Module 1: Environmental good

governance
The first chapter of the course describes the main ideas in
environmental good governance and the tools that governments use to
regulate the environmental behaviour of both companies and citizens.
Environmental good governance follows the principles of good
governance, but the difference is that in the case of environmental
good governance sustainability is advocated as the supreme
consideration in managing all human activities – political, social and
economic.

Before undertaking an environmental audit, auditors need to familiarise

themselves with the governance system in their country. They also
need a good understanding of general environmental principles and
tools that are accepted worldwide and to be familiar with sustainable
development.

In subsequent sections of the course the concept of sustainable

development, major environmental concepts and principles and the
most widespread environmental governance tools will be introduced.
Video 1: Introduction to environmental auditing in public sector. Environmental good
governance

https://www.youtube.com/watch?v=LN1oOQpQhQ8

1.1. Sustainable development

Environmental governance advocates sustainability as the supreme
consideration in managing all human activities – political, social and
economic. The concept of sustainability relies on sustainable
development. Sustainable development can be explained in various
ways, but the most widely recognised definition was phrased by
the Brundtland Commission in 1987:
“Sustainable development is development that meets the needs of the present without compromising the ability of
future generations to meet their own needs.”

Sustainable development is based on the three pillars of

sustainability: economic, environmental and social sustainability. It
is only achieved when there is balance or a trade-off between these
three aspects (see figure below).
Relationships in sustainable development – environmental, social and economic
concerns. 
Source: http://macaulay.cuny.edu/eportfolios/akurry/files/2011/12/SDsphere
s.jpg

Some authors have expanded this approach and added a fourth pillar
(for example cultural, political or institutional), but it is most important to
understand that sustainable development is a holistic, integrated
approach, meaning that in order to achieve sustainable development,
there needs to be a balance between different spheres of life.

At the United Nations Sustainable Development Summit in 2015, world

leaders adopted the 2030 Agenda for Sustainable Development, which
includes a set of 17 Sustainable Development Goals (SDGs) aimed at
ending poverty, fighting inequality and injustice and tackling climate
change by 2030. These 17 goals, listed below, are all accompanied by
specific targets – 169 in total.

Sustainable Development Goals

1. End poverty in all its forms everywhere

2. End hunger, achieve food security and improved nutrition and
promote sustainable agriculture
3. Ensure healthy lives and promote well-being for all at all ages
4. Ensure inclusive and equitable quality education and promote
lifelong learning opportunities for all
5. Achieve gender equality and empower all women and girls
6. Ensure availability and sustainable management of water and
sanitation for all
7. Ensure access to affordable, reliable, sustainable and modern
energy for all
 8. Promote sustained, inclusive and sustainable economic growth,
full and productive employment and decent work for all
9. Build resilient infrastructure, promote inclusive and sustainable
industrialization and foster innovation
10. Reduce inequality within and among countries
11. Make cities and human settlements inclusive, safe, resilient
and sustainable
12. Ensure sustainable consumption and production patterns
13. Take urgent action to combat climate change and its
impacts
14. Conserve and sustainably use the oceans, seas and
marine resources for sustainable development
15. Protect, restore and promote sustainable use of terrestrial
ecosystems, sustainably manage forests, combat desertification,
and halt and reverse land degradation and halt biodiversity loss
16. Promote peaceful and inclusive societies for sustainable
development, provide access to justice for all and build effective,
accountable and inclusive institutions at all levels
17. Strengthen the means of implementation and revitalize the
global partnership for sustainable development

See more at www.sustainabledevelopment.un.org 

In addition, a global indicator framework has been developed by the

Inter-Agency and Expert Group on SDG Indicators (IAEG-SDGs). The
global indicator framework was adopted by the General Assembly on 6
July 2017. The list includes 232 indicators on which general agreement
has been reached.

Read more about the indicators at the UN

webpage: https://unstats.un.org/sdgs/indicators/indicators-list/ 

The concept, goals and indicators of sustainable development can be used

for developing audit questions and audit criteria in all policy areas.

Sustainable development requires an effort from all sectors. As such,

in an ideal situation the evaluation of sustainable development
achievements would be incorporated into all audits, not just
environmental audits.
 

