate is to be fulfilled. Significantly, in this respect, such verificationdid not seem to be regarded as an essential requirement. However, laterdefinitions of ‘environmental audit’ stressed the need for verification aspart of the adoption of environmental management standards such asBS7750, ISO14001 and EMAS.

Given the early guidance on auditing, it is not surprising that earlyforms of environmental audits in local authorities tended to be mostlyreviews of the state of the environment with ‘accountability’ notablyabsent. Of significance, however, is that the term ‘audit’ was used todescribe them. Context is important here and Renger (1992) providesan insight to this when he describes how the word ‘environmental audit’had been hijacked to describe a wide range of procedures and docu-mentation which did not conform with ‘audit’ as portrayed in financialaccounting terminology. Indeed, Power has also commented on the pro-liferation of audit that occurred at this time (1994 and 1997a). Yet ithas to be acknowledged that such criticism, particularly from the pos-ition of the two authors, is based on notions of ‘audit’ in a financialsense which conflicts with the interpretation promoted by Jacobs onbehalf of the LGMB when he noted:

It is sometimes supposed that an environmental audit is like a financialaudit, only using environmental rather than monetary criteria. This iswrong. A financial audit is a verification that an organisation’saccounts are accurate, and must be conducted by an external body.



An environmental audit is not a check for accuracy: on the contraryit is more like a compilation of the environmental accounts themselves.And it need not be conducted by an outside body. (1991, p. 9)

At first sight there is a problem with this definition if ‘audit’ is to fulfilthe requirement of accountability. The LGMB promoted environmentalaudits as tools for internal use which would entail monitoring the localenvironment and making decisions on how to proceed. The audits werenot regarded as a means of informing the local electorate as to howenvironmental improvements might be achieved and/or promoted in thelocality generally and by all stakeholders. Rather it concentrated on theenvironmental state of the local authority as a way for management toidentify environmental problems and the need for action. Such practicesare a good exemplar of Power’s (1994) description that audits, such asthose of the environment had taken a ‘management turn’. However,these forms of environmental audits were often the preliminary stage ofa process of development towards environmental management decisionmaking. Local authorities could then begin to devise policies and todevelop environmental programmes.

Significantly, after the early encouragement to local authorities toundertake environmental audits, and in common with developments inthe private sector, the next vogue was to promote the use of environ-mental management systems (EMS) as a way forward (LGMB, 1993and 1994a). The development of EMS in local authorities has alsoattempted to encourage a change in corporate philosophy so that theenvironment is considered throughout council policy (ibid). Whilst notmandatory requirements, nor targeted specifically at the public sector,the significance of a number of standards for EMS developed in the1990s, is that most incorporated an ‘audit’ element. The standards,again, do not appear to have been designed with ‘accountability’ as anobjective. For example, many of the standards allowed optional statusto the external reporting of the results of the audit conducted to signifythat an EMS was in line with predetermined environmental policy. Usu-ally, this was not required. Take for example, British Standard 7750(BS7750) drafted in 1992, which was one of the first recommendationsto combine the development of an EMS with audit. Essentially itallowed an organisation to ensure compliance with its own environmen-tal policies, objectives and targets by providing a structure to supportenvironmental reviews and audits. The standard demanded that anenvironmental policy be developed and used to generate environmentalobjectives, targets and programmes, which were all subsequently subjectto verification but required no external reporting of a verification state-ment.

The exception came in the form of EMAS in 1993 which was part ofthe European Union’s Fifth Action Programme:Towards Sustainability


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and brought external reporting a step nearer. EMAS actually brings thephilosophy of environmental audits much closer to that of financialaudits. The latter has been described as growing from the outsideinwards and attaching itself to systems while the former is said to growfrom the inside outwards, attaching itself to regulatory frameworks(Power, 1997a). The description seems appropriate given that environ-mental audits were initially promoted as a management tool which sub-sequently developed to incorporate external reporting and which isupheld by an EU regulation, albeit of voluntary status. Under Article14 of the regulation, experimentation in the form of a UK pilot tookplace and LA-EMAS was formally launched in UK local authoritiesin 1995.