Below are five audit topics. Think about which SDGs would need to be
considered when conducting these audits.

Answer

1.2. Common environmental concepts

Environmental protection takes advantage of a number of principles
which are accepted worldwide and often introduced within the
framework of international agreements. These principles need to be
followed in policy design and can serve as a reference for auditors.
The major environmental concepts explained in this chapter are:

 public goods
 the prevention principle
 the precautionary principle
 the polluter-pays principle
 best available techniques/technology

Public goods

Many environmental resources – including water quality, open space,

biodiversity, and a stable climate – are characterised as public goods.

Public goods are not diminished when they are shared; they are non-
rivalrous and non-excludable. This means that the use of these goods
by one individual does not reduce their availability to others, and
individuals cannot be effectively excluded from their use.

Global public goods are necessities that must not be destroyed by any
one person or state.

Can you name any global public goods?

Answer

Examples include sunlight, air, wind and rain.

The prevention principle

Preventing environmental harm is always cheaper than covering the

cost of reclamation, and recovering previous conditions is sometimes
impossible (e.g. because of the extinction of a species). The
prevention principle states that a harmful activity should be avoided in
the case of certain unfavourable consequences. However, if the
benefits to society are higher, the principle is not applied. The
prevention principle has laid down the grounds for rules on the
transportation of hazardous wastes (e.g. the Basel Convention).

The precautionary principle

If an action or policy comes with a suspected risk of causing harm to
the public or the environment, and in the absence of scientific
consensus that the action or policy is indeed harmful, the burden of
proof that it is not harmful falls on those taking the action. Where there
are threats of serious or irreversible damage, a lack of scientific
certainty shall not be used as a reason for postponing cost-effective
measures to prevent environmental degradation.

The precautionary principle was first endorsed in 1982 when the World

Charter for Nature was adopted by the United Nations (UN) General
Assembly. The principle has thereafter been integrated into many other
legally binding international treaties, such as the Rio Declaration and
the Kyoto Protocol. Policy measures for preventing climate change and
those for regulating cultivation and the use of genetically modified
organisms (GMOs) are well-known examples of applying the
precautionary principle.
The National Audit Office of Estonia (NAOE) audited whether the goals set in the National Development Plan for Oil
Shale Use – to reduce the environmental impact of oil shale mining and processing and to increase the efficiency of
these two processes – had been achieved. In its report the NAOE stated:

“The Ministry of the Environment has not conducted the research required for the preparation of the new oil shale
development plan to help assess the impact of the mining of the annual volume of oil shale and the use of new
reserves on people, nature and the economy. The full impact of existing and closed mines and the industry must
thereby be considered. Increasing the annual mining limit and starting to use new oil shale reserves is impermissible
without complex research into this impact. The impact of mining on ground and surface water should also be more
thoroughly analysed, especially if it is known that the areas of ground and surface water whose status is bad due to oil
shale mining will keep growing in the future.”

This strong statement is based on the precautionary principle. 

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The precautionary principle is used to determine whether an action

should be taken in the face of incomplete data. It can be used when
developing audit questions:

Where environmental risk is uncertain or unknown but the consequences

of the risk materialising would be great or damage would be irreversible,
it should be assumed that the risk is significant and protection measures
should be planned accordingly.

The polluter-pays principle

According to the OECD (1972), the polluter-pays principle requires the

polluter to bear the cost of measures to reduce pollution according to
the extent of the damage done to society or the exceeding of an
acceptable level (standard) of pollution.  
This principle is important from the point of view of public finances and
is mentioned in principle 16 of the Rio Declaration on the Environment
and Development.

The polluter-pays principle leads to environmental liability, which aims

to prevent and remedy environmental damage. Environmental liability
is an obligation based on the principle that a polluting party should pay
for the damage it causes to the environment through its activities.

In some countries, environmental liability is a strict liability if the

damage can be attributed to a specific party. Strict liability means that
a person is legally responsible for the damage and loss caused by their
acts and omissions regardless of culpability (including fault in criminal
law terms).

The EU Environmental Liability Directive defines environmental

damage as damage to protected species and natural habitats, damage
to water and damage to soil. The directive can only be applied if there
is a clear causal link between the activity and the damage.

In an audit of the treatment of hazardous waste the NAOE used the

polluter-pays principle:
The NAOE audited whether the state had organised the treatment of radioactive waste according to requirements, and
thereby prevented any threat to the environment and people’s health.

Audit report: “The Environmental Board has not considered whether to require a financial guarantee for the treatment
of radioactive waste, or justified why no guarantee is required. There are currently no possibilities for the treatment of
natural radioactive waste in Estonia. 255 tons of such waste had been generated by 2013 and another 70 tons more
may be generated every year. Requiring a guarantee would give the state additional assurance that radioactive waste
would be finally treated and that it would not have to find the money for treating such waste itself if the producers of
the waste were unable to perform their obligations.”

http://www.riigikontroll.ee/tabid/206/Audit/2352/Area/15/language/en-US/Default.aspx

Environmental liability and the polluter-pays principle can be used when

developing audit questions and criteria.

 The one who is responsible for the environmental pollution

should also be responsible for covering the related costs.
 The polluter should pay for damage that it has caused to the
environment.

Best available techniques

Best available techniques or technology (BAT) requires the operator

must use the best possible economically justifiable technology to
protect the environment. BAT is not a ‘spare no expense’ approach
that always demands the use of the best technology available
regardless of the cost-benefit analysis – in practice, the cost aspect is
also taken into account.

The BAT concept was first used in the 1992 OSPAR Convention for
the Protection of the Marine Environment of the North-East Atlantic for
all types of industrial installations. BAT is mentioned in several EU
Directives and legal documents in other countries (including the United
States). It has acquired the status of customary law.
The NAOE audited whether the state, upon granting investment aid to animal holdings, had considered the importance
of BAT and the need for the integrated reduction of pollution, and guided businesses to use the best technological
solutions available.

Since the use of BAT was a prerequisite for obtaining an integrated environmental permit, it was used as a criterion in
the audit.

Rural development plans and other national strategy papers did not pay attention to improving the use of BAT, and the
need for the timely implementation of such techniques was not taken into account when planning measures for
development plans.

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BAT reference documents can be used as a source of criteria or for

developing audit recommendations:

 Environmental agencies in many countries store BAT reference

documents (BREFs), which are most easily found via an Internet
search.
 European BAT reference documents (BREFs) can be found online
at http://eippcb.jrc.ec.europa.eu/reference/.

1.3. Environmental governance tools

Governments address environmental impact with a variety of
instruments ranging from international agreements to national and
local governance acts, all of which seek to control, incentivise or
monitor environmental and sustainability impact.

Governments’ role in environmental protection is exercised mainly in

long-term planning by preparing strategies, regulating sectors by
developing legal acts, setting standards, issuing permits and licences,
and controlling compliance with regulations.

Governments have a number of mechanisms for regulating the

environmental behaviour of companies and public, such as:
  international conventions and treaties
 legislation and regulations
 policies and programmes
 permits and licensing
 monitoring and control
 Environmental Impact Assessments

Besides regulative instruments there are also:

 economic instruments (e.g. environmental charges and taxes

and emission trading schemes)

and voluntary instruments such as:

 Environmental Management Systems

When auditors study whether governments have managed to organise

the activities of companies and citizens in the best possible way, they
can focus their audit on these policy instruments and the targets set by
governments.

Focusing an audit on policy instruments you can ask for example:

 Do policy instruments support the strategic goals of the country?

 Are the policy instruments coherent and not contradicting one
another?
 Are the policies implemented?

International conventions and treaties

Governments have committed themselves to numerous international

environmental and sustainability agreements and conventions. These
bring about commitments, but often also significant financial
obligations.

Examples of international conventions relevant to environmental

auditing:

 The Ramsar Convention on the Preservation of Wetlands (1971)

 The Convention on International Trade in Endangered Species
of Wild Fauna and Flora (1973)
 The Vienna Convention and Montreal Protocol to Protect the Oz
one Layer (1985)
  The Basel Convention on the Control of Hazardous Waste and
their Transfer Across Borders (1989)
 The Convention on Biological Diversity (1992)
 The United Nations Framework Convention on Climate
Change (1992)
 The United Nations Convention to Combat Desertification (1994)
 The Rotterdam Convention on the Prior Approval of the Transfer
of Hazardous Chemicals (1998)
 The Cartagena Protocol on Biosafety (2000)
 The Stockholm Convention on Persistent Organic
Pollutants (2001)

Commitments deriving from such agreements may serve auditors as

criteria.