Riglar in Sheldon (1997) describes how LA-EMAS was deemed to bethe most appropriate tool for local authorities to utilise as it provideda framework in which environmental management initiatives couldbecome fully integrated into the core business of local authorities. Moresignificantly, the public reporting element of LA-EMAS enabled localauthorities to demonstrate their commitment to Local Agenda 21,detailed below (Riglar,1997). Significantly, in contrast to that of privatesector organisations, LA-EMAS is more onerous for local authorities(Central and Local Government Environment Forum 1993). In the priv-ate sector, single industrial sites can register under EMAS as long asthe whole company has an adequate environmental policy in place. InLA-EMAS the registration of a single operational unit is only allowedif the authority agrees to implement a policy as well as a CorporateOverview and Co-ordination System. The council must also make a fullcorporate commitment within a specified timescale and treat the initialunit registration as an intermediate step only.

Under the full LA-EMAS initiative, policy and service delivery functionsare evaluated to ensure that all operations are effectively ‘greened’, toachieve benefits of cost savings, compliance with policy and legislation,improved service delivery and increasing staff awareness (LGMB, 1996aand 1996b). The requirement for periodic environmental auditing atleast every three years includes publication of an audit report and exter-nal verification. Most would argue here, that giving an account is notthe same as accountability (see, Power 1994, Owen et al 1997 andHumphrey and Owen 2000) but it has to be acknowledged that whilst‘audit’ as a management tool is perpetuated under LA-EMAS (orEMAS), there is the added objective of providing environmental per-formance information to the public (Hillary, 1994). This observationis a good example of the accountability relationship between‘accountors’ and ‘accountees’, (in this case local government and localstakeholders), as defined by Ijiri (1983, p. 76) when he states that insuch a relationship, accountors are expected to account for their activi-



ties to accountees. However, evidence from Sheldon (1997) and fromthe study detailed in this paper suggests that local authorities have usedEMAS only as a managerialist function in that EMS are audited butthere is little external reporting of an audit statement.

The reason for this seem to be that local authorities have preferred toadopt ISO14001, another form of environmental management stan-dard, launched in 1996 by the International Organisation Of Stan-dardisation (ISO). In common with LA-EMAS, ISO14001 specifies therequirements for an environmental management system and is subjectto certification by a third party but the process of certification is notmandatory and can be conducted internally. Environmental objectivesand targets are set with a view to adopting a programme in which toachieve these aims. Audit procedures are adhered to as the whole pro-cess is subject to review so that continual improvements can be made.Yet the position of ‘audit’ is more flexible than that required by EMASas it is only a suggested, rather than a compulsory, feature and shouldone take place, there is no prescribed audit frequency. Further, LA-EMAS requires authorities not only to publish a document containinga description of policy, programme and EMS but also an environmentalstatement including factual data. From the viewpoint of transparencyand accountability this is a positive aspect of LA-EMAS which is nulli-fied if, as it appears, a majority of local authorities appear to favourthe ISO series (Riglar, 1997). On the other hand the LGMB maintainsthat adopting the ISO14001 is a preliminary step in helping local auth-orities reach a stage where they are ready to commit to LA-EMAS. Ithas to be acknowledged, however, that ISO14001 gives managementmore control over the system as council officers clearly have discretionover matters of audit and their frequency, environmental statementsand the certification process. Too much flexibility in areas such as thiscould lead the framework into an arena where it is effectively capturedby those with vested interests to control which areas are exposed toscrutiny. In contrast, the stringency of LA-EMAS holds it in a primeposition to enable a local authority to increase the accountability andtransparency of environmental operations. If adopted, such anapproach would seem to typify the analogy of the audit achieving boththe ‘doing’ and the ‘checking’ in relation to environmental performance(Humphrey and Owen, 2000). Such developments show that althoughenvironmental audits were often undertaken as a first step by local auth-orities, they subsequently became a part of EMS with any reporting ofsuch environmental audits, to be deferred until everything was in place.This latter approach contrasts with the experiences of the private sector.Arguably, before companies report externally on environmental per-formance they need to develop environmental accounting method-ologies or EMS, to be followed by audit systems of evaluation which


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can then be reported on (UNEP/Sustainability, 1996). Conversely, manycompanies, have often started reporting before appropriate environ-mental accounting and management systems have been developed. Theresulting environmental reporting therefore, representing more of ‘anaccount’ than ‘accountability’ and perhaps explaining why there havebeen criticisms that corporate environmental reporting has been failingto meet ‘accountees’ needs (see, UNEP/Sustainability, 1996, Deegan andRankin, 1996).