Read more in Auditing the Implementation of Multilateral Environmental

Agreements (MEAs): A Primer for Auditors.

Policies and programmes

Governments formulate national and sector policies, often in the form

of strategies, development plans and action plans. The policy design
cycle starts by identifying the issues that need to be addressed;
continues with policy design, implementation and enforcement; and is
completed with policy evaluation. It is good practice to involve different
stakeholders and interest groups in this process to ensure that all
important issues are considered and policies are built on
comprehensive understanding of stakeholders. Broad discussion
increases acceptance of an adopted policy and secures the best
results.
Policy design cycle (INTOSAI WGEA, 2016)

Major environmental areas usually have separate comprehensive

strategies – for example, the water strategy, tourism strategy, long-
term energy plan, forest management strategy and programme to
increase the share of renewables in the energy mix.

Strategies set long-term strategic targets for a given sector. Short-term

targets and concrete action are usually compiled in an action plan.
Strategic documents can be given different names; sometimes
strategies and action plans are combined in one document.

See also the INTOSAI WGEA paper ‘Market-based instruments for

environmental protection and management’.

Find out what the major environmental strategies and plans are in your
country. Write the titles of these documents below.

 Please write each title on a separate row.

States have joined international environmental agreements, thereby

assuming international commitments (e.g. reducing greenhouse gas
emissions). These commitments are usually transformed into national
programmes.

All policy documents, regulating the sector to be audited, need to be

examined in order to identify criteria.  

Regulatory/administrative instruments

Regulatory/administrative instruments (also called ‘command-and-

control instruments’) set clear conditions and allow little flexibility in
achieving goals. Such instruments include regulations, bans, permits
and standards.

Environmental standards are a good example of regulatory

instruments:

 air quality (e.g. PM10 in 24 hours, 150 μg/m3)

 water quality (e.g. lake pH should be between 6.5 and 7.5)
 use of a natural resource (e.g. no more than 50% of natural
forest may be damaged)

Standards may specify the desired state of the environment or set

limits on pollution/damage. See also the INTOSAI WGEA material
‘Market-based instruments for environmental protection and
management’.

Standards are usually defined in numbers and are therefore ideally suited
to measuring.

Environmental standards are good sources of audit criteria.

Permits, licences and agreements regulate the relationship between

the government and companies.

A government can set various conditions for activities that may have
an adverse effect on the environment, including:

 limits on pollution (national legislation, international treaties,

environmental standards, etc.)
 measures for the mitigation of environmental impact
 conditions for monitoring (e.g. emissions into the air)
 requirement to use the Best Available Technique for specified
activities
  requirements regarding reporting and arranging supervision so
as to determine whether permit conditions are being fulfilled

The NAOE used the data in extraction permits in its audit of mineral
resources. The activities of state authorities in organising the extraction
of mineral resources used in construction (sand, gravel, limestone and
dolomite) were audited.
Audit report: “Surveillance of mining has been insufficient. The mining reports submitted by extractors are not
checked properly, which means that the actual quarried amounts may be considerably larger than shown. Cases like
these cause damage to the environment, the state does not receive the correct fee for mining rights, the data on the
natural resources balance sheet show the remaining stock as being larger than it actually is and fair competition
between mining companies is not guaranteed.”

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An auditor can study the process of issuing permits (e.g. if the impact of
planned activities on the environment is weighed up and proper
mitigation measures are set or if monitoring and reporting conditions are
set).

Auditors can analyse whether it is checked that all companies who should
have a permit have actually obtained one.

Environmental permits may come with conditions, which are good

sources of audit criteria.

Market-based instruments

Many activities lead to environmental consequences, which are a

burden on society, as often there is a need to cover certain
expenditure. Costs which are not included in the actual price are called
‘external costs’.

Such costs include:

 the cost of disposing of a product at the end of its useful life

 the environmental degradation caused by the emissions,
pollutants and waste created during production
 the cost of health problems caused by toxic substances

Governments use market-based instruments to guide the behaviour of

companies and citizens and to address the market failure of external
costs or so-called ‘environmental externalities’. Externalities refer to
situations when the production or consumption of goods and services
imposes costs or benefits on others which are not reflected in the
prices charged for the goods and services being provided (OECD,
2016). 
Market-based instruments (MBIs) can be taxes, charges, levies,
tradable permit schemes, deposit refund systems, subsidies and more.
These instruments can be used to provide producers and consumers
with incentives to change their behaviour towards the more efficient
use of natural resources by reducing consumption and to look for more
effective ways of making environmental progress while providing them
with flexibility in how they do so.

Market-based instruments can be implemented in a systematic

manner, across an economy or region, across economic sectors or by
environmental medium (e.g. water). 

 Environmental taxes and charges

o Environmental taxes can be used, for example, to favour
recycling and discourage investment in and use of landfill
o Taxes or minimum prices can raise the cost of products to
discourage their use, for example taxes raising the price of
mined aggregates compared to the use of other products,
or minimum carbon pricing
o Tax relief can also be used to encourage infrastructure to
be built on previously used sites to support regeneration
o Deposit refund schemes – a deposit (tax) can be levied on
a product and paid back if certain behaviour is
implemented (e.g. a deposit return on beverage bottles)
 Environmental subsidies and incentives
o Subsidies (direct and indirect) and minimum price setting
for input can be used as a tool to increase the cost of more
environmentally destructive activities to encourage the use
of less damaging options
 Trading schemes (e.g. emission trading and resource
allocation)
 Liability and compensation schemes

See also the INTOSAI WGEA paper ‘Market-based instruments for

environmental protection and management’.

Market-based instruments provide solid financial data for auditing. It is

possible to study how well an instrument is implemented, how
effectively a levy is collected or how often fines are issued. 
The National Audit Office of Estonia audited the effectiveness of the collection and recovery of packaging waste. This
audit involved a study of a financial instrument: the collection of excise duty on packaging.

Audit report: “According to the NAOE, approximately one billion kroons in excise duty on packaging may not have
been recovered from packaging undertakings by the state in 2009. The NAOE based its assessment on the Ministry of
the Environment’s calculation method for the generation and recovery of packaging waste as well as on data from the
waste reporting information system, and found that most target recovery indicators for packaging waste were not met
in 2009.
Therefore, excise duty must be paid on the outstanding amount. However, the aim of the packaging waste collection
system is not to generate income for the State Treasury, but to collect as much waste as possible.” 

http://www.riigikontroll.ee/tabid/206/Audit/2164/Area/15/language/en-US/Default.aspx

Analysing the effectiveness of MBIs is more challenging: the auditor

needs to be cautious about other instruments and processes that may
have had a stronger effect on the audited area.
The National Audit Office of Estonia audited the effect of pollution charges on the reduction of environmental pollution.
The main question of the audit was whether the pollution charges had motivated enterprises to invest in
environmentally friendly technology.

Audit report: “The NAOE found as a result of the audit that pollution charges induce companies to reduce
environmental pollution if the aim of reducing the pollution is also supported by legislation and higher or increased
rates of charges; no effect was observed in other cases. The system of pollution charges would be considerably more
effective in encouraging the implementation of environmental protection measures if actual environmental damage
(external costs), incl. hazards from different pollutants, caused by production activities and opportunities to apply the
best available techniques were taken into account in establishing the rates of charges.

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An audit could be designed to measure the efficiency or/and effectiveness

of a government’s financial instruments in achieving the desired result
(e.g. reducing greenhouse gas emissions). 

Environmental Impact Assessment

Environmental Impact Assessment (EIA) is an evaluation of potential

positive or adverse impact that a proposed project may have on the
environment. The assessment takes into account the environmental,
social and economic aspects of the project.

The term EIA refers to both a decision-making process and a

document deriving from the evaluation process. However, some critics
say that an EIA is used as a decision-aiding rather than a decision-
making tool.