Local agenda 21 and sustainabilityExplaining the ‘greening’ of local authorities and the pressure for auditwould not be complete without reference to another significant develop-ment in the 1990s; that of LA21. Owing to a national commitment tosustainable development, local authorities have had to deal withdeveloping strategies for the implementation of LA21. The catalyst foraction came in 1992 at the Earth Summit in Rio de Janeiro when UnitedNations leaders committed themselves to a plan of action for sus-tainable development referred to as Agenda 21. Chapter 28 of thisdocument was specifically aimed at local authorities, the reasoningbeing that local authorities were deemed to be the level of governanceclosest to the people. Who better, therefore, to play a vital role in edu-cating, mobilizing and responding to the public to promote sustainabledevelopment? LA21 was suggested as a mechanism to develop strategiesfor sustainable development in local areas. Thus LA21 is the processof drawing up and implementation of local sustainable developmentplans by the local authority working in partnership with all sectors(stakeholders) in the community. It must be recognised that LA21 isan evolving process. There is no standard document or activity as anyachievement of sustainability will depend on the specific local prioritiesand local circumstances. Authorities must work in partnership withbusiness and all representative groups of people in their local environ-ment to share information and expertise in order to properly progressthe agenda. The LGMB, now renamed the Improvement DevelopmentAgency (IDA), has had a strong influence in this work providing guid-ance, training materials and networking opportunities to support andfurther local government initiatives. The term ‘putting its own house inorder’ was often used by the LGMB (1993 and 1994b) to describe thecontribution of a local authority to the community partnership whichunderpins the notion of LA21. One way to facilitate this is through thedevelopment of an EMS with ‘audit’ required to monitor the workingof the EMS and to assess the achievement of it’s objectives.

This would explain why the Audit Commission (1997) deemed LA-EMAS to be the cornerstone of LA21 when it published a report entitled‘Local Government’s Role as a Steward Of The Environment’ assessing



the progress of local authorities in some detail. Of significance in high-lighting the importance of local authorities, the Audit Commission out-lined their considerable powers to influence the community through acouncil addressing its own activities in the provision of services (anotherexponent of ‘putting its own house in order’), and through their regulat-ory and enabling roles. ‘Environmental audit’ would seem, therefore,to be heavily implicated in LA21.

Related influences and legislative developmentsAdditional pressures and encouragement to adopt LA-21 come fromnumerous initiatives nationally and internationally. Their significanceis that LA21 seems to have become the primary mechanism for the‘greening’ of local government. Internationally, the ‘UN’s ‘SustainableCommunities Project,’ ‘The International Council For Local Environ-ment Initiatives’ and ‘The European Sustainable Cities and Towns Cam-paign’ (Aalborg Charter) all help promote and facilitate LA21. Nation-ally and internationally there is a constant flow of legislation beingproduced resulting in increased obligations having to be met by compa-nies and public organisations alike, (e.g. increasing taxes on landfill,legislation on air quality through the Environment Act 1995). For localauthorities in particular, legislation on pollution control, waste manage-ment, land use planning, transportation and environmental health inrecent years has increased the emphasis on their regulatory functions.Such legislation is part of a national strategy for sustainable develop-ment which the government produced in 1994 (HMSO). Three yearslater, the LGMB (1997) ascertained that 73% of UK local authoritieshad committed themselves to LA21 and that there had been an upwardtrend of implementation over the preceding two years.

This finding coincided with the Prime Minister setting a target that alllocal communities, should have strategies for LA21 in place by the year2000. A Department of Environment, Transport and Region (DETR)’spublication ‘Sustainable Local Government for the 21st Century’(1998a) provided guidance in this respect making clear what thegovernment expects local authorities to do in order to meet the LabourGovernment’s national target that all local authorities have LA21 stra-tegies in place by the year 2000. Thus since 1997 (even though therewas a change of government in the UK) there has been a number ofinitiatives from central government to ensure that progress is madetowards national sustainability, making LA21 and potentially EMAS,even more of a priority for local government. For example, building onthe 1994 national strategy for sustainable development, the current UKgovernment wished to develop a new strategy and prepared a consul-tation document, ‘Opportunities for Change’ in 1998 (DETR, 1998b),owing to a concern that the 1994 strategy did not incorporate a social


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dimension. The 1998 document was an attempt to strengthen the strat-egy and add social and economic concerns to those of the environmen-tal. Whilst these national strategies are not solely focused on local auth-orities, the latter’s role is acknowledged through LA21 activitiesparticularly in a recent White paper, ‘A Better Quality of Life’ (DETR1999) which sets out fourteen quality of life indicators to assess howwell the nation is doing in achieving sustainable development.

The use of performance indicators to assess progress in sustainabledevelopment is not a new idea. It was suggested in work undertakenby the Audit Commission (1997) which resulted in the ‘EnvironmentalStewardship’ document. Perhaps it was inevitable that some kind ofperformance criteria in the area of sustainable development would bedeveloped and come under regular scrutiny and public exposure as hasclearly been the intention of central government since 1994. Such devel-opment, however, echoes the assertion of Humphrey and Owen (2000)that there is evidence of a performance measurement society (ratherthan an audit society) at work (p. 43). On the other hand it also offerssupport to Power’s (1994) assertion that things, in this case sustainabledevelopment, are being made ‘auditable’ in society which by implicationallows audit to proliferate. Whether this is ‘good’ or ‘bad’ depends uponwhat purpose the audit serves. For example, it would be positive if theenvironmental audit results in progress towards sustainable develop-ment, but unfortunate if the audit was used to validate the use of certaintypes of performance measures or the system of performance measure-ment per se.

Finally, another White paper which upholds the work on LA21 is thatof ‘Modernising Local Government: In Touch With the People’ (1998c).Legislation to implement the proposals is currently making its waythrough Parliament in a new Local Government Bill. Significantly, atthe heart of the proposals is the duty for local authorities to promotethe economic, social and environmental well-being and sustainabledevelopment of their areas (Pinfield 1999). Work on LA21 strategies iscited in the White Paper as it requires the instigation of communityplanning by councils. In addition councils will have to show, and indeedbeacon councils will be used by way of examples, that they areresponding to their local communities, have modern management struc-tures and have a successful best value regime (Pinfield, ibid). The mostprominent feature is that of involving local citizens in community plan-ning, albeit with a corporate managerialist structure to overseeimplementation of the community plans which must clearly promotelocal sustainable development. The reference to best value, is importanthere. The Local Government Bill is replacing the old compulsory com-petitive tendering (CCT) for the provision of services for best value,which means placing the onus on local government to prove that it is



delivering best value services (DETR, 1998d). Concern that best valuepractices may divert attention away from developing strategies forLA21 are allayed by the belief that there is scope for integrating thepractice and philosophy of sustainability with best value if the dutyto ensure social, economic and environmental well-being provides thecontext (Wright, 1998). Additionally the LGMB (1998e) has preparedpreliminary guidance on how to integrate best value and LA21 suggest-ing that the two are “all part of making local government more effectiveand responsive to the needs of communities” (p. 1).

Environmental audit practice and relatedactivities

The UK studyThe preceding summary of initiatives relating to environmental auditingserves to illustrate the progressive developments for the ‘greening’ oflocal authorities since 1989 and should put the following analysis ofenvironmental audits into better context. It confirms that the early aud-its were promoted for internal use rather than for external reportingpurposes and were reviews to assess the current state of the localenvironment. The longitudinal study undertaken, which dates back tothe early 1990s, attempted initially to ascertain how many local auth-orities had conducted environmental audits, what form of audit hadtaken place and what purpose were they serving. In other words werethey socially useful in improving the environment.

The county and borough councils in England and Wales were contactedin 1993, asked if they had conducted environmental audits and askedto provide a copy of their resulting audit reports. Given the voluntarystatus of environmental auditing and the developments outlined abovethis became somewhat problematic. For example, local authorities didnot have to conduct environmental audits, there was no particular legis-lation to compel them to develop environmental strategies. They hadto comply with legislation dealing with waste and air emissions but norigorous reporting requirements were in place. Thus it appeared thatlocal authorities responded to soft but subtle pressure to improve theirlocal environment in different ways, with different rates of activity andwith varying levels of transparency or methods of communication.Counting the number of environmental audits was not that meaningfulas some authorities were developing and implementing strategies foraction without the assistance of an audit. It also became clear that someauthorities who stated that they had not conducted environmental aud-its would then provide a Statement of the Environment report whichfitted the LGMB’s definition of an environmental audit. The significanceof this particular finding is that the local authority concerned had not


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thought of its SOE as an ‘audit’. More significantly, it was important,to examine any form of documentation provided and read carefully thetype of work that had been undertaken and where possible the reasonswhy such work had taken place. For example, many local authoritieswould refer to an audit as a starting point for developing an environ-mental strategy.