EIA requirements can vary from country to country. National law often
sets conditions on conducting an EIA:

 projects that need to be assessed (size of the project)

 conditions regarding how to make assessments (who makes
them and at which stage of a project)
 aspects of the environment likely to be significantly affected by
the proposed project
 significant impact arising from the project and evaluation of
alternatives
 measures for the prevention and mitigation of significant impact
 social and economic impact
Auditors obtain the relevant information by studying the EIA process
and EIA reports. The conditions set in EIA reports are often added to
the permits issued to developers.
Audit report: “Ineffectual applications and confusion in assessing environmental impact led to delays in launching
projects: the reviewing of applications by the European Commission took longer and additional terms and conditions
were established on funding decisions which the state would have to fulfil before the funds were allocated. The main
causes of the shortcomings that were identified were the demanding timeframe of the European Union's budgetary
process in launching projects and the lack of the necessary preliminary studies. It is the view of the National Audit
Office that more thorough assessment of the applications would have helped to avoid a number of these
shortcomings.”

http://www.riigikontroll.ee/tabid/206/Audit/1981/Area/15/language/en-US/Default.aspx

Strategic Environmental Assessment (SEA) is a systematic decision

support process which aims to ensure that environmental and where
possible other sustainability aspects are considered effectively in
developing policies, plans and programmes.

Both EIAs and SEAs are instruments that build on the precautionary
principle.

 An environmental auditor should be familiar with the national

requirements of EIAs and SEAs.
 EIA and SEA procedures and reports are useful sources of
information in all environmental audits, where applicable.

Environmental management systems and environmental

reporting

Besides regulatory and financial instruments, there are also voluntary

schemes for encouraging better environmental behaviour. An
Environmental Management System (EMS) is a voluntary tool with
which organisations can manage and improve their environmental
performance. An EMS helps organisations to identify environmental
impact and risks in order to incorporate them in their decision-making
process in line with financial aspects. An EMS requires an organisation
to set itself targets for continuous improvement in performance and to
monitor achievements.

The most common EMS tools are:

 ISO 14001, a standard which is recognised and used globally

 Eco-Management and Audit Scheme (EMAS), which is mostly
oriented towards Member States of the EU

However, having either of these accreditations indicates that an

organisation has set an environmental policy, identified its significant
environmental impact, set targets and an action plan to minimise the
impact and regularly reviews its environmental performance.

Companies implementing either ISO 14001 or EMAS have better data

and a better understanding of their environmental responsibilities.
Therefore, the use of voluntary environmental schemes should be
encouraged.

Reporting on organisations’ environmental performance is gaining

recognition. Besides environmental reporting, there are broader
sustainability and corporate social responsibility reports that cover
social issues. Sustainability reporting is gaining followers among
companies that want to demonstrate responsibility and present
measures they have taken in both the environmental and social
spheres. See more in ‘Sustainability Reporting: Concepts, Frameworks
and the role of Supreme Audit Institutions’ (INTOSAI WGEA, 2013).

EMS requirements can be used in a procurement process as criteria or in

evaluating the environmental aspects of a procurement.

Monitoring and control

Environmental monitoring involves the collection of data at certain

intervals and analysing the data to identify trends. Monitoring should
be taken into account by decision-makers in order to correct policy,
where necessary. It is good practice to make monitoring data available
to the general public.
Audit report: “There is no sufficient analysis as to what should be monitored, or where, or how. The fact that the
planning of environmental monitoring is not based on environmental problems also complicates the interpretation and
use of its results. State environmental monitoring is mostly planned in the light of EU and other international
commitments, while national needs are neglected. For example, the environmental impact of urban sprawl, transport
and several major industries has increased in recent years, but the need to adjust environmental monitoring
accordingly has not been analysed. At the same time, some international commitments (e.g. the monitoring of long-
range air pollution) are still not being fully met.”

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Controlling the behaviour of companies and inhabitants is necessary to

ensure compliance with regulations. This is usually done by the
environmental inspectorate. Sometimes municipalities also have a role
in controlling compliance with environmental regulations. Lack of data
on environmental conditions is often a major obstacle in audits. In
some cases it makes sense to contract experts to collect data. Some
observations not requiring specific expertise can also be made by
auditors (e.g. collecting visual evidence with a camera and GPS).
 The availability of monitoring data should be checked by auditors.
 Environmental monitoring data provides indicators of
environmental performance.