Given that there was some ambiguity surrounding the nature ofenvironmental audit work undertaken it became necessary to ask localauthorities what environmental initiatives they were adopting and howthey communicated their actions with the local community. When firstcontacted in 1993, a number of local authorities indicated they werein the process of conducting an environmental audit but reports werenot yet available, or they had intentions to conduct environmental aud-its. Audit reports continued to be collected as and when available, untila number of telephone interviews were conducted in 1997 and 1998to determine the stage of development each local authority had reachedand to ensure that no environmental audits were missing from theanalysis. Reports were requested from each council and have been usedto help analyse and evaluate the progress of their environmental agendaand of audit in particular. Since the initial contact in 1993, some localauthorities that indicated they were not going to conduct environmentalaudits had produced environmental reviews whilst others had com-pleted their audit processes or it would appear had not pursued environ-mental audits owing to other initiatives such as developing strategiesfor LA21. In other words, as the preceding analysis highlighted, localauthorities were responding to the evolving demands and pressures tomake progress towards sustainable development using whateverappeared to be the recommended mechanisms for doing so. Thus toensure completeness and reliability of the data collected, the period ofanalysis has been restricted to the five years between 1992 and 1997.This is not to signify that audit activity ceased after 1997 but it becamemore difficult to disentangle the environmental audits from other initiat-ives such as developing either strategies for LA21 or EMS. To highlightthe significance of these other initiatives and to show the difficulties ofobtaining complete information as local authorities tried to respond toa variety of demands in terms of sustainable development, it was neces-sary to record any efforts towards EMS, LA-EMAS or the pursuit ofLA21 as audit can potentially be involved in all three initiatives. In1998, it was ascertained that local authorities were continuing todevelop EMS and strategies for LA21. It was also established, thoughno documentation was provided to include in the analysis, that somelocal authorities were intending to pursue the full LA-EMAS. The analy-sis serves, therefore, to provide a pattern of activities which was con-tinuing even after the cut-off point.



Two final points about the analysis. Firstly, the study was complicatedby local government restructuring which entailed the disbandment of anumber of county councils as a controlling body and the creation of anumber of smaller and more localised unitary authorities. For example,as of 1 April 1996, Avon was divided into the four unitary authoritiesof Bath and NE Somerset, Bristol, N.Somerset and S.Gloucestershire.This restructuring was put in place by the previous government but theprogramme continued after 1997. The result was that the sample sizegrew between the start and end periods of the study, from 116 to 140local authorities. Table 1 provides a breakdown of these sample sizesover the five year period. Secondly, table 2 onwards reflect the numberof audits which local authorities, when contacted, said they had conduc-ted. The problem, and one of the points of the paper is that the resultingaudit reports were not always put into the public domain, they wereintended as an internal management device and it was, therefore, notpossible to examine all audit reports. Consequently, table 4 which sum-marises the content of the SOE and PIA reports refers only to thosethat were obtainable and which the local authorities were willing toprovide. A final point is that the analysis is based on the final sampleof 140 but refers to the development of environmental audit activityand related initiatives for the five year period.

Analysis of findings: the roller coaster effect ofaudit activity and other initiatives

Table 2 details the number of authorities that have conducted environ-mental audits in some form either as SOE, PIA or for EMAS purposes.Given the pressure on local authorities to adopt EMAS or EMS as away of facilitating or at least making a contribution to local agenda21 strategies, the table also provides an indication of the authorities’initiatives in this respect.

By 1997, 54 local authorities had undertaken an environmental auditwhich resulted in a report in the form of an SOE or a PIA. Only 5 wereat the early stages of introducing LA-EMAS and committed to obtainingaccreditation which requires regular audits of the EMS, publication of

Table 1 – Composition of local authorities in England and Wales

1992 1997County Councils 47 35Metropolitan Boroughs 36 36London Boroughs 33** 33**Unitary Authorities – 36*

116 140

*Includes Isle of Wight which has unitary county status**Includes City of London


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Table 2 – Environmental audits in the local authorities of England and Wales 1997

Some form of audit (A) No form of audit (B)S = 54 S = 86

No LA21/plans 1 11LA21 plans/strategies 24 38LA21/developing/piloting EMS 23 32LA21/EMS piloted and committed 6 5to accreditation (EMAS)Totals 54 86

an environment statement and some form of external validation. It maybe that those that were still developing and piloting an EMS will addexternal audit to the management process, however, the table is areflection of what was found up to the cut-off period and many statedthey were only interested in ISO14001 rather than EMAS accreditation.In relation to sustainable development, the table also highlights thatonly 12 local authorities had not yet developed any form of LA21 plansor activity. This compares with the findings of a LGMB (1997) studywhich ascertained that in 1996, 73% of local authorities wereimplementing strategies for LA21.

Thus for the period under review a clear pattern of audit activity wasobserved in local authorities. Environmental audits took place in theearly nineties, were downgraded as local authorities produced environ-mental policies and developed EMSs, rose again as an inevitable partof monitoring their EMSs, declined as authorities attempted to developstrategies for LA21 and may rise again as such strategies are put intoaction. This roller coaster pattern is there even if authorities were, andcontinue to be, at difference stages of development. Since the beginningof the nineties, over one third of the authorities have conducted eitherSOE or PIA forms of audit which involves taking stock of theirlocalities. More than half of local authorities were developing and pilot-ing an EMS. Regardless of which management standard is adopted,‘audit’, as either an initial review or a means of monitoring the systemto ensure adherence to predetermined polices, is a standard require-ment. LA21 provides the impetus for local authorities to tackle sus-tainable development. Significantly, the imperative to show that localauthorities are developing and actioning plans for LA21, has changedthe nature of environmental audit from an inward-looking perspectiveto that of it having an outward-looking focus. Whilst it would not beappropriate to state that environmental audit is the primary means ofprogressing towards sustainable development, it would seem to have auseful role in facilitating the process.

A further breakdown of the information in table 2 is provided in table 3to show how the initiatives, including that of audit, are dispersed across



Table 3 – Environmental initiatives in England and Wales, 1997, by category oflocal authorities

County Metro. Unitary LondonCouncils Councils Auth. Boroughs(S = 35) (S = 36) (S = 36) (S = 33)(A) (B) (A) (B) (A) (B) (A) (B)

No LA21 0 2 0 4 1 2 0 3LA21 only 12 5 7 11 2 13 3 9LA21 and EMS 11 1 7 5 0 17 5 9LA21/EMS and 4 0 1 1 0 1 1 3wants accred.Totals 27 8 15 21 3 33 9 24

S(A) = 54 S(B) = 86

the sample of county and metropolitan borough councils, unitary auth-orities and London boroughs. Within this table and those that follow,the (A) column signifies some form of audit activity, while (B) representsno form of audit undertaken in line with the totals in table 2. Thesignificance of the table lies only in that it reveals county councils arethe more advanced in having conducted some form of audit by 1997.Kent, for example, had produced a Sustainability Indicator Report andreferred to it as a SOE. Equally, by the cut-off date, nearly all the countycouncils had LA21 strategies.

For most categories the relatively lower number of local authorities thathad conducted audits can be explained by the lack of an imperative toconduct an environmental audit in contrast to the pressure for LA21strategies to be in place by the year 2000. It is worth noting that theprevious government specified 1996 as the target date for LA21 stra-tegies, the analysis above highlighting that local authorities were wellbehind government expectations. A possible explanation for this is ashortage of resources to develop plans, exacerbated by local authoritiesattempting to cope with restructuring and restrictions imposed by com-pulsory competitive tendering in the delivery of services. At this stage,Power’s warning that environmental audit is for management purposesonly and by implication makes little contribution towards transparencyand accountability appears validated. It should be remembered, how-ever, that local authorities have been responding, as best they could, toa variety of management standards and as indicated above, earlyactivity which involves reviews of the environment might be interpretedas only a preliminary step.

The swings and roundabouts of progress towardssustainable development

SOE and PIA type audits in the early 1990’s represented initial stepsinto environmental management for local authorities. They literally pro-


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vided many local authorities with a starting point to assess ‘where arewe now?’. Further examination of the resulting audit reports confirmsthem to be based mostly on existing data which was collected with theco-operation of various departments and organisations (see Boden etal, 1994). The amalgamation of data, which had not previously takenplace, is a clear advantage of the process.

In contrast to the intended aims of sustainable development which isto integrate environmental, social and economic issues, the early docu-mentation clearly concentrated on the environmental dimension. Areassuch as waste, air and water quality, conservation and transport forexample, constitute the very physical focus of early SOE reports whichare basically descriptive documents. Although more inward looking, thepolicy impact statements consider the authorities’ policies and theirimpact on the environment but use the same kind of descriptive basishighlighting areas of policy which enhance the environment and outli-ning potential areas where policy is still to be developed. The focus inPIAs is predominantly a physical one, there is no attempt to incorporateany social consideration such as crime or poverty. Concentration liesmore with energy saving policies and waste disposal though contem-plation of issues such as the importance of health and the need todevelop environmental education programmes. For the reason outlinedabove, only 44 out of a potential 54 of these early audit reports wereobtained from local authorities consisting of 30 SOEs and 14 PIAs.Table 4 details the topic areas which were identifiable from the auditreports which includes physical issues including air, water, waste, noise,energy, transport, radioactivity, and the countryside or nature; and twoforms of social issues. The first (1) includes education and health aware-ness in an attempt to incorporate the quality of life and the second (2)refers to an attempt to develop social awareness in the form of anti-poverty schemes or crime statistics.

Only one local authority has attempted to incorporate social awareness.This is significant on two fronts, that the SOE produced was referredto as a Sustainability Indicator Report and that it was produced at alater stage compared to some of the other reports in the sample. It isworth noting, however, that even an examination of LA21 docu-

Table 4 – Topic areas of a sample of SOE and PIA reports from local authoritiesin England and Wales

Type of Audit ReportSOE PIAS = 30 S = 14

Physical 25 13Social (1) 9 6Social (2) 1 0



mentation provided by the local authorities revealed that physicalenvironmental issues still appear to form the prominent parts of anynew initiatives. Transport and in particular congestion and air pollutionhave a considerable emphasis in the majority of the audit reports asdoes energy efficiency, recycling and waste minimisation, protection ofhabitats and land use. However, there are signs of authorities alsoattempting to address the competing notions of sustainability in a num-ber of council initiatives such as anti-poverty strategies, crime and qual-ity of life considerations. Incidentally, as evident in other docu-mentation obtained for the period, the linkage of environment issueswith employment, health and housing was addressed in a number ofaction plans and reports. As the LGMB (1997) point out ‘the revitalis-ation of town centres, supporting small shops and markets, local sourc-ing of goods, the maintenance of local facilities and the promotion oflocal distinctiveness are all manifestations of this’. It must be stressedthough that the linking of environmental, social and economic concernsis only in the early stages of even the most developed plans and in somecases it is not at all apparent. Of the documents examined only a limitednumber of authorities has actively incorporated social justice elements.Again, it was still early days and it may be that as local authoritiesbecome more experienced elements of this nature will surface in thefuture, a view that was acknowledged in Cumbria’s Local Agenda 21Strategy:

‘It is likely that this mix of environmental, social and economic issueswill change as more are built into the vision.’

What the table above is incapable of showing is the variation in presen-tation, length, depth, detail and local specificity of the audit reportswhich was even more apparent in LA21 documentation. For the reasonof space this is not something that was possible to go into in this paper.

ConclusionsThe analysis above has shown the proliferation of initiatives to ‘green’local authorities, often with audit as either an explicit or implicit mech-anism. There is clearly a national commitment to sustainable develop-ment with central government ensuring that local authorities are at theheart of any plans and their implementation. With so much pressure toimplement best value practices; to consult and communicate with localgroups in the development of LA21 strategies; to cope with the modern-isation of council management structures; and to fulfil the duty ofsocial, economic and environmental well-being, with no apparentincrease in resources, it remains to be seen whether local authoritieswill be able to deliver on sustainable development. Only time will tellif the financial resources will become available to local authorities in


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order to implement their LA21 strategies, though arguably committingmore resources is not in the spirit of sustainable development.

However, the main purpose of this paper was not to question the abilityof local authorities to be successful in making progress towards sus-tainable development. Rather the paper is an account of the role ofaudit in enabling that progress. The paper is useful in that it has triedto provide evidence of a type of non-financial audit in practice. Freedfrom the rigours and expectation of a financial audit, on the assumptionthat different types of audit may be necessary when evaluating environ-mental concerns (Gallhofer and Haslam, 1995) the paper has been ableto consider the conduct and purpose of environmental audits in thecontext of local government. Further, by investigating the potential ofenvironmental audit as an aid to making progress towards sus-tainability, the paper has also attempted to evaluate whether ‘audit’ issocially useful. In relation to this issue, whilst the longitudinal analysispermits an analysis of the changing importance of audit it also meansthat interpretation of the results is affected by the plethora of pressuresand initiatives to green local government during and even after the per-iod of study. These initiatives make it difficult to assess the influenceof environmental audits themselves on the activities of local authorities.Of those local authorities that conducted environmental audits, couldit be argued convincingly that they were used to inform EMS that weresubsequently developed or did the latter occur because of the greeningof local government initiatives on the part of the LGMB? Of course,this does not necessarily make environmental audits less useful, but itdoes mean interpreting the results with care.

As part of the consideration of the social usefulness of environmentalaudits, another problem lies in assessing whether environmental auditsenhance transparency and accountability. The conclusion here is alsounsatisfactory in that some did, some did not. Those audit reports notput into the public domain suggest a lack of transparency, and for thosethat were, it does not necessarily represent accountability if the issuesincluded are not representative of local stakeholders’ interests. In thisrespect, parallels can be drawn with the views expressed by Humphreyand Owen on the potential for establishing stakeholder capitalism inthe private sector:

However, for this to come about issues of corporate governance, ormore simply, introducing meaningful mechanisms for passing over realpower to stakeholder groups have to be centrally addressed. Withoutthis, the audit is easily made prey to organisational capture. (p. 47)

This, of course, is where LA21 comes into its own. Strategies for LA21should be a joint effort between local communities and local authorities.If, as suggested above, audit becomes a part of an evaluation when



implementing those strategies, it will have a useful role in focusing andreflecting on local community interests and would fulfil the needs fortransparency and accountability. Results of the audit could be used foramending actions to implement sustainable development, such amend-ments being derived once again through consultation with communitygroups. This would be the case providing the appropriate consultationwith a broad cross section of the ‘community’ had taken place. Unfortu-nately, this has not always occurred. Note, for example a survey of alllocal authorities in the UK which found that of those which haddeveloped their LA21 strategies, 16 percent had not involved their com-munities (Morris, 1999). Of equal concern from the survey was thatless than a quarter were encouraging the involvement of women andfewer than a seventh were specifically involving ethnic minorities. Also,and somewhat ironically, as some audit reports used in the study forthis paper referred to the social issues associated with crime, the surveyfound that only 1.7% of the representatives on community forums werefrom police and crime disorder groups. If this situation continues, anyenvironmental audit activity that results from implementation of LA21will not be fully representative of community interests and it would bedifficult to maintain that ‘accountability’ had been met. Taking a lessnegative stance, environmental audit and LA21 may still prove useful,providing there is a more concerted effort to ensure as wide a constitu-ency of groups as possible is represented in community forums. Thiswould then mean that, at least potentially, environmental audits canbe socially useful as they can facilitate and evaluate progress towardssustainable development by local authorities.

In developing sustainable development performance indicators and pro-moting LA21, the government certainly appears concerned that suchprogress should be measurable. A bigger worry is that the developmentof ‘quality of life’ performance indicators, may result in the efficiencyof the measurement system becoming the focus of ‘audit’ with the ‘out-comes’ of sustainable development being ignored (see Owen et al 1997;Bebbington and Gray, 1998; Power 1991, 1994, 1997a and 1997b).With the government’s commitment to sustainable development evidentin recent White Papers and the Local Government Bill, such concernmay be groundless. However, with the proliferation of private sectorpractices in the public sector and the so-called ‘new public manage-ment’, it is not surprising to voice the same concerns as those raisedabout the private sector; that the consequences of auditable measuresof performance, might be the managing of measurement systems (and/orstakeholder groups) rather than real progress towards sustainable devel-opment. Of equal significance in raising such concerns is the need toconsider other nations, given the global commitment to LA21 strategies,to investigate the type of initiatives for sustainable development being


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implemented at local government levels and to see if environmental aud-its are in any way implicated in such initiatives.

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Environmental audits in local government: a useful means to progress in sustainable development

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